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^^^^ir% J- if UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 2 290 BROADWAY [ NEWYORK, NY 10007-1866 i FiU SDMS Document 115620 SEP 26 2001 Federal Express - Return Receipt Requested HoUis Griffin, Director Division of Environmental Protection Department of Planning and Natural Resources Division of Environmental Protection Bldg. Ill-Apt. 14A Water Gut Homes-118 Christiansted, St. Croix USVI 00820-5065 Re: EPA Response to DPNR's Comments on the Record ofDecision for the Virt'in Islands Chemical Superfund Site. St. Croix. USVI Dear Mr. Griffin: Enclosed please find EPA's response to your comments on the Record ofDecision (ROD) for the Virgin Islands Chemical Site dated September 5,2001. I hope the responses will satisfy your concems. We will be sending you a copy ofthe draft Responsiveness Summary very shortly. Sincerely yours, Melvin llauptman, P.E., Leader Sediments/Caribbean Team Enclosiu-e cc: Syed Sydali- DPNR Mike Miner- CDM-FPC Internet Address (URL)« http://www.epa.gov 5 0 0 0 0 1 Recycled/Recyclable . Printed with Vefletable Oil Based Inks on Recycled Paper (Minimum 50% Postconsumer content) 1 • DPNR Comment #1 - ROD-Description of the Selected Remedy/Contingency Remedy (Pages ii-iv, Sections 11.2,11.3) "In the Declaration for Record ofDecision - page iii EPA states: '//i addition to the Selected Remedy, EPA will retain a contingency remedy in the event that an analysis of future groundwater monitoring data indicates that it is needed.' In Section 11.2 Description ofthe Selected Remedy pages 24-25 Additional monitoring wells will be installed to support the long term groundwater monitoring program. For both the Above-ground Storage Tank (AST) and Fonner Process Pit (FPP) areas, additional monitoring wells are planned 'As necessary to support the long term groundwatering (sic) program'. Based on DPNR's previous evaluations of reports comments and communications with EPA, the addition of the Contingency Remedy is one ofthe critical elements for DPNR's final acceptance ofthe ROD. As stated in a prior written communication with EPA, DPNR believes that detailed criteria for evaluating the effectiveness of MNA and implementation ofthe Contingency remedy should be included in the ROD." Response to Comment - The ROD has been revised to include more detailed requirements/criteria for: 1) routinely evaluating the effectiveness of MNA as part of long-term environmental monitoring program and 2) deciding if7when the contingency remedy should be implemented. Such requirements/criteria will conform with EPA's MNA poUcy and guidance and with A Guide to Preparing Superfund Proposed Plans, Records ofDecision, and Other Remedy Selection Decision Documents, Appendix B, Section 4 (entitled "Documenting Remedies Using MNA"). Please also keep in mind that: 1) the detailed requirements and schedule for completion ofthe RD/RA woric will be included in the Consent Decree Statement of Work which is prepared after the ROD is issued and 2) the approval of RD/RA submittals done under the Consent Decree will be made by EPA in consultation with DPNR. 2. DPNR Comment #2 - Purpose of the ROD (p.li) "DPNR is assuming that Section B (not included in docimients supplied for review and comment) will include site characterization data described in item #3, page ii, under Purposes ofthe ROD: ^'Provide ihe public with a consolidated source of information about the history, characteristics and risks " at the site. A list and description of all existing and potential and/or proposed ftiture wells in the sampling program for the AST, FPP and MNA areas, including those "necessary to support the long term groundwatering (sic) program " should also be included in this section. This data has been supplied in previous RQDs reviewed by DPNR." Response to Comment - The main body ofthe ROD is intended to provide a consolidated source of information about the site history, characteristics, and risks. Tables and figures (e.g., fi-om the RJ and FS reports) have been added to the ROD and 500002 referenced in the corresponding text to better illustrate the pertinent site conditions. Appendix B is intended to include the Administrative Record index, which is a Ust ofthe dociunents in the administrative record that were considered in reaching the decision and are available to the pubhc for review. The administrative record is maintained locally in the document repository at Department of Education's Curriculum Center and at your office. Regarding the long-term monitoring program, some additional, general clarifications/ requirements have been added to the ROD regarding the monitoring of existing shallow and deep wells. Please keep in mind that: 1) the detailed requirements and schedule for completion ofthe RD/RA work will be included in the Consent Decree Statement of Woric which is prepared after the ROD and 2) the approval of RD/RA submittals under the Consent Decree will be made by EPA in consultation with DPNR. Development of a detailed monitoring program will be completed as part ofthe RD and will include some additional monitoring wells. 3. DPNR Comment #3 - Purpose of the ROD (p.ii) A list of COCs, SSLs, MCLs, soil and groundwater sampling points, and historic contaminant concentrations found at the sampling sites should be identified in section B (See #2, above). Response to Comment - A tabulated hst of COCs, SSLs, and MCLs has been included in the ROD. Historic detections of COCs in groundwater and soil have been illustrated on the tables and/or figures to the ROD, as indicated above. 4. DPNR Comment #4 - Institutional Controls Re: Use of Groundwater (sections 3.0, 5.2,7.0, and 11.2) As has been implemented at other Superfund Sites, use of groundwater (potable or non- potable) should be restricted at the site pending a complete evaluation ofthe effects of pumping (onsite and offsite) on contaminant fate and transport. In addition. Institutional Controls for nearby, offsite deep wells should also be implemented if migration of contaminants toward those wells is possible, detected or the current remedy does not achieve plume control. Response to Comment - As indicated in various sections ofthe ROD, the selected remedy includes institutional controls to restrict groundwater use at the site until groundwater MCLs are achieved. The existing data do not support the need for institutional controls for offsite production wells. However, monitoring will be performed to ensure the remedy is protective. 5. DPNR Comment #5 - Public Question and Comment Section (Section 9.2.9) "This section should be submitted to DPNR for comment and review prior to the final 500003 draft ofthe ROD." Response to Comment - This section will be forwarded to DPNR shortly. 6. DPNR Comment #6 - Selected Remedy Re: Groundwater Monitoring WeUs (Section 11.2-11.3) "Due to the past, present or future potential for offsite migration of contaminants into groundwater, nearby deep wells at the perimeter ofthe site should be included in: the current sampling program, the Contingency Remedy, and identified in the ROD (as has occurred at other Superfimd sites)." Response to Comment - Refer to the response to DPNR Comments #1 and #2. 500004