CAMPBELL, ARELLANO & RICH
ATTORNEYS AT LAW
P.O. BOX 11899 
ST. THOMAS OFFICE:
CHARLOTTE AMALIE
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N0 4A * B KONGENS CADE
JOSEPH BRUCE Wm. ARELLANO 
SAINT THOMAS 
CHARLOTTE AMALIE
CAROL ANN RICH 
U.S. VIRGIN ISLANDS 00801 
TELEPHONE: 809/774-4858
———————————— 
TELECOPIER: 809/776-8*42
OF COUNSEL:
ROGER L. CAMPBELL 
ST. JOHN OFFICE:
SCANDIC EXECUTIVE OFFICES
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MONGOOSE JUNCTION
April 26, 1995 
CRUZ BAY
TELEPHONE: 809/693-8655
Ms. Caroline Kvan
U.S. EPA
290 Broadway
New York, NY 10007-1866
Re: Draft Feasibility Study; Tutu Wells Site
Dear Ms. Kwan:
In accordance with the schedule announced at the PRP
meeting in St. Thomas on April 19, 1995, I offer the
following comments on behalf of Ramsay Motors Inc., on the
draft Feasibility Study (FS) dated March, 1995.
Based upon the discussion in Section 4.1.1 of the FS,
and the presentation by de maximus for TEIC on April
19,1995, no soil remediation has been proposed for the
Ramsay site, because sampling did not reveal concentrations
of the contaminants of concern above NYS TAGM levels. 
We
agree with this assessment and urge EPA to accept TEIC's
recommendation. Moreover, as the RI confirms, none of the
contaminants detected in groundwater samples from the Ramsay
supply well and in samples from monitoring wells 15 and 17
on the Ramsay site, were detected in over 20 soil samples
taken from all over the property.
The RI found no impact or potential impact to
groundwater from the Ramsay site. 
Therefore, Ramsay will
not comment upon the remedial alternatives for groundwater,
except as those alternatives may affect Ramsay's ability to
continue to use its supply well. 
In other words, these
comments are from the point of view of a well owner, not a
PRP.
The FS describes eight Site-Wide Remedial Alternatives
(SWRAs). SWRA 1 is not under consideration. 
SWRAs 2,4,5,7
and 8 
all contemplate allowing certain private supply
wells, including the Ramsay well, to pump with POET systems.
SWRAs 3 and 6 contemplate closing all supply wells in the
area, including the Ramsay well. At the April 19 meeting,
de maximus recommended an SWRA which would allow Ramsay to
continue using its well, absent later developed information
that such use would interfere with the selected treatment
option or encourage the further 
spread of the northern
plume of chlorinated hydrocarbon contamination. 
It is our
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Ms. Caroline Kwan
April 26, 1995
Page -2-
understanding that TEIC views these risks as unlikely, given
the location and usage of Ramsay's well.
Initially, EPA voiced opposition to the concept that
any private supply well could be adequately Monitored to
safely allow pumping. There was a lively discussion about
compliance problems and the difference, from a public health
point of view, between commercial supply wells for non-
potable use, such as Ramsay's well, and wells serving
private residences or apartments. 
This letter will
memorialize our comments regarding this issue.
The Ramsay well is used as a source of non-potable
water for the operation of Ramsay's Ford dealership. The
well is pumped to a holding tank that is connected to supply
water for flushing toilets and washing cars or parts.
Ramsay does not operate a car wash, however, some cleaning
is done in connection with repair and warranty work
performed in the service area and body shop. The well is
not now, and never has been, used as a source of drinking
water or for bathing. Bottled drinking water is provided in
the sales area and the shop for employees and customers.
Ramsay's groundwater appropriation permit was renewed by
DPNR for the period from September 9, 1994 - September 9,
1996. A copy is enclosed for your ready reference. Ramsay
is permitted to pump 500 gallons per day. 
The permit
expressly states that the water is not to be used for human
consumption.
Ramsay has cooperated with EPA, DPNR and TEIC on every
level since the investigation began in 1987. 
Ramsay has
promptly complied with every applicable rule, regulation or
statute, and has responded to EPA's 104(e) requests fully.
Ramsay has also invested over $150,000.00 in expert fees and
costs alone in assisting with the RI by sampling soils and
waste oil and providing the results, and a site assessment
report by Cooper Environmental, to TEIC and to EPA. Ramsay
joined the PRP group and has actively assisted in its work.
We respectfully suggest that Ramsay has demonstrated for the
past seven years that it is a responsible corporate citizen
that can be trusted to comply with any reasonable
requirements that are necessary to allow the continued use
of its well for non-potable purposes. Therefore, if EPA is
considering closing Ramsay's well solely out of general
compliance concerns, the closure is unwarranted. Ramsay's
well should not be closed unless there is reliable evidence
that continued operations under the conditions in Ramsay's
current permit pose a risk to public health or the
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Ms. Caroline Kwan
April 26, 1995
Page -3-
impleaentation and success of the remedial alternative
selected by EPA for the Tutu Wells Site.
Finally, EPA should consider that by allowing Ramsay to
use its well, some of the cost that would otherwise be
allocated among the responsible parties will be avoided. If
the well is closed, some provision will have to be made to
replace the water supply now obtained from the well. This
potentially unnecessary expense 
should be avoided if
possible.
For all of these reasons, Ramsay urges EPA to accept TEIC's
recommendation not to close the Ramsay supply well. Ramsay
would be willing to enter into any reasonable agreement that
EPA may require to ensure Ramsay's continued compliance with
use restrictions.
Sincerely,
Carol Ann Rich, Esq.
cc: Mrs. Rita Ramsay
Ivan Cooper, P.E.
Andrew Prashack, Esq. (w/encl.)
All PRP Group members
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