C O M 
F E D E R A L 
P R O G R A M S 
C O R P O R A T I O N
a s u b s i d i a r y o f C a m p D r e s s e r & M c K e e l n c .
June 18, 1992
Ms. Caroline Kwan
U.S. Environmental Protection Agency
26 Federal Plaza
New York, New York 10278
PROJECT: 
TES V, EPA CONTRACT NO: 68-W9-0002
Work Assignment C02048
Tutu Veil Field Site
St. Thomas, U.S. Virgin Islands
DOCUMENT NO: 
TESV-C02048-EP-CMQV
SUBJECT; 
Samples for Surface Soil Risk Assessment
Tutu Service Station Investigation
Dear Caroline:
This letter is to inform you of the results of my discussion with Mark
Maddaloni of EPA on June 16 concerning the risk assessment for surface
soils at the Tutu Wells Site in the U.S. Virgin Islands. It is Mark's
understanding that the wording in the National Contingency Plan (NCP)
implies that any risk assessment performed during a CERCLA remedial
investigation should be quantitative, even if the pathway is not expected
to be major. 
While a quantitative evaluation can technically be performed
on data from a single sample (or from five samples as currently in the Tutu
scope), the reliability of the assessment increases with a greater number
of samples.
In this light, we discussed surface soil data needs for the Tutu
investigation. We discussed obtaining additional data from the uppermost
splitspoon of investigation borings, but most of these are located in paved
areas. I also mentioned that validated surface soil data is available from
previous investigations that EPA conducted in 1988 and 1989 as part of the
104(e) letter response investigation. Lists of the sample locations and
the types of analyses performed are attached.
The eighteen surface soil samples were collected by CDM FPC from areas of
suspected contamination on a number of area properties and are therefore
biased towards worst case soil concentrations. Samples collected in 1988
were analyzed for Volatile Organic Analytes (VOAs), Pesticides/
Polychlorinated Biphenols (PCBs), total petroleum hydrocarbons (TPH), lead
and chromium. Samples collected in 1989 were analyzed for VOAs, organic
extractables (semi-VOAs), TPH and Extraction Procedures Toxicity Testing
(EP Tox).
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111 Fulton Street, Suite 710 New York, NY 10038 212 393-9634 
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COM FEDERAL PROGRAMS CORPORATION
a subsidiary of Camp Dresser & McKee Inc.
Please show these lists to Mark for his evaluation as to whether the
addition of these samples would be suitable and sufficient for the
investigation. If they are not and more samples are required, COM FPC
suggests that a surficial soil be collected from boring B-l behind the
Curriculum Building and that additional grab samples be collected from
unpaved areas at the site.
Sincerely,
COM FEDERAL PROGRAMS CORPORATION
Sally Odland
Work Assignment Manager
cc: Mark Maddaloni, EPA
Scott Graber, COM FPC
Document Control (2 copies)
NYC file
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TUT
006