Superfund Record of Decision: Janssen, PR


           United States        Office of
           Environmental Protection   Emergency and
           Agency           Remedial Response
EPA/ROD/R02-93/218
September 1993
&EPA   Superfund
          Record of Decision
          Janssen, PR

-------
50272-101
REPORT DOCUMENTATION
PAGE
4.
7.
9.
12.
1. REPORT NO. 2.
EPA/ROD/R02-93/218
Title and Subtitle
SUPERFUND RECORD OF DECISION
Janssen, PR
First Remedial Action
Author(s)

Performing Organization Nam* and Address

Sponsoring Organization Nam* and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. Recipient's Accession No.
5. Report Date
09/30/93
6.
8. Performing Organization Rept. No.
1 0 Project Task/Work Unit No.
1 1 . Contract(C) or Grant(G) No.
(C)
(G)
13. Type of Report & Period Covered
800/800
14.
IS. Supplementary Notee

PB94-963823
16. Abstract (Limit: 200 words)

The 25-acre Janssen site is a pharmaceutical manufacturing facility located in Gurabo,
Puerto Rico. Land use in the area is predominantly light industrial, with some
low-density rural areas and a residential community located two miles from the site.
The site also borders the Mamey Creek, a tributary of the Gurabo River, which
eventually flows into the Rio Grande de Loiza River. An estimated 10,000 people who
reside within three miles of the site use public drinking water supply wells from the
Gurabo regional alluvial aquifer to obtain their drinking water supply. In addition,
there are 86 wells located within three miles of the site which currently are used for
agricultural, industrial, sanitary, and domestic purposes. The Janssen facility
consists of a chemical and manufacturing building, a pharmaceutical building, an
above-ground tank farm, a process wastewater treatment facility, a utilities building,
an electrical substation, a cooling tower, a new quality assurance/quality control
building, and two ground water production wells. In 1982, Janssen began manufacturing
operations for pharmaceutical products and intermediates onsite, and used chemicals
containing VOCs and other organics in these products. In 1989, Janssen discovered
chloroform in the onsite ground water production wells and, subsequently, discontinued
their use as a drinking water source. Later in 1989, Janssen voluntarily notified the

(See Attached Page) .
17. Document Analysis a. Descriptors
Record of Decision - Janssen, PR
First Remedial Action
Contaminated Media: soil, gw
Key Contaminants: VOCs (toluene), other organics

b. Identifiers/Open-Ended Terms
c. COSATI Field/Group
18. Availability Statement
1 9. Security Class (This Report)
None
20. Security Class (This Page)
None .
21. No. of Pages
74
22. Price
(SeeANSI-Z39.18)
S»» Initructlona on Rtvene
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce

-------
EPA/ROD/R02-93/218
Janssen, PR
First Remedial Action

Abstract (Continued)

State, EPA, and other agencies that it had detected chloroform in two drinking water wells
onsite at levels as high as 2,000 ug/1. After the release was discovered, Janssen
conducted a site investigation, which included pumping a production well to reduce the
further migration of the ground water volatile organics plume. In 1991, EPA required
Janssen to conduct a RI/FS and to implement Early Action Activities to mitigate possible
risks associated with existing chloroform contamination and reduce further migration of
the ground water plume. Later in 1991, Janssen installed soil vapor extraction wells and,
in 1992, conducted a trial test of the system. In 1993, pursuant to EPA approval, Janssen
began implementing this system. It is believed that the onsite soil and ground water
contamination is the direct result of a leakage from a fire trap at the Chemical Plant
building. This ROD addresses an interim remedial action for the contaminated soil and
ground water beneath the Chemical Plant building. The primary contaminants of concern
affecting the soil and ground water are VOCs, including toluene; and other organics.

The selected remedial action for this site includes continuing the operation of a soil
vapor extraction system to remove VOCs from soil; treating extracted soil vapors using
granular activated carbon, with discharge of emissions to the atmosphere; implementing a
system monitoring program, which includes collecting and analyzing soil vapors before and
after they are treated; continuing extraction and onsite treatment of ground water from
four recovery wells using air stripping to remove VOCs until a steam stripping unit can be
installed to replace the air stripping unit; discharging the treated water offsite to a
POTW, and then to Mamey Creek once the steam stripping unit is installed; monitoring soil,
ground water, surface water, and air; monitoring and analyzing influent and effluent from
the air stripping unit; and periodically collecting well head samples. The estimated
present worth cost for this remedial action is $8,987,800, which includes an estimated
annual O&M cost of $370,000 for 30 years.

PERFORMANCE STANDARDS OR GOALS:

Ground water cleanup goals are based on Federal SDWA MCLGs and MCLs. Soil cleanup, goals
were not provided.

-------
                          ROD FACT SHEET
SITE

Name:
Location/State  :
EPA Region:
HRS Score  (date):
Janssen Inc.
Gurabo, Puerto Rico
II
N/A
ROD

Date Signed:

Selected Remedies:

     Groundwater  -


     Soils

Operating Unit Number:

Capital cost:
Construction Completion:
0 & M
Present worth:
 September 30, 1993
 Pump and Treatment with Steam Air
 Stripper

 Soil Vapor Extraction System

 OU-1

 $3,300,000
 March 1995
 $ 370,000
 $ 8,987,800 (30 years)
LEAD

Remedial/Enforcement -
EPA/State/PRP -
Primary contact  (phone)
Secondary contact  (phone)
Main PRP(s) -
PRP Contact (phone) -
 Enforcement
 EPA
 Adalbert© Bosque (809) 729-6951
 Melvin Hauptman (212) 264-7681
 Janssen Inc.
 Juan Merced (809)  789-5000
WASTE

Type:
Medium :
Origin :

Est. quantity:
 Volatile organic compound
 Soil and Groundwater
 Leakage of a fire trap at the
 chemical building.
 Unknown

-------
                  Declaration for Record of Decision



SITE  NAME AND LOCATION


Janssen, Inc. Site, Gurabo, Puerto Rico


STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected interim remedial
action for the Janssen, Inc. Site (Site) in Gurabo, Puerto Rico,
which was chosen in accordance with the requirements of the
Comprehensive Environmental Response, Compensation and Liability
Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA) and the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP).  This
decision document explains the factual and legal basis for
selecting the interim remedy for this Site.

The Puerto Rico Environmental Quality Board (EQB)  concurs with
the selected remedy.  A letter of concurrence from EQB is
appended to this document.  The information supporting this
interim remedial action decision is contained in the
Administrative Record for the Site,  the index of which is also
appended.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the interim response
action selected by this Record of Decision (ROD),  rcay present an
imminent and substantial endangerment to human health, welfare,
or the environment.
DESCRIPTION OF THE SELECTED INTERIM REMEDY
The remedial alternative presented in this document is for an
interim remedy for the Site.  It focuses on groundwater
contamination as well as soil contamination beneath the Janssen
Chemical Plant Building.
                         i
EPA has separated the response actions at the Site into two
different areas (the ground water and the soil).  Currently, the
soil is being addressed by the soil vapor extraction system that
is being implemented pursuant to an EPA Administrative Order
signed in 1991.  This action should remove the compounds from the

-------
soils beneath the Chemical Plant Building so that they will no
longer leach into the ground water.  In addition, Janssen is
undertaking early actions to reduce the spread of the ground
water plume, namely pumping the ground water.  Janssen is
currently installing a conventional air stripping system to treat
the impacted ground water.  The selected interim remedy presented
in this ROD will continue to pump the impacted ground water to
prevent it from spreading further, initially treat the ground
water via conventional air stripping, and later on, treat the
ground water via steam stripping, an innovative technology.

The major components of the selected interim remedy, discussed in
this document as Alternative 2-IV for the ground water and
Alternative 3 for the soils, include the following:

     o    Pumping of impacted ground water from four recovery
          wells at a combined flow rate of approximately 80
          gallons per minute (gpm).  The exact number and
          location of wells and their pumping rates will be
          determined during design.

     o .   Treating the impacted ground water by steam stripping.
          Initially, a conventional air stripping unit will be
          installed to remove volatile organic compounds (VOCs)
          from the extracted ground water.  The installation and
          operation of the conventional air stripping unit will
          be initiated immediately and the steam air stripping
          unit will replace it within approximately eighteen
          months.

     o    Discharging the treated water from the conventional air
          stripping unit to the Puerto Rico Aqueduct & Sewer
          Authority (PRASA) Gurabo Treatment Plant until it will
          be replaced by the steam stripping unit.  At that time
          the treated water will be rerouted and discharged to
          Mamey Creek.

     O    Implementing a system monitoring program which includes
          the collection and monthly analysis of influent and
          effluent from the air stripping unit and periodic
          collection of well head samples.

In addition, Janssen,  with oversight from EPA, will continue to
operate and maintain the soils early action as follows:

     O    Operating a soil vapor extraction system to remove VOCs
          from soil until such time as no more VOCs can be
          effectively removed.   Soil vapors will be treated by
          using granular activated carbon (GAC) before being
          emitted to the atmosphere.  Emissions will be below the
          requirements established by the EQB.

-------
Implementing a system monitoring program which includes
the collection and analysis of soil vapors before and
after they are treated with GAC.
This selected interim remedial action differs from that in the
Proposed Plan with respect to the discharge of the treated water
from the ground water pump and treat system. The Proposed Plan
originally called for the discharge to be to the PRASA Gurabo
treatment plant. However, due to capacity restrictions, the
treated groundwater will only be discharged on a temporary basis
to the PRASA Gurabo treatment plant until the steam stripping
treatment system.is in place. At that time, the treated water
will be discharged to Mamey Creek.

DECLARATION OF STATUTORY DETERMINATIONS
The selected interim remedy is protective of human health and the
environment, complies with Federal and state requirements that
are legally applicable or relevant and appropriate to the
remedial action (ARARs) and is cost effective. This interim
remedy utilizes permanent solutions and alternative innovative
treatment technologies to the maximum extent practicable. This
interim remedy satisfies the statutory preference for remedies
that employ treatment that reduce the toxicity, mobility, or
volume of contamination as their principal element for the
groundwater and soil contamination. The final remedy for the
Site will be selected based on the data obtained from the
remedial investigation and feasibility study that is presently
ongoing.
William J^fiuszjfcijjptfi, P.E. Date
Acting R"egiona^
-------
DECISION SUMMARY

JANSSEN, INC. SITE

GURABO, PUERTO RICO
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION II

NEW YORK
-------
TABLE OF CONTENTS

DECISION SUMMARY PAGE

I. SITE LOCATION AND DESCRIPTION 1

II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 2

III. HIGHLIGHTS OF COMMUNITY PARTICIPATION 3

IV. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
WITHIN SITE STRATEGY 3

V. SUMMARY OF SITE CHARACTERISTICS 4

VI. SUMMARY OF SITE RISKS 9

VII. DESCRIPTION OF ALTERNATIVES 10

VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES .... 18

IX. DESCRIPTION OF THE SELECTED REMEDY 24

X. STATUTORY DETERMINATIONS 26

XI. DOCUMENTATION OF SIGNIFICANT CHANGES 28

ATTACHMENTS

APPENDIX A - FIGURES

APPENDIX B - GROUNDWATER DATA

APPENDIX C - SOIL DATA

APPENDIX D - COMMONWEALTH OF PUERTO RICO ENVIRONMENTAL
QUALITY BCM
-------
I. Site Location and Description

The Janssen, Inc. facility is located on twenty-five (25) acres
of land on Route 933, km. 0.1, Mamey Ward, Gurabo, Puerto Rico
(Appendix A, Figure 1). Janssen, Inc., a Puerto Rico
Corporation, is a wholly owned subsidiary of Janssen
Pharmaceutical N.V. The latter is a Belgian Corporation, which
is a wholly owned subsidiary of Johnson & Johnson. In January
1992, Janssen changed its name to OMB Pharmaceutical Partners
(OMB). For the sake of simplicity in this ROD, Janssen rather
than OMB, will be used to describe the company and the Site.

The facility, owned by Janssen, is located in a light industrial
area and approximately two miles from a residential community.
The Janssen facility includes a chemical and manufacturing
building, a pharmaceutical building, an above-ground tank farm, a
process waste water treatment facility, a utilities building, an
electrical substation, a cooling tower, a new quality
assurance/quality control building. Two ground water production
wells also exist within the facility. The Janssen Site
(facility) includes the facility and the associated groundwater
contamination plume emanating from the facility.

The area of investigation as shown on Figure 2 (Appendix A),
includes the Janssen Inc. and Johnson & Johnson plants, highway
PR-30, Mamey Creek and a dairy farm north of the Site. The land
use surrounding the Janssen facility includes low density rural,
residential, light industrial operations, a church, and a dairy
farm. The plant is bounded to the south and east by Mamey Creek,
to the west by road PR-933, and to the north by highway PR-31.

The towns of Gurabo and Juncos, which are two main population
centers in the area, are approximately 1.5 and 2.0 miles to the
east and west, respectively (See Figure 3, Appendix A). The
estimated population of these towns, according to the 1990
Census, is approximately 30,000 per town.

Mamey Creek, a tributary of the Gurabo River, is located
approximately 154 feet downslope of one of the groundwater wells
(W-2) showing the presence of VOCs at the Site and flows along
the southeast boundary within forty (40) feet of the plant
property. The surficial run-off flows toward Maroey Creek.

Groundwater wells at the Site are located within the Gurabo
regional aquifer which is a source of potable water for the
Gurabo municipality and surrounding areas. Public drinking water
supply wells are 1ocated within three (3) miles of the Site .
These wells are owned and operated by the Puerto Rico Aqueduct
and Sewer Authority ("PRASA") and serve approximately 10,000
people.
-------
II. Site History and Enforcement Activities

Pharmaceutical products and intermediates have been manufactured
at the plant since February 1982. The pharmaceutical plant
manufactures final products which include Vermox, Nizoral,
Hismanal and Imodium. The chemical plant produces pharmaceutical
intermediates for use by Janssen, Inc. Records of chemical usage
at the plant indicate the use of chloroform, toluene, acetone,
tetrahydrofuran, isopropanol, Methyl-Iso-Butyl-Ketone (MIBK), and
methanol.

Until April 1989, groundwater productions wells at the Site were
used for industrial purposes and as a source of drinking water
for Janssen employees. Upon knowledge of the chloroform
contamination, these wells were discontinued as a drinking water
supply source and were immediately restricted to production use
only.

In September 1989, Janssen voluntarily notified the Puerto Rico
Environmental Quality Board (EQB), EPA and other agencies that
chloroform was detected in two drinking water wells at the Site
at levels as high as 2,000 parts per billion (ppb). Later that
month, a Preliminary Assessment was conducted by EQB which
recommended this Site for an investigation.

After the release was discovered, Janssen retained the services
of Soil Tech Corporation to conduct an initial investigation of
the Site. In addition, actions (such as pumping production well
W-2) were taken to reduce the further migration of the ground
water volatile organics plume.

On June 15, 1990 an Information Request letter was sent to
Janssen to gather additional information about this matter. On
October 23, 1990 a Notice Letter was submitted to Janssen and
negotiations with Janssen were initiated.

On March 28, 1991 an Administrative Order on Consent was issued
by EPA that required Janssen to conduct a Remedial Investigation
and Feasibility Study (RI/FS). The order a3so required Janssen
to implement Early Action Activities designed to mitigate
possible risks associated with existing chloroform contamination
and reduce further migration of the ground water plume.

Pursuant to that order, in May 1991, Janssen submitted the
Summary Investigation (SI) Report which summarizes all the
activities and data collection investigations performed at the
facility. On July 31, 1991 Janssen F .omitted the Candidate
Technology Memorandum (CTM) which initially identified potential
remedial technologies that could be used at the Site. Soil vapor
extraction wells were installed in July 1991 and a trial test of
this system was conducted in July 1992. Start-up of the soil
-------
vapor extraction system began on March 10, 1993 pursuant to EPA
approval. In addition, the installation of extraction wells and
a conventional air stripper was initiated . In February 1993,
EPA approved the RI/FS work plan that was submitted by Janssen.
Work on the RI/FS is underway. In May 1993, Janssen submitted
the Focused Feasibility Study (FFS). An FFS is similar to an FS
except that it only considers a limited number of technologies
for particular areas of a site.

III. Highlights of Community Participation

The SI Report, FFS Report, Proposed Plan and other supporting
documentation for the Site were released to the public for
comment on June 8, 1993. These documents were made available to
the public in both the Administrative Record and information
repositories maintained at the EPA Docket Room in the Region II
New York City Office, the EPA Caribbean Field Office, the Town of
Gurabo Municipal Library located at Gurabo, Puerto Rico, and at
the EQB Library. The notices of availability for these documents
were published in the El Nuevo Dia Newspaper, the San Juan Star
Newspaper, as well as in La Seroana Newspaper on June 8, 1993. A
public comment period was initially held from June 8, 1993
through July 7, 1993. However, due to a request for an extension
to the public comment period, it was extended until August 9,
1993. On June 15, 1993 a public meeting was held at the
Municipal Assembly Room, Gurabo where representatives from EPA
presented the findings of the preliminary investigation and
answered questions from the public about the Site and the
remedial alternatives under consideration. On July 22, 1993 a
second meeting was conducted with a group of approximately twenty
local residents to further present the findings of the
investigation, answer questions and describe the remedial
alternatives evaluated. The notice for the extension of time was
published in El Nuevo Dia Newspaper and the San Juan Star on July
22, 1993. Responses to the comments received during the comment
period are included in the Responsiveness Summary, which is
appended to this ROD.

IV. Scope and Role of Operable Unit or Response Action Within
Site Strategy

EPA's decision to address the impacted ground water on an
expedited basis should serve to prevent the migration of
compounds found in the ground water and the potential threat to
public health and the environment. This action is an interim
action which will achieve significant risk reduction quickly
while a final remedial solution for the ground -water is being
developed.

EPA has separated the response actions at the Site into two
different areas. Those areas include groundwater impacted with
-------
volatile organics above federal ?-'oximum Contaminant Levels (MCLs)
and the impacted soil which is located beneath the Chemical Plant
Building. Currently, the soil is being addressed by the soil
vapor extraction system that is being imp]emented pursuant to the
Administrative Order. This action should serve to remove the
compounds from the soils beneath the Chemical Plant Building so
that they will no longer leach into the ground water. In
addition, Janssen is undertaking early actions to reduce the
spread of the ground water plume, namely pumping the ground
water. Through the remedy selected in this ROD, the ground water
will continue to be pumped to prevent it from spreading further,
be treated via conventional air stripping and discharged to the
Gurabo Publicly Owned Treatment Works (POTW), and later on be
treated via steam stripping and discharged to Mamey Creek.

The ultimate goal of the EPA Superfund approach to groundwater
remediation as stated in the National Oil and Hazardous
Substances Pollution Contingency Plan, 40 CFR Part 300 (NCP) is
to return usable groundwater to its beneficial use within a time
frame that is reasonable. The goal of this interim remedial
action is to halt the spread of the groundwater contaminant plume
and as such address a threat in the short term while a long term
solution is being developed. The result of this interim remedial
action will be monitored carefully to determine the feasibility
of achieving the final goal of meeting MCLs and non-zero MCL
Goals (MCLGs) in the groundwater. This interim remedial action
will permit the further collection of data on the aquifer without
delaying initial remediation measures.

EPA's Superfund Program uses EPA's Groundwater Protection
Strategy as guidance when determining the appropriate remediation
for contaminated groundwater at CERCLA sites. The Groundwater
Protection Strategy establishes different degrees of protection
for groundwaters based on their vulnerability, use, and value.
For the aquifer at the Janssen Site, which is classified by EPA
as a Class II aquifer, the final remediation goals will be
Federal Safe Drinking Water Act MCLs and non-zero MCLGs. Class
II aquifers include current and potential sources of drinking
water and groundwater potentially available for drinking water,
agriculture, or other beneficial use.

V. Summary of Site Characteristics

The objectives of Janssen's initial investigation were to
determine the hydrogeologic character of the local aquifer and
shallow soil system, including the direction and rate of ground
water flow and the chemical quality; to confirm the presence and
extent of compounds of concern in the unsaturated and saturated
zones; to identify the sources of chloroform; and to gather
sufficient quantitative and qualitative data to allow the
implementation of additional response activities to prevent
-------
significant migration of the ground water volatile organic
compounds plume at the Site.

The area of investigation includes the Janssen and Johnson &
Johnson Medical Plants (adjacent to Janssen), Highway PR-30,
Mamey Creek and a dairy farm north of the Site.

During this investigation, soil borings, soil sampling,
monitoring well installation, ground water sampling, water level
measurements, aquifer hydraulic testing and identification of
potable water supplies within three miles were conducted.

A. Site Geology and Hydrology

The geology in the vicinity of the Janssen facility consists of
volcanic rocks with local intrusions of batholiths and dikes.
These intrusive bodies are generally composed of granodiorites
and diorites. The age of the volcanic rocks ranges from Early to
Middle Cretaceous Periods, while the intrusive and metamorphic
rocks belong to the late Cretaceous and Early Tertiary Periods.

The volcanic formation at the Site is known as Los Negros
Formation. This formation is mainly composed of basalt and
volcanic breccia locally altered by hydrothermal effects.

The unconsolidated deposits found in the area are of Holocene Age
essentially composed of alluvium and colluvial material. The
thickness of this mantle deposit varies from 60 to 80 feet, with
maximum recorded thickness of more than 160 feet. Figure 4
(Appendix A) depicts the surficial geology in the vicinity of the
Janssen facility.

The project is located on the hydrogeological unit of the Gurabo
River, which is the main tributary to the Rio Grande de Lolza
(Loiza River). The Gurabo River unit has a total catchment area
of approximately 30.6 square miles. The basin is delineated to
the north and east by the El Yunque Mountain Range, and to the
south and west by the Cayey Mountain Range. The aquifer of this
region is composed of an alluvial valley that extends from the
town of Las Piedras to the southeast, to the town of Gurabo,
where the Gurabo unit intercepts the Lolza River. The areal
extent of this unit is shown on Figure 5 (Appendix A).

The geomorphological and hydrogeological conditions of the Gurabo
River unit are independent of the Lolza River. The Gurabo River
unit is composed mostly of sediments derived from plutonic and
volcanic rocks, while the area downgradient from the intersection
of the two rivers is composed mainly of tuffaceous sand,
siltstone, breccia, and conglomerates.

The most productive aquifer of this hydrogeo3ogical unit is
Generally composed of the alluvial deposits overlying 'the
-------
weathered rock. In areas where alluvial deposits are not found,
the transmissivity of the volcanic or intrusive rock depends on
the rock secondary porosity. The phreatic surface of this basin
(Caguas, Gurabo, Juncos Aquifer) is found at an average depth of
25 to 30 feet below existing grade. The phreatic surface usually
follows the same pattern of the topographic relief. In general,
the ground water flows towards the Gurabo River which is the main
surface water body in the area. Figure 6 (Appendix A) presents a
general hydrogeological cross-section.

At the project site, the main aquifer unit is the surficial
alluvial or colluvial deposits which overlay the weathered rock.
The thickness of the unconsolidated unit is about 60 to 80 feet.
The thickness of the weathered rock layer may range from 30 to 50
feet.

The elevation of the phreatic surface within the Site varies from
160 to 180 feet above mean sea level (30 to 40 feet below land
surface). The ground water flow direction is to the north-
northeast, following the existing topographic surface. The
hydraulic gradient is approximately 0.013 under normal recharge
and withdrawal conditions.

The aquifer system within the Site covers an area of
approximately 0.25 km2. The catch basin is limited to the north
by Highway PR-30, to the south and west by a surficial volcanic
formation, and to the south and east by Mamey Creek.

In addition to direct infiltration and recharge by precipitation,
the aquifer is recharged through fractures and foliation of the
bedrock. The hydraulic gradient of this system is about 0.13 and
flows in the same direction as the shallow aquifer. The
estimated saturated thickness of this recharge area is
approximately 30 feet for a total flow section of 70,000 ft2.
The local aquifer is also recharged by Mamey Creek, which flows
along the east and south limits of the Site. The average flow of
this creek has been estimated to be approximately 96,000 gal/day.
About 16 percent of this quantity infiltrates into the aquifer.

Water supplies for this area are derived from surface water
sources (PRASA rata, 1986). The total public water supplied to
the Caguas-Juncos Valley was about 20 million gallons per day
(mgd) in 1986. Additional sources of water in the study area are
about 6.8 mgd imported from Guaynabo and Humacao, and about 2.5
mgd pumped from the alluvial aquifer.

Wells are the most important source of ground water data in this
investigation due to their potential for contamination. A
comprehensive well inventory program was performed throughout the
area based on records of the U.S. Geological Survey (USGS) and
Puerto Rico Department of Natural Resources (DNR). Figure 7
-------
(Appendix A) lists and shows the location of wells in a radius of
three (3) miles from the Site. The records indicate the presence
of 86 wells. Wells were numbered from 1 through 86 for the
purpose of the SI report. Of these wells, only 11.6 percent
(10/86) are presently used as a source of potable drinking water
by PRASA. The remaining wells are used for agricultural,
industrial, and domestic purposes. The closest PRASA wells to
the Site are the Hato Nuevo (Nos. 81, 83, and 84) and Juncos
Wells (Nos. 30 through 35). These wells are located at about 1.7
and 2.0 miles north and west of the Site, respectively. The
Gurabo River, which is about 0.3 miles north of the Site, forms a
shallow hydraulic barrier between the Hato Nuevo Wells and the
Site. This precludes the possibility of the plume reaching these
wells. The Juncos wells are not within the ground water flow of
the aquifer.

The only wells that are close to the Site are wells No. 19, 20,
22, 23, 58, and 61. Wells No. 19 and 20 belong to Johnson &
Johnson, and No. 22 and 23 to Janssen, No. 58 to a Church, and
No. 61 to a dairy farm. Wells No. 19, 20, 22, and 23 were
previously used as a source of potable water and process water.
Immediately upon knowledge of the chloroform presence in the
water, Janssen ceased to use wells No. 22 and 23 as a source of
potable water. Well No. 58 is used for sanitary purposes and
Well No. 61 is used for livestock and irrigation. These wells
have been sampled and results indicate only trace levels of
contaminants at concentrations below the MCLs.

Most of the wells are located within the alluvium, which
constitutes the main aquifer in the area. Well yields range from
20 to 450 gallons per minute (gpm). Low yields normally
correspond to wells finished in the bedrock formation. Well
depth is variable with maximum depths of about 400 feet.
However, most wells are drilled according to depth-to-bedrock,
with screens opened through most of the saturated thickness of
the unconsolidated deposits.

B. Nature and Extent of Contamination

1. Groundwater

The ground water quality of the aquifer underlying and
downgradient of the Site has been assessed as part of the
preliminary work conducted and reported in the SI Report. One
hundred twenty three (123) ground water samples were collected
for chemical analysis.

All ground water samples 'obtained from the shallow and deep
monitoring wells, as well as from production wells, were analyzed
for the presence of chloroform, except for those samples
collected during the February 27, 1990 sampling event. Ground
-------
water samples collected during this sampling event were analyzed
for the full scan of volatile organics in the Priority Pollutant
list and other compounds used in the facility. Chloroform was
the most frequently detected compound and had the highest
detected concentration of 472 parts per million (ppm). Other
detected compounds were acetone, MIBK, tetrahydrofuran, methylene
chloride, and toluene. Of these, acetone and tetrahydrofuran
showed the highest concentrations with 41.6 and 49.5 ppm,
respectively.

Ground water samples collected from the existing monitoring well
network from January to October 1990 indicate that the chloroform
plume is centered at the Chemical Plant Building and that the
mass of the plume is partially contained. Ground water samples
taken at different depths within the aquifer indicate an increase
in concentration with depth.

In addition to the ground water samples collected during the
initial investigation, Janssen has conducted ground water
sampling from March 1991 until present. Figures 8-10 (Appendix
A) present the chloroform plume configuration corresponding to
November 1991, July 1992, and March 1993. Samples collected
during these sampling events were analyzed off-site in accordance
with EPA's Contract Laboratory Program (CLP) protocols. Samples
were analyzed for only those VOCs listed on the CLP Target
Compound List and additional compounds used at the Site
(methanol, tetrahydrofuran, and isopropanol) which are not in
this test. From the analyzed compounds only chloroform, acetone,
MIBK, methylene chloride, tetrahydrofuran and toluene were
detected. The analytical results have been included in the
monthly reports submitted to EPA.

Analyses of samples collected from Janssen production wells
(Appendix B, Tables 1 through 7) to date, as well as monitoring
wells at the Site, revealed the following VOCs at the following
maximum concentrations in parts per million (ppm):

Chloroform 472
Methylene Chloride 29
Tetrahydrofuran 110
Acetone 120
Toluene 36
Chlorobenzene 8
Methyl-Iso-Butyl Ketone (MIBK) 17
Methanol 22
Isopropanol 11

2. Soils and Sediments'

As part of the work conducted and reported in the SI Report, 57
soil samples and 3 sediment samples were coir.ec-i.ed for chemical

8
-------
analyses. The sediment samples were obtained from three sampling
points along Mamey Creek.

Soil samples were collected within the Chemical Plant Building
and its surroundings during various sampling events. Sample
collection depth ranged from 4 to 27 feet below existing ground
level. All samples corresponding to boreholes beyr-nd the
perimeter of the Chemical Plant Building did not show the
presence of volatile organic compounds. Soil samples taken
within the Chemical Plant Building, specifically in the process
area, showed concentrations of chloroform, methylene chloride,
toluene, acetone, MIBK, tetrahyrofuran, isopropanol,
chlorobenzene, and methanol.

Sediment samples obtained from Mamey Creek to determine the
potential of sediments to contain chloroform as a result of storm
water runoff from the industrial facility or discharge from the
aquifer showed non-detectable concentrations.

The analyses of soil samples collected at the Site (Appendix C,
Tables 8 through 15) indicated that there were measurable
concentrations of the following VOCs in the soil samples
collected under the Chemical Plant Building with the following
concentrations in ppm:

Methanol 0.09
Isopropanol 0.17
Chlorobenzene 131
Chloroform 465
Methylene Chloride 36
Toluene 8,250
Acetone 1,670
Methyl-Iso-Butyl
Ketone (MIBK) 194
Tetrahydrofuran 249

VI. Summary of Site Risks

Ground water samples collected at the Site revealed the presence
of some VOCs far above the Federal Safe Drinking Water Act MCLs
and MCLGs. These compounds included chloroform, methylene
chloride, acetone, toluene and chlorobenzene. Several of the
compounds, including chloroform and methylene chloride, are known
to cause cancer in laboratory animals and are suspected to be
human carcinogens. In addition, contaminants present in the soil
beneath the Chemical Plant Building continue to act as a source
of ground water contamination.

Ground water samples collected by Janssen from facility wells
indicate that the compounds of concern, notably chloroform, are
currently spreading both vertically and horizontally within the
-------
upper alluvial aquifer and have likely reached the bedrock.
Downgradient well samples also indicate that the chloroform plume
is presently migrating to the north and northeast of the
facility. Two private water supply wells (Well no. 58 and 61,
mentioned previously) are located in close proximity and
downgradient of the existing plume(s). To date, these have shown
only trace levels of contaminants at concentrations below the
MCLs, but in the absence of measures to prevent further plume
migration, these wells could become more significantly impacted.

Actual or threatened releases of hazardous substances from this
Site, if not addressed by the selected remedy or one of the other
active measures considered, may present an imminent and
substantial endangerment to human health, welfare and the
environment.
VII. Description of Alternatives

The Superfund law requires that any remedy selected for a site
must be protective of human health, welfare, and the environment,
cost-effective, and in accordance with statutory requirements.
Permanent solutions to contamination are to be achieved wherever
possible, and there is a bias for treating wastes and applying
innovative technologies. The remedial alternatives considered
for the Site are summarized below.

The time to implement includes the actual construction time and
the time needed to design and negotiate with Janssen for
implementation.

ALTERNATIVES FOR THE IMPACTED GROUND WATER

Alternative l - No Action
CERCLA requires that the "No Action" alternative be considered at
every site to provide a baseline of comparison among
alternatives. The No Action alternative assumes no additional
actions will be taken beyond the current activities at the Site.
All wells that are currently pumping are assumed to continue to
pump at their current rates. The costs for the No Action
alternative are as follows (they do not include the costs of
maintaining the current pumping system):
Capital Cost $0
Annual O&M > $0
10-year Present Worth $0
30-year Present Worth $0
10
-------
Alternative 2 - Deed Restrictions with Monitoring
This alternative involves deed restrictions being registered to
limit the land use activities at the entire affected area as well
as periodic ground water monitoring to track the movement and
concentration of the VOCs. Ground water use restrictions would
be recommended to be put in effect in the affected area to
prevent the use of impacted ground water. These institutional
controls would alert future property owners of potential Site
related risks. Deed and ground water restrictions would be
implemented by state and local officials. As the owners of
record, the deed restrictions would have to be filed by Janssen
and nearby well owners. Annual sampling of eighteen (18)
monitoring well clusters and six (6) production wells would
provide an assessment of the extent and mobility of the VOCs.
Presently, of the eighteen clusters proposed for sampling, eleven
are installed. The installed clusters consist of one, two, or
three monitoring wells for a total of 19 wells. The remaining
seven clusters would be installed as follows: five (5) clusters,
consisting of three (3) monitoring wells each, would be installed
within the extent of the chloroform plume; two (2) clusters would
be located downgradient of chloroform plume; and an additional
deep monitoring well would be installed adjacent to existing
shallow monitoring well JW-6. A combined total of 41 monitoring
wells would be available for sampling at the completion of the
proposed wells. Each monitoring and production well would be
sampled and analyzed for the presence of VOCs. Annual status
reports would be prepared.

The costs for this alternative are as follows:
Capital Cost $ 469,000
Annual O&M $ 64,750
10-year Present Worth $ 969,000
30-year Present Worth $1,464,400
Alternative 3 - Ground Water Extraction. Treatment and
Discharge System
This alternative was evaluated considering different treatment
and discharge options. The number of extraction wells and total
pumping rates were maintained constant at four wells and 80
gallons per minute (gpm) ,' respectively. Alternative 3-1 is
evaluated assuming that the water pumped is treated in a
conventional air stripping unit and discharged to the Gurabo
11
-------
Publicly Owned Treatment Works (POTW). Alternative 3-II is
evaluated assuming treatment of water in a steam stripping unit
with discharge to the Gurabo POTW. Alternative 3-III is similar
to Alternative 3-II but considers the reinjection of treated
water to the aquifer by the use of recharge wells. Alternative
3-IV is similar to Alternative 3-II in its use of a r^eam
stripping unit but treated water is discharged into Mamey Creek.

Deed restrictions and well construction controls will be
recommended to be implemented in order to restrict the
installation of water supply wells and limit the use of ground
water in the area during the implementation phase for all of the
alternatives within Alternative 3, i.e., 3-1, 3-II, 3-III, and 3-
IV. These restrictions will also alert future property owners of
potential site related risks. System monitoring includes
collecting and analyzing monthly influent and effluent samples
from the tower and periodically collecting wellhead samples.

Alternative 3-1 Four Extraction Wells and Conventional Air
Stripping with Discharge to Gurabo POTW
Impacted ground water will be pumped from four recovery wells at
a combined flow rate of 80 gpm. This water will be piped to a
conventional air stripping treatment system. It is estimated,
based on previous ground water modeling, that 80 gpm of ground
water may be pumped from the four wells at the same time without
causing a drastic reduction of aquifer capacity. However, the
exact number and location of wells and their pumping rates will
be determined during design.

The water will be pumped from the wells to a holding tank and
from the holding tank to a conventional air stripping unit. From
the stripping unit, treated water will be pumped to the existing
fire protection tank, from where the overflow of the tank will
discharge to a sanitary sump pit where water will be pumped to
the Gurabo POTW.

The air stripping system is capable of treating up to 150 -jpm of
water having the projected influent concentrations and will
comply with the quality criteria for discharge to the Gurabo
POTW.

It is expected that the recovery wells would be existing well W-
2R and new wells JE-1, JE-2, and JE-3. Each well will be pumping
at a rate of approximately 20 gpm. Well W-2R is located near the
center portion of the plume. Wells JE-1 and JE-2 vould be
located at the downgradient boundary of the plume to prevent off
Site migration of the plume. Well JE-3 would be .located north of
Well W-2R, closer to the center of the plume to remove the high
chloroform concentrations from the aquifer. However, the exact
number and location of wells and their pumping rates will be

12
-------
determined during design.

At this time, (because this is an early action designed to
prevent further plume migration), it is difficult to predict the
ultimate concentration to which chemical compounds in the aquifer
may be reduced with Alternative 3-1. The costs of this
alternative are as follows:
Capital Cost $ 525,000
Annual O&M $ 229,000
10-year Present Worth $2,293,300
30-year Present Worth $4,045,300
This alternative can be initiated as soon as the ROD is signed.
It does not require negotiations with Janssen because Janssen has
consented to this action within the Administrative Order.

Alternative 3-II - Four Extraction Wells and Steam Stripping
Unit with Discharge to Gurabo POTW
This alternative is a modification of Alternative 3-1. As in
Alternative 3-1, impacted ground water will be pumped from four
recovery wells at a combined flow rate of 80 gpm. The difference
is that the extracted ground water will be treated with a steam
stripping unit instead of a conventional air stripping unit.
However, the exact number and location of wells and their pumping
rates will be determined during design. The treated ground water
will then be discharged into the Gurabo POTW where it will
eventually discharge into the Gurabo River. Such discharge is
downstream of the water filtration plant presently under
construction. The benefit of the steam stripping unit over
conventional air stripping is that it can achieve lower effluent
concentrations for all compounds found in the ground water.

This technology which is an innovative technology uses a high-
efficiency countercurrent stripping developed by the Dow Chemical
Company. A carrier gas, in this case steam, is purged through
the impacted water with the volatile components being transferred
from the water into the gas phase. This treatment unit can
achieve effluent concentration limits below MCLs.

Once in the steam stripping unit the impacted ground water is
heated to the tower's operating temperature by injecting steam at
the bottom of the tower. Under these conditions of temperature
and reduced pressure, the VOCs are stripped from the water and
exit the top of the stripping to*er along with the steam. The
overheated stream flows to a wattr Cooled condenser where it is
condensed and pumped to a gravity separator. T'-e organic phase
from the gravity separator is pumped to and stored in a solvent

13
-------
storage tank for later treatment at an off-site facility. The
aqueous phase is rerouted to the system for subsequent treatment.

Treated ground water will be stored in the existing 250,000
gallon fire protection tank. The tank's overflow will flow to an
existing sanitary sump pit where it will be pumped through a 3-
inch diameter pipeline to the Gurabo POTW.

At this time, (because this is an early action designed to
prevent further plume migration), it is difficult to predict the
ultimate concentrations to which chemical compounds in the
aquifer may be reduced with Alternative 3-II. However, as this
system is totally enclosed, it can be operated on a continuous
basis until effluent contaminant concentrations are below MCLs
and MCLGs. The costs for this alternative are as follows:
Capital Cost $2,925,000
Annual O&M $ 365,000
10-year Present Worth $5,547,300
30-year Present Worth $8,543,600
The time to implement this alternative is approximately eighteen
months.
Alternative 3-III - Four Extraction Wells and Steam Stripping
Unit with Reinfection Wells
This alternative consists of the puropage from wells JE-1, J-E2,
JE-3 and W-2R as outlined in Alternatives 3-1 and 3-II and the
treatment with the steam stripping unit as in Alternative 3-II.
The main difference between this and Alternative 3-II is in the
disposal of the treated effluent. The treated effluent would be
reinjected into the aquifer by means of reinjection wells.

Because the treated water is to be injected into the ground, some
modifications would have to be made to the treatment system
described under Alternative 3-II. The injection quality criteria
for this alternative would be MCLs or MCLGs which is more
stringent than the discharge quality criteria for the Gurabo
POTW. Second, the effluent from the steam stripping unit would
flow from the fire protection storage tank into twelve (12)
reinjection wells located north of the Site to reinject the
treated water into the aquifer. The reinjection of the treated
water downgradient would provide a hydraulic barrier to reduce
plume migration. Each well would have an estimated injection
capacity of 10 gpm. Eight wells would be operating at any time
with the other four (4) wells serving as back-up wells.
Reinjection would recharge the aquifer with treated ground water.

14
-------
At this time (because this is an early action designed to prevent
further migration) it is difficult to predict the ultimate
concentration to which compounds in the aquifer may be reduced
with alternative 3-III. However, as this system is totally
enclosed, it can be operated on a continuous basis until effluent
contaminant concentrations are below MCLs and MCLGs. The costs of
this alternative are as follows:
Capital Cost
Annual O&M
10-year Present Worth
30-year Present Worth
$3,330,000
$ 270,000
$5,414,900
$7,480,600
The time to implement this alternative is approximately two
years.

Alternative 3-IV- Four Extraction Wells and Steam Stripping
Unit with Discharge to Karoey Creek

This alternative is a modification of Alternative 3-II. As in
Alternative 3-II, impacted ground water will be pumped from four
recovery wells at a combined flow rate of 80 gpm. However, the
exact number and location of wells and their pumping rates will
be determined during design. The water will flow from the wells
to the steam stripping unit and then it will be discharged to
Mamey Creek which is a tributary of the Gurabo River located at
about 1,500 meters downgradient of the Site. Because the water
is to be discharged to an existing surface body of water, the
discharge will have to meet National Pollutant Discharge
Elimination System (NPDES) discharge requirements.

Discharging the treated water to Mamey C: • ek must be carefully
considered since this creek is a tributary of the Gurabo River
which will be a source of potable drinking water for the Gurabo-
Juncos community through the use of a water filtration plant
presently under construction at about 2 kilometers from the Site.

At this time (because this is an early action designed to prevent
further migration) it is difficult to predict the ultimate
concentration to which compounds in the aquifer may be reduced
with Alternative 3-IV. However, as this system is totally
enclosed, it can be operated on a continuous basis until effluent
contaminant concentrations are below MCLs and MCLGs.The costs of
this alternative are as follows:
15
-------
Capital Cost $3,050,000
Annual O&M $ 270,000
10-year Present Worth $5,134,900
30-year Present Worth $7,200,600
The time to implement this alternative is approximately two and
one-half years.
ALTERNATIVES FOR SOURCE CONTROL (SOIL)

Alternative 1- No Action
The "No Action" alternative for soils would result in no effort
to prevent the further leaching of compounds from the soils to
the ground water. This alternative would result in the continued
leaching of chemical compounds into the aquifer for an unknown
period of time, affecting the quality of the ground water at the
Site. The costs for the No Action alternative are as follows:
Capital Cost
Annual O&M
10-year Present Worth
30-year Present Worth
$ 0
$ 0
$ 0
$ 0
Alternative 2 - Excavation and Disposal
This alternative involves the excavation and removal of soil
containing concentrations of chloroform and other volatile
organic compounds.

Excavation of the impacted soil, followed by removal to an
engineered disposal facility is a feasible alternative. However,
there are no local disposal options for hazardous materials in
Puerto Rico. Therefore, the estimated in-situ volume of 120,000
cubic feet which at the time of excavation could increase to
156,000 cubic feet (loose volume) would have to be shipped to a
secure, permitted Resource Conservation and Recovery Act (RCRA)
landfill facility in the continental United States.
i
Furthermore, because the soils are located beneath the Chemical
Plant Building and excavation depths are expected to reach 30
feet, significant implementability problems exist for this

16
-------
alternative. The selection of this option would require the
dismantling of the Chemical Plant Building, construction of a
replacement structure, and soil removal and disposal. The costs
of this alternative are as follows:
Capital Cost $62,036,000
Annual O&M 0
10-year Present Worth $62,036,000
30-year Present Worth $62,036,000
The time to implement this alternative is approximately five
years.

Alternative 3 - Soil Vapor Extraction

The Soil Vapor Extraction (SVE) alternative removes volatile
organic compounds from the unsaturated zone as vapors, without
excavation. SVE is accomplished in-situ (in place), by
installing vents of various designs consisting of gravel packs
extending to the surface, slotted or unslotted well casings
installed with or without gravel pack, or any other configuration
that allows gases to move from the soil. Passive systems consist
of vents that are open to the atmosphere and do not require
energy for extraction of gases. Active systems make use of
negative pressure or vacuum pumps to accelerate the removal of
vapors from the soil.

With SVE, the vapors are either discharged to the atmosphere or
treated before discharging, depending on vapor concentrations and
regulatory requirements.

The limitations of the SVE are associated with soil
characteristics that impede the movements of vapors to the
extraction well, emissions of volatiles, and explosion hazards.
Soils with limited pore space would require the use of more
closely spaced wells and possibly higher capacity pumps. The air
emissions may be controlled by using granular activated carbon
(GAC) at the discharge point. Explosion hazards Associated with
vapors can be overcome by using intrinsically safe equipment, and
by ensuring that adequate volumes of air are moved through the
system to keep vapor concentrations below the lower explosion
limit (LEL).

The SVE system requires minimal disruption of the Chemical Plant
operations. The system is very simple to operate and the removal
has been proven to be very effective for most volatile organics.
The costs of this alternative are as follows:
17
-------
Capital Cost
Annual O&M
10-year Present Worth
30-year Present Worth
$ 250,000
$ 100,000
$1,022,200
$1,787,200
The time to implement this alternative is immediate because it is
covered under the existing Administrative Order.

VIII. sumviiary of Comparative Analysis of alternatives

EPA has developed nine criteria (OSWER Directive 9355.3-01),
codified in the NCP §300.430(e) and (f), to evaluate potential
alternatives to ensure all important considerations are factored
into remedy selection. This analysis is comprised of an
individual assessment of the alternatives against each criterion
and a comparative analysis designed to determine the relative
performance of the alternatives and identify major trade-offs,
that is, relative advantages and disadvantages, among them.

The nine evaluation criteria against which the alternatives are
evaluated are as follows:

Threshold Criteria - The first two criteria must be satisfied in
order for an alternative to be eligible for selection.

1. o overall Protection of Human Health and the Environment
addresses whether or not a remedial alternative
provides adequate protection and describes how risks
posed through each exposure pathway (based on a
reasonable maximum exposure scenario) are eliminated,
reduced, or controlled through treatment, engineering
controls, or institutional controls.

2. o Compliance with ARARs addresses whether or not a
remedial alternative would meet all of the applicable
or relevant and appropriate requirements (ARARs) of
other Federal and State environmental statutes and/or
satisfy the criteria for invoking a waiver as set forth
in Section 121(d)(4) of CERCLA.

Primary Balancing Criteria - The next five "primary balancing
criteria" are to be used to weigh trade-offs among the different
hazardous waste management strategies.

3. o Long-Term Effectiveness and Permanence refers to the
ability of a remedial alternative to maintain reliable
protection of human health and the environment over
time, once cleanup goals have been met.
18
-------
4. o Reduction of Toxicity, Mobility, or Volume evaluates
the anticipated performance of the treatment
technologies a.remedial alternative may employ, or how
successfully particular treatment methods could reduce
the harmfulness or volume of contaminants, or their
potential to move in the environment.

5. o Short-Term Effectiveness addresses the period of time
needed to achieve protection and any adverse impacts on
human health that may be posed during the construction
and implementation period until cleanup goals are
achieved.

6. O Implementability evaluates the technical and
administrative feasibility of a remedial alternative,
including the availability of materials and services
needed to implement a particular option.

7. o Cost considers estimated capital and operation and
maintenance costs, and net present worth cost of the
alternatives.
Modifying Criteria - The next two criteria are regarded as
"modifying criteria", and are to be taken into account after the
above criteria have been evaluated. They are generally to be .
focused upon after public comments are received.

8. o State Acceptance indicates whether, based on its review
of the SI Report and the Proposed Plan, the
Commonwealth of Puerto Rico concurs with, opposes, or
has no comment on the preferred alternatives at the
present time.

9. o Community Acceptance refers to the public's general
response to the alternatives described in the Proposed
Plan.

The following is a summary of the comparison of each
alternative's strengths and weakness with respect to the nine
evaluation criteria.
GROUND WATER

1. Overall Protection of Human Health and the Environment

Concentrations of the compounds in ground water underlying and
downgradient of the Site exceed federal or Commonwealth MCLs and
MCLGs for chloroform, methylene chloride, tetrahydrofuran,
acetone, toluene and chlorobenzene. Ground water Alternatives 1
and 2 are not protective of human health and the environment

19
-------
because they do not control the migration of compounds at the
Site. Since they do not meet this threshold criterion, these
alternatives will not be discussed further. Alternatives 3-1
through 3-IV for the ground water medium would provide overall
protection consistent with the scope of this interim action by
controlling the ground water plume through the extraction and
treatment of the impacted water.

2. Compliance with ARARs

The ground water underlying the Site is a potable water supply
source, therefore, federal MCLs and non-zero MCLGs are ARARs. In
addition, the Puerto Rico MCLs are relevant and appropriate for
the cleanup of the aquifer. Alternatives 3-1 through 3-IV will
comply with these ARARs consistent with the limited scope of this
action. However, the goal of this interim remedial action is not
to restore the aquifer to the MCLs but to prevent the spread of
the contaminated ground water.

Discharge of treated water for Alternatives 3-1 and 3-II to the
Gurabo POTW will comply with the Puerto Rico Pretreatment
Standards as per Act No. 9, Regulation 4282, which is applicable.

PRDNR Law 136 calls for beneficial use of the waters of Puerto
Rico, thus avoiding waste. This is not an ARAR, but rather a "To
Be Considered" (TBC) criterion. Alternatives 3-III and 3-IV
would also provide a beneficial use of the water while recharging
the aquifer with treated ground water or discharging to Mamey
Creek which will enable some of the ground water to recharge the
aquifer.

Direct discharge of the treated water by reinjection or to the
Mamey Creek under Alternatives 3-III and 3-IV will comply with
NPDES requirements.

Ground water reinjection under Alternative 3-III will comply with
the substantive requirements of the Underground Injection Control
Regulations pursuant to the Commonwealth Act No. 9 and the
Federal Underground Injection Control Regulations, whichever are
more stringent.

3. Long-Term Effectiveness

Alternatives 3-III through 3-IV would all be effective in the
long-term for controlling plume migration. Alternatives 3-1 and
3-II would not be effective in the long-term because PRASA has
not agreed to accept the treated water on a long-term basis.
The implementation of Alternative 3-III would provide the most
reliable long-term effectiveness, since it includes the
reinjection of the treated water downgradient of v.he Site causing
a hydraulic barrier and reducing further off-site migration of

20
-------
the plume.

4. Reduction of Toxicity, Mobility or Volume Through Treatment

Alternatives 3-1 through 3-IV would reduce the toxicity, mobility
and volume permanently through extraction and treatment of
impacted ground water. The reinjection of the treated water
(Alternative 3-III) downgradient would provide a hydraulic
barrier to reduce the plume migration. Also, the reinjection of
treated water would reduce concentrations by dilution.

5. Short-Term Effectiveness

Alternatives 3-1 through 3-IV are not expected to cause any
short-term adverse impacts to the community or the environment
during the construction of the treatment systems. However,
Alternative 3-1 may be implemented almost immediately while the
other options will require longer implementation schedules.
Alternative 3-III would have the longest implementation time
because the design of a reinjection system is very complicated.

6. Xmplementability

Deed restrictions and well construction controls for Alternative
3-1 through 3-IV would be obtained with the cooperation of
regulatory agencies although they may be somewhat difficult to
enforce. All alternatives are technically feasible as the
necessary equipment, services and materials are available for
construction. Conventional air stripping units are readily
available but steam strippers require design and construction.
Steam stripping is an innovative technology but has been
successfully demonstrated to treat groundwater at high
concentrations. Conventional air stripping is a common and
demonstrated technology that has been used to treat ground water
at many sites. Alternatives 3-1 and 3-II are not implementable
for a long term remedy (but Alternative 3-1 is implementable on a
short term basis) as PRASA has indicated that it will not accept
this water on anything but a temporary basis (and Alternative 3-
II requires a steam stripper to be built first). An agreement
for the discharge of the treated water using the conventional air
stripper for treatment has been completed between PRASA and
Janssen. An agreement would have to be reached with PRDNR and
EQB to discharge the treated water to Mamey Creek or reinjection
into the aquifer but these are considered to be iroplementable.
7. Cost

Alternative 3-1 is the least costly with a Capital Cost of
$525,000, Annual O&M of $229,000, a 10-year present worth of

21
-------
$2,293,300 and a 30-year present worth of $4,045,300.
Alternative 3-II has a Capital Cost of $2,925,000, Annual O&M of
$365,000, a 10-year present worth of $5,747,300 and a 30-year
present worth $8,543,600. Alternative 3-III has a Capital Cost
of $3,330,000, Annual O&M Cost of $270,000, 10-year present worth
of $5,414,900 and a 30-year present worth of $7,480,600.
Alternative 3-IV has a Capital Cost of $3,050,000, Annual O&M
Cost of $270,000, a 10-year present worth of $5,134,900 and a 30-
year present worth of $7,200,600.

8. State Acceptance

The concurrence letter from the EQB is attached to this Record of
Decision as Appendix C.

9. Community Acceptance

All comments are addressed in the Responsiveness Summary, which
is appended to this Record of Decision as Appendix D.
BOILS

1. Overall Protection of Human Health and the Environment

The "No Action" alternative requires no change to the existing
conditions at the Site and as such would not provide overall
protection of human health and the environment; therefore, it was
eliminated from further consideration and will not be discussed
further. Alternatives 2 and 3 would provide overall protection
of human health and the environment. Alternative 2 would provide
the best overall protection because it would remove the impacted
soils from the Site. Alternative 3 would also provide protection
although it would take more time to reduce the compounds from the
soils.

2. Compliance with ARARs

There are no chemical-specific ARARs for contaminated soils. The
SVE system as described in Alternative 3 would be maintained
until no more VOCs could be effectively removed. It is
anticipated that any action-specific ARARs associated with soil
treatment can be met by each alternative. However, Alternative 2
would require that the soil be tested using the Toxicity
Characteristic Leaching Procedure (TCLP) (and, potentially
treated) to ensure that the soils comply with the RCRA Land
Disposal Restrictions before the soils could be disposed of off-

22
-------
site.
3. Long-Term Effectiveness and Permanence

Alternatives 2 and 3 are both protective in the long term;
however, Alternative 3 will require some operational time to
ensure that VOCs have been reduced such that they will ho longer
act as a source of contamination to the ground water.

4. Reduction of Toxicity, Mobility or Volume

Alternative 3 would be effective in reducing the toxicity,
nobility or volume of compounds and uses treatment in doing so.
Alternative 2 would generate a large volume of soils that would
have to be disposed of in an approved facility in the continental
United States. Alternative 2 (unless treatment is deemed
necessary) would not reduce the toxicity of the compounds but
would reduce the mobility since the contaminants would no longer
be present at the Site. Alternative 3 also generates small
volumes of Granular Activated Carbon that would have to be
disposed of or treated.

5. Short-Term Effectiveness

Alternative 2 is protective in the short-term by removing
impacted soils. However, the work to be performed before
removing soils includes the demolition of the Chemical Plant
Building, and the subsequent removal of the impacted soils which
would cause short-term impacts to the operations of the facility
and perhaps to workers. Alternative 3 would take longer to
achieve the goal of preventing further migration of compounds
from the soil to the ground water because the system has to be
operated for some period of time before the compounds are
removed.

6. Implementability

Alternative 2 would require the demolition of the Chemical Plant
Building. This will upset operations at the facility because a
new Chemical Plant Building would have to be built before the old
one could be torn down. Otherwise, facility operations would
come to a halt. This presents some significant problems for the
facility. Furthermore, excavation depths would be expected to
reach 30 feet, which presents a significant implementation
problem for this alternative. Alternative 3 is much more
implementable, requiring'only the installation of SVE wells,
vacuum pumps, and GAC treatment units for air emissions. All
materials, services, and equipment to implement this alternative
are readily available.

23
-------
7. Cost

Alternative 2 has a Capital Cost of $62,036,000, no O&M and the
10-year and 30-year present worth is $62,036,000. Alternative 3
has a Capital Cost of $250,000, Annual O&M of $100,000, the 10-
year present worth of $1,022,200 and a 30-year present worth of
$1,787,200.

8. State Acceptance

The concurrence letter from the EQB is attached to this Record of
Decision as Appendix C.

9. Community Acceptance

All comments are addressed in the Responsiveness Summary, which
is appended to this Record of Decision as Appendix D.

IX. Description of the Selected Remedy

Based on the results of the SI report, the detailed evaluation of
all comments submitted by interested parties during the public
comment period, and after careful consideration of all reasonable
alternatives, EPA selects Alternative 3-IV as an interim
alternative for the ground water medium and to continue with
Alternative 3 for the soils, as the choices for addressing the
contamination problem at the Janssen Site. However, it should be
noted that these alternatives have been selected as part of a
short term early action. It should also be noted that since the
construction of the steam unit would take approximately twelve to
eighteen months, a conventional air stripping unit will be
utilized as part of this early action. Treated water from the
conventional air stripping unit will be discharged to the PRASA
Gurabo POTW until the construction of the steam stripping unit.
At that time the treated water will be rerouted and discharged to
Mamey Creek. The final remedial action for this Site will be
selected as soon as the on-going Remedial Investigation and
Feasibility Study is completed. Specifically, the selected
interim alternatives for the ground water will involve the
following:

O Pumping of impacted ground water from four recovery
wells at a combined flow rate of approximately 80
gallons per minute (gpm). The exact number and
location of wells and their pumping rates will be
determined during design.
i

o Treating the impacted ground water by steam stripping.
Initially, a conventional air stripping unit will be
installed to remove volatile organic compounds (VOCs)

24
-------
from the extracted ground water. The installation and
operation of the conventional air stripping unit will
be initiated immediately and the steam air stripping
unit will replace it within approximately eighteen
months.

O Discharging the treated water from the conventional air
stripping unit to the Puerto Rico Aqueduct & Sewer
Authority (PRASA) Gurabo Treatment Plant until it will
be replaced by the steam stripping unit. At that time
the treated water will be rerouted and discharged to
Maroey Creek.

O Implementing a system monitoring program which includes
the collection and monthly analysis of influent and
effluent from the air stripping unit and periodic
collection of well head samples.

In addition, Janssen, with oversight from EPA, will continue to
operate and maintain the soils early action as follows:

o Operating a soil vapor extraction system to remove VOCs
from soil until such time as no more VOCs can be
effectively removed. Soil vapors will be treated by
using granular activated carbon (GAC) before being
emitted to the atmosphere. Emissions will be below the
requirements established by the EQB.

o Implementing a system monitoring program which includes
the collection and analysis of soil vapors before and
after they are treated with GAC.

The ultimate goal of the EPA Superfund Program's approach to
groundwater remediation as stated in the NCP is to return usable
groundwater to its beneficial use within a reasonable time frame.
Therefore, for the Janssen aquifer which is classified as a Class
II aquifer, the final remediation goal will be the MCLs and
MCLGs. However, it should be noted that this action is an
interim action which will achieve significant risk reduction
quickly while a final remedial action for the groundwater is
being developed.

EPA believes that the selected interim remedial Alternative 3-IV
for the ground water, and the implementation of the soil early
action provides the best balance amongst the alternatives
according to the evaluation criteria. Ground water Alternative
3-IV, an innovative technology, will provide a high level of
protection of human health and the environment. It will reduce
the toxicity, mobility and volume permanently through the
extraction and treatment of the impacted ground water. In
addition, by pumping and treating contaminated ground water first
through the use of a conventional air stripper, and then through

25
-------
the use of steam stripping, the plume can be contained
immediately. The utilization of four wells to contain the plume
and extract the impacted ground water is an active approach to
the problem. The potable water filtration plant which PRASA is
constructing is upstream from the discharge point of the Gurabo
POTW.

With respect to the soils early action, Alternative 3 will
provide overall protection because it should reduce the presence
of VOCs at the Site through in-situ treatment such that it will
no longer act as a source of contamination to the ground water.
It also would be more practical to implement rather than soil
removal and disposal because the Chemical Plant Building would
not have to be dismantled and another one built. Furthermore,
the selected alternative will generate less volume of waste.

X. Statutory Determinations

EPA's primary responsibility at Superfund sites is to select
remedial actions that are protective of human health and the
environment. CERCLA also requires that the selected remedial
action for the Site comply with applicable or relevant and
appropriate environmental standards established under federal and
State environmental laws, unless a waiver is invoked. The
selected remedy must also be cost-effective and utilize permanent
treatment technologies or resource recovery technologies to the
maximum extent practicable. The statute also contains a
preference for remedies that include treatment as a principal
element. The following sections discuss how the selected remedy
for contaminated groundwater and the soil beneath the Chemical
Plant Building at the Site meets these statutory requirements.

1. Protection of Human Health and the Environment

The selected interim remedy protects human health and the
environment by containing the contaminated groundwater plume and
by reducing levels of contaminants in the groundwater through
extraction and treatment as well as through deed restrictions.
Alternative 3-IV will provide overall protection by reducing the
toxicity, mobility and volume of contamination through treatment
of the contaminated water to meet federal and state ARARs.

With respect to the contaminated soil remediation, Alternative 3
will provide overall protection because it should reduce the
presence of VOC's at the Site through in-situ treatment such that
it will no longer act as a source of contamination to the ground
water. 4

2. Compliance with ARARS

The selected remedy will achieve compliance with chemical

26
-------
specific ARARs related to the groundwater at the Site within the
scope of this limited interim remedial action. The relevant and
appropriate requirements include the MCLs promulgated pursuant to
the Safe Drinking Water Act. Contaminants of concern at the Site
have Federal and/or Commonwealth MCLs and MCLGs. In addition, the
discharge to Maroey Creek will have to meet NPDES requirements.
There are no chemical specific cleanup standards for contaminated
soils.

At the present time it is expected that air emissions from the
conventional and the steam stripping tower will not be a problem.
Air emissions will be monitored and if necessary controls will be
implemented.

3. Cost Effectiveness
EPA believes the selected remedy is cost-effective in mitigating
the principal risk posed by contaminated ground water and soil
beneath the Chemical Plant Building within a reasonable period of
time. Section 300.430(f) (l)(ii) (D) of the NCP requires EPA to
evaluate cost-effectiveness by comparing all the alternatives
which meet the threshold criteria of protection of human health
and the environment and compliance with ARARs, against the three
balancing criteria (long-term effectiveness and permanence;
reduction of toxicity, mobility or volume through treatment; and
short-term effectiveness) to determine overall effectiveness and
then comparing overall effectiveness to cost to ensure that the
remedy is cost-effective. The selected remedy meets these
criteria and provides for overall effectiveness in proportion to
its cost. The selected ground water remedy has an estimated
capital cost of $3,050,000, annual O&M of $270,000, and 30-year
present worth of $7,200,600. The selected soil remediation has a
capital cost of $250,000, annual O&M of $100,000 and 30-year
present worth of
$1,787,200.
4. Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
Even though this is an interim remedial action, by treating both
the ground water and the contaminated soils, EPA has determined
that the selected interim remedy utilizes permanent solutions and
alternative (innovative) ^treatment technologies to the maximum
extent practicable. Although SVE is not as permanent as removing
the contaminated soils from beneath the Chemical Plant Building,
it will achieve levels in the soil that should prevent further
contamination to the ground water. The final remedy for the Site

27
-------
will be selected based on the data obtained from the remedial
investigation that is presently ongoing.

5. Preference for Treatment as a Principal Element
The selected interim remedy satisfies the s±3t..tory preference
for remedies that employ treatment that reduc. the toxic:ty,
mobility, or volume of contamination as their principal element
for the groundwater and soil contamination. The selected remedy
includes the installation and operation of a ground water
treatment system for contaminant recovery. The selected remedy
for the contaminated soils, the principal threat at the Site,
includes the operation of the SVE system.

XI. Documentation of Significant Changes
The Proposed Plan for the Janssen, Inc. Site was released for
public comment on June 8, 1993. For remediation of the
groundwater the Proposed Plan recommended Alternative 3-II; the
use of a steam air stripping unit with discharge of the treated
groundwater to the Gurabo POTW. Under this alternative, a
conventional air stripping unit would be installed to remove VOCs
from the extracted ground water until a steam stripping unit is
constructed. Once the steam stripping unit was installed, the
treated water would be discharged to the PRASA Gurabo treatment
plant. The 30-year present worth cost of this alternative is
$8,543,600.

Upon review of the comments received during the comment period,
in particular PRASA's comments, EPA has decided to select
Alternative 3-IV for the groundwater. According to PRASA, they
would be willing to temporarily accept the treated water at their
treatment plant. However, due to capacity problems, they would
not be able to accept this water over the life of the
remediation. PRASA commented in favor of Alternative 3-IV over
Alternative 3-II.

The difference between the proposed alternative and the selected
alternative is that under the selected alternative, the treated
water will be sent to the PRASA Gurabo treatment plant until the
construction of the steam air stripping unit is completed. At
that time the treated water will be rerouted to Mamey Creek. The
30-year present worth cost of this alternative is $7,200,000. No
changes were made to the soil remediation alternative as
presented in the Proposed Plan.
28
-------
FIGURES
JANSSEN INC. SITE
GURABO, PUERTO RICO

APPENDIX A
-------
UAYAGUEZ
JANSSEN SITE
Gurabo, Puerto Rico

Site Location
Figure No. i
5CAUE IN KJLOWCTERS

0 Q.S 1 1.5 2
-------
JANSSEN SITE
Gurabo, Puerto Rico
Study Area (1969)
Figure No. 2
-------
JANSSEN SITE
Gurabo, Puerto Rico
Genera] Area
Figure No. 3
CUM.BC IMMFAL 80UWM
H^.. "
JUNK* VIMVAL
SCALE IN KILOMETERS
0 0.3 1 1-5 2
SOIL TECH
-------
JANSSEN SITE
Gurabo. Puerto Rico
Surflcial Geology
Figure No. 4
SYMBOLS*
• »•«*•»•»•••»
• »»»»»«
» »• » # • »
»»»«»*
•»•**•••
PLE1STDCCNIC DEPOSITS - SEA SWRC
SANDS, DUNES AND SWAMP DEPOSITS.
PLEISTOCCNIC DEPOSITS OF ALLUVIAL
SEDIMENTS - PREVAILS SANDS, SILTS,
CLAYS AND GRAVELS.

SILTS AND SANDS, CONGLOMERATES.
LAVA. AND PALESCENUS AND ESCENUS
TUFFS.
TUFFACEDUS SANDS, SILTS. BRECCIA*
CONGLOMERATES. LAVA AND TUFFS.
SUPERIOR CRETACEOUS AGE.
LAVA, LAVA-BRECCIA, TUFF. AND
TUFFACEOUS BRECCIA, INFERIOR
CRETACEOUS AGE.
PLUTONIC ROCKS - GRANODIURITE
AND QUARTZDIURITC.

REGIONAL FAULTS

SURFICIAL WATER FEATURES
SOIL TECH
-------
JANSSEN SITE
Gurabo, Puerto Rico

Gurebo River Basin
Figure No. 5
ATLANTIC OCEAN
SM JJM
MAYAGUE2
01 Z 3 < 5 6 7 KILXCTERS
M-i
0 I
«KT«i WVTt Ul*
GRANX DC tOIZA RIVCR
UNIT BOUNDARY
— GURABO RIVCR UNIT
BOUNDARY
SOIL TECH
-------
JANSSEN SITE
Gurabo. Puerto Rico
General Hydrogeologica! Cross Section
Figure No. 6
3 100
g
3
LEGEND:
[v^l MOSTLY CLAY
E3] MOSTLY GRAVEL
F^V| SAND AND SILT
[>\1 WEATHERED ROCK
BEDROCK
WATER TABLE
500 1000 1500 8000
DISTANCE. IN FEET. VERTICAL EXAGGERATION X 5
£500
3000
SOIL TECH
-------
JANSSEN SITE
Gurabo, Puerto Rico

Well Inventory
Figure No. 7
SCALE IN KILOMETERS

0 0.5 1 LS 2
Primory use of wells
I Domestic
* Irrigotion
• Industrie)
a Public Supply
• Stock
CD Unused
O Unknown
SOIL TECH
\V\V///\\\\
-------
:ONCEKTRAT10N RAKGF

iS OVER 100.000

E3 10.001 - loo.ooo

@ 2.001-10.000

Q] 200-2.000
600 ft
DAIRY rAJOf
LEGEND :
PRODUCT10K >TLL
LOCATION
SHALLOW WONITORING
1TELL

DEEP MONITORING
WELL
FIGURE 8 CHLOROFORM PUME CONFIGURATION
NOVEMBER 1991, OMB GURABO, PUERTO RICO
SCALE : C.S. j DWG. BY : OLH j FILE : FIGURE 5 }JbT NQ.:69525-93
SOIL TECH
-------
LUME RANGE
Ii OVER 100,000
0 10.001 - 100.000
3 2.001 - 10.000
ED s - 2.000
SCALE :
0 250
500 ft
DAJRT
LEGEND :
A SHALLOW MONITORING
»TLL (JV)
A SOIL BORING COMPLETED
AS MONITORING YELL (JW)
^ EARLY WELL (EV)
PRODUCTION VELL
LOCATION (¥)
FIGURE 9 CHLOROFORM PLUME CONFIGURATION OF
JULY. 1992 OMB GURABO, PUERTO RICO
SCALE : G.S.
BY : OLH
FILE : FiGVSE 6 pOB. KO.. 89525-93
I
SOIL TECH
-------
DAIRY
B OVER 100.000
E jo.ooi - 100.000
B z.ooj - 10.000
d 8 - 2.000
LEGEND :

• PRODUCTION KUL
A SHALLOW KOKTTORWC
° TOL
4 PUP MONITORING
VEIL
(/}
'
see a
VOTE WELLS JT-i: AND W-l
»ERE W3T
lOcHLOROFORM PLUME CONFIGURATION OF V-.OtCH, 1993
OMB GUP.ABO. PUERTO RICO
XTT : OS. '11 /P3J SCALE : C.S |pW5 BT : OLH
u< 1 POB. NP.:89S?S-»;
SOIL TECH
. ..
' 'V •' t >•'
•'
-------
TABLES
JANSSEN IMC. SITE
GURABO, PUERTO RICO

APPENDIX B
-------
• TABLE 1 -:

SUMMARY GROUND WATER SAMPLES ANALYSIS RESULTS
CHLOROFORM PARAMETER
OMB SITE
GURABO, PUERTO RICO
Chloroform Concentration (ug/l)
Date
Jan/10/90
Feb/27/90
May/24/90
Oct/ 17/90
|Mar/27/9f /
Apr/08/91
May/07/91
< June/07/91
July/91
Aug/91
S;',::''H
IW-4
3
5
S
4
2
NS
NS
NS
5u
NS
NS
JW-4A
NC
NC
NC
24
3
NS
NS
NS
8
NS
NS
JW-3
13.500
12.300
16.800
12.900
7,i90
NS
NS
NS
IJ.OOOD
I3.000B
NS
NS
JW-3A
NC
NC
1.380
4.900
7.960
NS
NS
NS
6.000
NS
NS
JW-6
1
3
7
ND
ND
NS
NS
NS
3u
NS
NS
JW-7
69
7
23
10
6
NS
NS
NS
7
NS
NS
JW-7A
NC
NC
NC
102
243
NS
NS
NS
2600
260B
NS
NS
nv-a
361.000
397.000
148.000
110.000
472.000
NS
NS
NS
200.000O
240.000B
NS
NS
JW-8A
21.000
203.000
219.000
119.000
33.300
NS
NS
NS
740
NS
NS
JW-8B
JW-9
NC 6
NC
NC
276.000
48.200
NS
NS
NS
230.000D
260.000B
NS
5
3
2
5
NS
NS
NS
lOu
NS
NS | NS
JW-9A
NC
NC
2
1
13
NS
NS
JW-10
704
79
740
74
143
NS
NS
NS NS
3J
NS
NS
140
NS
NS
JW-IOA
NC
NC
9
2
ND
NS
NS
NS
lOu
NS
NS
JW-II
24
!R
M
3
10 1
NS
NS
NS
9
NS
NS
Qmlifitni
NC
NS
NO
BMDL
E
u
B
I
D
Not conitniclcd
Ntxumpled
Not deiecubfc
Below Minimum Detection Limit
Compound whne concmtnuon eiceab Ac citibraUon ringe.
Compound wu tiuljned tut not detected.
Rcponed Vilue below CRDL but time IDL.
Indkilci in esllnuted vtlue.
Duplkiu ample.
«7SJ.wpf
-------
TABLE 1 (CONT.)

SUMMARY GROUND WATER SAMPLES ANALYSIS RESULTS
CHLOROFORM PARAMETER
OMB SITE
GURABO, PUERTO RICO

Data
Jin/ 10/90
Peb/27/90
• Miy/24/90
;'.; Oct/ 17/90
Mir/27/91
Apr/08/91
M»y/07/9l
| June/07/91
July/91
Aug/91
Sept/91
JW-12
10
3.370
105
ND
1.230
NS
NS
I.OOOE
5u
1.100
13
1W-13A
NC
NC
NC
330
3.170
NS
NS
NS
430
NS
NS
Chloroform Concentration (ug/l) ||
JW-14
NC
NC
NC
NC
NC
NC
NC
NC
NC
NS
NS
EW-I
NC
NC
7
ND
ND
ND
ND
Su
5u
5u
Su
W-l
NS
NS
518
50
1
NS
NS
NS
5u
NS
NS
W-2
NS
NS
5.960
5.450
5.020
NS
NS
6.200D
2.300B
3.900
1.000
5.400
W-3P
NS
NS
*
4
W-4H
NS
NS
BMDL
1 ' ND
20
NS
NS
NS
6
NS
NS
32
29
ND
5u
5u
5u
Su
W-C
NS
NS
NS
NS
NS
NS
W-D |j
NS 1
NS i
NS
NS
NS
NS
NS US
NS
lOu
NS
NS
NS
NS
Su
NS
NC
NS
ND
BMDL
E
u
B
I
D
Not coraoucBd
Not unified
NddeictuMc
Below Minimum Dcuclkn Umh
Compound whose conccnnilon cicccdt die ulibrallon nii|C.
Compound wu uulyied but noi dcutlcd.
Reported Vilue betow CRDL but ibov* IDL.
Indkuci ui csiinuied value.
Dupliuu umpk.
W-C - Church WeD
W-D • DtbT Fum Well
<2753.»pf
-------
SUMMARY GROUND WATER SAMPLES ANALYSIS RESULTS
TOLUENE PARAMETER
OMB SITE
GURABO, PUERTO RICO
Toluene Concentration (ug/l)
Dale
Feb/90
Mar/91
luly/91
JW-4
ND
NS
Su
JW-4A
NC
NO
5u
JW-5
ND
NS
2SOu
JW5A
NC
NS
250u
JW-6
NS
NS
Ju
JW-7
BMDL
NS
Ju
JW-7A
NC
NS
5u
JW-8
BMDL
NS
36.000D
4.400
JW-8A
ND
ND
2.IOOJ
JW-8B
NC
NS
lO.SOOu
I.200J
JW-9
NS
NS
U
JW-9A
NC
ND
3J
JW-10
ND
NS
5u
JW-IOA
NC
ND
Su
JW-II
NS
NS
Su
Qualifier!:
NC - Not constructed
NS - Notumplcd
ND - Not dciccuble
BMDL- Below Minimum Detection Limit
B - Compound whose concentration eicetds the calibration range.
u - Compound was analyzed but not detected.
B • Reported Value below CRDL but above IDL.
] - Indicate! an estimated value.
D - Duplicate sample.
42753.wpf
-------
TABLE 2 (CONT.)

SUMMARY GROUND WATER SAMPLES ANALYSIS RESULTS
TOLUENE PARAMETER
OMB SITE
GURABO, PUERTO RICO
Toluene Concentration (ug/1)
Date
Peb/90
Mu/91
July/91
Aug/91
i, Sepl/91
JW-12
NS
NS
5u
504
3u
JW-I2A
NC
NC
NC
NC
NC
IW-I3A
NC
NS
234
NS
NS
EW-1
NC
NS
5u
3u
5u
W 1
NS
NS
3u
NS
NS
W-2
NS
NS
I30u
50u
250u
W-3P
NS
NS
3u
NS
W-4H
NS
NS
5u
5u
NS .; 3u
W-C
NS
NS
3u
NS
NS
W-D
NS
NS
NS
3u
NS
Qualifier!:
NC • Net coiuuiKfed
NS - Not sampled
ND • Not detectable
BMDL- Below Minimum Detection Umb
E • Compound whose concemrailon eiceeds die calibration range.
u - Compound wu analyzed but not delecled.
B - Reported Vihie below CROL but above IDL.
I - Indicaiei an estimated value.
D - Duplicate sample.
W-C - Church Well
W-D - Dairy Farm Well
42753.wpf
-------
TABLE 3 -
QUARTERLY SAMPLING
ANALYTICAL RESULTS
GROUND WATER SAMPLES
June 28, 1991

JANSSEN SITE
GURABO, PUERTO RICO
Coiccilrillon ng/l
-
Compound]
Melbyleie Chloride
Acelone
Chloroform
MIDK
Toluene
Telrahydrofuran
Carbon Disulflde
A7737
JW^
5>
lOu
5a
lOu
SB
I0a
Sa
A7738
JW-7
Si
101
7
lOu
5u
lOu
5.
A7739
JW-7A
5i
I0«
2606
lOu
5u
10i
5.
A7740
JW-II
5t
lOa
9
lOu
5u
19
Ju
A774I
JW-12
5.
I0i
Si
I0«
5i
10i
5«
A77«
JW-5
250»
SOOa
1 5,000 E
SOOa
250a
23.IOOE
SOOu
A7744
JW-SA
2SOn
SOOa
6.000
SOOa
2SOa
6,300
SOOu
A7745
W-2
I30«
2SOu
3,900
2SOi
130u
310
2SOa
A7747
JW 10
S.
I0i
140
lOu
Sa
10*
Sa
A7748
JW-IOA
Sa
16
lOa
lOa
SM
lOo"
lOa
I/ Two aiUowi compondi It Sllaaol lad Methane foiad. 3/ Uikaowi *id Melhiae 4/ Methane

i: Compound was antyzed but *ol delected.
J: Indlciles an estimated value.
E: Compouid whose conceiualloi eiceed the calibration range.
4II77.wpf
-------
xTABLE 3 (CONT.)
QUARTERLY SAMPLING
ANALYTICAL RESULTS
GROUND WATER SAMPLES
June 28, 1991

JANSSEN SITE
GURABO, PUERTO RICO
Coaccalniloa |ig/l II

Compounds
Melhylene Chloride
Ace lone
Chloroform
MIOK
Toluene
Telrahydrofuria
Carbon DUulflde
A7749
W-l"
5i
10*
5i
lOu
5i
10*
5*
A7751
JW-8
7,100
42.000
240.000E
7,100
4,400
25,700
5.000*
A7752
JW-8A
13,000
34,000
74,000
5,0008
2.IOOJ
46.000
5,000*
A7753
JW-8B
12,000
17,000
260,WH3P.
5000i
I.200J
41,400
5,000*
A77S4
Well *S8
5*
IQa
(On
lOn
5v
lOo
lOu
A7755
JW-13
254
51
430
50u
25a
340
50y
A7756
JW-9"
6
21
10*
10s
2J
I0i
5J
A7757
JW-9A"
8
32
5J
ion
3J
ion
10*
A7758
W-XP)
4J
lOi
6
lOi
So
lOi
5u
A7759
EW-1"
6
10*
5*
10*
5*
lOu
5.
A7760
JW-4*
5«
lOi
5«
lOi
5i
lOi
12
A7761
JW-4A
2J
10*
8
10*
..5*
10*
5*
A7763 |f
VM(II) j
5u
lOu
5*
10*
5*
10*
5*
I/ Two nkiow* compoiadi 2/ Sll««ol lid MCIIIM foiid. 31 UiUowi and Melhane 4/ Melhue

i: Compond wit inilyzed but *ol delected.
J: Indlciles i* esllmiied vitie.
E: Compond whose cooccilntloi exceed the cillbrilloi range.
4ll77.wp[
-------
.-TABLE 4
ANALYTICAL RESULTS (ug/l)
QUARTERLY SAMPLING
(MARCH, 1992)
OMB PHARMACEUTICAL PARTNERS
GURABO, PUERTO RICO
SAMPLE IDENTIFICATION *
Compound
•>
Melhylene
Chloride
Acetone
Chloroform
Benzene
Toluene
Chlorobcnzene
Ethylbenzene
Telrahydrofuran
Hexane
Mtihanol
B0262
JW-4
4BJ
1800E
67
lOu
6BJ
2J
lOu
lOu
18J
NO
BO2S4
JW-4A
2BJ
150
20
lOu
lOu
lOu
lOu
lOu
6J
ND
90240
JW-5
lOOOu
lOOOu
16000
120J
210BJ
230J
lOOOu
22000E
ND
ND
B0241
JW-SA
110BJ
1400
6600
SOOu
110BJ
6SJ
SOOu
5500
310J
ND
BO242
JW-6
1SBJ
1100B
340
50u
15BJ
SOu
50u
50u
34J
ND
BO245
JW-7
10J
570B
290
SOu
9BJ
SOu
SOu
lOu
62J
ND
BO243
JW-7A
3BJ
180
2SOB
lOu
4BJ
lOu
lOu
lOu
BO260
JW-8
2200J
91000
320000
2SOOOu
12000J
2700J
4900J
48000
13J ND
ND
9000
B0261
JW-8A
31000
120000
200000
20000U
9100BJ
20000u
20000u
102000
ND
6000
B02S2
JW8D
8000
19000B
74000
SOOOu
1300RJ
SOOOu
SOOOu
25000
ND
390
B0258
JW-9
lOu
2800B
8J
lOu
2BJ
lOu
lOu
lOu -
26J
ND
B0257
JW-9A
2BJ
1100B
20
lOu
2BJ
lOu
lOu
lOu
60J
ND
Melhanol Reporting Limil: 20 ug/l Method 8015

Qualifiers;

ND = Not detectable
BMDL = Below Minimum Detection Limit
II = Compound whose concentration exceeds the calibration range.
U = Compound was analyzed but not delected.
J = Indicates an estimated value.
BJ B Analyte is found in the associates blank as well as in the sample. It indicates probable/possible blank contamination and warns the dale user
to take appropriate action.
-------
TABLE A «X)NT.) >
ANALYTICAL RESULTS (ug/l)
QUARTERLY SAMPLING
(MARCH, 1992)
OMB PHARMACEUTICAL PARTNERS
GURABO, PUERTO RICO
SAMPLE IDENTIFICATION
Compound
f
Methylcne
Chloride
Acetone
Chloroform
Benzene
Toluene
Chlorobcnzenc
Elhylbenzene
Tclrahydrofuran
Hexane
Meihanol
BO247
JW-10
7BJ
1SOOB
210
2Su
5BJ
2Su
2Su
25u
13J
ND
BO249
JW-10A
33J
1200B
lOOu
lOOu
18BJ
lOOu
22J
lOOu
101J
ND
BO253
JW-11
lOu
770BE
20
lOu
2BJ
lOuJ
lOu
245E
31J
ND
B0248
JW-12
lOOu
870
1300
lOOu
17BJ
lOOu
lOOu
lOOu
78J
ND
BO251
JW-12A
lOu
720BB
lOu
lOu
2BJ
lOu
lOu
lOu
40J
ND
B02SS
JW-13
1SJ
320
360
2Su
4BJ
25u
2Su
2Su
13J
ND
B0246
W-l
lOu
9J
lOu
lOu
2BJ
lOu
lOu
lOu
ND
ND
BO239
W-2
500u
500u
3800
SOOu
92BJ
SOOu
SOOu
400J
ND
ND
BO264
W-3(P)
2BJ
lOu
5
lOu
2BJ
lOu
lOu
lOu
ND
ND
B0265
W-4(H)
lOu
12B
lOu
lOu
2BJ
lOu
lOu
lOu
ND
ND
B0263
EW-1
2SB
8SOBB
4SOB
lOu
47B
lOu
lOu
lOu
10J
ND
BU266
W-58
lOu
7BJ
lOu
lOu
lOu
lOu
lOu
lOu
ND
ND
Meihanol Reporting Unit: 20 ug/l Method 8015

Qualifiers;
ND
I3MDL
I-
U
J
UJ
Not detectable
Oelow Minimum Detection Limit
Compound whose concentration exceeds the calibration range.
Compound was analyzed but not delected.
Indicates an estimated value.
Analyte is found in the associates blank as well as In the sample. It Indicates probable/possible blank contamination and warns the dale user
to take appropriate action.
-------
TABLE 5
ANALYTICAL RESULTS (ug/l)
GROUND WATER QUARTERLY SAMPLING
(JULY, 1992)
OMB PHARMACEUTICAL PARTNERS
GURABO, PUERTO RICO
Compound
••••':.•••.• : '

Methylene
Chloride
Acetone
Chloroform
Benzene
; Toluene
Chlorobenzene
Eihylbenrene
Tetrahydrofuran
Hexane
Methanol
MIDK
SAMPLE IDENTIFICATION (LAB UD/SAMPLB ID)
HI637
JVM
IJ
170
SJ
SJ
6J
4
lOu
lOu
ND
60
lOu
BI628
JW-4A
lOu
31
15
lOu
IJ
lOu
lOu
lOu
ND
30
lOu
BI627
JW-S
270BJ
lOOOu
I50QO
lOOOu
lOOOu
IBOJ
lOOOu
22000
ND
30
lOOOu
BI626
JW-5A
I20BJ
SOOu
4600
SOOu
SOOu
SOOu
SOOu
2800
ND
100
SOOu
BI64I
JW-6
IJ
14
190
(Ou
3J
2J
lOu
lOu
ND
120
lOu
CB-1622
JW-7
38BJ
1200
46J
lOOu
lOOu
lOOu
lOOu
lOOu
ND
ND
lOOu
CB-1623
JW-7A
I4BJ
ISO
300.
25u
2Su
25u
2Su
2Su
ND
ND
2Su
BI6I9
JW-8
6300J
36000
2IOOOOE
lOOOu
3600J
2200J
lOOOu
19000
ND
5200
lOOOu
BI620
JW-8A
29000
230000E
300000B
lOOOOu
11000
1600)
lOOOOii
77000
ND
22000
17000
B162I
JW-8B
2700
2500u
B1645
JW-9
'.Ou
78
38000 3
2500u
220J
I80J
250(Hi
5900
ND
700
2500-j
lOu
lOu
lOu
lOu
lOu '
ND
140
iou
BI646
JW-9A
lOu
130
95
lOu
2J j
lOu
lOu
lOu
ND
70
lOu
Methanol Reporting Limit: 20 ug/l Method 8015

Qualifiers:

ND = Not detectable
BMDL = Below Minimum Detection Limit
E •= Compound whose concentration exceeds the calibration range.
u = . Compound was analyzed but not detected.
J •= Indicates an estimated value.
BJ - Analyte is found in the associates blank u well u in the (ample. It indicate! probable/possible blank contamination and warn* the date
user to lake appropriate action. '
-------
TABLE 5 (CONT.)
GROUND WATER ANALYTICAL RESULTS (ug/l)
QUARTERLY SAMPLING
(JULY, 1992)
OMB PHARMACEUTICAL PARTNERS
GURABO, PUERTO RICO
Compound

Melhylene
Chloride
Acetone
Chloroform
Benzene
Toluene
Chlorobenzene
Ethylbenzene
Tetrahydroruran
Hexane
Melhanol
MlfiK
SAMPLE IDENTIFICATION (LAB ID/SAMPLE ID)
BI62S
W-IO
3BJ
61
190
lOu
lOu
lOu
lOu
lOu
ND
370
lOu
B164C
JW-10A
3BJ
79
lOu
lOu
lOu
lOu
lOu
lOu
ND
ND
lOu
B1639
JW-II
2BBJ
600E
n
SOu
SOu
50:
SOu
49J
ND
ND
SOu
BI624
JW-12
3BJ
4 IDE
170
lOu
lOu
lOu
lOu
lOu
ND
ND
lOu
BI638
JW-12A
4BJ
ISO
35
lOu
lOu
lOu
lOu
lOu
ND
ND
lOu
BI629
JW-11
15J
19
ISO
lOu
lOu
lOn
lOu
lOu
lOu
300
lOu
B1643
W-l
2BJ
lOu
lOu
lOu
lOu
lOu
lOu
33
ND
ND
lOu
BI630
W-2
17BI
2Su
I60B
2Su
2Su
2)
2Su
210
ND
ND
2Su
B1642
W-3(P)
4BJ
lOu
lOu
lOu
lOu
lOu
lOu
lOu
ND
ND
(Ou
BI644
W-4(H)
3BJ
lOu
lOu
lOu
lOu
lOu
lOu
lOu
ND
ND
lOu
BI636
EW-I
4BJ
IS
I0p
B163S
W-58
4BI
lOu
lOu
tou ; iou
lOu
lOu
lOu
lOu
ND
ND
lOu
lOu
lOu
lOu "
lOu
ND
ND
lOu
BI634
W-61
4BJ
lOu
lOu
lOu
lOu
lOu
lOu
10l!
ND
ND
lOu
Melhanol Reporting Unit: 20 ug/l Method 80IS

Qualifiers:

ND = Not detectable
BMDL = Below Minimum Detection Limit
E = Compound whose concentration exceeds the calibration range.
u •» Compound was analyzed but not detected.
J ~ Indicates an estimated value.
BI - Analyte is found in the associates blank as well as in the sample. It Indicates probable/possible blank contamination and warm the date
-------
TABLE 6
ANALYTICAL RESULTS (ug/l)
QUARTERLY GROUND WATER SAMPLING
NOVEMBER 1992
OMB PHARMACEUTICAL PARTNERS
GURA11O, PUERTO RICO
SAMPLE IDENTIFICATION (LAB ID/SAMPLE ID)
Compound
JW-4
''!;"'.'','; ' : '? -
Methytene Chloride
Acetone
Chloroform
Toluene
Tetrahydrofuran
Xylene
Elhylbenzene
Chlorobeiuene
Mclhanol
Isoptopyl Alcohol
2BI
10 U
10 U
10 U
10 U
10 U
10 U
10 U
20 U
20 U
IW-4A
JW-5
JW-SA | JW-6
JW-7
VOLATILE ORGANIC COMPOUNDS
5BJ
4J
2J
10 U
10 U
10 U
10 U
10 U
20 U
20 U
1.400 B
420 BJ
16.000
1.000 U
24.000 E
1.000 U
1.000 U
240 J
20 U
20 U
43 BJ
100 U
2.100 E
100 U
1.900
100 U
100 U
10 J
20 U
20 U
79 B
33 B
830 E
61
14
1 J
10 U
10 U
66
20 U
6BJ
7J
97
10 U
10 U
10 U
10 U
10 U
20 U
20 U
JW-7A

20 BJ
25 B
400
25 U
25 U
25 U
25 U
25 U
20 U
20 U
JW8

13.000 B
79.000
270.000 E
6.700 J
36.000
10.000 U
10.000 U
2.200 J
20 U
20 U
JW-8A
JW-8B

57 .000 B
250.000 B
340,000
12.000 J
110.000
20.000 U
20.000 U
20.000 U
20 U
20 U
10.000 B
11.000 B
100.000
10.000 U
23.000
10.000 U
10.000 U
10.000 U
20 U
20 U
IW-9

12 B i:
<•
4J
JJ
10 U
4J
10 U
10 U
10 U
120
20 U
ND
NS
BMDL
B
U
J
- ldo» Ualamm Dcucum Unk
- Indicda x cuimcd nine.
- Aulric b biud U dx •Mcbletf bin* • »cfl H in
«* un^lc ll Mima pobd>le/paiiibk Mink uxumaatm ml "lira the tiler aa UK due u ute ippniirau iajo«.
-------
STABLE 6 (CONT.)
ANALYTICAL RESULTS (ug/l)
QUARTERLY GROUND WATER SAMPLING
NOVEMBER 1992
OMB PHARMACEUTICAL PARTNERS
GURAUO, PUERTO RICO
SAMPLE IDENTIFICATION (LAB ID/SAMPLE ID)
Compound
JW-10
JW-IOA
JWII
JW-12
JWI2A
JW-13
W-l
W-2
VOLATILE ORGANIC COMPOUNDS
Methylene Chloride
Acetone
Chloroform
Toluene
Telrihydrofiiun
Xylene
EUiylbenzene
Chlorobenzene
iMelhanol
Isopropyl Alcohol
3BJ
10 U
87
3J
10 U
10 U
10 U
10 U
20 U
20 U
9BJ
10 U
10 U
10 U
10 U
10 U
10 U
10 U
20 U
20 U
4DJ
40
14
21
60
10 U
10 U
10 U
30
20 U
3BJ
10 U
2J
10 U
10 U
10 U
10 U
10 U
34
20 U
2BJ
10 U
6J
10 U
10 U
10 U
10 U
10 U
20 U
20 U
IBJ
10 U
83
10 U
10 U
10 U
10 U
10 U
20 U
20 U
SBJ
10 U
10 U
10 U
10 U
10 U
10 U
10 U
20 U
20 U
97 BJ
820 B
1.200
100 U
260
100 U
100 U
100 U
20 U
20 U
W-3P | W-4H

6B1
SJ
3J
10 U
10 U
10 U
10 U
10 U
20 U
20 U
3BJ
9)
10 U
10 U
10 U
10 U
10 U
10 U
22
20 U
W-J8

6BJ
10 U
7J
10 U
10 U
10 U
10 U
10 U
20 U
20 U
W-61
EW-1
:•••• " . Y <
4BJ
3J
2J
10 U
10 U
10 U
10 U
10 U
20 U
20 U
11 B
4 J
10 U
10 U
10 U
10 U
10 U
10 U
10 U
10 U
N/A
ND
NS
BMDL

U
J
B
D
NM
Maun***
Bdaw MiMBua Dataln Umk
fe oUkrnlo. »««.

• m« • to d* iMfifc. h Indkma pratHMc/pxiWc LU>* caunikacio* Md •» UK
na a* UK tfai la u»c vfxopfiw ialo>.
-------
TABLE 7
QUARTERLY GROUND WATER SAMPLING ANALYSIS RESULTS (ug/l)
MARCH 1993
OMB SITE
GURABO, PUERTO RICO
| Compounds

Methylene Chloride
Acetone
Chloroform
MIBK
Toluene
Chlorobenzene
Teuahydrofiiran
Meihanol
: Isopropanol
Benzene
Ij llexane
Sample Idenliflcallon
JW-7A
4BJ
lOu
230E
lOu
1BJ
lOu
lOu
20u
20u
lOu
I4J
JW-8
10.000B
39.000B
100.000
2.400J
4.500BJ
lO.OOOu
21.000
730
580
lO.OOOu
NA
JW-8(D)
3.700BJ
12.000
92.000B
1.300)
I.900BJ
I.OOOJ
S.OOOu
1.200
410
S.OOOu
NA
JW-8A
27.000B
I30.000BE
160.000BE
13.000
8.200B
1.500J
82.000E
15.000
11.000
2,500u
740BJ
IW-8B
2.IOOBJ
2.100J
40.000
2.500u
530J
2.500u
11.000
170
20u
2.500U
NA
JW-9
6BJ
lOu
16
lOu
3J
lOu
lOu
20u
20u
8J
7J
JW-9A
7BJ
lOu
27
lOu
4J
lOu
lOu
38
20u
5BJ
18J
JW-IO
2BJ
lOu
88
lOu
2J
lOu
lOu
20
20u
lOu
3J
JW-10A
3BJ
8BJ
3BJ
lOu
2BJ
lOu
lOu
47
20u
lOu
5BJ
JW-ll
5BJ
lOu
12
lOu
3BJ
lOu
78
30
20u
lOu
8J
JW-12
30B
25u
430
25u
3BJ
25u
25u
20u
20u
25u
14J
JW-13
3BJ
10
210E
lOu
4J
41
lOu
900
20u
lOu
21J
JW-14
3BJ
5J
lOu
lOu
2fl!
EW-I
5BJ
lOu
lOu
lOu
lOu
lUu lOu
lOu
35
20u
lOu
61
lOu
28
20u
7BJ
18BJ ;
Well Legend:

W
JW/f
EW
JWM
(D)
(D)
Production Well
Shallow Monitoring Well
Early Warning Well
Deep Monitoring Well
Duplicate
Duplicate
Quallfkn:

NA
ND
NS
DMDL
B
u
J
B

DL
Not Available
Not Detected
Not Sampled
Below Minimum Detection Limit
Compound whose concentration exceeds the calibration range.
Compound was analyzed but not delected.
Indicated an estimated value.
Analyle is found in the associates blank as well as in the sample, ll indicates probable/possible blank
contamination and warns the user on the dale to lake appropriate action.
Sample diluted because exceeds calibration range.
NOTE: Analytic*) rendU not validated.
JCA/lvl/i«issen/43273.wpf
-------
TABLE 7 (CONT.)
QUARTERLY GROUND WATER SAMPLING ANALYSIS RESULTS (ug/l)
MARCH 1993
OMB SITE
GURABO, PUERTO RICO
| Compounds
L '"''
Meihylene Chloride
j Acetone
Chloroform
MIBK
,, Tuluene
•i
Chlorobenzene .
Telrahydroruran
Meihanol
,i hopropanol
. Ucnzene
Hexane
Sample Identification
W 1
IOB
lOu
lOu
lOu
3BJ
lOu
lOu
20u
20u
lOu
NA
W-2
3IOBJ
SOOu
3.900
SOOu
130BJ
SOOu
1.000
147
20u
NA
NA
W-3P
7BJ
lOu
31
lOu
U
lOu
lOu
20u
20u
6)
4J
W-4H
6BJ
lOu
lOu
lOu
U
lOu
lOu
27
20u
7BJ
4BJ
W-58
9BI
lOu
lOu
lOu
3BI
lOu
lOu
30
20u
lOu
3J
W-61
5BJ
lOu
2J
lOu
U
lOu
74
22
20u
6BJ
4BJ
W-61(D)
SBJ
lOu
2J
lOu
lOu
lOu
62
20u
20u
6BJ
4BJ
rw-4
6I1J
lOu
6J
lOu
2BJ
lOu
lOu
49
20u
lOu
I3J
JW-4A
SBJ
JOu
2J
lOu
1BI
lOu
lOu
37
20u
lOu
6J
JW-5DL
710BDJ
2.000u
/1.000BD
: 'XWu
460BDJ
2.000u
32.000
NA
NA
2.000U
NA
JW-5(D)
980BJ
6,200
25.000
2.SOOU
500J
2.SOOU
43,000
60
20u
2.SOOU
NA
JW-SA
2SOBJ
'.OOOti
17.000
l.OOOu
150J
1.000u
17.000
20u
20u
l.OOOu
NA
JW-6
3BJ ,
lOu
240E
lOu
31
21
!0u
210
20u
lOu
14J
JW-7
2BJ
lOu
62
lOu
2J
!0u
lOu
20ts
20u
lOu
S9J
WeU Legend:

W
JWI
EW
JWsTA -
(D)
QuiliTien:
Production Well
Shallow Monitoring Well
Early Warning Well
Deep Monitoring Well
Duplicate
NA
ND
NS
BMDL
E
u
J
B
DL
Not Available
Not Delectable
Not Sampled
Below Minimum Detection Limit
Compound whose concentration exceeds the calibration range.
Compound was analyzed but not delected.
Indicated an estimated value.
Analyie is found In the associates blank as well as in the sample, ll indicates
piohable/possible blank contamination and wims the user on the date to lake appropriate
action.
Sample diluted because exceeds calibration range.
NOTE: AiulytkaJ remit* not viKdaled.
JCA/lrl/jans$en/43275.wpf
-------
TABLES

JANSSEN INC. SITE
GDRABO, PUERTO RICO

APPENDIX C
-------
JANSSEN SITE
Gurabo, Puerto Rico

SOIL SAMPLES
SHALLOW SOIL BORINGS
TABLE 8
Sample Point
J-2-1
J-2-2
J-2-3
J-2-4
J.3-1*
J-3-2
J-3-3
J-3-4
J-5-2
J-5-3
J-5-4
J-5-5
J-8-2
J-8-3
J-8-4
J-8-5
Depth feet
5-7
10-12
15-17
20-22
0-2
5-7
10-12
15-17
5-7
10-12
15-17
20-22
5-7
10-12
15-17
20-22 '
Date
89-10-09
89-10-09
89-10-09
89-10-09
89-10-10
89-10-10
89-10-10
89-10-10
89-10-16
89-10-16
89-10-16
89-10-16
89-11-06
89-11-06
89-11-06
89-11-06
Time
1454
1504
1515
1617
0925
1000
1005
1050
1130
1137
1209
1219
1003
1009
1021
1056
Chloroform1'
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
1/ MDL = Minimum Detection Limit * 50
2J Drilled with a hand auger.
-------
SOIL SAMPLES
TABLE 8 (CONT.)
Sample Points
J-10-1
J-10-2
J-10-3
J-11-l
J-11-2
J-11-3
J-11-53
Depth feet
5-7
10-12
15-17
0-2
5-7
10-12
20-22
Date
(yy/mm/dd)
89-11-07
89-11-07
89-11-07
89-11-01
89-11-01
89-11-01
89-11-01
Time
1327
1336
1348
1355
1402
1411
1444
Chloroform
ND
ND
ND
ND
ND
ND
ND
3' Sample J-11-4 was a rock fragment.
-------
JANSSEN SITE
Gurabo, Puerto Rico

SOIL SAMPLES CONCENTRATIONS (ug/Kg)
SHALLOW SOIL BORINGS
March 3,1990

TABLE -9-
Sampling Points
Depth (feet) 1/
Compounds
Methanol
Isopropanol
Chlorobenzene
Chloroform
Methylene
Chloride
Toluene
Acetone
MIBK
Tetrahydrofuran
ST-M
0-2

ND
ND
ND
ND
498
BMDL
131,000
2,230
11,300
ST-1-2
2-4

ND
ND
ND
ND
447
ND
14,700
ND
BMDL
ST-1-3
4-6

ND
ND
ND
ND
493
ND
69,700^
BMDL
2,160
ST-1-4
6-8

ND
ND
ND
ND
430
974
379,000
8,090
16,170
ST-1-5
8-10

ND
ND
ND
ND
449
ND
240,000
2,600
5,990
ST-1-6
10-12

ND
ND
ND
ND
574
ND
5? 900
BMDL
4,100
BMDL c Below Minimum Detection Limit
ND = Non-Delectable
M = Measured from slab elevation
-------
JANSSEN SITE
Gurabo, Puerto Rico

SOIL SAMPLES CONCENTRATIONS (up/Kg)
SHALLOW SOIL BORINGS
July 22,1990

TABLE ±10.--
Sampling
Points
Compounds
Methanol
Isopropanol
Chlorobenzene
Chloroform
Methylene
Chloride
Toluene
Acetone
MIBK
Tetrahydrofuran
Strench 1-2

95.8
74.7
241
24.8
ND
28,300
416,000
49,200
4,270
Strench 3-4

ND
£8.9
131,000
141,000
35,700
1,210,000
ND
194,000
ND
Strench 5-6

BMDL
173
ND
ND
11.8
BMDL
82,900
BMDL
4,860
Strench 7-8

BMDL
151
BMDL
465,000
ND
8,250,000
BMDL
BMDL
ND
NO - Non-Delectable
BMDL * Below Minimum Detection Limit
-------
JANSSEN SITE
Gurabo, Puerto Rico

SOIL SAMPLES CONCENTRATIONS (ug/Kg)
SHALLOW SOIL BORINGS
July 30, 1990

TABLE 11 --. - -
Sampling
Points
Depth (feet)1'
Compounds
Methanol
Isopropanol
Chlorobenzene
Chloroform
Methylene
Chloride
Toluene
Acetone
M1BK
Tetrahydrofuran
1-A
0-1

ND
ND
24.6
ND
39.7
12.6
BMDL
28.4
20,400
1-B
1-2

ND
ND
ND
ND
1,800
ND
BMDL
ND
21,200
1-C
2-3

ND
BMDL
ND
ND
462
ND
5,840
1,470
27,600
1-D
3-4

ND
BMDL
ND
ND
3,790
ND
13,600
3,440
3£,300
1-E
4-5

ND
BMDL
ND
ND
1,810
ND
6,390
BMDL
16,600
ND * Non-Delectable
BMDL = Below Minimum Detection Limit
1/ Measured from slat elevation.
-------
JANSSEN SITE
Gurabo, Puerto Rico

SOIL SAMPLES CONCENTRATIONS (ug/Kg)
SHALLOW SOIL BORINGS
July 30,1990

.-TABLE. 12 -
Sampling Points
Depth (feet)1'
Compounds
Methanol
Isopropanol
Chlorobenzene
Chloroform
Methylene
Chloride
Toluene
Acetone
MIBK
Tetrahydrofuran
2-A
4-5

ND
ND
ND
ND
114
ND
BMDL
ND
1,270
2-B
5-6

ND
ND
ND
ND
ND
BMDL
92.1
11.2
312
2-C
6-7

ND
ND
ND
ND
ND
ND
279
ND
1,030
ND = Non-Detectable
BMDL = Below Minimum Detection Limit
\1 Measured.from slab elevation.
-------
JANSSEN SITE
Gurabo, Puerto Rico

SOIL SAMPLES CONCENTRATIONS (ug/Kg)
SHALLOW SOIL BORINGS
July 30, 1990
TABLE 13
Sampling Points
Depth (feet)1'
Compounds
Methanol
Isopropanol
Chlorobenzene
Chloroform
Methylene Chloride
Toluene
Acetone
MIBK
Tetrahydrofuran
3-A
4-5

ND
ND
ND
ND
10,800
ND
579,000
ND
65,800
3-B
5-6

ND
ND
ND
ND
1,310
ND
210,000
BMDL
17,000
3-C
6-7

BMDL
BMDL
ND
ND
ND
ND
459,000
6,460
36.300
3-D
7-8

ND
ND
ND
ND
ND
ND
99,700
BMDL
7,200
3-E
8-9

ND
ND
ND
ND
ND
ND
23,200
BMDL
7,850
ND - Non-detectable
BMDL = Bebw minimum detection limit
I/ Measured from slab elevation
-------
JANSSEN SITE
Gurabo, Puerto Rico

SOIL SAMPLES CONCENTRATIONS (ug/Kg)
SHALLOW SOIL BORINGS
July 30, 1990

14
Sampling Points
Depth (feet)1'
Compounds
Methanol
Isopropanol
Chlorobenzene
Chloroform
Methylene Chloride
Toluene
Acetone
MIBK
Tetrahydrofuran
4-A
4-5

BMDL
74.8
ND
NO
ND
ND
586,000
11,900
151,000
4-B
5-6

BMDL
BMDL
ND
ND
ND
ND
618,000
13,100
166,000
4-C
6-7

BMDL
BMDL
ND
ND
12,500
ND
1,670,000
13,700
249,000
4-D
7-8

BMDL
BMDL
ND
ND
ND
ND
1,040,000
BMDL
205,000
4-E
8-9

ND
BMDL
ND
ND
ND
ND
505,000
ND
62,800
ND = Non-detectable
BMDL = Below minimum detection limit
I/ Measured from slab elevation
-------
JANSSENSfTE
Gurabo, Puerto Rico

SOIL SAMPLES CONCENTRATIONS (ug/Kg)
SHALLOW SOIL BORINGS
July 30,1990

TABLE 15- -
Sampling Points
Depth (feet) v
Compounds
Methanol
Isopropanol
Chlorobenzene
Chloroform
Methylene Chloride
Toluene
Acetone
MIBK
Tetrahydrofuran
5-A
4-5
1 5-B
5-6
5-C
6-7
5-D
7-8
5-E
8-9

ND
BMDL
ND
ND
ND
ND
28,400
3,650
47,600
ND
BMDL
ND
ND
ND
ND
146.00D
ND
28,000
ND
BMDL
ND
ND
4,160
ND
244,000
ND
68,800
ND
ND
ND
ND
4,360
ND
71,000
BMDL
33,200
ND
ND
ND
ND
1,280
ND
24,700
• ND
9,620
ND = Non-Detectable
BMDL = Below Minimum Detection Limit
1/ Measured from slab elevation
-------
COMMONWEALTH OF PUERTO RICO
LETTER 0? CONCURRENCE

JANSSEN INC. SITE
GURABO, PUERTO RICO

APPENDIX D
-------
COMMONWEALTH OF PUERTO RICO / OFFICE OF THE GOVERNOR
ENVIRONMENTAL QUALITY BOARD
SUPERFUND PROGRAM
September 23, 1993
Mr. George Pavlou
Director
Emergency and Remedial Response Div.
U.S. Environmental Protection Agency
26th Federal Plaza, Room 747
New York, New York 10278

RE: ENVIRONMENTAL PROTECTION AGENCY
ENVIRONMENTAL QUALITY BOARD
CONCURRENCE LETTER
RECORD OF DECISION/
RESPONSIVENESS SUMMARY
JANSSEN, INC. SITE, GURABO, P.R.

Dear Mr. Pavlou:

The Superfund Program of the Environmental Quality Board (BQB) in coordination with
the Environmental Protection Agency (EPA), Caribbean Office, has beer, participating and
reviewing the above-mentioned documents.

Pursuant to public participation responsibilities under Section 117(a) of the
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) of 1980,
ax amended, and Section 300.430(0 of the National Contingency Plan, Environmental Protection
Agency (EPA) policy and guidance on Community Relations, a document referred as
"Declaration for Interim Record of Decision/Responsiveness Summary" was submitted for support
and comments.

The Puerto Rico Environmental Quality Board concurs with '.he selected alternative while
still promoting early actions remediation activities under the Superfund Accelerated Cleanup
Model (SACM) Program and innovative technologies implementation, sponsored by the
Superfund Innovative Technology Evaluation (Site) Program.

The "Declaration for Interim Record of Decision", which is a decision document, resumes
the selected interim remedial actions for the Janssen, Inc. Site, Gurabo, Puerto Rico.

The "Responsiveness Summary" is a response document to public comments arised from
the Public Meeting celebrated on June 8, 1993 and it is part of the Record of Decision (ROD)
package.
Green forests and crys'taUme raters, clean air and dear skies.
;Yoti protect life if you do not contaminate!
NATIONAL BANK PLAZA / 431 PONCE DE LEON AVE. / HATO REY, PUERTO RICO own
P.O. BOX 114S8 / SANTURCE, PUERTO RICO wmo / c809) 764-8824
-------
Page 2 of 2
The final selected alternative must comply with the Federal and State Regulations and all
applicable ARAR's in such a way that significantly reduce the potential threat to public health
aod the environment

After the comments review, in particular the Puerto Rico Aqueduct and Sewer Authority
(PRASA)'s comments, EPA decided to reevaluate the previous selected alternative presented on
the "Superfund Proposed Plan" (Alternative 3 II). According to this revision, EPA decided to
select Alternative 3 IV for the groundwater remmediarJon process. No changes were proposed
for the soil remediation Alternative 3.

Under the selected alternative (i.e. Alternative 3 IV) the treated water will be sent to
PRASA Gurabo Treatment Plant until the construction of the Steam Air Stripping unit is
completed, subsequently the treated waters will be rerouted to Mamey Creek and .subjected to a
National Pollutant Discharge Elimination System (NPDES) permit
If you have any question regarding this matter please contact Eng. Francisco Claudio Rfos,
Director. Air Quality Area, at phone numbers (809) 767-8071 or 767-8056.
Cordially,
Chairman
VR/inj

xc: Mr. Melvin Hauptmao
Eng. Carl-Axel P. Soderberg
Eng. Adidbeno Bosquc
Eng. Francisco Claudio
TOTflL P.03
-------