Letter regarding Request for Waste Classification and Permission for Disposal
& MILLER, INC. Environmental Services Ground Water Engineering Hydrocarbon Remediation Education May 19, 1993 Mr. Leonard Reed U.S. Virgin Islands Department of Planning and Natural Resources Nisky Center 8000, Suite 45 St. Thomas, U.S. Virgin Islands 00802 Re: Request for Waste Classification and Permission for Disposal Dear Mr. Reed: Pursuant to our recent telephone conversation and as a followup to my facsimile, enclosed is a copy of the March 2, 1993 letter to Caroline Kwan of the U.S. Environmental Protection Agency (USEPA). This letter describes the sampling procedures and results for the drilling cuttings from the Tutu Service Station Investigation. Geraghty & Miller believes this drilling material (which consists of soil and rock cuttings) should be classified as a non-hazardous solid waste because the Toxicity Characteristic Leachate Procedure (TCLP) and Resource Conservation and Recovery Act (RCRA) waste characteristic parameters were below limits for hazardous waste and within the limits of non-hazardous material. …
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& MILLER, INC. Environmental Services Ground Water Engineering Hydrocarbon Remediation Education May 19, 1993 Mr. Leonard Reed U.S. Virgin Islands Department of Planning and Natural Resources Nisky Center 8000, Suite 45 St. Thomas, U.S. Virgin Islands 00802 Re: Request for Waste Classification and Permission for Disposal Dear Mr. Reed: Pursuant to our recent telephone conversation and as a followup to my facsimile, enclosed is a copy of the March 2, 1993 letter to Caroline Kwan of the U.S. Environmental Protection Agency (USEPA). This letter describes the sampling procedures and results for the drilling cuttings from the Tutu Service Station Investigation. Geraghty & Miller believes this drilling material (which consists of soil and rock cuttings) should be classified as a non-hazardous solid waste because the Toxicity Characteristic Leachate Procedure (TCLP) and Resource Conservation and Recovery Act (RCRA) waste characteristic parameters were below limits for hazardous waste and within the limits of non-hazardous material. As discussed with the USEPA and Clifford Crooke on April 28, 1993, this soil could be useful as daily cover for the Bovoni Landfill. The Tutu Environmental Investigation Committee (TEIC) would like to receive a letter from the Department of Planning and Natural Resources (DPNR) that confirms that this material is non-hazardous. Please direct your response to: Ana Gloria Ramos Designated Coordinator Tutu Environmental Investigation Committee P.O. Box 364269 San Juan, Puerto Rico 00936-4269 TUT 006 146O 201 West Passaic Street, 3rd Floor 'Rochelle Park, New Jersey 07662 • (201) 909-0700 'FAX (201) 909-0567/0568 *64784* 64784 GERAGHTY # MILLER, INC. Based on your response, the TEIC will implement the appropriate handling and disposal of these drilling cuttings. If you require any additional information, please do not hesitate to call. Thank you for your assistance in this matter. Sincerely, GERAGHTY & MILLER, INC. Thomas V. Danahy Daniel A. Nachman Vice President/Project Director c: Caroline Kwan, USEPA Clifford Crooke, DPNR Adrian Shottroff, DPNR PR01301-WP4/S1893.LTR/df TUT OO6 1461