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Ground Water Contamination Occurrence and Sources in the Tutu Area, St. Thomas, U.S. Virgin Islands

Collection
Federal Reference
Sub-shelf
EPA SEMS (Superfund, Region 2)
Kind
Government Report
Island
St. Thomas
Date
1993
Pages
70
Text
Native Text

Arthir D Little Ground Water Contamination Occurrence and Sources in the Tutu Area St. Thomas, USVI Prepared for RoMnman & Colin November 1,1993 Arthur D. Little, Inc. Reference 44199-15 II..11' OO5 1638 *64569* 64569 Table of Contents Page Executive Summary 1.0 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 2.0 Potential Contaminant Sources in the Tutu Area . . . . . . . . . . . . . . . . . . . . . 2 2.1 Former LAGA Textile Facility ..................................... 2 2.2 US Virgin Island Department of Education Curriculum Center . . . . . . . . . . . . . . 6 2.3 Tutu Esso ................................................... 7 2.4 Tutu Texaco ................................................. 8 2.5 Ramsay Motor Company/Cobuild .................................. 9 2.6 Antilles/Gasset Motors/Consolidated Auto Parts Facility ................... 10 2.7 Rodriguez Auto Parts (EssoXShell Oil ............................... 11 2.8 O'Henry Cleaners ............................................. 11 2.9 Jim Tillett, Inc. …

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Arthir D Little Ground Water Contamination Occurrence and Sources in the Tutu Area St. Thomas, USVI Prepared for RoMnman & Colin November 1,1993 Arthur D. Little, Inc. Reference 44199-15 II..11' OO5 1638 *64569* 64569 Table of Contents Page Executive Summary 1.0 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 2.0 Potential Contaminant Sources in the Tutu Area . . . . . . . . . . . . . . . . . . . . . 2 2.1 Former LAGA Textile Facility ..................................... 2 2.2 US Virgin Island Department of Education Curriculum Center . . . . . . . . . . . . . . 6 2.3 Tutu Esso ................................................... 7 2.4 Tutu Texaco ................................................. 8 2.5 Ramsay Motor Company/Cobuild .................................. 9 2.6 Antilles/Gasset Motors/Consolidated Auto Parts Facility ................... 10 2.7 Rodriguez Auto Parts (EssoXShell Oil ............................... 11 2.8 O'Henry Cleaners ............................................. 11 2.9 Jim Tillett, Inc. ............................................... 13 2.10 Archies Welding and Auto Body Repair . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 2.11 Tracy Dodd Used Car Lot . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 2.12 Overseas Steel Fabrication . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 2.13 Virgin Islands Housing Authority/Tropical Motors . . . . . . . . . . . . . . . . . . . . . . . 14 2.14 Four Winds Plaza Partnership . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 2.15 Western Auto ................................................ 16 2.16 Home Petroleum, Inc7Caribbean Gas Corp. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 2.17 Old Tutu Wastewater Treatment Plant . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 2.18 Classic Printers, Inc. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 2.19 Fellowship Church/Storage Facilities, IncTWest Indies Enterprises, Inc. . . . . . . . . 18 2.20 Household Septic Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 3.0 Site Physical Characterization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 3.1 Geology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 3.2 Hydrology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 4.0 Tutu Site Environmental Investigations . . . . . . . . . . . . . . . . . . . . . . . . . . 22 5.0 Chemical Behavior in the Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 5.1 Chemical Movement in the E n v i r o n m e n t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 5.2 Chlorinated Solvent Degradation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 6.0 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 List of Appendices Appendix A LAGA Drycleaning Unit Waste Streams Appendix B Deed Search Appendix C Degradation of Chlorinated Compounds ArthirD Little TUT OO5 1639 Table of Contents (continued) List of Figures Figure 1-1: Turpentine Run Basin Aquifer in the Tutu Area Eastern St. Thomas, U.S. Virgin Islands, (1987) Figure 1-2: Tutu Area Base Map Figure 2-1: Potential Contaminant Sources in Tutu Area Figure 2-2: LAGA Building Floor Partition Plan Figure 2-3: PCE Flow, Showing Waste Streams LAGA Dry Cleaning Operations Figure 2-4: Travel Distances or Contaminants Originating at the Alleged Disposal Pit Figure 4-1: Soil Gas Survey Areas Figure 4-2: Chlorinated Compounds in Soil (ug/kg) Figure 4-3: Chlorinated Compounds in Ground Water (ug/1) Figure 5-1: Simulated Ground Water Elevations (ft) Under Non-Pumping Conditions Figure 5-2: Two Dimensional Representation of the Principal Fracture Plains Oriented Along Alleged Infiltration Pit Figure 5-3: Two Dimensional Representation of the Principal Fracture Plains Oriented Along Monitoring Well #1 Arthir D Little T °05 164° Executive Summary Arthur D. Little, Inc. (ADL), investigated the sources and occurrence of soil and ground water contamination in the Tutu area, focusing on the potential for the former LAGA Industries, Ltd. operations to have negatively impacted the Tutu Valley aquifer. Based on consideration of site characterizations to date, ADL's environmental modeling, the Plaintiffs' environmental modeling, and the historical operational characteristics of the former LAGA facility, we have found no conclusive evidence that the former LAGA textile operations contributed to contamination on the U.S. Virgin Islands Department of Education Curriculum Center property. Also, there is strong evidence that contamination released during the LAGA operations, if any, has not entered the Plaintiffs' wells. Further, there are numerous other potential sources more likely to have caused contamination in the Plaintiffs' wells. Allegations of contamination by the former LAGA textile facility have focused on chlorinated solvent contamination related to the drycleaning operation at the former textile facility. We reviewed in detail the former LAGA facility drycleaning operation. These operations used good state-of-the-art chemical handling practices and modern solvent reclamation machinery. The process was fully contained indoors, on a concrete slab. The operation produced one aqueous waste stream which was most likely discharged to the public sewer, and one solid waste stream which was disposed of off-site. These findings show that the former LAGA drycleaning operations are unlikely to have released chlorinated solvents to the soil or ground water. Chemical analysis of soil and ground water from the Curriculum Center property does, however, show contamination by petroleum hydrocarbons (benzene, toluene, xylene, and ethylbenzene) and chlorinated hydrocarbons. Our review of the available data and activities both on and in the vicinity of the Curriculum Center suggests that the contamination on the Curriculum Center property is most likely due to either Curriculum Center activities or migration of contamination onto the Curriculum Center from other locations. Further, the pattern of observed contamination combined with the characteristics of the site hydrology and geology support the following observations: • The chemical sources responsible for contamination in the Plaintiffs' wells are most likely closely aligned with the Tutu gut, not with sources more removed from the gut, such as the Curriculum Center location. The Plaintiffs' model of the Tutu Valley aquifer hydrogeology (by Mr. Wexler) suggests that travel times for contaminants, if any, released at, for example, the Curriculum Center would require more than 50 years to reach the Plaintiffs' wells, if they would reach them at all. • The pattern of chlorinated chemicals detected in ground water between the Curriculum Center and the Plaintiffs' wells suggests that much of the chlorinated compound contamination was released into dominantly anaerobic conditions, such as that likely to be found in the filtration basins on the Texaco and possibly Esso properties. The measured conditions in ground water at the Curriculum Center are highly aerobic, and, therefore, much less favorable for degradation of perchloroethylene (PCE). PCE released directly to ground water in the Curriculum Arthir D Little "UT COS 1641 Center would be unlikely to produce the dichloroethylene (DCE) and vinyl chloride concentrations detected between the Curriculum Center and Tutu Texaco. The observed spatial distribution of chlorinated chemicals in soil and ground water in the area between the USVI Housing Authority (VIHA) facility and the Plaintiffs' wells further suggests the likelihood that there are several sources of chlorinated compounds released to the environment in the Tutu Valley area. Facilities which may have released chlorinated compounds into the environment, based on their past or present activities, include Esso Tutu, Esso Rodriguez, Tillett, Inc., Archies, Ramsay Motors, Antilles, O'Henry, Old Tutu WWTP, Tutu Texaco, Western Auto, and VfflA. Many of these facilities which are geologically and hydrologically close to the Plaintiffs' wells, have documented chemical spills, leaking tanks, direct underground disposal, and generally poor chemical handling practices. Additionally, household septic systems and formerly operating (now closed) facilities could be sources. OOS 1642 Arthir D Little 1.0 Introduction Arthur D. Little, Inc. (ADL) was retained by Andreas Gal, Paul Lazare, and Panex Co. to investigate allegations that LAGA textile operations contributed to observed ground water contamination at the Plaintiffs' well fields. We Were initially contacted by Rosenman & Colin regarding the possibility of providing technical support in matters related to environmental contamination in the Tutu Valley area in February 1993. During August 1993, we began supporting Rosenman & Colin in matters related to U.S. Environmental Protection Agency (USEPA) actions in this area. Subsequently, we were retained specifically to support this litigation at the beginning of September 1993. The Plaintiffs, Four Winds Plaza Partnership and PID/Harthman, have operated production wells in the Tutu basin (Figures 1-1 and 1-2). In 1987, their production wells were closed down by order of the U.S. Virgin Islands (USVI) Department of Planning and Natural Resources (DPNR) due to the detection of contaminants above maximum contaminant levels (MCLs) for potable water. Four Winds Plaza Partnership reinitiated ground water production in 1988 and currently extracts about 2,000 gallons per day (GPD) for the purposes of non-potable carwash supply28. To determine whether or not LAGA textile operations contributed to the Tutu aquifer contamination, we reviewed pertinent documents, conducted field investigations, and modeled contaminant transport and fate. These activities were conducted principally during September and October 1993. The field sample collection and chemical analysis conducted by ADL are described in a separate document35. The rest of this report contains the following sections: • Section 2.0 summarizes our opinions regarding potential sources of chlorinated compound contamination in the Tutu Valley area • Section 3.0 summarizes our understanding of the geology (soils and rocks) and hydrology (water occurrence and movement) of the Tutu Valley area • Section 4.0 summarizes the relationship of prior investigations to the potential sources identified in Section 2.0. • Section 5.0 summarizes our understanding of chemical contamination movement and degradation in the Tutu Valley environment • Section 6.0 lists the references cited • Appendices A through C provide supporting information * Superscripted numbers located throughout the text identify references found in Section 6.0. Arthir D LrttJe TUT OO5 1643 2.0 Potential Contaminant Sources in the Tutu Area Section 2.0 presents our evaluation of potential sources for chlorinated chemical contamination in the Tutu Valley area. The area of the former LAGA Textile facility is discussed in two sections (2.1 and 2.2) to distinguish between activities and potential releases while the facility was used by LAGA for textile manufacturing and the subsequent activities by the USVI Department of Education. As a general comment, automotive fuel stations and repair operations historically used chlorinated solvents for degreasing and as a carrier agent for vehicle maintenance products. As environmental laws and sensitivities have changed over time, the use of chlorinated solvents has decreased due to their hazardous nature. Therefore, even though chlorinated solvents may not be present at a site today, they may have been used historically. This would be true for all of the vehicle maintenance facilities present in the area (e.g., Texaco, Rodriguez, Ramsay, Antilles, VIHA, Department of Education). Additionally, there are numerous other historic uses of chlorinated solvents and, consequently, potential sources of chlorinated solvent contamination in the Tutu Valley area. Several of these are described below. Figure 2-1 shows the location of the facilities discussed below. 2.1 Former LAGA Textile Facility The LAGA building was designed by Lockwood Green and constructed by the West Indies Company, Inc., in about 1970 on behalf of LAGA Industries, Ltd. The LAGA Industries textile operation began production in 1971, producing wool and polyester knit blend cloth. The primary operations were knitting, pressing patterns, and receiving/shipping. No cloth dying or other treatment was conducted. All polyester knit blend cloth was drycleaned at the facility. Wool cloth that became soiled was also drycleaned at the facility. Operations at LAGA ceased about 1978 and was subsequently sold to Panex Co. in 1979. The building was vacated in about 1982, at which time the USVI Department of Education renovated, and later occupied the building. The focus of Plaintiffs' allegations regarding the LAGA facility concern the drycleaning operation. Two former employees of the LAGA textile operation (Winston Smith and Anthony Richards) have alleged that spent PCE (also known as tetrachloroethylene, tetrachloroethene, perchlorethylene, and perc) and cooker residue were disposed to a pit located outdoors20. Mr. Smith claimed that PCE from the drycleaning still and muck cooker sludge were disposed to the alleged pit via a piping system. As described below, however, this account is not consistent with the environmental investigation results, nor is it the most likely mode of equipment operation. Further, Mr. Smith and Mr. Richards do not seem to have a clear and accurate recollection of the process. For example, Mr. Richards recounts adding water with cleaning solvent in the washer20. This would constitute wet washing rather than drycleaning, which was the LAGA operation. 2 ArthirD Little 5 644 Geraghty & Miller34 installed three soil borings at what they believed was the alleged disposal pit area. Geraghty & Miller apparently located the alleged disposal pit area based on the location of a concrete filled trench in the floor they believed to be the alleged disposal pipe. In Geraghty & Miller's soil boring records, however, there is no account of a sludge present at this location34, as would be expected if the disposal practice were as described in the testimony of Mr. Smith and Mr. Richards. Subsequent to the Geraghty & Miller investigation, we installed a deep borehole at the Geraghty & Miller boring site and also did not find sludges present35. Our work at other Superfund sites has shown that if a sludge was disposed at a site, then there is a record of it at the site would be present even long after disposal. The lack of any sludge or high soil concentration at the rear of the former LAGA facility, therefore, suggests that sludges were not deposited there. As part of our activities, we reviewed the LAGA drycleaning operation to assess the likelihood of a release of PCE to the environment. Overall, we believe that the likelihood of a significant release is extremely low. The LAGA drycleaning operations were state-of-the- art with the most advanced solvent recovery system of the day. The system was closed loop with no allowance for liquid solvent release outside the system. As described in detail below, there were two waste streams from the drycleaning operation, an aqueous waste stream from the solvent water separator and a solid (sludge) waste stream from the cooker, which was hauled to an off-site disposal location. Further, feedstock chemicals were handled in a manner that minimized the potential for a release to the environment. There were also undoubtedly fugitive emissions to the air. These would not, however, contribute to soil or water contamination. The drycleaning operation purchased by LAGA in 1971 used new equipment that included drycleaning washers, dryers, solvent/water separators, sniffers, solvent stills, and a muck cooker. Figure 2-2 shows the general location of this equipment in the building. In this process, fabric is placed in the drycleaning washers where PCE contacts the cloth and dissolves stains or other extraneous materials on the cloth. The process is referred to as "drycleaning" because no water is used on the cloth. After the cleaning cycle, the cloth is removed from the machine and placed in dryers that remove the PCE through the addition of hot air. The dryers are equipped with condensers to collect the trace amounts of drycleaning solvent in the air and return it to the dirty solvent still. Dirty solvent from the washer following each wash cycle is sent to a primary still which boils the solvent away from the entrained greases and dirt. The clean solvent from the still is piped back to the clean solvent tank. The muck (e.g., dirt, oils, and grease) accumulated in the still following the still cycle is then hardpiped to the muck cooker. The cooker further heats the muck and returns the little solvent residue still remaining back to the dirty or clean solvent tank, depending on the quality assurance needs. Eventually, the residual oil from the muck cooker, after a series of cooking cycles, builds up and must be removed. Some solvent would be temporarily released from the drycleaning process through volatilization of solvent on fabric removed from the washers. This vapor would be retrieved from the indoor atmosphere by the sniffers equipment and reintroduced into the clean solvent tank. Figure 2-3 shows the solvent flow and recovery systems for this operation. Figure 2-3 also indicates the two waste streams ArthirD Little T which are discussed further below. The entire drycleaning operation was conducted indoors, aboveground, over a 5-inch thick, reinforced concrete floor, in the location shown in Figure 2-2. For a short period after the facility startup until the equipment described above was installed, the LAGA facility sent cloth to Andrex for drycleaning2 and used a smaller Permac drycleaner unit at the facility. The Permac equipment was purchased in April 1970, before the plant began operation, and the system used in the former LAGA facility after the Permac, was purchased in November 1971, during the first year of operation. The Permac unit had essentially the same solvent recovery process built into the unit, except for the muck cooker. The Permac machine, therefore, in addition to the aqueous stream from the solvent/water separator, would have produced a waste stream similar to the muck sent to the muck cooker in the process described above. The Permac unit also had filters which would have contained PCE and would need to have been disposed of. We are not aware of any specific information about disposal of these waste streams. The aqueous waste stream from the solvent/water separators associated with the PCE recovery systems (Figure 2-2) was most likely channeled to the sanitary sewer where it would have been directed to the local publicly operated treatment works. Normal practice during the 1970s was to discharge the aqueous waste stream to a sewer. If there were a pipe discharging to the ground or a pit by the building, it would most likely have been from the tinier frame, which was in the same room as the drycleaning equipment and produced a clean (distilled) water discharge. Drawings by Lockwood Green indicate that a sanitary sewer was adjacent to the LAGA building, and it would be unlikely that the LAGA facility would not have connected to this sewer. Further, the main sanitary sewer line internal to the building ran beneath the room housing the drycleaning operation. The aqueous discharge from the drycleaning operation would be limited to the water driven from the wool cloth as it was dried and subsequently condensed. The polyester material does not retain water and, therefore, would not contribute water moisture to the separator systems. Since wool cloth was cleaned only when soiled, only a relatively small portion of the total cloth load at the drycleaning operation would have produced an aqueous waste stream. An estimate of the amount of solvent that would have been contained in this aqueous waste stream is provided in Appendix A. Our calculation indicates that about 0.01 pounds of solvent would be discharged each day. When discharged to the sewer, this solvent would be commingled with other sanitary wastes from the facility. The resulting solvent concentration in the sewer system would be approximately 0.01 mg/L within the main sewer line. The aeration system at the waste water treatment plant and turbulent flow through the sewer piping network would be adequate to reduce this amount of solvent to a negligible concentration, thus removing the LAGA solvent as a source of ground water contamination (calculation method prescribed in Appendix A). If the aqueous waste stream were discharged to the ground surface, it would be subject to ArthirD Little 441t««pwtjp«rapcrltrtM»-M 4 TUT GO'-- 1646 surface runoff, infiltration, and evaporation, similar to rainfall. Using the estimated mass balance for rainfall in this area49, about 8% of the discharge water would reach ground water. Over the eight years of plant operation, this would be approximately 2.6 pounds of PCE. Also, because the PCE would evaporate somewhat faster than the water in which it was carried, the actual amount of PCE reaching the ground water would be less than this estimate. If the aqueous waste stream were released to a pit, it would be subject to evaporation and infiltration. The evaporation rate would be approximately the same as the evaporation rate from a lake surface. We did not have evaporation rate data for St. Thomas, but in a generally similar climate, southern Florida, the lake surface evaporation rate is approximately 60 to 65 inches of water per year, using 60 inches/year as a lower bound estimate or 0.16 inches per day. One source alleged the existence of a 9-foot diameter disposal pit. The area of such a pit would be approximately 64 square feet As long as the surface of the pit were moist, the average daily evaporation would be 0.85 ft3 (about 6.4 gallons), or about 70% of the average daily aqueous discharge. In the absence of any further information about the alleged pit, the rate of infiltration into the ground is difficult to estimate. It would likely, however, be relatively slow because the soils in the area have low hydraulic conductivity and the bedrock is relatively competent (low fracture density). Further, any PCE reaching the bedrock surface would have to travel approximately 30 feet further down through bedrock to reach the first waterbearing fracture. Then, using the hydraulic conductivity and gradient information presented by Wexler21, any PCE reaching ground water would travel at a rate of approximately 2 feet per year under pumping conditions and one foot per year under non-pumping conditions. The actual travel velocity would be retarded by the effect of adsorption. As a cross check on these estimates using the Wexler hydrogeologic model, we estimated the travel velocity of MTBE from the available monitoring data. If the release date is assumed to be 1990 from either the Tutu Texaco or Tutu Esso stations, the travel velocity in the gut area would be approximately 41 m/year. This would be a maximum travel velocity because the MTBE was likely released before 1990. The model presented by Wexler showed a hydraulic conductivity of 0.25m/day (.82ft/day) in this area. Using a gradient and hydraulic conductivity of .113 and 6.67X10"3m/day, respectively in the LAGA facility area, again from the Wexler model, the ground water velocity in the LAGA area, calculated by scaling the MTBE velocity down in proportion to the hydraulic conductivity in this area, would be less than 4.0 feet per year. Figure 2-4 illustrates the flow paths and distances for contaminants released at the alleged pit area. At this rate, if contaminants were released at the LAGA facility in 1971, they would not have reached the Plaintiffs' wells to date, having traveled only about 72 feet during this period. The other solvent containing waste product from the LAGA drycleaning operation is the spent waxy sludge from the muck cooker. This sludge is a liquid when removed from the cooker but quickly sets up and forms a waxy solid with about 2% solvent remaining. Based on our best estimates of the drycleaning system operation, about 1 10 tons of this waxy 5 Arthir D LrtUe TUT 005 ±64? sludge would have been produced over the operational period of the LAGA facility. These estimates of sludge production rate and PCE content are based on a comparable operation for which records are available. We understand that this sludge was removed from the LAGA facility and disposed elsewhere. Again using the alleged 9-foot diameter disposal pit site, this material would be about 60 feet deep in the alleged disposal pit if disposed of on- site (calculation provided in Appendix A). This waxy sludge, if exposed to the environment, would be expected to leach the PCE extremely slowly and would undoubtedly still be obviously present if disposed in a pit The lack of any on-site evidence of sludge from the environmental investigations, therefore, supports the testimony that this material was not disposed of on-site. Considering chemical handling, operational incidents can occur during loading and unloading of solvents, and potentially, leaks or spills could occur. Solvents generally were delivered to LAGA in 55-gallon drums that were stored indoors over reinforced concrete21. The drums would not have been opened until they were indoors, and the PCE was introduced into the drycleaning machines indoors. Therefore, any spills would have occurred indoors. Assuming that a gallon of solvent is spilled on the floor, then it would likely wet the floor and begin to absorb into the concrete; however, prior to passing through the 6-inch thick reinforced concrete floor, the solvent would volatilize and be intercepted by the sniffers and recovered. One LAGA worker has attested that small spills were rapidly volatilized in this manner20. In summary, although the LAGA operation did use solvents of a type found in the aquifer, it is most likely that they were disposed of off-site and did not contribute to ground water contamination in the Tutu Valley aquifer. Further, if there were any on-site disposal, the contaminants would not have reached the Plaintiffs' wells. 2.2. US Virgin Island Department of Education Curriculum Center The Department of Education occupied the former LAGA textile building in 1981. At the time of their occupation, the property was free of drums and waste products21722. During our tour of the Department of Education building in October 1993, we identified the following shop areas: painting, masonry, plumbing, woodworking, kitchens, and welding/metal working. We noted a storage room containing paints, thinners, and degreasers, and other rooms for miscellaneous chemical storage. The outside grounds were littered with drums, pails, chemical sacks, and scrap parts. Most of the chemical drums were highly rusted, cracked, or grown over. The USEPA inspection team noted similar conditions in February 1989 and June 198923. During ADL's tour of the facility, we observed a shallow waste disposal pit where liquid had been channeled to the pit The pit was also fed by a PVC pipe line that appeared to be connected to the sink of the paint room at the Department of Education. There was obvious Arthir D Little TUI U05 164B red and white colored soil staining in the pit and in the paint room sink. The pit sediments possessed a strong organic chemical odor. We sampled the shallow soil at this location and detected benzene, toluene, ethylbenzene, and xylenes (BTEX). We also observed two other sinks with drains to the ground around the building; one in the kitchen shop, and one outside the welding shop. Sampling and chemical analysis has shown petroleum hydrocarbon and chlorinated hydrocarbon contamination of the Curriculum Center property. A soil gas sample collected by Geoscience Consultants, Ltd.37 in 1987 at one location on- site showed detectable levels of PCE in soil gas. Shallow soil sampling and drum sampling by the USEPA detected various hydrocarbons. A boring and monitoring well program conducted by TEIC indicated low levels of PCE (non-detect to 170 ug/L) were present in shallow soils, and low to moderate levels of PCE (1 ug/L to 590 ug/L) were found in ground water34. ADL tested additional shallow soils and ground water at the site in October 199335. The results indicate that much of the shallow soil is free of chlorinated compounds; however, one shallow sample near a former Department of Education drum storage area contained elevated levels of PCE (169 ug/kg) and TCE (6.5 ug/kg). Also, as mentioned above, a soil sample from the paint shop sink discharge pit contained BTEX. The origin of this contamination can not be clearly established with the available data. The poor chemical management practices at the Curriculum Center, combined with the types of chemicals used at the Curriculum Center, as noted above, suggest that the source could be releases from the Curriculum Center operations. Some of the contamination could also be due to migration from nearby properties, such as VIHA or Texaco. 2.3 Tutu Esso The Tutu Esso station is close to the Four Winds Plaza well field and is along Tutu Gut This facility began operations in 1969. A CERCLA 104(e) notification by Esso indicated that Esso used/stored waste oil, a variety of solvent based auto flushes, treatments, degreasers, cleaners and lubricants. The Esso station has vehicle maintenance bays, two underground oil/water separators, and an underground waste oil tank. At least five underground fuel storage tanks have been used on-site, and at least two have been excavated. The report by Garrett48 provides more detail on the underground chemical handling systems and practices. Leaks from underground storage tanks and discharges from the Esso oil/water separators to an alleged infiltration septic system have been well documented (e.g., HRS documentation record and Four Winds inspection document). Esso employees have reported that solvents were commonly disposed to waste oil pits which were pumped out and disposed to the toilet. Esso workers have also testified to pipeline leaks5. The sampling and analysis record indicates that in August 1987, TCA (58,000 ug/kg) and PCE (110,000 ug/kg) were detected Aithir D Little !UT in Esso waste oil/water separator samples, and in September 1988, TCA (100 mg/kg) and PCE (65 mg/kg) were again detected. Soil samples collected at the base of a leaking waste oil tank excavation at Esso were analyzed and PCE (91,000 ug/kg) and TCA (42,000 ug/kg) were again detected. In 1990, an EPA contractor collected oil samples from the waste oil UST that indicated PCE (30,000 ug/kg) and (25,000 ug/kg) were present5. Samples collected at the holding tank have indicated that presence of TCE (63,000 ug/kg) and TCA (43,000 ug/kg)5. A soil gas survey was conducted by Belgodere & Associates on the Esso property in April 1988 and DCE, TCE and PCE were detected. Testimony by Four Winds Plaza representatives indicate that during excavation of a water cistern, free product oil seeped into the excavation, and 10 drums of oil were removed. The discharge points for the oil/water separators and sanitary facilities have not been established. The Report by Mr. Carlos Garrett48 suggests the possible use of a septic tank and leaching pit, similar to the system used by the Tutu Texaco service station. A pit of this type is designed to effectively transfer b'quid into the ground and would allow a minimum of solvent volatilization. The anaerobic conditions common within these leach pits would have contributed to solvent biodegradation. For example, the anaerobic environment of the septic tank would have enhanced the biodegradation of any PCE or TCA into DCE, TCE, and vinyl chloride. Further, the presence of toluene tends to further accelerate the degradation (Appendix C). In contrast, our measurements of water in the Tutu aquifer near the Curriculum Center show adequate dissolved oxygen (7.9-8.6 mg/1 oxygen) and nitrate content to be considered aerobic. Thus, biodegradation of PCE and TCA is not expected to readily occur in the Tutu aquifer. In summary, the available data and records indicate that Esso used or processed chlorinated solvents, and that these solvents were likely to have been released to the environment through underground storage tank leaks or by discharge from oil/water separators. 2.4 Tutu Texaco The Tutu Texaco station began operation in 1966. This facility is located directly across the street from Four Winds Plaza and near Tutu Gut. During its history of operation, at least six underground storage tanks were installed, four maintenance bays were used, two fueling islands were operated, and an oil/water separator connected to a leaching tank was operated. Currently, there are also a total of about 75 drums stored on-site split between two separate locations, and two aboveground bulk storage tanks. The Texaco CERCLA 104(e) notification indicates that the Texaco station stored waste oils, a large variety of solvent based auto flushes, treatments and degreasers, cleaners, and lubricants. Among the hazardous constituents found in these specific products were TCA and PCE. During ADL's October 1993 tour of the Texaco station, we noted the presence of a tire puncture seal chemical that contains PCE and a parts cleaner chemical that contains chlorinated aromatic solvents. ArthirD Little TIJT 005 The documentation record of Texaco's operational history indicates that large releases of gasoline have occurred in the past, including losses of 100 to 150 gallons in 6/8124 and 4,072 gallons in 198736. Tank tightness testing in 1980 and tank inspections in 1988 confirmed that three underground storage tanks had lost integrity. When these tanks were finally removed, it was noted that strong odors of petroleum hydrocarbons and elevated HNu readings were recorded in the excavation26. EPA contractors in 1989 also noted a lack of containment for the drum storage area, and stains and petroleum saturated soils have been noted on the property26. A DPNR inspection of the facility in 1987 revealed seven violations of Virgin Islands regulation related to improper hazardous waste storage, soil contamination, illicit septic system hookup, and contamination of a storm sewer. During ADL's tour of the property in October 1993 we also noted a lack of secondary containment for drum storage areas and petroleum-like staining on the ground. An inspection of the Texaco station by Mr. Carlos Garrett of GVA Consultants in 1991 indicated that an oil/water separator was connected to an infiltration pit The infiltration pit reportedly contained about 1 1/2 feet of free product on the surface48. This infiltration pit would have a tendency to enhance degradation of chlorinated solvents in the same manner as the Esso infiltration described in Section 2.3. The chemical sampling record for the Texaco station indicates that TCA (2400 ug/kg) was present in Texaco's waste oil in August 1987 and, in September 1988 DCE (10 ug/kg) was found in soil samples. In June 1988 soil samples were found to contain TCE (39 ug/kg) and PCE (160 ug/kg). In July 1989, waste oil samples were collected that contained TCA (3900 ug/kg). In 1987, a soil gas survey of the Texaco station area conducted by GeoScience Consultants Ltd. showed PCE in air collected from the unsaturated zone37. In summary, the Texaco station used and continues to use chlorinated solvents such as PCE, and their waste management practices are such that ground water at the site could readily become contaminated. In addition, their use of a septic tank for waste disposal further enhances the potential for chlorinated solvent degradation to other chlorinated compounds (i.e., TCE, DCE, and vinyl chloride). 2.5 Ramsay Motor Company/Cobuild Ramsay Motor Company initiated operations in the Tutu area about 19784. Ramsay is located northeast of Four Winds Plaza along Tutu Gut. Ramsay Motor operations include at least three vehicle maintenance bays, an underground waste oil storage tank, a large scrap parts building, a vehicle painting operation, and a large drum storage area. Prior to Ramsay's operation, Cobuild operated a car repair facility from about 1974 to 19784. A CERCLA 104(e) notification for the facility indicates that waste oil, a large variety of solvent based auto flushes, treatments, degreasers, cleaners, and lubricants were used at the facility. The hazardous chemicals present in these products includes TCA and PCE27. During ADL's tour of the Ramsay facility in October 1993, we observed a brake parts 441Mteip«rLfpfnpart.tx1M«-»l 9 Arthir D Lrttle TUT cleaner that contains PCE and TCA, and a degreaser parts washer on-site. The two soil samples installed on-site both contained PCE (2 to 6 ug/kg)6. Samples from a ground water well along the northern portion of the property also contained chlorinated solvents. The underground storage tank was backfilled rather than removed, so it is difficult to assess its integrity. During ADL's field tour of the Ramsay facility, we noted that about 40 to 50 drums are present on-site, many with open tops, and obvious staining on the drums and at the drum base. The drums did not appear to be labeled, and have reportedly been stored on-site since Water and Power Authority (WAPA) stopped receiving waste about eight years ago3. The contents of these drums are not known by facility personnel. We also noted that there were two storm drains on-site, one of which was dry (appeared uphill), and the other (appeared downhill) had a rapid flow despite the dry weather conditions. This indicates that there may be a discharge from the facility to the storm drain other than rainwater. We also noted unsecured gas cylinders and a building completely filled with scrap metal and a yard containing numerous junked cars. These housekeeping issues point to a disregard for careful handling of materials. The vehicle maintenance bay area was not fully cemented and there was a soil trench along the back wall where most of the tools and chemicals were stored. Prior to 1992, the drum storage area had no secondary containment3. We also observed several locations where the concrete floor was patched in geometric patterns, possibly an indication of backfilled sumps or underground piping connections. The general housekeeping and chemical management practices create a high potential for leakage and spills. Since this facility is along the gut, chemicals released to the ground surface have a good chance of reaching ground water. 2.6 Antilles/Gasset Motors/Consolidated Auto Parts Facility The Antilles facility is located northeast of Four Winds Plaza along Tutu Gut. The facility began operations about 1968. Their operations include several vehicle maintenance bays and an underground and aboveground storage tank. A CERCLA 104(e) notification for the facility indicates that waste oil, engine fluids and miscellaneous chemicals were stored on-site. During ADL's October 1992 tour of the Antilles facility, we located a brake parts cleaner that contains TCE and TCA. The USEPA contractors survey of this facility indicated that messy housekeeping was present in the service yard and bays, and that waste oil was observed in a drainage ditch and had traveled off-site, and other portions of the Antilles facility were also oil stained. The USEPA contractors were not able to determine the integrity of the underground storage tank but did note that drums lacked adequate secondary containment28. The DPNR investigated the Consolidated Auto Parts Facility in 1987 and found extensive staining and improper waste disposal practices. 10 Arthir D Little TUT In August 1987, waste oil samples collected from a storm ditch and drain, and in September 1988, soil samples and surface water were analyzed. The results indicate that hydrocarbons were present but chlorinated solvents were not detected. The underground storage tank has not been excavated, so it is difficult to assess its integrity. The lack of chlorinated compound detection may be due to increased detection limits caused by the high concentrations of hydrocarbons, or may be due to collection of shallow samples from which chlorinated hydrocarbons have fully volatilized, or insufficient numbers of sampling locations. Reportedly, the numerous waste drums that were collected since WAPA stopped taking waste oils have been emptied into a 10,000 gallon aboveground storage tank. We have proposed in a workplan, issued to Antilles, that a sample be collected from this tank for chlorinated solvent analysis. This sample analysis would theoretically be representative of the average waste content generated by Antilles, et al. over a long time period. 2.7 Rodriguez Auto Parts (Esso)/Shell Oil The Rodriguez Auto Parts facility is located adjacent to the Harthman property. The facility began operations about 1981. Their operations include bulk underground fuel storage, underground oil collection pit, floor drains, and a cement cistern used for car wash water collection. The facility was operated by Shell Oil from 1971 to 1981. A CERCLA 104(e) notification indicated that waste oil and miscellaneous solvents were used. No sampling data are available for this site's oils, soils, or wastewaters, so it is difficult to evaluate its impact on the environment The available information is not adequate to support an opinion on their facility's likely contribution to ground water contamination. The character of the activities, however, suggests that further investigation is warranted. 2.8 O'Henry Cleaners The O'Henry facility is located across from the Harthman property, near potable water supply wells, and along Tutu Gut The facility began a drycleaning operation in 1981. The facility uses about 6 gallons per day of PCE in the process of drycleaning fabrics, based on their PCE purchasing records29. Current and former facility equipment/operations include a leaching pit, a sump holding tank, an underground wash water tank to the north of the property, a PCE drum storage area, aboveground and underground fuel storage, drains, and effluent discharges for steam condensate from the presses, and a clothes dryer. Arthir D Little TUT °05 1653 The documentation record for O'Henry indicates that spent PCE filters and residues were disposed of on-site in the past14. During ADL's tour of the facility in October 1993, we were told by O'Henry representatives that no PCE wastes are currently generated by the facility, and that everything is recycled. ADL proposed collecting waste samples from the O'Henry process, and we were again told that no wastes are generated. Our field tour of the facility, manufacturer's diagrams, and estimated drycleaning throughput for the O'Henry equipment would suggest, however, that wastes are generated by the facility. The wastes would include the Dri Vac machine PCE residues, PCE/water separator wastewaters, spent PCE filters, and spent solvent still bottoms. In 1987, the filters were disposed to sanitary trash, and spent PCE was reported as being recycled until evaporated9. Since no records of waste disposal are available for the facility, it is possible that all these wastes are being disposed on-site. The liquid wastes may be disposed of in a leaching basin or, for the liquid from the Dri Vac machine, directly to the ground. The spent PCE filters may be disposed to the sanitary trash for on island municipal landfill disposal, since we didn't see any landfill on-site. On October 26, 1993, ADL conducted field sampling at the O'Henry facility accompanied by Nancy D'Anna and Ken Loy (International Technology). We found that contrary to what we had been told earlier, O'Henry did have filters on their solvent drycleaner and had amassed eight drums of spent PCE on-site (RCRA Waste Classification #F001). This contradicts their 1987 notification to the USEPA which states that only dry residues are generated and all the solvent is evaporated. We also located a hose connected to the drycleaning machine that led to a bucket. The LAGA drycleaning facility waste management practices were more advanced then those practiced at O'Henry. LAGA had post-still-processing of solvent sludges, whereas O'Henry has none; hence, O'Henry's wastes are far more concentrated with PCE. LAGA used sniffers to clean the indoor air of PCE and all PCE collection systems were return piped to the solvent recovery system, whereas O'Henry has no indoor air cleaning devices and solvent collected in the Dri Vac system is piped outdoors to the ground. Ground water monitoring wells in the vicinity of O'Henry show elevated levels of PCE, including 300 ug/L at MW-02 and 250 ug/L at MW-04, and at the closest former potable water well the concentrations have been as high as 7,600 ug/L. TCE and DCE are also at elevated concentrations on-site. ADL representatives collected sanitary sewer sample presumably originating at the O'Henry site (on October 27, 1993) but have not had enough time yet to analyze the sample. The available environmental monitoring data in combination with the observations on waste generation and handling described above strongly suggest that the O'Henry drycleaning operation is a source of ground water contamination by chlorinated compounds. Soil sampling at the O'Henry site has found soil PCE concentrations as high as 440,000 ug/kg. Other sampling events have shown PCE soil contamination at concentrations of 180,000, 200,000, 15, and 29 (ug/kg); TCE at 75 ug/kg; and DCE (20 ug/kg)23. 12 Arthir D Little TUT 005 1*54 2.9 Jim Tillett, Inc. Tillett Inc. is located directly across the street from Four Winds Plaza, near Tutu Gut. Tillett, Inc. began operations about 1959. The operations at Tillett, Inc. included silkscreening, textile painting, piano refinishing, stripping and varnishing, and a restaurant. Materials management practices include a raw material storage area, floor drains, and an evaporation pit Reportedly, dry residues were disposed at a local dump30. In November 1987 a soil gas survey detected hydrocarbons, PCE, TCA and TCE at Tillett, Inc. A soil sample collected near the tillett well was found to contain PCE at low concentrations34. Due to the limited available contaminant data for this facility, it is difficult to assess their impact on the environment The soil sample containing PCE, however, suggests that further investigation may be warranted. 2.10 Archies Welding and Auto Body Repair Archies is located between Four Winds Plaza and Harthman, near Tutu Gut We do not know when Archies began operations at the site. ADL personnel toured the Archies facility in October 1993. Archies business consists of two maintenance garages where welding, auto body repair, and painting are conducted. During the tour we noted paints, primers, thinners, and one empty 30-gallon drum of engine degreaser. We also observed that spare auto parts, chemical containers, and scrap metals were littered throughout the yard area. We were not able to determine during our tour the underground piping and waste management systems in place. This business has not previously been investigated by the USEPA, so it is difficult to assess its impact on the environment This type of operation, however, commonly uses degreasing solvents and, based on the waste management practices we observed, could have released contaminants to the ground. 2.11 Tracy Dodd Used Car Lot The used car lot was home of Tracy's Radiators from 1989 until May 1993. Prior land uses include another used car lot and Top Banana, a fruit sales business. In October 1993, ADL representatives toured the used car lot and identified about eight empty drums. One of the drums was labeled as containing a flammable polyester liquid and another was labeled as a fruit preservative. The rest were unlabeled. No sampling has been conducted on-site so it is difficult to assess their environmental impact 13 ArthirD Little TUT oos 1*55 2.12 Overseas Steel Fabrication This facility is located near Four Winds Plaza and consists of one field office and one trailer, both of which were empty during ADL's tour of the facility. We were not able to determine the activities of Overseas Fabrication, and no sampling has been conducted on-site to assess their environmental impact 2.13 Virgin Islands Housing Authority/Tropical Motors VIHA is located immediately up valley of LAGA on the adjoining property. Tropical Motors operated at the VIHA site prior to 1978, and VIHA afterwards. Operations that have been conducted on-site include hazardous material storage, an underground storage tank for waste oils, a vehicle maintenance garage, parts degreasing machine, and a drum storage area with about 20 to 30 drums. During ADL's tour of this building in October 1993 we located the presence of pesticides, caustics, and parts cleaners. The parts cleaners contained TCA, TCE, and PCE. The hazardous material/waste management practices at VIHA include the use of an underground storage tank for waste oils storage. The UST was pumped out in 1987 but no excavation of the tank was conducted in order to determine its integrity. We were not able to determine if the UST was registered with the DPNR. We identified a parts cleaner outside one of the garages; runoff from this area is down the concrete drainage ditch to the gravel yard. Approximately 20 to 30 drums are outdoors, most of which are unlabeled but reportedly contain waste oils. The drums are stored on gravel with no secondary containment There are several small buildings near the VIHA potable water wells No. 1 and No. 2. These buildings contain likely hazardous waste drums, which we were not allowed by VIHA to inspect, that have reportedly leaked to the ground38. Reportedly, VIHA authorities are awaiting DPNR's testing of the drums to determine disposal methodology. A joint DPNR and USEPA inspection of the facility in April 1993 revealed the presence of numerous insecticide, caustic, cleaners, and conditioner drums present as well as unlabeled drums. The inspectors recommended that the waste oil drums should be bermed (they have not been as of 10/93). The deposition of Mr. Edward D. Lagarde38 indicated that degreasing operations were performed outdoors and that the floors were washed with degreasing solvents. These practices create a likelihood of releases to the environment and merit further investigation. The only sampling records available for this facility indicate that the waste oil from the underground storage tank contained petroleum products. Samples were not analyzed for specific chlorinated compounds. Ground water sampling of the potable water wells has shown elevated levels of nitrates and chlorinated substances. The presence of both of these compounds together may indicate that the common source is a septic pit nearby. Since VIHA is upgradient of the LAGA building under ambient ground water conditions, it is 14 Arthir D Little TUT °05 possible that VIHA chlorinated compound sources could have impacted ground water beneath the LAGA facility. 2.14 Four Winds Plaza Partnership Four Winds Plaza began to construct the current shopping plaza about 1977. Operations at the shopping plaza include a movie theater, car wash, assorted restaurants, an auto repair facility, an electronics store, a food store, and a general merchandise store. Equipment at The Plaza includes several backup diesel electric generators, several aboveground storage tanks and formerly an underground storage tank. In 1980, Four Winds Plaza applied for a test well permit and was granted a license to pump for domestic use, up to 500 gallons per day (GPD). In 1981, they applied for a permit to pump 43,000 GPD, but were denied by the permitting authority because the aquifer had already been over appropriated beyond the safe yield. During this time period, the permitting authority was also lowering pumping rates for commercial appropriations because they were not able to show need and prior use to authorized permit rates. In August 1981, a DPNR official observed Four Winds Plaza dispensing water to commercial entities without a permit, and also questioned whether they were exceeding their appropriation limit. Four Winds tried several other times thereafter to increase their well appropriation limit, but were denied for the reasons previously given. In 1987, the Four Winds wells were closed by DPNR. Then in 1989 their wells were reopened for the use of ground water supply for a car wash and a proposed laundromat business at the Plaza. The permitted pumping rate was increased to 50,000 GPD for each of the three wells in 1993. ADL personnel inspected Four Winds Plaza in October 1993 and found that there are a number of bulk storage tanks on-site, one of which was inspected in detail and found to have holes in its secondary containment. Also paper, wood, and food wastes were piled on- site, not in trash receptacles, and were causing an odor and visual nuisance. Storm water passing over the back store area had an oily sheen appearance and was discharging to a storm drain. During our visit, we noted a strong chemical odor emanating from this storm drain which is fed by Four Winds Plaza storm drains. Later, we sampled the drain directly down slope of the Four Winds discharge and found low levels of chlorinated solvents. The storm drain had a high flow rate despite no rainfall for that day. The water flow could have been contributed by the Four Winds Plaza Carwash, but we were not able to definitively determine the source. During the tour we also observed a black substance coating the sides of the rainfall collection pipes which appears to have run down the sides of the pipe Reportedly, this substance may be the tary material used to coat the roof. In September 1990, DPNR issued a notice of violation to Four Winds for exceeding potable water standards11. In October 1990, Four Winds received sampling results indicating that their roofing compound applied to the roof following Hurricane Hugo had contaminated the 15 ArthirD Little TUT s 1*57 cistern potable water with DCE, methylene chloride, TCE and trihalomethanes above potable standards12. A review of aerial photographs for the pre-development period of Four Winds Plaza indicates that numerous tanks were previously located on-site. The contents and integrity of these tanks could not be determined from the photo. It is possible that chemical storage occurred on-site prior to Four Winds Plaza development that may have contributed to observed chemical concentrations in ground water. 2.15 Western Auto Western Auto is located within Four Winds Plaza, along Tutu Gut. Western Auto began repair and parts distribution operations in 1978. Operations/equipment at Western Auto include maintenance bays, an aboveground diesel storage tank, two underground waste oil tanks, vehicle repair facilities, auto parts chemical storage, oil/water separator2, floor drains, sumps, and underground piping. ADL personnel conducted a limited tour of this facility but were not permitted to inspect maintenance bay chemical storage areas. Documentation1 indicates that at least three products are used/stored by Western Auto that contain chlorinated solvents. The documentation record for Western Auto indicates that the ownership of the two underground storage tanks on-site is questionable2. Apparently both Western Auto and Four Winds Plaza Partnership deny owning the tanks2. Eventually Western Auto finally registered the tanks in 1993, more than nine years after they were required to have been registered by the DPNR. These tanks received waste oils and any other substance that would have poured into the collection sump on the maintenance bay floor. A sample from one of these tanks in December 1992, indicated the presence of TCA (700 ug/L) in the underground tank10. Excavation of these tanks was undertaken in October 1993, and at the excavation base free product oils were found as well as oil saturated solid. Further excavation activities caused the rupturing of a nearby pipe which discharged a black colored liquid. The results of analytic testing of the tank excavation sediments and oils should help determine whether chlorinated solvent contamination is also associated with these tank leaks. A soil gas survey conducted by Target Environmental in 1992 showed that soil gas with detectable levels of hydrocarbon contamination were present extending about 100 feet from the Western Auto storage tanks27. These observations suggest that Western Auto may have contributed to the ground water contamination in the Four Winds Plaza area. 16 ArthirD Little TUT 2.16 Home Petroleum, IncJCaribbean Gas Corporation The Home Petroleum, Inc. gas station was located southeast of Harthman Plaza. The facility began operations in 1963 under the name of Caribbean Gas Corporation and later became Home Petroleum, Inc. until closing in 198619. This facility reportedly contained two to three underground storage tanks, some of which leaked. Reportedly, upon excavation of the tanks, free product hydrocarbons were observed in the excavation. Since this facility no longer exists and we were not able to obtain analytical records for any sampling at the site, it is difficult to assess its environmental impact Our data so far indicates that local service stations have used chlorinated solvents so it is reasonable to assume that this station also used chlorinated solvents. Water pumping in the Harthman, Elgin, and Harvey well fields may have caused chlorinated solvents released at this site to migrate upvalley towards the Plaintiffs' well fields. 2.17 Old Tutu Wastewater Treatment Plant The Old Tutu Wastewater Treatment Plant (WWTP) was built about 19674. It services the upper Tutu Basin and Harthman's Tutu Plaza facility. Its design capacity is about 220,000 gpd and currently processes about 50,000 gpd. The treatment equipment consists of grit separation, two aeration and activated sludge settling basins, and two air diffuser systems leading to a chlorination system with eventual discharge to an infiltration pond. The infiltration pond is reportedly between 5 to 15 feet deep, with a surface area of about 9,000 square feet. Due to the shallow soil thickness in the area, the infiltration pond may be excavated into bedrock. Evapotranspiration from the surface is likely to be approximately 555 gpd, based on lake evapotranspirauon rates in southern Florida (conservatively used 65 inches/year for this calculation). The remaining 49,445 gpd is expected to seep into the ground, recharging the ground water. Our sampling and chemical analysis of the influent wastewater received at the wastewater treatment plant did not detect any chlorinated solvents. The chlorination process at effluent discharge, however, can create chlorinated compounds such as hexachloroethane. Hexachloroethane will degrade readily to PCE and to a lesser extent, trichloroethene, dichloroethene, and vinyl chloride. All that is necessary for this process to occur is free chlorine residual in the presence of humic substances, both of which are expected for the Old Tutu WWTP. Given that the WWTP discharges at a large flow rate to the aquifer, about 17% of aquifer safe yield, it is conceivable that the WWTP could have contributed to the observed Tutu aquifer chlorinated compound contamination. The WWTP is hydrologically upgradient of both the Four Winds and Harthman well fields and, therefore, any release from the WWTP is expected to impact the Plaintiffs' well fields. None of the investigations to date have evaluated this possibility. ArthirD Little 17 TUT 5 ADL conducted sediment and aqueous sampling at the base of the Old Tutu WWTP infiltration pond in October 1993, but the samples have not yet been fully analyzed. A better understanding of the current potential for chlorinated compound formation at this site will be available once the samples have been analyzed. 2.18 Classic Printers, Inc. Classic Printers is located midway between the Harthman estate and Four Winds Plaza, across Route 38. We were unable to determine when this facility began operations and did not inspect the site. However, given the name of the business, it is likely that some inks and ink cleaning agents may have been used at the site that could contain chlorinated solvents. This site has not been investigated by the USEPA or others, so it is difficult to assess its impact on the Tutu aquifer. 2.19 Fellowship Church/Storage Facilities, Inc^West Indies Enterprises, Inc. This facility is located in Hidden Valley, upgradient of the Plaintiffs' well fields. The facility was developed prior to 1971 based on aerial photographs. Property owners have included the Fellowship Church (current owner), Storage Facilities, Inc., and West Indies Enterprises, Inc. The facility is rather large and old, but we were unable to determine what historic operations were conducted at the site. We have seen reference to a West Indies chemical and paint company located in Tutu in the 1970 and thought that this may have been their building, but were unable to confirm this. The facility includes at least one aboveground chemical storage tank of unknown current or past contents. Since this area has not been sampled, we were unable to determine its impact on the Tutu aquifer. Based on the potential for chemical handling at this site, however, it warrants further evaluation as a potential contaminant source in the Tutu Valley aquifer area. 2.20 Household Septic Systems Much of the Virgin Islands is serviced by household septic systems rather than by sanitary sewers40. Household septic tanks individually may not represent significant sources of chlorinated compounds, but collectively they can cause widespread aquifer contamination. Septic systems receive chlorinated compounds through household disposal of chemicals to sinks and drains. Many household products contain chlorinated compounds. These products, when disposed to a sanitary drain, discharge to the septic tank where they can then be transported to ground water. Additionally, many septic tank cleaning companies use chlorinated compounds to unclog or clean septic tanks, thus increasing the load of rttctM*.M 18 Arthir D Little TUT °05 chlorinated compounds to the aquifer. These septic discharges of chlorinated compounds could cause widespread distribution of chlorinated compound contamination in the aquifer. This is an issue which has not yet been adequately investigated for its potential contribution to contamination in the Tutu Valley aquifer. 19 ArthirD Little TLT 5 J-^i 3.0 Site Physical Characterization Detailed evaluations of the geology and hydrology, both on St. Thomas in general and at the Tutu site, have been provided in numerous reports32/40/41/42; therefore, only a brief summary has been provided here. For a detailed description of the site geology and hydrology, the reader is referred to those pertinent reports. 3.1 Geology The geology of the site consists of a thin soil layer overlying volcanic and volcaniclastic rocks. The soil thicknesses range from less than 2 feet to approximately 10 feet across the site. Two major rock units underlie the upper valley of Turpentine Run: the Water Island Formation, consisting primarily of lava flows and flow breccias and some intrusive dikes and plugs, and the Louisenhoj Formation, which are pyroclastic deposits consisting primarily of andesite. Turpentine run consists of gently rolling hills in a basin surrounded by steep slopes. The valley shape resulted from weathering and differential erosion of the bedrock along fault lines which dissect the valley. The LAGA Facility lies off the main fault line in a zone of relatively competent bedrock. We conducted surface reconnaissance of the geology in this Tutu Valley area, the results of which are presented in a separate report35. Our evaluation of the geology is generally consistent with that reported by Dr. Grenville Draper40. 3.2 Hydrology We reviewed several hydrologic studies for St. Thomas32/34/40/41/42. These studies are generally consistent with the water balance presented in Table 2 of the deposition by Mr. Wexler31. As shown in that table, the average annual rainfall is approximately 42 inches. Of the 42 inch average annual rainfall, 38.4 inches (91.4%) is transported back to the atmosphere via evapotranspiration. Strong solar radiation wind, and high vegetative cover provide for the high rate. Of the total rainfall, 0.4 inches (1%) are lost to storm water runoff; however, in the vicinity of the site, a significant portion of the land is covered by roads, buildings, or parking lots. Therefore, the amount of rain lost to stormwater runoff is likely to be higher in these developed areas than reported here. Only 3.2 inches (8% of the total rainfall) of rainfall infiltrates to the ground water. This is primarily a result of the soil type. The surface soils at the site act as a sponge, absorbing and retaining water at shallow depths and making it available to the surface vegetation. The soil is a clayey-silt mixture which tends to granulate or clump together when dry. The soil layer has high to moderate permeability when dry, but when wet, becomes increasingly impermeable and holds water in its pores, rejecting any excess. As the soil at the surface dries, it forms clumps and provides pathways for air infiltration into the soil causing further rapid evaporation31. Of the 3.2 inches per year that reaches the ground water, 2.3 inches are lost to evapotranspiration, 0.3 20 ArthirD Little TUT 005 inches supports base flow in Turpentine Run, and 0.6 inches discharges to the ocean. The water balance presented here does not account for water exports or consumptive losses. The primary aquifer in the study area lies within the Louisenhoj formation. The alluvium, (soil) forms a water-bearing unit of lesser significance. A number of extraction and monitoring wells have been installed in the vicinity of the site and data collected from these wells allows for aquifer analysis. Hydraulic conductivities at the site are reported to range from 3.5xlO"3 m/day to 2.5 m/day31. The higher hydraulic conductivities are located within the Turpentine Run gut and decrease significantly with distance from the gut The hydraulic conductivity beneath the former LAGA facility was reported as 6.67xlO~3 m/day3 . This low value is generally consistent with information collected at this location during drilling which indicated bedrock was very competent The deposition of Mr. Leo Swayze47 provides the most complete description of well pumping in the Tutu Valley we have seen. Even the pumping rates described in this reference, however, are subject to considerable uncertainty. Our best estimate of the cumulative time history of pumping from the aquifer at the site is displayed in Figure 3-1. The high rate of ground water extraction at the site, at or above the hydrogeologic safe yield, could result in the following negative impacts to the aquifer: • Compression of the openings within the aquifer where water is stored, resulting in less storage during times of recharge, thus, the loss of a valuable renewal resource • Increasing the potential for upwelling of saline water from beneath the island • Loss of recharge to streams and wetlands resulting in brackish water conditions and loss of ecological habitats 21 ArthirD Little TUT 4.0 Tutu Site Environmental Investigations Environmental investigations to date have focussed on the previously suspected source areas, but have not fully investigated all of the potential sources discussed in Section 2, nor have they presented convincing evidence that the LAGA facility operations contributed to either contamination at the Curriculum Center property or in the Plaintiffs' wells. Section 4.0 briefly reviews the relationship of the investigated areas to the potential contaminant sources. Section 4.0 is not an exhaustive review of all the available data. Figure 4-1 shows the soil gas survey areas. Notably absent is any exploration in the vicinity of VIHA, Ramsay Auto Parts, most of the Antilles property, Archies Auto Repair, Tracy's Radiator, and O'Henry's Drycleaners. Also, there is only one point on the Curriculum Center property. Figure 4-2 shows the location of soil samples taken by Geraghty & Miller. The Soiltech samples around Tutu Esso and ADL sampling around the Curriculum Center are not shown. The samples from Tutu Esso showed relatively high chlorinated compound concentrations. The additional soil sampling around the Curriculum Center showed relatively low or non- detectable concentrations. Notably absent is any soil sampling around VIHA, Ramsay Auto Parts, Tutu Texaco, Antilles Auto Repair, Archies Auto Repair, and Tracy's Radiator. Figure 4-3 shows the extent of ground water monitoring in the area. Notably absent are: • Chlorinated solvent plume edge definition in any direction, including upgradient • Monitoring west of the Four Winds Shopping Center • Monitoring downgradient from Ramsay Auto Parts or Antilles Auto Repair In general, environmental investigations are driven, and biased, by conceptual theories of contamination sources and movement. The collected data, in combination with other information, are then used to examine, and perhaps modify, the conceptual theories. For this area, our evaluation of the available data, potential sources, and principles of contaminant behavior in the environment suggest that further evaluation is needed before all the contributing sources will be known. 22 ArthirD Little TUT °05 5.0 Chemical Behavior in the Environment This section discusses two principle issues regarding chemical behavior in the environment and provides some interpretation of the observed conditions in the Tutu Valley aquifer in the context of those issues. Subsection 5.1 discusses chemical movement in the environment, and Subsection 5.2 discusses chlorinated hydrocarbon degradation in the environment. 5.1 Chemical Movement in the Environment After chemicals are introduced into the environment, they exist in either free phase or in association with environmental media (water, air, solids). Free phase chemicals move in accordance with forces applied directly to the free phase chemicals. Movement of chemicals associated with environmental media is governed by a combination of the environmental media movement and the dynamic transfer of chemicals among the media. The rest of this discussion will focus on the movement of chemicals dissolved in water. Except in extremely low conductivity environments such as very tight clays, underground movement of chemicals dissolved in water is dominated by movement of the water. This is commonly referred to as advective transport The chemical movement is also influenced by other processes. The two most important of these other processes are retardation by adsorption and dispersion. Adsorption of dissolved chemicals onto the media through which the water is flowing, has the effect of retarding the transport velocity of the chemical mass centroid in comparison to the average velocity of the water. Dispersion has the effect of spreading the chemical distribution, making the leading edge advance more rapidly, and the trailing edge more slowly, than the centroid of the chemical mass as well as producing contaminant motion transverse to the ground water flow direction. Evaluating advective transport of chemicals in ground water depends on an understanding of the ground water flow. Figure 5-1 shows the ground water potentiometric surface under non-pumping conditions as simulated by Wexler31. In the area shown on Figure 5-1, the Wexler simulation is very consistent with the piezometric surface interpretation presented by Jordan & Cosner41. The flow direction implied by this piezometric surface in the vicinity of the Curriculum Center is also shown on Figure 5-1. The representation in Figure 5-1 is based on a porous media flow model. This conceptualization is applicable to flow near the gut and may be applicable at a large distance scale for the enure aquifer. With increasing distance from the gut, however, the fracture density decreases and the local applicability of a porous media conceptualization decreases. The currently available data are not adequate to determine how well a porous media model represents flow conditions in the vicinity of the Curriculum Center. As a cross check on the likely flow directions, therefore, we also evaluated the fracture patterns in this area. Figures 23 TUT OO5 1665 5-2 and 5-3 shows the average fracture trace directions for this area in plan view. The fracture trace directions are generally consistent with the flow direction inferred from the piezometric head interpretation shown in Figure 5-1. The flow directions shown in Figure 5-1 are based on non-pumping conditions. Ground water flow directions are influenced by pumping of ground water. Ground water pumpage in this area was discussed in Section 3.0. We are not aware of a fully adequate evaluation of the influence of pumping on piezometric head or flow directions in this aquifer. The model developed by Wexler may provide an appropriate tool for evaluating the influence of pumping, but the accuracy of the pumping rates used in the simulations presented in his deposition had not been demonstrated. The report of Mr. Leo Swayze47 incorporated pumping rates which seemed to be based on more information than was available to Mr. Wexler, but we are not in full agreement with the methodology Mr. Swayze used to estimate well capture zones. Of particular interest in the vicinity of the Curriculum Center are the influence of the Tillett well and the VIHA wells. The analysis of both Mr. Wexler and Mr. Swayze indicate that in the absence of other pumping, chemicals in the ground water around the Curriculum Center will eventually be captured by the Tillett well under the Tillett well pumping rates during the 1970s and through 1987. The analysis of Mr. Swayze, however, suggests that when the VIHA wells are pumping, ground water under the Curriculum Center will be drawn upvalley, towards the VIHA wells. Mr. Wexler's simulation did not show this effect, but was based on a lower VIHA well pumping rate. Geraghty & Miller34 determined that the aquifer in this area may be viewed as having two zones, upper and lower. In the lower zone, recent data show a gradient going towards VIHA from the Tutu Texaco service station. Dissolved chemicals would also, therefore, move in the same direction. While none of these evaluations are definitive, they do suggest the likelihood that ground water flow directions, and consequendy dissolved chemical flow directions, in the vicinity of the Curriculum Center can be either toward the gut or away from the gut, toward VIHA, depending on pumping patterns in the aquifer. This suggests that contamination observed on the Curriculum Center property could be due to migration from off-site sources from either VIHA or Texaco. This possibility, in combination with the chemical handling practices of the Curriculum Center, support the position that the LAGA facility operation has not been shown to be responsible for contamination detected on the Curriculum Center property. This situation, in combination with the long travel time for ground water contaminant movement from the alleged LAGA disposal area and eventual capture by die Tillett Well clearly demonstrates that the LAGA facility operations were not responsible for contamination in die Plaintiffs' wells. 24 Arthir D LrtUe TUT cos i666 5.2 Chlorinated Solvent Degradation The available data on concentrations of PCE, TCE, DCE, and vinyl chloride indicate that there are multiple sources of contamination in the Tutu area. As noted by Dr. Eugene Meyer51, if only a single source of PCE were responsible for the contamination observed in the aquifer, ratios of the concentrations of PCE to TCE and TCE to DCE would be consistent across the affected wells once equilibrium was reached51. Differences in the ratios from well to well indicates multiple PCE sources, long duration continuous releases, or sources of TCE or DCE to the ground water independent of that formed through PCE degradation. A general discussion of chlorinated degradation is presented in Appendix C. Meyer has calculated his ratios in terms of concentrations in ug/1; we have worked in terms of umoles per liter, and calculated the ratios of individual chlorinated ethenes to total chlorinated ethenes. Because the number of moles of PCE initially present is conserved through the PCE-TCE-DCE-VC degradation chain, expressing the ratios in this manner provides a more meaningful measure of the degree of PCE transformation. The concentration ratios calculated in this manner, however, would still be expected to be equal from well to well, under equilibrium conditions, in the same way they would be when calculated in terms of mass concentrations. The data in the Tutu area show a wide range of concentration ratios. There are, nevertheless, some patterns which may be noted. In the southern pan of the area, the Eglin I, n, and HI wells show a consistent pattern of degradation products. These ratios are also consistent with the IT O'Henry monitoring well MW-03 (designated here as ITMW-03 to distinguish it from Geraghty & Miller well MW- 03), which is the O'Henry well closest to the Eglin wells. Data for these wells are listed below: Compound PCE TCE DCE VC Molar Ratio of Listed Compound to Total Chlorinated Ethanes Eglin 1 0.31 0.17 0.52 0.00 Eglin II 0.30 0.16 0.54 0.00 Eglin III 0.32 0.15 0.53 0.00 ITMW-03 0.28 0.17 0.55 0.00 These ratios are much different from those for wells ITMW-02 and ITMW-04, as well as the Harvey well, which are either closer or to the south of the O'Henry facility. In those samples, PCE ranges up to 74% of the total chlorinated ethenes, and DCE percentages are much lower than that indicated in the table above. This pattern could be due to either multiple sources in the area or continuing releases by O'Henry. 25 Arthir D Little TUT OO5 1667 Meyer has argued in his expert report that the contamination of the Tillett and Four Winds Plaza Wells indicate contamination from at least two independent sources of PCE and/or TCE51. The ratios of PCE degradation products to total chlorinated ethenes also support this view. Below, the Tillett well ratios are compared with those of MW-3, MW-4, and MW- 4D, the closest wells to the north of the Tillett well: Compound PCE TCE DCE VC Molar Ratio of Listed Compound to Total Chlorinated Ethanes Tiltett 020 0.10 0.70 0.00 MW-3 0.04 0.02 0.67 027 MW-4 0.14 0.06 0.80 0.00 MW-4D 0.14 0.04 0.82 0.00 The ratios for the Tillett well are inconsistent with any of the other wells, indicating at least two sources of contamination. Because of a clean area showing virtually no contamination exists to the north of the Eglin Wells, the O'Henry Dry Cleaners is not likely to contribute contaminants to the tillett well. The Tutu Esso service station identified by Meyer, the Tutu Texaco service station, and other facilities in this area (see Section 2.0) seem to be a much more likely sources. The northern Tutu area also indicates that multiple sources of contamination are present. The Ramsay well (north of Ramsay Auto) contains a much higher proportion of PCE than any of the wells nearby. PCE generally accounts for less than 15% of the total chlorinated ethenes in wells of this area. At the Ramsay well, the proportion is 82%. This suggests at least a different source of contamination in the area or a later release (or releases) affecting the well. The patterns of vinyl chloride (VC) occurrence may also be indicative of contamination sources. Reduction of DCE to vinyl chloride requires relatively strong reducing conditions. Vogel et al.52 report that this transformation would occur under conditions that are strong enough to reduce nitrate to nitrite. The ambient conditions in the aquifer in the Tutu area do not indicate that these conditions are present Ground water samples taken by ADL show high concentrations of dissolved oxygen, meaning that anaerobic conditions did not exist and a reducing environment was not present Also, data on nitrite and nitrate concentrations49750 in the area show nitrite concentrations to be much lower than nitrate concentrations, suggesting that even if anaerobic environments did exist, conditions were not sufficiently reducing to form either nitrite or vinyl chloride. Reducing conditions strong enough to support the transformation of DCE to vinyl chloride would, however, be expected to exist in a septic tank and may exist in any leaching pit. Septic systems operate anaerobically. The strong odors they are responsible for are a result of the reduction of sulfur to sulfide. This reaction requires more strongly reducing 26 Arthir D Little TUT 1668 conditions than the reduction of nitrate to nitrite, and thus the reduction of DCE to vinyl chloride would be expected to occur under these conditions. The Tutu Texaco service station is known to have used a leaching pit in which highly reducing conditions were likely. Esso Texaco may also have used such a pit The analytical data collected in the Tutu area are consistent with the Texaco service station, which discharged chlorinated organic compounds through its leaching pit, being the principal (if not the sole) source of vinyl chloride in the area. With the exception of the Harvey and Steele wells, which indicated low concentrations of vinyl chloride (2-3 ppb), the only other samples where unqualified concentrations of vinyl chloride are reported are near the Texaco station. The highest reported concentration of vinyl chloride in the Tutu area is 140 ppb at MW-03, next to the Texaco site. The next highest concentrations are 17 and 12 ppb at MW- 14 and MW-1D, which are near the Texaco facility to the north and northwest, respectively. As discussed earlier, migration from the Texaco facility to the north and northwest would be possible under some pumping conditions. Vinyl chloride was also detected to the north of the curriculum center building in samples taken by ADL. Concentrations were 11 and 5 ppb in the shallow and deep samples, respectively. The location from which these samples were taken is in the same direction relative to the Texaco station as MW-1D and MW-14, but farther away. These samples may represent a continuation of the plume from the Texaco station. This evaluation supports the concept that flow gradients have in the past and may currently be directed from the Tutu Texaco service station towards the Curriculum Center property. ArthirD Little 27 TUT GO5 1669 6.0 References 1 Law Office of Coon & Sanford, 1993, Western Auto Supplemental Response to Request for Information, Tutu Well Field Site, St. Thomas, USVI, submitted to U.S. EPA. ADL Document #3098 2 Law Office of Coon & Sanford, 1993, Request for Information, Tutu Well Field Site, St. Thomas, USVI, submitted to U.S. EPA. ADL Document #3100 3 Law Office of Campbell, Arellano & Rich, 1993, Second Request for Information, Tutu Well Field Site, submitted to U.S. EPA. ADL Document #3101 4 Estimated dates based on deed search data 5 Law Office of John K. Dema, P.C., 1993, Tutu Water Well Contamination Litigation, St Thomas, USVI, submitted to U.S. EPA. ADL Document #3004 6 Geraghty & Miller, Inc., 1993, Technical Rationale for Proposed Monitoring Well MW-15 at Ramsay Auto property, Tutu Service Station Investigation, St. Thomas, USVI. ADL Document #3003 7 9 12 Leonard Reed, 1987, Consolidated's Violations. ADL Document #3056 8 Leonard Reed, 1987, Texaco Tutu Service Station Inspection. ADL Document #3054 DPNR Inspection of O'Henry Laundry, 1987. ADL Document #3054 10 Savannah Laboratories data sheets for Western Auto, 1992. ADL Document #3012 11 DPNR/USEPA, 1993, Inspection of VI Housing Authority. ADL Document #3009 Four Winds Plaza Partnership Supplemental Response to Request for Information, 1993. ADL Document #3095 13 Laurel Grigg, 1981, Memorandum to Commissioner of Public Works. ADL Document #1680 14 NUS Corporation, 1991, Hazard Ranking System Documentation, Tutu Well Field, St. Thomas, USVI. ADL Document #3115 15 NUS Corporation, 1991, Hazard Ranking System Documentation, Tutu Well Field, St. Thomas, USVI, Reference Number 8. ADL Document #3118 28 ArthirD Little TUT 167° 16 Law Firm of Lasa, Escalera & Reichard, 1991, Tutu Well Site, St. Thomas, US VI, O/F: 71.181. ADL Document #7034 17 U.S. EPA Regional Administrator, 1987, Request for Information Under 42 USC. ADL Document #7035. 18 Target Environmental Services, Inc., 1992, Soil Gas Survey, Four Winds Shopping Center and Environs, Tutu Area, Anna's Retreat, U.S. Virgin Islands, prepared for Law Office of John K. Dema, P.C. Expert Report 19 Joint USEPA/DPNR Inspection of Home Petroleum, Inc, 1987. ADL Doc. 3054 20 Deposition of Mr. Winston Smith [Case No. 1989/220 and 1989/224] on January 16, 1992, pp. 29, 79-80. ADL Doc. 4004 21 Deposition of Mr. Fernando Moscoso, Case No. 1989/220 and No. 1989/224 on June 7, 1993, pp. 161-162, 167. ADL DOC. 4007 22 Deposition of Mr. Clement Hendricks, Case No. 1989/220 and No. 1989/224, on July 12, 1993, pp. 67-68. ADL Doc. 4008 23 HRS document Bates #L0000496. ADL Doc. 4021 24 Phil Single, 1981, Tutu Service Station Loading Hi Test Gasoline. ADL Doc. 9036 25 Well Inventory, Tutu Turpentine Run Site (1987). ADL Doc. 9081 26 HRS Document Record, Bates #L0000490 (1991). ADL Doc. 5021 27 HRS Document Record, Bates #L0000493 (1991). ADL Doc. 5021 28 HRS Document Record, Bates #L0000494 (1991). ADL Doc. 5021 29 Invoices and shipping records of PCE sold to L'Henri, Inc. (1990), Bates #L0000115- #L0000649. ADL Doc. 7024 30 HRS Document Record, Bates #L0000497 (1991). ADL Doc. 5021 31 Gartner Lee Inc., Simulation of Ground Water Flow in the Upper Turpentine Run Basin, St. Thomas, U.S. Virgin Islands, October 1993 32 United States Geological Survey, Relation of Bulk Precipitation and Evapotranspiration to Water Quality and Water resources, St. Thomas, Virgin Islands, 1977 29 Arthir D Little °05 J6 33 Dudley, Topper and Feuerzeig, Attorneys at Law, 1989, Request to Lift Cease and Desist Order for Operation of a Car Wash at Four Winds Plaza. ADL Doc. 7166 34 Geraghty & Miller, Inc., 1993, Technical Memorandum D. ADL Doc. F.2 35 Arthur D. Little, Inc., 1993, Environmental Investigation, Tutu Area 36 Texaco Puerto Rico, Inc. 1987, Product Inventory Analysis, Letter to C.R. Black. ADL Doc. 9008 37 GeoScience Consultants, Ltd., 1987, Final Report on Results of Soil Gas Survey, Tutu, St Thomas. ADL Doc. 022 38 Deposition of Edward Delargarde, 1993. ADL Doc. 4018 39 Deposition of Anthony Richards 40 Grenville Draper Report, 1993, Report on the Geology of the Four Winds Shopping Center, Tutu Area, Anna's Retreat, Eastern St. Thomas, U.S. Virgin Islands. Appendix I of Hydrologic Associates Inc., Report, Geohydrologic Analysis and Water Quality Data for the Upper Tutu Aquifer, 1993 41 Jordan and Cosner, United States Geological Survey Report... 1973 42 Graves, R.P., and Gonzales, R. 1988, Potentiometric Survey of Eastern St. Thomas, U.S. Virgin Islands: United States Geologic Survey (Society) Report 88-4131 43 Smith, H., Ajayi, O., 1983 Land Use, Runoff and Recharge on Selected Watersheds in the U.S. Virgin Islands, Caribbean Research Institute, College of the Virgin Islands, Tech. Rep. No. 13 ArthirD Little 30 TUT °05 i6 44 Ajayi, O., Smith, O., 1983, Compendium of Water Resources, Data for the U.S. Virgin Islands, Caribbean Research Institute, College of the Virgin Islands, Tech. Rep. No. 12 45 Canoy, M., Knudson, A., Garcia R., 1985, Reconnaissance of Ground Water Quality in the U.S. Virgin Islands, Water Resources Research Institute of the College of the Virgin Islands, Tech. Rep. No. 24 46 Stevens, K.E., Champney, R., Gomez, R., Alicea, J., 1981, Water Wells in St. Thomas, Virgin Islands, Caribbean Research Institute, College of the Virgin Islands, Tech. Rep. No. 11 Part One 47 Swayze., 1993, Geohydrologic Analysis and Water Quality Data for the Upper Tutu Aquifer, St. Thomas, Virgin Islands, Hydrologic Associates Inc. 48 Garrett, Report on Conditions Encountered at the Texaco Tutu and the Esso Tutu Automobile Services Stations in the Tutu-SL Thomas-USVI, Oct. 13, 1993. GVA 49 Ground Water Quality in the Virgin Islands 50 Geraghty & Miller, Inc. Table A-6 of Hydrogeologic Framework of the Turpentine Run Basin, St. Thomas 51 Meyer, E., 1993. Expert Report 52 Vogel, T.M., C.S. Criddle, and P.M. McCarty, 1987. Transformation of halogenated naliphatic compounds. Environmental Science and Technology 21:722-736 53 Donald Hamlin, 1985, Investigation and Report on Water Demand and Capability of Tillett Well, Bates No. A03315-A03359 54 W.F. McComb Engineering, 1985, Letter to Water Resources Commission, 5/24/85. Bates No. A03361-A03364 55 Poly Caribe, 1986, Letter to Four Winds Plaza Partnership re: Water Well Production 12/1/86, Bates No. A03284-A03289 56 Water Resources Commission, 1982, Ground Water Appropriation Permit Renewal for #405 Anna's Retreat, Bates No. A03446-A03448 (3/29/82) 57 Geraghty & Miller, 1991, Tutu Service Station Investigation Work Plan, 10/8/91, Bates No. A05843-A05844. 441M*ip«rUpftnpantxfM»-M 31 ArthirD Little m °05 6 Figures Arthir D Little TUT 005 1674 I I / ItftII f*/I TURPENTINE RUN AQUIFER BASIN |L£C04D| Turp«ntin« Run Bonn Boundary Ground Surfac* Topography (Ft.) Water Supply W«H Location 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 MARK) BRYAN lYELLlI MARK) BRYAN WELLI2 MARIO BRYAN rfELL|3 LOCKHART WELlj 1 LOCKHART WEL 2 LOCKHART WEl. 3 LOCKHART WELL 4 LOCKHART WEl. 5 DEMITRY WELL V1HA WELLl! V1HA WEU.I2 VIHA WELLI3 VIHA WELL|4 TILLLETS FOUR WINDS 1 FOUR WINDS H EGLIN WELLl 1 EGLIN WELLI2 EGLIN WEI1|3 STEEL HARVEY CRUSHER BAKERY 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 CREGER MOTORS WELLl 1 CREGER MOTORS WEU.I2 CREGER MOTORS WEIll3 CREGER MOTORS WEU.J4 E'S & A CORP WELL, 1 E'S it A CORP WELL, 2 E'S A A CORP WELLj 3 E'S & A CORP WELLj 4 LAPLACE SMITH MATTHIAS FARRINGTON POLY CARIB/DEVCON 1 POLY CARIB/DEVCON 2 POLY CARIB/DEVCON j 3 POLY CARIB/DEVCON 4 PUBLIC WELL/DIDI WELL DEPT. OF AGRICULTURE APPROXIMATE Source: USGS Woter-Resourcos Investigations Report 88-4131 1 KM 2KM Figure 1-1 Turpentine Run Bath Aquifer In the Tutu Area Eastern 8T. Thomat. U.S. Virgin Islands, (1987) MOSENMAN * COUN 441M-OM AS SHOWN OCT. IMS DUttto Cambridge, Massachusetts TUT 005 1675 NOTE: NO RMMX mMUBN ON HMmmrs nmi PLAZA MMC woman WNUBI FOR KB MCA MONITORING WELL WATER SUPPLY WELL 100 M«ten Source: Geraghty it Miller Figure 1-2. TUTU AREA BASE MAP HG5DHMI 1 COJN 44»»-W9 AS StOWN OCT. 1993 a- OM Tutu WWTP In vafey By Chtorinatlon Of ErnWrt Ramsay Motors Vehicle Repair UST Waste Oil Storage Tank Drum Storage PCE Found in Soil Vtft Para Wovw/vvicit Marina VIM Floor <***•) Wh Onrav Storm Sewer Contains Chlorinated Compound* Dept « Education InfMrotton PR Sanitary Sewer Contain! Chlorinated Antilles Vehicle Repair AGST For Waste Oil Drum Storage lexaco Vehicle Repair Chlorinated Solvent Use Drum Storage Chlorinated Solvents Found In Waste Oil And Soil wit no Furnei mnwm OHHMmwwrs nmi PLAZA euUMC RXJIFOfl rod tits NVA TIHett Pointing.Vamishing Stripping Western Auto Vehicle Repair USTS For Waste Oil Underground Piping Chlorinated Solvent Used Trocy's Vehicle Maintenance Esso Tutu Vehicle Repair Underground Oil Seperaton Underground Piping Chlorinated Solvent Used Potential Septic System PCE Found In Soib.Ofl/Woter Seperator And Waste Oi UST Household Septic Tanks Provide Distributed Source of Chlorinated Compounds Former Paint Store I Potential Disposal of Paints and Solvents LEGEND - FENCE LINE MONITORING WELL Classic Printers Inks and Solvents STORM SEWER LINE WATER SUPPLY WELL SANITARY SEWER LINE Archies vehicle Autobody Repair And Painting O'Henry's Dry Cleaning Septic Tank PCE Filter Disposal Solvent Disposal Water Saturated With Solvent Disposal PCE Found In Sots Potential Contaminant Sources In Tutu Area ROSCMMN I CTJUN Home Petroleum vehicle Repair Undrground Storage Tanks Potential Chlorinated Solvent Use 0 100 Meters Basemap Source: Geraghty & Miller 'x! •••4 Wit NO <M HNTOtMITS 1UIU PIA» BUUMC FOOTPRMT MUAOI PW MS/WA DISTANCE TRAVELED BASED ON MBTE AS A TRACER DISTANCE TRAVELED DURING PUMPING CONDITIONS 'ANCE TRAVELED DURING NONPUMPING CONDITIONS H C LEGEND FENCE LINE MONITORING WELL WATER SUPPLY WELL FLOW PATHS (GARTNER & LEE) «FC/F1MOt HOtC K1HOUUI MC. 0 100 kteton Basemap Source: Geraghty & Miller Figure 2-4_ TRAVEL DISTANCES FOR CONTAMINANTS ORIGINATING AT THE ALLEGED DISPOSAL PIT AFTER 2O YEARS OF TRAVEL TIME ROSCNMAN 1 COLJN 44199-084 AS SHOVN OCT. 1993 CO N a* wcrwwrs iuiu ruu UU>N: FOOIPRNT «WMt£ NX '• - v FENCE LINE MONITORING WELL WATER SUPPLY WELL GCL SOIL GAS SURVEY AREA ALVAREZ-DIAZ ASSOC. SOIL GAS SURVEY AREA TARGET ENVIRONMENTAL INC SOIL GAS SURVEY AREA OT/RMOI 0 100 M»t»r« Base Map Source: Geraghty & Miller 0- •--J •-0 Rgure 4-1 SOIL GAS SURVEY AREAS rat ROSCMMN I COLIN 44199-032 AS SHOWN OCT. 1993 MOIL NO FumcR uroMwnoM ON MMUWWfS TUTU PIAZA BUUMC FOOIWM TOR IMS ««A \ O MONITORING WELL WATER SUPPLY WELL SOIL BORING LOCATION SURFACE SOIL LOCATION J INDICATES ESTIMATED CONCENTRATION D ANALYTE IDENTIFIED AS SECONDARY DILUTION 45/67 INDICATES DUPLICATE SAMPLE VALUE NOTE. ALL VALUES INDICATED ARE FOR TETRACHLOROETHENE EXCEPT LOCATION B-15 WHICH ALSO HAS A TRICHLOROETHENE VALUE OF 6J m/roua, KM KTKUUH *c. 0 100 Meters Source: Geraghty & Miller 0- CO -Figure 4-2- CHLORINATED COMPOUNDS IN SOIL (ug/kg) ROSCNMAN 1 COL IN «199-039 AS SHOVN OCT. 1993 N RAMSAY OCE 1.4/1.4 TCE 0.89/0.94 PCE 16/16 VIHA-I VCE 2UJ OCE 6J TCE 1UI PCE SJ MW-1D VCE 12J OCE 600J TCE 52J PCE 190 -4 DCE 86 TCE 8J PCE 25 Tturr DCE 290 TCE 62 PCE 140 NOIL K> ruroo mmMTDH OH WRTMMTS IU1U BAZA euu»* fconwn HMMU n* me NKA MW-6R OCE 39 TCE 3J PCE 13 CHT-2 OCE <SO TCE <50 PCE <50 CHT-3 OCE OOOO TTF <*000 PCE <iooo I UW-10 DCE 130 TCE 29J PCE 25J CRUSHER VCE 0.5U DCE 0.19J TCE 0.08J PCE 1.2 UW02 DCE 370 TCE 570 PCE 3000 MONITORING WELL WATER SUPPLY WELL EGUN-K OCE 32 TCE 13 PCE 34 OCE 300 TCE 290 2500 INDICATES ESTIMATED CONCENTRATION AMALYTE IDENTIFIED AS SECONDARY DILUTION STEEL DCE 140 TCE 33 PCE 65 VCE 3.3 CONCENTRATION EXCEEDS CALIBRATION RANGE: ESTIMATED VALUE VINYL CHLORIDE NOTE: CHEMICAL DATA FROM VARIOUS SOURCES VALUES CHOSEN AS CLOSE TO FALL 92 AS POSSIBLE KFC/TOOO HOC PC1MOUUN NC. 1.2-DCHLOROETHENE TRCHLOROETHENE TETRACHLOROETHENE 1.4/1.4 INDICATES SAMPLE VALUE/DUPLICATE VALUE H- i> 00 0 100 M*t«ra Bosemap Source: Geraghty & Miller CHLORINATED COMPOUNDS IN GROUNDWATER (ug/l) ncmc* mo ROSENHAN i COLIN 44199-040 AS SHOWN DTT. 1993 N tan. Noruno •mnwoi OBI WITMMr; TUIU •UUMC roam* rat MSMOI w rLOW DI"ECTiCN WATER SUPPLY WELL NOTE: GROUND WATER ELEVATIONS FROM WEXLER. 1993 0 100 Mcton Basemop Source: Geroqhty & Miller ———————— Figure 5-1 ——————————— SIMULATED GROUND WATER ELEVATIONS (FT.) UNDER NON-PUMPING CONDITIONS ROSCNHAN I COLIN 44199-041 AS SHOVN OCT. 1993 00 Looding Dock 0 N Tinter Frome FINISHING Decolor Drycleoners ond Dryers PCE STILLS WAREHOUSE KNITTING #1 I KNITTING #2 sidewalk 100 FT. PREPARED FOR: ROSENMAN & COLIN DATE: OCT. 1993 DWG. NO.: 44199-019 SCALE: AS SHOWN Source: Lockwood Greene Engineers, Inc. Sportonburg. S.C. (Job # 69049) TITLE: Figure 2-2 Laga Building Floor Partition Plan TUT 005 1683 SOLID WASTE IO LANOFIU ' IIDWEST DRY CLEANING MACHINE WATER PCE/WATER SEPARATOR HUEBSCH RECLAIMERS(6) PCE/WAT.ER SEPARATOR 1-"- cr- CO-£ SOURCE: 8OCCS COMPANY (ADAPTED BY AOL) ""**»"* ROSENMAN & COLIN MTE- 10/93 SCM.t NONE OWC NO. 44199-021 DAAHM rr (iftrruLS) W>PIKMO BT (MTVMS) ArthirD Little ,„„ Figure 2-3 PCC FLOW. SHOWING WASTE STREAMS LAGA DRY CLEANING OPERATIONS Figure 3-1 Cumulative Pumping Rates in Tutu Valley 1960 350000 • ~ 300000 • • - - - • - - -^'.•-'^•^•i^JJ?^r 1 250000 • _o I 200000 • | 5 150000 • i 100000 + 5 50000 SI. M. 55. St. 57 1965 1970 1975 Time (years) 1980 1985 1990 FIG3-1.XLC "UT 005 1685 Printed 10/30/93 6:42 PM Attorney Client Work Product Privileged and Confidential Appendix A,3 Calculating Maximum Expected PCE Concentrations From Former LAGA Facility After Passing Through New Tutu WWTP parameter________________unite___value_________notes Input Density of Water Average Water Through WWTP Alleged Water From LAGA PCE Concentration in LAGA Water PCE mass lost during trip to WWTP PCE mass tost at WWTP Calculations Alleged water from LAGA Average Water Through WWTP PCE mass allegedly from LAGA PCE mass lost during trip to WWTP PCE mass in influent to WWTP PCE mass lost at WWTP PCE mass in effluent of WWTP 30% o) WWTP 300.000 gpd capacity PCE solubility estmaled. Uc*V highar horn EPA, IMOdata, pg41 values pertinent to expected influent gal/day I/day gal/day I/day mg/day mg/day mg/day mg/day mg/day 8.4 32 100000 378541 4760 95 4665 4284 381 EPA, 1960. An Exposure and Risk Assessment lor Tetraohkxoelhylene, Office ol Water Regulations and Standards (WH-SS3) (used values from those erhes believed to have influents to those expected trom LAGA between 10 and SO ppb, CAMS nclude: SaMord UK. Minwonh UK, Indianapolis IN, Lewiston PA. Grand Rapids Ml, Flint Ml. see below) City SaMord. UK Mnworth, UK Indianapolis. IN lewulon. PA Grand Rap»s, Ml Flint. Ml Average Influent Concemratior ugyi 30 46 51 45 IS X \ 36 1 Percent Removal 03% 86% 90% 03% 80% 06% »?% WWTPEFFL.XLS Arthir D Little TUT Pagel 005 1686 Appendix B Deed Search Curriculum Center From Aux 26, page 44 Warranty Deed dated 11/30/1970 From Cobuild Companies, NC. (Formerly known as West Indies Enterprises, Inc.) to LAGA Industries, Ltd. Recorded December 3, 1970. Book 12-1, page 325. No. 6822. Deed Dated 12/12/1979 from LAGA Industries, LTD to The Duplan Corporation of 1430 Broadway, NY, NY to PANEX CO., c/o Bisen & Fishman, 645 5th Ave., NY, NY. Recorded 12/20/79, Book 20T, page 409. No. 5245. Warranty Deed Dated 12/23/81 from PANEX CO., a partnership consisting of Paul Lazare and Andreas Gal of 1450 Broadway, NY, NY 10018, to The Government of The Virgin Islands of the U.S.. Recorded 2/9/82, Book 23H, pg. 175. No. 539. Texaco From Aux 17. pg. 115 Warranty Deed dated November 7, 1966 from Sidney S. Kessler, agent for the stockholders of St. Thomas Real Estate Corporation, to Texaco Antilles, LTD., a province of Ontario Canada Company. Recorded 1/10/1967, Book 8-P, page 222. No. 57. Warranty Deed dated May 16, 1974 from Texaco Antilles, LTD of Ontario, Canada to Texaco Caribbean, LTD. Recorded June 28, 1974. Book 15-S, page 330, no. 2615 (T. Box 12 atty. Barley). Aux 17. pg. 8 Warranty Deed dated October 28, 1966. From St. Thomas Real Estate Corporation to Sinna S. Kessler, agent for the stockholders of St. Thomas Real Estate Corporation. Recorded November 4, 19966. Book 8N pg. 137, no. 4617. O'Henry 81 ArtJur D Little TUT 005 1.637 From Aux 14. pg. 11 Warranty Deed dated February 9, 1965 from West Indies Marine Sales, Inc. to Francois Realty Corporation. Recorded March 2, 1965. Book 7Q page 279. No. 1183. Bargain and Sale Deed dated June 1, 1984 from Francois Realty Corp. to the Cyril V. Francois Associates of P.O. Box 276, St. Thomas, VI. Recorded June 27, 1984 Book 25-W, page 40. No. 2460. Lease dated May 29, 1981 from Francois Realty Corp. of 41 Norre Gade, St. Thomas, VI to L'Henri, Inc. of P.O. Box 232, St. Thomas, VI for a period of 20 years commencing April 1, 1981 and terminating on the 20th of March, 2001. Recorded September 28, 1981, Book 22-X, page 197. No. 3415. Consent of the Owner to mortgage by L'Henri, Inc. to First Pennsylvania Bank, NH, between Francois Realty Corp. and L'Henri, Inc. to First Pennsylvania Bank. Recorded December 11, 1981, Book 23-D, page 187. No. 4374. Landlord's Consent to conditional assignment of Lease (Leasehold Mortgage) between L'Henri, Inc. and Buy The Case, Inc. Dated. June 29, 1982. Recorded July 7, Bk. 23-J pg 369. No. 2276. Ramsays From Aux. 32. page 25. Deed dated July 25, 1974 from Cobuild Companies, Inc. to Rudy D'Angelico and Yvonne Louise D'Angelico of Box 7101 C'sted St. Croix, USVI, recorded September 6, 1974. Book 15X, page 309. No. 3649. Warranty Deed dated May 19, 1978 from Rudy D'Angelico and Yvonne Louise D'Angelico to R & R Properties, Inc. Recorded June 9, 1979, Recorded June 9, 1978. Book 18-X, page 329, No. 1842. Quitclaim Deed dated December 17, 1986 from R & R Properties, Inc. to Rita Ramsay of 19M Estate Solberg, St. Thomas, VI. Recorded December 30, 1986. Book 29P, page 439. No. 6665. From County Reg. Pg. 450 82 Arthir D Little TUT 005 1683 Antilles Lot 214 From Aux 23. Pg. 325 Warranty Deed dated December 14, 1968 from West Indies Enterprises, Inc. to Siegfried Torinus and Waltraud Torinus as tenants by the entirety. Recorded September 29, 1969. Book 11B, page 46. No. 1213. Memorandum of Right of First Refusal dated March 30, 1971, referring to a lease between Siegfried Torinus and Fred Eaglin and Seth Larrabee dated February 26, 1971 to a portion of PCC 214 Annas Retreat for a term of 5 years beginning 4/1/1971. This refusal is in regard to event of sale of property. Recorded August 25, 1971. Book 13A, pg. 97. No. 2758. VIHA from Aux. 29. pg. 211 Warranty Deed dated February 15, 1972 from Co-Build Companies, Inc. to Stephen H. Komfeld, General Partner and Husnu M. Ozyegian, General Partner d/b/a Annas Retreat Realty Company. Recorded July 19, 1973, Book 14S, page 354. No. 3283. Warranty Deed dated November 7, 1973 from Stephen H. Komfeld and Husnu M. Ozyegian, d/b/a Annas Retreat Realty Company to Warren S. Newman of 7 King St. C'sted SL Croix, VI. Recorded November 16, 1973, book 15A, page 263. No. 5073. Quitclaim Deed dated February 7, 1978 from Warren S. Newman of 300 East 56th SL, NY, NY 10022 to Joseph F. Sanson of #14 Tracy Way, Cowpet Bar Village, St. Thomas, VI. Recorded March 28, 1978, book 18S pg., 48, no 78. Certificate of sale dated June 12, 1978 from Alfred E. Francis, U.S. Marshall for the Virgin Islands to the VIHA, recorded August 9, 1978, book 19C, page 461, No. 2696. Quitclaim Deed dated July 7, 1978 from Joseph F. Samson of 14 Tracy Way, Cowpet Bay East SL Thomas, VI to VIHA of Box T668, Oswald Harris Court, St. Thomas, VI. Recorded November 21, 1978, book 192, page 45, No. 3953. Deed of Marshal dated November 28, 1978 from Alfred E. Francis, US Marshal for the Virgin Islands to VIHA, PO Box 7668, Recorded December 21, 1978, Book 19N, page 309., No. 4312. AIM* B3 Arthir D Little TUT 005 VITEL CO. From Aux 20. page 230 Warranty Deed dated October 16, 1968 from Jim Tillet Caribbean, Inc. to VITEL Co. of Box 1141, St. Thomas, VI. Recorded October 21, 1968, book 94, page 259, No. 3684. TILLET From Aux 7. page 60 Deed dated November 12, 1958 from the St. Thomas Real Estate Corporation to Everett B. Birch and Patti Birch. Recorded November 19, 1958 in book 4T, page 264. No. 1406. Warranty Deed dated May 19, 1959 from Everett B. Birch and Patti Birch to JIM TILLET CARIBBEAN, Inc. Recorded May 21, 1959, book 42, page 48. Tracys Radiator From Aux 42. page 100 TITLE TO MBT MOTORS, INC. Warranty Deed dated August 29, 1986 from MBT Motors, Inc. to Excalibur, Inc. of PO Box 7614, St. Thomas, VI. Recorded November 20, 1986, Book 29J page 381, No. 5832. From Aux 9. page 37 Warranty Deed dated March 15, 1961 from St. Thomas Real Estate Corp. to Eric Winter and Nancy Winter as tenants by the entirety. Recorded April 11, 1961. Book 5T, page 96. No. 640. Warranty Deed dated June 22, 1979 from Gloria Belvedere of St. Thomas, VI to Branko, Inc. of 128 Annas Retreat, St. Thomas, VI. Recorded July 24, 1979. Book 20F, page 185. No. 2842. Warranty Deed dated June 25, 1979 from John E. Branham of NY to Branko, Inc. of 128 Annas Retreat, St. Thomas, VI. Recorded July 24, 1979. Book 20F, page 188. No. 2843. B4 Arthir D Lrttle TUT 005 Marshals Deed, dated November 9, 1984. From John Washington, U.S. Marshal to MET Motors, Inc. Recorded December 4, 1984, book 26J, page 62. No. 4698. Deed of Gift dated January 3, 1966 from Eric Winter and Nancy Winter to Nancy Winter. Recorded January 14, 1966, book 8c, page 28, no. 71. Warranty Deed dated May 1, 1978 from Nancy Winter of 116 Archwood Avenue, Annapolis, MD 21401 to Branko Inc. of 128 Annas Retreat Recorded May 25, 1978, Book 18W, page 88, No. 1562. Deed dated August 14, 1978 from Branko, Inc. to Gloria M. Belvedere of No. 128 Annas Retreat and John C. Branham of 43 Spray Court, Bayport, NY as Tenants in Common. Recorded September 7, 1978. Book 19F, page 29, no. 3045. Fellowship Church Indenture dated May 16, 1975 from Richard Reubin, receiver of Cobuild Co., Inc. (aka West Indies Enterprises, Inc.), to IBC Properties, Inc. c/o International City Bank, STTVI to parcel 394148-99, 100, 101 and 102 and Parcel No. 215 Annas Retreat Recorded May 23, 1975 Book 16-P page 1 No. 1676. Indenture dated 2/23/77 from Richard Reuben, trustee in bankruptcy of Cobuild Co., Inc. (aka West Indies Enterprises, Inc.) c/o Adelman and Lovine, Esqs., Suite 1900, Two Penn Center Plaza, Philadelphia, PA 19120 to EBG Properties, Inc. to First National City Bank, St. Thomas, VI to Parcel 394- A Recorded April 12, 1977 Book 17-V page 125 No. 979. Quitclaim deed dated July 1, 1977 from IBG Properties, Inc., of P.O. Box 7954, St. Thomas VI, to Joseph F. Sanson of 14 Tracy Way, Cowpet Bay Village, St. Thomas, VI. Recorded July 8, 1977, Book 18-A page 475 No. 2304. Quitclaim deed dated December 29, 1978 from Joseph Sanson of Box 19, Red Hook Shopping Center, St. Thomas VI to a Sue Mortimer and her successors as trustee of the Sue Mortimer Trust U/A/O 7/1 1/1977 of Vitraco Park, St. Thomas VI recorded 1/5/1979 Book 19-0 page 159 No. 33. Warranty Deed dated Feb. 11, 1988 from Sue Mortimer, trustee to Storage Facilities, Inc., c/o Island Block Corporation, No. 1 Hasnerks Grade St., St. Thomas VI. Recorded March 2, 1988, Book 31-S page 376 no. 890. Warranty Deed dated Sept 14, 1992 from Storage Facilities, Inc. to F.C. Fellowship Church of St. Thomas Inc. of P.O. Box 7158, St. Thomas VI 00801-7158. Recorded Sept. 29, 1992 Book 394 page 405 no. 5116. B5 Arthir D Little 4 Winds Plaza Quitclaim Deed Sept 12, 1985 from Aux 41 page 164 from Three Two Two Developers, Ltd. to 4 Winds Plaza Partnership of P.O. Box 3692 St. Thomas VI recorded Oct. 8, 1985 Book 27-N page 369 No. 4371. Quitclaim Deed dated August 15, 1977 from Aux 35 page 83 from Plaza Associates to Three Two Two Developers, Ltd. Recorded August 24, 1977 Book 18E page 95 No. 2884. Warranty Deed dated 7/17/70 from West Indies Enterprises, Inc. to Kenneth G. Klein recorded 7/21/1970 Book 12-A page 49 No. 5227. Quitclaim Deed dated April 9, 1974 from Kenneth G. Klein to Antilles International Trust Company, Ltd. of P.O. Box 86 Roadtown Tortola BVI recorded April 30, 1974 Book 15-0 Page 305 No. 1699. Order confirming sale dated March 13, 1976 Civil No. 488-1973 action to foreclose mortgage action on Notes Court ordered the sale conducted by U.S. Marshal on 2/27/1976 be sold to Richard I. Rubin receiver for Cobuild Companies, Inc. (aka West Indies Enterprises, Inc.) Marshall should make a Marshal's Deed to this property. Recorded June 15, 1976 Book 17-6 Page 44 No. 1535. Certificate of Sale dated March 13, 1976 from Alfred E. Francis, U.S. Marshal certifying that Richard I. Rubin, receiver for Cobuild Companies, Inc., aka West Indies Enterprises, Inc., has purchases at a sale held on 2/27/76 PcL 392. Recorded 7/13/76, Book 17H Page 165 No. 1723. Marshal's Deed dated 7/30/76 from Alfred E. Francis as United States marshal for the District Court of the VI to Richard I. Rubin of Cobuild Companies, Inc., aka West Indies Enterprises, Inc. c/o Stuart H. Savett, Esq., 1214 IVB Building, 1700 Market Street, Philadelphia PA. Recorded August 11, 1976. Book 17-1 Page 408 No. 2004. Receiver's Deed dated Nov. 22, 1976 from Richard I. Rubin, as Receiver of Cobuild Companies, Inc., aka West Indies Enterprises, Inc., c/o Stuart H. Savett, 1214 IVB Building, 1700 Market St., Philadelphia PA 19103 to Three Two Two Developers, Ltd. of Suite 875, Frenchmans Reef Hotel, St. Thomas VI. Recorded Nov. 22, 1976 Book 17-N Page 398 No. 3081. Quitclaim Deed dated 7/5/77 from Three Two Two Developers, Ltd. to Plaza Associates. Recorded July 22, 1977 Book 18-B Page 480 No. 2487. B6 ArthirD Little TUT 005 1692 Quitclaim Deed dated Aug. 5, 1977 from Plaza Associates to Three Two Two Developers, Ltd. Recorded August 24, 1977 Book 18-F Page 95 No. 2884. Leases: 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. 22. 23. 24. 25. 26. 27. 28. 29. 30. 31. 32. 5/22/78 5/22/78 5/22/78 11/14/78 3/6/79 5/10/79 8/17/79 5/22/78 5/22/78 10/3/78 11/30/78 5/22/78 5/22/78 5/22/78 5/22/78 5/22/78 5/22/78 5/18/79 9/18/79 7/16/79 mi/19 3/20/80 3/5/81 11/1/79 2/1/82 5/3/82 5/3/82 7/1/82 6/18/82 9/8/82 7/26/83 3/1/84 Hamilton Caribbean Assoc., Inc. Army/Navy Surplus Records, Needles & Things VI Furniture Center Bassim Jamal Isis (mini-mall) ITT Financial Corp. Gardner McLaughlin, Inc. Gourmet Gallery, Inc. Pueblo Supermarkets First Penn Bank RC Cobb of The Virgin Islands, Inc. Florida West Amusement (Theater) Pizza Hut Veronica Simmonds (kiosk) West Indies Corporation West Auto Supply Company Kinney Shoe Corp. Leonig David-Island Boutique Cupios Shoe Store Rosevan Fabrics LB Development Company Bachman's Bakery Suboh Saleh and/or Najah Saleh Abjada Dale Bachman Timeout Family Amusement Center of Puerto Rico DNL Boutique West Indian Food Corporation Arthur S. Newton, Third World Electronics People's Fashion Just a Thought Amusements d/b/a Jimbo's Glentronics of St. Thomas, Inc. HB Inc. d/b/a Bachman's Bakery Esso, 4 Winds Plaza and Car Wash Warranty Deed dated Dec. 16, 1968 from West Indies Enterprises, Inc. to Esso Standard Oil Co. (P.R.). Recorded December 23, 1968 Book 10-E Page 265, No. 4497. B7 ArthirD Little TUT OO5 1693 Warranty Deed dated 12/18/69 from Esso Standard Oil Company (Puerto Rico) to Esso Standard Oil SA Limited, a Bahama Corp. GPO Box 1930 Santunce PR 00936. Recorded 2/27/1970 Book 11-P Page 195 No. 3200. Quitclaim Deed dated 1/3/89 from Esso Standard Oil SA Limited to Esso Virgin Islands, Inc., of PO Box 8619 St. Thomas VI. Recorded April 11, 1989 Book 33-W Page 410 No. 1857. Certificate of Attachment dated 6/16/82 from Dept of Finance against Esso Standard Oil SA Ltd. for 1980. Taxes $800.89 recorded Feb. 4.1985. Lien Book XJJ Page 475 No. 471. Lot 7 Rodriguez Auto Parts and Esso From Aux 4 p.307: Deed of Gift dated Oct. 31, 1955 from Ludwig Christensen and Eona Christensen, his wife, to William C. Christensen, their son. Recorded Oct. 31, 1955 Book 41 Page 546 No. 868. Warranty Deed dated July 12, 1963, from William Christensen to Courtland Adkins recorded 7/19/63 Book 6T Page 39 No. 2773. Warranty Deed dated Nov. 14, 1978 from Courtland Adkins and Martha Adkins, of PO Box 23087 Oakland Park, FL 33307 to Ephraim Adkins and Courtland Adkins. Recorded 1/10/79 Book 19-O Page 311 No. 85. Warranty Deed dated Nov. 12, 1986 from Ephraim Adkins individually and Ephraim Adkins and Jeffrey A. Adkins trustees to E's and A's Corporation of PO Box 2576, St. Thomas VI. Recorded Dec. 1, 1986 Book 29-L Page 144 No. 6029. Final Adjudication dated May 3, 1980 Probate No. 8/1980. In the matter of the estate of Courtland Adkins, deceased, as title to Jeffrey A. Adkins and Ephraim Adkins as trustees to one half (1/2) interest Recorded April 7, 1993 Book 40-Z Page 41 No. 1714. Certificate of Correct Spelling of Corporate Name dated June 2, 1993 from Rodriguez Auto Parts Inc. to Carl H. and Constance J. Pattison. Recorded June 2, 1993 Book 41-G Page 413 No. 2718. Consent of Lessons to Assignment of Lease dated Dec. 6, 1982. Recorded Jan. 18, 1983 Book 24-F Page 108 No. 136. B8 ArthirD Little TiJT 005 ±694 Personal Guaranty of Lease dated 12/22/82. Recorded 1/18/1983 Book 24-F Page 110 No. 136C. Sublease Agreement dated April 6, 1971 from Carl H. Pattison and Constance H. Pattison to the Shell Company (Puerto Rico) limited to sublease a portion of Pel. 7 Suite Charlotte Amalie containing 24,148 sq. ft for Auto Car Wash for a term of 5 years commencing 60 days of prior notice to landlord. Subleased to Shell for car wash, subleased from Shell for gas station. Recorded May 28, 1971 Book 12-V Page 205 No. 1593. Sublease Agreement dated April 6, 1971 from the Shell Company (Puerto Rico) Limited to Carl H. Pattison and Constance J. Pattison of St Thomas to sublease portion of Pel. 7 Charlotte Amalie for period of 5 years. Recorded May 28, 1971 Book 12-V page 210 No. 1594. OLD TUTU WWTP From Aux. 18 Page 238. 8/23/1967 Warranty Deed from Sidney Kesler Agent for the Stockholders of St Thomas Real Estate Corporation to the Government of the Virgin Islands. Recorded October 9, 1967 Book 9-B Page 315, No. 4251. Parcel 2 KRONP IV page 52 Subdivided: Parcel No. 2-4 to Versailles Associates 0.844 acres. From page 53. same book: Warranty Deed dated 12/22/83 from Amalia Mylner, D8 PO Box 941, St. Thomas VI to Versailles Associates of PO Box 3678, St. Thomas VI. Recorded 1/10/84. Book 25-1 page 369 No. 92. Warranty Deed dated 4/26/93 from Versailles Associates to Winsor E. Daniel and Juell D. Daniel of PO Box 9496, SL Thomas VI 00801. Recorded May 24, 1993, Book 41-F page 100 No. 2486. Contract of Sale dated 4/1/87 from Versailles Associates to Winsor Daniel, recorded 5/5/87, Book 30-H page 236 No. 2225. B9 Arthir D Little TUT 005 1.695 Parcel No. 2-1, 2-2, 2-3, 2-5, and 2-6 to B. Read Miller and Nancy N. Miller to page 205. From KRONP IV:2Q5: Warranty deed dated 4/19/88 from Amalia Mylner to B. Read Miller and Nancy Miller of Buccaneer Mall No. 33, St. Thomas VI 00802. Recorded 8/19/92, Book 39-R page 379 No. 4363. Insert diagram of "Frank's best guess at sanitary sewer flow around the curriculum center" Lessors Estoppel Certificate dated 3/2/81 between Arthur L. Witty and Donald McCarthy d/b/a "Mainland Appliances" on portions located at Pels 2-1,2-2, and 2-3 Est. Charlotte Amalie. Recorded April 1, 1981. Book 22-h page 160 No. 1175. Consent to Assignment of Lease dated 3/2/81 between Arthur L. Witty and Donald McCarthy d/b/a "Mainland Appliances" and the Chase Manhattan Bank. Recorded 4/1/81 Book 22-H page 162 No. 1176. Assignment of Lease dated April 1, 1981 by Donald McCarthy to the Chase Manhattan Bank on Pels 2-1, 2-2, and 2-3 Est. Charlotte Amalie. Recorded April 1, 1981 Book 22-H page 164 No. 1179. Supplemental Assignment of Lease dated 7/6/82 between Donald McCarthy, d/b/a "Mainland Appliances" and the Chase Manhattan Bank for an additional $90,000 recorded 7/6782 Book 23-S page 325 No. 2217. Acknowledgement of First Priority Leasehold Mortgage dated Aug. 4, 1982 between Versailles Associates and Arthur Witty on behalf of Arthur Witty Fort Mylner Shopping Center. Recorded Aug. 6, 1982 Book 23-U page 368 No. 2827. IV Page 205 Quitclaim Deed dated 7/20/92 from B. Read Miller and Nancy N. Miller to Miller Properties, Inc. of Buccaneer Mall No. 33 St. Thomas VI 00802 Recorded 8/19/92 Book 39R page 479 No. 4363. Assignment of Rents and Leases dated 4/1/93 from Miller Properties, Inc. to the Bank of Nova Scotia. Recorded 4/1/93 Book 40-Y page 206 No. 1629. *Parcel No. 2-7 to Miller Properties, Inc. to Aux 48 page 103. lt*»xp*rtrpiM|ie*.«oeMfr«a BIO Arthir D Little TUT °05 169 Warranty Deed dated 7/10/92 from Amalia Mylner to Miller Properties, Inc. of Buccaneer Mall No. 33, St. Thomas USVI 00802. Recorded Aug. 3, 1992 Book 39- P page 87 No. 4081. KFC from: KRONP m - page 771 Deed dated 4/4/38 from V.A. Christensen and Ludvig Christensen and V.A. Miller to Svend Aage Mylner. Recorded 4/6/38 Book 3V No. 292 page 319. Deed dated May 29, 1971 from Svend Aage Mylner to Amalia Mylner, an individual, 1/2 interest in said property. Recorded 12/13/71 Book 13-F page 169 No. 4146. Lease dated 9/27/62 between Svend and Amalia Mylner and Arthur L. Witty leasing 1.69 acres of a portion of Pel. 2-1 est Charlotte Amalia for 10 yrs. Recorded Oct. 12, 1962, Book 6-K page 344 No. 2157. Lease dated 1/26/63 from Arthur L. Witty to Island Drug and Gift Shop, Inc. leasing Parcel 2-1-B, an area of 6,220 sq. ft. for a term of 9 yrs 7 months commencing 3/1/63 recorded 2/13/63 Book 6N page 267 No. 573. Lease dated 4/23/63 from Arthur L. Witty to Carib. Gas Corporation on Pel. 2-1-C for a term of 10 years $200/mo. Recorded 4/30/63 Book 6Q page 123 No. 3020. Lease dated 4/17/64 from Arthur L. Witty to Robert Heggie and Jack Lachelle on Parcel 2-1-B comprising 6,200 sq. ft. for a term beginning May 1, 1964 to Oct. 31, 1972. Recorded April 29, 1964 Book 7C Page 386 No. 1617. Lease dated 9/1/66 between Arthur L. Witty Fort Mylner Shopping Center and the Virgin Islands National Bank to lease portion of Bay No. 1 at the Northerly End of Fort Mylner located on Pel. 2-1-C Est. Charlotte Amalie for a period of 10 years. Recorded 9/16/66 Book 8L page 346 No. 3988. Amended lease dated 9/1/65 between Svend and Amalia Mylner and Arthur L. Witty to lease Pel. 2-1 and 2-2 est Charlotte Amalie, comprising 2,113 acres for a term expiring 12/31/90. Recorded 9/16/66. Book 8L page 354 No. 3989. Release dated (no date) from Arthur L. Witty giving government permission to construct culvert and public road. Recorded November 12, 1970. Easement Book II page 159 No. 6597 on Parcel 2-1-B. Sublease dated April 17, 1973 from Christina Fuentes to Jose Santos Acosta to a room in Bay No. 9-C within the Fort Mylner Shopping Center located at Parcel 2-1- C for a term of 12 months. Recorded June 4, 1973 Book 14-P page 277 No. 2549. n>MnMnN44tt««q»rtrpta|)p-b.«ocM»-M B11 ArthirD Little T °05 6? Certificate of limited partnership dated April 23, 1971 Arthur Witty Fort Mylner Shopping Center. Recorded June 18, 1971 Book 12-V page 54 No. 1736. Amendment to amended lease (Item G) dated Nov. 20, 1980 between Amalia Mylner of Box 941, St Thomas VI and Arthur L. Witty of Box 358, St. Thomas, VI to Extend Lease for an additional 5 years through 12/31/95. Recorded November 20, 1980 Book 21-X page 48 No. 4334. Contract of sale dated 11/20/80 from Amalia Mylner of Box 941, St. Thomas, US VI to Arthur L. Witty of Box 358, St. Thomas, USVI to sell a strip of Parcel 2 Charlotte Amalie. Recorded November 20, 1980. Book 21-X page 45 No. 4333. Lease dated May 19, 1975 between Arthur L. Witty and Donald McCarthy d/b/a Mainland Appliances on premises located at Parcels 2-1, 2-2, and 2-3 Estate Charlotte Amalie #3 New Qtr. Recorded April 1, 1981 Book 22-14 page 146 No. 1174. Parcel 2 KRONP IV - page 52 Subdivided: Parcel No. 2-4 to Versailles Associates 0.844 acres. From page 53 same book: Warranty deed dated 12/22/83 from Amalia Mylner D8, P.O. Box 941, St. Thomas, VI to Versailles Associates of P.O. Box 3678, St. Thomas, VI. Recorded 1/10/84. Book 25-1 page 369 No. 92. Warranty deed dated 4/26/93 from Versailles Associates to Winsor E. Daniel and Juell D. Daniel of P.O. Box 9496, SL Thomas, VI 00802. Recorded May 24, 1993 Book 41-F page 100 No. 2486. Contract of sale dated 4/1/87 from Versailles Associates to Winsor Daniel recorded 5/5/87 Book 30-H page 236 No. 2225. Parcel no. 2-1, 2-2, 2-3, 2-5, and 2-6 to B. Read Miller and Nancy N. Miller to page 205. From Kronp IV - 205: Warranty deed dated 4/19/88 from Amalia Mylner to B. Read Miller and Nancy Miller of Buccaneer Mall No. 33, St. Thomas, VI 00802. Recorded 8/19/92 Book39-R page 479 No. 4363. B12 ArthirD Little Lessors Estoppel Certificate dated 3/2/81 between Arthur L. Witty and Donald McCarthy d/b/a "Mainland Appliances" on portions located at Parcels 2-1, 2-2, and 2- 3 ESL Charlotte Amalie. Recorded April 1, 1981. Book 22-H page 160 No. 1175. Consent to Assignment of Lease dated 3/2/81 between Arthur L. Witty and Donald McCarthy d/b/a "Mainland Appliances" and the Chase Manhattan Bank. Recorded 4/1/81 Book 22-H page 162 No. 1176. Assignment of Lease dated April 1, 1981 by Donald McCarthy to the Chase Manhattan Bank on Parcels 2-1, 2-2, and 2-3 Est Charlotte Amalie. Recorded April 1, 1981 Book 22-H page 164 No. 1179. Supplemental Assignment of Lease dated 7/6/82 between Donald McCarthy, d/b/a "Mainland Appliances" and the Chase Manhattan Bank for an additional $90,000. Recorded 7/6/82 Book 23-S page 325 No. 2217. Acknowledgement of First Priority Leasehold Mortgage dated August 4, 1982 between Versailles Associates and Arthur Witty on behalf of Arthur Witty Fort Mylner Shopping Center. Recorded Aug. 6, 1982 Book 23-U page 368 No. 2827. Quitclaim deed dated 7/20/92 from B. Read Miller and Nancy N. Miller to Miller Properties Inc. of Buccaneer Mall No. 33, St. Thomas, VI 00802. Recorded 8/19/92 Book 39 R page 479 No. 4363. Assignment of Rents and Leases dated 4/1/93 from Miller Properties Inc. to the Bank of Nova Scotia. Recorded 4/1/93 Book 40-Y page 206 No. 1629. *Parcel No. 2-7 to Miller Properties, Inc. to Aux. 48 page 103. Warranty deed dated 7/10/92 from Amalia Mylner to Miller Properties, Inc. of Buccaneer Mall No. 33, St. Thomas, VI 00802. Recorded August 3, 1992 Book B9-P page 87 No. 4081. Harthman Estate Deed dated 2/15/43 from Viggo Christiansen to Sammy Harthman and Louis Lindquist. Recorded 4/1/43 Book 3W page 912 No. 55. Deed dated 3/18/46 from Louis Lindquist to Sammy Harthman on Grantors Interest in Est. Charlotte Amalie. Recorded May 14, 1946 Book 3X page 912 No. 206. B13 Arthir D Little TUT oos 1.699 Final Adjudication dated 11/12/85 Probate No. 13/1983 in the matter of the Estate of Sammy Emanuel Harthman as title to Rhoda J. Harthman, 1/3 interest in a 1/9 interest to each of the following: Edgar A. Harthman, Arthur E. Harthman, Albert E. Harthman, Sammy E. Harthman, Jr., Austin E. Harthman and Charlotte A. LaBarre nee Harthman. Recorded Nov. 20, 1985 Book 27-R page 69 No. 5082. Indenture dated May 16, 1975 from Richard Reubin, Receiver of Cobuild Co. Inc. a/k/a West Indies Enterprises, Inc., to IBG Properties Inc., c/o First National City Bank, St Thomas, VI to parcel 394, 148-99, 100, 101, 102, and parcel no. 215 Annas Retreat. Recorded May 23, 1975 Book 16-P page 1 No. 1676. Indenture dated 2/23/77 from Richard Reuben, Trustee in Bankruptcy of Cobuild Co., Inc. a/k/a West Indies Enterprises Inc. c/o Adelman & Lovine, Esquires, Suite 1900, Two Penn Center Plaza, Philadelphia, PA 19120 to IBG Properties, Inc. to First National City Bank, St. Thomas, VI to parcel 394-A. Recorded April 12, 1977 Book 17-V page 125 No. 979. New Tutu WWTP Aux. 18. Page 238 Warranty deed dated August 23, 1967 from Sidney Kessler, Agent for the Stockholders of St Thomas Real Estate Corporation to the Government of the Virgin Islands. Recorded October 9, 1967. Book 8-B, pg. 315. No4251 B14 ArthirD Little TUT 005 1700 Appendix C Degradation of Chlorinated Compounds C.1 Degradation Pathway for Tetrachorloethene (PCE) Tetrachloroethene (PCE) can undergo reductive dehalogenation mediated by microorganisms in strongly reducing ground water (4). The breakdown products are thchloroethane (TCE), dichloroethene (DCE), and vinyl chloride, as shown in Figure C-l. The presence of toluene in anaerobic environments (e.g., such as in the Esso and Texaco septic pits) has been found to stimulate the reductive dechlorination of PCE (6). This suggest that at sites contaminated by gasoline, the transformation of PCE would be enhanced. Under aerobic conditions and less reducing (denitrifying) conditions, PCE tends to persist (4). The abiotic degradation of PCE also occurs very slowly. The compound is not easily hydrolyzed; volatilization is a more important loss process for shallow surface waters (1,2,3). Trichloroethene can be reduced to dichloroethene, which itself may be subsequently reduced to vinyl chloride or transformed to chloroethane (4,5). Because the ease (and speed) with which these reductions occur is proportional to the number of chlorine atoms in the molecule, stronger reducing conditions are required to reduce TCE than to reduce PCE, and even more strongly reducing conditions are required to reduce DCE than TCE (5). Under highly reducing (methanogenic) conditions in laboratory scale experiments, vinyl chloride has been observed to degrade relatively rapidly—100% removal within 11 weeks in the presence of sand (4). It has been suggested that vinyl chloride may be mineralized to carbon dioxide under anaerobic conditions (13). Because water would serve as the source of oxygen for carbon dioxide, molecular oxygen would not be necessary for the reaction to occur. Another study (15) found that the addition of nutrients, such as methane, methanol, ammonium phosphate and phenol, was necessary for vinyl chloride to be degraded under anaerobic conditions. After five months 89% of the vinyl chloride had been degraded in samples to which nutrients had been added, while in samples without the addition of nutrients, vinyl chloride was found to be resistant to transformation. Methane and ethylene were the main products of vinyl chloride degradation. Carbon dioxide was observed only when oxygen-containing nutrients were added. Studies examining the biodegradation of radio-labelled vinyl chloride under aerobic conditions in a shallow aquifer indicated rapid degradation (14). After 108 days, more than 99% was degraded, and approximately 65% of the labelled carbon was mineralized to carbon dioxide (14). The presence of compounds that are formed from the breakdown of PCE under certain conditions does not mean that PCE is the source. The same compounds may C1 ArthirDLittle TUT --, 170i Figure 1. Tetrachloroethene (PCE) Degradation Pathway c Ul Ul \ Cl Cl PCE H\c = c Cl TCE PCE = tetrachloroethene TCE = trichloroethene DCE = dichloroethene VC = vinyl chloride c = cis t = trans Cl H H I I H - C - C - Cl H H Chtoroethane Cl H \ H H vc Sources: Vogel etal., 1987(5); Barrio-Lage etal., 1986(10). have been introduced into the environment directly, or they may have been formed through the degradation of other chlorinated organic compounds (e.g., TCA), as shown by the alternate routes to PCE degradation products in Figure C-2 or introduced into the ground directly. Hexachloroethane is readily reduced to PCE (5), and because hexachloroethane is a stronger electron acceptor than oxygen, its reduction is favored even under aerobic conditions. Thus PCE could be the second rather than the first step in the reaction sequence described above. There seems to be no evidence that trichloroethane (TCA) is a degradation product of PCE, although it may be formed through the stepwise hydrogenolysis of hexachloroethane to pentachlorethane, tetrachloroethane, and then trichloroethane (5). A number of the compounds identified as products in the breakdown chain of PCE, such as 1,1 -DCE, vinyl chloride, and chloroethane can also result from TCA degradation (5). TCA is not a. chemical suspected of being used at the LAGA textile operation but was present in Texaco and Esso waste oils. The conditions present in the aquifer do not favor the transformation of the PCE to the observed degradation products (see section below). The aquifer conditions indicate that the vehicle maintenance stations are a more likely source of the DCE, VCE and TCE observed in the aquifer due to the stations' use of septic systems produce anaerobic conditions more favorable to the reduction of chlorinated organic compounds to the observed compounds. The stations are sources of toluene contamination in the aquifer-through codisposal with solvents and leaking gasoline tanks. As noted above, PCE degradation is enhanced in the presence of toluene (6). It is also apparent that the TCE, VCE and DCE found in ground water are not necessarily formed by PCE degradation as mistakenly indicated in Technical Memorandum n by Geraghty & Miller, Inc. In fact, TCE is a common solvent reported as present in many of the facility CERCLA 104(e) notifications. C.2 Chlorinated Organic Compounds in Wastewater Treatment Plant Effluents Chlorinated organic compounds are found in the effluents of wastewater treatment plants for two reasons. These compounds are often present in the influent of the plants and are not completely removed by the treatment process. They are also formed through the disinfection of the plant's effluent with chlorine. The table below summarizes the results of a survey of the concentrations of chlorinated organic compounds in the effluents of 40 U.S. municipal waste water treatment plants. The data are for pollutants that were detected in at least 10 percent of the 302 samples analyzed. C2 Arthir D Little TUT 005 170.-. Figure 2: Alternate Routes to PCE Degradation Products a. TCE from HCE Cl Cl \ Cl— C — C — Cl / \ Cl Cl HCE H Cl \ Cl— C—C — Cl / \ Cl Cl PCA H Cl \ / C = C / \ Cl Cl TCB Cl Cl \ / c = c / \ Cl PCE Cl b. DCEfromHCEorTCA H Cl Cl \ \ Cl H — C— C— Cl / \ H Cl 1,1,1- H Cl— C — C — Cl / \ Cl Cl HCE TCA H\ Cl H Cl— C — C — Cl v Sc, \ Cl PCA Cl \ H— C — C — Cl / \ Cl Cl 1.1.2-TECA \ Cl c = c H 1,1-DCE \ Cl H\ H Cl— C — C — Cl / \ Cl Cl 1.1A2-TECA \ H\ Cl e-DCE H \ Cl Sources: Vogel el al, 1987 (5) and Barrio Lage et al. 1986 (10) Note: Final degradation products may be formed from any compound along the degradation pathway. HCE - hexacNoroelharte PCA - pentachloroethane TECA - tetrachloroethane TCA - trichloroelhane DCA - dichtoroethane CA - chbroethane PCE - tetrachtoroethene (perchloroethylene) TCE - frichloroethene DC . dichloroelhene VC - vinyl chloride C-CIS TUT 005 17O4 (continued) Figure 2: Alternate Routes to PCE Degradation Products (continued) c. Vinyl Chloride from HCE orTCA d. Chk>ro«thane from HCE or TCA H\ Cl Cl Cl \ Cl Cl Cl— C— C— Cl \ Cl\ Cl w v ^ / \ H Cl 1.1,1 -TCA H H-SC / /C, V '•' H Cl \ / C = C / \ H Cl 1,1-OCE \ / \ Cl Cl HCE H T ci \ / Cl— C— C— Cl ^ -X' Cl PCA Cl TV Cl H x H j-c'-CI CI-/C-C^-CI XCI \ /Cl Cl \ ,1.2-TECA N^ f 1.1A2TECA ^ H H H H H— NC— C—CI \-G / \ / \ Cl Cl Cl Cl 1.M-TCA e-OCE I •"""^ H T H ^^^ \^ > = < ^ H Cl vc 01 —— ti —— O —— \J\ / \ a r*i V/l H T Cl \ / ci— c— c— ci / \ Cl Cl n/* A PCA H Cl ^^ ^X H— C— C— Cl Cl / \ Cl Cl 1,1.1.2. TECA H T Cl \ / H — C— C— Cl H / \ H Cl 1,1,1 -TCA H r«i Cl \ / H H — C— C— Cl / \ H 1.1-DCAH ——————— ^ c = c / \ a PI \j\ PCE H I f*l ' Ol \ / c = c / \ H H Cl Cl \ / TCE — c— c— ci / \ Cl Cl 1,1,2,2-TECA v \h \ — C— C— Cl \ Cl JCI ^^ TC \ ,. H T H \ / H H -/C-C\-H Nc = c/ Cl Cl r( \\ Cl *->i i i.nr* c-OCE Compound Parcant of Sampfes with ItotoctabU Concentrations Maximum Concentration ug/l Mettaylene Chloride Chloroform Tetrachloroetbene (PCE) 1,1,1-Trichloroethane (TCA) Trichloroetbene (TCE) trans-l^-Dichloroetbene (DCE) 1,1-Dichloroetbene (DCE) 86 87 79 52 45 39 29 62,000 87 UOO 3,500 230 17 11 Source: Mills et al., 1985 (7). The reaction of free chlorine with huraic substances in drinking water and wastewater leads to the formation of trihalomethanes (THM), such as chloroform, and small quantities of hexachloroethane (HCE)(3,8). The rate (and generally the extent) of THM formation increases with temperature, Ph, and the concentration of organic precursors (8). Free chlorine is necessary for the formation of THMs, but free chlorine residuals in excess of the chlorine demand have little effect in increasing the rate of THM formation (8). Because the precursors of THM formation (humic materials) are naturally occurring and not industrial pollutants, the presence or absence of industrial dischargers to the sewage treatment plant does not affect THM formation (8). As noted above, hexachlorethane (HCE) is readily reduced to PCE. This transformation can occur under any environmental conditions including aerobic conditions (5,9). The reduction of HCE to PCE has been observed in the field—in aerobic ground water (9). References 1. Gilbert, D. et al., 1980. An Exposure and Risk Assessment for Trichlorethylene. U.S. EPA, Washington, D.C. Final Draft Report. 2. Howard, P.H. et al., 1991. Handbook of Environmental Degradation Rates. Lewis Publishers, Chelsea, Michigan. 3. Howard, P.H. 1989. Handbook of Environmental Fate and Exposure Data. Lewis Publishers, Chelsea Michigan. 4. Barber, L.E. et al., 1988. Long term fate of organic micropollutants in sewage-contaminated ground water. Environmental Science and Technology 22:205-211. ArthirD Little C3 TUT OO5 1706 5. Vogel, T.M., C.S. Griddle, and P.M. McCarty, 1987. Transformation of halogenated aliphatic compounds. Environmental Science and Technology 21:722-736. 6. Sewell, G.W. and S.A. Gibson, 1991. Stimulation of the reductive dechlorination of tetrachloroethylene in anaerobic aquifer microcosms by the addition of toluene. Environmental Science and Technology 25:982-984. 7. Mills, W.B. et ah, 1985. Water Quality Assessment: A screening Procedure for Toxic and Conventional Pollutants in Surface and Ground Water-Part 1 (Revised 1985). U.S. Environmental Protection Agency, Athens Georgia. EPA/600/6-85/002a. 8. Williams, R.B., and G.L. Gulp, 1986. Handbook of Public Water Systems. Van Nostrand Reinhold Co., New York. 9. Schwartzenbach, R.P., P.M. Gschwend, and D.M. Imboden, 1993. Environmental Organic Chemistry. John Wily & Sons, New York. 10. Barrio-Lage G. et al., 1986. Sequential Dehalogenation of Chlorinated Ethenes. Environmental Science and Technology 20:96-99. 11. Geraghty & Miller, Inc. Table A-6 of Hydrogeologic Framework of the Turpentine Run Basin, St. Thomas. 12. Bodek, I. et al., 1988. Environmental Inorganic Chemistry. Pergamon Press, New York. 13. Vogel, T.M. and P.L. McCarty, 1985. Biotransformation of Tetrachloroethylene to Trichloroethylene, Dichloroethylene, Vinyl Chloride, and Carbon Monoxide under Methanogenic Conditions. Applied and Environmental Microbiology 49:1080-1083. 14. Da vis, J.W. and C.L. Carpenter, 1990. Aerobic degradation of vinyl chloride in ground water samples. Applied and Environmental Microbiology 56:3878- 3880 (abstract). 15. Barrio-Lage, G.A. et al., 1990. Enhanced anaerobic biodegradation of vinyl chloride in ground water. Environmental Toxicology and Chemistry 9:403- 415. 16. Meyer, E., 1993. Expert Report C4 Arthir D Little TUT 005 170?