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C D M F E D E R A a s u b s i d i a r y o f C a m p March 26, 1993 L P R O G R A M S D r e s s e r & M c K e e I n c . C O R P O R A T I O N Mr. Ervin Smieszek TES V Regional Project Officer U.S. Environmental Protection Agency 26 Federal Plaza, Room 737 New York, NY 10278 PROJECT: DOCUMENT NO: SUBJECT: Dear Mr. Smieszek: TES V, EPA CONTRACT NO: 68-W9-0002 Work Assignment C02048 Tutu Well Field Site St. Thomas, U.S. Virgin Islands TESV-C02048-EP-CVXM Technical Review of Technical Memorandum II Results of the Field Program Tutu Service Station Investigation Document Control No: TESV-C02048-LR-CVXN Please find enclosed the letter report titled "Technical Review of "Technical Memorandum II, Results of the Field Program Tutu Service Station Investigation, St. Thomas, U.S. Virgin Islands" and dated February 1993, as partial fulfillment of the reporting requirements for work assignment C02048. If you have any comments regarding this submittal, please contact Sally Odland of CDM Federal Programs Corporation at (212) 393-9634 within two weeks of the date of this letter. Sincerely, CDM FEDERAL PI /li^UI Scott B. Graber TES V REGIONAL MANAGER IS CORPORATION Attachment cc: C. Kwan, EPA Work Assignment Manager ^•Mtflilttrife CDM FPC Work Assignment Manager Document Control, CDM FEDERAL PROGRAMS CORPORATION (2 copies) NYC File TUT 006 1633 111 Fulton Street, Suite 710 New York. NY 10038 212393-9634 *64819* 64819 TECHNICAL REVIEW OF TECHNICAL MEMORANDUM II RESULTS OF THE FIELD PROGRAM TUTU SERVICE STATION INVESTIGATION ST. THOMAS, U.S. VIRGIN ISLANDS" dated February 1993 TUTU WELL FIELD SITE ST. THOMAS, U.S. VIRGIN ISLANDS Prepared for U.S. ENVIRONMENTAL PROTECTION AGENCY Office of Vaste Programs Enforcement Washington, D.C. 20460 EPA Work Assignment No. EPA Region Site No. Contract No. CDM FEDERAL PROGRAMS CORPORATION Document No. Prepared By Work Assignment Project Manager Telephone Number EPA Work Assignment Manager Telephone Number Date Prepared C02048 II 2P1D 68-W9-0002 TESV-C02048-LR-CVXN CDM FPC Sally Odland (212) 393-9634 Caroline Kwan (212) 264-0151 March 26, 1993 TUT OO6 1634 C O M F E D E R A L , P R O . G R A M S C O R P O R A T I O N a s u b s i d i a r y o f C a m p D r e s s e r & M c K e e I n c . March 26, 1993 Ms. Caroline Kvan U.S. Environmental Protection Agency 26 Federal Plaza New York, Nev Tork 10278 PROJECT: TBS V, BPA CONTRACT NO: 68-W9-0002 Vork Assignment C02048 DCN: TESV-C02048-LR-CVXN SUBJECT: Review of Technical Memorandum II Results of the Field Program, Tutu Service Station Investigation, St. Thomas, U.S. Virgin Islands Dear Ms. Kvan: COM FEDERAL PROGRAMS CORPORATION (COM Federal) has completed its review of Geraghty & Miller's (G&M's) report "Technical Memorandum II, Results of the Field Program, Tutu Service Station Investigation, St. Thomas, U.S. Virgin Islands", prepared for the Tutu Environmental Investigation Committee (TEIC) and dated February 1993. The report was received by COM Federal on March 3, 1993. The purpose of the TBIC report is to present preliminary results of the field investigation and to determine if additional investigation is necessary before completing the remedial investigation (RI). COM Federal's general comments concerning the report are presented below, followed by specific comments with respect to the text. GENERAL COMMENTS 1. COM Federal concurs vith G&M that the downgradient extent of petroleum contamination has been adequately defined. Based on the maps, it appears that the upgradient extent of petroleum contamination can be delineated without additional wells. However, a well might be warranted to the west of Western Auto, to establish whether that facility contributes to groundwater contamination. (The Target Soil Gas Survey of the Western Auto property did not indicate any major areas of concern, however.) The locations of the proposed wells should be plotted on a map. Several questions remain as to the sources of chlorinated volatile organic compounds (VOCs) in groundwater. CDM Federal concurs with G&M that there are apparently at least two sources of chlorinated VOCs at the site - one in the vicinity of the Curriculum Building and, possibly, Tillet Gardens, the second in the vicinity of O'Henri cleaners. The Texaco and BSSQ stations do not appear to be major————— " 111 Fulton Street, Suite 710 New-yJdr, NY 10038 212393-9634 TUT O06 1635 COM FEDERAL PROGRAMS CORPORATION - . . - . , . .. . i* a subsidiary at Camp Dresser & McKee Inc. contributors of the chlorinated plume. 2. COM Federal has compared the analytical results of our split sample anlayses with GUI's results. All the split and PRP data compare within acceptable limits. Data comparison tables will be submitted to EPA following receipt of one outstanding validated data package from BPA's Monitoring Management Branch (MMB). 3. For the pumping tests, it is standard to present the following data graphically: background water level fluctuations; rainfall and barometric pressure data, if collected; and all measured water levels in all wells monitored during testing. 4. It would be useful to present subsurface soil data from borings and monitoring wells on the same map in the RI report to create a more integrated picture of soil contamination. 5. Detailed core logs and drillers logs have not been provided. Though not crucial for this technical memorandum, they should be presented in the RI report. 6. The VTHA supply veils should definitely be included in the next round of groundvater sampling. A schedule of pumping should be included, if available. SPECIFIC COMMENTS 1. Page 2-1, Paragraph 2, first sentence - The other principal contaminants of concern (i.e., PCB, TCB and DCB) should be named. 2. Page 2-2, Paragraph 1 - The logs in Appendix A do not shov blows/foot or HNu readings as indicated in this paragraph. 3. Page 2-2 - The fact that BPA's contractor, COM Federal, split a nuaber of samples with Geraghty and Miller and sent them to a separate laboratory for confirmatory analysis should be mentioned in the QC sample discussion in the RI report. (As mentioned in General Comments, the results of the separate analyses are comparable.) 4. Page 2-3, Section 2.2.1 - The outcrop descriptions are not provided. 5. Page 2-4, Paragraphs 1 and 2 - Downhole drilling pressure, rate of penetration per foot and water circulation observations are not provided. Nor are the bedrock coring logs. 6. Page 2-4, Section 2.2.3 - The downhole geophysical logs (caliper and sonic) are not provided in this technical memorandum. 7. Page 2-6, Paragraph 2, last sentence - the sentence should read that veil MV-12D was completed as a deep, not a shallow, well. 8. Page 2-12, Section 2.4, Paragraph 2 - GUI needs to mention that the maximum aquifer test pumping rate was constrained by the capacity of the on-site water treatment system. Thus the aquifer was not stressed as much as it could have been. 9. Page 2-13, Paragraph 1 - G&M should specify the frequency of manual «• Printed on R«yded Paper COM FEDERAL PROGRAMS CORPORATION a subsidiary of Camp Dresser & McKee Inc. vater level measurements collected during the test. • ~ ' 10. Page 2-13, Section 2.4.2, first sentence - The text should make clear that the tvo veils vere not pumped simultaneously. 11. Page 3-2, Section 3.1.2 - Hov do the volcanic sandstone and siltstone described equate to the formations described under regional geology? 12. Page 3-10, Paragraph 4, last sentence - Tvo possible explanations exist for the difference in heads observed betveen the shallov and deep veils: 1) local perched conditions Bay exist; or 2) a recharge source exists in the vicinity. 13. Page 3-12, Paragraph 1, last sentence - The veils for vhich the data are not usable should be specified. 14. Page 3-12, Section 3.3.1 - Dravdovn data should have been superimposed on a variety of type curves to assess the type of aquifer before determining that the Cooper-Jacob straight-line method vas the appropriate one to use. 15. Page 3-12, Section 3.3.1, 6th sentence - The text states that correction of dravdovn values vas not necessary, but on the associated figures, the y-axis is labelled "corrected dravdovn". * • ' ** 16. Page 3-14, Section 3.3.2 - If the data for the pumping test of MW-6D is not useable due to the rainfall as stated on page 3-12, then G&M should x-v qualify the discussion and numbers presented in this section. Based on figures 3-8 and 3-9, COM Federal believes that steady state conditions had not been reached after 24 hours of pumping and that the shape of the dravdovn curves indicate that the system is being devatered. 17. Page 3-15 - The "dravdovn" measured in veil NV-7 is less than 0.1 foot. This change may not be due to the pumping veil, located 230 feet away. 18. Page 4-1, Section 4.1 - The results from the soil boring samples should be considered in conjunction vith those from the monitoring veils because they are really the same medium. Treating them separately makes it harder to assess the distribution of contaminants in .subsurface soil. 19. Page 4-3, Paragraph 2, item 2 - Total Petroleum Hydrocarbon (TPB) results are often elevated in fine-grained soils because the extraction method is more efficient due to the greater surface area from vhich the solvent can extact the TPH. This effect, hovever, does not result in "false positives*. 20. Page 4-6, Section 4.3.1, Paragraph 1, fourth sentence - Only sample SS-5 is from the Tillett property; Sample SS-3 is from the Curriculum Building. 21. Page 4-7, Section 4.5 - The analytes that are present above background concentrations should be listed, especially if any of them are contaminants of concern from a health perspective. 22. Page 4-8, Section 4.6 - See preceding comment. ^_ ^ . „ . • „ , . „ . ' TUT 006 1637 Printed on Recycled Papa COM FEDERAL PROGRAMS CORPORATION ' a auMdtery at Ctimp DressM & McKee Inc. • •• . '•• ' • - - •;-' ;-•• i • " • • . : - ' "•'.'. '.-.v.. • : - - . . •••••• 23. Page 6-1, Last Paragraph - G&M should try to obtain more information on which supply veils are pimping and at what rates. . . ' 24. Page 6-2, Section 6.2, Paragraph 2, last sentence - G&M has not provided adequate evidence for "false positive11 TPH concentrations. TPH is certainly not unexpected in a service station study. Furthermore, as stated earlier, fine-grained soils Bay result in elevated concentrations due to acre efficient extraction, but should n o t result i n false-positive values. . . . . - - 7 - V 25. Page 6-2, Section 6.2, Paragraph 3 -The focus of the BNA discussion should not be on the possible laboratory artifacts* but rather on the polynuclear aromatic hydrocarbons that were detected at a number of properties. . • '•. . _ - • ' V -:,'.'. ,/-.; ': ''.': i- :-':"" ;.;- :'.;•;;-;. --. '•-.-,.. '' "• ', ' 26. Page 6-3, Paragraph 3 - According to the naps, arsenic vas detected at 185 ppm in boring B-13 on the O'Henri property. This is three orders of Magnitude higher than background.. '...:r';\ . :^ r -; ..^' , ."...- "'••.- 27. Page 6-5, Paragraph 3 - Based on the groundvater results presented in this report, it appears that theupgradient extent of petroleum constituents can be defined vith the existing data. Additional yells aiight be warranted to conclusively establish liability vith respect to chlorinated compounds. . . - , ;,C. " ;; . . 28. Page 7-1, item 2 - EPA Region II only accepts total, not dissolved, •etals results in remedial investigations. Total aetal values are used both in the assessement of groundvater risk and in evaluating remedial technologies. :; . . -. , V....;.' :._,-/.; :•-"•• * ;;-V'3:.. v- '••.'-;•/ •'••,: •- '.-". . 29. Figure 3-1 - The labelling of geologic units from veil to veil is inconsistent on this diagram. : .-. •./.";.';,;. .'.-""-/;'.."-.•'"!; •":;•'•' •'•'"., If you have any questions concerning^ this reviev, please contact me at (212)393-9634. _._,..• . . ' • ". • ''- :.>. :;V'--V;; •^••^, ":••:'••.- -..':•::' Sincerely, •. •.•-;..-,.•_•;'/•:;". ._ ; .-•..-.' • : v'.":' '; '.•'.";'-_-''•.•'-;{' ;1 .^...•'';•" • CUM FEDERAL PROGRAMS CORPORATION ^ : ; ; :- ^ * / Sally Odland Vork Assignment Manager Printed on Recycled Paper TUT 006 1638