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J^GERAGHTY . <S? .MILLER, INC. Environmental Services Ground Water Engineering Hydrocarbon Remediation Education November 22, 1994 Ms. Caroline Kwan, Project Manager USEPA Region II 26 Federal Plaza, Room 737 New York, NY 10278 Re: Sampling Procedures and Waste-Classification Analytical Results of Drill Cuttings, Tutu Wells Site, St. Thomas, U.S. Virgin Islands Dear Ms. Kwan: On behalf of de maximis, inc., Designated Coordinator for the Tutu Environmental Investigation Committee (TEIC), Geraghty & Miller, Inc. has prepared this submittal regarding sampling of drill cuttings from the Phase II Remedial Investigation (RI) on June 29, 1994 from the Tutu Wells Site, St. Thomas, U.S. Virgin Islands. The analytical parameters included USEPA Toxicity Characteristic Leachate Procedure (TCLP) and Resource Conservation and Recovery Act (RCRA) waste characteristic parameters (e.g., ignitability and corrosivity). Two composite samples of the drilling material were collected, with each sample representing one-half of the total material (approximately 60 drums). Each sample was retrieved with a stainless steel spoon and placed in a stainless steel bowl. After collecting a representative portion, the material was mixed in the bowl and immediately transferred to the sample containers. As shown on the accompanying tables, all analytical results were below method detection limits with the exception of cadmium at 0.011 parts per million (ppm) in sample DS-2. This value is well below the TCLP regulatory limit of 1 ppm (40 CFR Part 261). No other TCLP parameters were detected. The results for other waste characteristic parameters were also indicative of non-hazardous material. The material was non-ignitable and the corrosivity was within the non-hazardous range of between 2 to 12.5 pH units. Reactive cyanide and reactive sulfide were below the method detection limits. Therefore, the drill cuttings are classified as non-hazardous. TUT OO6 O5&4 201 West Passaic Street, 3rd Floor • Rochelle Park, New Jersey 07662-(201) 909-0700* FAX (201) 909-0567/0568 *64622* 64622 GERAGHTY & MILLER. INC. Since this material is non-hazardous, it should be disposed of as a non-hazardous solid waste. The TEIC will coordinate the proper disposal of this non-hazardous solid waste with the USEPA and Virgin Islands Department of Planning and Natural Resources. Your assistance would be greatly appreciated. If you have any questions, please call. Sincerely, GERAGHTY & MILLER, INC. Thomas V Danghy (/ SenieHSclentist/Project Manager Daniel Nachman Vice President/Project Officer c: Geoff Siebel, de maximis, inc. Paul Ryan, Texaco Leonard Reed, DPNR Adrian Schotroff, DPNR g:\JVrqecU\tutu\prfXM3.03g\corrcsp\kwanl 107. Itr TUT O06 O565 Table 2. Concentrations of Toxicity Characteristic Leaching Procedure Base Neutral and Acid Extractable Organic Compounds in Composite Drum Samples Collected in June 1994 at the Tutu Wells Site, St. Thomas, U.S. Virgin Islands.__________________________________________________________________ Sample ID: DS-I DS-2 Analyle Date: 29-Jun 94 29-]un-94 m Si p Cresol(s) o-Crcsol 1 ,4-Dichlorobenzene 2,4-Dinitrotoluene Hexachlorobenzene Hexochlorohutadicne Hexachloroethane Nitrobenzene Pcnlachlorophcnol Pyridine 2,4,5-Trichlorophenol 2 ,4 ,6-Tr ichlorophenol 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.25 U 0.1 U 0.25 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 005U 0.05 U 0.05 U 0.25 U 0.1 U 0.25 U 0.05 U Analyte concentrations in milligrams per liter (parts per million (ppm)). Analyses were performed by Enseco- East of Somerset, New Jersey, using USEPA Method 8270 and Toxicity Characteristic Leaching Procedure. U The compound was analyzed for, but not detected at the corresponding reporting limits. Cr- GERAGHTY<*MILI.i :.R.INC Table 3. Concentrations of Toxicity Characteristic Leaching Procedure Pesticides and Herbicides in Composite Drum Samples Collected in June 1994 at the Tutu Wells Site, St. Thomas, U.S. Virgin Islands. Simple ID: DS-I DS-2 Analyte Dale: 29-Jun-94 29-Jun-94 gnmma-BHC (Lindane) Chlordane Endrin Meptachlor (and its epoxide) Methoxychlor Toxaphene 2.4D 2,4,5-TP(Silvex) 0.0005 U O.OOSU 0.001 U 0.0005 U O.OOSU 0.05 U O.OOSU 0.001 U 0.0005 U O.OOSU 0.001 U 0.0005 U O.OOSU 0.05 U O.OOSU 0.001 U Analyte concentrations in milligrams per liter (parts per million Ippm]). Analyses were performed by Enseco- East of Somerset, New Jersey, using standard U.S. Environmental Protection Agency methodology and Toxicity Characteristic Leaching Procedure. U The compound was analyzed for, but not detected at the corresponding reporting limits. C —i GERAGHTY c* MII.LHR. INC Table 4. Concentrations of Toxicity Characteristic Leaching Procedure Metals in Composite Drum Samples Collected in June 1994 at the Tutu Wells Site, St. Thomas, U.S. Virgin Islands. Sample ID: DS-I DS-2 Analyte Date: 29-Jun-94 29-Jun-94 Arsenic Barium Cadmium Chromium Lead Mercury Selenium Silver 0.1U 1 U 0.005 U 0.01 U 0.05 U 0.0002 U 0.2 U 0.01 U 0.1 U IU 0.005 U 0011 0.05 U 0.0002 U 0.2 U 0.01 U Analyte concentrations in milligrams per liter (parts per million [ppm]). Analyses were performed by Enseco- East of Somerset, New Jersey, using standard U.S. Environmental Protection Agency methodology and Toxicity Characteristic Leaching Procedure. U The analytc was analyzed for, but not detected at the corresponding reporting limits. -i 0- CD GHRAGHTY & MIU.HR. INC Table I. Concentrations of Toxicity Characteristic Leaching Procedure Volatile Organic Compounds in Composite Drum Samples Collected in June 1994 at the Tutu Wells Site, It Thnmai 11 $ Viroin lelanHi St. Thomas, U.S. Virgin Islands. Simple ID: DS-1 DS-2 Analylc Dale: 29-Jun-94 29-Jun 94 Benzene Carbon tetrachloride Chlorobenzene Chloroform 1 ,2-Dichloroethane 1,1-Dichloroethene 2-Butanone Tetrachlorocthene Trichloroethene Vinyl chloride 0.12 U 0.12U 0.12 U O.I2U 0.12U 0.12U 0.25 U 0.12U 0.12U 0.25 U 0.12 U O.I2U 0.12 U 0.12 U O.I2U 0.12U 0.25 U O.I2U 0.12U 0.25 U Analyte concentrations in milligrams per liter (parts per million [ppm]). Analyses were performed by Enscco- East of Somerset, New Jersey, using USEPA Method 8240 and Toxicity Characteristic Leaching Procedure. U The compound was analyzed for, but not detected at the corresponding reporting limits. HaH GERAGHTY & MII.I.HR. INC