© Timothy R Knutson Texaco Inc 2000 Westchester Avenue Attorney White Plains NY 10650 Phone 914 253 4633 Fax 914 253 4629 Andrew Praschack, Esq. USEPA - Region II Caribbean Field Office, Office 2A 1413 Fernandez Juncos Avenida Santurce, Puerto Rico 00909 October 26, 1993 Re: Revised Schedule for Comprehensive RI, Tutu Wells Site, St. Thomas, USVI Dear Andy: As per our agreements in our meeting at U.S. Environmental Protection Agency (USEPA) offices in Santurce, Puerto Rico on October 21, 1993, the Tutu Environmental Investigation Committee (TEIC) has prepared a revised schedule (Figure 1) for the completion of the remedial investigation (RI) and preparation of a draft feasibility study (FS) for the Tutu Wells Site. The scope of the RI has been expanded to include a larger areal extent, and to incorporate the data regarding other sites and potential sources of volatile organic-contaminants (VOCs) and other constituents that have been generated, and will be generated, by the Potentially Responsible Parties (PRPs) that you have identified and other parties to the private litigation regarding the site. As agreed during our meeting, the goal is to complete the second phase of RI field work, submit a draft RI Report, incorporate the USEPA's comments into a final RI Report, submit an analysis of remedial alternatives, and submit a draft FS Report by December 1, 1994. TEIC and Geraghty & Miller will expend all efforts to work with the PRP Group and to expedite this aggressive schedule and complete the indicated work on time, or sooner if at all feasible. The schedule shown of Figure 1 was prepared assuming that prolonged delays will not be caused by difficulties in obtaining property access or permits for field activities, or any other problems which are unforeseen and unaccounted for at present. This schedule is also contingent on several assumptions regarding USEPA review A TUT 006 1337 ) *64758* 64758 time and work product generation, including: • Review and approval of this supplemental RI Scope Addendum (submitted to the USEPA by December 21, 1994) by January 20, 1994. • Completion of the Baseline Risk Assessment by USEPA no later than 4 weeks after receipt of validated groundwater quality data from the second monitoring well sampling event. • Review by USEPA of the Draft RI Report 4 weeks after submittal. The PRPs and their consultants appreciate the cooperation of the USEPA in recognizing the expanded scope of the RI, and look forward to a continued working relationship to complete the RI and FS in accordance with the aggressive schedule shown on Figure 1. If you have any questions, please call. Sincerely, TUTU ENVIRONMENTAL INVESTIGATION COMMITTEE • / ""'")/ Timothy R. Knutson, Esq. Texaco Christopher Gibson, Esq. Archer & Greiner Attachment cc: Mel Hauptman; USEPA Paul Ryan; Texaco Carolyn Kwan; USEPA Thomas V. Danahy, Geraghty & Miller, Inc. Sarah K. Odland,'CDM Federal Programs Daniel A. Nachman, Geraghty & Miller, Inc. Henning Moe; CDM Federal Programs Alberto Gutierrez, H + GCL Ana Gloria Ramos; TEIC p TUT 006 1339 PROJECT: Allf GERAGHTY COMPREHENSIVE RI SCHEDULE PROJECT NO. FIGURE 1 Ali' & MILLER, INC. PROO 13.001 SYM REVISIONS DATE .. Environmental Services LOCATION: AUTiiORIZA TION NO. TUTU WELLS SITE LEGEND: SCHEDULED PROGRESS PROJECT SCHEDULE DESCRIPTION: I I ACTUAL PROGRESS SCH'D BY: D. NACHMAN DATE: 10/22/93 SCHEDULED PROGRESS (,c) ST. THOMAS, U.S. VIRGIN ISLANDS CHK'D BY: T. DANAHY DATE: 10/22/93 --------- ACTUAL PROGRESS (,c) • MILESTONES APPV'D BY: D. NACHMAN DATE: 10/22/93 ITEM 1993 I 1994 I 1995 NOV DEC JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV DEC JAN FEB MAR APR NO. 31 7 14 21 28 5 12 19 211 2. 9 11 23 30 e 13 20 27 e 13 20 27 3 10 17 24 1 8 15 22 29 5 12 19 11 3 10 17 24 31 7 14 21 28 4 11 ,e 25 2 9 11 13 30 I 13 20 27 4 II 18 25 1 8 IS 22 29 S 12 19 28 5 12. 19 28 2 9 1813 30 1 DATA COMPILATION; PREP. OF RI SCOPE ADDENDUM 2 SUBMITTAL OF OF RI SCOPE ADDENDUM - 12/21/93 • 3 USEPA REVIEW OF RI SCOPE ADDENDUM 4 USEPA APPROVAL OF RI SCOPE ADDENDUM • 5 PREPARATION FOR FIELDWORK/COORDINATE SUBCONTRACTORS 6 INSTALLATION & DEVELOPMENT OF B TO 10 NEW WELLS 7 SECOND GROUNDWATER SAMPLING EVENT B DATA VALIDATION 9 BASELINE RISK ASSESSMENT (RA) BY USEPA (ESTIMATED) 10 PREPARATION OF DRAFT RI REPORT 11 SUBMITTAL OF DRAFT RI REPORT (6 WEEKS AFTER ITEM 9) ,. 12 USEPA REVIEW OF DRAFT RI REPORT (ESTIMATED) 13 MEETING WITH USEPA RE: USEPA COMMENTS ON DRAFT RI • 14 PREPARATION OF FINAL RI REPORT 15 SUBMITTAL OF FINAL RI REPORT -~ 16 ANALYSIS OF REMEDIAL ALTERNATIVES (START AFTER ITEM 9) 17 SUBMITTAL OF ITEM 1 6 (WITHIN 6 WEEKS AFTER ITEM 9) 0 18 MEETING WITH USEPA RE: REMEDIAL ALTERNATIVES n 19 RESUBMISSION OF ANALYSIS OF REMEDIAL ALTERNATIVES H 20 PREPARATION OF DRAFT FEASIBILITY STUDY (FS) REPORT 21 ~~~M'1'afRAF I t'EASIBILI I l ::> I UUl Kl:.t-'UI'< I l7 VVl:.1:.1'.::S Ar IC.I'( • 22 PRESENTATION TO USEPA RE: DRAFT FS REPORT • 23 USEPA REVIEW OF FEASIBILITY STUDY (DURATION NOT SHOWN) 24 USEPA COMMENTS ON DRAFT FS REPORT (IF NECESSARY) 25 MEETING RE: USEPA COMMENTS ON FS REPORT (IF NECESSARY) 26 PREPARATION OF FINAL FS REPORT (IF NECESSARY) 27 SUBMITTAL OF FINAL FS REPORT (IF NECESSARY) 28 B:TU-257 EPA REGION II SCANNING TRACKING SHEET DOC ID # 64758 DOC TITLE/SUBJECT: TUTU WELLS SUPERFUND SITE FIGURE 1 COMPREHENSIVE Rl SCHEDULE (Page: TUT 006 1339) THIS DOCUMENT IS OVERSIZED AND CAN BE LOCATED IN THE ADMINISTRATIVE RECORD FILE AT THE SUPERFUND RECORDS CENTER 290 BROADWAY, 18™ FLOOR NEW YORK, NY 10007