UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 
REGION II 
SDMS Document 
DATE: 
SEP 0 8 1995 
115573 
PJBJECT: Technical Review 8f the Draft Data Summary Report for the Virgin Island 
Chemical Site 
FROM: Shari Stevens, Environmental Scientist 
Surveillance and Monitoring Branch (ESD-SMB) 
TO: Sherrel D. Henry, Remedial Project Manager 
New York/Caribbean Superfund Branch II (ERRD-NyCSB2-E) 
As you requested, we have reviewed the "Draft Data Summary 
Report," dated August 1995, prepared by Harding Lawson 
Associates for the Virgin Island Chemical Site in St. Croix, 
U.S. Virgin Island. 
The sampling data (from groundwater monitoring wells and soil 
borings) collected appears to have been designed to support an 
assessment of the risks associated with on-site contamination. 
However, it would be appropriate to investigate the level and 
extent of contamination in the River Gut. The figures of the 
site illustrate that potential contaminant pathways may exist 
into the Gut from surface water runoff. The storm drainage 
systems are another pathway for contaminants leading directly 
into the Gut particularly the central storm drain which is 
connected to the process area and the process pit. 
Contaminants in site surface soils could be washed into the 
River Gut through these pathways especially "%f adsorbed to fine 
particles. Due to the intermittent nature of the Gut, 
contaminants bound to fine sediment could be resuspended and 
washed downstream during storm events. This reinforces the need 
to delineate the extent of off-site contamination, as the river 
may act as a pathway for transporting site contaminants into 
sensitive habitats such as wetlands and/or coastal areas. The 
slowing effect that wetlands or delta areas have on streams 
allows sediments to settle out of the water column. This 
creates a depositional area where contaminants can concentrate. 
The potential for the transport of contaminants associated with 
the site should be addressed, and may create a need to sample 
depositional areas along the River Gut. 
A recommendation was made in the April 26, 1994 to sample the 
top 12 inches of surface soil on-site. As indicated in Table 
2-1 the top 2 feet of some of the soil boring samples were 
analyzed. The zero to one foot depth is the zone of soil in 
which the majority of ecological receptors will receive their 
exposure to soil contamination. Including additional depth in 
the sample may dilute the contaminant, thus underestimating the 
risk. 
305260 
In Section 3.3 (page 6) of the Baseline Ecological Assessment 
the discussion of pathways for potential sources does not 
include incidental ingestion. It may appropriate to consider 
this pathway since it can sometimes be a significant percentage 
of intake depending on the species. 
In the April 26, 1994 BTAG memorandum, we recommended that it 
would be appropriate to conduct some form of a biological survey 
to determine what, if any, habitat and species were present on 
site. It was indicated in this report that there are no 
habitats identified as suitable to support rare, threatened, or 
endangered species. In January 1995, prior to this 
determination, most of the vegetation on site was removed with 
heavy equipment. We would be interested in reviewing the 
information used to support this determination. 
The potential sources of concern are the open drainage channels 
of the process pit area, soils in the area of the AST's with 
elevated VOC concentrations, and stained soils associated with a 
discharge for the AST labeled "Tank 5". However, it may also be 
appropriate to consider the elevated levels of zinc that were 
discovered on site. In Section 5.2.2.3 page 25 it is stated 
that the pesticides were not considered because of the 
widespread use of pesticides and relatively low concentrations. 
A discussion of what values were used to evaluate potential 
risks to ecological receptors was not included in this report. 
In the April 26, 1994 BTAG memorandum we recommended appropriate 
ecologically based screening criteria. Therefore, a discussion 
should be incorporated into this document describing the 
screening process utilized. 
In section 4.0 (page 9) an assumption is made that the 
concentrations of the sediments in the storm drain have 
decreased. However, the drain sediments have not been sampled 
since 1985. Therefore, it may be appropriate to sample these 
sediments to determine the concentration of contaminant in this 
pathway. 
If you have any questions, comments, or require further 
information, please contact Michael Clemetson at (908) 321-6712. 
cc: Carole Petersen, ERRD-NycSB2 
Mel Hauptman, ERRD-NYCSB2-E 
Mark Sprenger, HQ-ERT 
Gina Ferreira, ERRD-PSB 
Bob Witte, OPM-EIB 
Diane Wehner, NOAA 
John Cantilli, WMD-MWPB 
Karen Kracko, WESTON/REAC 
,'/<. J l 
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