OCT-15-1993 .14:36 
FROM 
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October 14,
OirtetCW
(*09) 
3S4-3077
Andrew Fr«schaK, Eflquire
United statae Envipgnaental Protection
Caribbean field office
1413 FHrnantiez Junaoa Avenue
Santurce, Puerto Rioo 
0090S
<rutu WBliri«ld« Bit*,
Andy:
Ws 
ara 
writirwr on behalf 
of 
tfte 
Putu Envirorun*ntal
investigation enramitt*« ("TEIC") to forw^Jly request an extenaion
of time to prwid* th« taohnieal aeliv«r»i>iec eeheduled for
suisnteeion pursuant to the February, 1992 Administrative Order an
Oonasnt ("AOC") . AB w» sbmli discuss fcalow, th* expansion &f tftis
PCD j met from a narrow, B«cvice station atudy tte an expanded
aquifer-vid* afudy dictates tha ne«d COJ- adflitlenal time.
There can t>o no «tue»tien that th* ntu<3y, as originally
connanrfn.at.ed in th» February, 1992 *ocr has xaid«rgon« an evolution
viiieh iias greatly expaadafl ito 
frttramfetere- 
This iaoe is
acknowl»dg»d in cajfcliis* Swan's Augurt 30, 1993 letter reviaving
tn« 
£>KF Tfl^hnical Conmitteft's connenta on Technical w«naran<su»
Ho, II. 
in that l«*ter/ tb* Agency BdtnowlBflges thit tb« 7BIC
investigation "neeossarily was cDn«uctBd froa elaj»r projeinity to
tha TeXftso and Saso eervieft stations,* {p. 53 and «»at th« "eoop*
e£ the 
inv«stig»tiDn has ftjcpanded. " (p. 6). 
Nonetheless,
significant progress has been aado in identifying tha multiple
sources of groundwatisr and goii oontominfttien at the siea.
TUT 
007 
O936
*64949*
64949
OCT-15-1993 14:37_ F
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Andrew FrasehaX, Esquire
oetoiber 14, 19*3
2
with regard to the status of the originally approved achedule,
th* effective date of the AOC van Karch 4, 1993, and that dictated
a start of work of April gt is 92. Son* of the earlier tasks
identified iu this aehedula, including tha subaittai oS ^Technical
Memorandum No, I, ware noapletefi ahead of tchodyle.
Unfortunately, delays war* incurred • in the euhaittal and
review of Technical Kemoranaum No, II. Th« originally approved
wwrie plan anticipated thbt Tershnieal HeworanduiB Kro. II would to*
submitted on Oeeaoher 16, 1992 and that SPA would approve it by
January Zl/ 1993. In actuality, Technical Meaoranduun NO- XI Vas
not vuomitted until Karen i, 2.993. Tiiare are sevRral reaeena far
this dalay.
First, tha detivarables «er» expanded to include all of the
validated soil data .*o oonffloeions couia be reaanad regard J ng
potential sources of eentaftittatian. 
second/ delays were
encountered as a r*»ult of Tfiic's roviow of Technical Meaerandun
Ko. IT. Finally, it took longer than anticipated for £FA to review
T«ehnieal Kenoratidun NO. II and to provide its extensive
TJie originally approved ecbeaule did not anticipate that a
second field effort would b* required; inatood, it only anticipated
that a second grotmdwatcrr ftaicplin? event would be l&plenentedt. ?h«
need for additional monitoring walla and soil aaaples vocld, ax
neceaaitVr extend t&e eciiedulft beyond that Whioh ia shown on the
originally approved EPA war* plan and beyond tha septeafcer 30, 199*
completion date that you havo discussed for the ROD.
Furth»rffiotcr it was the hope of TEIc that «ra vould be *bl« to
re-jnobilizc to iBplBm«nt: the Phasa tr field vork in lat« AnguflC,
1992. Hov»rer, several difficulties arose, inclusin? difeioulties
obtaining aeoBco which hindered this offort. Additionally, delays
were encountered as a result of discussions vhich V«TA taking place
batweftn B?A and the expanded PRP Committee <. We certainly did not
var.t to charge ahead if there waa a substantial (jfroyp of PiU?c
felt that tha work wan lacking or deficient frais a teohnical
on the other hand, we have made trenendoue stridee in our
errorta to ±org» a ERP group who aay fee in a position to aupport
and implement an integrated aquifer renetty. In short , we have
formed a. ?RP ^roup connisting of thooo entities who either own or
oparata properties froa which tharo is a suspected discharge of
contaminants into the aquifer. B?A hus b»»ii extreaaly Bttpbortive
of tbee* efforts beeauee E?A realizes, 03 do the jnemhors of TE1C,
that auooeaafully romediatdrjg groundwater contamination emanatingr
TUT 007 0937
Tn 
£12125458050 
P.0~>
OCT-15-1993 
14:38 
FROM 
EPS
OCT-14-199G 
1VJ09 
FRO1 
O3>€R8JGRE1SER 
TO 
1S097297747 
P.04/-aS
Andrew Prasehak, Esquire
October 14, 1993
Page 3
from multiple sources requires close cooperation between the PRPs
and-the Agency.
We anticipate that vithin the next several weeks, many of tha
PRPs will have signed a KRP Agreement, it also appears that Esco
and Texaco will continue under the auspices of TE1C to complete
the RI/FS. However, the PKP Technical Committee will be kept
closely apprised of all developments. 
These are promising
developments which, in the long run, should provide a framework for
the regulated community and the Agency to work together.
In summary, the schedule must be for a variety of reasons/
many of which are beyond our control. 
There can be little
question, however, that we sit at a critical crossroad in our
continuing relationship with the Agency. If tfte Agency wants to
perform a comprehensive study of this aquifer-wide contamination,
and if the Agency wants to address the concerns of the other PRPs
at this site, then modifications must be made to this schedule
which will make it impossible for the Agency to issue a re'sord of
decision ("ROD") by September 30, 1994.
We have attached hereto a project eohedule for completing the
RJ and FS assuming that the work recommended by the expanded PR?
Technical Committee is implemented. This schedule envisions the
atubmittal of a supplemental work plan to EPA by December 21, 19S>3
and provides for three to five weeks of EPA review. Remobiiization
to begin .the field work for Phase ti will start in early March,
1994. Two months for this expanded field program are anticipated;
the second groundwater sampling event would begin two weeks after
well development and would take approximately one month because the
PKP Technical Committee has envisioned * comprehsnaiva sampling
event of all monitoring wells and supply wells in the study area.
The schedule shown on the Attached figure envisions a draft SI
report being submitted to EPA by late October, 1994 and a final FS
in March, 1995.
We have arranged a meeting for October 21, 1993 between the
Agency's legal and technical staff and TEIG's legal and technical
staff to discuss these concerns, we will also attempt to diacuss
these issues with jfs. Kwan and yourself prior to that date.
in the end, the members of TEIC are confident that we share
T^* f??? 9°*ls ** the Agency — namely, to conduct a study which
identifies all sources of contamination in the wellfields and which
proposes a remedial action plan which is coat-effective and
protective of the public health and safety. 
We will take a
flexible approach regarding the schedule, scope and structure of
TUT OO7 O938
OCT-15-1993 14:38 
FROM 
EPft
OCT-14-1993 
17=09 
FROM
TO
TO
82125458050 
P.0-
18097297747 
P.05/BS
Andrew PraacnaK, Esguira
October 14, IS93
Page 4
the HI/PS so as to accommodate EPA's regulatory needs, and we are
eagar to complete the studies BO that we ean start resolvina the
problems that are identified. Please call trim or me with any
questions or comments. 
*
you for your help. 
\
^A~T^Z^' £,____
CHRISTC HER* R* GISSON
CRG:jdh
Attachment
cc; Timothy R. Knutoon, Esquire (via telecopier)
11™ GJoria Jtattos 
(via telecopier)
w. Brown, Esquire 
(via telecopier)
TUT OO7 09^9
OCT-15-1993 14:39" 
FROM 
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OCT-14-1993 1V:£S FRO1
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TBSKO LESS. KFT * 516897950574
TO
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8212545305S
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