Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Tutu Wellfield Superfund Site
Proposed Cleanup Plan
Public Meeting
SCHEDULED 
Thursday, August 23, 2018 
7:00PM
Grace Gospel Chapel
St. Thomas, USVI
*528394*
528394
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Cecilia Echols –
EPA Community Involvement Coordinator
Caroline Kwan –
EPA Project Manager
Meeting Participants
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
EPA will present the conclusions of the Focused 
Source Remedial Investigation, Risk Assessment 
and Feasibility Study 
EPA will present and discuss the Proposed Plan 
for the cleanup of the contaminant source areas 
of the Tutu Site
Public is encouraged to provide comments 
tonight and until Friday September 7, 2018
Meeting Objectives
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Meeting Agenda
Superfund Overview
Site Background
Remedial Investigation
Risk Assessment 
Feasibility Study
Preferred Remedy
Questions/Comments?
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Toxic waste disposal disasters prompted law passage
by Congress in 1980
Provides Federal funds for cleanup of hazardous
waste sites
Allows EPA to respond to emergencies involving
hazardous substances
Empowers EPA to compel Potentially Responsible
Parties to pay for or conduct site clean up
Superfund Law 
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Superfund Cleanup Process
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Meeting Agenda
Superfund Overview
Site Background
Remedial Investigation
Risk Assessment 
Feasibility Study
Preferred Remedy
Questions/Comments?
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Tutu Wellfield 
Superfund Site
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
1969 - Curriculum Center property owned by LAGA 
Industries Ltd. (LAGA), a textile manufacturing facility
1970 to 1978 – Purchased by Duplan Corporation and 
began dry cleaning operations using Tetrachloroethene
(PCE)
1979 to 1981 - Purchased by Panex, sold to VIDE
1982 to 2017 - Multi-use building by VIDE
Site History
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
• 1982 to 1989 - Multiple investigations by EPA and 
Potentially Responsible Parties (PRPs)
• 1994 to 1995 - Remedial Investigation (RI) identified 
co-mingled plumes with chlorinated volatile organic 
compounds (CVOCs) and petroleum/gasoline 
components
• September 1995 - Site listed on the National Priorities 
List (NPL)
• Studies concluded that the CVOC plume with 
dichloroethene (DCE), tetrachloroethene (PCE), 
trichloroethene (TCE), and vinyl chloride (VC) 
originated at or near the Curriculum Center
Site History
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
August 1996 - Operable Unit 1 (OU1) Record of Decision 
(ROD) selected groundwater extraction and treatment to 
restore  groundwater
• 2004 - Construction of the remedy completed and 
included two groundwater treatment systems to treat the 
CVOC plume
• 2004 to 2013 - Groundwater treatment facilities operated 
by EPA; transferred to USVI in 2013
• April 2015 - Operable Unit 2 (OU2) created by EPA to 
investigate potential additional contaminant source areas
Site History
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Status of OU1 Remediation 

Current Remedy: Groundwater 
extraction, ex-situ treatment, 
discharge to Turpentine Run, and 
institutional controls

Groundwater treatment systems 
installed at the Curriculum Center 
property and near O’Henry Dry 
Cleaners 

SVE system installed at the 
Curriculum Center and operated 
from 2004 to 2006; significant 
decrease in influent 
concentrations 

Insufficient reduction of 
contamination at the Curriculum 
Center area
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Meeting Agenda
Superfund Overview
Site Background
OU2 Remedial Investigation
Risk Assessment 
Remedial Alternatives
Preferred Remedy
Questions/Comments?
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
OU2 Study Area - Curriculum Center Property
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
OU2 Focused Source RI
Activities conducted at the Curriculum Center property 
April 2016 to June 2017
Surface geophysical survey
Rock matrix diffusion sampling and analysis
Monitoring well installation
Borehole geophysical investigation
Packer testing and sampling
Groundwater sampling
Groundwater level monitoring
Dense non-aqueous phase liquid (DNAPL) monitoring 
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
OU2 Groundwater Sampling Results
Characterized bedrock aquifer; defined two hydraulically 
conductive zones 
DNAPL is present and will act as an ongoing source 
Dissolved phase CVOC contamination is present 
Contaminants present in the rock matrix will continue to 
back-diffuse into groundwater 
The degree of natural degradation varies throughout the 
Curriculum Center area
The capture zone of the existing extraction system does 
not extend far enough in a downgradient direction
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Monitoring Well Exceedances Summary
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Conceptual Site Model
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Meeting Agenda
Superfund Process Overview
Site Background
Remedial Investigation
Risk Assessment
Remedial Alternatives
Preferred Remedy
Questions/Comments
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
OU2 Risk Assessment Process
Step 1 • Hazard Identification
Step 2 • Exposure Assessment
Step 3 • Toxicity Assessment
Step 4 • Risk Characterization
Drinking water use pathway
Source: Thinkstock Photos
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
OU2 Risk Assessment Summary
• Contaminated groundwater presents an unacceptable 
exposure risk.
• VC, TCE, PCE and cis-1,2-DCE pose a lifetime cancer 
risk exceeding 1x10-4
• Vapor intrusion from PCE and TCE are also of potential 
concern to workers 
• Future use of the building is currently unknown
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Meeting Agenda
Superfund Process Overview
Site Background
Remedial Investigation 
Feasibility Study
Preferred Remedy
Questions/Comments?
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Remedial Alternatives – Cleanup Options
Alternative 1 – No Action
Alternative 2 – Expand Existing Pump and Treat
System
Alternative 2A – Reinjection
Alternative 2B – Air Sparging/ Soil Vapor Extraction
(AS/SVE)
Alternative 2C – In Situ Chemical Oxidation (ISCO)
Alternative 2D – Surfactant Flushing
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Remedial Alternatives – Cleanup Options 
(continued)
Alternative 3 – In Situ Thermal Treatment and
Pump and Treat
Alternative 4 – In Situ Steam Injection and Pump
and Treat
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Alternative 1 – No Action
•
No Action to remediate the contaminated groundwater
•
No Institutional Controls
Pros – Basis for comparison with other process options
Cons – Contaminants in groundwater will continue to spread. Human health and 
environmental risks remain
Costs-
•
Capital Cost: $0
•
Annual operations and maintenance (O&M) Costs:  $0
•
Present-Worth Cost:  $0
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Remedial Alternatives – Common Elements for 
Alternatives 2, 3 and 4

Pre-Design 
Investigation (PDI) 

Institutional Controls

Upgrade the current 
system 

Long-term monitoring 
until clean up levels 
are achieved

Site Management 
Plan

Five Year Reviews
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Alternative 2 – Expand Existing Pump and Treat System
•
Expand existing system, add 2 new 
extraction wells downgradient 
•
Upgrade current system capacity
•
Replace existing equipment
•
Alternate pumping from source area wells
•
Dual-phase extraction (DPE) / enhanced 
fluid recovery (EFR) from source area wells
Pros - containment of plume; removal of 
DNAPL
Cons - remedial timeframes are long
Timeframe-
•
Estimated to be in excess of 30 years;
•
Pump and treat (P&T) and long term 
monitoring (LTM) costs estimated for 30 
years.
Costs-
•
Capital Cost: $4,616,924
•
Annual operations and maintenance (O&M) 
Costs:  $7,600,039
•
Present-Worth Cost:  $12,273,313
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Alternative 2A – Reinjection
Enhancement of Alternative 2 with reinjection 
of treated water downgradient through 2 new 
injection wells
Pros- better hydraulic control and maintaining 
water   balance
Cons - additional hydrogeological analysis 
needed; reinjection wells will need 
maintenance; long remedial timeframes
Timeframe -
•
Estimated to be in excess of 30 years; 
•
P&T and LTM costs estimated for 30 
years.
Costs-
•
Capital Cost: $425,260
•
Annual O&M Costs: $51,364 plus Alt 2
•
Present-Worth Cost: $476,624
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Alternative 2B – AS/SVE
Enhancement of Alternative 2 with air sparging and 
soil vapor extraction (AS/SVE) in source areas; add 
25 SVE and 30 AS  wells
Pros- mobilize residual DNAPL within the zone 
influenced by air sparging; may increase the mass 
removal rate reducing the timeframe of the P&T 
system 
Cons- air flow may not be uniform, depends on how 
well the injected air permeates from injection point, 
connectivity of fractures and groundwater mounding
Timeframe-
•
The AS/SVE system at source area for 5 years; 
•
Based on calculations, downgradient area will 
reach drinking water standards in 25 years; 
•
LTM costs estimated for 30 years
Costs -
•
Capital Cost: $1,710,790
•
Annual O&M Costs: $169,501 plus Alt 2
•
Present-Worth Cost: $1,880,291
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Alternative 2C – ISCO
Enhancement of Alternative 2 with in situ 
chemical oxidation (ISCO) cylinders in select 
source area wells; 64 cylinders in 12 
monitoring wells; replaced yearly
Pros- passive treatment for source area 
concentrations; less expensive
Cons - will affect the bioactivity in the aquifer 
Timeframe -
•
ISCO at source area for 5 years;
•
Based on calculations, downgradient 
from treated source area will reach 
drinking water standards in 25 years; 
•
LTM estimated for 30 years
Costs-
•
Capital Cost: $93,920
•
Annual O&M Costs: $98,620 plus Alt 2
•
Present-Worth Cost: $192,540
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Alternative 2D – Surfactant Flushing
Enhancement of Alternative 2 with surfactant 
flushing in source areas; 2 deep injection 
wells, 5 shallow injection wells
Pros - removal of source area concentrations 
and DNAPL 
Cons- effective only if there is contact; ability 
of the formation to accept a sufficient volume 
of surfactant solution is unknown
Timeframe -
•
Surfactant flushing at source area for 1 
year; 
•
Based on calculations, downgradient 
from treated source area will reach 
drinking water standards in 25 years; 
•
LTM estimated for 26 years.
Costs -
•
Capital Cost: $1,222,799
•
Annual O&M Costs: Same as Alt 2
•
Present-Worth Cost: $1,222,799
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Alternative 3 – In Situ Thermal Treatment and 
Pump and Treat System
•
In situ thermal treatment to target DNAPL in 
source areas and pump and treat for 
hydraulic control; 260 to 270 heater wells, 
co-located with 260 to 270 vacuum 
extraction points
•
Add 2 downgradient extraction wells and 
upgrade the current treatment system 
capacity and equipment
Pros - ability to penetrate fractured rock matrix 
and to treat DNAPL and CVOCs
Cons - high capital costs 
Timeframe -
•
Thermal at source area for 2 years; 
•
Based on calculations, downgradient from 
treated source area will reach perimeter 
P&T wells in 10 years; 
•
LTM estimated for 12 years.
Costs-
•
Capital Cost: $79,015,003
•
Annual O&M Costs: $4,094,323
•
Present-Worth Cost: $83,221,216
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Alternative 4 – In Situ Steam Injection and 
Pump and Treat 
•
In situ steam injection in source areas to 
release DNAPL with pump and treat for 
hydraulic control, 60 steam injection wells and 
30 multi-phase extraction wells
•
Add 2 downgradient extraction wells and 
upgrade the current treatment system capacity 
and equipment
Pros - mobilize DNAPL which will be captured by 
the extraction wells
Cons - effectiveness of steam injection relies on its 
ability to contact, heat, and physically displace 
contaminants; high capital costs
Timeframe-
•
Steam treatment at source area for 2 years; 
•
Based on calculations, downgradient from 
treated source area will reach drinking water 
standards in 25 years; 
•
LTM estimated for 27 years
Costs-
•
Capital Cost: $23,541,419
•
Annual O&M Costs: $7,169,229
•
Present-Worth Cost: $30,773,828
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
EPA’s Nine Criteria 
for Selecting Cleanup Plans
EPA uses nine criteria to 
evaluate remedial alternatives 
presented in the Feasibility 
Study and choose which to 
implement
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Threshold Criteria 
1.
Overall Protection of Human Health and 
the Environment: Will the plan protect people and 
the plant and animal life on and near the Site? EPA 
cannot and will not choose a plan that does not meet this 
basic criterion.
2.
Compliance with Applicable or Relevant 
and Appropriate Requirements: Does the 
alternative meet all federal and state environmental 
statutes, regulations and requirements? The chosen 
cleanup plan must meet this criterion.
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Balancing Criteria 
3.
Long-Term Effectiveness and Permanence: Will the effects of the 
cleanup last or could it be ineffective and cause future risks?
4.
Reduction in Toxicity, Mobility or Volume through Treatment: Does 
the alternative reduce the harmful effects, spread of, and amount 
of the contaminated material?
5.
Short Term Effectiveness: How soon will site risks be reduced? 
Could the cleanup cause short-term hazards to workers, residents 
or the environment?
6.
Implementability: Is the alternative technically feasible? Are the 
right goods and services (i.e. treatment machinery, space at an 
approved disposal facility) available to complete the plan?
7.
Cost: What is the total cost of an alternative over time? EPA must 
choose a plan that gives necessary protection at reasonable cost.
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Modifying Criteria 
8.
State/Territory Acceptance: Do state/territory 
environmental agencies agree with EPA’s 
proposal?
9.
Community Acceptance: Acceptance of 
preferred alternative by the impacted 
community will be assessed following the 
public comment period.  Provide your 
comments.
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Remedial Alternatives Cost Estimates
Alternative
Capital Cost
Annual
Operation &
Maintenance 
Periodic Cost
Total 
Present 
Value
1 – No Action
$0
$0 
$0
$0
2 – Expand Existing Pump and 
Treat
$4.6 million
$433,315 
(Years 1 to 30)
$176,750      
(Year 30)
$12.2 million
2A – Reinjection
$425,260
$11,500  
(Years 1 to 30)*
Same as Alt 2 
(Year 30)
$476,624 **
2B – AS/SVE
$1,710,790
$37,950  
(Years 1 to 5)*
Same as Alt 2
(Year 30)
$1,880,291**
2C – ISCO
$93,920
$22,080 
(Years 1 to 5)*
Same as Alt 2
(Year 30)
$192,540**
2D – Surfactant Flushing
$1,222,799
Included in Alt 2
(Years 1 to 26)
Included in Alt 2 
(Year 26)
Included in 
Alt 2
3 – In Situ Thermal Treatment 
and Pump and Treat
$79,015,003
$433,315
(Years 1 to 12)
$176,750 
(Year 12)
$83,221,216
4 – In Situ Steam Injection and 
Pump and Treat
$23,541,419
$433,315 
(Years 1 to 27)
$176,750 
(Year 27)
$30,773,828
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Meeting Agenda
Superfund Overview
Site Background
Remedial Investigation 
Remedial Alternatives
Preferred Remedy
Questions/Comments
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Preferred Remedy - Alternative 2 , Expand Existing 
Groundwater Extraction and Ex-Situ Treatment (Pump and 
Treat) with Alternative 2A, Reinjection
Expansion of the existing pump and treat system to include downgradient extraction wells;
Upgrade pump and treat system to higher flow rate;
Upgrade all treatment equipment to accommodate additional flow and improve efficiency; 
Reinjection of treated water;
Alternate pumping from existing monitoring wells with high contaminant concentrations;
Dual phase extraction from source area wells; and
Long-term groundwater monitoring.
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Contingency Remedy - Alternative 2 , Expand Existing 
Groundwater Extraction and Ex-Situ Treatment 
(Pump and Treat) with Alternative 2B, AS/SVE
Expansion of the existing pump and treat system to include downgradient extraction wells;
Upgrade pump and treat system to higher flow rate;
Upgrade all treatment equipment to accommodate additional flow and improve efficiency; 
Air Sparging/SVE at source areas and
Long-term groundwater monitoring.
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Questions and Comments?
Please address written comments no later than  
Friday, September 7, 2018 to:
Caroline Kwan
US EPA 
290 Broadway, 20th Floor
New York, NY  10007-1866
Phone: (212) 637-4275
E-mail:  kwan.caroline@epa.gov
Region 2 serving the people of New Jersey, 
New York, Puerto Rico and the U.S. Virgin Islands
8/27/2018
Tutu Wellfield Superfund Site
***
Public Meeting
Thursday, August 23, 2018 
Thank you!
https://www.epa.gov/superfund/tutu-wellfield