9 1993
EXPRESS MAIL
RETURN RECEIPT REQUESTED
Ana Gloria Ramos, P.E.
Designated Coordinator
Tutu Environmental Investigation Committee
P.O. Box 364269
San Juan, Puerto Rico 00936-4269
Re: 
Comments on Technical Memo II and RI from the Tutu's Technical Group
Dear Ms. Ramos:
Enclosed please find the above-referenced document. I would like to have your consultant review
the contents of this document. A conference call is scheduled for Wednesday, August 25, 1993 at
2:30 pm to discuss the contents of this document. Please dial (202) 260-4276 at 2:30 pm to access
the conference line.
Please call me if you have any questions.
Sincerely yours,
Caroline Kwan
Project Manager
New York/Caribbean Superfund Branch II
Enclosures
Sally Odland-CDM
Thomas Danahy- G&M
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*64952*
64952
505 Marquette NW, Ste. 1100- Albuquerque, NM 87102
(505) 842-0001 • FAX: (505) 842-0595
GCL
August 13, 1993
TELEFAX AND
FED EXPRESS
Ms. Caroline Kwan
Project Manager
USEPA - Region n
26 Federal Plaza, Room 737
New York, New York 10278
RE: COMMENTS ON TECHNICAL MEMORANDUM H AND RI, TUTU SITE,
US. VIRGIN ISLANDS
Dear Ms. Kwan:
The group (Technical Group) comprised of the technical representatives of the PRPs listed
below is pleased to submit our comments on Technical Memorandum n prepared by
Geraghty and Miller and our further recommendations on how we can promptly proceed to
completion of an appropriate RI/FS and ROD. All were afforded an opportunity to
participate on the Technical Group including the Government of the Virgin Islands, the
Virgin Island Housing Authority, and Mr. and Mrs. Torinus. Those not joining in this
document indicated that they had not yet obtained technical representatives and therefore
could not participate in the drafting of these comments. It is the unanimous opinion of the
technical group that the Technical Memorandum n and the additional recommended work
will not comprise a complete RI for the Tutu site. Therefore, we believe that it is
necessary to supplement the existing and proposed site database to facilitate a timely,
technically feasible and cost-effective solution for the remediation of the Tutu problem.
Prior to executing additional investigations, the development and implementation of a
supplemental work plan that incorporates appropriate data quality objectives and recognizes
the importance of significant additional work performed outside the TEIC committee is
critical. A supplemental work plan should be developed with the cooperation of the
Technical Group to ensure participation of all interested parties.
The purpose of the Technical Group is cooperation toward implementing an effective
remedy for the observed soil and groundwater impacts at the site. By pooling our collective
knowledge about the site and by scheduling any required field work at each site, we believe
that the we can deliver a superior remedial strategy at a reasonable cost Towards this end,
you will note that we have spent considerable time and energy to develop specific comments
on additional work required to reach a defensible ROD.
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Ms. Caroline Kwan
Page 2
August 13, 1993
As we explained to you in our teleconference of 8/10/93, the group is just beginning to
work together and a formal agreement has not been completed; however, we have provided
specific and useful comments directed towards the completion of an RI/FS and ROD on the
timetable presented to us by you. We believe the formation of this Technical Group is a
very positive step toward a cost-effective remedy for the site. We look forward to working
with USEPA in resolving this matter.
Sincerely,
Alberto A. Gutierrez, CPG
Coordinator, Technical Group
AAG/54153/KWANOOl/LTR
Enclosures
THE TECHNICAL GROUP CONSISTS OF:
John T. Burkart, R.G., REA - Cooper Environmental, Ramsay Motors, Inc.
Ivan A. Cooper, P.E. - Cooper Environmental, Ramsay Motors, Inc.
Stephen Dubyk - H+GCL, Inc., Texaco Caribbean, Inc.
Donald P. Galya, P.E. - ENSR Consulting and Engineering, Western Auto, Inc.
Bruce K. Green - Caribbean Hydro-Tech, Inc., Four Winds Plaza Partnership
Randall T. Hicks - H+GCL, Inc., Texaco Caribbean Inc.
David E. Langseth - Arthur D. Little, Inc., Andreas Gal & Paul Lazare
Kenneth L. Loy - International Technology Corporation, L'Henri, Inc.
Thomas F. Maquire, CPG - Blasland & Bouck Engineers, P.C., Esso, S.A.
Belinda K. Price, MS, RPG - International Technology Corporation, L'Henri, Inc.
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August 13, 1993
Page 1 of 6
TECHNICAL GROUP COMMENTS ON
TECHNICAL MEMORANDUM H AND
RECOMMENDATIONS FOR REMEDIAL INVESTIGATION
The following are a series of comments that are intended to provide the USEPA Region II
with recommendations to supplement Technical Memorandum n, thereby establishing a
comprehensive Remedial Investigation (RI). The comments were developed by the
Technical Group. Our comments relating to Technical Memorandum n are presented in
Section A. Section B consists of our recommended objectives for a RI. Work elements
which should be completed prior to implementation of Remedial Investigation field work are
discussed in Section C. Section D presents a list of work elements and justification which,
based on our present knowledge of the site, are required to meet the stated objectives of
the RI. Implementation of Section C (below) may show that additional field programs are
required.
A. General Comment by PRP Group Concerning Geraghty and Miller Technical
Memorandum II
1. Tech Memo n made some conclusions that are not supported by information presented
in this report The data presented in the report includes only that from the TEIC wells;
and the analyses and conclusions of the report focus on the TEIC well data. It is
recommended that the conclusions of the report should be disregarded, except to the
extent that conclusions support specific recommendations regarding future field work.
The Memorandum should base recommendations upon data included in the document or
data which are clearly referenced in other available documents. The data provided in
Technical Memorandum n and data collected by the recommended work will not be
sufficient for a complete RI.
B. Provide a list of objectives which should be addressed by a Remedial Investigation for
the site
The selection of an appropriate set of objectives to assure that a RI/FS achieves the desired
goal of supporting a ROD is critical in this effort Since significant additional work has
been completed at this site beyond that considered in Tech Memo n and outside the TEIC
group, it is necessary to incorporate these data to the extent that they are helpful in
developing a RI/FS that can be supported by all PRPs. Based upon our evaluation of the
site conditions and the data available to the PRPs, the following remedial responses are
possible at the site:
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August 13, 1993
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i. Source control/remediation, point of use treatment, no active aquifer restoration
program
ii. Point of use treatment only
iii. An integrated source/aquifer remediation program
iv. No action
Following from the remedial responses presented above, the following objectives for the RI
are appropriate:
1. Provide sufficient data to determine the radius of influence of each production and
large-diameter monitor wells in or near the contaminant groundwater plume to permit
design of point of use treatment.
2. Provide sufficient data to predict contaminant concentrations in production wells within
the Tutu aquifer to permit design of point of use treatment.
3. Examine existing data to determine concentrations of major ions in groundwater to
permit prediction of operation and maintenance costs of point of use treatment systems.
4. Provide sufficient data to determine aquifer characteristics, contaminant distribution,
exposure pathways, and receptors to permit the development of a defensible risk
assessment and an evaluation of remedial alternatives for the site.
5. Provide sufficient data to determine the magnitude and extent of unsaturated zone
contamination at each potential source in sufficient detail to design/implement
appropriate source control/remediation.
6. Provide sufficient data to determine soil and aquifer characteristics to permit the
selection of interim remedial actions, short-term measures or remedial designs for source
control/remediation at each potential source.
7. Provide sufficient data to determine contributions from surface runoff, sanitary and
storm sewer line leakage.
C Suggested work elements which need to be conducted prior to any additional field
work towards a Remedial Investigation
1. CompQe and provide to PRPs a complete bibliography of site information. All
published reports, public documents (e.g. submitted to EPA), non-privileged documents
(e.g. reports the PRPs are willing to release), depositions, correspondence, and historic
aerial photographs, should be included in this bibliography.
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August 13, 1993
Page 3 of 6
2. Compile and synthesize chemical data into a computerized database for the purposes of
statistical analyses and map generation. Chemical data reported in dissimilar units (such
as ppmv versus pg/L in the soil vapor surveys) must be converted and standardized to
the same unit of measurement Data from all PRPs should be included in this database.
Geraghty and Miller may already have developed a database which may be expanded to
meet the needs of future field work.
3. Develop a computerized base map for the entire area, including all impacted water
supply wells.
4. Update the existing well inventory compiled by Geraghty and Miller and also identify
locations of all soil borings, soil vapor points, surface soil sampling locations, sump and
tank pit sampling locations, monitor wells, production wells and rock outcrops on the
base map (item 3, above). This will allow data gaps to be identified. Many sample and
soil boring locations, and monitor wells installed by the PRPs are not presented in
Technical Memorandum n.
5. Prepare a summary of all lithologic logs and well completion diagrams for wells/borings
on site. Hydrogeologic cross sections should be included in this summary.
6. Review and analyze all applicable data and analyses based upon a specific set of Data
Quality Objectives.
7. Evaluate existing aquifer test data to determine adequacy of tests. Tests conducted by
Caribbean Hydro-Tech may be sufficient to characterize certain portions of the site.
Aquifer test data presented in Technical Memorandum n are of limited application
toward a RI due to the documented logistical problems associated with the tests.
D. Work elements required as part of a Remedial Investigation to be incorporated into
imminent field work currently scheduled to be performed in 1993
1. Survey all wells to a common datum within the investigation area; establish a site
coordinate system. This will permit creation of complete and accurate potentiometric
surface maps.
2. Those monitor wells where analytical results were compromised due to elevated
detection limits, or where other problems have affected anah/te identification should be
re-sampled. Detection limits must equal or surpass drinking water standards for the
anatytes of concern.
3. A single-event water quality analysis program should be performed on all wells in the
area. Field analysis of dissolved oxygen and dissolved carbon dioxide should be included
in this program. Samples for analysis of known or suspected contaminants should be
collected and these data used to determine protocol for future regular sampling as
needed.
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Page 4 of 6
4. Additional shallow and deep wells are necessary to fully define the pattern of
groundwater contamination. However, we strongly urge that the items listed in Section
C must be completed before any additional field work is done. Notwithstanding our
unanimous opinion that the items in Section C must be completed before specific well
locations can be evaluated or recommended in a technically-defensible manner, we offer
the following comments on Geraghty & Miller's recommendations for additional wells as
shown on Figure 7-1 of Tech Memo n.
• 
MW-15: The proposed location for this well should be moved approximately 50
feet west-northwest to ensure that the well does not lie close to locations of
documented releases. The new location should be hydraulically equivalent to the
original MW-15 location.
• 
MW-16: Provided site conditions are appropriately dealt with such that the
underground storage tank at this location can be removed without jeopardizing
the integrity of the well.
Examples of additional wells that were discussed by the Technical Group and may be
useful in the delineation of groundwater contamination are as follows:
• 
An additional shallow well should be located equidistant between MW-9 and
proposed MW-18 to further define the down-gradient extent of organic
contamination.
• 
A monitoring well should be installed up-gradient of the O'Henry laundry. This
should be located 100 feet north-northeast of existing well MW-2 on the
O'Henry property.
• 
Monitoring wells should be installed 300 feet due east of existing well MW-7 and
200 feet due east of MW-10 and -10D, adjacent to Highway 382.
• 
Several wells should be installed down-gradient of the Harvey well.
• 
A monitoring well should be installed at the fence line between Ramsay Motors
and Antilles Motors directly south of the original proposed location of MW-15.
Justifications for these additional wells will be provided in subsequent communications
upon EPAs request.
5. With respect to recommendations for additional soil borings, the PRP Group has
examined the proposed recommendations from Geraghty & Miller. Although those
recommended locations may indeed provide useful additional information, the group
feels that without the systematic completion of the items included in Section C it is not
prepared to individually comment on the soil boring locations suggested by Geraghty &
Miller.
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August 13, 1993
Page 5 of 6
6. An evaluation of contaminant migration pathways arising from sanitary and storm sewers
is necessary. The potential for these features to act as sources has not been
investigated; therefore, appropriate measures should be taken to examine the potential
for these sources.
The process by which any additional field investigations should take place is described
below:
• 
Complete items included in Section C
• 
Evaluate need for additional field work, recommend and design additional field
work
• 
Implement additional field work
• 
Complete data evaluation
• 
Complete RI/FS
The PRP Group feels that it is important, in order to arrive at a defensible RI for the site,
that the data included as part of Section C activities be thoroughly considered in the
development of the final RI/FS.
E. Preliminary recommendations for additional work required for a complete Remedial
Investigation
1. Complete additional soil vapor surveys and obtain additional sofl samples as necessary to
define extent and magnitude of unsaturated zone contamination at each potential source
area.
2. Agree to a single sampling and analysis protocol (including Data Quality Objectives) for
the RI and any sampling conducted for subsequent interim remedial actions, tank
removals, etc. Soil samples at all sites should be evaluated for solvents and other
organic contaminants using standardized sampling and analytical techniques which will
optimize the recovery and analysis of representative samples. Air permeability, bulk
density, sofl moisture, soil clay and organic content, and grain-size distribution
measurements at specific locations may be appropriate if sofl venting techniques are to
be considered for contaminant control and source remediation at each potential source
area. The method for determining the depth to bedrock in borings and wells must be
standardized.
3. Obtain quarterly water level measurements on all wells identified in the area.
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August 13, 1993
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4. Develop adequate conceptual models of the hydrogeologic system, contaminant
distribution, contaminant transport pathways and controlling fate mechanisms.
This memorandum was developed by the following Technical Group:
John T. Burkart, R.G., REA - Cooper Environmental, Ramsay Motors, Inc.
Ivan A. Cooper, P.E. - Cooper Environmental, Ramsay Motors, Inc.
Stephen Dubyk - H*GCL, Inc., Texaco Caribbean, Inc.
• Donald P. Galya, P.E. - ENSR Consulting and Engineering, Western Auto, Inc.
Bruce K Green - Caribbean Hydro-Tech, Inc., Four Winds Plaza Partnership
Randall T. Hicks - H*GCL, Inc., Texaco Caribbean Inc.
David E. Langseth - Arthur D. Little, Inc., Andreas Gal & Paul Lazare
Kenneth L. Loy - International Technology Corporation, L/Henri, Inc.
Thomas F. Maquire, CPG - Blasland & Bouck Engineers, P.C., Esso, S.A
Belinda K Price, MS, RPG - International Technology Corporation, UHenri, Inc.
54153/RESPONS4.LTR
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