I -d
N05IQ3
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
Preliminary Ao«rooam«nt and Confirmation v£ Authorization Of
;UBJECT\ CERCLA Removal Action Monies for the 
TUTU Well Site, Anna's
Retreat, Saint Thomas, U.S. Virgin islands - ACTION MEMORANDUM
FROM:
Carlos B. O'Neill /^L^ 
0^ „
*' *«— AjQs^^^if-i
TO: On-Scene Coordinator
Stephen D. Luftig, Director
Emergency and Remedial Response Division
?HRU: George H. Zachos, Acting Chief
•>-.• 
1 Prevention Branch
T 
MHARY
•"*', MC. Allan smitn
L . . 
. . 
anning and Natura
Virgin Islands, • rbally request*
Protection Agency (EPA) provide
sampling of one well which was 
-
unpleasant odor. This well is
prwiaea potaoie water supply 
?
Thorns*, 
The well is located 
. •
in t 
Tutu Section of Anna' 
Re-
was 
•V.-wed by an ad<
role of Lead Agency after
! £ 1 O -: 5
R e s o - r
. that t '•
i a I y t i c a
^c r te ~
*tC'.\i I-
• j r
of
! I £<
ional requ
r sampling-
were fou
'his verbs-
i by DPNR -•>
f c • SPA 
fco ass s •'
" -> ind i-: i ted 
'.
c o n t -UT> i n a t e d
.• -4 -j u e s t wa g f •" \ 1 o v .•*
-. August 10, 
'97
se-vera-l-ccnniirwn;iTrl
hazardous substances
formal request in *r
in July and A- 
if 1987. EPA cor.fi -.ed by si-pUno «
analysis, th 
.minat' 
if ground1'.' 
r wi. :h 
,-)ia'
organic c<i so, 
, 
A ma_j'"
r -ontaminan'- in the oroun
tetrachloroeth, lene (TC6-. 
Thi EPA 10-Da.. t,ealth A-
Level of 175 ppb was exceeded in three (3) of twcn
wells sampled, with two of the three contani nated •'
private r»Bidenti«l wells. 
The c one e n tr« ti cpne f .'
from 240 to 7. ''O ppb with a<>" 
: f ) a^dition^l .4 
• o i-
Island's inter-... maximum per:., st, *bl« ^ 
«-•: ration le 
'<
on September 1, 1987 
DPNR for 
le organice in d:
water in the Turpent 
Rur. Aquif- 
0 ppb for a single
povnd or 100 ppb for 
\! volati 
rgani- son pounds^ .
of the previously me 
ned sever 
la w*,? 
iid*ntial
w« 11 s .
H FORM 1349-1 O/M)
*64419*
64419
N05IQ3
-2-
This Action Memorandum will document funding authorized for
Phase I of the Tutu Well Site CERCLA Removal Action. 
Phase I
addresses only residences having contaminated drinking water
wells with volatile organic compounds above levels established
by the U.S.v.l.'s interim maximum permissible concentration
levels fur pocaoie water. rnis action aid not include wens
where water is used primarily for commercial, business,
industrial and/or trade purposes. It also did not include
wells contaminated solely by gasoline or gasoline by-products
which are not hazardous substances within the definition of
Section 101(14) of CERCLA. This action includes the decontam-
ination and cleaning of residential cisterns contaminated
by hazardous substances, the modification of plumbing/ the
delivery of water by tank trucks as a temporary alternate water
supply, and a well water monitoring program. 
The total project
ceiling authorized for a 52-week period is 5100,000 of which
$40,000 is estimated for mitigation contracting; $45,000 for
TAT's extramural coats; and $15,000 for BPA'S intramural ccits .
This memorandum will confirm your prior verbal authonzatio
of Trust Fund monies, issued to the Chief, incident Respons
• «-» n » « w « r » t i o « e « « * i » n • n O e » *>»"»»>« W 1, 1 9 O T , t» i n i t i a t e 0:,-=
removal action at the subject site, and subsequently revised
to the current project ceiling of $100,000.
II. 
BACKGROUND
A. 
Historical ^information
A request for EPA analytical support for on* veil in the Tutu
Section of St. Thomas was made verbally 
:: July 15, 1987 from
DPNR. On July 31, 1987, a verbal re'r.^st *°r EPA to assume
the role of Lead Agency was made, and this was followed by a
written confirmation of the request, dated August 10, 1987
(received by the Emergency and Remedial Response Division on
August 19, 1987). The initial request was based on a reporc
that one well was reported to have a strong odor, characteris-
tic of a petroleum product. 
This well is a major source of
commercially provided potable water for the eastern portion of
the island. EPA'S preliminary investigation commenced on July
21, 1987, witv a field reconnaissance and sampling of this one
well and six additional wells identified in the immediate area.
Several of these wells are also major water suppliers of public
drinking water to the eastern part of the island.
I'd 
G f : I I <L 8 / S3-- 10__________NOSIQ3
-3-
Laboratory results from this survey indicated that the initial
well was highly contaminated with gasoline and chlorinated
organics, and the additional six veils contained elevated
levels of chlorinated volatile organic compounds. 
Based on
these results, DPNR declared that an imminent health threat
existed, which could affect approximately 20,000 people living
in St. Thomas.
in addition, an indefinite number of tourists who vacation in
St. Thomas were at risk since these commercial wells supply
water to major hotels and restaurants. DPNR issued orders to
close these seven commercial wells to protect public health.
Subsequent to this action, EPA expanded their sampling plan
due to the threat of greater contamination to drinking water
wells in the area. 
EPA along with DPNR, identified other
wells within the Tutu Water/Turpentine Run Aquifer which may
be impacted by the hazardous substances identified to be pres-
ent in the groundwater. A second round of groundwater well
sampling took place on August 10 and 11, 1987, which included
a total of twenty-four (24) wells identified in the Tutu
Section of Anna's Retreat. All twenty—four wells were sampled
and analyzed for volatile organic compounds. 
Following these
results, DPNR closed the five private wells which service two
three-family homes and one apartment building housing twelve
studio uni ts.
B . si te Sotting/Deacription
The contaminated wells are located in the Tutu Section of
Anna's Retreat, St. Thomas, U.S. virgin islands. The five
'5) private wells recently ordered closed are located in the
Tutu residential area. At the present tiae, the affected
area is not serviced by any public water supply. EPA sampled
a total of twenty-four (24) wells in the Tutu area and found
five private wells and eight (3) commercial wells seriously
contaminated with up to 7,600 ppb of PCS. (See map attached).
C. 
Quantity and Type of Substance Present
EPA sampled and analyzed for suspected volatile organic com-
pounds on July 22 and August 10, 1987. Listed below are the
maximum concentrations of the hazardous substances identified
in the drinking water wellst
f f : I I L8/S2/ 1 0 
______MQ5IQ3
-4-
M^ximum 
statutory Source of
Concentration 
Hazardous substances
C o n t ajn i nan t 
Found (ppbj~ 
under CERCLA
Tetrachloroethylene 
7,600 
Clean water Act
Section 307(a)
Trichloroethylene 
61 
Clean Water Act
Section 307(a)
Benzene 
1,400 
Clean Water Act
Sec tion 307(a)
The results of .the sampling are contained in Tables I and II.
PCE contamination ranged from non-detectable to seven thousand-
six hundred parts per billion (7,600 ppb). 
Sampling results
adequately document 3 wells with contamination above EPA's 175
ppb PCE 10-Day Health Advisory Level and eight (8) wells above
the DPNR's interim standards for maximum contaminant levels of
volatile organic compounds in drinking water.
III. THREAT
A. 
Threat of Public Exposure
Direct contact with PCE may cause eye and ;. -• '••••' ".ati an
along with dry scaly and fissured dermatitis. 
Ac u 
exi.'S ; .
through absorption, inhalation or ingestion, may cause ce-<- 
T
nervous system depression, hepatic injury and anesthetic death,
has been found to be carcinogenic.
This is a case of actual contamination in excess of the EPA
175 ppb PCE 10-Day Health Advisory Level for a three-family
house and one apartment building housing twelve studio units.
In the other three family apartment dwellings, the well con-
tamination exceeded the interim DPNR drinking water standard
of 50 ppb for any single volatile organic constituent. in
addition to the exposure via consumption of the water, or
eating food prepared with this water, showering with water
contaminated with volatile organics can contaminate the air to
significantly unhealthy levels.
Sf : I I LJ8/S2-' 10__________NQ51Q3 bd3
-5-
The location, direction and dimensions of the plane are af-
fected by variations in water table depth, rate of pumping
of the wells, duration and intensity of rainfall, and inter-
mittent releases of chemical* from one or more sources, all
of which are unknown at this time. Given the above variables
which affect contaminant strengths in any w«ll within th«
plume may vary randomly.
On September 2, 1987, DPNR issued three (3) orders to close
wells and issued two (2) advisory letters to homeowners not to
use w«ll water for drinking, bathing and washing.
B. 
Evidence of Extent of Release
' iveatigation, sampling and analyses by EPA have identified
contaminated g.-oundwater, as described above, and containing
contaminates, as described in Tables I and II.
C. 
Previous 
ctionB to Abate Threat
>'-> mitigative action was taken by any Potentially Responsible
Pii'ty prior to EPA's recent activities.
D. 
Current Actions to Abate Threat
EPA has commenced an investigation of the Tutu Water/Turpentine
Run Aquifer by establishing a cooperative agreenent with the
U.S. Geologic Survey to define the characteristics of this
aquifer and to determine the extent of contamination. 
EPA and
DPNR have also completed Aquifer and a monthly well monitoring
Program is being developed.
DPNR has issued a »:otal of ten (10) orders/advisories to well
owners to close sixteen (16) wells.
A local dry-cleaner has been Identified as using and storing
PCE. Handling, storage an3 disposal practices from this
facility are unknown at this time. DPNR has proposed to issue
an advisory to local dry cleaning «stablishments instructing
them to properly store and hold all waste for proper disposal
by an industrial waste hauler. DPNR with the assistance of EPA
is conducting an assessment of at least nine (9) facilities
identified to be potential sources of hazardous waste and/or
substance releases in the Tutu area.
St7 : I I <L8-'£5' JO__________N05IQ3 bd3
-6-
EPA has cleaned the homeowner's cisterns that have been contam-
inated by hazardous substances from the groundwater, modified
the existing home plumbing to terminate well connections, and
intends to continue to deliver clean water via tank truck* on a
regular basis, and establish a surveillance program for all
wells in the area by a monthly groundwater monitoring program.
This Phase I, short-term removal action will mitigate the threat
to public health by providing a temporary alternate source of
water for affected consumers.
IV. 
ENFORCEMENT
The contaminant plume is generally believed by both DPNR and
EPA, to have its source from past and present improper handling
and disposal practices of organic solvents, possibly from dry
cleaners aid auto repair shops operating in the area. This site
hag been referred to the site compliance Branch for enforcement
a c t i o - . 
t- .^r-jrney and enforcement project officer have been
a s s i - r - 
.is case. 
E^A issued Request for information
letter. 
. Potentially Responsible Parties.
V 
. j-_'__ -D PROJECT
A . 
"!b j ec_t '. 
j^f_ 
e phase I Removal Action
-ri.-i. 
bjective of the Phase I of the removal action is
the <iiti'-a 
r. ->£ the threat to public health by providing a
•afe potabl 
wither supply to the affected residences.
TWO three-family homes and one apartment complex housing
twelve studio units were identified as being dependent on
groundwater from their own private wells. Their respective
wf 1 IB were ordered closed-down by DPNR for exceeding interim
drinking water standards.
TO reach the objective of providing a safe interim drinking
water supply and protect the health of the public at risk, the
following removal action was initiated, water storage cisterns,
which received contam 
^ted groundwater from affected wells,
were cleaned and sanitized. Cisterns were filled with clean,
safe, drinking water. 
Water tank trucks from local water haul-
ers will be providina water for the affected cisterns on a reg-
ular basis. 
Plumbing modification was made to disconnect water
lines from the contaminated wells which provide groundwater to
the cisterns.
• d 
9 f •• I 1 i 8 <" S3/MQ_______ 
N Q S I Q 3 bd3 
UQdd
-7-
An attempt to connect well water directly to toilets for flush-
ing will be made, if physically and economically feasible.
A well surveillance program will be implemented involving all
the wells-i-n-the Turpentine Run Aquifer, thru monthly sampling
and monitoring.
The longer term, phase n objective will require the provision
of a permanent alternate water supply in lieu of the temporary
trucking of water to the threatened consumers within the plume
area. Upon completion of an analysis of the alternatives for
permanent water supply to these residences, a recommendation
will be made for phase II.
B. 
project Estimated Costs
water consumption per person per day on the average is thirty
(30) gallons. it is estimated that the one apartment building
has twelve studio units with the average of two people per unit.
The two other private homes are three-family dwellings with the
average of ten people in each. The cisterns in the three family
houses are small and, therefore, a supply of water- nast—b«—deliv-
ered every two or three weeks, respectively. The delivery period
is currently estimated to be one year or when a permanent alter-
c - *-- -—"<<«»<t. whichever occurs first.
I 'd IWiOl 
I 'd 
53:21 i8/S3/IO 
NOSIQ3 «d3 WOBd
-8-
Extr«mur«l TAT Cost
TAT Monitoring and sampling program
(including travel and per diem I................. $35,000
TAT Technical and administrative
support (including travel and per diem )......... $10, OOP
Total TAT Coat 
$45,000
Intramural EPA Cost
(Including -tavel and per diem ).................. $15 / 000
ESTIMATED TOTAL PROJECT COST. .........$ 100 , 000
T'.' 
.gure represents the estimated total for Phase I. 
It
be reduced significantly, if a reliable and permanent
iate water oupply is found sooner than the proposed
jeka delivery period) might be increased, depending upon
the identification of new drinfcing water wells found to be
contaminated with hazardous substances within the affected
area.
C. 
P r o j act s c h e d u 1 e
project initiation of cistern clean-up and safe wat*r d .-: •
livery has already been implemented baaed on verbal fundi/;:
authorization. Safe water delivery period is currently
estimated not to exceed one year or when a permanent alternate
water supply can be provided, whichever occurs first.
V. RECOMMENDATIONS
Conditions at the Tutu Well Site meet the requirements of
Section 300.65 of the National Contingency Plan (NCP) for «
CRRCLA/SARA removal action. 
EPA has determined that there ia
• threat to public health at the site (section 300 . 65 (b ) ( 1 ) ,
This determination was based on t
1) Human exposure to unaceeptably high levels of acutely
toxic substances (Section 300 . 65 ( b ) ( 2 ) ( i ) , and
2) Contamination of drinking water supply (Section 300.^5
(b)(2) (ii).
5 'd
I 0
NOS1Q3
-9-
The resident population at risk currently relies on
well water as their source of potable water.
private
This removal action complies with section I04(b)(2) of CERCLA,
as amended by SARA, in that it is consistent with the efficient
performance of long-term remedial measures, by providing an
interim supply of potable water to the public until a permanent
water supply can be secured.
This is a written confirmation of the initial and revised verbal
approval of up to $100,000 for the total project ceiling estab-
lished on September 1, 1987, by the Director of the Emergency
and Remedial Response Division to the OSC for the CERCLA renoval
action at the Tutu Well Site, The mitigation contracting ceil-
ing is estimated at $40,000, with an additional $45,000 for TAT
costs, and SIS,000 for EPA costs.
Your authority to authorize these funds is pursuant to Deputy
Administrator Alvin Aim's memorandum of Delegation Number 14-lA
dated April 15, 1984, and Richard Dewling'e Redelegation Order
R-ll-1200.6 of August 29, 1984.
/} L-^
I) Lf-
APPROVAL:
DATE:
DISAPPROVAL!
DATS:
cc: 
(after approval is obtained)
C. Daggett, 2RA
R. Salkie, 2ERR-DD
S. Luftig, 
2ERR
G. Zachos, 2ERR-RP
B. Sprague, 2ERR-RP
J. Csapor, 2ERRD-SC
G. Pavlou, 2ERRD-NYCRA
J. Marshall, 20EP
P. Gelabert, 2CFO
R. Gherardi, 20PM-FIN
T. Sullivan, PM-214F (EXPRESS MAIL)
T. Fields, WH-548B
P. McKechnie, 2IG
1JT
I 
'd 
,11:21
N05IQ3 Wd3 WOdd
'-_ 1
N*U tiWuiNt RESULTS
TUTU VEIL SZTI
IT. THOMAS, U.S. VIRGIN ISLANDS
SAMPLE
LOCATION
4 VXVOS 11
IGLXV VELL 01
IGLXV VILl 02
KLIN VELL 13
KAXTHKAtf IAKIRT
HARTHKAV CRUSH
HAfiTXKAN S9TATI
RODRICWM AUTO
BRTAV
ALPHA, LEONARD
SMITH, tOCITA
OEYCOH 03
DIYCOV 01
DEPI
DINITRI
VIHA VILl 13
VI HA VIU 01
RAK5CT
STE1L
HARVET
MATHIAS
FRANCOIS
OMCH
TILLIT
T1LLZT DUP
FIELD OLAVX
SAMPLS
VUMBER
•••*•»
Q01A
001A
00 3A
00 4A
OOftA
00(A
007A
OOVA
009A
010A
011A
01ZA
013A
014A
020A
021A
022A
OJOA
031A
033A
033A
034A
036 A
03CA
037A
04QA
DATE 
OATI
SAMPLED AVALXSEO 001
H/10/07 00/11/17 CV
00/10/07 00/13/07 CO
00/10/07 00/13/07 CV
00/10/07 00/13/07 CV
00/10/07 00/13/07 IV
00/10/07 00/13/07 IV
00/10/07 00/13/07 PV
01/10/07 00/13/07 IV
00/10/07 00/13/07 CV
00/10/07 00/13/07 PV
ol/l?/l? il/ii/l? 8
01/10/07 00/13/07 CV
00/10/07 00/13/07 VA
00/10/07 00/13/07 CV
00/10/07 00/13/07 IV
01/10/07 00/13/0? IV
91/10/07 00/13/0? IV
Ot/10/07 00/13/0? PV
00/10/07 00/13/0? PV
00/10/07 00/13/0? PV
00/10/0? 00/13/07 PV
00/10/0? 00/13/07 PV
00/10/07 00/13/07 CV
00/10/07 00/13/07 CV
00/10/07 00/13/0? VA
mmm mmm mmm ••• •«••
1300
1400
0
21 
72
11 
30
13 
43
If 
f?
3
30
1
1
0
1
1 
110
0
0
0t
0
10
7
20 270
01 7000
4 
CO
20 120
0 
0
0 240
31 130
0 
0
00
33
0
213 .f
13 .T
74 .T
Cl .T
1 .t
12 .T
0 .T
0 ,f
o ,r
0 .T
•1 .9
0 .f
0 .T
0 .f
0 ,T
7 ,?
12 .T
1 *T
Cl .f
10 ,f
t .1
140 .f
0 ,T
070 .f
120 .?
0 .f
TABU II
TUT 
O02 
O686
f 'd
-' 10
N U S l U d
Or/28/17
3 »:-<?:,*
LOCATION
•*»•••••
JHOTOVAC SAMPLING MSVLTS
TUTU VEIL flTC
ST. THOMAS, U.I. VIRCXN ISLANDS
DATl 
tATI
SAMPLED 
ANALniD SOURCE UK 
TC1 
Kf 
TOL OCt OCN8
HARTKHAH CSUS- T-473 07/JJ/I7 07/50/17 IK
MARTHHAN ftAKtftY l?-474 07/22/17 07/10/17 IV
' VINDS KELlfi 
17.475 07/22/17 07/30/17 Ctf
VIMOS VCO41 t?-474 07/22/17 07/30/17 CH
TILLIT 
17-477 07/22/17 07/30/17 CU
,iH* 
I7-47S 07/32/17 07/JO/I7 IH
KUN 
I7-47J 07/22/S7 07/30/17 0*
TILUT 
17-410 07/tt/l? 07/30/17 Ol
07/32/17 07/30/17 HA
0
0
7
7
7 103
0 
)
It 
14
It 
€1
*33 
Ift 
200
15
1
t 
34
11 
It
10-
4
41
1
3
I 32'
1 
1
.T.
,T,
.T.
,1,
.».
,T,
.T.
1 .t.
» .T.
TABLB I
\
TUT 
002 
0687