UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
A
I
DATE: 
UU ! 27 
l994
cUBJECT.RCRA Review of Draft Remedial Investigation (RI) for Tutu Wells
Site, Virgin Islands
FROM: Andrew Bellina, P . E
Chief, Hazardous Wa"ste Facilities Branch (2AWM-HWF)
'Carole Petersen, Chief
New York/Caribbean Superfund Branch II (2ERRD-NYCA-II)
The Tutu Wells were historically used as a potable water supply
source. Through the presence of UST's located at several service
stations, auto recycling operations, and dry cleaning
establishments, the ground water has become contaminated with
BTEX and chlorinated solvent compounds located in a plume
approximately 108 acres in size. Chlorinated VOC's and BTEX
compounds exceed EPA maximum contaminant levels in the ground
water. An information request letter was sent to several
possible sources of contamination under Section 104 of CERCLA and
3007 of RCRA. A subsequent Administrative Order (AO) issued by
EPA required ground water monitoring and placement of residents
affected by contamination on a public water source. RCRA
comments include the following:
1) Where RCRA waste or hazardous constituents contribute to
contamination of the aquifer, RCRA standards specify source
control and treatment of the ground water and other media to
-- 
below health based levels.
2) Any waste that is found to be RCRA hazardous during any
subsequent remediation activities, must be managed in accordance
with RCRA standards.
3) Since it appears that sources of RCRA waste constituents in
the ground water are small business operators, an education or
outreach program is appropriate to notify these sources of the
proper handling and disposal of hazardous waste.
REGION II FORM 132O-1 (0/86)
TUT 
006 
0964
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