Site: 
Site Name: 
Site Location: 
HRS Score: 
Date Listed on the NPL: 
RECORD OF DECISION FACT SHEET 
EPA REGION II 
Virgin Island Chemical Superfund Site 
St. Croix, U.S. Virgin Island 
50.00 
June 17, 1996 
SDMS Document 
81207 
Record of Decision: 
Date Signed: 
Selected Remedy: 
The major components ofthe Selected Remedy are as follows: 
1. 
Treatment of contaminated soils and groundwater in the Above-groimd Storage 
Tank (AST) Area using Soil Vapor Extraction and Air Sparging (SVE/AS) 
2. 
Monitored Natural Attenuation (MNA) of contaminated groundwater in the 
Former Process Pit (FPP) Area. 
3. 
Institutional controls to restrict land and groundwater use at the Site until the 
remedial action objectives are met. 
In addition, groundwater extraction and treatment has been retained as a contingency 
remedy for the AST and FPP Area, which would be implemented in the event that SVE 
and MNA is subsequently determined after implementation to not be adequately 
protective or reasonably effective. 
500005 
Estimated Date 
of Construction Completion: September 2002 
Incurred Capital Cost: 
Additional Capital Cost 
Present Worth O&M Cost 
for SVE/AS Treatment: 
Present Worth O&M Cost 
for MNA and Long-term 
Monitoring: 
Total Present Worth Cost: 
Lead; 
Lead Agency: 
Primary Contact: 
Secondary Contact: 
Main PRPs: 
Waste: 
Waste Type: 
Waste Origin: 
Estimated Waste Quantity: 
Contaminated Media: 
$565,000 
$285,760 
$84,000 
$469,500 
$1,404,260 
U.S. Environmental Protection Agency, Region II 
Emergency and Remedial Response Branch 
Caroline Kwan, RPM 
(212)637-4275 
Melvin Hauptman, Leader - Sediments/Carribean Team 
(212)637-3952 
Pharmacia, Berlex Laboratories 
Volatile organic compounds - (i.e., mainly ethylbenzene, xylene, 
chloroform) 
Pharmaceutical manufacturing and blending operations 
8,700 cubic yards of contaminated soils, 980,000 gallons of 
contaminated groundwater 
Subsurface soils, groundwater 
5 0 0 0 0 6 
RECORD OF DECISION 
VIRGIN ISLAND CHEMICAL SUPERFUND SITE 
ST. CROIX, U.S. VIRGIN ISLANDS 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 
REGION II 
NEW YORK, NEW YORK 
500007 
DECLARATION FOR THE RECORD OF DECISION 
SITE NAME AND LOCATION 
Virgin Island Chemical Superfiind Site 
Estate Bethlehem Middle Works 
St. Croix, U.S. Virgin Islands 
CERCLIS ID No. VID980651095 
STATEMENT OF BASIS AND PURPOSE 
This decision document presents the U.S. Environmental Protection Agency's (EPA's) Selected 
Remedy for the Virgin Island Chemical Superfiind Site ("the Site"), located in Estate Bethlehem 
Middle Works in the south-central portion of St. Croix in the U.S. Virgin Islands, which was 
chosen in accordance with the requirements ofthe Comprehensive Environmental Response, 
Compensation, and Liability Act (CERCLA), 42 U.S.C. Sections 9601-9675, as amended, and to 
the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan 
(NCP), 40 CFR Part 300. This decision document explains the factual and legal basis for 
selecting the remedy for the Site. The information supporting this remedial action decision is 
contained in the administrative record for the Site. The administrative record index is attached 
(see Appendix D). 
The Virgin Islands Department of Planning and Natural Resources (VIDPNR) has been consulted 
and concurs with the Selected Remedy (see Appendix E). 
ASSESSMENT OF THE SITE 
The response action selected in this Record of Decision (ROD) is necessary to protect public 
health or welfare or the environment from actual or threatened releases of pollutants or 
contaminants fi-om the Site which may present an imminent and substantial endangerment to 
public health or welfare or the envirorunent. 
DESCRIPTION OF THE SELECTED REMEDY 
The remedy selected is the only operable unit for the Site. 
EPA's Selected Remedy for the Site includes soil vapor extraction/air sparging (SVE/AS), 
monitored natural attenuation (MNA), and institutional controls. The Selected Remedy was 
presented in the Final Feasibility Study Report (FS) and is described in further detail below. The 
FS evaluated and screened remedial altematives for contaminated soil and groundwater at the 
Site. The FS used a comparative analysis to evaluate five altematives and identify the advantages 
and disadvantages of each. EPA selected the remedy for the Site based upon the results ofthe FS. 
The Selected Remedy for contaminated soil and groundwater includes the following features: 
500008 
Use and expansion ofthe existing SVE/AS system to treat contaminated groimdwater, 
saturated soil, and unsaturated soil at the Abovegroimd Storage Tank (AST) source area; 
• 
Use of MNA to address low-level residual contamination in groundwater at the Former 
Process Pit (FPP) area and downgradient areas; and 
The Department of Planning and Natural Resources in consultation with EPA, will utilize 
institutional controls (in the form of existing well permitting laws and regulations) to limit 
the pumping of groundwater at the Site to prevent interference with the selected remedy 
and to also prevent human exposure to contaminated groundwater until MCLs are 
achieved. 
The Selected Remedy is protective of human health and the environment through the following: 
1. 
Active source control and contaminant mass removal will occur at the AST area via use of 
an SVE/AS system to remove ethylbenzene and xylene fi-om the source area soils and 
from groundwater to achieve soil SSLs and groundwater MCLs. AS treatment will also 
enhance conditions for aerobic biodegradation ofthese contaminants. 
2. 
Natural attenuation of low-level residual volatile organic compotmd (VOC) 
contamination, mainly chloroform, in groimdwater will continue in the FPP area under 
closely monitored conditions until groundwater MCLs are achieved. 
3. 
The Department of Planning and Natural Resources will utilize institutional controls (in 
the form of existing well permitting laws) to limit the pumping of groundwater at the Site 
to prevent interference with the selected remedy and to also prevent human exposure to 
contaminated groundwater until MCLs are achieved. 
In addition to the Selected Remedy, EPA has retained groundwater extraction and treatment as a 
contingency remedy for the groundwater in the AST and FPP areas. This contingency remedy 
will be implemented in the event that analyses of groundwater monitoring data indicate that; 1) 
the groundwater plume exceeding MCLs is migrating downgradient and could potentially move 
beyond the Island Chemical property boundary line or 2) MCLs will not be achieved anywhere in 
the aquifer within a time frame that is reasonable compared to that offered by the contingency 
remedy. 
The decision to implement the contingency remedy will be made by EPA, in its sole discretion, 
according to criteria specified iii Section 11.3 ofthe ROD. 
5 0 0 0 0 9 
STATUTORY DETERMINATIONS 
The Selected Remedy attains the mandates of CERCLA Section 121 and, to the extent practical, 
the NCP. Specifically, the Selected Remedy is protective of human health and the environment, 
complies with federal and territorial requirements that are applicable or relevant and appropriate 
to the remedial action, is cost-effective, and utilizes permanent solutions and altemative treatment 
technologies to the maximum extent practicable. 
This remedy also satisfies the statutory preference for treatment as a principal element ofthe 
remedy (i.e., reduces the toxicity, mobility, or volume of hazardous substances, pollutants, or 
contaminants as a principal element through treatment). 
Because this remedy may result in hazardous substances, pollutants, or contaminants remaining 
on-Site above levels that allow for unlimited use and unrestricted exposure for approximately 5 
years, a review will be conducted no less often than once every five years after initiation of 
remedial action to ensure that the remedy is, or will be, protective of human health and the 
environment. 
ROD DATA CERTIFICATION CHECKLIST 
The following information is included in the Decision Summary section of this ROD. Additional 
information can be found in the Administrative Record file for this Site. 
• 
Chemicals of concem (COCs) and their respective concentrations. 
• 
Baseline risk represented by the COCs. 
• 
Cleanup levels established for COCs and the basis for these levels. 
• 
Techniques for addressing source materials that constitute principal threats. 
• 
Current and reasonably anticipated future land use assumptions and current and potential 
fiiture beneficial uses of ground water used in the baseline risk assessment and ROD. 
• 
Potential land and ground-water use that will be available at the Site as a result ofthe 
Selected Remedy. 
• 
Estimated capital, armual operation and maintenance, and total present worth costs, 
discount rate, and the number of years over which the remedy cost estimates are projected. 
• 
Key factors that led to selecting the remedy. 
|Y\ 
Kenny 
/ ] 
Date 
al Administrator 
nvironmental Protection Agency, Region II 
u 
O-Z. 
500010 
RECORD OF DECISION 
DECISION SUMMARY 
VIRGIN ISLAND CHEMICAL SUPERFUND SITE 
ST. CROIX, U.S. VIRGIN ISLANDS 
5 0 0 0 1 1 
TABLE OF CONTENTS 
Section 
Page 
1.0 INTRODUCTION 
1 
1.1 
Site Name, Location, and Description 
1 
1.2 
Site History and Removal Action 
1 
2.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION 
3 
3.0 SCOPE AND ROLE OF ACTION 
5 
4.0 SUMMARY OF SITE CHARACTERISTICS 
5 
4.1 
Geology and Hydrogeology 
6 
4.2 
Soil 
7 
4.3 
Groundwater 
8 
4.4 
Gut System 
8 
4.5 
Fate and Transport 
9 
5.0 CURRENT AND POTENTIAL FUTURE LAND USE 
9 
5.1 
Current Land Use 
9 
5.2 
Future Land Use 
9 
6.0 SUMMARY OF SITE RISKS 
10 
6.1 
Human Health Risk 
10 
6.2 
Environmental Concems 
11 
7.0 REMEDIAL ACTION OBJECTIVES 
12 
8.0 DESCRIPTION OF ALTERNATIVES 
13 
8.1 
Altemative 1: No Further Action 
14 
8.2 
Altemative 2: MNA with Institutional Controls 
14 
8.3 
Altemative 3: SVE/AS for the AST Area, MNA for the FPP Area, and 
Institutional Controls 
15 
8.4 
Altemative 4: SVE/AS for the AST Area, Groundwater Extraction and Treatment 
For the FPP Area, and Institutional Controls 
15 
8.5 
Altemative 5: Groundwater Extraction and Treatment for the AST Area, MNA for 
the FPP Area, and Institutional Controls 
16 
5 0 0 0 1 2 
TABLE OF CONTENTS 
Section 
Page 
9.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 
17 
9.1 
NCP Evaluation and Comparison Criteria 
17 
9.2 
Evaluation of the Altematives Against the NCP Criteria 
18 
10.0 PRINCIPLE THREAT WASTES 
21 
11.0 SUMMARY OF THE SELECTED REMEDY 
22 
11.1 
Rationale for Selected Remedy 
22 
11.2 
Description ofthe Selected Remedy 
; 
23 
11.3 
Description of Contingency Remedy 
25 
12.0 STATUTORY DETERMINATIONS 
25 
12.1 
Protection of Human Health and the Environment 
25 
12.2 
Comphance with ARARs 
26 
12.3 
Cost Effectiveness 
26 
12.4 
Utilization of Permanent Solutions and Altemative Treatment Technologies 
(or Resource Recovery Technologies) to the Maximum Extent Practicable . . . 26 
12.5 
Preference for Treatment as a Principle Element 
27 
12.6 
Five-Year Review Requirements 
27 
13.0 DOCUMENTATION OF SIGNIFICANT CHANGES 
27 
APPENDICES 
A 
Figures 
B 
Tables 
C 
Responsiveness Summary 
D 
Administrative Record Index 
E 
VIDPNR Letter of Concurrence 
500013 
LO INTRODUCTION 
Ll 
Site Name, Location, and Description 
The Virgin Island Chemical Superfiind Site ("the Site") includes a former chemical facihty and 
properties located at Plot 13Q (approximately 3.5 acres) of Estate Bethlehem Middle Works in the 
south-central portion of St. Croix in the U.S. Virgin Islands (see Figure 1). Site access is via 
Route 66, which traverses the island east and west and abuts the south-southwest boundary ofthe 
Site. Plot 13Q is bordered to the north and east by an intermittent stream, the River Gut, which 
originates north ofthe Site and drains to the Caribbean Sea. The River Gut joins the Bethlehem 
Gut approximately 800 feet southeast ofthe Site. They are collectively then called the Fairplain 
Gut. The groundwater underlying the Site flows predominantly to the south-southeast. 
Land use surrounding the Site is mostly industrial and commercial. A water service company and 
an undeveloped lot exist immediately to the west and northwest ofthe Site. A concrete batch 
plant and two automobile repair shops are located east-northeast ofthe Site, on the opposite side 
ofthe River Gut. Two paving companies are located north-northwest ofthe Site across the River 
Gut. The Henry Rohlsen Airport (formerly known as the Alexander Hamilton Airport) is situated 
about 1,500 feet south ofthe Site and a prison lies 0.25 mile to the northwest. Two residential 
properties are located about 0.33 mile north and 0.75 mile northwest ofthe Site. 
Plot 13Q is owned by CHS Holding Corporation and is currently unoccupied and overgrown with 
heavy vegetation. A chain-link fence was installed in Spring 2000 along the property line to 
secure the area from unauthorized access. 
Over half of the property was covered by buildings and/or process equipment from past 
pharmaceutical manufacturing and blending operations. Certain ofthe potentially responsible 
parties demolished the buildings in the Spring of 2002. There are no remaining stmctures except 
a concrete pad that housed the buildings. 
Two storm drains are located on-Site. The Central Storm Drain runs beneath the paved area 
between the former laboratory and maintenance buildings. The Southem Storm Drain, where 
observed, is a concrete-lined depression along the southem wall ofthe former maintenance 
building and the edge ofthe reactor area. Both storm drains discharge to the River Gut. 
L2 
Site History and Removal Action 
From 1968 to 1982, the Site was used for a variety of pharmaceutical manufacturing and blending 
operations under a number of different corporate entities. In general, toluene, pyridine, and 
quinidine (chemicals used by many ofthe occupants) have been historically spilled or otherwise 
released in significant volumes at the Site. 
In October 1982, EPA was notified ofthe facility's impending closure and off-Site removal of 
waste materials. Between 1984 and 1991, several investigations were conducted at the Site by 
EPA and a former tenant. Island Chemical Company, which was later acquired by Berlex 
Page -1-
500014 
Laboratories Inc. (Berlex). This investigative work identified six areas of potential environmental 
concem (see Figure 2): 
(1) 
Laboratory and Warehouse Building 
(2) 
Aboveground Storage Tank (AST) Area 
(3) 
Former Process Pit (FPP) Area 
(4) 
Loading Dock/Former Laboratory Pit Area 
(5) 
Soil Beneath Concrete Pad Near ASTs (northem comer ofthe Site), and 
(6) 
Concrete Storage Pad (north ofthe laboratory and warehouse buildings). 
During the initial assessment stages ofthe Site by regulatory agencies, both EPA and Berlex 
conducted several response activities. These activities included soil excavation with on-Site 
treatment (e.g., drying trays) or off-Site disposal, dmm removals, and off-Site disposal of AST 
contents. 
Between September 1989 and October 1991, EPA conducted a removal action at the Site. At that 
time, the laboratory/warehouse building was found to contain approximately 400 drums (some 
extremely deteriorated), leaking cylinders ofchlorine and hydrogen chloride, and over 800 
containers of laboratory reagents that included sodium metal, potassium cyanide, and ethyl ether. 
EPA removed 354 drums containing 14,720 gallons of various chemicals and 8,061 pounds of lab 
pack chemicals from the laboratory/warehouse building. 
On June 17, 1996, the Site was placed on the National Priorities List. On September 29,1994, 
EPA entered into an Adminisfrative Order on Consent (AOC), Index No. II CERCLA-94-0401, 
with Berlex and Island Chemical Company. Pierrel S.p.A, a subsidiary of Pharmacia Corporation 
and also a former tenant at the Site, was added as a Respondent to this AOC in April 1999. The 
AOC required the performance of a Remedial Investigation and Feasibility Study (RI/FS) at the 
Site. 
The primary objectives ofthe RI were to: I) collect the data needed to characterize the nature and 
extent of contamination and adequately support human health and ecological baseline risk 
assessments and 2) provide a basis on which a subsequent, cost-effective, remedial action plan 
would be recommended. The following specific data requirements were addressed: 
• 
Background concentrations of inorganic contaminants in surface soil through sampling 
and analysis; 
• 
Nature and extent of potential surface and subsurface soil impacts on the Site through 
sampling and analysis; 
• 
Nature and extent of potential groundwater impacts through monitoring well installation 
and sampling and analysis; 
• 
Site-specific geologic and hydrogeologic conditions through lithologic evaluation, water 
level measurements, etc.; and 
Page -2-
5 0 0 0 1 5 
• 
Nature and extent of potential soil/sediment contamination in the Gut System (i.e., River, 
Bethlehem, and Fairplain Guts) through sampling and analysis. 
All six areas of potential concem were investigated during the initial assessment and the 
subsequent RI. Based on the data collected, only the AST and FPP areas were determined to 
require remediation. 
2.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION 
Public participation in the remedy selection process is required by CERCLA Sections 113 and . 
117, 42 U.S.C. Sections 9613 and 9617, and 40 CFR Section 300.430(f)(3) ofthe NCP. These 
sections require that, before adoption of any plan for remedial action to be imdertaken by EPA, 
the State, or an individual (e.g., potentially responsible party), the lead agency shall: 
1. 
Publish a notice and make the Proposed Plan available to the public, and 
2. 
Provide a reasonable opportunity for submission of written and oral comments and an 
opportunity for a public meeting at or near the Site regarding the Proposed Plan and any 
proposed findings relating to cleanup standards. The lead agency shall keep a franscript of 
the meeting and make such transcript available to the public. The information made 
available to the public under item 1, above, shall provide a reasonable explanation ofthe 
Proposed Plan and altemative proposals considered. 
Additionally, notice ofthe final remedial action plan set forth in the ROD must be published, and 
the plan must be made available to the public before commencing any remedial action. Such a 
final plan must be accompanied by a discussion of any significant changes to the preferred 
remedy presented in the Proposed Plan along with the reasons for the changes. A response 
(Responsiveness Summary) to each ofthe significant comments, criticisms, and new data 
submitted in written or oral presentations during the public comment period must be included 
with the ROD. 
A summary of community involvement activities at the Site follows: 
November 1994 - EPA visited the Site and spoke to representatives or owners ofthe businesses 
and restaurants adjacent to the Site about upcoming sampling activities. 
January 1995 - EPA delivered a fact sheet door-to-door to affected businesses and nearby 
residents. The fact sheet explained the nature ofthe contamination and the need for the RI. 
February 15,1995 - EPA held a public meeting at the Department of Education Curriculum 
Center to present the RI work plan and to answer questions from the community. 
Page-3-
5 0 0 0 1 6 
August 1995 - EPA completed a Community Relations Plan for the Site, which documented 
community concems expressed during the November 1994 visits and the Febmary 1995 pubic 
meeting. 
September 1997 - EPA prepared and distributed another fact sheet describing completed and 
ongoing remedial investigation activities. 
June 27,2001 - EPA released the RI and FS reports and the Proposed Plan for pubhc comment. 
These documents were made available to the public in the EPA Docket Room in Region II, New 
York and the information repository at the University ofthe Virgin Islands, St. Croix Campus 
Library, Kingshill, St. Croix. A notice announcing the public comment period and a public 
meeting, along with the availability ofthe RI and FS reports and Proposed Plan, was published on 
June 27, 2001. The public comment period originally was scheduled from June 27 through July 
27, 2001. In response to public request for additional time, EPA extended the pubhc comment 
period an additional 15 days to August 11, 2001. 
July 12,2001 - EPA and VIDPNR hosted a public meeting to present the conclusions ofthe 
RI/FS, fiirther elaborate on the reasons for recommending the Preferred Altemative, and to receive 
public comments. The meeting was held at 7:00 p.m. at the Department of Education Curriculum 
Center on Centerline Road in Kingshill, St. Croix. Representatives from EPA presented the 
Proposed Plan, which discussed the following five altematives: 
• 
Altemative 1: No Further Action 
• 
Altemative 2: Monitored Natural Attenuation (MNA) with Institutional Controls 
• 
Altemative 3: Soil Vapor Extraction/Air Sparging (SVE/AS) for the AST area, MNA for 
the FPP area, and Institutional Confrols 
• 
Altemative 4: SVE/AS for the-AST area, Groundwater Exfraction and Treatment for the 
FPP area, and Institutional Confrols 
• 
Altemative 5: Groundwater Extraction and Treatment for the AST area, MNA for the FPP 
area, and Institutional Controls 
Altemative 3 was presented as EPA's Preferred Altemative. In addition, EPA proposed to retain 
Altemative 4 as a contingency remedy that would be implemented in the event that the analyses 
of fiiture groundwater monitoring data indicate that active remediation ofthe contaminated 
groundwater is appropriate. A portion ofthe meeting was dedicated to answering questions and 
accepting formal oral comments from the public. Community acceptance ofthe Selected Remedy 
is discussed in Section 9.0, Summary of Comparative Analysis of Altematives, of this Decision 
Summary. 
EPA's response to comments received during the public comment period is included in the 
Responsiveness Summary, which is part of this ROD, and is designated as Appendix C. 
Page-4-
500017 
3.0 SCOPE AND ROLE OF RESPONSE ACTION 
This is the first and only operable unit at the Site. 
The Selected Remedy addresses soil and groundwater contamination in the AST area and 
groundwater contamination in the FPP area at the Virgin Island Chemical Superfund Site. The 
Selected Remedy will use a soil vapor extraction/air sparging system to freat groundwater, 
saturated soil, and unsaturated soil at the AST area and MNA to address groundwater in the FPP 
area. The Department of Planning and Natural Resources will utilize institutional confrols (in the 
form of existing well permitting laws) to limit the pumping of groundwater at the Site to prevent 
interference with the selected remedy and to also prevent human exposure to contaminated 
groundwater until MCLs are achieved. 
The Selected Remedy is necessary to protect human health and the environment. 
4.0 SUMMARY OF SITE CHARACTERISTICS 
RI/FS activities were conducted at the Site, with EPA and VIDPNR oversight, from 1994 to 2000. 
The primary objectives ofthe RI were to: 1) collect the data needed to characterize the nature and 
extent of contamination and adequately support human health and ecological baseline risk 
assessments and 2) provide a basis on which a subsequent, cost-effective, remedial action plan 
would be recommended. 
The RI field investigation was completed in four phases from 1995 through 1998. Six areas of 
potential environmental concem were investigated (see Figure 2): 
(1) 
Laboratory and Warehouse Building 
(2) 
Aboveground Storage Tank (AST) Area 
(3) 
Former Process Pit (FPP) Area 
(4) 
Loading Dock/Former Laboratory Pit Area 
(5) 
Soil Beneath Concrete Pad Near ASTs (northem comer ofthe Site) 
(6) 
Concrete Storage Pad (north ofthe laboratory and warehouse buildings) 
The following Site-specific data were collected as part ofthese investigations: 
• 
Background concenfrations of constituents in surface soils 
• 
Nature and extent of potential surface and subsurface soil impacts on Site 
• 
Nature and extent of potential groundwater impacts on Site/ofF Site 
• 
Site-specific geologic and hydrogeologic conditions 
• 
Nature and extent of potential soil/sediment impacts in the Gut system (i.e.. River, 
Bethlehem, and Fair Plains Guts). 
Page-5-
5 0 0 0 1 8 
The FS was initiated subsequent to completion ofthe RI, which included the collection of 
supplemental RI data and the performance of an SVE/AS pilot study in the AST and FPP areas in 
2000. 
The results ofthe RI investigation are summarized below. The results ofthe SVE/AS pilot study, 
which was conducted as part ofthe FS, are fiirther discussed in Section 8.0. 
4.1 
Geology and Hydrogeology 
Geology 
• * . 
.
.
.
. 
The Site geology generally consists of approximately 90 feet of fill and alluvium overlying the 
clayey marl ofthe Kingshill Formation (see Figures 2 and 3). 
• 
Fill material [thickness varies from 0 to approximately 10 feet below ground surface 
(bgs)]- Consists of reworked alluvium material, as described below. 
• 
Alluvium (to approximately 90 feet bgs) - Consists of brown and grey clay-rich sediments 
with lesser and varying amounts of silt and fine sand. Enfrained within the clay-rich 
matrix to approximately 30 to 40 feet bgs are more permeable sand and gravel lenses. 
These lenses are localized and not uniform or continuous across the Site. 
Kingshill Formation (below approx. 90 feet bgs) - Consists of white to light brown and 
grey, stiff clay with lesser amounts of sand. 
Hydrogeology 
The water table depth fluctuates from approximately 10 to 30 feet bgs according to precipitation, 
which generally varies according to an aimual cycle. 
Multiple rounds of groundwater level measurements were taken during the RI to characterize 
groundwater flow during both the wet and dry periods. Based upon the results ofthese 
measurements, it was determined that two distinct water-bearing zones exist within the alluvium. 
The "shallow" alluvium zone corresponds to the interval between 0 to approximately 50 feet bgs, 
and the "deep" alluvium.zone refers to the interval between approximately 50 to 100 feet bgs. 
The characteristics ofthese zones are illustrated on the groundwater elevation iso-contour maps 
(see Figures 4 to 7) and hydrographs (see Figures 8 and 9) included in Appendix A. 
Figures 4 through 7 contain interpreted groundwater elevation contours in the shallow and deep 
alluvium during high (i.e., March 6, 2000) and low (i.e., October 21,1998) water table conditions. 
The predominant groimdwater flow direction within both the shallow and deep alluvium is to the 
south-southeast, with a localized easterly flow component also apparent in the shallow alluvium 
proximal to monitoring well MW-10 during high water table conditions. Horizontal gradients in 
the shallow and deep alluvium range from approximately 0.002 to 0.014 feet per foot (ft/ft) and 
from 0.003 to 0.014 ft/ft, respectively^ The vertical gradients between the shallow and deep 
Page-6-
5 0 0 0 1 9 
alluvium are consistently downward and range from -0.005 to -0.11 ft/ft. The hydrauhc 
conductivities for the shallow and deep alluvium ranged from 0.90 to 18.14 feet per day (ft/d) and 
from 2.73 to 5.65 ft/d, respectively. 
Figures 8 and 9 contain the results of continuous water level measurements from two 
shallow/deep well pairs (MW-6/MW-8 in the AST area, MW-2/MW-7 in the FPP area), 
respectively, along with corresponding precipitation data for a period of approximately 3 weeks. 
In both cases, the hydrograph for the deep well exhibited a response (i.e., a corresponding change 
in water level) to off-site pumping, whereas the shallow well exhibited a steady decline and no 
response to off-site pumping. This information supports the conclusion that an aquitard exists 
between the shallow and deep alluvium, which prevents direct hydraulic communication between 
theses two zones. This conclusion is fiirther supported by the distribution of groundwater 
contaminants, as fiirther discussed in Section 4.3. 
4.2 
Soil 
Surface Soil 
The analytical results from surface soil samples were compared to EPA's SSLs, risk-based 
screening levels derived from other EPA guidance documents, and Site background 
concentrations (for metals only). Arsenic was detected above the risk-based screening level of 
3.83 parts per million (ppm) (non-detected to 8.8 ppm); iron was detected above twice the Site 
background concentration of 31,933 ppm (18,100 ppm to 63,400 ppm); and manganese was 
detected above the risk-based level of 1,600 ppm (311 ppm to 2,100 ppm) in several samples. 
Based upon further evaluation ofthe data as part ofthe risk assessment (see Section 6.0), no 
contaminants of significant concem were identified in the surface soil. 
Subsurface Soil 
The analytical results from subsurface soil samples were compared to EPA's SSLs for protection 
of groundwater and to Site background concenfrations (for metals only). Based on these 
comparisons and the groundwater data collected during the RI, metals and semi-volatile organic 
compounds (SVOCs) were not considered to be a significant concem. 
The predominant contaminants determined to have impacted subsurface soils in the AST area 
were ethylbenzene (7 parts per billion (ppb) to 320,000 ppb) and xylene (2 ppb to 2,000,000 ppb). 
The SSLs for ethylbenzene and xylene are 6,500 ppb and 90,000 ppb, respectively. The impacted 
subsurface soils generally encompass an on-Site area between Tanks 3 and 10 (see Figure 10). 
The zone of impact was estimated to be approximately 7,800 square feet (sf) in area and to extend 
from two feet bgs to the water table interface (approximately 25 feet bgs). 
While concenfrations of chloroform were not detected above the SSL of 600 ppb (maximum 
concentration of chloroform was 410 ppb), this chemical was included as a contaminant of 
potential concem (COPC) based upon its detection in groundwater. The subsurface soils within a 
400-square-foot area, from 20 to 25 feet bgs, near monitoring well MW-2 (i.e., the location where 
Page-7-
500020 
highest concentrations of chloroform were detected in groundwater; see Figure 13), were 
conservatively assumed to be impacted with chloroform. 
4.3 
Groundwater 
The following volatile organic compounds (VOCs) were detected above the federal Maximum 
Contaminant Levels (MCLs) in groundwater: ethylbenzene, xylene, and chloroform. 
Groundwater quality in the AST area was determined to be impacted by ethylbenzene (700 ppb to 
23,000 ppb) and xylene (27,000 ppb to 110,000 ppb). The MCLs for ethylbenzene and xylene are 
700 ppb and 10,000 ppb, respectively. Concenfration iso-contour maps illustrating the 1998 
extent ofthe ethylbenzene and xylene contamination exceeding MCLs in groundwater are 
included as Figures 11 and 12, respectively. In 1998, the area and depth of groundwater impact 
above MCLs were estimated to be approximately 14,000 sf and 40 to 50 feet bgs, respectively, 
based upon the results of groundwater samples collected from shallow monitoring wells MW-1, 
MW-6 and MW-10, deep monitoring well MW-8, and multiple geoprobe and temporary well 
sampling locations. The most recent results from groundwater sampling completed during the 
period of March to May 2000 indicate that the groundwater plume is not expanding. 
Ethylbenzene and xylene were not detected in any ofthe existing off-Site production wells. 
Groundwater quality in the FPP area was determined to be impacted by chloroform. The MCL 
for chloroform is 100 ppb. A concenfration iso-contour map illusfrating the 1998 extent of 
chloroform contamination exceeding MCLs in groundwater is included as Figure 13. In 1998, the 
area and depth of impact above the MCL was estimated to be approximately 3,000 sf and 40 to 50 
feet bgs, respectively, based upon the results of groundwater samples collected from shallow 
monitoring wells MW-2 and MW-11, deep monitoring well MW-7, and multiple geoprobe and 
temporary well sampling locations (96 ppb to 3,800 ppb). The most recent results from 
groundwater sampling completed during the period of March to May 2000 indicate that 
chloroform concenfrations (38 ppb to 76 ppb) have decreased below the MCL, excluding the 
localized area of temporary well FPP-VMP-ID (25 -137 ppb; located 10 feet from MW-2). 
Chloroform was not detected in any off-Site production wells. 
Methylene chloride was also notably detected in groundwater at both the AST and FPP areas. 
However, methylene chloride was also detected in field, trip, and laboratory blanks and at 
concentrations that can be attributed to laboratory contamination rather than actual Site 
conditions. To be conservative, this chemical was included as a COPC. 
4.4 
Gut System 
Several metals were detected at the reference location (RG-2), uspsfream of Plot 13Q, in the River 
Gut. The distribution ofthese metals was generally variable throughout the Gut System. 
However, a slight increase in the concenfration of certain metals was noted at several locations 
downsfream ofthe facility and at one location in the Bethlehem Gut. 
These elevated concenfrations in the River Gut are likely the result ofthe depositional nature of 
the locations. No metals were detected above EPA SSLs and, thus, they are not of concem. 
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4.5 
Fate and Transport 
The existing data obtained during the RI/FS support the following conclusions: 
1) 
An active source of ethylbenze and xylene contamination exists in the unsaturated zone 
soils at the AST area, which will continue to impact the underlying groundwater quality at 
concenfrations exceeding MCLs. However, the existing groimdwater data indicate that 
ethylbenzene and xylene plumes exceeding MCLs have reached steady state as a result of 
natural attenuation processes (e.g., biodegradation, adsorption, dilution) and, hence, are 
not expanding or migrating beyond their current position. The groundwater plumes 
exceeding MCLs in this area generally coincide, extend just north ofthe Site property 
boundary, and have not impacted off-Site production wells. The current impact to 
groundwater quality will persist so long as the active source remains present. 
2) 
An active source of chloroform contamination was not identified in the FPP area. Existing 
groundwater data indicate that the chloroform plume is confracting as a result of natural 
attenuation processes, with current groundwater quality in this area predominantly 
conforming with MCLs. The groundwater plume exceeding MCLs is within the Plot 13Q 
property boundary and has not impacted off-Site production wells. 
5.0 CURRENT AND POTENTIAL FUTURE LAND USE 
The Revised Final Human Health Risk Assessment (2000) considered both current and potential 
future land use scenarios. The Site and the surrounding area have been generally developed for 
various commercial/ industrial uses, and it is reasonable to assume that such uses will continue 
into the extended fiiture. The exposure pathways of ingestion, inhalation, and dermal absorption 
via contact with the COPCs in groundwater, soils, and sediments were identified for evaluation. 
Potential human receptor populations were evaluated for each pathway and either mled out or 
included in the risk assessment. This evaluation identified the following possible exposure 
pathways: 
5.1 
Current Land Use 
• 
Residential (child/adult) exposure to groundwater via six off-Site wells was evaluated. 
This pathway was deemed incomplete as no COPCs were identified for the groundwater 
from these off-Site wells in the immediate vicinity ofthe Site. 
• 
Trespasser (pre-adolescent/adult) exposure to COPCs in the surface soil/sediment 
collected from the Site and the stream system (Gut System) was evaluated for three 
pathways (incidental ingestion, dermal contact, and inhalation of particulates). Pre-
adolescent children were assumed to be those between 7 and 12 years of age. 
5.2 
Future Land Use 
• 
Industrial/Commercial (adult) exposures on-Site to COPCs in groundwater, surface soil, 
and sediment were evaluated for three pathways (ingestion, inhalation of VOCs 
(groundwater) and particulates (soil and sediment), and dermal contact). 
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• 
Constmction worker (adult) exposures on-Site to COPCs in surface soil, subsurface soil 
(up to 12 feet bgs), and soil/sediment in the Gut System were evaluated for three pathways 
(incidental ingestion, dermal contact, and inhalation of particulates). Exposure to 
groundwater was not evaluated for this receptor since groundwater at the Site is generally 
encountered at depths between 18 and 20 feet bgs. Since constmction activities are not 
anticipated to occur at such depths, exposure to groundwater was not considered. In 
addition to evaluating the potential for risk associated with direct contact with 
contaminants in subsurface soil, the same data also were compared to EPA's SSLs to 
detennine if concenfrations could adversely impact groundwater through migration 
(leaching). 
• 
Off-Site residential (child/adult) exposures to COPCs in groundwater were evaluated for 
three pathways (ingestion, dermal contact, and inhalation of particulates or VOC vapors). 
For this scenario, it was assumed that on-Site concenfrations could be present in an off-
Site well for the entire exposure duration. In reality, no COPCs were detected in the off-
Site wells or in the wells at the edge ofthe Site nor are they expected to reach these areas 
in the future, as discussed in Sections 4.1 and 4.3. Therefore, frie exposure assumptions 
used in this scenario are exfremely conservative. 
6.0 SUMMARY OF SITE RISKS 
Based upon the results ofthe RI, a baseline risk assessment was conducted to estimate the risks 
associated with current and future Site conditions. A baseline risk assessment is an analysis ofthe 
potential adverse human health and ecological effects caused by hazardous substance releases 
from a Site in the absence of any actions to control or mitigate these under current and fiature land 
uses. The results ofthe baseline risk assessment are discussed below and summarized on Tables 1 
through 10. 
6.1 
Human Health Risk 
An evaluation was made of all potential exposure routes which cause exposure to chemicals of 
potential concem at the Site for people living or working iri the area. The estimated carcinogenic 
risks and noncarcinogenic hazards were compared to EPA guidelines and generally-accepted 
target risk levels. Carcinogenic risks falling within the target range of 1 X 10'* to 1 X 10"^ and 
noncarcinogenic hazards less than 1 were considered to be below the statutory threshold. 
Under a fiiture land use scenario, the cumulative carcinogenic risk estimates for exposure to 
groundwater for the industrial/commercial worker (9 X 10^), the adult resident (8 X 10"*) and the 
child resident (4 X 10"*) exceed EPA's target risk range. These exposure scenarios assumed that 
the on-Site groundwater would be used as a potable water source for drinking and bathing. 
Inhalation of volatilized chloroform accounts for most ofthe cumulative risk for this medium. 
Although the maximum detected concenfrations of ethylbenzene and xylene exceeded their 
respective MCLs in the AST area, theresults of the Human Health Risk Assessment showed that 
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exposure to these two COPCs alone over time did not present unacceptable risks or hazards to 
human health based upon their levels of detection throughout the entire Site. 
For the evaluation of noncancer human health hazards, potential fiiture industrial/commercial and 
residential groundwater use exceeded EPA's target hazard index (HI) of 1. For the 
industrial/commercial worker exposure and both residential scenarios, chloroform was the major 
contributor. Both adult and child residential His exceeded 1 (255 and 600, respectively), as did 
the industrial/commercial worker (330). Ingestion and inhalation of chloroform contributed to 
virtually all ofthe noncancer hazard for the industrial/commercial worker and residential 
groundwater use scenario. Ingestion of iron and manganese also contributed less significantly to 
the hazard estimates. 
All contaminants in the subsurface soil were below levels of concem, and were not carried into 
the human health risk assessment. On-Site surface soil and soil/sediment in the Gut System did 
not demonsfrate carcinogenic risks for the adult industrial/commercial worker, adult and pre-
adolescent trespassers and constmction workers above EPA's target risk range. Noncancer 
hazards were near or below EPA's HI of 1.0. For the constmction worker scenario, the total HI 
was 1.2, although no individual chemical exceeded the HI of 1.0. Arsenic, iron and manganese 
were included in the Human Health Risk Assessment. However, all risks and hazards associated 
with exposure to these chemicals are within EPA's acceptable levels and by themselves are not 
considered to be a health concem. They do, however contribute to the overall risk at the Site. 
In summary, chloroform in the groundwater is the main risk and hazard driver for the 
industrial/commercial worker and the adult and child resident for the future groundwater use 
scenario, with methylene chloride and arsenic contributing to the risk as well. Manganese and 
iron also contributed to the estimated non-cancer risk; however, these compounds are naturally 
occurring in groundwater and do not have MCLs. Ethylbenzene and xylene did not significantly 
contribute to the calculated risks, as described above. However, ethylbenzene and xylene 
exceeded their respective MCLs in groundwater in the AST area and, therefore are considered 
contaminants of concem. 
6.2 
Environmental Concerns 
A Screening Ecological Risk Assessment (SERA) focused on the drainage channels adjacent to 
and downsfream ofthe Site, including the River Gut (which serves as the northeastem and 
southeastem Site boundary), Bethlehem Gut, and Fairplain Gut. The SERA was developed using 
data obtained through a surface soil/sediment sampling program conducted within the three 
drainage channels. 
In general, aluminum exposure may potentially impact herbivorous, insectivorous, and 
piscivorous wildlife foraging in the River, Bethlehem and Fairplain Guts. Aluminum, chromium, 
vanadium and zinc, identified for plants, measured adjacent to or downsfream ofthe Site were 
found at similar or lower concentrations to those measured at the upsfream reference location 
(RG-2). This finding suggests that the contaminants of potential ecological concem have been 
transported from upgradient sources. Historical (1986) and current (1997) data for soil collected 
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from the Central and Southem Storm Drains suggest that several metals (e.g., aluminum, 
manganese, and zinc) may have been historically discharged to downsfream areas ofthe River 
Gut (near sample location RG-13). 
The potential contribution of aluminum has decreased over the years, as evidenced by the 
substantial reduction in concenfrations measured in 1997, as compared to 1986. In addition, the 
aluminum concenfrations measured in soil from the storm drains collected in 1997 were similar to 
those measured in soil collected from the River Gut upsfream ofthe drain discharge points. 
Therefore, a current on-Site source of aluminum to the River Gut is unlikely. The Bethlehem Gut, 
which contained the second highest concenfration of aluminum, also is a potential source of 
exposure in the Fairplain Gut. A bauxite plant is located in close proximity to the Site and serves 
as a likely source ofthe aluminum concenfrations detected. 
7.0 REMEDIAL ACTION OBJECTIVES 
The remedy outlined in this ROD is intended to be the final remedial action for the Site. 
Remedial action objectives (RAOs) are medium-specific (e.g., soil, groundwater, etc.) goals for 
protecting human health and the environment. 
The RAOs for the Virgin Island Chemical Superftmd Site are to: 
• 
Mitigate the toxicity, mobility, and/or volume of VOCs (ethylbenzene and xylene) in soils 
in the AST area so as to minimize continued leaching to groundwater; 
• 
Mitigate the toxicity, mobility, and/or volume of VOCs (ethylbenzene and xylene) in 
groundwater in the AST area and downgradient so as to achieve MCLs and protect 
potential future groundwater users; 
• 
Mitigate the toxicity, mobility, and/or volume of chloroform in groundwater in the FPP 
area and dovragradient so as to achieve MCLs and protect fiiture potential groundwater 
users; and 
• 
Restrict on-Site groundwater use to non-potable purposes until the water quality is 
restored to MCLs. 
The Applicable or Relevant and Appropriate Requirements (ARARs) and other To-Be-Considered 
criteria (TBCs) for soil and groundwater remediation at the Virgin Islands Chemical Site are 
summarized in Table 13. The groundwater cleanup goals are based upon the primary MCLs for 
drinking water, as established by federal regulations. There are no promulgated federal or 
territory cleanup standards for soils. In addition, the results ofthe baseline risk assessment did 
not identify any unacceptable human health risks associated with direct exposure to the 
contaminated soils at the Site. Therefore, Site-specific cleanup goals for Site soil contaminants 
were developed as TBCs using the EPA Soil Screening Level (SSL) methodology for the 
migration to groundwater pathway. 
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Additional ARARs and/or TBC, specific to remedial freatment system design and operation, will 
be dictated by the applicable federal and territorial regulations (e.g., for surface water and air 
discharges) as referenced in Table 13. 
8.0 DESCRIPTION OF ALTERNATIVES 
Based on the results ofthe RI, EPA evaluated five remedial altematives that would address soil 
and groundwater contamination at the Virgin Island Chemical Superfund Site. 
As part of evaluating altematives, a soil vapor exfraction/air sparging pilot study was performed 
in Spring 2000 at both the AST and FPP areas to better assess the effectiveness of SVE/AS 
freatment in these areas. The results ofthe pilot test supported the following conclusions: 
SVE/AS would be an effective Combined technology for removing ethylbenzene and 
xylene from the AST source area soils and groundwater. AS freatment would also 
enhance the conditions for aerobic biodegradation ofthese contaminants. 
• 
SVE/AS would not be effective for freatment ofthe FPP area, based upon the low air 
permeability of soils and the low chloroform concenfrations remaining in the soils and 
groundwater in this area. The analytical results of groundwater samples collected prior to, 
during, and after SVE/AS testing fiirther indicated that chloroform concenfrations in 
groundwater have decreased since 1998 to below the MCL as a result of natural 
attenuation, excluding a localized area near temporary monitoring well FPP-VMP-ID. 
Following completion ofthe pilot study, five remedial altematives were developed for evaluation. 
Four altematives involved active cleanup measures. One altemative evaluated MNA. Two 
altematives evaluated SVE/AS, combined with MNA in one case and groundwater exfraction and 
treatment in the other case. Groundwater extraction and freatment with MNA was evaluated as 
the remaining altemative. All ofthese active cleanup altematives included institutional confrols. 
As required by CERCLA, a No Further Action altemative was evaluated as a basis for comparison 
with the other active cleanup methods. The FS Altematives have been modified to reflect 
institutional confrols that are appropriate to current Site conditions and implementation 
responsibilities. 
The following section describes the remedial altematives evaluated in the FS for the Site. The 
Selected Altemative is Altemative 3 (i.e.. Soil Vapor Extraction/Air Sparging for the AST area, 
MNA for the FPP area, and Institutional Confrols). The Contingency Altemative for groundwater 
is a combination of Altemative 4 and Altemative 5 (i.e.. Soil Vapor Exfraction/Air Sparging for 
the AST Area, Groundwater Exfraction and Treatment for the AST and FPP Areas, and 
Institutional Confrols). 
Note that the capital cost presented in this section of the ROD includes expenses related to the 
labor, equipment, and material costs of constmction. Operations and Maintenance (O&M) cost 
refers to the cost over time of operating labor, maintenance, materials, energy, disposal, and 
adminisfrative activities. Present-worth provides an analysis ofthe current value of all costs. 
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Present-worth cost is calculated based on a predetermined interest rate and the time period over 
which an altemative will be completed. 
8.1 
Alternative 1: No Further Action 
Under the No Further Action alternative, no new response actions would be initiated at the Site. 
The security fence installed in Spring 2000 would remain and be maintained, but the existing 
SVE/AS system installed for the pilot study in the Spring of 2000 would be rendered non-
operational. The potential risks associated with the contamination would not be minimized by 
this action. 
• 
Incurred capital costs of existing fence: 
$45,000 
Estimated present-worth O&M costs: 
$12,000 
Total estimated present-worth cost: 
$57,000 
(based upon 30 years of maintenance) 
8.2 
Alternative 2: MNA with Institutional Controls 
Altemative 2 would include MNA for COPCs in groundwater in the AST area and FPP area. 
Under this altemative, groundwater conditions would be monitored over an assumed period of 15 
years using existing wells at the Site, plus additional monitoring wells would be installed at the 
AST and FPP areas. 
The following parameters would be monitored: ethylbenzene and xylene isomers (AST area only), 
chloroform and dichloromethane (FPP area only), dissolved oxygen, reduction/oxidation (redox) 
potential, total organic carbon, ferrous iron, sulfate, sulfide, and methane. The monitoring 
frequency is assumed to consist of quarterly sampling for Year 1, semi-annual sampling for Years 
2 and 3, and annual sampling thereafter to Year 15. 
The Department of Planning and Natural Resources in consultation with EPA, will utihze 
institutional confrols (in the form of existing well permitting laws and regulations) to limit the 
pumping of groundwater at the Site to prevent interference with the selected remedy and to also 
prevent human exposure to contaminated groundwater until MCLs are achieved. 
Estimated capital costs: 
$116,560 
Estimated present-worth O&M costs: 
$545,530 
Total estimated present-worth cost: 
$662,090 
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8.3 
Alternative 3: SVE/AS for the AST Area, MNA for the FPP Area, and Institutional 
Controls 
In addition to the institutional confrols identified in Altemative 2, this altemative includes 
expansion and use ofthe existing SVE/AS system to freat groundwater, saturated soil, and 
unsaturated soil at the AST area. 
For the AST area, Altemative 3 includes using the existing air sparging system for volatilizing 
VOCs in shallow groundwater and the soil vapor extraction system to capture sparged vapors 
from the groundwater and to remove VOCs in the soils above the water table. Additional afr 
sparging/soil vapor extraction wells would be installed during implementation ofthe remedy to 
remediate contaminated groundwater and soil in the AST area. 
This altemative includes periodic monitoring ofthe SVE/AS system. Altemative 3 assumes: 1) 
one year of SVE/AS operation to achieve the SSLs and groundwater MCLs and 2) three years of 
verification groundwater monitoring after shutdown ofthe SVE/AS system in the AST area to 
assure that MCLs are achieved in groundwater. 
For the FPP area, MNA would be implemented for low-level residual VOC contamination in 
groundwater. Altemative 3 includes the same sampling scheme for groundwater monitoring as 
stated in Altemative 2 for an assumed period of 15 years. 
• 
Incurred capital costs: 
$ 565,000 
• 
Estimated additional capital costs: 
$ 285,760 
• 
Estimated present-worth O&M costs: 
$ 553,500 
• 
Total estimated present-worth cost: 
$1,404,260 
8.4 
Alternative 4: SVE/AS for the AST Area, Groundwater Extraction and Treatment 
for the FPP Area, and Institutional Controls 
In addition to the institutional confrols identified in Altemative 2, this altemative includes: 
• 
SVE/AS to treat groundwater, saturated soil, and unsaturated soil at the AST area, and 
• 
A groundwater extraction and freatment system to hydraulically confrol and freat impacted 
groundwater at the FPP area. 
The SVE/AS portion ofthe remedy in the AST area would be the same as described in Altemative 
3. 
At the FPP area, the groundwater extraction system would be comprised of two exfraction wells 
located approximately 70 feet apart. Each well would be equipped with a submersible pump. The 
primary exfraction well would be located in the area where the highest concenfrations of 
chloroform in groundwater were historically encountered. The secondary extraction well would 
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be located downgradient ofthe first well. The combined capture zone from both wells would 
encompass the FPP area and the historic extent ofthe chloroform plume. 
The treatment system would consist of a storage/equalization tank, from which groundwater 
would be pumped to a low profile air stripper for removal of chloroform. Treated water would be 
discharged via pipeline to the River Gut. 
It is estimated that 5 years would be required for operation ofthe groundwater freatment and 
exfraction system to meet MCLs. 
Altemative 4 includes the following monitoring scheme: 
• 
Pre- and post-air stripper water sampling to evaluate removal efficiency in the air stripper 
and compliance with surface water discharge limits; 
• 
Periodic air flow monitoring to ensure sufficient air flow from the blower for mass fransfer 
in the stripper; 
Monitoring of differential pressure across the air stripper, in addition to periodic visual 
inspection ofthe trays to evaluate whether fouling or other impediments to air flow have 
occurred; 
• 
Calculation of mass emissions from the air stripper by using the measured concenfrations 
of chloroform in the influent water and treated water and the flow rate from the storage 
tank to the stripper. 
• 
Assessment ofthe cone of depression and extent of capture zone induced by the exfraction 
wells by measuring water levels at new and existing groundwater monitoring wells. 
Altemative 4 includes the same sampling scheme for groundwater monitoring described in 
Altemative 2. It was assumed that monitoring in the FPP area would continue through the 
operation ofthe extraction system (i.e., until the attainment of MCLs), plus two years of post-
shutdown monitoring. 
• 
Incurred capital costs: 
$ 565,000 
Estimated additional capital costs: 
$ 654,240 
Estimated present-worth O&M costs: 
$ 877,330 
Total estimated present-worth cost: 
$2,096,570 
8.5 
Alternative 5: Groundwater Extraction and Treatment for the AST Area, MNA for 
tbe FPP Area, and Institutional Controls 
In addition to the institutional confrols identified in Altemative 2, this altemative includes: 
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• 
MNA for impacted groundwater in the FPP area, and a groundwater exfraction and 
treatment system to capture and treat impacted groundwater at the AST area. 
At the FPP area, the MNA portion ofthe remedy would be the same as described in Altemative 2. 
At the AST area, the groundwater exfraction system would consist of two exfraction wells located 
within the zone of highest xylene and ethylbenzene impacts. The expected combined capture 
zones ofthese wells would encompass the entire AST area and the extent ofthe xylene and 
ethylbenzene plumes. 
The treatment system would be comprised ofthe same components and be subject to the same 
monitoring scheme as described in Altemative 4. Treated water would be discharged to the River 
Gut at a location northeast ofthe AST area. 
Altemative 5 includes the same sampling scheme for groundwater monitoring as identified in 
Altemative 2. In the FPP area, the assumed duration of monitoring would be 15 years. In the 
AST area, the assumed duration of monitoring would be seven years (i.e., five years during 
extraction system operation and two years of post-shutdown monitoring). 
• 
Incurred capital costs: 
$ 565,000 
• 
Estimated additional capital costs: 
$ 556,480 
• 
Estimated present-worth O&M costs: 
$1,030,370 
• 
Total estimated present-worth cost: 
$2,151,850 
9.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 
Section 300.430(e)(9) ofthe NCP requires that EPA evaluate and compare the remedial cleanup 
altematives based on the nine criteria listed below. The first two criteria, (1) overall protection of 
human health and the environment and (2) compliance with applicable or relevant and appropriate 
requirements (ARARs), are threshold criteria that must be met for the Selected Remedy. The 
Selected Remedy must then represent the best balance ofthe remaining primary balancing and 
modifying criteria. 
9.1 
NCP Evaluation and Comparison Criteria 
9.1.1 
Threshold Criteria 
(1) 
Overall protection of human health and the environment addresses whether or not a 
remedy provides adequate protection and describes how risks posed through each 
exposure pathway (based on a reasonable maximum exposure scenario) are eliminated, 
reduced, or confrolled through freatment, engineering methods, or institutional confrols. 
(2) 
Compliance with applicable or relevant and appropriate requirements (ARARs) 
addresses whether or not a remedy would meet all ofthe applicable or relevant and 
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500030 
appropriate requirements of other federal and state environmental statutes and regulations 
or provide grounds for invoking a waiver. 
9.1.2 
Primary Balancing Criteria 
(3) 
Long-term effectiveness and permanence refer to the ability of a remedy to maintain 
reliable protection of human health and the environment over time, once cleanup goals 
have been met. It also addresses the magnitude and effectiveness ofthe measures that may 
be required to manage the risk posed by treatment residuals and/or unfreated wastes. 
(4) 
Reduction of toxicity, mobility, and volume through treatment is the anticipated 
performance ofthe freatment technologies, with respect to these parameters, that a remedy 
may employ. 
(5) 
Short-term effectiveness addresses the period of time needed to achieve protection and 
any adverse impacts on human health and the environment that may be posed during the 
constmction and implementation period until cleanup goals are achieved. 
(6) 
Implementability is the technical feasibility (e.g., the difficulty ofthe altemative to 
constmct and operate) and adminisfrative ease (e.g., the amount of coordination with other 
government agencies) of a remedy, including the availability of necessary materials and 
services. 
(7) 
Cost includes the estimated capital, operation and maintenance, and net present-worth 
costs. 
9.1.3 
Modifying Criteria 
(8) 
Territorial acceptance indicates whether, based on its review ofthe RI/FS reports and the 
Proposed Plan, the Territory (VIDPNR) concurs with, opposes, or has no comment on the 
preferred remedy at the present time. 
(9) 
Community acceptance refers to the public's general response to the altematives 
described in the Proposed Plan and the RI/FS reports. 
9.2 
Evaluation of the Alternatives Against the NCP Criteria 
This section summarizes the evaluation ofthe remedial altematives against the nine NCP criteria. 
The following subsections are a brief summary ofthe evaluation and comparison ofthe 
altematives against each criteria. Additional details ofthe evaluation ofthe altematives are 
presented in the FS. 
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9.2.1 
Overall Protection of Human Health and the Environment 
The No Further Action altemative does not address Site risks. 
All ofthe remaining altematives include a monitoring component to evaluate the protectiveness of 
the remedy. 
Although natural attenuation would still occur under the No Further Action altemative, there 
would be no verification or measure ofthe extent to which these processes are occurring. 
Altemative 3 would be more effective than MNA alone (Altemative 2) in overall protection of 
human health, since the inclusion of SVE/AS would remove mass from the AST area more 
quickly and reduce the amount of time to achieve MCLs and SSLs. Similarly, Altemative 3 
would be more effective than Altemative 5 in three ways: (1) SVE would rapidly remove and 
reduce the contaminant source in the unsaturated zone, whereas groundwater exfraction alone 
would not address the unsaturated zone; (2) AS is expected to be more effective at remediating 
contaminated groundwater than conventional groundwater extraction and freatment based upon 
the localized nature of contaminant distribution, higher silt/clay content ofthe Site soils, and poor 
yield ofthe shallow aquifer. AS would also better facilitate aerobic biodegradation processes via 
introduction of air; and (3) SVE/AS would be more readily implemented considering that a 
system is already in place from the pilot study. 
With respect to Altemative 4, the existing groundwater data indicate that cleanup via groundwater 
exfraction and freatment in the FPP area would occur no more rapidly than via natural attenuation 
(included as a component in Altematives 1, 2, 3, and 5). The groundwater data from Spring 2000 
indicate that only one temporary monitoring point exhibits chloroform concenfrations above its 
MCL. These findings support the conclusion that natural attenuation is adequately protective 
without the need for any active exfraction system. 
9.2.2 
Compliance with ARARs 
The No Further Action altemative does not include a monitoring component to verify compliance 
with chemical-specific ARARs for groundwater or soil. Altematives 1 (No Further Action) and 2 
would not achieve compliance with chemical-specific ARARs in the AST area within a time 
frame that is comparable to that offered by other active remedial altematives based upon the 
presence of a residual source. All other altematives can be implemented to achieve and verify 
compliance with ARARs within a reasonable time frame. 
9.2.3 
Long-Term Effectiveness and Permanence 
Altematives 1 and 2 will not provide long-term protection against the risks posed by contaminated 
groundwater and soils in the AST area. Also, Altemative 1 does not provide a monitoring 
component to verify the long-term effectiveness of natural attenuation. Altemative 2 will allow 
Site contaminants to remain in the AST area for a greater period of time than Altematives 3,4 and 
5. However, off-Site risks to human health and the envfronment are not expected with any 
Page-19-
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altemative. A permanent remedy will be achieved more quickly by Altematives 3 and 4, since 
contaminant mass will be removed more quickly from the AST area soil and groundwater, rather 
than by reliance on solely natural biological and physical processes under Altemative 2 or by 
groundwater freatment alone under Altemative 5. Altematives 3,4 and 5 are expected to perform 
similarly in the FPP area over the long-term, based upon the low concenfrations of chloroform 
remaining in soil and groundwater. 
9.2.4 
Reduction of Toxicity, Mobility, and Volume through Treatment 
Altematives 1 and 2 do not include remedies that involve active treatment in the AST or FPP 
areas. Therefore, these altematives would not actively reduce contaminant toxicity, mobility, or 
volume. Passive reduction would occur in both areas as a result of natural attenuation processes. 
For Altematives 3 and 5, active control and removal of mass would occur via SVE/AS or 
groundwater exfraction in the AST area, but would not occur in the FPP area. Altemative 4 
would control and remove contaminant mass at both the FPP and AST areas using SVE/AS 
treatment and groundwater exfraction and freatment, respectively. However, the relative 
reduction achieved in the FPP area by pump and freat Altemative 4 would be comparable to that 
offered by natural attenuation under Altematives 1,2, 3 and 5, based upon the low concenfrations 
and limited mass of contamination present m the FPP area. 
Altematives 3 and 4 would also provide secondary reduction of toxicity, mobility, and volume 
through treatment by enhancing natural biodegradation processes that will reduce ethylbenzene 
and xylene mass in the AST area. The oxygen delivered to groundwater via air sparging will 
likely augment aerobic biodegradation ofthese contaminants. 
9.2.5 
Short-Term Effectiveness 
The relative short-term effectiveness provided by Altematives 1 and 2 is comparable and greater 
than that provided by Altematives 3,4 and 5, because Altematives 1 and 2 do not involve the 
completion of intmsive remedial constmction work within areas containing contaminated 
groundwater or soils. 
Altematives 3,4 and 5 include the constmction of an active remediation system in the AST and/or 
FPP areas. A limited amount of intmsive constmction work (i.e., new SVE/AS wells, 
groundwater exfraction wells, new monitoring wells/points) will be required for these altematives, 
within areas containing contaminated groundwater and/or soils, to complete remedial system 
installation. This work can be completed using conventional constmction equipment and 
techniques and standard measures to ensure worker health and safety. The relative short-term 
effectiveness achieved by Altemative 3 is greater than that achieved by Altematives 4 and 5, 
because a pilot SVE/AS system is already in-place and would only require minor modifications 
for full-scale implementation. The relative short-term effectiveness provided by Altematives 4 
and 5 is comparable, since both require the installation of groundwater exfraction and freatment 
systems. 
Page -20-
500033 
9.2.6 
Implementability 
In general, all five altematives are implementable. Altemative 1 is the simplest to implement, 
followed in order of ease by Altematives 2, 3, 5, and 4, considering that an operational SVE/AS 
system for Altematives 3 and 4 already exists at the Site. Materials, services, and equipment 
associated with the implementation of each remedial altemative are generally available on the 
U.S. mainland and on larger islands, such as Puerto Rico. Certain units, such as the low-profile 
air stripper (i.e., Altematives 4 and 5), and associated spare parts are somewhat less widely 
available in the Virgin Islands, and would need to be manufactured and shipped from the U.S. 
mainland, necessitating a longer lead time. Also, Altematives 3, 5, and 4 (in that order) are 
increasingly more intensive in terms of operation and maintenance than Altematives 1 and 2. 
9.2.7 
Cost 
Costs for each remedial altemative increase in the following order: Altemative 1, Altemative 2, 
Altemative 3, Altemative 4, and Altemative 5. However, most ofthe capital costs for the 
SVE/AS system associated with Altematives 3 and 4 have aheady been incurred as a result ofthe 
pilot SVE/AS system. 
9.2.8 
Territorial Acceptance 
VIDPNR has been consulted throughout this process and concurs with the Selected Remedy, 
Altemative 3, and the Contingency Remedy, a combination of Altematives 4 and 5 for 
groundwater only. 
9.2.9 
Community Acceptance 
Public comment on the RI, FS, and Proposed Plan was solicited during a formal pubhc comment 
period originally designated from June 27 to July 27,2001. In response to public request for 
additional time, EPA extended the public comment period an additional 15 days tp August 11, 
2001. Comments generally favored the Preferred Altemative. Appendix C contains a summary 
of community responses to the Selected Remedy. 
10.0 PRINCIPLE THREAT WASTES 
The NCP establishes an expectation that EPA will use freatment to address the principle threats 
posed by a Site wherever practicable (NCP Section 300.430(a)(l)(iii)(A)). Identifying principle 
threat wastes combines concepts of both hazard and risk. In general, principle threat wastes are 
those source materials considered to be highly toxic or highly mobile that generally cannot be 
contained in a reliable manner or would present a significant risk to human health or the 
environment should exposure occur. Conversely, non-principle threat wastes are those source 
materials that generally can be reliably contained and that would present only a low risk in the 
event of exposure. The manner in which principle threats are addressed generally will determine 
whether the statutory preference for treatment as a principle element is satisfied. 
Page-21-
500034 
The source materials identified at the Site include contaminated soils and groundwater in the AST 
area. The predominant contaminants of potential concem are ethylbenzene, xylene, and 
chloroform. These source materials constitute principle threat wastes; therefore, the statutory 
preference for treatment is applicable to the AST area. 
In the FPP area, groundwater is impacted by chloroform. However, recent groundwater sampling 
results indicate that the chloroform concenfration has decreased since 1998 to below its MCL as a 
result of natural attenuation, excluding a localized area near temporary monitoring well FPP-
VMP-ID. 
In Spring 2000, a soil vapor extraction/air sparging pilot study was performed at both the AST 
and FPP areas to better assess the effectiveness of SVE/AS freatment in these areas. Results of 
the pilot study supported these conclusions: 
• 
SVE/AS would be an effective technology for removing ethylbenzene and xylene from the 
AST source area soils and groundwater. AS freatment would also enhance the conditions 
for aerobic biodegradation ofthese contaminants. 
SVE/AS would not be effective for freatment ofthe FPP area, based upon the low afr 
permeability of soils and the low chloroform concenfrations remaining in the soils and 
groundwater in this area. 
In addition, recent groundwater samphng (November 2001) in the AST area has shown that 
concenfration of toluene, ethylbenzene and xylenes are below the MCLs. Thus, SVE/AS is a 
reliable remedy to accomplish active source confrol and contaminant mass removal in the AST 
area. Based upon the low concentrations and limited mass of contamination in the FPP area, 
natural attenuation is expected to continue to reduce chloroform levels. 
11.0 SUMMARY OF THE SELECTED REMEDY 
Based upon consideration of CERCLA requirements, the detailed analysis of altematives, and 
public comments, EPA has determined that Altemative 3 (SVE/AS for the AST Area, MNA for 
the FPP Area, and Institutional Confrols) is the appropriate remedy for the Virgin Island Chemical 
Superfund Site. EPA has also selected a contingent remedy in the AST and FPP areas which 
includes a groimdwater exfraction and freatment remedy to assure the MCLs for groundwater are 
achieved in a reasonable time frame. 
11.1 
Rationale for Selected Remedy 
Altemative 3 either meets or exceeds benefits associated with the selecting criteria when 
compared to the other altematives. The Selected Remedy will reduce risk to human health and 
the environment through the following: 
• 
As required, Altemative 3 meets the threshold cleanup evaluation criteria (overall 
protection of human health and the environment and comphance with ARARs). 
Page-22-
500035 
Altemative 3 provides very good long-term effectiveness and permanence. 
Altemative 3 actively controls the source materials and removes contaminant mass in the 
AST area. 
Altemative 3 mitigates the human health risks (defined by the risk assessment). 
Altemative 3 is readily implementable. An operational SVE/AS system for Altemative 3 
aheady exists at the Site. 
Altemative 3 offers a cost-effective solution that meets the cleanup goals for the Site. 
The Selected Remedy achieves the appropriate balance considering Site-specific conditions and 
criteria identified in CERCLA and the NCP. The contingency remedy (Altematives 4 and 5) also 
achieves these criteria. 
11.2 
Description of the Selected Remedy 
The principle components ofthe Selected Remedy (Altemative 3) are as follows: 
SVE/AS for the AST Area 
• 
The existing SVE/AS system will be expanded to actively freat the entire volume of: 1) 
contaminated groundwater exceeding MCLs and 2) contaminated soils exceeding SSLs. 
Air sparging will be used to strip VOCs from groundwater, and soil vapor exfraction will 
be used to recover sparged VOC vapors and to remove VOCs from the unsaturated zone 
soils. 
• 
SVE/AS system performance monitoring will be required throughout the duration ofthe 
system operation and maintenance to verify and monitor freatment system performance 
and to assess remedial progress, as approved by EPA. 
• 
SVE/AS system operation will continue to operate until the EPA's SSLs in soils and 
groundwater MCLs are achieved. It is anticipated that SSLs and MCLs will be achieved 
in less than five years. 
• 
Air discharge criteria and compliance monitoring will be in accordance with federal and 
territorial requirements. 
• 
Achievement of soil cleanup goals will be verified by collecting confirmatory soil samples 
across the impacted area. Sampling will be performed using an appropriate grid system, 
with samples collected at appropriate depth intervals to the water table at each grid node 
within the contaminated area. 
Page -23-
5 0 0 0 3 6 
Long-term groundwater monitoring and reporting will be initially performed on a 
quarterly basis. Groundwater samples will be collected for VOCs analysis, and field 
measurements will be taken for water quality parameters (i.e., dissolved oxygen, 
conductivity, temperature, pH, and oxidation reduction potential) at MW-1, MW-6, MW-
8, MW-10, and at least three additional monitoring wells to be installed at locations 
approved by EPA. Water level measurements will be taken at all existing monitoring 
wells/points. The frequency of long-term monitoring will be subjected to annual review 
and may be modified, as approved by EPA. Long-term groundwater monitoring will 
continue until the groundwater quality achieves MCLs. 
MNA for the FPP Area 
• 
Long-term groundwater monitoring and reporting will be initially performed on a 
quarterly basis. Groundwater samples will be collected for VOCs analysis, and field 
measurements will be taken for water quality parameters at MW-2, MW-7, MW-11, MW-
13, and at least three additional, existing and/or new monitoring wells approved by EPA. 
In addition, samples will be collected for analysis of intrinsic biodegradation parameters 
(e.g., total organic carbon, nifrate, sulfate, ferrous iron, hydrogen sulfide, methane) at 
MW-2, MW-11, and at least two other well locations approved by EPA. Water level 
measurements will be taken at all existing monitoring wells/points. The frequency of 
long-term monitoring will be subjected to annual review and may be modified, as 
approved by EPA. Long-term groundwater monitoring will continue until the 
groundwater quality conforms with MCLs. 
• 
The environmental monitoring results from the FPP area will be used to confirm that the 
VOC plume is attenuating and that its leading edge is not advancing downgradient. 
Downgradient monitoring wells, as identified above, will be used to frack the VOC plume 
exceeding MCLs. The monitoring results will also be compared against feasibility study 
estimates regarding natural attenuation rates, with the results of updated frend analyses 
included as part of quarterly remedial progress reports. 
• 
Groundwater exfraction and freatment has been retained as a contingency remedy for this 
and the AST area, as described in Section 11.3, which will be implemented in the future, if 
warranted based upon monitoring results. The decision to implement the contingency 
remedy will be based upon evidence (e.g. statistical analysis, modeling) that the VOCT 
plume is attenuating at rates that are significantly less than feasibility study predictions 
and that are less than cleanup rates that could otherwise be achieved by the contingency 
remedy. 
Institutional Confrols 
The Department of Planning and Natural Resources in consultation with EPA, will utilize 
institutional confrols (in the form of existing well permitting laws and regulations) to limit 
the pumping of groundwater at the Site to prevent interference with the selected remedy 
Page -24-
500037 
and to also prevent human exposure to contaminated groundwater until MCLs are 
achieved. 
11.3 
Description of Contingency Remedy 
In addition to the Selected Remedy, EPA has retained groundwater exfraction and freatment as a 
contingency remedy for groundwater at the AST and FPP areas. The contingency remedy will be 
implemented in the event that the VOC plume is attenuating at rates that are significantly less than 
feasibility study predictions and that are less than cleanup rates that could otherwise be achieved 
by the contingency remedy. The total capital cost ofthe contingency groundwater remedy for 
the AST and FPP areas is $1,067,840. 
The contingency remedy for the AST Area and FPP Area groundwater includes: 
• 
Installation of one or more groundwater extraction wells to achieve hydraulic confrol of 
groundwater exceeding MCLs and to actively remove VOCs from the aquifer. 
• 
Above-ground treatment of groundwater using air stripping to reduce VOC concenfrations 
below the VIDPNR criteria permitted for subsequent surface water discharge to the River 
Gut. 
• 
Completion of freatment system performance and compliance monitoring and long-term 
groundwater monitoring, as generally described in Section 11.2, until MCLs are achieved. 
12.0 STATUTORY DETERMINATIONS 
Under CERCLA Section 121, EPA must select a remedy that is protective of human health and 
the environment, that complies with ARARs, is cost effective, and uses permanent solutions and 
altemative freatment technologies or resource recovery technologies to frie maximum extent 
practicable. In addition, CERCLA includes a preference for remedies that include freatment as a 
principle element, which permanently and significantly reduces the volume, toxicity, or mobihty 
of hazardous substances. 
12.1 
Protection of Human Health and tbe Environment 
The Selected Remedy will protect human health and the environment through the use of an 
SVE/AS system which will remove ethylbenzene and xylene from the AST source area soils and 
groundwater to achieve MCLs and SSLs. AS freatment will also enhance conditions for aerobic 
biodegradation ofthese contaminants. Natural attenuation will continue to be implemented in the 
FPP area for low-level residual VOC contamination in groundwater. Additionally, institutional 
controls will be implemented at the Site to reduce the potential for human exposure to 
contaminants. These confrols will restrict land and/or groundwater use until the SSLs and MCLs 
are achieved. 
Page -25-
500038 
In addition to source control via SVE/AS, a groundwater exfraction and freatment system to 
capture and freat impacted groundwater at the AST area was considered m the FS process. Ofthe 
two treatment options, SVE/AS freatment was considered more effective for these reasons: (1) 
SVE would rapidly remove and reduce the contaminant source in the unsaturated zone, whereas 
groundwater exfraction alone would not address the unsaturated zone; (2) AS is expected to be 
more effective at removing contaminants from groundwater than conventional groundwater 
extraction and freatment based upon the localized nature of contaminant distribution, higher 
silt/clay content ofthe Site soils, and poor yield ofthe shallow aquifer. AS woiild also better 
facilitate aerobic biodegradation processes via infroduction of air; and (3) SVE/AS would be more 
readily implemented considering that a system is already in place from the pilot study. 
12.2 
Compliance with ARARs 
The Selected Remedy will comply with all ARARs for the Site; no waivers will be necessary. 
The Site groundwater quality will be restored to federal MCLs for drinking water (40 CFR Part 
141), and the impacted subsurface soils will be restored to EPA SSLs (which are TBCs) for 
protection of groundwater quality. The SVE/AS system will operate in accordance with national 
emissions standards for hazardous air pollutants (NESHAPS; 40 CFR Part 161) and territorial afr 
pollution confrol requirements (VIC, Title 12, Chapter 9). Well installation and abandonment will 
be performed in accordance with Territorial requirements (VIC Title 12, Chapter 5). 
12.3 
Cost Effectiveness 
The Selected Remedy is cost-effective and represents a reasonable value for the money to be 
spent. In making this determination, the following definition was used: "A remedy shall be cost-
effective if its costs are proportional to its overall effectiveness" [NCP Section 300.430(f)(ii)(D)]. 
This was accomplished by evaluating the "overall effectiveness" of those altematives that 
satisfied the threshold criteria (i.e., were both protective of human health and the environment and 
ARAR-compliant). Overall effectiveness was evaluated by assessing three ofthe five balancing 
criteria in combination (i.e., long-term effectiveness and permanence; reduction of toxicity, 
mobility, and volume through treatment; and short-term effectiveness). Overall effectiveness was 
then compared to costs to determine cost-effectiveness. The estimated present worth cost ofthe 
Selected Remedy is $1,404,260. A significant portion ofthe capital costs for the SVE/AS system 
associated with the remedy have aheady been incurred as a result ofthe pilot SVE/AS system. 
12.4 
Utilization of Permanent Solutions and Alternative Treatment Technologies (or 
Resource Recovery Technologies) to the Maximum Extent Practicable 
The Selected Remedy utilizes permanent solutions and freatment technologies to the maximum 
extent practicable. In the AST area, the existing SVE/AS system will be used to actively freat and 
remove contaminant mass from AST area soil and groimdwater. SVE/AS provides is a pennanent 
remedy, which will be achieved more quickly than other altematives relying on natural biological 
and/or physical processes alone. In the FPP area, MNA will be implemented to achieve reduction 
in chloroform levels in groundwater comparable to that offered by an active exfraction system. 
Based upon the low concentrations of chloroform remaining in soil and groundwater, natural 
Page-26-
5 0 0 0 3 9 
attenuation is expected to perform similarly in the FPP area over the long-term. Together, 
SVE/AS and MNA provide the highest effectiveness at the least cost. 
Of those altematives that are protective of human health and the environment and comply with 
ARARs, EPA has determined that the Selected Remedy for the Site provides the best balance in 
terms of long-term effectiveness and permanence, treatment, implementability, cost, and territorial 
and community acceptance. 
12.5 
Preference for Treatment as a Principle Element 
An SVE/AS pilot study was performed in Spring 2000 at both the AST and FPP areas to better 
assess the effectiveness of SVE/AS freatment in these areas. The results ofthe pilot test 
supported the conclusions that: (1) SVE/AS would be an effective technology for removing 
ethylbenzene and xylene from the AST source area soils and groundwater, (2) AS freatment 
would also enhance the conditions for aerobic biodegradation ofthese contaminants, and (3) 
SVE/AS would not be effective for freatment ofthe FPP area, based upon the low afr permeability 
of soils and the low chloroform concentrations remaining in the soils and groundwater in this 
area. 
The Selected Remedy satisfies the statutory preference for freatment by using the operational 
SVE/AS system that already exists at the Site to treat groundwater, saturated soil, and unsaturated 
soil at the AST source area. Additionally, MNA will be implemented in the FPP area for low-
level residual VOC contamination in groundwater, supported by recent data which indicate that 
natural attenuation is adequately protective without the need for active treatment. The Selected 
Remedy is both technically practicable and cost effective as a result of implementation ofthe pilot 
system. 
12.6 
Five-Year Review Requirements 
Because contaminated soils and groundwater may remain on-Site above levels that allow for 
unlimited use and unrestricted exposure for approximately 5 years, the Selected Remedy will be 
reviewed no less often than once every five years consistent with Section 121 of CERCLA and 
Section 300.430(f)(4)(ii) ofthe NCP. The 5-year review includes a review ofthe groundwater 
monitoring data and an evaluation as to how well the Selected Remedy is achieving the RAOs and 
ARARs that it was designed to meet. 
13.0 DOCUMENTATION OF SIGNIFICANT CHANGES 
The Proposed Plan for soil and groundwater contamination in the AST and FPP areas at the 
Virgin Island Chemical Superfund Site was released for public comment in June 2001. The 
Proposed Plan identified Altemative 3, Soil Vapor Exfraction/Air Sparging (SVE/AS) with MNA 
and Institutional Confrols, as the Preferred Altemative. Altemative 4 was also identified as the 
Contingency Remedy at that time. Comments were received during the public comment period. 
No significant changes were made to the Preferred Altemative with the exception of including a 
contingent remedy for groundwater in the AST area in the event that the SVE/AS remedy fails to 
Page-27-
500040 
meet performance standards. The contingent remedy shall be groundwater exfraction and 
freatment in the AST and FPP areas to assure that MCLs for groundwater are achieved in a 
reasonable time frame. 
Page -28-
500041 
APPENDIX A 
FIGURES 
500042 
REFERENCE 
1.) MAP TAKEN FROM U.S.G.S. 7.5 MINU-fE QUADRANGLE OF 
CHRIS-nANSTED. VIRGIN ISLANDS. 
2000 
scole 
2000 
feet 
003-6016 
AM 
AS SHOWN 
DATE: 
11/07/00 
US01-029 
DR SUBTIIU: 
03 
SITE LOCATION MAP 
Golder Associates 
VIRGIN ISLAND CHEMICAL SITE 
nouRE 1 
FIGURE 1 
500043 
TW-S >l 
I 
V 
'T' '7' m 111 [T1 frl M m mxsl l?l 1=^ •=• fsi Tsl Tsi Tt! rii M Tal " ° ^ , * • 
L-J ej llJ IJ 111 Id 111 t l I!) ItJ IU W W W W l:'J w w ej w 
"// 
/ / 
I 
LEGEND 
I 
MW-t2 C 
-* 
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s 
I 
1 
( — 1 
( 
1 
<*> <J) 
NOTES 
PRODUCTION WEU. LOCATION 
SHAaOW MONITORING W E U LOCATION 
DEEP MONITORING WELL LOCATION 
STORMWATER INLET 
EXISTING A80VECR0UND STORAGE TANK 
LOCATION 
FORMER ASOVECROUNO STORAGE TANK 
LOCATION 
^ CROSS-SECTION LOCATION 
1.) MONITORING W E a LOCATIONS ARE APPROXIMATE. 
REFERENCE 
1.) DRAWING BASED ON FIGURE 3 - 7 OF THE R.I. 
REPORT ENTITLED "MONITORING VrtU. LOCATION MAP" 
DATED 1 / 1 1 / 9 9 , BY MclAREN/HART, INC. 
SO 
scale 
y 
(»l«rwl»""" 
/ 
003-6016 
AS SHOWN 
07/27/00 
US01-026 
03 
Golder Associaies 
MONITORING WELL 
LOCATION MAP 
VIRGIN ISLAND CHEMICAL SITE 
FIGURE 2 
Ul 
o 
o 
o 
Ul 
FIGURE 3 
Ul 
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o 
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FIGURE 4 
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US01-03S 
o m m u i 
(j3 
Golder Assodaies 
SHALLOW GROUNDWATER 
CONTOUR MAP -10/21/98 
VIRGIN ISLAND CHEMICAL SITE 
500048 
FIGURE 6 
. •.-j..i.7»'*>«f: 
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STREAM 
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™ 
TREE IME 
APPROX. LOCATICM OF CFFS1E WELLS 
SHALLOW HOMTmNO WEU. LOCATION 
ONSITE PRODUCTION WELL LOCATION 
DEEP MCMTtlRINO WEU. LOCATION 
• 
n 
— 
— 
GROUNDWATER CONTOUR (FEET MSL) 
7.79 
GROUNDWATER OEVATION (FEET MSL) 
REFERENCE 
1.) DRAWINO TAKEN FROM RGURE 4 - 9 QF RJ. REPORT 
ENTITLED *DEEP GRdUNDWATER ELEVATION CONTOURS 
OCTOBER 21, 1888*, DATED 02/17/DO AND WATER LEVEL 
MEASUREMENTS TAKEN ON 1 0 / t l / « 8 BY McLAREN/HART, 
Ma 
ISO 
scale 
ISO 
feet 
•-
t 
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003-60ia 
M m 
AM 
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• « « 
AS SHOWN 
• • " 
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•"•- 
Msm-mr 
• l u n e 
03 
Golder Assodates 
DEEP GROUNDWAtER 
CONTOUR MAP -10/21/98 
VIRGIN ISLAND CHEMICAL SITE 
r 
500049 
FIGURE 7 
0.5 
Hydrographs for wells In AST Area 
•MW-8 (Deep) 
+ MW-6 (Shallow) —a—Rainfall 
0.18 
0.00 
1/22/98 
1/24/98 
1/26/98 
1/28/98 
1/30/98 
2/1/98 
2/3/98 
2/5/98 
2/7/98 
2/9/98 
2/11/98 
Date 
18 No.: 
003-6016 
I BY: 
DSL 
I K B ^ M ^ 
OSL 
SAS 
SCALE 
AS SHOWN 
DATE 
07/27/00 
FILE No.: 
Hydrographs.XLS 
01RECT0RY-. 
Golder\FS\Hydrogeo 
Golder Associates 
HYDROGRAPHS FOR SHALLOW AND DEEP 
WELLS IN AST AREA 
VIRGIN ISLAND CHEMICAL SITE 
FIGURE 8 
Hydrographs for wells in FPP Area 
1/22/98 
1/24/98 
1/26/98 
1/28/98 
1/30/98 
2/1/98 
Date 
•MW-7 (Deep) 
•• MW-2 (Shallow) 
• Rainfall 
0.18 
2/3/98 
2/5/98 
2/7/98 
2/9/98 
2/11/98 
JOB No.: 
OR BY: 
003-6016 
OSL 
DSL 
SAS 
SCALE 
AS SHOWN 
DATE; 
07/27/00 
FIL£ No.; 
Hydrographs.XLS 
DIRECTORY. 
Golder\FS\Hydrogeo 
Golder Associates 
HYDROGRAPHS FOR SHALLOW AND DEEP 
WELLS IN FPP AREA 
VIRGIN ISLAND CHEMICAL SITE 
FIGURE 9 
« MW--IO 
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SBAST-6 
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NOTES 
MW-13 
O 
LEGEND 
I.) SOIL BORING LOCAHONS ARE APPR0MMA1E.\ 
\ 
2.) SOIL BORINGS SHOWN WITHM SHAOCO AREA ' 
EXHIBITED OEIECnONS OF EtmUEMZENC ANO XYLENE 
ABOVE MGW SSLS (DAF-10) 
REFERENCE 
I.) DRAWmO BASED ON nCURE 4-11 OF THE RJ. 
REPORT EHPTIED TSnMATtD AREAL EXTENT OF IMPACTEO 
SOIL - AST AREA* M1E0 2/17/00. PROVIDED DT 
MelAREN/HART. MC. 
^ - 
PRODUCTUN WEa LOCATION 
Iff 
SHALLOW MOMIDRINC WEU LOCATION 
O 
DEEP MONITORINO WEU LOCATION 
• 
SOIL BORING SAMPLE LOCATION 
( 
~1 EXISTING ABOVEGROUND STORAGE TANK LOCATION 
C I I J 
FORMER ABOVEGROUND STORAGE TANK LOCATION 
APPRONMAIE AREA OF IMPACTEO SOIL ABOVE SSU 
40 
•cc1« 
003-6016 
MJS 
AS SHOWN 
11/07/00 
USOI-022 
03 
Golder Assodafes 
ESTIMATED AREAL EXTENT 
OF IMPACTED SOIL 
- AST AREA 
VIRGIN ISLAND CHEMICAL SITE 
500052 
FIGURE 10 
TW-5^ 
,TW-4 
,TW-2 
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DQIES: 
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CSTIMAItO CONCENIRAIIOH 
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(rrniKHZCNt - 700 pph, 
nUNt - 10.000 ppk) 
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RcsuiTS rnou ONSIC CC (stPicuaw « « ; ) 
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(SCPTEMSCR •>«;) 
LEGEND 
PRODUCTION W E a LOCATION 
SHAaOW MONITORING W E a LOCATION 
DEEP MONITORING WEU LOCATION 
GEOPROBE GROUNDWATER SAMPLE LOCATWN 
TEMPORARY W E a LOCATION 
—1V>— 
ETHTLBENZENE CONTOUR (ppb) 
I 
I 
EWSTINO ABOVEGROUND STORAGE TANK LOCATION 
NOTES 
1.) FOR COMPARISON, CONCENTRATIONS FROM IHE MAY 
2000 SAMPLING EVENT ARE REPORTED IN PARENTHESES 
NEXT TO W E a ID. A a UNITS ARE ppb. 
REFERENCE 
1.) DRAWINO BASED ON nCURE 4 - 1 3 OF THE R.L REPORT 
ENDTUD "ESTIMATED AREAL EXTENT OF 
ETHYLBENZENE-IMPACTED SHAaOW GROUNDWATER - AST 
AREA* DATED J / 1 7 / 0 0 . PROVIOEO BY McLAREN/HART, INC. 
30 
•cole 
30 
003-6016 
MJS 
AS SHOWN 
11/07/00 
USOI-024 
03 
Golder Assodates 
ESTIMATED AREAL EXTENT OF 
ETHYLBENZENE-IMPACTED SHALLOW 
GROUNDWATER IN 1998 • AST AREA 
VIRGIN ISLAND CHEMICAL SITE 
500053 
FIGURE 11 
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LEGEND 
c 
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CD 
/ — - T 
k 
I 
PROOUCIION w e a 
L O C A T I O N 
SHAUOW MONITORING W E U LOCAHON 
DEEP MONITORINO WELL LOCATION 
GEOPROBE GROUNDWATER SAMPLE LOCATION 
TEMPORARY W E U LOCATION 
XYLENE CONTOUR (ppb) 
EXISTING ABOVEGROUND STORAGE TANK LOCATION 
FORMER ABOVEGROUND STORAGE TANK LOCATION 
NOTES 
I.) FOR COMPARISON, CONCENTOAHONS fHOM THE MAY 
2000 SAMPLING EVENT ARE REPORTED IN PARENTHESES 
NEXT TO WEU 10. 
ALL UNITS ARE ppb. 
REFERENCE 
1.) DRAWING BASED ON PCURE 4 - 1 2 OF TOE R.L REPORT 
ENTTOEO tSDMATED AREAL EXTENT OF XYLENE-IMPACTED 
SHALLOW GROUNDWATER - 
AST AREA' DATED 2 / 1 7 / 0 0 , 
PROVIDED BY McLAREN/HART. INC. 
30 
ftcole 
003-6016 
MJS 
AS SHOim 
11/07/00 
OS01-023 
03 
Golder Associates 
ESTIMATED AREAL EXTENT OF 
XYLENE-IMPACTED SHALLOW 
GROUNDWATER IN 1998 - AST AREA 
VIRGIN ISLAND CHEMICAL SITE 
500054 
FIGURE 12 
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(MAY 2000). 
LEGEND 
•()^ 
PRODUCTION » « U LOCADON 
^ 
SHAUOW MONITORING W E U LOCADON 
D 
DEEP MONITORING WELL LOCATION 
•• 
GEOPROBE GROUNDWATER SAMPLE LOCATION 
— t o — 
CHLOROFORM CONTOUR (ppb) 
NOTES 
1.) FOR COMPARISON. CONCENTRADONS FROM IHE 
MARCH ANO MAY 2 0 0 0 SAMPLING EVENT ARE REPORTED 
IN PARENTHESES NEXT TO WEU ID. 
A U UNITS ARE ppb. 
REFERENCE 
1.) DRAWING BASED ON FIGURE 4 - 1 6 OF THE R.I. REPORT 
ENDTLED "ESDMATED AREAL EXTENT OF 
CHLOROFORM-IMPACTED SHAUOW GROUNDWATER - 
AST 
AREA" DATED 2 / 1 7 / 0 0 . PROVIDED BY McLAREN/HART. INC. 
003-6016 
11/07/00 
USOI-025 
03 
Golder Associates 
ESTIMATED AREAL EXTENT OF 
CHLOROFORM-IMPACTED SHALLOW 
GROUNDWATER IN 1998 - PROCESS PIT AREA 
VIRGIN ISLAND CHEMICAL SITE 
15 
500055 
FIGURE 13 
APPENDIX B 
TABLES 
500056 
W 
^ T a b l e l 
^ 
^ 9 
Summary of Chemicals of Concern IVl^edium-Speciflc Exposure Point Concentrations ^ F 
Scenario Timeframe: 
IVIedium: 
Exposure IVIedium: 
Exposure Point 
Soil On-Site 
Chemical of 
Concern 
Arsenic 
Chromium 
Future 
Surface Soil 
Surface Soil/Air 
Concentration 
Detected 
Min 
0.81 
14.8 
IVIax 
8.8 
32 
Units 
mg/l<g 
mg/l<g 
Frequency 
of 
Detection 
6/8 
12/12 
Exposure Point 
Concentration 
1 
6.83 
26 
Exposure Point 
Concentration 
Units 
mg/l<g 
mg/l<g 
Statistical 
IVIeasure 
95th UCL-T 
95th UCL-N 
Key 
95th UCL-T: 95% Upper Confidence Limit, lognormal distribution 
95th UCL-N: 95% Upper Confidence Limit, normal distribution 
Ul 
o 
o 
o 
cn 
•J 
• 
^ 
Table 2 
Summary of Chemicals of Concern^p Medium-Specific Expos 
Scenario Timeframe: 
Medium: 
Exposure Medium: 
Exposure 
Point 
Local Aquifers 
Chemical of 
Concern 
Chlorofonn 
Methylene Chloride 
Arsenic 
Iron 
Manganese 
Future 
Groundwater 
Local Aquifers 
Concentration 
Detected 
Min 
2 
2 
2 
31 
10.2 
Max 
3880 
4300 
5.2 
10100 
3570 
Units 
ug/L 
ug/L 
ug/L 
ug/L 
ug/L 
Frequency of 
Detection 
39/79 
5/79 
5/24 
18/24 
23/23 
ure Point Concentrations ^ 1 ^ 
Exposure Point 
Concentration 
1 
865 
40 
1.4 
10100 
1614 
Exposure Point 
Concentration 
Units 
ug/L 
ug/L 
ug/L 
ug/L 
ug/L 
Statistica 
Measure 
95th UCL-" 
95th UCL--
95th UGL-1 
MAX 
95th UCL-r 
Key 
95th UCL-T: 95% Upper Confidence Limit, lognormal distribution 
95th UCL-N: 95% Upper Confidence Limit, normal distribution 
MAX: Maximum detected concentration 
Ul o 
o 
o 
U l 
CO 
Ul 
o 
o 
o 
Ul 
vo 
^ 
Table 3 
C i f l p r Toxicity Data 
i • 
Pathway: Ingestion, Dermal 
1 
Chemical of Concern 
Chloroform 
Methylene Chloride 
Arsenic 
Oral 
Cancer 
Slope 
Factor 
6.1 E-03 
7.5E-03 
1.5E+00 
Dermal 
Cancer 
Slope 
Factor 
6.1 E-03 
7.5E-03 
1.47E+00 
Slope Factor 
Units 
1/mg/kg/d 
1/mg/kg/d 
1/mg/kg/d 
Weight of 
Evidence/Cancer 
Guideline Description 
B2 
B2 
A 
Source 
"IRIS 
IRIS 
IRIS 
Date (mm/dd/yy) 
01/15/99 
01/15/99 
01/15/99 
Pathway: Inhalation 
Chemical of Concern 
Chloroform 
Methylene Chloride 
Arsenic 
Chromium VI 
Unit 
Risk 
2.3E-05 
4.7E-07 
4.3E-03 
1.2E-02 
Units 
ug/m3 
ug/m3 
ug/m3 
ug/m3 
Inhalation 
Cancer Slope 
Factor 
8.1 E-02 
1.65E-03 
1.51E+01 
4.2E+01 
Units 
1/mg/kg/d 
1/mg/kg/d 
1/mg/kg/d 
1/mg/kg/d 
Weight of 
Evidence/Cancer 
Guideline Description 
B2 
82 
A 
A 
Source 
IRIS 
IRIS 
IRIS 
IRIS 
Date 
(mm/dd/yy) 
01/15/99 
01/15/99 
01/15/99 
09/03/98 
Key 
IRIS: Integrated Risk Information System, U.S. EPA 
EPA Weight of Evidence Group: 
A - Human carcinogen 
81- Probable human carcinogen 
82 - Probable human carcinogen 
C - Possible human carcinogen 
D - Not classified as a human carcinogen 
E - Evidence of noncarcinogenicity 
limited human data are available 
sufficient evidence in animals and inadequate or no evidence in humans 
Ul 
o 
o 
o 
a\ 
o 
m 
Pathway: Ingestion, 
Chemical of 
Concem 
Chloroform 
Methylene Chloride 
Arsenic 
Chromium 
Iron 
Manganese 
Demnal 
Chronic/ 
Subchronic 
Chronic 
Chronic 
Chronic 
Subchronic 
Chronic 
Chronic 
Oral RfD 
Value 
1E-02 
6E-02 
3E-04 
3E-03 
3E-01 
2E-02 
Iable4 
Noncan^HoxIclty Data 
Oral RfD Dermal RfCAJermal RfD 
Units 
Units 
mg/kg/d 
mg/kg/d 
mg/kg/d 
mg/kg/d 
mg/kg/d 
mg/kg/d 
1E-02 
6E-02 
2.94E-04 
6E-05 
3E-02 
2E-03 
mg/kg/d 
mg/kg/d 
mg/kg/d 
mg/kg/d 
mg/kg/d 
mg/kg/d 
Primary Target Organ 
Liver 
Liver 
Skin 
NOAEL 
LIver/Hearl/Pancreas 
CNS 
Combined 
Uncertainty/ 
Modifying 
Factors 
1000/1 
100/1 
3/1 
300/3 
1/NA 
NA/3 
Sources of RfD: Target 
Organ 
IRIS 
IRIS 
IRIS 
IRIS/Hmdey et al., 1996 
NCEA 
IRIS 
• 
Dates of RfD: 
Target Organ 
(mm/dd/yy) 
01/15/99 
01/15/99 
01/15/99 
09/03/98 
07/23/96 
09/26/98 
Pathway: Inhalation 
Chemical of 
Concem 
Chloroform 
Methylene Chloride 
Chromium 
Manganese 
Chronic/ 
Subchronic 
Chronic 
Subchronlc/Chronic 
Subchronic 
Chronic 
Inhalation 
RfC 
3E-04 
3E+00 
3E-05 
5E-05 
Inhalation 
RfC Units 
mg/m3 
mg/m3 
mg/m3 
mg/m3 
Inhalation 
RfD 
8.6E-05 
8.6E-01 
3E-05 
1.43E-05 
Inhalation 
RfD Units 
mg/kg/d 
fng/kg/d 
mg/kg/d 
mg/kg/d 
Primary Target Organ 
Liver/Kidney 
Liver 
Lung 
CNS 
Combined 
Uncertainty/ 
Modifying 
Factors 
1000/NA 
100/NA 
300/1 
1000/1 
Sources of RfC:RfD: 
Target Organ 
NCEA 
HEAST 
HEAST 
HEAST 
Dates 
(mm/dd/yy) 
12/01/97 
07/01/97 
07/01/97 
07/01/97 
Key 
IRIS: Integrated Risk Information System, U.S. EPA 
HEAST: Health Effects Assessment Summary Tables, U.S. EPA 
NCEA: National Center for Environmental Assessment 
NOAEL: No Observed Adverse Effect Level 
CNS: Central nervous system 
Scenario Timeframe: 
Receptor Population: 
Receptor Age: 
Medium 
Groundwater 
Exposure 
Medium 
Groundwater 
Air 
Surface Soil 
Surface Soil 
Risk Charactei 
^ ^ Table 5 
H l o n Summary -
Future 
Industrial/Commercial Worker 
Adult 
Exposure 
Point 
Local Aquifers 
Local Aquifers 
Chemical of 
Concern 
Chloroform 
Methylene Chloride 
Arsenic 
Chloroform 
Surface Soil 
lArsenic 
Carcinogens 
• 
Carcjnogenic Risk 
Ingestion 
2E-05 
1E-06 
9E-06 
N/A 
Inhalation 
N/A 
N/A 
N/A 
8E-04 
Dermal 
4E-06 
1E-07 
4E-10 
N/A 
Groundwater risk total =: 
2E-06 
~ 
7E-07 
Soil risk total = 
Total risk = 
Exposure 
Routes 
Total 
3E-05 
1E-06 
9E-06 
8E-04 
9E-04 
2E-06 
2E-06 
9E-04 
Key 
—: Toxicity criteria are not available to quantitatively address this route of exposure 
N/A: Route of exposure is not applicable to this medium. 
cn 
o o 
o 
a\ 
i-» 
Ul 
o 
o 
o 
a\ 
to 
^ 
Table 6 
^ 
Risk Charactei^Pion Summary - Carcinogens 
^ P 
Scenario Timeframe: 
Receptor Population: 
Receptor Age: 
Medium 
Surface Soil 
Exposure 
Medium 
Surface Soil 
Air 
Future 
Trespasser 
Adult 
Exposure 
Point 
Surface Soil 
Surface Soil 
Chemical 
of Concern 
Arsenic 
Arsenic 
Chromium 
Carcinogenic Risk 
ingestion 
9E-07 
N/A 
N/A 
Inhalation 
N/A 
5E-10 
5E-09 
Dermal 
2E-07 
N/A 
N/A 
Soil risk total = 
Total risk = 
Exposure 
Routes 
Total 
1E-06 
5E-10 
5E-09 
1E-06 
1E-06 
Key 
N/A: Route of exposure is not applicable to this medium. 
• 
Scenario Timeframe: 
Receptor Population: 
Receptor Age: 
Medium 
Groundwater 
Exposure 
Medium 
Groundwater 
Air 
^ T a b l e ? 
^ 
Risk CharacteriWon Summary - Carcinogens 
^ ^ 
Future 
Resident 
Adult 
Exposure Point 
Tap Water 
Water Vapors Via Bathing 
Chemical of Concern 
Chloroform 
Methylene Chloride 
Arsenic 
Chloroform 
, Carcinogenic Risk 
Ingestion 
7E-05 
4E-06 
3E-05 
N/A 
Inhalation 
N/A 
N/A 
N/A 
2E-04 
Dermal 
1E-06 
4E-08 
1E-10 
N/A 
Groundwater risk total = 
Total risk= 
Exposure 
Routes 
Total 
8E-05 
4 E-06 
3E-05 
2E-04 
3E-04 
3E-04 
Key 
N/A: Route of exposure is not applicable to this medium. 
Ul o 
o 
o 
a\ 
U) 
• 
Risk Characterizat ifl|5ummary - Carcinogens 
• 
Scenario Timeframe: 
Future 
Receptor Population: 
Resident 
Receptor Age: 
Child 
Medium 
Groundwater 
Exposure 
Medium 
Groundwater 
Air 
Exposure Point 
Tap Water 
Water Vapors Via Bathing 
Chemical of 
Concern 
Chloroform 
Methylene Chloride 
Arsenic 
Chloroform 
Carcinogenic Risk 
Ingestion 
4E-05 
2E-06 
2E-05 
N/A 
Inhalation 
N/A 
N/A 
N/A 
9E-05 
Dermal 
5E-07 
1E-08 
5E-11 
N/A 
Groundwater risk total: 
Total risk: 
Exposure 
Routes 
Total 
4E-05 
2E-06 
2E-05 
9E-05 
2E-04 
2E-04 
Key 
N/A: Route of exposure Is not applicable to this medium. 
Ul o 
o 
o 
cn 
^ ^ 
Table 9 
^ P 
Risk Characterizat^^Bummary - Carcinogens 
• 
Scenario Timeframe: 
Future 
Receptor Population: 
Resident 
Receptor Age: 
Adult+Child 
Medium 
Groundwater 
Exposure 
Medium 
Groundwater 
Air 
Exposure Point 
Tap Water 
Water Vapors Via Bathing 
Chemical of 
Concern 
Chloroform 
Methylene Chloride 
Arsenic 
Chloroform 
Carcinogenic Risk 
1 
ingestion 
1E-04 . 
7E-06 
5E-05 
N/A 
Inhalation 
N/A 
N/A 
N/A 
3E-04 
Dermal 
2E-06 
4E-08 
2E-10 
N/A 
Groundwater risk total: 
Total risk: 
Exposure 
Routes 
Total 
1E-04 
7E-06 
5E-05 
3E-04 
5E-04 
5E-04 
Key 
N/A: Route of exposure is not applicable to this medium. 
Ul 
o 
o 
o 
o\ 
Ul 
V 
«e10 
^ 
^ 
Risk CharacterizatlorWnmmary - Non-Carcinogens 
^ | F 
Scenario Timeframe: 
Receptor Population: 
Receptor Age: 
Medium 
Groundwater 
Exposure 
Medium 
Groundwater 
Air 
Future 
Industrial/Commercial Worker 
Adult 
Exposure Point 
Local Aquifers 
Local Aquifers 
Chemical of 
Concern 
Chloroform 
Manganese 
Chloroform 
Primary 
Target 
Organ 
- Liver 
CNS 
Liver 
Non-Carcinogenic Hazard Quotient 
ff 
Ingestion 
1.0E+00 
9.5E-01 
N/A 
Inhalation 
N/A 
N/A 
3.3E+02 
Dermal 
2.0E-01 
2.1E-01 
N/A 
Groundwater Hazard Index TotaN 
Receptor Hazard Index = 
Liver Hiazard Index = 
CNS Hazard Index = 
Exposure 
Routes 
Total 
1.2E+00 
1.2E+00 
3.3E+02 
3.3E+02 
3.3E+02 
3.3E+02 
1.2E+00 
Key 
N/A: Route of exposure is not applicable to this medium. 
Ul 
o o o cn 
cn 
^ 
U|le11 
W ^ 
Risk Characferizafior^Pmmary - Non-Carcfnogens 
• 
Scenario Timeframe: 
Future 
Receptor Population: 
Resident 
Receptor Age: 
Adult 
Medium 
Groundwater 
Exposure 
Medium 
Groundwater 
Air 
Exposure Point 
Tap Water 
Water Vapors Via Bathing 
Chemical of 
Concern 
Chloroform 
iron 
Manganese 
Chloroform 
Primary Target 
Organ 
Liver 
Liver/Heart/Pancreas 
CNS 
Liver 
Non-Carclnogenic Hazard Quotient 
Ingestion 
2.8E+00 
1.1E+00 
2.7E+00 
N/A 
Inhalation 
N/A 
N/A 
N/A 
6.4E+01 
Dermal 
4.8E-02 
2.1 E-02 
5.0E-02 
N/A 
Groundwater Hazard Index Tota'= 
Receptor Hazard Index = 
Liver Hazard Index = 
CNS Hazard Index = 
Heart/Pancreas Hazard Index = 
Exposure 
Routes 
Total 
2.9E+00 
1.1E+00 
2.7E+00 
6.4E+01 
7.1E+01 
7.1E+01 
6.8E+01 
2.7E+00 
1.1E+00 
Key 
N/A: Route of exposure is not applicable to this medium. 
Ul 
o o o cn 
-J 
^ 
-^316 12 
^ P 
Risk Characterlzatior^Bnmary - Non-Carcinogens 
• 
Scenario Timeframe: 
Future 
Receptor Population: 
Resident 
Receptor Age: 
Child 
Medium 
Groundwater 
Exposure 
Medium 
Groundwater 
Air 
Exposure Point 
Tap Water 
Water Vapors Via Bathing 
Chemical of 
Concern 
Chloroform , 
Iron 
Manganese 
Chloroform 
Primary Target Organ 
Liver 
Liver/Heart/Pancreas 
CNS 
Liver 
Non-Carclnogenic Hazard Quotient 
Ingestion 
8.3E+00 
3.2E+00 
7.7E+00 
N/A 
Inhalation 
N/A 
N/A 
N/A 
1.5E+02 
Dermal 
8.9E-02 
3.9E-02 
9.3E-02 
N/A 
Groundwater Hazard Index Total= 
Receptor Hazard Index = 
Liver Hazard Index = 
CNS Hazard Index = 
Heart/Pancreas Hazard Index = 
Exposure 
Routes 
Total 
8.4E+00 
3.3E+G0 
7.8E+00 
1.5E+02 
1.7E+02 
1.7E+02 
1.6E+02 
7.8E+00 
3.3E+00 
Key 
N/A: Route of exposure is not applicable to this medium. 
Ul 
o o o cn 
00 
TABLE 13 
/ 
ARARx/TBCs 
Virgin Islands Chemical Site, Si. Croix, USVI 
Chemical-Specific ARARs/TBCs; 
Constituent 
of 
Concern 
Groundwater: 
Cblorofofm 
Arsenic 
Ethylbenzene 
Methylene CWoride 
Xylene 
Subsurface Soil: 
Ethylbenzene 
Xylene 
Prelimi lary 
Remei iial 
GoJl 
100 ug/l 
50 ug/L 
700 ug/L 
5 ug/L 
10,000 u?/L 
6.500 ug/kg 
90,000 ug/kR 
Reference 
40 CFR Part 141 - Primary MCLs 
40 CFR Part 141 - Primary MCXs 
40 CFR Part 141 - Primary MCLs 
40 CFR Part 141 - Primary MCLs 
40 CFR Pan 141 - Primary MCLs 
EPA SSL methodology, migration to groundivater pathway 
EPA SSL methodology, micration to groundwater pathway^ 
Action-Soeciflc ARARs/TBCs: 
Action 
Earthwork 
Air discharge from the SVE/AS system 
Well installation 
Hazardous waste management 
Hazardous waste tfansporution 
Contracfor health and safety 
Regulation 
VIC, Title 12, Chapter 13. Sections 533 and 534 
vie, Title 12, Secuon 206-20 
40 CFR Part 161 (NESHAPS) 
vie; Title 12, Section 157 (driller requirements) 
vie; Title 12, Part 161 (well sealing requirements) 
vie. Title 19, Pan FV, Chapter 58 
49 CFR Parte 107 and 171.1 . 171.500 
29 CTR 1926 (OSHA) 
Location-Spefifie ARARsH-BCs; 
Location 
Work within flood plains and wetlands 
Work within coastal zones 
Regulation 
Executive Order 11988 and 11990 
16 u s e 1451 (Coastal Zone Management Act) 
15 CFR 298 
40 CFR 6.302(d) 
Notes: 
ARARs - Applicable or Relevant aiul Appropriate Requirements 
CFR • Code of Federal Regulations 
MCLs - Maximum Contaminant Levels 
NESHAPS • National Emissions Standards for Hazardous Air Pollutants 
OSHA - Occupational Health and Safety Act 
SSL - Soil Screening Level 
SVE/AS • Soil Vapor Extraction/Air Sparging 
TBCs - To Be Considered criteria 
ug/kg - microgram per kilogram 
ug/L - microgram per liter 
u s e > United Stales Code 
VIC - Virgin Islands C^ode 
500069 
Table IT Summary of Analytes Detected in Soli above Screening Levels 
Virgin Island Chemical SKe, St. Croix, U.S. Virgin Islands 
Area of Site 
Medium 
Parameter 
Screening 
Level 
Sample ID 
Sample 
Date 
Sample Interval 
Concentration 
(n bis) 
VOC Constltuehts lln ua/Kal 
AST Area 
Subsurface Soil 
Ethylbenzene 
13,000= 
Xylenes (totaO 
190,000* 
SBB-1 
SBB-2 
S8B.4 
S88.4 
SBB-4 
S8B-11 
S88-17 
SBB-17 
Sa^ST•2 
SBB-1 
SBB-4 
SB6-4 
S8B-11 
SBB-17 
SBB-17 
Jan-85 
May-86 
May-ge 
May-86 
May-86 
li«ay-86 
May-96 
May.96 
Jun-97 
Jan-SS 
May-96 
May-96 
May-86 
May-96 
May-96 
6-8 
22-24 
10-12 
12-14 
20-22 
20-22 
14-16 
20-22 
8-10 
6-8 
12-14 
20-22 
20-22 
14-16 
20-22 
57,000 
32,000 
150,000 
100,000 
170,000 
58,000 DJ 
320,000 
270,000 
34,000 DEJ 
310,000 E 
630,000 
980,000 
320,000 D 
2.000,000 EJ 
1,600,000 EJ 
SVOC CcnsBtuents lln UQ/XQI 
Former Laboratory 
PtArea 
Suifaes Soil 
Pentachlorophanol^ 
30= 
Storm Drains 
Surface Soil 
Isophorone' 
500= 
Inorganic ComDounds (In mofltol 
S8F-3 
SOSSO-2 
Jan-85 
Oct-87 
River Gut (Fairplains) 
Surface Soil 
Arsenic' 
1.64' 
ASTArea 
Subsurlaoe Soi 
Cyanide' 
40= 
FPG-2 
Sep-87 
0-1 
1,800 J 
2500 
ASTArea 
Fonner Drum Area 
Former Laboratory 
Pit Area 
Storm Drains 
Surface Soil 
Surface Soil 
Surface Soil 
Surface Soil 
Iron' 
Manganese' 
Iron' 
Iron' 
Iron' 
Arsenic' 
31933' 
i,«oo' 
31833' 
31933' 
31833' 
1.64' 
SB8-1 
SBE-1 
SBB-1 
SBD-4 
S8F-3 
SDCSD-2 
SCCSO-2 
SOCSO-3 
Jan-85 
Jan-85 
Jan-85 
Jan-85 
Jan-85 
Oet-97 
Oc»-87 
Oet-87 
0-1 
0-2 
0-1 
0-1 
0-1 
0-1 
0-1 
0-1 
32,100 'J 
32,200'J 
1,860 
37,300-J 
63,400-J 
58,800 
8.8 
3.7 
Z 8 J 
Farmer Drum Area 
Subsurface Soil 
Cadmium* 
SB8-1 
SB8-1 
SBE-1 
SB640-1 
Jan-85 
Jan-85 
Jan-85 
Jun-87 
6-8 
24-26 
20-22 
10-12 
60.2 N*J 
47.3 N-J 
51.7 
10.1 • 
'Site-specific bacKground level 
^SB>A RBC: Risk-based saeening cortoentration 
=USEPA SSL- Based on migration to groundwater pathway. No SSL has been established for total xylenes, so the most conservative 
value for an isomer (o-xylene) has been used for screening purposes. 
'Chemical does not constitute signHkant risk based on she risk assessment (McLaren-Hart 2000). 
'Arsenic, iron and manganese were induded in the Human Health Risk Assessment However, all rials and hazards assodated 
with exposure to these chemicals are vMin ^ A ' s acceptable levels and are not considered to be a heaRh concern. 
D - Analyte quantitatad at a dIutxNt. 
E - Exceeded calbratian range of instrument 
J • Estimated value. 
N - Spile recovery not wihin control UmMiu 
na - data not available 
* - Duplicate analysis not VMthin control imits. 
• • Not applicable 
ft bis - feet below land surface 
500070 
O.AOin-6OlCVaCU»llVI'n0i4gni1KOD T d t e J d l 
Golder Associates 
P a g e l o T I 
Table 15. Summary of Analytes Detected In Groundwater above Screening Levels 
Virgin Island Chemical Site, St. Croix, U.S. Virgin Islands 
Area of SHe 
Parameter 
Screening 
Level 
Well ID 
Sample 
Date 
Concentration 
VOC Constituent5 lln uoILl 
FPP Area 
Chloroform 
100-
ASTArea 
EthyH>enzene 
700' 
Xylenes(total) 
10,000* 
MW-2 
MW-2 
MW-2 
MW-2 
MW-2 
MW-2 
^m-^ 
MW-1 
MW-1 
MW-1 
MW-1 
MW-1 
MW-1 
MW-6 
MW-6 
MW.« 
MW-6 
MW-6 
MW-6 
MW-6 
MW-1 
MW-1 
MW-1 
MW-I 
MW-1 
MW-1 
MW-6 
MW-6 
MW-6 
MW-6 
MW-6 
MW-6 
MW-6 
Jun-96 
Jan-9e 
Mar.88 
Oct-98 
Oct-98 
Mar-00 
Fel>-95 
Jan-98 
Mar-88 
Mar-00 
Jun-01 
Aufl-OI 
Nov-01 
Jun-96 
Jan-98 
Mar-S8 
Mar-00 
Jun-01 
Aug-01 
Nov-01 
Jan-98 
Mar-88 
Mar-00 
Jun-01 
AuB-01 
Nov-01 
Jun-96 
Jan-98 
Mar-88 
Mar-00 
Jun-01 
Aug-01 
Nov-01 
470 
1500J 
2400 
150 
580 
37 
750 
20,000 
18,000 
19,600 
28.000 
3,500 
f70 
23,000 
22,000 
20,000 
12.400 
26,000 
12,000 
« 
86,000 
80,000 
89,000 
130,000 
24,000 
(SO 
27,000 
110,000 
98,000 
60,700 
150,000 
83,000 
ta 
Inorganic Comoounds (In uo/LI 
Fonner O u m Areas 
Upgradient of Site 
ASTArea 
Leacf 
Lead= 
Antimon/ 
15' 
15' 
e' 
MW-5 
MW-5 
MW-5 
MW-5 
MW-10 
MW-10 
Feb-95 
May-95 
Jan-g8 
Mar-98 
Jan-98 
Mar-88 
17 
20.3 S 
».7U 
1.1 U 
7 J U 
50.7 
MW-6 
Jan-98 
' Sol! Vapor Extraction and Air Sparging system operated in the AST Area t>eginning June, 2(X)1. 
Wells MW-1 and MW-6 monitor effectiveness of system. 
6.2 B 
Data in bold italics does not exceed screening levels and is included to show recent data trends. 
'Treatment Technk^e Action Level (intended fOr applicabon to tap water concentratnns) 
¥ederalMCL 
*Chem\ca\ does not constitute significant risk t>ased on site risk assessment (McLaren-Hart, 2000). 
6 • Result is t>etween instrument detection limit and Contract Required Detection Limit 
J - Estimated value. 
S • Determined by Method of Standard Addttions. 
U - Analyte not detected The minimum quantitation limit is listed. 
500071 
a^ao}.eolevxuxs.v^ljMelmROD Trtiieudi 
Colder Associates 
Page 1 of 1 
GROUNDWATER SAMPLING RESULTS 
AST AREA SOIL VAPOR EXTRACTION/AIR SPARGING SYSTEM MONITORING WELLS 
VIRGIN ISLAND CHEMICAL SITE, ST. CROIX, U.S. VIRGIN ISLANDS 
Volatile Organics 
Ethylbenzene 
Toluene 
Total Xylenes 
Total TEX 
MCL' 
700 
1000 
10000 
MW-1 
Baseline 
6/6/2001 
28000 
320 
130000 
158320 
3rd Quarter 
8/6/2001 
3500 
72 
24000 
27500 
U 
4th Quarter 
11/14/2001 
170 
10 
850 
1020 
U 
MW-6 
1 
Baseline 
6/6/2001 
26000 
1300 
150000 
176000 
U 
3rd Quarter 
8/6/2001 
12000 
390 
83000 
95000 
U 
4th Quarter 
11/14/2001 
6 
1 
63 
69 
^^^ 
l! 
Volatile Organics 
Ethylbenzene 
Toluene 
Total Xylenes 
Total TEX 
MCL' 
700 
IOOO 
10000 
AST-VMP-ID 
Baseline 
6/6/2001 
180 
2 
550 
732 
3rd Quarter 
8/6/2001 
30 
7 
1900 
1900 
U 
U 
4th Quarter 
11/14/2001 
2 
2 
9 
2 
U 
U 
AST-VMP-2D 
1 
Baseline 
6/6/2001 
620 
2 
2100 
2722 
3rd Quarter 
8/6/2001 
680 
13 
3100 
3780 
U 
4th Quarter 
11/14/2001 
2 
0.5 
18 
20 
II 
Ul 
o 
o 
o 
-J 
to 
Volatile Organics 
Ethylbenzene 
Toluene 
Total Xylenes 
Total TEX 
MCL' 
700 
1000 
10000 
AST-VMP-3D 
Baseline 
6/6/2001 
170 
5 
270 
445 
3rd Quarter 
8/6/2001 
34 
1 
160 
194 
J 
U 
J 
4th Quarter 
11/14/2001 
120 
4 
500 
620 
U 
AST-VMP-4D 
1 
Baseline 
6/6/2001 
0.5 
0.5 
0.5 
0 
U 
U 
U 
3rd Quarter 
8/6/2001 
0.5 
0.2 
0.5 
0 
U 
U 
U 
_ ^ 
4th Quarter 
11/14/2001 
0.5 
0.5 
1 
0 
U 
u u 
1 
'MCL - Federal Maximum Contaminant Levels (40 CFR Part 141) 
Notes: 
Units are (ig/L 
Total Xylenes were calculated by the laboratoty. 
Qualifiers were applied to the results by the laboratory or by Golder Associates following data evaluation. 
U = non-detect 
J == estimated 
0:Pra|eclsAX)3401S/6oklerlPMr 
ROD Tebles.xl*/SVE AS 
Colder Associates 
Page 1 of 1 
APPENDIX C 
RESPONSIVENESS SUMMARY 
500073 
RESPONSIVENESS SUMMARY 
The Proposed Plan for the Virgin Island Chemical Superfund Site (the "Site") was released for 
public comment on June 27, 2001. The public comment period was scheduled from Jime 27, 
2001 through July 27,2001. In response to public request, it was extended 15 days to August 11, 
2001. During the public comment period, EPA held one public meeting to discuss the Proposed 
Plan and receive comments on the Selected Remedy. In addition, EPA received three written 
comment on the Proposed Plan during the comment period. This document summarizes the 
questions and concems received during the pubhc comment period. These concems have been 
grouped into several categories for ease of discussion. EPA's response to each comment follows 
in itahcs. 
Residences/Businesses in Site Vicinity 
1. 
One commenter wanted to know if the two residential communities referred to in the 
Proposed Plan as being north and northwest ofthe Site are the communities of Bethlehem 
and Profit. 
Estate Bethlehem and Estate Profit are the two residential communities referred to in the 
Proposed Plan. 
2. 
Several people mentioned that a sheep farm is located next to the Site. They reported that 
sheep and goats grazed from the Site prior to it being fenced and asked if EPA had 
approached the farm's owners. 
EPA did not contact the farm owners. However, at EPA's request, the parties performing 
the RI/FS did secure the Site area with a fence in April 2000. 
3. 
A resident was concemed that a water service company is located next to the Site. 
EPA is aware ofthe water service company's well (Carina Well) and its activities. The 
Carina well was installed during the fourth phase ofthe Rlfor the Site, within the past two 
years. The Water Service Company (Carina) was required ta apply far territory permits 
to drill the well and to pump the well, respectively, bath of which were received and 
approved by the Virgin islands Department of Planning and Natural Resources (DPNR). 
The Carina well is only permitted to pump water far nan-patable use. In addition, the 
company must sample the water on a regular basis far drinking water parameters as part 
of its permit to verify that the water meets drinking water standards. 
EPA conducted an independent check on the Carina well ta verify sampling results 
obtained by Carina. The data show that the groundwater results are below MCLs. 
The Carina well is upgradient ofthe Site. The hydrographs provided as Figures 8 and 9 
ofthe ROD further indicate that the contaminated shallow zone at the Site is not 
influenced by Carina well pumping. 
C-1 
5 0 0 0 7 4 
Health Risks from Site Exposure 
4. 
Several commenters asked whether EPA would investigate reports of heightened incidents 
of ilhiesses such as cancer in the local community to determine if there is a potential link 
to past exposure to Site contaminants. 
EPA explained that the Agency for Toxic Substances and Disease Registry (ATSDR) can 
perform a public health assessment to determine whether any relationship exists between 
current illnesses in the community and historical exposures to the Site. EPA offered ta 
provide concemed residents with a contact name at ATSDR to call and request this 
service. 
EPA also repeated that the Site does not pose any unacceptable risks under the current 
use exposures at bath an-Site and off-Site locations. The contamination at both the 
Former Process Pit (FPP) area and the Aboveground Storage Tank (AST) area exist 
below the ground surface, within the unsaturated subsurface soils and groundwater, and it 
has remained predominantly on the Site. Within the groundwater itself, the contamination 
is limited to the upper aquifer, which is not in direct communication with the deeper 
aquifer. Also, the groundwater flows away from residential communities in the Site 
vicinity. Lastly, groundwater at the Site is nat used for drinking purposes. Currently, the 
Site is unoccupied and fenced. 
5. 
Another person suggested that EPA conduct a study of persons who consumed sheep from 
the farm next to the Site to determine the existence of any adverse health effects. 
This was not identified as a potentially significant exposure by ATSDR in their Public 
Health Assessment, therefore ATSDR has determined that such a study is not warranted. 
6. 
One person wanted to know the specific health effects of exposure to chloroform, 
ethylbenzene and xylene. 
Short-term effects from exposure ta chlaroform via inhalation include central nervous 
system effects, such as dizziness, fatigue, and headaches. Long- term exposure to 
chloroform via inhalation ar ingestion may result in liver or kidney damage. Dermal 
contact with large amounts of chloroform may result in skin rashes. EPA has identified 
chloroform as a probable human carcinogen, based on the results of animal studies. 
Exposure to ethylbenzene may result in central nervous system effects such as dizziness, 
throat and eye irritation, and liver ar kidney effects. Short-term and long-term exposure 
to high levels of xylenes may cause central nervous system effects such as headaches, lack 
of muscle coordination, dizziness, confusion, and impairment of balance. Also, eye, nose, 
and throat irritation, skin rashes, and liver or kidney damage are associated with 
exposure to xylenes. 
C-2 
500075 
7. 
Another commenter wanted to know if benzene and xylene are cancer causing or 
carcinogenic compoimds. 
EPA has identified benzene as a known human carcinogen. Xylenes and ethylbenzene are 
not carcinogenic. 
8. 
One resident wanted to know about the odor ofthe three contaminants of concem at the 
Site. 
EPA described ethylbenzene and xylene as having a gasoline smell, and chloroform as 
having a sweet, organic smell. 
9. 
One conmienter asked if EPA could calculate the health risks associated with exposure to 
the Virgin Island Chemical facility when it was still operational. 
EPA has no way of calculating that type of risk at this time. Information which is 
necessary to conduct this type of risk assessment, such as records which provide chemical 
usage and concentrations during the time of facility operation, is not available. 
10. 
One commenter was concemed about the effect of volatile organic compounds (VOCs) on 
communities downwind ofthe Site over time. 
Downwind populations are not at risk. Exposure to chemicals downwind of a Site would 
occur from inhalation of airborne surface soils at the Site. Because ofthe chemical 
properties associated with volatile organic chemicals, they are nat likely ta remain in 
surface sails aver time; they will either migrate ta the groundwater ar volatilize to air 
shortly after they have been introduced to the surface soil. This phenomenon occurs until 
the contaminants in the surface sail are for the most part gone. Therefore, any airborne 
surface soils from the Site would not contain the volatile organic chemicals associated 
with Site activities, because the surface soils no longer contain VOCs.. 
11. 
A commenter asked what EPA means by acceptable levels of risk. 
EPA evaluates exposures based on the potential risk of developing cancer and the 
potential far noncancer health hazards. Ihe likelihood of an individual developing cancer, 
is expressed as a probability. Current Superfund guidelines for acceptable levels of risk 
are an individual lifetime excess cancer risk in the range of 10^ to 10^, corresponding ta 
a one-in-ten-thousand to a one-in-a-million excess cancer risk. In other wards, a 1(T* 
cancer risk means one additional cancer may be seen in a population of 10,000 people as 
a result of exposure to Site contaminants. For noncancer health effects, a hazard index 
(HI) is calculated. An HI represents the sum ofthe individual exposure levels compared 
ta their corresponding reference doses. Whenever a noncancer HI is at the "threshold 
level" (measured as an HI less than 1), noncancer health effects are not expected to occur. 
12. 
A commenter wanted to know where she could take her well water for annual testing. 
C-3 
5 0 0 0 7 6 
// is the responsibility of private homeowners ta test their well water. The Virgin Islands 
Department of Planning and Natural Resources (DPNR) is available to provide a list of 
qualified laboratories for this purpose, but the homeowner must make the arrangements 
and assume the sampling and analytical costs. 
Sampling of private residential wells would only be performed by EPA if future 
groundwater monitoring results indicate that the contamination is spreading in the 
direction of such wells. 
13. 
Another commenter asked how she could obtain a copy ofthe public health evaluation 
completed for the Site by ATSDR. 
Persons interested in receiving a copy of this document can call Mr. Arthur Black, ATSDR 
regional representative. His phone number is (212) 637-4307. A copy ofthe report is 
also available in the Repository. 
14. 
Inmates from the Golden Grove Adult Correctional Facility in Kingshill, St. Croix 
submitted a petition expressing concem about health problems within the inmate 
population. The petition cited several symptoms and illnesses that the iimiates believe can 
be attributed to Site contamination, and requested a remedy to address their concems. 
EPA has determined that the contamination at the Site, which is predominantly located 
within the Site property boundary and below the ground surface, does not pose a 
significant off-Site health risk. EPA's remedy will reduce an-Site risk ta acceptable levels. 
Groundwater samples were collected from selected production wells near the Site during 
the RI, which confirmed that the production wells have not been impacted by Site 
contaminants. It is further noted that groundwater flows south-southeast fi'om the Site, 
whereas the Golden Grave Adult Correctional Facility is located northwest (i.e., 
upgradient) ofthe Site. 
Nature/Extent of Site Contamination 
15. 
Several commenter asked whether the groimdwater contamination extends beyond the Site 
boundaries. 
Groundwater contamination is isolated predominantly within the fence line ofthe 
property. A small portion of groundwater contamination extends beyond the fence line. 
Furthermore, the existing data indicates that groundwater contamination is not migrating 
beyond its current boundary. The SVE/AS system is expected to fully treat the 
contaminated groundwater in the AST area, and MNA has been and is expected to 
continue to address the FPP area groundwater.. 
16. 
One commenter read that a gut is present on the Site property and contaminants have 
entered the gut and reached the sea. 
C-4 
500077 
EPA has taken sediment samples from the River Gut, which originates north ofthe Site 
and drains to the Caribbean Sea. The River Gut joins the Bethlehem Gut approximately 
800 feet southeast ofthe Site. They are collectively then called the Fairplain Gut. 
In consultation with the Department of Interior, National Oceanic and Atmospheric 
Administration, sediment samples were taken from at least 25 locations from the facility 
along the River Gut to the ocean. The results showed minimal to no impact from the Site. 
17. 
One commenter asked for an explanation ofthe RI finding that arsenic was detected above 
its risk-based level in surface soil. 
The arsenic levels detected at the Site are naturally occurring, even though these levels 
are above the risk-based level for arsenic. Arsenic is a naturally occurring metal. The 
risk-based level for arsenic for exposure under a commercial/industrial scenario is 3.8 
parts per million. The concentrations of arsenic detected in the sails at the Site range 
from 0.8 parts per million to 8.8 parts per million. These concentrations are within the 
range of naturally occurring arsenic associated with sails ofthe type found at the Site. 
18. 
A commenter wanted to know if toluene, which was detected in earlier investigations at 
the Site, is currently a potential contaminant of concem. 
EPA did nat detect toluene above the MCL in groundwater, therefore, toluene was not 
included as a contaminant of concern. 
19. 
One commenter asked about the effect of rain on benzene and xylene in the AST area, and 
a commenter wanted to know whether samples were taken during rainy and dry seasons. 
A four-phase investigation was completed at the Site, which included multiple 
groundwater sampling events during different seasons to characterize the effects ofthe 
annual precipitation cycle an Site groundwater elevations and contaminant 
concentrations. Enhanced vertical contaminant transport from the unsaturated zone to 
groundwater can occur during rain events. Likewise, recharge of rain water ta the 
aquifer can result in the dilution of contaminant concentrations in groundwater. Hence, 
bath cases cause groundwater contaminant concentrations to fluctuate over time. 
However, locations subjected to signiflcant impact by ethylbenzene and xylene within the 
aquifer would not loose detectable evidence of such impacts after each rain event, as these 
chemicals tend to adsorb to the soils and then leach off more slowly into the groundwater 
over time (i.e., tailing effect). 
20. 
One commenter asked ifEPA had conducted fish tissue sampling. 
EPA did not detect elevated levels of contaminants in sediments in the most recent 
sampling event. Therefore, EPA did not conduct fish tissue sampling. 
C-5 
500078 
21. 
A commenter wanted to know what happened to the drums which were taken from the Site 
during previous removal activities conducted by EPA and Berlex. 
EPA and Berlex transported the drums off-Site ta a permitted hazardous waste disposal 
facility to the U.S. mainland for treatment and disposal. 
22. 
The Committee on Planning & Environmental Protection (CPEP) ofthe 24* Legislature of 
the Virgin Islands would like to know how confident EPA is regarding its conclusion that 
chloroform or any other contaminant of concem does not appear to be migrating off-Site. 
The existing Site data from the Farmer Process Pit area indicate that off-Site groundwater 
quality, downgradient of this area, has nat been impacted by Site contaminants above 
MCLs. The most recent groundwater data further indicate that the current impact ta an-
Site groundwater quality is localized to the immediate area ofthe Former Process Pit and 
is limited to low levels of chloroform that are generally at ar below the federal MCL for 
drinking water. 
The existing Site data from the Above-ground Storage Tank area indicate that the current 
impact to on-Site groundwater quality is localized to the general area between farmer 
tanks T-4 and T-12 and is limited to concentrations of ethylbenzene and xylene that exceed 
MCLs. The existing data further indicate that: 1) off-Site impact to groundwater quality 
above MCLs, downgradient of this area, is limited to within 50 feet ofthe west property 
line that abuts this area and 2) the contaminant plume exceeding MCLs is nat expanding. 
Based an all the data collected, EPA is confident that the contaminants of concerns are 
not migrating. 
Community Involvement in Superfund Process 
23. 
Several commenters felt that EPA does not give the community adequate notice of 
opportunities for public participation, such as public hearings. They suggested that EPA 
run the same public notice in the newspaper over several days and that EPA use radio and 
television to a greater extent, particularly Spanish stations. 
EPA submitted a script in English ta various local radio stations to broadcast for several 
days prior ta the public meeting. EPA also has developed a mailing list of more than 100 
people who attended the last public meeting (1995).. From that list, EPA mailed over 100 
fliers about the public meeting during the couple of weeks preceding the public meeting. 
However, these materials were not translated into Spanish. EPA will consider Spanish 
translation in the future. 
24. 
One commenter questioned whether the public comment period designated from June 27 
to July 27,2001 was sufficient for the public to research and respond to the Proposed Plan. 
According to Superfund law, EPA must provide at least a 30-day public comment period, 
which was announced in the St. Croix Daily News and the St. Croix Avis on June 27, 
C-6 
5 0 0 0 7 9 
2001. In addition, an information repository has been maintained for the Site at the St. 
Croix Campus Library located in the University ofthe Virgin Islands. If the public 
submits a request for additional time, EPA will always grant an extension of time. 
A request for an extension was made and EPA agreed ta extend the public comment period 
far an additional 15 days during the public meeting. The public comment period closed 
on August 11,2001. 
25. 
One commenter wanted to know if residents ofthe Profit and Bethlehem communities and 
inmates ofthe Golden Grove Correctional Facility were informed in advance of potential 
health consequences associated with airbome dust released during drum removal and soil 
excavation activities at the Site. Likewise, EPA should now notify nearby communities of 
upcoming remedial activities so that they can protect themselves from any potential 
contaminant releases. 
Based on the levels of chemicals detected in the soils, exposure ta airbome dust would nat 
have been a concem for downwind communities during the drum removal and sail 
excavation activities. Nevertheless, the public was notified of this removal by publication 
in the Daily News on January 15, 1990. 
EPA makes every effort ta inform the public before initiating an action through press 
releases, fact sheets and public meetings, to name a few. During the Removal Action, 
EPA also issued several press releases on the status ofthe removal action. EPA will 
continue to issue press releases during the remedial action. Further, any potential for 
releases will be controlled using appropriate health and safety procedures in accordance 
with an approved Health and Safety Plan which will be available ta the public. 
Length of EPA Investigation 
26. 
Several commenters wanted to know why it took seven years for EPA to investigate the 
Site and then once the Site was placed on the National Priorities List, another seven years 
to get to this point. 
A farmer tenant. Island Chemical Company (acquired later by Berlex, one ofthe Potential 
Responsible Parties) performed a removal action in the early-1980s. Several 
investigations were conducted by EPA and the former tenant between 1984 and 1991, with 
an additional, more comprehensive removal action completed by EPA from 1989 to 1991 
ta address the immediate threats ta human health and the environment at the Site. EPA 
entered into an Administrative Order on Consent with Berlex and Island Chemical 
Company in 1994 and subsequently added the Site to the NPL in 1996. The remedial 
investigation (RI) ofthe Site was completed in four phases from 1995 to 1998, which fully 
characterized the Site and addressed all potential human health and environmental 
concerns. The feasibility study (FS) was completed from 1999 to 2000, which included the 
performance of a comprehensive sail vapor extraction/air sparging (SVE/AS) pilot study 
C-1 
500080 
at the AST and FPP areas. TheRI and FS reports were finalized in 2001 following 
technical review and comment an the draft reports by EPA and DPNR. 
27. 
One commenter asked if the "delay" had any affect on the contaminants that EPA initially 
found at the Site. 
For this particular Site, EPA has found that the concentration levels ofthe contaminants 
continue ta decrease aver time and predominantly remain limited to discrete areas within 
the Site boundary, despite the fact the initial releases likely occurred mare than 20 years 
ago. For example, groundwater sampling events from last year indicated that chloroform 
concentrations had decreased below the MCL. 
28. 
CPEP is concemed about the length of time it took to characterize the nature and extent of 
contamination at the Site. The committee wanted to know whether any samples were 
collected to determine what contaminants were left at the Site and their corresponding 
concentrations after the 1989 removal action. CPEP notes that the Proposed Plan does not 
indicate whether the data used to characterize Site risks were collected recently or when 
concentrations were higher. CPEP believes that the length of time as well as the recency of 
the data used to drive the risk assessment may have significantly altered the risk 
characterization, as well as the selected preferred remedy. 
The Site conditions existing after the 1989-1991 removal action were characterized in the 
remedial investigation from 1994 to 1998. The risk assessment considered the Site data 
collected during the remedial investigation, as well as conservative exposure scenarios 
corresponding ta bath current and future land use. The remedial investigation report, 
which included the risk assessment, was reviewed and approved by EPA in consultation 
with DPNR. 
The cleanup goals far the Site soils and groundwater are based upon EPA's soil screening 
level methodology and federal MCLs for drinking water, respectively. Hence, the cleanup 
goals are independent ofthe contaminant concentrations detected at the Site during the 
remedial investigation. 
Potentially Responsible Parties 
29. 
One commenter contacted the U.S. Attorney's Office to inquire about prosecution ofthe 
parties who are potentially responsible for the Site contamination. The caller was told that 
the statute of limitations had run out at the Site. She wanted to know why EPA had not 
informed the U.S. Attomey's OfiBce of potential criminal activity at the Site in a timely 
fashion. Several community members shared their view that the people ofthe Virgin 
Islands should be compensated for their loss of natural resources. 
EPA has na evidence at this time ta suggest that a criminal prosecution is warranted. 
EPA has worked closely with the Virgin Islands Department of Planning and Natural 
Resources (VIDPNR) ta keep the local agency informed about the Site. Two ofthe 
C-8 
5 0 0 0 8 1 
potentially responsible parties, Berlex and Pierrel S.p.A. (a subsidiary of Pharmacia), are 
taking an active rale in the Site cleanup. Natural Resources damages are the 
responsibility ofthe trustee agencies, which include The National Oceanic and 
Atmospheric Administration, Department of Interior and the Virgin Island Government. 
The Trustees have been actively involved with EPA's activities aver the last several years. 
30. 
A commenter wanted to know why EPA waited until the year 2000 to erect a fence around 
the Site. This person also believes EPA should have posted warning signs at the Site to 
discourage individuals from consuming animals that graze on herbs or "bush tea" that 
grow in the area. 
The fence was installed by the PRPs after many failed attempts to have the property 
owner, CHS Holding Corporation, install it The PRPs requested the consent of CHS 
Holding Corporation to put up the fence, which taak some time to obtain. The fence was 
installed by the PRPs in 1999. 
Cleanup Goals of Selected Remedy 
31. 
One resident questioned whether EPA could ever restore the Site property to its original 
state. 
EPA selects a remedy in accordance with the nine criteria outlined by the National Oil 
and Hazardous Substances Pollution Contingency Plan (NCP), including cost, 
implementability, and effectiveness. Superfund law requires EPA to clean up a Site to 
acceptable levels of risk, and cleanup goals are established based on the reasonably 
anticipated land use. The Virgin Island Chemical Site was an industrial property; EPA's 
cleanup will allow the property ta be used industrially. The groundwater at the Site will 
be remediated ta drinking water standards, which do nat distinguish between residential 
and nonresidential scenarios. 
32. 
CPEP requested more information on the exact decision criteria (quantitative or 
qualitative) which will be used by EPA to determine whether to implement the 
contingency remedy, which consists of groundwater exfraction and freatment at locations 
where monitored natural attenuation is proposed under the Selected Remedy. The CPEP's 
concem surrounded the contingency remedy and the design ofthe fiiture groundwater 
monitoring program that could yield data necessary to trigger implementation ofthe 
contingency remedy. The CPEP indicated that is was currently unclear from the 
documentation provided whether the monitoring design will be statistically based and 
sufficiently protective to detect the criteria for determining whether the implementation of 
the plan is necessary to protect human health and environment. More specifically, the 
committee wanted to know what would be or is the acceptable decision error rate (i.e., .01, 
.05, 0.1 or greater) for failing to decide to implement the contingency remedy if the data 
indicates that it should be implemented. 
C-9 
5 0 0 0 8 2 
Current EPA Monitored Natural Attenuation (MNA) policy and protocol do not require 
that statistics be used to decide when a contingency remedy should be implemented, nor 
do they require that EPA specify an acceptable decision error rate. 
The decision ta implement the contingency remedy will be based upon: 1) evidence (i.e., 
definitive data from groundwater sampling) that the leading edge ofthe VOC plume 
exceeding MCLs is advancing ar 2) evidence (i.e., definitive data, statistical analysis, 
modeling) that the VOC plume is attenuating at rates that are significantly less than 
feasibility study predictions and that are clearly less than cleanup rates that could 
otherwise be achieved by the contingency remedy. For administrative purposes, the Site 
property boundary will be designated as the reference point, as it is generally the leading 
edge ofthe VOC plume exceeding MCLs. MW-11 and at least one other new monitoring 
well location approved by EPA immediately downgradient of the property boundary line 
will serve as sentinel, ar "trigger, " wells to test the first decision criterion. If the 
groundwater sample results from quarterly monitoring exceed MCLs, as detected in one 
round of sampling and confirmed by a subsequent verification round of sampling, at any 
sentinel well (i.e., ar any well downgradient thereof), then the contingency remedy will be 
implemented. The second decision criterion will be evaluated on a regular basis during 
preparation of quarterly remedial progress reports based upon the results of data 
evaluation/interpretation, statistical analysis, numerical modeling, and other standard 
methods/protocols described in the EPA MNA guidance and other directives. 
The public will be kept informed of its clean-up progress and would be advised of a 
decision to implement the contingency remedy. 
Other Superfund Sites in St Croix 
33. 
One commenter wanted to know ifEPA currently has other Superfimd Sites in St. Croix. 
The Virgin Island Chemical Site is the only federal Superfund Site in St Croix listed on 
the NPL. EPA is aware of two other, the Hess and St Croix Alumina Sites, which are 
facilities handled under the Resource Conservation and Recovery Act (RCRA). Superfund 
generally focuses more on inactive, abandoned hazardous waste facilities. 
34. 
The commenter also asked whether EPA would take confrol ofthese RCRA facilities if 
the facilities were to close down. 
EPA explained that oil and gasoline are generally not covered under Superfund, which is 
governed by the Comprehensive Environmental Response, Compensation, and Liability 
Act (CERCLA), as amended. RCRA facilities contain treatment, storage and disposal 
units which, when they cease ta be used far that purpose, must be closed in accordance 
with certain RCRA requirements. Sa even though a RCRA facility may become inactive, it 
would nat necessarily became a Superfund Site. It is passible that an abandoned RCRA 
facility could be addressed by EPA or owner/operators under CERCLA. However, EPA 
C-10 
500083 
would only become involved with the facility if Superfund assistance was requested. Also, 
a hazardous waste Site must be added to the National Priorities List before EPA can use 
federal funds for long-term remedial action. 
C-11 
500084 
#1 LAGOON STREET COMPLEX 
FREDEUIKSIED, ST. C B O K . U.S.V.1. 00840 
Caroline Kwan 
Remedial Project Manager 
United States Environmental Protection Agency 
290 Broadway, 20"" Floor 
New York, NY 10007-1866 
Dear Ms. Kwan: 
On behalf of Senator Alicia "Chucky" Hansen, I would like to submit the following 
comments regarding the EPA's proposed plan to clean up the Virgin Islands Chemical 
Superfimd site. Although the "EPA was notified in October of 1982 ofthe facility's 
impending closure and off-site removal of waste materials" and although "between 1984 
and 1991 several investigations were conducted at the Site by EPA", it took until January 
31 and February 1,1989 for the EPA to remove "400 drums (some exfremely 
deteriorated) leaking cylinders ofchlorine and hydrogen chloride, and over 800 
containers of laboratory reagents that included sodium metal, potassium cyanide and 
ethyl ether". The EPA also removed "354 drums containing 14,720 gallons of various 
chemicals and 8,061 pounds of lab pack chemicals from the laboratory/warehouse 
building". 
It is deplorable that it took from 1982 until 1989, seven years, for the EPA to remove the 
drums. Furthermore, the EPA did not have the courtesy to inform or warn the adjacent 
prison known as Golden Grove Correctional Facility or the Profit and Bethlehem 
residential communities ofthe potential health consequences ofthe dust made airbome by 
the removal of the drums. 
The area ofthe facility was not even fenced until the year 2000, eighteen years after EPA 
was first notified ofthe facility's closure and sixteen years after the EPA first conducted 
its investigation. Up until the year 2000, sheep and goats would graze from the 
facilities' grounds and our St. Croix residents consumed those animals. 
I believe the EPA was too slow (sixteen years) in conducting its investigation and clean-
up and that is unacceptable. 
I believe the EPA should have notified the prosecutorial agencies about the dumped 
hazardous waste materials. 
500085 
I believe the EPA should have immediately fenced the area and put warning signs of DO 
NOT ENTER so that unsuspecting individuals do not consume the animals that graze or 
the herbs or "bush tea" that grow in the area. 
I believe the EPA should have given better notice to the community and utilize the 
airwaves to give notice about the public meeting. 
I believe the EPA shoulti have notified the public regarding the airbome contaminants 
created by the previous soil excavation and should now notify the adjacent communities 
so that they can protect themselves from any potential contaminants produced by the 
remediation plan. 
I believe the people ofthe Virgin Islands should be compensated for their loss of natural 
resources. 
I believe a comprehensive health study should be made on the people ofthe Virgin 
Islands to determine whether or not the Island Chemical site has impacted on the 
community negatively. 
Cordially, 
Amelia B. Joseph, Esq. 
on behalf of Senator Alicia "Cbucky" Hansen 
500086 
500087 
INMATE POPULATION 
GOL0EN GROVE ADULT CORRFrTrnNTAT PAI-TT rrv 
RURAL ROUTE #1 
^"RRECTIONAL FACILITY 
KINGSHILL ST. CROIX 00851 
PETTTTON 
GREETINGS: 
WE THE UNDERSIGNED OF THE INMATE POPULATION HERE AT THE 
GOLDEN GROVE ADULT CORRECTIONAL FACILITY ARE ADDRESSING A PETITION 
DUE TO A CARCINOGENIC RISK OF TOXICITY OF GROUND CONTAMINATION 
THAT IS AFFECTING PRISONER HEALTH FOR THE LAST (2) TWO DECADES. THIS 
CONTAMINATION IS RESPONSIBLE FOR SKIN DISCOLORATION AND RASH, HAIR 
COLORATION, SEVERE LOST OF APPETITE, ULCERS OF THE STOMACH. KIDNEY 
DILAPIDATION DUE TO ADVERSE HEALTH EFFECTS ASSOCIATED WITH THE SOIL 
IRRIGATION OF THE WATER WE ACCOMODATE. IN REGARD TO THESE 
SYMPTOMS THAT IS DETERJOATING AND DIMINISHING OUR HEALTH DUE TO THE 
DISPOSITION WE AS INMATE HERE IN THIS INSTITUTION ARE UP AGAINST, WE 
STRONGLY FEEL THIS ADVERSE FORMALITY ACCOUNTS FOR THE CUMULATIVE 
RISK OF BEING EXPOSE TO THE CARCINOGENIC RISK OF CANCER IN THE NEAR 
FUTURE. WE THE UNDERSIGNED OF THE INMATE POPULATION PRAY FOR AN 
ADOVOCATE OF SUPPORT FROM ANY ENTITY, FEDERAL AGENCY, 
GOVERNMENTAL AGENCY AND ANY FORM OF RESOURCE THAT CAN ASSESS AN 
ALTRERNATIVE FOR AN EFFECTIVE REMEDY OF OUR CONCERNS WE ARE UP 
AGAINST. 
RESPECTFULLY SUMITTED 
./?^2rf iuUx:USXAf\xj \X(\Mib 
I w w ^ Q g j ^ . 
36.M^A'i;6 ba-n.yv/g^ ( 
. V " ^ 
Friday, August 10,2001 
Caroline Kwan, Remedial Project Manager 
United States Environmental Protection Agency 
290 Broadway, 20* Floor 
New York, NY 10007-1866 
Dear Ms. Kwan, 
As Chairman ofthe Committee on Planning & Environmental Protection (CPEP) 
ofthe 24* Legislature of Virgin Islands, and on behalf of the people ofthe Territory, I am 
providing the following comments on the Proposed Plan for the Virgin Islands Chemical 
Superfund Site (the Site) dated June 2001.. 
My first concem surrounds the contingency remedy and the design ofthe future 
groundwater monitoring program that could yield data necessary to trigger 
implementation ofthe contingency remedy. It is currently unclear from the 
documentation provided whether the monitoring design will be statistically based and 
sufficiently protective to detect the criteria for determining whether the implementation 
ofthe plan is necessary to protect human health and environment. More specifically, 
what would be or is the acceptable decision error rate (i.e., .01,.05, 0.1 or greater) for 
failing to decide to implement the contingency remedy when in fact data indicates that it 
should be implemented. 
Furthermore, the six words ofthe fifth paragraph states "...data indicates that it is 
needed", however, while this implies that quantitative criteria has been developed or will 
be developed for taking action, it is unclear whether in fact these criteria are quantitative 
and if so, what are the decision criteria. 
Secondly, we are also concemed with the length of time it took to characterize the 
site and wonder whether any samples were collected to determine what contaminants 
were left at the site and their corresponding cpncenfrations after the removal action in 
January and February of 1989. This document also does not indicate whether the data 
used to characterize site risks were data collected recently or when concentrations were 
higher. The length of time involved as well as the balance of data used to drive the risk 
assessment (i.e., recent versus old) may have significantly altered the risk 
characterization, as well as the selected preferred remedy. 
Finally, on page six in the "Groundwater" section, what level of confidence is 
associated with the conclusion that chloroform does not appear to be migrating offsite 
and for that matter, any other contaminant of concem. 
500088 
We are pleased for the opportunity to provide some input on the proposed remedy 
and look forward to the issuance of a Record of Decision that, to the extent possible, 
takes all Virgin Islanders concems into serious consideration. 
Cordially, 
Donald "Ducks" Cole, Chairman 
Committee on Planning and Environmental Protection 
24* Legislature ofthe Virgin Islands 
500089 
APPENDIX D 
ADMINISTRATIVE RECORD INDEX 
500090 
ISLAND CHEMICAL SITE 
ADMINISTRATIVE RECORD FILE 
INDEX OF DOCUMENTS 
1.0 
SITE 
IDEl^IFICATION 
1.1 Background - RCRA and Other Infonnation 
P. 
100001 - Report: RCRA Enforcement. Interim Report- No 
100085 
Analysis Data. Berlex Laboratories, St. Croix, VI. 
prepared by Ms. Carol Price, Environmental 
Scientist, Berlex Laboratories (ICC), prepared for 
U.S. EPA, March 13, 1986. 
P. 
100086 - Letter to Mr. Charles Dolan, U.S. EPA, Emergency 
100271 
and Remedial Response Division, Region II, from 
Alan L. Klyes, Ph.D., Enviro-Sciences, Inc., 
re: Island Chemical Company, U.S. Virgin Islands, 
April 17, 1986. (Attachment: Project Summary 
(with Attachments A - N) for Island Chemical 
Company, Inc., (Berlex) St. Croix, Virgin 
Islands). 
1.2 Notification/Site Inspection Reports 
P. 
100272 - Report: Final Draft Site Inspection Report, VI 
100572 
Chemical, St. Croix, U.S. Virgin Islands, Volume 1 
of 2, prepared by Halliburton NUS Environmental 
Corporation Superfund Division, prepared for 
Environmental Services Division, U.S. EPA, 
September 4, 1991. 
P. 
,100573 - Report: Final Draft Site Inspection Report. VI 
100847 
Chemical, St. Croix, U.S. Virgin Islands, Volume 2 
of 2. prepared by Halliburton NUS Environmental 
Corporation, prepared for Environmental Services 
Division, U.S. EPA, September 4, 1991. (NOTE: 
Pages 100835 through 100847 are CONFIDENTIAL. 
These pages can be located at the U.S. EPA, 
Superfund Records Center, 290 Broadway, 18th 
Floor, N.Y., N.Y., 10007-1866.) 
500091 
2.0 REMOVAL RESPONSE 
2 .5 Action Memorandum 
P. 
200001 - Memorandum to Mr. William J. Muszynski, P.E., 
200042 
Acting Regional Administrator, U.S. EPA, Region 
II, from Mr. Douglas R. Kodama, On-Scene 
Coordinator, Response and Prevention Branch, U.S. 
EPA, Region II, re: Preliminary Assessment, 
Removal Site Evaluation, and Funding Authorization 
Request for a CERCLA Removal Action at the Virgin 
Island Chemical Company, Inc..Site, St. Croix, 
U.S. Virgin Islands, Action Memorandum, August 8, 
1989. 
3.0 REMEDIAL INVESTIGATION 
3.2 Sampling and Analysis Data/Chain of Custody Forms 
P. 
3 00001 - Letter to Ms. Sherrel Henry, Remedial Project 
300124 
Manager, U.S. EPA, Region II, from Mr. Jason M. 
Schindler, Associate Geologist, Harding Lawson 
Associates, re: Non-CLP Results of Potable Water 
Sampling, Island Chemical Company, St. Croix, U.S. 
Virgin Islands, January 3, 1995. (Attachment: 
Non-CLP laboratory data package. Report of 
Laboratory Analysis, prepared by Pace Inc., 
Environmental Laboratories). 
P. 
300125 - Memorandum to Mr. Jason Schindler, Harding Lawson 
300227 
Associates (HLA), Philadelphia, from Mr. Mike 
Phillips, HLA, Denver, re: Island Chemical Company 
Data Review, January 10, 1995. (Attachment: 1. 
HLA Data Quality Assurance Review Summary, 
Volatile Organic Compounds Analysis, Case 
Number: 94195, Project Number: 29872 10-wl, Island 
Chemical Company, reviewed January 3, 1995; 2. 
HLA Data Quality Assurance Review Summary, 
Semivolatile Organic Compounds Analysis, Case 
Number: 94195, Project Number: 29872 10.1, Island 
Chemical Company, reviewed January 4, 1995; 3. 
HLA Data Quality Assurance Review Summary, Metals 
Analysis, Case Number: 94195, Project Number: 
29872 10.1, Island Chemical Company, reviewed 
January 5, 1995; 4. HLA Data Quality Assurance 
500092 
Review Summary, Semivolatile Organic Compounds 
Analysis, Case Number: 94195, Project Number: 
29872 10.1, Island Chemical Company, reviewed 
January 5, 1995; 5. HLA Data Quality Assurance 
Review Summary, Organochlorine Pesticides and 
Polychhlorinated Biphenyls Analysis, Case Number: 
94195, Project Number 29872 10.1, Island Chemical 
Company, reviewed January 5, 1995; and 6. HLA 
Data Quality Assurance Review Summary, Semi-
volatile Organic Compounds Analysis, Case Number: 
94195, Project Number: 29872 10.1, Island Chemical 
Company, reviewed January 9, 1995). 
P. 
300228 - Letter to Mr. Jonathan Rude, U.S. EPA Contract 
300228 
Laboratory Program, from Ms. Pamela J. Philip, 
Work Assignment Manager, CDM Federal Programs 
Corporation, re: Completed CLP Paperwork for Case 
Number 23153, February 9, 1995. 
P. 
300229 - Letter to Ms. Sherrel D. Taylor-Domville, U.S. 
300233 
EPA, Region II, from Mr. Bharat Patel, C.P.G., 
Associate Hydrogeologist, and Mr. Jason M. 
Schindler, Associate Geologist, Harding Lawson 
Associates, re: Results of February 14 and 15, 
1995 Quality Assurance Field Audit, Island 
Chemical Company Site, Remedial Investigation, St. 
Croix, U.S. Virgin Islands, March 1, 1995. 
P. 
300234 - Table 4-2 (Draft): Soil Sample Analytical Results 
300241 
- Volatile Organic Compounds, Virgin Island 
Chemical Company, January 31, 1995. (Attachment: 
Table 4-8 (Draft): Groundwater Sample Analytical 
Results - Volatile Organic Compounds, Virgin 
Island Chemical Company, May 11, 1995. 
P. 
300242 - Letter to Ms. Kathy Kinsella, RSCC, Lockheed, from 
300253 
Ms. Pamela Philip, Work Assignment Manager, CDM 
Federal Programs Corporation, re: Completed CLP 
Paperwork and Sampling Trip Report for Case Number 
23237, February 28, 1995. (Attachment: Report: 
Sampling Trip Report. Virgin Islands Chemical 
Site. St. Croix. U.S. Virgin Islands, prepared by 
CDM Federal Programs Corporation, prepared for 
U.S. EPA, Region II, February 28, 1995) . 
500093 
3 00254 - Letter to Mr. Jonathan Rude, U.S. EPA, Contract 
300256 
Laboratory Program, from Ms. Pamela Philip, Work 
Assignment Manager, CDM Federal Program 
Corporation, re: Completed CLP Paperwork for Case 
Number 23237, February 28, 1995. (Attachment: 
U.S. EPA, Inorganic Traffic Report & Chain of 
Custody Report (for Inorganic CLP Analysis), 
February 15, 1995). 
300257 - Letter to Ms. Sherrel Taylor-Domville, U.S. EPA, 
300688 
Region II, Emergency and Remedial Response 
Division (ERRD), from Mr. Jason Schindler, 
Associate Geologist, Harding Lawson Associates, 
re: Results of Soil and Initial Groundwater 
Sampling, Island Chemical Company, St. Croix, U.S. 
Virgin Islands, April 7, 1995. (Attachment: 1. 
Letter to Mr. Steve Bruckner, Harding Lawson & 
Associates, from Ms. Elaine Wild, QA Officer, Pace 
Inc. Environmental Laboratories, re: the attached 
pyridine analysis supporting raw data for Report 
Groups #95010, 95020 and 95022, April 5, 1995; 2. 
Raw pyridine data for Report Groups #95010, 95020, 
95022. 
300689 - Data Package: Harding Lawson & Associates (HLA) 
300851 
Data Quality Assurance Review Suitmiary, Semi-
volatile Organic Compound Analysis, April 12, 
1995. 
3 00852 - Letter to Ms. Sherrel D. Taylor-Domville, U.S. 
300854 
EPA, Region II, from Mr. Matthew Gordan, for Mr. 
Bharat Patel, C.P.G., Managing Associate 
Hydrogeologist, and Mr. Jason M. Schindler, 
Associate Geologist, Harding Lawson Associates, 
re: Results of Second Quality Assurance Field 
Audit, Island Chemical Company Site, Remedial 
Investigation, St. Croix, U.S. Virgin Islands, 
June 7, 1995. 
-
300855 - Letter to Ms. Sherrel Henry, Work Assignment 
300858 
Manager, U.S. EPA, Region II, from Ms. Pamela 
Philip, Work Assignment Manager, CDM Federal 
Programs Corporation, re: Draft Assessment of PRP 
Data Validation Activities, Virgin Island Chemical 
Site, St. Croix, U.S. Virgin Islands, July 14, 
1995. 
(Attachment Report: Draft Data Assessment 
of PRP Data Validation Activities, Virgin Island 
500094 
chemical Site, St. Crcix, U.S. Virgin Islands, 
prepared by CDM Federal Programs Corporation). 
300859 - Letter to Ms. Sherrel Henry, U.S. EPA, Region II, 
300861 
from Mr. John S. Virgie, P.G., Senior Geologist, 
and Mr. Edward A. Nemecek, R.G,, C.P.G., Principal 
Hydrogeologist, Harding Lawson Associates, re: 
Soil Sampling Program - AST Area, Phase II 
Remedial Investigation, Virgin Island Chemical 
Site, St. Croix, U.S. Virgin Islands, June 28, 
1996. (Attachment: Figure 1, Surface Soil Sample, 
Soil Boring Locations, AST Area, Island Chemical 
Co., St. Croix, U.S. Virgin Islands, prepared by 
Harding Lawson Associates, June 14, 1996), 
300862 - Letter to Ms. Caroline Kwan, Remedial Project 
300936 
Manager, U.S. EPA, Region II, from Mr. Perry Katz, 
Principal Environmental Scientist, McLaren Hart, 
Inc., re: VICHEM Site, St. Croix, U.S. Virgin 
Islands, November 1997 Monthly Progress Report, 
December 15, 1997. (Attachments: (1) Report: 
Attachment, November 1997 Monthly Progress Report, 
List of Tables; (2) Table 1, Virgin Island 
Chemical Site, Soil Boring Sampling Results, 
Volatile Organic Compounds; (3) Table 2, Virgin 
Island Chemical Site, Soil Boring Sampling 
Results, Semivolatile Organic Compounds; (4) Table 
3, Virgin Island Chemical Site, Soil Boring 
Sampling Results, Metals; (5) Table 4, Virgin 
Island Chemical Site, Gut and Storm Drain Surface 
Soil Sampling Results, Semivolatile Organic 
Compounds; (6) Table 5, Virgin Island Chemical 
Site, Gut and Storm Drain Surface Soil Sampling 
Results, Metals; (7) Table 6, Virgin Island 
Chemical Site, Gut and Storm Drain Surface Soil 
Sampling Results, Physicochemical Parameters; (8) 
.Table 7, Virgin Island Chemical Site, (Jut and 
Storm Drain Surface Soil Sampling Results, Grain 
Size Analysis; (9) Table 8, Virgin Island Chemical 
Site, Fairplain Gut/Manning Bay Sediment Sampling 
Results, Semivolatile Organic Compounds; (10) 
Table 9, Virgin Island Chemical Site, Fairplain 
Gut/Manning Bay Sediment Sampling Results, Metals; 
(11) Table 10, Virgin Island Chemical Site, 
Fairplain Gut/Manning Bay Sediment Sampling 
. . 
Results, Physicochemical Parameters; (12) Table 
500095 
11, Virgin Island Chemical Site, Fairplain 
Gut/Manning Bay Sediment Sampling Results, Grain 
Size Analysis; (13) Table 12, Virgin Island 
Chemical Site, Soil Boring Sampling Results, 
Biological Parameters; (14) Table 13, Virgin 
Island Chemical Site, Soil Boring Sampling 
Results, Physicochemical Parameters; (15) Table 
14, Virgin Island Chemical Site, Preliminary Soil 
Boring Sampling Results, Process Pit Area, 
Volatile Organic Compounds and (16) Table 15, 
Virgin Island Chemical Site, Preliminary Soil 
Boring Sampling Results, Lab Pit Area, Volatile 
Organic Compounds. 
3.3 Work Plan 
P. 
300937 - Report: Island Chemical Company, Inc., Remedial 
301284 
Investigation St. Croix, U.S. Virgin Islands, 
Draft Work Plan. Volume I of II, Work Plan and 
Appendices A through C. prepared by Harding Lawson 
Associates, prepared for Island Chemical Company, 
Inc., March 17, 1994. 
P. 
301285 - Report: Island Chemical Company. Inc., Remedial 
301764 
Investigation St. Croix, U.S. Virgin Islands, 
Draft Work Plan, Volume II of II, Work Plan and 
Appendices D through O. prepared by Harding Lawson 
Associates, prepared for Island Chemical Company, 
Inc., March 17, 1994. 
P. 
301765 - Report: Draft Remedial Investigation Work Plan. 
302136 
Island Chemical Company, Inc., St. Croix. U.S. 
Virgin Islands, prepared by Harding Lawson 
Associates, prepared for Island Chemical Company, 
Inc., August 5, 1994. 
P. 
302137 - Letter to Ms. Sherrel Henry, U.S. EPA, Region II, 
302141 
from Mr. Edward A. Nemecek, R.G., C.P.G., 
Principal Hydrogeologist, Harding Lawson 
Associates, re: Revised Draft Remedial 
Investigation Work Plan Schedule, Island Chemical 
Company, Inc., St. Croix, U.S. Virgin Islands, 
September 14, 1994. (Attachments: (1) 
Distribution List, Island Chemical Company, Inc., 
St. Croix, U.S. Virgin Islands, September 19, 
1994; 
(2) Outline for Island Chemical Company 
500096 
Inc. Remedial Investigation Report, September 19, 
1994; 
(3) Figure 8-1: Work Plan Implementation 
Schedule, Island Chemical Company, St. Croix, U.S. 
Virgin Islands, September 19, 1994). 
P. 
302142 - Letter to Ms. Sherrel Taylor-Domville, U.S. EPA, 
302160 
Region II, Emergency and Remedial Response 
Division, U.S. EPA, Region II, from Mr. Jason M. 
Schindler, P.G,, Associate Geologist, Harding 
Lawson Associates, re: Draft Phase II Work Plan, 
Remedial Investigation, VICHEM Site, St. Croix, 
U.S. Virgin Islands, November 21, 1995. 
(Attachment: Report: Draft Phase II Remedial 
Investigation Work Plan, Virgin Island Chemical 
Site, Remedial Investigation, St. Croix. U.S. 
Virgin Islands, prepared by Harding Lawson 
Associates, Engineering and Environmental 
Services, prepared for Island Chemical Company, 
November 21, 1995). 
P. 
302161 - Letter to Ms. Caroline Kwan, Remedial Project 
302188 
Manager, U.S. EPA, Region II, from Ms. Lori G. 
Singer, Sills Cummis Zuckerman Radin Tischman 
Epstein & Gross, re: Vichem Site/St. Croix, Virgin 
Islands, November 6, 1996. (Attachments: (1) 
Letter to Wilfredo Geigel, Esq., from Ms. Lori G. 
Singer, Sills Cummis Zuckerman Radin Tischman 
Epstein & Gross, re: CHS Holding Co., Inc., 
October 14, 1996; (2) Letter to Lori Singer, Esq., 
Sills Cummis Zuckerman Radin Tischman Epstein & 
Gross, from Wilfredo A. Geigel, Esq., re: Berlex 
V. CHS, October 17, 1996; (3) Report: Draft 
Remedial Investigation Work Plan Addendum - Phase 
III. Virgin Island Chemical Site, St. Croix, U.S. 
Virgin Islands, prepared by Harding Lawson 
Associates, Engineering and Environmental 
Services, prepared for Island Chemical Company, 
November 7, 1996). 
P. 
302189 - Report: Draft Remedial Investigation Work Plan 
302231 
Addendum - Phase III, Virgin Island Chemical Site. 
St. Croix, U.S. Virgin Islands, prepared by 
Harding Lawson Associates, Engineering and 
Environmental Services, prepared for Island 
Chemical Company, January 20, 1997. 
500097 
F. 
302232 - Memorandum to Ms. Caroline Kwan, Remedial Project 
302291 
Manager, U.S. EPA, Region II, from Mr. John S. 
Virgie, Senior Geologist, Harding Lawson 
Associates, Engineering and Environmental Services 
and Mr. Edward A. Nemecek, Principal 
Hydrogeologist, Regional Geosciences Manager, 
Harding Lawson Associates, Engineering and 
Environmental Services, re: Draft Remedial 
Investigation Work Plan Addendum - Phase III, 
Virgin Island Chemical Site, St. Croix, U.S. 
Virgin Islands, June 20, 1997•(Attachment: Report: 
Draft Remedial Investigation Work Plan Addendum -
Phase III. Virgin Island Chemical Site, St. Croix. 
U.S. Virgin Islands, prepared by Harding Lawson 
Associates, Engineering and Environmental 
Services, prepared for Island Chemical Company, 
June 20, 1997). 
P. 
302292 - Memorandum to Ms. Caroline Kwan, Remedial Project 
302355 
Manager, U.S. EPA, Region II, from Mr. John S. 
Virgie, Senior Geologist, Harding Lawson 
Associates, Engineering and Environmental 
Services, re: Revised Draft Remedial Investigation 
Work Plan - Phase III, Virgin Island Chemical 
Site, St. Croix, U.S. Virgin Islands, July 25, 
1997. (Attachment: Report: Draft Remedial 
Investigation Work Plan Addendum - Phase III. 
Virgin Island Chemical Site, St. Croix, U.S. 
Virgin Islands, prepared by Harding Lawson 
Associates, Engineering and Environmental 
Services, prepared for Island Chemical Company, 
July 25, 1997). 
P. 
302355A - Letter to Ms. Caroline Kwan, U.S. EPA, Region II, 
3023550 
from Mr. Perry Katz, Principal Environmental 
Scientist and Ms. Norma Eichlin, Senior Engineer, 
McLaren Hart, Inc., re: Island Chemical Site, St. 
Croix, U. S. Virgin Islands, Supplemental Remedial 
Investigation (Phase IV RI), August 12, 1998. 
P. 
302355P - Letter to Ms.Caroline Kwan, U.S. EPA, Region II, 
302355Q 
from Mr. Perry Katz, Principal Environmental 
Scientist and Ms. Norma Eichlin, Senior Engineer, 
McLaren Hart, Inc., re: Island Chemical Site, St. 
Croix, U. S. Virgin Islands, Clarifications to 
Supplemental Remedial Investigation dated August 
12, 1998, August 24, 1996. 
r '"' 
8 
500098 
3 02355R- Letter to Ms. Caro]ine Kwan, Remedial Project 
302355DD Manager, U.S. EPA, Region II, from Mr. Perry Katz, 
Principal Environmental Scientist and Ms. Norma 
Eichlin, Senior Engineer, McLaren Hart, Inc., re: 
Island Chemical Site, St. Croix, U.S. Virgin 
Islands, Field Modifications During Supplemental 
Remedial Investigation (Phase IV RI) , November 20, 
1998. (NOTE; Pages 302355AA through 302355DD are . 
CONFIDENTIAL. These pages can be located at the 
U.S. EPA, Superfund Records Center, 290 Broadway, 
IS"* Floor, N.Y., N.Y., 10007-1866.) 
3.4 Remedial Investigation Reports 
P. 
302356 - Report: Compendium of Well Water Data Collected at 
302357 
the Virgin Island Chemical Co. bv the U.S. EPA 
(1986 - 1990)• undated.• 
P. 
302358 - Report: Draft Technical Memorandum Pathways 
302367 
Analysis Report and Phase I Baseline Risk 
Assessment Summary, Virgin Island Chemical Site. 
St. Croix, U.S. Virgin Islands, prepared by 
Harding Lawson Associates, prepared for Island 
Chemical Company, Inc., August 14, 1995. 
302368 - Letter to Ms. Sherrel D. Taylor-Domville, U.S. 
302368 
EPA, Region II, from Mr. Jason M, Schindler, 
Associate Geologist, and Mr. Edward A. Nemecek, 
R.G., C.P.G., Principal Hydrogeologist, Harding 
Lawson Associates, re: Draft Data Summary Report, 
Remedial Investigation, Virgin Island Chemical 
Site, St. Croix, U.S. Virgin Islands, August-15, 
1995. 
302369 - Report: Draft Data Summary Report, Virgin Island 
302886 
Chemical Site, St. Croix, U.S. Virgin Islands. 
U.S. EPA Index No. II CERCLA-94-04 01. Volume I of 
II. prepared by Harding Lawson Associates, 
prepared for Island Chemical Company, August 15, 
1995. 
302887 - Report: Draft Data Summary Report, Virgin Island 
303349 
Chemical Site. St. Croix, U.S. Virgin Islands. 
U.S. EPA Index No. II CERCLA-94-0401. Volume II of 
500099 
II. prepared by Harding Lawson Associates, 
prepared for Island Chemical Company, August 15, 
1995. 
303350 - Letter to Ms. Alison Devine, U.S. EPA, Region II, 
303358 
from Mr. Robert D. Goltz, P.E., ARCS II Program 
Manager, CDM Federal Programs Corporation, re: 
Technical Review of Draft Supplemental Data 
Summary Report, Virgin Island Chemical Site, St. 
Croix, U.S. Virgin Islands, October 8, 1996. 
(Attachment: Report: Technical Review of the 
Draft Supplemental Data Summary Report, Virgin 
Island Chemical Site, prepared by CDM Federal 
Programs Corporation, prepared for U.S. EPA, 
Region II, October 8, 1996). 
303359 - Report: 
Revised Final Remedial Investigation 
303676 
Report, Volume 1 and Remedial Investigation 
Addendum. Virgin Island Chemical Site, St. Croix. 
U. S. Virgin Islands, prepared by Golder 
Associates Inc., prepared for Berlex Laboratories, 
Inc. and Pharmacia & Upjohn, October 2000. 
303677 - Report: 
Final Remedial Investigation Report. 
304262 
Virgin Island Chemical Site, St. Croix, Virgin 
Islands. Volume II, Appendices A-G, I-K. prepared 
by McLaren/Hart, Inc., prepared for Berlex 
Laboratories, Inc. and Pharmacia & Upjohn, 
February 2000. 
304263 - Report: 
Final Remedial Investigation Report. 
304841 
Virgin Island Chemical Site, St. Croix, Virgin 
Islands, Volume III, Appendix H, prepared by 
McLaren/Hart, Inc., prepared for Berlex 
Laboratories, Inc. and Pharmacia & Upjohn, 
February 2000. 
304 842 - Report: 
Draft Soil Vapor Extraction/Air Sparging 
305249 
(SVE/AS) Pilot Study Report. Virgin Island 
Chemical Site. St. Croix. U. S. Virgin Islands. 
prepared by Golder Associates Inc., prepared for 
Berlex Laboratories, Inc. and Pharmacia & Upjohn, 
October 2000. 
^° 
500100 
3.5 Correspondence 
P. 
3 05250 - Letter to Mr. Edward A. Nemecek, Principal 
3 05254 
Hydrogeologist, from Ms. Carole Petersen, 
Chief, New York/Caribbean Superfund Branch II, 
U.S. EPA, Region II, re: Comments on the Draft 
Phase II Remedial Investigation Work Plan, Island 
Chemical Site, St. Croix, U.S. Virgin Islands, 
undated. 
P. 
305255 - Letter to Mr. James Oland, Supervisor, Caribbean 
305255 
Field Office, U.S. Fish and Wildlife Service, from 
Mr. Robert Hargrove, Chief, Environmental Impacts 
Branch, U.S. EPA, re: initiating consultation with 
the U.S. Fish and Wildlife Service to determine 
whether there are any federal endangered/ 
threatened Species or critical habitats present on 
or in the vicinity of the Island Chemical Company 
National Priorities List site, located in the 
Christiansted Jurisdiction, St. Croix, U.S. Virgin 
Islands, June 30, 1995. 
P. 
305256 - Letter to Ms. Sherrel Henry, Remedial Project 
305259 
Manager, U.S. EPA, Region II, from Ms. Diane 
Wehner, NOAA Coastal Resource Coordinator, U.S. 
Dept. Of Commerce, re: review of Draft Data 
Summary Report for the Virgin Island Chemical 
Site, September 7, 1995. 
P. 
305260 - Memorandum to Ms, Sherrel D. Henry, Remedial 
305261 
Project Manager, U.S. EPA, Region II, from Ms. 
Shari Stevens, Environmental Scientist, U.S. EPA, 
Region II, re: Technical Review of the Draft Data 
Summary Report for the Virgin Island Chemical 
Site, September 8, 1995. 
P. 
305262 - Letter to Ms. Sherrel Henry, Work Assignment 
305268 
Manager, U.S. EPA, Region II, re: Technical Review 
of PRP Data Summary Report for the Virgin Island 
Chemical Site, September 18, 1995. 
P. 
305269 - Letter to Ms. Sherrel Taylor-Domville, U.S. EPA, 
305270 
Region II, from Mr. Jason M. Schindler, P.G., 
Associate Geologist, and Mr. Edward A. Nemecek, 
R.G., C.P.G., Regional Geosciences Manager, 
Harding Lawson Associates, re: Supplemental Work 
. . 
Plan, Remedial Investigation, Virgin Island 
Chemical Site, St. Croix, U.S. Virgin Islands, 
October 20, 1995. 
500101 
500102 
F. 
305271 - Letter to Ms. Alison Devine, U.S. EPA, Region II, 
305277 
from Mr. Robert D. Goltz, P.E., ARCS II Program 
Manager, CDM Federal Programs Corporation, re: 
Technical Review of Draft Phase II Work Plan, 
Virgin Island Chemical Site, St. Croix, U.S. 
Virgin Islands, December 11, 1995. (Attachment: 
Report: Technical Review of the Draft Phase II 
Work Plan. Virgin Island Chemical Site. St. Croix, 
U.S. Virgin Islands, prepared by CDM Federal 
Programs Corporation; prepared for, U.S. EPA, 
Region II, December 11, 1995. 
P. 
305278 - Letter to Ms, Sherrel Henry, Remedial Project 
305281 
Manager, U.S. EPA, Region II, from Ms. Diane E. 
Wehner, NOAA Coastal Resource Coordinator, U.S. 
Dept. of Commerce, re: review of the Draft Phase 
II Remedial Investigation (RI) Work Plan for the 
Island Chemical Company, Inc. Site, December 14, 
1995. (Attachments: 1. Site Location Map, and 2. 
Figure 13 - Gut Soil Sampling Program). 
P. 
305282 - Letter to Mr. Edward A. Nemecek, Principal 
305286 
Hydrogeologist Co., from Ms. Carole Petersen, 
Chief, N.Y./Caribbean Superfund Branch II, U.S. 
EPA, Region II, re: Comments on the Draft Phase II 
Remedial Investigation Work Plan, Island Chemical 
Site, St. Croix, U.S. Virgin Islands, January 31, 
1996, 
P. 
305287 - Letter to Ms. Sherrel Taylor-Domville, U.S. EPA, 
305303 
Region II, from Mr. Jason M. Schindler, P.G., 
Associate Geologist, and Mr. Edward A. Nemecek, 
R.G., Principal Hydrogeologist, Harding Lawson 
Associates, re: Response to Comments, Draft Phase 
II Remedial Investigation Work Plan, Island 
Chemical Company, St. Croix, U.S. Virgin Islands, 
February 23, 1996. (Attachments: (1) Letter to 
Carol Berns, Esq., U.S. EPA, Region II,. from 
Lori G. Singer, Esq., Sills, Cummis, Zuckerman, 
Radin, Tischman, Epstein, & Gross, re: Plot Q of 
Estate Bethlehem Middle Works off of Melvin Evans 
Highway (Route 66) in St. Croix, U.S. Virgin 
Islands (Vichem Site), Supplemental Work Plan 
Issues, December 11, 1995; (2) Letter to Docket 
Coordinator, Headquarters, U.S. EPA, CERCLA Docket 
Office, from Lori G. Singer, Esq., Sills, Cummis, 
Zuckerman, Radin, Tischman, Epstein, & Gross, re: 
NPL, Proposed Rule No. 16, Tuesday, January 18, 
1994 ("Proposed Rule"), Island Chemical 
Corp./Virgin Islands Chemical Corp., St. Croix, 
Virgin Islands, March 21, 1994; (3) Letter to 
500103 
Docket Coordinator, Headquarters, U.S. EPA, CERCLA 
Docket Office, from Teri L. Copeland, M.S., 
Principal Toxicoiogist, Harding Lawson Associates, 
re: NPL, Proposed Rule No. 16, 11894 Island 
Chemical Corp./Virgin Islands Chemical Corp., St. 
Croix, Virgin Islands, March 21, 1994). 
P. 
3 05304 - Letter to Ms. Sherrel Taylor-Domville, U.S. EPA, 
305305 
Region II, from Mr. Jason M. Schindler, P.G., 
Associate Geologist, and Mr, Edward A. Nemecek, 
R,G., C.P.G., Principal Hydrogeologist, Regional 
Geosciences Manager, Harding Lawson Associates, 
re: Proposed Site Activities, Phase II Remedial 
Investigation Work Plan, Island Chemical Company, 
St. Croix, U.S. Virgin Islands, April 12, 1996. 
P. 
305306 - Letter to Mr. Jason Schindler, P.G,, Associate 
305306 
Geologist, Harding Lawson Associates, from Ms. 
Sherrel D. Henry, Project Manager, U. S. EPA, 
Region II, re: Proposed Site Activities Phase II 
Remedial Investigation Work Plan, Island Chemical 
Site, St. Croix, U.S. Virgin Islands, April 17, 
1996. 
P. 
305307 - Letter to Mr. Jason Schindler, P.G., Associate 
305307 
. Geologist, Harding Lawson Associates, from Ms. 
Sherrel D; Heniry, Project Manager, U. S, EPA, 
Region II, re: Proposed Site Activities Phase II 
Remedial Investigation Work Plan, Island Chemical 
Site, St. Croix, U.S. Virgin Islands, April 18, 
1996. 
P. 
305308 - Letter to Mr. Jason Schindler, P.G., Associate 
305309 
Geologist, Harding Lawson Associates, re: Comments 
on Proposed Site Activities, Phase II Remedial 
Investigation Work Plan, Island Chemical Site, St. 
Croix, U.S. Virgin Islands, May 2, 1996. 
P. 
305310 - Letter to Ms. Sherrel D. Henry, U.S. EPA, Region 
305312 
II, from Mr. John S. Virgie, P.G., Senior 
Geologist, and Mr. Edward A. Nemecek, R.G., 
C.P.G., Principal Hydrogeologist, Regional 
Geosciences Manager, Harding Lawson Associates, 
re: Additional Requested Information, Prop>osed 
Site Activities, Phase II Remedial Investigation 
Work Plan, Island Chemical Company, St. Croix, 
U.S. Virgin Islands, May 15, 1996. (Attachment: 
Figure 1, Proposed Surface Soil and Soil Boring 
Locations, Island Chemical Company, St. Croix, 
U.S. Virgin Islands, prepared by Harding Lawson 
Associates, May 14, 199€), 
500104 
P, 
305313 - Letter to Mr. Austin Moorehead, Director, Division 
305313 
of Environmental Protection, Department of 
Planning and Natural Resources, Government of the 
Virgin Islands of the United States, from Ms. 
Sherrel D. Henry, Remedial Project Manager, U.S. 
EPA, Region II, re: request to discuss the status 
of the Site, May 16, 1996. 
P. 
305314 - Letter to Lori G. Singer, Esq., Sills Cummis 
3 05314 
Zuckerman Radin Tischman Epstein & Gross, from Mr. 
Melvin Hauptman, Leader, Sediments/Caribbean Team, 
Emergency Remedial and Response Division, re: 
Approval of McLaren/Hart Inc. for Implementation 
of the RI/FS at the Island Chemical Site, St. 
Croix, USVI, August 8, 1997. 
P. 
3 05315 - Memorandum to Ms. Caroline Kwan, Remedial Project 
305315 
Manager, Sediments/Caribbean Team, from Ms. Grace 
Musumeci, Chief, Environmental Review Section, re: 
Virgin Islands Chemical Site, St. Croix, USVI, 
Compliance with the National Historic Preservation 
Act, March 31, 1999. 
P. 
305316 - Letter to Ms. Caroline Kwan, Remedial Project 
305317 
Manager, U.S. EPA, Region. II, from Mr. Perry Katz, 
Principal Environmental Scientist, McLaren Hart, 
Inc., re: Virgin Island Chemical Site, St. Croix, 
U.S. Virgin Islands, Schedule for Installation of 
Site Fence, January 26, 2000, 
P. 
305318 - Letter to Mr. Perry Katz, Principal Environmental 
305319 
Scientist, McLaren Hart, Inc., from Ms. Caroline 
Kwan, Project Manager, Sediments/Caribbean Team, 
U.S. EPA, Region II, re: Virgin Island Chemical 
Site, St. Croix, United States Virgin Islands, 
January 27, 2000. 
P. 
305320 - Report: Weekly Progress Report - 2/15/00 Through 
305320 
2/21/00, Implementation of Pilot-Scale Study. 
Virgin Island Chemical Site. St. Croix, U.S. 
Virgin Islands, facsimile date February 24, 2000. 
P. 
305321 - Letter (w/attachments) to Ms. Caroline Kwan, 
305330 
Remedial Project Manager, U.S. EPA, Region II, 
from Mr. Perry Katz, Managing Environmental 
Scientist and'Ms. Norma Eichlin, Supervising 
Engineer, McLaren Hart, Inc., re: Virgin Island 
Chemical Site, St. Croix, U.S. Virgin Islands, 
500105 
Revisions to Calculation of Site-Specific Dilution 
Attenuation Factor, May 16, 2000. 
P. 
305331 - Letter (w/attachments) to Ms. Caroline Kwan, 
305345 
Remedial Project Manager, U. S. EPA, Region II, 
from Mr. Terry E. Grimmer, M. S., R. E. A., Head 
of Environmental Health & Safety, Berlex 
Laboratories, Inc., and Mr. William G. Gierke, P. 
G., Corporate E&S, Environmental Remediation, 
Pharmacia & Upjohn, re: Notification - Replacement 
of Prime Contractor/Consultant, Virgin Island 
Chemical Site, Remedial Investigation/Feasibility 
Study (RI/FS), July 12, 2000. 
4.0 FEASIBILITY STXJDY 
4.3 Feasibility Study Reports 
P. 
400001 - Report: 
Feasibility Study Report, Virgin Island 
400170 
Chemical Site. St. Croix, U. S. Virgin Islands, 
prepared by Golder Associates Inc., prepared for 
Berlex Laboratories, Inc. and Pharmacia & Upjohn, 
June 2 001, 
4.4 Proposed Plans (SOP, FOP) 
P. 
400171 - Report: Superfund Proposed Plan, Virgin Island 
400182 
Chemical Site, St. Croix, U. S. Virgin Islands, 
prepared by U.S. EPA, Region II, June 2001. 
4.6 
Correspondence 
P. 
4 00183 - Letter to Mr. Perry Katz, Project Manager, McLaren 
400190 
Hart, from Ms. Caroline Kwan, Project Manager, 
Sediments/Caribbean Team, U.S. EPA, Region II, re: 
Comments of the Feasibility Study Technjical Memo 
and Draft Treatability Study Work Plan for the VI 
Chemical Site, St. Croix, USVI, April 22, 1999. 
7.0 
ENFORCEMENT 
7.3 Administrative Orders 
P, 
700001 - Letter to Lori Singer, Esq., Sills, 
700037 
Cummis, Zuckerman, Radin, Tischman, Epstein, & 
Gross, from Mr. Paul Simon, Section Chief, 
V*! 
N,Y,/Caribbean Superfund Branch, ORC, U.S. EPA, 
Region II, re: Virgin Island Chemical Site; 
I 500106 
Administrative Order on Consent, Index No, II 
CERCLA-94-0401, October 3, 1994, (Attachment: 
Administrative Order on Consent for Remedial 
Investigation/Feasibility Study, Island Chemical 
Co., Inc. And Berlex Laboratories, Inc., 
Respondents, Index No. II CERCLA-94-0401, 
September 29, 1994). 
P. 
700038 - Letter to Mr. William Whitlock, Esq., Pharmacia & 
700039 
Upjohn Co., from Ms. Jeanne M. Fox, Regional 
Administrator, U.S. EPA, Region II, re: Virgin 
Island Chemical Superfund Site, Administrative 
Order on Consent for Remedial 
Investigation/Feasibility Study, Index No. II, 
CERCLA-94-04 01, April 14, 1999. 
9.0 NATURAL RESOURCE TRUSTEES 
9.4 Correspondence 
P. 
900001 - Letter to Mr. Robert Witte, U.S. EPA, Region II, 
900002 
from Mr. Roy E. Adams, Commissioner/SHPO, 
Government of the Virgin Islands of the United 
States, Department of Planning and Natural 
Resources, re: Request for Review of Proposed 
"Remedial Work" at the Island Chemical Site in St. 
Croix, USVI, May 20, 1994. 
10.0 PUBLIC PARTICIPATION 
10.1 Comments and Responses 
P. 
10.0001 - Mailing List form requesting additional 
10.0001 
information on the Virgin Island Chemical site, 
completed by Mr, Keruaeth C, Haines, President, 
Coastal Consultants, March 27, 1995, 
10.2 Community Relations Plans 
P, 
10.0002 - Letter to Mr. Eustace Carr, from Ms. Sherrel 
10.0002 
Henry, Remedial Project Manager, U.S. EPA, Region 
II, re: Community Relations Activities at the 
Virgin Island Chemical Site, February 1, 1995. 
P, 
10.0003 - Letter to Ms. Jennifer Jackson, The University of 
10.0003 
the Virgin Islands, St, Croix Campus, from Ms. 
Sherrel Henry, Remedial Project Manager, U.S, EPA, 
Region II, re: Community Relations Activities at 
the Virgin Island Chemical Site, February 1, 1995. 
500107 
P. 
10.0004 - Letter to Mr. Jeff Lawlor, Virgin Islands Port 
10.0004 
Authority, from Ms. Sherrel Henry, Remedial 
Project Manager, U.S. EPA, Region II, re: 
Community Relations Activities at the Virgin 
Island Chemical Site, February 1, 1995. 
P. 
10.0005 - Letter to Mr. Robert E. Simmons, Postmaster, from 
10.0005 
Ms. Sherrel Henry, Remedial Project Manager, U.S. 
EPA, Region II, re: Community Relations Activities 
at the Virgin Island Chemical Site, February 1, 
1995. 
P. 
10.0006 - Letter to Mr. Luis Cora, Comptroller, Virgin 
10.0006 
Islands Paving, Inc., from Ms. Sherrel Henry, 
Remedial Project Manager, U.S. EPA, Region 
II, re: Community Relations, Activities at the 
Virgin Island Chemical Site, February 1, 1995. 
P. 
10.0007 - Letter to Ms. Natalie B. Stevens, Assistant 
10.0007 
Manager, Charlie's Concrete Services, from Ms. 
Sherrel Henry, Remedial Project Manager, U.S. EPA, 
Region II, re: Community Relations Activities at 
the Virgin Island Chemical Site, February 1, 1995. 
P. 
10.0008 - Letter to Ms. Antoinette King, King's Automotive, 
10.0008 
from Ms. Sherrel Henry, Remedial Project Manager, 
U.S. EPA, Region II, re: Community Relations 
Activities at the Virgin Island Chemical Site, 
February 1, 1995, 
P. 
10.0009 - Letter to Mr. Joe C. Pitts, Vice President t 
10.0009 
General Manager, VIAPCO, from Ms. Sherrel Henry, 
Remedial Project Manager, U.S. EPA, Region II, re: 
Community Relations Activities at the Virgin 
Island Chemical Site, February 1, 1995, 
P. 
10.0010 - Letter to Ms. Karen V. Chapman, Administrative 
10.0010 
Specialist, University of the Virgin Islands, from 
Ms. Sherrel Henry, Remedial Project Manager, U.S. 
EPA, Region II, re: Community Relations Activities 
at the Virgin Island Chemical Site, February 1, 
1995. 
P. 
10.0011 - Letter to Ms. Sherrel Henry, Remedial Project 
10.0020 
Manager, U.S. EPA, from Ms. Pamela J. Philip, Work 
Assignment Manager, CDM Federal Programs 
Corporation, re: Island Chemical Site, St. Croix, 
U.S.V.I., Updated Community Relations Mailing 
List, April 26, 1995. (Attachment: Mailing List, 
Island Chemical/Virgin Island Chemical Site, April 
20, 1995.) 
n 1 
p. 
10.0021 - Plan: Draft Communitv Relations Plan, Virgin 
10.0063 
Island Chemical, St. Croix, U.S. Virgin Islands, 
prepared by CDM Federal Programs Corporation, 
prepared for U.S. EPA, August 1995. 
10.4 Piiblic Meeting 
P. 
10.0064 - Announcement of Public Meeting to present the 
10.0065 
Work Plan for the Virgin Island Chemical Superfund 
Site, February 1995. 
P. 
10.0066 - Sign-in Log for, U.S. EPA, Region II, Public 
10.0067 
Meeting for Virgin Island Chemical Superfund Site, 
Attendees, Wednesday, February 15, 1995. 
10.6 Fact Sheets and Press Releases 
P. 
10.0068 - Fact Sheet:: Remedial Investigation/Feasibility 
10.0071 
Study, Virgin Island/Island Chemical Site, 
Christiansted, St. Croix, U.S. Virgin Island, 
prepared by U.S. EPA, Region II, January 1994. 
P. 
10.0072 - Fact Sheet: Remedial Investigation/Feasibility 
10.0074 
Study, Virgin Island/Island Chemical Site, 
Christiansted, St. Croix, U.S. Virgin Island, 
prepared by U.S. EPA, Region II, December 1994. 
P. 
10.0075 - .Superfund Update: Virgin Island/Island Chemical 
10.0077 
Site, Christiansted, St. Croix, Virgin Island, 
prepared by U.S. EPA, Region II, May 1996. 
11.0 TECHNICAL SOURCES AND GUIDANCE DOCUMENTS 
11.3 State Guidance 
P. 
11.0001 - Report: Virgin Islands Rules & Regulations. Air 
11.0006 
-Pollution Control, Title 12, Chapter 9. facsimile 
April 21, 1999. (Attachment: Government of the 
Virgin Islands of the United States Department of 
Planning and Natural Resources, Air Pollution 
Control, Application Information, General, 
facsimile April 21, 1999.) 
500108 
APPENDIX E 
VIDPNR LETTER ON CONCURRENCE 
500109 
GOVERNMENT OF THE VIRGIN ISLANDS OF THE UNITED STATES 
Deparunent of Planning & Naliiral Re.foiirce.'; 
Divi.uon of Environmental Protection 
RAINBOW PLAZA 
45 MARS HILL 
FREDERIKSTED, ST. CROIX 00841 
(340)773-1082 
July 23, 2002 
Mr. George Pavlous 
Director, ERRD 
US Environmental Protection Agency 
290 Broadway 
New York, NY 10007-1866 
R£: 
DPNR concurrence on tbe Virgin Islands Chemical Record of Decision 
Dear Mr. Pavlous: 
This letter provides the Virgin Islands Department of Planning and Natural Resources (DPNR) 
concurrence on the US Environmental Protection Agency (EPA) Record of Decision (ROD) for 
the Virgin Islands Chemical Superfund Site in St. Croix. 
Based on discussions between your staff and DPNR on July 17, 2002, the proposed change to the 
language on the Institutional Control section ofthe ROD is acceptable as follows: 
'^The Department of Planning and Natural Resources, in consultation with EPA, 
will utilize institutional controls (in the form of existing well permitting laws and 
regulations) to limit tbe pumping of groundwater at tbe Site to prevent interference 
with tbe selected remedy and to also prevent human exposure to contaminated 
groundwater until MCLs are achieve." 
DPNR expects to work closely with EPA during the implementation ofthe selected remedy for 
the Site - Altemative 3 (SVE/AS for the AST Area, MNA for the FPP Area, and Institutional 
Controls) and Altemative 4 (SVE/AS for the AST Area, Groundwater Extraction and Treatment 
for the FPP Area, and Institutional Controls) as a contingency remedy which would be 
implemented if MNA does not reduce groundwater contamination to MCLs in a reasonable 
timeframe. DPNR considers this Record ofDecision as an important step towards the eventual 
reclamation of a valuable Virgin Islands resource. 
Thank you. 
Sincerely, 
^ 
3DIJJ0 S.H0J,03yia 
eo:2iwd i-sn^oo 
Jean C. Plaskett, Esq. 
Commissioner 
A><-i i^Jo ••••IBH 'i' "^3143 
II NQi53a"Vc{3"S"n 
5 0 0 1 1 0 
iDM ci-viunvK/ucr-waiergui 
• /-20- I , o-iDAiu ; viur.AiK/Utr-watergut-> 
1212 ea? 4264;# 2/ 2 
GOVERNMENT OFTHE VIRGIN ISLANDS OF THE UNfTRD S'TATRS 
ncpaniiKiii ('/ Claiming SL Nntm-al Ketounc^ 
Division (if F.t\viit>nmtiittil Piotfvlion 
RAINBOW PLAZA 
45 MARS HILL 
FREDERIKSTED. -ST CROIX 00841 
(340)773.1082 
July 23, 2002 
Mr, George Pavlous 
Director. ERRD 
US EnvironmentaJ Protection Agency 
290 Broadway 
Now York. NY 10007-1866 
RE: 
DPNR concurrence OB the Vir^gin Islands Chemical Record ofDecision 
Dear Mr. Pavlous: 
This letter js^vides the Virgin Islands Department of Planning and Natural Resources (DPNR) 
concurrence on the US Environment&i Protection Agency (EPA) Rec»rd ofDecision (ROD) for 
the Virgin Islands Chemical Superfund Site in St Croix. 
Based on discussions between your stuff and DPNR on July 17,2002, the proposed change to the 
language on tho Institutional Control section uf (he ROD is acceptable as follows: 
*^he Department of Planning and Natarai Rcsonrccs, In consultation with EPA, 
will utilize institutional controls On the form of existing well permitting laws and 
regulations) to Umit the pumping of groundwater at the Site to prevent interference 
with tbe gelected remedy and to abo prevent human exposure to contaminated 
groundwater until MCLs lire achieved." 
DPNR expects to work closely with EPA during the implementation ofthe selected remedy for 
the Site - Altemative 3 (SVE/AS for the AST Area. MNA for die FPP Area, and Institutional 
Controls) and Altemative 4 (SVE/AS for the AST Area, Groundwater Extraction and Treatment _ 
for the FPP Area, and Institutional Controls) as a contingency remedy which would be 
implemented if MNA does not reduce groundwater contamination to MCLs in a reasonable 
timeframe. DPNR considers diis Record of Decision as an important step towards the uvenlual 
reclamation of a valuable Virgin Islands resouree. 
Thank you. 
Sincerely, 
i ^ l ^ s n C. Plaskett, Esq. 
Commissioner 
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