CAMPBELL, ARELLANO & RICH
ATTORNEYS AT LAW
P.O. BOX 11899 
ST THOMAS OFFICE:
CHARLOTTE AMALIE. ST. THOMAS
NQ
JOSEPH BRUCEWm. ARELLANO 
U.S. VIRGIN ISLANDS 00*01 
CHARLOTTE AMALIE
CAROL ANN RICH 
TELEPHONE 809/774-4858
———————————— 
TELECOPIER: 809/776-8442
W. MARK HILLSMAN 
SJ JQHN OFF,CE
OF COUNSEL-
ROGER L. CAMPBELL 
SCANDIC EXECUTIVE OFFICES
MONGOOSE JUNCTION
CRUZ BAY
TELEPHONE 809/775-«655
September 30, 1994
VIA TELECOPIER
Ms. Caroline Kwan
New York-Caribbean Superfund Branch
USEPA Region II
Jacob K. Javitz Federal Building
26 Federal Plaza
New York, NY 10278
Re: Tutu Wells Site Draft Risk Assessment/Draft RI Comments
Ramsay Motors - File 92115
Dear Ms. Kwan:
This firm is counsel for Ramsay Motors, Inc. the Ford
dealership located at No. 405 Anna's Retreat, St. Thomas,
Virgin Islands.
We wish to offer the following comments to the Revised
Pathway Exposure Report Draft Endangerment Assessment for
the Tutu Wells Site, St. Thomas, USVI, which we understand
will be Section 7 in the Phase II Remedial Investigation
report.
There are substantive inaccuracies in Table 8, Potential
Exposure Pathways, both Present Use GroundWater and Future
Use GroundWater, as well as Section 3.2 (page 24). These
three citations indicate that pumping occurs at the Ramsay
well, and further assumes that it is reasonable that this
water may be used for primary purposes, including drinking.
The Ramsay supply well has been permitted for pumping at 500
gallons per day by the DPNR (formerly by the Department of
Public Works) since 1978 or 1979. In 1987-88, stop pumping
orders were issued by DPNR to several well owners in the
Tutu area. I have reviewed the stop pumping orders that were
issued, and the file and records at EPA, Region II and at
DPNR Nisky, St. Thomas. 
Although DPNR was aware of the
Ramsay well, no stop pumping order was ever issued to Ramsay
Motors. Had such an order been issued, Ramsay would have
complied with it. The EPA, DPNR, and TEIC have at all times
been aware that the Ramsay well was pumping. The supply well
has been included in each quarterly sampling round, and
Ramsay Motors has always cooperated in providing TEIC, EPA
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64658
and 
DPNR 
with access 
for testing, inspection, and
measurements of the supply well. To my knowledge, at no time
has any governmental agency ever indicated to Ramsay, orally
or in writing, that use of the well was improper.
Moreover, DPNR has consistently renewed Ramsay's permit.
Mr. Ivan Cooper of Cooper Environmental Inc., attended a
meeting organized by DPNR in April 1993 in St. Thomas for
the purpose of discussing well usage in Tutu as Ramsay's
representative. At that meeting, pumping of the Ramsay well
was discussed, and DPNR elected not to close the Ramsay
well, so as to maintain the status quo that has existed
since 1988-89.
Therefore, the implication in the report, whether or not
intended, that Ramsay may be pumping the supply well
illegally, or without DPNR's knowledge, is inaccurate. We
request that the record be appropriately clarified, as
Ramsay has at all times cooperated fully with all laws,
regulations, and requests by EPA, DPNR, and TEIC. Any
implication in the report to the contrary is unwarranted and
unfair to my client.
Although Table 8 lists "Ingestion" of groundwater by
employees of Ramsay as an exposure route, this does not
occur. This well is not piped for drinking. It is hard piped
into toilets and faucets for hand washing and hose spigots
for occasional car rinsing. Bottled water is supplied for
employee and customer drinking purposes. Additionally, it is
common Virgin Islands practice not to drink from hoses, as
quality and taste problems are endemic. Therefore, ingestion
of Ramsay Well water is not a realistic concern.
Please modify the Risk Assessment to correct the errors that
appeared in the draft report. If you have any questions,
please feel free to give a me a call. Thank you for your
attention.
Sincerely,
irol Ann Rich, Esq.
CAR/bel
cc: Ivan a. Cooper P.E., Cooper Environmental, Inc..
Jack McBurney, de maximus, Inc.
Daniel Nachman, Geraghty and Miller
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