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LAW OFFICES OF JOHN K. DEMA, RC, JOHN K. DEMA C ARE Y-ANNE MOODY 11 November 1994 •* 9 CO 3Ts x "- Roy Adams, Commissioner cv, Department of Planning and Natural Resources 5 United States Virgin Islands £2 Nisky Center ~ Charlotte Amalie, St. Thomas 00801 O5s • Andrew Praschak, Esquire o Assistant Regional Counsel f USEPA - Caribbean Field Office « 1413 Fernandez Juncos Avenue 1 Santurce, Puerto Rico 00909 CO x- Ms. Caroline Kwan o Project Manager o USEPA - Region II co 26 Federal Plaza, Room 737 g New York, New York 10278 CO 1 Re: Tutu Water Wells Site Investigation co St. Thomas. United States Virgin Islands EC X °. Dear Commissioner Adams, Attorney Praschak and Ms. Kwan: o H On November 1, 1994, I submitted a letter to you describing in detail my ^ concerns with Geraghty & Miller's attempt in the Draft Phase II RI to exclude H" Esso from its responsibility for releasing chlorinated hydrocarbons into the £ Turpentine Run Aquifer. Historical site information is available that co documents the fact that chlorinated hydrocarbons were used in profusion over § the years at the Esso Tutu Service Station ("ETSS"). Any analyses that <r excludes, overlooks or otherwise distorts data in an investigation of sources w and migration pathways of chlorinated volatile organic chemicals in the « groundwater at the Tutu Wells Site is a disservice to the residents of the United States Virgin Islands. TUT OO6 0636 *64635* 64635 Roy Adams, Commissioner 11 November 1994 Andrew Praschak, Esquire Ms. Caroline Kwan Attached, please see the summary of my letter to you of November 1, 1994. I have also included a few additional comments based on discussions at the meeting held in St. Thomas on November 2-3, 1994. Please note the opinions and data advanced by our experts, including Dr. David Keith Todd and Dr. Paul Fahrenthold, which stand in direct opposition to the conclusions reached by Geraghty & Miller. Dr. David Keith Todd has published numerous works, including the textbook, Groundwater Hydrology. His recent publication is as co-editor for Geraghty & Miller's The Water Encyclopedia, which is advertised as "The Flagship Publication of the New Geraghty & Miller Book Series." Dr. Paul Fahrenthold, former Chief of the Organic Chemicals Branch of the U.S. EPA, has over twenty-five years of experience in activities related to the evaluation of groundwater contamination migration. In summary, I believe that previous activities including soil/aquifer characteristics provide indisputable evidence that Esso Tutu Service Station contributed chlorinated VOCs to the groundwater. Ignoring its contribution is a serious omission and error. Very K. Dema, Esquire JKD/s Attachments cc: Four Winds Plaza Partnership TUT 006 0637