TWO THOUSAND WESTCHESTER AVENUE
WHITE PLAINS. N. Y. 1O65O
March 12, 1996
Caroline Kwan
Remedial Project Manager
U.S. Environmental Protection Agency
290 Broadway, 20th Floor
New York, NY 10007-1866
RE: Tutu Wellfield HPL Site
Revised Superfund Proposed Plan
Dear Ms. Kwan:
These brief comments regarding the above-referenced draft document
are submitted on behalf of Texaco Caribbean Inc. (TCI). TCI has
been identified by the Environmental Protection Agency (EPA) as a
potentially responsible party (PRP) at the Tutu Wellfield site.
1. 
It is unclear from the legend and map in Figure 1 which
portions of the plumes indicated represent Chlorinated VOCs >100
ppb.
2. On page 8, right column, we believe that following should be
added to the soil objectives in the section titled "Remedial Action
Objectives"
Removal of contaminants of concern in-situ, where practicable.
3. On page 9, left column, we believe that the following language
should be added after the first paragraph in the section titled
Soil Remedial Alternatives (SRA) for Impacted Soil":
These SCPs can be implemented as early as Spring 1996.
As we have discussed, Texaco has designed and is prepared to
implement a remedial system to fulfill the SCP objectives
articulated in the Proposed Plan.
4. On page 9, right column, we believe that the language in the
third bullet in SRA l overstates the objective and should be
reworded to say that soil or rock from impacted areas should not be
removed unless it is appropriately tested and then, if indicated,
properly treated or disposed of.
5. On page 10, right column, we believe that the language in the
first full paragraph after the bullets related to SRA 3 should be
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modified to state that: "The SVE systems described would be
operational until VOCs are present in the extraction weULair vapor
stream at acceptable levels."
6. On page 12, left column/ we believe that the following language
should be added after the first paragraph in the section titled
Groundwater Remedial Alternatives (GRA) for Impacted Groundwater11:
These SCPs can be implemented as early as Spring 1996.
Again, as we have discussed, Texaco has designed and is prepared to
implement a remedial system to fulfill the SCP objectives
articulated in the Proposed Plan.
7. 
Regarding GRAs 2-4, we believe that EPA has previously
indicated that connection to the WAPA system is a possible
component of the alternatives. If this is the case, it should be
indicated in the title and text of the alternative descriptions.
Thank you for this opportunity to comment on the Proposed Plan
document. Feel free to contact me at 914-253-4633 to discuss these
comments.
Sincerely,
fe>
Timothy R. Knutson
Counsel for Texaco Caribbean Inc.