& MILLER, INC.
Environmental Services
Ground Water 
Engineering 
Hydrocarbon 
Remediation 
Education
May 19, 1993
Mr. Leonard Reed
U.S. Virgin Islands Department of
Planning and Natural Resources
Nisky Center 8000, Suite 45
St. Thomas, U.S. Virgin Islands 00802
Re: 
Request for Waste Classification and Permission for Disposal
Dear Mr. Reed:
Pursuant to our recent telephone conversation and as a followup to my facsimile, enclosed
is a copy of the March 2, 1993 letter to Caroline Kwan of the U.S. Environmental Protection
Agency (USEPA). This letter describes the sampling procedures and results for the drilling
cuttings from the Tutu Service Station Investigation. Geraghty & Miller believes this drilling
material (which consists of soil and rock cuttings) should be classified as a non-hazardous solid
waste because the Toxicity Characteristic Leachate Procedure (TCLP) and Resource
Conservation and Recovery Act (RCRA) waste characteristic parameters were below limits for
hazardous waste and within the limits of non-hazardous material.
As discussed with the USEPA and Clifford Crooke on April 28, 1993, this soil could be
useful as daily cover for the Bovoni Landfill. The Tutu Environmental Investigation Committee
(TEIC) would like to receive a letter from the Department of Planning and Natural Resources
(DPNR) that confirms that this material is non-hazardous. Please direct your response to:
Ana Gloria Ramos
Designated Coordinator
Tutu Environmental Investigation Committee
P.O. Box 364269
San Juan, Puerto Rico 00936-4269
201 West Passaic Street, 3rd Floor • Rochelle Park, New Jersey 07662* (201) 909-0700 • FAX (201) 909-0567/0568.
TUT 
OO6 
1.5O6
*64797*
64797
GERAGHTY & MILLER, INC.
Based on your response, the TEIC will implement the appropriate handling and disposal
of these drilling cuttings. If you require any additional information, please do not hesitate to
call. Thank you for your assistance in this matter.
Sincerely,
GERAGHTY & MILLER, INC.
Thomas V. Danahy 
//
Project Manager
-SenioT~Scleirti
Daniel A. Nachman
Vice President/Project Director
/"*"N 
c: 
Ana Gloria Ramos, TEIC
Clifford Crooke, DPNR
Adrian Shottroff, DPNR
PR01301-WP4/51893.LTR/df
TUT 
006 
15O7