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09/28/93 11:26 TEXftCO LEGflL DEPT •» 98097297747 09/24/95 12.'12 NO.112 P003 535 842 0595 ^505 842 0595 H+GCL ALBQ OFPC 1^1002 SOSMaft)U6tt6NW,Sto. 1100'Albuquerwe. (SOS) &2-0601 • FAX: (505) &2-053S SrtOS September 22, 1993 TELEFAX AND WED EXPRESS M&Mehrm Bauptraan Manager USEPA - Region n 26 Federal Hasa, Room 747 New York, New York 10278 RE: TUTU STEBi U.S. VIRGIN ISLANDS Dear Mr. Hauptmaiu Ms. Kwan suggested that correspondence regarding this ease be directed to you during her leave. Dozing the past several weeks, parties related to the above-referenced site have been working together to form a FRP Group to devise * coordinated remedial strategy to address the documented contamination and pool data on each site to permit inteltigeat decisions regarding future site investigations. Prior to the finalizau'on of the PUP Agreement, a number of t*****^1 representatives of likely FRP Group membets have formed a committee (Technical Group) to provide joint comments to EPA. Our August 13, 1993 letter, which raised certain regarding work elements proposed in Technical Memorandum n prepared by Geraghty and MSler, was the first formal communication between this new group and EPA Since our first communication, the Technical Group has met (via telephone) several times to discuss an integrated approach to achieving aa appropriate area-wide remedy. The Technical Group fe conStient that these positive steps wul lead to a quicker and more effective remedy for the entire jwcsn of concern* Although the TEIC f\mn"ttff>- members could meet the schedule set forth ID the existing AOC fiw rew-fetjon plans for their specific service stations, such a plan may not meet the goal of an integrated solution for the area. Therefor*, the Technical Group developed a preliminary scope of work based upon our letter dated August 13 that should meet the ultimate objective. This scope consists of the following tasks: • Prepare a bibliography of an available information on the site. Include references submitted by PRPs, references from EPA and other public information. • Prepare a database of available technical information. Such a database should permit statistical analysis of various types of data provided by previous studies of TEIC, as •wen as investigations by PRPs. • Expand the existing base map of the site and survey all wells to a common datum. Those data at* also required for the database. TUT O06 1346 I *64762* 64762 09/28/93 11:26 TEXACO LEGAL DEPT * 98097297747 505 842 0595 NO.112 P084 09/24/93 12:13 39505 842 0595 H+GCL ALBQ OFFC (£003 Mr.' MeMn Hauptraan September 22, 1993 Update the -well inventory presented in Technical Memorandum I to include all monitor wells of TETC, the PRPs and any other supply wells. Compile all HtholOgic data for the site. Include all TEIC borings, borings and wells of PRPs and other readily available data. all aquifer test data to determine the quality of hydraulic data for the fate. Include evaluation of tests conducted by PRPs and others. I * Prepare a Remedial Investigation Workplan for the entire area of interest. Use data developed in previous tasks to guide the scope of work, the purpose of the Remedial Investigation is to develop sufficient information for the design of an appropriate remedial response. Potential remedial responses should be clearfy identified in the RI Workplan. Geraghty aad Miller has provided us with a schedule for the proposed work for the site. I have attached their proposed schedule to this letter. The schedule shows delivery of the HI WprfcpUm to EPA on or before December 21, 1993. Field work for completion of the RI wffl commence five weeks after EPA approval of our approach. Whereas this schedule is not Gkdy to permit the development of a Record of Decision prior to September 1994, we believe that this coordinated effort of all thePRPs will result in the implementation of a site-wide zemedy more expeditbusly than the TEIC Committee could do independently. In addition to efforts of the Technical Group described above, several members of the group have developed responses to EPA's letter dated August 30. The following points should be more carefully considered by USEPA. More specific comments or recommendations may be developed after an Technical Group members have been allowed to review the database that will be generated by Geraghty and Miller. Work dements suggested in our comments may be modified or *li^fTiflit'a'i1 after review of the data. These specific comments and our letter dated August 30, should provide EPA with an indication of work elements that may be included in the RI workplan. T.™. Section P; Worie Elements Required as Part of a Remedial Investipattoa. concealing items listed in the initial Technical Group letter to USEPA, various members of the group have generated the following responses to specific comments by Commexrt 2, Page 2; Wells in areas known to have high levels of organic compounds should ! not be resampled by low detection limit methods, since sample dilution may be required. Sample dilutinm may obscure the presence of some compounds present by raising their detection limits. More robust methods that do not require sample dilution should be used in these areas j to achieve results. Methods capable of detecting the presence o£ compounds at concentrations near drinking water standards should be reserved for areas of low level contamination, such as i near the margins of the plume. OTGCL TUT 006 1347 09/28/93 11:26 TEXfiCO LEGAL DEPT * 98097297747 NO.112 P005 585 842 0595 ' ^ 09/24/93 12:14 %?505 842 0585 H+GCL ALBQ OFFC W1004 u u Mr. Mdvin Hauptman September 22, 1993 Page3 Comment 3, Page 3: The water quality parameters requested will include analyses for volatile and semivolatfle organic compounds, dissolved oxygen, dissolved carbon dioxide, biological oxygen demand, Eh, and oxidation state of iron. However, without a thorough review of analyses currently available from the site, recommendation of specific methods for these analytes are not warranted at this time. Comment 4, Page 3: EPA should reconsider the rwrMnmendation to move the tnonitr>"^g MW-15 to a position more consistent with gtouadwater flow direction and further away from pooled petroleum products that were reported to EPA by NUS as emanating from activities on adjacent property (toea occupied by Thomas Gassett, G.B. Industries) and migrating onto the Ramsay property at the south fence line. The shallow groundwster flow direction, illustrated on Hgure 3-4 of Technical Memorandum H, Groundwater Contour Map Shallow Wells, November 16, 1992, is to the southwest in the Ramsay area. The shallow groundwater flow direction in the vicinity of Ramsay Motors was j calculated by triangulating the groundwater elevation of MW-1, MW-2, and MW-4, The ' calculated groundwater flow direction is sooth 31" west This calculated flow direction substantiates and validates the shallow groundwater flow direction presented in Figure 3-4 of Technical Memorandum H in the Ramsay area. Further, as noted by NUS, pooled surface oil easts at the Ramsay fence line, near the original proposed location of MW-15. The continued location of MW.iS as originally proposed would be closer to documented releases from the property to the northwest, which may cause false positive information concerning the impact from the dram storage and former underground holding tank on groundwater in the immediate area. Comment a), Page 4; EPA dismissed the need for a monitoring weD between MW-d and proposed well MW-18 with the rationalisation that wells MW-10S and CHT-2 were adequate for this purpose. However* ao additional well may be justified at this location because there is currently no sbaDow well located directly down-gradient of the Esso Tutu Station. CHT-2 is located directly down-gradient of the MW-9 well cluster. However, both CHT-2 and MW-9 are located west, and cross-gradient (not down-gradient), from the Esso station. Tech Memo tt states that MW-10 is located down-gradient of the station, however no justification for this statement is presented. In act; MW-1QS is located down-gradient of the eastern edge of the Esso station, but there is no shallow monitoring well located directly down-gradient from the center of the station or from potential groundwater contamination sources at the station. While CHT-3 is located immediately down gradient of the station, it is not at a location that win provide a dear nnfteretandipg of potential impact from up-gradieat sources. Additionally, analytical results from CHT-3 wore not provide in Technical Memorandum EL A well located either equidistant between MW-9 and MW-18 (or slightly west of CHT.TD) would provide this missing information. Oowfneot bX Paae 4: Information legardmg the location of MW-02 and otter wells at the O*Heary laundry site has previously been supplied Us EPA Likewise, all analytical data from groundwater sod soil samples have also been supplied to EPA MW-02 is located on the west side of the OHenry laundry site, between the building itself and Highway 39 (in the parking TUT 006 1348 09/28/93 11:27 TEXftCO LEBAL DEPT * 98097297747 NO.112 P00b 505 842 0S95 09/24/93 12:14 9505 842 0595 B-H3CL ALBQ OFFC Mr. Melvifi Hauptmaa ! September 22, 1993 Page4 j lot). AH monitoring wells at the site are between 33.5 and 52 feet in depth, and the depth to •water varies firom 9 to 32 feet. Consequently, the screened internal of the proposed monitoring well should monitor the free water surface (estimated to be approximately 20 feet below ground surface), and can be furt&er defined as "shaBow". The proposed monitoring wen to be located j 100 feet north-northeast of MW-02 would be up-gradient of MW-02 and would help to determine if contamination in MW-02 is emanatiag from an up-gradient groundwater source or &om & surface water source, such as the storm sewer. Comment c), Page 4: HPA disagreed with the recommendation to InstaD wells to d^ff***- the eastern nuigin of the groumhvater plume. However, the two eastern-most well* in the central and southern portion of the plume (MW.5, MW-7 and MW-10 and MW-10D) an exhibit well in excess of drinking water standards for chlorinated or hydrocarbon compounds. Wells located at or near the proposed location will also verity hydraulic gradients in this portion of the plume. There is no evidence that shows hydraulic gradients in the vidnity of the site are necessarily controlled by surface topography, smce site hydrology is strongly by fracture flow. Comment e), Page 5: As stated m the previous section concerning MW-15, since groundwater direction is southwest, a monitoring well directly south of the drum storage area will not monitor the down-gradient effects of a release. The proposed location SPA has chosen win determine potential oil pools associated with ideases from adjacent property, but it win not determine Ramsay Motor's contribution to the contamination to the Tutu area. EPA should consider the Impact of pooled surface oil as documented in the NUS report when evaluating locations for a monitoring wen. The only viable answer is to locate MW-15 remote from die pooled oQ area, and install an additional monitoring well at the Ramsay/ Antilles fence line or southwest of the fence fine on Antilles property. The latter drilling location would be more suitable due to the topographic features associated between Ramsay and Antilles. The existing location will mix results from any potential Ramsay releases and operations resulting in pooled oO at the Ramsay/Antilles fence fine. The response should be twofold: 1. Investigate the down-gradient direction of the drum storage area and underground 2. Investigate the oil pools reported by NUS from adjacent properly activities. This can be accomplished by installing a monitoring well not south of the drum area, but west of the dram area, A monitoring well along the fence line between Ramsay and Antilles or on Antffles property will meet the objective of the NUS reported spill Therefore,, two monitoring wells - a relocated MW-15 and ao additional monitoring well at the Ramsay/Antilles fence line or Antilles property is a better approach to identify source Comment 5, Page 5: While soil borings were not proposed by Geragbty and MOler in Technical Memorandum IE, so2 borings will be necessary to complete investigations of suspected TUT O06 1349 09/28/93 11:27 TEXftCO LEGPL DEPT t 98097297747 NO.112 P087 505 842 0595 08/24/93 12:16 VtBQB 842 0585 H+GCL ALBQ OFFC ! lg]006 Mr, Mdvin Hauptman September 22, 1993 source areas. Locations of the soil borings cannot be determined without thorough review of all data generated at the site to ent 6, Page 5: Technical Memorandum Q (Geraghty and MBter, 1993) includes a figure showing the ctorra sewer layout (Figure 3-6), however, the potential £br this to be a pathway for contamination was not investigated, In addition, the construction of the storm and sanitary sowers has not been investigated to determine if joints, cracks and decayed sections exist, or if overflow occurs. All of these may provide the opportunity for grouadwater infiltration. There am numerous potential sources and a steep topographic gradient in the Tutu area, with surface water Sow channelized down Tutu Gut. These facts imply that chore is potential for Kontaminated surface water to travel significant distances before infiltrating to groundwater. Therefore, it is necessary to investigate the surface water channel as a potential source for grouadwater coatatninnrtnn Son samples should be taken along the length of the sanitary and storm sewers. Alternately, a soil organic vapor survey could be conducted along the length of the sewers with targeted soil samples where the sou1 vapor survey indicates the presence of > v volatile vapors. The work should be performed as early as possible by Geraghty aad Muler pursuant to tbe determination of the most effective method for this investigation and the schedule rtfvmsfied previously. Under comments on Section 15: JPrcfonfnaiv fecf""""'^jgtjk*n< fnr additional work reanired for a conrpleteRL concerning items listed in the initial PRP Technical Committee letter to USEPA, the group has .generated the following responses to specific comments by the EPA. Comment 1, Page 5: Additional soil vapor studies and soil sampling in tbe Tutu Area may be warranted. SoU vapor studies have been a valuable tool, providing information to an parties involved in the investigation. After the planned review of all data collected in die Tutu area, the Committee wffl identify any gaps that require additional investigation. Soil vapor surveys and sofl samples will be recommended if it is determined to be an appropriate method for preliminary evaluation of a specific site. Soil sample locations wffl also be chosen after review of the data and/or completion of additional soQ gas surveys. These methods have always been part of tbe investigative process at Tutu. The use of soil vapor surveys as a preliminary investigative tool, in critical areas that have not been investigated (or have been under* investigated), wffl provide for a more accurate, efficient and cost-effective study. Soil sampling w&l provide additional information on the relationship between surface and groundwater contamination. Comment 2, Page 5: Although standardization of the sampling and analysis protocol for tbe THCC Investigations may have been accomplished for work conducted to date, this standardization has not necessarily applied to relevant work conducted outside of the TEIC. More importantly, since additional PRPs have been identified by EPA, the scope of the investigation needs to be reevaluated. This will lead to a data collection program that is more comprehensive and representative than the current program. The recvaluatlon process should include compilation and evaluation of all available data, updating the site conceptual model, .^ identifying data gaps, review of data quality objectives and evaluation of sampling and analysis options. Sampling and analysis protocol will depend on the expected types and concentrations 0i*GCL TUT OO6 1350 09/28/93 11:27 TEXACO LE6AL DEPT * 98097297747 NO.112 P008 505 342 0595 09/24/93 12:16 1SSQS 842 0595 H-cGCL ALBQ OFFC IS007 Mr. Melviri Hattptmaa September 22, m of contaminants in the monitoring •wells to be sampled (please refer to Cnmrnftnt 2 on Section D, above). Since the development of an integrated area-wide investigation expands the number of wells and area to be sampled, determination of a sampling and analysis protocol must be included as an element of the overall reevaluatton of the project. The Technical Group, which is comprised of representatives of most of the Tutu PRjps, Is in the process of organizing for this reevaluation. We hope this clarification of our statements presented in previous correspondence with you wfll farther justify our recommendations which we believe wfll result in a more comprehensive remediation for fh« area. Alberto A. Gutierrez, CFG Coordinator, Technical Group cc: Andy Praschak, USEPA THE TECHNICAL GROUP CONSISTS OF: John T. Burkart, R.G., REA - Cooper Environmental, Ramsay Motors, Inc. Ivan A. Cooper, P-E- - Cooper Environmental, Ramsay Motors, Inc. Step&ert Dubyfc, RG, RJBA - ITGCL, Iiux, Texaco Caribbean, Inc. DonaM P. Galya, P.E. - EJS5R Consulting and Engineering, Western Auto, Inc. Brace K. Green - Caribbean Hydro-Tech, Inc., Four Winds Plaza Partnership Randal] T. Hicks, CPQ- - H*Gd« In&, Texaco Caribbean Inc. Andrew EL Smyth • Arthur D. Little, Ino, Andrea? Gai & Paul Lazare Kenneth L. Loy - International Technology Corporation, Lflenri, Inc. Thomas F. Maquire, CPG - Blasland & Bouck Engineers, P.CX, Esso, SA. Belinda K. Price, MS, RPO - International Technobgy Corporation, L*Henri, Inc. Ana Gloria Ramos, TEIC Coordinator - Easo, Paul Ryan - Texaco Caribbean, Inc. TUT OO6 1351 PROJECT: fl& GERAGHT Y PROPOSED PROJECT SCHEDULE /Qy& MILLER, INC. ^^ff Environmental Services ^scRIP TON: TUTU WELLS SITE PROJECT SCHEDULE ~ ^^ u.s. VIRGIN ISLANDS TASK 1 BIBLIOGRAPHY TASK 2 DATABASE TASK 3 BASE MAP TASK 4 WELL INVENTORY TASK 5 LITHOLOGIC LOGS, CROSS SECTIONS TASK 6 AQUIFER TEST ANALYSIS TASK 7 DATA ANALYSIS, DEVELOPMENT OF Rl WORK PLAN FIELD WORK, MOBILIZATION SEPTEMBER XX XX OCTOBER '// SETUP '// '// '// //, NOVEMBER * RECEIPT OF ALL DATA ID/IB 7/, DATA // '// //< '// '//, '/< ENIRY ^ ^/ <X/ //, X/ // y/ // <// // // // PRttKTNO. PRQ01301 LEGEND: rxxxxi L 1 Illllllll * DECEMBER * TABLE Of CONTENTS/000. couun V/ XX XX///y\\ TEE REV Jill FlHAt CW E TO USI 2/21 HI EP» KJKOW£D PROGRESS ACTUAL PROGRESS tCHOXUO HtOOHtS* 00 REMEW MKJISTOHtS JANUARY Illli uSEPAIlll REVIEW SYU FIGURE 1 REVISIONS ICHD Vf. R.P, CWD BY: J.B. APPVD BY: O.N. FEBRUARY <x DATE DATE: 22SEPTB3 DATE: 22SEPT93 DATE: 22SEPT93 MARCH y/ ? >• // APRIL // _J\ ^> c c c