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I -d N05IQ3 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION II Preliminary Ao«rooam«nt and Confirmation v£ Authorization Of ;UBJECT\ CERCLA Removal Action Monies for the TUTU Well Site, Anna's Retreat, Saint Thomas, U.S. Virgin islands - ACTION MEMORANDUM FROM: Carlos B. O'Neill /^L^ 0^ „ *' *«— AjQs^^^if-i TO: On-Scene Coordinator Stephen D. Luftig, Director Emergency and Remedial Response Division ?HRU: George H. Zachos, Acting Chief •>-.• 1 Prevention Branch T MHARY •"*', MC. Allan smitn L . . . . anning and Natura Virgin Islands, • rbally request* Protection Agency (EPA) provide sampling of one well which was - unpleasant odor. This well is prwiaea potaoie water supply ? Thorns*, The well is located . • in t Tutu Section of Anna' Re- was •V.-wed by an ad< role of Lead Agency after ! £ 1 O -: 5 R e s o - r . that t '• i a I y t i c a ^c r te ~ *tC'.\i I- • j r of ! I £< ional requ r sampling- were fou 'his verbs- i by DPNR -•> f c • SPA fco ass s •' " -> ind i-: i ted '. c o n t -UT> i n a t e d .• -4 -j u e s t wa g f •" \ 1 o v .•* -. August 10, '97 se-vera-l-ccnniirwn;iTrl hazardous substances formal request in *r in July and A- if 1987. EPA cor.fi -.ed by si-pUno « analysis, th .minat' if ground1'.' r wi. :h ,-)ia' organic c<i so, , A ma_j'" r -ontaminan'- in the oroun tetrachloroeth, lene (TC6-. Thi EPA 10-Da.. t,ealth A- Level of 175 ppb was exceeded in three (3) of twcn wells sampled, with two of the three contani nated •' private r»Bidenti«l wells. The c one e n tr« ti cpne f .' from 240 to 7. ''O ppb with a<>" : f ) a^dition^l .4 • o i- Island's inter-... maximum per:., st, *bl« ^ «-•: ration le '< on September 1, 1987 DPNR for le organice in d: water in the Turpent Rur. Aquif- 0 ppb for a single povnd or 100 ppb for \! volati rgani- son pounds^ . of the previously me ned sever la w*,? iid*ntial w« 11 s . H FORM 1349-1 O/M) *64419* 64419 N05IQ3 -2- This Action Memorandum will document funding authorized for Phase I of the Tutu Well Site CERCLA Removal Action. Phase I addresses only residences having contaminated drinking water wells with volatile organic compounds above levels established by the U.S.v.l.'s interim maximum permissible concentration levels fur pocaoie water. rnis action aid not include wens where water is used primarily for commercial, business, industrial and/or trade purposes. It also did not include wells contaminated solely by gasoline or gasoline by-products which are not hazardous substances within the definition of Section 101(14) of CERCLA. This action includes the decontam- ination and cleaning of residential cisterns contaminated by hazardous substances, the modification of plumbing/ the delivery of water by tank trucks as a temporary alternate water supply, and a well water monitoring program. The total project ceiling authorized for a 52-week period is 5100,000 of which $40,000 is estimated for mitigation contracting; $45,000 for TAT's extramural coats; and $15,000 for BPA'S intramural ccits . This memorandum will confirm your prior verbal authonzatio of Trust Fund monies, issued to the Chief, incident Respons • «-» n » « w « r » t i o « e « « * i » n • n O e » *>»"»»>« W 1, 1 9 O T , t» i n i t i a t e 0:,-= removal action at the subject site, and subsequently revised to the current project ceiling of $100,000. II. BACKGROUND A. Historical ^information A request for EPA analytical support for on* veil in the Tutu Section of St. Thomas was made verbally :: July 15, 1987 from DPNR. On July 31, 1987, a verbal re'r.^st *°r EPA to assume the role of Lead Agency was made, and this was followed by a written confirmation of the request, dated August 10, 1987 (received by the Emergency and Remedial Response Division on August 19, 1987). The initial request was based on a reporc that one well was reported to have a strong odor, characteris- tic of a petroleum product. This well is a major source of commercially provided potable water for the eastern portion of the island. EPA'S preliminary investigation commenced on July 21, 1987, witv a field reconnaissance and sampling of this one well and six additional wells identified in the immediate area. Several of these wells are also major water suppliers of public drinking water to the eastern part of the island. I'd G f : I I <L 8 / S3-- 10__________NOSIQ3 -3- Laboratory results from this survey indicated that the initial well was highly contaminated with gasoline and chlorinated organics, and the additional six veils contained elevated levels of chlorinated volatile organic compounds. Based on these results, DPNR declared that an imminent health threat existed, which could affect approximately 20,000 people living in St. Thomas. in addition, an indefinite number of tourists who vacation in St. Thomas were at risk since these commercial wells supply water to major hotels and restaurants. DPNR issued orders to close these seven commercial wells to protect public health. Subsequent to this action, EPA expanded their sampling plan due to the threat of greater contamination to drinking water wells in the area. EPA along with DPNR, identified other wells within the Tutu Water/Turpentine Run Aquifer which may be impacted by the hazardous substances identified to be pres- ent in the groundwater. A second round of groundwater well sampling took place on August 10 and 11, 1987, which included a total of twenty-four (24) wells identified in the Tutu Section of Anna's Retreat. All twenty—four wells were sampled and analyzed for volatile organic compounds. Following these results, DPNR closed the five private wells which service two three-family homes and one apartment building housing twelve studio uni ts. B . si te Sotting/Deacription The contaminated wells are located in the Tutu Section of Anna's Retreat, St. Thomas, U.S. virgin islands. The five '5) private wells recently ordered closed are located in the Tutu residential area. At the present tiae, the affected area is not serviced by any public water supply. EPA sampled a total of twenty-four (24) wells in the Tutu area and found five private wells and eight (3) commercial wells seriously contaminated with up to 7,600 ppb of PCS. (See map attached). C. Quantity and Type of Substance Present EPA sampled and analyzed for suspected volatile organic com- pounds on July 22 and August 10, 1987. Listed below are the maximum concentrations of the hazardous substances identified in the drinking water wellst f f : I I L8/S2/ 1 0 ______MQ5IQ3 -4- M^ximum statutory Source of Concentration Hazardous substances C o n t ajn i nan t Found (ppbj~ under CERCLA Tetrachloroethylene 7,600 Clean water Act Section 307(a) Trichloroethylene 61 Clean Water Act Section 307(a) Benzene 1,400 Clean Water Act Sec tion 307(a) The results of .the sampling are contained in Tables I and II. PCE contamination ranged from non-detectable to seven thousand- six hundred parts per billion (7,600 ppb). Sampling results adequately document 3 wells with contamination above EPA's 175 ppb PCE 10-Day Health Advisory Level and eight (8) wells above the DPNR's interim standards for maximum contaminant levels of volatile organic compounds in drinking water. III. THREAT A. Threat of Public Exposure Direct contact with PCE may cause eye and ;. -• '••••' ".ati an along with dry scaly and fissured dermatitis. Ac u exi.'S ; . through absorption, inhalation or ingestion, may cause ce-<- T nervous system depression, hepatic injury and anesthetic death, has been found to be carcinogenic. This is a case of actual contamination in excess of the EPA 175 ppb PCE 10-Day Health Advisory Level for a three-family house and one apartment building housing twelve studio units. In the other three family apartment dwellings, the well con- tamination exceeded the interim DPNR drinking water standard of 50 ppb for any single volatile organic constituent. in addition to the exposure via consumption of the water, or eating food prepared with this water, showering with water contaminated with volatile organics can contaminate the air to significantly unhealthy levels. Sf : I I LJ8/S2-' 10__________NQ51Q3 bd3 -5- The location, direction and dimensions of the plane are af- fected by variations in water table depth, rate of pumping of the wells, duration and intensity of rainfall, and inter- mittent releases of chemical* from one or more sources, all of which are unknown at this time. Given the above variables which affect contaminant strengths in any w«ll within th« plume may vary randomly. On September 2, 1987, DPNR issued three (3) orders to close wells and issued two (2) advisory letters to homeowners not to use w«ll water for drinking, bathing and washing. B. Evidence of Extent of Release ' iveatigation, sampling and analyses by EPA have identified contaminated g.-oundwater, as described above, and containing contaminates, as described in Tables I and II. C. Previous ctionB to Abate Threat >'-> mitigative action was taken by any Potentially Responsible Pii'ty prior to EPA's recent activities. D. Current Actions to Abate Threat EPA has commenced an investigation of the Tutu Water/Turpentine Run Aquifer by establishing a cooperative agreenent with the U.S. Geologic Survey to define the characteristics of this aquifer and to determine the extent of contamination. EPA and DPNR have also completed Aquifer and a monthly well monitoring Program is being developed. DPNR has issued a »:otal of ten (10) orders/advisories to well owners to close sixteen (16) wells. A local dry-cleaner has been Identified as using and storing PCE. Handling, storage an3 disposal practices from this facility are unknown at this time. DPNR has proposed to issue an advisory to local dry cleaning «stablishments instructing them to properly store and hold all waste for proper disposal by an industrial waste hauler. DPNR with the assistance of EPA is conducting an assessment of at least nine (9) facilities identified to be potential sources of hazardous waste and/or substance releases in the Tutu area. St7 : I I <L8-'£5' JO__________N05IQ3 bd3 -6- EPA has cleaned the homeowner's cisterns that have been contam- inated by hazardous substances from the groundwater, modified the existing home plumbing to terminate well connections, and intends to continue to deliver clean water via tank truck* on a regular basis, and establish a surveillance program for all wells in the area by a monthly groundwater monitoring program. This Phase I, short-term removal action will mitigate the threat to public health by providing a temporary alternate source of water for affected consumers. IV. ENFORCEMENT The contaminant plume is generally believed by both DPNR and EPA, to have its source from past and present improper handling and disposal practices of organic solvents, possibly from dry cleaners aid auto repair shops operating in the area. This site hag been referred to the site compliance Branch for enforcement a c t i o - . t- .^r-jrney and enforcement project officer have been a s s i - r - .is case. E^A issued Request for information letter. . Potentially Responsible Parties. V . j-_'__ -D PROJECT A . "!b j ec_t '. j^f_ e phase I Removal Action -ri.-i. bjective of the Phase I of the removal action is the <iiti'-a r. ->£ the threat to public health by providing a •afe potabl wither supply to the affected residences. TWO three-family homes and one apartment complex housing twelve studio units were identified as being dependent on groundwater from their own private wells. Their respective wf 1 IB were ordered closed-down by DPNR for exceeding interim drinking water standards. TO reach the objective of providing a safe interim drinking water supply and protect the health of the public at risk, the following removal action was initiated, water storage cisterns, which received contam ^ted groundwater from affected wells, were cleaned and sanitized. Cisterns were filled with clean, safe, drinking water. Water tank trucks from local water haul- ers will be providina water for the affected cisterns on a reg- ular basis. Plumbing modification was made to disconnect water lines from the contaminated wells which provide groundwater to the cisterns. • d 9 f •• I 1 i 8 <" S3/MQ_______ N Q S I Q 3 bd3 UQdd -7- An attempt to connect well water directly to toilets for flush- ing will be made, if physically and economically feasible. A well surveillance program will be implemented involving all the wells-i-n-the Turpentine Run Aquifer, thru monthly sampling and monitoring. The longer term, phase n objective will require the provision of a permanent alternate water supply in lieu of the temporary trucking of water to the threatened consumers within the plume area. Upon completion of an analysis of the alternatives for permanent water supply to these residences, a recommendation will be made for phase II. B. project Estimated Costs water consumption per person per day on the average is thirty (30) gallons. it is estimated that the one apartment building has twelve studio units with the average of two people per unit. The two other private homes are three-family dwellings with the average of ten people in each. The cisterns in the three family houses are small and, therefore, a supply of water- nast—b«—deliv- ered every two or three weeks, respectively. The delivery period is currently estimated to be one year or when a permanent alter- c - *-- -—"<<«»<t. whichever occurs first. I 'd IWiOl I 'd 53:21 i8/S3/IO NOSIQ3 «d3 WOBd -8- Extr«mur«l TAT Cost TAT Monitoring and sampling program (including travel and per diem I................. $35,000 TAT Technical and administrative support (including travel and per diem )......... $10, OOP Total TAT Coat $45,000 Intramural EPA Cost (Including -tavel and per diem ).................. $15 / 000 ESTIMATED TOTAL PROJECT COST. .........$ 100 , 000 T'.' .gure represents the estimated total for Phase I. It be reduced significantly, if a reliable and permanent iate water oupply is found sooner than the proposed jeka delivery period) might be increased, depending upon the identification of new drinfcing water wells found to be contaminated with hazardous substances within the affected area. C. P r o j act s c h e d u 1 e project initiation of cistern clean-up and safe wat*r d .-: • livery has already been implemented baaed on verbal fundi/;: authorization. Safe water delivery period is currently estimated not to exceed one year or when a permanent alternate water supply can be provided, whichever occurs first. V. RECOMMENDATIONS Conditions at the Tutu Well Site meet the requirements of Section 300.65 of the National Contingency Plan (NCP) for « CRRCLA/SARA removal action. EPA has determined that there ia • threat to public health at the site (section 300 . 65 (b ) ( 1 ) , This determination was based on t 1) Human exposure to unaceeptably high levels of acutely toxic substances (Section 300 . 65 ( b ) ( 2 ) ( i ) , and 2) Contamination of drinking water supply (Section 300.^5 (b)(2) (ii). 5 'd I 0 NOS1Q3 -9- The resident population at risk currently relies on well water as their source of potable water. private This removal action complies with section I04(b)(2) of CERCLA, as amended by SARA, in that it is consistent with the efficient performance of long-term remedial measures, by providing an interim supply of potable water to the public until a permanent water supply can be secured. This is a written confirmation of the initial and revised verbal approval of up to $100,000 for the total project ceiling estab- lished on September 1, 1987, by the Director of the Emergency and Remedial Response Division to the OSC for the CERCLA renoval action at the Tutu Well Site, The mitigation contracting ceil- ing is estimated at $40,000, with an additional $45,000 for TAT costs, and SIS,000 for EPA costs. Your authority to authorize these funds is pursuant to Deputy Administrator Alvin Aim's memorandum of Delegation Number 14-lA dated April 15, 1984, and Richard Dewling'e Redelegation Order R-ll-1200.6 of August 29, 1984. /} L-^ I) Lf- APPROVAL: DATE: DISAPPROVAL! DATS: cc: (after approval is obtained) C. Daggett, 2RA R. Salkie, 2ERR-DD S. Luftig, 2ERR G. Zachos, 2ERR-RP B. Sprague, 2ERR-RP J. Csapor, 2ERRD-SC G. Pavlou, 2ERRD-NYCRA J. Marshall, 20EP P. Gelabert, 2CFO R. Gherardi, 20PM-FIN T. Sullivan, PM-214F (EXPRESS MAIL) T. Fields, WH-548B P. McKechnie, 2IG 1JT I 'd ,11:21 N05IQ3 Wd3 WOdd '-_ 1 N*U tiWuiNt RESULTS TUTU VEIL SZTI IT. THOMAS, U.S. VIRGIN ISLANDS SAMPLE LOCATION 4 VXVOS 11 IGLXV VELL 01 IGLXV VILl 02 KLIN VELL 13 KAXTHKAtf IAKIRT HARTHKAV CRUSH HAfiTXKAN S9TATI RODRICWM AUTO BRTAV ALPHA, LEONARD SMITH, tOCITA OEYCOH 03 DIYCOV 01 DEPI DINITRI VIHA VILl 13 VI HA VIU 01 RAK5CT STE1L HARVET MATHIAS FRANCOIS OMCH TILLIT T1LLZT DUP FIELD OLAVX SAMPLS VUMBER •••*•» Q01A 001A 00 3A 00 4A OOftA 00(A 007A OOVA 009A 010A 011A 01ZA 013A 014A 020A 021A 022A OJOA 031A 033A 033A 034A 036 A 03CA 037A 04QA DATE OATI SAMPLED AVALXSEO 001 H/10/07 00/11/17 CV 00/10/07 00/13/07 CO 00/10/07 00/13/07 CV 00/10/07 00/13/07 CV 00/10/07 00/13/07 IV 00/10/07 00/13/07 IV 00/10/07 00/13/07 PV 01/10/07 00/13/07 IV 00/10/07 00/13/07 CV 00/10/07 00/13/07 PV ol/l?/l? il/ii/l? 8 01/10/07 00/13/07 CV 00/10/07 00/13/07 VA 00/10/07 00/13/07 CV 00/10/07 00/13/07 IV 01/10/07 00/13/0? IV 91/10/07 00/13/0? IV Ot/10/07 00/13/0? PV 00/10/07 00/13/0? PV 00/10/07 00/13/0? PV 00/10/0? 00/13/07 PV 00/10/0? 00/13/07 PV 00/10/07 00/13/07 CV 00/10/07 00/13/07 CV 00/10/07 00/13/0? VA mmm mmm mmm ••• •«•• 1300 1400 0 21 72 11 30 13 43 If f? 3 30 1 1 0 1 1 110 0 0 0t 0 10 7 20 270 01 7000 4 CO 20 120 0 0 0 240 31 130 0 0 00 33 0 213 .f 13 .T 74 .T Cl .T 1 .t 12 .T 0 .T 0 ,f o ,r 0 .T •1 .9 0 .f 0 .T 0 .f 0 ,T 7 ,? 12 .T 1 *T Cl .f 10 ,f t .1 140 .f 0 ,T 070 .f 120 .? 0 .f TABU II TUT O02 O686 f 'd -' 10 N U S l U d Or/28/17 3 »:-<?:,* LOCATION •*»••••• JHOTOVAC SAMPLING MSVLTS TUTU VEIL flTC ST. THOMAS, U.I. VIRCXN ISLANDS DATl tATI SAMPLED ANALniD SOURCE UK TC1 Kf TOL OCt OCN8 HARTKHAH CSUS- T-473 07/JJ/I7 07/50/17 IK MARTHHAN ftAKtftY l?-474 07/22/17 07/10/17 IV ' VINDS KELlfi 17.475 07/22/17 07/30/17 Ctf VIMOS VCO41 t?-474 07/22/17 07/30/17 CH TILLIT 17-477 07/22/17 07/30/17 CU ,iH* I7-47S 07/32/17 07/JO/I7 IH KUN I7-47J 07/22/S7 07/30/17 0* TILUT 17-410 07/tt/l? 07/30/17 Ol 07/32/17 07/30/17 HA 0 0 7 7 7 103 0 ) It 14 It €1 *33 Ift 200 15 1 t 34 11 It 10- 4 41 1 3 I 32' 1 1 .T. ,T, .T. ,1, .». ,T, .T. 1 .t. » .T. TABLB I \ TUT 002 0687