LAW OFFICES OF JOHN K. DEMA, RC,
JOHN K. DEMA
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11 November 1994
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Roy Adams, Commissioner
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Department of Planning and Natural Resources
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United States Virgin Islands
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Nisky Center
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Charlotte Amalie, St. Thomas 00801
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Andrew Praschak, Esquire
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Assistant Regional Counsel
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USEPA - Caribbean Field Office
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1413 Fernandez Juncos Avenue
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Santurce, Puerto Rico 00909
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Ms. Caroline Kwan
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Project Manager
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USEPA - Region II
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26 Federal Plaza, Room 737
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New York, New York 10278
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Re: 
Tutu Water Wells Site Investigation
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St. Thomas. United States Virgin Islands
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Dear Commissioner Adams, Attorney Praschak and Ms. Kwan:
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On November 1, 1994, I submitted a letter to you describing in detail my
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concerns with Geraghty & Miller's attempt in the Draft Phase II RI to exclude
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Esso from its responsibility for releasing chlorinated hydrocarbons into the
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Turpentine Run Aquifer. 
Historical site information is available that
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documents the fact that chlorinated hydrocarbons were used in profusion over
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the years at the Esso Tutu Service Station ("ETSS"). 
Any analyses that
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excludes, overlooks or otherwise distorts data in an investigation of sources
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and migration pathways of chlorinated volatile organic chemicals in the
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groundwater at the Tutu Wells Site is a disservice to the residents of the
United States Virgin Islands.
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Roy Adams, Commissioner 
11 November 1994
Andrew Praschak, Esquire 
Page 2
Ms. Caroline Kwan
Attached, please see the summary of my letter to you of November 1, 1994. I
have also included a few additional comments based on discussions at the
meeting held in St. Thomas on November 2-3, 1994. Please note the opinions
and data advanced by our experts, including Dr. David Keith Todd and Dr. Paul
Fahrenthold, which stand in direct opposition to the conclusions reached by
Geraghty & Miller.
Dr. David Keith Todd has published numerous works, including the textbook,
Groundwater Hydrology. His recent publication is as co-editor for Geraghty &
Miller's The Water Encyclopedia, which is advertised as "The Flagship
Publication of the New Geraghty & Miller Book Series."
Dr. Paul Fahrenthold, former Chief of the Organic Chemicals Branch of the
U.S. EPA, has over twenty-five years of experience in activities related to the
evaluation of groundwater contamination migration.
In summary, I believe that previous activities including soil/aquifer
characteristics provide indisputable evidence that Esso Tutu Service Station
contributed chlorinated VOCs to the groundwater. Ignoring its contribution is
a serious omission and error.
Very
K. Dema, Esquire
JKD/s
Attachments
cc: 
Four Winds Plaza Partnership
TUT 
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0637