Letter to Mr. Richard Caspe, Director, Emergency Response and Remedial Division, U.S. EPA, Region II, from Mr. Hollis L. Griffin, Director, Department of Planning & Natural…
SENT BY:VIDPNR/DEP-watergui : 2-27- 2 ; 3:49PM ; VIDPNR./DEP-Waiergui- 1212 637 4284:# 9/10 n u MM GOVERNMENT OF THE VIRGIN ISLANDS OF THE UNITED STATES Ocparimeni of Planning & Natural Resources ' gDMS Document Division ofEnvironmcnlal Proleciion WAlliKdUTHOMtS 1118 C;irRl.S-|'IANSTED. ST. CROrX 00»aO-50fi.^ fSOO) 773-()56.5 V^ 115619 May 11,2001 Mr. Richard Caspe Director - ERRD EPA, 290 Broadway New York, NY 10007-1866 RE: Virgin Islands Chemical Superfund Facility - Response toEPA letter of 4/19/01 1. EPA response to DPNR comments on VI Chemical Superfund Site Final Draft Feasibility Study. 2. Proposed Plan for the VI Chemical Superfund Site Final Draft Feasibility Study Thank you for your review of DPNR's concems regarding the characterization ofthe hydrogeology al Site. After reviewing your response, DPNR believes it must stand by our original comments. Please understand that these comments were not based solely on USGS data and publications but also by direct observations and extensive field experience. …
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SENT BY:VIDPNR/DEP-watergui : 2-27- 2 ; 3:49PM ; VIDPNR./DEP-Waiergui- 1212 637 4284:# 9/10 n u MM GOVERNMENT OF THE VIRGIN ISLANDS OF THE UNITED STATES Ocparimeni of Planning & Natural Resources ' gDMS Document Division ofEnvironmcnlal Proleciion WAlliKdUTHOMtS 1118 C;irRl.S-|'IANSTED. ST. CROrX 00»aO-50fi.^ fSOO) 773-()56.5 V^ 115619 May 11,2001 Mr. Richard Caspe Director - ERRD EPA, 290 Broadway New York, NY 10007-1866 RE: Virgin Islands Chemical Superfund Facility - Response toEPA letter of 4/19/01 1. EPA response to DPNR comments on VI Chemical Superfund Site Final Draft Feasibility Study. 2. Proposed Plan for the VI Chemical Superfund Site Final Draft Feasibility Study Thank you for your review of DPNR's concems regarding the characterization ofthe hydrogeology al Site. After reviewing your response, DPNR believes it must stand by our original comments. Please understand that these comments were not based solely on USGS data and publications but also by direct observations and extensive field experience. Chir comments go beyond site-specific, localized conditions because of our concems to adequately predict contaminant fate and transport. Proposed Plan DPNR is pleased to see that EPA recognizes the practicality of retaining Altemative 4 as a contingency remedy. DPNR recognizes the financial attractiveness to EPA in selecting Monitored Natural Attenuation (NMA) as the preferred remedy. However, DPNR retains a healthy skepticism regarding MNA's effectiveness under the varied hydrological conditions exhibited here in the territory and believes that the proposed contingency remedy is justified. 400198 SENT BY:VIDPNR/DEP-waiergui ; 2-27- 2 : 3:50PM ; VlDPNR/DEP-Waiergui-' 1212 637 4284:#10/10 At some point,- DPNR would welcome the opporttmity to discuss with EPA the various criteria to be used to determine if MNA is providing the proper level of overall protection of human health and the environment. Thank you. Sincerely Hollis L. CMffin Director Cc: Caroline Kwan, RPM 400199