J^GERAGHTY
. <S? .MILLER, INC.
Environmental Services
Ground Water 
Engineering 
Hydrocarbon 
Remediation 
Education
November 22, 1994
Ms. Caroline Kwan, Project Manager
USEPA Region II
26 Federal Plaza, Room 737
New York, NY 10278
Re: 
Sampling Procedures and Waste-Classification Analytical Results of Drill Cuttings, Tutu
Wells Site, St. Thomas, U.S. Virgin Islands
Dear Ms. Kwan:
On behalf of de maximis, inc., Designated Coordinator for the Tutu Environmental
Investigation Committee (TEIC), Geraghty & Miller, Inc. has prepared this submittal regarding
sampling of drill cuttings from the Phase II Remedial Investigation (RI) on June 29, 1994 from
the Tutu Wells Site, St. Thomas, U.S. Virgin Islands. The analytical parameters included
USEPA Toxicity Characteristic Leachate Procedure (TCLP) and Resource Conservation and
Recovery Act (RCRA) waste characteristic parameters (e.g., ignitability and corrosivity).
Two composite samples of the drilling material were collected, with each sample
representing one-half of the total material (approximately 60 drums). Each sample was retrieved
with a stainless steel spoon and placed in a stainless steel bowl. After collecting a representative
portion, the material was mixed in the bowl and immediately transferred to the sample
containers.
As shown on the accompanying tables, all analytical results were below method detection
limits with the exception of cadmium at 0.011 parts per million (ppm) in sample DS-2. This
value is well below the TCLP regulatory limit of 1 ppm (40 CFR Part 261). No other TCLP
parameters were detected. The results for other waste characteristic parameters were also
indicative of non-hazardous material. The material was non-ignitable and the corrosivity was
within the non-hazardous range of between 2 to 12.5 pH units. Reactive cyanide and reactive
sulfide were below the method detection limits. Therefore, the drill cuttings are classified as
non-hazardous.
TUT 
OO6 
O5&4
201 West Passaic Street, 3rd Floor • Rochelle Park, New Jersey 07662-(201) 909-0700* FAX (201) 909-0567/0568
*64622*
64622
GERAGHTY & MILLER. INC.
Since this material is non-hazardous, it should be disposed of as a non-hazardous solid
waste. The TEIC will coordinate the proper disposal of this non-hazardous solid waste with the
USEPA and Virgin Islands Department of Planning and Natural Resources. Your assistance
would be greatly appreciated. If you have any questions, please call.
Sincerely,
GERAGHTY & MILLER, INC.
Thomas V Danghy 
(/
SenieHSclentist/Project Manager
Daniel Nachman
Vice President/Project Officer
c: 
Geoff Siebel, de maximis, inc.
Paul Ryan, Texaco
Leonard Reed, DPNR
Adrian Schotroff, DPNR
g:\JVrqecU\tutu\prfXM3.03g\corrcsp\kwanl 107. Itr
TUT 
O06 
O565
Table 2. 
Concentrations of Toxicity Characteristic Leaching Procedure Base Neutral and Acid Extractable Organic Compounds in Composite Drum Samples Collected in June 1994
at the Tutu Wells Site, St. Thomas, U.S. Virgin Islands.__________________________________________________________________
Sample ID: DS-I 
DS-2
Analyle 
Date: 
29-Jun 94 
29-]un-94
m Si p Cresol(s)
o-Crcsol
1 ,4-Dichlorobenzene
2,4-Dinitrotoluene
Hexachlorobenzene
Hexochlorohutadicne
Hexachloroethane
Nitrobenzene
Pcnlachlorophcnol
Pyridine
2,4,5-Trichlorophenol
2 ,4 ,6-Tr ichlorophenol
0.05 U
0.05 U
0.05 U
0.05 U
0.05 U
0.05 U
0.05 U
0.05 U
0.25 U
0.1 U
0.25 U
0.05 U
0.05 U
0.05 U
0.05 U
0.05 U
0.05 U
005U
0.05 U
0.05 U
0.25 U
0.1 U
0.25 U
0.05 U
Analyte concentrations in milligrams per liter (parts per million (ppm)).
Analyses were performed by Enseco- East of Somerset, New Jersey, using USEPA Method 8270 and Toxicity Characteristic Leaching Procedure.
U 
The compound was analyzed for, but not detected at the corresponding reporting limits.
Cr-
GERAGHTY<*MILI.i :.R.INC
Table 3. 
Concentrations of Toxicity Characteristic Leaching Procedure Pesticides and Herbicides in Composite Drum Samples Collected in June 1994 at the Tutu Wells Site, St.
Thomas, U.S. Virgin Islands.
Simple ID: DS-I
DS-2
Analyte
Dale:
29-Jun-94 
29-Jun-94
gnmma-BHC (Lindane)
Chlordane
Endrin
Meptachlor (and its epoxide)
Methoxychlor
Toxaphene
2.4D
2,4,5-TP(Silvex)
0.0005 U
O.OOSU
0.001 U
0.0005 U
O.OOSU
0.05 U
O.OOSU
0.001 U
0.0005 U
O.OOSU
0.001 U
0.0005 U
O.OOSU
0.05 U
O.OOSU
0.001 U
Analyte concentrations in milligrams per liter (parts per million Ippm]).
Analyses were performed by Enseco- East of Somerset, New Jersey, using standard U.S. Environmental Protection Agency methodology and Toxicity Characteristic Leaching Procedure.
U 
The compound was analyzed for, but not detected at the corresponding reporting limits.
C
—i
GERAGHTY c* MII.LHR. INC
Table 4. 
Concentrations of Toxicity Characteristic Leaching Procedure Metals in Composite Drum Samples Collected in June 1994 at the Tutu Wells Site, St. Thomas, U.S.
Virgin Islands.
Sample ID: DS-I
DS-2
Analyte
Date:
29-Jun-94 
29-Jun-94
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
0.1U
1 U
0.005 U
0.01 U
0.05 U
0.0002 U
0.2 U
0.01 U
0.1 U
IU
0.005 U
0011
0.05 U
0.0002 U
0.2 U
0.01 U
Analyte concentrations in milligrams per liter (parts per million [ppm]).
Analyses were performed by Enseco- East of Somerset, New Jersey, using standard U.S. Environmental Protection Agency methodology and Toxicity Characteristic Leaching Procedure.
U 
The analytc was analyzed for, but not detected at the corresponding reporting limits.
-i
0-
CD
GHRAGHTY & MIU.HR. INC
Table I. 
Concentrations of Toxicity Characteristic Leaching Procedure Volatile Organic Compounds in Composite Drum Samples Collected in June 1994 at the Tutu Wells Site,
It Thnmai 11 $ Viroin lelanHi
St. Thomas, U.S. Virgin Islands.
Simple ID: DS-1 
DS-2
Analylc 
Dale: 
29-Jun-94 
29-Jun 94
Benzene
Carbon tetrachloride
Chlorobenzene
Chloroform
1 ,2-Dichloroethane
1,1-Dichloroethene
2-Butanone
Tetrachlorocthene
Trichloroethene
Vinyl chloride
0.12 U
0.12U
0.12 U
O.I2U
0.12U
0.12U
0.25 U
0.12U
0.12U
0.25 U
0.12 U
O.I2U
0.12 U
0.12 U
O.I2U
0.12U
0.25 U
O.I2U
0.12U
0.25 U
Analyte concentrations in milligrams per liter (parts per million [ppm]).
Analyses were performed by Enscco- East of Somerset, New Jersey, using USEPA Method 8240 and Toxicity Characteristic Leaching Procedure.
U 
The compound was analyzed for, but not detected at the corresponding reporting limits.
HaH
GERAGHTY & MII.I.HR. INC