EPA/ROD/R02-96/268
1996

EPA Superfund

Record of Decision:

TUTU WELLFIELD
EPA ID: VID982272569
OUOl
TUTU, VI
08/05/1996

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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

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DECLARATION FOR THE RECORD OF DECISION

SITE NAME AND LOCATION

Tutu Wellfield Site

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 Wellfield Site (Site) in accordance with the
reguirements of the Comprehensive Environmental Response, Compensation and Liability Act of
1980, as amended (CERCLA), 42 U.S.C. §9601 et seg. and to the extent practicable 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 CFP 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 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 Wellfield Site, the principal threat are
surface and subsurface soil containing high concentrations of mobile contaminants of concern,
and non-agueous phase liguids (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;

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!	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 0'Henry Dry Cleaners and the Curriculum Center where dense
nonagueous phase liguids (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 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 remedial design).

0'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 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 phrase.
Additional source delineation is reguired prior to installation of the in-situ SAVE 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

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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.

GROUNDWATER 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 aguifer 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 guality 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
DPNR and 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 operation 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 migration. 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 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
will provide hydraulic barriers around source areas, allowing the reduction
of contaminants in other parts of the aguifer 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 capacity of

100 gpm. Water will be treated to surface water criteria for discharge
to the storm sewer near the 0'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

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supplied (i.e., through collection of rain water to cisterns and trucking
water by tanker truck).

!	Conduct semi-annual groundwater sampling to monitor its guality and

contaminant migration. The monitoring program will include the sampling
approximately 15 wells at or near the plume boundary for VOCs and base
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 facility to 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 modeling. A wetlands assessment may be required if
the groundwater modeling shows an adverse effect from discharge of treated water to the
wetlands.

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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 DNAPL below); (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 DNAPLs are present in the
unsaturated and/or saturated soils and fractured bedrock at the Curriculum Center and 0'Henry
Dry Cleaners properties. If DNAPLs are present in either of these areas, there are technical
limitations, from an engineering perspective, which may make it impracticable to find and remove
all the DNAPLs from these properties. This will be especially true if DNAPLs are present in the
complex fractured bedrock, either above or below the water table. Because DNAPL contributes to
dissolved phase groundwater contamination, restoration of groundwater in the vicinity of the
Curriculum Center and 0'Henry Dry Cleaners may be technically impracticable. Therefore, a waiver
of MCLs ultimately may be required for the Curriculum Center and 0'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.

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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
HRS 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 source 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 0 & 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 guantity: N/A
Contaminated media: Soil and groundwater

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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

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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

TABIiE OF CONTENTS	page

SITE NAME, LOCATION AND DESCRIPTION 	 1

SITE HISTORY AND ENFORCEMENT ACTIVITIES 	 1

HIGHLIGHTS OF COMMUNITY PARTICIPATION 	 3

SCOPE AND ROLE OF OPERABLE UNIT 	 4

SUMMARY OF SITE CHARACTERISTICS 	 4

SUMMARY OF SITE RISKS 	 10

SELECTION OF SITE CLEANUP LEVELS 	 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 SIGNIFICANT CHANGES 	 44

ATTACHMENTS

APPENDIX I.	FIGURES

APPENDIX II.	TABLES

APPENDIX III. ADMINISTRATIVE RECORD INDEX
APPENDIX IV. TERRITORIAL LETTER OF CONCURRENCE
APPENDIX V.	RESPONSIVENESS SUMMARY

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SITE NAME, LOCATION AND DESCRIPTION

The Tutu Wellfield Site 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 shop, 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 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 chromatograph (GC)
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

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sampling event (excluding methylene chloride, which is a common laboratory contaminant) was
2,000 ppb of PCE in the Harvey Supply Well.

In January 1988, EPA initiated a limited Comprehensive Environment Response, Compensation, and
Liability Act (CERCLA) removal action that included the decontamination and cleaning of five
residential cisterns contaminated by hazardous substances, modification of plumbing, delivery of
water by tank truck 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 Reguest 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 reguests, EPA
issued a Unilateral Administrative Order (AO) under CERCLA and RCRA on March 22, 1990 to Texaco,
Esso, and 0'Henry Dry Cleaners. This AO reguired 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 Wellfield Site 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 reguiring the implementation of a Remedial Investigation (RI)
and Feasibility Study (FS) in the Tutu area. Texaco and Esso formed the Tutu Environmental
Investigation Committee (TEIC) in March 1990 and retained Geraghty & Miller to prepare a work
plan for, and to implement, the RI and FS. A final VOC was entered into by EPA, Texaco, and Esso
on February 19, 1992.

EPA proposed the Tutu Wellfield Site for inclusion on the National Priorities List (NPL) on
February 1, 1992. The Site became finalized on the NPL on September 29, 1995.

In March 1995, EPA issued a Consent Order to L'Henri, Inc. (0' Henry Dry Cleaners) for soil
cleanup. Pursuant to that Order, approximately 700 cubic feet of PCE contaminated soil was
removed at the 0'Henry Dry Cleaners property and treated on site by soil venting.

Since 1993, EPA had 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 RI report, FS report, and the Proposed Plan for the Site were originally released 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 RI report, FS report and the Proposed Plan were made available to the public in the

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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 Journal 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
guestions 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 OPERABIiE 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 contaminated
groundwater; 2) to contain the spread of contamination in the aguifer, and, if possible, restore
the aguifer to drinking water guality; 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 commercial 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 RI were: 1) to
identify and characterize the potential sources of groundwater contamination, 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 RI 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 RI, 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:

*	VIHA

*	Curriculum Center

*	Ramsay Motors

*	Antilles Auto Parts

*	Texaco Tutu Services Station

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Tillett Gardens
Four Winds Plaza
Former Western Auto
Esso Tutu Service Station
0'Henry Dry Cleaner
Fire Station
Vitelco

God of Holiness Church
Lutheran Church
Assembly of God Church

Concurrent with the RI activities, commercial and residential supply wells in the Tutu valley
were sampled on a quarterly basis.

HYDROGEOLOGY

The Tutu Wellfield Site is underlain by bedrock consisting mainly of andesitic, volcanoclastic
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 surficial alluvial 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 Wellfield Site. 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 RI, surface and subsurface soil samples were collected from borings
and monitoring well boreholes. Soil quality data was collected from 15 properties in the
project study area to identify impacted soils.

Soil samples collected during the RI 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

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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) 0'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 dens
non-agueous phase liguid (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 0'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 DNAPL to be present in the subsurface soils near the 0'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 vicinity of the former UST
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

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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, 00 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.

GROUNDWATER INVESTIGATIONS AND RESULTS

During the Phase I RI, groundwater samples were collected from 19 monitoring wells in the Tutu
area. During the Phase II RI, 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 guality parameters. In addition, eight rounds of groundwater supply well
samples were collected and analyzed during the RI. 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 contamination 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 vicinity of 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 RI 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 concentration 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-agueous phase liguids (DNAPLs) are therefore suspected to be present in this

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vicinity. The maximum concentrations of 1,1-DCE and vinyl chloride also strongly suggest the
presence of chlorinated DNAPL in the vicinity of the Curriculum Center, (see Table 2)

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 0'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 0'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 0'Henry Dry Cleaners. The
historical presence of PCE at concentrations in excess of 1,500 ppb in wells adjacent to the
0'Henry facility suggests the possible presence of DNAPLs in 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-agueous phase liguids (LNAPL).

CONTAMINANT MIGRATION PATHWAYS

Contaminant may migrate through environmental media at the Tutu Wellfield Site via several
mechanisms. First, the constituent-containing soils can act as a source of constituents to
environmental media. Second, migration into air may occur via volatilization or 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 pathways.
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 RI, a baseline risk assessment was conducted to estimate the risks

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associated with current and future Site conditions. The baseline risk assessment estimates the
human health and ecological risks which could result from exposure to chemical contamination at
the Tutu Wellfield Site if no remedial action were taken.

Risk to human health is defined as the likelihood that people living, working, or playing on to
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 exposure,

the frequency and duration of these exposures, and the pathways (e.g., ingesting
contaminated well-water) by which humans are potentially 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 contaminants included VOCs,
semivolatile 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 0'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, toxicity and 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.

Toxicity Assessment

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Under current EPA guidelines, the likelihood of carcinogenic (cancer-causing) and
noncarcinogenic effects 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 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)-1, 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 10-4 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 Wellfield Site was completed in 1994.

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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 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 10-4 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 lot 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 ot
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 2 X 10-4 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.

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.

Groundwater 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

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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 gualitative 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 guantitative 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, linking contaminant concentrations to effects on ecological receptors

!	Risk Characterization - measurement or estimation of both current and future

adverse effects.

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 jamaicensis), representing
a high order food web consumer, and the anole (Anolis sp.), 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 toxicological benchmark 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.

Risk 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 dividing the 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:

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! 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 0'Henry Dry Cleaners
property, where the maximum concentration 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.

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
Anole will be 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
! toxicological data

Uncertainty in environmental sampling arises in part from the potentially uneven distribution of

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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 characteristic 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.

Uncertainties in toxicological data 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
As s e s sment Report.

SEIiECTION OF SITE CLEANUP IiEVELS

The cleanup levels for groundwater at the Tutu Wellfield Site 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 DNAPLs are 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).

Therefore 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 (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

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properties where soil quality is believed to be impacting groundwater quality: 1) the Curriculum
Center, 2) Texaco Tutu Service Station, 3) Esso Tutu Service Station and 4) 0'Henry Dry
Cleaners. SSLs for these properties are shown in Table 12. These concentrations represent a
conservative estimate of residual concentrations of contaminants that could remain in soils such
that the resulting groundwater concentration 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 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 environment. 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 restoration 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 risk

greater than 1 in 10,000 or a hazard index greater than 1.

!	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

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control of the hazardous 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 alternatives
(Groundwater Remediation Alternatives (GRA) 1, 2, 3, and 4) for addressing groundwater
contamination associated with the Tutu Wellfield Site. Construction times reflect only the time
reguired to construct or implement the remedy and does not include the time reguired 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
Wellfield Site 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
reguired 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 reguired at the Tillett Gardens
property. In September 1995, EPA and DPNR collected confirmatory soil 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, indicating that PCBs are no longer a concern for this
property.

Soil Remedial Alternatives (SPA) For Impacted Soil:

Source Control Programs (SCPs) for the Texaco and Esso Service Stations will be implemented 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 (0 & M) and
total present worth costs of SRA 2, SRA 3, SRA 4 and SRA 5 include the implementation of the
SCPs. The 0 & M cost has been estimated based on the projection that the 0 & M of the SCPs will
continue for 5 years. (The actual 0 & M period may be shorter or longer than 5 years.)

SRA 1: No Action/Institutional Controls

Capital Cost: $15,000
0 & M Present Worth: $0

Total Present Worth, 30-Yr. Cost: $15,000
Construction Time: Not applicable

The Superfund program reguires that the "no-action" alternative be considered as a baseline for
comparison with other alternatives. The institutional controls as recommended 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, 0'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

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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;

!	Institutional controls in the form of Governmental controls and/or proprietary

controls would be sought which prohibit removal or disturbance of bedrock at
0'Henry Dry Cleaners and the Curriculum Center where DNAPLs may be present.

SRA 2: Institutional Controls/Capping

Capital Cost: $ 311,000
0 & 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 following actions:

!	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 0'Henry Dry Cleaners have been evaluated 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 reguire installation of a cap or pavement, as
necessary.

SRA 3: Institutional Controls/Capping/In-situ Soil Vapor Extraction (SVE)/Excavation and
Off-site Disposal

Capital Cost: $ 1,533,000
0 & M Present Worth: $ 2,062,000
Total Present Worth, 30-Yr. Cost: $ 3,595,000
Construction Time: 12 to 18 months

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 treatment technology

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which consists of the installation of a network of vadose zone extraction 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 particle 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 volatilzating into 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 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 determined

after confirmatory sampling during RD).

0'Henry Dry Cleaners:

!	In-situ SVE treatment of impacted soils;

!	In-situ SVE treatment in the unsaturated^d 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;

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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.

Sourced removal can be achieved by excavating contaminated soil at Four Winds Plaza/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 excavate
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 subsequent 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.

SRA 4: institutional Controls/Capping/Ex-situ SVE/Excavation and On-site Disposal

Capital Cost: $ 1,502,000
0 & 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 0'Henry Dry Cleaners, there would be some excavation
and ex-situ SVE of impacted soils instead of in-situ SVE, and at the Curriculum 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 contaminants
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 Plaza/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.

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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 determined

after confirmatory sampling during RD).

0'Henry Dry Cleaners:

!	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 subseguent 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/In-situ SVE/Excavation and Off-Site Disposal

Capital Cost: $ 2,035,000
0 & 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 0'Henry Dry Cleaners, some of the impacted soils
would be excavated and disposed of off-Site.

Specifically, SRA 5 consists of the following actions:

!	Institutional controls as described in SRA 1.

Texaco Tutu Service Station:

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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).

0'Henry 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
the unsaturated zone;

!	Thermal oxidation for off-gas treatment.

Soil at individual properties where contamination is above the SSLs identified for the Tutu
Wellfield Site 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 permitted hazardous waste treatment
or disposal facility. Clean fill material would be brought 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
eguipment, including backhoes, power shovels and clamshells can be used to excavate soil and
decontaminated afterward. The excavated material can be containerized 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 implemented as an
early remedial action for GRA 2, 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 (0 & M) and total

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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.

GRA 1: No Action/Institutional Controls/Monitoring

Capital Cost: $ 15,000
0 & 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 proprietary
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 following actions:

!	Institutional controls to prohibit unauthorized use of groundwater or installation of

new wells. Authorization must be obtained from DPNR and 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 guality and contaminant

migration. The monitoring program includes sampling approximately 15 wells at or near
the plume boundary for VOCs and BNAs, and would last throughout the remedial action and
O&M (estimated, for costing purposes, to be approximately 30 years).

GRA 2: Institutional Controls/Source Containment/POET Systems/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 to a methodology for hydraulic containment of the potential groundwater
contamination source areas (0'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 discharge for distribution for potable
purposes. In other areas of the aguifer, natural attenuation would be relied upon.

The total flow capacity of the treatment facility would be 55 gpm. Property acguisition might
be reguired for such treatment facility.

GRA 2 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 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 aguifer 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.

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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 to prohibit unauthorized use of groundwater or installation of new

wells. Authorization must be obtained from DPNR and 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 MCLs through treatment in large
portions of the Tutu Wellfield Site. (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 0'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 contaminant migration.
The monitoring program includes sampling approximately 15 wells at or near the plume
boundary for VOCs and BNAs, and would last throughout 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

GRA 3 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 hydraulically contain
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 GRA 2.

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 Wellfield Site, thus reducing pumping requirements.

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GRA 3 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 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 aguifer 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
guality 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 DPNR and 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 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 0'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 guality and contaminant

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).

GRA 4: 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

GRA 4 is identical to GRA 3, with the addition of the installation of two groundwater recovery
wells for hydraulic control of two of the areas identified as potential source areas (0'Henry
Cleaner and Curriculum Center). GRA 4 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)

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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 Wellfield 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 Wellfield Site, thus reducing pumping requirements.

GRA 4 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 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 to prohibit unauthorized use of groundwater or installation of new

wells. Authorization must be obtained from DPNR and 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 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, allowing the reduction of contaminants in other parts of the
aquifer and potentially reducing the time needed to reach MCLs in large portions of the
Tutu Wellfield Site. (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 0'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 contaminant

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).

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!	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 facility to 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 the NCP, 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 adeguate 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 ARARs addresses whether or not a remedy would meet all of the applicable
(legally enforceable), or relevant and appropriate (reguirements that pertain to
situations sufficiently similar to those encountered at a Superfund site such that their
use is well suited to the site) reguirements of federal and state environmental statutes
and reguirements 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 over time, once cleanup goals
have been met. It also addresses the magnitude and effectiveness of the measures that
may be reguired 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 protection 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 availability of materials and services needed.

7.

Cost includes estimated capital and operation and maintenance costs, and the
present-worth costs.

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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 reservations
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 reguirements of this criterion due to
the current and potential future exposures to unacceptable levels of contamination. In addition,
it is unclear whether adeguate institutional controls could be obtained and would remain in
place over time. SRA 3, SRA 4 and SRA 5 provide egual 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. GRA 2 does not meet this criterion in part because POET
systems are not considered an adeguate long-term solution for potential impact of 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 RCRA Land 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 reguire 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 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 Level (MCLs) for drinking
water. In addition, the Virgin Islands Water Pollution Control Act reguires 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 reguires
any remedial action to minimize harm to or within wetlands.

GRA 1 (No Action/Institutional Controls) does not comply with ARARs because without active

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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 qroundwater restoration at the Curriculum Center and 0'Henry Dry Cleaners properties miqht
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 0'Henry Dry, Cleaners
properties qroundwater. EPA's memorandum Guidance for Evaluatinq the Technical Impracticability
of Groundwater Remediation (OSWER Directive 9233334.2-25, October 1993) recoqnizes that the
presence of DNAPLs may make qroundwater restoration technically impracticable.

!	Lonq-Term Effectiveness and Permanence

SRA 1 does not meet this criterion. SRA 2 is effective at minimizinq the transport of impacted
soil or leachinq of contaminants, but does not totally eliminate potential future exposure. SRA
3/SRA 4 and SRA 5 address this criterion by either removinq contaminated soils from the Site or
reducinq the levels of contamination in soils. A combination of SRA 3/SRA 4 would be the most
favorable remedy in complyinq with this criterion. The lonq-term effectiveness and permanence
of SRA 3/SRA 4 is very hiqh in that the contaminated soils would be treated and the contaminated
areas restored.

GRA 2 is not effective as a lonq-term or permanent remedy. The potential for off-Site
qroundwater transport of contaminants may still exist, dependinq on the ability to utilize
private wells and to coordinate their pumpaqe to hydraulically contain impacted qroundwater.
GRA 3 is not considered favorable for this criterion because effectiveness on the plume capture
would be continqent 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 to be active. GRA 4 would be the most
effective GRA for this criterion because it provide both plume and source containment, and the
qreatest potential for remediation of the aquifer.

!	Reduction in Toxicity, Mobility, or Volume Throuqh Treatment

SRA 1 and SRA 2 do not provide treatment or reduction in contaminant volume and therefore do not
comply with this criterion, althouqh cappinq or impermeable cover (for all alternatives) does
reduce contaminant transport to the qroundwater. SRA 3/SRA 4 reduce the toxicity, mobility and
volume of impacted soil by treatment. SRA 5 would also reduce the toxicity, mobility and volume
of impacted soils by treatment, thouqh some of the impacted soils at the 0'Henry Dry Cleaners
facility would be excavated and shipped off-Site for disposal, rather than beinq treated throuqh
in-situ or ex-situ SVE. SRA 4 has the most potential for reducinq soil contaminants because
some of the impacted soil would be treat in an enqineered environment rather than in-situ.

GRA 2 would be moderately effective in the reduction of toxicity, mobility and volume because
source control would result in contaminant removal from qroundwater, and intermittent pumpinq of
residential wells equipped with POETs would also result in some reduction in the volume of COCs
in qroundwater. The toxicity, mobility and volume of impacted qroundwater in GRA 3 would be
reduced throuqh containment and pumpinq; however the potential presence of DNAPLs in the bedrock
aquifer at the Site could act as a continual source of qroundwater contamination throuqhout the
life of the remedial action. GRA 4 would extract and treat the most impacted qround water, thus
maximizinq the reduction in toxicity, mobility, and volume. The effects of DNAPLs that may be
present in the bedrock aquifer would be reduced with source control, decreasinq the time needed
to reduce contaminant concentrations within most of the aquifer.

Short-Term Effectiveness

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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
installing 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 reguired for
installation, and therefore, it would be the most effective GRA at addressing this criterion.
The construction related to GRA 3 and GRA 4 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.

!	Implementability

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 aguifer 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.
GRA 4 would not be favorable under this criterion because it has the most significant
administrative reguirements. GRA 4 places the greatest withdrawal demand on the Tutu aguifer and
may create upconing of mineralized water in some areas of the aguifer. Therefore, pre-design
studies must carefully optimize reguired pumping rates. GRA 3 would be the most implementable
because this GRA is it the least obtrusive, minimizing the 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 reguire the least amount of eguipment and materials to construct.

!	Cost

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 Responsiveness Summary
portion of this ROD following the review of all public comments received on the RI/FS report and
the Proposed Plan. All comments submitted during the public comment period were evaluated and

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are addressed in the attached Responsiveness Summary (Appendix V)

SEIiECTED REMEDY

EPA and DPNR have determined after reviewing the alternatives and public comments, that
Alternatives SRA 3/SRA 4 and GRA 4 are the appropriate remedies for the Site, because the best
satisfy the requirements of CERCLA §121, 42 U.S.C. §9621 and the NCP'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 form of Governmental controls and/or proprietary controls

will be sought which prevent permanently the removal or disturbance of bedrock at 0'Henry
Dry Cleaners and the Curriculum Center where 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 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 remedial design).

0'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;

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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 phrase.
Additional source delineation is reguired 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 contaminated 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)

!	Efforts will be made to have existing domestic and commercial wells within the

confines of the groundwater plume decommissioned if these well, 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 aguifer 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 guality improves to allow
extraction and use of untreated groundwater.

!	Institutional controls (in the form of Governmental control and/or proprietary

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 decommissioned, or installation of
any new wells within the confines of the plume area.

!	Implement Source Control Programs (consisting of installation and operation 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 migration. 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 hydraulically contain

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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, allowing the reduction of contaminants in other parts
of the aguifer 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 capacity of 100

gpm. Water will be treated to surface water criteria for discharge to the storm
sewer near the 0'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 guality 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 reguired during the pre-design stage
prior to implementation of this remedy. Groundwater extraction system design will be based on
field and aguifer testing and groundwater modelling. A wetlands assessment may be reguired 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)(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) 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

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laws, unless a waiver can be justified pursuant to CERCLA §121(d)(4), 42 U.S.C. §9621(d)(4).

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 presumptive 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.

GRA 4 provide the maximum protection of human health and the environment because it provide 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 DNAPLs are present.

Compliance with ARARs

The selected soil and groundwater remedy will be in compliance with all ARARs, subject to the
discussion of DNAPs, below.

The major ARARs for soil remediation are the RCRA Land 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.

EPA recognizes that the restoration of certain portions of the Tutu aquifer to MCLs may be
technically impracticable, due to the high probability that DNAPLs are present in the
unsaturated and/or saturated soils and fractured bedrock at the Curriculum Center and 0'Henry
Dry Cleaners properties. If DNAPLs are present in either of these areas, there are technical
limitations, from an engineering perspective, which may make it impracticable to find and remove
all the DNAPLs from these properties. This will be especially true if DNALPs are present in the
complex fractured bedrock, either above or below the water table. Because DNAPL contributes to
dissolved phase groundwater contamination, restoration of groundwater in the vicinity of the
Curriculum Center and 0'Henry Dry Cleaners may be technically impracticable.

However, insufficient Site characterization data are available at this time to support a

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Technical Impracticability (TI) evaluation. The future determination of technical
impracticability 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 agueous plume outside of the containment area. In such a case, the TI waiver will be
spacially restricted to a limited TI zone, which lies within a groundwater containment area.
Outside of the TI 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 TI 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

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 groundwater 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.

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APPENDIX I
FIGURES

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APPENDIX II
TABIiES

Table 1. Summary of Analytes Detected in Soil above Soil Screening Levels at the Tutu Wells Site, St. Thomas, U.S. Virgin Islands.

Property	Parameter

Depth
(ft bis)

SSLs	Sample	Sample Interval

(ug/kg)	Name	(ft bis)

Chlorinated VOC Constituents

Curriculum Center

Esso Tutu Service Station

0'Henry Dry Cleaners

1,1,1-Trichloroethane

Tetrachloroethene

1,1,1-Trichloroethane

Trichloroethene

1.1-Dichloroethane

1.2-Dichloroethene(trans)(1)
Tetrachloroethane

0.0 - 2.8
0.0 - 4.0

4.0 - 15.0

4.0 - 15.0

731
320

32

32

4.0 - 15.0
0.0 - 4.0
4.0 - 15.0
0.0 - 4.0
4.0 - 15.0
0.0-1.6 375

1.7 - 22.0

31

TWS-03

B-103
SS-3

SS-7
SS-8

SS-7
SS-8

0.0 - 0.3

0.0 - 1.0
3.0

5.0
7.0

5.0
7.0

32 SS-8	7.0

320 SS-3	3.0

32 SS-8	7.0

320 SS-3	3.0

32 SS-7	5.0

SS-8	7.0
e-01 (surface soil)

e02-02	1.5-2.5

OHSS-1	2.0

OHSS-1

OHSS-1FR
B-13

5.0
8.0
5.0

4.0 - 8.0

Concentration
(ug/kg)

1, 800

394
1,100

520
1,500

44
58

45
560
70

3,200

75
110

440,000*
180,000
5,400 D

59,000 D
400 J
22,000
200 D

Trichloroethene

1.7 - 22.0

31

e02-02

1.5 - 2.5

75

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BTEX Constituents
Curriculum Center

Ramsay Motors

Benzene
Toluene
Ethylbenzene
Xylenes

Benzene
Ethylbenzene

0.0 - 2.8	150

0.0 - 2.8	150

0.0 - 2.8	150

0.0 - 2.8	150

4.0 - 15.0
0.0 - 4.0

4.0 - 15.0	15

SS-12
TWS-03
SS-12
TWS-03
SS-12
TWS-03
S5-12
TWS-03

15 HB-2
74 HB-5

HB-2

See last page for footnotes.

0

0

LO

o
1

0

0

- 0.3

0

0

- 0.5

0

0

- 0.3

0

0

- 0.5

0

0

- 0.3

0

0

- 0.5

0

0

- 0.3

4.5
2.3

6,300 J
2,700
270,000
500,000
12,000J
47.000
77,000
420,000

17 J

190 J

4.5

290

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Table 1. Summary of Analytes Detected in Soil above Soil Screening Levels at the Tutu Wells Site, St. Thomas, U.S. Virgin Islands.

Property

Texaco Tutu Service Station

Parameter

Benzene
Ethylbenzene

Depth
(ft bis)

0.0- 8.7

0.0 - 8.7

SSLs
(ug/kg)

67

67

Sample
Name

TT-1D
TT-1D FR
OW/SB-1
TT-1D
TT-1D FR

Sample Interval
(ft bis)

4.5 - 5.0
4.5 - 5.0
6.5
4.5 - 5.0
4.5 - 5.0

Concentration
(ug/kg)

(170)

69

(630)

110/ (210)

140

Esso Tutu Service Station

Benzene

8.7 - 15.0
0.0 - 4.0

4.0 - 15.0

13
74

15

OW/SB-1

SS-3
TP-3
TP-5
TP-8

B-102
SS-7

SS-E

9.5

3.0

(Northeast Floor)
(Center Floor)
(South)

10.0 - 12.0
5.0
7.0

67/ (50)

880
230 J
1,100
93

625
160
270

Toluene

0.0 - 4.0

74

4.0 - 15.0

15

SS-3
SS-4
SS-5
SW-3
TP-3
TP-6

B-101

SS-1
SS-7
SS-8

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

53,000
4, 600
6,500
520
,200
180,000

28
548

46,000
33,000
51,000

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Ethylbenzene	0.0-4.0	74	SS-3

SS-4
SS-5
SS-3
TP-8
TP-5
TP-6

4.0-15.0	15	B-101

B-102

B-103
SS-1
SS-7
SS-8

See last page for footnotes.

3.0
3.0
3.0

0.0 - 2.0
(South Wall)
(Center Floor)
(East Floor)

10.0 - 12.0
4.0 - 6.0
8.0 - 10.0
10.0 - 12.0
7.0 - 7.5
9.0
5.0
7.0

11,000
990
520
170
520
7, 000

55,000

304
58

1,117
1, 037
26
12,000

I,700

II,000

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Table 1. Summary of Analytes Detected in Soil above Soil Screening Levels at the Tutu Wells Site, St. Thomas, U.S. Virgin Islands.

Property

Parameter

Depth	SSLs	Sample	Sample Interval

(ft bis)	(ug/kg)	Name	(ft bis)

Concentration
(ug/kg)

Esso Tutu Service Station
(continued)

Xylenes

0.0-4.0

74

SS-3

SS-4
SS-5
SW-3
TP-2
TP-3
TP-6
TP-7
TP-8

3.0

3.0
3.0
0.0 - 2.0
(North Floor)
(Northeast Floor)

(East Floor)
Southwest Floor
(South Wall)

77,400

24,200
29,000
1,170
1,600 E
31,000 E
540,000
300 E
220

4.0 - 15.0

15

B-101

B-102

SS-1
SS-7
SS-8

8.0 - 10.0
10.0 - 12.0
10.0 - 12.0
8.0 - 10.0
10.0 - 12.0
9.0
5.0
7.0

168
2,295
2,295
1,141
575**
80,400
58,000
78,000

Western Auto

Benzene

0.0 - 4.0
4.0 - 15.0

74
15

SS-1

SS-6
Tl-2

2.0

5.0 - 6.0
4.0

140
34

29 J

Toluene

0.0 - 4.0

74

SS-1
T2-AS
T2-ASRE

2.0
0.0 - 0.5
0.0 - 0.5

3, 900
760 J
800 J

4.0 - 15.0

15

MW-24-2

Tl-3

Tl-4

T2-1S

T2-3S

4.0 -
4.0
4.0
6.7
6.7

6.0

(34)

25 J
16 J
28 J
740 J

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Ethylbenzene	0.0-4.0	74	SS-1

SS-2
T2-AS
T2-ASRE
T2-SN
T2-4S

4.0 - 15.0

15

SS-4

SS-5

SS-6

SS-7

SS-8

SS-9

Tl-1

Tl-2

Tl-3

Tl-4

Tl-4

T2-1S

T2-2S

T2-3S

See last page for footnotes.

2.0
3.0
0.0 - 0.5

0.0 - 0.5
1.0 - 1.5
1.0 - 1.5

5.0 - 6.0
5.0 - 6.0
5.0 - 6.0
5.0 - 6.0
5.0
5.0
4.0
4.0
4.0
4.0
4.0
6.7
6.7
6.7

1, 600
850
890 J
1,000 J
230
150

37
100
420
270
340
290
100
240
20 J
18

16 J
230
29 J
980 J

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Table 1. Summary of Analytes Detected in Soil above Soil Screening Levels at the Tutu Wells Site, St. Thomas, U.S. Virgin Islands.

Property

Parameter

Depth
(ft bis)

SSLs
(ug/kg)

Sample
Name

Sample Interval
(ft bis)

Concentration
(ug/kg)

Western Auto
(Continued)

Xylenes

0.0 - 4.0

74

SS-1

2

0



34,000

SS-2

3

0



501

T2-AS

0

0

0.5

5, 800

T 2-AS RE

0

0

0.5

8,100

T2-SN

1

0

1.5

120

4.0 - 15.0

15

SS-4

SS-5

SS-6

SS-8

Tl-1

Tl-2

T2-1S

T2-2S

T2-3S

5.0
5.0
5.0
5.0
4.0
4.0
.7
6.7
6.7

6.0
6.0
6.0

128

125

2,700

53

85

210

430

51 J

7, 000

SSLs based on USEPA-subcontractor (CDM Federal Program Corp. 1995b) report on vadose zone modeling. Criteria are site-
specific, except for data from soil samples collected from Western Auto and Ramsay Motors, which are screened against
criteria applicable to the Esso Tutu Service Station.

Data reported in parentheses at Western Auto are from soil samples collected by ENSR Consulting & Engineering, Inc.

Data reported in parentheses at the Texaco Tutu Service Station are from soil samples collected by Blasland, Bouck & Lee, Inc.

*	Reported by the U.S. Environmental Protection Agency as tetrachloroethane; this is believed to be a
typographical error.

**	Result includes only methylxylene; o- and p-xylene data not available.

(1)	1,2-Dichloroethene (1,2-DCE) results reported as total 1,2-DCE and SSL applies to the trans-1,2-DCE isomer.
SSLs Soil Screening Levels. SSLs provided by the USEPA (CDM Federal Programs Corporation 1995b); see note above.
BTEX Benzene, toluene, ethylbenzene, and xylenes.

FR	Field replicate.

VOC	Volatile organic compound.

J	Result detected below reporting limit and/or an estimated concentration.

D	Analyte identified at a secondary dilution.

E	Exceeds instrumrnt calibration range.

ug/kg	Micrograms per kilogram, eguivalent to parts per billion (ppb).

ft bis	Feet below land surface.

USEPA	U.S. Environmental Protection Agency.

-------
Table 2. Summary of Analytes Detected in Groundwater Above Remedial Action Levels at the Tutu
Wells Site. St. Thomas, U.S. Virgin Islands.

Parameter

Oral
(ug/L)

Well

Designation

Concentration
(ug/L)
5/94

6/94

7/94

Volatile Organic Compounds
Vinyl chloride

MW-3
MW-15
MW-16

TT-3D
TT-5

48
260 D
1300
9 J
42

1,2-Dichloroethane(total)* 100

CHT-7D
DW-1

La Place**

MW-1

MW-1D

MW-3

MW-4

MW-6D

MW-7

MW-8

MW-10

MW-10D

MW-15

MW-16

Steele**

Tillett

TT-2

TT-2FR

TT-3D

TT-5

95

76 J
110 J

100
360 D

91

92	J

950 D
500
440 D
76 J
100
180
88 J

1500 D
2100

330
330
280
180

1,2-Dichlorethane

5

TT-1

250

-------
Trichloroethene	5	MW-1	--	78

MW-1D

—

71

MW-3

--

17 J

MW-4

--

6 J

MW-6D

--

11

MW-7

--

27

MW-8

--

10 J

MW-10

18 J

--

MW-100

14 J

--

MW-12D

9 J

--

MW-15

--

23

MW-16

--

72 J

MW-17

--

9 J

MW-21D

--

14 J

OHMW-4

16

--

Smith

19 J

--

Tillett

45

--

TT-2

--

20 J

TT-2 FR

--

20 J

TT-3D

—

15 J

See last page for footnotes.

-------
Table 2. Summary of Analytes Detected in Groundwater Above Remedial Action Levels at the Tutu
Wells Site. St. Thomas, U.S. Virgin Islands.

Parameter	RAL	Well

(ug/L)	Designation

Volatile Organic Compounds (continued)

Concentration
(ug/L)
5/94	6/94

7/94

Benzene

CHT-3
KFC-1
MW-5
MW-7
SW-2
SW-3
SW-7
SW-7 FR
TT-1
TT-1D
TT-4

1700
110 J
460 DJ

21
550 J
10000
99
110
21000
700

J
J
D
D
D

21000

Tetrachloroethene

CHT-6D
CHT-7D
Delegarde
DW-1
DW-2
MW-1
MW-1D
MW-3
MW-4
MW-4D
MW-6D
MW-6R
MW-7
MW-8

MW-10
MW-10D
MW-12D
MW-13D
MW-15
MW-16
MW-17
MW-20D
MW-21D
MW-25
OHMW-1
OHMW-2
OHMW-3
OHMW-4
Ramsay
Smith
SW-4

15 J

18

34 J
48 J
33 J

10
26

6 J

140

11
110 J

12
36

42 J

330 D
360
56
20 J
17 J
31
10
130
38 J

28 J
120
71 J

37
22 J
45 J
11

15 J

See last page for footnotes.

-------
Table 2. Summary of Analytes Detected in Groundwater Above Remedial Action Levels at the Tutu
Wells Site. St. Thomas, U.S. Virgin Islands.

Parameter

RAL
(ug/L)

Volatile Organic Compounds (continued)
Tetrachloroethene (continued)	5

Well
Designation

Tillett

Concentration

(ug/L)

5/94

6/94

180

TT-2
TT-3
TT-3D

90

91
23

Toluene

1000

SW-3
TT-1
TT-4

3200 J
16000 D
17000

Ethylbenzene

700

CHT-3
MW-5
SW-3
TT-1
TT-4

1800 D
760 DJ
4100 J
3700 D
3300 J

Xylenes (total)

10000	SW-3

TT-1

22000 J
18000 D

-------
Inorganic Compounds/Analytes

Aluminum

50 to 200

Four Winds II FR**

Harvey**

CHT-7D

Delegarde	1890 B

Gassett**	154 B

MW-1

MW- 6R

MW-7

MW-8

MW-9S	2050

MW-10	956

MW-10D	160 B

MW-1ID	147 B

MW-12D	93.9

MW-15
MW-17
MW-24
MW-25

OHMW-1	245000

OHMW-2	8970

OHMW-3	60000

OHMW-4	356000

Smith	60.9 E

SW-5	12100

SW-6	14500

63.1
111 E

118 B

18600 J
46400
10300
28700

3730 J
33000 J
4160
15800

See last page for footnotes

-------
Table 2. Summary of Analytes Detected in Groundwater Above Remedial Action Levels at the Tutu
Wells Site. St. Thomas, U.S. Virgin Islands.

RAL

Parameter	(ug/L)

Inorganic Compound/Analytes (continued)
Aluminum (continued) 50 to 200

Well
Designation

TT-1
TT-1D

6/94

Concentration
(ug/L)
6/94

6130 J
153 B

7/94

TT-2
TT-5

1090 J
787 J

DW-1
DW-2

1490

300

Antimony

Four Winds II **
KFC-1
MW-1
MW-2
MW-3
MW-4
MW-5
MW-6D
MW-7
MW-13D
MW 18
MW-2ID
MW-22D
OHMW-1
OHMW-3
SW-2
SW-3
SW-7
SW-7FR
TT-1
TT-3D
VIHA I **

22

16.1 B
50.7 B

18 . 6 BJ
17.6 B
15 B
17 B
20.1 B
20.1 B
25.3 B
21.3 B
424 B
20.6 B
19.6 B
22.3 BJ

15.4 BJ
16.4 BJ
19.2 BJ
17.6 BJ
19.7 B
19 B

20.6

Arsenic
Barium

50
2000

OHMW-2

MW-13D
OHMW-4

80.8

4320

4400 B

Beryllium

4

MW-13D

40.8 B

-------
Chromium

See last page for footnotes

DW-2

628

—

MW-1

--

453

MW-2

--

619

MW-6R

--

203

MW-7

--

1050

MW-8

--

210

MW-13D

--

4300

MW-17

--

238

OHMW-1

2200

--

OHMW-3

4610

--

OHMW-4

397

—

-------
Table 2. Summary of Analytes Detected in Groundwater Above Remedial Action Levels at the Tutu
Wells Site. St. Thomas, U.S. Virgin Islands.

RAL	Well	Concentration

Parameter	(ug/L)

Inorganic Compounds/Analytes (continued)
Copper	TT

Designation

MW-13D
OHMW-4

5/94

1370

(ug/L)
6/94

1730 J

7/94

Iron

300

Delegarde
DW-1
Gassett**
Harvey**
DW-2
KFC-1
MW-1
MW-1D
MW-2
MW-3
MW-4
MW-4D
MW-5
MW-6R
MW-7

4120 J

300

1150

3100
80000 J
25600
10500
19900
3830
7590
1440
5730
56900
44800

2500

-------
See last page for footnotes

MW-8	— 49700

MW-9S	3760

MW-10	1410

MW-10D	607

MW-11D	323

MW-12D	334

MW-13	— 3670

MW-13D	— 378000

MW-15	— 5360

MW-17	— 43500

43500

MW-18	— 63500 J

MW-19	— 3420 J

MW-20	— 23900

MW-20D	— 37800

MW-21D	— 19400

MW-24	— 6890

MW-25	— 30500

OHMW-1	338000

OHMW-2	15700

OHMW-3	15400

OHMW-4	572000

SW-2	— 14100 J

SW-3	— 108000 J

SW-4	— 5140

SW-5	18600

SW-6	20300 J

SW-7	— 14800 J

Tillett	530

TT-1	— 7810

TT-1D	— 515

TT-2	— 2320

TT-5	-- 1130

-------
Table 2. Summary of Analytes Detected in Groundwater Above Remedial Action Levels at the Tutu
Wells Site. St. Thomas, U.S. Virgin Islands.

RAL	Well

Parameter	(ug/L)	Designation

Concentration
(ug/L)
5/94	6/94

7/94

Inorganic Coumpounds/Analytes (continued)
Lead	TT

Gassett
MW-1
MW-9S
MW-18
MW-20
MW-20D
OHMW-1
OHMW-2

167
53.7

48.3
201

27.1 J

27.4
16
20

OHMW-3
OHMW-4
SW-3
SW-7
SW-7FR

17.3
71.8

143
70.8
93.8 J

-------
Manganese

50

CHT-7D
Delegarde
Four Winds II**
Four Winds II FR **
Harvey**
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-10D
MW-12D
MW-13
MW-13D
MW-15
MW-16
MW-17
MW-18
MW-19
MW-20
MW-20D
MW-2ID
MW-2 4
MW-2 5

282

163 B

257
620

2560
597
216
114

1030 J
570
338
356
2540
1290
55.1
1080
736
453
2350

110
20400
149
532
1550
3740 J
72.6 J
997
1140
402
215
982

125
119

See last page for footnotes.

-------
Table 2. Summary of Analytes Detected in Groundwater Above Remedial Action Levels at the Tutu
Wells Site. St. Thomas, U.S. Virgin Islands.

Parameter

RAL
(ug/L)

Well
Designation

Concentration
(ug/L)

5/94	6/94

7/94

Inorganic Compounds/Analytes (continued)

Manganese (continued) 50 OHMW-1	5870

OHMW-3	3180

OHMW-4	13500

SW-2	—	943 J

SW-3	—	6340 J

TT-1	—	1710

TT-1D	—	1880

TT-2	—	1220

TT-4	—	957

TT-5	--	1110

Mercury 2 OHMW-1	3.1	-

Nickel 100 MW-4D	-	460

DW-2	374

MW-1	—	124

MW-2	—	25 6

MW-6R	—	127

MW-7	—	445
MW-8

MW-10D	189

MW-13D	—	2050

MW-17	—	140

OHMW-1	1120 J

OHMW-3	1840 J

OHMW-4	603 J

Thallium 2 DW-1	--	2.4 B

MW-2 4	—	2.1 B

-------
Chloride

250,000

Eglin I**
Eglin III**
Harvey**
Matthias**
MW-21D
OHMW-1
OHMW-2
OHMW-3
Smith
SW-5

269

368

294

354
332
351
335
378

402

1700

Total Dissolved Solids 5000.000

CHT-3
CHT-6D
CHT-7D

1320
850
870

Delegarde
DW-1
DW-2
Eglin I**
Eglin III**

1440

1180
1330

910
870

See last page for footnotes.

-------
Table 2. Summary of Analytes Detected in Groundwater Above Remedial Action Levels at the Tutu
Wells Site. St. Thomas, U.S. Virgin Islands.

RAL	Well	Concentration

Parameter	(ug/L)	Designation	(ug/L)

5/94 6/94 7/94

Inorganic Compound/Analytes (continued)
Total Dissolved Solids (continued)

500,000	Four Winds I**

Gassett**

Harthman Race Track

Harvey**
KFC-1
La Place**
Matthias**
MW-1
MW-1D
MW-2
MW-3
MW-4
MW-4D
MW-5
MW-6D
MW-6R

700
1100

1360

1070

920
880
910
900
920
1180
810
840
910

1240

1190

MW-7
MW-8

760
920

MW-9S
MW-10
MW-12D

830

790
640

MW-13	— 900

MW-13D	— 1520

MW-15	— 990

MW-17	— 870

MW-18	— 800

MW-19	— 1040

MW-20	— 500

MW-20D	— 780

MW-2ID	— 2260

MW-22D	— 1890

MW-2 4	— 940

MW-2 5	— 950

OHMW-1	354

OHMW-2	1110

OHMW-3	1290

OHMW-4	1040

Ramsay	870

Smith	335

SW-5	378

-------
Nitrate (as N) (mg/L) 10,000 Gassett**	11.3

Harthman

Race Track	13.6

MW-1	— 12.4

MW-2	— 15.9

MW-13	— 10.6

MW-17	— 22.7

MW-2 4	— 13.3

Ramsay	10

See last page for footnotes.

-------
Table 2. Summary of Analytes Detected in Groundwater Above Remedial Action Levels at the Tutu
Wells Site. St. Thomas, U.S. Virgin Islands.

*	Analytical results reported for total isomers (cis- and trans-) for

1,2-dichloroethene (1,2-DCE): RAL is for trans-isomer.

**	Sample results were not validated.

Not available.
mg/L	Milligrams per liter.

ug/L	Micrograms per liter.

B	The reported value was obtained form a reading that was less than the Contract

Reguired Detection Limit (CRDL) but greater than or egual to the Instrument
Detection Limit (IDL).

J	Estimated value.

D	Compound concentration was determined at a secondary dilution factor.

RAL	Remedial Action Level.

TT	Treatment technigue. (Action Levels: Copper 1,300 ug/L, lead 15 ug/L). Values in

parentheses are determined by the USEPA.

USEPA	U.S. Environmental Protection Agency.

Note:

RALs derived from Federal Drinking Water Standards.

-------
SUMMARY OF

Tillett Gardens and Art
Center

VOCs:

None Selected
SVOCs:

None Selected

Pesticides/PCBs:

Aroclor 1242

Inorganics:

Antimony
Arsenic
Manganese
Vanadium

TABIiE 3
TUTU WELLS SITE
ALS OF POTENTIAL CONCERN IN

SURFACE SOIL

Fire Dept/Texaco Gas
Station/Antilles Auto
Parts/Ramsay Motor Co.

VOCs:

None Selected
SVOCs:

Benzo(b)fluoranthene
Benzo(a)pyrene

Pesticides/PCBs:

None Selected

Inorganics:

Antimony
Beryllium
Manganese
Vanadium

MATRICES BY AREA OF CONCERN

Curriculum Center
Building (Present)

VOCs:

None Selected
SVOCs:

2-Methylphenol
4-Methylphenol

Pesticides/PCBs:

None Selected

Inorganics:

Antimony

Arsenic

Beryllium

Manganese

Vanadium

Curriculum Center

Building (Future)

0'Henry Dry Cleaners
and Liguor Barn

VOCs:

None Selected
SVOCs:

2-Methylphenol
4-Methylphenol

Pesticides/PCBs:

None Selected

Inorganics:

Antimony

Arsenic

Beryllium

Manganese

Vanadium

VOCs:

Tetrachloroethene
SVOCs:

None Selected

Pesticides/PCBs:

None Selected

Inorganics:

Antimony
Arsenic
Manganese
Vanadium

-------
Table II. Groundwater Chemical-Specific Remedial Action Levels Identified for the
Tutu Wells Site, St. Thomas, U.S. Virgin Islands.

Groundwater RAls

USEPA

Parameters

MCLs
(mg/L)

MCLGs
(mg/L)

Volatile Organic Compounds (continued)

Carbon disulfide
1,1-Dichloroethene

1.1-Dichloroethene

1.2-Dichloroethene(cis)
1,2-Dichloroethene(trans)
Chloroform

1,2-Dichloroethane
2-Butanone

1.1.1-Trichloroethane
Carbon tetrachloride
Vinyl acetate
Bromodichloromethane
1,1,2,2-Tetrachloroethane
1,2-Dichloropropane
trans-1,2-Dichloropropene
Trichloroethene
Dibromochloromethane

1.1.2-Trichloroethane
Benzene

cis-1,3-Dichloropropene

Bromoform

2-Hexanone

4-Methyl-2-pentanone

Tetrachloroethene

Toluene

Chlorobenzene

Ethylbenzene

Styrene

Total xylenes

0.007

0.07
0.1

0.005

0.2
0.005

0.005

0.005
0.005

0.005

0.7
0.1
10

0.007

0.07
0.1

0.2
0

0.003
0

0

1

0.7
0.1
10

Pesticides/PCBs

alpha-BHC

beta-BHC

delta-BHC

gamma-BHC(Lindane)

Heptachlor

Aldrin

See last page for footnotes.

-------
Table II. Groundwater Chemical-Specific Remedial Action Levels Identified for the
Tutu Wells Site, St. Thomas, U.S. Virgin Islands.

Groundwater RALs

Parameters

USEPA

MCLs
(mg/L)

MCLGs
(mg/L)

Pesticides/PCBs, continued

Heptachlor epoxide

Endosulfan I

Dieldrin

4,4' -DDE

Endrin

Endosulfan II
4,4'-DDD

Endosulfan sulfate
4,4'-DDT
Methoxychlor

Chiordane(alpha and/or gamma)

Toxaphene

Aroclor 1016

Aroclor 1221

Aroclor 1232

Aroclor 1242

Aroclor 1248

Aroclor 1254

Aroclor 12 60

Endrin ketone

0.002

0.04
0.003

0.002

0.04
0
0

Semivolatile Organic Compounds

Phenol(s)

bis(-2-Chloroethyl)ether
2-Chlorophenol

1.3-Dichlorobenzene

1.4-Dichlorobenzene
Benzyl alcohol

1,2-Dichlorobenzene

2-Methylphenol

bis(2-Chloroisopropyl)ether

4-Methylphenol

N-Nitroso-di-propylamine

Hexachloroethane

Nitrobenzene

Isophorone

2-Nitrophenol

0.6
0.075

0.6

0.6

0.6

See last page for footnotes.

-------
Table II. Groundwater Chemical-Specific Remedial Action Levels Identified for the
Tutu Wells Site, St. Thomas, U.S. Virgin Islands.

Groundwater RALs

USEPA

Parameters

MCLs
(mg/L)

MCLGs
(mg/L)

Semivolatile Organic Compounds (continued)

2,4-Dimethylphenol
Benzoic acid

bis(2-Chloroethoxy)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-Trichlorophenol

2.4.5-Trichlorophenol
2-Chloronaphthalene

2-Nitroaniline
Dimethylphthalate
Acenaphthylene

3-Nitroaniline
Acenaphthene

2,4-Dinitrophenol

4-Nitrophenol
Dibenzofuran

2,4-Dinitrotoluene

2,6-Dinitrotoluene

Diethylphthalate

4-Chlorophenyl-phenylether

Fluorene

4-Nitroaniline

4,6-Dinitro-2-methylphenol

N-Nitroisodiphenylamine

4-Bromophenyl-phenylether

Hexachlorobenzene	0.001	0

Penta-chlorophenol	0.001	0

Phenanthrene

Anthracene

Di-n-butylphthaiate

Fluoranthene

See last page for footnotes.

-------
Table II. Groundwater Chemical-Specific Remedial Action Levels Identified for the
Tutu Wells Site, St. Thomas, U.S. Virgin Islands.

Groundwater RALs

Parameters

MCLs
(mg/L)

US EPA

MCLGs
(mg/L)

Semivolatile Organic Compounds (continued)

Pyrene

Butylbenzylphthalate
3,3-Dichlorobenzidine
Benzo(a)anthracene
bis(2-Ethylhexyl)phthalate
Chrysene

Di-n-octyl phthalate
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Indeno(1,2,3-c d)pyrene
Dibenz(g,h)anthracene
Benzo(g,h,i)perylene

0.1 (P)

0.0001 (P)
0.006

0.0002 (P)

0.0001
0.0004 (P)
0.0003 (P)

0 (P)

0 (P)
0

0	(P)
0

0	(P)

0	(P)

All RAls expressed in milligrams per liter (mg/L) unless indicated.
Currently, there are no federal standards for soil or sediment.

mg/L
TT

(1)

US EPA

RALs

MCLs

MCLGs

PCBs

(P)

Milligrams per liter.

Treatment Technigue (Action Levels: Copper 1.3 mg/L, lead 0.015 mg/L)
Values determined by USEPA.

Value classified as a Secondary Maximum Contaminant Level (SMCL).

U.S. Environmental Protection Agency.

Remedial Action Levels.

Maximum contaminant level.

Maximum contaminant level goals.

Polychlorinated biphenyls.

No standard available.

Proposed.

-------
TABLE 3 (Cont'd)

Tillett Gardens and
Art Center

VOCs:

None Selected

SVOCs:

Benzo(a)pyrene

TUTU WELLS SITE

SUMMARY OF CHEMICALS OF POTENTIAL CONCERN IN SITE MATRICES BY AREA OF CONCERN

SUBSURFACE SOIL

Fire Dept./Texaco Gas
Station/Antilles Auto
Parts/Ramsay Motor Co.

VOCs:

None Selected

SVOCs:

Benzo(a)pyrene

Curriculum Center
Building (Future)

VOCs:

None Selected

SVOCs:

None Selected

Esso Gas Station
and Splash and Dash
Car Wash

VOCs:

None Selected

SVOCs:

None Selected

GROUNDWATER

0'Henry Dry Cleaners
and Liquor Barn

VOCs:

None Selected

SVOCs:

None Selected

Site-Wide

VOCs:

Benzene
1,2 Dichloroethene (Total)
Tetrachloroethene
Toluene

Vinyl Chloride
SVOCs:

None Selected

Pesticides/PCBs:
Not Analyzed

Pesticides/PCBs:
None Selected

Pesticides/PCBs:	Pesticides/PCBs:

Not Analyzed	Not Analyzed

Pesticides/PCBs:
Not Analyzed

Pesticides/PCBs:
Not Analyzed

Inorganics:

Antimony

Arsenic

Beryllium

Manganese

Vanadium

Inorganics:

Antimony

Arsenic

Barium

Beryllium

Manganese

Vanadium

Inorganics:

Antimony

Arsenic

Beryllium

Manganese

Vanadium

Inorganics:

Antimony

Arsenic

Beryllium

Manganese

Vanadium

Inorganics:

Antimony
Arsenic
Manganese
Vanadium

Inorganics:

Antimony
Arsenic
Beryllium
Chromium VI
Manganese
Nickel
Vanadium

-------
TABLE 4

CHEMICALS OF POTENTIAL CONCERN FOR SITE SURFACE SOILS
TUTU WELLS SITE

CHEMICALS

Frequency of
Detection

Range of Detected Concentrations
Minimum	-	Maximum

VOCs (ug/kg)
Methylene Chloride
2-Butanone
Trichloroethylene
Benzene

4-Methyl-2-pentanone
Tetrachloroethylene
Toluene
Ethylbenzene
Xylenes(Total)

1/16
1/17
2/19
2/19
2/19
5/19
5/19
5/19
9/20

1.0	J

6.0	J

8.0	J

15

2.0	J

3.0	J

1.0	J

1.0 J
44.5 J
65 J
45 J
33 J
440000
1300
2100
5600

SVOCs(ug/kg)

Phenol	2/12

2-Methylphenol	1/12

4-Methylphenol	1/12

2,4-Dimethylphenol	1/12

Benzoic acid	1/7

Naphthalene	3/13

Acenaphthene	1/13

Fluorene	1/13

Di-n-butylphthalate	3/13

Fluoranthene	2/13

Pyrene	3/13

Chrysene	1/13
Bis(2-ethylhexyl)phthalate 1/13

Benzo(b)fluoranthene	2/13

Benzo(a)pyrene	2/13

Benzo(g,h,i)perylene	3/13

39 NJ

4100

52 J
100 J
76 J

84 J
270 J
82 J

000000
320000
1300000 J
42000 J
63 JN
7700 J
190 J
420 J
9400 J
740 J
2000

59 J
5400
870 J
770 J
430 J

Location of
Maximum

Range of Non Detect Concentrations
Minimum -	Maximum

MWS-16-AVD	0 UJ	-	14000 UB

SS-3-AVS	11 UJ	-	11000 U

SS-3-AVS	6.0 U	-	14000 U

eC-lOS	6.0 U	-	14000 U

eC-lOS	11 U	-	27000 U

e-01	6.0 U	-	880 U

eC-lOS	6.0 U	-	14000 UJ

eC-lOS	6.0 U	-	14000 UJ

eC-lOS	6.0 UJ -	14000 UJ

eL-02 01S

350

U

11000 UJ

eL-02 01S

350

U

11000 UJ

eL-02 01S

350

U

11000 UJ

eL-02 01S

350

U

11000 UJ

SS-6-AVS

1800

U -

380000 U

eL-02-01S

350

U

1300 UJ

eR-02-02S

350

U -

78000 U

eR-02-02S

350

U

78000 U

SS-3-AVS

34

J

78000 U

eR-02-02S

350

U

78000 U

eR-02-02S

350

U

78000 U

SS-5-AVS

350

U

78000 U

eR-02-02S

136

UBJ-

78000 U

eR-02-02S

350

U

78000 U

eR-02-02S

350

U

78000 U

eR-02-02S

350

U

78000 U

-------
TABIiE 4, Continued

CHEMICALS OF POTENTIAL CONCERN FOR SITE SURFACE SOILS
TUTU WELLS SITE

Frequency of	Range of Detected Concentrations

Detection	Minimum	-	Maximum

CHEMICALS

PESTICIDES/PCBs (ug/kg)







Endosulfan I

1/13

--

92

Aroclor-1242

1/13

—

120000 J

INORGANICS and CYANIDE

(mg/kg)





Aluminum

3/7

21100

27350

Antimony

1/7

—

5.9 BJ

Arsenic

2/7

2.1

13.7

Barium

3/7

33.9 B-

67.2

Cadmium

1/7

--

0.7 B

Chromium

3/7

23. 6

42.2 J

Cobalt

3/7

16.3

25.55 J

Copper

3/7

52

108.7

Iron

3/7

29400

38400

Lead

4/7

3.1

8 6.35 SJ

Manganese

3/7

834

872

Nickel

3/7

14.7

21.7

Sodium

2/7

319 B

470 B

Vanadium

3/7

83.1

119

Zinc

3/7

52.0

108

Cyanide, total

1/7

—

1.1

Location of
Maximum

Range of Non-Detect Concentrations
Minimum -	Maximum

eL-02-01S
eTT-15S

9 U
90 U

MWS-16-AVD
B-2
B-13A
B-2

MWS-16-AVD
MWS-16-AVD

MWS-16-AVD
MWS-16-AVD
B-2
SS-5-AVS
MWS-16-AVD
MWS-16-AVD
B-13A
B-2
B-2
B-2

21300
4.08 UBNJ
1.46 UBWJ
44.2 UB
0.48 U
19.93 UNJ
13.85 UJ
54.95 UJ
27725 J
11.3 J
699.5 UJ
11.5 UJ
273.25 UBJ
72.65 UNJ
95.75 UJ
0.53 U

1700 UJ
1100 UJ

26950
6.35 UBNJ
18.65 UJ
96.25 U
0.7 U
33.95 UNJ
22.75 UJ
79.65 UNJ
48800
19.95 J

886 U
18.15 U
488.50 UB
96.50 UNJ
318
0.64 U

-------
CHEMICALS OF POTENTIAL CONCERN FOR SITE SURFACE SOILS
TUTU WELLS SITE

EPA Data Qualifiers:

U - Analyte was analyzed for but not detected
J - Estimated value
B - For organic parameters:

Compound found in the associated blank as well as in the sample
For Inorganic parameters:

Reported value was obtained from a reading that was less than the Contract Reguired Detection Limit, but greater than or egual to the
Instrument Detection Limit
N - Presumptive evidence of a compound

S - The reported value was determined to by the Method of Standard Additions

W - Post digestion spike for Furnace AA analysis is out of control limits, while sample absorbance is less than 50% of spike absorbance
* Duplicate analysis not within control limits

-------
TABLE 5

TUTU WELLS SITE
POTENTIAL EXPOSURE PATHWAYS

Matrix
PRESENT-USE SCENARIOS:

Receptor
Population(s)

Surface Soil

Exposure
Route(s)

Retained for
Quantitative Analysis

Site Residents	Ingestion	Yes

(Adults and Children)	Dermal Contact*	Yes

(Tillett Gardens and Art Center) Inhalation of Particulates	No

Inhalation of VOCs	No

Site Workers
1- (Employees of the Fire Dept.,
Texaco gas station, Antilles
auto parts, and Ramsay motor
company)**

Ingestion	Yes

Dermal Contact*	Yes

Inhalation of Particulates	No

Inhalation of VOCs	No

2- Employees of the Curriculum Ingestion	Yes

Center Building) Dermal Contact*	Yes

Inhalation of Particulates	No hour)

Inhalation of VOCs	No

Justification

Site residents are expected to come into direct contact with
surface soil in the vicinity of their home and Tillett Gardens and
Art Center. The inhalation of particulates from surface soil is
assumed to be negligible, as the areas where samples were
collected either consist of hard packed soil or are covered by
vegetation. The inhalation of VOCs is also assumed to be
negligible, as no VOCs were selected as chemicals of potential
concern. The inhalation pathways were therefore not selected
for further evaluation.

Site workers may come into direct contact with surface soil
during the course of a normal work day (i.e., outdoor work, lunch
hour). The inhalation of particulates from surface soil is assumed
to be negligible, as the areas where samples were collected
consist of either hard packed soil or are covered to a large extent
by vegetation. The inhalation of VOCs is also assumed to be
negligible, as no VOCs were selected as chemicals of potential
concern. The inhalation pathways were therefore not selected
for further evaluation.

Site workers may come into direct contact with surface soil
during the course of a normal work day (i.e., outdoor work, lunch

The inhalation of particulates from surface soil is assumed
to be negligible, as the areas where samples were collected
consist of either hard packed soil or are converted to a large extent
by vegetation. The inhalation of VOCs is also assumed to be a
negligible, as no VOCs were selected as chemicals of potential
concern. The inhalation pathways were therefore not selected
for further evaluation.

-------
3- (Employees of the Esso gas
station and the Splash and
Dash car wash)

4- (Employees of 0'Henry dry
cleaners and Liquor Barn)

Ingestion	No

Dermal Contact*	No
Inhalation of Particulates No

Inhalation of VOCs	No

Ingestion	Yes

Dermal Contact*	Yes

Inhalation of Particulates	No

Inhalation of VOCs	Yes

Since the Esso gas station and Splash and Dash car wash
properties are completely paved, no surface soil is available for
contact. Therefore, no surface soil exposure can occur.

Site workers may come into direct contact with surface soil
during the course of a normal work day (i.e., outdoor work, lunch
during the course of a normal work day (i.e.,outdoor work, lunch
hour). The inhalation of particulates from surface soil is assumed
to be negligible, as the area where samples were collected
is covered to a large extent by dense vegetation. Since a VOC was
selected as a chemical of potential concern for this area, the
inhalation of VOCs pathway was retained for further evaluation

-------
TABLE 5

TUTU WELLS SITE
POTENTIAL EXPOSURE PATHWAYS

Matrix

Receptor
Population(s)

Exposure
Route(s)

PRESENT-USE SCENARIOS CONT'D:

Retained for
Quantitative Analysis

Surface Soil (Cont'd)

Construction Workers
(Site-Wide)

Ingestion	No

Dermal Contact **	No

Inhalation of Particulates	No

Inhalation of VOCs	No

Subsurface Soil

Site Residents
(Adult and Children)

Ingestion
Dermal Contact*

(Tillett Gardens and Art Center)

Inhalation of Particulates
Inhalation of VOCs

No
No
No
No

Site Workers
1- (Employees of the Fire Dept.,
Texaco gas station, Antilles
auto parts, and Ramsay motor
company)

2- (Employees of the Curriculum

Ingestion	No

Dermal Contact*	No

Inhalation of Particulates	No

Inhalation of VOCs	No

Center Building)

Ingestion	No

Dermal Contact*	No

Inhalation of Particulates	No

Inhalation of VOCs	No

3- (Employees of the Esso gas
station and the Splash and
Dash car wash)

4- (Employees of 0'Henry dry
cleaners and Liquor Barn)

Ingestion
Dermal Contact*
Inhalation of Particulates
Inhalation of VOCs

Ingestion
Dermal Contact*
Inhalation of Particulates
Inhalation of VOCs

No
No
No
No

No
No
No
No

Construction Workers
(Site-Wide)

Ingestion
Dermal Contact*
Inhalation of Particulates

No
No
No

Justification

No construction work is currently in progress in any areas of
concern at the site

No construction work (i.e., excavation activity) is currently in
progress in this area of the site.

No construction work (i.e., excavation activity) is currently in
progress in the area of the site

No construction work (i.e., excavation activity) is currently in
progress in this area of the site.

No construction work (i.e., excavation activity) is currently in
progress in this area of the site.

No construction work (i.e., excavation activity) is currently in
progress in this area of the site.

No construction work (i.e., excavation activity) is currently in
progress in any areas of concern at the site.

-------
TABLE 5
TUTU WELLS SITE
POTENTIAL EXPOSURE PATHWAYS

Receptor

Matrix	Population(s)

PRESENT-USE SCENARIOS CONT'D:

Exposure
Route(s)

Retained for
Quantitative Analysi

Groundwater

Site Residents
(Adults and Children)

Ingestion

Dermal Contact (Shower)
Inhalation of VOCs (Shower)

Yes
Yes
Yes

Site Workers
(All)

Ingestion	Yes

Dermal Contact (Shower)	No

Inhalation of VOCs (Shower)	No

Construction Workers
(Site-Wide)

Ingestion	No

Dermal Contact (Shower)	No

Inhalation of VOCs (Shower)	No

FUTURE-USE SCENARIOS:

Surface Soil

Residents
(Adults and Children)
Tillett Gardens and Art Center)

Ingestion
Dermal Contact*

Inhalation of Particulates
Inhalation of VOCs

Yes
Yes
Yes
No

Justification

Currently, an order against drinking and bathing in groundwater
at the site has been issued. However, since evidence of
pumping exists at the Ramsay well, residents may be using the
groundwater for these purposes in addition to secondary
purposes such as clothes washing, lawn watering, etc.

Currently, an order against drinking and bathing in groundwater
at the site has been issued. However, since evidence of
pumping exists at the Ramsay well, site workers may be using
the groundwater for drinking. Site workers are not expected to
shower on-site.

No construction work (i.e., excavation activity) is currently in
progress in any areas of concern at the site.

Site residents are expected to come into direct contact with
surface soil in the vicinity of their home and Tillett Gardens and
Art Center. The inhalation of particulates exposure route may be
of concern due to the potential for future construction work
(i.e., excavation activity) in this area. The inhalation of VOCs i
assumed to be negligible, as no VOCs were selected as chemicals
of potential concern. The inhalation of VOCs pathway was
therefore not selected for further evaluation.

-------
Site Workers

1- (Employees of the Fire Dept.,	Ingestion	Yes

Texaco gas station, Antilles	Dermal Contact*	Yes

auto parts, and Ramsay motor	Inhalation of Particulates	Yes

company)**	Inhalation of VOCs	No

Site workers may come into direct contact with surface soil
during the course of a normal work day (i.e., outdoor work, lunch
hour). The inhalation of particulates exposure route may be of
concern due to the potential for future construction work
(i.e., excavation activity) in this area. The inhalation of VOCs is
assumed to be negligible, as no VOCs were selected as chemicals
of potential concern. The inhalation of VOCs pathway was
therefore not selected for further evaluation.

-------
TABLE 5
TUTU WELLS SITE
POTENTIAL EXPOSURE PATHWAYS

Receptor Exposure	Retained for

Matrix Population(s) Route(s)	Quantitative Analysi
FUTURE-USE SCENARIOS CONT'D:

Surface Soil (Cont'd)

2- (Employees of the Curriculum Ingestion	Yes

Center Building) Dermal Contact*	Yes

Inhalation of Particulates	Yes

Inhalation of VOCs	No

3-	(Employees of the Esso gas Ingestion	No
station and the Splash and Dermal Contact*	No
Dash car wash) Inhalation of Particulates	No

Inhalation of VOCs	No

4-	(Employees of 0'Henry dry Ingestion	Yes
cleaners and Liguor Barn) Dermal Contact*	Yes

Inhalation of Particulates	Yes

Inhalation of VOCs	Yes

Construction Workers Ingestion	Yes

(Tillett Gardens and Art Center) Dermal Contact*	Yes

Inhalation of Particulates	Yes

Inhalation of VOCs	No

Justification

Site workers may come into direct contact with surface soil
during the course of a normal work day (i.e., outdoor work, lunch
hour). The inhalation of particulates exposure route may be of
concern due to the potential for future construction work
(i.e., excavation activity) in this area. The inhalation of VOCs is
assumed to be negligible, as no VOCs were selected as chemicals
of potential concern. The inhalation of VOCs pathway was
therefore not selected for further evaluation.

Since the Esso gas station and Splash and Dash car wash
properties are completely paved, no surface soil would be
available for contact. Therefore, no surface soil exposure can
occur.

Site workers may come into direct contact with surface soil
during the course of a normal work day (i.e., outdoor work, lunch
hour). The inhalation of particulates exposure route may be of
concern due to the potential for future construction work
(i.e., excavation activity) in this area. Since a VOC was selected as
a chemical of potential concern for this area, the inhalation of VOCs
pathway was retained for further evaluation.

The potential exists for further commercial or residential
development of the Tillett Gardens and Art Center area of concern.
Construction workers would be expected to routinely contact
surface soil during excavation activities. The inhalation of
particulates exposure route may also be of concern as a result of
this activity. The inhalation of VOCs is assumed to be
negligible as no VOCs were selected as chemicals of potential
concern. The inhalation of VOCs pathway was therefore not
selected for further evaluation.

-------
Subsurface Soil

Residents Ingestion	No

(Adults and Children) Dermal Contact*	Yes

(Tillett Gardens and Art Center) Inhalation of Particulates	Yes

Inhalation of VOCs	No

During potential future construction work (i.e., excavation
activity), residents may come into direct contact with exposed
subsurface soil. However, they are assumed to ingest a
negligible amount of excavated subsurface soil. The inhalation of
VOCs is also assumed to be negligible, as no VOCs were selected
as chemicals of potential concern. The inhalation of VOCs pathway
was therefore not selected for further evaluation.

-------
TABLE 5
TUTU WELLS SITE
POTENTIAL EXPOSURE PATHWAYS

Receptor	Exposure	Retained for

Matrix Population(s)	Route(s)	Quantitative Analysi

FUTURE-USE SCENARIOS CONT'D:

Subsurface Soil (Cont'd)

Site Workers	Ingestion	No

1- (Employees of the Fire Dept.,	Dermal Contact*	Yes

Texaco gas station, Antilles	Inhalation of Particulates	Yes

auto parts, and Ramsay motor	Inhalation of VOCs	No
company)

2- (Employees of the Curriculum	Ingestion	No

Center Building)	Dermal Contact*	Yes

Inhalation of Particulates	Yes

Inhalation of VOCs	No

3- (Employees of the Esso gas	Ingestion	No

station and the Splash and Dermal Contact*	Yes

Dash car wash)	Inhalation of Particulates	Yes

Inhalation of VOCs	No

4- (Employees of 0'Henry dry Ingestion	No

cleaners and Liguor Barn) Dermal Contact*	Yes

Inhalation of Particulates	Yes

Inhalation of VOCs	No

Justification

During potential future construction work (i.e., excavation
activity), site workers may come into direct contact with exposed
subsurface soil. However, they are assumed to ingest a
negligible amount of excavated subsurface soil. The inhalation of
VOCs is also assumed to be negligible, as no VOCs were selected
as chemicals of potential concern. The inhalation of VOCs pathway
was therefore not selected for further evaluation.

During potential future construction work (i.e., excavation
activity), site workers may come into direct contact with exposed
subsurface soil. However, they are assumed to ingest a
negligible amount of excavated subsurface soil. The inhalation of
VOCs is also assumed to be negligible, as no VOCs were selected
as chemicals of potential concern. The inhalation of VOCs pathway
was therefore not selected for further evaluation.

During potential future construction work (i.e., excavation
activity), site workers may come into direct contact with exposed
subsurface soil. However, they are assumed to ingest a
negligible amount of excavated subsurface soil. The inhalation of
of VOCs is also assumed to be negligible, as no VOCs were selected
as chemicals of potential concern. The inhalation of VOCs pathway
was therefore not selected for further evaluation.

During potential future construction work (i.e., excavation
activity), site workers may come into direct contact with exposed
subsurface soil. However, they are assumed to ingest a
negligible amount of excavated subsurface soil. The inhalation of
VOCs is also assumed to be negligible, as no VOCs were selected
as chemicals of potential concern. The inhalation of VOCs pathway
was therefore not selected for further evaluation.

-------
Construction Workers Ingestion	Yes

(Tillett Gardens and Art Center) Dermal Contact*	Yes

Inhalation of Particulates	Yes

Inhalation of VOCs	No

The potential exists for further commercial or residential
development of the Tillett Gardens and Art Center area of concern.
Construction workers would be expected to routinely contact
subsurface soil during excavation activities. The inhalation of
particulates exposure route may also be of concern as a result of
this activity. The inhalation of VOCs is assumed to be
negligible, as no VOCs were selected as chemicals of potential
concern. The inhalation of VOCs pathway was therefore not
selected for further evaluation.

-------
TABLE 5
TUTU WELLS SITE
POTENTIAL EXPOSURE PATHWAYS

Receptor

Matrix	Population(s)

FUTURE-USE SCENARIOS CONT'D:

Exposure
Route(s)

Retained for
Quantitative Analysis

Justification

Groundwater

Site Residents
(Adults and Children)

Ingestion
Dermal Contact (Shower)
Inhalation of VOCs (Shower)

Yes
Yes
Yes

Currently, an order against drinking and bathing in groundwater
at the site has been issued. However, since evidence of pump-
ing exists at the Ramsay well, residents may continue to use
the groundwater in the future for these purposes in addition to
secondary purposes such as clothes washing, lawn watering.

Site Workers
(All)

Ingestion
Dermal Contact (Shower)
Inhalation of VOCs (Shower)

Yes
No
No

Currently, an order against drinking and bathing in groundwater at
the site has been issued. However, since evidence of pumping
exists at the Ramsay well, site workers may continue to use the
groundwater in the future for drinking. Site workers are not
expected to shower on-site.

Construction Workers

Ingestion	Yes

Dermal Contact (Shower)	No

Inhalation of VOCs (Shower)	No

Currently, an order against drinking and bathing in groundwater
at the site has been issued. However, since evidence of pump-
ing exists at the Ramsay well, construction workers may continue
to use the groundwater in the future for drinking. Construction
workers are not expected to shower on-site.

* The dermal contact pathway can only be guantitatively evaluated for PCBs and cadmium as only these chemicals have established dermal absorption factors (PCBs = 6% and cadmium = 1%).
All other chemicals will be gualitatively discussed.

**It should be noted that present and potential future site workers at the Fire Department and Texaco gas station were not considered receptors for surface soil since no surface soil
samples were collected at the Fire Department, and the Texaco gas station is completely paved (all soil samples would be subsurface). However, all individual areas in the area of
concern are listed to be consistent with those listed for the subsurface soil area of concern.

-------
TABLE 6
TUTU WELLS SITE

CHRONIC TOXICITY VALUES FOR POTENTIAL NONCARCINOGENIC HEALTH EFFECTS
DOSE-RESPONSE RELATIONSHIP (1)

NONCARCINOGENS:

REFERENCE DOSES (RfD)

Oral RfD	Uncertainty	Inhalation RfD	Uncertainty

CHEMICALS	(mg/kg-day)	Factor	(mg/kg-day)	Factor

Inorganics

Manganese (water)

5

0E-03



1

1.4E-05

1000

Mercury

3

0E-04

(2)

1000

8.6E-05 (2)

30

Nickel (sol. salt)

2

0E-02



300

-

-

Selenium

5

0E-03



3

-

-

Silver

5

0E-03



3

-

-

Thallium (chloride)

8

0E-05



3000

-

-

Vanadium

7

0E-03

(2)

100

-

-

Zinc (and compounds)

3

0E-01



3

-

-

NOTES:

- Calcium, iron, magnesium, potassium, and sodium are considered essential nutrients and will not be guantitatively evaluated in the risk assessment
* The current drinking water standard for copper is 1.3 mg/1. The DWCD (1987) concluded that toxicity data are inadeguate for calculation of a reference dose for this chemical

(1)	All toxicity values obtained from IRIS (on-line June 22 and 30, 1994, July 1, 1994, August 4,1994,and December 6, 1994) unless otherwise noted.

(2)	Toxicity values obtained from HEAST Annual FY-1994.

(3)	Toxicity values obtained from HEAST Annual FY-1994: Toxicity values are found in USEPA documents but were calculated by alternative methods not currently practiced by the RfD

Work Group.

(4)	Toxicity values were originally obtained from the Superfund Health Risk Technical Support Center, September 27,1993. Those values were confirmed by the USEPA Risk Assessment
Specialist.

(5)	The endosulfan toxicity values are reported, as none are available for the endosulfan I Isomer.

USEPA WEIGHT-OF-EVIDENCE:

A - Human Carcinogen.

B1 - Probable Human Carcinogen. Limited human data are available.

B2 - Probable Human Carcinogen. Sufficient evidence of carcinogenicity in animals and inadeguate or no evidence in humans.
C - Possible Human Carcinogen.

D - Not Classifiable as to human carcinogenicity.

E - Evidence of noncarcinogenicity for humans.

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TABLE 7
TUTU WELLS SITE
TOXICITY VALUES FOR POTENTIAL CARCINOGENIC HEALTH EFFECTS
DOSE - RESPONSE RELATIONSHIP (1)

CARCINOGENS:
SLOPE FACTORS (SF)

CHEMICALS

Oral SF
(Mg/kg day)-1

Inhalation SF
(mg/kg day)-1

Weight-of-
Evidence

Volatile Organics

Acetone

Benzene	2.9E- 02

Bromodichloromethane	6.2E- 02

Bromoform	7.9E- 03

Bromomethane
2-Butanone
Carbon Disulfide
Chlorobenzene

Chloroform	6.1E-03

Chloromethane	1.3E-02 (2)

Dibromochloromethane	8.4E-02

1.1-Dichloroethane

1.2-Dichloroethane	9.1E-02

1.1-Dichloroethane	6.0E-01
cis 1,2-Dichloroethane

1.2-Dichloroethene	(Total)

Ethylbenzene
2-Hexanone

Methyl-tert-Butyl-Ether
4-Methyl-2-Pentanone

Methylene Chloride	7.5E-03

n-Propylbenzene

Tetrachloroethene	5.2E-02 (3)

Toluene

1.1.1-Trichloroethane

1.1.2-Trichloroethane	5.7E-02

2.9E-02
3.9E-03

8.1E-02
0.3E-03 (2)

9.1E-02
1.8E-01

1.6E-03
2.0E-03 (3)

5.6E-02

D

A

B2

B2

D

D

D

B2

C

C

C

B2

C

D

B2

C-B2
D
D
C

Trichloroethene
Vinyl Chloride
Xylenes (Total)

1.1E-02 (3)
1.0E-00 (2)

6.0E-03 (3)
3.0E-01 (2)

B2

A

D

-------
Semivolatile Organics

Acenaphthene -	-	-

Acenaphthylene -	-	D

Anthracene -	-	D

Benzoic Acid -	-	D

Benzoic Acid -	-	B2

Benzo(a)anthracene	7.3E-01*	-	B2

Benzo(a)pyrene	7.3E+01	-	B2

Benzo(b)fluoranthene	7.3E-00*	-	B2

Benzo(b)fluoranthene	7.3E-01	-	B2

Benzo(g,h,i)perylene -	-	D

Benzo(k)fluoranthene	7.3E-02*	-	B2

Bis (2-chloroethyl)ether 1.1E+00 1.1E+00	B2

Bis(2-ethylhexyl)phthalate 1.4E-02	-	B2

Butylbenzylphthalate -	-	C

-------
TABLE 7
TUTU WELLS SITE
TOXICITY VALUES FOR POTENTIAL CARCINOGENIC HEALTH EFFECTS
DOSE - RESPONSE RELATIONSHIP (1)

CARCINOGENS:
SLOPE FACTORS (SF)

CHEMICALS	Oral SF	Inhalation SF	Weight-of-

(mg/kg-day) -1	(mg/kg-day)-1	Evidence

Semivolatile Organics (Cont'd)

Carbazole 2.0E-02 (2)	-	B2

Chrysene 7.3E-03*	-	B2

Di-n-butylphthalate -	-	D

Di-n-octylphthalate -	-	-

Dibenzofuran -	-	D

1,2-Dichlorobenzene -	-	D

1,4-Dichlorobenzene 2.4E-02 (2)	-	B2

Diethylphthalate -	-	D

2,4-Dimethylphenol -	-	-

Dimethylphthalate -	-	D

Fluoranthene -	-	D

Fluorene -	-	D

Indeno(1,2,3,-cd)pyrene 7.3E-01*	-	B2

2-Methylnaphthalene -	-	-

2-Methylphenol -	-	C

4-Methylphenol -	-	C

Naphthalene -	-	D

2-Nitrophenol -	-	-

Phenanthrene -	-	D

Phenol -	-	D

Phthalic Anhydride (IIC) -	-	-

Pyrene -	-	D

1,2,4-Trichlorobenzene -	-	D
Pesticides PCBs

Chlordane 1.3E+00	1.3E+00	B2
Endosulfan (4) -

PCBs (Aroclors) 7.7E+00	-	B2
Inorganics

Aluminum -	-	-

Antimony -	-	-

Arsenic 1.75E+00	1.5E+01	A

Barium -	-	-

Beryllium 4.3E+00	8.4E+00	B2

Cadmium -	6.3E+00	B1
Chromium III

Chromium VI -	4.2E+01	A

Cobalt -	-	-

Copper ** -	-	D

Cyanide -	-	D

Lead (and compounds-Inorg.) -	-	B2

Manganese (water) -	-	D

-------
TABLE 7

TUTU WELLS SITE

TOXICITY VALUES FOR POTENTIAL CARCINOGENIC HEALTH EFFECTS
DOSE - RESPONSE RELATIONSHIP (1)

CHEMICALS

CARCINOGENS:
SLOPE FACTORS (SF

Oral SF
(mg/kg-day) -1

Inhalation SF
(mg/kg-day)-1

Weight-of-
Evidence

Inorganics (Cont'd)

Mercury

Nickel (sol. salt)

Selenium

Silver

Thallium(chloride)
Vanadium
Zinc (and compounds)-

D

D
D
D

D

NOTES:

-Calcium, iron, magnesium, potassium, and sodium are considered essential nutrients and will not be
gualitatively evaluated in the risk assessment.

*Relative Potency Values were used in conjunction with slope factors per USEPA Provisional Guidance
in Quantitative Risk Assessment of Polycyclic Aromatic Hydrocarbons (July 1993).

**The current drinking water standard for copper is 1.3 mg/1. The DWCD (1987) concluded that
toxicity data are inadeguate for calculation of a reference dose for this chemical.

(1)	All toxicity values obtained from IRIS (on-line June 22 and 30, 1994, July 1, 1994, August 4,
1994, and December 6, 1994) unless otherwise noted.

(2)	Toxicity values obtained from HEAST Annual FY-1994.

(3)	Toxicity values were originally obtained from the Superfund Health Risk Technical Support
Center, September 27, 1993. these values were confirmed by the USEPA Risk Assessment
Specialist.

(4)	The endosulfan toxicity values are reported, as none are available for the endosulfan I Isomer.
USEPA WEIGHT-OF-EVIDENCE:

A - Human Carcinogen.

B1 - Probable Human Carcinogen. Limited human data are available.

B2 - Probable Human Carcinogen. Sufficient evidence of carcinogencity in animals and inadeguate

or no evidence in humans.

C - Possible Human Carcinogen.

D - Not classifiable as to human carcinogenicity.

E - Evidence of noncarcinogenicity for humans.

-------
TABLE 8
TUTU WEIiLS SITE

COMBINING NONCARCINOGENIC HAZARD INDEX VALUES ACROSS PATHWAYS

MEDIA

RECEPTOR
POPULATION

EXPOSURE
ROUTE

INDIVIDUAL
HAZARD INDEX

SURFACE SOIL

Tillett Gardens and Art Center Residents:
Area	Adults

Ingestion
Dermal Contact
Inhalation of Particulates
Total Hazard Index=

3.2E-01
NA

6.7E-01
9.9E-01

Children (0-6 years)

Ingestion
Dermal Contact
Inhalation of Particulates
Total Hazard Index =

3.0E+00
NA

3.1E+00
6.1E+00

Fire Dept./Texaco gas station/ Site Workers
Antilles auto parts/Ramsay motor (Employees)
co. Area

Ingestion
Dermal Contact
Inhalation of Particulates
Total Hazard Index=

9.7E-02
NA

2.0E-01
3.0E-01

Curriculum Center Building
Area (Present-Use)

Site Workers
(Employees)

Ingestion
Dermal Contact
Total Hazard Index=

2.5E-01
NA

2.5E-01

Curriculum Center Building Site Workers
Area (Future-Use)	(Employees)

Ingestion
Dermal Contact
Inhalation of Particulates
Total Hazard Index=

2.3E-01
NA

2.1E-01
4.4E-01

0'Henry dry cleaners and Site Workers
Liguor Barn Area	(Employees)

Ingestion
Dermal Contact
Inhalation of Particulates
Inhalation of VOCs
Total Hazard Index=

1.5E-01
NA

2.1E-01
NA

3. 6E-01

Tillett Gardens and Art Center Construction
Area (Future-Use)	Workers

Ingestion
Dermal Contact
Inhalation of Particulates
Total Hazard Index =

9.9E-01
NA

2.4E-02
1.0E+00

CHEMICALS CONTRIBUTING THE GREATEST
AMOUNT TO HAZARD INDEX VALUES

Manganese

Manganese
Manganese

-------
TABLE 8
TUTU WELLS SITE
COMBINING CARCINOGENIC RISKS ACROSS PATHWAYS

MEDIA

SURFACE SOIL

RECEPTOR
POPULATION

EXPOSURE
ROUTE

INDIVIDUAL
CANCER RISK

Tillett Gardens and Art Center Residents:
Area	Adults

Children (0-6 years)

Ingestion
Dermal Contact
Inhalation of Particulates
Total Carcinogenic Risk=

Ingestion
Dermal Contact
Inhalation of Particulates
Total Carcinogenic Risk=

Fire Dept/Texaco gas station/	Site Workers Ingestion

Antilles auto parts/Ramsay (Employees) Dermal Contact

motor co. Area

Curriculum Center Building Site Workers
Area (Present-Use)	(Employees)

Curriculum Center Building Site Workers
Area (Future-Use)	(Employees)

Inhalation of Particulates
Total Carcinogenic Risk=

Ingestion

Dermal Contact

Total Carcinogenic Risk=

Ingestion
Dermal Contact
Inhalation of Particulates
Total Carcinogenic Risk=

0.2E-06
NA

5.5E-07
8.8E-06

1.9E-05
NA
6.4E-07
2.0E-05

1.3E-06
NA
1.3E-06
1.3E-06

3.7E-06
NA
3.7E-06

9.1E-07
NA

4.5E-00
9.6E-07

CHEMICALS CONTRIBUTING THE GREATEST
AMOUNT TO RISK

Arsenic

Arsenic
Arsenic

Arsenic

-------
0'Henry dry cleaners and
Liquor Barn Area

Site Workers
(Employees)

Tillett Gardens and Art Center Construction
Area(Future-Use)	Workers

Ingestion	9.7E-0G

Dermal Contact	NA

Inhalation of Particulates	3.4E-07

Inhalation of VOCs	4.9E- 07

Total Carcinogenic Risk=	1. IE- 05

Ingestion	5.7E-05

Dermal Contact	4.3E-05

Inhalation of Particulates	6.6E-09
Total Carcinogenic Risk= 1.0E-04

-------
TABLE 10

SUMMARY OF HAZARD INDICES
TUTU WEIiLS SITE

CHEMICAL

HAZARD INDEX

Anole (lizard)

Red-Tailed Hawk

VOLATILE ORGASTICS

Benzene
2-Butanone
Ethylbenzene
Methylene Chloride

1.24 E-05
6.44 E-05
3.96 E-03
4.34 E-05

2.42	E-06
1.26 E-04

7.72	E-04

8.47	E-06

4-Methyl-2-pentanone
Tetrachloroethylene
Trichloroethylene
Toluene

Xylenes (Total)

2.64 E-03

8.04
1.09 E-04
1.49 E-03
1.66 E-02

5.16 E-05
1.57

2.14 E-05
2.91 E-04
3.26 E-03

SEMI-VOLATILE ORGASTICS

Acenaphthene	NE

Benzo(b)fluoranthene	NE

Benzoic Acid	4.13 E-03

Benzo(g, h,i)perylene	NE

Benzo(a)pyrene	6.57 E-03
Bis(2-ethylhexyl)phthalate 1.06 E-03

Chrysene	NE

Di-n-butylphthalate	1.93 E-02

2, 4-Dimethylphenol	0.12

Fluoranthene	0.151

Fluorene	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

-------
TABLE 10

SUMMARY OF HAZARD INDICES
TUTU WELLS SITE
CONTINUED

CHEMICAL

HAZARD INDEX
Anole (lizard)

Red-Tailed Hawk

SEMI-VOLATILES (Cont'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

NE
NE
80.8
NE

3.45 E-03

Chromium trivalent (Cr+3) 9.2 E-03

NE
NE

0.334
NE

1.57 E-04
1.45 E-03

Chromium,	hexavalent 1.69
(Cr+6)

Cobalt	NE

Copper	NE

0.133

NE
NE

-------
TABLE 10

SUMMARY OF HAZARD INDICES
TUTU WELLS SITE
CONTINUED

CHEMICAL	HAZARD INDEX

Anole (lizard)	Red-Tailed Hawk

INORGANICS AND CYANIDE	(Cont'd)

Iron NE	NE

Lead 4.42	0.864

Manganese 1.24	0.242

Nickel 1.98	0.222

Sodium NE	NE

Vanadium NE	NE

Zinc NE	NE

Cyanide 1.31 E-03	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.

-------
Table 11. Groundwater Chemical-Specific Remedial Action Levels Identified for the
Tutu Wells Site, St. Thomas, U.S. Virgin Islands.

Groundwater RALs

Parameters

Inorganics

Aluminum
Antimony

US EPA
MCLs
(mg/L)

0.05 to 0.20 (1)
0.006

MCLGs
(mg/L)

0.006

Arsenic

Barium

Beryllium

Cadmium

Calcium

Chromium
Cobalt
Copper
Iron
Lead

Magnesium

Manganese

Mercury

Nickel

Potassium

Selenium

Silver

Sodium

Thallium

0.05
2.0
0.004
0.005

0.1

TT

0.3 (1)
TT

0.05
0.002
0.1

0.05
0.1

0.002

2.0
0

0.005
0.1
1.3
0

0.002
0.1

0.05
0.0005

Vanadium

Zinc

Cyanide

Nitrate (as N)

Chloride
pH (units)

Total dissolved solids

Volatile Organic Compounds

Chioromethane
Bromomethane
Vinyl chloride
Chloroethane
Methylene chloride
Acetone

5.0
0.2

10.0
250 (1
6.5-8.
500 (1)

0.002
0.005

0.2
10.0

See last page for footnotes.

-------
Table 12. 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

4

0'Henry Dry Cleaners

Other properties (1)

0 -	4.0

0 -	15.0

0 -	1.6

7 -	22.0

0 -	4.0

0 -	15.0

320
32

375

31

320

32

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 (CDM Federal Programs Corporation 1995b).

ft bis Feet below land surface.

VOCs Volatile organic compounds.

BTEX	Benzene, toluene, ethylbenzene, and xylenes.

ppb	Parts per billion, eguivalent to micrograms per kilogram (ug/kg).

No values provided.

(1)	The U.S. Environmental Protection Agency (USEPA) directed the use of soil screening

levels for the Esso Tutu Service Station at all other properties.

-------
Table 12. 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

0'Henry Dry Cleaners	0.0 - 1.6	375

1.7 - 22.0	31

Other properties (1)	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 (CDM Federal Programs Corporation 1995b).

ft bis Feet below land surface.

VOCs	Volatile organic compounds.

BTEX Benzene, toluene, ethylbenzene, and xylenes.

ppb	Parts per billion, eguivalent to micrograms per kilogram (ug/kg).

No values provided.

(1)	The U.S. Environmental Protection Agency (USEPA) directed the use of soil screening levels

for the Esso Tutu Service Station at all other properties.

-------
APPENDIX III

ADMINISTRATIVE RECORD INDEX

07/09/96	Index Chronological Order

TUTU WELLS SITE Documents

Document Number: TUT-0006-0213 to 0231	Parent: TUT-006-0212	Date: / /

Title: Sampling Trip Report, Tutu Wellfield Site, July 22-30, 1992

Type: REPORT
Category: 3.4.0.0.0 RI Reports

Author: none: CDM 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, O'Henry Dry Cleaners Soil Remediation

Type: GRAPHIC
Category: 3.4.0.0.0 RI Reports
Author: none: none
Recipient: none: none

Document Number: TUT- 006-0472 To 0472	Parent: TUT-006-0468	Date: / /

Title: Figure 1: Soil Excavation and Storage Locations, O'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

Parent: TUT-006-0468

Date: / /

Title: Visual Classification of Soils

Type:	OTHER
Category: 3.4.0.0.0 RI Reports
Author: none: IT Corporation
Recipient: none: none

Document Number: TUT-006-0502 To 0502	Parent: TUT-006-0497	Date: / /

Title: Summary of Soil Cleanup Goals/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 1041(e) Letter Response Samples, Tutu-Ramsay Site (ug/kg)
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-006-1010 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: TUT-006-1028	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 & Miller
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

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 Wells 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 Wells 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
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-006-1090 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: Geraghty & 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-006-1141 To 1142	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

-------
Document Number: TUT-006-1146 To 1213

Parent: TUT-006-1134

Date: / /

Title: Appendix A: Soil Gas Chromatagraphs

Type:	DATA

Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Forms
Author: none: Geraghty & Miller
Recipient: none: none

Document Number: TUT-006-1222 To 1222	Parent: TUT-006-1221	Date: / /

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

Document Number: TUT-008-0589 To 0592	Parent: TUT-008-0588	Date: / /

Title: Tutu Water Wells Contamination Litigation Counsel List
Type:

Category: 7.8.0.0.0 Enforcement Correspondence
Author: none: none
Recipient: none: none

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

Document Number: TUT-004-2306 To 2309	Parent: TUT-004-2305	Date: 01/01/01

Title: Responses to EPA Comments on the Draft Work Plan for Evaluation and Interim Remediation of
Soils, O'Henry Laundry, Tutu, St. Thomas, USVI

Type:	REPORT
Category: 3.3.0.0.0 Work Plan
Author: none: IT Corporation
Recipient: none: US EPA

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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 Wellfield, 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-0060612	Date: 01/01/01

Title: Attachment 1: Detailed Comments 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: Summary Report of Tank Closure and Subseguent Investigations Behind Western
Auto

Type:	REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: ENSR
Recipient: none: none

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 Geraghty & 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

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Document Number: TUT-006-1917 To 1917

Date: 01/01/01

Title: (Memorandum regarding Full Validation on Seven Groundwater 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 Number: TUT-006-2135 To 2140	Parent: TUT-006-2133

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)

Date: 01/01/01

Recipient: none: none

Document Number: TUT-006-2157 To 2158

Parent: TUT-006-2148

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: 4.3.0.0.0 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, Quality 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

Title: Order in the Matter of Tutu Waters, St. Thomas, U.S.V.I.

Date: 07/31/87

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

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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.

Document Number: TUT-003-0750 To 0751	Date: 08/07/87

Title: Order In the Matter of The Plaza Associates, St. Thomas, U.S.V.I.

Type: LEGAL DOCUMENT
Category: 7.3.0.0.0 Administrative Orders

Author: Canegata, David D.: 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-003-0846 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: Belgodere & Associates
Recipient: none: none

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Document Number: TUT-003-0986 To 1012

Parent: TUT-003-0985

Date: 10/14/87

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.

Recipient:	TUT-003-1058

Document Number: TUT-003-1058 To 1245	Parent: TUT-0031013	Date: 12/18/87

Title: Final Report on Results of Soil Gas Survey, Tutu, St. Thomas, U.S. Virgin Islands, Supplement

Type:	REPORT

Category:	7.8.0.0.0 Enforcement Correspondence

Author:	none: Geoscience Consultants, LTD.

Recipient:	none: Texaco-Caribbean, Inc.

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Document 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 Wells 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 D.: US EPA

Document Number: TUT-003-0756 To 0757	Date: 01/06/88

Title: Order in the Matter of ESSO Standard Oil (SA) , Ltd. Gottlieb's Quickway 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

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

Date: 01/11/88

Document Number: TUT-003-1684 To 1994

Title: (104e Reguest for Information Letter)

Type:	CORRESPONDENCE

Category:	7.7.0.0.0 Notice Letters and Responses

Author:	Dagget, 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 response to Reguest 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

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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	Date: 03/01/88

Title: Site Analysis, Tutu Wellfield, St. Thomas, Virgin Islands
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

Document Number: TUT-004-0034 To 0037	Date: 03/02/88

Title: (Letter on behalf of Jim Tillet in response to 01/11/88 Reguest for information)

Type:	CORRESPONDENCE

Category:	7.7.0.0.0 Notice Letters and Responses

Author:	Junkin, Timothy D.: attorney

Recipient:	Kwan, 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 Reguest 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 Reguest For Information Letter)

Type:	CORRESPONDENCE

Category:	7.7.0.0.0 Notice Letters and Responses

Author:	Kwan, Caroline: US EPA

Recipient:	Consolidated Auto: Potentially Responsible Party (PRP)

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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)

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:	Kwan, 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.

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Document Number: TUT-002-0688 To 0692

Date: 08/22/88

Title: Action Memorandum - Request for 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

Document Number: TUT-003-0758 To 0762	Date: 02/23/89

Title: (Order in) The Matter 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, Gassett 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

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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
Author: Mayo, Joseph: NUS Corporation
Trube, Diane: NUS Corporation
Recipient: none: US EPA

Document Number: TUT-002-0059 To 0214

Title: Final Draft Preliminary Assessment, Laga
St. Thomas, U.S. Virgin Islands

(PA) Report

Date: 03/24/89

Building/Virgin Islands, Department of Education,

Type: PLAN

Category: 1.3.0.0.0 Preliminary Assessment (PA) Report
Author: Trube, Diane: NUS Corporation
Recipient: 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

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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 D.: US EPA
Recipient: Barbel, Leo T.: L'Henri, Inc.

President: ESSO Standard Oil Co. S. A. Ltd.

President: Texaco-Caribbean, Inc.

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: Kwan, Caroline: US EPA

Document Number: TUT-007-1205 To 1205	Date: 08/17/89

Title: (Letter regarding Tutu Wells 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, Rodolfo: 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

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Document Number: TUT-002-0059 To 0214

Date: 03/24/89

Title: 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
Condition: DRAFT

Author: Trube, Diane: NUS Corporation
Recipient: 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-007-1209 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 D.: US EPA
Recipient: Barbel, Leo T.: L'Henri, Inc.

President: ESSO Standard Oil Co. S. A. Ltd.

President: Texaco-Caribbean, Inc.

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: Kwan, Caroline: US EPA

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Document Number: TUT-007-1205 To 1205

Date: 08/17/89

Title: (Letter regarding Tutu Wells 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, Rodolfo: Weston Spill Prevention & Emergency Response Div (SPER)
Manfreda, 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

Type:	CORRESPONDENCE

Category:	7.8.0.0.0 Enforcement Correspondence

Author:	Chester, Amy: Assistant Regional Counsel, EPA

Recipient:	Torres, Francis: Goldman & Antonetti

Document Number: TUT-003-2495 To 2496	Date: 10/13/89

Title: (Letter on behalf of Esso Standard Oil Company S.A. Limited, in response to 06/30/89 Reguest
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 D.: US EPA

Document Number: TUT-003-2493 To 2494	Date: 11/0189

Title: (Letter on behalf of L'Henry Inc., in response to 6/30/89 Reguest for Information)

Type:	CORRESPONDENCE
Category: 7.7.0.0.0 Notice Letters and Responses
Author: D' Anna, Nancy: attorney
Recipient: Luftig, Stephen D.: USEPA

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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. , Esg. : Assistant Regional Counsel, EPA

Recipient: Cepeda-Rodriguez, J., Esg: Goldman Antonetti Ferraiouli Axtmater & Hertell
D' Anna, Nancy, Esg.: attorney
Hodge Tankenson, Maria: attorney
Mittelholzer, George E.: Texaco

Ramos, Anna Gloria: ESSO Standard Oil Co. S. A. Ltd.

Torres, Francis, Esg: Goldman Antonetti Ferraiouli Axtmater & Hertell

Document Number: TUT-007-1196 To 1201	Date:

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, Esg.: attorney

Recipient:	Chester, Amy, Esg.: Assistant Regional Counsel, EPA

Document 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 0'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: Muszynski, William J.: US EPA
Recipient: various: various

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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, Esg.: attorney
Recipient: Chester, Amy.: Assistant Regional Counsel, EPA

Document Number: TUT-003-1252 To 1371	Date: 05/21/90

Title: (Tutu Wells Site Administrative Orders Nos. IL-CERCLA-00401 and RCRA-90-UST-9003-0401 Monthly
Progress Reports for May 1990, to March 1992, to September 1992, and November 1992)

Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence

Author: Ramos, Ana Gloria: Tutu Environmental Investigation Committee

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 comments regarding the
proposed Administrative Order on Consent)

Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence

Author: Fernandez-Torres, Francis: Goldman Antonetti Ferraiouli Axtmater & 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

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Document Number: TUT-005-0352 To 0358

Date: 04/04/91

Title: (Letter with attached comments 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 Committee

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 Reguest for Information)

Type:	CORRESPONDENCE

Category:	7.7.0.0.0 Notice Letters and Response

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 with TEIC and its consultants regarding the RI/FS
workplan.

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 Work Plan)

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-003-2476 To 2479	Date: 05/09/91

Title: (Letter on behalf of Esso Tutu Service Station forwarding attached documents in response to
Reguest for Information)

Type:	CORRESPONDENCE

Category:	7.7.0.0.0 Notice Letters Responses

Author:	Ramos, Ann Gloria: ESSO Standard Oil Co. S. A. Ltd.

Recipient:	Chester, Amy: US EPA

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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 & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: none: Tutu Environmental Investigation Committee

Document Number: TUT-001-0001 To 2053	Date: 08/28/91

Title: Final Draft Hazard Ranking System Documentation, Tutu Wellfield, 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--693 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 & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: none: Tutu Environmental Investigation Committee

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: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: none: Tutu Environmental Investigation Committee

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 & Miller
Recipient: none: Tutu Environmental Investigation Committee

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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: Kwan, 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: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Kwan, Caroline: US EPA

Document Number: TUT-006-1899 To 1902	Date: 09/19/91

Title: (Memorandum regarding Tutu Wells 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: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Francis, Leo: Department of Public Works

Document Number: TUT-006-1891 To 1892	Date: 09/27/91

Title: (Memorandum regarding Tutu wells 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

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Document Number: TUT-006-1890 To 1890

Date: 10/18/91

Title: (Letter regarding Approval of the Tutu Services Investigation Workplan, 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

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

Author: Danahy, Thomas V.: Geraghty & Miller
Moffatt, Clinton: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Kwan, Caroline: US EPA

Document Number: TUT-006-1888 To 1888	Date: 11/19/91

Title: (Letter regarding Approval of the Tutu Services 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 Committee

Document Number: TUT-006-1887 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 & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Kwan, Caroline: US EPA

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Document Number: TUT-002-2408 to 2467

Date: 01/16/92

Title: Fourth Sampling Report, October 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
Dunnan, Cameron S.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: none: Tutu Environmental Investigation Committee

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 RI 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 Proposed for Superfund 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.

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Document 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
& 9003-92-0401)

Type: LEGAL DOCUMENT
Category: 7.3.0.0.0 Administrative Orders

Author: Chester, Amy R.: Assistant Regional Counsel, EPA
Recipient: Cepeda-Rodriguesz, Jose Esg: Goldman & Antonetti
McCay, Scott R., Esg.: Goldman & Antonetti

Document Number: TUT-007-1189 To 1189	Date: 02/21/92

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: Chester, Amy R.: Assistant Regional Counsel, EPA
Recipient: Cepeda-Rodriguez, J., Esg: 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 Wells Site)

Type:	CORRESPONDENCE

Category:	7.8.0.0.0 Enforcement Correspondence

Author:	Chester, Amy R.: Assistant Regional Counsel, EPA

Recipient:	Tharpes, Yvonne, Esg.: Department of Planning and Natural Resources (DPNR)

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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 M.: Lockheed Engineering & Sciences Company

Recipient: Scalise, Laura: US EPA

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: Kwan, Caroline: US EPA
Attached: TUT-006-1882

Document Number: 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 & Miller

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: Danahy, Thomas V.: Geraghty & 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 Committee
Recipient: Turnbull, Winston: none

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Document Number: TUT-003-1372 To 1558

Date: 03/10/92

Title: (Tutu Wells Site Administrative Order Index No. II-RCRA Preceeding 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:	Kwan, Caroline: US EPA

Document Number: TUT-006-1829 To 1850	Date: 03/10/92

Title: (Letter with attached tables and figures regarding Reguest 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.: Geraghty & Miller
Moffatt, Clinton: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Shank, Todd: Department of Planning and Natural Resources (DPNR)

Document Number: TUT-006-1818 To 1828	Date: 03/11/92

Title: (Letter with attached tables and figures regarding Reguest 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 & Miller
Moffatt, Clinton: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Francis, Leo: Department of Public Works

Document 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 & Miller
Nachman, Daniel: Geraghty & Miller
Recipient: Kwan, Caroline: US EPA

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 Aguifer 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

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Document Number: TUT-007-1186 To 1188

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-Rodriguez, Jose A.: Goldman Antonetti Ferraiuoli Axtmater & Hertell
Recipient: Kwan, 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 Wells Superfund Site, Community Relations Update

Type:	CORRESPONDENCE

Category:	10.6.0.0.0 Fact Sheets and Press Releases

Author:	none: US EPA

Recipient:	none: none

Document Number: TUT-003-1559 To 1592	Date: 04/07/92

Title: Community Relations Plan, Tutu Wells Site, St. Thomas, U.S. Virgin Islands
Type: PLAN

Category: 10.2.0.0.0 Community Relations Plan

Author: Masson, Cecilia: CDM Federal Programs Corporation
Recipient: Kwan, Caroline: US EPA

Document Number: 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.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: none: Tutu Environmental Investigation Committee

Document Number: TUT-004-0151 To 0153	Date: 04/10/92

Title: Comparison of Geraghty and Miller's and CDM FPC's Interpretation of Fracture Traces in the
Immediate Vicinity of the Tutu Wellfield Site

Type: GRAPHIC
Author: none: none
Recipient: none: none

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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

Document Number: TUT-006-1815 To 1815

Title: (Letter regarding documents to be deposited in the Tutu repository.)

Date: 04/10/92

Type:	CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Kwan, Caroline: US EPA
Recipient: Masson, Cecilia A.: CDM Federal Programs Corporation

Document Number: TUT-004-0157 To 0158

Date: 04/10/92

Title: (Letter regarding Technical Memorandum I, Tutu Service 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-006-1813 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 & Miller
Recipient: Odland, Sally: CDM 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.

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Document Number: TUT-006-1812 To 1812

Date: 04/21/92

Title: (Letter regarding the completed Community Relations Plan for the Tutu Wells Site and RI/FS
scoping/informational meeting.)

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 Committee

Document Number: TUT-006-0358 To 0391	Date: 04/22/92

Title: Brossman Short Form for the Tutu Wellfield Site, St. Thomas, U.S. Virgin Islands

Type:	REPORT

Category:	3.4.0.0.0 RI Reports

Author:	none: CDM 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 Number: TUT-007-1299 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 & McKee (CDM)

Recipient:	Hodge, Irma: U.S. Virgin Islands Housing Authority

Document Number: TUT-007-1175 To 1182	Parent: TUT-007-1166	Date: 05/01/92

Date:

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: Windschauer, Robert, P.G.: Subsurface Detection Investigation Inc.

Recipient: Dema, John K., P.C.: Law Offices of John K. Dema, P.C.

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Document Number: TUT-006-1784 To 1784

Parent: TUT-007-1166

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.
II-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: Kwan, Caroline: US EPA

Document Number: TUT-006-1809 To 1811	Date: 05/11/92

Title: (Letter regarding Reimbursement for Drilling Water, Tutu, St. Thomas)

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: Gumbs, Samuel: U.S. Virgin Islands Housing Authority

Document Number: TUT-006-1807 To 1808	Date: 05/13/92

Title: (Letter regarding Request for USEPA Comments on the Quality Assurance Project Plan. (QAPP),
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: 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 Work /QA Plan

Type:	CORRESPONDENCE

Category:	3.5.0.0.0 Remedial Investigation Correspondence

Author:	Scalise, Laura: US EPA

Recipient:	Kwan, Caroline: US EPA

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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.

Dunnan, Cameron S.
Nachman, Daniel A.

Geraghty & Miller
Geraghty & Miller
Geraghty & Miller

Recipient: none: Tutu Environmental Investigation Committee

Document Number: 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: Kwan, Caroline: US EPA
Recipient: Ramos, Anna Gloria, P.E.: Tutu Environmental Investigation Committee

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 Committee

Document Number: TUT-004-0155 To 0156	Date: 05/17/92

Title: (Letter regarding Relocation o Proposed Monitoring Well MW-11D, 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-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

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Document Number: TUT-006-0323 To 0357

Date: 05/19/92

Title: Revised Brossman Short Form for the Tutu Wellfield Site, St. Thomas, U.S. Virgin Islands

Type:	REPORT

Category:	3.4.0.0.0 RI Reports

Author:	none: CDM Federal Programs Corporation

Recipient:	none: US EPA

Document Number: TUT-006-1794 To 1802	Date: 05/19/92

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: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Kwan, Caroline: US EPA

Document Number: 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 Wells Superfund Site, St. Thomas - Index of
Documents attached)

Type:	CORRESPONDENCE

Category:	10.9.0.0.0 Public Correspondence

Author:	Masson, Cecelia: Camp Dresser & McKee (CDM)

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 & McKee (CDM)

Recipient:	Moyik, Catherine E.: US EPA

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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:	Graber, Scott B.: Camp Dresser & McKee (CDM)

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:
Category:
Author:

Recipient:

CORRESPONDENCE
10.9.0.0.0 Public Correspondence

Danahy, Thomas V.
Messinger, John E.
Nachman, Daniel A.
McC aule y, Yvonne:

Geraghty & Miller
Geraghty & Miller
Geraghty & Miller
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, Lak: 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 Groundwater Investigation, Revised Brossman Short Form

Type:	REPORT

Category:	3.5.0.0.0 Remedial Investigation Correspondence

Author:	none: CDM Federal Programs Corporation

Recipient:	none: US EPA

Document Number: TUT-006-1792 To 1792	Date: 06/04/92

Title: (Memorandum regarding Tutu Wells Site - Soil & Groundwater Investigation, Revised Oversight
Work/QA Plan)

Type:	CORRESPONDENCE

Category:	3.5.0.0.0 Remedial Investigation Correspondence

Author:	Scalise, Laura: US EPA

Recipient:	Kwan, Caroline: US EPA

Attached:	TUT-***-****** TUT-006-1793

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Document Number: TUT-007-1257 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 & McKee (CDM)

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 Well Field Site)

Type:	CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Graber, Scott B.: CDM Federal Programs Corporation
Recipient: Moyik, Catherine E.: 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: CDM Federal Programs Corporation
Recipient: Kwan, Caroline: US EPA

Document Number: TUT-007-1292 To 1293	Date: 06/19/92

Title: (Letter regarding documents for Tutu Wells Information Repository - Index of Documents attached)

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)

Document Number: TUT-0061785 To 1785	Date: 06/22/92

Title: (Memorandum regarding Tutu Wells Site - Soil & Groundwater Investigation Revised Oversight
Work/QA Plan)

Type:	CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Scalise, Laura: USA EPA
Recipient: Kwan, Caroline: USA EPA

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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, Esg.: Law Offices of John K. Dema, P.C.

Recipient: none: various PRPs

Document Number: TUT-006-0232 To 0287	Date: 07/23/92

Title: Summary of Field Oversight Activities, June 1992, Tutu Wellfield Site, St. Thomas, U.S. Virgin
Islands

Type:	REPORT
Category: 3.4.0.0.0 RI Reports

Author: Odland, Sally: CDM Federal Programs Corporation
Recipient: none: US EPA

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 Number: 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: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Parasar, Uma: Geraghty & Miller
Recipient: none: Tutu Environmental Investigation Committee

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

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Document Number: TUT-006-0212 To 0212

Date: 0811/92

Title: (Letter forwarding the Sampling Trip Report for July 22 through July 30, 1992)

Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Odland, Sally: CDM Federal Programs Corporation
Recipient: Kinsella, Kathy: US EPA
Attached: TUT-006-0213

Document Number: TUT-006-1778 To 1781	Date: 08/14/92

Title: (Letter regarding Proposed Soil Boring B-14 through B-16 Tutu Service Station Investigation,
St. Thomas, U.S. Virgin Islands)

Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial
Author: Danahy, Thomas V.:
Nachman, Daniel A.:
Recipient: Kwan, Caroline: US

Investigation Correspondence
Geraghty & Miller
Geraghty & Miller
EPA

Document Number: TUT-006-1782 To 1782	Date: 08/14/92

Title: (Memorandum regarding Sewer Connection)

Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence

Author: Estrill, 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-006-1784

Document Number: TUT-003-0736 To 0737	Date: 08/14/92

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: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Reive, Michael D.: Geraghty & Miller
Recipient: Kwan, Caroline: US EPA
Attached: TUT-003-0738

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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: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Recipient: Kwan, Caroline: US EPA
Attached: TUT-006-1764 TUT-006-1772

Document 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: Kwan, Caroline: US EPA

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Document Number: 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: CDM 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: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller

Document Number: TUT-006-1758 To 1760	Date: 08/26/92

Title: (Letter regarding Abandonment of Monitoring Well MW-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 & Miller
Recipient: Kwan, Caroline: US EPA

Document Number: TUT-006-1743 To 1757	Date: 08/31/92

Title: (Letter regarding submittal of attached SAS client reguest Nos.1148 & 1049)

Type:	CORRESPONDENCE

Category:	3.5.0.0.0 Remedial Investigation Correspondence

Author:	Desikan, Vasu: Camp Dresser & McKee (CDM)

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 RI Reports

Author: none: Savannah Laboratories Environmental Services, Inc.

Recipient: none: none

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Document Number: TUT-006-1741 To 1742

Date: 09/01/92

Title: (Letter regarding Abandonment of Monitoring Well MW-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 & Miller
Recipient: Kwan, Caroline: US EPA

Document Number: TUT-006-1737 To 1738	Date: 09/14/92

Title: (Letter regarding attached revised schedule for field work at the Tutu Service Station Remedial
Investigation)

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-006-1739 To 1740	Date: 09/14/92

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: Kwan, Caroline: US EPA

Document Number: TUT-006-1734 To 1736	Date: 09/18/92

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 & Miller
Reive, Michael D.: Geraghty & Miller
Recipient: Adams, Roy E.: Department of Planning and Natural Resources (DPNR)

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Document Number: TUT-007-1166 To 1167

Date: 09/21/92

Title: (Fax Transmittal of Letter regarding Four Winds Plaza Partnership, Reguest 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, Vasguez & 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)

Document Number: TUT-006-0209 To 0209	Date: 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 RI Reports

Author: Agrelot, Jose C.: Soil Tech
Recipient: none: none

Document Number: TUT-006-0210 To 211	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, Eugenio C.: Goldman Antonetti Ferraiuoli Axtmater & Hertell
Recipient: Dema, John K. , Esg.: Law Offices of John K. Dema, P.C.

Knoepfel, Richard R.: attorney

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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

Document Number: TUT-007-1163 To 1163	Date: 10/15/92

Title: (Letter regarding Tutu Well Water Contamination Litigation - Reguest for Site Investigation
at Esso Tutu)

Type:	CORRESPONDENCE

Category:	7.8.0.0.0 Enforcement Correspondence

Author:	Dema, John K., Esg.: Law Offices of John K. Dema, P.C.

Recipient:	Romero, Eugenio C. Esg.: 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 Aguifer 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

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Document Number: TUT-006-1722 To 1723

Date: 10/23/92

Title: (Letter with attached map regarding Four Winds Plaza 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: Danahy, 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:	Kwan, Caroline: US EPA

Recipient:	Dema, John K., Esg.: Law Offices of John K. Dema, P.C.

Document Number: TUT-006-1720 To 1721	Date: 10/27/92

Title: (Letter regarding Tutu Aguifer 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)

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 K. Esg.: Law Offices of John K. Dema, P.C.

Recipient:	Kwan, Caroline: US EPA

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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:	Kwan, Caroline, US EPA

Recipient:	Ramos, Ana Gloria: Tutu Environmental Investigation Committee

Document Number: TUT-006-1714 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 & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Kwan, Caroline: US EPA

Document Number: TUT-006-1707 To 1711	Date: 10/30/92

Title: (Letter regarding Tutu Aguifer 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)

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:	Kwan, 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

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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:	Kwan, 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 & Miller
Recipient: Restovic, Mirko: Department of Public Works

Document Number: TUT-004-1963 To 1985	Parent: TUT-004-1959	Date: 11/30/92

Title: Report of Results for the 4 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 RI Reports

Author: none: CDM Federal Programs Corporation
Recipient: none: US EPA

Document Number: TUT-007-1284 To 1286	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 (CDM)

Recipient:	McCauley, Yvonne: Department of Planning and Natural Resources (DPNR)

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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 (CDM)

Recipient:	Kwan, Caroline: US EPA

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, Cecelia: CDM 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

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Document Number: TUT-004-1952 To 1958

Date: 12/12/92

Title: Report of Results for Project #4: Winds (W. 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 K.: 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:	Kwan, 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.: CDM Federal Programs Corporation

Recipient:	Smieszek, Erwin: US EPA

Document Number: TUT-003-0364 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: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Parasar, Uma: Geraghty & Miller
Recipient: none: Tutu Environmental Investigation Committee

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Document Number: TUT-006-1227 To 1264

Parent: TUT-006-1226

Date:

01/01/93

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

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:	Kwan, Caroline: US EPA

Document Number: TUT-005-1803 To 2166

Date: 01/11/93

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:	3.4.0.0.0 RI Reports

Author:	none: Geraghty & Miller

Recipient:	none: Tutu Environmental Investigation Committee

Document Number: TUT-006-1676 To 1677

Title: (Letter regarding attached Monthly Progress Report No. 12, Tutu Well Site)

Date: 02/10/93

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-003-2470 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 Reguest for Information)

Type:	CORRESPONDENCE

Category:	7.7.0.0.0 Notice Letters and Responses

Author:	Berne, Alphonse: Potentially Responsible Party (PRP)

Recipient:	Kwan, Caroline: US EPA

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Document Number: TUT-003-2377 To 2429

Date: 03/01/93

Title: (Letter on behalf of Four Winds 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

Document Number: TUT-006-1462 To 1470	Parent: TUT-006-1458	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: Kwan, 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 & Miller
Nachman, Daniel: Geraghty & Miller
Recipient: Kwan, Caroline: US EPA

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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: Geraghty & Miller
Recipient: Scalise, Laura: US EPA

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 Reguest 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
Reguest 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

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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 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

Document Number: TUT-004-1932 To 1951	Date: 03/11/93

Title: 0'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 Winds 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: Dema, Jack, Esg.: Law Offices of John K. Dema, P.C.

Document 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.: Geraghty & Miller
Moffatt, Clinton: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Dema, Jack, Esg.: Law Offices of John K. Dema, P.C.

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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 No. 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 Reguest 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

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.: CDM Federal Programs Corporation
Recipient: Smieszek, Erwin: 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: CDM Federal Programs Corporation

Recipient:	Kwan, Caroline: US EPA

Attached:	TUT-006-1643

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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.: CDM Federal Programs Corporation

Recipient:	Smeiszek, 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 Reguest 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-003-2050 To 2050	Date: 03/31/93

Title: (Letter forward Western Auto's Supplemental Response to Reguest 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 Reguest 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-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

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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 Islands)

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: Kwan, Caroline: US EPA

Document Number: TUT-006-1566 To 1588

Date: 04/05/93

Title: (Letter regarding attached Soil Gas Survey for the UST Areas, Four Winds 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: Kwan, 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 (DPNR)

Recipient:	Kwan, Caroline: US EPA

Document Number: TUT-006-1563 To 1564

Title: (Letter regarding attached Monthly Progress Report No. 14, 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

Date: 04/13/93

Document Number: TUT-006-1552 To 1562

Title: (Letter with attached figures and data regarding Four Winds Test Well Logs)

Date: 04/15/93

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 K. Dema, P.C.

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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-006-1517	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 K., Esguire: 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 Reguest & Procedure)

Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Coon, John R.: Coon & Sanford, Law Offices
Recipient: Praschak, Andrew L., Esg.: 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

Document Number: TUT-006-1460 To 1461	Parent: TUT-006-1458	Date: 05/19/93

Title: (Letter regarding Reguest 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)

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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-006-1487 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: Kwan, Caroline: US EPA

Document Number: TUT-002-1141 To 1329	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: Burdick, Jeffrey S.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: none: Tutu Environmental Investigation Committee
Attached: TUT-002-1330

Document Number: TUT-002-1330 To 1802	Parent: TUT-002-1141	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

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Document Number: TUT-002-1140 To 1140

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: Danahy, Thomas V.: Geraghty & Miller
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 & Miller
Recipient: Kwan, Caroline: US EPA

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 Reguest 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-006-1486 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., Esguire: Law Offices of John K. Dema, P.C.

Recipient:	Cepeda-Rodriguez, Jose A.: Goldman Antonetti Cordova and Axtmeyer

Document Number: TUT-006-1483 To 1485	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:	Colon-Franceschi, Carols: Goldman Antonetti Cordova and Axtmeyer

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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

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	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:	Gal, Andreas: Potentially Responsible Party (PRP)

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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:	Cregue, Linda: Potentially Responsible Party (PRP)

Document Number: TUT-003-1651 To 1653

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

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)

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

Date: 06/04/93

Date: 06/04/93

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: W.L. Gore & Associates, Inc.

Recipient: none

Date: 06/04/93

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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 Wellfield Site)

Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Graber, Scott B.: Camp Dresser & McKee (CDM)

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 & McKee (CDM)

Recipient: none: US EPA

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:	Kwan, 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.: Geraghty & Miller
Mozer, Robert: Geraghty & Miller
Recipient: Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Committee

Document 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

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Document Number: 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, Esg.: attorney

Recipient:	Kwan, Caroline: US EPA

Document Number: TUT-003-1698 To 1700	Date: 06/16/93

Title: (Letter on behalf of Ramsey Motors, Inc. in response to Reguest 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 Reguest for Information)

Type:	CORRESPONDENCE

Category:	7.7.0.0.0 Notice Letters and Responses

Author:	Coon, John R.: attorney

Recipient:	Praschak, Andrew: US EPA

Document Number: TUT-006-1458 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-006-1460 TUT-006-1462

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, Katherine: attorney

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Document 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, Mathew L.: attorney

Recipient:	Praschak, Andrew L.: US EPA

Document 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 & Hertell

Recipient:	Dema, John K., Esq.: Law Offices of John K. Dema, P.C.

Attached:	TUT-***-****** TUT-006-1446 TUT-006-1447

Document 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

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

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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 (DPNR)

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, Jeffrey S.: Geraghty & Miller
Danahy, Thomas V.: Geraghty & Miller
Mozer, Robert: Geraghty & Miller
Recipient: Ramos, Ana Gloria: Tutu Environmental Investigation Committee

Document Number: TUT-006-1425 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. , Esg.: Law Offices of John K. Dema, P.C.

Recipient:	Colon-Franceschi, Carlos: Goldman Antonetti Ferraiuoli Axtmater & Hertell

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., Esg.: Law Offices of John K. Dema, 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:	Kwan, Caroline: US EPA

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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

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: Blasland & Bouck Engineers
Recipient: none: Geraghty & Miller

Document Number: TUT-005-1708 To 1802	Date: 08/02/93

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

Document Number: TUT-005-1154 To 1154	Date: 08/04/93

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 (CDM)

Rossman, Brad, Esq.: US Dept of Justice
Simon, Paul, Esq.: US EPA
Wheeler, Lee, Esq.: Roy F. Weston, Inc.

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Document Number: TUT-004-1410 To 1415

Date: 08/10/93

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

Document Number: TUT-006-1378 To 1379	Date: 08/13/93

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. 18)

Type:	CORREPSONDENCE

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-006-1380 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:	Kwan, Caroline: US EPA

Document Number: TUT-006-1374 To 1377	Date: 08/18/93

Title: (Letter regarding attached Reguest for CDM and Roy Weston Sampling Results at Tutu Wellfield
Site)

Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Blazey, Douglas R.: US EPA
Recipient: Dema, John K., Esg.: Law offices of John K. Dema, 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. Documentation of Technical Discussions with PRPs on Response Actions
Author: Kwan, Caroline: US EPA
Recipient: Kwan, Caroline: US EPA

Ramos, Ana Gloria, P.E.: Tutu Environmental Investigation Committee

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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
Di(2-ethylhexyl)phthalate (CASRN 117-81-7)

Type:	RESORT

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:	D'Anna, Nancy, Esg.: attorney

Recipient:	Praschak, Andrew, Esg.: 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
Recipient: 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

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 Analysis Data/Chain of Custody Forms
Author: none: none
Recipient: none: none

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Document Number: TUT-006-1353 To 1369

Date: 09/10/93

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. 19)

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-006-1346 To 1352	Parent: TUT-006-1345	Date: 09/22/93

Title: (Letter regarding TUT 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, Melvin: 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: Knutson, Timothy R.: Texaco

Recipient:	Praschak, Andrew, Esg.: Assistant Regional Counsel, EPA

Attached:	TUT-006-134 6

Document Number: TUT-004-1100 To 1140	Date: 10/01/93

Title: Hydrogeologic Assessment/Source Identification, Upper Tutu Aquifer Basin, Tute, 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 1405	Date: 10/01/93

Title: Geohydrologic Analysis and Water 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: PID/Harthman Anna's Retreat, St. Thomas, USVI

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Document Number: TUT-006-0577 To 0578

Parent: TUT-006-0570

Date: 10/01/93

Title: Text of an unspecified report 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-007-1912 To 1954	Date: 10/04/93

Title: (Memorandum regarding transmittal of Oswer 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

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., Esg: 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, Esg.: attorney

Recipient:	Praschak, Andrew, Esg.: US EPA

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Document Number: TUT-007-0936 To 0940

Date: 10/14/93

Title: (Letter regarding Tutu Wellfields 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, Esg.: US EPA

Document 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:	D'Anna, Nancy, Esg.: 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, Esg.: Archer & Greiner
Knutson, Timoty R., Esg.: Texaco
Recipient: Praschak, Andrew, Esg.: 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)

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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 D. Little, Inc.

Recipient: none: Rosenman & Colin

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 (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-005-0313 To 0350	Date: 11/09/93

Title: Phase I Site Assessment and Interim Remedial Measures Workplan, 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 - Law 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.
II-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

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Document Number: TUT-005-0264 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 (DPNR)

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 Custody 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 0'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 is done by the Institute of Geotechnical
Engineering)

Type:	CORRESPONDENCE

Category:	3.5.0.0.0 Remedial Investigation Correspondence

Author:	Harsch, Katherine E.: attorney

Recipient:	Praschak, Andrew L., Esg.: US EPA

Attached:	TUT-006-1316

Document Number: TUT-006-1327 To 1332	Date: 12/08/93

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. 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:	Kwan, Caroline: US EPA

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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: Kwan, 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

Document Number: TUT-005-0263 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, Mark: W.L. Gore & Associates, Inc.

Recipient:	Bierschenk, John: ENSR

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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 Soil,
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
Attached: TUT-004-2313

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.: Blasland & Bouck Engineers

Maguire, Thomas F.: Blasland & Bouck Engineers
Recipient: Danahy, 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 Winds 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	Date: 01/12/94

Title: (Letter regarding attached Monthly 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:	Kwan, Caroline: US EPA

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Document Number: TUT-0042311 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

Document Number: TUT-006-1290 To 1297	Date: 01/24/94

Title: (Letter regarding 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 & Miller

Nachman, Daniel A.: Geraghty & Miller
Recipient: Kwan, Caroline: US EPA

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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 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-006-1285 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, USVI.)

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)

Document Number: TUT-006-1283 To 1284	Date: 01/31/94

Title: (Letter regarding Reports for Review)

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-004-0628 To 0650	Date: 02/01/94

Title: Transmittal with attached Site Assessment Program, Tutu Esso Station, Tutu, St. Thomas, U.S.
Vi rgin Is1ands.

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

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Document Number: TUT-006-1282 To 1282

Date: 02/04/94

Title: (Letter regarding a reguest for additional raw data for the matrix spike data associated wi
sample DRMOl 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, Esg.: attorney

Document Number: TUTU-007-1151 To 1153	Date: 02/11/94

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

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:	Kwan, 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:	Kwan, Caroline: US EPA

Recipient:	Allen, Cynthia V.: Department of Planning and Natural Resources (DPNR)

Document Number: TUTU-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

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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

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-006-1233 To 1224	Parent: TUT-006-1221	Date: 03/02/94

Title: (Fax memorandum regarding Property Access to Proposed Monitoring Well Locations MW-20, MW-20D,
and MW-23D)

Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Colberg, Alberto: none
Recipient: Danahy, Tom: Geraghty & Miller
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 Wells 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. Dema, 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

MW-23D and Newly Identified Delegarde Supply Well, Southeast Area of Tutu Well Site, St. Thomas,
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

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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: Danahy, Thomas V.: Geraghty & Miller

Nachman, Daniel A.: Geraghty & Miller
Recipient: Kwan, Caroline: US EPA

Document Number: TUT-004-2310 To 2310	Date: 03/11/94

Title: Revised Phase II Remedial Investigation Implemenation 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: Kwan, Carolyn: US EPA

Praschak, Andrew: attorney

Document Number: TUT-006-1226 To 1226	Date: 03/11/94

Title: (Letter regarding Request a Storm Sewer Trench in the Tutu Wells Site Area, St. Thomas, U.S.
Virgin Islands)

Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investment Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Green, Bruce: none
Attached: TUT-006-1227

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Document Number: TUT-005-1307 To 1321

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 RI Reports

Author:	Ramos, Ana Gloria: Tutu Environmental Investigation Committee

Recipient:	none: US EPA

Document 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

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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 MW-20D, 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

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 & Miller
Recipient: Kwan, Caroline: US EPA
Attached: TUT-006-1141 TUT-006-1143 TUT-006-1144 TUT-006-1145 TUT-006-1146

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 Nisky
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

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Document Number: TUT-004-2305 To 2305

Date: 04/07/94

Title: (Letter regarding the Transmittal of Resonses 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 K., R.P.G.: IT Corporation
Recipient: Kwan, 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 & Miller

Nachman, Daniel A.:	Geraghty & Miller

Recipient: Kwan, Caroline: US	EPA

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 To 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

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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

Document Number: TUT-006-1084 To 1085	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 RI Reports

Author:	none: de maximis, inc.

Recipient: none: US EPA

Document Number: TUT-007-1149 To 1150	Date: 05/03/94

Title: (Letter re: In the Matter of the Tutu Wells Site, Administrative Order on Consent 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 MW-24 Well 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

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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:
Category:
Condition:
Author:

Recipient:
Attached:

CORRESPONDENCE

3.5.0.0.0 Remedial Investigation Correspondence
MARGINALIA; MISSING ATTACHMENT
Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
O'Dell, Brent: Geraghty & Miller
Kwan, Caroline: US EPA
TUT-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: Coberg, Alberto: Geraghty & Miller

Danahy, 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

Document Number: TUT-006-1079 To 1080	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. Remedial Investigation Correspondence
Author: Colberg, Alberto: Geraghty & Miller

Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Tillet, James: none

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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 & Miller

Danahy, Thomas V.: Geraghty & Miller
Nachman, Danial A.: Geraghty & Miller
Recipient: Gasset, Thomas A.: none

Document Number: TUT-006-1083 To 1083	Date: 05/10/94

Title: (Letter forwarding the Monthly Status 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:	Kwan, Caroline: US EPA

Attached:	TUT-006-1084

Document Number:	TUT-006-1063 To 1064	Date: 05/11/94

Title: (Letter regardomg 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

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 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: Hodge, Cynthia: none

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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, Danial A.: Geraghty & Miller
Recipient: Turnball, Wallace: none

Document Number: TUT-006-1071 To 1072	Date: 05/11/94

Title: (Letter regarding Sampling of Water Supply Wells 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: Knoepfel, Richard R.: attorney

Document Number: 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 & Miller

Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Harvey, Inez: none

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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:
Category:
Author:

Recipient:

CORRESPONDENCE

3.5.0.0.0 Remedial Investigation Correspondence
Colberg, Alberto: Geraghty & Miller
Danahy, Thomas V.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Smith, Dennis: none

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, Danial 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 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, Danial A.: Geraghty & Miller
Stern, David E.: Geraghty & Miller
Recipient: Murnan, 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: Kwan, C.: US EPA

Odland, S.: CDM Federal Programs Corporation
Ryan, P.: Texaco

Shottroff, A. : Department of Planning and Natural Resources (DPNR)

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Document Number: TUT-007-1147 To 1148

Parent: TUT-007-1146

Date: 05/18/94

Title: (Letter regarding permenent 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 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: Law, Michael: US Dept of Justice

Document Number: TUT-004-0136 To 0136	Date: 05/24/94

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., Esg.: US EPA

Document Number: TUT-007-1146 To 1146	Date: 05/25/94

Title: (Letter regarding Tutu Wells 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

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

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Document Number: TUT-004-0248 To 0616

Date: 06/01/94

Title: Closure Report for Underground Storage Tanks, Four Winds 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, 0'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: Kwan, Caroline: US EPA

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 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-006-1048

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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

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 RI 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,
0'Henry Laundry, Tuto, 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-006-1042 To 1045	Date: 08/06/94

Title: (Letter regarding Groundwater monitoring, Tutu Wells Site Remedial Investigation)

Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Danahy, Thomas V.: Geraghty & Miller
Morales, Wanda I.: Geraghty & Miller
Nachman, Daniel A.: Geraghty & Miller
Recipient: Reed, Leonard: Department of Planning and Natural Resources (DPNR)

Simmonds, Ralda V.: U.S. Virgin Islands Housing Authority

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Document Number: TUT-007-0833 To 0870

Date: 07/08/94

Title: (Letter regarding the attached Revised Pathway Exposure Report Draft Endangerment Assessment,
Tutu Wells Site, St. Thomas, Virgin Islands)

Type: CORRESPONDENCE
Category: 7.2.0.0.0 Endangerment Assessments

Author:	Goltz, Robert D., P.E.: Camp Dresser & McKee (CDM)

Recipient: Kollar, Keith: US EPA

Document Number: TUT-006-1038 To 1038	Date: 07/08/94

Title: (Letter regarding the 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: Kwan 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: Danahy, Thomas V.: Geraghty & Miller
Morales, Wanda I.: Geraghty & Miller
Nachman, Daiel A. : Geraghty & Miller
Recipient: Simmonds, Ralda V.: none

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Document Number: TUT-006-1035 To 1035

Date: 07/15/94

Title: (Letter regarding Validation of Soil and Groundwater 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 Laudry, 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-006-1200 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

Document Number: TUT-006-1024 To 1024	Date: 08/03/94

Title: (Letter regarding Approval of the Workplan for Evaluation and Interim Remedation of Soils
at the O'Henry Laudry, Tutu, St. Thomas)

Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence

Author:	Peterson, Carole: US EPA
Recipient: D'Anna, Nancy: attorney

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Document Number: TUT-006-1023 To 1023

Parent: TUT-006-1022

Date: 08/04/94

Title: (Memo regarding TEIC/EPA/DPNR Conference Call, Tutu Wells Field Project)

Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence

Author:	McBurney, Jack: de maximix, inc.

Recipient: Kwan, 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 maximis, 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 Toxicity Information for Benzene (CASRN 71-43-2), Chromium VI (CASRN
7440-47-3), Di(2-ethylhexyl) phthalate (CASRN 117-81-7) and Vinyl Chloride (CASRN 75-01-4) (Tutu
Wellfield Site/St. Thomas, Virgin Islands

Type: CORRESPONDENCE
Category: 3.4.0.0.0 RI Reports

Author:	Dollarhide, Joan S.: none
Recipient: Maddaloni, Mark: US EPA
Attached: TUT-005-1307 TUT-005-1322

TUT-005-1327

TUT-005-1349

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:	Kwan, 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:	McBurney, John P.: Phillips Building
Recipient: Kwan, Caroline: US EPA
Attached: TUT-006-1020

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Document Number: TU-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:	McBurney, 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

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:	McBurney, 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 Endangerment 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

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-066-1015

Date: 08/26/94

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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

Document Number: TUT-006-1006 To 1006	Parent: TUT-006-1005	Date: 08/31/94

Title: Tutu Well Fields Project Progress Report, August 1994

Type:	REPORT

Category:	3.4.0.0.0 RI 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, Esg.: 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 Groundwater Sampling of the Delegrade
Supply Well, 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
Potenza, John C.: Geraghty & Miller
Recipient: Seibel, Geoff: de maximis, inc.

Attached: TUT-006-1010

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Document 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: Kwan, 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 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: Kwan, 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, Esg.: Assistant Regional Counsel, EPA

Document Number: TUT-007-1122 To 1123	Date: 09/29/94

Title: (Letter regarding attached Comments on Endangerment Assessment Tutu Wells 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 Techology Corporation (IT)

Recipient:	Kwan, Caroline: US EPA

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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 Wells Site Draft Risk Assessment/Draft Ramsay Motors -File 92115)

Type:	CORRESPONDENCE

Category:	3.5.0.0.0 Remedial Investigation Correspondence

Author:	Rich, Carol Ann: Campbell, Arellano & Rich

Recipient:	Kwan, Caroline: US EPA

Document Number: TUT-006-0653	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

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 Group and DPNR)

Type:	CORRESPONDENCE

Category:	3.5.0.0.0 Remedial Investigation Correspondence

Author:	Kwan, 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:	Kwan, Caroline: US EPA

Attached:	TUT-006-0995

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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:	Kwan, 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:	Kwan, Caroline: US EPA

Attached:	TUT-006-0999

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 ATTACHEMENT

Author: Danahy, Thomas V.: Geraghty & Miller

Nachman, Daniel A.: Geraghty & Miller
Recipient: Kwan, Caroline: US EPA

Document Number: TUT-006-0990 To 0990	Date: 10/13/94

Title: (Transmittal 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

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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 Wells 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 0'Henry Laundry)

Type:	CORRESPONDENCE

Category:	3.5.0.0.0 Remedial Investigation Correspondence
Author: Price, Belinda: IT Corporation

Recipient:	Kwan, Caroline: US EPA

Document Number: TUT-004-0227 To 0247	Date: 10/25/94

Title: Facsimile transmital 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:	Kwan, Caroline: US EPA

Document Number: TUT-006-0965 To 0984	Date: 10/25/94

Title: (Letter forwarding enclosed Groundwater Samples from O'Henry Laundry, St. Thomas, U.S.V.I.)

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-006-0964 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

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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

Document Number: TUT-006-0662 To 0963	Date: 10/25/94

Title: (Letter regarding Four Winds Plaza Partnership's comments on Geraghty & Miller, Inc.'s Draft
Phase II Remedial Investigation)

Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Dema, John K.: Law Offices of John K. Dema, P.C.

Recipient: Adams, Roy: Department of Planning and Natural Resources (DPNR)

Kwan, Caroline: US EPA
Praschak, Andrew: US EPA

Document Number: TUT-006-0641 To 0648	Parent: TUT-006-0636	Date: 11/02/94

Title: (Memorandum regarding Evaluation of Geraghty & Miller Remedial Investigation Report)

Type:	CORRESPONDENCE

Category:	3.5.0.0.0 Remedial Investigation Correspondence

Author:	Fahrenthold, 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-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

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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, Dore: US EPA

Recipient:	Petersen, Carole: US EPA

Document Number: TUT-007-1117 To 1119	Date: 11/09/94

Title: (Leter 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 L.: 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 & Miller, 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

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Document Number: TUT-006-0651 To 0651

Date: 11/10/94

Title: (Letter regarding Tutu Wellfields 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: Kwan, 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 Wells Site Investigation, St. Thomas, United States Virgin Islands)

Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence
Author: Dema, John K., Esg.: Law Offices of John K. Dema, P.C.

Recipient: Adams, Roy: Department of Planning and Natural Resources (DPNR)

Kwan, Caroline: US EPA
Praschak, Andrew, Esg.: US EPA
Attached: TUT-006-0638 TUT-006-0641

Document Number: TUT-006-0606 To 0606	Date: 11/14/94

Title: (Letter of Transmittal regarding Form l'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: Geraghty & Miller
Recipient: Naugle, Jill E.: CDM Federal Programs Corporation

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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:	Kwan, 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, Esg.: Campbell, Arellano & Rich

Recipient:	Kwan, 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: Kwan, Caroline: US EPA
Attached: TUT-006-0617 TUT-006-0621 TUT-006-0634

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 Envirnmental Investigation Committee ("TEIC")

Type:	CORRESPONDENCE

Category:	3.5.0.0.0 Remedial Investigation Correspondence
Author: Leland, Richard G.: Rosenman & Colin

Recipient:	Dwan, 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, Esg.: Rosenman & Colin

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Document Number: TUT-006-0579 To 0600

Date: 11/15/94

Title: (Letter with attached summary comments regarding "Draft Phase II Remedial Investigation, Tut
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

Document Number: TUT-006-0562 To 0563	Date: 11/23/94

Title: (Memorandum regarding Biological Technical Assistance Group Meeting Phase II Remedial
Investigation for Tutu Wells)

Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correponence

Author:	Stevens, Shari: US EPA
Recipient: Kwan, 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:	Nazario, Benjamin I.: Department of Planning and Natural Resources (DPNR)

Recipient:	Kwan, Caroline: US EPA

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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

Document Number: TUT-006-0530 To 0530	Date: 12/08/94

Title: (Letter regarding Monthly Status Report No. 34, 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-006-0531

Document Number: TUT-006-0524 To 0525

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., Esg.: Rosenman & Colin

Document Number: TUT-006-0526 To 0527

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., Esg.: Law of John K. Dema, P.C.

Date: 12/22/94

Date: 12/22/94

Document Number: TUT-006-0528 To 0529

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, Esg.: Campbell, Arellano & Rich

Date: 12/22/94

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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: 12/21/94

Title: Tutu Well Site, St. Thomas, U.S. Virgin Islands, Monthly Progress Report #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:	Kwan, 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 (DPNR)

Attached: TUT-006-0502

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Document Number: TUT-006-0490 To 0494

Date: 01/12/95

Title: (Memorandum regarding Selection of Soil Standards or Background/Values 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: Kwan, 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

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'Henri, 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.

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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,
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-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 Service, Inc.

Recipient:	none: Esso Caribbean and South America

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

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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: McBurney, 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 0'Henry Dry Cleaners)

Type: CORRESPONDENCE
Category: 2.7.0.0.0 Removal Response Correspondence

Author:	D'Anna, Nancy: attorney
Recipient: Praschak, Andrew, Esg.: US EPA

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 Analysis 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 0'Henry Laundry, Tutu, St. Thomas)

Type: CORRESPONDENCE
Category: 3.5.0.0.0 Remedial Investigation Correspondence

Author:	Price, Belinda K.: 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

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Document Number: TUT-007-12 67 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

Document Number: TUT-006-2159 To 2160	Parent: TUT-006-2148	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 Administration Order on Consent for Removal Action at the L'Henry, Inc.
Property)

Type:	CORRESPONDENCE

Category:	2.7.0.0.0 Removal Response Correspondence

Author:	Kwan, Caroline: US EPA

Recipient:	Reed, Leonard: US EPA

Document Number: TUT-007-0871 To 0895	Date: 03/03/95

Title: Administration Order on Consent for Removal Action

Type: LEGAL DOCUMENT
Category: 7.3.0.0.0 Administration 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

Author:	Simon, Paul: US EPA
Recipient: D'Anna, Nancy: attorney

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Document Number: TUT-004-0195 To 0207

Date: 03/06/95

Title: Field Activities Report - L'Henri, Inc. (0'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 & Miller, 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: Kwan, 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 Island
Type: PLAN

Category: 10.2.0.0.0 Cummunity Relations Plan
Author: none: Camp Dresser & McKee (CDM)

Recipient: none: US EPA

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: Kwan, Caroline: US EPA
Attached: TUT-006-0461

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Document Number: TUT-006-0461 To 04 61

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:
Category:
Author:
Recipient:

REPORT

3.4.0.0.0 RI Reports
none: de maximis, inc.
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 Sites; 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

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 Wellfield

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, Administration 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: Kwan, Caroline: US EPA

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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. Weston, Inc.

Recipient:	Kwan, 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 & McKee (CDM)

Recipient: none: US EPA

Document Number: TUT-006-2441 To 0313	Date: 03/24/95

Title: Final Endangerment Assessment, Tutu Wells 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 (CDM)
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: Kwan, Caroline: US EPA

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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 RI Reports

Author:	none: de maximis, inc.

Recipient:	none: US EPA

Document Number: TUT-005-0408 To 0706	Parent: TUT-005-0406	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	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

Document Number: TUT-006-2168 To 2173	Date: 04/04/95

Title: (Letter regarding attached Comments 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

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Document Number: TUT-005-0406 To 0407

Date: 04/06/95

Title: (Letter regarding Submittal 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 Corportation
Recipient: Kwan, Caroline: US EPA
Attached: TUT-006-0456

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: Kwan, 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

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Document Number: TUT-006-2161 To 2162

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 Islands

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 (DPNR)

US EPA

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:	Belinda, Andrew: US EPA

Recipient:	Petersen, Carole, US EPA

Document Number: TUT-006-2143 To 2147	Date: 04/17/95

Title: (Letter regarding Tutu Water 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: Kwan, Caroline: US EPA
Attached: Tut-006-2157 TUT-006-2159 TUT-006-2161

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Document Number: TUT-006-2163 To 2164

Date: 04/17/95

Title:

(Memorandum regarding Tutu Wells Site - Draft Feasibility Study: Air Program Branch Review)

Type: CORRESPONDENCE
Category: 4.5.0.0.0 Feasibility Study Correspondence

Author:	Gonzalez, Marlone: US EPA
Recipient: Kwan, Caroline: US EPA

Document Number:	TUT-006-2141 To 2142	Date: 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 Feasibility 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:	Kwan, 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: Kwan, Caroline: US EPA

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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 L.: 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 Feasibility Study Correspondence

Author:	Price, Belinda K.: IT Corporation
Recipient: Kwan, Caroline: US EPA

Document Number: TUT-006-2126 To 2132	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 Feasibility Study Correspondence

Author:	Reed, Leonard: Department of Planning and Natural Resources (DPNR)

Recipient: Kwan, Caroline: US EPA

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

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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 BTAG'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

Document Number: TUT-0060435 To 0435	Date: 05/10/95

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, Geoffrey C.: 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.

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Document Number: TUT-007-1379 To 1549

Date: 06/26/95

Title: Technical 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 & Kalinowki, Inc.

Recipient: none: none

Document Number: TUT-008-0584 To 0587	Date: 07/10/95

Title: (Letter regarding EPA's Responses to Western 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., Esp.: Coon & Sanford, Law Offices

Document Number: TUT-007-1301 To 1378	Date:

Title: Final Report, Estimation of Soil Cleanup Concentrations Reguired 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:	CDM 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 Groundwater and Soils
Remediation Sources Control Program")

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-008-0315

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Document Number: Soil Remediation Report, 0'Henry Laundry, Tutu, St. Thomas, U.S. Virgin Islands

Date:

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.

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 Tut 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

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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:	Kwan, 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:	Kwan, 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, Marc 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

Document Number:	TUT-007-1995 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

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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-008-0580 To 0580	Date: 08/15/95

Title: (Memorandum regarding Tutu Wellfield Superfund Site, St. Thomas, USVI, Draft Proposed Plan)

Type: CORRESPONDENCE
Category: 4.5.0.0. Feasibility Study Correspondence

Author:	Brock, Frank C.: US EPA
Recipient: Kwan, Caroline: US EPA

Document Number: TUT-008-0610 To 0611	Date: 08/17/95

Title: (Letter regarding Tutu Wellfield 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. Esg.: US EPA

Document Number: TUT-008-0578 To 0578	Date: 08/18/95

Title: (Letter of Transmittal for Reguest 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 Reguest 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 Natual Resources (DPNR)

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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:	Bellina, 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 Soil 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

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 List attached)

Type: CORRESPONDENCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Newman, John M.: Porzio, Bromberg & Newman
Recipient: Kwan, Caroline: US EPA

Praschak, Andrew, Esg.: 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 Wellfield Superfund Site)

Type:	CORRESPONDENCE

Category:	7.8.0.0.0 Enforcement Correspondence

Author:	Gnudi, Robyn M.: Edell & Associates

Recipient:	Kwan, Caroline: US EPA

Attached:	TUT-008-0589

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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

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 0'Henry Dry Cleaners, 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

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 & Kalinowski, Inc.

Peabody, Carey E., Ph.D.: Erler & Kalinowdki, Inc.

Recipient: Leaonard, 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 Table 1 from January 11, 1996 Letter regarding "Proposal for Disposal
of Drums Containing Solid Drilling Spoils with Low Levels of Petroleum Hydrocarbons at the
Bavoini 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

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Document Number: TUT-008-0297 To 0313

Date: 02/01/96

Title: Tutu Wellfield Superfund 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

Document Number: TUT-008-0621 To 0624	Date: 02/15/96

Title: (Letter regarding attached Addendum to Final Human Risk Assessment)

Type: CORRESPONDENCE
Category: 8.3.0.0.0 Health Assesement Correspondence

Author:	Odland, Sally, P.G.: CDM Federal Programs Corporation
Recipient: Kwan, Caroline: US EPA

Document Number: TUT-008-0626 To 0705	Date: 03/05/96

Title: Public Meeting Transcript, Tutu Wellfield 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 Wellfield 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 responses to the revised Superfund Proposed Plan, Tutu Wellfield Site, St.
Thomas, Virgin Islands)

Type: CORRESPONDENCE
Category: 10.9.0.0.0 Public Correspondence

Author:	Gjessing, Helen W.: The League of Women Voters
Recipient: none: none

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Document Number: TUT-008-0517 To 0518

Date: 03/12/96

Title: (Letter regarding Tutu Wellfield NPL Site, Revised Superfund Proposed Plan)

Type: CORRESPONDENCE
Category: 4.5.0.0.0 Feasibility Study Correspondence

Author:	Knutson, Timothy R.: attorney
Recipient: Kwan, Caroline: US EPA

Document Number: TUT-008-0519 To 0576	Date: 03/12/96

Title: (Lettere 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 Feasibility Study Correspondence

Author:	D'Anna, Nancy: attorney
Recipient: Kwan, 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 Feasibility Study Correspondence
Author: Bierschenck, John, P.E.: ENSR
Butler, Eric, Ph.D.: ENSR
Galya, Donald P., P.E.: ENSR
Recipient: Kwan, Caroline: US EPA

Document Number: TUT-008-0513 To 0516	Date: 03/13/96

Title: (Letter regarding comments 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: Kwan, Caroline: US EPA

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APPENDIX IV

TERRITORIAL IJ3TTER OF CONCURRENCE



July 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.

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APPENDIX V

RESPONSIVENESS SUMMARY
ATTACHMENT A

LETTERS SUBMITTED DURING THE PUBLIC COMMENT PERIOD

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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 stripper,
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 (LWVVI), 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
! Remaining Concerns

! Attachment: Community Relations Activities at the Tutu

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:

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(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 Prosposed 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 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:

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! 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 0'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 guestions 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 technigues 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 guestions or reguest 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 guestions 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

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TAG process. Applications were available during these meetings also. Additional applications
for a TAG are still available from EPA, upon reguest.

Extent of Contamination

(1) The community would like a general guantification of the amount of contamination found at
the Tutu site.

EPA Response: EPA has placed monitoring wells throughout the Tutu site to guantify 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 aguifer. 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 guarts 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

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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 aguifer 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 technigues 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 form 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 aguifer 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

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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 designed 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 0'Henry 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 LWWI 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 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

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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 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

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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 0'Henry,

Texaco, or the Curriculum Center, so Esso's SSLs were applied to Western Auto. It
should be noted that the SSLs for 0'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 inadeguate 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 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 reguiring Four Winds to investigate the pipe for leaks
using inline survey technigues and to repair any significant ruptures identified during
remediation. Groundwater downgradient of Four Winds will be monitored during the implementation
of the Tutu aguifer 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

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(1)	Both Western Auto and 0'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 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)	0'Henry states that since the gasoline additive, MTBE, can be traced from Texaco and Esso
as far downgradient as the Delegrade well, that Esso must be considered a source of impact to
groundwater all the way to the Delegarde well. Furthermore, 0'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 it.

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 ugradient 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.

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. O'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

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distribution does not take into consideration the effects of pumping the Elgin 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 Elgin wells, which would partially draw O'Henry
VOCs toward the east. Also, impacts on flow fields from pumping at the Smith and LaPlace wells
need to be 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

(1) O'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 adeguate placement of extraction wells to capture the contamination in the
Tutu aguifer.

Presence of DNAPLs at O'Henry

(1) O'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 O'Henry 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 inthe 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

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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 aguifer restoration in the vicinity. If it is present, a technical
impracticability waiver for ARARs achievement may ultimately be reguired, because such
groundwater cleanup objectives might not be achievable.

Proposed Soil Remedy for 0'Henry

(1) 0'Henry protested the proposed remedy of excavation and soil vapor extraction, stating that
remediation has already occurred at 0'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 0'Henry were excavated before EPA had finalized their vadose zone
modeling to determine soil cleanup levels that would be protective of groundwater. 0'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 wall 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 reguire
remediation.

EPA's selected remedy does not call for any further excavation at 0'Henry 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 Aguifer

(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 aguifer 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 aguifer 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?

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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 freguent or less freguent testing is warranted.

! 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.

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ATTACHMENT A

COMMUNITY RELATIONS ACTIVITIES
AT THE TUTU WELLFIELD SUPERFUND SITE

Community relations activities conducted at the Tutu Wellfield Superfund Site have included:

! EPA conducted community interview 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 reguests from the public
(October 1994)

! 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 guestion 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

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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.

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TWO THOUSAND WESTCHESTER AVENUE
WHITE PLAINS, N.Y. 10650

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 VOC >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.

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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.

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ENSR Ref. No: 7218-001
ENSR Doc. No: 55-DPG-552

Ms Caroline Kwan

Emergency and Remedial Response Division
U.S. Environmental Protection Agency
2 6 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 reguest 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 1.2x10 9 (see enclosed Stephens and Associates report). The very low hydraulic
conductivity and the continuous extent of this clay layer creates a condition unlike that
elsewhere in Tutu Valley. These geologic conditions effectively isolate the overlying alluvial
material from the groundwater. Since the intext of the SSL values is apparently to provide soil
cleanup values that are protective of groundwater and appropriate for site specific conditions,
it is clear that the Esso Tutu SSL values are inappropriate for Western Auto. Site-specific
cleanup values that consider the extremely low transport in the clay layer at Western Auto
should be calculated.



! SSL values for benzene should not be applied for 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 SSI values derived for
benzene for the other BTEX parameters (toluene, ethylbenzene, and xylenes) is inappropriate
and overly conservative.

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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 with 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 cleanup
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
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.

The "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.

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The 35 cubic yard value is apparently incorrect. During soil removal associated with 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 25 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 clear 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 pope and the former Western
Auto USTs."



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 is the most appropriate soil remediation technigue for Western Auto.

Section 4.6.2.5 discusses the two retained Western Auto soil remediation options, capping.

Table 5-4 sets forth estimated capital costs for capping 117 sguare 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 clay 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 sguare 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 upgradient under the Four Winds
building.

On page 2-18, paragraph 2 of the final FS it is stated that" ...at the Four Winds Plaza,

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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 indicated the presence of heavy range petroleum hydrocarbons under the building,
with the highest concentrations centered under the Cost-U-Less store. The maximum concentration
of C18 compounds in the Gore-Sorber study was 2.2 y.g/sorber, while the highest concentration of
tridecane was 1.0 - 1.2 y.g/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 as tridecane)and thus are
less amenable to soil vapor detection. Based on this, it is expected 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 UST location. This petroleum contamination
was apparently transported into the former UST location via the 4-inch PVC pipe and the graval
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 Aguifer.

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 Aguifer. 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 9, 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 clean soil. Geraghty and Miller removed additional soil during the
installation of MW-24.

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In addition, it should be noted that the most significant contamination concern at the Tutu site
is the chlorinated VOC contamination of groundwater. Essentially all 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 feel free to
contact us with any questions that you may have on our comments.

Sincerely,

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ENSR Ref. No: 7218-001
ENSR Doc. No: 55-DPG-553

Ms. Caroline Kwan

Emergency and Remedial Response Division
U.S. Environmental Protection Agency
2 6 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 reguest 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-1
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 gydraulic conductivity value for well
SW-7 is given. Finally, the data and analyses by which the hydraulic conductivity values were
derived are not presented.



! The calculated groundwater velocity is not supported by adeguate 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 prosity to calculate groundwater
velocity in a fractured bedrock system assumes that an eguivalent 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
aguifer.

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! 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-8, 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
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 primarily because the analysis does not consider the
overall decrease or downward gradient in chlorinated VOCs in the Tutu aguifer. 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 aguifer 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 RI at wells MW-1 (near Laga), 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-1 and MW-7, MW-1 and MW-8, and MW-7 and
MW-8 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-8 to MW-10, 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

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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 RI) for well MW-7, which is the nearest well
upgradient of the Four Winds wells, values of 38.6%, 8.0%, 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 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 guestions that you may have on these comments.

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NANCY D' ANNA
ATTORNEY AT LAW

P.O. BOX 8330, CRUZ EAY
ST. JOHN, U.S. VIRGIN ISLANDS 00831

(809) 776-6533 FAX (809) 776-6260

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
Remediation", Tutu Well Site, St. Thomas,

Virgin Islands

Dear Ms. Kwan:

Enclosed are three copies of the comments prepared
documents. These comments are provided on behalf of my
are being transmitted to counsel for the members of the
Parties. Please feel free to contact my office, if you
matter.



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 Tutu 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 Unites 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 foregoing 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.

Plan for

by my office on the above referenced
client, L'Henri, Inc. These comments
group of Potentially Responsible
have any guestions concerning this

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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
groudwater 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 groundwater, 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 TCE, 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, pas 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

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conclusion is supported by the actual data collected during the soil remediation conducted by
L'Henri, Inc. at the 0'Henry store. The actual soil data collected demonstrates that chlorinated
contamination is not present at a depth below six feet at 0'Henry. Further, the presence of
DNAPL at the site has been assumed based on the presence of PCE in 0HMW4, a well which is
located side gradient, and not down gradient from 0'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 0'Henry Dry Cleaners.

The soil remediation alternatives provided in the proposed action plan do not take into
consideration that remediation has already occurred at 0'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 0'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 aguifer after the hurricane. Conseguently, 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 reguired to restore the aguifer 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.

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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 aguifer 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
aguifer 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

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problem. We would welcome any suggestions you may have and look forward to working with you in
the future.

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Ms. Caroline Kwan

New York/Caribbean Superfund Section
U.S. Environmental Agency Region II
290 Broadway, 20th Floor
New York, NY 10007-1866

Transmittal of Comments and Concerns Related to
Calculated Site Specific Soil Cleanup Standard for the
0'Henry 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, July 1995, Final Report, Estimation of Soil
Cleanup Concentrations Reguired 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,
Esg. from Carole Peterson received July 27, 1995, and in Geraghty 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 reguest filed by Nancy D'Anna, Esg. IT Corporation (IT) at the reguest 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 guestion 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 Corporation is a
wholly owned subsidiary of International Technology Corporation calculate the appropriate site
specific soil cleanup standard (IT, 1994, Work Plan for evaluation and Interim Remediation of
Soils, 0 'Henry Laundry, Tutu, St. Thomas, U.S.V.I.) and as pointed out in Section 3.4 of IT,
1995, Soil Remediation Report O'Henry Laundry, Tutu, St. Thomas, U.S.V.I. (Revision 1), use of
the site Specific Foe in the model would lead to a higher soil cleanup standard than that
presented in 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:

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INTERNATIONAL TECHNOLOGY CORPORATION

Ms. Caroline Kwan	December 20, 1995

!	A composite soil profile generated by CDM Federal for the 0'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 0'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 are 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 0'Henry site.

This parameter is used in the calculation of the dilution factor. A resulting
dilution factor of 0.04 was subseguently used for the calculations of the target
soil leachate concentration of <132 y.g/L for the acceptable groundwater MCL of <5
y.g/L. During soil remediation activities conducted in March 1995 at the 0'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 addition, a lower
source length results in a lower leachate flux rate of 5.025 ft3/yr instead of the
flux rate of 10.05 ft3/yr used by CDM Federal in the soft leaching model.

!	The allowable contaminant concentration in soft was calculated by CDM Federal using

an foe value of 0.006 in soils above 1.6 feet and an assumed foe value of 0.0002.

CDM Federal cover letter to the EPA which accompanies the CDM Federal, July 1995,
report acknowledges that the model results are very sensitive to the input value for
organic carbon content of the soils and states "This represents a significant
uncertainty in the model results. CDM Federal recommends that the soil cleanup
goals calculated here be recalculated if additional site-specific data becomes
available and revised if necessary at that time." The foe obtained by IT for soils
at a depth of 5-6 feet at the 0'Henry site indicate that foe is 0.008. Therefore,
it is appropriate that the soil cleanup concentration be recalculated.

Using the Soil Screening framework as described or, page 2-22 of EPA, December 1994, the
simple site specific soil screening level (SSL) is backcalculated from acceptable groundwater
concentrations. First the acceptable groundwater concentration is multiplied by the dilution
factor to obtain the target leachate concentration. The partition eguation is then used to
calculate the eguilibrium soil concentration corresponding to this soil leachate concentration.

Using this simple methodology (ignoring chemical degradation) and using the site specific
parameters as described above for PCE at the 0'Henry site yields the following:

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! Allowable groundwater concentration is 4.9 mg/1 (i.e., <5mg/l), the site-specific dilution
factor is 1/0.02 therefore the allowable leachate concentration is 245 mg/1

! Kd is calculated to be 2.18 (foe assumed to be 0.006) for soils above 1.6 feet and 2.91
(foe assumed to be 0.008) for soils below 1.6 feet, therefore the allowable soil
concentration is calculated to be 534 mg/kg for soils above 1.6 feet and 713 mg/kg for
soil below 1.6 feet. (Note that recalculated values through the CDM Federal spreadsheet
accounting for biodegradation should result in higher allowable soil concentrations than
those presented here).

The site specific soil cleanup standards for the 0'Henry site were calculated by CDM Federal
based on the assumption that soil remediation activities had not been performed. Soil
remediation was conducted in March, 1995 for the 0'Henry site. Soil left in place is
represented by two distinct profiles; soil left in place at the excavation base overlain by
clean backfill material and soil beneath the concrete area on the northern excavation wall IT
has presented an evaluation of impact to groundwater of the soils left in place in the revised
Soil Remediation Report (IT, August, 1995) using the VLEACH model. This evaluation indicates
soil left at the site will not impact groundwater to greater than the MCL for PCE.

IT, therefore, reguests that EPA review the method currently used to calculate the site specific
soil cleanup standards for the 0'Henry site and revise these standards based on the comments
presented here.

If you have any guestions regarding these comments, please contact L'Henri Inc., Counsel Nancy
D'Anna, Esg. at (809) 776-6533 or me at (423) 690-3211. Additionally, please note the change
of area code for east Tennessee.



IT Corporation is a wholly owned subsidiary of International Technology Corporation

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TECHNICAL REVIEW COMMENTS
SOIL REMEDIATION REPORT FOR
0'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 for the 0'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/I.
These cleanup goals are developed from unsaturated zone calculations that take Into account
Infiltration of precipitation. PCE adsorption-desorption from site soils, anaerobic
biodegradation 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 does not take into account all site specific data
available. Further, IT cannot verify the results of EPA modeling presented for the 0'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 me 0'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 distract PCE soil concentration profiles.

Profile 1: Soils left in place at the excavation base overlain by clean backfill material
brought from offsite. 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 I (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

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within the vadose zone using a finite difference method. The modeling 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 0'Henry is predominantly sandy silt with clay soil.
Dry, bulk density = 1.53 g/mL
Volumetric water content = 0.3

Other revised input parameters included:

!	Hydraulic gradient =0.073 ft/ft (EPA Final Report, Estimation of Soil Cleanup

Concentrations Reguired to Protect Groundwater as a Source of Drinking Water,
Tutu Wells Site, USVI, 1995)

!	Organic Carbon Partition Coefficient (Koc)=364 mg/1 EPA, 1995)

!	Soil organic carbon fraction (foc)= 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 VLEACH
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 aguifer
directly below the contaminated vadose zone. The mixing model assumes complete mixing in the
water column.

PCE concentrations in groundwater [M]pcegw was calculated using:

[M]PCEGW= [M]PCELeachate/year

Volume of water flowing through unit width per year

Where water volume =nxtxLxW

n = porosity = 0.4

t =	aguifer thickness = 10 ft

L =	flow velocity using a hydraulic conductivity of 1.5 ft/day

and hydraulic gradient of 0.073
W = A unit cross-sectional width

Water volume = 0.4 x 10 ftx 42.37 ft/year x 1 ft = 169.5 ~/year
=	169.5 ft3/year

=	4796 liters/year.

The incremental increase in PCE concentrations in groundwater for the 0'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 0'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 confirmatory laboratory. Analyses of samples were

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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 guestion 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 (EXS05, EXS26, EXS27, and EXS35). Of these samples, there
was only one sample (EXS27) where the IT laboratory results was more than double the field GC
result (195 y.g/kg from field GC and 850 y.g/kg from IT laboratory) . For this sample, a
duplicate analysis was performed. The result (570 y.g/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.

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Comment 3: High concentrations of 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 0'Henry building.

Response:	We agree that field GC and confirmation samples indicate that soil with

concentrations above the provisional cleanup level of 200 y.g/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 1.1.2, page 1-2 and 1-3. The provisional level or 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 ft (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 or these samples underwent analysis. The text here and on page 3-3 should clarify the
depth interval sampled and that only sample LH01 and its duplicate were analyzed.

Response:	We agree; two samples (i.e., one sample LH01 and its duplicate LH02) 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.

Comment 4: Section 2.2, 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.

Response: We agree. The text will be revised accordingly.

Comment 5: Section 2,6, page 2-6. The text indicates that a PID was not available during
installation of boring ITSB-01. Presumably the PID 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.

Response: Table 3 summarizes PID readings taken during soil remediation activities PID
readings will be included in the report.

Comment 6: 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

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revised to discuss how large this estimated result could potentially be.

Response: 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.

Comment 7: 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 residual contaminants at these
sample sites (and others exceeding the cleanup goals) to serve as ongoing sources of groundwater
contamination.

Response: See response to General Comment No. 1.

Comment 8: 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.

Response:	Explanation of data qualifiers will be added to the text.

Comment 9:	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.

Response: See response to General Comment No. 2.

Comment 10: 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 0'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.

Response: Section 3.3, page 3-3 on geotechnical testing incorrectly reports the results of
ASTM D-2974 as fraction 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 the fraction of organic carbon by
dividing by 1.724 (Dragun, J. 1988). Following this approach, and using the average fraction

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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 0'Henry site has been removed.

Response: See response to General Comment No. 3.

Comment 12: Section 5.0, page 5-1, second bullet. The argument that the average PCE
concentration is soils is nearly egual to the provisional cleanup level, when the reported PCE
concentrations are as much as five times greater than the provisional level, is not valid. The
text must be revised.

Response: We agree. See response to General Comment No. 1.

Comment 13: Section 5.0, page 5-1, second bullet, final sentence. The report states that, due
to the distance to the water table (approximately 16 feet), PCE concentrations much greater than
200 ug/kg would be needed to result in detectable concentrations of PCE in groundwater. Based
on EPA's soil leaching modeling, this statement is not true. Attached is a new soil profile
constructed for the 0'Henry property using the maximum residual contamination remaining at each
depth in soils, post-excavation, as reported in the IT soil removal report. The site-wide
values for infiltration, Kd and biodegradation were used. The corresponding contaminant
breakthrough curve indicates that leaching of these soils will result in concentrations of PCE
in groundwater of approximately 30 ug/1 In the future, well above the drinking water standard of
5 ug/1.

The EPA mode/assumes a low organic carbon content in the deeper soil horizon, but allows for
anaerobic biodegradation of PCE throughout the soil column. The modeling indicated that almost
no compound attenuation occurs in the deeper zone, due to the low organic carbon content and
biodegradation 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 unattenuated to the water table, regardless of the distance of the source from
groundwater. The text should remove this statement.

Response:	Please see response to General Comment No. 1.

Comment 14: Section 5.0, page 5-2. 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

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concentrations in boring ITSB-01 appears representative of the depth profile of PCE
concentration in soil in the excavation area. PCE which may have 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 for preferred contaminant migration (soils are uniform) the
contaminant profile in boring ITSB-01 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 5-2, 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 soil remedial action is reguired. 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.

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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, U.S. 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 0'Henry Laundry,
Tutu, St. Thomas, U.S. Virgin Islands.

IT Corporation, 1995, Soil Remediation Report, O'Henry Laundry, Tutu, St. Thomas, U.S. Virgin
Islands.

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Table 1

Concentration Profiles Used in the Model

O'Henry Laundry, St. Thomas, U.S.	Virgin Islands

Concentration Profile Depth Interval	PCE Concentration

No. (ft)	(ppb)

1	0 - 8.25	0
8.25 - 10	170

2	0-3	38
3-5	560
5-10	1100

Table 2

Highest Groundwater PCE Concentrations
O'Henry Laundry
St. Thomas, U.S. Virgin Islands

Concentration
Profile
No.

(Refer Table 1)

Highest Groundwater
PCE Concentration
(Ug/L)

Time for Peak Impact
(Years)

Beneath Excavated
Area

0.026

76

Beneath Paved
Concrete Area

2

0.44

90

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Table 3

Summary of Organic Vapor Readings
O'Henry Laundry
St. Thomas, U.S. Virgin Islands

PID Reading

Sample No.	(ppm)

EXS06	2

EXS07	0.1

EXS08	22

EXS09	34
EXS10 0.2

EXS11	0.25

EXS12	0.5

EXS13	1.8

EXS14	1.8

EXS15	0.1

EXS16	0.3

EXS17	0.5

EXS18	1.0

EXS19	0

EXS20	0

EXS21	0.5

EXS22	1.0

ESX23	2.0

EXS24	1.0

EXS25	4.0

EXS2 6	1.5

EXS27	1.5

EXS28	11.0

EXS29	3.0

EXS30	3.0

EXS31	7.5

EXS32	1.0

EXS33	4.0

EXS34	2.0

EXS35	0.5

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Table 4

A Comparison of PCE Results (|lg/kg)

Sample Number	Field GC	IT Laboratory	EPA Laboratory

ITSB-01-05.0

237.69a

120



ITSB-01-10.0

12.38

2 J



ITSB-01-14.5

4.33/4.98

11 U



EXS01

214.40

140D



EXS02

197.26

120



EXS03

181.34

54



EXS04

324.09

100 D



EXS05

83.85

100



EXS23

275.38

290 D

100 J

EX24

57.80

21

2 J

EXS25

173.90

190

210 J

EXS2 6

220.33

300 D



EXS27

195.14

850 D/570 D



EXS28

242.71

210 D

220 J

EXS29

171.48

150 D



EXS30

155.45

1100

480 J

EXS31

169.41

560 D

630 J

EXS32

63. 61

38

34 J

EXS33

15.17

31

30 J

EXS34

74.60

170

30 J

EXS35

109.65

160



a Highlighting indicates which analytical method yielded the highest concentration for each
sample.

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SENT BY: I.T. CORP KNOXVILLE : 3- 7-96 : 2:07PM : 1.1

Comments on Geraghty and Miller, Inc. 1995,

Draft Feasibility Study Tutu Wells Site,

St. Thomas, U.S. Virgin Islands

Section 2.1.1.3. Groundwater flow direction is still not sufficiently well understood in the
deep bedrock aguifer 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 1,000 ft x 1,500 feet. Groundwater contours representing deep
bedrock groundwater flow beneath the follow properties should be dashed: 0'Henry laundry,

Liguor Barn, 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 feet intervals). It is not appropriate to use the 5 foot
contour intervals. In addition, the Graves and Gonzales map uses "dashed" (indicating
approximately located) and "gueried" (indicating uncertain) contours over much of the area and
particularly the area to the south and southeast of the 0'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-unigue 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 originates 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 OHMB-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 guestionable. The use of a centralized groundwater
treatment system will reguire piping from one end of the Tutu area to the other with associated
problems due to the hilly nature of the site. This brings up guestions of access, liability if
pipes leak or are damaged, and maintenance. Likewise, future liability is a potential issue of
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?

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SENT BY: I.T. CORP KNOXVILLE : 3- 7-96 : 2:07PM : 1.1

Section 4.5. The following activities are recommended to be included in the pre-design
activities (and costs):

Pre-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 the 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 using 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 DNAPL do not appear to be consistent with the
contaminant plumes drawn. For the area drawn near the 0'Henry Dry Cleaners, the DNAPL plume
extends outside the 10 ppb "total VOCs" contour. Please explain rationale for the extent of the
suspected DNAPL 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.

Comments on Cost Estimates Provided. Note that a detailed review was performed of cost
estimates for SWRA 4 (Table 4.9) because this was the (assumed) preferred alternative. Comments
on this cost estimate are also applicable to other cost estimates.

The following are comments on the Groundwater Treatment Capital Cost:

The unit cost for Deed 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 the cost include work plan and reporting requirements?

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SENT BY: I.T. CORP KNOXVILLE : 3- 7-96 : 2:07PM : 1.1

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 filling for underground piping
installation for piping to the centralized treatment system? If so, how will leak
detection be accomplished?

What is included in Pre-Treatment? 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 pre-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 Above ground Storage Tank? Does the unit cost
include shipping and installation?

Make sure that the cost for the Treatment Building includes cost for a foundation.

Is electric for just the central treatment system or for the recovery well sites also?

Each of the POET systems may need individual design. For example they may need
individual design for electrical work and housing.

The following are 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 the 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
the other sites? Detail should be provided for each site such as size of the vacuum
blower, number of extraction wells, piping wells, treatment of condensate, and
installation cost.

Does Engineering include detailed design, material balance, drawings, and
preparation of specifications and bid packages?

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SENT BY: I.T. CORP KNOXVILLE : 3- 7-96 : 2:07PM : 1.1

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 it include recovery wells also?

Does the cost for carbon replacement include the disposal of spent carbon?

Does Treatment System Monitoring include both air and water sampling (influent
and effluent)? What will they be analyzed for? 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 Eguipment Replacement include installation cost?

In addition the following observations are made concerning the cost buildup:

Pre-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.

Demobilization and decommissioning of recovery wells, SVE systems and the
groundwater treatment plant should be included. In addition, closure and post-
closure activities should be included in the cost.

Cost should be included for air emissions evaluation and permit application.

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Comments

Final Remedial Investigation (RI) Report
Tutu Wells Site., Tutu, St. Thomas
Report Prepared by Geraghty and Miller (April 19953
Comments by IT Corporation for L'Henry Inc. (June 7 1995).

GENERAL COMMENTS

1.	Deep groundwater flow in the area around and hydrogeologically downgradient of the

0'Henry Dry cleaners is inconsistent between the two groundwater flow maps presented.

The deep groundwater elevation contour maps presented in the RI are inconsistent with
each other for the area around and hydrogeologically downgradient of 0'Henry Dry
Cleaners. The May 10, 1994 groundwater flow map is the most appropriate because the
map includes data from wells Steele, Harvey, Eglin II and Eglin III (wells that are in the
immediate vicinity of the 0'Henry facility) which are not included on the May 23-24,
1994 map. Groundwater data from these wells indicate a groundwater "high" extending
from Eglin I to Steele which approximately coincides with the topographic high (this is
missing on the May 23-24 map). From the Eglin well area, groundwater and conseguently
contaminants would move to the southwest (beneath the 0'Henry Dry Cleaners), south
(toward the Steele well) and southeast (toward the LaPlace well). Data from the Geraghty
and Miller pump test at Eglin indicate a preferential flow path southeast from Elgin
(interpreted as fracture flow). In addition, shallow groundwater flow supports a local
southwesterly flow direction in the immediate vicinity of 0'Henry (in general shallow and
deep groundwater flow would be expected to be similar.)

2.	Presentation of individual chemical compound plumes (specifically chlorinated solvents)
are not consistent with groundwater flow maps in the area around and hydrogeologically
downgradient of the 0'Henry Dry Cleaners.

This is the first time individual compound plume maps have been presented for
Tetrachloroethene (PCE), trichloroethene (TCE), 1,2-Dichloroethene (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 aud 1,2-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 RI. To develop more defensible
plume maps for these compounds, flow lines were drawn on figures 4-12 and 4-13
(attached). Then flow 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 (figure 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 were transferred to the plume maps and
the plumes redrawn 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 Eglin
well to the LaPlace well as reflective of the divergent groundwater flow. Further it

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should be noted that no groundwater elevation data is available south of MW-22D therefore
the plume is conjectural downgradient 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 VOC plumes in groundwater

The RI states that there are two plumes 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 VOCs or for the
individual compounds. The contaminant maps for PCE are the most appropriate to discuss
the extent of contamination in the Tutu area. 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 pattern 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 wells which is nearly impossible when considering the
flow 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
are presented on page 5-33 of the Final RI. These criteria are as follows:

!	"If impact to soil at a property was established based on the NYS TAGM values,

and similar constituents were found in the groundwater 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 in groundwater at concentrations in excess of

1 percent of their aqueous solubility at a property, these detections were viewed as
an indication of the possible presence of nonaqueous phase liquids (NAPLS) in the
unsaturated or saturated zone. The property was therefore considered to represent
a source of impact to groundwater."

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
0'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 0'Henry facility. Since
MTBE is a compound which moves quickly with the groundwater, it can be considered

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as 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) from Esso to the south. Since MTBE did not originate at the
0'Henry Dry Cleaner and MTBE is found in drinking water supply wells Eglin I, Eglin
III, 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 inadeguate evaluation of the sanitary sewer system as a source of
contamination.

The RI inadeguately 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 VOCs detected in the storm sewer at the Esso station is attributed in the RI
to infiltrating groundwater because Blasland, Bouck and Lec (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 0'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 Geraghty 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 Cat laundry). The Tom Cat Laundry uses water
from the Eglin supply wells in its machines without prior treatment therefore the
water entering the sewer (and therefore sampled by ADL) is effectively Eglin well
water.

6.	Misinterpretation of O'Henry Dry Cleaners as one of the main source areas for the
southern plume.

The RI claims that O'Henry Dry Cleaners is "the main" and "the principal source of the
southern chlorinated plume". The basis for 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 groundwater in the vicinity of O'Henry may have

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originated at any source upgradient. The presence of elevated VOCs does not
logically lead to the conclusion that the property is a source.

! Consideration of the groundwater flow maps together with contaminant concentration
maps indicate that it is unlikely that contaminants entering the groundwater at
0'Henry have contaminated the Steele, LaPlace, Smith, Mathias and Delegarde wells.

! Data recently obtained during the soil removal action at the 0'Henry Dry Cleaners
confirm that no DNAPL 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 DNAPL evaluation.

The Final RI discussion of the likely presence of DNAPL indicates a high probability of
DNAPL release at the 0'Henry Dry Cleaner based on the historical use of PCE as a
dry cleaning solvent using the criteria set forth in EPA 1992b. This is inappropriate use
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 0'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 0'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 0'Henry Dry Cleaners is that concentrations of PCE in groundwater samples
from two sampling rounds (between 1987 and 1991) were at levels which exceeded 1
percent of the solubility. This may indicate that free-phase existed before 1991.

However, concentrations of PCE in groundwater samples collected from the Harvey supply
well since 1991 have been much lower, indicating no free-phase since 1991. Therefore
there is no evidence to conclude that PCE is present as a separate phase in groundwater
beneath the 0'Henry Dry Cleaners.

If it is assumed that the criteria provided in the Final RI for determining the high
probability of DNAPL in groundwater is correct then historical data provided for the
Tillet supply well indicate that this area should also be identified as an area suspected
to contain DNAPL in the saturated zone.

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