EPA Superfund
Record of Decision:
PB96-963801
EPA/ROD/R02-96/268
October 1996
Tutu Wellfield Site,
St. Thomas, U.S. Virgin Islands
8/5/1996
-------
RECORD OF DECISION
Tutu WellfieldSite
Anna's Retreat, St. Thomas, U.S. Virgin Islands
United States Environmental Protection Agency
Region II
New York, New York
July 1996
-------
DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Tutu WellfieldSite
Anna's Retreat, St. Thomas, U.S. Virgin Islands
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) documents the U.S^ Environmental Protection Agency's
(EPA's) selection of the remedial action for the Tutu WellfieldSite (Site) in accordance
with the requirements of the Comprehensive Environmental Response, Compensation
and Liability Act of 1980, as amended (CERCLA), 42 U.S.C. §9601 et seq. and to the
extent practicable the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP), 40 CFR Part 300. An administrative record for the site, established pursuant
to the NCP, 40 CFR 300.800, contains the documents that form the basis for EPA's
selection of the remedial action (see Appendix III).
The U.S. Virgin Islands Department of Planning and Natural Resources (DPNR) has been
consulted on the planned remedial action in accordance with CERCLA §121 (f), 42 U.S.C.
§9621 (f), and it concurs with the selected remedy (see Appendix IV).
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the site, if not addressed by
implementing the response action selected in this ROD, may present an imminent and
substantial endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
This operable unit is the only operable unit for the Site.
The principal threat at the site is posed by exposure to groundwater. The selected
remedy addresses both groundwater and the source materials that may be acting as a
reservoir for migration of contamination to groundwater. EPA has determined that these
source materials constitute principal threat wastes. At the Tutu WellfieldSite, the
principal threat wastes are surface and subsurface soil containing high concentrations of
mobile contaminants of concern, and non-aqueous phase liquids (free product or
NAPLs). Surface soils with non-mobile contaminants of low to moderate toxicity were
determined to represent low-level threat wastes.
-------
The major components of the selected remedy include the following:
SOIL REMEDIATION ALTERNATIVE(SRA 3/4)
• Institutional controls in the form of Governmental controls and/or proprietary
controls will be sought which place limitations on property usage (e.g., for
commercial or industrial use only);
• Institutional controls in the form of Governmental controls and/or proprietary
controls will be sought which ensure that excavation or soil disturbance at any of
the impacted areas will not occur in the future without full permit approval,
proper worker-protection precautions, and air monitoring for potential fugitive
emissions;
• Institutional controls in the form of Governmental controls and/or proprietary
controls will be sought which prohibit the excavation, transportation .and usage of
soil or rock from impacted areas without EPA and DPNR approval;
• Institutional controls in the form of Governmental controls and/or proprietary
controls will be sought which prevent permanently the removal or disturbance of
bedrock at O'Henry Dry Cleaners and the Curriculum Center where dense
nonaqueous phase liquids (DNAPLs) may be present in the subsurface.
The following remedial activities will take place at the affected properties:
Texaco Tutu Service Station:
• In-situ Soil Vapor Extraction (SVE) treatment of impacted soil;
• Catalytic oxidation for off-gas treatment.
Esso Tutu Service Station:
• In-situ SVE treatment and bioventingof impacted soil;
• Thermal oxidation for off-gas treatment.
Four Winds Plaza/Western Auto:
• Excavation and off-Site disposal of additional soils, if needed (to be deter- '
mined after confirmatory sampling during remedial design).
O'Henrv Dry Cleaners:
-------
• In-situ SVE treatment of impacted soils, or, if such in-situ SVE proves to be
ineffective, excavation and ex-situ SVE of impacted soils followed by the
redepositing of the treated soil on-Site;
• In-situ SVE treatment in the unsaturated bedrock;
• Thermal oxidation for off-gas treatment.
Curriculum Center:
• Excavation of impacted soils, followed by either off-Site disposal, or ex-situ
SVE and redepositing of the treated soil on-Site;
• In-situ SVE treatment in unsaturated bedrock areas and in soil areas not
suitable for excavation, to remediate contaminated soils and/or rocks
present in the unsaturated zone;
• Thermal oxidation for off-gas treatment.
The potential effectiveness of in-situ SVE will be determined during the pre-design
phase. Additional source delineation is required prior to installation of the in-situ SVE
treatment systems to insure the effectiveness of the remediation.
Buried 4-inch diameter PVC piping may be a potential source of contamination at the
Four Winds Plaza, near the former Western Auto underground storage tank area.
Additional investigation during the pre-design phase will be conducted to determine the
need for remedial work in the area of Four Winds Plaza. Western Auto removed their
underground storage tank and paved the area with a concrete cap in August 1994.
Confirmatory sampling of the tank grave area will be completed to confirm that no
residual contaminated soil above the cleanup levels (SSLs) has been left in-place. If
such contaminated soil is found to be present, it will be excavated and disposed of off-
Site.
CROUNDWATER REMEDIATION ALTERNATIVE(GRA 4)
• Efforts will be made to have existing domestic and commercial wells
within the confines of the groundwater plume decommissioned if these
wells are determined to interfere with the operation of the groundwater
pump and treat system that will be installed as part of this remedial
action. During the remedial design it will be determined which wells
would interfere with this remedial action and which wells would continue
to operate as they may enhance aquifer restoration, which is a goal of this
remedial action. For those wells that are decommissioned, EPA would
-------
analyze alternative sources of water for the users of those wells and
determine appropriate alternate sources of water for the affected users.
These wells could be reestablished at some point in the future, when and
if groundwater quality improves to allow extraction and use of untreated
groundwater.
Institutional controls in the form of Governmental controls and/or propri-
etary controls will be sought to prohibit unauthorized use of groundwater
or the installation of new wells. Authorization must be obtained from
DPNRand EPA before use of existing wells (i.e., wells that are not decom-
missioned) or installation of any new wells within the confines of the
plume area.
Implement Source Control Programs (consisting of installation and opera-
tion of extraction wells and air strippers) at the Texaco and Esso Service
Stations to address impacted groundwater in the immediate vicinity of
these facilities.
Install groundwater recovery wells for hydraulic control of plume migra-
tion. The proposed containment program will include the installation of
three recovery wells (RW-1, RW-2, and RW-3) strategically placed in an
effort to hydraulicallycontain plume migration. (See Figure 5)
Install two groundwater recovery wells (RW-4 and RVV-5) for hydraulic
control of chlorinated VOC contaminant sources. The source containment
will provide hydraulic barriers around source areas, allowingthe reduction
of contaminants in other parts of the aquifer and potentially reducing the
time needed to reach Maximum Contaminant Levels (MCLs). (See Figure
5)
Construct a central groundwater treatment facility with a total flow capaci-
ty of 100 gpm. Water will be treated to surface water criteria for discharge
to the storm sewer near the O'Henry Dry Cleaners facility leading to
Turpentine Run or treated to MCLs for distribution for potable purposes.
EPA, in consultation with the Virgin Islands Government, will choose one
of these two options during the remedial design phase. If a decision is
made to treat the water to surface water criteria (not to MCLs), then water
will continue to be supplied to affected residents as it is currently being
supplied (i.e., through collection of rain water to cisterns and trucking
water by tanker truck).
Conduct semi-annual groundwater sampling to monitor its quality and
contaminant migration. The monitoring program will include the sampling
approximately 15 wells at or near the plume boundary for VOCs and base
IV
-------
neutrals and acids (BNAs), and would last for the duration of the remedial
action and O&M (estimated, for costing purposes, to be approximately 30
years).
• Natural attenuation of low concentration contaminants at the plume edges
and downgradient of RW-2 and RW-3.
Various potable use options for with respect to the treated groundwater are as
follows:
connect to the existing Water and Power Authority water main;
truck the treated water to the impacted residences within the plume area;
install a water distribution system from the central treatment facilityto the
impacted residences within the plume area.
EPA, in consultation with the Virgin Islands Government, will chose one of these options
during the remedial design phase. Additional field work will be required during the pre-
design stage prior to implementation of this remedy. Groundwater extraction system
design will be based on field and aquifer testing and groundwater modelling. A
wetlands assessment may be required if the groundwater modelling shows an adverse
•effect from discharge of treated water to the wetlands.
DECLARATION OF STATUTORY DETERMINATIONS
The selected remedy meets the requirements for remedial actions set forth in CERCLA
§121, 42 U.S.C. §9621: (1) it is protective of human health and the environment; (2) it
attains a level or standard of control of the hazardous substances, pollutants and
contaminants, which at least attains the legally applicable or relevant and appropriate
requirements (ARARs) under federal and territorial laws (subject to the discussion of
DNAPLbelow); (3) it is cost-effective; (4) it utilizes permanent solutions and alternative
treatment (or resource recovery) technologies to the maximum extent practicable; and
(5) it satisfies the statutory preference for remedies that employ treatment to reduce the
toxicity, mobility, or volume of the hazardous substances, pollutants or contaminants at
a site.
EPA recognizes that the restoration of certain portions of the Tutu aquifer to MCLs may
be technically impracticable, due to the high probability that DNAPLsare present in the
unsaturated and/or saturated soils and fractured bedrock at the Curriculum Center and
O'Henry Dry Cleaners properties. If DNAPLsare present in either of these areas, there
are technical limitations, from an engineering perspective, which may make it impracti-
cable to find and remove all the DNAPLsfrom these properties. This will be especially
-------
true if DNAPLsare present in the complex fractured bedrock, either above or below the
water table. Because DNAPLcontributes to dissolved phase groundwater contamina-
tion, restoration of groundwater in the vicinity of the Curriculum Center and O'Henry
Dry Cleaners may be technically impracticable. Therefore, a waiver of MCLs ultimately
may be required for the Curriculum Center and O'Henry Dry Cleaners properties
groundwater due to the presence of DNAPLs.
A five-year review of the remedial action pursuant to CERCLA§121(c), 42 U.S.C.
§9621 (c), will be necessary, because this remedy will result in hazardous substances
remaining on-site above health-based levels.
Jeanne M.
Regional A&mini
\X
VI
-------
RECORD OF DECISION FACT SHEET
EPA REGION II
Site;
Site name: Tutu Wellfield Site
Site location: Anna's Retreat, St. Thomas, U.S. Virgin Islands
MRS score: 50.00, August 21, 1991
Listed on the NPL: September 29, 1995
Site ID #: VID982272569
Record of Decision:
Date signed: July , 1996
Selected remedy: Soil Vapor Extraction for impacted soil and plume and spurce contain-
ment/treatment for contaminated groundwater
Estimated Construction Completion: 9/99
Capital cost: Soil:$ 1.5 million; Groundwater: $ 3.2 million (in 1996 dollars)
Annual O & M cost: Soil: $ 120K; Groundwater: $ 314K
Present-worth cost: (5 % discount rate for 30 years) Soil: $ 3.6 million
Groundwater: $ 9.0 million
Lead:
PRP-Lead Site
Primary Contact: Caroline Kwan, (212) 637-4275
Secondary Contact: Melvin Hauptman, (212) 637-3952
Main PRPs: Refer to the attached PRPs list
Waste;
'Waste type: chlorinated solvents, benzene, toluene, ethylbenzene, xylene
-------
Waste origin: Underground storage tanks, dry cleaner, textile company
Estimated waste quantity: N/A
Contaminated media: Soil and groundwater
VIII
-------
Tutu Wellfield Site Potentially Responsible Parties
1. Texaco Caribbean, Inc.
2. Virgin Islands Dept. of Education
3. Four Winds Plaza Partnership
4. L'Henri, Inc.
5. Andreas Gal
6. Paul Lazare
7. Ramsay Motors, Inc.
8. Esso Standard Oil, S.A., Ltd.
9. Western Auto Supply Company
10. Francois Realty Company
IX
-------
RECORD OF DECISION
DECISION SUMMARY
Tutu Wellfield Site
Anna's Retreat, St. Thomas, U.S. Virgin Islands
United States Environmental Protection Agency
Region II
- New York, New York
July 1996
-------
TABLE OF CONTENTS
SITE NAME, LOCATIONAND DESCRIPTION 1
SITE HISTORY AND ENFORCEMENT ACTIVITIES 1
HICHLIGHTSOF COMMUNITY PARTICIPATION 3
SCOPE AND ROLE OF OPERABLE UNIT 4
SUMMARY OF SITE CHARACTERISTICS 4
SUMMARY OF SITE RISKS 10
SELECTION OF SITE CLEANUPLEVELS 17
REMEDIAL ACTION OBJECTIVES 18
DESCRIPTION OF REMEDIAL ALTERNATIVES 19
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 32
SELECTED REMEDY 38
STATUTORY DETERMINATIONS 42
DOCUMENTATION OF SIGNIFICANTCHANCES 44
ATTACHMENTS
APPENDIX!. FIGURES
APPENDIX II. TABLES
APPENDIXIII. ADMINISTRATIVERECORD INDEX
APPENDIXIV. TERRITORIALLETTEROF CONCURRENCE
APPENDIXV. RESPONSIVENESS SUMMARY
-------
SITE NAME, LOCATION AND DESCRIPTION
The Tutu WellfieldSite is located in the upper Turpentine Run basin in eastern central
St. Thomas, U.S. Virgin Islands in the Estate Anna's Retreat section of the island. A Site
Location Map is provided in Figure 1. The Site is surrounded by hills to the west, north,
and east. Various commercial establishments, including operating gas stations, car
repair shops, a shopping center, a dry cleaner, fast food restaurants, etc. are located
along the major roads in the area, within the boundaries of the Site. Private homes and
multi-family housing, such as the Virgin Islands Housing Authority (VIHA) projects,
occupy the less heavily traveled roads (see Figure 2).
The Turpentine Run Basin trends north-south and is surrounded by relatively steep
slopes. Other valleys in the area, such as the valley south of the Virgin Islands Housing
Authority (VIHA) and the Curriculum Center (along which Route 484 runs), and the
valley just west of the Benjamin Oliver School, trend northeast-southwest. Land surface
elevations along the Turpentine Run decrease from about 200 feet above mean sea level
(msl) at the northern end of the site to approximately 100 feet above msl at the
southern end of the site.
The Turpentine Run is an intermittent stream that traverses the length of the basin. In
the upper Turpentine Run Basin, the stream generally flows from north to south
following Route 38. In the lower basin, the stream turns around Mt. Zion and then
trends southeast. Surface-water runoff is collected in a storm-water catchment system.
Storm water and secondary sewage eventually discharge to the Turpentine Run. The
Turpentine Run is partially channelized and ultimately discharges into Mangrove Lagoon
and the Caribbean Sea. There is a forested wetland system located at the southeastern
portion of the Site on Highway 32.
According to the most recent census data (U.S. Census Bureau 1990), approximately
9,100 people live in the Tutu subdistrict of St. Thomas. The Tutu subdistrict, also
known as Anna's Retreat, covers 1.5 square miles (4 square kilometers) in the central-
eastern part of St. Thomas. Tutu is second to Charlotte Amalie in population density on
St. Thomas and contains approximately 20 percent of the island's population.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
In July 1987, Mr. Tillett, owner of Tillett Gardens, contacted the USVI Department of
Planning and Natural Resources (DPNR) regarding an odor emanating from his well
water. DPNR requested EPA assistance in sampling groundwater at the Tillett and other
wells located in the Turpentine Run Basin. The analytical results from the sampling
indicated that these wells contained elevated levels of chlorinated volatile organic
compounds (VOCs) and gasoline constituents. Based on groundwater sampling results,
DPNR closed 13 commercial and five private wells in the Tutu area between July and
September 1987. Many of these wells are currently in use for non-potable purposes.
After the initial sampling of six supply wells in July 1987, EPA's sampling and screening
-------
investigation was expanded to include 24 supply wells beginning in August 1987.
Analyses for benzene, toluene, perchloroethylene (PCE), trichloroethylene (TCE), and
1,2-trans dichloroethylene (DCE) were performed using a Photovac field gas chromato-
graph (GO for samples collected monthly from August through December 1987.
The October 1987 groundwater samples were also analyzed for Hazardous Substance
List (HSL) VOCs, base neutral and acid extractable compounds (BNAs), and metals by
USEPA-contracted laboratories. Fourteen of the 24 supply wells sampled during this
sampling event had elevated values of VOCs including trans-1,2-DCE, TCE, PCE, toluene,
benzene, and methyl tertiary-butyl ether (MTBE). The October 1987 sampling event
confirmed the August 1987 groundwater sampling results and also detected arsenic (15
part per billion (ppb)), selenium (915 ppb), and zinc (460 ppb) in some of the wells
sampled. The highest reported contaminant concentration during the October 1987
sampling event (excluding methylene chloride, which is a common laboratory contami-
nant) was 2,000 ppb of PCE in the Harvey Supply Well.
In January 1988, EPA initiated a limited Comprehensive Environmental Resppnse,
Compensation, and Liability Act (CERCLA) removal action that included the decontamina-
tion and cleaning of five residential cisterns contaminated by hazardous substances,
modification of plumbing, delivery of water by tank trucks as a temporary alternative
water supply, and implementation of a well-water monitoring program.
Laboratory analysis for HSL VOCs, BNAs, metals, and cyanide was performed on 18
supply well samples collected in November 1988. EPA also sampled and analyzed 123
cisterns that were filled with groundwater pumped from supply wells located in this
area. Three of the cisterns contained total VOCs in excess of 1,000 ppb.
From 1988 to 1990, EPA sent Information Request letters under Section 104 of CERCLA
and 3007 of the Resource, Conservation and Recovery Act (RCRA) to a number of
businesses regarding operations and waste disposal at these businesses. Based on the
findings of these requests, EPA issued a Unilateral Administrative Order (AO) under
CERCLA and RCRA on March 22, 1990 to Texaco, Esso, and O'Henry Dry Cleaners. This
AO required these parties to implement EPA's well-water monitoring program, to
provide potable water to residents with contaminated well water, and to coordinate and
design plans to connect those residents to the local public water supply. After re-
evaluation of the impracticability of connecting these residents to the public water line
by the PRPs due to the intermittent shut-off of the public water supply by the Water
and Power Authority during drought seasons, an escrow account was set up with the
PRPs in February 1994 to provide trucked water to impacted residents in the Tutu
WellfieldSite until their wells are returned to potable use. These parties have been fully
complying with this AO since its issuance.
In June 1989, EPA sent Texaco and Esso a draft Administrative Order on Consent (AOC)
pursuant to the authority of CERCLA and RCRA requiring the implementation of a
-------
Remedial Investigation (Rl) and Feasibility Study (FS) in the Tutu area. Texaco and Esso
formed the Tutu Environmental Investigation Committee (TEIC) in March 1990 and
retained Ceraghty & Miller to prepare a work plan for, and to implement, the Rl and FS.
A final AOC was entered into by EPA, Texaco, and Esso on February 19, 1992.
EPA proposed the Tutu Wei Ifield Site for inclusion on the National Priorities List (NPL) on
February 1, 1992. The Site became finalizedon the NPL on September 29, 1995.
In March 1995, EPA issued a Consent Order to L'Henri, Inc. (O' Henry Dry Cleaners) for
soil cleanup. Pursuant to that Order, approximately 700 cubic feet of PCE contaminated
soil was removed at the O'Henry Dry Cleaners property and treated on site by soil
venting.
Since 1993, EPA has identified a number of additional potentially responsible parties
(PRPs) with respect to the Site including, but not unlimited to, Francis Realty Company,
the Virgin Islands Dept. of Education, Four Winds Plaza Partnership, Andreas Gal and
Paul Lazare, Ramsay Motors, Inc., and Western Auto Supply Company.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Rl report, FS report, and the Proposed Plan for the Site were originallyreleased to
the public for..comment on August 23, 1995. However, due to the arrival of Hurricane
Marilyn in September 1995, and the resulting devastation in St. Thomas, the public
meeting was postponed for six months. The Proposed Plan was re-released to the
public for comment on February 12, 1996. The Rl report, FS report and the Proposed
Plan were made available to the public in the administrative record file at the EPA
Docket Room in Region II, New York and the EPA Caribbean Field Office (CFO) in San
Juan, Puerto Rico. Information repositories are also located at the Department of
Education Curriculum Center, Anna's Retreat, St. Thomas, U.S.V.I.and the Department
of Planning and Natural Resources Environmental Protection Division, Wheatley Shop-
ping Center II, St. Thomas, U.S.V.I. The notice of availability for the above-referenced
documents was published in the Virgin Islands Daily News on February 10 and 11,
1996, and the Virgin Islands Weekly lournal on February 16, 1996. The public comment
period on these documents was held from February 12, 1996 to March 13, 1996.
On March 5, 1996, EPA conducted a public meeting at the Department of Education
Curriculum Center in Anna's Retreat to inform local officials and interested citizens
about the Superfund process, to review current and planned remedial activities at the
Site, and to respond to any questions from area residents and other attendees.
Responses to the comments received at the public meeting and in writing during the
public comment period are included in the Responsiveness Summary (see Appendix V).
-------
SCOPE AND ROLE OF OPERABLE UNIT
This is the first and only operable unit at the Site.
The objectives of the remedial investigation and response actions at the Tutu Wellfield
Site are: 1) to protect the public from health risks associated with the use of contami-
nated groundwater; 2) to contain the spread of contamination in the aquifer, and, if
possible, restore the aquifer to drinking water quality; and 3) to address contaminated
soils, which represent a source of the groundwater contamination.
Early response actions taken by EPA and DPNR to mitigate risks to human health from
Site related contaminants included the closing of contaminated residential and commer-
cial supply wells in 1987 and the cleaning of residential cisterns in 1988. In addition,
leaking underground storage tanks were removed at the two gas stations in 1988 and
1989 to prevent the further release of petroleum compounds to groundwater from the
source area.
SUMMARY OF SITE CHARACTERISTICS
Remedial investigation/feasibility study (RI/FS) activities were conducted at the Tutu
Wellfield Site, with EPA oversight, from 1992 to 1994. The overall objectives of the Rl
were: 1) to identify and characterize the potential sources of groundwater contamina-
tion, 2) to determine the horizontal and vertical extent of contamination, 3) to determine
the rate and direction of contaminant transport, and 4) to determine the potential
migration pathways for petroleum hydrocarbons and chlorinated VOCs in soil and
groundwater at the Site.
The Rl was conducted in two phases. Phase I focused on determining the extent of
groundwater contamination and on identifying existing sources of the groundwater
contamination. Based on the Phase I findings, the groundwater investigation was
expanded to the south in Phase II. In addition, during Phase II Rl, available soil data
from various PRP investigations was compiled for each property that had been identified
as a potential source area during Phase I. The following properties were investigated
and/or inspected during the Phase II soil investigation:
* VI HA
* Curriculum Center
* Ramsay Motors
* Antilles Auto Parts
* Texaco Tutu Services Station
* Tillett Gardens
* Four Winds Plaza
* Former Western Auto
* Esso Tutu Service Station
-------
* O'Henry Dry Cleaner
* Fire Station
* Vitelco
* Cod of Holiness Church
* Lutheran Church
* Assembly of Cod Church
Concurrent with the Rl activities, commercial and residential supply wells in the Tutu
valley were sampled on a quarterly basis.
HYDROGEOLOGY
The Tutu WellfieldSite is underlain by bedrock consisting mainly of andesitic, volcanocl-
astic tuffs, breccias, and conglomerates of the Water Island and Louisenhoj Formations.
The overburden consists of a thin soil layer and alluvial deposits which range in
thickness from less than 2 feet on the valley slopes to approximately 30 feet in the axis
of the valley.
The primary aquifer beneath the study area is the fractured volcanic bedrock. Ground-
water is stored and transmitted through fracture sets along major lineaments (faults,
joints, and bedding planes). Groundwater flow is to the south and southeast from the
highland areas (recharge zones) towards the lower Turpentine Run basin (discharge
zone). The surficialalluvial deposits, where saturated, form a-secondary aquifer of lesser
significance due to their limited thickness and lateral extent. The alluvial aquifer is in
direct hydraulic communication with the bedrock aquifer, although local perched water
conditions may exist at the top of bedrock.
The terms "shallow" (also referred to as overburden) and "deep" bedrock zones have
been used in the remedial investigation of the Tutu WellfieldSite. The terminology
refers to the screened depths of monitoring and supply wells which have been installed
throughout the Tutu Valley. The "shallow" bedrock zone is defined by wells screened
across the water table. The "deep" bedrock zone is defined by deeper monitoring wells
(generally screened 30 to 50 feet below the water table) and by existing supply wells
(deep, open boreholes drilled to depths of 200 to 300 feet below ground surface).
SOIL INVESTIGATIONS AND RESULTS
During the Phase I and II Rl, surface and subsurface soil samples were collected from
borings and monitoring well boreholes. Soil quality data was collected from 15 proper-
ties in the project study area to identify impacted soils.
Soil samples collected during the Rl were analyzed for target compound list (TCL) VOCs
and base neutral acids (BNAs), target analyte list (TAL) metals, cyanide, and petroleum
hydrocarbons. Site-specific, vadose zone modeling-derived soil screening levels (SSLs)
-------
were used as guidance values to identify soil areas that might require remediation based
on the potential for leaching of contaminants into groundwater. Further explanation on
how the SSLs were derived can be found in the section of the Selection of Site Cleanup
Levels. The properties identified with soil concentrations above the SSLs were placed
into two categories: 1) properties with soil impacted by chlorinated VOCs, and 2)
properties with soil impacted by petroleum-related compounds including benzene,
toluene, ethylbenzene, and xylene (BTEX).
Based on the exceedance of SSLs for chlorinated constituents, three properties were
identified as having chlorinated VOCs in soil at high enough concentrations to potentially
impact groundwater. The principal chlorinated VOCs detected include PCE, TCE, 1,2-
DCE, 1,1,1-trichloroethane (1,1,1-TCA), and 1,1-dichloroethane (1,1-DCA). In addition,
five properties were identified as having BTEX compounds in soil.
Chlorinated VOCs in Soil
Three properties were identified as having significant chlorinated VOC impact to soil,
based on exceedance of EPA's site-specific SSLs: 1) the Curriculum Center, 2) Esso Tutu
Service Station, and 3) O'Henry Dry Cleaners, (see Table 1)
At the Curriculum Center, approximately 3 to 1800 micrograms per kilogram (ug/kg) of
PCE was detected in eight samples at the north-central side of the main building in the
vicinity of the former discharge pipe and presumed former waste pit. TCE was detected
in four samples at concentrations from 1 to 130 ug/kg. One chlorinated VOC, 1,1,1-
TCA, was detected above the EPA's SSLs. It is suspected that higher concentrations of
chlorinated VOCs may be present in the soil beneath the building or in the unsaturated
bedrock. The elevated concentrations of chlorinated VOCs in groundwater adjacent to
and immediately downgradient of the Curriculum Center indicate a high probability that
pure product is present in the unsaturated zone as dense non-aqueous phase liquid
(DNAPL)at the Curriculum Center.
At the Esso Tutu Service Station, PCE, TCE, 1,1,1-TCA, 1,2-DCE, and 1,1-DCA were
detected above EPA's SSLs in four samples at concentrations ranging from 44 to 3,200
ug/kg. These chlorinated VOCs were detected at the western portion of the property,
near the, north oil/water separator.
PCE was found in the vicinity of the O'Henry Dry Cleaners above EPA's SSLs in the
southwestern portion of the property. The range of PCE concentration was 200 to
440,000 ug/kg. In addition, there is a potential for DNAPLto be present in the subsur-
face soils near the O'Henry Dry Cleaners since historical concentrations (up to 1,500
part per billion (ppb)) of PCE in groundwater in adjacent wells have exceeded 1 percent
of the solubility of PCE.
-------
BTEX in Soil
The site-specific SSLs for BTEX compounds were exceeded at five properties: 1) the
Curriculum Center (formerly the Laga Building), 2) Ramsay Motors, 3) Texaco Tutu
Service Station, 4) Western Auto, and 5) Esso Tutu Service Station, (see Table 1)
At the northeast corner of the Curriculum Center, in an area where a sink from the
paint shop drain discharged to the ground, BTEX compounds exceeded EPA's SSLs in
two surface soil samples. The individual BTEX compounds ranged from benzene at
2,700 ug/kg to toluene at 500,000 ug/kg.
Benzene and ethylbenzene were detected in the vicinity of the underground storage
tank (UST) at the Ramsay Motors property at levels above their respective EPA SSLs;
benzene at 17 ug/kg and ethylbenzene at 190 ug/kg and 290 ug/kg.
At the Texaco Tutu Service Station, BTEX compounds were found in the vicinityof the
former USTs and at the oil/water separator at concentrations exceeding EPA's SSLs.
Results ranged from 69 ug/kg for benzene to 630 ug/kg for ethylbenzene.
At the Western Auto facility, BTEX constituents were detected in 21 soil samples at
concentrations above EPA's SSLs. All individual BTEX constituents exceeded EPA's SSLs.
These results ranged from toluene and ethylbenzene at 16 ug/kg and xylene at 34,000
ug/kg. A shallow gravel layer underlying the pavement in this area also contained
visible stained oil. The impacted soil was located adjacent to an underground storage
tank, which was removed in August 1994.
At the Esso Tutu Service Station, BTEX compounds exceeded EPA's SSLs in 16 samples
near the gasoline pump island, the north oil/water separator, and the former UST
excavation. Individual BTEX concentrations above EPA's SSLs ranged from 26 ug/kg of
ethylbenzene to 540,000 ug/kg of xylenes.
PCBs in Soil
At the Tillett Gardens property, no chlorinated VOCs or BTEX constituents were
detected above screening levels in the Site soil. However, elevated concentrations
(120,000 ug/kg) of the PCB Aroclor 1242 were detected in one surface sample in 1988.
Because this sample concentration resulted in unacceptable risks to human health from
direct exposure, EPA collected confirmatory samples from the affected area in August
1995 to delineate the extent of impacted soils. PCBs were not detected in any of the
confirmatory samples, indicating that PCBs are no longer a concern at this property.
-------
CROUNDWATER INVESTIGATIONS AND RESULTS
During the Phase I Rl, groundwater samples were collected from 19 monitoring wells in
the Tutu area. During the Phase II Rl, the study was expanded to the south and a
comprehensive round of groundwater samples was collected from 51 monitoring wells
and 15 supply wells in'the Tutu Valley, (see Figure 3) Theses samples were analyzed
for VOCs, BNAs, metals, and various inorganic water quality parameters. In addition,
eight rounds of groundwater supply well samples were collected and analyzed during
the Rl. The groundwater sampling result indicate the presence of four main plumes of
contamination at the Tutu Wellfield Site: two chlorinated VOC plumes and two BTEX
plumes.
Chlorinated VOC Plumes
The two chlorinated VOC plumes are referred to as the northern and southern VOC
plumes because of their locations (See Figure 4). In general, the concentrations within
these plumes, in both the shallow and deep zones, appear to be decreasing since 1992,
with the exception of the northern chlorinated plume in the immediate vicinity of the
Curriculum Center. Concentrations of VOCs in the northern part of the north plume
have not decreased with time, nor have the shape or general extent of VOC contamina-
tion changed in this area, indicating that the northern chlorinated VOC plume is
relatively stable. This stability suggests that there may be a continuing source of VOCs
to groundwater in the vicinityof the Curriculum Center.
The shallow northern chlorinated VOC plume, which originates near the Curriculum
Center, extends approximately 1,600 feet south, in the direction of the groundwater
flow, to a point just, southeast of Four Winds Plaza and is approximately 500 feet wide.
The highest concentrations of total chlorinated VOCs occur in shallow zone monitoring
wells, where chlorinated VOC concentrations greater than 1,000 parts per billion (ppb)
were detected.
The principal chlorinated VOCs detected in the northern plume are 1,2-DCE, PCE and
TCE. Vinyl chloride was also detected in wells near the Curriculum Center. The
maximum concentrations of these hazardous substances detected in groundwater
during the Rl were 1,2-DCE at 2,100 ppb, vinyl chloride at 1,300 ppb, PCE at 360 ppb
and TCE at 78 ppb. All these hazardous substances exceed the Safe Drinking Water Act
Maximum Contaminants Levels (MCLs) for drinking water. The MCLs for 1,2-DCE, PCE,
TCE and vinyl chloride are 70, 5, 5 and 2 ppb, respectively. Historically, the concen-
tration of PCE in the Tillett supply well, located downgradient of the Curriculum Center,
has been reported up to 2,040 ppb, which exceeds 1 percent of the solubility of PCE.
Dense non-aqueous phase liquids (DNAPLs) are therefore suspected to be present in
this vicinity. The maximum concentrations of 1,1-DCE and vinyl chloride also strongly
suggest the presence of chlorinated DNAPLinthe vicinityof the Curriculum Center, (see
Table 2)
8
-------
In the southern part of the northern chlorinated VOC plume, south of Tillett Gardens,
VOC concentrations increase with depth. Concentrations in this part of the plume,
however, are generally lower than they are near the Curriculum Center. The highest
concentrations of chlorinated VOCs in this part of the plume were PCE at 140 ppb, 1,2-
DCE at 100 ppb and TCE at 33 ppb.
The southern VOC plume originates near the O'Henry Dry Cleaners and extends
southeast approximately 4,000 feet and it is approximately 800 feet wide. In the
shallow zone, the highest total concentration of VOCs detected in 1994 was 181 ppb in
a monitoring well just downgradient of O'Henry Dry Cleaners. In the deep zone, total
chlorinated VOCs were detected above 100 ppb in several private supply wells. The
chlorinated VOCs detected in the southern plume consist primarily of PCE, TCE, and
1,2-DCE above MCLs, with PCE contributing about 75 percent of the total chlorinated
VOCs detected in wells near the O'Henry Dry Cleaners. The historical presence of PCE
at concentrations in excess of 1,500 ppb in wells adjacent to the O'Henry facility
suggests the possible presence of DNAPLsin the saturated zone.
BTEX plumes
The shallow BTEX plume located near the Texaco Tutu Service Station is approximately
400 feet long from north to south and approximately 200 feet wide from east to west. In
the deep zone, it is approximately 300 feet by 130 feet in areal extent. The plume is
elongated in the direction .of shallow groundwater flow and appears to have migrated
past the Tillett Supply Well since 1982. The maximum concentration of benzene is
21,000 ppb, ethylbenzene is 3,700 ppb and xylenes is 18,000 ppb. The MCLs for
benzene is 5 ppb, ethylbenzene is 700 ppb and total xylenes is 10,000 ppb. These
concentrations exceed the MCLs. (see Figure 4)
The shallow BTEX plume located near the Esso Tutu Service Station, as identified by
existing monitoring wells, measures approximately 250 feet by 175 feet. The maximum
concentration of benzene detected at this location is 10,000 ppb, ethylbenzene is 4,100
ppb and xylenes is 22,000 ppb. The concentrations exceed the MCLs.
Direct observations of floating product and sheens in some monitoring wells at the Esso
Tutu and Texaco Tutu Service Stations confirmed the presence of light non-aqueous
phase liquids (LNAPL).
CONTAMINANTMICRATION PATHWAYS
Contaminants may migrate through environmental media at the Tutu WellfieldSite via
several mechanisms. First, the constituent-containing soils can act as a source of
constituents to other environmental media. Second, migration into air may occur via
volatilizationor fugitive dust emissions. Third, migration into groundwater may occur
by direct vertical migration of contaminants or by percolation of infiltrating rain water
-------
that dissolves the contaminants of concern. Fourth, transport into surface water
(Turpentine Run) may occur via groundwater discharge.
Several factors influence the significance of each of these migration or transport path-
ways. These factors include the properties of the environmental media, the constituent
concentration, and the physical and chemical properties of the constituent itself.
SUMMARY OF SITE RISKS
Based upon the results of the Rl, a baseline risk assessment was conducted to estimate
the risks associated with current and future Site conditions. The baseline risk assess-
ment estimates the human health and ecological risks which could result from exposure
to chemical contamination at the Tutu WellfieldSite if no remedial action were taken.
Risk to human health is defined as the likelihood that people living, working, or playing
on or near the Site may experience health problems as a result of their exposure to
contaminants from the Site. The ecological risk evaluation appraises actual or potential
effects of contaminants on plants and animals.
HUMAN HEALTH RISK ASSESSMENT
A four-step process is used for assessing Site-related human health risks for a reasonable
maximum exposure scenario:
• Hazard Identifications - identifies the chemical contaminants of concern at the
Site based on several factors such as toxicity, frequency of occurrence, and
concentration.
• Exposure Assessment - estimates the magnitude of actual and/or potential
human exposures, the frequency and duration of these exposures, and the
pathways (e.g., ingesting contaminated well-water) by which humans are poten-
tially exposed.
• Toxicity Assessment - determines the type of adverse health effects associated
with chemical exposures, and the relationship between magnitude of exposure
(dose) and severity of adverse effects (response).
• Risk Characterization - summarizes and combines outputs of the exposure and
toxicity assessments to provide a quantitative assessment of Site-related risks.
Hazard Identifications- The baseline risk assessment began with selecting chemical
contaminants of concern which would be representative of Site risks. These contami-
10
-------
nants included VOCs, semivolatiie organic compounds (SVOCs), and inorganics.
Several of these contaminants, such as benzene, tetrachloroethane, and vinyl chloride,
which are VOCs; benzo(a)pyrene and benzo(b)fluoranthene, which are SVOCs; and
arsenic and chromium VI, which are inorganics, are either known human carcinogens or
are known to cause cancer in laboratory animals and are probable human carcinogens.
The summary of the contaminants of concern in sampled matrices is listed in Tables 3
and 4 for human health and the environmental receptors, respectively.
Exposure Assessment- The baseline risk assessment evaluated the health effects which
could result from exposure to chemical contamination as a result of ingestion, dermal
contact, inhalation of particulates, and inhalation of VOCs. Exposure scenarios involving
surface soil, subsurface soil, and groundwater were quantitatively addressed for three
receptor groups: 1) current and potential future residents in the Tillett Gardens and Art
Center area; 2) current and potential future Site workers (employees) at the Fire
Department, Texaco gas station, Antilles Auto Parts and Ramsay Motor Co., Curriculum
Center Building, and O'Henry Dry Cleaners and Liquor Barn; and 3) potential future
construction workers. Only the Tillett Gardens and Art Center area was selected for
quantitative evaluation for the construction worker scenario based on the chemical
concentrations detected, toxicityand the calculated residential risks.
A total of seven exposure pathways were evaluated under possible on-site current and
future land-use conditions. Potential exposure pathways are listed in Table 5. The
reasonable maximum exposure was evaluated.
Toxlcity. Assessment
Undercurrent EPA guidelines, the likelihood of carcinogenic (cancer-causing) and
noncarcinogeniceffects due to exposure to Site chemicals are considered separately. It
was assumed that the toxic effects of the site-related chemicals would be additive.
Thus, carcinogenic and noncarcinogenic risks associated with exposures to individual
compounds of concern were summed to indicate the potential risks associated with
mixtures of potential carcinogens and noncarcinogens, respectively.
Noncarcinogenic risks were assessed using a hazard index (HI) approach, based on a
comparison of expected contaminant intakes and safe levels of intake (Reference Doses).
Reference doses (RfDs) have been developed by EPA for indicating the potential for
adverse health effects. RfDs, which are expressed in units of milligrams/kilogram-day
(mg/kg-day), are estimates of daily exposure levels for humans which are thought to be
safe over a lifetime. Estimated intakes of chemicals from environmental media (e.g., the
amount of a chemical ingested from contaminated drinking water) are compared to the
RfD to derive the hazard quotient for the contaminant in the particular medium. The HI
is obtained by adding the hazard quotients for all compounds across all media that
11
-------
impact a particular receptor population. The RfDs for the compounds of concern at
the Site are presented in Table 6.
Potential carcinogenic risks were evaluated using the cancer slope factors developed by
EPA for the contaminants of concern. Cancer slope factors (SFs) have been developed
by EPA's Carcinogenic Risk Assessment Verification Endeavor for estimating excess
lifetime cancer risks associated with exposure to potentially carcinogenic chemicals.
SFs, which are expressed in units of (mg/kg-day)"', are multiplied by the estimated
intake of a potential carcinogen, in mg/kg-day, to generate an upper-bound estimate of
the excess lifetime cancer risk associated with exposure to the compound at that intake
level. The term "upper bound" reflects the conservative estimate of the risks calculated
from the SF. Use of this approach makes the underestimation of the risk highly unlikely.
The SF for the compounds of concern are presented in Table 7.
For known or suspected carcinogens, EPA considers excess upper-bound individual
lifetime cancer risks of between 10" to 10"6 to be acceptable. This level indicates that
an individual has not greater than a one in ten thousand to one in a million chance of
developing cancer as a result of site-related exposure to a carcinogen over a 70-year
period under specific exposure conditions at the site. For non-carcinogenic health
effects, EPA considers that a hazard index greater than 1.0 indicates a potential for non-
carcinogenic health effects to occur as a result of Site-related exposures.
The calculated carcinogenic risks and non-carcinogenic hazards for the exposure
pathways and receptor groups evaluated in the Risk Assessment are summarized below.
Table 8 shows carcinogenic risks, combined across all pathways for each receptor
group. No surface or subsurface soil pathways exceeded the target carcinogenic risk
range for any current or future receptor group. However, hypothetical future exposure
to Site contaminants in the groundwater by area residents (adults and children) and Site
workers results in carcinogenic risks exceeding EPA's target risk range. The risks were
primarily attributed to PCE and vinyl chloride. Table 9 shows the calculated non-
carcinogenic hazard index values, combined across pathways, for each receptor group.
For soils, the only exposure that exceeded the hazard index of 1.0 was for ingestion or
inhalation of surface soils by children residents in the Tillett Gardens area. The hazard
was primarily due to manganese concentrations, which were within the range of Site
background manganese values. The HI for ingestion of Site groundwater was exceeded
for all receptor groups. The hazards were attributed to 1,2-DCE, PCE, antimony,
manganese and vanadium.
Current and Potential Future Residents (Tillett Gardens and Art Center area):
The baseline human health risk assessment for the Tutu WellfieldSite was completed in
1994. The conclusion of the assessment indicated that residential exposure to surface
soils in the Tillett Gardens and Art Center area showed carcinogenic risks in exceedance
12
-------
of the upper-bound of the target range. These risks were due largely to PCB Aroclor
1242 which had been reported on surface soil samples collected in 1988 by EPA's
contractor. In August 1995, EPA conducted a confirmatory soil sampling at the Tillett
Gardens and Art Center. These soil samples were analyzed for VOCs and PCBs. No
PCBs were detected in any of the samples. Therefore, EPA recalculated the surface soil
risk for carcinogenic risks to the current and future residents at the Tillett Gardens and
Art Center area using the new data. The revised risk calculation is reflected below:
Surface soil risk calculations show that carcinogenic risks to current or future residents
at the Tillett Gardens and Art Center area are within the EPA target risk range of 10^ to
10"6. The individual pathway and receptor risks are 8.2E-06 (adult ingestion), 5.5E-07
(adult inhalation), 1.9E-5 (child ingestion), and 6.4E-07 (child inhalation) (Table 8). The
30-year combined risk for adult + child is 2.9E-05. These risks were solely attributed to
arsenic. Dermal contact risks were evaluated qualitatively because dermal absorption
factors were not available for Contaminants of Concern (COCs). For non-carcinogenic
effect, the total hazard index for the child ingestion and inhalation of surface soil routes
of exposure was 6.1, which is above the hazard index of 1.0 (Table 9). This risk was
attributable to manganese. No adult hazard index values exceeded 1.0.
Subsurface soil was found to pose an acceptable risk to current or future residents;
neither the dermal contact route nor the inhalation of particulates route resulted in
carcinogenic risks of hazard index values above current federal guidelines.
Groundwater was found to pose an unacceptable risk to future residents for the
ingestion route of exposure. The ingestion route showed a carcinogenic risk for adults of
6 X 10"4, which is greater than the upper-bound of the acceptable risk range. The adult
hazard index was 29 and the child hazard index was 67.
Current and Potential Future Site Workers (Employees) in Target Business
Surface soil and subsurface soil were found to pose an acceptable risk to current and
future site workers for the ingestion, dermal contact, inhalation of particulates, and
inhalation of VOCs routes. None of these routes resulted in carcinogenic risks or hazard
index values above current federal guidelines.
Groundwater was found to pose an unacceptable risk to future site workers via the
ingestion route. The carcinogenic risk of about 2X10"" exceeds the upper-bound of the
target risk range, and the hazard index of 10 exceeds the acceptable level of 1.0. The
estimated risks are primarily due to the cumulative effects of tetrachloroethene and vinyl
chloride which, when combined, contributed 83 percent to total carcinogenic risk
calculations.
13
-------
Potential Future Construction Workers:
Surface soil and subsurface soil were found to pose an acceptable risk to human health
for the ingestion, dermal contact, and inhalation of particulates routes of exposure
evaluated. None of these routes resulted in carcinogenic risks or hazard index values
above EPA guidelines.
Ground water was found to pose an unacceptable hazard to future construction workers
for noncarcinogens for the ingestion route. Although the carcinogenic risk did not
exceed the current federal guidelines, the hazard index of 9 exceeds the target level of
1.0.
Conclusions
The baseline risk assessment indicated that groundwater poses unacceptable risks of
exposure to carcinogens and/or noncarcinogens for all three receptor groups. The only
unacceptable risk from exposure to site soils was limited to one property (Tillett
Gardens) where the noncarcinogenic hazard index for surface soils was exceeded for the
residential scenario.
Actual or threatened releases of hazardous substances from this Site, if not addressed
by the preferred alternative or one of the other active measures considered, may
represent a current or potential threat.to public health, welfare or the environment.
ECOLOGICAL RISK ASSESSMENT
A four-step process is used for assessing Site-related ecological risks for a reasonable
maximum exposure scenario:
• Problem Formulation - a qualitative evaluation of contaminant release, migration,
and fate; identification of contaminants of concern, receptors, exposure pathways,
and known ecological effects of the contaminants; and selection of endpoints for
further study
• Exposure Assessment - a quantitative evaluation of contaminant release, migration,
and fate; characterization of exposure pathways and receptors; and measurement
or estimation of exposure point concentrations
• Ecological Effects Assessment - literature reviews, field studies, and/or toxicity
tests, linkingcontaminant concentrations to effects on ecological receptors
• Risk Characterization- measurement or estimation of both current and future
adverse effects.
14
-------
The ecological risk assessment began with evaluating the contaminants associated with
the Site in conjunction with the Site-specific biological species/habitat information. The
chemicals of potential concern include 9 volatile organic compounds, 16 semivolatile
organic compounds, 1 pesticide, 15 inorganic analytes, and cyanide. Two potential
ecological receptor species were chosen as indicator species for the Site: the red-tailed
hawk (Buteo /ama/cens/s), representing a high order food web consumer, and the anole
(Anolissp.), a lizard representing a consumer closer to the base of the food web.
Exposure to Site surface soil was the only medium considered within the ecological risk
assessment; exposure of ecological receptors to Site contamination was not considered
likely to occur via groundwater, surface water, or subsurface soil. Potential risks to
.ecological receptors were assessed by comparing estimated exposure levels (total body
doses or TBDs) with toxicologicalbenchmark values (reference toxicity values or RTVs).
Exposure levels were estimated using the worst-case scenario, assuming ecological
receptor exposure to maximum concentrations of Site-related surface soil chemical
concentrations.
Risks to each of the selected receptors were evaluated using hazard indices which were
determined for each surface soil contaminant of concern, where appropriate toxicity
values were available, by dividingthe estimated TBDs by the RTVs. Cumulative hazard
indices were determined by summing all of the hazard indices for each target ecological
receptor. Cumulative hazard indices were compared to an effects threshold of One (1)
per EPA' s Framework for Ecological Risk Assessment (EPA/630/R-92/001) to evaluate
potential ecological risks to individual organisms, as follows:
• hazard index less than 1.0 <= low probability of adverse effects
• hazard index greater than or equal to 1.0 = adverse effects likely to occur.
Conclusions
Anole. The potential risk from Site surface soil chemicals was assumed to arise from
exposure via ingestion of soil and invertebrates. The estimated cumulative hazard index
is 138, indicating the potential for adverse health risks to individual anoles as a result of
exposure to Site-related chemicals in soil (primarily arsenic) if the receptor and its food
sources are consistently exposed to maximum surface soil concentration. Considering
the limited home range expected for the anole (less than 1 percent of the Site area),
some anoles may be exposed to maximum surface soil concentrations. Examples of
these areas include the O'Henry Dry Cleaners property, where the maximum concen-
tration for arsenic and tetrachloroethylene were found, and the Curriculum Center
property, where the maximum concentration for phenol was found, (see Table 10)
However, most of the anoles on and adjacent to the Site would contact much lower
levels of Site-related chemicals, because the majority of Site-related chemicals have low
detection frequencies and thus have not been found uniformly throughout the Site.
15
-------
Since the Risk Assessment was performed, soils with the highest concentrations of PCE
have been excavated from the O'Henry property in 1995. Consequently, the current
potential risks to the Anolewillbe significantly lower than the potential risk calculated in
the Ecological Risk Assessment.
Red-Tailed Hawk. The potential risk from Site surface soil chemicals was assumed to
arise from exposure via ingestion of small mammals, reptiles/amphibians, invertebrates,
and soil. The estimated cumulative hazard index is 4, indicating a potential for adverse
health effects to the red-tailed hawk as a result of exposure to Site-related chemicals in
soil if the receptor and its food sources are consistently exposed to maximum surface
soil concentrations. Furthermore, the hawk appears to have a markedly reduced risk
potential compared to that of the lizard. This difference is primarily attributed to the
large range of the bird as compared to the area of the Site-related chemicals in surface
soil, (see Table 10)
This evaluation has considered the worst-case scenario, that the receptor will be
consistently using foodstuffs from the portion of the Site where maximum surface soil
chemical concentrations are available. Due to the limited distribution of the majority of
surface soil contaminants of concerns, the actual adverse risk to the red-tailed hawk is
expected to be less than as projected by the current cumulative hazard index.
Uncertainties in the Human Health and Ecological Risk Assessments
The procedures and inputs used to assess risks in this evaluation, as in all such
assessments, are subject to a wide variety of uncertainties. In general, the main sources
of uncertainty include:
environmental chemistry sampling and analysis
environmental parameter measurement
. fate and transport modeling
exposure parameter estimation
toxicologicaldata
Uncertainty in environmental sampling arises in part from the potentially uneven
distribution of chemicals in the sampled media. Consequently, there is significant
uncertainty as to the actual levels present. Environmental chemistry-analysis error can
stem from several sources including the errors inherent in the analytical methods and
characteristics of the matrix being sampled.
Uncertainties in the exposure assessment are related to estimates of how often an
individual would actually come in contact with the chemicals of concern, the period of
time over which such exposure would occur, and in the models used to estimate the
concentrations of the chemicals of concern at the point of exposure.
16
-------
Uncertainties in toxicologicaldata occur from extrapolating from animals to humans and
from high to low doses of exposure; as well as from the difficulties in assessing the
toxicity of a mixture of chemicals. These uncertainties are addressed by making
conservative assumptions concerning risk and exposure parameters throughout the
assessment. As a result, the Risk Assessment provides upper-bound estimates of the
risks to populations near the Site, and is highly unlikely to underestimate actual risks
related to the Site.
More specific information concerning public health risks, including a quantitative
evaluation of the degree of risk associated with various exposure pathways, is presented
in the Risk Assessment Report.
SELECTION OF SITE CLEANUP LEVELS
The cleanup levels for groundwater at the Tutu WellfieldSite are driven by MCLs and
drinking water standards established by federal and territorial regulations, (see Table 11)
The Tutu aquifer is classified as a potable drinking water supply, therefore the drinking
water standards are the cleanup goals. It must be noted that it may not be possible to
restore the aquifer to drinking water standards in those areas where DNAPLsare
present.
Treatment goals for extracted groundwater may vary from aquifer remediation goals (i.e.
MCLs), depending on the discharge standards that apply to the location to which treated
groundwater is discharged (i.e., if treated groundwater is not used for potable supply, it
may be discharged to surface water or to the sanitary sewer at appropriate discharge
criteria).
There are no promulgated federal or territorial cleanup regulatory standards for soils.
Furthermore, the baseline risk assessments conducted for the Site indicate that current
concentrations of contaminants in Site soils present acceptable human health risks for
direct exposure pathways. (The only unacceptable direct exposure risk from soils was
from manganese in surface soils at the Tillett Garden and Art Center, which caused the
non-carcinogenic Hazard Index for residential use to slightly exceed the target level of 1.
However, the manganese concentrations in soil at this property were within the range of
concentrations detected in un-impacted background soils at the Site and are therefore
believed to be naturally occurring.) Therefore, site-specific cleanup guidelines for
contaminants in soils were developed by EPA based on the contaminants' potential to
leach into groundwater and thereby contribute to the groundwater ingestion risk.
The soil cleanup guidelines were determined by modeling contaminant transport
through the vadose (unsaturated) zone using a one-dimensional mixing cell model
(CDM Federal, 1995). The soil leaching calculations were based on equations derived
from EPA's "Evaluation of Groundwater Extraction Remedies" (EPA/540/2-89/054,
September 1989), and incorporated Site-specific information on soil characteristics
17
-------
(composition, porosity, organic carbon content, depth to water, etc.). The principal
chemicals exceeding MCLs or driving risk in groundwater at the Tutu site are the volatile
petroleum hydrocarbons (BTEX) and the chlorinated VOCs (PCE, TCE, DCE and vinyl
chloride). Soil screening levels (SSLs) were therefore calculated for BTEX (using
benzene as an indicator compound) and chlorinated VOCs (using PCE as an indicator
compound) for four properties where soil quality is believed to be impacting groundwa-
ter quality: 1) the Curriculum Center, 2) Texaco Tutu Service Station, 3) Esso Tutu
Service Station, and 4) O'Henry Dry Cleaners. SSLs for these properties are shown in
Table 12. These concentrations represent a conservative estimate of residual concentra-
tions of contaminants that could remain in soils such that the resulting groundwater
concentrations would be at or below MCLs.
For properties with lesser amount of BTEX contamination, Ramsay Motors and Western
Auto, separate site-specific vadose zone modeling.was not performed. Instead, it was
assumed that since the soil profiles (depth to bedrock, depth to water, etc) at the Esso
Tutu Service Station and the Texaco Service Station are similar to those at Ramsay and
Western Auto, their SSLs were appropriate screening values. The EPA's SSLs for BTEX
that were calculated for Texaco and Esso were essentially the same (13 and 15 ug/kg,
respectively). Therefore, Esso's SSL of 15 was applied to screen BTEX constituents at
the other properties within or adjacent to the Four Winds Plaza area.
The derived SSLs are guideline values which may be adjusted by EPA as additional site-
specific soils data becomes available during pre-design activities.
REMEDIAL ACTION OBJECTIVES
Remedial action objectives are specific goals to protect human health and the environ-
ment. These objectives are based on available information and standards such as
applicable or relevant and appropriate requirements (ARARs) and risk-based levels
established in the risk assessment.
The following remedial action objectives were established:
• Remove and/or control the sources of groundwater contamination.
• Remove contamination in groundwater. Restore the aquifer to drinking
water standards, except to the extent that such full groundwater restora-
tion proves to be technically impracticable due to the presence of DNAPLs.
• Control the migration of impacted groundwater.
• Prevent human ingestion of groundwater exhibiting excess lifetime cancer
risks greater than 1 in 10,000 or a hazard index greater than 1.
18
-------
Prevent direct human contact and exposure to contaminated soils that
pose excess cancer risks greater than 1 in 10,000 or a hazard index greater
than 1.
Eliminate leaching of contaminants of concern from soils into ground-
water at concentrations which adversely impact groundwater quality and
which might ultimately have negative ecological effects.
DESCRIPTION OF REMEDIAL ALTERNATIVES
CERCLA§121(b)(1), 42 U.S.C. §9621(b)(1), mandates that a remedial action must be
protective of human health and the environment, cost effective, and utilize permanent
solutions and alternative treatment technologies or resource recovery technologies to
the maximum extent practicable. Section 121(b)(1) also establishes a preference for
remedial actions which employ, as a principal element, treatment to permanently and
significantly reduce the volume, toxicity, or mobility of the hazardous substances,
pollutants and contaminants at a site. CERCLA§121(d), 42 U.S.C. §9621(d), further
specifies that a remedial action must attain a level or standard of control of the hazard-
ous substances, pollutants, and contaminants, which at least attains ARARs under
federal and state laws, unless a waiver can be justified pursuant to CERCLA§121(d)(4),
42 U.S.C. §9621 (d)(4).
This ROD evaluates in detail, five remedial alternatives (Soil Remediation Alternatives
(SRA) 1, 2, 3, 4, and 5) for addressing the soil contamination and four remedial alterna-
tives (Groundwater Remediation Alternatives (GRA) 1, 2, 3, and 4 ) for addressing
groundwater contamination associated with the Tutu WellfieldSite. Construction times
reflect only the time required to construct or implement the remedy and does not
include the time required to design the remedy, negotiate with the responsible parties,
procure contracts for design and construction, or conduct operation and maintenance at
the Site.
In December 1995, EPA and DPNR conducted a site inspection of all properties at the
Tutu WellfieldSite following the restoration of power to the area after the devastation
of Hurricane Marilyn. Based on the site inspections, it was determined that no soil
remedial action will be required for the Ramsay Motors property at this time. The
concrete floor in the area of subsurface soil contamination had been thought to be
cracked but now appears to be of sound integrity, with no visible signs of cracking, and
at this time, it will not be necessary to repair this area as recommended in the FS.
Institutional controls are needed as to Ramsay Motors' property, however (see the
discussion of institutional controls, below).
EPA and DPNR also determined that soil remediation will not be required at the Tillett
Gardens property. In September 1995, EPA and DPNR collected confirmatory soil
19
-------
samples from the previous area of aroclor (PCBs) contamination to verify the locations
and volumes of impacted soils. No PCBs were detected in any of the samples, indicat-
ing that PCBs are no longer a concern for this property.
Soil Remedial Alternatives (SRA) For Impacted Soil:
Source Control Programs (SCPs) for the Texaco and Esso Service Stations will be imple-
mented for SRA 2, SRA 3, SRA 4 and SRA 5. SCPs at these facilities include installation
of in-situ Soil Vapor Extraction (SVE) treatment and/or bioventing of impacted soils. This
action is consistent with EPA's expectation to use treatment to address principal threat
wastes. The anticipated duration of each of the SCPs is 5 years. The capital cost,
operation & maintenance (O & M) and total present worth costs of SRA 2, SRA 3, SRA 4
and SRA 5 include the implementation of the SCPs. The O & M cost has been estimat-
ed based on the projection that the O&M of the SCPs will continue for 5 years. (The
actual O&M period may be shorter or longer than 5 years.)
SRA 1: No Action/Institutional Controls
Capital Cost: $15,000
O&M Present Worth: $0
Total Present Worth, 30-Yr. Cost: $15,000
Construction Time: Not applicable
The Superfund program requires that the "no-action" alternative be considered as a
baseline for comparison with other alternatives. The institutional controls as recom-
mended in SRA 1 are defined as follows for all properties within the confines of the
plume which contain soil contamination that exceeds the SSLs, including: Esso Service
Station, Texaco Service Station, .Ramsay Motors Company, Four Winds Plaza/Western
Auto, O'Henry Dry Cleaners and the Curriculum Center.
• Institutional controls in the form of Governmental controls and/or proprietary
controls would be sought which place limitations on property usage (e.g., limit
the properties to commercial or industrial use);
• Institutional controls in the form of Governmental controls and/or proprietary
controls would be sought which prohibit excavation or soil disturbance at any of
the impacted areas without prior approval, proper worker-protection precautions,
and air monitoring for potential fugitive emissions;
• Institutional controls in the form of Governmental controls and/or proprietary
controls would be sought which prohibit the use or transport of excavated soil or
rock from impacted areas without EPA and DPNR approval;
20
-------
Institutional controls in the form of Governmental controls and/or proprietary
controls would be sought which prohibit removal or disturbance of bedrock at
O'Henry Dry Cleaners and the Curriculum Center where DNAPLsmay be
present.
SRA 2: Institutional Controls/Capping
Capital Cost: $311,000
O & M Present Worth: $ 396,000
Total Present Worth, 30-Yr. Cost: $ 707,000
Construction Time: 12 to 18 months
The focus of SRA 2 is to design and implement capping at all properties where impacted
soil or rock is present except at the Texaco and Esso Service Stations where in-situ
SVE/bioventing will be implemented as part of the SCP.
SRA 2 consists of the followingactions:
• Institutional controls as described in SRA 1;
• Design and implement capping, i.e. geomembrane, pavement, concrete or soil
caps, at all the properties where impacted soil or rock is present (apart from the
Texaco and Esso Service Stations);
• Implement Source Control Programs (SCPs) at the Texaco and Esso Service
Stations.
Capping reduces but does not eliminate leaching of contaminants of concern (COCs) to
ground water. The Curriculum Center, Texaco Tutu Service Station, Esso Tutu Service
Station, Four Winds Plaza/Western Auto and O'Henry Dry Cleaners have been evaluat-
ed against the SSLs and based on the property-specific circumstances, under this
alternative, full or partial capping would be installed, modified, and/or maintained at
each property. Caps already exist at some individual properties, while other properties
would require installation of a cap or pavement, as necessary.
SRA 3: Institutional Controls/Capping/ln-situ Soil Vapor Extraction (SVE)/
Excavation and Off-site Disposal
Capital Cost: $ 1,533,000
O & M Present Worth: $ 2,062,000
Total Present Worth, 30-Yr. Cost: $ 3,595,000
Construction Time: 12 to 18 months
21
-------
The focus of SRA 3 is to design and implement in-situ SVE at most of the locations
where contaminated soils present a threat to the groundwater. In-situ SVE is a treat-
ment technology which consists of the installation of a network of vadose zone extrac-
tion wells or trenches in areas where soil contamination with VOCs exists. VOCs
present in the unsaturated, interstitial vapor space between the soil particles are
extracted under influence of a vacuum that is induced by a blower. This action upsets
the equilibrium that exists between the constituents present in the interstitial vapor
space and any constituents that might be present in an adsorbed phase on the soil
particles or be present in the free phase. As the constituents in the vapor phase are
removed by the vacuum, some of the adsorbed or free-phase constituents adjust to the
shift in equilibrium by volatilizatinginto the soil pore spaces. The newly volatilized
constituents are then removed under the constant influence of the vacuum that is
induced by the extraction blower. For biodegradable compounds such as BTEX, an
added benefit is gained from the enhanced biodegradation of these compounds by
indigenous soil biota due to increased soil oxygen levels. Technologies for treating the
exhaust from the extraction blower includes thermal oxidation (thermox) or catalytic
oxidation (catox). During the operation of the SVE systems, an impermeable cover is
installed over the impacted area to prevent short-circuiting of the systems.
The SVE systems would be operated until no VOCs are present in the extraction well air
vapor system.
In particular, SRA 3 consists of the following actions:
• Institutional controls as described in SRA 1.
Texaco Tutu Service Station:
• . In-situ SVE treatment of impacted soil;
• Catalytic oxidation for off-gas treatment.
Esso Tutu Service Station:
• In-situ SVE treatment and bioventing of impacted soil;
• Thermal oxidation for off-gas treatment.
Four Winds Plaza/Western Auto:
• Excavation and off-Site disposal of additional soils, if needed (to be deter-
mined after confirmatory sampling during RD).
22
-------
O'Henry Dry Cleaners: . .
• In-situ SVE treatment of impacted soils;
• In-situ SVE treatment in the unsaturated bedrock;
• Thermal oxidation for off-gas treatment.
Curriculum Center:
• Excavation and off-Site disposal of impacted soils;
• In-situ SVE treatment in unsaturated bedrock areas and in soil areas not
suitable for excavation, to remediate contaminated soils and rocks present
in the .unsaturated zone;
• Thermal oxidation for off-gas treatment.
While in-situ SVE is the primary remediation technique under this alternative, at
properties where in-situ SVE is not feasible due to technical limitations or is cost-
prohibitive (due to small volume), impacted soils would be excavated, containerized and
shipped off-site for disposal.
Source removal can be achieved by excavating contaminated soil at Four Winds Pla-
za/Western Auto and the Curriculum Center . The excavated material would be
containerized and tested for waste classification. If the soils are deemed non-hazardous,
they would be disposed of locally. If they are deemed hazardous, they would be
transported off-Island to a permitted hazardous waste treatment or disposal facility.
The impacted soil can be'removed from properties by mechanical excavation. Standard
excavating equipment, including backhoes, power shovels and clamshells can be used
.to excavate soil and can be decontaminated afterward. The excavated material can be
containerized and loaded directly into trucks for off-site treatment or disposal.
SVE will reduce the level of contaminants in soil or bedrock at the specified properties,
thus reducing the potential for leaching of contaminants to ground water and subse-
quent off-Site migration. The SVE systems described would be operational until no
VOCs are present in the extraction well air vapor stream. Air emission controls on the
SVE systems will be protective of human health and the environment by meeting
emission permit standards under the Clean Air Act.
23
-------
SRA 4: Institutional Controls/Capping/Ex-situ SVE/Excavation and On-site Disposal
Capital Cost: $ 1,502,000
O & M Present Worth: $ 2,038,000
Total Present Worth, 30-Yr. Cost: $ 3,540,000
Construction Time: 12 to 18 months
SRA 4 is the same as SRA 3 except that at O'Henry Dry Cleaners, there would be some
excavation and ex-situ SVE of impacted soils instead of in-situ SVE, and at the Curricu-
lum Center, the soils to be excavated would be treated via ex-situ SVE and re-deposited
on Site rather than being sent off-Site for disposal.
Ex-situ SVE is the application of vapor phase extraction technologies to remove contami-
nants from soils that have been excavated from their original place of contamination and
placed above ground. The impacted soil can be removed from properties by mechanical
excavation. Standard excavating equipment, including backhoes, power shovels and
clamshells can be used to excavate soil and decontaminated afterward. The excavated
material can be staged for subsequent treatment, or, in the case of Four Winds Pla-
za/Western Auto, containerized and loaded directly into trucks for off-Site treatment or
disposal.
In particular, SRA 4 consists of the following actions:
• Institutional controls as described in SRA 1.
Texaco Tutu Service Station:
• In-situ SVE treatment of impacted soil;
• Catalytic oxidation for off-gas treatment.
Esso Tutu Service Station:
• In-situ SVE treatment and bioventing of impacted soil;
• Thermal oxidation for off-gas treatment.
Four Winds Plaza/Western Auto:
• Excavation and off-Site disposal of additional soils, if needed (to be deter-
mined after confirmatory sampling during RD).
O'Henrv Dry Cleaners:
24
-------
• Excavation, ex-situ SVE of impacted soils and redepositing of the treated
soil on-Site;
• In-situ SVE treatment in the unsaturated bedrock and soil areas not
suitable for excavation, to remediate contaminated soils and rocks present
above the water table;
• Thermal oxidation for off-gas treatment.
Curriculum Center:
• Excavation, ex-situ SVE of impacted soils and redepositing of the treated
soil on-Site; -,., ; , •
• In-situ SVE treatment in unsaturated bedrock areas and in soil areas not
suitable for excavation to remediate contaminated soils and rocks present
in the unsaturated zone;
• Thermal oxidation for off-gas treatment.
Ex-situ SVE will reduce the level of contaminants in soil at the specified properties, thus
reducing the potential for leaching of contaminants to ground water and subsequent off-
Site migration. Air emission controls on the SVE system and covering of the soil piles
during treatment would be protective of human health and the environment by meeting
emission permit standards. The SVE systems described would be operated until no
VOCs are present in the extraction well air vapor stream. The treated soil would be
disposed of on-Site.
SRA 5: Institutional Controls/ln-situ SVE/Excavation and Off-Site Disposal
Capital Cost: $ 2,035,000
O & M Present Worth: $ 1,786,000
Total Present Worth, 30-Yr. Cost: $ 3,821,000
Construction Time: 12 to 18 months
SRA 5 is identical to SRA 3 except that at O'Henry Dry Cleaners, some of the impacted
soils would be excavated and disposed of off-Site.
Specifically, SRA 5 consists of the followingactions:
• Institutional controls as described in SRA 1.
25
-------
Texaco Tutu Service Station: . .
• In-situ SVE treatment of impacted soil;
• Catalytic oxidation for off-gas treatment.
Esso Tutu Service Station:
• In-situ SVE treatment and bioventing of impacted soil;
• Thermal oxidation for off-gas treatment.
Four Winds Plaza/Western Auto: . .
• Excavation and off-Site disposal of additional soils, if needed (to be deter-
mined after confirmatory sampling during RD).
O'Henrv Dry Cleaners:
• Excavation and off-Site disposal of impacted soils;
• In-situ SVE treatment in.the unsaturated bedrock, and soil areas not
suitable for excavation, to remediate contaminated soils and rocks present
above the water table;
• Thermal oxidation for off-gas treatment.
Curriculum Center:
• Excavation and off-Site disposal of impacted soils;
• In-situ SVE treatment in unsaturated bedrock areas and in soil areas not
suitable for excavation, to remediate contaminated soils and rocks present
in the unsaturated zone;
• Thermal oxidation for off-gas treatment.
Soil at individual properties where contamination is above the SSLs identified for the
Tutu WellfieldSite would be excavated and containerized except at the Texaco and Esso
Service Stations. The excavated contaminated soil would be sampled to determine if it
is hazardous waste. If the soils are deemed non-hazardous, they would disposed of
locally. If they are deemed hazardous, they would be transported off-Island to a permit-
ted hazardous waste treatment or disposal facility. Clean fill material would be brought
26
-------
in to restore each of the areas to grade. Topsoil and seed or paving would be installed
to finish the restoration.
The impacted soil can be removed from properties by mechanical excavation. Standard
excavating equipment, including backhoes, power shovels and clamshells can be used
to excavate soil and decontaminated afterward. The excavated material can be contain-
erized and loaded directly into trucks for off-site treatment or disposal.
Groundwater Remedial Alternatives (GRA) for Impacted Groundwater:
Source Controls Programs (SCPs) for Texaco and Esso Service Stations will be imple-
mented as an early remedial action for CRA2, GRA 3 and GRA 4. The early remedial
action will consist of installation of extraction wells and air strippers to contain and treat
the plumes of impacted groundwater at these facilities. The capital cost, operation &
maintenance (O & M) and total present worth costs of GRA 2, GRA 3 and GRA 4
include the implementation of the SCPs. The anticipated duration of each SCP is 5
years, though the actual duration may prove to be shorter or longer than that estimate.
GRA1: No Action/Institutional Controls/Monitoring
Capital Cost: $ 15,000
O & M Present Worth: $ 1,377,000
Total Present Worth, 30-Yr. Cost: $ 1,392,000
Construction Time: 12 months
Under this alternative, institutional controls in the form of governmental and/or propriet-
ary controls would be sought to prevent the installation of new supply wells in the
affected area. Water would continue to be supplied to affected residents as it is
currently being supplied (i.e., through collection of rain water to cisterns and trucking
water by tanker trucks).
More specially, GRA 1 consists of the followingactions:
• Institutional controls to prohibit unauthorized use of groundwater or installation of
new wells. Authorization must be obtained from DPNRand EPA before use of
existing wells or installation of any new wells within the confines of the plume
area.
• Conduct semi-annual groundwater sampling to monitor its quality and contami-
nant migration. The monitoring program includes sampling approximately 15
wells at or near the plume boundary for VOCs and BNAs, and would last throug-
hout the remedial action and O&M (estimated, for costing purposes, to be
approximately 30 years).
27
-------
GRA 2: Institutional Controls/Source Containment/POET Svstems/Treatment/Discharge
Capital Cost: $ 2,366,000
O & M Present Worth: $ 6,223,000
Total Present Worth, 30-Yr. Cost: $ 8,589,000
Construction Time: 12 to 18 months
GRA 2 consists of a methodology for hydraulic containment of the potential groundwater
contamination source areas (O'Henry Dry Cleaners and the Curriculum Center) that
exhibit the highest groundwater VOC concentrations, and incorporates treatment of
pumped groundwater and either discharge of treated water to surface water or dis-
charge for distribution for potable purposes. In other areas of the aquifer, natural
attenuation would be relied upon.
The total flow capacity of the treatment facility would be 55 gpm. Property acquisition
might be required for such treatment facility.
GRA 2 consists of the followingelements:
• Efforts would be made to have existing domestic and commercial wells within
the confines of the groundwater plume decommissioned if these wells are deter-
mined to interfere with the operation of the groundwater pump and treat system
that will be installed as part of this remedial action. During the remedial design it
will be determined which wells would interfere with this remedial action and
which wells would continue to operate as they may enhance aquifer restoration,
which is a goal of this remedial action. For those wells that are decommissioned,
EPA would analyze alternative sources of water for the users of those wells and
determine appropriate alternate sources of water for the affected users. These
wells could be reestablished at sortie point in the future, when and if groundwa-
ter quality improves to allow extraction and use of untreated groundwater.
• Institutional controls to prohibit unauthorized use of groundwater or installation of
new wells. Authorization must be obtained from DPNRand EPA before use of
existing wells (i.e., wells that are not decommissioned) or installation of any new
wells within the confines of the plume area.
• Implement SCPs at the Texaco and Esso Service Stations to address impacted
groundwater in the immediate vicinity of these facilities.
• Install two groundwater recovery wells (RW-4 and RW-5) for hydraulic control of
chlorinated VOC contaminant sources. The source containment would provide
hydraulic barriers around source areas, allowing the reduction of contaminants in
other parts of the aquifer and potentially reducing the time needed to reach
28
-------
MCLs through treatment in large portions of the Tutu WellfieldSite. (See Figure
5)
Install point of entry treatment systems (POETS) at the Four Winds Plaza, and the
Steele, Smith, Laplace and Matthias residences.
Construct a central groundwater treatment facility with total flow capacity of 55
gallons per minute (gpm). Water would be treated to surface water criteria for
discharge via the storm sewer near the O'Henry Dry Cleaners to Turpentine Run
or would be treated to MCLs for distribution for potable purposes.
Natural attenuation of low concentration contaminants at the plume edges.
Conduct semi-annual groundwater sampling to monitor its quality and contami-
nant migration. The monitoring program includes sampling approximately 15
wells at or near the plume boundary for VOCs and BNAs, and would last throug-
hout the remedial action and O&M (estimated, for costing purposes, to be
approximately 30 years).
GRA 3: Institutional Controls/Plume Containment/Treatment/Discharge
Capital Cost: $.2,537,000
O&M Present Worth: $ 4,929,000
Total Present Worth, 30-Yr. Cost: $ 7,466,000
Construction Time: 12 to 18 months
CRA3 consists of a methodology for hydraulic containment of the delineated plumes
and incorporates treatment of pumped groundwater and either discharge of treated
pumped groundwater to surface water or discharge for potable purposes.
This proposed containment program would include the installation of at least three
recovery wells (RW-1, RW-2 and RW-3). These wells would be strategically placed to
hydraulicallycontain plume migration. Selected residential and commercial groundwater
use in some areas would counteract the hydraulic containment program and reduce the
program's effectiveness in containing the impacted groundwater. Thus, this alternative
would include the same institutional controls (including some well decommissioning) as
described in GRA2.
The total flow capacity of the treatment facility would be 55 gpm. Property acquisition
might be required for such treatment facility; the facility would be located in the vicinity
of the southern plume containment wells. This location would be at a lower elevation
when compared to the rest of the Tutu WellfieldSite, thus reducing pumping require-
ments.
29
-------
GRA3 consists of the following elements:
• Efforts would be made to have existing domestic and commercial wells within
the confines of the groundwater plume decommissioned if these wells are deter-
mined to interfere with the operation of the groundwater pump and treat system
that will be installed as part of this remedial action. During the remedial design it
will be determined which wells would interfere with this remedial action and
which wells would continue to operate as they may enhance aquifer restoration,
which is a goal of this remedial action. For those wells that are decommissioned,
EPA would analyze alternative sources of water for the users of those wells and
determine appropriate alternate sources of water for the affected users. These
wells could be reestablished at some point in the future, when and if groundwa-
ter quality improves to allow extraction and use of untreated groundwater.
• Institutional controls to prohibit unauthorized use of groundwater or installation of
new wells. Authorization must be obtained from DPNRand EPA before use of
existing wells (i.e., wells that are not decommissioned) or installation of any new
wells within the confines of the plume area.
• Implement SCPs at the Texaco and Esso Service Stations to address impacted
groundwater in the immediate vicinity of these facilities.
• Install groundwater recovery wells for hydraulic control of plume migration. The
proposed containment program would include the installation of three recovery
wells (RW-1, RW-2, and RW-3) strategically placed in an effort to hydraulically
contain plume migration. (See Figure 5)
• Construct a centra! groundwater treatment facility with total flow capacity of 55
gallons per minute (gpm). Water would be treated to surface water criteria for
discharge via the storm sewer near the O'Henry Dry Cleaners to Turpentine Run
or would be treated to MCLs for distribution for potable purposes. If a decision is
made to treat the water to surface water criteria (not to MCLs), then water would
continue to be supplied to affected residents as it is currently being supplied (i.e.,
through collection of rain water to cisterns and trucking water by tanker truck).
• Natural attenuation of low concentration contaminants at the plume edges.
• Conduct semi-annual groundwater sampling to monitor its quality and contami-
nant migration. The monitoring program includes the sampling approximately 15
wells at or near the plume boundary for VOCs and BNAs, and would last for the
duration of the remedial action and O&M (estimated, for costing purposes, to be
approximately 30 years).
30
-------
GRA4: Institutional Controls/Source and Plume Containment/Treatment/Discharge
Capital Cost: $3,175,000
O & M Present Worth: $ 5,856,000
Total Present Worth, 30-Yr. Cost: $ 9,031,000
Construction Time: 12 to 18 months
GRA4 is identical to GRA3, with the addition of the installation of two groundwater
recovery wells for hydraulic control of two of the areas identified as potential source
areas (O'Henry Cleaner and Curriculum Center). CRA4 proposes the containment of
plume migration as well as hydraulic source containment in areas that are suspected of
being sources of impacts to ground water. (See Figure 5)
The source containment would provide hydraulic barriers around source areas, thus
reducing COCs in other parts of the aquifer, and would likely reduce the time needed to
reach MCLs in large portions of the Tutu WeiIfield Site. The plume containment wells
would prevent the continued migration of Site contaminants.
The total flow capacity of the treatment facility would be 100 gpm. Property acquisition
might be required for such treatment facility; the facility would be located in the vicinity
of the southern plume containment wells. This location would be at a lower elevation
when compared to the rest of the Tutu WellfieldSite, thus reducing pumping require-
ments.
GRA4 involves the following actions:
• Efforts would be made to have existing domestic and commercial wells within
the confines of the groundwater plume decommissioned if these wells are deter-
mined to interfere with the operation of the groundwater pump and treat system
that will be installed as part of this remedial action. During the remedial design it
will be determined which wells would interfere with this remedial action and
which wells would continue to operate as they may enhance aquifer restoration,
which is a goal of this remedial action. For those wells that are decommissioned,
EPA would analyze alternative sources of water for the users of those wells and
determine appropriate alternate sources of water for the affected users. These
wells could be reestablished at some point in the future, when and if groundwa-
ter quality improves to allow extraction and use of untreated groundwater.
• Institutional controls to prohibit unauthorized use of groundwater or installation of
new wells. Authorization must be obtained from DPNRand EPA before use of
existing wells (i.e., wells that are not decommissioned) or installation of any new
wells within the confines of the plume area.
31
-------
• Implement SCPs at the Texaco and Esso Service Stations to address impacted
groundwater in the immediate vicinity of these facility.
• Install groundwater recovery wells for hydraulic control of plume migration. The
proposed containment program would include the installation of three recovery
wells (RW-1, RW-2, and RW-3) strategically placed in an effort to hydraulically
contain plume migration. (See Figure 5)
• Install two groundwater recovery wells (RW-4 and RW-5) for hydraulic control of
chlorinated VOC contaminant sources. The source containment would provide
hydraulic barriers around source areas, allowingthe reduction of contaminants in
other parts of the aquifer and potentially reducing the time needed to reach
MCLs in large portions of the Tutu WellfieldSite. (See Figure 5)
• Construct a central groundwater treatment facility with total flow capacity of 100
gallons per minute (gpm). Water would be treated to surface water criteria for
discharge via the storm sewer near the O'Henry Dry Cleaners to Turpentine Run
or would be treated to MCLs for distribution for potable purposes. If a decision is
made to treat the water to surface water criteria (not to MCLs), then water would
continue to be supplied to affected residents as it is currently being supplied (i.e.,
through collection of rain water to cisterns and trucking water by tanker truck).
• Conduct semi-annual groundwater sampling to monitor its quality and contami-
nant migration. The monitoring program includes the sampling approximately 15
wells at or near the plume boundary for VOCs and BNAs, and would last for the
duration of the remedial action and O&M (estimated, for costing purposes, to be
approximately 30 years).
• Natural attenuation of low concentration contaminants at the plume edges.
Various potable use options for treated water are as follow:
connect to the existing Water and Power Authority water main;
truck the treated water to the impacted residences within the plume area;
install a water distribution system from the central treatment facilityto the
impacted residences within the plume area.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In selecting a remedy, EPA considered the factors set out in CERCLA§121, 42 U.S.C.
§9621, by conducting a detailed analysis of the viable remedial alternatives pursuant to
32
-------
the NCR, 40 CFR §300.430(e)(9) and OSWER Directive 9355.3-01. The detailed analysis
consisted of an assessment of the individual alternatives against each of nine evaluation
criteria and a comparative analysis focusing upon the relative performance of each
alternative against those criteria.
The following "threshold" criteria must be satisfied by any alternative in order to be
eligible for selection:
1. Overall protection of human health and the environment addresses whether or
not a remedy provides adequate protection and describes how risks posed
through each exposure pathway (based on a reasonable maximum exposure
scenario) are eliminated, reduced, or controlled through treatment, engineering
controls, or institutional controls.
2. Compliance with ARARsaddresses whether or not a remedy would meet all of
the applicable (legally enforceable), or relevant and appropriate (requirements
that'pertain to situations sufficiently similar to those encountered at a Superfund
site such that their use is well suited to the site) requirements of federal and
state environmental statutes and requirements or provide grounds for invoking a
waiver.
The following "primary balancing" criteria are used to make comparisons and to identify
the major trade-offs between alternatives:
3. Long-term effectiveness and permanence refers to the ability of a remedy to
maintain reliable protection of human health and the environment overtime,
once cleanup goals have been met. It also addresses the magnitude and
effectiveness of the measures that may be required to manage the risk posed by
treatment residuals and/or untreated wastes.
4. Reduction of toxicity, mobility, or volume via treatment refers to a remedial
technology's expected ability to reduce the toxicity, mobility, or volume of
hazardous substances, pollutants or contaminants at the site.
5. Short-term effectiveness addresses the period of time needed to achieve protec-
tion and any adverse impacts on human health and the environment that may be
posed during the construction and implementation periods until cleanup goals
are achieved.
6. Implementability refers to the technical and administrative feasibility of a remedy,
including the availabilityof materials and services needed.
7. Cost includes estimated capital and operation and maintenance costs, and the
present-worth costs.
33
-------
The following "modifying"criteria are considered fully after the formal public comment
period on the Proposed Plan is complete:
8. Territorial acceptance indicates whether, based on its review of the RI/FS and the
Proposed Plan, the Territory supports, opposes, and/or has identified any reserva-
tions with the preferred alternative.
9. Community acceptance refers to the public's general response to the alternatives
described in the Proposed Plan and the RI/FS reports. Factors of community
acceptance to be discussed include support, reservation, and opposition by the
community.
A comparative analysis of the remedial alternatives based upon the evaluation criteria
noted above follows:
• Overall Protection of Human Health and the
Environment
SRA 1 (No Action/Institutional Controls) does not meet the requirements of this criterion
due to the current and potential future exposures to unacceptable levels of contamina-
tion. In addition, it is unclear whether adequate institutional controls could be obtained
and would remain in place over time. SRA 3, SRA 4 and SRA 5 provide equal protection
of human health and the environment because they mitigate exposure to contaminants
and reduce their migration to the environment through capping, excavation or soil
treatment by vapor extraction.
GRA 1 does not meet this criterion. GRA2 does not meet this criterion in part because
POET systems are not considered an adequate long-term solution for potential impact
on human health. GRA 3 and GRA 4 will meet this criterion as long as recovery well
capture zones are effective and institutional controls are effectively enforced. GRA 4 will
provide the maximum protection of human health and the environment because it
provides the maximum capture of impacted groundwater by implementing both plume
and source containment.
• Compliance with ARARs
The major ARARs for soil remediation are the RCRALand Disposal Restrictions (LDRs).
The major "To-be-Considered" (TBCs) criteria are the SSLs which are the preliminary
cleanup goals. The SSLs are guidance values to identify soil areas that may require
remediation based on the potential for leaching of contaminants into groundwater. The
EPA's SSLs may be revised after additional soil organic carbon, soil and groundwater
contaminant concentration data and other pertinent hydrogeologic data are collected
during the pre-design phase. SRA 1 and SRA 2 will not comply with TBCs because no
soil would be removed and soil contaminant levels would not be reduced below SSLs
34
-------
and thus could continue to act as a source of contamination to the groundwater. SRA 3,
SRA 4 and SRA 5 can comply with the SSLs for all properties that undergo excavation or
treatment. Excavation and disposal proposed in SRA 3, SRA 4 and SRA 5 can comply
with LDRs for off-Site disposal.
Major ARARs for groundwater remediation include the Federal Safe Drinking Water Act
and its implementing regulations, and the Virgin Islands Drinking Water Standards (Title
19, Chapter 51 of the Virgin Islands Code), which establish Maximum Contaminant
Levels (MCLs) for drinking water. In addition, the Virgin Islands Water Pollution Control
Act requires Territorial Pollution Discharge Elimination System (TPDES) permits which
establish discharge limits to surface water. The Federal Executive Order 11990 for the
Protection of Wetlands also requires any remedial action to minimize harm to or within
wetlands. - .
GRA 1 (No Action/Institutional Controls) does not comply with ARARs because without
active remediation, it is uncertain whether the aquifer will ever attain MCLs. All other
treatment schemes (GRA 2, GRA 3, and GRA 4) have the ability to meet ARARs over
time. However, GRA 4 would best meet this criterion because it has the ability to
restore the aquifer the quickest.
Full groundwater restoration at the Curriculum Center and O'Henry Dry Cleaners
properties might prove to be technically impracticable due to the suspected presence of
DNAPLs. Therefore, a waiver of MCLs.ultimately may be required for the Curriculum
Center and O'Henry Dry Cleaners properties groundwater. EPA's memorandum
Guidance for Evaluating the Technical .Impracticability of Groundwater Remediation
(OSWER Directive 9233334.2-25. October 1993) recognizes that the presence of
DNAPLs may make groundwater restoration technically impracticable.
• Long-Term Effectiveness and Permanence
SRA 1 does not meet this criterion. SRA 2 is effective at minimizing the transport of
i/npacted soil or leaching of contaminants, but does not totally eliminate potential future
exposure. SRA 3/SRA 4 and SRA 5 address this criterion by either removing contaminat-
ed soils from the Site or reducing the levels of contamination in soils. A combination of
SRA 3/SRA 4 would be the most favorable remedy in complying with this criterion. The
long-term effectiveness and permanence of SRA 3/SRA 4 is very high in that the
contaminated soils would be treated and the contaminated areas restored.
GRA 2 is not effective as a long-term or permanent remedy. The potential for off-Site
groundwater transport of contaminants may still exist, depending on the ability to utilize
private wells and to coordinate their pumpage to hydraulically contain impacted
groundwater. GRA 3 is not considered favorable for this criterion because effectiveness
of the plume capture would be contingent upon RW-1, RW-2 and RW-3. Since there
are no source containment wells in GRA 3, other than the SCPs, sources may continue
35
-------
to be active. GRA4 would be the most effective GRAfor this criterion because it
provides both plume and source containment, and the greatest potential for remediation
of the aquifer.
• Reduction in Toxicitv. Mobility, or Volume Through Treatment
SRA 1 and SRA 2 do not provide treatment or reduction in contaminant volume and
therefore do not comply with this criterion, although capping or impermeable cover (for
all alternatives) does reduce contaminant transport to the groundwater. SRA 3/5RA 4
reduce toxicity, mobility and volume of impacted soil by treatment. SRA 5 would also
reduce the toxicity, mobility and volume of impacted soils by treatment, though some of
the impacted soils at the O'Henry Dry Cleaners facility would be excavated and shipped
off-Site for disposal, rather than being treated through in-situ or ex-situ SVE. SRA 4 has
the most potential for reducing soil contaminants because some of the impacted soil
would be treated in an engineered environment rather than in-situ.
GRA2 would be moderately effective in the reduction of toxicity, mobility and volume
because source control would result in contaminant removal from groundwater, and
intermittent pumping of residential wells equipped with POETs would also result in
some reduction in the volume of COCs in groundwater. The toxicity, mobility and
volume of impacted groundwater in GRA3 would be reduced through containment and
pumping; however, the potential presence of DNAPLsin the bedrock aquifer at the Site
could act as a continual source of groundwater contamination throughout the life of the
remedial action. GRA 4 would extract and treat the most impacted ground water, thus
maximizing the reduction in toxicity, mobility, and volume. The effects of DNAPLsthat
may be present in the bedrock aquifer would be reduced with source control, decreas-
ing the time needed to reduce contaminant concentrations within most of the aquifer.
• Short-Term Effectiveness
SRA 2 (Institutional Controls/Capping) would be most effective in the short-term
because it would minimize the fugitive emissions caused by installation of a remedy and
reduce the off-Site impacts. Moderate short-term impacts would occurred during the
implementation of SRA 3/SRA 4. The impacts would be caused by fugitive emissions
and the potential erosion associated with install ing caps, SVE wells, and/or excavation.
However, dust control and emission monitoring and control measures would be
implemented during construction to minimize short-term impacts.
GRA 2 would minimize the amount of construction or disturbance that is required for
installation, and therefore, it would be the most effective GRA at addressing this
criterion. The construction related to GRA 3 and GRA4 is greater than that of GRA 2,
thus creating more potential for impacts to workers and area residents. However, any
impacts could be easily controlled.
36
-------
• Implementabilitv
All of the SRAs evaluated are implementable.
Difficulties might be encountered in seeking to implement some or all of the institutional
controls under the various soil and groundwater remedial alternatives. For example, the
existing wells are owned by individual property owners, which may create a need for a
significant amount of coordination. It may be difficult to ensure that the wells on Site
will not be pumped and that the safe yield for the aquifer will not be exceeded. GRA 2
is the least implementable of all the GRAs because operation issues could be significant
due to maintenance related to the treatment facility and the operation of individual
property owner POET systems. GRA4 would not be favorable under this criterion
because it has the most significant administrative requirements. GRA 4 places the
greatest withdrawal demand on the Tutu aquifer and may create upconing of mineral-
ized water in some areas of the aquifer. Therefore, pre-design studies must carefully
optimize required pumping rates. GRA 3 would be the most implementable because
this GRA is the least obtrusive, minimizingthe amount of impact to the area. The
treatment system design for GRA 3 would be simple to operate, as it would be at a
minimum flow rate and would require the least amount of equipment and materials to
construct.
The cost estimates associated with the alternatives are presented above. SRA 3 and SRA
4, respectively, are the lowest cost soil alternatives that include some sort of treatment
of impacted soils (total present worth of approximately $ 3.6 million). SRA 5 has a
slightly higher total present worth of $ 3.8 million and SRA 2 has the lowest total
present worth of $ 707,000.
GRA 3 has the lowest cost with a total present worth of $ 7.5 million,followed by GRA
2 with a total present worth of $ 8.6 million. GRA 4 has the highest cost with a total
present worth of $ 9.0 million.
• Territorial Acceptance
The Virgin Islands Department of Planning and Natural Resources concurs with the
selected remedy.
• Community Acceptance
Community acceptance of the preferred remedy has been assessed in the Responsive-
ness Summary portion of this ROD followingthe review of all public comments received
on the RI/FS report and the Proposed Plan. All comments submitted during the public
37
-------
comment period were evaluated and are addressed in the attached Responsiveness
Summary (Appendix V).
SELECTED REMEDY
EPA and DPNRhave determined after reviewing the alternatives and public comments,
that Alternatives SRA 3/SRA 4 and GRA4 are the appropriate remedies for the Site,
because they best satisfy the requirements of CERCLA§121, 42 U.S.C. §9621, and the
NCR's nine evaluation criteria for remedial alternatives, 40 CFR §300.430(e)(9).
The major components of the selected remedy are as follows:
SOIL REMEDIATION ALTERNATIVE (SRA 3/4)
• Institutional controls in the form of Governmental controls and/or proprietary
controls will be sought which place limitations on property usage (e.g., for
commercial or industrial use only);
• Institutional controls in the form of Governmental controls and/or proprietary
controls will be sought which ensure that excavation or soil disturbance at any of
the impacted areas will not occur in the future without full permit approval,
proper worker-protection precautions, and air monitoring for potential fugitive
emissions;
• Institutional controls in the form of Governmental controls and/or proprietary
controls will be sought which prohibit the excavation, transportation and usage of
soil or rock from impacted areas without EPA and DPNR approval;
• Institutional controls in the fbrm of Governmental controls and/or proprietary
controls will be sought which prevent permanently the removal or disturbance of
bedrock at O'Henry Dry Cleaners and the Curriculum Center where DNAPLsmay
be present in the subsurface.
The following remedial activities will take place at the affected properties:
Texaco Tutu Service Station:
• In-situ Soil Vapor Extraction (SVE) treatment of npacted soil;
• Catalytic oxidation for off-gas treatment.
Esso Tutu Service Station:
• In-situ SVE treatment and bioventing of impacted soil;
38
-------
• Thermal oxidation for off-gas treatment.
Four Winds Plaza/Western Auto:
• Excavation and off-Site disposal of additional soils, if needed (to be deter-
mined after confirmatory sampling during remedial design).
O'Henry Dry Cleaners:
• In-situ SVE treatment of impacted soils or, if such in-situ SVE proves to be
ineffective, excavation and ex-situ SVE treatment of impacted soils followed
by the redepositing of the treated soil on-Site;
• In-situ SVE treatment in the unsaturated bedrock;
• Thermal oxidation for off-gas treatment.
Curriculum Center:
• Excavation of impacted soils, followed by either off-Site disposal, or ex-situ
SVE and redepositing of the treated soil on-Site;
• In-situ SVE treatment in unsaturated bedrock areas and in soil areas not
suitable for excavation, to remediate contaminated soils and rocks present
in the unsaturated zone;
• Thermal oxidation for off-gas treatment.
The potential effectiveness of in-situ SVE will be determined during the pre-design
phase. Additional source delineation is required prior to installation of the in-situ SVE
treatment systems to insure the effectiveness of the remediation.
Buried 4-inch diameter PVC piping may be a potential source of contamination at the
Four Winds Plaza, near the former Western Auto underground storage tank area.
Additional investigation during the pre-design phase will be conducted to determine the
need for remedial work in the areas of the Four Winds Plaza. Western Auto removed its
underground storage tank and paved the area with a concrete cap. Confirmatory
sampling of the tank grave area will be completed to confirm that no residual contami-
nated soil above the SSLs is left in-place. If such soil is present, it will be excavated and
disposed of off-Site.
GROUNDWATER REMEDIATION ALTERNATIVE(GRA 4)
39
-------
Efforts will be made to have existing domestic and commercial wells
within the confines of the groundwater plume decommissioned if these
wells are determined to interfere with the operation of the groundwater
pump and treat system that will be installed as part of this remedial
action. During the remedial design it will be determined which wells
would interfere with this remedial action and which wells would continue
to operate as they may enhance aquifer restoration, which is a goal of this
remedial action. For those wells that are decommissioned, EPA would
analyze alternative sources of water for the users of those wells and
determine appropriate alternate sources of water for the affected users.
These wells could be reestablished at some point in the future, when and
if groundwater quality improves to allow extraction and use of untreated
groundwater.
Institutional controls (in the form of Governmental control and/or propriet-
ary controls) will be sought to prohibit unauthorized use of groundwater or
the installation of new wells. Authorization must be obtained from DPNR
and EPA before use of existing wells (i.e., wells that are not decommis-
sioned) or installation of any new wells within the confines of the plume
area.
Implement Source Control Programs (consisting of installation and opera-
tion of extraction wells and air strippers) at the Texaco and Esso Service
Stations to address impacted groundwater in the immediate vicinity of
these facilities.
Install groundwater recovery wells for hydraulic control of plume migra-
tion. The proposed containment program will include the installation of
three recovery wells (RW-1, RW-2, and RW-3) strategically placed in an
- effort to hydraulicallycontain plume migration. (See Figure 5)
Install two groundwater recovery wells (RW-4 and RW-5) for hydraulic
control of chlorinated VOC contaminant sources. The source containment
will provide hydraulic barriers around source areas, allowingthe reduction
of contaminants in other parts of the aquifer and potentially reducing the
time needed to reach Maximum Contaminant Levels (MCLs). (See Figure
5)
Construct a central groundwater treatment facility with a total flow capaci-
ty of 100 gpm. Water will be treated to surface water criteria for discharge
to the storm sewer near the O'Henry Dry Cleaners facility leading to
Turpentine Run or treated to MCLs for distribution for potable purposes.
EPA, in consultation with the Virgin Islands Government, will choose one
of these two options during the remedial design phase. If a decision is
40
-------
made to treat the water to surface water criteria (not to MCLs), then water
will continue to be supplied to affected residents as it is currently being
supplied (i.e., through col lection of rain .water to cisterns and trucking
water by tanker truck).
• Conduct semi-annual groundwater sampling to monitor its quality and
contaminant migration. The monitoring program will include the sampling
of approximately 15 wells at or near the plume boundary for VOCs and
base, neutral and acids, and would last for the duration of the remedial
action and O&M (estimated, for costing purposes, to be about 30 years).
• Natural attenuation of low concentration contaminants at the plume edges
and downgradient of RW-2 and RW-3.
Various potable use options with respect to the treated groundwater are as follows:
connect to the existing Water and Power Authority water main;
truck the treated water to the impacted residents within the plume area;
install a water distribution system from the central treatment facility to the
impacted residents within the plume area. .
EPA, in consultation with the Virgin Islands Government, will choose one of these
options during the remedial design phase. Additional field work will be required during
the pre-design stage prior to implementation of this remedy. Groundwater extraction
system design will be based on field and aquifer testing and groundwater modelling. A
wetlands assessment may be required if the groundwater modelling shows an adverse
effect from discharges of treated water to the wetlands.
STATUTORY DETERMINATIONS
As previously noted, CERCLA§121(b)(1), 42 U.S.C. §9621(b)(l), mandates that a
remedial action must be protective of human health and the environment, cost effective,
and utilize permanent solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable. Section 121(b)(1) and the
NCP (40 CFR Section 300.430(a)(1)(iii)), also establish a preference for remedial actions
which employ treatment to permanently and significantly reduce the volume, toxicity, or
mobility of the hazardous substances, pollutants, or contaminants at a site. CERCLA
§121(d), 42 U.S.C. §9621 (d), further specifies that a remedial action must attain a
degree of cleanup that satisfies ARARs under federal and state laws, unless a waiver can
be justified pursuant to CERCLA §121 (d)(4), 42 U.S.C. §9621 (d)(4).
41
-------
For the reasons discussed below, EPA has determined that the selected remedy meets
the requirements of CERCLA§121, 42 U.S.C. §9621:
Protection of Human Health and the Environment
SRA 3/SRA 4 afford the protection of human health and the environment by treatment
of impacted soils to reduce their volumes, mobilities and toxicities. SVE is a presump-
tive remedy technology that has proven effective in treating VOCs in soils. SVE will
provide long-term effectiveness and permanence and will maintain reliable protection of
human health and the environment over time.
GRA4 provides the maximum protection of human health and the environment
because it provides the maximum capture of impacted groundwater by implementing
both plume and source containment. This alternative extracts and treats the most
impacted groundwater, thus maximizing the reduction of the toxicity, mobility and
volume of hazardous substances in the groundwater. Implementing plume and source
containment would provide the greatest potential for remediation of the aquifer.
Implementing source containment should expedite the remediation of other portions of
the aquifer and make these portions of the aquifer useable sometime in the future. It is
possible that MCLs may not be achieved at locations where DNAPLsare present.
Compliance with ARARs
The selected soil and groundwater remedy will be in compliance with all ARARs, subject
to the discussion of DNAPIs, below.
The major ARARs for soil remediation are the RCRALand Disposal Restrictions (LDRs).
The major "To-be-Considered" (TBCs) criteria are the SSLs which are the preliminary
cleanup goals. SRA 3 and SRA 4 will comply with the SSLs for all properties that
undergo excavation or treatment. Excavation and disposal proposed in SRA 3 and SRA 4
will comply with LDRs for off-Site disposal. Appropriate air pollution control equipment
will be selected during the remedial design, subject to Federal and Territorial approval.
Emissions controls would be installed as required to comply with Federal and Territorial
air regulations.
ARARs for groundwater remediation include the Federal Safe Drinking Water Act and its
implementing regulations and the Virgin Islands Drinking Water Standards (Title 19,
Chapter 51 of the Virgin Islands Code), which establish Maximum Contaminant Levels
(MCLs) for drinking water. In addition, the Virgin Islands Water Pollution Control Act
requires Territorial Pollutant Discharge Elimination System (TPDES) permits which
establish discharge limits to surface water. The Federal Executive Order 11990 for the
Protection of Wetlands also requires any remedial action to minimize harm to or within
wetlands.
42
-------
EPA recognizes that the restoration of certain portions of the Tutu aquifer to MCLs may
be technically impracticable, due to the high probability that DNAPLsare present in the
unsaturated and/or saturated soils and fractured bedrock at the Curriculum Center and
O'Henry Dry Cleaners properties. If DNAPLsare present in either of these areas, there
are technical limitations, from an engineering perspective, which may make it impracti-
cable to find and remove all the DNAPLsfrom these properties. This will be especially
true if DNAPLsare present in the complex fractured bedrock, either above or below the
water table. Because DNAPLcontributes to dissolved phase groundwater contamina-
tion, restoration of groundwater in the vicinity of the Curriculum Center and O'Henry
Dry Cleaners may be technically impracticable.
However, insufficient Site characterization data are available at this time to support a
Technical Impracticability (Tl) evaluation. The future determination of technical impracti-
cability will be made by EPA based on site-specific characterization data obtained during
remedial design and by remedy performance data collected from soil vapor extraction
wells and groundwater extraction wells. If further supporting evidence for the existence
of a DNAPL constraint is found, it should still be feasible and practicable to at least: 1)
limit further migration of contaminated groundwater using a containment system; and 2)
restore that portion of the aqueous plume outside of the containment area. In such a
case, the Tl waiver will be specially restricted to a limited Tl zone, which lies within a
groundwater containment area. Outside of the Tl zone, ARARs would still apply.
All reasonable efforts, will be made to identify the location of DNAPLs source areas
through historical information searches and site characterization efforts. Even if a Tl
waiver is ultimately invoked, contamination sources must be identified and removed or
treated to the extent practicable.
Cost-Effectiveness
The selected soil remedy is cost-effective. It has been demonstrated to provide overall
effectiveness proportional to its cost. This technology has proven effective in reducing
VOC contaminant concentrations at their source, thereby reducing the time needed for
the pump and treat groundwater remedy. Thus, the selected groundwater alternative is
cost-effective. The present worth of the selected soil remedy is $3,595,000.
Although the selected groundwater remedy is more expensive than most of the
alternatives analyzed, these alternatives did not include plume and source containment
and treatment, which are critical components in meeting the remedial action objectives
and satisfying the statutory criteria. Thus, the selected groundwater alternative is cost-
effective. The present worth of the selected groundwater remedy is $ 9,031,000.
The Utilization of Permanent Solutions and Alternative Treatment Technologies to the
Maximum Extent Practicable
43
-------
The selected remedy utilizes permanent solutions and treatment technologies to the
maximum extent practicable. The selected remedy provides the best balance of trade-
offs among the alternatives with respect to the evaluation criteria
The selected soil remedy will reduce the toxicity, volume and mobility of the impacted
soil from source areas by providing treatment. In addition, the selected groundwater
remedy will control the migration of contaminated groundwater and provides treatment
of this groundwater.
Preference for Treatment as a Principal Element
In keeping with the statutory preference for treatment as a principal element of the
remedy, the remedy provides for the treatment of impacted soil, and contaminated
groundwater at the Site. By treating the impacted soil and the contaminated groundwa-
ter at and near the source areas, all exposure pathways will be eliminated.
DOCUMENTATION OF SIGNIFICANT CHANGES
The present worth O&M costs were revised using a 5% discount rate versus the 3%
rate which was used in the Proposed Plan. Therefore, the total present worth costs for
all the soil remedial alternatives (except SRA 1- Institutional controls) and groundwater
remedial alternatives are revised.
4,4
-------
APPENDIX I
FIGURES
-------
v^O-'isn — , •. . ' -"..js"-! >-^
£^3^'y/ •<*•'! ";
"^Ol:""/ /c>o '•" ifT"s
SCURCL- USCS-EAS7CRN ST. TViCU»S. VRCN ISLANDS. 1SS« (PMOTORCV1SLD - 1982)
GERAGHTY
& MILLER, INC.
Environmental Services
SITE LOCATION
TUTU WELLS SfTE
ST. THOMAS. U.S. VIRGIN ISLANDS
-------
£-*
J^\ I
ANTIUfS AUTO
iiurn
TRACT 0000
ESSO TU1U
SERVICE SUnnw
ROORICUEZ ESSO
SERVICE STATXX
ARCHlfS
AU;C SCOT
XEIITUCXT FRIED CHICKEN
HOOCE RESIDENCE
LA PUACE>
TORT UTLNES
SHOPPING
StWACE TREATUEKT.
CEN1ER
UATmiAS RESIDENCE
HARPER RESIDENCE
GERACHTY
cV MILLER. INC
PROPERTY LOCATIONS
TUTU W£ILS SITE
5: TWCUAS u 5 viftCiN ISLANDS
-------
-£3L*.
^m^f^^-
'^i^m: \,.ft/
TUTU WELLS SITE
ST. THOMAS, U.S. VIRGIN ISLANDS
-------
V-'V£
^^Cr^- ^^jXg&r*-**;' l'*--^3f> ' *^>~. \rO- ^V £. ^
i^^^^^^*"--7^^ f> >^ ^
fe^^j«3l^^^^ ^^ >#OA
^Ib^^uOi^V^A-c-f-^fe °U'CC^\--^
. -^T~^—•-* --xX ^\V .• O • /"v VAV~ J-; '•
LEGEND ~ ts=^?Xj^_V. ','r, - ^^Sv ,' '. ^ --'r'; '
^A^fe
\\c5 >#&**<•
BTEX > 10 ppt)
Chlorinated VOCs
> 100 ppb
Chlorinated VOCs
> 10 ppb
O
fO'" yri.NE:
SF-C="'NC CCNl
SJx^Ct T^iAlM
. CtNTI^
Sourw: Gcnghty & Miller. Inc. Ph»* II Rl. 199^
^c
TUTU WELLS SITE
ST. THOMAS, U.S. VIRGIN ISLANDS
C3M
Figure If.
-------
COMIWCD CATTUU ZONE 1TTTWATSO FOI TEXACO
tXt»ACnON*EUJTE*.| AWOTT*'-: r.'.MflNCAT
J-i a cru AMD 10 cfM. «£S«cnve.T
" (OLE* * KALIWIX1. INC IWJI
COMIIKED CATTVU :o.-is tfr.Mf.Tto ran is so
••'. MW.». I*. I A.1D CHT. J
/N
•' /
\ ./' J;/;
>// 8 i j '
/}' -"
r-f CKA* H r
•u- .J.-v--- •
' *.
TUTU WELLS SfTE
ST. THOMAS, U.S. VIRGIN ISLANDS
Figure
**CONCEPTUAL
WELLS LOCATIO.
(EXACT WELLS
LOCATIONS WIL
BE DECIDED
DURING REMEDI
DESIGN)
-------
APPENDIXII
TABLES
-------
Tabl*
Pago 1 ol •»
Summary ol Analytaa D«t«ctad in Soil «bov« Soil Scraamng L«v*la at tha Tutu Walla Sit*. St. Thornat. U.S. Virgin Island}.
Proparry P«f«matar
ChUxinatad VOC Con»iitu«na
Curriculum Cantar I.l.l-Trichforoathan*
E«iO Tutu Sarviea Station Tatracnloroathana
1.1,1 -Trichloroalhana
Trienloroatrxn*
l.l-Oichloroatnjrta
1.2.0i«N.».,h.n..W«,
O'H«nry Dry Oaanara • Tatrschlo>e«tr>ana
Trichloro«rn«rv»
BTEX Co««mu«nt»
Curriculum Cantaf B*n2*n«
Tolu*n«
Ethylbarvzar*
Xy
-------
Pago I 0{ 1
Table J— Summary ol AnaMee Detected in Soil above Soil Screening Laval) at the Tutu Walls Site. Si. Thomas. U.S. Virgin Islands.
Property Parameter Depth SSLi Sample
lit bit) tug/Vgl Mama
Taxaco Tutu Service Station Benzene 0.0-8.7 67 TT-IO
TT-1DFR
Ethylbanitne 0.0-8.7 67 OW/S8-1
TT-10
TT-IO FR
8.7-15.0 13 OW/SS-1
Eiao Tutu Sarvica Station Banzane 0.0 - 4.0 74 SS-3
TP-3
TP-5
TP-8
4.0-15.0 IS B-102
SS-7
SS-8
Toluene 0.0 - 4.0 74 SS-3
SS-4
ss-s
SW-3
TP-3
TP-6
4.0-15.0 15 B-101
SS-1
SS-7
SS-8
Eihytbenjen* 0.0 - 4.0 74 SS-3
SS-4
SS-S
SW-3
TP-8
TP-5
TP-6
4.0 • 15.0 IS B-101
8-102
B-103
SS-1
SS-7
SS-8
Sample Interval
in ble)
4.5 - 5.0
4.S • S.O
6.5
4.5 - S.O
4.5 • S.O
9.5
3.0
(Northeast Floor)
(Cantor Floor)
(South)
10.0- 12.0
S.O
7.0
3.0 .
3.0
3.0
0.0 - 2.0
(Northeast Floor)
(East Floor)
8.0- 10.0
10.0- 12.0
9.0
5.0
7.0
3.0
3.0
3.0
0.0 - 2.0
(South Weil)
(Cantar Floor)
(East Roer)
10.0- 12.0
4.0 - 8.0
8.0-10.0
10.0- 12.0
7.0 - 7.5
9.0
5.0
7.0
Concentration
lug/Vgl
(1701
69
(6301
110 / (210)
140
67 / (SO)
880
230 J
1.100
93
625
. 160
270
53.000
4.6OO
e.soo
520
5.200
180,000
28
548
46.00O
33.0OO
51.000
11.000
990
520
170
520
7.000
SS.OOO
304
58
1.117
1.037
26
12.0OO
1.7OO
11.0OO
See last pag* (or footnotes.
GERAGHTY & MILLER. INC.
-------
P.g. 3 ol
• Table / . Summary of Analytei Detected in Soil ebove Soil Screening Leveli at th« fvtu Well* Sim. St. Thorn**. U.S. Virgin I
Property Parameter 0«oth SSL* S«mol«
(ft bill
-------
le _ KJ
Teble _ J Summary of
Pege A of 4
Detected in Soil above Soil Screening Loved et the Tutu Welle Site. St. Thomas. U.S. Virgin Islands.
Property Perameter Depth SSLi Sample
(ft bit) (ug/kgl Name
Wettern AUTO Xylenee • 0.0-4.0 74 SS-1
(continued) SS-2
T2-AS
T2-ASRE
T2-SN
4.0-15.0 IS SS-4
SS-S
SS-6
SS-8
T1-1
T1-2
TMS
T2-2S
T2-3S
Semple Interval
(ft bill
2.0
3.0
0.0 - 0.5
0.0-0.5
1 .0 - 1 .5
S.O • 6.0
5.0 • 8.0
S.O • 6.0
S.O
4.0
4.0
6.7
6.7
6.7
Concentration
lug/Vgl
34.000
501
5.800
6.100
120
128
125
2.700
S3
85
210
430
51 J
7.000
SSLi bifid on USEPA-subcontractor (COM Federal Program* Corp. 199Sb) report on vedoee lone modeling. Criteria ara site-
specific, except for deta from soil samplee collected from Western Auto and Rameay Motors, which ara screened sgajnit
criteria applicable to the Esse Tutu Service Station.
Data reported in parentheeee at Weetern Auto ere from soil samples collected by ENSR Consulting fc Engineering , Inc.
Data reported in perentheesi et the Texaco Tutu Service Station are from soil sample* collected by Bleslend. Boucfc *. Lee. Inc.
* Reported by the U.S.-Environmental Protection Agency as tetrechloroethana; this is believed to be a
typographical error.
* * Result includee only methylxvlene: o- and p-xy ene data not available.
'" 1.2-Oiehloroethene (1,2-OCE) results reported a* total 1.2-DCE and SSL applies to tha trana-1.2-OCE isomer.
SSLs Soil Screening Lewis. SSU provided bythe USEPA (COM Federal Programs Corporation 1995b): see note above.
BTEX Benzene, toluene, ethylberuene, and xvtsnee.
FR Field replicate.
VOC Volatile organic compound.
J Result detected below reporting limit and/or an asbrrutad concentration.
D Anaiyta identified at • secondary dilution.
E Exceeds instrument calibration rang*.
ug/Vg Micrograms per kilogram, equivalent to pens per billion (ppb).
ft bis Feet below land surface.
USEPA U.S. Environmental Protection Agency.
ATAXSCHT j ju.j
GER.ACHTY & NOLLER. INC.
-------
Pago \ of 9
Table
Summary o' Analysts Delected m G'oundwater Above Remedial Action Laval! at tha Tutu Walls Sita.
Si. Thomas. U.S. Virgin Islands.
SAL Wall
Parameter (uj/U Designation
Volatile Organic Comoounds
Viny( chloride 2 MW-3
MW-15
MW-16
TT-3D
TT-S
1.2-DichJoroeihenef total) • 100 CHT-7D
DW-1
La Place • •
MW-t
• MW-1D
MW-3 .
MW-4
MW-6D
MW-7
MW-8
MW-10
MW-1 00
MW-15
MW-16
Sieela"
Tillen
TT-2
TT-2FR
TT-3D
TT-5
1,2-Dichloroetnana £ TT-1
Trieh/oroethene 5 MW-1
MW-1D
MW-3
MVV-4
MW-60
MW-7
MW-8
. . MW-10
MW- 1 00
MW- 1 20
MW-15
MW-16
MW-1 7
MW-210
OHMW-4
Smith
Titian
TT-2
TT-2 FR
TT-30
Concentration
(uo/LI
5/94
.-
-
.-
-
_
-
95
..
.-
-
_
-
_
76 J
110 J
~
-
100
360 D
_
-
-
-
„
..
-
..
..
-
..
18 J
14 J
9 J
-
..
_
_
16
19 J
45
-
-
—
6/94
48
2600
1300
9 J
42
91
92 J
.
9SOO
SOO
4dO 0
- 76 J
100
180
88 J
-
1500 D
2100
- -
-
330
330
2 SO
180
290
78
71
17 J
6 J
11
27 .
10 J
-
--
23
72 J
9 J
14 J
..
-
-
20 J
20J
JS J
7/94
-
-
•-
—
-
.-
-
..
-.
-
_
.
-
-
.-
_
-
-
--
-
-
-
•-
••
_
...
-
-
«
--
-
-
--
«
-
-
-
-
-
-
--
-
**
Saa laat paga lor lootnotai.
I ).03>\OArAtwCV.XlS
GER-^GHTY & MILLER. INC.
-------
Page I ol 9
. Table
Summary of Analyses Delected in Grounflwater Above Remedial Action Levels at the Tutu Walls Sue.
St. Thomas. U.S. Virgin Islands.
HAL Well
Parameter (ug.l) Designation
Volatile Organic Compounds (continued)
Benzene « CHT-3
KFC-1
MW-S
MW-7
SW-2
SW-3
SW-7
SW-7 FR
TT-1
TT-1D
TT-4
Tetrachloroethene 5 CHT-6D
CHT-7D
Dalegarde
DW-1
DW-2
MW-1
MW- 1 D
MW-3
MW-4
MW-4D
MW-50
MW-6R
MW-7
MW-8
MW-10
MW-1 00
MW-12D
MW-1 30
MW-1S
MW-1 6
MW-17
MW-200
MW-21D
MW-25
• . OHMW-1
OHMW-2
OHMW-3
OHMW-4
Ramsey
Smith
SW-4
Concentration
(ug/L)
5/94
_.
_
..
-
-
- •
_
.-
..
..
-
„
-
IS J
•
18
-
-
..
-
-
..
..
_
-
34 J
48 J
33 J
~
- '
-
..
-
-
-
10
26
6 J
140
11
110 J
"
6-9.*
17CO
110 J
460 OJ
21
550 J
10000 J
99 J
110J
21000 D
•700 0
21 COO
12
36
•-
42 J
.-
330 D
360
S3
20 J
17 J
31
10
130
38 J
..
-
..
28 J
120
71 J
37
22 J
45 J
11
..
«
..
..
-
-
IS J
7/94
..
-
-
«
-
-
.
..
•-
„
-
.-
.-
.-
.-
~
^~
.-
..
-
-
-
»
-
-
-
-
-
..
-
-
-.
..
—
See last page for footnotes.
1 3 03J\O»TAiMCk.XLS
GERAGHTY & MILLER. INC.
-------
Page 3 ol 9
JL
Summary ol Analyses Detected in Groundwater Above Remedial Action Levels at :-i» Tuiu Wells Site.
St. Thomas. U.S. Virgin Islands.
RAL
Parameter (ug/Lt
Volatile Organic Comoounds (contmuad)
Tatrachloroatnana (continued) S
Toluene 1 000
Ethylbaniana 700
Xylanaa (total) 1CCOO
(noroanic Comoounds/Analvtas
Aluminum SO to 2GO
• .
Well
Designation
Tillen
rr-2
rr-3
' TT-30
SW-3
TT-1
TT-4
CHT-3
MW-5
SW-3
TT-1
TT-4
SW-3
TT-1
Four Winds II FR"
Harvev"
CHT-70
Oalagarcte
Gasian* •
MW-1
MW-6R
MW-7
MW-8
MW-9S
MW-10
MW-1 00
MW-1 10
MW-120
MW-TS
MW-1 7
MW-24
MW-25
OHMVV- 1
OHMW-2
OHMW-3
OHMW-4
Smith
SW-5
SW-6
Concantiatien
(uoll
5/94
180
-.
-
-
..
-
-
„
_
-
..
--
„
-
-
-
1890 B
154 B
-.
. ..
..
-
2050
956
160 B
147 B
93.9
_
_
_
_
245000
8970
60000
35600O
60.9 B
1210O
14SOO
6/94
90
91
23
3200 J
\ 6000 D
17000
18000
760 OJ
4100 J
"3700 0
3300 J
22000 J
180000
-
118 3
-
•-
186COJ
464GO
10300
28700
-
-
-
--
~
3730 J
33000 J
4160
15800
-
-
-
-
-
..
—
7/94
-
-
-
..
-
-
..
..
-
_
-
63.1 B
1113
-
--
-
••
-
-
-
»
•-
--
-
-
--
-
••
«
••
See last page tot footnotes.
O 0]IV>ATA\MCl.Xl.S
GER.AGHTY & MILLER. INC.
-------
Page •» ol 9
Table 2> Summary of Analyses Detected in G'oundwater Abova Ramadial Action levels at (he Tutu Walls Sue.
Si. Thomas. U.S. Virgin Islands.
SAL
Parameter (us/ll
Inorganic Compounds/Analyses (continued)
Aluminum (continued) 50 to 2CO
Antimony £
Arsanic £O
Barium IOCO
Beryllium 4
Chromium 1 00
Wall
Dasignttion
TT-1
TT-1D
TT-2
TT-5-
DW-1
DW-2
Four Winds II • •
KFC-1
MW-1
MW-2
MW-3
MW-4
MW-5
MW-60
MW-7
MW-1 30
MW-1 8
MW-210
MW-220
OH MW-1
OHMW-3
SW-2
SW-3
SW-7
SW-7FR
TT-1
TT-3D
VIHA 1 ' •
OHMW-2
MW-1 3D
OHMW-4
MW-13D
DW-2
MW-1
MW-2
MW-6R
MW-7
MW-8
MW-1 3D
MW-1 7
OHMW-1
OHMW-3
OHMW-4
Concentration
lug/L)
5/94
mm
..
..
..
-
1490
„
-
_
'
-
..
-
-
-
-
-
-
-•
1S.1 B
50.7 B
-
-
-.
-
..
-
80.8
„„
4320
--
623
-
-
-
-
~
..
-
2200
4610
397
6/94
6130 J
153 B
1090 J
787 J
3CO
•-
„
18.6 SJ
17.63
15 3
17 3
" 20.1 B
20.1 8
25.3 3
21.3 B
424 B
20.6 3
19.5 B
22.3 BJ
..
-
15.4 BJ
16.4 3J
19.2 3J
17.6 BJ
19.7 3
19 B
-
4400 3
"
40.8 B
_
453
619
203
1050
210
4300
238
-
-
—
7/94
„
--
-
-•
22 B
-
-
-.
-
-
-
..
-
-
-
..
-
-
•-
-
-
20.6 B
--.
„
-
••
..
-
-
-
-
-
-
--
-
-
"*
Saa la§t paga for loolnotaa.
E:\AMOJtCT\TUT uvmoai}.037
-------
Page S of 9
. Tabla £. Summary ol Analyses Delected in Giour.dwater Above Remedial Action Levels at the Tutu Wells Sue.
St. Thomas. U.S. Virgin Islands.
RAL Wall
Parameter (ug/V) Designation
Inofganie Compound5*AnaMes (continued)
Copper TT MW-130
OHMW-4
Iron 300 Dalegarda
DW-1
Gastan"
Harvay"
DW-2
KFC-1
MW-1
MW-1D
MW-2
MW-3
MW-4
MW-4D
MW-5
MW-6R
MW-7
MW-8
MW-9S
MW-10
MW- 1 00
MW- 1 1 0
MW-12D
MW-13
MW-130
MW-15
MW-1 7
MW-18
MW- 1 9
MW-20
MW-200
MW-2 10
MW-24
MW-25
OHMW-1
. . OHMW-2
OHMW-3
OHMW-4
SW-2
SW-3
SW-4 '
SW-S
SW-6
SW-7
Tillett
TT-1
TT-1D
TT-2
TT-S
Concantration
(uo/LI
5/94
„
1370
4120 J
..
300
-
_
..
..
..
-
-
..
'--
-
_
-
3760
1410
607
323
334
.-
_
-
-
-
-
-
-
..
-
..
338000
15700
154000
572000
-
.-
-
1860O
20300 J
..
530
-
-
-
.
6.94
1730 J
••
_
11 SO
-
--
3100
80COO J
2S600
10SOO
19900
- 3830
7590
144O
5730
' 56900
44800
49700
'
..
-
-
3670
373COO
5360
43500
63500 J
3420 J
23900
37800
194OO
6890
30EOO
-
..
-
-
14100 J
108000 J
S14O
-
-
14800 J
-
7810
SIS
2320
1130
7/94
„
-
-
2500
..
-
-
-
-
..
-
..
--
-
..
.
-
-.
-
-
-
-
--
-
-
-
-
•-
-
.-
-
•'
••
-
~
-
••
-
Saa Uit paga tor looinotat.
GERAGHTY & MILLER. INC.
-------
Page 6 ol 9
t Tablo 2. Summary of Analyses Detected in Graundwator Above Remedial Action Levels at the Tutu Wells Site.
St. Thomas. U.S. Virgin Islands.
RAL Well
Parameter lug.U Designation
Inoraeni'e Comoaunds/dnalvi«> (continued)
Lead T7 Gassatt
MW-1
MW-9S
MW-1 8
MW-20
MW-20Q
OHMW-1
OHMW-2
OHMW-3
OHMW-4
SW-3
SW-7
SW-7FR
Manganese £0 CHT-7D
Delegarde
Four Winds II • •
Four Winds II FR"
Harvey • •
OW-2
KFC-1
MW-1
MW-1D
MW-2
MW-3
MW-4
MW-40
MW-S
MW-6R
MW-7
MW-8
MW-9S
MWOO
MW-1 00
MW- 1 20
MW-1 3
MW-130
MW-1S
MW-1 6
MW-1 7
MW-1S
MW-1 9
MW-20
MW-2OD
MW-2 ID
MW-24
MW-25
Concentration
luQ/'L)
5/94
167
-
53.7
..
-
-
48.3
201
17.3
71.8
..
..
-
„
163 B
..
-
267
620
--
-
• •
--
•-
-
-
-
-
-
-
2560
597
216
1 14
..
..
-
-
-
.-
-
-
-
-
..
6/9«
27.1 J
•-
27.4
16
20
--
.-
143
70.8
- 93.8 J
282
-
.
-
-
-
1030 J
570
338
356
2540
1290
55. 1
1080
736
453
2350
-
110
204CO
149
532
1550
3740 J
72.6 J
997
1140
402
215
982
7/94
-
--
--
.-
-
-
--
„
125
119
--
..
-
-
-•
--
«
-
-
.-
-
-
--
--
-
--
-
-
-
--
-•
-
-
--
••
**
Sao last page lor footnotes.
GERAGHTY
-------
Psgo 7 ol 9
• Tabla {„. Summary 0< Analytas Datactad in G'our.flwttor Above Remedial Action Levals at the Tutu Walls Site.
St. Thomas. U.S. Virgin Islands.
RAL
Paramatar
-------
3 ol 9
• Table 2. Summary ol Analyies Oatactad in Groundwatar Above Remedial Action levels at the Tutu Walls Site.
St. Thomas. U.S. Virgin Islands.
RAL Wall
Parameter (ug/L) Designation
Inorganic Compeunds/Analvres (continued)
Total Dissolved Solids (continued) 500.000 Four Winds 1* *
Gasaatl"
Narthman Race Track . .
Harvey"
KFC-1
La Place ' '
Matthias * *
MW-1
MW- 1 0
MW-2
MW-3
MW-4
MW-4D
MW-S
MW-60
MW-6R
MW-7
MW-8
MW-9S
MW-10
MW-1 20
MW- 1 3
MW-1 3D
MW-1 5
MW-1 7
MW-1 8
MW-1 9
MW-20
MW-200
MW-21D
MW-22D
MW-2 4
MW-2S
OHMW- 1
OHMW-2
OHMW-3
• • . OHMW-4
Ramsay
Smith
SW-S
Nitrate (at N) (mg/L) 10.0OO Gessetf
Hanhman
Race Track
MW-1
MW-2
^ MW-13
^ , MW-1 7
• . . MW-24
Ramsay
Concentration
lua.'Ll
5/94
„
700
1100
-
-
1360
..
..
-
-
-
«
-
.
-
.-
830
790
640
-
-
..
-
-
-
-
-
-
-
-
.-
354
1 1 10
1290
1040
870
33S
378
11.3
13.6
..
-
-
-
10
6/94
..
-
-
-
1070
--
9:0
880
910
900
920
1180
810
840
910
760
920
..
..
_
900
1S20
990
870
SCO
104Q
ECO
780
2260
1890
940
9EO
..
..
•
..
-
_
-
_
-
12.4
15.9
10.6
22.7 .
13.3
"
7/94
1240
.-
7190
-
-
-
-
-
..
..
-
-
-
..
..
-
-
-
-
..
_
-
-
_
-
..
,.
-
-
~
..
-
_
••
„
..
-
--
-
-•
••
Sa« la*t page lor footnot««.
GERAGHTY
-------
Table
9 ol 9
Summary °( Ana'Vtes Detected in Groun<]w6t«f Above Remedial Action Levels at the Tutu Welts Site.
St. Thonnas, U.S. Virgin Islands.
• Analytical results reooned for total isomers (cis- and trans-) lor 1.2-dichloroethene (1.2-OCE): RAL is
for trans- isomer.
• • Sample results were not validated.
Not available.
mg/L Milligrams per liter.
ug/L Micrograms per liter.
B The reponed value was obtained from a reading that was less than the Contract Required Detection Limit (CRDL),
but greater than or equal to the Instrument Detection Limit (IDLI.
J Estimated value.
0 Compound concentration was determined at a secondary dilution factor.
RAL Remedial Action Level.
TT Treatment technique. (Action Levels: Copper 1.300 ug/L. lead IS ug/U. Values in parentheses are
determined by the USEPA.
USEPA U.S. Environmental Protection Agency.
Note: RAL> derived from Federal Drinking Water Standards.
O:\A*«OjtCT\TUT U
O O.037\OATA\MCL.XLS
GERAGHTY & MILLER. INC.
-------
• SIMM TABLE _./
coi'c »i r.
TUTU WELLS SITE
SUMMARY OF CHEMICALS OF POTENTIAL CONCERN IN SITE MATRICES OY AREA OF CONCERN
SUHFACE SOIL
TIIUII Girdgtit and Art
C«nl«r
VOCs:
None Selected
SW2C*.
None Selecled
E«IicW«&£Caj;
Arocloi 1242
tac/noaJti;
Anllmony
Aisonlc
Monganese
Vanadium
Fir* D»pl7T»««eo G«*
SUIIanMnllll«« Aulo
Peil«/narni*y Molor Co.
VOCs:
None Selecled
SVJ2S&
Banzo(b)lluoienlhene
Benzo(B)pyiene
Peslkidts/PCBs:
None SeUcIed
Inorganics:
Anllmony
Beryllium
Manganese
Vanndkim
Curriculum CenUr
Oulldlno (Pr«**ril)
iS2Ci
None Selected
£W2Ci
2-MeHiytphenol
4-Melhylpheno(
EeilicldtsOECDt:
None Selected
/no/pflfifcs:
Antimony
Arsenic
Oerylltum
Mnngnnsse
Vonadlinn
Curriculum Ccnlar
Uulllllng (Futuro)
J32CK
None Selecled
SYQC&
2-Melhytphenol
4-Melhylphenol
CffsK'ac/jaCCfls.
None Selecled
iocraflo/cs.'
Anllmony
Ai sonic
Ontylllum
Mnngnnese
Vanndhim
O'llenry Dry Cl»«n»f •
•nd Liquor Dim
B2Ci
Teliechloroethene
syocs:
None Selecled
EffilicMesECJ^
None Selecled
Inoiyanics:
Antimony
Aisenlc
Mnngonoso
Vanadium
-------
TAOLE J> (Confd)
TUTU WELLS SITE
SUMMARY OF CHEMICALS OF POTENTIAL CONCERN IN SITE MATRICES OY AREA OF CONCERN
Tlllotl Gard«n« and
Art Contvr
y^od.'
None Sole clod
syosx
Oenzo(a)pyrene
Posto'des/PCGs:
Hoi Analytod
taoraan/ci:
Antimony
Aisenlc
Oeryflium
Manganese
Vanadium
Fir* D«pt/T««aco Gat
SUIIonrAntlllaa Auto
Parla/Ramtay Motor Co.
w*
Nona Selected
SKQCz
Benio(a)pyren*
Ptsticidts/PCBs:
None Soloclod
tactuauici,'
Antimony
Arsenic
Batlum
Derytlium
Manganese
Vanadium
SUBSURFACE SOIL
Curriculum Center
Dulldlng (Fulum)
XQCz
None Selected
SMX&
None Selected
PjHticides/PCBs;
Not Annlytod
(natnflflfci;
Anlimony
Aicenlc
Oerytflum
Manganese
Vanadium
EnoGkt Station
and Splath and Dach
Car Wa»h
uasz
None Selected
SVOd:
None Selected
Peslicidts/PCDs:
Not Analytod
Insuvaoks;
Antimony
Aisenlc
Beiyfflum
Manganese
Vanadium
CnoUNDWATER
O'llonry Dry CUanert 1 , SlU-Wldo
and Liquor Oarn ; |
*>
VOCs: !
None Selected [
I
SHOCK
None Selected
Peslicidos/PCDs: |;
Not Analytod [
toeroau/u; >
Antimony f;
Atsonlc
Manganese • ',
Vanadium '•/
t
(
1:
JfflCi'
Benzene
1.2 Dichloroelhene (Total)
Telrachloroethene
Toluene
Vinyl Chloride
SVOCs:
None Selected
Pesticides/PCDs:
Not Annlytod
Jaswwl^
Antimony
Arsenic
Beryllium
Chromium VI
Manganese
Nickel
Vanadium
-------
SSS COC 1UIU «1 5
CHEMICALS OF POTENTIAL CONCERN FOR SITE SURFACE SOILS
TUTU WELLS SITE
CHEMICALS
VOCs lug/to)
Moihyyl)phlhalala
Bonio(b)l1uwanlhorM
Bonio(a)pytono
Bontojq.h.ljperylons
Fioqiioncy ol
Ooloclion
1/16
1/17
2/19
2/19
2/19
5/19
5/19
5/19
9/20
2/12
1/12
1/12
1/12
\n
3/13
1/13
1/13
3/13
2/13
3/13
1/13
1/13
2/13
2/13
3/13
Rango ol OolocKwi Coi
-------
ssscoc luiuns
lAULk 4 .
CHEMICALS OF POTENTIAL CONCERN FOR SITE SURFACE SOILS
TUTU WEILS SITE
I' Z ul 3
CHEMICALS
Fioquoncy ol
Dolocllon
Ramjo ol Doloclod Conconlialioiu
Minimum
Mailmum
Location ol
Manlmim
Rango ol Non Oolocl Conccnualions
Miramnm
Manimiim
PESTICIDES/PCBl luiWnl
Endosullan 1
Aiock>M242
INORGANICS
Aluminum
Antimony
Aisonlc
Bailum
Cadmium
Chromium
Cobalt
Coppot
Iron
Load
Manga no s«
Nickel
Sodium
Vanadium
Zinc
Cf arid*, tola!
1/13
1/13
and CYANIPE mio/luil
3/7
1/7
2/7
3/7
1/7
3/7
3/7
3/7
3/7
4/7
3/7
3/7
2/7
3/7
3/7
1/7
...
21100
2.1
33 0 0
...
23 C
163
52
20400
3.1
834
14.7
3190
83 1
520
—
92
1 20000 J
27350
5.9 GJ
13.7
672
0.70
42 2 J
2S55J
1087
38400
06.35 SJ
872
21 7
470 B
119
106
1.1
OL020IS
oTT 153
MWS 16 AVO
B2
0-1 3 A
02
MWS 16 AVO
MWS 16 AVO
MWS- 16 AVO
MWS- 16- AVO
B2
SS5 AVS
MWS-lfi-AVO
MWS 16 AVD
B-I3A
02
B2
02
9U
90 U
21300
4 00 UDNJ
I46UOWJ
442UD
0.48 U
1993UNJ
13 85 UJ
54 .95 UJ
27725 J
11 3 J
699 5 UJ
115UJ
273.25 UDJ
72 65 UNJ
95.75 UJ
0 53 U
1 700 UJ
1 100 UJ
26950
6.35 UONJ
I865UJ
962SU
0.7 U
33 95 UNJ
22.75 UJ
79 65 UNJ
40800
I99SJ
886 U
18 ISO
408 50 UD
96 SO UNJ
316
064U
-------
sss cue-lulu »is
CHEMICALS OF POTENTIAL CONCERN FOR SITE SUHFACE SOILS
TLTTU WELLS SITE
EPA Oau Oualiliors:
U - Analyla was analyiod (or but not liolcclol
J • Estimated value
B • Foi oiganic parameters:
Compound found In Iho associated blank as well as in Iho sample
For Inorganic puamelois:
Reported value w«a obtained horn a reading Dial was loss Ilian ttio Conlcacl DoquiioO Ooloclion Limit, but gioalof than or oqual lo Iho
Inslnimont OtlocUon Limit
N • Pr»sumpl)v» •vldgnc« ol a oompouivl
S • The lopotlod valu* was doloimlnod lo by Iho Mottiod ol Skjivlard Aditlions
W • Post dlQosfcn spike lot Furnace AA analysis Is out ol control limits, while sainplo absorbanco Is loss than 50V. ol spiKo absoibjnco
• • Dupllcal* inalysls nol wilhin oonirol Innrli
-------
fxp pw»rxis
TUTU WELLS SITE
POTENTIAL EXPOSURE PATHWAYS
Matrli
Receptor
Population)))
Enpoeure
Route(a)
Retained for
Quantitative Analyala
Justification
PRESENT - USE SCENARIOS:
Surface Soil
Sit* Residents
(Adult* and Chittun)
(TilleM Gaideni and Art Cental)
Ingest) on
Dermal Contact*
Inhalation ol Particulatas
Inhalation ol VOCs
Site Workers
(Employee! ol tw Fit* Dept,
TeMco oa* station. Antilles
auto part*, and Ramsay motor
company)"
2- (Employe*a of the Curriculum
Canter Buildino)
3- (EmployMi ol Ih* Easo OBJ
tlalion and lha Splash and
Daah car waah)
4- (Employe** ol O'llenry dry
deaneia and Liquor Bain)
Ingeslion
Doimal Conlacl'
Inhalation ol Particulotaa
Inhalation ol VOCs
Innestion
Daimal Contact*
Inhalation ol Particulalaa
Inhalation ol VOC*
Innestion
Oaimal Contact*
Inhalation ol Particulalaa
Inhalation ol VOCa
Ihgeslion
Deimal Contact*
Inhalation ol Poittcifales
Inhalation ol VOCa
Yes Sile residenla era expected to coma into direct contact with
Yaa surface soil in (ha vicinity ol their home and Tillelt Gardens and
No Art Cantor. Tha inhalation ol pamcirfalos Irom aurlaca aoil 11
No assumed lo ba nagtirjibta. us Ihft oroas wttera aamplos wor0
collactad ailhar consist ol hard packed aori or era covaiad by
varjalalion. Tha inhalation ol VOCs it also aasumed to ba
negligible, as no VOCa were selected aa chemicals ol potential
concern The inhalation pottiwoys were therefore not selected
lor further evaluation.
Yea Site woikeis may come into direct contact with surface soil
Yea during lite course of a normal work day (i.e.. outdoor work, lunch
No hour). The inhalation ol particulars Irom surface soil is assumed
.No lo be nsnlirjibla. •» lne •'••*• where samples ware collected
consist ol either hard packed aoil or ere covered lo • large e«lenl
by vegetation. The inhalation ol VOCa ia also asumad lo lie
neglioible. es no VOCa wen> selected ea chemicals ol potential
concern. The inhalation pathways ware therefore not selected
(or further evaluation.
Yes Sile workers may coma into duacl contact with surface soil
Yea during the count* ol • normal work day (i.e.. outdoor work, lunch
No hour). Tha inhalation of paniculates Irom surface soil ia assumed
No lo ba negligible, is the trail where tamplet ware collected
consist ol either hard packed aoil or ere covered to a large extant
by vegetation. Tha inhalation ol VOCa ia also assumed to be
negligible, as no VOCa were selected aa chemicals ol potential
concern. The inhalation pathways were therefore not selected
lor further evaluation.
No Sine* the Esso gaa station end Splash and Dash car wash
No properties are completely paved, no aurlaca soil ia available for
No contact. Thereto™, no surface soil exposure can occur.
No
Yes Site woifcers may come into rtiecl contact with surface soil
Yea during the course ol a normal work day (I.e., outdoor work, lunch
No hour). The inhalation ol particulalea from surface aoil is assumed
Yea to be negligible, as the area whaie samplaa were collected
la covered lo a too}* extent by dense vegetation. Since a VOC was
selected as a chemical ol potential concern lor this area, lha
Inhalation ol VOCa pathway was retained lor further evaluulinn.
-------
TUTU WELLS SITE
POTENTIAL EXPOSURE PATHWAYS
Matrix
Beceplor
Population)*)
Exposure
Routefe)
Retained lot
Quantitative Analysla
Justification
PRESENT • USE SCENARIOS CONfO:
Suifact SoilfConfd)
Construction Workers
(Site-Wide)
Ingaslion
Damtal Contact'
Inhalation ol Particulars
Inhalalion ol VOCs
No
No
No
No
No construction woik is currently in progress in any areas ol
concern at the sila.
Subsurface Sot
Silt Raiidanli
(Adult* and Children) Defmal Contact*
(Tiletl Garden* and Art Center) Inhalalion ol Paniculate*
Inhalalion ol VOCs
No
No
No
No
No consliuclion work (i.e., excavation activity) is currently in
progress in this area ol the ails.
Sit* Wotkere
1- (Employe** ol the Fire D«pl..
Texaco gaa station. Antill**
auto parts, and Ramsay motor
company)
2- (Employees ol In* Curriculum
Center BuiWnrj)
3- (Employees ol the Esso fjas
elation and lha Splash and
Dash car wash)
4- (Employees ol O'Hanry dry
cleaner* and Liquor Bam)
Construction Workers
(Site Wide)
Ingaslion
Dermal Contact*
Inhalation ol Particulatas
Inhalation olVOC*
Inpaslion
Dermal Contact*
Inhalalion ol Perticuloles
Inhalalion ol VOCt
Innefbon
Dermal Contact*
Inhalation ol Particulales
Inhalalion ol VOCt
InQeslion
Dermal Contact*
Inhalation ol Particulatas
Inhalalion ol VOCs
Inrjaition
Dermal Contact*
Inhalation ol Partlculotas
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No construction woik (i.e., excavation activity) is currently in
progress in thi* are* ol the sit*.
No construction work (i.e.. excavation activity) is currently in
progress in this are* ol the site.
No construction work (i a . excavation activity) is currently in
progress in this area ol the site.
No construction work (i.e., excavation activity) is currently in
progress in IN* area ol the silo.
No construction work (i.e.. excavation activity) is currently in
progress in any areas ol concern at (he sila.
-------
tnlvt
EXP PWAVXIS
TADLE £
TUTU WELLS SITE
POTENTIAL EXPOSURE PATHWAYS
Matrix
Receptor
Population!*)
Exposure
Rotile(a)
Retained (or
Quantitative Analysis
Justification
PRESENT • USE SCENARIOS CONTO:
Gioundwalar
Site Residents
(Adults end CNIdren)
Site Woikars
InnesUon Yai
Doimnl Contact (Shower) Yes
Inhalation ol VOCs (Shower) Yes
Ingoslion Yes
Dennol Contact (Shower) No
Inhalation of VOCs (Shower) No
Currently, an order against drinking and bathing in groiindwaler
at the silo has been issued However, since evidence ol
pumping exists at the Ramsay wall, tesidants may be using lite
gioundwaler lot Iheso purposes in addition lo secondary
purposes such as clothes washing, lawn watering, etc.
Currently, an order against drinking and bathing in groundwaler
at the site has been issued. However, since evidence ol
pumping exists at the Ramsay well, sile workers may be using
Hie groundwaler (or diinking. Site workers am not expected to
shower on*site.
Construction Workers
FUTURE • USE SCENARIOS:
Surtoce Soil
Ingastion No
Oennol Contact (Shower) No
Inhalation ol VOCs (Shower) No
Residents Ingastion Yes
(Adults and Children) Dermal Contact' Yes
(Tilen Gardens and Art Center) Inhalation of Paniculates Yes
Inhalation of VOCs No
No construction work (i.e.. excavobon activity) is currently in
progress in any areas ol concern at the sile.
Sile residents are expected lo come into direct contact with
surface eoM In the vicinity ol their home and Tilled Gardens and
Art Center. The inhalation ol perDculales exposure route may be
ol concern due lo the potential lor future construction work
(i.e., excavation activity) In this area. The inhalation ol VOCs is
assumed to be na^igible, as no VOCs were selected as chemicals
ol potential concern. The inhalation o( VOCs pathway was
therefore not selected (or further evaluation.
Sile Workers
(Employees ol lite Fire Depl.,
Texaco gas station, Antilles
auto parts, and Ramsay motor
company)"
Innasbon
Dermal Contact*
Inhalation ol Participates
Inhalation ol VOCs
Yes Sile walkers may come into direct contact with surleca soil
Yes durir^) the course ol a normal workday (i e., outdoor work, lunch
Yes hour). Tha inhalation ol peiliculales exposure route may be ol
No concern duo lo (ho potential lor future construction work
(i.e., excovetion activity) in this area. The inhalation of VOCs is
assumed lo be negligible, as no VOCs were selected as chemicals
of potential concern. The inhalation ol VOCs pathway was
therefore not selected lor further evaluation.
-------
t«p PWA» ws
TUTU WELLS SITE
POTENTIAL EXPOSURE PATHWAYS
Matrix
Receptor
Population!*)
Exposure
Roula(a)
Retained (of
QuenllUUve Analyst*
Justification
FUTURE • USE SCENARIOS CONT'D:
Surface Soil (Confd)
Subiurfac* Soil
(Employees ol Ilia Cuinciiltim
Center Ouifding)
3- (Employees ol the Esso gat
station and Ihe Splash and
Dash car wash)
4- (Employees olO'llemy dry
doanai$ and Liquor Dam)
Ingosbon
OermeJ Contact"
Inhalation ol Porticulales
Inhalolion ol VOCi
.Inge soon
Dermal Contact*
Inhalation ol Pofticiilatas
Inhalaliun ol VOC>
Ingostion
Darmal Contact*
Inliolotion ol Paniculate*
Inhalation ol VOCs
Construction Workers Ingestion
(Tillell Gardens and Art Canlar) Oeitnal Contact*
Inhalation ol Perticulotes
Inhalation ol VOC>
Rasidanli
(Adults and CNIdren)
(Tilletl Gardens and Art Canter)
Ingest/on
Oarmal Contact*
Inhalation of ParBculales
Inhalation ol VOCs
Yes
Yai
No
No
No
No
No
Yaj
Yes
Yai
Yes
Yai
Ya*
Yas
No
No
Yas
Yea
No
Site woikers may coma into duvet contact with surlaca soil
dining llw course of a normal work day (i o . outdoor woik. lunch
hour). The inhalation ol poiticuloles e»posuie roula may be ol
concern due lo Ihe polenlial lor lulure conslnjclion work
(i e . eircovobon activity) in tins area Die inhalation ol VOCs is
assumed lo be negligible, as no VOCs ware selected as chemicals
ol potential concern. The inhalation ol VOCs palhwoy was
therefore not selected lor further evaluation.
Since the Easo gas sliilkm and Splash and Dash car wash
properties ere completely paved, no surface soil would be
available lor contact. Therefore, no surface soil euppsure can
occur.
Site workers may come into ikiecl contact with surlji « -ml
dkrring the coursa ol a normal work day (i a., outdoor work, lunch
hour). The inhalation ol poitkulales eiuosure route may be ol
conco/n duo lo Iho potanlial lor lulure construction work
(i e.. excavation activity) in this area. Since a VOC was selected as
a chemical ol polenlial concern lor this area, Ihe inhalation ol VOCs
pathway was retained lor further evaluation.
The potential exists lor further commercial or residential
development ol the Tillell Gardens end Art Canter area ol concern.
Construction workers would be expected to routinely contact
surface soil during excavation activities. The inhalation ol
portkuloles exposure route may also be ol concern as a result ol
(his activity. The inhalation ol VOCs is assumed lo be
naglioiMe as no VOCs were selected as chemicals ol potential
concern. The inhalation of VOCa pathway was therefore not
selected lor further evaluation
During potential lulure construction work (i a., excavation
activity), residents may come into direct contact with axposad
subsurface soil. However, they ore assumed lo ingest a
negligible amount ol excavated subsiirloce soil. The inhalation ul
VOCa is also assumed lo be negligible, as no VOCi were saluclad
as chumicals ol potential concern. The inlialalion ol VOCs pathway
was therefore not selected for fiirtlior evaluation
-------
I/IIV4
|xr> w»Ar KIS
IAW.L- J3
TUTU WELLS SITE
POTENTIAL EXPOSURE PATHWAYS
Receptor
PopulaUon(a)
Exposure
Roul«(a)
Retained (or
Quantitative Analysla
Juslilicalion
FUTURE • USE SCENARIOS CONT'O:
Subsurface Soit(Confd)
Site Workers Ingestion
I- (Employe** ol the Fire Depl., Oermol Contact*
Texaco gas station, Antilles Inhalation ol Particulates
aulo parts, and Ramsay motor Inhalation ol VOCs
company)
2- (Employ*** ol the Curriculum Ingestion
Canter Building) Oacmal Contact'
Inhalation ol Partictilates
Inhalation ol VOCa
3- (Employ**! ol th* Esso got
ttation and the Splash and
Dash car wash)
4- (Employ*** ol O'Henry dry
cleaner* and Liquor Bam)
Construction Workers
(Triton Gardens and Art Cental)
Dermal Contact*
Inhalab'on ol Perticulatas
Inhalation ol VOC*
Ingestion
Dermal ConUtcl*
Inhalation ol Particulates
Inhalation olVOCt
Ingestion
Dermal Contact*
Inhalabon ol Peioculoles
Inhalation ol VOC»
No During potential future construction work (i.e.. excavation
Yes • activity), site workers may com* into direct contact with eiposad
Yes . stibsurlaca soil. However. Iliey are assumed lo ingest a
No negligible amount ol excavated subsurface soil. The inhalation ol
VOCs is also assumed to l>« negligible, as no VOCs were selected
as chemicals ol potential concern The inhalation bl VOCs pathway
was therefore not selected lor further evaluation
No During potential lulure construction work (i a., *>cavation
Yes activity), sit* workers may com* into direct contact with exposed
Yes subsmfoca soil. However, they are assumed lo ingest e
No negligible amount ol excavated subsurface soil'. The inhalation ol
VOCs is also assumed to be negligible, as no VOCs went selected
as chemicals ol potential concern. Th* inhalation ol VOCs pathway
was therefore not selected lor further evaluation.
No During potential lulure construction work (i.*.. excavation
Y*t activity), sit* workers may com* into direct contact with axposad
Yes subsurteo* toil. However, they are assumed lo ingest a
No noglioibla amount ol excavated subsurface soil. The inhalation ol
•VOCs i* also assumed to be negligible, as no VOCs war* selected
as chemicals ol potential concern. Th* inhalation ol VOCs pathway
wos therefore not selected lor Further evaluation
No During potential lulure construction work (i *., excavation
Ye* activity), sit* workers may com* into drect contact with axposvd
Ye* subsurface soil. However, they are assumed lo ingest a
No negligible amount ol excavated subsurface soil. The inhalation ol
VOC* is also assumed lo be negligible, as no VOCs were Mlecled
as chemicals ol potential concern. Tha inhalation ol VOCs pathway
was therefore not selected lor further evaluation.
Yes The potential exists lor further commercial or residential
Yei • development ol the Tillell Gardens and Art Center areeol concern.
Yes Construction workers would be *xpacled lo routinely contact
No subsurface soil during excavation activities. The inhalation ol
paniculate* exposure rout* may also be ol conc«m as a result of
this activity. Th* inhalalion ol VOCa is assumed to ba
negligible, as no VOCs ware selected as chemicals ol potential
concern. The inhalation ol VOCs pathway was therefore not
selected lor hirther evaluation.
-------
*/!>«<
[IPPWATX13
TAULE $
TUTU WELLS SITE
POTENTIAL EXPOSURE PATHWAYS
Matrix
Receptor
Population)*)
Exposure
Roule(a)
Retained lor
Quantitative Analysis
Justification
FUTURE • USE SCENARIOS CONT'D:
G/ounuWa/flr
Sit* Residents
(AdulU and Children)
Site Workars
(AB)
Conslniclion Workers
inrjastion Yes
Dermal Contact (Showar) Yes
Inhalation ol VOCs(Soowei) Yes
Ingestion Yai
•Oeimal Contact (Shower) No
Inhalabon ol VOCs (Showar) No
Ingeslion Y«»
Damial Contact (Showar). No
Inhalabon ol VOCs (Showar) No
Curienlly. on ordai against drinking und bathing in groundwolnr
at lha silo has boon issued Howavar. sine* evidence ol pomp
ing exists at lha Ramsay wall, residents may continue to use
Die groiindwaler in lha luhira lor Uiasa purposes in addition to
secondary purposes such as clothes washing, lawn wnlennij.
Currently, an ordar againsl drinking and bathing in groundwatar at
lha sile has been issued. However, since evidence ol pumping
exists ol the Ramsay wall, site workers may continue to use lha
groundwotar in the luture lor blinking Sile walkers are not
expected to .shower on-site.
Currently, an order against drinking and bathing in gnuintlwuler
at the site has been issued. However, since evidence ol pump-
ing exists al the Ramsay wel. construction workars may continue
to use the groundwaler in lha lulure lor drinking Construction
workars are not expected to shower on sile
•The dermal contact pathway can orty ba quantitatively evaluated lor PCBs and cadmium as only these chemicals have established dermal absorption (actors (PCBs - 6% and cadmium - 17.).
AN other chemical! will ba qualitatively discussed.
"II should be noted thai present and potential lulura site workers al the Fire Department end Texaco gas station were not considered receptors lor surface soil since no surluce soil samples
were collected al the Fira Department, and lha Texaco gat station ia completely paved (all toil lamplei would ba subsurface). However, all individual areaa in the araa of
concern ait listed lo ba consilient with those lifted loi lha subsurface soil area ol concern.
-------
!»*«!
IOINOI ) >•
tAUI.b fy
1UTU WEILS SITE
ClinONlC 1OXICI1Y VALUES FOR POTENTIAL NONCARCINOGENIC HEALTH EFFECTS
DOSE • RESPONSE DELATIONS)IIP (I)
CHEMICALS
Volilttt Orgtnlct
Action*
DaniMM
Onxnodlclilaioniolhan*
Dtamolotm
fbomomolhiM
2-Oulinon*
Cuban DUulliilo
ChlOfObwii«w
Chloioloim
ChloiamalhiiM
DiUomachkNocnalhana
l.l-OlcMar*ni«fM
T«(r*cnkxo*lnon*
Toluene
1.1.1'TikhloiMilurtt
1 l.2-Ttfchlaio*lh«n«
IrtcMonMltMn*
W>ylChlofkJ»
XylMMl (ToUl)
StmlroltlUt Orgtnltt
AcMtphUwn*
Ant\»c«n«
BcntofcAdd
B*nio|i)inlh(KWM
0*nto(b)luoranitHin*
0*n>o(o.l>.l)P«Vlon»
D«nio(li)flu«*nlhan*
^2
-------
I»»V4
(OIMOS 1 ib
1UIUWEIISSITE
CHMONIC tOXICIIV VALUES FOR POIENIIAl NONCARCINOGENIC HEALTH EFFEC1S
COSE • RESPONSE RELATIONSHIP (I)
CHEMICALS
Siml*vlttU» Organic* (Conl'd)
CtUYsen*
Oi-n-bulylphlhalato
Di n-oclylphtialil*
Oibanioajiu
1.2 DtcWoiobonzon*
l.4-DMiloiob«nion*
Owlhylphlnalat*
2.4-Dlm«iylph*nol
OunoUiylphlhilal*
Fhjoianihon*
FliinrwM
lndono(l.2.3-al)pyiona
2-Me liylnanhtltakina
2 Matiylptonal
4 M»tlylph«nol
2-Nik optional
NaphthalMia
Pnananlnrona
Phenol
Ph(iallcAnhy(lrkto|TIC)
Pyran*
1 ,2.4-Trkhkxobanian*
Chkifdan*
EndoMiHan
PCBs(Arodors)
Inarpanlca
AJumkium
Antimony
A/Mnle
Barium
Bcryltum
Cadnium(tood)
Cadmium (WIIM )
Chromtum III
Chromium VI
Coball
Cop pot'
CyanMa
L«ad(andconnrniirMh IniwQl
NONCARCINOGENS:
REFERENCE DOSES (RIO)
Oral RID
(inry*0-ffciy)
1 OC Ol
20E02(2)
-
9 Ot-02
-
a on 01
20E-02
IOI_'.OI(2|
4 OC 02
4 OE 02
5»t 02(<)
SOE03(2)
•
40E-02(4)
'6 OE-OI
20E.OO
30E-02
1 OC 02
6 OE-OS
6E-03(2)
•
40E-04
30E-O4
7.0E-02
SOE-03
IOE03
SOE04
t.OEtOO
SOE-03
•
201102
Uncoiuioty Inhalation RID
Factor (mn/fcg-rlay)
1000
1000
•
1000 57E-02|3)
23E-OI
1000
3000
100
3000
30OO
•
•
looo
1000
•
1000
•
100
1000 3 4E-02 (2)
3000
1000 . S7E-02(2)
1000
100
•
-
1000
3
3 I4E-04(3)
100
10
10
100
500
-
-
100
•
Uncuiiainiy
Facint
•
IUOO
too
•
•
300
•
1000
.
•
•
1000
•
•
•
•
:
-------
lAIJlt O
TUTU WEI IS SHE
CMMONIC TOXICIIY VALUES FOR POTENIIAl NONCAflCINQGCNIC IICAI III EFFECTS
tx>se • RESPONSE RELATIONS) iii>(0
CHEMICALS
MorganJca
ManQanesa (waloi)
Moicury
Nickel (sol. sail)
Selenium
Silver
Thallium (chkxklo)
Vanadium
line (and compounds)
NONCARCINOGENS:
Oral Mil)
(n»ytc/i (Uv)
50C-03
30E-04(2)
2 OU-Oi
S OC03
son 03
OOE-05
7 OE 03 (2)
3 OF: -01
REFERENCE
llncailamry
Factor
1
lOOO
3 no
3
3
3000
too
3
DOSES (RIO)
Inliiiliilinn HID
("•a*o-<«»ir)
1 .4F.-05
B6E OS(2)
•
'
DlKUirlumly
f acini
1000
30
•
-
•
MOTES:
- Calcium, lion. maonosmm. nobssimn. and sodium aio oonsliloiuil ussomial railrionts and wtl not bo quanlikilivuly ovalualud
in tia risk ass*ssnwnl
Mha cunanl (kinkingwalof slandaitl Ira coppei Is 1.3 mut Tho DWCO (1007) concluded lhal lo»iciry dJla aio Inaduqiialu kir calculalion
ol a laloiono* dos* loc Dili chemical
(11 Al tonlcl^ valuaa ohialnad lorn IRIS (on-lina Jun« ?2 and 30, 1094, Jity I. IW*. AuQusI 4.1904. and Ooconilioc 6. 1994) imlois olliuniriso nolod.
(2) Tankily values obtained ftom IIEAST Annual FV-1994.
(3) Todcliy vaki«s obtalnad kom IIEASI Annual FY-1004: Toiicity vakies aio found in USEPA documanls bill woie calciilalod by
alltmalk* nwlhods nol amcnly praclicad by ti« HID Wwk Gioup.
(4) Toikily valu»J «rai« orlolnaJly obUinod bom Nw Stipoikind I loahli nisk Toclinical Support Cenlor. Soplomhoi 27.1993. Thosa valuos woio
oonfiimed by In* USEPA Risk Assossmanl Spadallsl.
(5) !h» mutosulbn kuldly valuos a<» lopodod. as none aia availablo loi llio andosullan I Isomof
USEPA WEIGHT • OF • EVIDENCE:
A • Human Caicbtooan
Bl • Piobabl* Human Caicinooun linilod human ilala aio availablo
B2 • Piobabto Human Carcinogen. Sulklanl avldonc* ol caicinooonicily In animals and Inadoquala a no ovKlonco in luimans.
C • Possible Human Caidnogen
0 • Nol Classilabl* as lo human ca/cinogoniciiy.
E • Evidanc* ol noocajcuwoonlcily lot humans.
-------
I OI'OS IIS
i ADII; '7
lu.iu writs SUP
lOXICIIY VALUES FOn POICNIIAI. CARCINOOrNIC MEAllll EITCCIS
UOSE - nrsroNsn nriAiioNsiiip 10
CHEMICALS
Volmttli Orginlct
Acotono
Onnten*
OtomodWiloioiniltiang
Otonntoim
Oiofinmothnnc
2-OuMnonB
Cubon DituMdo
Ctilorotenian*
CMotohnn
Chlwoinolhatw
DibfomodilofWTWlImn*
I.MXcMoiovlhww
f.2-DlcMo«Mfhin(
I.l-Dfclilotoolhtiw
ell 1.2 OWitoro»»mn9
1.2-LMchlotooltuHio (lolnl)
Eiliylbontcn*
2-1 Ipntnon*
MglltyMMl OutylElKit
4 Molliyl y.PooUnonn
Molhykina Clilnld*
n-l'io|iylboiuniHi
lolindilotonlimi*
loluotM
l.l.l-lrldilmooltiina
1.1.2-Tildilmooliiin*
libJilnoellioii*
Vinyl Clilwld.
Xy1«no5(Iolal)
Stmlvotilllt Otgtntci
Aoonaphllmn*
AconaphlliylRn*
Anlhfioen*
OoiuotcAcid
Ootno(*)iintiiM:an*
Danio(«)pyieiM
Ognio(b)nuoianH«rM
B«n/o(o.h.l)p
-------
1ADLC
7
ILMUWFllSSlin
toxicnv VALUES ronporrNtiAi. CAMCINOOENIC MEAL in
oost • nr.sroNSE MF.LAIIONSHIP (i|
llHlMIGAin
Simlrolftll* Oigtnlc i (Conl'd)
Cwliiuola
Chrysong
01 n hutylphtli.il.lle
01 n octylphlhfllnl*
Oibsniofuian
1 .2 Oclilorolxiniong
l.4-Olclila>ulxHi/on«
Otofiylplitialalo
2.4 UimolliylplMwiol
Oimnliylnhlial.-ila
riuomnltiono
riuotoim
lnrtoi>D(l.2,3-cd)pyiBn0
2-Molltytniiplilhiilono
2 Mnlhyt|ilwiK>l
4-Molliylplnnul
Naphlhnloiio
2 Nilioplnnol
l'h«nanlluniin
Plionol
Pyinno
1.2.4-lildilototioniano
Ptfllcldtt/PCOt
Chlmdara
EndasuVan (4)
PCBs (Aiocbis)
Inorganic*
Aluminum
ArSBiite
Owlum
Doiylliuin
CiK>i'um
ClHOirium III
CliioiHutn VI
Catmll
Coppgi"
CynnkM
lead (and compounds- lno<0.)
M.inqanq-a (wnlni)
CARCINOGENS:
SLOPE FACTORS (SF)
Oinl SF Inli.ibilion SF Walglil ol
(ing/Vg-dny)- 1 (in/ltg day)- 1 EvkJpncn
2 OE-02 (2| • 02
73C-03' • 02
0
.
0
0
2.4E-0?(2| • 02 '
0
.
0
D
0
7.3COI- • 02
.
C
C
0
.
0
u
0
0
l.3EiOO - I3E.OO 02
.
T.7E.OO • 0?
•
I75E.OO I.SEiOl A
-
43E.OO . 94E.OO 02
63C.OO HI
.
4.2C(OI A
.
D
D
0?
D
-------
IAIH.C
tUIUWULSSIIC
loxicnv VALUES ron POIENIIAL cAnciNor.ENic IIEAI. m crrtcis
OOSE - riE SPONSE netAI IONSI iw» 11)
mi MICAIS
Inoigtnlct fConl'd)
Meicury
Nickel (sol. bill)
S«lonium
SilYBI
thallium (cMotkJn)
Vanadium
Zinc (snd compounds)
CARCINOGENS:
SLOPE FACtOflS(SF)
Olnl Sr ItitinLilioM SF
(mcXkgaiy).l [iiy'Vcj ll.iy) 1
.
.
.
.
.
-
WolgJilol
Evidence
D
0
D
0
0
NOICS
• Culduin. ton. nnpmslum. potassium, and sodinii mo consMmod MsonUnl nutlonls nnJ win not bo quniililnllvoly avolunlixl
In (lio lisK usouindfil.
•llobiivo Potency Vnluns woit usod In onn)uiKllnn wild -Jopn Inclots pm USEPA 1'iovisloiinl Cuidnncn Im Oii.iniii.nlvo Mi
-------
TAOIE
TUTU WCUS SITE
COMDINING CARCINOGENIC DISKS ACROSS PATHWAYS
MEDIA
5WIMCC SOIL
Tilled Ga'dnns and An Ccnlof
Area
Fno Oopl rToiaco gns sl.illon/
Anllllos nulo pnils' Ramsay
motor co. Afon
Cuiilculuin Ccnlo) OulkJimj
A/ca (Piosont Uso)
Cuiiiculu'ii Cciilnr Duilding
Aipa (Futmo-Uso)
O'ltumy tliy claanoii and
Liquor DiMit Area
lillull Gaidons anrt Ail Conlor
Aio.i(Fun«o-Uio)
nccci'ioii
poi'uiAiion
nosldcnts:
Adulls
Childicn (0-6 years
Silo Workois
(Employoos)
Silo Woiheis
(Employcos)
Silo Workois
Employed*)
Silo Workers
Employcus)
Consliuclion
WorltofS
CXPOSUlin
nouic
Ingoslion
Octm.il Contact
Inhalation ol Pailiculalcs
Tolil Carcinogenic Risk =
Ingoslion
Domini Contncl
Inlialallon ol Pailiculatos
ToUl C«tclnog«nlc Risk =
Ingoslion
Oonnnl Conine!
Inhnlallon ol Patllcublos
Tolnl Cmclnononlc Risk =
Ingoslion
CXjtmnl Contact
Total Coiclnogenlc Risk =
Ingoslion
Oiiin.ll Conlncl
Inhnlallon ol Paillculalus
folol Cotclnou«nlc fllsk =
ngosliori
3oiin.il Contact
ulialalion ol Pnilicul.ilus
nhalaiion ol VOCs
roltl Cmclnogonlc ftlik =
ngoslion
Oarmal Contact
ulialalion ol Poillcolalos
Toltl Coiclnogonlc fllsk =
IMDIVIDUAI.
CANCEII "ir.K
0.2E-OG
NA
5.SE07
O.DE-00
I.9E-05
NA
64E07
2.0E-05
1.3EOG
NA
2.7E09
LDH-no
3.7EOG
NA
3.7E-OG
O.fE-07
NA
4.5E-OU
O.CL-07
07E.OG
NA
3.46-07
4.9E-07
LIE-OS
5.7E05
4.3C05
cce-oa
I.OE-04
CHEMICALS CONTMIUUTING THE GHEAIEST
AMOUNT TO niSK
Aiscnlc
-.
"
Aisonlc
Aisonlc
Arsenic
-
..
••
.-
..
-
..
-
..
..
**
P.ltJO I
-------
MI vrv«AYAOiim: »
TUTU WP.I.LS SITE
COMDINING NONCARCINOGENIC HAZARD INUGX VALUES ACROSS PATHWAYS
MEDIA
sunrAcc SOIL
tilled Gnidcns and Ail Conlni
Aif.i
Ffio DcpIV TOIDCO gas station/
Anlillos aulo pails' Ramsay moloi
. co Aioa
Cuniculum Conloi Duildlng
Aio.i (Piosonl-Uso)
Cuniculum Contor Oullding
Afca (Fuluio-Uso)
O Monty diy doanots arid
Llquoi Unto Aiua
lilloll Gaidons and Ail Ccnloi
Aroa (Fuluio Uso)
RECEPTOn
POPULATION
Rosidnnls:
Adulis
Cliildtcn (00 ycais
Silo Woikois
(Cmpfoyccs)
Silo Woikois
lErnptoyoos)
Silo Woikois
Employoos)
Silo Woikors
Einploynor.)
Consbuclton
Woikois
EXPOSURE
noUTE
Ingoslion
Donn.nl Contact '
Inhalnlion ol Paiticulatcs
Tol»l ll*»rd Ind* * -
Ingcslion
Oeimal Contact
Inhalation o( Paillculalos
Total llctaid lnd«i =
Ingoslion
Ooim.il Contact
Inhalation ol Pniliculatos
Total tloierd Indoi =
Ingoslion
Ooini.il Contact
Total llcmrd Index =
ngcsllon
)cin>,il Conlacl
nli.ilaliori ol P.iilicul.ilos
lolol llntord Index =
rigoslion
Donn.il Conl.icl
nhiilalioii ol Paitlculnlos
nliolallon ol VOCs
Total Hazard lnd»x =
ngosllon
Ooiinal Conlacl
nli.it.illon of Paillculalos
Total \\atnd tndai r
INDIVIDUAL
HANARO INOrX
3.ZE-OI
NA
C.7G 01
9.9E 01
D.OE tOO
NA
3.IEVOO
G.IE'OO
9.7E02
NA
20COI
3.0EOI
2.5EOI
NA
2.5UOI
2.3EOI
NA
2.1E-OI
-I.-IC-OI
I.5E-OI
NA
2.ICOI
NA
3.GEOI
9.9EOI
NA
2.4E02
I.OE<00
CHEMICALS CONtniOUTING THE GREATEST
AMOUNT TO ItAZARO INDEX VALUES
_
Manganose
Mangancso
Manganese
;;
•-
-
Pngo I
-------
TABLE. JO
SUMMARY OF HAZARD INDICES
TUTU WELLS SITE
CHEMICAL
HAZARD INDEX
Anole (lizard)
Red-Tailed Hawk
VOLATILE ORGANICS
Benzene
2-Butanone
Ethylbenzene
Methylene Chloride
4-Methyl-2-pentanone
Tetrachloroethylene
Trichloroethylene .
Toluene
Xylenes (Total)
1.24E-05
6.44 E-05
3.96 E-03
4.34 E-05
2.64 E-03
8.04
1.09 E-04
1.49 E-03
1.66E-02
2.42 E-06
1.26 E-04
7.72 E-04
8.47 E-06 -
5. 16 E-05
1.57
2. 14 E-05
2.91 E-04
3.26 E-03
SEMI- VOLATILE ORGANICS
Acenaphthene
Benzo(b)fluoramhene
Beozoic Acid
Benzo(g,h.i)perylene
Benzo(a)pyrene
Bis(2-ethylhexyl)phthalate
Chrysene
Di-n-butylphthalate
2,4-Dimethylphenol
Fluoranthene
Fluorene
' NE
NE
4. 13 E-03
NE
6.57 E-03
1.06 E-03
NE
1.93 E-02
0.12
0.151
8.64 E-04
NE
NE
8.08 E-05
NE
1.28 E-03
2.08 E-04
NE
3.76 E-03
2.3 E-02
2.96 E-04
1.68 E-04
52
-------
TABLE JO
SUMMARY OF HAZARD INDICES
TUTU WELLS SITE
CONTINUED
CHEMICAL
HAZARD INDEX
Anole (lizard)
Red-Tailed Hawk
SEMI-VOLATILES (Com'd)
2-Methylphenol
4-Methylphenol
Naphthalene
Phenol
Pyrene
NE
NE
NE
36.34
6.83 E-03
NE
NE
NE
0.6
1.33 E-03
PESTICIDES/PCB'S
Endosulfan I
Aroclor-1242
3.37 E-02
2.86
' 6.57 E-03
0.115
INORGANICS AND CYANIDE
Aluminum
Antimony
Arsenic
Barium
Cadmium
Chromium, trivalent (Cr*3)
Chromium, hexavalent
(CO
Cobalt
Copper
NE
NE
80.8
NE
3.45 E-03.
9.2 E-03
1.69
NE
NE
NE
NE
0.334
NE
1.57E-04
1.45 E-03
0.133
NE
NE
53
-------
TABLE.} C
SUMMARY OF HAZARD INDICES
TUTU WELLS SITE
CONTINUED
CHEMICAL
HAZARD INDEX
Anole (lizard)
Red-Tailed Hawk
INORGANICS AND CYANIDE (Cont'd)
Iron
Lead
Manganese
Nickel
Sodium
Vanadium
Zinc
Cyanide
NE
4.42
1.24
1.98
NE '
NE
NE
1.31 E-03
NE
0.864
0.242
0.222
NE
NE
NE
2.55 E-04
NE denotes "not evaluated" due to lack of toxicity data.
1 The most conservative chromium hazard index (i.e., Cr +6) was used in the determination
of these cumulative indices.
54
-------
Table \ \. Groundwater Chemical-Specific Remedial Action Levels Identified for the
Tutu Wells Site, St. Thomas. U.S. Virgin Islands.
Page 1 of 5
Parameters
Groundwater RALs
USEPA
MCLs
-------
Page 2 of 5
Table 11 . Groundwater Chemical-Specific Remedial Action Levels Identified for the
Tutu Wells Site, St. Thomas, U.S. Virgin Islands.
Groundwater RALs
USEPA
Parameters MCLs MCLGs
(mg/L) (mg/L)
Volatile Organic Compounds (continued)
Carbon disulfide
1,1-Dichloroethene 0.007 0.007
1,1-Dichloroethane — - *•-
1,2-Dichloroethene(cis) 0.07 . 0.07
1,2-Dichloroethene(trans) ~OTI 0.1
Chloroform
1,2-Dichloroethane 0.005 0
2-Butanone —
1,1,1-Trichioroethane 0.2 0.2
Carbon tetrachioride 0.005 0
Vinyl acetate -
Bromodichlor.pmethane
1,1,2,2-Tetrachloroethane -
1,2-Dichloropropane
trans-1,2-Dichloropropene ——\"
Trichloroethene ,0.005 0
Dibromochloromethane -"'
1.1,2-Trichloroethane 0.005 0.003
Benzene ...... 0.005 0
cis-1,3-Dichloropropene
Bromoform -
2-Hexanone -
4-Methyl-2-pentanone ....-^ _
Tetrachloroethene 0.005 : 0
Toluene - 1
Chlorobenzene ^~~H^.-_
Ethylbenzene ^2^ 0.7
Styrene 0.1 0.1
total xylenes 10 10
Pesticides/PCBs
alpha-BHC «
beta-BHC
delta-BHC - •
gamma-BHCILindane)
Heptachlor « 0
Aldrin -- 0
See last page for footnotes.
GERAGHTY & MILLER. INC.
-------
Page 3 of 5
Table | \. Groundwater Chemical-Specific Remedial Action Levels Identified for the
Tutu Wells Site. St. Thomas. U.S. Virgin Islands.
Groundwater RALs
USEPA
Parameters MCLs MCLGs
(mg/U (mg/U
Pesticides/PCBs. continued
Heptachlor epoxide
Endosulfan I -
Dieldrin
4,4'-DDE
Endrin . ' 0.002 0.002
Endosulfan II
4,4'-DDD
Endosulfan sulfate
4,4'-DDT
Methoxychlor 0.04 0.04
Chlordanefaipha and/or gamma) - 0
Toxaphene 0.003 0
Aroclor 1016
Aroc!or1221
Aroclor 1232
Aroclor 124 2 . . ..
Aroclor 1248
Aroclor 1254
Aroclor 1260
Endrin ketone —
SemivplaTile Organic Compounds
Phenol(s) -
bis(-2-Chloroethyl)ether
2-Chlorophenol
1,3-Dichlorobenzene 0.6 0.6
. 1,4-Dichlorobenzene 0.075
Benzyl alcohol —
1,2-DichIorobenzene 0.6 0.6
2-Methylphenol -
bis(2-Chloroisopropyl)ether - -
4-Methytphenol — -
N-Nitroso-di-propylamine — —
Hexachloroethane - -
Nitrobenzene — ' —
Isophorone -•-
2-Nitrophenol —
See last page for footnotes.
C:\APBOjec-nTUTuwwooiJ.03T\DATA\CMtM.xls
GER.AGHTY & NOLLER. INC.
-------
Page 4 of 5
Tabk ) \ Groundwater Chemical-Specific Remedial Action Levels Identified for the
Tutu Wells Site, St. Thomas. U.S. Virgin Islands.
Groundwater RALs
USEPA
Parameters MCLs MCLGs
(mg/U (mg/L)
Semivolatile Organic Compounds (continued)
2,4-Dimethylphenol - ..
Benzoic acid ~
bis(2-Chloroethoxv)methane
2,4-Dichlorophenol
1,2,4-Trichlorobenzene 0.07 0.07
Naphthalene -- . -
4-Chloroaniline —
Hexachlorobutadiene
4-Chloro-3-methylphenol - -
2-Methylnaphthalene - -
Hexachlorocyclopentadiene 0.05 0.05
2.4,6-Trichloroph«nol
2,4,5-Trichlorophenol —
2-Chloronaphthalene -
2-Nitroaniline • — . —
Dimethylphthalate
Acenaphthyiene ~
3-Nitroaniline -- -
Acenaphthene -
2,4-Dinitrophenol -- -
4-Nitrophenol -
Dibenzofuran - -
2,4-Dinitrotoluene - -
2,6-Dinitrotoluene - ~
Diethylphthalate -- -
4-Chtorophenyl-phenylether
Fluorene
4-Nitroaniline -- —
4.6-Dinitro-2-methylphenol -- -
N-Ni:rosodiphenylamine
4-Bromophenyl-phenylether
Hexachlorobenzene 0.001 0
Penta-chlorophenol 0.001 0
Phenanthrene - -
Anthracene -
Di-n-butylphthalate - -
Fluoranthene —
See last page for footnotes.
GER.AGHTYcf \QLLER. INC.
-------
Page 5 of 5
Table J J Groundwater Chemical-Specific Remedial Action Levels Identified for the
Tutu Wells Site, St. Thomas, U.S. Virgin Islands.
Groundwater RALs
Parameters
USEPA
MCLs
(mo/L)
MCLGs
-------
Table I 2 Summary of Soil Screening Levels Provided by the U.S. Environmental Protection
Agency, Tutu Wells Site, St. Thomas, U.S. Virgin Islands.
Property Depth Chlorinated BTEX
(ft bis) VOCs Compounds
(ppb) (ppb)
Curriculum Center 0.0-2.8 731 150
(former LAGA Facility) 2.8-35.0 73 37
Texaco Tutu Service Station 0.0 - 8.7 290 67
8.7-15.0 29 13
Esso Tutu Service Station . 0.0 - 4.0 320 74
4.0- 15.0 .32 15
O'Henry Dry Cleaners 0.0 - 1.6 375
1.7-22.0 31
Other properties m 0.0 - 4.0 320 74
4.0-15.0 32 15
Soil screening levels are based on site-specific estimates for leaching of contaminants that may
result in exceedance of groundwater drinking standards (COM Federal Programs Corporation 1995b).
ft bis Feet below land surface.
VOCs Volatile organic compounds.
BTEX Benzene, toluene, ethylbenzene, and xylenes.
ppb Parts per billion, equivalent to micrograms per kilogram (ug/kg).
No values provided.
111 The U.S. Environmental Protection Agency (USEPA) directed the use of soil screening levels
for the Esso Tutu Service Station at all other properties.
G:\A«OJCCT\TV/TUVWOO1 3.0 371CATAV3Oll.CLN.Xl.!
GERAGHTYfi? MILLER. INC.
-------
Table I 2 Summary of Soil Screening Levels Provided by the U.S. Environmental Protection
Agency, Tutu Wells Site, St. Thomas. U.S. Virgin Islands.
Property
Curriculum Center
(former LAGA Facility)
Texaco Tutu Service Station
Esso Tutu Service Station
O'Henry Dry Cleaners
Other properties m
Depth
(ft bis)
0.0- 2.8
2.8 -35.0
0.0- 8.7
8.7 - 15.0
0.0-4.0
4.0- 15.0
0.0- 1.6
1.7 -22.0
0.0 - 4.0
4.0 - 15.0
Chlorinated
VOCs
(ppb)
731
73
290
29
320
32
375
31
320
32
BTEX
Compounds
(ppb)
150
37
67
13
74
15
-
74
15
Soil screening levels are based on site-specific estimates for leaching of contaminants that may
result in exceedance of groundwater drinking standards (COM Federal Programs Corporation 1995b).
ft bis Feet below land surface.
VOCs Volatile organic compounds.
BTEX Benzene, toluene, ethylbenzene, and xylenes.
ppb Parts per billion, equivalent to micrograms per kilogram (ug/kg).
No values provided.
111 The U.S. Environmental Protection Agency (USEPA) directed the use of soil screening levels
for the Esso Tutu Service Station at all other properties.
GERAGHTYc? MILLER. INC
-------
APPENDIXIII
ADMINISTRATIVE RECORD INDEX
-------
07/09/96 Index Chronological Order Page: 1
TUTU WELLS SITE Documents
Document Number: TUT-006-0213 To 0231 Parent: TUT-006-0212 Date: / /
Title: Sampling Trip Report, Tutu Wellfield Site, July 22 - 30, 1992
Type: REPORT
Category: 3.A.0.0.0 RI Reports
Author: none: COM Federal Programs Corporation
Recipient: none: none
Document Number: TUT-007-1281 To 1281 Parent: TUT-007-1279 Date: / /
Title: National Priorities List, Tutu Wellfield, Tutu, Virgin Islands-Site Description
Type: REPORT
Category: 10.6.0.0.0 Fact Sheets and Press Releases
Author: none: US EPA
Recipient: none: none
Document Number: TUT-006-0444 To 0445 Parent: TUT-006-0438 Date: / /
Title: Table 1. Listing of the inaccuracies in Section 2.2.1.2 of the Feasibility Study with regard
to Western Auto
Type: OTHER
Category: 3.4.0.0.0 RI Reports
Author: none: ENSR
Recipient: none: none
Document Number: TUT-006-0456 To 0456 Parent: TUT-006-0454 Date: / /
Title: Figure 1: As-Built Soil Venting Pile, 0'Henry Dry Cleaners Soil Remediation
Type: GRAPHIC
Category: 3.4.0.0.0 RI Reports
Author: none: none
Recipient: none: none
-------
07/09/96
Index Chronological Order
TUTU WELLS SITE Documents
Page: 2
Document Number: TUT-006-M72 To 0472
Parent: TUT-006-0468
Date: / /
Title: Figure 1: Soil Excavation and Storage Locations, 0'Henry Laundry, St. Thomas, U.S. Virgin
Islands
Type: GRAPHIC
Category: 3.4.0.0.0 RI Reports ' '
Author: none: IT Corporation
Recipient: none: none
Document Number: TUT-006-0474 To 0475
Title: Visual Classification of Soils
Type: OTHER
Category: 3.4.0.0.0 RI Reports
Author: none: IT Corporation
Recipient: none: none
Parent: TUT-006-0468
Date: / /
Document Number: TUT-006-0502 To 0502 Parent: TUT-006-0497 Date: / /
Title: Summary of Soil Cleanup Coals/Screening Levels for Tutu-Ramsay Site (ug/kg)
Type: OTHER
Category: 3.4.0,0.0 RI Reports
Author: none: none
Recipient: none: none
Document Number: TUT-006-0986 To 0989
Date: / /
Title: Table 1: Organic Compounds Detected in 104(e) Letter Response Samples, Tutu Uellfield Area,
St. Thomas, U.S. Virgin Islands
Type: OTHER
Category: 3.4.0.0.0 RI Reports
Author: none: none
Recipient: none: none
-------
07/09/96 Index Chronological Order Page: 3
TUTU WELLS SITE Documents
Document Number: TUT-006-1010 To 1010 Parent: TUT-006-1008 Date: / /
Title: Table 1: Groundwater Analytical Results, EDelegarde Supply Well, Tutu Wells Site, U.S. Virgin
Islands
Type: OTHER
Category: 3.4.0.0.0 RI Reports
Author: none: Geraghty & Miller
Recipient: none: none
Document Number: TUT-006-1029 To 1029 Parent: TUTr006-1028 Date: / /
Title: Table: Concentrations of Volatile Organic Compounds in Soil Samples Collected in March and
April 1994 at the Tutu Wells Site, St. Thomas, U.S. Virgin Islands
Type: OTHER
Category: 3.4.0.0.0 RI Reports
Author: none: Geraghty & Hi Her
Recipient: none: none
Document Number: TUT-006-1030 To 1031 Parent: TUT-006-1028 Date: / /
Title: Table 2: Concentrations of Base Neutral and Acid Extractable Organic Compounds in Soil Samples
Collected in March and April 1994 at the Tutu Wells Site, St. Thomas, U.S. Virgin Islands
Type: OTHER
Category: 3.4.0.0.0 RI Reports
Author: none: Geraghty & Miller
Recipient: none: none
Document Number: TUT-006-1032 To 1032 Parent: TUT-006-1028 Date: / /
Title: Table 3: Concentrations of Metals in Soil Samples Collected in March and April 1994 at the
Tutu Wells Site, St. Thomas, U.S. Virgin Islands
Type: OTHER
Category: 3.4.0.0.0 RI Reports
Author: none: Geraghty & Miller
Recipient: none: none
-------
07/09/96
Index Chronological Order
TUTU WELLS SITE Documents
Page: 4
Document Number: TUT-006-1033 To 1033
Parent: TUT-006-1028
Date: / /
Title: Table 4: Concentrations of Cyanide, Total in Soil Samples Collected in March and April 1994
at the Tutu Wells Site, St. Thomas, U.S. Virgin Islands
Type: OTHER
Category: 3.4.0.0.0 RI Reports
Author: none: Geraghty & Miller
Recipient: none: none
Document Number: TUT-006-1034 To 1034
Parent: TUT-006-1028
Date: / /
Title: Table 5: Concentrations of Total Petroleum Hydrocarbons in Soil Samples Collected in March
and April 1994 at the Tutu Wet Is Site, St. Thomas, U.S. Virgin Islands
Type: OTHER
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: none: Geraghty & Miller
Recipient: none: none
Document Number: TUT-006-1056 To 1057
Title: (Map of Tutu Uells Site area)
Parent: TUT-006-1054
Date: / /
Type: GRAPHIC
Category: 3.4.0.0.0 RI Reports
Author: none: none
Recipient: none: none
Document Number: TUT-006-1087 To 1087
Parent: TUT-006-1086
Date: / /
Title: Table 1: Proposed Sampling Locations for Comprehensive Sampling Event; May/June 1994, Tutu
Uells Site, St. Thomas, U.S. Virgin Islands
Type: OTHER
Category: 3.4.0.0.0 RI Reports
Author: none: Geraghty & Miller
Recipient: none: none
-------
07/09/96 Index Chronological Order Page: 5
TUTU WELLS SITE Documents
Document Number: TUT -006- 1090 To 1119 Parent: TUT-006-1088 Date: / /
Title: Installation of Proposed Monitoring Well MW-24. Western Auto UST Area, Tutu Wells Site, St.
Thomas
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Condition: DRAFT
Author: none: Ceraghty 4 Miller
Recipient: none: none
Document Number: TUT-006-1120 To 1120 Parent: TUT-006-1088 Date: / /
Title: Figure 1: Western Auto Garage Area Site Plan, Tutu Service Station Investigation
Type: GRAPHIC
Category: 3.4.0.0.0 RI Reports
Condition: DRAFT; MARGINALIA
Author: none: none
Recipient: none: none
Document Number: TUT-006-1H1 To 1U2 Parent: TuT-006-1134 Date: / /
Title: Table 1: Results of Portable GC Analyses of Soil Gas Samples Collected on February 28, 1994
through March 10, 1994 at the Curriculum Center, Tutu Wells Site, St. Thomas, U.S. Virgin Islands
Type: OTHER
Category: 3.4.0.0.0 RI Reports
Author: none: none
Recipient: none: none
Document Number: TUT-006-1143 To 1143 Parent: TUT-006-1134 Date: / /
Title: Table 2: Results of the Portable GC Analyses of Soil Gas Samples Collected on March 8 through
10, 1994 at the Virgin Islands Housing Authority, Tutu Wells Site, St. Thomas, U.S. Virgin
Islands
Type: OTHER
Category: 3.4.0.0.0 RI Reports
Author: none: none
Recipient: none: none
-------
07/09/96
Index Chronological Order
TUTU WELLS SITE Documents
Page: 6
Document number: TUT-006-1146 To 1213
Title: Appendix A: Soil Cas Chromatagraphs
Parent: TUT-006-1134
Type: DATA
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody forms
Author: none: Geraghty & Miller
Recipient: none: none
Date: / /
Oocunent Number: TUT-006-1222 To 1.222
Title: Meeting with EPA and DPNR (Draft Agenda)
Type: OTHER
Category: 3.4.0.0.0 RI Reports
Condition: DRAFT
Author: none: none
Recipient: none: none
Parent: TUT-006-1221
Date: / /
Document Number: TUT-008-0589 To 0592 Parent: TUT-008-0588
Title: Tutu Water Wells Contamination litigation Counsel List
Type:
Category: 7.8.0.0.0 Enforcement Correspondence
Author: none: none
Recipient: none: none
Date: / /
Document Number: TUT-004-0143 To 0150 Parent: TUT-004-0142 Date: 01/01/01
Title: Plan for Evaluation and Remediation of Soils O'Henry Laundry, Tutu St. Thomas, USVI
Type: PLAN
Category: 2.1.0.0.0 Sampling and Analysis Plans
Author: none: none
Recipient: none: none
-------
'07/09/96 Index Chronological Order Page: 7
TUTU UELLS SITE Oocunents
Doeunent Number: TUT -OtK- 2306 To 2309 Parent: TUT-004-2305 Date: 01/01/01
Title: Responses to EPA Contnents on the Draft Work Plan for Evaluation and Interim Remediation of
Soils, 0' Henry Laundry, Tutu, St. Thomas, USVI
Type: REPORT
Category: 3.3.0.0.0 Work Plan
Author: none: IT Corporation
Recipient: none: US EPA
Document Number: TUT -005 -0404 To 0405 . Date: 01/01/01
Title: Demonstration Projects: Implementation of Presumptive Remedies for VOC's in Soils Sites, Site
1: Tutu uellfield, St. Thomas, U.S. Virgin Islands
Type: OTHER
Category: 3.3.0.0.0 Work- Plan
Author: none: none
Recipient: none: none
Document Number: TUT-006-0617 To 0620 Parent: TUT-006-0612 Date: 01/01/01
Title: Attachment 1: Detailed Connents on Draft Tutu Wells Site Remedial Investigation
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: none: ENSR
Recipient: none: none
Document Number: TUT-006-0621 To 0633 Parent: TUT-006-0612 Date: 01/01/01
Title: Attachment 2: Sunnary Report of Tank Closure and Subsequent Investigations Behind Western
Auto
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: ENSR
Recipient: none: none
-------
07/09/96 Index Chronological Order Page: 8
TUTU WELLS SITE Documents
Document Number: TUT-006-0638 To 0640 Parent: TUT-006-0636 Date: 01/01/01
Title: Summary of Four Winds Plaza Partnership's Comments on Ceraghty & Miller's Draft Phase II RI
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: none: none
Recipient: none: none
Document Number: TUT-006-1915 To 1916 Date: 01/01/01
Title: (Letter regarding Approval of the Phase II Remedial Investigation Implementation Workplan
for the Tutu Wells Site, St. Thomas)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Petersen, Carole: US EPA
Recipient: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Committee
Document Number: TUT-006-1917 To 1917 Date: 01/01/01
Title: (Memorandum regarding Full Validation on Seven Grounduater Samples on Tutu Wells Site)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Hauptman, Melvin: US EPA
Recipient: Kubik, Kevin: US EPA
Document Nunber: TUT-006-2135 To 2140 Parent: TUT-006-2133 Date: 01/01/01
Title: Coastal Hazardous Waste Site Review on the Tutu Wells Site
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: National Oceanic & Atmospheric Administration (NOAA)
Recipient: none: none
-------
07/09/96 Index Chronological Order Page: 9
TUTU UELLS SITE Documents
Document Number: TUT-006-2157 To 2158 Parent: TUT-006-2U8 Date: 01/01/01
Title: Table 1. Listing of Inaccuracies in Section 2.2.1.2 of the Feasibility Study with regard to
Western Auto.
Type: DATA
Category: A. 3. 0.0.0 Proposed Plan
Author: none: none
Recipient: none: none
Document Number: TUT-003-0821 To 0845 Date: 09/17/83
Title: ESSO Tutu Car Care Center Investigation Plan, Duality Assurance/Quality Control Plan
Type: PLAN
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Belgodere, Carlos M.: Belgodere & Associates
Ramos, Ana Gloria: ESSO Standard Oil Co. S. A. Ltd.
Recipient: none: US EPA
Document Number: TUT-003-0744 To 0745 Date: 07/31/87
Title: Order in the Hatter of Tutu Waters, St. Thomas, U.S. V.I.
Type: LEGAL DOCUMENT
Category: 7.3.0.0.0 Administrative Orders
Author: Smith, Alan D.: Department of Planning and Natural Resources (DPNR)
Recipient: none: Tutu Waters
Document Number: TUT-003-0746 To 0749 Date: 08/05/87
Title: First Amended Order in the Matter of Texaco Caribbean, Inc., St. Thomas
Type: LEGAL DOCUMENT
Category: 7.3.0.0.0 Administrative Orders
Author: Smith, Alan D.: Department of Planning and Natural Resources (DPNR)
Recipient: none: Texaco-Caribbean, Inc.
-------
*07/09/96 Index Chronological Order Page: 10
TUTU WELLS SITE Documents
Document Number: TUT-003-0750 To 07S1 Date: 08/07/87
Title: Order In the Hatter of The Plaza Associates, St. Thomas, U.S. V.I.
Type: LEGAL DOCUMENT
Category: 7.3.0.0.0 Administrative Orders
Author: Canegata, David C.: Department of Planning and Natural Resources (DPNR)
Recipient: none: The Plaza Associates
Document Number: TUT-003-0752 To 0753 Date: 09/02/87
Title: Order In the Matter of Steele Well, St. Thomas, U.S. V.I.
Type: LEGAL DOCUMENT
Category: 7.3.0.0.0 Administrative Orders
Author: Smith, Alan D.: Department of Planning and Natural Resources (DPNR)
Recipient: none: Steele Well
Document Number: TUT-003-0754 To 0755 ' - Date: 09/02/87
Title: Order In the Matter of Harvey Well, St. Thomas, U.S. V.I.
Type: LEGAL DOCUMENT •
Category: 7.3.0.0.0 Administrative Orders
Author: Smith, Alan D.: Department of Planning and Natural Resources (DPNR)
Recipient: none: Harvey Well
Document Number: TUT-003-OS46 To 0873 Date: 10/01/87
Title: ESSO Tutu Car Care Center Investigation Plan, Health and Safety Plan
Type: PLAN
Category: 7.8.0.0.0 Enforcement Correspondence
Author: none: Betgodere & Associates
Recipient: none: none
-------
S7/09/96 Index Chronological Order Page: 11
TUTU WELLS SITE Documents
Document Number: TUT-003-0986 To 1012 Parent: TUT-003-0985 Date: 10/U/87
Title: Work Plan for Soil Gas Survey, Texaco Service Station, Tutu, St. Thomas, U.S. Virgin Islands
Type: PLAN
Category: 7.8.0.0.0 Enforcement Correspondence
Author: none: Geoscience Consultants, LTD.
Recipient: none: Texaco-Caribbean, Inc.
Document Number: TUT-003-0874 To 0984 Date: 10/15/87
Title: Action Plan for Texaco Caribbean Inc., U.S. Virgin Islands
Type: PLAN
Category: 7.8.0.0.0 Enforcement Correspondence
Author: none: Lebron Associates
Recipient: none: none
Document Number: TUT-003-0985 To 0985 Date: 10/16/87
Title: (Letter forwarding the enclosed revised Action Plan for the Texaco Caribbean, Inc., Service
Station at the Tutu Wells site)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Hroch, William: Texaco-Caribbean, Inc.
Recipient: Smith, Alan D.: Department of Planning and Natural Resources (DPNR)
Attached: TUT-003-0986
Document Number: TUT-003-1013 To 1057 Date: 12/18/87
Title: Final Report on Results of Soil Gas Survey, Tutu, St. Thomas, U.S. Virgin Islands
Type: REPORT
Category: 7.8.0.0.0 Enforcement Correspondence
Author: none: Geoscience Consultants, LTD.
Attached: TUT-003-1058
-------
39/96 Index Chronologic*! Order Page: 12
TUTU WELLS SITE Documents
«mnt Nuifeer: TUT-OOJ-1058 To 1245 Parent: TUT-003-1013 Date: 12/18/87
itle: Final Report on Results of Soil Gas Survey, Tutu. St. Thonas. U.S. Virgin Islands, Supplement
Type: REPORT
Category: 7.8.0.0.0 Enforcement Correspondence
Author: none: Ceoseience Consultants, LTD.
Recipient: none: Texaco-Caribbean, inc.
Oocunent Number: TUT-002-0677 To 0687 Date: 01/06/88
Title: Action Memorandum - Preliminary Assessment and Confirmation of Authorization of CERCLA Removal
Action Monies for the Tutu Uells Site, Anna's Retreat, Saint Thomas, U. S. Virgin Islands
Type: CORRESPONDENCE
Category: 2.5.0.0.0 Action Memorandum
Author: O'Neill, Carlos E.: US EPA
Recipient: Luftig, Stephen 0.: us EPA
Oocunent Number: TUT-003-0756 To 0757 Date: 01/06/88
Title: Order in the Matter of ESSO Standard Oil (SA), Ltd. Gottlieb's Quickuay Station
Type: LEGAL DOCUMENT
Category: 7.3.0.0.0 Administrative Orders
Author: Smith, Alan D.: Department of Planning and Natural Resources (DPNR)
Recipient: none: ESSO Standard Oil Co. S. A. Ltd.
Document Number: TuT-002-1803 To 1827 Date: 01/11/88
Title: ESSO Tutu Service Station Soil Vapor Investigation Plan (Second Revision)
Type: PLAN
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: Ramos, Ana Gloria: ESSO Standard Oil Co. S. A. Ltd.
Recipient: none: Department of Planning and Natural Resources (DPNR)
none: US EPA
-------
07/09/96
Index Chronological Order
TUTU WELLS SITE Oocunents
Page: 13
Document Number: TUT-003-1684 To 1694
Title: (104e Request for Information Letter)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Dagger, Christopher J.: US EPA
Recipient: Tillet, Jim: Potentially Responsible Party (PRP)
Date: 01/11/88
Document Number: TUT-004-0038 To 0046 Date: 01/25/88
Title: (Letter on behalf of Virgin Islands Housing Authority in reponse to Request for Information)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Condition: ILLEGIBLE
Author: Potentially Responsible Party (PRP)
Recipient: Daggett, Christopher J.: US EPA
Document Number: TUT-003-1246 To 1251
Date: 02/04/88
Title: (Letter forwarding the attached revised pages to be inserted into the Final Report on Results
of Soil Gas Survey, Tutu, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Hroch, William: Texaco-Caribbean, Inc.
Recipient: Smith, Alan D.: Department of Planning and Natural Resources (DPNR)
Document Number: TUT-002-0578 To 0603
Title: Site Analysis, Tutu Uellfield, St. Thomas, Virgin Islands
Date: 03/01/88
Type: PLAN
Category: 1.4.0.0.0 Site Investigation (SI) Report
Author: Mata, Larry: Bionetics Corporation
Osberg, Thomas R.: Environmental Photographic Interpretation Center (US EPA)
Sitton, Mary D.: Bionetics Corporation
Recipient: none: US EPA
-------
07/09/96 Index Chronological Order Page: 14
TUTU WELLS SITE Documents
Document Nunber: TUT-004-0034 To 0037 Date: 03/02/85
Title: (Letter on behalf of Jin Tiller in response to 01/11/88 Request for Information}
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Junk in. Timothy 0.: attorney
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-004-0032 To 0033 Date: 03/07/88
Title: (Letter on behalf of Jim Tillet in response to 1/11/88 Request for Information)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Junkin, Timothy: attorney
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-003-1683 To 1683 Date: 05/18/88
Title: (Follow-up information on the Request For Information Letter)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Kuan, Caroline: US EPA
Recipient: Consolidated Auto: Potentially Responsible Party (PRP)
Document Number: TUT-003-1671 To 1682 Date: 05/27/88
Title: (Request for Information Letter to Classic Printer Ink)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Luftig, Stephen D.: US EPA
Recipient: Joseph. Bert: Potentially Responsible Party (PRP)
-------
8r/09/96 Index Chronological Order Page: 15
TUTU WELLS SITE Documents
Document Number: TUT -004 -0031 To 0031 Date: 06/01/88
Title: (Letter regarding Follow-up Information on the Request for Information for Esso Tutu Car Care
Center at the Tutu Site, St. Thomas, USVI)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Ramos, Ana Gloria: ESSO Standard Oil Co. S. A. Ltd.
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-003-0669 To 0731 Date: 08/01/88
Title: ESSO Tutu Service Station • Soil Gas Vapor Screening Survey, Report (Revised)
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: Belgodere & Associates
Recipient: none: ESSO Standard Oil Co. S. A. Ltd.
Document Number: TUT-002-0688 To 0692 Date: 08/22/88
Title: Action Memorandum - Request for a Twelve Month Exemption for the Tutu Well Site, Saint Thomas,
US Virgin Islands
Type: CORRESPONDENCE
Category: 2.5.0.0.0 Action Memorandum
Author: O'Neill, Carlos E.: US EPA
Recipient: Muszynski, William J.: US EPA
Document Number: TUT-003-2497 To 0030 Date: 08/22/88 Confidential
Title: (Letter on the behalf of Esso Standard Oil Company, forwarding attached documents in response
to Request for Information)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Ramos, Ana Gloria: ESSO Standard Oil Co. S. A. Ltd.
Recipient: Kwan, Caroline: US EPA
-------
"07/09/96 Index Chronological Order Page: 16
TUTU WELLS SITE Documents
Document Number: TUT-003-0758 To 0762 Date: 02/23/89
Title: (Order in) The Hatter of ESSO Standard Oil S. A. Ltd./Rodriguez Gasoline Station, St. Thomas,
Virgin Islands
Type: LEGAL DOCUMENT
Category: 7.3.0.0.0 Administrative Orders
Author: Smith, Alan D.: Department of planning and Natural Resources (DPNR)
Recipient: none: ESSO Standard Oil Co. S. A. Ltd.
Document Number: TUT-001-2054 To 2215 . Date: 03/24/89
Title: Final Draft Preliminary Assessment, Cassett Motors, St. Thomas, U.S. Virgin Islands
Type: PLAN
Category: 1.3.0.0.0 Preliminary Assessment (PA) Report
Author: Mayo, Joseph: NUS Corporation
Trube, Diane: NUS Corporation
Recipient: none: US EPA
Document Number: TUT-001-2216 To 2396 Date: 03/24/89
Title: Final Draft Preliminary Assessment, Tutu ESSO, St. Thomas, U.S. Virgin Islands
Type: PLAN
Category: 1.3.0.0.0 Preliminary Assessment (PA) Report
Author: Mayo, Joseph: NUS. Corporation
Trube, Diane: NUS Corporation
Recipient: none: US EPA
Document Number: TUT-001-2397 To 0058 Date: 03/24/89
Title: Final Draft Preliminary Assessment, Ramsey Motors, St. Thomas, U.S. Virgin Islands
Type: PLAN
Category: 1.3.0.0.0 Preliminary Assessment (PA) Report
Author: Mayo, Joseph: NUS Corporation
Trube, Diane: NUS Corporation
Recipient: none: US EPA
-------
19/96 Index Chronological Order Page: 17
TUTU WELLS SITE Documents
;unent Number: TUT-002-0059 To 02U Date: 03/24/89
tie: Final Draft Preliminary Assessment, Laga Building/Virgin Islands, Department of Education,
St. Thomas, U.S. Virgin Islands
Type: PLAN
Category: 1.3.0.0.0 Preliminary Assessment (PA) Report
ondition: DRAFT
Author: Trube, Diane: NUS Corporation
incipient: Mayo, Joseph: NUS Corporation
none: US EPA
Document Number: TUT-002-0215 To 0388 Date: 03/31/89
Title: Final Draft Preliminary Assessment, Tutu Texaco, St. Thomas, U.S. Virgin Islands
Type: PLAN
Category: 1.3.0.0.0 Preliminary Assessment (PA) Report
Author: Mayo, Joseph: NUS Corporation
Trube, Diane: NUS Corporation
Recipient: none: US EPA
Document Number: TUT-002-0389 To 0577 Date: 05/26/89
Title: Final Draft Preliminary Assessment, Tutu Texaco, St. Thomas, U.S. Virgin Islands
Type: PLAN
Category: 1.3.0.0.0 Preliminary Assessment (PA) Report
Author: Mayo, Joseph: NUS Corporation
Trube, Diane: NUS Corporation
Recipient: none: US EPA
Document Number: TUT-007-1208 To 1210 Date: 06/30/89
Title: {Letter regarding Tutu Wells Site, St. Thomas, U.S.V.I., Contamination Investigation pursuant
to Sections 106 and 107 of CERCLA, as amended and Section 9003 of RCRA, as amended)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Luftig, Stephen 0.: US EPA
Recipient: Barbel, LeoT.: L'Henri, Inc.
President: ESSO Standard Oil Co. S. A. Ltd.
President: Texaco-Caribbean, Inc.
-------
;7/09/96 Index Chronological Order Page: 15
TUTU WELLS SITE Documents
Document Number: TUT-007-1206 To 1207 Date: 07/24/89
title: (Letter regarding Tutu Wells Site, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Mittelholzer, George E.: Texaco-Caribbean, Inc.
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-007-1205 To 1205 Date: 08/17/89
Title: (Letter regarding Tutu Uells Site, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Pavlou, George: US EPA
Recipient: Hogde Tankenson, Maria: attorney
Document Number: TUT-002-0629 To 0676 Date: 09/01/89
Title: Tutu Well Site Potable Water Alternatives Report, Anna's Retreat, St. Thomas, U. S. Virgin
Islands
Type: REPORT
Category: 2.1.0.0.0 Sampling and Analysis Plans
Author: Hafner, Rodotfo: Weston Spill Prevention & Emergency Response Div (SPER)
.Hanfreda, James: Weston Spill Prevention & Emergency Response Div (SPER)
Recipient: O'Neill, Carlos E.: US EPA
Santos, Luis: US EPA
Sprague, Bruce: US EPA
Document Number: TUT-007-1204 To 1204 . Date: 09/13/89
Title: (Letter granting Esso Standard Oil Company, an extension to respond to the June 30, 1989 Administrative
Order)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Chester, Amy: Assistant Regional Counsel, EPA
Recipient: Torres, Francis: Goldman & Antonetti
-------
07/09/96 Index Chronological Order Page: 19
TUTU WELLS SITE Documents '
Document Number: TUT-003-249S To 2496 Date: 10/13/89
Title: (Letter on behalf of Esso Standard Oil Company S.A. Limited, in response to 06/30/89 Request
for Information)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Ramos, Ana Gloria: ESSO Standard Oil Co. S. A. Ltd.
Recipient: Luftig, Stephen 0.: US EPA
Document Number: TUT-003-2493 To 2494 Date: 11/01/89
Title: (Letter on behalf of L' Henry Inc., in response to 6/30/89 Request for Information)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: D' Anna, Nancy: attorney
Recipient: Luftig, Stephen D.: US EPA
Document Number: TUT-007-1202 To 1203 Date: 11/09/89
Title: (Letter regarding responses to proposed June 30, 1989 Administrative Order for the Tutu Wells
Site)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Chester, Amy R., Esq.: Assistant Regional Counsel, EPA
Recipient: Cepeda-Rodriquez, J., Esq: Golotaan Antonetti Ferraiuoli Axtmater & Hertell
0' Anna, Nancy, Esq.: attorney
Hodge Tankenson, Maria: attorney
Mittelholzer, George E.: Texaco
Ramos, Anna Gloria: ESSO Standard Oil Co. S. A. Ltd.
Torres, Francis, Esq.: Goldman Antonetti Ferraiuoli Axtmater & Hertell
Document Number: TUT-007-1196 To 1201 Date: 12/21/89
Title: (Letter regarding attached comments prepared on behalf of L'Henri, Inc. to the proposed settlement
order)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: D'Anna, Nancy, Esq.: attorney
Recipient: Chester, tuny, Esq.: Assistant Regional Counsel, EPA
-------
•07/09/96 Index Chronological Order Page: 20
TUTU WELLS SITE Documents
Docunent Number: TUT-002-0604 To 0628 Date: 02/27/90
Title: (Tutu Wells Site Inspection Reports for February 27 • March 1, 1990, and August 20 - 22, 1990)
Type: REPORT
Category: 1.4.0.0.0 Site Investigation (SI) Report
Author: none: US EPA
Recipient: none: none
Document Number: TUT-005-0359 To 0403 Date: 03/01/90
Title: Remedial Investigation Workplan for O'Henry Laundry, St. Thomas, U.S. Virgin Islands
Type: PLAN
Category: 3.3.0.0.0 Work Plan
Author: none: Geo-Caribe, Inc.
none: Pedro Pandzardi & Associates
Recipient: none: none
Document Number: TUT-003-0763 To 0786 Date: 03/22/90
Title: Administrative Order in the Matter of the ESSO Standard Oil S. A., Limited, Texaco Caribbean,
Inc., L'Henri, Inc., d/b/a O'Henry Cleaners - Tutu Wells Site
Type: LEGAL DOCUMENT
Category: 7.3.0,0.0 Administrative Orders
Author: Huszynski, William J.: US EPA
Recipient: various: various
Document Number: TUT-007-1194 To 1195 Date: 04/16/90
Title: (Letter regarding Tutu Well Site, St. Thomas, Virgin Islands)
Type: CORRESPONDENCE
Category: 7.8.0.0,0 Enforcement Correspondence
Author: D'Anna, Nancy, Esq.: attorney
Recipient: Chester, Amy R.: Assistant Regional Counsel, EPA
-------
07/09/96 Index Chronological Order Page: 21
TUTU WELLS SITE Documents
Docunent Number: TUT-003-1252 To 1371 Date: 05/21/90
Title: (Tutu Wells Site Adninistnative Orders Nos. Il-CERCLA-00401 and RCRA-90-UST-9003-0401 Monthly
Progress Reports for May 1990, to March 1992, June 1992, to September 1992, and November 1992)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Ramos, Ana Gloria: Tutu Environmental.Investigation Coonittee
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-007-1192 To 1193 Date: 12/03/90
Title: (Letter regarding request for extension of the deadline to receive conroents regarding the
proposed Administrative Order on Consent)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Fernandez-Torres, Francis: Goldman Antonetti Ferraiuoli Axtmater i Hertell
Recipient: Chester, Amy, Esq.: Assistant Regional Counsel, EPA
Document Number: TUT-002-1828 To 2066 Date: 01/01/91
Title: 1st Sampling Report, September 1990, Tutu Wells Site Quarterly Sampling, St. Thomas, U. S.
Virgin Islands
Type: REPORT
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: none: Geraghty & Miller
Recipient: none: Tutu Environmental Investigation Committee
Document Number: TUT-003-1663 To 1670 Date: 04/04/91
Title: (104e Request for Information Letter)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Callahan, Kathleen: US EPA
Recipient: various: Goldman & Antonetti
-------
07/09/96 Index Chronological Order Page: 22
TUTU WELLS SITE Documents
Document Number: TUT-005-0352 To 0358 Date: 04/04/91
Title: (letter with attached ccmnents regarding the Tutu Service Station Investigation Work Plan
dated January 1991)
Type: CORRESPONDENCE
Author: Petersen, Carole: US EPA
Recipient: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Conntittee
Document Number: TUT-003-2480 To 2492 Date: 04/29/91
Title: (Letter on behalf of Esso Standard Oil S.A. Limited's forwarding attached documents in response
to Request for Information)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Torres, Francis: attorney
Recipient: Callahan, Kathleen: US EPA
Document Number: TUT-005-0351 To 0351 Date: 05/02/91
Title: List of attendees at the Technical Meeting uith TEIC and its consultants regarding the RI/FS
uorkplan.
Type: MISCELLANEOUS
Category: 3.3.0.0.0 Work Plan
Author: none: US EPA
Recipient: none: none
Document Number: TUT-006-1913 To 1914 Date: 05/03/91
Title: (Letter regarding Tutu Service Station Investigation Uork Plan)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty t Miller
Nachman, Daniel A.: Geraghty 4 Miller
Recipient: Kwan, Caroline: US EPA
-------
£7/09/96 Index Chronological Order Page: 23
TUTU WELLS SITE Documents
Document Number: TUT -003 -2476 To 2479 Date: OS/09/91
Title: (Letter on behalf of Esso Tutu Service Station forwarding attached documents in response to
Request for Information)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Ramos, Ann Gloria: ESSO Standard Oil Co. S. A. Ltd.
Recipient: Chester, Any: US EPA
Document Number: TUT-002-2067 To 2302 . • Date: 05/13/91
Title: Second Quarter Sampling Report, February 1991, Tutu Wells Site, Quarterly Sampling, St. Thomas,
U. S. Virgin Islands
Type: REPORT
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: Danahy, Thomas V.: Geraghty & Miller
Gulizie, Lidya: Geraghty t Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: none: Tutu Environmental Investigation Committee
Document Number: TUT-001-0001 To 2053 Date: 08/26/91
Title: Final Draft Hazard Ranking System Documentation, Tutu Wellf ield, St. Thomas, U.S. V.I.
Type: PLAN
Category: 1.1.0.0.0 Background - RCRA and other information
Condition: DRAFT
Author: Feinberg, Richard L.: NUS Corporation
Recipient: none: US EPA
Document Number: TUT-002-0693 To 0910 Date: 09/01/91
Title: Revised Sampling, Analysis, and Monitoring Plan for Wells Tutu Wells Site, St. Thomas, U.S.
Virgin Islands
Type: PLAN
Category: 3.1.0.0.0 Sampling and Analysis Plan (SAP)
Author: Danahy, Thomas V.: Geraghty t Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: none: Tutu Environmental Investigation Committee
-------
07/09/96 Index Chronological Order Page: 24
TUTU WELLS SITE Documents
Document Number: TUT-002-0911 To 0956 Date: 09/01/91
Title: Health and Safety Plan, Tutu Service Station Investigation, St. Thomas, U. S. Virgin Islands
Type: PLAN
Category: 3.1.0.0.0 Sampling and Analysis Plan (SAP)
Author: Oanahy. Thomas V.: Geraghty ( Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: none: Tutu Environmental Investigation Comnittee
Document Number: TUT-002-2303 To 2407 . Date: 09/06/91
Title: Third Sampling Report, June 1991, Tutu Wells Site, St. Thomas, U. S. Virgin Islands
Type: REPORT .
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: Danahy, Thomas V.: Geraghty & Miller
Garcia, Juan: Geraghty & Miller
Nachman, Daniel A.: Geraghty t Miller
Recipient: none: Tutu Environmental Investigation Committee
Document Number: TUT-006-1906 To 1912 Date: 09/11/91
Title: (Letter regarding Response to Draft Comments by USEPA on Tutu Service Station Investigation
Workplan)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-006-1903 To 1905 Date: 09/16/91
Title: (Letter regarding Response to Laura Scalise's Draft Comments on Tutu Service Station Investigation
Work Plan dated May 1991}
Type: CORRESPONDENCE
Category: 3.S.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Kwan, Caroline: US EPA
-------
07/09/96 Index Chronological Order Page: 25
TUTU WELLS SITE Documents
Document Nutter: TUT-006-1899 To 1902 Date: 09/19/91
Title: (Memorandum regarding Tutu Uells Site RI, Draft Work Plan)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Scalise, Laura: US EPA
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-006-1893 To 1898 Date: 09/23/91
Title: (Letter with attached tables and figure regarding Request for Temporary Discharge of Groundwater
Treatment Plant.)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Oanahy, Thomas V.: Geraghty & Killer
Nachman, Daniel A.: Geraghty & Miller
Recipient: Francis, Leo: Department of Public Works
Document Number: TUT-006-1S91 To 1892 Date: 09/27/91
Title: (Memorandum regarding Tutu Uells Site RI, Draft Quality Assurance Project Plan)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Scalise, Laura: US EPA
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-006-1890 To 1890 Date: 10/18/91
Title: (Letter regarding Approval of the Tutu Services Stations Investigation Uorkplan, St. Thomas,
USVI)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Petersen, Carole: US EPA
Recipient: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Committee
-------
•07/09/96 Index Chronological Order Page: 26
TUTU WELLS SITE Documents
Document Number: TUT-006-1889 To 1889 Date: 10/23/91
Title: (Letter regarding Tutu Service Station Investigation Work Plan, St. Thomas, U.S. Virgin Islands.)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty I Miller
Hoffatt, Clinton: Geraghty I Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Kuan, Caroline: US EPA
Document dumber: TUT-006-1888 To 1888 Date: 11/19/91
Title: (Letter regarding Approval of the Tutu Services Stations Investigation Quality/Assurance Project
Plan, St. Thomas, USVI)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Petersen, Carole: US EPA
Recipient: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Comnittee
Document Number: TUT-006-1387 To 1887 Date: 12/05/91
Title: (Letter regarding Analytical Parameters, Tutu Service Station Investigation, St. Thomas, U.S.
Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty t Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-002-2408 To 2467 Date: 01/16/92
Title: Fourth Sampling Report, October 1991, Tutu Uells Site, St. Thomas, U. S. Virgin Islands
Type: REPORT
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: Danahy, Thomas V.: Geraghty I Miller
Dunnan, Cameron S.: Geraghty & Miller
Nachman, Daniel A.: Geraghty £ Miller
Recipient: none: Tutu Environmental Investigation Coimittee
-------
07/09/96 Index Chronological Order Page: 27
TUTU UELLS SITE Documents
Document Number: TUT-006-0392 To 0434 Date: 02/01/92
Title: Soil Gas Survey, Four Winds Shopping Center and Environs, Tutu Area, Anna's Retreat, U.S.
Virgin Islands
Type: REPORT
Category: 3.4.0.0.0 Rl Reports
Author: none: Target Environmental
Recipient: none: law Offices of John K. Dema, P.C.
Document Number: TUT-007-1282 To 1283 Parent: TUT-007-1279 Date: 02/07/92
Title: U.S. EPA News - For Release: Tutu Well Site on St. Thomas Propoed for Super-fund List
Type: MISCELLANEOUS
Category: 10.6.0.0.0 Fact Sheets and Press Releases
Author: none: US EPA
Recipient: none: none
Document Number: TUT-006-1886 To 1886 Date: 02/12/92
Title: {Letter regarding Tutu Wells Site, St. Thomas, USVI)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Kwan, Caroline: US EPA
Recipient: Callender, Malcolm C.: legislature of the Virgin Islands
Document Number: TUT-003-0787 To 0820 Date: 02/19/92
Title: Administrative Order on Consent in the Matter of the Tutu Wells Site, Anna's Retreat, St.
Thomas, U.S.V.I., ESSO Standard Oil S. A., Limited, Texaco Caribbean Inc., Respondents
Type: LEGAL DOCUMENT
Category: 7.3.0.0.0 Administrative Orders
Author: Muszynski, William J.: US EPA
Recipient: various: ESSO Standard Oil Co. S. A. Ltd.
various: Texaco-Caribbean, Inc.
-------
•37/09/96 Index Chronological Order Page: 28
TUTU WELLS SITE Documents
Docunent Number: TUT-007-0898 To 0932 Date: 02/21/92
Title: (Letter regarding the attached Tutu Wells Site, Administrative Order Index No. II-RCRA-7003
t 9003-92-0401)
Type: LEGAL DOCUMENT
Category: 7.3.0.0.0 Administrative Orders
Author: Chester, Amy R.: Assistant Regional Counsel, EPA
Recipient: Cepeda-Rodriguez.Jose Esq: Goldman I Antonetti
HcCay, Scott'R., Esq.: Goldman t Antonetti
Document Number: TUT-007-1189 To 1189 Date: 02/21/92
Title: (Letter regarding Tutu Hells Site, Administrative Order Index No. II-RCRA-7003 & 9003-92-0401)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Chester, Amy R.: Assistant Regional Counsel, EPA
Recipient: Cepeda-Rodriquez, J., Esq: Goldman & Antonetti
McCay, R. Scott: Texaco
Attached: TuT-007-1190
Document Number: TUT-007-1190 To 1191 Parent: TUT-007-1189 Date: 02/21/92
Title: (Letter regarding Tutu Uells Site)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Chester, Amy R.: Assistant Regional Counsel, EPA
Recipient: Tharpes, Yvonne, Esq.: Department of Planning and Natural Resources (DPNR)
Document Number: TUT-006-1882 To 1885 Parent: TUT-006-1881 Date: 02/24/92
Title: (Letter regarding Tutu Well Field, TID «02-920217/Charge *231-24-028)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Quadri, Syed H.: Lockheed Engineering & Sciences Company
Recipient: Scalise, Laura: US EPA
-------
07/09/96 Index Chronological Order Page: 29
TUTU WELLS SITE Oocunents
Document Number: TUT-006-1881 To 1881 Date: 02/26/92
Title: (Memorandum regarding Tutu Wells Site • Soil and Groundwater Investigation Draft Oversight
Work/QA Plan)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Scalise, Laura: US EPA
Recipient: Kuan, Caroline: US EPA
Attached: TUT-006-1882
Docunent Nutter: TUT-002-0957 To 1094 Date: 03/01/92
Title: Quality Assurance Project Plan, Tutu Service Station Investigation, St. Thomas, U.S. Virgin
Islands
Type: PLAN
Category: 3.1.0.0.0 Sampling and Analysis Plan (SAP)
Author: none: Geraghty & Hi Her
Recipient: none: Tutu Environmental Investigation Committee
Document Number: TUT-003-0530 To 0668 Date: 03/01/92
Title: Tutu Service Station Investigation, Work Plan, St. Thomas, U. S. Virgin Islands
Type: PLAN
Category: 3.3.0.0.0 Work Plan
Author: Oanahy, Thomas V.: Geraghty S Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: none: Tutu Environmental Investigation Committee
Document Number: TUT-006-1851 To 1880 Date: 03/04/92
Title: (Letter with attached figures and correspondence regarding Site Access Agreement, Tutu Environmental
Investigation, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Comnittee
Recipient: Turnbull, Winston: none
-------
07/09/96 Index Chronological Order Page: 30
TUTU WELLS SITE Documents
Document Number: TUT-003-1372 To 1558 Date: 03/10/92
Title: (Tutu Wells Site Administrative Order on Consent Index No. II-RCRA Proceeding 7003 and 9003-92-0401
Monthly Progress Reports for March 1992, to November 1992)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Ramos, Ana Gloria: Tutu Environmental Investigation Committee
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-006-1829 To 1850 Date: 03/10/92
Title: (Letter with attached tables and figures regarding Request for Temporary Authorization of
Air Discharge in the Tutu Area, St. Thomas, U.S. Virgin Islands.)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Ceraghty £ Hitler
Hoffatt, Clinton: Geraghty t Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Shank, Todd: Department of Planning and Natural Resources (DPMR)
Document Number: TUT-006-1818 To 1828 Date: 03/11/92
Title: (Letter with attached tables and figures regarding Request for Temporary Authorization of
Ground-Water Discharge to Sanitary Sewer in the Tutu Area, St. Thomas, U.S. Virgin Islands.)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty t Miller
Moffatt, Clinton: Geraghty & Miller
Nachman, Daniel A.: Geraghty I Miller
Recipient: Francis, Leo: Department of Public Works
Docunent Number: TUT-006-1816 To 1817 Date: 03/20/92
Title: (Letter regarding Tutu Service Station Investigation Work Plan and Quality Assurance Project
Plan, St. Thomas, U.S. Virgin Islands.)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty I Miller
Nachman, Daniel: Geraghty & Miller
Recipient: Kwan, Caroline: US EPA
-------
•37/09/96 Index Chronological Order Page: 31
TUTU UELLS SITE Oocunents
Document Number: TUT-007-1279 To 1280 Date: 03/24/92
Title: U.S. EPA News - For Release: Tuesday, March 24, 1992 - EPA Orders Esso and Texaco to Investigate
the Extent of Chemical Contamination in Turpentine Run Aquifer on St. Thomas
Type: MISCELLANEOUS
Category: 10.6.0.0.0 Fact Sheets and Press Releases
Author: none: US EPA
Recipient: none: none
Attached: TUT-007-1281 TUT-007-1282
Document Number: TUT-007-1186 To 118S Date: 03/24/92
Title: (Letter regarding Tutu Wells Site, Administrative Order Index No. II-RCRA-7003 & 9003-92-0401) '
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Cepeda-Rodriquez, Jose A.: Goldman Antonetti Ferraiuoli Axtmater & Hertell
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-006-1589 To 1590 ' Parent: TUT-006-1566 ' Date: 03/29/92
Title: (Letter regarding Western Auto Site Investigation - March, 1993)
Type: CORRESPONDENCE
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: Green, Bruce K.: Caribbean Hydro-Tech, Inc.
Recipient: Crooke, Clifford: Department of Planning and Natural Resources (DPNR)
Document Number: TUT-003-1593 To 1600 Date: 04/01/92
Title: Tutu Wet Is Super fund Site, Community Relations Update
Type: CORRESPONDENCE
Category: 10.6.0.0.0 Fact Sheets and Press Releases
Author: none: US EPA
Recipient: none: none
-------
'07/09/96 Index Chronological Order Page: 32
TUTU WELLS SITE Documents
Document Number: TUT-003-1559 To 1592 Date: 04/07/92
Title: Connunity Relations Plan, TutuUells Site, St. Thomas, U.S. Virgin Islands
Type: PLAN
Category: 10.2.0.0.0 Coimunity Relations Plan
Author: Masson, Cecilia: COM Federal Programs Corporation
Recipient: Kuan, Caroline: US EPA
document Hunter: TUT-002-1095 To 1139 Date: 04/10/92
Title: Technical Memorandum I, Tutu Service Station Investigation, St. Thomas, U.S. Virgin Islands
Type: PLAN
Category: 3.1.0.0.0 Sampling and Analysis Plan (SAP)
Author: Danahy, Thomas V.: Gerajhty * Miller
Nachman, Daniel A.: Geraghty S Miller
Recipient: none; Tutu Environmental Investigation C omit tee
Document Number: TUT-004-0151 .To 0153 Date: 04/10/92
Title: Comparison of Geraghty and Miller's and COM FPC's Interpretation of Fracture Traces in the
!mediate vicinity of the Tutu UellField Site
Type: GRAPHIC
Author: none: none
Recipient: none: none
Document Number: TUT-004-0154 To 0154 Date: 04/10/92
Title: Specific Comments on the Magnetometer Survey Tutu Service Station Investigation
Type: CORRESPONDENCE
Category: 3.1.0.0.0 Sampling and Analysis Plan (SAP)
Author: none: none
Recipient: none: none
-------
.07/09/96 Inc:> Chronological Order Page: 33
TUTU WELLS SITE Documents
Document Number: TUT-006-1815 To 1815 Date: 04/10/92
Title: (Letter regarding documents to be deposited in the Tutu repository.)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Kuan, Caroline: US EPA
Recipient: Masson, Cecilia A.: COM Federal Programs Corporation
Document Number: TUT-004-0157 To 0158 Date: 04/10/92
Title: (Letter regarding Technical Memorandum I, Tutu Service Station Investigation, St. Thomas,
U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty t, Milter
Moffatt, Clinton: Geraghty & Mi Her
Nachman, Daniel A.: Geraghty t Miller
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-006-1813 To 1814 Date: 04/15/92
Title: (Letter with attached table regarding Aerial Photographs, Tutu Service Station Investigation,
St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty t Miller
Recipient: Odland, Sally: COM Federal Programs Corporation
Document Number: TUT-006-1783 To 1783 Parent: TUT-006-1782 Date: 04/21/92
Title: Temporary Discharge Permit granted to Geraghty and Miller Environmental Services by Government
of The Virgin Islands of the United States
Type: OTHER
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Cornwall, May Adams: Government of The Virgin Islands of the U.S.
Estrill, Gilbert: Government of The Virgin Islands of the U.S.
-------
C7/D9/96 Index Chronological Order Page: 34
TUTU WELLS SITE Documents
Document Hunter: TUT-006-1812 To 1812 Date: 04/21/92
Title: (Letter regarding the completed Community Relations Plan for the Tutu Wells Site and Rl/FS
scoping/informational meeting.)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Kuan, Caroline: US EPA
Recipient: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Committee
Document Number: TUT-006-0358 To 0391 Date: 04/22/92
Title: Brossman Short Fora for the Tutu Wellfield Site, St. Thomas, U.S. Virgin Islands
Type: REPORT
Category: 3.4.0.0.0- RI Reports
Author: none: CON Federal Programs Corporation
Recipient: none: US EPA
Document Number: TUT-003-0732 To 0735 Date: 05/01/92
Title: Fact Sheet, Remedial Investigation/Feasibility Study, Tutu Wells Superfund Site, St. Thomas,
U. S. Virgin Islands
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: none: US EPA
Recipient: none: none
Document Nunber: TUT-OOM299 To 1300 Date: 05/01/92
Title: (Letter regarding Information Repository, Tutu Wells Superfund Site, St. Thomas - Index of
Documents attached)
Type: CORRESPONDENCE
Category: 10.9.0.0.0 Public Correspondence
Author: Masson, Cecilia: Camp Dresser & HcKee (COM)
Recipient: Hodge, Irma: U.S. Virgin Islands Housing Authority
-------
07/09/96 Index Chronological Order Page: 35
TUTU WELLS SITE Docunents
Document Number: TUT-007-1175 To 1182 Parent: TUT-007-1166 Date: 05/01/92
Title: Final Report, Ground Penetrating Radar Investigation, St. Thomas Esso Gas Station Site, St.
Thomas, U.S. Virgin Islands
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: Uindschauer, Robert, P.G.: Subsurface Detection Investigation Inc.
Recipient: Dema, John K., P.C.: Law Offices of John K. Oema, P.C.
Document Number: TUT-006-1784 To 1784 Parent: TUT-006.-1782 Date: 05/06/.92
Title: (Letter regarding Request for Temporary Authorization of Ground-Water Discharge to Sanitary
Sewer in the Tutu Area, St. Thomas, USVI)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Francis, Leo H.: Government of The Virgin Islands of the U.S.
Recipient: Danahy, Thomas V.: .Geraghty & Miller
Document Number: TUT-007-1183 To 1185 Date: 05/11/92
Title: (Letter regarding attached Tutu Well Site, Administrative Order on Consent Index No. Il-RCRA-Proceeding
7003 and 9003-0401, Monthly Progress Report No. 3)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Committee
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-006-1809 To 1811 Date: OS/11/92
Title: (Letter regarding Reimbursement for Drilling water. Tutu, St. Thomas)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Oanahy, Thomas V.: Geraghty t Killer
Moffatt, Clinton: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Gumbs, Samuel: U.S. Virgin Islands Housing Authority
-------
'07/09/96 Index Chronological Order Page: 36
TUTU UELLS SITE Documents
Document Minfeer: TUT-006-1807 To 1808 Date: OS/13/92
Title: (Letter regarding Request for USEPA Commenti on the Quality Assurance Project Plan 4QAPP),
Tutu Service Station Investigation, St. Thomas, U.S. Virgin Islands.)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Oanahy, Thomas V.: Geraghty 4 Miller
Nachman, Daniel A.: Geraghty I Miller
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-006-1805 To 1806 Date: 05/14/92
Title: (Memorandum regarding attached comments on Tutu Wells Site - Soil and Groundwater Investigation
Revised Oversight Uorfc /QA Plan)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Scalise, Laura: US EPA
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-002-2468 To 0201 Date: 05/15/92
Title: Fifth Sampling Report, February 1992, Tutu Wells Site, St. Thomas, U. S. Virgin Islands
Type: REPORT
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: Danahy, Thomas V.: Geraghty & Miller
Ounnan, Cameron S.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: none: Tutu Environmental Investigation Committee
Document Nunber: TUT-006-1803 To 1803 Date: 05/15/92
Title: (Letter regarding Revised Quality Assurance Project Plan (QAPP), Tutu Service Station)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Kuan, Caroline: US EPA
Recipient: Ramos, Anna Gloria, P.E.: Tutu Environmental Investigation Committee
-------
07/09/96 Index Chronological Order Page: 37
TUTU UELLS SITE Documents
Document Number: TUT-006-1804 To 1804 Date: 05/15/92
Title: (Letter regarding Revised Quality Assurance Project Plan (QAPP) dated March 1992)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: kwan, Caroline: US EPA
Recipient: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Contnittee
Document Number: TUT-004-0155 To 0156 Date: 05/17/92
Title: (Letter regarding Relocation of Proposed Monitoring Well MU-110, Tutu Service Station Investigation,
St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Oanahy, Thomas V.: Geraghty & Miller
Moffatt, Clinton: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-004-2000 To 2000 Date: 05/18/92
Title: Site Plan, Tutu Service Station Investigation, St. Thomas, U.S.Virgin Islands, Figure 1.
Type: GRAPHIC
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: none: Geraghty & Miller
Recipient: none: none
Document Number: TUT-006-0323 To 0357 Date: 05/19/92
Title: Revised Brossman Short Form for the Tutu Vettfield Site, St. Thomas, U.S. Virgin Islands
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: COM Federal Programs Corporation
Recipient: none: US EPA
-------
'07/09/96 Index Chronological Order Page: 38
TUTU WELLS SITE Documents
Oocunent Nuifcer: TUT-006-1794 To 1802 Date: 05/19/93
Title: (Letter regarding Addendum to Technical Memorandum I Tutu Service Station Investigation, St.
Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3. 5. 0.0.0 Remedial Investigation Correspondence
Author: Oanahy, Thomas V.: Geraghty t Miller
Hachman, Daniel A.: Geraghty & Miller
Recipient: Kuan, Caroline: US EPA
Document Nunber: TUT-007-1264 To 1266 Date: 05/20/92
Title: U.S. EPA, Region II, Public Informational Meeting for Tutu Wells Superfund Site, Wednesday,
May 20, 1992 - Attendees Sign- in Log
Type: OTHER
Category: 10. 5. 0.0.0 Documentation of Other Public Meetings
Author: none: US EPA
Recipient: none: none
Document Number: TUT-007-1296 To 1298 Date: 05/26/92
Title: (Letter regarding Information Repository - Tutu Hells Superfund Site, St. Thomas - Index of
Documents attached)
Type: CORRESPONDENCE
Category: 10.9.0.0.0 Public Correspondence
Author: Masson, Cecelia: Camp Dresser & McKee (COM)
Recipient: McCauley, Yvonne: Department of Planning and Natural Resources (DPNR)
Document Number: TUT-007-1260 To 1263 Date: 05/27/92
Title: (Letter regarding the attached meeting announcement flyer and poster)
Type: CORRESPONDENCE
Category: 10.3.0.0.0 Public Notice(s)
Author: Graber, Scott B.: Camp Dresser I McKee (COM)
Recipient: Moyik, Catherine E.: US EPA
-------
07/09/96 Index Chronological Order Page: 39
TUTU WELLS SITE Documents
Document Number: TUT-007-1273 To 1278 Date: 05/27/92
Title: (Letter regarding the attached Fact Sheet *2)
Type: CORRESPONDENCE
Category: 10.6.0.0.0 Fact Sheets and Press Releases
Author: Craber, Scott B.: Camp Dresser I KcKee (COM)
Recipient: Moyik. Catherine E.: US EPA
Document Number: TUT-007-1294 To 1295 Date: 05/27/92
Title: (Letter regarding Documents for Tutu Wells Site Repository)
Type: CORRESPONDENCE
Category: 10.9.0.0.0 Public Correspondence
Author: Danahy, Thomas V.: Ceraghty t Miller
Messinger, John E.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: McCauley, Yvonne: Department of Planning and Natural Resources (DPNR)
Document Number: TUT-006-1793 To 1793 Parent: TUT-006-1792 Date: 05/28/92
Title: (Letter regarding Tutu Well Field Site, St. Thomas, US Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Ranganathan, Laic: Lockheed Engineering & Sciences Company
Recipient: Scalise, Laura: US EPA
Document Number: TUT-006-0288 To 0322 Date: 06/04/92
Title: Soil Oversight and Sampling, Soil and Croundwater Investigation, Revised Brossman Short Form
for the Tutu Uellfield Site, St. Thomas, U.S. Virgin Islands
Type: REPORT
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: none: CDN Federal Programs Corporation
Recipient: none: US EPA
-------
O7/09/96 Index Chronological Order Page: 40
TUTU WELLS SITE Documents
Document Number: TUT-006-1792 To 1792 Date: 06/04/92
Title: (Memorandum regarding Tutu Wells Site - Soil & Grounduater Investigation, Revised Oversight
Work/OA Plan)
Type: CORRESPONDENCE . .
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Scalise. Laura: US EPA
.Recipient: Kuan, Caroline: US EPA
Attached: TUT-***-"*"* TUT-006-1793
Document Number: TUT-007-12S7 To 1259 Date: 06/08/92
Title: (Letter regarding the attached newspaper notice for public meeting)
Type: CORRESPONDENCE
Category: 10.3.0.0.0 Public Notice(s)
Author: Graber, Scott B.: Camp Dresser t McKee (COM)
Recipient: Moyik, Catherine E.: US EPA
Document Number: TUT-006-1788 To 1791 Date: 06/12/92
Title: (Letter regarding attached Review of Addendum to Technical Memorandum I Tutu Service Station
Investigation, Tutu Uell Field Site)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial'Investigation Correspondence
Author: Graber, Scott B.: COM Federal Programs Corporation
Recipient: Moyilc, Catherine £.: US EPA
Document Number: TUT-006-1786 To 1787 Date: 06/18/92
Title: (Letter regarding Samples for Surface Soil Risk Assessment, Tutu Service Station Investigation)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Odland, Sally: COM Federal Programs Corporation
Recipient: Kwan, Caroline: US EPA
-------
V7/09/96 . Index Chronological Order Page: 41
TUTU WELLS SITE Documents
Document Number: TUT-007-1292 To 1293 Date: 06/17/92
Title: (Letter regarding documents for Tutu Wells Information Repository - Index of Oocunents attached)
Type: CORRESPONDENCE
Category: 10.9.0.0.0 Public Correspondence
Author: Hasson, Cecilia: Camp Dresser t McKee (COM)
Recipient: McCauley Yvonne: Department of Planning and Natural Resources (DPNR)
Document Number: TUT-006-1785 To 1785 Date: 06/22/92
Title: (Memorandum regarding Tutu Wells Site - Soil & Grounduater Investigation Revised Oversight
Uork/OA Plan)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Scalise, Laura: US EPA
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-007-1168 To 1174 Parent: TUT-007-1166 Date: 07/21/92
Title: In the District Court of the Virgin Islands, Division of St. Thomas - St. John, Master Docket
File No. 1989-107 - In Re: Tutu Water Wells Contamination Litigation
Type: LEGAL DOCUMENT
Category: 7.3.0.0.0 Administrative Orders
Author: Moody, Carey-Anne, Esq.: Law Offices of John K. Dema, P.C.
Recipient: none: various PRPs
Document Nunber: TUT-006-0232 To 0287 Date: 07/23/92
Title: Summary of field Oversight Activities, June 1992, Tutu Wellfield Site, St. Thomas, U.S. Virigin
Islands
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: Odland, Sally: CDH Federal Programs Corporation
Recipient: none: US EPA
-------
07/09/96 Index Chronological Order Page: 42
TUTU WEILS SITE Documents
Document Number: TUT-007-0896 To 0897 Date: 07/23/92
Title: Order TEIC 01-92
Type: LEGAL DOCUMENT
Category: 7.3.0.0.0 Administrative Orders
Author: Adams, Roy E.: Department of Planning and Natural Resources (DPNR)
Recipient: illegible: illegible
Document Ninber: TUT-003-0202 To 0363 Date: 08/01/92
Title: Sixth Sampling Report, May 1992, Tutu Wells Site, St. Thomas, U. S. Virgin Islands
Type: REPORT
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: Oanahy, Thomas V.: Geraghty t Miller
Nachman, Daniel A.: Geraghty & Miller
Parasar, lima: Geraghty & Miller
Recipient: none: Tutu Environmental Investigation Conmittee
Document Number: TUT-003-0738 To 0743 Parent: TUT-003-0736 Date: 08/01/92
Title: Revision to Appendix C, Tutu Service Station Investigation Work Plan, St. Thomas, U.S. Virgin
Islands
Type: PLAN
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: none: Geraghty & Miller
Recipient: none: Tutu Environmental Investigation Committee
Document Number: TUT-006-0212 To 0212 Date: 08/11/92
Title: (Letter forwarding the Sampling Trip Report for July 22 through July 30, 1992)
Type: CORRESPONDENCE
Category: 3.S.0.0.0 Remedial Investigation Correspondence
Author: Odland, Sally: COM Federal Programs Corporation
Recipient: Kinsella, Kathy: US EPA
Attached: TUT-006-0213
-------
< 07/09/96 Index Chronological Order Page: 43
TUTU WELLS SITE Doeuroc-.its
aaasaaassa^aasaaaaaaaaaaassaaaeaeeeaaesasssassssssaseaaasaasaassssaajeassaaaaaaBassaaBcasasaasesasaaaaaaaasaaaaassaaaaaar
Document Number: TUT-006-1778 To 1781 Date: 08/U/92
Title: (Letter regarding Proposed Soil Soring B-U through B-16 Tutu Service Station Investigation,
St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.S.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty S Miller
Nachman, Daniel A.: Geraghty S Miller
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-006-1782 To 1782 Date: 08/14/92
Title: (Memorandum regarding Sewer Connection)
Type: CORRESPONDENCE
Category: 3.S.0.0.0 Remedial Investigation Correspondence
Author: Estrilt, Gilbert: Government of The Virgin Islands of the U.S.
Martin, Tyrone: Government of The Virgin Islands of the U.S.
VanBeverhoudt, Leal: Government of The Virgin Islands of the .U.S.
Recipient: Francis, Hon. Leo: Government of The Virgin Islands of the U.S.
Attached: TUT-006-1783 TUT-OQ6-1784
Document Number: TUT-003-0736 To 0737 Date: 08/17/93
Title: (Letter forwarding the enclosed revision of Appendix C for the Tutu Service Station Investigation
Work Plan, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.S.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty 4 Miller
Reive, Michael D.: Geraghty & Miller
Recipient: Kuan, Caroline: US EPA
Attached: TUT-003-0738
Document Number: TUT-006-1763 To 1763 Date: 08/18/92
Title: (Fax transmittal forwarding attached documents re: surface soil and sludge sampling)
Type: CORRESPONDENCE
Category: 3.S.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty S Miller
Recipient: Kuan, Caroline: US EPA
Attached: TUT-00&-1764 TUT-006-1772
-------
,07/09/96 index Chronological Order Page: 44
TUTU UELLS SITE Documents
Ooeunent Number: TUT-006-1764 To 1771 Parent: TUT-006-1763 Date: 08/18/92
Title: (Letter regarding Proposed Surface Soil and Sludge Sampling Locations, Tutu Service Station
Investigation, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty ( Miller
Recipient: Kuan, Caroline: US EPA
Oocunent Nunber: TUT-006-1772 To 1777 Parent: TUT-006-1763 Date: 08/18/92
Title: (Fax transmittal regarding attached Surface Soil Sampling method)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Odland, Sally: COM Federal Programs Corporation
Recipient: Danahy, Thomas V.: Geraghty & Miller
Document Number: TUT-006-1761 To 1762 Date: 08/21/92
Title: (Letter regarding attached Anticipated Schedule for August through November 1992, Tutu Service
Station Investigation, St. Thomas, Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Oanahy, Thomas V.: Geraghty i Miller
Nachman, Daniel A.: Geraghty & Miller
Document Number: TUT-006-1758 To 1760 Date: 08/26/92
Title: (Letter regarding Abandonment of Monitoring Uell MU-6, Tutu Service Station Investigation,
St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty i Miller
Recipient: Kuan, Caroline: US EPA
-------
-07/09/96 Index Chronological Order Page: 45
TUTU WELLS SITE Documents
Document Umber: TUT-006-1743 To 1757 . Date: 08/31/92
Title: (Letter regarding submittal of attached SAS client request Nos.lUS S 1049)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Desikan, Vasu: Camp Dresser t McKee (COM)
Recipient: Savoia, Peter: US EPA
Document Number: TUT-005-2367 To 0208 Date: 09/01/92
Title: Comprehensive Quality Assurance Plan
Type: PLAN
Category: 3.4.0.0.0 HI Reports
Author: none: Savannah Laboratories Environmental Services, Inc.
Recipient: none: none
Document Number: TUT-006-1741 To 1742 ' - Date: 09/01/92
Title: (Letter regarding Abandonment of Monitoring Well MU-6, Tutu Service Station Investigation,
St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty I Miller
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-006-1737 To 1738 Date: 09/14/92
Title: (Letter regarding attached revised schedule for field uork at the Tutu Service Station Remedial
Investigation)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty t Miller
Nachman, Daniel A.: Geraghty t Miller
Recipient: Kwan, Caroline: US EPA
-------
"07/09/96 Index Chronological Order Page: 46
TUTU WELLS SITE Documents
Document Number: TUT-006-1739 To 1740 Date: 09/H/92
Title: (Letter regarding attached Anticipated Schedule for August through November 1992 Tutu Service
Station Investigation, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Kuan, Caroline: US EPA
Oociment Nunfcer: TUT-006-1734 To 1736 Date: 09/16/92
Title: (Letter with attached table regarding Active Supply Wells in the Tutu Area, St. Thomas, U.S.
Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty 4 Miller
Reive, Michael D.: Geraghty & Miller
Recipient: Adams, Roy t.: Department of Planning and Natural Resources (DPNR)
Docunent Nunber: TUT-007-1166 To 1167 Date: 09/21/92
Title: (Fax Transmittal of Letter regarding Four Winds Plaza Partnership, Request for Inspection
of Esso Tutu Service Station, Tutu, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Garrett, Carlos R., P.E.: Garrett, Vasquez & Asociados
Recipient: Kwan, Caroline: US EPA
Attached: TUT-007-1168 TUT-007-1175
Document Number: TUT-007-1291 To 1291 Date: 10/09/92
Title: (Letter regarding Information Repository, Tutu Wells Superfund Site, St. Thomas)
Type: CORRESPONDENCE
Category: 10.9.0.0.0 Public Correspondence
Author: Masson, Cecilia: Camp Dresser & McKee (CDM)
Recipient: McCauley, Yvonne: Department of Planning and Natural Resources (DPNR)
-------
37/09/96 . Index Chronological Order Page: 47
TUTU WELLS SITE Documents
Document Number: TUT-006-0209 To 0209 Bate: 10/13/92
Title: Weekly Meeting Report • 10, Tutu Site Investigation, St. Thomas, U.S. Virgin Islands
Type: REPORT
Category: 3.4.0.0.0 Rt Reports
Author: Agrelot, Jose C.: Soil Tech
Recipient: none: none
Document Number: TUT-006-0210 To 0211 Date: 10/13/92
Title: Weekly Meeting Report • 9, Tutu Site Investigation, St. Thomas, U.S. Virgin' Islands
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: Agrelot, Jose C.: Soil Tech
Recipient: none: none
Document Number: TUT-007-1164 To 1165 Date: 10/13/92
Title: (Letter regarding Tutu Water Wells Contamination Litigation)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Romero, Eugenic C.: Goldman Antonetti Ferraiuoli Axtmater & Hertell
Recipient: Dema, John K., Esq.: Law Offices of John K. Dema, P.C.
Knoepfel, Richard R.: attorney
Document Number: TUT-006-1731 To 1733 Date: 10/13/92
Title: (Letter regarding attached Monthly Progress Report No. 8, Tutu Well Site)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Committee
Recipient: Kwan, Caroline: US EPA
-------
-37/09/96 Index Chronological Order Page: 48
TUTU UELLS SITE Docunents
Document Number: TUT-007-1163 To 1163 Date: 10/15/92
Title: (Letter regarding Tutu Well Water Contamination Litigation - Request for Site Investigation
at Esso Tutu)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Oema, John K., Esq.: Lau Offices of John K. Dema, P.C.
Recipient: Romero, Eugenio C. Esq.: Goldman Antonetti Ferraiuoli Axtmater & Hertell
Document Number: TUT-004-1996 To 1999 . Date: 10/19/92
Title: Lab Data Management System - Region II, Completed Project Approval and Completed Analysis
Report for Tutu Well Fields.
Type: REPORT
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: Finazzo, Barbara: none
Recipient: none: none
Document Number: TUT-006-1728 To 1730 Date: 10/20/92
Title: (Letter with attached table regarding Relocation of Pumping Tests and Revised Schedule, Tutu
Service Station Investigation, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Moffatt, Clinton: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-006-1724 To 1727 Date: 10/21/92
Title: (Letter with attached table and map regarding Aquifer Pumping Tests, Four Winds Plaza, Tutu,
St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Moffatt, Clinton: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Cepeda, Jose: Goldman Antonetti Cordova & Axtmayer
-------
Q7/09/96 Index Chronological Order Page: 49
TUTU WELLS SITE Documents
Document Number: TUT-006-1722 To 1723 Date: 10/23/92
Title: (Letter with attached map regarding Four Winds Plaza Monitoring Uell Access, Tutu Service
Station Investigation, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Oanahy, Thomas V.: Geraghty & Miller ' '
Moffatt, Clinton: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-004-1986 To 1995 Date: 10/27/92
Title: Concentrations of Volatile Organic Compounds in Soil Samples Collected in August 1992 at the
Tutu Wells Site, St. Thomas, Virgin Islands. •
Type: DATA
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Condition: DRAFT
Author: none: Geraghty & Miller
Recipient: none: none
Document Number: TUT-007-1156 To 1162 Date: 10/27/92
Title: (Letter regarding enclosed correspondence discussing relocation of pumping tests and Fig.
1 Pumping Test Piping Layout)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Kuan, Caroline: US EPA
Recipient: Dema, John K., Esq.: Law Offices of John K. Dema, P.C.
Document Number: TUT-006-1720 To 1721 Date: 10/27/92
Title: (Letter regarding Tutu Aquifer Pumping Tests, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Moffatt, Clinton: Geraghty & Mi Her
Nachman, Daniel A.: Geraghty & Miller
Recipient: Reed, Leonard: Department of Planning and Natural Resources (DPNR)
-------
07/09/96 Index Chronological Order Page: 50
TUTU WELLS SITE Documents
Document Number: TUT-007-1155 To 1155 Date: 10/29/92
Title: (Letter regarding Four Winds Plaza Monitoring Well Access, Tutu Service Station Investigation,
St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Dema, John 1C. Esq.: Law Offices of John K. Dema, P.C.
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-006-1712 To 1713 Date: 10/29/92
Title: (Facsimile regarding Four Winds Monitoring Well Access, Tutu Service Station Investigation,
St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Kuan, Caroline: US EPA
Recipient: Ramos, Ana Gloria: Tutu Environmental Investigation Committee
Document Number: TUT-006-17U To 1719 Date: '10/29/92
Title: (Letter with attached tables regarding Anticipated Schedule for Pumping Tests, Tutu Service
Station Investigation, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Milter
Nachman, Daniel A.: Geraghty & Mi Her
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-006-1707 To 1711 Date: 10/30/92
Title: (Letter regarding Tutu Aquifer Pumping Tests, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Moffatt, Clinton: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Reed, Leonard: Department of Planning and Natural Resources (DPNR)
-------
07/09/96 Index Chronological Order Page: 51
TUTU WELLS SITE Documents
Document Number: TUT-006-1701 To 1706 Date: 11/02/92
Title: (Facsimile regarding Revised Schedule - Pump Tests)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas: Geraghty & Miller
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-006-1698 To 1700 Date: 11/11/92
Title: (Letter regarding attached Monthly Progress Report No. 9, Tutu Well Site)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Committee
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-006-1696 To 1697 Date: 11/13/92
Title: (Memorandum regarding Comments - Tutu Well Site - Draft Work Plan)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Tannenbaum, Larry: US EPA
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-006-1694 To 1695 Date: 11/19/92
Title: (Letter with data regarding Volume and Quality of Water Discharged to Sanitary Sewer, Tutu
Service Station Investigation)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Moffatt, Clinton: Geraghty & Miller
Nachman, Daniel A.: Geraghty 8 Miller
Recipient: Restovic, Hirlco: Department of Public Works
-------
•07/09/96 Index Chronological Order Page: 52
TUTU WELLS SITE Documents
Document Number: TUT-004-1963 To 1985 Parent: TUT-OXK-1959 Date: 11/30/93
Title: Report of Results for the A Winds Western Auto Project.
Type: DATA
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: none: Savannah Laboratories Environmental Services, Inc.
Recipient: Green, Bruce: Caribbean Hydro-Tech, Inc.
Document Number: TUT-005-2167 To 2366 Date: 12/02/92
Title: Summary of Field Oversight Activities June 2 Through November 6, 1992, Tutu Well Field Site,
St. Thomas, U.S. Virgin Islands
Type: REPORT
Category: 3.4.0.0.0 Rl Reports
Author: none: COM Federal Programs Corporation
Recipient: none: US EPA
Document Number: TUT-007-1284 To 12B6 Date: 12/04/92
Title: (Letter regarding Information Repository, Tutu Wells Superfund Site, St. Thomas)
Type: CORRESPONDENCE
Category: 10.9.0.0.0 Public Correspondence
Author: Masson, Cecilia: Camp Dresser & McKee (COM)
Recipient: McCauley, Yvonne: Department of Planning and Natural Resources (DPNR)
Document Number: TUT-007-1290 To 1290 Date: 12/04/92
Title: (Letter regarding Tutu Wells Site Information Repositories)
Type: CORRESPONDENCE
Category: 10.9.0.0.0 Public Correspondence
Author: Masson, Cecelia: Camp Dresser & McKee (COM)
Recipient: Kwan, Caroline: US EPA
-------
07/09/96 Index Chronological Order Page: 53
TUTU WELLS SITE Detriments
Document Number: TUT-004-1959 To 1960 Date: 12/04/92
Title: (Letter regarding Western Auto Site Investigation)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Green, Bruce K.: Caribbean Hydro-Tech, Inc.
Recipient: Crooke, Clifford: Department of Planning and Natural Resources (DPNR)
Attached: TUT-004-1961 TUT-004-1963
Document Number: TUT-007-1287 To 1289 Date: 12/04/92
Title: (Letter regarding Information Repository, Tutu Wells Superfund Site, St. Thomas)
Type: CORRESPONDENCE
Category: 10.9.0.0.0 Public Correspondence
Author: Masson, Cecilia: COM Federal Programs Corporation
Recipient: Hodge, Irma: U.S. Virgin Islands Housing Authority
Document Number: TUT-006-1686 To 1688 Date: 12/09/92
Title: (Letter regarding attached Monthly Progress Report No. 10, Tutu Well Site)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Committee
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-006-1689 To 1693 Date: 12/09/92
Title: (Memorandum regarding attached Tutu Wells Site - CERCLA Technical Systems Audit)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Scalise, Laura: US EPA
Recipient: Kwan, Caroline: US EPA
-------
07/09/96
Index Chronological Order
TUTU WELLS SITE Documents
Page: 54
Document Number: TUT-004-1952 To 1958 Date: 12/12/92
Title: Report of Results for Project #4: winds (U. Auto).
Type: DATA
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: none: Savannah Laboratories Environmental Services, Inc.
Recipient: Green, Bruce: Caribbean Hydro-Tech, Inc.
Document Number: TUT-004-1961 To 1962 Parent: TUT-004-1959 Date: 12/12/92
Title: (Letter regarding Western Auto Site Investigation-December 7-11, 1992)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Green, Bruce 1C.: Caribbean Hydro-Tech, Inc.
Recipient: Crooke, Clifford: Department of Planning and Natural Resources (DPNR)
Document Number: TUT-006-1685 To 1685 Date: 12/14/92
Title: (Letter regarding Tutu Well Site audit report for the CERCLA limited technical systems audit)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Kuan, Caroline: US EPA
Recipient: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Committee
Document Number: TUT-006-1680 To 1684
Date: 12/15/92
Title: (Letter regarding attached Letter Report titled "Technical Review of the Soil Gas Survey,
UST Areas, Four Winds Shopping Center, Performed by Target Environmental Services Inc. in September
1992")
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Graber, Scott B.: CDH Federal Programs Corporation
Recipient: Smieszek, Erwin: US EPA
-------
.07/09/96
Index Chronological Order
TUTU WELLS SITE Docunents
Page: 55
Document Number: TUT-003-03M To 0529 Date: 12/18/92
Title: Seventh Sampling Report, Tutu Wells Site, St. Thomas, U.S. Virgin Islands
Type: REPORT
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: Oanahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Parasar, Uma: Geraghty & Miller
Recipient: none: Tutu Environmental Investigation Committee
Document Number: TUT-006-1227 To 1264 Parent: TUT-006-1226
Title: Water Wells on St. Thomas, U.S. Virgin Islands
Type: REPORT
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Condition: MARGINALIA
Author: Kessler, Richard: US Geological Survey (USGS)
Steiger, Judy I.: US Geological Survey (USGS)
Recipient: none: none
Date: 01/01/93
Document Number: TUT-006-1678 To 1679
Title: (Letter regarding attached Monthly Progress Report No. 11, Tutu Well Site)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Committee
Recipient: Kuan, Caroline: US EPA
Date: 01/11/93
Document Nunber: TUT-005-1803 To 2166
Date: 02/01/93
Title: Technical Memorandum II, Results of the Field Program, Tutu Service Station Investigation,
St. Thomas, U.S. Virgin Island
Type: REPORT
Category: 3.A.0.0.0 RI Reports
Author: none: Geraghty & Miller
Recipient: none: Tutu Environmental Investigation Committee
-------
•07/09/96 Index Chronological Order Page: 56
TUTU WELLS SITE Documents
Document Number: TUT-006-1676 To 1677 Date: 02/10/93
Title: (Letter regarding attached Monthly Progress Report No. 12, Tutu Well Site)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Committee
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-003-2470 To 2475 Date: 02/22/93
Title: (Letter on behalf of Government of the Virgin Islands of the United States, Department of
Education, forwarding attached documents in response to Second Request for Information)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Berne, Alphonse: Potentially Responsible Party (PRP)
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-003-2377 To 2429 Date: 03/01/93
Title: (Letter on behalf of Four Uinds Plaza Partnership forwarding attached documents in response
to Request for Information)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Dema, John K.: attorney
Recipient: Kwan, Caroline: US EPA
Praschak, Andy: US EPA
Document Number: TUT-003-2430 To 2469 Date: 03/01/93
Title: (Letter on behalf of Western Auto forwarding attached documents in response to Request for
Information)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Coon, John R.: attorney
Recipient: Kwan, Caroline: US EPA
-------
07/09/96 Index Chronological Order Page: 57
TUTU WELLS SITE Documents
Document Number: TUT-006-U62 To 1470 Parent: TUT-006-US8 Date: 03/02/93
Title: (Letter with attached data regarding Sampling Procedures and Waste Classification Analytical
Results of Drilling Cuttings, Tutu Service Station Investigation, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Moffatt, Clinton: Geraghty & Miller
Nachman, Daniel: Geraghty & Miller
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-006-1508 To 1516 Parent: TUT-006-1506 Date: 03/02/93 -
Title: (Letter with attached data regarding Sampling Procedures and Waste Classification Analytical
Results of Drilling Cuttings, Tutu Service Station .Investigation, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Moffatt, Clinton: Geraghty I Miller
Nachman, Daniel: Geraghty & Miller
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-006-1665 To 1666 Date: 03/02/93
Title: (Letter regarding Addendum to Revised Draft Technical Memorandum II, Results of the Field
Investigation, Tutu Service Station Investigation, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Burdick, Jeffrey S.: Geraghty & Miller
Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Scalise, Laura: US EPA
-------
07/09/96 Index Chronological Order Page: 58
TUTU WELLS SITE Documents
Document Number: TUT-006-1667 To 1675 Date: 03/02/93
Title: (Letter with attached data regarding Sampling Procedures and Waste-Classification Analytical
Results of Drilling Cuttings, Tutu Service Station Investigation, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Moffatt, Clinton: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-003-2356 To 2376 Date: 03/05/93
Title: (Letter on behalf of Virgin Islands Housing Authority forwarding attached documents in response
to the Second Request for Information)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Francois, Conrad E.: Potentially Responsible Party (PRP)
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-003-2075 To 2355 Date: 03/08/93
Title: (Letter on behalf of Ramsey Motors forwarding attached documents in response to the Second
Request for Information)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Rich, Carol Ann: attorney
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-006-1658 To 1660 Date: 03/08/93
Title: (Letter regarding attached Monthly Progress Report No. 13, Tutu Well Site)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Committee
Recipient: Kwan, Caroline: US EPA
-------
_07/09/96 Index Chronological Order Page: 59
TUTU UELLS SITE Documents
Document Number: TUT-006-1661 To 1664 Date: 03/08/93
Title: (Letter with attached data regarding Analytical Parameters and Sampling Locations, Eighth
Sampling Event, Tutu Uells Site, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-004-1932 To 1951 Date: 03/11/93
Title: O'Henry Data
Type: DATA
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: none: none
Recipient: none: none
Document Number: TUT-006-1652 To 1657 Date: 03/17/93
Title: (Letter with attached data regarding Current MCL Standards)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Committee
Document Number: TUT-006-1648 To 1649 Date: 03/18/93
Title: (Letter regarding Monitoring Well Access, Four Uinds Plaza, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Moffatt, Clinton: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Oema, Jack, Esq.: Law Offices of John K. Dema, P.C.
-------
7/09/96 Index Chronological Order Page: 60
TUTU WELLS SITE Documents
Jocuroent Number: TUT -006- 1650 To 1651 Date: 03/18/93
Title: (Letter regarding Supply Well Access for the Eighth Sampling Event, Four Winds Plaza, St.
Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Ceraghty & Miller
Moffatt, Clinton: Geraghty & Miller
Nschman, Daniel A.: Geraghty & Miller
Recipient: Dema, Jack, Esq.: Law Offices of John K. Dema, P.C.
Document Number: TUT-006-1647 To 1647 Date: 03/22/93
Title: (Letter regarding Notice for Discharge of 1,000 Gallons of Treated Water into the Sanitary
Sewer on April 2, 1992)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Moffatt, Clinton: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Estril, Gilbert: Department of Public Works
Document Number: TUT-006-1645 To 1646 Date: 03/23/93
Title: (Letter regarding attached Monthly Progress Report Mo. 35, Tutu Well Site)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Committee
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-003-2066 To 2074 Date: 03/24/93
Title: (Letter on behalf of Antilles Automotive forwarding attached answers to Request for Information)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Creger, R. Bradley: Potentially Responsible Party (PRP)
Recipient: Kwan, Caroline: US EPA
-------
07/09/96 Index Chronological Order Page: 61
TUTU WELLS SITE Documents
Document Number: TUT-006-1633 To 1638 Date: 03/26/93
Title: (Letter regarding attached Letter Report titled "Technical Review of Rechnical Memorandum
II, Results of the Field Program Tutu Service Station Investigation, St. Thomas, U.S. Virgin
Islands")
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Graber, Scott B.: COM Federal Programs Corporation
Recipient: Smieszek, Eruin: US EPA
Document Number: TUT-006-1639 To 1642 ' Date: 03/26/93
Title: (Letter regarding Review of Technical Memorandum II, Results of the Field Program, Tutu Service.
Station Investigation, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Odland, Sally: COM Federal Programs Corporation
Recipient: Kwan, Caroline: US EPA
Attached: TUT-006-1643
Document Number: TUT-006-1643 To 1644 Parent: TUT-006-1639 Date: 03/26/93
Title: (Letter regarding Technical Review of Technical Memorandum II, Results of the Field Program,
Tutu Service Station Investigation)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Graber, Scott B.: COM Federal Programs Corporation
Recipient: Smieszek, Erwin: US EPA
Document Number: TUT-003-1816 To 2049 Date: 03/31/93 Confidential
Title: (Letter on behalf of Four Winds Plaza Partnership forwarding attached documents as a Supplemental
Response to the Request for Information)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice letters and Responses
Author: Detna, John K.: attorney
Recipient: Kwan, Caroline: US EPA
Praschak, Andy: US EPA
-------
07/09/96 Index Chronological Order Page: 62
TUTU WELLS SITE Documents
Document Number: TUT-003-2050 To 2050 Date: 03/31/93
Title: (Letter forwarding Western Auto's Supplemental Response to Request for Information)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Coon, John R.: attorney
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-003-2051 To 2065 ' Date: 03/31/93
Title: (Letter forwarding Western Auto's Supplemental Response to Request for Information)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Coon, JohnR.: attorney
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-006-1603 To 1632 Date: 03/31/93
Title: (Letter with attached correspondence and data regarding underground storage tanks found at
the Four Winds Shopping Center adjacent to the Western Auto Store.)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Torres, Francis: Goldman Antonetti Cordova & Axtmayer
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-006-1591 To 1602 Date: 04/01/93
Title: (Letter with attached correspondence and data regarding Response to Tutu Wells Site Audit
Report, St. Thomas, U.S. Virgin Islads)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Gulizia, Lidya: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Kuan, Caroline: US EPA
-------
07/09/96
Index Chronological Order
TUTU UELLS SITE Documents
Page: 63
Document Number: TUT-006-1566 To 1588
Date: 04/05/93
Title: (Letter regarding attached Soil Gas Survey for the UST Areas, Four Uinds Shopping Center Tutu
Area, Anna's Retreat, United States Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Torres, Francis: Goldman Antonetti Cordova & Axtmayer
Recipient: Kuan, Caroline: US EPA
Attached: TUT-006-1589
Document Number: TUT-006-1565 To 1565
Date: 04/07/93
Title: (Letter regarding the technical review of the data collected to date pertaining to the contamination
of the Tutu aquifer.)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Reed, Leonard G.: Department of Planning and Natural Resources (OPNR)
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-006-1563 To 1564
Title: (Letter regarding attached Monthly Progress Report No. 14, Tutu Uell Site)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Committee
Recipient: Kuan, Caroline: US EPA
Date: 04/13/93
Document Number: TUT-006-1552 To 1562 Date: 04/15/93
Title: (Letter with attached figures and data regarding Four Uinds Test Uell Logs)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Green, Bruce K.: Caribbean Hydro-Tech, Inc.
Recipient: Dema, Jack, Esq.: Law Offices of John 1C. Oema, P.C.
-------
07/09/96 Index Chronological Order Page: 64
TUTU WELLS SITE Documents
Document Number: TUT-006-1547 To 1551 Date: 04/20/93
Title: (Letter regarding Review of Technical Memorandum II, Results of the Field Program, Tutu Service
Station Investigation, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Condition: MARGINALIA
Author: Petersen, Carole: US EPA
Recipient: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Committee
Document Number: TUT-006-1519 To 1544 Parent: TUT-006-1S17 Date: 05/06/93
Title: (Letter with attached Access Agreement and Standard Operating Procedure regarding Tutu Wells
Site Tank Sampling)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Coon, John R.: Coon & Sanford, Law Offices
Recipient: Dema, John 1C., Esquire: Law Offices of John K. Dema, P.C.
--------.-------•------••------------.-------?--.------------------------------------.-.--- — ............*.._....._.....
Document Number: TUT-006-1517 To 1518 Date: 05/07/93
Title: (Letter regarding Tutu Wells Site/Tank Sampling Request & Procedure)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
• Author: Coon, John R.: Coon & Sanford, Law Offices
Recipient: Praschak, Andrew L., Esq.: US EPA
Attached: TUT-006-1519
Document Number: TUT-006-1545 To 1546 Date: 05/07/93
Title: (Letter regarding the attached Monthly Progress Report No. 15, Tutu Well Site)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Committee
Recipient: Kwan, Caroline: US EPA
-------
07/09/96 Index Chronological Order Page: 65
TUTU WELLS SITE Documents
Document Number: TUT-006-H60 To 1461 Parent: TUT-006-H58 Date: 05/19/93
Title: (Letter regarding Request for Waste Classification and Permission for Disposal)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Killer
Nachman, Daniel A.: Geraghty & Miller
Recipient: Reed, Leonard: Department of Planning and Natural Resources (DPNR)
Document Number: TUT-006-1506 To 1507 Date: 05/19/93
Title: (Letter regarding Request for Waste Classification and Permission for Disposal)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
. Author: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Reed, Leonard: Department of Planning and Natural Resources (DPNR)
Attached: TUT-006-1508
Document Number: TUT-006-1503 To 1505 Date: 05/20/93
Title: (Facsimile regarding Site Access Notice, Four Winds Plaza, St. Thomas, U.S. V.I.)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Dema, John K., Esquire: Law Offices of John K. Dema, P.C.
Recipient: Colon Franceschi, Carlos: Goldman Antonetti Cordova and Axtmeyer
Document Number: TUT-006-H87 To 1502 Date: 05/21/93
Title: (Letter with attached figures regarding Summary of April 27 and 28 Meetings Concerning the
Tutu Service Station Investigation in St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Kuan, Caroline: US EPA
-------
07/Ov/96 Index Chronological Order Page: 66
TUTU WELLS SITE Documents
Document Number: TUT-002-1141 To 1339 Parent: TUT-002-1140 Date: 05/28/93
Title: Technical Memorandum II, Results of the Field Program - Tutu Service Station Investigation,
St. Thomas, U.S. Virgin Islands --Volume 1 of 2
Type: REPORT
Category: 3.1.0.0.0 Sampling and Analysis Plan (SAP)
Author: Surdick, Jeffrey S.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Hitter
Recipient: none: Tutu Environmental Investigation C omit tee
Attached: TUT-002-1330
Document Number: TUT-002-1330 To 1802 Parent: TUT-002-1U1 Date: 05/28/93
Title: Technical Memorandum II, Results of the Field Program - Tutu Service Station Investigation,
St. Thomas, U.S. Virgin Islands --Volume 2 of 2
Type: REPORT
Category: 3.1.0.0.0 Sampling and Analysis Plan (SAP)
Author: Burdick, Jeffrey S. : Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: none: Tutu Environmental Investigation Committee
Document Number: TUT-002-1140 To 1UO Date: 05/28/93
Title: Technical Memorandum II, Results of the Field Investigation, Tutu Service Station Investigation,
St. Thomas, U.S. Virgin Islands
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Oanahy, Thomas V.: Geraghty & Hitler
Nachman, Daniel A.: Geraghty & Miller
Recipient: Kwan, Caroline: US EPA
Attached: TUT-002-1141
Document Number: TUT-006-1471 To 1471 Date: 05/28/93
Title: (Letter regarding Technical Memorandum II, Results of the Field Investigation, Tutu Service
Station Investigation, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Mi Her
Recipient: Kwan, Caroline: US EPA
-------
07/09/96 Index Chronological Order Page: 67
TUTU WELLS SITE Documents
Document Number: TUT-003-1701 To 1815 Date: 06/02/93 Confidential
Title: (Letter on behalf of Four Winds Plaza Partnership forwarding attached documents in the Third
Supplemental Response to Request for Information)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Dema, John K.: attorney
Recipient: Kuan, Caroline: US EPA
Praschak, Andy: US EPA
Document Number: TUT-006-U86 To 1486 Date: 06/02/93
Title: (Facsimile regarding Site Access Notice, Four Winds Plaza, St. Thomas, U.S.V.I.)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Dema, John K., Esquire: Law Offices of John K. Dema, P.C.
Recipient: Cepeda-Rodriguez, Jose A.: Goldman Antonetti Cordova and Axtmeyer
Document Number: TUT-006-U83 To U85 . Date: 06/03/93
Title: (Letter regarding Site Access Notice, Four Winds Plaza, Tutu, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Coon, John R.: Coon & Sanford, Law Offices
Recipient: Coton-Franceschi, Carlos: Goldman Antonetti Cordova and Axtmeyer
Document Number: TUT-006-1421 To 1423 Date: 06/03/93
Title: (Letter regarding the Site Access Agreement, Tutu Environmental Investigation, St. Thomas,
U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Ramos, Ana Gloria: Tutu Environmental Investigation Committee
Recipient: Bukle, Reverand Kenrick: Church of God Holiness
-------
07/09/96
Index Chronological Order
TUTU UELLS SITE Documents
Page: 68
Document Number: TUT-003-1636 To 1638 Date: 06/04/93
Title: (General Notice Letter)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Pavlou, George: US EPA
Recipient: Creger, R. Bradley: Potentially Responsible Party (PRP)
Document Number: TUT-003-1639 To 1641 ' Date: 06/04/93
Title: (General Notice Letter)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Pavlou, George: US EPA
Recipient: Lazare, Paul: Potentially Responsible Party (PRP)
Document Number: TUT-003-1642 To 1644 Date: 06/04/93
Title: (General Notice Letter)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Pavlou, George: US EPA
Recipient: Tillet, Jim: Potentially Responsible Party (PRP)
Document Number: TUT-003-1645 To 1647
Title: (General Notice Letter)
Type: CORRESPONDENCE
Category: 7.7.0.0,0 Notice Letters and Responses
Author: Pavlou, George: US EPA
Recipient: Gal, Andreas: Potentially Responsible Party (PRP)
Date: 06/04/93
-------
.07/09/96
Index Chronological Order
TUTU WELLS SITE Documents
Page: 69
Document Number: TUT-003-1648 To 1650 Date: 06/04/93
Title: (General Notice Letter)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Pavlou, George: US EPA
Recipient: Creque, Linda: Potentially Responsible Party (PRP)
Document Number: TUT-003-1651 To 1653 Date: 06/04/93
Title: (General Notice Letter)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Pavlou, George: US EPA
Recipient: Francois, Conrad: Potentially Responsible Party (PRP)
Document Number: TUT-003-1654 To 1656 Date: 06/04/93
Title: (General Notice Letter)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice .Letters and Responses
Author: Pavlou, George: US EPA
Recipient: Wilson, Daniel H.: Potentially Responsible Party (PRP)
Document Number: TUT-003-1657 To 1659
Title: (General Notice Letter)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Pavlou, George: US EPA
Recipient: Four Winds Plaza Partners: Potentially Responsible Party (PRP)
Date: 06/04/93
-------
07/09/96
Index Chronological Order
TUTU WELLS SITE Documents
Page: 70
Document Number: TUT-003-1660 To 1662
Title: (General Notice Letter)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Pavlou, George: US EPA
Recipient: Ramsey, Rita: Potentially Responsible Party (PRP)
Date: 06/04/93
Document Number: TUT-006-0634 To 0635 Parent: TUT-006-0612
Title: Standard Operating Procedures for Gore-Sorber Screening Modules
Type: OTHER
Author: none: U.I. Gore & Associates, Inc.
Recipient: none: none
Date: 06/04/93
Document Number: TUT-003-1601 To 1601
Date: 06/08/93
Title: (Letter forwarding the Letter Report entitled, "Data Comparison and Evaluation Report for
Groundwater and Soil Split Samples at the Tutu Uellfield Site)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Graber, Scott B.: Camp Dresser & HcKee (COM)
Recipient: Smieszek, Erwin: US EPA
Attached: TUT-003-1602
Document Number: TUT-003-1602 To 1632 Parent: TUT-003-1601 Date: 06/08/93
Title: Letter Report - Data Comparison and Evaluation Report - Tutu Wellfield Site
Type: REPORT
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: none: Camp Dresser & HcKee (COM)
Recipient: none: US EPA
-------
57/09/96 Index Chronological Order Page: 71
TUTU WELLS SITE Documents
Document Number: TUT-006-1390 To 1420 * Date: 06/09/93
Title: (Letter forwarding the enclosed Tutu Wells Site - O'Henry's Monitoring Well Results)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: D'Anna, Nancy: attorney
Recipient: Kuan, Carolyn: US EPA
Document Number: TUT-006-1472 To 1482 Date: 06/11/93
Title: (Letter with attached data and figures regarding the Technical Approach for Monitoring Well
Installation at Western Auto Underground Storage Tanks, Tutu Service Station Investigation,
St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE .
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Ceraghty & Miller
Mozer, Robert: Geraghty & Miller
Recipient: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Committee
Docunent Number: TUT-006-1447 To 1457 Parent: TUT-006-1445 Date: 06/11/93
Title: (Letter regarding Technical Approach for Monitoring Well Installation at Western Auto Underground
Storage Tanks, Tutu Service Station Investigation, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Mozer, Robert: Geraghty & Miller
Recipient: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Committee
Document Nunber: TUT-007-1081 To 1101 Date: 06/14/93
Title: (Letter Regarding Tutu Well Contamination Litigation - Attached: Monitoring Well Construction
Diagrams)
Type: CORRESPONDENCE
Category: 7.6.0.0.0 Documentation of Technical Discussions with PRPs on Response Actions
Author: D'Anna, Nancy, Esq.: attorney
Recipient: Kuan, Caroline: US EPA
-------
07/.09/96 Index Chronological Order Page: 72
TUTU WELLS SITE Documents
Document Number: TUT-003-1698 To 1700 Date: 06/16/93
Title: (Letter on behalf of Ramsey Motors, Inc. in response to Request for Information)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Rich, Carol Ann: attorney
Recipient: Praschak, Andrew L.: US EPA
Document Number: TUT-003-1696 To 1697 Date: 06/17/93
Title: (Letter on behalf of Western Auto in response to Request for Information)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Coon, JohnR.: attorney
Recipient: Praschak, Andrew: US EPA
Document Number: TUT-006-H58 To 1459 ' . Date: 06/17/93
Title: (Letter regarding attached Monthly Progress Report No. 16 for Tutu Well Site)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Committee
Recipient: Kwan, Caroline: US EPA
Attached: TUT-***-*"*** TUT-***-****** TUT-006-H60 TUT-006-U62
Document Number: TUT-003-1633 To 1635 Date: 06/18/93
Title: (General Notice Letter)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Pavlou, George: US EPA
Recipient: Harsch, (Catherine: attorney
-------
07«'09/96 Index Chronological Order Page: 73
TUTU WELLS SITE Documents
Oocunent Number: TUT-003-1695 To 1695 Date: 06/18/93
Title: (Letter on behalf of Jim Tillet in response to 6/4/93 Request for Information)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Myers, Hatheu L.: attorney
Recipient: Praschak, Andrew L.: US EPA
Oocunent Number: TUT-006-1445 To 1445 Date: 06/21/93
Title: (Letter regarding Site Access Notice, Four Winds Plaza, Tutu, St. Thomas, U.S. Virgin Islands).
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Colon-Franceschi, Carlos: Goldman Antonetti Ferraiuoli Axtmater i Hertell
Recipient: Dema, John K., Esq.: Law Offices of John K. Dema, P.C.
Attached: TUT-»**-»»*»** TUT-006-1446 TUT-006-1447
Oocunent Number: TUT-006-1446 To 1446 " Parent: TUT-006-1445 Date: 06/21/93
Title: (Letter regarding Site Access Notice, Four Winds Plaza, Tutu, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Franceschi-Colon, Carlos: Goldman Antonetti Ferraiuoli Axtmater & Hertell
Recipient: Coon, John R., Esq.: Coon & Sanford, Law Offices
Document Number: TUT-007-0941 To 1080 Date: 06/26/93
Title: (Letter regarding Tutu Water Wells Contamination Litigation, St. Thomas, U.S. Virgin Islands
- Attached: Exhibit A - P)
Type: REPORT
Category: 7.6.0.0.0 Documentation of Technical Discussions with PRPs on Response Actions
Author: Dema, John K., Esq.: Law Offices of John K. Dema, P.C.
Recipient: Kwan, Caroline: US EPA
Praschak, Andy, Esq.: Assistant Regional Counsel, EPA
~ s -=
-------
07/09/96 Index Chronological Order Page: 74
TUTU WELLS SITE Documents
Document Number: TUT-004-1416 To 1931 Date: 07/01/93
Title: Letter regarding Tutu Wells Contamination Litigation with attached analytical package including
chain of custody records, volatile data, sample data, standards data, blank data and run logs
for groundwater samples collected in March 1993.
Type: DATA
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: D'Anna, Nancy, Esq.: attorney
Recipient: Kwan, Carolyn: US EPA
Document Number: TUT-006-1427 To 1428 Date: 07/01/93
Title: (Letter regarding Groundwater Sampling Results for the Mathias Well, Tutu Wells Site, St.
Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Burdick, Jeffrey S.: Geraghty & Miller
Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Reed, Leonard: Department of Planning and Natural Resources (OPNR)
Document Number: TUT-006-1429 To 1444 Date: 07/01/93
Title: (Letter regarding Technical Rationale for Proposed Monitoring Well MW-15 at Ramsey Auto Property,
Tutu Service Station Investigation, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Burdick, Jeffreys.: Geraghty & Miller
Danahy, Thomas V.: Geraghty & Miller
Mozer, Robert: Geraghty & Miller
Recipient: Ramos, Ana Gloria: Tutu Environmental Investigation Committee
Document Number: TUT-006-H25 To 1426 Date: 07/06/93
Title: (Letter regarding Site Access Notice, Four Winds Plaza, Tutu)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Dema, John K., Esq.: Law Offices of John K. Dema, P.C.
Recipient: Colon-Franceschi , Carlos: Goldman Antonetti Ferraiuoli Axtmater & Hertell
-------
S7/09/96 Index Chronological Order Page: 75
TUTU WELLS SITE Documents
Document Number: TUT-006-1424 To 1424 Date: 07/15/93
Title: (Letter regarding Site Access Notice, Four Winds Plaza, Tutu)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Dema, John K., Esq.: Law Offices of John K. Oema, P.C.
Recipient: Colon- Franceschi , Carlos: Goldman Antonetti Ferraiuoli Axtmater & Hertell
Document Number: TUT-006-1388 To'1389 Date: 07/17/93
Title: (Letter regarding attached Tutu Well Site Administrative Order on Consent, Index No. II-RCRA-Proceeding
7003 and 9003-92-0401, Monthly Progress Report No. 17)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Committee
Recipient: Kwart, Caroline: US EPA
Document Number: TUT-006-1370 To 1373 Date: 07/21/93
Title: Fax Transmittal of Special Analytical Services - Client Request SAS NO. 1149
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: none: US EPA
Recipient: none: none
Document Number: TUT-004-0047 To 0130 Date: 08/01/93
Title: Removal/Closure Plan for Two Underground Storage Tanks, Four -Winds Plaza, Western Auto, St.
Thomas, USVI
Type: PLAN
Category: 2.1.0.0.0 Sampling and Analysis Plans
Author: ENSR: ENSR
Recipient: none: none
-------
07/09/96
Index Chronological Order
TUTU WELLS S.1TE Oocunents
Page: 76
Document Number: TUT-004-0651 To 0659 Parent: TUT-004-0628 Date: 08/01/93
Title: Supplement Site Assessment Program, Tutu Esso Station, Tutu, St. Thomas, U.S. Virgin Islands.
Type: PLAN
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: none: BiasIand & Bouck Engineers
Recipient: none: Ceraghty & Miller
Document Number: TUT-005-1708 To 1802
Title: IEA-CT Laboratory Quality Assurance Plan
Type: PLAN
Category: 3.4.0.0.0 RI Reports
Author: Culik, Marsha K.: none
Recipient: none: none
Date: 08/02/93
Document Number: TUT-007-1154 To 1154
Title: (Fax Transmittal of letter regarding Tutu Water Wells Litigation)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Dema, John K., Esq.: Law Offices of John K. Dema, P.C.
Recipient: Field, Bob, Esq.: Camp Dresser & McKee (CDH)
Rossman, Brad, Esq.: US Dept of Justice
Simon, Paul, Esq.: US EPA
Wheeler, Lee, Esq.: Roy F. Ueston, Inc.
Date: 08/04/93
Document Number: TUT-004-1410 To 1415
Title: Performance Evaluation Report, Water Supply Study Number WS032.
Type: DATA
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: none: none
Recipient: none: none
Date: 08/10/93
-------
07/09/96 Index Chronological Order Page: 77
TUTU WELLS SITE Documents
Document Number: TUT-006-1378 To 1379 Date: 08/13/93
Title: (Letter regarding attached Tutu Well Site, Administrative Order on Consent, Index No. 11-RCRA-Proceeding
7003 and 9003-92-0401 Monthly Progress Report No. 18)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Committee
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-006-1380 To 1387 Date: 08/13/93
Title: (Letter regarding attached Comments on Technical Memorandum II and RI, Tutu Site, U.S. Virgin
Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Guttierrez, Alberto CPG: H+GCL
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-006-1374 To 1377 Date: 08/18/93
Title: (Letter regarding attached Request for COM and Roy Weston Sampling Results at Tutu Wei (field
Site)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Blazey, Douglas R.: US EPA
Recipient: Dema, John K., Esq.: Lau Offices of John K. Oema, P.C.
Document Number: TUT-007-1102 To 1110 Date: 08/19/93
Title: (Letter regarding the attached Comments on Technical Memo II and RI from the Tutu's Technical
Group)
Type: CORRESPONDENCE
Category: 7.6.0.0.0 Docunentation of Technical Discussions uith PRPs on Response Actions
Author: Kuan, Caroline: US EPA
Recipient: Kuan, Caroline: US EPA
Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Committee
-------
07/09/96 Index Chronological Order Page: 78
TUTU WELLS SITE Documents
Document Number: TUT-005-1322 To 1326 Parent: TUT-005-1305 Date: 08/25/93
Title: Risk Assessment Issue Paper for: Derivation of a Provisional Subchronic RfC for Oi(2-ethylhexyl)phthalate
(CASRN 117-81-7)
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Condition: DRAFT
Author: none: US EPA
Recipient: none: none
Document Number: TUT-004-0142 To 0142 Date: 09/01/93
Title: (Letter regarding the Evaluation and Remediation of Soils at O'Henri Cleaners, Anna's Retreat
St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 2.7.0.0.0 Removal Response Correspondence
Author: O'Anna, Nancy, Esq.: attorney
Recipient: Praschak, Andrew, Esq.: US EPA
Attached: TUT-004-0143
Document Number: TUT-007-1887 To 1894 • Date: 09/01/93
Title: Presumptive Remedies: Policy and Procedures - (Quick Reference Fact Sheet)
Type: OTHER •
Category: 11.2.0.0.0 EPA Regional Guidance
Author: none: US EPA
Re'cipient: none: none
Document Number: TUT-007-1895 To 1920 • Date: 09/01/93
Title: Presumptive Remedies: Site Characterization and Technology Selection for CERCLA Sites with
Volatile Organic Compounds in Soils - (Quick Reference Fact Sheet)
Type: OTHER
Category: 11.2.0.0.0 EPA Regional Guidance
Author: none: US EPA
Recipient: none: none
-------
07/09/96 Index Chronological Order . Page: 79
TUTU WELLS SITE Documents
Document Number: TUT-004-1406 To 1409 Date: 09/03/93
Title: Organic Performance Evaluation Sample, Individual Laboratory Summary Report.
Type: DATA
Category: 3.2.0.0.0 Sampling and Analysts Data/Chain of Custody Forms
Author: none: none
Recipient: none: none
Document Number: TUT-006-1353 To 1369 Date: 09/10/93
Title: (letter regarding attached Tutu Well Site Administrative Order on Consent, Index No. 11-RCRA-Proceeding
7003 and 9003-92-0401 Monthly Progress Report No. 19)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Committee
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-006-1346 To 1352 Parent: TUT-006-1345 Date: 09/22/93
Title: (Letter regarding Tutu Site, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Guttierez, Alberto A. CPG: H+GCL
'Recipient: Hauptman, Helvin: US EPA
Document Number: TUT-006-1345 To 1345 Date: 09/27/93
Title: (Letter regarding Tutu Wells Site)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: ICnutson, Timothy R.: Texaco
Recipient: Praschak, Andrew, Esq.: Assistant Regional Counsel, EPA
Attached: TUT-006-1346
-------
07/09/96 Index Chronological Order Page: 80
' . TUTU WELLS SITE Documents
Document Number: TUT-004-1100 To 1140 Date: 10/01/93
Title: Hydrogeologic Assessment/Source Identification, Upper Tutu Aquifer Basin, Tutu, St. Thomas,
U.S. Virgin Islands.
Type: REPORT
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: none: Blasland & Bouck Engineers
Recipient: none: none
Document Number: TUT-004-1141 To H05 ' Date: 10/01/93
Title: Geohydrologic Analysis and Uater Quality Data for the Upper Tutu Aquifer, St. Thomas, Virgin
Islands, Appendices I - X.
Type: DATA
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: none: Hydrologic Associates U.S.A., Inc.
Recipient: none: Four Winds Shopping Plaza Anna's Retreat, St. Thomas, USVI
none: PIO/Harthman Anna's Retreat, St. Thomas, USVI
Document Number: TUT-006-0577 To 0578 Parent: TUT-006-0570 Date: 10/01/93
Title: Text of an unspecified report regarding Ramsay Motor Company and Antilles/Gasset Motors/Consolidated
Auto Parts Facility.
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: Arthur D. Little, Inc.
Recipient: none: none
Document Number: TUT-007-1921 To 1954 Date: 10/04/93
Title: (Memorandum regarding transmittal of Osuer Directive 9234.2-25: "Guidance for Evaluating the
Technical Impracticability of Ground Water Restoration")
Type: CORRESPONDENCE
Category: 11.5.0.0.0 Technical Sources and Guidance Document Correspondence
Author: Guimond, Richard J.: US EPA
Recipient: Various Regions: US EPA
-------
07/09/96 Index Chronological Order Page: 81
TUTU WELLS SITE Documents
Document Number: TUT-004-0138 To 0141 Date: 10/08/93
Title: (Letter regarding Notification of UST Closure/Removal for Western Auto St. Thomas, US Virgin
Islands)
Type: CORRESPONDENCE
Category: 2.7.0.0.0 Removal Response Correspondence
Author: Coon, John R., Esq.: attorney
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-006-1342 To 1344 Date: 10/08/93
Title: (Letter regarding attached Tutu Well Site, Administrative Order on Consent Index No. II-RCRA-Proceeding
7003 and 9003-92-0401, Monthly Progress Report No. 20)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial .Investigation Correspondence
Author: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Committee
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-004-0137 To 0137 . Date: 10/13/93
Title: (Letter regarding Soil Removal)
Type: CORRESPONDENCE
Category: 2.7.0.0.0 Removal Response Correspondence
Author: D'Anna, Nancy, Esq.: attorney
Recipient: Praschak, Andrew, Esq.: US EPA
Document Number: TUT-007-0936 To 0940 Date: 10/14/93
Title: (Letter regarding Tutu Uellf ields Site, Virgin Islands)
Type: CORRESPONDENCE
Category: 7.6.0.0.0 Documentation of Technical Discussions with PRPs on Response Actions
Author: Gibson, Christopher R.: Archer & Greiner
Recipient: Praschak, Andrew, Esq.: US EPA
-------
(J//09/96 Index Chronological Order Page: 82
TUTU WELLS SITE Documents
Doo/nent Number: TUT-006-1340 To 1341 Date: 10/21/93
Title: (Letter regarding validation of data submitted to EPA in August 1993)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Kwan, Caroline: US EPA
Recipient: O'Anna, Nancy. Esq.: attorney
Document Number: TUT-006-1337 To 1339 Date: 10/26/93
Title: (Letter regarding attached revised schedule (Figure I) for comprehensive RI, Tutu Wells Site,
St. Thomas. USVI)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Gibson, Christopher, Esq.: Archer & Greiner
Knutson, Timoty R., Esq.: Texaco
Recipient: Praschak, Andrew, Esq.: US EPA
Document Number: TUT-006-1316 To 1326 " Parent: TUT-006-1313 Date: 10/28/93
Title: Tutu Wellfield Contamination, St. Thomas, U.S. Virgin Islands
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: none
Recipient: Mr. & Mrs. Torinus: Potentially Responsible Party (PRP)
Document Number: TUT-005-1638 To 1707 Date: 11/01/93
Title: Ground Water Contamination Occurrence and Sources in the Tutu Area, St. Thomas, U.S. Virgin
Islands
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: Arthur 0. Little, Inc.
Recipient: none: Rosenman & Colin
-------
of/09/96 Index Chronological Order . Page: 83
TUTU WELLS SITE Oocunents
Document Number: TUT-005-1349 To 1358 Parent: TUT-005-1305 Date: 11/09/93
Title: Risk Assessment Issue Paper for: Evaluation of Subchronic Oral Systemic Toxicity for Vinyl
Chloride (CASRM 75-01-4)
Type: REPORT
Category: 3.4.0.0.0 Rl Reports
Condition: DRAFT
Author: none: US EPA
Recipient: none: none
Document Number: TUT-005-0313 To 0350 . Date: 11/09/93
Title: Phase I Site Assessment and Interim Remedial Measures Uorkplan, Tutu Texaco Station, Tutu,
St. Thomas, U.S. V.I.
Type: PLAN
Category: 3.3.0.0.0 Work Plan
Author: none: H+GCL
Recipient: none: O'Connor & Lemos - Lau Offices
Document Number: TUT-006-1334 To 1336 Date: 11/09/93
Title: (Letter regarding attached Tutu Well Site, Administrative Order on Consent, Index No. M-RCRA-Proceeding
7003 and 9003-92-0401 Monthly Progress Report No. 21)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
• Author: Ramos, Ana Gloria: Tutu Environmental Investigation Committee
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-006-1333 To 1333 Date: 11/10/93
Title: (Letter regarding Texaco Tutu Service Station)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Ryan, Paul F.: Texaco
Recipient: Kwan, Caroline: US EPA
-------
07/09/96 Index Chronological Order Page: 84
TUTU WELLS SITE Documents
Document Number: TUT-005-02M To 0312 Date: 11/30/93
Title: Letter with attached Assessment/Remediation Work Plan, Western Auto, St. Thomas, USVI
Type: PLAN
Category: 3.3.0.0.0 Work Plan
Author: none: ENSR
Recipient: Crooke, Clifford: Department of Planning and Natural Resources (DPMR)
Document Number: TUT-004-0672 To 1099 Date: 12/01/93
Title: Site Investigation Report, Ramsay Motors, Tutu, St. Thomas, U.S. Virgin Islands.
Type: REPORT
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of C.ustody Forms
Author: none: Cooper Environmental, Inc.
Recipient: none: Campbell, Arellano & Rich
Document Number: TUT-004-2313 To 0032 Parent: TUT-004-2312 Date: 12/01/93
Title: Work Plan for Evaluation and Interim Remediation of Soils O'Henry Laundry, Tutu, St. Thomas,
U.S. Virgin Islands
Type: REPORT
Category: 3.3.0.0.0 Work Plan
Author: none: IT Corporation
Recipient: none: L'Henri, Inc.
Document Number: TUT-006-1313 To 1315 Date: 12/08/93
Title: (Letter regarding enclosed initial report/analysis done by the Institute of Geotechnical Engineering)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Harsch, (Catherine E-: attorney
Recipient: Praschak, Andrew L., Esq.: US EPA
Attached: TUT-006-1316
-------
07/09/96 Index Chronological Order Page: 85
TUTU WELLS SITE Documents
Oocunent Number: TUT -006- 1327 To 1332 Date: 12/08/93
Title: (Letter regarding attached Tutu Well Site. Administrative Order on Consent Index Wo. II-RCRA-Proeeeding
7003 and 9003-92-0401 Monthly Progress Report Mo. 22)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Ramos, Anna Gloria, P.E.: ESSO Standard Oil Co. S. A. Ltd.
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-005-0033 To 0229 Date: 12/20/93
Title: Letter with attached Phase II Remedial Investigation Work Plan, tutu Wells Site, St. Thomas,
U.S. Virgin Islands, Volume 1 of 2.
Type: PLAN
Category: 3.3.0.0.0 Work Plan
Author: Danahy, Thomas V.-. Geraghty & Miller
McDonnell, Marie F.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Kuan, Caroline: US EPA
none: Tutu Environmental Investigation Committee
Document Number: TUT-005-0230 To 0262 Date: 12/20/93
Title: Letter with attached Phase II Remedial Investigation Work Plan, Tutu Wells Site, St. Thomas,
U.S. Virgin Islands, Volume 2 of 2.
Type: PLAN
Category: 3.3.0.0.0 Work Plan
Author: Danahy, Thomas V.: Geraghty & Miller
McDonnell, Marie F.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
none: Tutu Environmental Investigation Committee
Recipient: Kwan, Caroline: US EPA
-------
07/.09/96 Index Chronological Order Page: 86
TUTU WELLS SITE Documents
Document Number: TUT-OOS-0263 To 0263 Date: 12/20/93
Title: Phase II Remedial Investigation Implementation Schedule, Tutu Wells Site, St. Thomas, U.S.
Virgin Islands
Type: GRAPHIC
Category: 3.3.0.0.0 Work Plan
Author: none: Geraghty & Miller
Recipient: none: none
Document Number: TUT-004-0660 To 0671 Date: 12/21/93
Title: Letter with attached letter report representing findings from the GORE-SORBER Screening Survey
(survey) conducted at the Western Auto site in St. Thomas, Virgin Islands.
Type: DATA
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: Stutman, Hark: U.L. Gore & Associates, Inc.
Recipient: Bierschenk, John: ENSR
Document Number: TUT-005-1327 To 1348 Parent: TUT-005-1305 Date: 12/22/93
Title: Risk Assessment Issue Paper for: Evaluation of Subchronic Inhalation Systemic Toxicity for
Vinyl Chloride (CASRN 75-01-4)
. Type: REPORT
Category: 3.4.0.0.0 RI Reports
Condition: DRAFT
Author: none: US EPA
Recipient: none: none
Document Number: TUT-004-2312 To 2312 Date: 12/30/93
Title: (Letter regarding the Transmittal of Work Plan for Evaluation and Interim Remediation of Soils,
O'Henry Laundry, Tutu, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3. 5. 0.0.0 Remedial Investigation Correspondence
Author: Price, Belinda K., R.P.G.: IT Corporation
Recipient: Kuan, Caroline: US EPA
Attached: TUT-004-2313
-------
,07/09/96
Index Chronological Order
TUTU UELLS SITE Documents
Page: 87
Document Number: TUT-006-1308 To 1312
Date: 01/05/94
Title: (Letter with attached data and figures regarding Tank Excavation Sample Data, Tutu Wells Site,
St. Thomas, USVI)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Coyne. David S.: SIas land & Bouck Engineers . .
Maguire, Thomas F.: Blasland & Bouck Engineers
Recipient: Oanahy, Thomas V.: Geraghty & Miller
Document Number: TUT-006-1301 To 1307
Date: 01/10/94
Title: (Letter regarding Addendum to Site Assessment/Remediation Work Plan-Dated November 30, 1993,
Western Auto • Four Uinds Plaza, St. Thomas, USVI)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Bierschenk, John: ENSR
Sarriera, William: ENSR
Recipient: Crooke, Clifford: Department of Planning and Natural Resources (DPNR)
Document Number: TUT-006-1298 To 1300
Title: (Letter regarding attached Monthly Progress Report No. 23, Tutu Well Site)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Committee
Recipient: Kuan, Caroline: US EPA
Date: 01/12/94
Document Number: TUT-004-2311 To 2311
Date: 01/21/94
Title: List of attendees at the discussions with TEIC and its contractor on Phase II workplan for
the Tutu Wells Site, St. Thomas, USVI.
Type: MISCELLANEOUS
Category: 3.3.0.0.0 Work Plan
Author: none: US EPA
Recipient: none: none
-------
oV/09/96 Index Chronological Order Page: 88
TUTU WELLS SITE Documents
Document Number: TUT-006-1290 To 1297 Date: 01/24/94
Title: (Letter regarding attached Addendum to Appendix A - Soil Gas Survey Procedures, Phase II Remedial
Investigation (RI) Work Plan, Tutu Wells Site, St. Thomas, U.S. Virgin Islands.)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Killer
Nachman, Daniel A.: Geraghty & Miller
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-005-1636 To 1636 . Date: 01/25/94
Title: Phase II Remedial investigation, Virgin Island Housing Authority Soil-Gas Survey Grid, Tutu
Wells Site, St. Thomas, U.S. Virgin Islands
Type: GRAPHIC
Category: 3.4.0.0.0 RI Reports
Author: none: Geraghty & Miller
Recipient: none: none
Document Number: TUT-005-1637 To 1637 Date: 01/25/94
Title: Phase II Remedial Investigation, Cirriculum Center (Former Laga Facility) Soil-Gas Survey
Grid, Tutu Wei Is Site, St. Thomas, U.S. Virgin Islands
Type: GRAPHIC
Category: 3.4.0.0.0 RI Reports
Author: none: Geraghty & Miller
Recipient: none: none
Document Number: TUT-006-1285 To 1289 Date: 01/27/94
Title: (Letter regarding Application for an Amendment to DPNR Earth Charge Permit No. STT-281-93,
Tutu Wells Site, Anna's Retreat, St. Thomas, USV1.)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Colberg, Alberto: Geraghty & Miller
Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel: Geraghty & Miller
Recipient: Allen, Cynthia V.: Department of Planning and Natural Resources (DPNR)
-------
37/09/96
Index Chronological Order
TUTU WELLS SITE Documents
Page: 89
Document Number: TUT-006-1283 To 1284
Title: (Letter regarding Reports for Review)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty S Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Kuan, Caroline: US EPA
Dace: 01/31/94
Document Number: TUT-004-0628 To 0650
Date: 02/01/94
Title: Transmittal with attached Site Assessment Program, Tutu Esso Station, Tutu, St. Thomas, U.S.
Virgin Islands.
Type: PLAN
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: Maguire, Thomas F.: Blasland & Bouck Engineers
Recipient: Danahy, Thomas V.: Geraghty & Miller
Attached: TUT-004-0651
Document Number: TUT-006-1282 To 1282
Date: 02/04/94
Title: (Letter regarding a request for additional raw data for the matrix spike data associated with
sample ORM01 for validation by the EPA)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Kwan, Caroline: US EPA
Recipient: D'Anna, Nancy, Esq.: attorney
Document Number: TUT-007-1151 To 1153
Title: (Letter regarding amendments to proposed site access and release agreement)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Francois, Conrad, E. II: U.S. Virgin Islands Housing Authority
Recipient: Danahy, Thomas V.: Geraghty & Miller
Date: 02/11/94
-------
Or/09/96
Index Chronological Order
TUTU WELLS SITE Documents
Page: 90
Document Number: TUT-006-1279 To 1281 Date: 02/14/94
Title: (Letter regarding attached Monthly Progress Report No. 24, Tutu Well Site)
Type: CORRESPONDENCE
Category:"3.5.0.0.0 Remedial Investigation Correspondence
Author: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Committee
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-006-1278 To 1278 Date: 02/15/94
Title: (Letter regarding Phase II Field Activities at Tutu Well Site)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Kuan, Caroline: US EPA
Recipient: Allen, Cynthia V.: Department of Planning and Natural Resources (DPNR)
Document Number: TUT-006-1277 To 1277 Date: 02/18/94
Title: (Letter regarding Revised Schedule for Field Activities, Tutu Well Site, St. Thomas, USVI.)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Colberg, Alberto: Geraghty & Miller
Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-006-1273 To 1276
Date: 02/22/94
Title: (Letter with attached sample location figures regarding Transmittal of Soil and Groundwater
Analytical Data and Slug Test Data for O'Henry Laundry, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Price, Belinda K., R.P.G.: IT Corporation
Recipient: Kwan, Caroline: US EPA
-------
J//09/96 Index Chronological Order Page: 91
TUTU UELLS SITE Documents
Document Number: TUT-004-0617 To 0627 Date: 03/02/94
Title: Data Assessment, Tutu Wells Site.
Type: REPORT
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: Taylor, Karen: none
Document Number: TUT-006-1223 To 1224 Parent: TUT-006-1221 Date: 03/02/94
Title: (Fax memorandum regarding Property Atfcess to Proposed Monitoring Well Locations MW-20, MW-20D,
and MU-23D)
Type: CORRESPONDENCE
Category: 3.S.0.0.0 Remedial Investigation Correspondence
Author: Colberg, Alberto: none
Recipient: Danahy, Tom: Geraghty & Hi Her
Knutson, Tim: Texaco
Ramos, Ana Gloria: ESSO Standard Oil Co. S. A. Ltd.
Ryan, Paul: Texaco
Document Number: TUT-006-1272 To 1272 Date: 03/09/94
Title: (Letter regarding Tutu Water Uells Contamination, St. Thomas, United States Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Dema, John K., Esquire: Law Offices of John K. Deroa, P.C.
Recipient: Kwan, Caroline: US EPA
Praschak, Andy, Esquire: US EPA
Document Number: TUT-006-1269 To 1271 Date: 03/10/94
Title: (Letter with attached map regarding Request for Approval Regarding Proposed Monitoring Well
MU-23D and Newly Identified Delegarde Supply Well, Southeast Area of Tutu Well Site, St. Thomas,
Virgin Islands.)
Type: CORRESPONDENCE
Category: 3.S.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Hi Her
Nachman, Daniel A.: Geraghty & Killer
Recipient: Kwan, Caroline: US EPA
-------
37/09/96 Index Chronological Order Page: 92
TUTU WELLS SITE Documents
Document Number: TUT-006-1265 To 1268 Date: 03/10/94
Title: (Letter regarding Revised Schedule, Phase II Remedial Investigation, Tutu Wells Site, St.
Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Oanahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-004-2310 To 2310 Date: 03/11/94
Title: Revised Phase II Remedial Investigation Implementation Schedule, Tutu Wells Site, St. Thomas,
U.S. Virgin Islands
Type: GRAPHIC
Category: 3.3.0.0.0 Work Plan
Author: none: Geraghty & Miller
Recipient: none: none
Document Number: TUT-006-1221 To 1221 Date: 03/11/94
Title: (Letter forwarding the enclosed agenda for the PRP group meeting on March 24 in St. Thomas)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Knutson, Timothy R.: Texaco
Recipient: Prashak, Andrew: US EPA
Attached: TUT-006-1222 TUT-006-1223
Document Number: TUT-006-1225 To 1225 Date: 03/11/94
Title: (Letter regarding the Remediation Plan)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: D'Anna, Nancy: attorney
Recipient: Kuan, Carolyn: US EPA
Praschak, Andrew: attorney
-------
-07/09/96 Index Chronological Order Page: 93
TUTU UELLS SITE Documents
Document Number: TUT-006-1226 To 1226 Date: 03/11/94
Title: (Letter regarding Request a Storm Sewer Trench in the Tutu Uells Site Area, St. Thomas, U.S.
Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Green, Bruce: none
Attached: TUT-006-1227
Document Number: TUT-005-1307 To 1321 Parent: TUT-005-1305 Date: 03/14/94
Title: Risk Assessment Issue Paper for: Derivation of a Provisional Subchronic Inhalation RfC for
Benzene (CASRN 71-43-2)
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Condition: DRAFT
Author: none: US EPA"
Recipient: none: none
Document Number: TUT-006-1218 To 1218 Date: 03/14/94
Title: (Letter forwarding the Monthly Progress Report No. 25)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Ramos, Ana Gloria: Tutu Environmental Investigation Committee
Recipient: Kwan, Caroline.: US EPA
Attached: TUT-006-1219
Document Number: TUT-006-1219 To 1220 Parent: TUT-006-1218 Date: 03/14/94
Title: Monthly Progress Report No. 25, March 14, 1994
Type: REPORT
Category: 3.4.0.0.0 Rl Reports
Author: Ramos, Ana Gloria: Tutu Environmental Investigation Committee
Recipient: none: US EPA
-------
87/09/96
Index Chronological Order
TUTU WELLS SITE Documents
Page: 94
Oocunent Number: TUT-006-1216 To 1217
Date: 03/17/94
Title: (Letter regarding Approval of the Phase II Remedial Investigation Implementation Workplan
for the Tutu Wells Site, St. Thomas)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Petersen, Carole: US EPA
Recipient: Ramos, Ana Gloria: Tutu Environmental Investigation Committee
Document Number: TUT-006-1144 To 1144
Parent: TUT-006-1134
Date: 03/21/94
Title: Phase II Remedial Investigation Curriculum Center (Former Laga Facility), Soil-Gas Survey
Results, Tutu Wells Site, St. Thomas, U.S. Virgin Islands
Type: GRAPHIC
Category: 3.4.0.0.0 RI Reports
Author: none: Geraghty & Miller
Recipient: none: none
Document Number: TUT-006-1145 To 1145
Parent: TUT-006-1134
Date: 03/21/94
Title: Figure II: Phase II Remedial Investigation, Virgin Islands Housing Authority, Soil-Gas Survey
Grid, Tutu Wells Site, St. Thomas, U.S. Virgin Islands
Type: GRAPHIC
Category: 3.4.0.0.0 RI Reports
Author: none: Geraghty & Miller
Recipient: none: none
Document Number: TUT-006-1214 To 1215
Date: 03/21/94
Title: (Letter regarding Monitoring Wells MW-23D, MW-20 and HW-20D, Tutu Wells Site, St. Thomas,
U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Oanahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Kwan, Caroline: US EPA
-------
07/09/96 Index Chronological Order Page: 95
TUTU WELLS SITE Documents
Document Number: TUT-006-1134 To 1140 Date: 03/22/94
Title: (Letter regarding Soil Gas Survey Report for the Curriculum Center and Virgin Islands Housing
Authority, Tutu Wells Site, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Burke, John: Geraghty & Miller
Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty £ Hitler
Recipient: Kuan, Caroline: US EPA
Attached: TUT-006-W1 TUT -006-1 143 . TUT-006-1144 TUT-006-1145 TUT-006-1K6
Document Number: TUT-007-0933 To 0935 Date: 03/24/94
Title: Meeting Between EPA, DPNR, and the Tutu Well Fields PRP Group - March 24, 1994 - 9:00 at Misky
Center. Attached: 1. TEIC Meeting with EPA and DPNR at DPNR Offices, St. Thomas, March 24,
1994 2. Log of Attendees
Type: OTHER
Category: 7.6.0.0.0 Documentation of Technical Discussions with PRPs on Response Actions
Author: none: US EPA
Recipient: none: none
Document Number: TUT-004-2305 To 2305 Date: 04/07/94
Title: (Letter regarding the Transmittal of Responses to EPA Comments and Work Plan for Evaluation
and Interim Remediation of Soils, O'Henry Laundry, Tutu, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3. 5. 0.0.0 Remedial Investigation Correspondence
Author: Price, Belinda <., R.P.G.: IT Corporation
Recipient: Kuan, Caroline: US EPA
Attached: TUT-004-2306
Document Number: TUT-006-1131 To 1133 Date: 04/08/94
Title: (Letter regarding Monthly Status Report No. 26, Tutu Wells Site, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Milter
Nachman, Daniel A.: Geraghty & Miller
Recipient: Kwan, Caroline: US EPA
-------
07/09/96 Index Chronological Order Page: 96
TUTU WELLS SITE Documents
Document Number: TUT-006-1128 To 1130 Date: 04/12/94
Title: (Letter regarding the Appointment of a New Designated Coordinator, Tutu Wells Site, St. Thomas,
U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Gibson, Christopher: Archer & Greiner
Document Number: TUT-006-1124 To 1125 Date: 04/13/94
Title: (Letter regarding the Proposed Supply Well Pumpage Impact Study, Four Winds Plaza, Tutu Wells -
Site)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Potenza, John C.: Geraghty & Miller '
Recipient: Smith, Richard: Law Offices of John K. Dema, P.C.
Document Number: TUT-006-1126 Tp 1127 Date: 04/13/94
Title: (Letter regarding the Proposed Supply Well Pumpage Impact Study, Tutu Wells Site)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Potenza, John C.: Geraghty & Miller
Recipient: Turnball, Wallace: none
Document Number: TUT-006-1122 To 1123 Date: 04/26/94
Title: (Letter forwarding a copy of the site access agreement)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Condition: MISSING ATTACHMENT
Author: Musiker, Laurie B.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Harvey, Inez: none
-------
07/09/96 Index Chronological Order Page: 97
TUTU WELLS SITE Documents
Document Number: TUT-006-1084 To 108S Parent: TUT-006-1083 Date: 04/30/94
Title: Tutu Well Fields Project Progress Report, April 1994
Type: REPORT
Category: 3.4.0.0.0 Rl Reports
Author: none: de maxim's, inc.
Recipient: none: US EPA
Document Number: TUT-007-1149 To 1150 Date: 05/03/94
Title: (Letter re: In the Hatter of the Tutu Wells Site, Administrative Order on C.onsent Index No.
II-RCRA-Proceeding 7003 & 9003-92-0401)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Gibson, Christopher R.: Archer & Greiner
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-006-1121 To 1121 Parent: TUT-006-1088 Date: 05/03/94
Title: Figure 2: Proposed Monitoring Well KW-24 Uell Construction, Tutu Wells Site, St. Thomas,
U.S. Virgin Islands
Type: GRAPHIC
Category: 3.4.0.0.0 RI Reports
Condition: DRAFT
Author: none: Geraghty & Miller
Recipient: none: 'none
Document Number: TUT-006-1086 To 1086 Date: 05/05/94
Title: (Letter regarding Comprehensive Groundwater Sampling Event, Tutu Wells Site, St. Thomas, U.S.
Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Seibel, Geoffrey C.: de maximis, inc.
Recipient: Kwan, Caroline: US EPA
Attached: TUT-006-1087
-------
07/09/96 Index Chronological Order Page: 98
TUTU WELLS SITE Documents
Document Number: TUT-006-1088 To 1089 Date: 05/05/94
Title: (Letter regarding the Excavation at Western Auto, Tutu Wells Site, St. Thomas, U.S. Virgin
Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Condition: MARGINALIA; HISSING ATTACHMENT
Author: Danahy, Thomas V.: Geraghty & Miller
Machman, Daniel A.: Geraghty & Miller
O'Oetl, Brent: Geraghty S Mi I lei-
Recipient: Kwan, Caroline: US EPA
Attached: TUT-006-1090 TUT-006-1120 TUT-006-1121
Document Number: TUT-006-1075 To 1076 Date: 05/10/94
Title: (Letter regarding Sampling of Water Supply Wells During May/June 1994, Tutu Wells Site, St.
Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Colberg, Alberto: Geraghty & Miller
Oanahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Steele, Elin W.: none
Document Number: TUT-006-1077 To 1078 Date: 05/10/94
Title: (Letter regarding Sampling of Water Supply Wells During May/June 1994, Tutu Wells Site, St.
Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Colberg, Alberto: Geraghty & Miller
Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: none: none
-------
'07/09/96 Index Chronological Order Page: 99
TUTU WELLS SITE Documents
Document Number: TUT-006-1079 To 1080 Date: 05/10/94
Title: (Letter regarding Sampling of Water Supply Wells During Hay/June 1994, Tutu Wells Site, St.
Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: CoI berg, Alberto: Geraghty & Miller
Danahy, Thomas V.: Geraghty & Miller ' '
Nachman, Daniel A.: Geraghty & Miller
Recipient: Tillet, James: none,
Document Number: TUT-006-1081 To 1082 Date: 05/10/94
Title: (Letter regarding Sampling of Water Supply Wells During May/June 1994, Tutu Wells Site, St.
Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 5.4.0.0.0 Record of Decision Correspondence
Author: Colberg, Alberto: Geraghty & Mi Her
Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Gasset, Thomas A.: none
Document Number: TUT-006-1083 To 1083 Date: 05/10/94
Title: (Letter-forwarding the Monthly S'tatus Report No. 27, Tutu Wells Site, St. Thomas, U.S. Virgin
Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: McBurney, John P.: de maximis, inc.
Seibel, Geoffrey C.: de maximis, inc.
Recipient: 1C wan, Caroline: US EPA
Attached: TUT-006-106%
Document Number: TUT-006-1063 To 1064 Date: 05/11/94
Title: (Letter regarding Sampling of Water Supply Wells During May/June 1994, Tutu Wells Site, St.
Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Colberg, Alberto: Geraghty & Hi Her
Oanahy, Thomas V.: Geraghty & Miller
-------
"07/09/96 Index Chronological Order Page: 100
TUTU WELLS SITE Documents
(Continued)
Document Number: TUT-006-1063 To 1064 Date: 05/11/94
Author: Nachman, Daniel A.: Geraghty & Miller
Recipient: Simmonds, Ralda V.: none
Document Number: TUT-006-1065 To 1066 Date: 05/11/94
Title: (Letter regarding Sampling of Water Supply Wells During Hay/June 1994, Tutu Wells Site, St.
Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE . .
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Colberg, Alberto: Geraghty & Miller
Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Hodge, Cynthia: none
Document Number: TUT-006-1067 To 1068 Date: 05/11/94
Title: (Letter regarding Sampling of Water Supply Wells During May/June 1994, Tutu Wells Site, St.
Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Colberg, Alberto: Geraghty & Miller
Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Turnbull, Horace: none
Document Number: TUT-006-1069 To 1070 Date: 05/11/94
Title: (Letter regarding the Sampling of Water Supply Wells During May/June 1994, Tutu Wells Site,
St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Colberg, Alberto: Geraghty & Miller
Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Turnball, Wallace: none
-------
07/09/96 Index Chronological Order Page: 101
TUTU WELLS SITE Documents
Oocunent Number: TUT-006-1071 To 1072 Date: 05/11/94
Title: (Letter regarding Sampling of Water Supply Wells During May/June 1994, Tutu Wells Site, St.
Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Colberg, Alberto: Geraghty & Miller
Oanahy, Thomas V.: Geraghty & Hi Her
Nachman, Daniel A.: Geraghty & Miller
Recipient: Knoepfel, Richard R.: attorney
Document Nunber: TUT-006-1073 To 1074 Date: 05/11/94
Title: (Letter regarding Sampling of Water Supply Wells During May/June 1994, Tutu Wells Site, St.
Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Colberg, Alberto: Geraghty & Milter
Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Harvey, Inez: none
Document Number: TUT-006-1059 To 1060 . Date: 05/12/94
Title: (Letter regarding Sampling of Water Supply Wells During May/June 1994, Tutu Wells Site, St.
Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Colberg, Alberto: Geraghty & Miller
Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Smith, Dennis: none
-------
'07/09/96 Index Chronological Order Page: 102
TUTU WELLS SITE Documents
Document Number: TUT-006-1061 To 1062 Date: 05/12/94
Title: (Letter regarding Sampling of Water Supply Wells During May/June 1994, Tutu Wells Site, St.
Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Colberg, Alberto: Geraghty & Miller . .
Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Jones, Ura: none
Document Number: TUT-006-1054 To 1055 Date: 05/13/94
Title: (Letter regarding Access to Monitoring Well "KFC Corp."; Tutu Uells Site, St. Thomas, U.S.
Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Mi Her
Stern, David E.: Geraghty & Miller
Recipient: Human, Robert J-: attorney
Attached: TUT-006-1056
Document Number: TUT-006-1058 To 1058 Date: 05/13/94
Title: (Transmittal sheet regarding Geraghty & Miller, Inc.'s proposed 524.2 methodology for Delegarde,
Harthman (Wilfred), Harthman (Crosher), K.F. Chicken, VIHA I, and VIHA III)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Condition: MARGINALIA
Author: Seibel, Geoff: de maximis, inc.
Recipient: Kuan, C.: US EPA
Odland, S.: COM Federal Programs Corporation
Ryan, P.: Texaco
Shottroff, A.: Department of Planning and Natural Resources (DPNR)
-------
37/09/96 Index Chronological Order Page: 103
TUTU UELLS SITE Documents
Document Number: TUT-007-1U7 To 1U8 Parent: TUT-007-1U6 Date: 05/18/94
Title: (Letter regarding perraenent permit for remediation activities)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: O'Toole, Patrick, P.G.: Blasland & Bouck Engineers
Recipient: Schottroff, Adrian: Department of Planning and Natural Resources (DPNR)
Document Number: TUT-006-1052 To 1053 . ' Date: 05/23/94
Title: (Letter regarding Sampling of Water Supply Uells During May/June 1994, Tutu Wells Site, St.
Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Colberg, Alberto: Geraghty & Miller
Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Law, Michael: US Dept of Justice
Document Number: TUT-004-0136 To 0136 Date: OS/24/94
Title: (Letter regarding Tanks Removed from Vernon Morgan Texaco Station)
Type: CORRESPONDENCE
Category: 2.7.0.0.0 Removal Response Correspondence
Author: Knutson, Timothy R.: Texaco
Recipient: Praschak, Andrew L., Esq.: US EPA
Document Number: TUT-007-1146 To 1146 Date: 05/25/94
Title: (Letter regarding Tutu Uells Contamination Litigation)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Capdeville, Douglas L.: attorney
Recipient: Reed, Leonard G.: Department of Planning and Natural Resources (DPNR)
Attached: TUT-007-1147
-------
67/09/96 Index Chronological Order Page: 104
, TUTU WELLS SITE Documents
Document Number: TUT-006-1050 To 1051 Date: 05/25/94
Title: (Letter regarding Conditional Approval of the Work Plan for Evaluation and Interim Remediation
of Soils at O'Henry Laundry, Tutu, St. Thomas, U.S. V.I.)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Petersen, Carole: US EPA
Recipient: D'Anna, Nancy: attorney
Document Number: TUT-004-0248 To 0616 Date: 06/01/94
Title: Closure Report for Underground Storage Tanks, Four Uinds Plaza, Western Auto, St. Thomas,
U.S. Virgin Islands.
Type: REPORT
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: none: ENSR
Recipient: none: none
Document Number: TUT-004-2001 To 2304 Date: 06/01/94
Title: Work Plan for Evaluation of Interim Remediation of Soils, O'Henry Laundry, Tutu, St. Thomas,
U.S. Virgin Islands
Type: REPORT
Category: 3.3.0.0.0 Work Plan
Author: none: IT Corporation
Recipient: none: L'Henri, Inc.
Document Number: TUT-004-0134 To 0135 Date: 06/10/94
Title: (Letter regarding Closure Report for Underground Storage Tanks Western Auto, St. Thomas, US
Virgin Islands)
Type: CORRESPONDENCE
Category: 2.7.0.0.0 Removal Response Correspondence
Author: Coon, John R.: attorney
Recipient: Kuan, Caroline: US EPA
-------
• 07/09/96 Index Chronological Order Page: 105
TUTU WELLS SITE Documents
Document Number: TUT-005-1359 To 1635 Date: 06/10/94
Title: Phase I Remedial Investigation Report, St. Thomas, U.S. Virgin Islands
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: GCL Environmental Science and Engineering
Recipient: none: Texaco-Caribbean, Inc.
Document Number: TUT-006-1047 To 1047 Date: 06/10/94
Title: (Letter forwarding Monthly Status Report No. 28, Tutu Uells Site, St. Thomas, U.S. Virgin
Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: McBurney, John P.: de maximis, inc.
Seibel, Geoffrey C.: de maximis, inc.
Recipient: Kwan, Caroline: US EPA
Attached: TUT-006-1048
Document Number: TUT-006-1048 To 1049 Parent: TUT-006-1047 Date: 06/10/94
Title: Tutu Well Fields Project Progress Report, May 1994
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: de maximis, inc.
Recipient: none: US EPA
Document Number: TUT-007-1139 To 1145 Date: 06/28/94
Title: (Fax Transmittal regarding attached 6/21/94 letter discussing Tutu Water Wells Litigation)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Praschak, Andrew: Assistant Regional Counsel, EPA
Recipient: Kwan, Caroline: US EPA
-------
"07/09/96 Index Chronological Order Page: 106
TUTU WELLS SITE Documents
Document Number: TUT-006-1040 To 1041 Parent: TUT-006-1039 Date: 06/30/94
Title: Tutu Well Fields Project Progress Report, June 1994
Type: REPORT
Category: 3.4.0.0.0 Rt Reports
Author: none: de maximis, inc.
Recipient: none: US EPA
Document Number: TUT-006-1046 To 1046 - Date: 06/30/94
Title: (Letter regarding the Transmittal of Work Plan for Evaluation and Interim Remediation of Soils,
O'Henry Laundry, Tutu, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Price, Belinda K. : IT Corporation
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-006-1042 To 1045 Date: 07/06/94
Title: (Letter regarding Grounduater Monitoring, Tutu Uells Site Remedial Investigation)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Morales, Uanda I.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Mi Her
Recipient: Reed, Leonard: Department of Planning and Natural Resources (OPNR)
Simmonds, Ralda V.: U.S. Virgin Islands Housing Authority
Document Number: TUT-007-0833 To 0870 Date: 07/08/94
Title: (Letter regarding the attached Revised Pathway Exposure Report Draft Endangerment Assessment,
Tutu Uells Site, St. Thomas, Virgin Islands)
Type: CORRESPONDENCE
Category: 7.2.0.0.0 Endangerment Assessments
Author: Goltz, Robert 0., P.E.: Camp Dresser & HcKee (COM)
Recipient: Kollar, Keith: US EPA
-------
07/09/96 Index Chronological Order Page: 107
TUTU WELLS SITE Documents
Document Number: TUT-006-1038 To 1038 Date: 07/08/94
Title: (Letter regarding the Texaco Tutu Service Station - Phase 1 Remedial Investigation Report,
St. Thomas, U.S. V.I.)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Ryan, Paul F-: Texaco
.Recipient: Kuan, Caroline: US EPA
Document Number: TUT-006-1039 To 1039 Date: 07/08/94
Title: (Letter forwarding the Monthly Status Report No. 29, Tutu Wells Site, St. Thomas, U.S. Virgin
Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: McBurney, John P.: de maximis, inc.
Seibel, Geoffrey C.: -de maximis, inc.
Recipient: Kwan, Caroline: US EPA
Attached: TUT-006-1040
Document Number: TUT-006-1036 To 1036 • Date: 07/12/94
Title: (Letter regarding Texaco Tutu Service Station - Phase I Remedial Investigation Report, St.
Thomas, U.S.V.I.)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Ryan, Paul F.: Texaco
Recipient: Crooke, Clifford: Department of Planning and Natural Resources (DPNR)
Document Number: TUT-006-1037 To 1037 Date: 07/12/94
Title: (Letter regarding Groundwater Monitoring, Tutu Wells Site Remedial Investigation)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Oanahy, Thomas V.: Geraghty & Miller
Morales, Wanda I.: Geraghty i Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Simmonds, Ralda V.: none
-------
07/09/96 Index Chronological Order Page: 108
TUTU WELLS SITE Documents
Document Number: TUT-006-1035 To 1035 Date: 07/15/94
Title: (Letter regarding Validation of Soil and Grounduater Data from the TuTu Wells Site, St. Thomas,
U.S.V.I.)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Kwan, Caroline: US EPA
Recipient: McBurney, John: de maximis, inc.
Seibel, Geoffrey: de maximis, inc.
Document Number: TUT-006-1028 To 1028 Date: 07/21/94
Title: (Letter regarding Draft RI Report, Tutu Wells Site, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Kwan, Caroline: US EPA
Attached: TUT-006-1029 TUT-006-1030 . TUT-006-1032 TUT-006-1033 TUT-006-1034
Document Number: TUT-006-1025 To 1027 Date: 07/25/94
Title: (Letter regarding Response to Comment on, and Addendum for "Work Plan for Evaluation and Interim
Remediation of Soils" O'Henry Laundry, Tutu, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Price, Belinda K.: IT Corporation
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-006-1020 To 1020 Parent: TUT-006-1019 Date: 07/31/94
Title: Tutu Well Fields Project Progress Report, July 1994
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: de maximis, inc.
Recipient: none: US EPA
-------
^ 07/09/96 Index Chronological Order Page: 109
TUTU WELLS SITE Documents
Document Number: TUT-006-1024 To 1024 Date: 08/03/94
Title: (Letter regarding Approval of the Uorkplan for Evaluation and Interim Remediation of Soils
at the 0' Henry Laundry, Tutu, St. Thomas)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Peterson, Carole: US EPA
Recipient: D'Anna, Nancy: attorney
Document Number: TUT-006-1023 To 1023 Parent: TUT-006-1022 Date: 08/04/94
Title: (Memo regarding TEIC/EPA/OPNR Conference Call, Tutu Well s Fie Id Project)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: McBurney, Jack: de max! mis, inc.
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-006-1022 To 1022 Date: 08/05/94
Title: (Fax Transmittal sheet forwarding enclosed memo)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
. Author: McBurney, Jack: de max i mis, inc.
Recipient: various: various parties associated with the site
Attached: TUT-006-1023
Document Number: TUT-005-1305 To 1306 Date: 08/08/94
Title: (Memo regarding Subchronic Toxieity Information for Benzene (CASRN 71-43-2), Chromium VI (CASRM
7440-47-3), Di(2-ethylhexyl) phthalate (CASRN 117-81-7) and Vinyl Chloride (CASRN 75-01-4)(Tutu
Uellfield Site/St. Thomas, Virgin Islands
Type: CORRESPONDENCE
Category: 3.4.0.0.0 Rl Reports
Author: Dollarhide, JoanS.: none
Recipient: Maddaloni, Mark: US EPA
Attached: TUT-005-1307 TUT-005-1322 TUT-005-1327 TUT-005-1349
-------
07/09/96 Index Chronological Order Page: 110
TUTU WELLS SITE Documents
Document Number: TUT-006-1021 To 1021 Date: 08/09/94
Title: (Letter regarding Remediation Scheduled by L'Henri, Inc.)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: D'Anna, Nancy: attorney
Recipient: 1C wan, Caroline: US EPA
Document Number: TUT-006-1019 To 1019 Date: 08/10/94
Title: (Letter forwarding Monthly Status Report No. 30, Tutu Wells Site, St. Thomas, U.S. Virgin
islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: McSurney, John P.: Phillips Building
Recipient: Kwan, Caroline: US EPA
Attached: TUT-006-1020
Document Number: TUT-007-1129 To 1138 Date: 08/23/94
Title: (Letter regarding the attached PRP Comments of Pathway Exposure Report Draft)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: HcBurney, John P.: de maximis, inc.
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-006-1017 To 1018 Date: 08/24/94
Title: (Memo regarding Minutes of Conference Call Between EPA and TEIC on August 16, 1994)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: McBurney, John P.: de maximis, inc.
Recipient: various: various parties associated with the site
-------
07/09/96 Index Chronological Order Page: 111
TUTU WELLS SITE Documents
Document Number: TUT-007-1127 To 1128 Date: 08/26/94
Title: (Letter regarding additional comments on Pathway Exposure Report Draft)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: HcBurney, John P.: de maximis, inc.
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-006-1011 To 1012 Date: 08/26/94
Title: (Letter regarding the Endangerroent Assessment for the Tutu Wells Site, St. Thomas, U. S.V.I.}
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Condition: MARGINALIA
Author: Peterson, Carole: US EPA
Recipient: McBurney, John: de maximis, inc.
Seibel, Geoffrey: de maximis, inc.
Attached: TUT-006-1013
Document Number: TUT-006-1014 To 1014 . Date: 08/26/94
Title: (Transmittal sheet forwarding enclosed letter)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: McBurney, J.P.: Phillips Building
Recipient: Kwan, Caroline: US EPA
Attached: TUT-006-1015
Document Number: TUT-006-1015 To 1016 Parent: TUT-006-1014 Date: 08/26/94
Title: (Letter regarding Additional Comments on Pathway Exposure Report Draft)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: McBurney, John P.: de maximis, inc.
Recipient: Kwan, Caroline: US EPA
-------
07/09/96 Index Chronological Order Page: 112
TUTU WELLS SITE Documents
Document Number: TUT-006-1006 To 1006 Parent: TUT-006-1005 Date: 08/31/94
Title: Tutu Uell Fields Project Progress Report, August 1994
Type: REPORT
Category: 3.4.0.0.0 Rl Reports
Author: none: de maximis, inc.
Recipient: none: none
Document Number: TUT-006-1013 To 1013 Parent: TUT-006-1011 Date: 08/31/94
Title: (Memo regarding Clarification/Confirmation of Submittal Date, Draft RI and Remedial Alternatives
Memo, Tutu Well Site, U.S. V.I.)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Seibel, Geoff: de maximis, inc.
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-007-1125 To 1126 Date: 09/06/94
Title: (Letter regarding Site Access Agreement)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: D'Anna, Nancy: attorney
.Recipient: D'Amour, Kevin, Esq.: attorney
Document Number: TUT-006-1008 To 1009 Parent: TUT-006-1007 Date: 09/06/94
Title: (Letter regarding Analytical Results for July 27, 1994 Grounduater Sampling of the Delegarde
Supply Uell, Tutu Wells Site, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Oanahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty I Miller
Potenza, John C.: Geraghty & Miller
Recipient: Seibel, Geoff: de maximis, inc.
Attached: TUT-006-1010
-------
.07/09/96 Index Chronological Order Page: 113
TUTU WELLS SITE Documents
Docunent Number: TUT-006-1007 To 1007 Date: 09/07/94
Title: (Letter regarding Tutu Well Field Project, Delegarde Well Analytical Results)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: McBurney, John P.: de maximis, inc.
Recipient: Kuan, Caroline: US EPA
Attached: TUT-006-1008
Document Number: TUT-006-1005 To 1005 Date: 09/09/94
Title: (Letter forwarding Monthly Status Report No. 31, Tutu Uells Site, St. Thomas, U.S. Virgin
Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: McBurney, John P.: de maximis, inc.
Recipient: Kwan, Caroline: US EPA
Attached: TUT-006-1006
Document Number: TUT-006-1003 To 1004 Date: 09/21/94
Title: (Memo regarding comments on the draft risk assessment for the Tutu Wells Site)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Condition: MARGINALIA
Author: Maddaloni, Mark: US EPA
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-007-1124 To 1124 Date: 09/26/94
Title: (Letter regarding Tutu Well Fields)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Knutson, Timothy R.: Texaco
Recipient: Praschak, Andrew, Esq.: Assistant Regional Counsel, EPA
-------
07/09/96 Index Chronological Order Page: 1U
TUTU WELLS SITE Documents
Document Number: TUT-007-1122 To 1123 Date: 09/29/94
Title: (Letter regarding attached Garments on Endangerment Assessment Tutu Uells Site, St. Thomas,
U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Price, Belinda K., R.P.G.: International Technology Corporation (IT)
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-006-0999 To 1000 Parent: TUT-006-0998 Date: 09/30/94
Title: Tutu Well Fields Progress Report, September 1994
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: de maximis, inc.
Recipient: none: none
Document Number: TUT-006-1001 To 1002 Date: 09/30/94
Title: (Letter regarding Tutu Uells Site Draft Risk Assessment/Draft RI Comments Ramsay Motors -
File 92115)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Rich, Carol Ann: Campbell, Arellano & Rich
Recipient:' Kuan, Caroline: US EPA
Document Number: TUT-006-0653 To 0653 Parent: TUT-006-0652 Date: 10/01/94
Title: Tutu Well Fields Project Progress Report October 1994
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: de maximis, inc.
Recipient: none: none
-------
.or/09/96 Index Chronological Order Page: 115
TUTU UELLS SITE Documents
Document number: TUT-006-0995 To 0996 Parent: TUT-006-0994 Date: 10/03/94
Title: (Letter regarding Meetings Scheduled with TEIC, Tutu Wells Site PRP Croup and DPNR)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author': Kuan, Caroline: US EPA
Recipient: Reed, Leonard: Department of Planning and Natural Resources (DPNR)
Document Number: TUT-006-0994 To 0994 Date: 10/11/94
Title: (Letter regarding scheduled meeting dates)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Reed, Leonard G.: Department of Planning and Natural Resources (DPNR)
Recipient: Kuan, Caroline: US EPA
Attached: TUT-006-0995
Document Number: TUT-006-0997 To 0997 Date: 10/11/94
Title: (Transmittal sheet forwarding enclosed letter)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: McBurney, J.P.: de maximis, inc.
Recipient: Kuan, Caroline: US EPA
Attached: TUT-006-0998
Document Number: TUT-006-0998 To 0998 Parent: TUT-006-0997 Date: 10/11/94
Title: (Letter forwarding the Monthly Status Report No. 32, Tutu Wells Site, St. Thomas, U.S. Virgin
Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: McBurney, John P.: de maximis, inc.
Seibel, Geoffrey C.: de maximis, inc.
Recipient: Kuan, Caroline: US EPA
Attached: TUT-006-0999
-------
07/09/96 Index Chronological Order . Page: 116
TUTU WELLS SITE Documents
=s ss====================—====—=——=======s ========s==s============z=======3=======;:===£==================:£==£££==~====== =
Document Number: TUT-006-0992 To 0993 Date: 10/12/94
Title: (Letter regarding Submittal of Draft Remedial Investigation Report, Tutu Wells Site, St. Thomas,
U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Condition: MISSING ATTACHMENT
Author: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Mi Her
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-006-0990 To 0990 Date: 10/13/94 -
Title: (Transmittat form forwarding the Soil Data Validation Report, and the Water Data Validation
Report, Volumes 1-4)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Condition: MISSING ATTACHMENT
Author: illegible: Geraghty & Miller
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-006-0991 To 0991 Date: 10/13/94
Title: (Memo forwarding a copy of the Draft Remedial Investigation Report (RI) dated October 1994
for the Tutu Uells Site)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Petersen, Carol: US EPA
Recipient: various: US EPA
Document Number: TUT-006-0985 To 0985 Date: 10/24/94
Title: (Transmittal sheet forwarding information regarding sample e-01 at O'Henry Laundry)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Price, Belinda: IT Corporation
Recipient: Kwan, Caroline: US EPA
-------
•07/09/96 Index Chronological Order Page: 117
TUTU WELLS SITE Documents
Document Number: TUT-004-0227 To 0247 Date: 10/25/94
Title: Facsimile transmit tal with attached groundwater sample analyses for 0' Henry Laundry, Tutu
St. Thomas
Type: DATA
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: Price, Belinda: IT Corporation
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-006-0965 To 0984 Date: 10/25/94
Title: (Letter forwarding enclosed Grounduater Samples from 0' Henry Laundry, St. Thomas, U.S. V.I.)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Price, Belinda 1C.: IT Corporation
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-006-0964 To 0964 • Date: 10/27/94
Title: (Memorandum regarding RCRA Review of Draft Remedial Investigation (RI) for Tutu Wells Site,
Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Bellina, Andrew: US EPA
Recipient: Petersen, Carole: US EPA
Document Number: TUT-007-1120 To 1121 Date: 11/01/94
Title: (Memorandum regarding the Biological Technical Assistance Group Meeting, Endangerment Assessment
for Tutu Wells)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Stevens, Shari: US EPA
Recipient: Kwan, Caroline: US EPA
-------
07/09/96 Index Chronological Order Page: 118
TUTU WELLS SITE Documents
Document Number: TUT-006-0662 To 0963 Date: 11/01/94
Title: (Letter regarding Four Uinds Plaza Partnership's comments on Geraghty & Milter, Inc.'s Draft
Phase II Remedial Investigation)
Type: CORRESPONDENCE
Category: 3. 5. 0.0.0 Remedial Investigation Correspondence
Author: Dema, John <.: Law Offices of John K. Dema, P.C.
Recipient: Adams, Roy: Department of Planning and Natural Resources (DPNR)
Kuan, Caroline: US EPA
Praschak, Andrew: US EPA
Document Number: TUT-006-0641 To 0648 Parent: TUT-006-0636 Date: 11/03/94
Title: (Memorandum regarding Evaluation of Geraghty & Miller Remedial Investigation Report)
Type: CORRESPONDENCE
.Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Fahrcnthold, P.: Fahrenthold & Associates, Inc.
Recipient: Smith, Rich: Law Offices of John K. Dema, P.C.
Document Number: TUT-006-0473 To 0473 Parent: TUT-006-0468 Date: 11/03/94
Title: Attendance List, November 3, 1994 Site Walk, O'Henry Laundry, Tutu, St. Thomas, U.S. V.I.
Type: OTHER
Category: 3.4.0.0.0 RI Reports
Author: none: none
Recipient: none: none
Document Number: TUT-006-0661 To 0661 Date: 11/07/94
Title: (Memorandum regarding Tutu Wells Site - Phase II Draft Remedial Investigation: Air Programs
Branch Review) .
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Gonzales, Marlon: US EPA
Recipient: Kwan, Caroline: US EPA
-------
07/09/96 Index Chronological Order Page: 119
TUTU WELLS SITE Documents
Document Number: TUT-006-0660 To 0660 Date: 11/08/94
Title: (Memorandum regarding Tutu Wells Site, St. Thomas, VI, Draft Remedial Investigation Report)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: LaPosta, Done: US EPA
Recipient: Petersen, Carole: US EPA
Document Number: TUT-007-1117 To 1119 Date: 11/09/94
Title: (Letter regarding: 1. the diskette which contains the Model Consent decree and 2. the attached
sign-in sheets from November 2-4, 1994 Meeting)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Praschak, Andrew t.: Assistant Regional Counsel, EPA
Recipient: Dema, John K.: Law Offices of John K. Dema, P.C.
Document Number: TUT-006-0654 To 0659 Date: 11/09/94
Title: (Memorandum regarding Hydrogeologic Review of Draft RI Report, Tutu Wells Site, St. Thomas,
dated August 1994, prepared by Geraghty & Hi Her, Inc.)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Ross, Linda: US EPA
Recipient: Hauptman, Mel: US EPA
Document Number: TUT-006-0649 To 0650 Date: 11/10/94
Title: (Letter regarding Confirmation of Project Schedule, Tutu Wells Site RI/FS)
Type: .CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Seibel, Geoffrey C.: de maximis, inc.
Recipient: Kwan, Caroline: US EPA
-------
07/09/96 Index Chronological Order Page: 120
TUTU UELLS SITE Documents
Document Number: TUT-006-0651 To 0651 Date: 11/10/94
Title: (Letter regarding Tutu Uellfields Progress Reports)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: McBurney, John P.: de maximis, inc.
Recipient: Reed, Leonard: Department of Planning and Natural Resources (DPNR)
Document Number: TUT-006-0652 To 0652 Date: 11/10/94
Title: (Letter regarding Monthly Status Report No. 33, Tutu Wells Site, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: McBurney, John P.: de maximis, inc.
Seibel, Geoffrey C.: de maximis, inc.
Recipient: Kuan, Caroline: US EPA
Attached: TUT-006-0653
Document Number: TUT-006-0601 To 0605 Parent: TUT-006-0579 Date: 11/11/94
Title: Base Map Figures IT-1 - IT-5, Tutu Wells Site. St. Thomas, U.S. Virgin Islands
Type: GRAPHIC
Condition: DRAFT
Author: none: Geraghty & Miller
Recipient: none: none
Document Number: TUT-006-0636 To 0637 Date: 11/11/94
Title: (Letter regarding Tutu Water Uells Site Investigation, St. Thomas, United States Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Dema, John K., Esq.: Law Offices of John K. Dema, P.C.
Recipient: Adams, Roy: Department of Planning and Natural Resources (DPNR)
Kwan, Caroline: US EPA
Praschak, Andrew, Esq.: US EPA
Attached: TUT-006-0638 TUT-006-0641
-------
07/09/96 Index Chronological Order Page: 121
TUTU WELLS SITE Documents
Document Number: TUT-006-0606 To 0606 Date: 11/14/94
Title: (Letter of Transmittal regarding Form 1's, Phase II Remedial Investigation, Tutu Wells Site,
St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3. 5. 0.0.0 Remedial Investigation Correspondence
Author: Stern, David: Ceraghty & Miller
Recipient: Naugle, Jill E.: COM Federal Programs Corporation
Document Number: TUT-006-0607 To 0608 Date: 11/14/94
Title: (Memorandum regarding Tutu Wells Site - Phase II Draft Remedial Investigation: Air Programs
Branch Review)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Gonzales, Marlon: US EPA
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-006-0609 To 0611 Date: 11/14/94
Title: (Letter regarding Phase II Remedial Investigation Tutu Wells Site October 1994 (Draft))
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
• Author: Rich, Carol Ann, Esq.: Campbell, Arellano & Rich
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-006-0612 To 0616 Date:- 11/14/94
Title: (Letter regarding Comments on Draft Phase II Remedial Investigation Tutu Wells Site, St. Thomas,
U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author; Bierschenk, John: ENSR
Galya, Donald P., P.E.: ENSR
Recipient: Kuan, Caroline: US EPA
Attached: TUT-006-0617 TUT-006-0621 TUT-006-0634
-------
"07/09/96 Index Chronological Order Page: 122
TUTU UELLS SITE Documents
Document Number: TUT-006-0570 To 0573 Date: 11/15/94
Title: (Letter regarding comments on behalf of PRPs to the Draft Remedial Investigation Report ("RI")
submitted by the Tutu Environmental Investigation Committee ("TEIC"))
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Lei and, Richard G.: Rosentnan & Colin
Recipient: Kuan, Caroline: US EPA
Attached: TUT-006-0574 TUT-006-0577
Document Number: TUT-006-0574 To 0576 Parent: TUT-006-0570 Date: 11/15/94
Title: (Letter regarding Review of RI Report)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Smyth, Andrew: Arthur D. Little, Inc.
Recipient: Leland, Rick, Esq.": Rosen/nan 4 Colin
Document Number: TUT-006-0579 To 0600 ' -Date: 11/15/94
Title: (Letter with attached summary comments regarding "Draft Phase II Remedial Investigation, Tutu
Wells Site, St. Thomas, U.S. Virgin Islands")
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Loy, Kenneth L.: IT Corporation
Recipient: Kwan, Caroline: US EPA
Attached: TUT-006-0601
Document Number: TUT-006-0564 To 0569 Date: 11/22/94
Title: (Letter with attached data regarding Sampling Procedures and Waste-Classification Analytical
Results of Drill Cuttings, Tutu Wells Site, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel: Geraghty & Miller
Recipient: Kwan, Caroline: US EPA
-------
07/09/96 Index Chronological Order Page: 123
TUTU WELLS SITE Documents
Document Number: TUT-006-0562 To 0563 Date: 11/23/94
Title: (Memoranda regarding Biological Technical Assistance Group Meeting Phase II Remedial Investigation
for Tutu Wells)
Type: CORRESPONDENCE
Category: 3. S. 0.0.0 Remedial Investigation Correspondence
Author: Stevens, Shari: US EPA
Recipient: Kuan, Caroline: US EPA
document Number: TUT-006-0531 To 0532 Parent: TUT-006-0530 Date: 11/30/94
Title: Tutu Wells Site RI/FS Project Schedule
Type: MISCELLANEOUS
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: de maximis, inc.
Recipient: none: none
Document Number: TUT-006-0547 To 0561 Date: 11/30/94
Title: (Letter with attached DPNR comments on the October 1994 Draft Remedial Investigation (RI)
report for the Tutu Wells Superfund Site in St. Thomas, USVI )
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Naiario, Benjamin I.: Department of Planning and Natural Resources (DPNR)
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-006-0533 To 0546 Date: 12/01/94
Title: (Facsimile regarding DPNR Comments on the Draft Remedial Investigation for the Tutu Wellfield
Superfund Site in St. Thomas, USVI)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Rosoff, D.: Department of Planning and Natural Resources (DPNR)
Recipient: Kwan, Caroline: US EPA.
-------
07/09/96 Index Chronological Order Page: 124
TUTU WELLS SITE Documents
= ==r=ss= = 5=s==s=========s=s ============£=========ss==sss=ss==s==ss:s23;Esss=s=s=s===ss======2ssrss==a ===ss = = 5Sszrs = = rs = = = =
Document Number: TUT-006-0530 To 0530 . Date: 12/08/94
Title: (Letter regarding Monthly Status Report Mo. 34, Tutu Uells Site, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: HcBurney, John P.: de maximis, inc.
Seibel, Geoffrey C.: de maximis, inc.
Recipient: Kwan, Caroline: US EPA
Attached: TUT-006-0531
. i. .. . — ........i.. —. .... . —.. .. .
Document Number: TUT-006-0524 To 0525 Date: 12/22/94
Title: (Letter regarding Comments on Draft RI • Tutu Superfund Site)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Kwan, Caroline: US EPA
Recipient: Leland, Richard G., Esq.: Rosenman & Colin
Document Number: TUT-006-0526 To 0527 Date: 12/22/94
Title: (Letter regarding Comments on Draft RI - Tutu Superfund Site)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Kwan, Caroline: US EPA
Recipient: Dema, John K., Esq.: Law Offices of John K. Dema, P.C.
Document Number: TUT-006-0528 To 0529 Date: 12/22/94
Title: (Letter regarding Comments on Draft RI - Tutu Superfund Site)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Kwan, Caroline: US EPA
Recipient: Rich, Carol Ann, Esq.: Campbell, Arellano & Rich
-------
•07/09/96 Index Chronological Order Page: 125
TUTU WELLS SITE Documents
Document Number: TUT-006-0503 To 0523 Date: 12/28/94
Title: (Letter with attached comments regarding Draft Phase II Remedial Investigation (RI) and Development
and Screening of Remedial Alternatives Reports for the Tutu Wells Site, St. Thomas, USVI)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Petersen, Carole: US EPA
Recipient: McBurney, John P.: de maximis, inc.
Seibel, Geoffrey C.: de maximis, inc.
Document Number: TUT-006-0496 To 0496 Parent: TUT-006-0495 Date: 12/31/94
Title: Tutu Well Site, St. Thomas, U.S. Virgin Islands, Monthly Progress Report 1*35, December 1994
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: de maximis, inc.
Recipient: none: US EPA
Document Number: TUT-006-0495 To 0495 Date: 01/10/95
Title: (Letter forwarding the Monthly Status Report No. 35, Tutu Wells Site, St. Thomas, U.S. Virgin
Islands)
Type: CORRESPONDENCE
Category: 3.5'.0.0.0 Remedial Investigation Correspondence
Author: McBurney, John P.: de maximis, inc.
Seibel, Geoffrey C.: de maximis, inc.
Recipient: 1C wan, Caroline: US EPA
Attached: TUT-006-0496
Document Number: TUT-006-0497 To 0501 Date: 01/10/95
Title: (Letter regarding EPA Response to DPNR's Comments on the Tutu Wells Site Draft Remedial Investigation
Report, St. Thomas)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Petersen, Carol: US EPA
Recipient: Nazario, Benjamin I.: Department of Planning and Natural Resources (OPNR)
Attached: TUT-006-0502
-------
07/09/96 Index Chronological Order Page: 126
• TUTU WELLS SITE Documents
Document Number: TUT-006-0490 To 0494 Date: 01/12/93
Title: (Memorandum regarding Selection of Soil Standards or BackgroundValues for Metals, Tutu Wells
Site, St. Thomas, U.S. Virgin Isls)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel: Geraghty & Miller
Recipient: McBurney, Jack: de maximis, inc.
Document Number: TUT-007-1116 To 1116 ' Date: 01/13/95
Title: (Letter regarding Final Endangerment Assessment for the Tutu Wells Site, St. Thomas, USVI)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Kuan, Caroline: US EPA
Recipient: McBurney, John: de maximis, inc.
Seibel, Geoffrey: de maximis, inc.
Document Number: TUT-006-0485 To 0489 Date: 01/27/95
Title: (Letter regarding Western Auto Supply Company's Reply to EPA's December 28, 1994 Comments
on Geraghty & Miller's Draft Phase II Remedial Investigation Report for the Tutu Wells Site,
St. Thomas, U.S. V.I.)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Coon, John R.: none
Recipient: Petersen, Carol: US EPA
Document Number: TUT-006-0467 To 0467 Parent: TUT-006-0466 Date: 01/31/95
Title: Tutu Well Site, St. Thomas, U.S. Virgin Islands, Monthly Progress Report #36, January 1995
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: de maximis, inc.
Recipient: none: US EPA
-------
07/09/96 Index Chronological Order Page: 127
TUTU WELLS SITE Documents
Document Number: TUT-005-1232 To 1298 . Parent: TUT-005-1231 Date: 02/01/95
Title: Site-Specific Safety and Health Plan, Interim Remediation of Soils, L'Kenri, Inc., Tutu, St.
Thomas, U.S. Virgin Islands
Type: PLAN
Category: 3.4.0.0.0 RI Reports
Author: none: IT Corporation
Recipient: none: L'Henri, Inc.
Document Number: TUT-005-1299 To 1304 Date: 02/01/95
Title: Site Specific Health and Safety Plan Addendum I, Evaluation and Interim Remediation of Soils,
0'Henry Laundry, Tutu, St. Thomas, U.S. Virgin Islands
Type: PLAN
Category: 3.4.0.0.0 RI Reports
Author: none: IT Corporation
Recipient: none: L'Henri, Inc.
Document Number: TUT-006-0476 To 0484 Parent: TUT-006-0468 Date: 02/01/95
Title: Site Specific Health and Safety Plan Addendum I, Evaluation and Interim Remediation of Soils,
O'Henry Laundry, Tutu, St, Thomas, U.S. Virgin Islands
Type: PLAN
Category: 3.4.0.0.0 RI Reports
Author: none: IT Corporation
Recipient: none: L'Henri, Inc.
Document Number: TUT-007-1841 To 1886 Parent: TUT-007-1839 Date: 02/01/95
Title: Site Remediation and Supplemental Investigation Program, Esso Tutu Service Station, Tutu,
Anna's Retreat, St. Thomas, U.S.V.I.
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: Forensic Environmental Services, Inc.
Recipient: none: Esso Caribbean and South America
-------
07/09/96 Index Chronological Order Page: 128
TUTU URLS SITE Documents
Document Number: TUT-006-0468 To 0471 Date: 02/02/95
Title: (Letter regarding the Addendum to Work Plan for Evaluation and Interim Remediation of Soils,
O'Henry Laundry, Tutu, St. 'Thomas, U.S. V.I.)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Loy, Kenneth L.: IT Corporation
Recipient: Kwan, Caroline: US EPA
Attached: TUT-006-0472 TUT-006-0473 TUT-006-0474 TUT-006-0476
Document Number: TUT-007-2347 To 2423 Parent: TUT-007-2339 Date: 02/03/95
Title: Analytical Testing Results from Drum Sampling Activities at the Tutu Texaco Service Station,
St. Thomas, U.S. Virgin Islands
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: Erler & Kalinowski, Inc.
Recipient: none: none
Document Number: TUT-006-0466 To 0466 Date: 02/10/95
Title: (Letter forwarding Monthly Status Report No. 36, Tutu Wells Site, St. Thomas, U.S. Virgin
Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: HcBurney, John P.: de maximis, inc.
Seibel, Geoffrey C.: de maximis, inc.
Recipient: Kwan, Caroline: US EPA
Attached: TUT-006-0467
Document Number: TUT-004-0132 To 0133 Date: 02/16/95
Title: (Letter regarding Removal Action at O'Henry Dry Cleaners)
Type: CORRESPONDENCE
Category: 2.7.0.0.0 Removal Response Correspondence
Author: D'Anna, Nancy: attorney
Recipient: Praschak, Andrew, Esq.: US EPA
-------
07/09/96 Index Chronological Order Page: 129
TUTU WELLS SITE Documents
Document Number: TUT-007-2338 To 2338 Date: 02/16/95
Title: Data Narrative, Project #987, Tutu Wellfield
Type: DATA
Category: 3.2.0.0.0 Sampling and Analysts Data/Chain of Custody Forms
Author: none: none
Recipient: none: none
Document Number: TUT-005-1231 To 1231 Date: 02/24/95
Title: (Letter regarding Transmittal of Revised Health and Safety Plan and Addendum I to the Health
and Safety Plan for Interim Soil Remediation O'Henry Laundry, Tutu, St. Thomas)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Price, Belinda 1C.: IT Corporation
Recipient: Kwan, Caroline: US EPA
Attached: TUT-005-1232
Document Number: TUT-007-1839 To 1840 Date: 02/24/95
Title: (Letter forwarding report entitled, Site Remediation and Supplemental Investigation Program,
Esso Tutu Service Station, Tutu, Anna's Retreat, St. Thomas, U.S.V.I.)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Gibson, Christopher R.: Archer & Greiner
Recipient: Kwan, Caroline: US EPA
Attached: TUT-007-1841
Document Number: TUT-007-1267 To 1272 Date: 03/01/95
Title: EPA Region II, Environmental Update, Tutu Wells Site, St. Thomas, U.S. Virgin Islands
Type: REPORT
Category: 10.6.0.0.0 Fact Sheets and Press Releases
Author: Kwan, Caroline: US EPA
Recipient: none: none
-------
"07/09/96 Index Chronological Order Page: 130
TUTU WELLS SITE Docunents
Document Number: TUT-006-2159 To 2160 Parent: W-006-2U8 Date: 03/01/95
Title: Western Auto-Four Winds Plaza, Tutu, USVI, Sampling Locations (two maps)
Type: GRAPHIC
Category: 4.3.0.0.0 Proposed Plan
Author: none: ENSR
Recipient: none: none
Document Number: TUT-004-0131 To 0131 Date: 03/03/95
Title: (Letter regarding Administrative Order on Consent for Removal Action at the L'Henry, Inc.
Property)
Type: CORRESPONDENCE
Category: 2.7.0.0.0 Removal Response Correspondence
Author: Kuan, Caroline: US EPA
Recipient: Reed, Leonard: US EPA
Document Number: TUT-007-0871 To 0895 Date: 03/03/95
Title: Administrative Order on Consent for Removal Action
Type: LEGAL DOCUMENT
Category: 7.3.0.0.0 Administrative Orders
Author: Fox, Jeanne M.: US EPA
Recipient: Magras, Henry: L'Henri, Inc.
Document Number: TUT-006-0465 To 0465 Date: 03/03/95
Title: (Letter forwarding a copy of the Administrative Order on Consent, Index No. II-CERCLA-95-0401;
L'Henry, Inc.)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Condition: MISSING ATTACHMENT
Author: Simon, Paul: US EPA
Recipient: D'Anna, Nancy: attorney
-------
-07/09/96 Index Chronological Order Page: 131
TUTU WELLS SITE Documents
Document Mumber: TUT-004-0195 To 0207 Date: 03/06/95
Title: Field Activities Report - L'Henri, Inc. (O'Henry Cleaner)
Type: REPORT
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: none: US EPA
Recipient: none: none
Document Number: TUT-006-0462 To 0464 Date: 03/06/95
Title: (Letter in response to Geraghty & Miller, Inc.'s February 24, 1995 letter requesting the U.S.
Virgin Islands DPNR's approval of Geraghty & Hitler, Inc.'s waste characterization of drill
cuttings generated during the Phase II Remedial Investigation)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Reed, Leonard: Department of Planning and Natural Resources (DPNR)
Recipient: Danahy, Thomas: Geraghty & Miller
Document Number: TUT-004-0169 To 0182 ' -Date: 03/09/95
Title: (Field Data Sheets, Analysis Requests, and Chain of Custody Records for O'Henry Cleaner)
Type: DATA
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: Ward, Greg: IT Corporation
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-007-1211 To 1256 Date: 03/10/95
Title: Revised Community Relations Plan, Tutu Well Field Superfund Site, St. Thomas, U.S. Virgin
Islands
Type: PLAN
Category: 10.2.0.0.0 Community Relations Plan
Author: none: Camp Dresser & McKee (CDM)
Recipient: none: US EPA
-------
07/09/96 Index Chronological Order Page: 132
TUTU WELLS SITE Documents
Document Number: TUT-006-0460 To 0460 Date: 03/10/95
Title: (Letter forwarding the Monthly Status Report No. 37, Tutu Wells Site, St. Thomas, U.S. Virgin
Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: McBurney, John P.: de maximis, inc.
Seibel, Geoffrey C.: de maximis, inc.
Recipient: Kuan, Caroline: US EPA
Attached: TUT-006-0461
Document Number: TUT-006-0461 To 0461 Parent: TUT-006-0460 Date: 03/10/95
Title: Tutu Well Site, St. Thomas, U.S. Virgin Islands, Monthly Progress Report #37, February 1995
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: de maximis, inc.
Recipient: none: US EPA"
Document Number: TUT-004-0208 To 0226 Date: 03/17/95
Title: Lab Data Management System - Region II - Completed Project Approval, Completed Analysis Report
for Tutu Wellfield
Type: DATA
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: none: US EPA
Recipient: none: none
Document Number: TUT-006-2174 To 2174 Date: 03/17/95
Title: (Memorandum regarding Tutu Wells Site; St. Thomas, USVI, Draft FS Report)
Type: CORRESPONDENCE
Category: 4.5.0.0.0 Feasibility Study Correspondence
Author: Petersen, Carole: US EPA
Recipient: Various: US EPA
-------
'07/09/96 Index Chronological Order Page: 133
TUTU UELLS SITE Documents
Document Number: TUT-007-2319 To 2337 Date: 03/17/95
Title: Lab Data Management System - Region II, Completed Project Approval and Completed Analysis
Report for Tutu Uellfield
Type: DATA
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: Finazzo, Barbara A.: US EPA
Recipient: none: none
Document Number: TUT-006-0459 To 0459 Date: 03/21/95
Title: (Letter regarding L'Henri, Inc. d/b/a O'Henry Dry Cleaners, Administrative Order on Consent,
Index Number II-CERCLA-95-0401)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: D'Anna, Nancy: attorney
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-004-0159 To 0168 Date: 03/24/95
Title: (Facsimile Transmittal with Attached Sampling Trip Report - Tutu Wells (Laga Building))
Type: DATA
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: Garcia, Ivan: Roy F. Ueston, Inc.
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-006-2175 To 2440 Date: 03/24/95
Title: Final Endangerment Assessment, Tutu Wells Site, St. Thomas, Virgin Islands, Volume I of IV
Type: REPORT
Category: 7.2.0.0.0 Endangerment Assessments
Author: none: Camp Dresser •& HcKee (COM)
Recipient: none: US EPA
-------
"07/09/96 Index Chronological Order Page: 134
TUTU WELLS SITE Documents
Document number; TUT-006-2441 To 0313 Date: 03/24/95
Title: Final Endangerment Assessment, Tutu Wei Is Site, St. Thomas, Virgin Islands, Volume II of IV
Type: REPORT
Category: 7.2.0.0.0 Endangerment Assessments
Author: none: Camp Dresser & McKee (CDM)
Recipient: none: US EPA
Document Number: TUT-007-0314 To 0746 Date: 03/24/95
Title: Final Endangerment Assessment, Tutu Wells Site, St. Thomas, Virgin Islands, Volume III of
IV
Type: REPORT
Category: 7.2.0.0.0 Endangerment Assessments
Author: none: Camp Dresser & McKee (COM)
Recipient: none: US EPA
Document Number: TUT-007-0747 To 0832 Date: 03/24/95
Title: Final Endangerment Assessment, Tutu Wells Site, St. Thomas, Virgin Islands, Volume IV of IV
Type: REPORT
Category: 7.2.0.0.0 Endangerment Assessments
Author: none: Camp Dresser & McKee (CDM)
Recipient: none: US EPA
Document Number: TUT-007-2309 To 2318 Date: 03/24/95
Title: Facsimile Transmittal forwarding attached Sampling Trip Report, Tutu Wells (Laga Building)
Type: CORRESPONDENCE
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: Garcia, Ivan: Weston Environmental Designers Consultants
Recipient: Kuan, Caroline: US EPA
-------
07/09/96 Index Chronological Order Page: 135
TUTU WELLS SITE Documents
Document Number: TUT-006-0458 To 0458 Parent: TUT-006-0457 Date: 03/31/95
Title: Tutu Well Site, St. Thomas, U.S. Virgin Islands, Monthly Progress Report #38, March 1995
Type: REPORT
Category: 3.4.0.0.0 ftl Reports
Author: none: de maximis, inc.
Recipient: none: US EPA
Document Number: TUT.-005-0408 To 0706 Parent: TUT-OOS-0406 Date: 04/01/95 •
Title: Phase II Remedial Investigation, Tutu Wells Site, St. Thomas, U.S. Virgin Islands - Volume
I of III
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: Geraghty & Miller
Recipient: none: Tutu Environmental Investigation Committee
Document Number: TUT-005-0707 To 0773 Parent: TUT-005-0406 Date: 04/01/95
Title: Phase II Remedial Investigation, Tutu Wells Site, St. Thomas, U.S. Virgin Islands, Volume
II of III
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: Geraghty & Miller
Recipient: none: Tutu Environmental Investigation Committee
Document Number: TUT-005-0774 To 1230 Parent: TUT-005-0406 Date: 04/01/95
Title: Phase II Remedial Investigation, Tutu Wells Site, St. Thomas, U.S. Virgin Islands, Volume
III of III
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: Geraghty & Miller
Recipient: none: Tutu Environmental Investigation Committee
-------
'07/09/96 Index Chronological Order Page: 136
TUTU WELLS SITE Documents
Document Number: TUT-006-2168 To 2173 Date: 04/04/95
Title: (Letter regarding attached Conments on "Draft Feasibility Study", Tutu Wells Site, St. Thomas,
U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 4.5.0.0.0 Feasibility Study Correspondence
Author: Price, Belinda K.: IT Corporation
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-005-0406 To 0407 Date: 04/06/95
Title: (Letter regarding Submit tal of Phase II Remedial Investigation Report, Tutu Wells Site, St.
Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel: Geraghty & Miller
Recipient: Kwan, Caroline: US EPA
Attached: TUT-005-0408 TUT-005-0707 TUT-005-0774
Document Number: TUT-006-2166 To 2167 Date: 04/06/95
Title: (Memorandum regarding Tutu Wells Site, Draft Feasibility Study)
Type: CORRESPONDENCE
Category: 4.5.0.0.0 Feasibility Study Correspondence
Author: Filippelli, John: US EPA
Recipient: Hauptmann, Melvin: US EPA
Document Number: TUT-006-0454 To 0455 Date: 04/10/95
Title: (Letter regarding Work Plan for Initial Soil Sampling Event, Post Soil Remediation, O'Henry
Laundry, Tutu, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Price, Belinda: IT Corporation
Recipient: Kuan, Caroline: US EPA
Attached: TUT-006-0456
-------
t)7/09/96 Index Chronological Order Page: 137
TUTU WELLS SITE Documents
Document Number: TUT-006-0457 To 0457 Date: 04/10/95
Title: (Letter forwarding the Monthly Status Report No. 38, Tutu Wells Site, St. Thomas, U.S. Virgin
Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: McBurney, John P.: de maximis, inc.
Seibel, Geoffrey C.: de maximis, inc.
Recipient: Kuan, Caroline: US EPA
Attached: TUT-006-0458
Document Number: TUT-004-0183 To 0194 Date: 04/11/95
Title: Lab Data Management System - Region II, Completed Project Approval - Completed Analysis Report,
Tutu O'Henry Cleaner
Type: DATA
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: none: US EPA
Recipient: none: none
Document Number: TUT-006-2161 To 2162 Parent: TUT-006-2148 Date: 04/12/95
Title: Gore-Sorber Screening Survey, Western Auto Site, St. Thomas, U.S. Virgin Islands
Type: GRAPHIC
' Category: 4.5.0.0.0 Feasibility Study Correspondence
Author: none: W.L. Gore £ Associates, Inc.
Recipient: none: none
Document Number: TUT-007-1550 To 1640 Date: 04/13/95
Title: Groundwater and Soils Remediation Program for Texaco Tutu Service Station, St. Thomas, U.S.
Virgin (stands
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: Erler & Kalinowski, Inc., Consulting Engineers and Scientists
Recipient: Texaco
Department of Planning and Natural Resources (OPNR)
US EPA
-------
07/09/96 Index Chronological Order Page: 138
TUTU WELLS SITE Documents
Document Number: TUT-006-2165 To 2165 Date: 04/14/95
Title: (Memorandum regarding RCRA Review of Feasibility Study (FS) for Tutu Wells Site, Virgin Islands)
Type: CORRESPONDENCE
Category: 4.5.0.0.0 Feasibility Study Correspondence
Author: Bellina, Andrew: US EPA
Recipient: Petersen, Carole: US EPA
Document Number: TUT-006-2143 To 2147 Date: 04/17/95
Title: (Letter regarding Tutu Water Wells Superfund Site, St. Thomas, U.S. V.I. , Comments of Western
Auto to Geraghty & Miller Proposed FS)
Type: CORRESPONDENCE
Category: 4.5.0.0.0 Feasibility Study Correspondence
Author: Coon, John R.: Coon, Sanford & Amerling, P.C.
Recipient: Petersen, Carole: US EPA
Document Number: TUT-006-2148 To 2156 Date: 04/17/95
Title: (Letter regarding Comments on Tutu Site FS)
Type: CORRESPONDENCE
Category: 4.5.0.0.0 Feasibility Study Correspondence
Author: Bierschenk, John: ENSR
Galya, Donald P., P.E.: ENSR
Recipient: ICwan, Caroline: US EPA
Attached: TUT-006-2157 TUT-006-2159 TUT-006-2161
Document Number: TUT-006-2163 To 2164 Date: 04/17/95
Title: (Memorandum regarding Tutu Wells Site - Draft Feasibility Study: Air Programs Branch Review)
Type: CORRESPONDENCE
Category: 4.5.0.0.0 Feasibility Study Correspondence
Author: Gonzalez, Marlon: US EPA
Recipient: Kuan, Caroline: US EPA
-------
07/09/96 Index Chronological Order Page: 139
TUTU WELLS SITE Documents
Document Dumber: TUT-006-2141 To 2142 Bate: 04/19/95
Title: (Memorandum regarding Tutu Wells, St. Thomas, Virgin Islands, Draft Feasibility Study (FS)
Report)
Type: CORRESPONDENCE
Category: 4.5.0.0.0 Feasibility Study Correspondence
Author: Brock, Frank C.: US EPA
Recipient: Petersen, Carole: US EPA
Document Number: TUT-006-2133 To 2134 Date: 04/20/95
Title: (Memorandum regarding Tutu Wells Site Feasibility Study)
Type: CORRESPONDENCE
Category: 4.5.0.0.0 Feasibi I ity Study Correspondence
Author: Wehner, Diane: National Oceanic & Atmospheric Administration (NOAA)
Recipient: Stevens, Shari: US EPA
Attached: TUT-006-2135
Document Number: TUT-006-0446 To 0447 Date: 04/26/95
Title: (Letter regarding Tutu Water Wells Contamination Litigation)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Newman, John M.: Porzio, Bromberg & Newman
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-006-0448 To 0450 Date: 04/26/95
Title: (Letter regarding the Biological Technical Assistance Group (BTAG) Meeting of April 20, 1995)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Stevens, Shari: US EPA
Recipient: Kuan, Caroline: US EPA
-------
*07/09/96 Index Chronological Order Page: 140
TUTU WELLS SITE Documents
Document Number: TUT-006-0451 To 0453 Date: 04/26/95
Title: (Letter regarding comments on behalf of Ramsey Motors Inc., on the draft Feasibility Study
(FS) dated March, 1995)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Rich, Carol Ann: none ' '
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-006-0438 To 0443 Date: 04/27/95
Title: (Letter regarding Comments on Final Phase II Remedial Investigation, Tutu Wells Site, St.
Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Butler, Eric I.: ENSR
Galya, Donald P.: ENSR
Recipient: Kwan, Caroline: US EPA
Attached: TUT-006-0444
Document Number: TUT-006-2122 To 2125 Date: 04/27/95
Title: (Letter regarding attached Additional Comments on "Draft Feasibility Study", Tutu Wells Site,
St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 4.5.0.0.0 Feasibi I ity Study Correspondence
Author: Price, Belinda K.: IT Corporation
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-006-2126 To 213? Date: 04/27/95
Title: (Letter regarding attached DPNR Comments on the Draft Feasibility Study for the Tutu Wellfield
Superfund Site in St. Thomas, USVI)
Type: CORRESPONDENCE
Category: 4.5.0.0.0 Feasibi I ity Study Correspondence
Author: Reed, Leonard: Department of Planning and Natural Resources (OPNR)
Recipient: Kwan, Caroline: US EPA
-------
•D7/09/96 Index Chronological Order Page: 141
TUTU WELLS SITE Documents
Document Number: TUT-006-0436 To 0436 Parent: TUT-006-0435 Date: 04/30/95
Title: Tutu Well Site, St. Thomas, U.S. Virgin Islands, Monthly Progress Report #39, April 1995
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: de maximis, inc.
Recipient: none: US EPA
Document Number: TUT-006-0437 To 0437 . Date: 05/03/95
Title: (Letter regarding Confirmation of Receipt of Approval for Soil Sampling and Notice of Sampling
Date, Post Soil Remediation 0' Henry Laundry, Tutu, St. Thomas, U.S. Virgin Islands}
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Price, Belinda K.: IT Corporation
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-006-1918 To 2121 Date: 05/03/95
Title: (Letter with attached exhibits (A-C) regarding Tutu Wells Site Draft Feasibility Study)
Type: CORRESPONDENCE
Category: 4.5.0.0.0 Feasibility Study Correspondence
Author: Hogan, Edward A.: Porzio, Bromberg & Newman
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-007-1111 To 1115 Date: 05/09/95
Title: (Memorandum regarding response to STAG'S memo dated April 26, 1995 on the Tutu Wells Site)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Kwan, Caroline: US EPA
Recipient: Stevens, Shari: US EPA
-------
•07/09/96 Index Chronological Order Page: 142
TUTU UELLS SITE Documents
Document Number: TUT-006-0435 To 0435 Date: OS/10/95
Title: (Letter forwarding the Monthly Status Report No. 39, Tutu Wells Site, St. Thomas, U.S. Virgin
Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: McBurney, John P.: de maximis, inc.
Seibel, GeoffreyC.: de maximis, inc.
Recipient: Kwan, Caroline: US EPA
Attached: TUT-006-0436
Document Number: TUT-007-1641 To 1838 Date: 05/11/95
Title: Soil Remediation Report, O'Henry Laundry, Tutu, St. Thomas, U.S Virgin Islands
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: Price, Belinda K.: IT Corporation
Recipient: L'Henri, Inc.
Document Number: TUT-007-1379 To 1549 Date: 06/26/95
Title: Techncial Memorandum 1, Basis of Design for the Groundwater and Soils Remediation Source Control
Program, Texaco Tutu Service Station, St. Thomas, U.S. Virgin Islands
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: Erler & Kalinowski, Inc., Consulting Engineers and Scientists
Recipient: US EPA
Department of Planning and Natural Resources (DPNR)
Document Number: TUT-008-0315 To 0506 Parent: TUT-008-0314 Date: 06/26/95
Title: Technical Memorandum 1, Basis of Design for the Groundwater and Soils Remediation Source Control
Program
Type: REPORT
Category: 4.2.0.0.0 FS Reports
Author: none: Erler & Kalinowski, Inc.
Recipient: none: none
-------
-07/09/96 Index Chronological Order Page: 143
TUTU WELLS SITE Documents
Document Number: TUT-008-0584 To 0587 Date: 07/10/95
Title: (Letter regarding EPA's Responses to Uestern Auto Comments on the Draft fS and Final Phase
II RI>
Type: CORRESPONDENCE
Category: 4.5.0.0.0 Feasibility Study Correspondence
Author: Kwan, Caroline: US EPA
Recipient: Coon, John R., Esq.: Coon & Sanford, Law Offices
Document dumber: TUT-007-1301 To 1378 Date: 07/11/95
Title: Final Report, Estimation of Soil Cleanup Concentrations Required to Protect Groundwater as
a Source. of Drinking Water, Tutu Well Site, U.S. Virgin Islands
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: COM Federal Programs Corporation
Recipient: US EPA
Document Number: TUT-008-0314 To 0314 Date: 07/19/95
Title: (Letter of Transmittal for the "Groundwater and Soils Remediation Program Report, Tutu Texaco
Service Station" and the "Technical Memorandum 1, Basis of Design for the Grounduater and Soils
Remediation Source Control Program")
Type: CORRESPONDENCE
Category: 4.5.0.0.0 Feastbt I ity Study Correspondence
Author: Hart, Deborah A., P.E.: Erler & Kalinowski, Inc.
Recipient: Kwan, Caroline: US EPA
Attached: TUT-008-0315
Document Number: TUT-007-2424 To 0212 Date: 08/01/95
Title: Soil Remediation Report, O'Henry Laundry, Tutu, St. Thomas, U.S. Virgin Islands
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: IT Corporation
Recipient: none: L'Henri, Inc.
-------
'07/09/96 Index Chronological Order Page: HA
TUTU WELLS SITE Documents
Document Number: TUT-008-0581 To 0581 Date: 08/02/95
Title: (Letter regarding Tutu Wells Site, Proposed Plan)
Type: CORRESPONDENCE
Category: 4.5.0.0.0 Feasibility Study Correspondence
Author: Filippelli, John: US EPA
Recipient: Hauptman, Melvin: US EPA
Document Number: TUT-008-0582 To 0583 Date: 08/02/95
Title: (Memorandum regarding Tutu Wells Site - Draft Proposed Plan: Air Programs Branch Review)
Type: CORRESPONDENCE
Category: 4.5.0.0.0 Feasibility Study Correspondence
Author: Gonzales, Marlon: US EPA
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-007-2270 To 2272 ' Date: 08/03/95
Title: (Letter regarding Tutu Wells Site, St. Thomas, U.S. Virgin Islands, Notice of Potential Liability)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Kwan, Caroline: US EPA
Recipient: Lazare, Paul: Potentially Responsible Party (PRP)
Document Number: TUT-007-2273 To 2275 Date: 08/03/95
Title: (Letter regarding Tutu Wells Site, St. Thomas, U.S. Virgin Islands, Notice of Potential Liability
of Panex Industries, Inc.)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Kwan, Caroline: US EPA
Recipient: Newman, John: Porzio, Bromberg & Newman
-------
"07/09/96 Index Chronological Order Page: H5
TUTU WELLS SITE Documents
Document Number: TUT-007-2276 To 2278 Date: 08/03/95
Title: (Letter regarding Tutu Wells Site, St. Thomas, U.S. Virgin Islands, Notice of Potential Liability
of Laga Industries, Ltd.)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Kuan, Caroline: US EPA
Recipient: Newman, John: Porzio, Bromberg & Newman
Document Number: TUT-007-2279 To 2281 Date: 08/03/95
Title: (Letter regarding Tutu Wells Site, St. Thomas, U.S. Virgin Islands, Notice of Potential Liability)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Kuan, Caroline: US EPA
Recipient: Gal, Andreas: Potentially Responsible Party (PRP)
Document Number: TUT-007-2282 To 2284 Date: 08/03/95
Title: (Letter regarding Tutu Wells Site, St. Thomas, U.S. Virgin Islands, Notice of Potential Liability
of Panex Company)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
' Author: Kwan, Caroline: US EPA
Recipient: Edell, Hare Z.: Edell & Associates, P.C.
Document Number: TUT-007-2285 To 2287 Date: 08/03/95
Title: (Letter regarding Tutu Wells Site, St. Thomas, U.S. Virgin Islands, Notice of Potential Liability
of Duplan Corporation)
Type: CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: Kwan, Caroline: US EPA
Recipient: Newman, John: Porzio, Bromberg & Newman
-------
07/09/96 Index Chronological Order Page: 146
TUTU WELLS SITE Documents
Document Number: TUT-007-1955 To 2269 Date: 08/04/95
Title: Draft Final Feasibility Study, Tutu Wells Site, St. Thomas, U.S. Virgin Islands
Type: REPORT
Category: 4.2.0.0.0 FS Reports
Condition: DRAFT
Author: Geraghty & Miller
Recipient: Tutu Environmental Investigation Committee
Document Number: TUT-008-0295 To 0296 Date: 08/07/95
Title: (Memorandum regarding Tutu Wells Site)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Stevens, Shari: US EPA
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-008-OS80 To 0580 Date: 08/15/95
Title: (Memorandum regarding Tutu Uellfield Super-fund Site, St. Thomas, USVI, Draft Proposed Plan)
Type: CORRESPONDENCE
Category: 4.5.0.0.0 Feasibility Study Correspondence
Author: Brock, Frank C.: US EPA
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-008-0610 To 0611 Date: 08/17/95
Title: (Letter regarding Tutu Uellfield Superfund Site)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Newman, John M.: Porzio, Bromberg & Newman
Recipient: Kwan, Caroline: US EPA
Praschak, Andrew L. Esq.: US EPA
-------
07/09/96 Index Chronological Order Page: 147
TUTU WELLS SITE Documents
Document Number: TUT-008-0578 To 0578 Date: 08/18/95
Title: (Letter of Transmittal for Request for Permit to Operate Catalytic Oxidizer at Texaco Tutu
Service Station, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 4.5.0.0.0 Feasibility Study Correspondence
Author: Hart, Deborah A., P.E.: Erler & Kalinowski, Inc.
Recipient: Kwan, Caroline: US EPA
Attached: TUT-008-0579
Document Number: TUT-008-0579 To 0579 Parent: TUT-008-0578 Date: 08/18/95
Title: (Letter regarding Texaco Tutu Service Station, St. Thomas, U.S. Virgin Islands, Groundwater
and Soils Remediation Program Request for Permit to Operate Catalytic Oxidizer (EKI 940058.03))
Type: CORRESPONDENCE
Category: 4.5.0.0.0 Feasibility Study Correspondence
Author: Hart, Deborah A., P.E.: Erler & Kalinowski, Inc.
Recipient: Perez, Juan A.: Department of Planning and Natural Resources (DPNR)
Document Number: TUT-008-0577 To 0577 Date: 08/24/95
Title: (Memorandum regarding RCRA Review of Proposed Plan for Tutu Wells Site, Virgin Islands)
Type: CORRESPONDENCE
Category: 4.5.0.0.0 Feasibility Study Correspondence
Author: Bel Una, Andrew, P.E.: US EPA
Recipient: Petersen, Carole, Chief: US EPA
Document Number: TUT-008-0219 To 0294 Date: 08/31/95
Title: (Letter forwarding the attached Comment Responses and Revised Soft Remediation Report, 0'Henry
Laundry, Tutu, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Price, Belinda K., R.P.G: IT Corporation
Recipient: Kwan, Caroline: US EPA
-------
'07/09/96 Index Chronological Order Page: 148
TUTU WEILS SITE Documents
Document number: TUT-008-0593 To 0609 Date: 09/07/95
Title: (Letter regarding Tutu Wellfield Superfund Site. Enclosure: Tutu Water Wells Contamination
Litigation Counsel Counsel List attached)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Newman, John H.: Porzio, Bromberg & Newman
Recipient: Kwan, Caroline: US EPA
Praschalc, Andrew, Esq.: US EPA
Document Number: TUT-007-2297 To 2308 Date: 09/12/95
Title: (Memorandum regarding Documentation of Transmittal of attached Sampling Report DCN# 07571)
Type: CORRESPONDENCE
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: Leahy, Jennifer: Weston Environmental Designers Consultants
O'Neill, Thomas: Weston Environmental Designers Consultants
Recipient: Chong, Margaret, OSC: US EPA
Document Number: TUT-008-0588 To 0588 Date: 09/13/95
Title: (Letter regarding Tutu Uellfield Superfund Site)
Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Gnudt, RobynM.: Edell & Associates
Recipient: Kwan, Caroline: US EPA
Attached: TUT-008-0589
Document Number: TUT-007-2288 To 2296 Date: 09/28/95
Title: (Memorandum regarding attached Report for Tutu Well Survey)
Type: CORRESPONDENCE
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: Finazzo, Barbara A.: US EPA
Recipient: Kwan-Appelman, Caroline: US EPA
-------
•07/09/96 Index Chronological Order Page: U9
TUTU WELLS SITE Documents
Document Number: TUT-008-0215 To 0218 Date: 12/19/95
Title: (Letter regarding Transmittal of Comments and Concerns Related to Calculated Site Specific
Soil Cleanup Standard for the O'Henry Dry Cleaners, Tutu St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Price, Belinda 1C., R.P.C: IT Corporation
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-007-2339 To 2346 Date: 01/11/96
Title: (Letter regarding Proposal for Disposal of Drums Containing Solid Drilling Spoils with Low
Levels of Petroleum Hydrocarbons at the Bavoni Landfill, Tutu Texaco Service Station, St. Thomas,
U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Kriegman King, Michelle: Erler & Kalinows'ki, Inc.
Peabody, Carey E., Ph.D.: Erler & Kalinowski, Inc.
Recipient: Leonard, Reid: Department of Planning and Natural Resources (DPNR)
Rosoff, David: Department of Planning and Natural Resources (DPNR)
Attached: TUT-007-2347
Document Number: TUT-008-0213 To 0214 Date: 01/19/96
Title: (Letter' forwarding attached Tab'le 1 from January 11, 1996 letter regarding "Proposal for Disposal
of Drums Containing Solid Drilling Spoils with Low Levels of Petroleum Hydrocarbons at the
Bavoni Landfill, Tutu Texaco Station, St. Thomas, U.S., V.I)
Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Peabody, Carey E.: Erler & Kalinowski, Inc.
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-008-0297 To 0313 Date: 02/01/96
Title: Tutu Uellfield Super fund Site, St. Thomas, U.S. Virgin Islands, F.S. Addendum, February 1996
Type: REPORT
Category: 4.2.0.0.0 FS Reports
Author: none: de maximis, inc.
Recipient: none: none
-------
"07/09/96 Index Chronological Order Page: 150
TUTU WELLS SITE Documents
======= ==== = ======:===========ss=s:====================:;==s===========;==========:===== === === ===:=========r== =
Document Number: TUT-008-0612 To 0624 Date: 02/15/96
Title: (Letter regarding attached Addendum to Final Human Health Risk Assessment)
Type: CORRESPONDENCE
Category: 8.3.0.0.0 Health Assesement Correspondence
Author: Odland, Sally, P.C.: COM Federal Programs Corporation
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-008-0625 To 0705 Date: 03/05/96
Title: Public Meeting Transcript, Tutu Uellfield Superfund Site
Type: OTHER
Category: 10.4.0.0.0 Public Meeting Transcripts
Author: Norman, Julee: Certified Shorthand Reporter
Recipient: none: none
Document Number: TUT-008-0706 To 0707 Date: 03/10/96
Title: (Letter regarding comments on Tutu Uellfield Proposed Plan and comments made at the public
hearing on March 5, 1996)
Type: CORRESPONDENCE
Category: 10.9.0.0.0 Public Correspondence
Author: Smith, Henry H., Ph.D.: University of the Virgin Islands
Recipient: Kwan, Caroline: US EPA
Document Number: TUT-008-0708 To 0708 Date: 03/10/96
Title: (Letter regarding response to the revised Superfund Proposed Plan, Tutu Uellfield Site, St.
Thomas, Virgin Islands)
Type: CORRESPONDENCE
Category: 10.9.0.0.0 Public Correspondence
Author: Gjessing, Helen U.: The League of Women Voters
Recipient: none: none
-------
707/09/96 Index Chronological Order . Page: 151
TUTU WELLS SITE Documents
Document Number: TUT-008-0517 To 0518 Date: 03/12/96
Title: (Letter regarding Tutu Uellfield NPL Site, Revised Superfund Proposed Plan)
Type: CORRESPONDENCE
Category: 4.5.0.0.0 Feasibility Study Correspondence
Author: Knutson, Timothy R.: attorney
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-008-0519 To 0576 Date: 03/12/96
Title: (Letter regarding the attached comments on "Feasibility Study" and "Proposed Plan for Remediation",
Tutu Well Site, St. Thomas, Virgin Islands. Exhibits 1 through 4 attached.)
Type: CORRESPONDENCE
Category: 4.5.0.0.0 Feasibi I ity Study Correspondence
Author: D'Anna, Nancy: attorney
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-008-0507 To 0512 Date: 03/13/96
Title: (Letter regarding Comments on Draft Final FS, Tutu Wells Site, St. Thomas, U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 4.5.0.0.0 Feasibi I ity Study Correspondence •
Author: Bierschenck, John, P.E.: ENSR
Butler, Eric, Ph.D.: ENSR
Gatya, Donald P., P.E.: EMSR
Recipient: Kuan, Caroline: US EPA
Document Number: TUT-008-0513 To 0516 Date: 03/13/96
Title: (Letter regarding corroents on Forensic Esso Tutu Station Report, Tutu Wells Site, St. Thomas,
U.S. Virgin Islands)
Type: CORRESPONDENCE
Category: 4.5.0.0.0 Feasibility Study Correspondence
Author: Bierschenk, John, P.G.: ENSR
Galya, Donald P., P.E.: ENSR
Recipient: Kuan. Caroline: US EPA
-------
APPENDIXIV
TERRITORIAL LETTER OF CONCURRENCE
-------
CNViaONMCNTAI. PNOTCCTiON
TDD Wow rrr*«ia
GOVERNMENT OF THE VIRGIN ISLANDS OF THE UNTIED STATES
• 0--
DEPARTMENT OF PLANNING AND NATURAL RESOURCES
WHEATUEY SHOPPING CENTER II
CHARLOTTE AMAUE, ST. THOMAS, V.I. OO602
My 18,1996
Ms. Jeane Fox
Regional Administrator
U.S. Environmental Protection Agency
290 Broadway
New York, NY 10007-1866
Dear Ms. Fox,
This letter provides the Virgin Islands Department of Planning and Natural
Resources' (DPNR's) concurrence on the U.S. Environmental Protection Agency's
(EPA's) Record of Decision for the Tutu Wellfield Site in St. Thomas.
DPNR expects to work closely with EPA during the implementation of the selected
Soil Remediation Alternative (SRA 3/4) and Groundwater Remediation Alternative
(GRA 4). DPNR considers this Record of Decision as an important step toward the
eventual reclamation of a valuable Virgin Islands resource.
Thank you for your consideration in this matter.
Sincerely yours,
Beulah Dahnida-Smith
Commissioner
cc: Kathleen Callahan, EPA
-------
APPENDIXV
RESPONSIVENESS SUMMARY
ATTACHMENTA
LETTERS SUBMITTED DURING THE PUBLIC COMMENT PERIOD
-------
APPENDIX V
RESPONSIVENESS SUMMARY
TUTU WELLFIELD SUPERFUND SITE
St. THOMAS, U.S. VIRGIN ISLANDS
A. INTRODUCTION
A responsiveness summary is required by Superfund policy. It
provides a summary of citizens' comments and concerns received
during the public comment period, and the United States
Environmental Protection Agency's (EPA's) and the Virgin Islands
Department of Planning and Natural Resources's (DPNR's) responses
to those comments and concerns. All comments summarized in this
document have been considered in EPA's and DPNR's final selection
of a remedial action for the Tutu Wellfield site.
B. OVERVIEW
At the time of the public comment period, EPA had already
identified a preferred remedial alternative for the Tutu Wellfield
Superfund Site in St. Thomas, U.S. Virgin Islands. EPA's
recommended alternative addressed the soil and groundwater
contamination problems at the site. The selected alternative
specified in the record of decision (ROD) for soils involves a
combination of institutional controls, in-situ (in place) or ex-
situ soil vapor extraction (SVE), excavation, and on-site or off-
site disposal. The selected alternative for groundwater involves
institutional controls, source and plume containment, treatment
using an air strip'per, and discharge of treated water.
Judging from the comments received during the public comment
period, local residents and other concerned parties, including the
League of Women Voters of the Virgin Islands (LWWI) , the public
generally supports the Proposed Plan that outlined the preferred
alternative and agrees that a combination of soil remediation
alternatives 3 and 4 and groundwater remediation Alternative 4
provide the greatest means for protection of human health and the
environment.
These sections follow:
• Background on Community Involvement
• Summary of Comments Received During the Public Comment
Period and Agency Responses
Part I: Summary and Response to Local Community
Concerns
Part II: Comprehensive Response to Specific Legal
and Technical Questions
1
-------
• Remaining Concerns
• Attachment: Community Relations Activities at the Tutu
Wellfield Superfund Site
C. BACKGROUND ON COMMUNITY INVOLVEMENT
Community interest in the Tutu Wellfield Superfund Site dates to
July 1987 when Mr. Eric Tillett noticed an odor emanating from his
well. He contacted DPNR, and DPNR in turn contacted EPA for
assistance. Since 1987, community concern and involvement have
remained fairly active.
Major concerns expressed during the remedial planning activities at
the Tutu site focused on the notification of potentially
responsible parties (PRPs), the interpretation of sampling results
and continued use of well water, the extent of contamination and
cleanup schedule, and the restoration of the environment. These
concerns and how EPA addressed them are described below:
(1) Some PRPs expressed concern about their future liability and
requested that EPA consider relief such as de minimis settlements.
EPA Response: EPA has not identified a "de minimis" PRP at the
Site, for purposes of Section 122(g) of CERCLA, 42 U.S.C.
§9622 (g) . EPA has had a number of meetings with some or all of the
PRPs where liability issues have been discussed, and the PRPs will
have an additional opportunity to discuss issues relating to the
status of the parties when remedial design/remedial action
("RD/RA") negotiations are conducted with EPA immediately following
insurance of the ROD.
(2) Residents requested that EPA present sampling results in a
meaningful way and assure only authorized water use by public
establishments and private citizens.
EPA Response: In February 1995, EPA mailed letters to residential
well owners that expressed sampling results in terms of the level
of contaminants in their wells versus acceptable, federal drinking
water standards and provided information on health risks.
Concerning water use, EPA has continued to restate the distinction
between its role to make recommendations based on risk studies and
DPNR's role to regulate water use in the local area.
(3) The community is concerned about whether or not the plumes are
moving or have become larger, and would like to know when cleanup
activities will begin.
EPA Response: EPA is monitoring the areas of contamination
periodically and is prepared to take immediate action should any
movement of the plumes pose an imminent threat to human health or
the environment. Once the ROD is signed, EPA will enter into RD/RA
negotiations with the PRPs, about a 2 to 4-month process, and,
-------
subsequently, the remedial design phase will be commenced.
(4) The community would like the affected aquifer restored to
acceptable federal drinking water standards so that all Islanders
can enjoy its use.
EPA Response: It is the goal of EPA to implement a cleanup
technology that will contain the sources of contamination and
associated plumes, remove the contaminants from groundwater by
extraction and treatment, and, where technically feasible, restore
the aquifer water quality to be suitable for public consumption.
The RI report, FS report and the Proposed Plan for the site were
released to the public for comment on August 23, 1995. These
documents were made available to the public in the administrative
record file at the EPA Docket Room in Region II, New York and the
information repositories at the Curriculum Center in Anna's Retreat
and the DPNR offices in the Wheatley Shopping Center. A public
meeting to present the Proposed Plan was scheduled for September,
1995. However, due to Hurricane Marilyn's destruction to St.
Thomas in September, the public meeting was canceled until basic
living and working conditions could be restored to the Island. The
Proposed Plan was reissued on. February 12, 1996. The public
comment period on these documents was held from February 12 to
March 13, 1996.
On March 5, 1996, EPA conducted a public meeting at the Curriculum
Center in Anna's Retreat to inform local officials and interested
citizens about the Superfund process, to review current and planned
remedial activities at the site, and to respond to any questions
from area residents and other attendees.
D. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
AND AGENCY RESPONSES
The following correspondence (see Attachment A) was received during
the public comment period:
• Letter from the League of Women Voters
• Letter from Dr. Henry Smith, Director of Water Resources
Research Institute, University of the Virgin Islands
• Letter from the attorney representing Texaco
• Two letters from the attorneys and technical consultant for
Western Auto
• Letter from the attorney representing O'Henry
A summary of the comments contained in the above letters and the
comments provided by the public at the March 5, 1996, public
meeting, as well as EPA's response to those comments follows.
Part I of this section addresses those community concerns and
comments that are non-technical in nature. Responses to specific
legal and technical questions are provided in Part II. Comments in
-------
each Part are categorized by relevant topics.
Part I - Summary and Response to Local Community Concerns
Public Participation
(1) Concern was raised by an individual regarding meeting the
community acceptance criterion and that EPA has not conducted
enough community relations activities to meet this criterion. This
individual stressed that it is important for the general public,
particularly the affected community, to understand the documents
presented to them by EPA, such as the Proposed Plan.
EPA Response: EPA responded .that perhaps this individual was not
aware of the extensive community interaction that has been
conducted at this site and the efforts that were made to present
technical and non-technical material in language that is
understandable to the general public. At the Tutu Wellfield site
this has been a continual process beginning in 1992 and continuing
to the present. EPA has used a variety of outreach techniques to
disseminate information about the site, its history, contamination
and plans for cleanup to the affected community including
interviews, fact sheets, and public meetings. EPA conducted face-
to-face interviews with residents in the community in February 1992
and again in October 1994. Residents were given the opportunity to
express their concerns, ask questions or request additional
information. EPA has prepared three fact sheets which explained in
nontechnical language the history of the site, the purpose of the
studies and their results and answers to concerns raised during the
interviews. These- fact sheets were distributed to over 1400
residents of the Tutu Community. EPA also held several public
meetings beginning with the release of the RI work plan, to offer
the community opportunities to learn more about the Superfund
process, to ask questions about those aspects they do not
understand and to present comments and concerns during the public
comment periods. The informal availability session held in April
1995 was attended by over 50 members of the affected community.
Questions regarding groundwater and contaminant movement through
the subsurface, cleanup technologies proposed by EPA and soil
contamination found at the site were discussed in language
understandable to the public. In addition, EPA has also enlisted
volunteers in the community to pass along information to their
neighbors in the form of printed handouts. Education on the
Superfund process and the technologies related to the Tutu site has
been ongoing as evidence of long-term commitment to public
participation.
(2) Elaborate on other resources available to the community to
better understand the situation at the Tutu site, beyond selection
of the preferred alternative.
EPA Response: An organized group affected by a Superfund site can
-------
apply for a technical assistance grant (or TAG) in the amount of
$50,000 to hire a technical consultant. This adviser would keep
the group informed of ongoing site activities and help them better
understand the entire process. EPA informed the public at the May
1992 and April 1995 meetings about the TAG process. Applications
were available during these meetings also. Additional applications
for a TAG are still available from EPA, upon request.
Extent of Contamination
(1) The community would like a general quantification of the
amount of contamination found at the Tutu•site.
EPA Response: EPA has placed monitoring wells throughout the Tutu
site to quantify the amount of contamination at each property. At
the LAGA building, for instance, the highest concentration of
contamination was found to be 360 parts per billion (ppb) of
perchloroethylene (PCE). The drinking water standard for PCE is 5
ppb. . In addition, EPA is monitoring the size of '. the plumes
surrounding these highly concentrated areas. The LAGA plume is
estimated to be about 500 to 1,000 feet in length, (see Figure 4 of
the ROD for graphical depiction and Table 2 for concentrations of
contaminants detected)
Risks to Human Health and the Environment
(1) The community would like to know what they can do on a daily
basis to reduce the risk of harm to their health from exposure.
EPA Response: Because the primary risk to human health is from
groundwater, the community should not drink water from the aquifer.
To ensure public safety, DPNR closed contaminated wells and
affected residents are being supplied with trucked water for their
potable use. With these precautions taken into consideration, the
risk of accidental ingestion of contaminated groundwater is very
small. In addition, the community is reminded that cancer risk
estimates are based on long-term exposure, that is, the daily
ingestion of more than two quarts of contaminated water for 30
years.
(2) Individuals are concerned about whether EPA or Health and
Human Services plans to monitor a sample population over time to
determine any health risks from the site contamination.
EPA Response: EPA itself does not conduct epidemiologic studies to
follow a population in time to detect' disease incidences. The
Agency for Toxic Substances and Disease Registry (ATSDR) does have
that capacity.
ATSDR Response: ASTDR will not be able to conduct an epidemiology
study for this site because the population potentially affected is
too small to derive meaningful results. Very large populations are
-------
necessary for such studies. However, ASTDR will conduct an
education program for local health care professionals to teach them
how to identify symptoms of exposure.
(3) The LWWI is concerned about control of the plume, particularly
threats to wildlife in the Mangrove Lagoon.
EPA Response: At present, contaminated groundwater from the Site
has migrated to Delegarde well area. Measured concentrations in
the Delegarde well are relatively low, about 30 ppb of total VOCs.
Until the preferred remedy is implemented, contaminated groundwater
from the Site will continue to migrate and will potentially
discharge into a small wetland area and Turpentine Run immediately
south of Delegarde on Rt. 32. From there, the discharged and
diluted water will flow with the Turpentine Run stream towards
Mangrove Lagoon, approximately 2 miles to the southeast. EPA's
ecological risk assessment has determined that the Mangrove Lagoon
has not been impacted from the Tutu Wells Site.
Implementation of the preferred remedy would place wells near the
end of the plume to prevent discharge to the wetland described
above, which is about 5 miles from the lagoon. During the remedial
design phase, additional field studies will be conducted to assess
and minimize any impacts that the selected remedy would have on the
wetlands.
(4) The community would like to know if construction activities in
the Tutu area could affect the dynamics of the aquifer and further
endanger the environment.
EPA Response: We do not anticipate any significant impacts to the
environment during construction activities at the Site, Any
impacts would be minimized and controlled. Construction and
implementation of the selected remedy would change the plume
configuration by capturing the contaminants in the groundwater and
preventing further migration of the contaminated groundwater. This
would prevent further ecological or environmental impacts
associated with the contaminated groundwater.
(5) Citizens were concerned about what techniques were used to
clean their cisterns during the Superfund removal action in 1988
and whether EPA recommended any type of filtration system for
residuals.
EPA Response: The cisterns were cleaned and disinfected using a
high pressure water jet to physically flush contaminants from the
system. For biological contamination, chlorine bleach {sodium
hypochlorite solution) followed by a thorough rinse was conducted.
At the same time, the plumbing of affected residential homes was
modified to disconnect the cisterns from the well for regular home
use. EPA did not recommend a filtration system because residents
were being supplied with clean trucked water for potable use.
-------
Cleanup Schedule
(1) Citizens want to know when the actual cleanup process will
begin and whether the budget crisis will affect the schedule.
EPA Response: EPA anticipates that the ROD will be signed in the
Summer of 1996. EPA then will ask the PRPs, the people who caused
the pollution, whether they are willing to implement the remedy
that EPA selected in the ROD. Assuming the PRPs agree to implement
the cleanup, the process by which the PRPs negotiate and enter into
a legal agreement to accept this responsibility takes appropriately
two to four months. Next, the PRPs would have to conduct some pre-
design field work and design the remedy, which can take up to two
years. Actual cleanup would therefore take place about two and a
half to three years from now.' We do not presently expect EPA's
budgetary limitations to significantly affect this Site since we
expect that the PRPs will implement the remedy. However, cuts in
the EPA's budget could affect our ability to oversee the project.
Cleanup Technology
(1) A community member asked how long wells will remain capped and
what will be done with soil that is removed from the site.
EPA Response: The selected remedy calls for existing domestic and
commercial wells within the confines of the groundwater plume to be
decommissioned if these wells are determined to interfere with the
operation of the groundwater pump and treat system that will be
installed as part of this remedial action. During the remedial
design it will be determined which wells would interfere with this
remedial action and which wells would continue to operate as they
may enhance aquifer restoration, which is a goal of this remedial
action. For those wells that are decommissioned, EPA would analyze
alternative sources of .water for the users of those wells and
determine appropriate alternate sources of water for the affected
users. These wells could be reestablished at some point in the
future, when and if groundwater quality improves to allow
extraction and use of untreated groundwater. The amount of time
that will take is unclear.
If soil to be removed from the Site is found to be hazardous, then
it will be disposed of at a qualified treatment or disposal
facility in compliance with EPA regulations. The facility will be
located off-island, since the U.S.V.I. does not have a qualified
facility that is permitted to accept hazardous wastes. If however,
the soil that is excavated is found to be non-hazardous, it could
be disposed of at a non-hazardous waste landfill on St. Thomas.
(2) A community member asked EPA to explain thermal oxidation.
EPA Response: Thermal oxidation is the process by which
contaminated gases that are drawn from the ground are burned off in
-------
a properly controlled manner before being released to the
environment at acceptable levels.
(3) Citizens would like to know what type of technology EPA will
use to clean up the water and whether the water will be tested
afterwards.
EPA Response: In addition to using pumping wells to control the
plume, EPA or the PRPs will install a water treatment process. An
air stripper is the most proven technology for volatile organic
compounds, which are present at the site. EPA will test both the
water influent, before it goes to the air stripper, and the
effluent to make sure it meets federal drinking water standards
before distribution or surface water criteria if the water is
discharged to a storm drain.
(4) An interested party questioned whether there are any
historical precedents where the cleanup alternatives EPA has
proposed for the Tutu site have been proven to treat groundwater
sufficiently for release to a public distribution system.
EPA Response: There are many instances where air strippers have
been used to restore groundwater to federal and state drinking
water standards for further consumption by the public. This.
technology is particularly common in Long Island, New York which is
a designated sole source aquifer.
Restoration of the Aquifer and Protection of the Environment
(1) The community would like to know how long it will take to
restore the aquifer.
EPA Response: Two properties (the Curriculum Center and the
O1Henry properties) within the Tutu site may have DNAPLs (dense
non-aqueous phase liquids) in the groundwater and subsurface soils,
which if present, will act as a continuous releasing source to the
fractured rock in these locations. If DNAPLs are present, EPA or
the PRPs will have to continuously pump and control the movement of
this plume. While the fringes of the plume could possibly be
cleaned up quickly, perhaps in three to five years, restoration of
the aquifer in the source areas could take considerably longer,
tens of years, and may not be technically able to be restored in
the foreseeable future.
(2) EPA has stated that it will restore the groundwater to
potability, except where DNAPLs are present. The LWWT would like
to know how EPA has determined with certainty the location of
DNAPLs at the Tutu site.
EPA Response: EPA determined the location of probable DNAPLs at
two properties at the Tutu site using an indirect process. The
8
-------
concentration of contaminants in the groundwater at these two
locations is significantly higher than what would result from the
soil concentration at these locations. This finding suggests that
pure product may be locally present in the. subsurface soils and
leaking into groundwater.
(3) The community would like to know whether monitoring programs
are in place to protect the Island's resources from the threat of
further contamination related to the various properties located at
the Tutu site, as well as other properties throughout the Islands
that operate similar businesses, such as gas stations and dry
cleaners.
EPA Response: Both EPA and DPNR are involved in monitoring
programs at the Tutu site to assure that no further contamination
occurs as a result of these facilities. In addition, there are
Island-wide monitoring programs to protect the environment. One
Federal Law (the Resource, Conservation and Recovery Act (RCRA) and
implementing regulations) regulates the installation, operation,
and maintenance of underground storage tanks used by. petroleum
companies and the proper handling and disposal of perchloroethylene
("perc"), the primary waste product generated by dry cleaners.
Part II - Comprehensive Response to Specific Legal .and Technical
Questions
Wording of Proposed Plan
(1) Texaco presented a list of suggested revised wording for the
Proposed Plan.
EPA Response: The Proposed Plan will not be reissued. However, EPA
has considered Texaco's proposed revisions to the text in context
of the Record of Decision. Texaco proposed that the SVE systems
should be operated until VOCs are present in the extraction well
air vapor stream at "acceptable levels." EPA does not agree with
this proposal and instead has provided in the ROD that the SVE
systems will be operated until no VOCs are present in the
extraction well air vapor systems.
Proposed Remedy for Western Auto
(1) Western Auto protested the proposed soil remedy of excavation
for their former facility, based on the following arguments:
a) The soil screening levels (SSLs) developed for Esso are
not applicable to the Western Auto site because the
geology at their site is different than that at Esso;
b) The SSLs were determined based on benzene and are overly
conservative for other BTEX compounds;
-------
c) Western Auto already excavated the contaminated soil when
they removed their underground storage tank in 1994;
d) Western Auto recently built a concrete cap over the
entire area of concern, excluding only the area where the
4-inch PVC pipe was excavated, to prevent migration of
any remaining contaminants in soil; and
e) If there are any contaminants remaining in soil they will
not move to groundwater because 1) the concrete cap
prevents infiltration of rain water, and 2) there is a
very low permeability clay (test results provided)
underlying the gravels at the site that will prevent
migration to groundwater.
EPA Response: EPA has considered the comments and evidence
submitted by Western Auto.
a) Because vadose zone modeling is a time-consuming process,
soil profiles and soil screening levels (SSLs). were only
developed for the four properties suspected of being the
major contributors of groundwater contamination. These
SSLs were then applied to the other properties as a
screening level exercise. The geology at Western Auto is
- more similar to that at Esso than to the geology at
O'Henry, Texaco, or the Curriculum Center, so Esso's SSLs
were applied to Western Auto. It should be noted that
the SSLs for O'Henry, Esso and Texaco are virtually
identical.
b) The SSLs are intentionally very conservative cleanup
goals and are geared towards the highest risk, most
mobile contaminants, on the theory that if the soil is
remediated to address the compound with the most
stringent SSLs, then the other compounds in that chemical
group will simultaneously be addressed. EPA acknowledges
that if benzene is not present in soils at Western Auto,
then higher SSLs could be used and still be protective of
groundwater. The new SSLs would have to be determined
based on the chemical characteristics and transport
properties of toluene, ethylbenzene or xylenes.
c) EPA, at this time, is not prepared to refute the
allegation that the majority of soil contamination at
Western Auto was excavated during the UST removal.
However, the removal was performed without EPA oversight.
EPA is concerned that soil contamination remains, because
inadequate confirmatory sampling was performed at the
time to assure either DPNR or EPA that all residual
contamination had been excavated.
d) The concrete cap had not been installed when EPA
• 10
-------
identified the preferred remedy for the Proposed Plan.
e) EPA agrees that the presence of the underlying clay,
combined with the overlying concrete will reduce the risk
of migration of any residual soil contaminants to
groundwater. However, additional excavation may need to
be performed unless a confirmatory sampling program
around the tank grave indicates that residual
contaminated soils still present are not above EPA's
SSLs. Additional confirmatory soil sampling will be
performed during remedial design. If the confirmatory
soil sampling reveals .contaminant concentrations above
the SSLs, additional excavation will be performed. The
concrete cap must -be routinely inspected and maintained
free of cracks.
PVC Pipe beneath Four Winds
(.1) Western Auto reiterated that the 4-inch PVC pipe that was
ruptured during their tank excavation originates beneath the Four
Winds Plaza and should be addressed by Four Winds, not Western
Auto. Western Auto excavated the pipe on their former property up
to the edge of the building, where they cut and capped it. Western
Auto believes that this pipe is probably the source of the
petroleum compounds (diesel and heavier hydrocarbon constituents)
identified beneath Four Winds Plaza by a Gore Sorber soil gas
survey.
EPA Response: EPA agrees that the pipe is the probable source of
the hydrocarbons detected in soil gas beneath the Four Winds Plaza.
These contaminants do not appear to have impacted groundwater yet.
However, EPA will be requiring Four Winds to investigate the pipe
for leaks using inline survey techniques and to repair any
significant ruptures identified during remediation. Groundwater
downgradient of Four Winds will be monitored during the
implementation of the Tutu aquifer remedy to make sure that Four
Winds is not acting as a source of groundwater contamination.
Esso as a Source of Chlorinated VOCs to Soil and Groundwater
(1) Both Western Auto and O'Henry commented that Esso should be
identified as a source of VOC releases to soil and groundwater.
They believe that the full extent of VOC contamination in soils at
Esso has not been adequately delineated in the RI or Esso' s plan
for source control investigations (prepared by Forensic
Environmental Services). Western Auto presented a graphic profile
of VOC concentrations in groundwater showing probable impacts to
groundwater in the vicinity of the Esso service station.
EPA Response: Esso has been identified in the RI as a source of VOC
11
-------
releases to soils and a probable source of VOCs to groundwater.
The full extent of VOC soil contamination is not known at this
time. Esso's source control action will be an integral part of the
final remedy for the Tutu site. As part of their pre-design
investigations, Esso will install additional borings to confirm the
extent of VOC contamination of soils. Soil vapor extraction wells
are planned to remove the VOCs, as well as the BTEX, in soils.
The exact location of these wells will not be decided until the
additional pre-design investigations are complete.
With respect to Esso's contribution of VOC's to groundwater, EPA
agrees that monitoring well data indicate a probable impact in the
vicinity of the service station.
(2) O'Henry states that since the gasoline additive, MTBE, can be
traced from Texaco and Esso as far downgradient as the Delegarde
well, that Esso must be considered a source of impact to
groundwater all the way to the Delegarde well. Furthermore,
O'Henry contends that the groundwater flow maps in the RI
misrepresent flow in the vicinity of O'Henry. . O'Henry's
consultant, IT, has recontoured the VOC maps from the RI to show
their interpretation that groundwater from O'Henry is separated
from the southern VOC plume-by a groundwater divide, whereas Esso
is upgradient of the VOC plume and, by implication, the principal
source of i't.
EPA Response: Although the distribution of the gasoline additive
MTBE in site groundwater strongly suggests that some constituents
in groundwater originating at Esso have traveled past O'Henry to
the leading edge of the plume, it is unclear that either BTEX or
VOCs from Esso have traveled that far. VOCs do not travel as
quickly as MTBE and therefore, will not migrate as far in a given
amount of time. Concentrations of total VOCs in groundwater
downgradient of Esso, but upgradient of O'Henry, range from non-
detect to 19 ug/1. Downgradient of O'Henry, concentrations
increase to greater than 100 ug/1. The Eglin wells, which are
located between the two facilities had total VOC concentrations up
to 74 ug/1, but they have been pumping and could draw water from
O'Henry as well as from Esso.
The effects of historical and current well pumping complicate the
interpretation. The historical pumping of the Harvey well near
O'Henry and the current pumping of the Eglin wells has probably
significantly affected the migration of VOC contamination from Esso
and O'Henry. Based on the available groundwater quality and flow
data, it is unclear at this point in time whether Esso VOCs are
commingled with the VOC plume from O'Henry. Additional groundwater
sampling of Esso's and other monitoring wells during the pre-design
stage, combined with groundwater modeling to be performed during
the extraction system design stage, should assist in the
determination of the extent of VOC migration from the Esso station.
12
-------
The depictions of groundwater flow direction and contaminant
distribution presented in the RI are reasonable, honor all
available data, and fit the regional flow field. There is a degree
of interpretation to the flow direction, due to the spacing of the
wells, but this is not sufficient to change the overall
conclusions. 0'Henry's interpretation of groundwater flow relies
upon the inference of a groundwater divide to separate groundwater
flow emanating from O'Henry from that of Esso. However, this
groundwater "high" transects the topographic ridge east of O'Henry
and was observed in only one round of deep well data. It is not
apparent in either sampling round in the shallow groundwater data,
which is where a topographic influence on groundwater flow might be
expected. The O'Henry interpretation of flow and contaminant
distribution does not take into consideration the effect of pumping
the Eglin wells.
(3) O'Henry states that a flow path between the Harvey well and the
Smith or La Place wells is impossible, considering their
interpreted flow paths. Therefore the VOCs detected in these wells
must come from Esso, not O'Henry.
EPA Response:
Based on groundwater flow maps presented in the RI, the Smith and
LaPlace wells do appear to be located cross-gradient from the
O'Henry plume. However, the flow fields presented in the RI do not
consider the effects of pumping from the 'Eglin wells, which would
partially draw O'Henry VOCs towards the east. Also, impacts on
flow fields from pumping at the Smith and LaPlace wells need to be
considered. The Tutu aquifer is a complex fracture flow system,
where flow will preferentially follow high conductivity zones.
O'Henry cannot be ruled out as a contributor of contamination in
these residential wells based on a literal interpretation of the RI
flow maps.
Groundwater Flow in the Vicinity of Esso
(1) Western Auto's consultant, ENSR, commented on the lack of
supporting data for a perched water table and the calculated
groundwater velocity at Esso presented in Esso's plan for source
control investigations, prepared by Forensic Environmental
Services.
EPA Response:
One of the purposes of the source control investigations is to
collect additional data to refine the current interpretation of
groundwater flow at the Esso station to improve the source control
design. The estimates presented in the work plan will be modified
as new site data become available.
Current Location of Groundwater Contaminant Plumes
11
-------
(1) 0'Henry commented that most of the groundwater elevation data
in the RI was collected during a drought. Since Hurricane Marilyn,
rainfall has increased dramatically and it is possible that the
location of the groundwater contamination plumes have shifted.
EPA Response:
Additional water level and contaminant concentration data will need
to be collected during the design stage. This information will be
used in conjunction with groundwater flow and transport modeling to
ensure adequate placement of extraction wells to capture the
contamination in the Tutu aquifer.
Presence of DNAPLs at O*Henry
(1) 0'Henry comments that the actual evidence obtained during the
remediation of the soil at the O'Henry Dry Cleaning Store
demonstrates that DNAPL contamination is not present in the soil.
EPA Response: The possible presence of DNAPLs beneath the O1Henry
building or in fractures above or below the water table cannot be
ruled out, even with the recent excavation data. DNAPLs can be
very difficult to locate in the subsurface. Their probable
presence is indicated by the very elevated concentrations of PCE
(at greater than 1% of its solubility) detected in the Harvey well
in the past and are supported by the historical site usage/disposal
of PCE filters. Concentrations of PCE in the Harvey well are now an
order of magnitude lower than in the past. However, the
groundwater flow field has changed in the past few years. Under
its current non-pumping conditions, the Harvey well could now be
cross gradient, rather than downgradient of a potential source of
DNAPLs. DNAPL is very persistent in the environment. If DNAPLs
were present in 1991 when the Harvey well concentrations were high,
they are likely to be present still.
If DNAPL is present, it may very well significantly affect the
duration of the remedy and the potential for complete aquifer
restoration in the vicinity. If it is present, a technical
impracticability waiver for ARARs achievement may ultimately be
required, because such groundwater cleanup objectives might not be
achievable.
Proposed Soil Remedy for O'Henry
(1) 0'Henry protested the proposed remedy of excavation and soil
vapor extraction, stating that remediation has already occurred at
O'Henry when they excavated soils behind the facility in 1995 with
EPA approval and oversight. Further, it is O'Henry's opinion that
the cleanup standards provided by EPA have been incorrectly
calculated because they do not take into account all site-specific
data.
-------
EPA Response: The soils at O'Henry were excavated before EPA had
finalized their vadose zone modeling to determine soil cleanup
levels that would be protective of groundwater. O'Henry was aware
at the time of the provisional nature of the cleanup goal they were
using to define the excavation limits. Regardless, concentrations
of PCE detected in the excavation walls are high enough to result
in groundwater concentrations above MCLs, whether IT's VLEACH model
or EPA's soil leaching model are used. EPA re-ran its soil
leaching model, incorporating the newly available site-specific
data from 0'Henry and using a soil contaminant profile of the
current, post-excavation concentrations of PCE. The resulting
groundwater concentrations are still above drinking water
standards, therefore EPA considers that soils at 0'Henry still-
require remediation.
EPA's selected remedy does not call for any further excavation at
O1Henry unless in-situ SVE does not work. However, soil vapor
extraction must be attempted to reduce the remaining VOC
concentrations in soil.
Technical Feasibility of Remediating the Tutu Aquifer
(1) 0'Henry commented that there is no basis in the administrative
record to assume that cleanup to groundwater standards through the
decommissioning of existing wells and installation of groundwater
recovery wells will be cost effective or will result in restoration
of the groundwater to drinking water standards.
EPA Response: EPA acknowledges that it may not be possible to
restore the entire aquifer to drinking water standards, especially
if DNAPLs are present. However, if such sources are locally
present and are controlled to contain their spread, then it should
at least be technically feasible to restore the remainder of the
aquifer to a potable water supply within a reasonable time frame.
E. REMAINING CONCERNS
Issues and concerns that EPA was unable to address during remedial
planning activities include the following:
• Will EPA intensify its sampling program once groundwater
from the affected wells is considered safe for human
consumption?
As part of the operation and maintenance plan to be
implemented after construction of the remedy is complete,
long-term semi-annual sampling of approximately 15 wells
at or near the plumes will be conducted. During that
time, EPA will re-evaluate its sampling program to
determine if more frequent or less frequent testing is
warranted.
15
-------
The LWWI is concerned that, during the March 5, 1996
public meeting, ATSDR stated that the population affected
by the Tutu well pollution is too small to merit an
epidemiological study, although ATSDR will conduct an
education program for local health care professionals.
The LWWI would like the dissemination of information to
extend to non-professionals in the community and has
offered to help with publicity and follow-up activities
through the local media.
EPA welcomes any efforts that the LWWI is willing to
make in concert with the ATSDR to reach the general
community with information about health risks associated
with the site. Involvement of the LWWI in news articles
and radio and television programs would be helpful.
LWWI' s letter of offer of assistance was forwarded to
Steve Jones, ATSDR Regional Representative. He is
located at 290 Broadway , 18th Floor, New York, NY 10007-
1866.
16
-------
ATTACHMENT A
COMMUNITY RELATIONS ACTIVITIES
AT THE TUTU WELLPIELD SUPERFUND SITE
Community relations activities conducted at the Tutu Wellfield
Superfund Site have included:
• EPA conducted community interviews with local residents
and property owners, personnel from the VI Department of
Health and DPNR, and a member of the VI legislature
(February 1992)
• EPA prepared Community Relations Plan (April 1992)
• EPA established information repositories at the Tutu Hi
Rise building and the DPNR office at the Nisky Shopping
Center (April 1992), since moved to the Wheatley Shopping
Center II following Hurricane Marilyn
• EPA prepared and distributed a fact sheet that describes
the Superfund program and reviewed the history of the
Tutu Wellfield site, and opportunities for community
involvement (April 1992)
• EPA issued a notice in the paper advertising a public
meeting to discuss the work plan for the remedial
investigation (May 1992)
• EPA held its first public meeting to discuss the work
plan for the remedial investigation/feasibility study
(RI/FS), present an overview of the Superfund process,
and discuss risk assessment investigations (May 1992)
• EPA prepared and distributed a fact sheet outlining the
schedule and work tasks of the remedial investigation
(May 1992)
• ATSDR conducted an assessment of public health concerns
and held two public meetings in the community, but there
was no attendance (December 1992)
• EPA conducted a second set of interviews in the. Tutu
community to gain a firsthand perspective on the
effectiveness of its community relations activities thus
far (October 1994)
• EPA relocated the information repository from the Tutu Hi
Rise Housing Authority to the Department of Education
Curriculum Center, per several requests from the public
(October 1994)
17
-------
• EPA mailed letters to residential well owners in Tutu,
explaining their well sampling results (February 1995)
• EPA prepared and distributed a fact sheet to over 1400
members of the affected community addressing concerns
citizens have raised during the October - November 1994
interviews. The fact sheet was prepared in a question
and answer format. The fact sheet also contained
information explaining presumptive remedy and soil vapor
extraction (March 1995)
• EPA prepared Revised Community Relations Plan (March
1995)
• EPA prepared and distributed flyers announcing an
informal availability session held at Curriculum Center
in Anna's Retreat (April 1995)
• EPA held an informal .availability session at the
Curriculum Center in Anna's Retreat. Technical
specialists were present with maps and figures" to answer
questions on groundwater and soil contamination,
contaminate movement through subsurface, and cleanup
technologies (April 1995)
• EPA publicized a public comment period to be held from
February 12, 1996 to March 13, 1996 by advertising in the
local newspapers, on the radio, distributing flyers and
displaying posters (February 1996)
• EPA held a public meeting at the Curriculum Center in St.
Thomas to record comments by the public on results of the
RI/FS and the.proposed plan (March 1996). A transcript
of this hearing is available at the information
repositories located at the Curriculum Center and DPNR.
18
-------
TWO THOUSAND WESTCHESTER AVENUE
WHITE PLAINS. N. Y. IO65O
March 12, 1996
Caroline Kwan
Remedial Project Manager
U.S. Environmental Protection Agency
290 Broadway, 20th Floor
New York, NY 10007-1866
RE: Tutu Wellfield NPL Site
Revised Superfund Proposed Plan
Dear Ms. Kwan:
These brief comments regarding the above-referenced draft document
are submitted on behalf of Texaco Caribbean Inc. (TCI). TCI has
been identified by the Environmental Protection Agency (EPA) as a
potentially responsible party (PRP) at the Tutu Wellfield site.
1. It is unclear from the legend and map in Figure 1 which
portions of the plumes indicated represent Chlorinated VOCs >100
ppb.
2. On page 8, right column, we believe that following should be
added to the soil objectives in the section titled "Remedial Action
Objectives"
Removal of contaminants of concern in-situ, where practicable.
3. On page 9, left column, we believe that the following language
should be added after the first paragraph in the section titled
Soil Remedial Alternatives (SRA) for Impacted Soil":
These SCPs can be implemented as early as Spring 1996.
As we have discussed, Texaco has designed and is prepared to
implement a remedial system to fulfill the SCP objectives
articulated in the Proposed Plan.
4. On page 9, right column, we believe that the language in the
third bullet in SRA 1 overstates the objective and should be
reworded to say that soil or rock from impacted areas should not be
removed unless it is appropriately tested and then, if indicated,
properly treated or disposed of.
5. On page 10, right column, we believe that the language in the
first full paragraph after the bullets related to SRA 3 should be
-------
modified to state that: "The SVE systems described would be
operational until VOCs are present in the extraction well air vapor
stream at acceptable levels."
6. On page 12, left column, we believe that the following language
should be added after the first paragraph in the section titled
Groundwater Remedial Alternatives (GRA) for Impacted Groundwater":
These SCPs can be implemented as early as Spring 1996.
Again, as we have discussed, Texaco has designed and is prepared to
implement a remedial system to fulfill the SCP objectives
articulated in the Proposed Plan.
7, Regarding GRAs 2-4, we believe that EPA has previously
indicated that connection to the WAPA system is a possible
component of the alternatives. If this is the case, it should be
indicated in the title and text of the alternative descriptions.
Thank you for this opportunity to comment on the Proposed Plan
document. Feel free to contact me at 914-253-4633 to discuss these
comments.
Sincerely,
Timothy R. ""Rhutson
Counsel for Texaco Caribbean Inc.
-------
EN5R
Consulting • Engineering • Remediation ' & Naoog Park
Acton. MA 01720
(508) 635-9500
March 13, 1996 FAX (508,635-9! 30
ENSR Ref. No: 7218-001
ENSR Doc. No: 55-DPG-552
Ms. Caroline Kwan
Emergency and Remedial Response Division
U.S. Environmental Protection Agency
26 Federal Plaza
New York, NY 10278
RE: Comments on Draft Final FS
Tutu Wells Site, St. Thomas, U.S. Virgin Islands
Dear Ms. Kwan:
At the request of Western Auto's attorneys, this letter provides comments on the Draft Final
Feasibility Study (FS).
• The use of Esso Tutu SSL values at Western Auto is inconsistent with the
available geologic Information.
On page 2-15, paragraph 1 it Is stated that the SSL values developed for Tutu Esso are used for
all properties in the Tutu Site region, except those where site specific SSLs were developed,
because '...the subsurface conditions at the Esso Tutu Service Station are representative of
conditions throughout the Tutu Valley". This means that the SSL values developed for Esso Tutu
have been used for the former underground storage tank (UST) area behind Western Auto.
However, the geologic conditions behind Western Auto are not similar to those at Esso Tutu, or
elsewhere in Tutu Valley. This is, in fact, stated in the FS on page 2-5 (paragraph 1, last
sentence) as follows... * An exception to this condition was observed at Western Auto, where
alluvial deposits were only saturated in a perched zone within a gravel layer overlying a clay
layer*.
The hydraulic conductivity of the clay at Western Auto is extremely low with measurements
values of 1.2 x 10"9 and 4.3 x 10* (see enclosed Stephens and Associates report). The very low
hydraulic conductivity and the continuous extent of this day layer creates a condition unlike that
elsewhere in Tutu Valley. These geologic conditions effectively Isolate the overlying alluvial
material from the groundwater. Since the intent of the SSL values is apparently to provide soil
cleanup values that are protective of groundwater and appropriate for site specific conditions,
it is dear that the Esso Tutu SSL values are inappropriate for Western Auto. Site-specific
cleanup values that consider the extremely low transport in the day layer at Western Auto should
be calculated.
-------
ENR
Ms. Caroline Kwan
March 13. 1996
Page 2
• SSL values for benzene should not be applied Tor other BTEX parameters.
It is apparent from FS Table 2-4 that the same SSL values have been used for all of the BTEX
parameters. Based on Table 1 included with EPA's comments on the draft FS, it appears as if
the SSL values were determined from an analysis of benzene. Applying SSL values derived for
benzene for the other BTEX parameters (toluene, ethylbenzene, and xylenes) is inappropriate
and overly conservative.
The drinking water standard or Maximum Contaminant Level (MCL) value for benzene is 5 ppb,
while MCL values for toluene, .ethylbenzene, and xylenes are 1000 ppb, 700 ppb, and 10,000 ppb
respectively. Since soil cleanup levels are a function of toxicity and mobility, the SSLs for BTEX
parameters other than benzene are much too stringent Based on toxicity alone, the SSLs for
xylenes are at least 2000 times too stringent.
• The proposed soil excavation at Western Auto is based on Inappropriate
data.
The basis for the proposed soil excavation at Western Auto is presumably the comparison
between the soil contaminant concentration data and SSL values presented In Table 2-4. The
Western Auto soil contaminant concentration data is not appropriate for this comparison because
the soil samples used in the comparison are from soil that was excavated and removed from the
site. Also, as pointed out in our comments on the draft FS, the sample wrth the highest BTEX
concentrations (SS-1) is not a soil sample. Sample SS-1 is presented as a soil sample (page
2-19; paragraph 3) but is actually a sample of product that leaked out of the waste oil vent pipe
after the pipe was inadvertently ruptured during the tank removal.
In addition to the inappropriate soil data that has been used in the comparison, the SSL values
are also inappropriate. As discussed above, SSL values derived for Esso Tutu are used for
Western Auto, even though the geologic conditions that would determine site-specific deanup
values are significantly different for the two sites. As also discussed above, SSL values derived
for benzene have been used for the other BTEX parameters, even though SSLs for the other
BTEX parameters should be orders of magnitude higher than those for benzene.
• The extent of the proposed excavation for Western Auto is not Justified.
A soil remediation option for Western Auto consisting of excavation is discussed In Section
4.6.2.5. A soil excavation volume of 181 cubic yards for Western Auto is developed in Table 4-5
and the estimated cost for the excavation option is developed in Table 5-6.
We have several concerns with this item. First, the amount of soil to be excavated should be
justified. We made this comment on the draft FS and EPA apparently agreed to our comment
-------
EKR.
Ms. Caroline Kwan
March 13,1996
Page 3
since In their response to our comment they stated"... the FS should clearly explain how affected
areas and depths were obtained for all sites.* Table 4-5 provides the input values for the volume
calculation, consisting of estimated depths and areas of impacted soils; however, no source or
justification for these input parameters has been provided.
Second, the draft FS proposed a soil removal volume of 133 cubic yards and this value has
somehow been increased to 181 cubic yards in the draft final FS. No justification was provided
for the previous value in the draft FS, and no justification has been provided for the change in
the value in the current version of the FS.
Finally, it is not clear that any soil at all should be removed from the site given the inappropriate
soil contaminant concentration data and SSL values (as discussed above) used in the
comparison that Is the basis for the proposed excavation.
• The value of the soil remediation credit is Incorrect and the methodology of
application of the credit Is confusing.
A 'credit* for 35 cubic yards of soil previously removed and replaced with clean backfill has been
included as part of the soil excavation option .for Western Auto. This is stated on page 4-51 and
reflected in the amount of soil to be disposed of, as indicated on Table 5-6.
The 35 cubic yard value is apparently incorrect. During soil removal associated with UST
closure, 85 cubic yards of material were excavated and removed from the area. This is
discussed in the ENSR June 1994 report on UST closure. In addition, Geraghty and Miller
removed substantial amounts of material during the installation of monitoring well MW-24. The
source of the incorrect 35 cubic yard value is not provided in the FS.
Also, the methodology for application of the credit is confusing. The proposed area of
excavation at Western Auto shown on FS Figure 4-5 is largely encompassed by the area of soil
removed during the tank closure activities. Figure 3 of the June 1994 UST Closure Report shows
this area. Since the FS apparently proposes excavation of the same area as that previously
remediated, it is not dear what is meant by a 'credit* and how the credit is to be applied.
• Discussion of remediation of the 4-inch PVC pipe should be Included in an FS
section on Four Winds, not Western Auto.
Remediation of the 4-Inch PVC pipe is discussed in Section 4.6.2.5, the Western Auto soil
remediation section. It is stated that the *...PVC pipe is not related to Western Auto operations.
However, the further investigation and possible remediation of the PVC pipe should be
coordinated with Western Auto due to the proximity of the PVC pipe and the former Western
Auto USTs.*
-------
EhRR
Ms. Caroline Kwan
March 13, 1996
Page 4
As we have pointed out previously, the 4-Inch PVC pipe has already been removed from the
ground, not only in the vicinity of the former USTs but up to the edge of the Four Winds building
where it is capped. The pipe is still intact under the Four Winds building. Remediation of the
pipe should be evaluated but this effort is clearly associated with the Four Winds property, not
Western Auto. Including a discussion of this effort In the Western Auto section gives the
impression that it is the responsibility of Western Auto, even though a statement to the contrary
has been Included.
• Capping '19 the most appropriate soil remediation technique for Western Auto.
Section 4.6.2.5 discusses the two retained Western Auto soil remediation options, excavation and
capping. Table 5-4 sets forth estimated capital costs for capping 117 square yards behind
Western Auto.
Section 4.6.2.5 only briefly mentions capping but has a relatively extensive- discussion of
excavation, giving the Impression that excavation is the preferred alternative. However, given the
previously performed soil removal, and the impermeable nature of the day soil in the region
combined with related lack of a transport mechanism for any remaining low levels of
contaminants in soil to reach groundwater, capping provides the best remedial option for this
area. Furthermore, Four Winds has already capped the vast majority of this area with a thick
layer of concrete. The only portion remaining to be capped is a narrow band associated with
the trench left over from removal of the 4-inch pipe.
Also, the source and justification for the value of 117 square yards associated with the capping
option in Table 5-4 are not provided.
• The Gore-Sorber study results indicate that both diesel and heavy range
hydrocarbons, unrelated to Western Auto operations, are present upgradlent
under the Four Winds building.
On page 2-16, paragraph 2 of the final FS it is stated that"... at the Four Winds Plaza, potential
Impacts to soil cannot be ruled out due to the detection of elevated soil gas concentrations of
diesel components.' The Gore-Sorber data indeed indicate the presence of diesel range
petroleum hydrocarbons beneath the Four Winds building. However, the Gore-Sorber results
also indicate the presence of heavy range petroleum hydrocarbons under the building, wrth the
highest concentrations centered under the Cost-U-Less store.
The maximum concentration of C1B compounds in the Gore-Sorber study was 2.2 pg/sorber,
while the highest concentration of tridecane was 1.0 -1.2 pg/sorber. Tridecane is representative
of diesel range petroleum hydrocarbons. C18 compounds are at the upper weight range of the
compounds detected by Gore-Sorbers and therefore are representative of heavy range petroleum
hydrocarbons. Higher weight compounds are less volatile than lower weight compounds (such
as tridecane) and thus are less amenable to soil vapor detection. Based on this, it is expected
-------
Ms. Caroline Kwan
March 13, 1996
PageS
that C18 measurements would be much lower than tridecane measurements, unless there were
much greater concentrations of heavier weight petroleum hydrocarbons present. Since C18
compounds were measured at higher concentrations than tridecane, there must be significant
concentrations of heavy weight petroleum hydrocarbons present under the Four Winds building.
In summary, the Gore-Sorber data indicate that both diesel and heavy weight petroleum
hydrocarbons are present under the Four Winds building. This data and the other available
information also indicate that the peak concentrations of this contamination are located under
the building, upgradient of the former Western Auto LIST location. This petroleum contamination
was apparently transported into the former UST location via the 4-inch PVC pipe and the gravel
layer, which acted as transport mechanisms.
• In sum, the objective data pertinent to the soil condition behind Western Auto
conclusively indicates that any contamination behind the Four Winds Plaza
is an isolated condition unrelated to the Tutu Aquifer.
The scientific data which has been gathered and analyzed pertaining to the area behind Four
Winds Plaza points to the conclusion that any contamination present in the soil remained in the
soil and could not have been transported to the Tutu Aquifer. The data which leads to this
conclusion may be summarized as follows:
- The hydraulic conductivity of the clay soils in which the USTs were located has been
measured at values of 1.2 x 10"9 and 4.3 x 10**, values which virtually preclude any
transport. The lack of transport is demonstrated by the documented perched water table
condition existing behind the Four Winds building.
- Groundwater testing and data from MW-24 conclusively demonstrates that there has
been no contribution of contaminants to groundwater directly beneath the location of the
former USTs.
- The area has historically been paved and, in fact, was recently largely capped with a
thick layer of concrete. The only area remaining uncapped is a strip directly above the
path of the 4-inch PVC pipe which was removed and capped at approximately the time
of the tank removal.
- Western Auto has removed and disposed of 85 cubic yards of contaminated material
near the location of the former USTs. This area was then lined with a plastic liner and
backfilled with dean soil. Geraghty and Miller removed additional soil during the
installation of MW-24.
-------
Ms. Caroline Kwan
March 13, 1996
Pages
In addition, it should be noted that the most significant contamination concern at the Tutu site
is the chlorinated VOC contamination of groundwater. Essentially ail the discussion with respect
to potential contamination at Western Auto is related to petroleum constituents. Chlorinated
VOCs and, in particular, chlorinated VOC contamination of groundwater are not even an issue
for Western Auto.
We appreciate the opportunity to provide EPA with comments on the FS. Please feeJ free to
contact us with any questions that you may have on our comments.
Sincerely,
Donald P. Galya, P.E.
Program Director
John Bierschenk, P.G.
Senior Remediation Geologist
Eric Butler, Ph.D.
Senior Consulting Chemist
TOTftL P.07
-------
Consulting • Engineering • Remediation 35 Nagog Park
Acton, MA 01720
(508) 635-9500 '
FAX (508) 635-9180
March 13, 1996
ENSR Ret. No: 7218-001
ENSR Doc. No: 55-DPG-553
Ms. Caroline Kwan
Emergency and Remedial Response Division
U.S. Environmental Protection Agency
26 Federal Plaza
New York, NY 10278
RE: Comments on Forensic Esso Tutu Station Report
Tutu Wells Site, St Thomas, U.S. Virgin Islands
Dear Ms. Kwan:
At the request of Western Auto Supply Company's attorneys, ENSR Consulting and Engineering
has reviewed the February 1995 Forensic Environmental Services report "Site Remediation and
Supplemental Investigation Program: Esso Tutu Service Station'. This letter contains comments
on that document. Comments on this document are being presented to the US EPA because
of their relevance to the Remedial Investigation/Feasibility Study process.
• The evidence for a perched water table at Esso Tutu appears to be confusing
and non-convincing.
In Section 2.1.2 (pages 2-3 and 2-4) it is stated that there Is a region of perched groundwater in
the vicinity of well SW-7. Hydraulic conductivity values from slug tests for wells SW-1, SW-3,
MW-8, and DW-1 are presented. The lowest conductivity values are located at wells SW-i and
SW-3.
It is not clear from this information what the site specific conditions are that cause the perched
water table. The lowest conductivity values are at wells SW-1 and SW-3, but apparently
groundwater is not perched in those locations. Also, the hydraulic conductivity value for well
SW-7 is given. Finalry, the data and analyses by which the hydraulic conductivity values were
derived are not presented.
-------
ENR
Ms. Caroline Kwan
March 13, 1996
Page 2
• The calculated groundwater velocity is not supported by adequate scientific
Justification.
In Section 2.1.2 (page 2-4) a groundwater velocity of 4.7 feet/year is calculated assuming an
effective porosity of 0.15. The actual calculation for the velocity is not shown. Assumed values
of parameters such as hydraulic conductivity and the hydraulic gradient that are necessary for
the calculation of groundwater velocity are not stated. Rational for the assumed porosity value
of 0.15 is not provided; however, this value can range from 0 to 0.5 for various types of fractured
bedrock. Also, the use of an effective porosity to calculate groundwater velocity in a fractured
bedrock system assumes that an equivalent porous medium approximation is appropriate. No
information is provided to justify this assumption. Finally, the calculated groundwater velocity
does not appear to be correct based on the contaminant plume in the Tutu aquifer.
• The Esso Tutu chlorinated VOC soil data do not define the limit of
contamination and the existing data Indicate significant contaminant levels.
In Section 2.2.2 (page 2-7) it is stated that Esso Tutu soil samples SS-1 and SS-6 define the
eastern and western extent of contamination and that Esso soil samples SS-4 and SS-5 define
the north and south extent of contamination. It Is also stated that Esso sample SS-1, obtained
from a depth of nine feet, had non-detectable levels of chlorinated VOCs, implying that this
sample defines the vertical extent of contamination.
Esso sample SS-1 does not define either the horizontal or vertical extent of chlorinated VOC
contamination. The detection limit for all chlorinated VOCs in this sample was 1600 ppb, too
high to be a reliable indicator of the absence of contamination. Also, significant levels of
chlorinated VOCs were detected in Esso samples SS-3, SS-7, and SS-B, which are located in the
same horizontal location as Esso sample SS-1. This provides further Indication that the
horizontal extent of contamination is not defined. Finally, it is not clear how Esso samples SS-4
and SS-5 could define the extent of north and south contamination. Both are located too close
to each other and are not located to the north and south of the location of the highest detectable
chlorinated VOC concentrations (Esso sample SS-3). The attached foldout figure (Figure 1)
graphically portrays the PCE and 1,2 DCE soil data at Esso Tutu.
• The groundwater and soil data Indicate that there is a significant potential for
a chlorinated VOC contribution to groundwater from Esso Tutu.
Section 2.3.4 uses data from monitoring wells CHT-4, CHT-7D, MW-8, MW-10, and MW-10D to
determine whether the Esso Tutu station has had an impact on groundwater concentrations of
chlorinated VOCs. This determination is made using a statistical analysis of groundwater
concentrations and relative weight ratios of tetrachlorethene (PCE), trichloroethene (TCE), and
-------
Ms. Caroline Kwan
March 13. 1996
Pages
1,2-dichloroethene (DCE). The analysis indicated that relative weight ratios and concentrations
of PCE, TCE, and DCE were statistically similar upgradient and downgradient of the station.
This analysis does not demonstrate that Esso Tutu has had no Impact on chlorinated VOCs
concentrations in groundwater. This is primarily because the analysis does not consider the
overall decrease or downward gradient in chlorinated VOCs in the Tutu aquifer. There Is a
substantial decrease in groundwater concentrations of chlorinated VOC from north to south down
the Tutu valley from the Laga facility. .A, chlorinated VOC source in this area may add
contaminants to the aquifer without causing a noticeable increase in concentrations, but may
decrease the contaminant concentration gradient or rate of contaminant concentration decrease.
This is, in fact, seen with PCE concentrations at the site. Calculating the concentration gradient
using Geraghty & Miller PCE data reported in the Rl at wells MW-1 (near Lags), MW-7 (south of
Tillet), MW-8 (north of Esso Tutu), and MW-10 (south of Esso Tutu). To the north of Esso Tutu,
the concentration gradients of PCE between MW-t and MW-7, MW-1 and MW-8,and MW-7 and
MW-6 were determined to be 0.36 ppb/ft, 0.37 ppb/ft, and 0.38 ppb/ft, respectively. In contrast,
the concentration gradient across Esso Tutu, from MW-B to MW-10, Is 0.019 ppb/ft. These
gradients provide an indication of the rate of PCE decrease in terms of concentration decrease
(in ppb) per foot of distance. The substantially lower concentration gradient from MW-8 to MW-
10 indicates that rate of decrease in PCE concentration across Esso Tutu is substantially less
than the same rate from Laga down to Esso Tutu. This trend is graphically demonstrated in the.
attached figure (Figure 2) showing PCE concentration values in groundwater at monitoring wells
MW-1, MW-7, MW-8. and MW-10. This information Indicates that Esso Tutu could be impacting
PCE groundwater concentrations.
The similarity of relative weight ratios seen in the Forensic analysis could be attributable to the
relative proximity of the wells used and the pumping influence of the Four Winds wells. The Four
Winds wells could have influenced the chlorinated VOC concentrations in the wells that Forensic
has used as upgradient wells (monitoring wells CHT-4 and MW-8). In fact, if relative weight ratios
are calculated (using data from the Rl) for well MW-7, which is the nearest well upgradient of the
Four Winds wells, values of 38.6%, 8.0%, and 53.4% are obtained for PCE, TCE, and DCE,
respectively. The PCE and DCE relative weight ratios for well MW-7 are significantly different
than the corresponding ratios for the wells near Esso Tutu, again indicating that there may be
an impact on groundwater concentrations of chlorinated VOCs at that facility.
Finally, the concentrations of chlorinated VOCs in soil at Esso Tutu Indicate the potential for
groundwater contamination. Table 2-4 of the FS shows soil concentrations above SSLs (soil
screening levels). One of the Esso Tutu samples shown in FS Table 2-4 indicates a PCE
concentration of 1500 ppb at a depth of 7 feet. The SSL value at Esso Tutu is 32 ppb for PCE
in soils that are greater than 4 feet in depth. It should be noted that the USEPA developed the
Esso Tutu SSL values specifically to be protective of groundwater at Esso Tutu. An exceedance
of the standard by a factor of greater than forty Indicates a significant potential for groundwater
-------
EKR,
Ms. Caroline Kwan
March 13, 1996
Page 4
contamination. At a nine foot depth in the same location as the sample discussed above, a
sample with a non-detect at 1600 ppb was obtained. Both of these samples were located at
depths less than 10 feet to groundwater. There was no deeper sample at this location with a
relatively low detection limit. This indicates that there is a significant potential for groundwater
contamination through the soil route at this location.
Please feel free to contact us with any questions that you may have on these comments.
Sincerely,
Donald P. Garya, P.E
Program Director
64.
John Bierschenk, P.G.
Senior Remediation Geologist
TOTftL P.05
-------
THE LEAGUE
OF WOMEN VOTERS
POST OFFICE BOX 638 « ST. THOMAS, U.S. VIRGIN ISLANDS 00804 • (809) 774-8620
10 March 1996
Response to the Revised Superfund Proposed Plan
Tutu Wellfield Site, St. Thomas, Virgin Islands
The League of Women Voters of the Virgin Islands (League, LWVVI) is pleased to respond
favorably to the Revised Superfund Plan for the Tutu Wellfield Site, St. Thomas, U. S. Virgin
Islands. The League's Committee on Planning and Environmental Quality (PEQ) has examined all
of the alternatives carefully and agree that a combination of Soil Remediation Alternatives 3 and
4, and the Groundwater Remediation Alternative 4 provide the greatest potential for protection of
human health and the environment of the site.
LWWI has two remaining concerns related to public health and acquifer testing. Regarding the
testing schedule, semi-annual sampling of approximately 15 wells at or near the plume for VOCs
and BNAs is recommended. This is to continue through the remedial period of 30 years. Our
question is whether, if and when any of these wells are considered sufficiently safe for human
consumption, the testing will be increased to a monthly (or at least bi-monthly) schedule? The
rationale for this request is based on the fact that DNAPLs or contaminants from other sources
could apparently enter the water at any time, and the water be totally consumed by unsuspecting
buyers over the next few months before discovery.
At the March 5th hearing , one of the representatives of the Agency for Toxic Substances and
Disease Registry (ATSDR) stated that the population affected by the Tutu well pollution is too
small to merit an epidemiological study. This was disturbing to many in the audience. ATSDR
will conduct an education program for local health care pi ofessionals to assure thai they know
what to look for and how to respond to the signs of disease. We believe that an intense program
of this sort will certainly be very helpful, but that the dissemination of information to non-
professionals is equally important - in other words, additional efforts must be made to reach the
less well-educated and less environmentally aware of the community. The League would be
pleased to help with publicity and with follow-up activities through the local media: news articles,
radio or television programs. Please let us know how we can help.
Sincerely,
s**L&4-£*A— £'/ls '
Helen W. Gjessin^EQ Chtfir
ANNIVERSARY
1920-1995
-------
' NANCY D'ANNA
ATTORNEY AT LAW
P.O. BOX 833O. CRUZ BAY
ST. JOHN, U.S. VIRGIN ISLANDS OO83I
(809) 77(5-6533 FAX (8O9) 776-62(50
March 12, 1996
By Telefax and Mail
(212) - 637 - 3966
EXPRESS MAIL '
Caroline Kwan, Project Manager
New York/Caribbean Superfund Branch 2
U.S. EPA Region II
290 Broadway, 20th Floor
New York, New York 10007-1866
Re: Comments on "Feasibility Study" and "Proposed Plan for
Remediation", Tutu Well Site, St. Thomas,
Virgin Islands
Dear Ms. Kwan:
Enclosed are three copies of the comments prepared by my
office on the above referenced documents. These comments are
provided on behalf of my client, L'Henri, Inc. These comments are
being transmitted to counsel for the members of the group of
Potentially Responsible Parties. Please feel free to contact my
office, if you have any questions concerning this matter.
Sincerely,
Nancy D'Anna, Esq.
ND/aw
-------
COMMENTS ON FEASIBILITY STUDY AND PROPOSED PLAN FOR REMEDIATION
TUTU WELL SITE, ST. THOMAS, UNITED STATES VIRGIN ISLANDS
SUBMITTED ON BEHALF OF L'HENRI, INC.
I. General Comments
Upon review of the administrative record maintained for Tut-u
Well Site, St. Thomas, United States Virgin Islands, it is
apparent, that International Technology Corporation, ("IT") on
behalf of L'Henri, Inc. has previously submitted comments on the
Report of the Remedial Investigation, (attached as Exhibit 1), the
Draft Feasibility Study (attached as Exhibit 2) and the Comments of
the United States Environmental Protection Agency on the Report
prepared by IT of the Soil Remediation conducted at the 0'Henry Dry
Cleaners, (attached as Exhibit 3). There are basic conclusions
reached in the forgoing documents which appear to be inconsistent
with the data generated from the sampling at the Tutu Well Site.
On behalf of L'Henri, Inc., IT has previously submitted comments on
these inconsistencies. As set forth in more detail below, we again
reiterate those comments previously submitted.
A. The conclusion that L'Henri is the primary source of
contamination of chlorinated compounds in the southern portion of
the aquifer is not supported by the data concerning crroundwater
flow, or an accurate interpretation of the VOC plume.
As stated previously, in the comments submitted by IT on
behalf of L'Henri, Inc. the most appropriate depiction of the deep
groundwater elevation contour map for the area down gradient from
the 0'Henry dry cleaning store is contained in the map drawn for
data collected on May 10, 1994. This map is most appropriate
because it contains data from the Steele, Harvey, Eglin II, and
-------
Eglin III wells. As demonstrated on the May 10, 1994 map, deep
aroundwater, and consequently contaminants, would flow southwest,
beneath the 0'Henry dry cleaning store. The flow path from the
0'Henry dry cleaning store does not pass through the location of
the Steele or LaPlace wells. Shallow groundwater flow is generally
southwesterly in the vicinity of O'Henry. See, Exhibit 1, general
comment 1 and attached depictions of the deep and shallow
groundwater flow maps) , Exhibit 2 Comment on Section 2.1.1.3.
The presentation of the TGE, PCE, AND 1,2 DCE in the deep
groundwater is not consistent with the appropriate deep groundwater
flow map as presented in the Report of the Remedial Investigation.
A more consistent depiction' of the plumes was submitted by IT with
the comments on the Report of the Remedial Investigation. See,
Exhibit 1, comment 2 and attached maps.
In addition, as stated in the Feasibility Study and Proposed
Action Plan, 1,2 DCE is present in the southern portion of the
aquifer at the level of 100 ppb. 1,2 DCE contamination is not
present in the soil at the O'Henry Dry Cleaning Store at
significant levels.
B. The significance of the Esso Tutu Service Station as a
source of contamination in the southern portion of the aquifer is
ignored.
The accurate depiction of groundwater flow lines demonstrates
that the majority of the contamination which is present in the
southern portion of the aquifer could not originate at the O'Henry
Dry Cleaners, assuming that groundwater flow direction has not
significantly changed with time. Additional evidence for this
-------
position is found in examination of the presence of MTBE
contamination in the aquifer. MTBE is a gasoline additive, and is
not used in any form in the dry cleaning process. MTBE is found in
the deep groundwater south of the Tutu Texaco Station, past the
Esso Tutu Service Station, to the Delegarde well.
Further, it is without question, that the former operator of
the Esso Tutu Service Station emptied the holding tank which
contained waste oil, heavily contaminated with chlorinated
hydrocarbons by pumping the tank into the toilet, which emptied
directly into the sanitary sewer. In spite of this evidence of
improper disposal and the obvious potential that the sanitary sewer
remains as a potential source of chlorinated contamination, this
potential source has not been investigated. See, Soil Tech, 1990;
Exhibit 1, comment 5. Moreover, chlorinated hydrocarbon
contamination has been detected in the sanitary sewer and soil at
the Esso Tutu Service Station.
Further,' there is a PCE hot spot located in the area
identified as the "northern plume". This area, and its potential
source has been ignored. In addition, if the accurate direction of
groundwater is considered, it is impossible for a direct flow path
to extend from the Harvey Supply Well to the Smith Supply Well.
See, Exhibit 1, comment 1, and attached maps.
C. The actual evidence obtained during the remediation of the
soil at the O'Henry Dry Cleaning Store demonstrates that DNAPL
contamination is not present in the soil.
The Report on the Remedial Investigation stated that the
concentration of PCE in the soil was not high enough to conclude
-------
the PCE was present in a separate phase in the soil. This
conclusion is supported by the actual data collected during the
soil remediation conducted by L'Henri, Inc. at the O'Henry store.
The actual soil data collected demonstrates that chlorinated
contamination is not present at a depth below six feet at
O'Henry. Further, the presence of DNAPL at the site has been
assumed based upon the presence of PCE in OHMW4, a well which is
located side gradient, and not down gradient from O'Henry, and the
historical use of PCE at the dry cleaning store. See, exhibit 2,
comments Section 2.2.2.1.
II. Soil Remediation at the O'Henry Dry Cleaners. .
The soil remediation alternatives provided in -the. proposed
action plan do not take into consideration that remediation has
.already occurred at O'Henry with EPA approval and oversite.
Further, the cleanup standards provided by EPA have been
incorrectly calculated. Site modeling utilized by EPA does not
take into account all site specific data available. However,
without conceding that said modeling is appropriate, utilizing the
method of calculation provided by EPA, with appropriate site
specific data, the cleanup standard to be used at the O'Henry site
would be 534 mg/kg for soil above 1.6 feet and 713 mg/kg for soil
below 1.6 feet, not 31 ppb. See, Exhibit 4.
III. Groundwater Remediation at the Tutu Well Site.
Initially, we note, that prior to Hurricane Marilyn, the
Virgin Islands had experienced a drought with lasted in excess of
two years. During this period, most of the groundwater elevation
data was collected. During and following Hurricane Marilyn,
-------
rainfall has increased dramatically. In St. Croix, IT has observed
that groundwater elevation increased a much as ten feet, in one
aquifer after the huricane. Consequently, it is possible that the
location of the groundwater contamination plumes have shifted.
Further, there is no basis in the administrative record to
assume that clean up to groundwater standards through the
decommissioning of existing wells, installation of groundwater
recovery wells will be cost effective or will result in restoration
of the groundwater to drinking water standards. The pumping of
groundwater in the Tutu valley has operated to stabilize the plume
and to prevent the downward migration of the plumes in the prior
years. Utilization of existing wells may be more effective than
the method proposed by EPA. Moreover, there has been no
consideration of the time period required to restore the aquifer
through the efforts of pumping and treating the
groundwater, as compared to natural attenuation. The additional
technical comments concerning the groundwater treatment system were
contained in the comments submitted by IT to the draft Feasibility
Study and are reiterated herein. Said comments are attached as
Exhibit 3 for your convenience.
-------
March 10, 1996
Ms. Caroline Kwan
Remedial Project Manager
U. S. Environmental Protection Agency
290 Broadway, 20th Floor
New York, New York 10007-1866
Dear Ms. C. Kwan:
Thanks for the opportunity to review the Proposed Plan and to
provide comments made at the public hearing on March 5, 1996.
My principal concern is that the document summarizing the Proposed
Plan on which the public in Tutu was expected to provide input on
was written in a foreign language. The low public participation at
the hearing on. March 5, 1996 and previous hearings I feel can be
partly attributed to this. I am confident that you as well as I
sincerely believe that true success of any actions at this
Superfund site is greatly dependant and enhanced by participation
from the affected population. While it may be too late to
translate this document in to language that the bulk of the
population can comprehend I advise you that no remediation
alternative can be properly implemented unless there is
communication to the persons affected in language that they can
understand. An effective public information program is vital to
whatever remediation alternative is selected. Having said all this
though, I confess that I am fully aware of the difficulties of
effectively presenting this material in a form understandable to
the general public.
In my work at the Virgin Islands Water Resources Research
Institute, we consider public participation to be critical and I
know how difficult it is to obtain. I also am aware of efforts
made by your office to secure public input. These efforts though
need to be expanded. Given the enormity of the Tutu aquifer
problem and the effect that it can have on people's lives a it
would be appropriate that a comprehensive information program be
included in the cleanup. This should be more than just reliance on
-------
volunteers as was mentioned in the hearing.
Also, I urge that the introduction of treated water directly in to
the Tutu water distribution systems be well researched. I am fully
aware of the need to use all available water and also I know that
this practice might have been followed elsewhere. However, in the
instant situation where the affected community is smaller than
most, the technical awareness and confidence in water treatment
processes low, public acceptance of this alternative at the
implementation is not assured.
My comments are intended to help you in your efforts and I hope
that they will be accepted as such. At the Water Resources
Research Institute of the University of the Virgin Islands we are
as concerned as you are about the risks to public health caused by
the contamination of this aquifer and applaud your efforts. We
encourage you to not look as public participation as only a
responsibility dictated by CERCLA but rather an essential component
of any remedial alternative that will provide for maximum
protection of the environment and human health. If we can be of.
any assistance to you, please do not hesitate to call on us.
The University's Eastern Caribbean Center and the WRRI have
committed themselves to working with the Tutu community the
minimize the effects of the water contamination problem. We urged
community groups to have members participate in the March 5 hearing
and have applied for an Environmental Justice grant to enable us to
work formally with community based groups to transfer information
and develop skills and confidence to actively participate in
resolving the problem. We would welcome any suggestions you may
have and look forward to working with you in the future.
Sincerely,
Henry H. Smith, Ph.D.
Director
-------
.SENT Br •' I. i. t-uor.
Tennessee 3~">2
rat
December 19, 1995
Ms. Caroline Kwan
New York/Caribbean Superfund Section
U.S. Environmental Agency Region II
290 Broadway, 20th Floor
New York, NY 10007-1866
Tra nsmlttal of Comments and Concerns Related to
Calculated Site Specific Soil Cleanup Standard for the
O'Hcgnt Dry Cleaners. Tutu. St. Thomas. U.S. Virgin Islands
Dear Ms. Kwan:
This letter presents comments and concerns relating to the site specific soil cleanup standard
presented by the EPA as applicable to the 0'Henry Dry Cleaners, Tutu, St. Thomas, The site
specific standard is presented in CDM Federal, Jufy 1995, Final Report, Estimation of Soil
Cleanup Concentrations Required to Protect Groundwater as a Source of Drinking Water. This
standard was referred to as the applicable standard by the EPA in the CDM Federal, 1995,
document but is also presented in the EPA Technical Review Comments on IT, 1995 Soil
Remediation Report for the O'Henry Dry Cleaners, Tutu St. Thomas, presented in a letter to
Nancy D'Anna, Esq. from Carole Peterson received July 27, 1995, and in Geraghry and Miller
Inc., 1995, Final Feasibility Study for the Tutu. Wells site, Tutu, St. Thomas. Materials in the
form of calculation sheets and a spreadsheet were supplied by the EPA on October 6, 1995, in
response to a FOIA request filed by Nancy D'Anna, Esq. IT Corporation (IT) at the request of
L'Henri Inc., has reviewed this computer spreadsheet in addition to the above referenced
documents and has the following comments and concerns with the Soil Cleanup Concentration
presented by the EPA for the O'Henry Dry Cleaners site:
Development of the site specific soil cleanup levels for the Tutu Wells site by CDM Federal was
based on an EPA, December, 1994, Technical Background Document for Soil Screening
Guidance (Review Draft). Formulae used for the estimation of the mixing zone depths and
derivation of the dilution factor in the supplied spreadsheet were cited from the EPA document,
however, the EPA document used is a draft review copy that is marked "Do Not Cite or Quote."
Since this method is in review draft stage which has not undergone full EPA and public review
and comment, we question the use of the method as applied through the spreadsheet by CDM
Federal. IT has previously used the one-dimensional, finite difference model VLEACH to
It Caporaaon u awnotfy ownfdMtectov at liatiraaecal ftstateloff Csitanaon
-------
INTERNATIONAL. TECHNOIOGY CORPORATION
Ms. Caroline Kwan 2 . December 20,1995
calculate the appropriate site specific soil cleanup standard (77,1994, Work Plan for Evaluation
and Interim Remediation of Soils, O'Henry Laundry, Tutu, St. Thomas, US.V.I.) and as pointed
out in Section 3.4 of 77, 1995, Soil Remediation Report O'Henry Laundry, Tutu, St. Thomas,
UJS.V.L (Revision 1), use of the site specific Foe in the model would lead to a higher soil cleanup
standard than that presented m the Work Plan (IT, 1994). The model VLEACH is listed among
those appropriate to be used for site specific soil cleanup standard determination in EPA,
December, 1994 Technical Background Document for Soil Screening Guidance (Review Draft).
Understanding that the VLEACH model is conservative in that it does not consider chemical or
biological degradation, it is reasonable to expect that use of the VLEACH model would result
in lower soil cleanup standards than the CDM Federal spreadsheet model using the same site
specific parameters. IT believes that use of VLEACH is appropriate for calculating the site
specific soil cleanup standards for this site.
Notwithstanding the above, assuming that the method applied by CDM Federal is appropriate for
the calculation of site specific soil cleanup standards, following is a listing of assumptions which
should be amended as indicated for the O'Henry site:
• A composite soil profile generated by CDM Federal for the O'Henry Dry Cleaners
simulating the soils present beneath the contaminated zone is not representative of actual
soils present at the site. The generated profile indicates that the site contains clayey sands
(SC) and silty sands (SM) and clayey silts at depth intervals of 0 to 2.1 ft, 2.1 to 10.96
ft, and 10.96 to 22 ft respectively. However, visual classification of soils during soil
remediation activities for the excavation area and soil boring ITSB-01 indicated that soils
are uniform and predominantly sandy silt with clay (ML) from the ground surface to a
depth of 8.25 ft. An andesitic unweathered bedrock underlies the silty soils. Because the
soil type simulated for the O'Henry Dry Cleaners was not representative of site soil
conditions, model soil parameters including the assumed water content (which was taken
to be the effective porosity), total porosity, soil layer thickness, and soil mass (dry bulk
density) were not accurate parameters for the site. Site specific soil parameters obtained
during soil remediation activities arc as follows:
- Volumetric water content = 0.3
- Dry bulk density = 1.53 g/cc
- Total porosity = 0.4.
• A contaminant source length of 50 ft was used by CDM Federal for the O'Henry site.
This parameter is used in the calculation of the dilution factor. A resulting dilution factor
of 0.04 was subsequently used for the calculations of the target soil leachate concentration
of <132 iig/L for the acceptable groundwater MCL of <5 ug/L. During soil remediation
activities conducted in March 1995 at the O'Henry site, field observations indicated that
a contaminant source length parallel to the groundwater flow for the site is approximately
25 feet (Note: 25 ft is used conservatively, the actual source length is probably less than
20 feet). Using the source length of 25 feet results in a dilution factor of 0.02. In
!T Ccfprouuuii a a wnaiiy owned taBaaay a Inurnmima/ Ttaaanff/
-------
it-M CT ; I . I . LUKT. KAUAVILU: • o- /-ao . i-o/r»j . 1.1. tuu- ^VWAMLU:- _ ioua.
-------
i£i\7 ar-'i.K cuw. KAUAVILU: • o- /-a6 ; 1-57W1 . 1.1. U/KT KAUAVILLE-
NTBZNAIIONAI nCHNOLOCY CCWOBATOtf
Ms. Caroline Kwan 4 December 20, 1995
If you have any questions regarding these comments, please contact L'Henri Inc., Counsel Nancy
D'Anna, Esq. at (809) 776-6533 or me at (423) 690-3211. Additionally, please note the change
of area code for east Tennessee.
Sincerely,
^
Belinda K. Price, R.F.G.
Project Manager
cc: Andrew Praschak Esq., EPA
Leonard Reed, DPNR
Nancy D'Anna Esq.
Jack McBurney, de mpdmis, inc.
If Cli'HiWBHJI'fflWfy owned AIBPOWV a imwnotenol lacnnaeaY Ci»|ju.uu.ii
-------
TECHNICAL REVIEW COMMENTS
SOIL REMEDIATION REPORT FOR
Q'HENRY LAUNDRY, TUTU, ST. THOMAS
Reference: Letter to Nancy D'Anna, Esq., from Carole Peterson received July 27, 1995.
General Comments;
Comment 1: The limits of the excavation were determined from field gas
chromatograph results and using a provisional soil cleanup level of
200 ug/kg, based on preliminary vadose zone leaching modeling.
The final EPA cleanup goals Tor the O'Henry property, based on
revisions to the model, are 375 ug/kg PCE in the 0-1.6 feet depth
interval, and 31 ug/kg PCE at depths greater than 1.6 ft, which will
result in levels of PCE in groundwater below the MCL of 5 ug/l.
These cleanup goals are developed from unsaturated zone
calculations that take into account infiltration of precipitation, PCE
adsorption-desorptlon from site soils, anaerobic biodegradatlon of
PCE and mixing of contaminated leachate with groundwater in the
underlying aquifer. Based on the final EPA calculations, additional
soils remediation is needed to address potential sources of
groundwater contamination.
Response: Cleanup standards calculated by the EPA assume soil contamination
occurs at the soil cleanup standard concentration for the entire soil
column. Site modeling performed by the EPA and reported in specific
comment No. 15 docs not take into account all site specific data
available. Further, IT cannot verify the results of EPA modeling
presented for the O'Henry site because site specific input parameters,
input/output files, and spreadsheet calculations have not been presented
However, using the leachate to groundwater dilution factor of 0.04
assumed for the O'Henry site by the EPA (CDM, 1995), and back-
calculating from the groundwater MCL for PCE of 5 ppb, the equivalent
concentration of PCE in leachate entering groundwater would be 125
ppb. This value is higher than the soil cleanup standard of 31 ppb
presented by the EPA which would suggest that the soil cleanup
standard must be greater than 125 ppb.
Based upon analytical results of the confirmatory soil samples collected
during soil remediation activities and physical conditions at the site,
soils left in place at the O'Henry Laundry site represent two distinct
PCE soil concentration profiles.
Profile 1: Soils left in place at the excavation base overlain bv clean
backfill material brought from ofrsite. Analytical results indicated that
soils used as backfill material from ground surface to a depth of 8.25
feet within the excavation area were clean soils with PCE
concentrations below detection limits. Soils underlying the backfill
-------
material at the excavation base, at a depth of 8.25 ft and deeper, were
found to contain PCE at a maximum concentration of 170 ppb. The
soil boring ITSB-01 defines the limits of the contamination at 10 feet
below grade (i.e., nondetect at 10 feet).
Profile 2: Soils beneath the concrete area on the northern excavation
wall. Soils collected from the northern excavation wall, beneath the
paved concrete slab were found to contain PCE with maximum
concentrations of 38 ppb, 560 ppb, and 1100 ppb at depth intervals of 2
to 3 ft, 3.75 to 4 ft, and 5.33 to 5.88 ft, respectively. No depth limit
has been defined for the contamination under the paved concrete area;
however, the depth of the base of contamination was assumed to be the
same as for Profile 1 (see response to Specific Comment No. 14).
Table 1 shows the two vertical distribution profiles of PCE soil
concentrations. Using the above PCE concentration soil profiles and site
specific soil parameters obtained during the soil remediation activities
(IT, 1995), groundwater impact due to the mobilization and migration of
PCE in the vadose zone was estimated using the computer program
VLEACH Version 2.0 (Ravi, et al., 1993). VLEACH is a one-
dimensional vadose zone model that predicts contaminant behavior
within the vadose zone using a finite difference method The modelling
assumptions were the same as those described in the Workplan (IT,
1994) with the exceptions as described below.
These values were obtained during the March 1995 soil remediation
activities (IT, 1995) :
• The soil type at O'Henry is predominantly sandy silt with
clay soil.
Dry bulk density = 1.53 g/mL
• Volumetric water content = 03
Other revised input parameters included:
Hydraulic gradient =0.073 ft/ft (EPA Final Report,
Estimation of Soil Cleanup Concentrations Required to
Protect Groundwater as a Source of Drinking Water, Tutu
Wells Site,USVI, 1995)
• Organic Carbon Partition Coefficient (1^=364 ml/g
(EPA.1995)
Soil organic carbon fraction (f^)= 0.006 (EPA, 1995).
(The more conservative of the two site specific values
determined by IT and the EPA, see also the response to
Specific Comment 10.)
-------
Model data files (LHENRI for Profile 1 and LHENRI2 for Profile 2) are
attached. The VUEACH model provides information on the amount of
PCE released to the groundwater in terms of grams per year at every
time step. PCE concentrations in groundwater due to the impact of
leachate were estimated using VLEACH/mass loading estimates and a
one-cell mixing model for the aquifer directly below the contaminated
vadose zone. The mixing model assumes complete mixing in the water
column.
PCE concentrations in groundwater [M] %? was calculated using:
Volume of water flowing through unit vidth per year
Where water volume = n x t x L x W
n = porosity = 0.4
t = aquifer thickness = 10 ft
L = flow velocity using a hydraulic conductivity of U ft/day
and hydraulic gradient of 0.073
W = A unit cross-sectional width
Water volume = 0.4 x 10 ft x 42.37 ft/year x 1 ft
169.5 ftVyear
= 4796 liters/year.
The incremental increase in PCE concentrations in groundwater for the
O'Henry site using the two PCE concentration soil profiles are shown in
Figures 1 and 2 respectively. Table 2 summarizes the highest
groundwater PCE concentrations and the time at which the peak impact
occurs beneath the site. Figures 1 and 2 show that with the current
PCE soil concentration profiles, groundwater beneath the O'Henry site
will not be impacted above EPA action limits. The site specific
modeling will be incorporated into a new chapter titled, "Evaluation of
Impact to Groundwater of Soils Left in Place."
Comment 2: Concentrations of PCE reported in cooGrmatory laboratory
analyses of samples were in many cases significantly higher than the
field GC results, especially from the deeper samples and excavation
wall samples. Usually, laboratory analyses of VOCs yield lower
concentrations than do field results, due to compound volatilization
during shipping and handling. The higher laboratory PCE results
for many samples call into question the reliability of the field GC
results to accurately determine whether residual PCE
concentrations are below the provisional (or any) cleanup level.
-------
Response: A comparison of the PCE results from samples collected and analyzed
by the field GC and in the laboratory by IT and split samples analyzed
by the EPA are included on Table 4. An examination of this table
indicates that the field GC analyses yielded the highest concentrations in
10 samples, the IT laboratory analysis yielded the highest concentrations
in 8 samples and the EPA laboratory yielded the highest concentrations
in 2 samples. The field GC result was only lower than the IT
laboratory result for four samples where an EPA laboratory split sample
result was not available (EXSOS, EXS26, EXS27, and EXS3S). Of
these samples, there was only one sample (EXS27) where the IT
laboratory results was more than double the field GC result (195 ng/kg
from field GC and 850 ng/kg from IT laboratory). For this sample, a
duplicate analysis was performed. The result (570 Hg/kg ) is
intermediate of the field GC and IT laboratory results.
For the samples for which EPA split samples are available and where
the IT (or EPA) laboratory results are higher than the field GC, four
samples have laboratory results which are more than double the field
GC results (EXS30, EXS31, EXS33, and EXS34). In three of these
samples, the IT laboratory has the highest concentration and in one case
the: EPA has the highest concentration.
There are only three samples where the field GC analysis was below the
preliminary cleanup standard and where the confirmation sampling
analysis was above the preliminary cleanup standard (EXS27, EXS30,
and EXS31). These three samples are located beneath the concrete slab
on the northern wall of the excavation.
In addition, the following should be noted
Quality control measures were taken during field analysis to
support the validity of the test method Appropriate instrument
calibrations were performed and check standards were
continuously analyzed throughout the field analysis to verify
correct instrument performance. Accuracy and precision data
(i.e., MS/MSD samples and surrogate spikes) indicate no
problem with data generated by the field GC.
• Interpretation of soil VOC data is often fraught with difficulties
due to inherent problems with the sampling and analytical
process. Losses of VOCs have been reported due to
volatilization caused by sample disruption during field or
laboratory subsampling, as well as leakage and/or transformation
during preanalytical handling. VOCs may become physically
entrapped in the microstructure of soils and can be difficult to
desorb and remove during extraction. In addition, ancillary soil
properties (e.g., water content, organic carbon content,
temperature) can affect spatial variability and soil VOC behavior.
-------
VOC concentrations vary in soils both in space and time.
Therefore, variability in measurement of VOCs can be large as a
result of natural variability. Focus should be on the
comprehensive data sets rather than on discrete values and on
the laboratory confirmation samples rather than the field GC.
The confirmation samples indicate that soils have been removed to
below the preliminary cleanup standard with the exception of an area of
soil beneath the concrete slab. A new subsection will be added to
Chapter 3.0 titled, "Evaluation of Field Screening and Laboratory
Analytical Results," which will compare the results as described above.
Comment 3: High concentrations or PCE in the southeastern part of the
excavation pit and the southern pit wall near the Liquor Barn (e.g.,
EXS12, EXS27, EXS30, and EXS31) indicate that not all soils
containing PCE above 200 ug/kg were removed. It therefore
appears that additional PCE-contaminated soils exist beneath the
O'Henry building.
Response: We agree that field CC and confirmation samples indicate that soil with
concentrations above the provisional cleanup level of 200 jig/kg are left
in place beneath the concrete paving at the northern end of the
excavation. This will be incorporated in the first paragraph of the
conclusions section.
Specific Comments
Comment 1: Section 1.12. page 1-2 and 1-3. The provisional level of 200 ug/kg
has been revised to 31 ug/kg For soils more than 1.6 feet below
ground surface, based on EPA's final vadose zone modeling results.
This information should be incorporated into the text.
Response: The information as requested will be added to the text in Section 1.0;
however, please see response to General Comment No. 1.
Comment 2: Section 2.1. page 2-1. The maximum concentration of PCE
previously reported in subsurface soils was 180,000 ug/kg in sample
e-02-02 from a depth of 1.5-2.5 It (Figure 5-11 of the Draft Final
Remedial Investigation Report), not the 59,000 ug/kg in boring SSI
as reported here.
Response: We agree; however, it should be noted that the soil boring SSI was
targeted to the same location as e02-02. Therefore, data from SSI is
more recent than e02-02. The text will be revised accordingly.
Comment 3: Section 2.1. page 2-1. The sample depths of the two undisturbed
soil samples that were submitted for geotechnical analyses should be
listed. According to Appendix A, apparently only one of these
-------
Response:
Comment 4:
Response:
Comment 5:
Response:
Comment 6:
Response:
Comment 7:
samples underwent analysis. The text here and on page 3-3 should
clarify the depth interval sampled and that only sample LH01 and
itd duplicate were analyzed.
We agree; two samples (i.e., one sample LH01 and its duplicate LHU2)
were collected; however, only one sample, LH01 from a depth interval
of 5 to 6.5 feet, was analyzed for geotechnical parameters. The text
will be revised accordingly.
Section 2J. page 2-1. Here and elsewhere, the text should indicate
that the cleanup level of 200 ug/kg was an assumed cleanup level
and was used provisionally.
We agree. The text will be revised accordingly.
Section 2.6. page 2-6. The text indicates that a FID was not
available during installation of boring ITSB-01. Presumably the
PFD had arrived by the time of the soil excavation work, yet no
organic vapor readings are presented in any section of the report.
If PID readings are available they should be discussed In the text
because they would aid in identifying contaminated soil zones within
and adjacent to the excavated area.
Table 3 summarizes PID readings taken during soil remediation
activities. PID readings will be included in the report.
Section 3.1. page 3-1. second paragraph. PCE concentrations of up
to 2,845 ug/kg were found at a depth of 3-4 ft at location EXS12.
Table 3-1 indicates this is an estimated concentration since the value
exceeded the instrument calibration range. The text should be
revised to discuss how large this estimated result could potentially
be.
The reported value from sample EXS12 is reported as an estimated
concentration. A sample aliquot of 0.5 g was used for analysis; the
analytical results exceeded the calibration linear range. Due to
problems obtaining additional supplies, the sample was not reextracted
and reanalyzed with a smaller aliquot A smaller sample aliquot would
have allowed the analytical result to be within linear range; thus a more
accurate value would be reported. The reported result is most likely
slightly higher than the actual concentration. This will be added to the
text.
Section 3.1. page 3-1. third paragraph. Soil samples collected from
the excavation wall adjacent to the concrete slab exceeded the
provisional PCE cleanup level of 200 ug/kg. Given that the EPA
has established an even lower soil PCE cleanup goal to be protective
of groundwater, the report should discuss the potential for the
-------
Response:
Comment 8:
Response:
Comment 9:
Response:
Comment 10:
Response:
residual contaminants at these sample sites (and others exceeding
the cleanup goals) to serve as ongoing sources of groundwater
contamination.
See response to General Comment No. 1.
Table 3.2. Please include a brief discussion of the data qualifiers
used in this table, particularly the "D" qualifier, in the associated
text on page 3-2.
Explanation of data qualifiers will be added to the text.
Section 3.2. page 3-2. Based on Tables 3«1 and 3-2 and the
associated figures, almost half of the samples that underwent both
CLP and field GC analysis show higher PCE concentrations in the
CLP results than the GC results. See General Comment 2. The
text on page 3-2 should discuss why this is the case, and how this
finding may affect interpretation of all of the field GC results.
See response to General Comment No. 2.
Section 3.3. page 3-3. The organic carbon content is reported as
0.015 (1.5 %) in a sample collected from a depth of 5 - 6.5 ft. This
value is almost three times higher than the value reported from the
O'Henry property from two EPA samples collected from the top
two feet (average TOC = 0.6 %), and much higher than the organic
carbon values of 0.0002 (0.02%) to 0.001 (0.1%) used by IT in the
VLEACH modeling. The report should discuss the
representativeness of this value relative to other site-reported or
assumed TOC values, and its implications for PCE movement
through the soils. The ASTM method (D2974-87) used by IT is a
combustion/incineration method that will also count inorganic
carbon (e-g., carbonate and bicarbonate), unless it is deliberately
removed during the sample preparation stage. (The Lloyd Kahn
method, "Determination of Total Organic Carbon in Sediment",
1988, which is often used by EPA, includes an acid treatment step
during sample preparation to remove inorganic carbon.) Given the
presence of carbonate rocks in the area, eroded carbonate material
is probably present in many Tutu soils. This could account for the
higher values reported In the subsurface by IT versus the surface
soil values reported by EPA.
Section 3.3, page 3-3 on geotechnical testing incorrectly reports the
results of ASTM D-2974 as traction of organic carbon. The actual
parameter measured by ASTM D-2974 is the fractional organic material
contained in the sample. As reported in Appendix A of the document,
the two analyses performed by ASTM D-2974 produced fractional
organic material results of 0.015 and 0.013. The fraction of organic
-------
material can be related to (he fraction of organic carbon by dividing by
1.724 (Dragun, J. 1988). Following this approach, and using the
average fraction of organic material (0.014), yields a fractional organic
carbon content of 0.008 or 0.8 percent. The model VLEACH uses
"organic carbon fraction" as an input parameter which is why the
ASTM method was applied by IT,
The percentage of organic carbon calculated by IT is, therefore,
comparable with the percentage of total organic carbon as presented by
the EPA. The fraction organic carbon value used by IT in calculation
of the PCE cleanup standard using VLEACH (IT, 1994) was lower than
the values determined from laboratory tests. The effect of using a
higher fraction organic content in the previous modeling would have
resulted in a higher cleanup standard. This will be added to the text.
Comment 11: Section 5.0. page 5*1. first sentence. Based on the residual PCE
contamination greater than 200 ug/kg detected in soils in the
excavation pit southeastern wall, this sentence should be revised to
indicate that not all of the source of potential groundwater
contamination at the O'Henry site has been removed.
Response: See response to General Comment No. 3.
Comment 12: Section S.O. page 5-1. second bullet The argument that the average
PCE concentration is soils is nearly equal to the provisional cleanup
level, when the reported PCE concentrations arc as much as Gve
times greater than the provisional level, is not valid. The text must
be revised.
Response: W
-------
compound attenuation occurs in the deeper zone, due to the low
organic carbon content and blodegradation rate loss terms used.
Furthermore, PCE volatilization is predicted to be a very minor
attenuation process at depths below about 1 meter due to the
presence of anaerobic breakdown products found in soils below this
depth. Therefore, PCE will migrate in leachate relatively
uoattenuated to the water table, regardless of the distance of the
source from ground water. The text should remove this statement.
Response: Please see response to General Comment No. 1.
Comment 14: Section 5.0. page S-2. The text states that PCE concentrations were
below detectable levels beneath 10 ft in boring ITSB-01. The report
should indicate, however, that this boring may not be indicative of
concentrations in surrounding soils. Based on sampling results
shown in Figures 2-4 and 2-7, the higher PCE concentrations exist
in nearby soils.
Response: Based on an evaluation of the spatial PCE concentrations from field GC
and laboratory confirmation sampling- shown in Figures 2-3 through 2-7
of the report, the depth profile for PCE concentrations in boring ITSB-
01 appears representative of the depth profile of PCE concentration in
soil in the excavation area. PCE which may nave entered soil and
migrated from the unpaved area back under the concrete will have the
following characteristics:
• It is unlikely to have migrated more than a few feet horizontally.
• It will not volatilize as fast because it is effectively "capped."
• It will not migrate vertically downward in the dissolved phase as
fast because there is a reduced driving force (i.e., lower
infiltration).
Given the above characteristics and visual observations which indicate
no residual free phase in soil and no vertical pathway fur preferred
contaminant migration (soils are uniform) the contaminant profile in
boring ITSB-OJ may not be indicative of concentrations in soils beneath
the paved area in terms of actual concentrations; however, it likely
accurately reflects the "general profile" where the maximum
concentration of PCE in soil is between 5 and 10 feet below grade and
there is non-detect below 10 feet. This will be added to the text
Comment 15: Section 5.0. page S-2. first paragraph, last sentence. The report
states that excavation of soils to a depth of 8 ft has removed all
PCE-contaminated soil. Given the sampling results provided in the
report, this is a False and misleading sentence which must be
revised.
-------
Response: See response to General Comment No. 3.
Comment 16: Section 5.0. page 5-2. The report recommends that no further in
situ remediation be performed at the site. However, the revised
EPA soil action levels for PCE indicate that the concentrations of
PCE remaining in soils in the vicinity of the excavation will be
ongoing sources of PCE contamination of groundwater above
MCLs. Based on the site findings and EPA's soil action levels, some
form of additional sol) remedial action is required. The use of soil
vapor extraction (SVE) and angled extraction wells, for example,
could be effective in removing residual PCE beneath the adjacent
building.
Response: See response to General Comment No. 1.
References
CDM Federal Programs Corporation, 1995, Final Report Estimation of Soil Cleanup
Concentrations Required to Protect Groundwater as a Source of Drinking Water, Tutu
Wells Site, US. Virgin Islands.
Dragun, J., 1988, The Soil Chemistry of Hazardous Materials, Hazardous Materials Control
Research Institute.
IT Corporation, 1994, Work Plan for Evaluation and Interim Remediation of Soils O'Henry
Laundry, Tutu, St. Thomas, US. Virgin Islands.
IT Corporation, 1995, Soil Remediation Report, O'Henry Laundry, Tutu, St. Thomas,
Virgin islands.
10
-------
Table 1
Concentration Profiles Used in the Model
O'Hanry Laundry, St. Thomas, U.S. Virgin Islands
Concentration Profile
No.
1
2
Depth Interval
(ft)
0 . 8.25
8.2S - 10
0-3
3-5
5- 10
PCE Concentration
(PPb)
0
170
38
560
1100
11
-------
Table 2
Highest Qroundwater PCE Concentrations
O'Henry Laundry
St Thomas, U.S. Virgin islands
Beneath Excavated
Area
Beneath Paved
Concrete Area
Concentration
Profile
No.
(Refer Table 1)
1
2
Highest Groundwater
PCE Concentration
fc8/L)
0.026
0.44
Time for Peak Impact
(Years)
76
90
12
-------
Table 3
Summary of Organic Vapor Readings
O'Henry Laundry
St Thomas, U.S. Virgin Islands
Sample No.
EXS06
EXS07
EXS08
EXS09
EXS10
EXS11
: EXS12
EXS13
EXS14
EXS15
EXS16
EXS17
EXS18
EXS19
' EXS20
EXS21
EXS22
• ESX23
EXS24
. EXS2S
EXS26
EXS27
EXS26
EXS29
EXS30
EXS31
! EXS32
EXS33
EXS34
EXS35
PID Reading
(ppm)
2
0.1
22
34
0.2
0.25
0.5
1.8
1.8
0.1
0.3
03
1.0
0
0
0.5
1.0
2.0
1.0
4.0
1.5
1.5
11.0
3.0
3.0
7.5
1.0
4.0
2.0
03
13
-------
Table 4
A Comparison of PCE Results
Sample Number
rrsB-01-05.0
ITSB-01-10.0
iTSB-oi-14.5
EXS01
EXS02
EXS03
EXS04
EXS05
EXS23
EXS24
EXS25
EXS26
EXS27
EXS28
EXS29
EXS30
EXS31
EXS32
EXS33
EXS34
EXS3S
Field GC
237.69*
12.38
4.33/4.98
214.40
197.26
181.34
324.09
83.95
275.38
57.80
173.90
220.33
195.14
242.71
171.48
155.45
169.41
63.61
15.17
74.60
109.65
IT Laboratory
120
2J
11 U
140 O
120
54
100 D
100
290 D
21
190
300 D
850 0/570 D
210 D
150 D
1100
560 D
38
31
170
160
EPA Laboratory
100 J
2J
210 J
220 J
480 J
630 J
34 J
30 J
30 J
'Highlighting indicates whiclvanalyticaJ method yielded the highest concentration (or each sample.
14
-------
FIGURE 1
0.030 -i
Predicted Groundwoter lmpact-foc=0.006
(Area under Excavation)
Time (years)
-------
FIGURE 2
0.500 -
0.400 -
o
(D 0.200 -
O
"O
c
Z5
O
O
0.100 H
0.000
0
Predicted Groundwater lmpoct-foc=0.006
(Area under Paved Concrete)
100
200
Time (years)
300
400
-------
SENT BY: I. T. CORP. KNOXVILLE : 3- 7-96 : 2:06PM : l.i.
Comments on Geraghty and Miller, Inc. 1995,
Draft Feasibility Study Tutu Wefls Site,
St Thomas, U.S. Virgin Islands
2.1.1.3. Groundwater flow direction is still not sufficiently well undentood in the
deep bedrock aquifer in the southern portion of the Tutu "site" ie south of the Esso station.
No measured groundwater elevations were used between the locations SW-6, MW-21D,
MW-22D and west of these wells, an area of 1,000ft x 1,500 feet Groundwater contours
representing deep bedrock groundwater flow beneath this following properties should be
dashed: O'Henry laundry, liquor Bam, and Archies Welding. The map included in Graves
and Gonzales 1988, used as justification for the "generalized regional flow" presented by
Geraghty and Miller, indicates a lower level of detail (contours are shown at no less than
ten foot intervals) than included on figure 2-4 (contours are shown at five foot intervals).
It is not appropriate to use the 5 foot contour intervals, la addition, the Graves and
Gonzales map uses 'dashed* (indicating approximately located) and "queried* (indicating
uncertain) contours over much of the area and particularly the area to the south and
southeast of the O'Henry laundry. Further, the text included in Graves and Gonzales 1988
states "Several wells were being pumped, or had just terminated, when the water levels were
measured ...These water levels reflect a pumping or recovery condition; therefore, static
water-level conditions throughout the Turpentine Run basin at the time of measurement
cannot be assumed*. Because the flow map presented by Geraghty and Miller (figure 2*4)
shows a non-unique solution, the positioning of the recovery wells RW-2, RW-3 and RW-5
may be inappropriate. Also, please explain why data from MW-22D is included on both the
shallow and deep flow maps.
Section 2.2.2.1. First Paragraph. Since there is no such compound as Total chlorinated
VOC", the shape of each individual VOC compound plume should be discussed. The edges
of the plumes should be defined as the drinking water standard (DWS) for each individual
compound (where a DWS exists). What is meant by "The southern plume originate! near
the O'Henry Dry Cleaners'? Regardless of the current location of chlorinated VOCs in the
groundwater, the origin of these chlorinated VOCs in groundwater south of the O'Henry
property is unknown.
Third Paragraph. According to the shallow bedrock groundwater flow map presented
in figure 2-3, monitoring well OHMW-04 is located sidegradient to the O'Henry Dry
Cleaners not downgradient! as stated in the text.
Section 3.4.2. The practicality of a centralized groundwater treatment system and use of
POET systems on domestic and commercial wells is questionable. The use of a centralized
groundwater treatment system will require piping from one end of the Tutu area to the
omer with associated problems due to the hilly nature of the site. This brings up questions
of access, liability if pipes leak or are damaged, and maintenance. Likewise, future liability
1
-------
is a potential issue if monitoring indicates that contaminants are present in the effluent
water of a permitted domestic or commercial wells. These issues should be very carefully
considered before including a centralized groundwater treatment system and POET systems
on domestic and commercial wells as part of the site remedy.
Section 4.4. Since the FS apparently chooses two alternatives (SWRAs 4 and 7) which is
the SWRA advocated? '
Section 4.5. The following activities are recommended to be included in the pre-design
activities (and costs): \
Fre-design work plan and reports of work performed.
Placement of additional deep bedrock monitoring wells in the area identified in the
comment on section 2.1.1.3 above and additional groundwater level monitoring
including wells not: currently included on the flow maps to determine whether the
assumed groundwater flow south of the Esso station is correct.
Groundwater modeling should be conducted to explore the limits of contaminant
movement and to demonstrate that the proposed groundwater extraction well
scenario will effectively capture .die plume. Because of the uncertainty in flow
direction in the area south of the Esso station it is recommended that a sensitivity
analysis be performed assuming a southwesterly flow direction to the Kentucky Fried
Chicken property and a southeasterly flow direction thereafter to test the recovery
well scenario if Geraghty and Miller are incorrect in their interpretation of flow
direction.
Figure 4-7. Areas marked; as suspected to contain DNAFL do not appear to be consistent
with the contaminant plumes drawn. For the area drawn near the O'Henry Dry Geaners,
the DNAPL plume extends outside the 10 ppb "total VOCs" contour. Please explain the
rationale for the extent of the suspected DNAFL areas shown.
The locations of recovery wells should take into account the presence of individual
compounds of concern (not just the "total VOC plume*). By considering just the 'total
VOCs* the recovery wells may not be appropriately located. Individual compound maps
should be presented and an analysis as to the appropriateness of the recovery well network
to recover the individual compounds of concern should be addressed.
Why does the map list only selected data for selected wells. Explain the rationale for only
presenting certain data. In addition, it appears that not all of the available data has been
used to construct the "total VOC" plume, for example data for MW-15 has not been
incorporated. Please explain.
-------
SENTBY'-I.T, CORP. KNOXVIU-E : 3- 7-96 : 2:07PM : I.I.
OH Coat F-ttimafojj PrflYJded. Note that ft detailed review was performed of the
cost estimate for SWRA 4 (Table 4.9) became this was the (assumed) preferred alternative.
Comments on this cost estimate are also applicable to other SWRA cost estimates.
The following are comments on the Grouadwater Treatment Capital Cost:
The unit cost for peed Restrictions seems low.
Explain what is included in Site Preparation/Mobilization. How many locations are
included? (ie does it include site prep for the treatment system location, piping
locations and recovery well locations?)
Clarify how many wells are included in Well Abandonment How will the wells be
abandoned. Does itbe cost include work plan and reporting requirements?
Does Site Acquisition mean purchase or lease? Is it for the site for the groundwater
treatment system only or does it include piping locations and recovery well locations?
If land is to be purchased, what will be final disposition after the end of the
remediation. Also does the O&M costing include any taxes to be paid.
A detailed breakdown of the Groundwater Extraction System costs should be
provided Does this also include the trenching and rilling for underground piping
installation for piping to the centralized treatment system? If so, how will leak
detection be accomplished?
What is included in Pre-Treatmeat? A scale inhibitor and metals treatment should
be included. In addition, a bench-scale test will be required to estimate the chemical
dosage so that adequate ore-treatment is performed.
Does the cost for the Low Profile Air Stripper include installation? The cost
provided seems low for two air strippers in series.
Does the Liquid Phase Carbon Treatment System include one or two beds?
How many Process Pumps are included and are these Process Pumps and Piping and
Discharge Pumps and Piping just for the treatment system? State how many pumps
and the length of piping.
What is the assumed size of the Aboveground Storage Tank? Does the unit cost
include shipping and installation?
Make sure that the cost for the Treatment Building includes cost for a foundation.
U*S.COM/W/»»W
-------
i • t . i . \~wr\r . iv »
Is Electric for just the central treatment system or for the recovery well sites also?
"Bar* of the POET systems may need individual design. For example they may need
individual design far electrical work and housing.
The following ate comments on the Soil Treatment Capital Cost:
The cost of Excavation/Disposal, Site Restoration and Excavated Soil Sample
Analysis is much too low. Will individual Corrective Action Plans be prepared?
Does die cost include preparation of reports? How will the soils be disposed? It
would be much more practical to build soil venting piles or to perform other on-site
treatment of excavated soils. How many samples will be collected per site? What
analyses will be performed? Does the cost include data validation? This cost item
should be broken down on an individual site basis.
Why is the cost for the SVE system at the Curriculum Center so much higher than
the other sites? Detail should be provided for each site such as size of the vacuum
blowers, number of extraction wells, piping details, treatment of condensate, and
installation cost
Does Engineering; include detailed design, material balance, drawings, and
preparation of specifications and bid packages?
Does Construction Supervision include installation of the systems? Does it include
a Health and Safety! Officer at the site during construction?
The following are comments on the Operations and Maintenance Cost:
Where is the cost included for an Operations and Maintenance Plan?
O&M cost should be included for the domestic and commercial wells set up with
POET systems. This should include scheduled maintenance, sampling, and reporting.
How many and which wells are included in Groundwater Monitoring (ie recovery
wells, monitoring wells, domestic and commercial wells)? Does the unit cost include
semi-annual reports? Does the cost include Quality Control samples and data
validation?
The Electricity will supply approximately 30 Hp. Is this just for the treatment system
or does h include recovery wells also?
Does die cost for carbon replacement include the disposal of spent carbon?
Does Treatment System Monitoring include both air and water sampling (influent
-------
sevr BY:I.T. CORP. KNOXVILLE = a- 7-se = 2:o8PM ; I.T. CORP KNOXVILLE- i809776626o:# 7/22
and effluent)? What will they be analyzed fix? Does the cost include Quality
Control samples and data validation? Does the cost include reports?
Does Administration include data reporting or is it just project management?
Does Equipment Replacement include installation cost?
In addition the following observations are made concerning the cost buildup:
Pie-design activities as described in Section 4.5 have not been included in the cost
estimates. For example SVE pilot test, bioventing pilot test if appropriate, air
stripper pilot test, and metals removal pilot test should be included in the cost. This
appears to significantly underestimate the final cost of remediation.
Cost does not appear to include: preparation of plans, O&M manuals and reports;
start up costs; licenses, permits and legal fees; insurance and bonds.
Shipping and travel may be underestimated.
Demobilation and decommissioning of recovery wells, SVE systems and the
groundwater treatment plant should be included. Li addition, closure and post-
closure activities should be included in the cost
Cost should be included for air emissions evaluation and permit application.
-------
Comment!
Final Remedial lorestigation (RI) Report
Total Wen* Site, Tntu, SL Thona*
Report Prepared by Gcragbry and Miller (April 1995)
Comment* by IT Corporation for L'Henri Inc. (June 71595).
GENERAL COMMENTS
1. Deep groundwater: flow in the area around and hvdroeeologlcallv downgment of the
O'Heory Dry Cleaners is inconsistent between the two gronndwater flow g"^ nresented.
The deep groundwater elevation contour maps presented in the RI are incraistent with
each other for the uei around and hydrogeoIogicaHy downgndient of CTHenry Dry
Qeanen. The May 10,1994 groundwater flow map is the most appropriac because the
map includes data from wells Steele, Harvey, Eglin II and Eglin III (wells an ire in the
immediate vicinity of the O'Henry facility) which are not included on the May 23-24,
1994 map. Groundwater data from these wells fridiegm * groundwater "hi£* extending
from Eglin I to Steele which approximately coincides with the topographic agh (this is
missing on the May 23-24 map). From the Eglin well area, groundwater and subsequently
contaminants would move to the southwest (beneath the O'Henry Dry QoBers), south
(toward the Steele well) and southeast (toward the LaFlace well). Data from £B Oeraghty
and Miller pomp test at Eglin indicate a preferential flow path southess from Eglin
(interpreted as fracture flow). In addition, shallow groundwater flow supports a local
southwesterly flow direction in the immediate vicinity of O'Henry (in general shallow and
deep groundwater flow would be expected to be similar).
2. Presentation of individual chemical compound plumes (specifically chlorinscd solvent^
are not consistent with groundwater flow maps in the area around and hvduEeologicallY
down gradient of thy O'Henrv Dry Cleaners.
This is the first time individual compound .plume maps have been presented for
Tetrachlorbethene (PCE), trichloroethene fTCE), 1,2-Dlchloroethene (1,2-DCE), vinyl
chloride and methyl tert butyl ether (MTBE) therefore this is the first opportunity to
comment on them.'
The presentation of PCE, TCE and 1£-DCE in shallow groundwater (figures 5-25. 5-27
and 5-29 respectively) are not consistent with groundwater flow maps for the shallow
groundwater (figures 4-12 and 4-13) as presented in the RL To develop more defensible
plume maps for these compounds, flow lines were drawn on figures 4-12 and 4-13
(attached). Then Bow lines were transferred to the plume maps and the plumes redrawn
to take into account the flow directions (attached). These redrawn maps indicate that the
PCE, TCE and 1,2-DCE plumes in the shallow groundwater are located further to the west
than shown in the RI and are elongated to the south rather than to the southeast (as shown
in the RI).
The presentation of PCE, TCE and 1,2-DCE in deep groundwater (figures 5-26, 5-28 and
5-30 respectively) are not consistent with the appropriate deep groundwater flow map (see
-------
comment 1 above) for the deep groundwater (figure 4-14) as presented in the RI (figure
4*14). To develop more defensible plume maps for these compounds, flow lines were
drawn on figure 4-14 (attached). Then flow lines woe transferred to the plume maps and
the plumes redraws to take into account the flow directions (attached). The redrawn
plume maps (which include a 5 ppb line for TCE) indicate similar patterns for the PCE,
TCE and 1,2-DCE plumes, showing a wider plume in the area extending from the Egiin
well to the LaPIace well as reflective of the divergent groundwater flow. Further it should
be noted thai no groundwater elevation data is available south of MW-22D therefore the
plume is conjectural downgndient of that location.
In addition, the outermost contours presented for individual compounds in the RI should
be revised to reflect the EPA MCLs. This is valid since the data is not generally
constrained by non detect values (presumably 10 ppb was used as the outermost contour
to reflect the detection level for these compounds).
3. Inappropriate Interpretation of VQC plumes in groundwater
The RI states that there are two plume* of VOCs. This is misleading and is an
inappropriate interpretation. It appears from the text that a "plume" is defined as an area
with greater than 10 ppb total VOCs. However, there is no technical basis for this
definition. A more valid interpretation should be based on the individual VOC
compounds. Further, there is no technical basis presented for using 10 ppb (apparently
an arbitrary number) as the limit of the contamination for total VOCi or for the individual
compounds. The contaminant maps for PCE are the most appropriate to discuss the extent
of contamination in the Turn ares. The contaminant maps for PCE (figures 5-25 and 5-26)
indicate three areas with PCE greater than 100 ppb in the shallow groundwater (referred
to herein as the northern, central and southern hot spots), but a more diffuse plume in.the
deep groundwater. This patten appears similar for other individual chlorinated VOCs.
There is no discussion in the RI of the central PCE hot spot, except to refer to it as a
subset of the "northern plume". This is a significant area and warrants discussion.
In the text discussing the "southern chlorinated VOC plume", a statement is made that the
'100 ppb contour extends from the Harvey Supply Well to the Smith Supply Well". This
infers a flow path between the two well* which is dearly impossible when considering the
Bow maps.
4. Misinterpretation of the significance of Esso as a source of potential contamination
Criteria for evaluating whether a property represented a source of impact to groundwater
ate presented on page 5-33 of the Final RI. These criteria are as follows:
• "If impact to soil at a ptupeity was established based on the NYS TAGM values,
ind similar constituents were found In the gtoundwater at or downgradient of the
property at higher concentrations than upgradient, the property was considered to
represent a source of impact to groundwater.
-------
• If organic compounds were detected io groundwater at concentrations in excess of
1 percent of their aqueous solubility it a property, these detections were viewed as
an indication of the possible presence of nonaqueous phase liquids (NAPLS) in the
unutunted or saturated zone. The property was therefore considered to represent
a source of impact to groundwster."
Showing the groundwater flow lines on the contaminant plume maps indicates that the
majority of the VOCs in the southern portion of the aquifer did not originate from the
O'Henry Dry Cleaners. Additional evidence for this position is provided in the analysis
of MTBE, a gasoline additive. MTBE has contaminated the deep aquifer in an area
extending south from the Texaco station, past the Esso station to the Delegarde Well.
Note that MTBE is found at low concentrations in wells near the O'Henry facility. Since
MTBE is 8 compound which moves quickly with the groundwater, it can be considered
aa a tracer for any chemicals emanating from the gas stations. Therefore, MTBE can be
used to trace the general direction of groundwater flow (and therefore direction of
chemical movement) tram Esso to the south. Since MTBE did not originate at the
O'Henry Dry Cleaners and MTBE is found in drinking water supply wells Eglin I, Eglin
m, Harvey, Steele, LaPlace, Smith and Delegarde, downgradient of the Esso facility, the
Esso station MUST be considered a source to impact to groundwater all the way to the
Delegarde well. :
5. Inappropriate and inadequate evaluation of the sanitary sewer system as a source of
contamination. ;
The RI inadequately addresses historical sources to the sanitary sewer as a potential source
of contamination to the subsurface. For example, the report ignores the fact that the waste
oil holding tank, (used to dispose of VOCs) was emptied directly into the toilet (therefore
directly entering the sanitary sewer system) at the Esso station (Soil Tech, 1990).
Chlorinated VOO detected in the storm sewer at the Esso station Is attributed in the RI
to infiltrating groundwater because Blasland, Bouck and Lee (Esso's consultant) 'observed
groundwater infiltrating into the sewer" when the sample was collected Further, the
assertion that the storm water sewer occurs within the water table in this area is based on
one reading from one location therefore this assertion Is an assumption, not a conclusion
as presented in the :RI report.
The discussion in the RI of the sanitary sewer results infers that O'Henry is a current
source of VOCs to the sanitary system because "the highest concentrations of chlorinated
VOCs were found in the sanitary sewer samples from O'Henry'. This is misleading for
several reasons:
• The "samples' at the sewer near O'Henry are actually one sample and its duplicate.
• The text implies that the water in the sanitary sewer is from O'Henry. In reality,
water enters the sewer from a variety of sources, including the Tom Cat laundry.
As has been pointed out to Oeraghty and Miller on several occasions, at the time
when the sample was collected from the sewer, water was flowing into the sewer
-------
from the north side (from the Tom Cu laundry). The Tom Cat Laundry use* water
from the Eglin supply wells in its machine* without prior treatment therefore (he
water entering the sewer (and therefore sampled by ADL) i* effectively Eglin well
water.
6. Misinterpretation of O'Henrv Dry Cleaners as one of the main source areas for t>]g
southern plume.
the RI claims that O'Henry Dry Cleaners is 'the main* and 'the principal source of the
southern chlorinated plume*. The basis fix this statement is that "In the southern
chlorinated plume, relatively high chlorinated VOC concentrations have been detected in
the vicinity of and downgradient of O'Henry". Further, the RI claims that "This
conclusion Is confirmed by the high concentrations of PCE in soil from this area*. These
claims are not supported by the data for the following reasons:
• Since "Relatively high concentrations' is not defined it is not known what is meant
by this.
• Chlorinated VOCs detected in grooadwater in the vicinity of O'Henry may have
originated at any source upgndient. The presence of elevated VOCs does not
logically leadta the conduiion that the property Is a source.
• Consideration of the grounoVater flow maps together with contaminant concentration
maps indicate that ft is unlikely that contaminants entering the groundwater at
O'Henry nave contaminated the Steele, LaPlace, Smith , Mathias and Dclegaroe
wells.
• Data recently obtained during the soil removal action at the O'Henry Dry Cleaners
confirm that no DNAFL is present in the soils (Soil Remediation Report, IT, May
1995). Further, during the soil removal action, soil samples were collected from a
boring placed where previously the highest levels of PCE detected in soils were
found.. The soil samples indicated that no PCE is present in soils below 10 feet.
Note that the unsaturated zone extends to approximately 20 feet at this location.
7. Comments Concerning DMAPL evaluation^
The Final RI discussion of the likely presence of DNAFL indicates s high probability of
a DNAFL release at the O'Henry Dry dcaners based on the historical use of PCE as a
dry cleaning solvent using the criteria set forth in EPA 1992b. This is inappropriate uae
of this EPA publication where the goal is to provide guidance for site characterization.
The Final RI states that the concentrations of PCE in soils found at O'Henry are not high
enough to conclude that PCE is present as a separate phase in soils. Data recently
obtained during the soil removal action at the O'Henry Dry Cleaners confirm that no
DNAPL Is present in the soils. (Soil Remediation Report, IT April 1995).
Evidence used in the Final RI to indicate that DNAPL is present in the groundwater
beneath the O'Henry Dry Cleaners is that concentrations of PCE in groundwater samples
-------
from two tampiiag round* (between 1987 ud 1991) were »l levels which exceeded 1
percent of the solubility. Thii may indicate thit free-phase existed before 1991.
However, conceotntioDi of PCE in groundwater samples collected from the Harvey supply
well since 1991 have been mnch lower, indicating no free-phase since 1991. Therefore
there it no evidence to conclude that PCE is present as a separate phase in groundwater
beneath the O'Heory Dry Cleaners.
If it is assumed that the criteria provided in the Final RJ for determining the high
probability of DNAFL in groundwater is correct, then historical data provided for the
TIHet supply well indicate that this area should also be identified as an area suspected to
contain DNAFL in: the saturated zone.
-------
-------
v/..-" (/.,r ..
o t .£.•-;-•• /
-------
-------
-LJ' -,' " vi P _£, \
JRH®.
-------
-------
-------
-------
\\ .TVV\ i\ \~\ , ? ur >i
IU1 WJ&\ flWS
-------
------- |