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OCT-15-1993 .14:36 FROM EPft TO 82125458050 P.01 FRTM FRatRSGRElHER TO <fc ONE i«MI0 P.O. HADBOKPICLC. N.J PAX TRANSMIT'. -tL ^nif^Hi 4MHTQTMAM* WP«S». miaawt mt«.MMu< SSPi!!*!"" "w« F «K** October 14, OirtetCW (*09) 3S4-3077 Andrew Fr«schaK, Eflquire United statae Envipgnaental Protection Caribbean field office 1413 FHrnantiez Junaoa Avenue Santurce, Puerto Rioo 0090S <rutu WBliri«ld« Bit*, Andy: Ws ara writirwr on behalf of tfte Putu Envirorun*ntal investigation enramitt*« ("TEIC") to forw^Jly request an extenaion of time to prwid* th« taohnieal aeliv«r»i>iec eeheduled for suisnteeion pursuant to the February, 1992 Administrative Order an Oonasnt ("AOC") . AB w» sbmli discuss fcalow, th* expansion &f tftis PCD j met from a narrow, B«cvice station atudy tte an expanded aquifer-vid* afudy dictates tha ne«d COJ- adflitlenal time. There can t>o no «tue»tien that th* ntu<3y, as originally connanrfn.at.ed in th» February, 1992 *ocr has xaid«rgon« an evolution viiieh iias greatly expaadafl ito frttramfetere- This iaoe is acknowl»dg»d in cajfcliis* Swan's Augurt 30, 1993 letter reviaving tn« £>KF Tfl^hnical Conmitteft's connenta on Technical w«naran<su» Ho, II. in that l«*ter/ tb* Agency BdtnowlBflges thit tb« 7BIC investigation "neeossarily was cDn«uctBd froa elaj»r projeinity to tha TeXftso and Saso eervieft stations,* {p. 53 and «»at th« "eoop* e£ the inv«stig»tiDn has ftjcpanded. " (p. 6). Nonetheless, significant progress has been aado in identifying tha multiple sources of groundwatisr and goii oontominfttien at the siea. TUT 007 O936 *64949* 64949 OCT-15-1993 14:37_ F TO Tfl 132125458050 P. 02 Andrew FrasehaX, Esquire oetoiber 14, 19*3 2 with regard to the status of the originally approved achedule, th* effective date of the AOC van Karch 4, 1993, and that dictated a start of work of April gt is 92. Son* of the earlier tasks identified iu this aehedula, including tha subaittai oS ^Technical Memorandum No, I, ware noapletefi ahead of tchodyle. Unfortunately, delays war* incurred • in the euhaittal and review of Technical Kemoranaum No, II. Th« originally approved wwrie plan anticipated thbt Tershnieal HeworanduiB Kro. II would to* submitted on Oeeaoher 16, 1992 and that SPA would approve it by January Zl/ 1993. In actuality, Technical Meaoranduun NO- XI Vas not vuomitted until Karen i, 2.993. Tiiare are sevRral reaeena far this dalay. First, tha detivarables «er» expanded to include all of the validated soil data .*o oonffloeions couia be reaanad regard J ng potential sources of eentaftittatian. second/ delays were encountered as a r*»ult of Tfiic's roviow of Technical Meaerandun Ko. IT. Finally, it took longer than anticipated for £FA to review T«ehnieal Kenoratidun NO. II and to provide its extensive TJie originally approved ecbeaule did not anticipate that a second field effort would b* required; inatood, it only anticipated that a second grotmdwatcrr ftaicplin? event would be l&plenentedt. ?h« need for additional monitoring walla and soil aaaples vocld, ax neceaaitVr extend t&e eciiedulft beyond that Whioh ia shown on the originally approved EPA war* plan and beyond tha septeafcer 30, 199* completion date that you havo discussed for the ROD. Furth»rffiotcr it was the hope of TEIc that «ra vould be *bl« to re-jnobilizc to iBplBm«nt: the Phasa tr field vork in lat« AnguflC, 1992. Hov»rer, several difficulties arose, inclusin? difeioulties obtaining aeoBco which hindered this offort. Additionally, delays were encountered as a result of discussions vhich V«TA taking place batweftn B?A and the expanded PRP Committee <. We certainly did not var.t to charge ahead if there waa a substantial (jfroyp of PiU?c felt that tha work wan lacking or deficient frais a teohnical on the other hand, we have made trenendoue stridee in our errorta to ±org» a ERP group who aay fee in a position to aupport and implement an integrated aquifer renetty. In short , we have formed a. ?RP ^roup connisting of thooo entities who either own or oparata properties froa which tharo is a suspected discharge of contaminants into the aquifer. B?A hus b»»ii extreaaly Bttpbortive of tbee* efforts beeauee E?A realizes, 03 do the jnemhors of TE1C, that auooeaafully romediatdrjg groundwater contamination emanatingr TUT 007 0937 Tn £12125458050 P.0~> OCT-15-1993 14:38 FROM EPS OCT-14-199G 1VJ09 FRO1 O3>€R8JGRE1SER TO 1S097297747 P.04/-aS Andrew Prasehak, Esquire October 14, 1993 from multiple sources requires close cooperation between the PRPs and-the Agency. We anticipate that vithin the next several weeks, many of tha PRPs will have signed a KRP Agreement, it also appears that Esco and Texaco will continue under the auspices of TE1C to complete the RI/FS. However, the PKP Technical Committee will be kept closely apprised of all developments. These are promising developments which, in the long run, should provide a framework for the regulated community and the Agency to work together. In summary, the schedule must be for a variety of reasons/ many of which are beyond our control. There can be little question, however, that we sit at a critical crossroad in our continuing relationship with the Agency. If tfte Agency wants to perform a comprehensive study of this aquifer-wide contamination, and if the Agency wants to address the concerns of the other PRPs at this site, then modifications must be made to this schedule which will make it impossible for the Agency to issue a re'sord of decision ("ROD") by September 30, 1994. We have attached hereto a project eohedule for completing the RJ and FS assuming that the work recommended by the expanded PR? Technical Committee is implemented. This schedule envisions the atubmittal of a supplemental work plan to EPA by December 21, 19S>3 and provides for three to five weeks of EPA review. Remobiiization to begin .the field work for Phase ti will start in early March, 1994. Two months for this expanded field program are anticipated; the second groundwater sampling event would begin two weeks after well development and would take approximately one month because the PKP Technical Committee has envisioned * comprehsnaiva sampling event of all monitoring wells and supply wells in the study area. The schedule shown on the Attached figure envisions a draft SI report being submitted to EPA by late October, 1994 and a final FS in March, 1995. We have arranged a meeting for October 21, 1993 between the Agency's legal and technical staff and TEIG's legal and technical staff to discuss these concerns, we will also attempt to diacuss these issues with jfs. Kwan and yourself prior to that date. in the end, the members of TEIC are confident that we share T^* f??? 9°*ls ** the Agency — namely, to conduct a study which identifies all sources of contamination in the wellfields and which proposes a remedial action plan which is coat-effective and protective of the public health and safety. We will take a flexible approach regarding the schedule, scope and structure of TUT OO7 O938 OCT-15-1993 14:38 FROM EPft OCT-14-1993 17=09 FROM TO TO 82125458050 P.0- 18097297747 P.05/BS Andrew PraacnaK, Esguira October 14, IS93 the HI/PS so as to accommodate EPA's regulatory needs, and we are eagar to complete the studies BO that we ean start resolvina the problems that are identified. Please call trim or me with any questions or comments. * you for your help. \ ^A~T^Z^' £,____ CHRISTC HER* R* GISSON CRG:jdh Attachment cc; Timothy R. Knutoon, Esquire (via telecopier) 11™ GJoria Jtattos (via telecopier) w. Brown, Esquire (via telecopier) TUT OO7 09^9 OCT-15-1993 14:39" FROM EPft OCT-14-1993 1V:£S FRO1 IB/''.. JO 15:56 - TBSKO LESS. KFT * 516897950574 TO TO 8212545305S P. N0.6S2 P832 f TU'T 007 0940