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C O M F E D E R A L P R O G R A M S a s u b s i d i a r y o f C a m p D r e s s e r & M c K e e I n c . June 12, 1992 Ms. Catherine E. Moyik TES V Regional Project Officer U.S. Environmental Protection Agency 26 Federal Plaza Room 737 New York, NY 10278 C O R P O R A T I O N PROJECT: DOCUMENT NO: SUBJECT: Dear Ms. Moyik: TES V, EPA CONTRACT NO: 68-V9-0002 Work Assignment C02048 Tutu Well Field Site St. Thomas, U.S. Virgin Islands TESV-C02048-EP-CMMC Review of Addendum to Technical Memorandum I Tutu Well Field Site Document Control No: TESV-C02048-LR-CMNB Please find enclosed the letter report titled "Review of Addendum to Technical Memorandum I, Tutu Service Station Investigation" for the Tutu Well Field Site, St. Thomas, U.S. Virgin Islands, as partial fulfillment of the reporting requirements for work assignment C02048. If you have any comments regarding this submittal, please contact Sally Odland of COM FPC at (212) 393-9634 within two weeks from the date of this letter. Sincerely, CDM FEDERAL PROGRAMS CORPORATION Scott B. Graber TES V REGIONAL MANAGER Attachment cc: C. Kwan, EPA Work Assignment Manager S. Odland, CDM FPC Work Assignment Manager Document Control, CDM FEDERAL PROGRAMS CORPORATION (2 copies) NYC File TUT O06 1788 ---—•-— j --,——-— 111 Fulton Street, Suite 710 New York, NY 10038 212393-9634 *64893* 64893 REVIEW OF ADDENDUM TO TECHNICAL MEMORANDUM I TUTU SERVICE STATION INVESTIGATION TUTU WELL FIELD SITE ST. THOMAS, U.S. VIRGIN ISLANDS Prepared for U.S. ENVIRONMENTAL PROTECTION AGENCY Office of Waste Programs Enforcement Washington, D.C. 20460 EPA Work Assignment No. EPA Region Site No. Contract No. COM FEDERAL PROGRAMS CORPORATION Document No. Prepared By Work Assignment Project Manager Telephone Number EPA Work Assignment Manager Telephone Number Date Prepared C02048 II 2P1D 68-W9-0002 TESV-C02048-LR-CMNB COM FPC Sally Odland (212) 393-9634 Caroline Kwan (212) 264-0151 June 12, 1992 TUT O06 1789 C O M F E D E R A L P R O G R A M S a s u b s i d i a r y o f C a m p D r e s s e r & M c K e e I n c . June 12, 1992 Ms. Caroline Kwan U.S. Environmental Protection Agency 26 Federal Plaza New York, New York 10278 C O R P O R A T I O N PROJECT: DCN: SUBJECT: TES V, EPA CONTRACT NO: 68-W9-0002 Work Assignment C02048 Tutu Well Field Site St. Thomas, U.S. Virgin Islands TESV-C02048-LR-CMNB Review of Addendum to Technical Memorandum I Tutu Service Station Investigation Dear Ms. Kwan: COM FEDERAL PROGRAMS CORPORATION (COM FPC) has reviewed the Geraghty & Miller's letter entitled "Addendum to Technical Memorandum I, Tutu Service Station Investigation, St. Thomas, Virgin Islands", dated May 19, 1992. As I informed you in our phone conversation on June 9, CDM FPC finds that this addendum adequately reflects the changes to monitoring well locations, methods for split-spoon sampling and analytical parameters for surface soils and drummed waste agreed upon in the technical meeting held between EPA, CDM FPC, the Tutu Environmental Investigation Committee (TEIC), and TEIC's contractors, Geraghty and Miller and Soil Tech and in New York on May 5, 1992. Geraghty and Miller has also provided more details to support the magnetometer survey results in response to our comments on Technical Memorandum I. These responses are also satisfactory for the purposes of the report. Geraghty and Miller did not show the proposed borings or monitoring wells on the magnetic field maps as requested. However, the locations can be figured out by comparing diagrams and CDM FPC does not feel it would be productive at this time to redo the figures since they have served their purpose, which was to determine if proposed drilling locations would interfere with any subsurface structures or utilities. Geraghty and Miller has asked EPA to comment on whether the proposed additional surface soil sampling will be considered satisfactory for a risk -1- 111 Fukon Street. Suite 710 New York. NY 10038 212393-9634 NJT 006 1790 COM FEDERAL PROGRAMS CORPORATION a suosidiary of Camp Dresser & McKee inc Ms. Kwan June 12, 1992 Page Two assessment. Three onsite samples are proposed, collected from probable contaminated areas as determined by soil staining (two at the Curriculum Building and one from boring B-13 at the 0'Henry Cleaners). Two background samples will also be collected. These samples should provide adequate data for a qualitative evaluation of surface soil risk. A quantitative evaluation would require additional samples. However, due to the urban nature of the site, areas of exposed surface soil are sparse, and this exposure pathway will provide negligible risk compared to groundwater. By sampling the potentially worst surface soil areas, EPA will have data representing the highest risk areas. COM FPC believes that a qualitative evaluation of these areas will provide an adequate determination of a risk that is expected to be minimal. However, since EPA or an as yet undesignated contractor will be performing the risk assessment, I suggest you ask EPA's risk assessor, Hark Haddaloni, if he believes a quantitative assessment of surface soil risk will be required by EPA. Sincerely, COM FEDERAL PROGRAMS CORPORATION -S Sally OdlShd Work Assignment Manager -2- TUT 006 1791