PB97-963814
EPA/541/R-97/105
January 1998
EPA Superfund
Record of Decision:
Janssen Inc., OU 1
Gurabo, PR
9/30/1997
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RECORD OF DECISION
Janssen inc. Site
Gurabo, Puerto Rico
United States Environmental Protection Agency
Region II
New York, New York
September 1997
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Janssen Inc.
Gurabo, Puerto Rico
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) documents the U.S. Environmental Protection Agency's
(EPA's) selection of the remedial action for the Janssen Inc. Site in accordance with the
requirements of the Comprehensive Environmental Response, Compensation and Liability
Act of 1980, as amended (CERCLA), 42 U.S.C. §9601 ei seq.. and to the extent
practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP),
40 CFR Part 300. An administrative record for the site, established pursuant to the NCP,
40 CFR 300.800, contains the documents that form the basis for EPA's selection of the
remedial action (see Appendix E).
The Puerto Rico Environmental Quality Board (EQB) has been consulted on the planned
remedial action in accordance with Section 121 (f) of CERCLA, 42 U.S.C. §9621 (f), and
concurs with the selected remedy (see Appendix C).
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the site, if not addressed by
implementing the response action selected in this ROD, may present an imminent and
substantial endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The remedial alternative described in this document represents the final remedy for the
Janssen Inc. Site. It addresses contaminated soil at the site and contaminated
groundwater in the underlying aquifer. An Interim Record of Decision, signed in September
1993, addressed the threats associated with soil and groundwater contamination in the
short term while a long term solution was being developed.
EPA has separated the response actions at the site into two different areas {the soil and
the groundwater). Currently, soil contamination is being addressed by soil vapor extraction
pursuant to an EPA Administrative Order signed in 1991. This action was implemented
to remove volatile organics compounds (VOCs) from the soils beneath the Chemical Plant
Building and thereby limit the leaching of VOCs into the underlying groundwater. A steam
air stripping system, placed in operation in November 1994 in accordance with the Interim
ROD, is addressing the groundwater contamination.
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The major components of the selected remedy, identified in this document as Alternative
5 for the groundwater and Alternative 3 for the soils, include the following:
For the groundwater remedy, Janssen will continue to operate and maintain the Steam Air
Stripper placed in operation in November 1994 as follows:
• Pumping of impacted ground water from seven extraction wells at a flow rate
of 80 gallons per minute (GPM) to 160 GPM to restore the aquifer to
maximum contaminant levels and prevent the migration of the contaminated
groundwater;
• Treating the impacted groundwater by steam stripping;
• Implementing a system monitoring program which includes the collection and
analysis of influent and effluent from the steam air stripping unit on a monthly
basis and periodic collection of well-head samples;
• Implementing a monitoring program which includes the collection and
analysis of groundwater monitoring well samples on a quarterly basis during
the first five years and then twice a year thereafter; and
• Using a portion of the treated water at Janssen for nonpotable purposes,
and discharging the excess to the Gurabo Pump Station which is part of the
wastewater collection system operated by the Puerto Rico Aqueduct and
Sewer Authority (PRASA).
For the soil remedy, Janssen will continue to operate and maintain the interim Soil Vapor
Extraction (SVE) system as follows:
• Operating the SVE system to remove VOCs from the soil until such time as
VOCs can no longer be effectively removed. Soil vapors will be treated with
granular activated carbon (GAG) before being emitted to the atmosphere.
Emissions will be below the limits established by EQB of 15 pounds per day
or 3 pounds per hour.
• Implementing a system monitoring program which includes the collection and
analysis of soil vapors before and after GAG treatment.
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DECLARATION OF STATUTORY DETERMINATIONS
The selected remedy meets the requirements for remedial actions set forth in Section 121
of CERCLA, 42 U.S.C. §9621: (1) it is protective of human health and the environment;
(2) it attains a level or standard of control of the hazardous substances, pollutants and
contaminants, which at least attains the legally applicable or relevant and appropriate
requirements (ARARs) under federal and state laws; (3) it is cost-effective;(4) it utilizes
permanent solutions and alternative treatment (or resource recovery) technologies to the
maximum extent practicable; and (5) it satisfies the statutory preference for remedies that
employ treatment to reduce the toxicity, mobility, or volume of the hazardous substances,
pollutants or contaminants at a site.
A review of the remedial action pursuant to Section 121 (c) of CERCLA), 42 U.S.C.
§9621 (c), will be conducted within five years after the commencement of the remedial
action to ensure that the remedy continues to provide adequate protection to human health
and the environment, because this remedy will result in hazardous substances remaining
on-site above health-based levels.
Jeanne M. Fox / / 9 >— / Date
Regional Adminis
in
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DECISION SUMMARY
JANSSEN, INC. SITE
GURABO, PUERTO RICO
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
NEW YORK
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TABLE OF CONTENTS
DECISION SUMMARY PAGE
I. SITE LOCATION AND DESCRIPTION 1
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 1
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 HEALTH RISKS AT THE SITE '. . . 9
VII. DESCRIPTION OF ALTERNATIVES 12
VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 19
IX. DESCRIPTION OF THE SELECTED REMEDY 25
X. STATUTORY DETERMINATIONS 26
XI. DOCUMENTATION OF SIGNIFICANT CHANGES 28
ATTACHMENTS
APPENDIX A - FIGURES
APPENDIX B - TABLES
APPENDIX C - COMMONWEALTH OF PUERTO RICO ENVIRONMENTAL
QUALITY BOARD LETTERS OF CONCURRENCE
APPENDIX D - RESPONSIVENESS SUMMARY
APPENDIX E - ADMINISTRATIVE RECORD INDEX
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I. Site Location and Description
The Janssen Site is located on twenty-five (25) acres of land on route 933, km. 0.1, Mamey
Ward, Gurabo, Puerto Rico. The site is owned by Johnson and Johnson Pharmaceutical
Partners (JJPP). The Site is located in a light industrial area and is approximately two
miles from a residential community. Johnson and Johnson Pharmaceutical Partners
(formerly known as Janssen Product Inc.), is registered with the PR Department of State
and is a partnership between Johnson and Johnson Pharm. Co. and McNeil
Pharmaceutical Co., both of which are registered in Delaware. Janssen Product Inc. was
acquired by Johnson and Johnson Pharmaceutical Partners in (or prior to) January 1994.
Janssen Product Inc. began operations at this facility in 1982. For the sake of simplicity
in this ROD, "Janssen Inc." or "Janssen", rather than "JJPP", will be used to refer to the
company and the Site.
The property where Janssen Inc. is located includes a chemical and manufacturing
building, a pharmaceutical building, an above-ground tank farm, a process waste water
treatment facility, a utilities building, an environmental laboratory, an administration
building, an electrical substation, a cooling tower, and a new quality assurance/quality
control building (Figure 1). Also, two groundwater production wells exist within the Site.
The Site is bounded to the south and east by Mamey Creek, to the west by Road PR-933,
and to the north by Highway PR-30 (Figure 2). Mamey Creek, a tributary of the Gurabo
River, is approximately 150 feet down slope of one of the impacted groundwater wells (W-
2). Two groundwater production wells at the Site are located within the Gurabo regional
aquifer which is a source of potable water for the Gurabo and Juncos municipalities. In
addition, public drinking water supply wells (Hato Nuevo wells) are located within three (3)
miles of the Site. These wells are owned and operated by the Puerto Rico Aqueduct &
Sewer Authority (PRASA) and serve approximately 10,000 people. . :
The area of investigation as shown on Figure 2, includes the Janssen Inc. plant and the
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. Surface run-off from the site flows
toward Mamey Creek.
The towns of Gurabo and Juncos, which are the two main population centers in the area,
are approximately 1.5 and 2.0 miles to the east and west, respectively (Figure 3). The
estimated population of these towns, according to the 1990 Census, is approximately
30,000 per town.
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
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intermediates for use by Janssen, Inc. Records of chemical usage at the plant indicate the
use of chloroform, toluene, methylene chloride, chlorobenzene, acetone, tetrahydrofuran,
isopropanol, Methyl isobutyl ketone (MIBK), and methanol.
In April 1989, two of the on site wells, which were sampled by Janssen, indicated
chloroformJevels at 2 parts per million (ppm) which exceed the Safe Drinking Water Act
Maximum Contaminant Level (MCL) of 100 part per billion (ppb) standard. These two
wells, used for production and drinking water for Janssen employees, were immediately
restricted to production use only.
In September 1989, Janssen notified EPA, EQB, P.R. Department of Health (DOH),
PRASA, P.R. Department of Natural and Environmental Resources (DNER), and the
Municipality of Gurabo of the release of chloroform into the environment. Later that month,
a Preliminary Assessment was conducted by EQB which recommended this Site for a high
priority 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 prevent further migration of a groundwater volatile
organics plume.
On June 15, 1990 an Information Request letter was sent to Janssen. On October 23,
1990 a Notice Letter was issued to Janssen and negotiations with Janssen were initiated.
On March 28,1991 EPA entered an Administrative Order on Consent (AGO) with Janssen
to conduct a Remedial Investigation and Feasibility Study (RI/FS) for the Site. The AGO
also required Janssen to implement Early Action Activities designed to prevent additional
leaching of tetrahydrofuran, methylene chloride, acetone, toluene, chlorobenzene,
isopropanol, MIBK and 1,4 dichlorobenzene into the groundwater and to prevent further
migration of the groundwater chloroform plume.
A soil vapor extraction system (SVE) was placed in operation on March 10, 1993 pursuant
to the EPA Administrative Order. The SVE system was designed to remove the
compounds from the soils beneath the Chemical Plant Building so that they will no longer
leach into the groundwater. On September 30, 1993 an Interim Record of Decision
(IROD) was signed by EPA. EPA separated the response actions at the Site into two
different areas (the groundwater and the soil). Under the IROD, Janssen continued to
operate and maintain the SVE system.
The selected interim remedy in the 1993 IROD also called for the continued pumping of
impacted groundwater and treating the groundwater to reduce the spread of the
groundwater plume. This was accomplished by pumping the groundwater. At the time of
the IROD, Janssen installed a conventional air stripping system to treat the impacted
groundwater while the selected steam air stripper was under construction. The operation
of the conventional air stripper commenced in October 1993.
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The operation of the steam air stripper, an innovative technology, commenced in
November 1994 and continues until the present.
III. Highlights of Community Participation
The Remedial Investigation Report, Feasibility Study Report, Proposed Plan and other
support documents were made available to the public for a public comment period starting
August 28, 1997. These documents were available in the Administrative Record and in
information repositories maintained at the EPA Docket Room in the Region II New York
City Office, the EPA Caribbean Environmental Protection Division Office, the Town of
Gurabo Municipal Library, and at the EQB Library. The notices of availability were
published in the El Nuevo Dia Newspaper, the San Juan Star Newspaper, and the La
Semana Newspaper on August 28, 1997. The public comment period lasted through
September 27, 1997. On September 10,1997 a public meeting was held at the Municipal
Assembly Room, Gurabo, where representatives from EPA presented the findings of the
remedial investigation and answered questions from the public about the Site and the
remedial alternatives under consideration. At that meeting representatives from EPA
presented the findings of the investigations and answered questions from the public about
the Site and the remedial alternatives under consideration. Responses to the comments
received during the comment period are included in the Responsiveness Summary (see
Appendix D). .
IV. Scope and Role of Operable Unit or Response Action Within Site Strategy
EPA's decision to address the impacted groundwater will serve to reduce the migration of
compounds found in the groundwater and the potential threat to public health and the
environment. This action is the final remedial action.
EPA has separated the response actions at the Site into two different areas. Those two
areas are the impacted groundwater and the impacted soil located beneath the Chemical
Plant Building. The soil is being addressed by the SVE system that was implemented
pursuant to the Administrative Order and the Interim ROD. The SVE system will remove
compounds from the soils beneath the Chemical Plant Building so that they will no longer
leach into the groundwater.
Groundwater is being addressed by a Steam Air Stripper pursuant to the Interim ROD
signed in 1993. Groundwater will continue to be pumped to prevent the spread of the
contaminated plumes. The groundwater will be treated via steam air stripping, used
internally and then discharged to the Gurabo Pump Station.
The ultimate goal of the groundwater remediation is to return usable groundwater to its
beneficial use within a time frame that is reasonable. The results of this remedial action will
be monitored to determine the final success of achieving MCLs in the groundwater.
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EPA's Superfund Program has a Groundwater Protection Strategy guidance to be used
when determining the appropriate remediation for contaminated groundwater at CERCLA
sites. The Groundwater Protection Strategy establishes different degrees of protection for
groundwater based on vulnerability, use, and value. For the aquifer at the Janssen Site,
which is classified by EPA as a Class II aquifer, the final remediation goal is MCLs.
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V. Summary of Site Characteristics
The objectives of the investigations at the site were to define the hydrogeologic character
of the local aquifer and shallow soil system, including the direction and rate of groundwater
flow and the chemical quality. The investigation would determine the magnitude and
extent of VOCs in the unsaturated and saturated zones, identify the sources of chloroform;
and gather sufficient data to allow for the implementation of response activities which
would prevent the migration of the groundwater volatile organic compounds plume.
During this investigation, soil borings, soil sampling, monitoring well installation,
groundwater 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.
Aerial photogeological interpretation, was used to determine rock fracture pattern at the
Site. It was found that the principal joint sets strikes from north 40 to 50 degrees west,
while dipping to the northeast from 50 to 60 degrees.
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 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 Loiza (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
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from the town of Las Piedras to the southeast, to the town of Gurabo, where the Gurabo
unit intercepts the Loiza River. The areal extent of this unit is shown on Figure 5.
The geomorphological and hydrogeological conditions of the Gurabo River unit are
independent of the Loiza River. The Gurabo River unit is composed mostly of sediments
derived frompiutonic 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 hydrogeological 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 groundwater flows
towards the Gurabo River which is the main surface water body in the area. Figure 6
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 groundwater 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 data, 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.
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Wells are the most important source of groundwater 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 DNER.
Figure 7 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 Rl 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), Juncos Wells (Nos. 30 through 35) and the Mamey
well. These wells are located at about 1.7, 2.0, and 0.25 miles, north, west and south 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
groundwater flow of the aquifer due to the presence of the hydraulic barrier caused by
Maney Creek.
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 J&J, 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 was formerly used for
livestock and irrigation and is currently out of service. These wells have been sampled and
results indicate only trace levels of contaminants at concentrations below the MCLs. In
addition, Janssen has collected groundwater samples from PRASA wells that have shown
no-detectable concentrations of VOCs.
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 groundwater quality of the aquifer underlying and downgradient of the Site has been
assessed as part of the remedial investigation conducted and reported in the Remedial
Investigation report. Two groundwater sampling and analysis rounds were performed as
part of the Rl activity during 1994. A list of wells included in first and second round of
groundwater sampling is included in Table 1 and 2. A total of 84 field samples were
collected and analyzed during these two events. In addition, a third groundwater sampling
for total and dissolved metals was performed in selected wells during June 1995. The
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purpose of this sampling was to determine the origin of manganese concentrations in
groundwater.
The samples collected during the two round of sampling were analyzed for Target
Compound List and Target Analyte List Metals following Contract Laboratory Program
procedures. The following are the principal findings encountered during the Rl. A
description of the sampling and analysis rounds are discussed in detail in the Final Rl
Report (Soil Tech Corporation, May 9,1996). Based on the analytical results the following
conclusions were presented:
• Chloroform and tetrahydrofuran are the two VOCs consistently present in the
groundwater. Concentrations of chloroform ranged from non-detectable to over 220
ppm. The highest concentrations are found below and south of the Chemical Plant
Building. Concentration decreases towards the north. Figure 8 presents the
groundwater chloroform plume configuration based on laboratory results of samples
collected during the initial groundwater sampling event. Figure 9 thru 11 present the
chloroform plume configuration for the shallow, intermediate and deep monitoring
wells based on validated laboratory results from samples collected during the
second sampling round.
• Tetrahydrofuran is found at concentrations ranging from non-detectable to 40 ppm.
The highest concentrations were found below the Chemical Plant Building. Figures
15 through 17 present the tetrahydrofuran plume configuration for the shallow,
intermediate and deep monitoring wells.
• Cross sections prepared of concentrations of chloroform and tetrahydrofuran versus
depth and concentration contour maps for the different well levels indicated that
below the Chemical Plant Building the higher concentrations are found in the
fractured rock while in monitoring wells to the north the higher concentration are
found in the alluvial deposits.
• Based on the data collected during the August 1994 groundwater sampling, a June.
1995 special sampling for inorganics, and the July 1995 quarterly groundwater
sampling the highest VOCs concentrations in groundwater are found below and in
the periphery of the Chemical Plant Building. The highest chloroform
concentrations were detected in the deep well JW-8A immediately south of the
Chemical Plant Building, during the August 1994 sampling (220 ppm). The June
1995 and the July 1995 sampling showed chloroform concentrations of 69 ppm and
110 ppm at well JW-8A. The highest tetrahydrofuran concentrations were detected
in the shallow well JW-15 immediately to the north of the Chemical Plant Building
(40 ppm) during the August 1994 groundwater sampling. Well JW-15 showed
tetrahydrofuran concentrations of 22 ppm and 35 ppm during the June and July
1995 samplings, respectively.
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The 0.1 ppm chloroform contour extends to the north and northeast of monitoring
well JW-191 (located in the Dairy Farm north of the Site), based on the chloroform
plume configuration for the intermediate wells from October 1995. The chloroform
plume cover an area of approximately 0.06 square miles. In 1995, when this data
was gathered, use of the water supply well on the farm was discontinued, and
Janssen had PRASA connect the farm to the public water supply system.
2. Mamey Creek Investigation
This investigation entailed the collection and analysis of surface water and sediment
samples in Mamey Creek located along the eastern side of the Janssen Site.
• Surface water and soil samples collected along Mamey Creek did not show the
presence of VOCs except for chloro-methane at an estimated concentration of
0.007 ppm.
• All samples collected indicated the presence of the same inorganic parameters
found in the groundwater and soils.
• Data collected from the piezometers and monitoring wells at the Site indicates that
the creek recharges the aquifer.
• During low flow conditions, Mamey Creek discharge is very low. However, under
reasonable rainfalls (4.24 inches in two days) a discharge volume of 311 ftVsec.
was measured. This is indicative of the potential discharge capacity of the creek.
3. Soils
As part of the Rl, seven shallow and eight deep soil borings were performed as part of the
soils investigation. Laboratory analysis were performed on a total of twenty-nine soil
samples. The purpose of the shallow soil boring program was to determine the presence
and extent, if any, of volatile organic compounds in the subsoils above the water table.
The information collected was used to supplement that obtain for the IROD. Three shallow
boring (B-1, B-2 and B-4) were performed inside the Chemical Plant Building (Figure 12)
while the other four shallow boring (B-3, B-5, B-6 and B-7) were located southwest and
south of the Chemical Plant Building (Figure 13).
The seven shallow borings identified as B-1 to B-7 were proposed to be drilled to
groundwater level, approximately 30 to 25 feet below ground. Depth attained ranged
between ten and thirty-six feet below grade.
Soil sampling analytical results obtained from the borings drilled inside the Chemical Plant
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uilding and throughout the Site as part of this ROD indicated the following:
• Chloroform concentrations were only detected in boreholes drilled south of the
Chemical Plant Building. Concentrations ranged from non-detectable to 1.4 ppm.
• Tetrahydrofuran was detected below the Chemical Plant Building and in the bore-
holes located to the south. Tetrahydrofuran concentrations in soils beneath the
Chemical Plant Building ranged from non-detectable to 8.4 ppm. Concentration of
tetrahydrofuran detected in soils south of the Chemical Plant Building varied from
non-detectable to 0.074 ppm.
• All samples analyzed for inorganic compounds indicated the presence of aluminum,
antimony, arsenic, barium, cadmium, calcium, chromium, cobalt, copper, iron,
magnesium, manganese, nickel, vanadium, and zinc. These inorganic compounds
are related to the geologic origin of the deposits.
• Aluminum, calcium, chromium, copper, iron, magnesium, manganese, nickel and
zinc are common volcanic rocks forming minerals, while antimony, arsenic, barium,
cadmium, cobalt and vanadium are accessory minerals of volcanic rocks and
sometimes are concentrated by hydrothermal events. On the other hand, there has
not been use of these metals in the processes carried out at Site.
• The analytical results of soil samples collected below the Chemical Plant Building
indicated that the soil vapor extraction system has been effective in removing the
VOCs from the unsaturated zone except for tetrahydrofuran. This chemical
compound is present but at lower concentrations than those measured during the
1991 investigation.
VI. Summary of Heath Risks at the Site
Based upon the results of the Rl, a baseline risk assessment (RA) was conducted to
estimate the risks associated with future site conditions. The RA was released by EPA on
August 8, 1995. This Risk Assessment evaluated human health risks associated with
future residents using groundwater at the site were there to be no further remedial actions
taken. Risks were evaluated based on potential human exposure to contaminants
currently present in Site groundwater. To be most protective of human health, the baseline
risk assessment assumed that the Site would be developed for residential use in the future.
The RA was prepared in accordance with the NCP and EPA's guidance for the
performance of risk assessment in the Superfund program. The RA will help to establish
acceptable exposure levels for using in developing remedial alternatives.
The data used in the baseline risk assessment included groundwater samples collected
by Soil Tech in 1994 and 1995.
Risk to human health is defined as the likelihood that people living, working or playing on
or near the Site may experience health problems as a result of their exposure to
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contaminants from the site. The ecological risk evaluation appraises actual or potential
effects of the Site on plants and animals.
Human Health Risk Assessment
A four-step ^process is utilized for assessing site-related human health risks for a
reasonable exposure scenario: "Hazard Identification" identifies the contaminants of
concern at the site based on several factors such as toxicity, frequency of occurrence and
concentration. "Exposure Assessment" estimates the magnitude of actual and/or potential
human exposures, and the pathways (e.g., ingestion of contaminated well water) by which
humans are potentially exposed. "Toxicity Assessment" determines the types of adverse
health effects associated with the chemical exposures and the relationship between the
magnitude of exposure (dose) and severity of adverse effects (response). "Risk
Characterization" summarizes and combines outputs of the exposure and toxicity
assessments to provide a quantitative (e.g., one-in-one million excess cancer risk)
assessment of site-related risks.
The baseline risk assessment began with selecting contaminants of concern in the
groundwater which would be representative of Site risks. Volatile Organic Compounds
(VOCs) of concern included: chloroform, tetrahydrofuran, and 1,4-dichlorobenzene. Many
of these chemicals are known or potential human carcinogens based on either human
evidence or data from laboratory animal studies.
The exposure assessment evaluated the health effects which could result from exposure
to contaminants as a result of ingestion of the groundwater or inhalation of VOCs while
showering. The exposure pathways generally consist of four elements: a source and
mechanism of release; a transport medium; an exposure point (point of contact); and an
exposure route (ingestion, etc.) at the exposure point. Exposure scenarios involving
groundwater were quantitatively addressed. The RA concluded that at present,
groundwater at the Janssen Site is not used for drinking water purposes and therefore
current exposures were not assessed. No residents or workers are currently exposed to
compounds of concern in groundwater at the Janssen Site, and the Site presents no
current risks to residents at Gurabo. The potential exists, in the future, for further
commercial or residential development of the Site. Therefore, in the future there is a
potential for individuals to obtain their drinking water from wells installed into the
contaminated aquifer beneath the site. Potentially exposed individuals are future Site
residents who may ingest impacted groundwater and inhale compounds volatilizing from
groundwater during showering. The RA utilized reasonable maximum exposure scenarios
in order to generate conservative estimates which would not underestimate health risks.
Evaluation of Risks
For carcinogens, risks are estimated as the incremental probability of an individual
developing cancer over a lifetime as a result of exposure to the potential carcinogen. The
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risks of the individual chemicals are summed for each pathway to develop a total risk
estimate. The acceptable risk range is one in ten thousand to one in a million excess risk
of an individual developing cancer over a 70 year lifetime from exposure to the
contaminant(s) at the site.
To assess the overall noncarcinogenic effects posed by more than one contaminant, EPA
has developed the Hazard Quotient (HQ) and Hazard Index (HI). The HQ is the ratio of
the chronic daily intake for a contaminant to the Reference Dose for the chemical; the
reference dose being a measure of the chemical's "threshold" for adverse effects with
many built-in safety factors. The HQs are summed for all contaminants within an exposure
pathway (e.g., groundwater ingestion) to give the HI. When the HI exceeds 1, there may
be concern for potential noncarcinogenic health effects, if the contaminants in question
are believed to cause a similar toxic effect.
EPA bases its decision to conduct site remediation (cleanup) on the risk to human health
and the environment. Cleanup actions may be taken when EPA determines that risk at a
site exceeds the cancer risk level of one in ten thousand or if the noncarcinogenic HI
exceeds a level of 1. Once either of these thresholds have been exceeded, remedial
action alternatives are evaluated to reduce the risk levels to within EPA's acceptable risk
range of one in ten thousand to one in a million and an HI of 1.
Toxicity Assessment/Risk Characterization
Future Residents
The results of the baseline risk assessment indicated that the highest carcinogenic risks
were attributable to groundwater ingestion and inhalation while showering for future site
residents. Groundwater was found to pose a carcinogenic risk to human health for the
ingestion and inhalation routes of exposure over a chronic duration. For drinking water
ingestion and showering it is assumed that the individual will obtain their water from the
aquifer at the current concentrations over the next 30 years. The ingestion route showed
total carcinogenic risks for adults and children 1.7 in 1,000. The primary chemical
contributing to this risk is chloroform. For inhalation of volatiles while showering the
carcinogenic risk is 2 in 100. The main chemical contributing to the risk is chloroform.
The carcinogenic risks for the future site residents are greater than the upper-bound of
EPA's target risk range.
Non-carcinogenic hazards were also assessed. For non-carcinogenic effects, the HI for
adults and children for ingestion of contaminated groundwater was 64, exceeding EPA's
acceptable target level of 1. For inhalation while showering the HI was 0.001 which is
within EPA's acceptable target risk range. The main chemicals contributing to the
exceedence is chloroform.
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Conclusions
The baseline risk assessment results indicate that ingestion of groundwater poses an
unacceptable risk for carcinogens and an unacceptable hazard for non-carcinogens for
future site residents. In addition, inhalation of VOCs while showering poses a hazard
through ingestion Actual or threatened releases of hazardous substances from this site,
if not addressed by the preferred alternative or one of the other active measures
considered, may present a current or potential threat to public health, welfare or 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 GROUNDWATER
Alternative 1 - No Action
The NCP requires that the "No Action" alternative be considered at every site to provide
a baseline of comparison among alternatives. The No Action alternative involves the use
of wells W-2 and W-4(H). Wells W-1 and W-3(P) will remain shut-off. Only well W-2 assists
in the reduction of contaminants of concern since it is located near the existing plume.
Well W-4 (H) will continue to provide potable drinking water to Janssen Inc. And J&J
facilities. This well is about 500-feet upgradient of the existing plume. The water extracted
from W-2 will be used for on-site non-potable activities such as cooling tower and
production. The remaining water will be treated at the Janssen Waste Water Treatment
Plant (WWTP).
The costs for the No Action alternative are as follows:
Capital Cost $0
Annual O&M $0
10-year Present Worth $0
30-year Present Worth $0
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Alternative 2 - Deed Restrictions with Monitoring
This alternative involves registering deed restrictions to limit the land use activities over the
impacted aquifer as well as periodic groundwater monitoring to track the movement and
concentrations of VOCs. Groundwater use restrictions would be implemented to prevent
the use of impacted groundwater as a drinking water source. Deed and groundwater
restrictions would be implemented by DNER. Janssen will also be responsible to provide
an adequate source of potable water to owners of wells impacted by the VOC plume. This
may be accomplished by connecting well owners to the PRASA potable water distribution
system, and/or other acceptable source.
Quarterly sampling of forty nine (49) monitoring wells and six production wells will provide
an ongoing assessment of the extent and mobility of the VOC plume. The monitoring wells
are installed in clusters consisting of one, two, or three monitoring wells for a total of 49
wells. Samples will be collected quarterly and analyzed for the volatile fraction of the
Target Compound List plus other contaminants of concern not included in that list.
Contract Laboratory Program protocols will be followed to assure the quality of the data.
The purpose will be to determine the contaminants present and their concentrations.
Quarterly status reports will be filed with the appropriate regulatory agencies.
Partial containment of VOCs and recovery of groundwater will be achieved by the
continued operation of well W-2 as discussed in Alternative 1.
The costs for this alternative include the cost for obtaining deed notations, operation and
maintenance of monitoring wells and costs associated with connecting well owners in the
area to potable water supplies. The costs are summarized below:
The costs for this alternative are as follows:
Capital Cost $1,049,329
Annual O&M $273,830
10-year Present Worth $3,163,771
30-year Present Worth $5,258,767
Alternative 3 - Groundwater Extraction and Treatment with Discharge to Mamey
Creek
This alternative considers the pumping of impacted groundwater from the four recovery
wells (wells JE-1, JE-2R, JE-3 and W-2R) along with wells JE-4 and JE-5 installed during
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1996 and existing well W-1 to the pumping regime. Wells will be pumping at a minimum
combined flow rate of 80 gallons per minute (gpm) up to a maximum of 160 gpm. 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 1,500 meters down gradient
of the Site. Because the water is to be discharged to an existing surface water body, the
discharge shall have to meet federal regulatory MCLs.
Discharging the treated water to Mamey Creek must be carefully considered since this
creek is a tributary of the Gurabo River which is a source of potable drinking water for the
Gurabo-Juncos community. The drinking water is obtained from a filtration plant about 2
kilometers down stream from the Site. In addition, to perform this activity, it is necessary
to obtain an National Pollutant Discharge Elimination System (NPDES) permit and comply
with effluent limitations. The Rl determined that the naturally occurring inorganic
concentrations in the groundwater already exceed the water quality standards. Additional
treatment to remove the inorganic contaminants will be needed in order to comply with the
discharge effluent limitations.
Deed restrictions and well construction controls will restrict the installation of water supply
wells and limit the use of groundwater in the area during the implementation phase for this
alternative. 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 steam stripping unit and periodically collecting wellhead samples.
As in alternative 2, this alternative includes the quarterly sampling of forty-nine (49)
monitoring wells and six production wells to provide assessment of the extent and mobility
of the VOCs. Sampling will be collected on a quarterly basis during the first five years and
then twice a year thereafter. The monitoring wells are installed in clusters consisting of
one, two, or three monitoring wells for a total of 49 wells. Samples will be analyzed for the
volatile fraction of the TCL plus other contaminants of concern not included in that list. CLP
protocols will be followed to assure the quality of the data. The purpose will be to.
determine which contaminants are present and their concentrations. Quarterly status
reports will be submitted to EQB and EPA.
Alternative 3 has the following capital and O&M cost:
Capital Cost $4,220,695
Annual O&M $500,929
10-year Present Worth $8,088,742
30-year Present Worth $11,921,214
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Alternative 4 - Groundwater Extraction and Treatment with Injection to Groundwater
This alternative considers, as Alternative 3, the pumping of impacted groundwater from the
four recovery wells installed as part of the interim remedial alternative (wells JE-1, JE-2R,
JE-3and W-2R) with the addition of wells JE-4 and JE-5 installed during 1996 and existing
well W-1 to the pumping regime. Wells will be pumping at a minimum combined flow rate
of 80 gpm up to a maximum of 160 gpm. The treated effluent will be injected into the
aquifer by means of injection wells.
Because the treated water is to be injected into the ground, some modifications have to be
made to the treatment system described under Alternative 3. The injection quality criteria
for this alternative will be MCLs. Second, the effluent from the steam stripping unit will flow
from the fire protection storage tank into twelve (12) reinjection wells located north of the
Site to reinject the treated water to the aquifer. Each well will have an estimated injection
capacity of 10 gpm. Eight wells will be operating at any time with the other four (4) wells
serving as back-up wells. Reinjection would resupply the aquifer with treated groundwater
causing a hydraulic barrier and reducing further off-site migration of the plume.
Deed restrictions and well construction controls will restrict the installation of water supply
wells and limit the use of groundwater in the area during the implementation phase for this
alternative. 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 steam stripping unit and periodically collecting wellhead samples.
As in alternatives 2 and 3, this alternative considers the quarterly sampling of forty-nine
(49) monitoring wells and six production wells to provide an assessment of the extent and
mobility of the VOCs. Sampling will be collected on a quarterly basis during the first five
years an then twice a year. The monitoring wells are installed in clusters consisting of one,
two, or three monitoring wells for a total of 49 wells. Samples will be analyzed for the
volatile fraction of the TCL plus other contaminants of concern not included in that list. CLP
protocols will bo followed to assure the quality of the data collected. The purpose will be
to determine the present contaminants and their concentrations. Quarterly status reports
will be filed with the appropriate regulatory agencies.
The capital and O&M costs for this alternative are as follows:
Capital Cost $4,497,540
O&M $500,929
10-year Present Worth $8,365,587
30-year Present Worth $12.198,059
The time to implement this alternative is approximately eighteen months.
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Alternative 5 - Groundwater Extraction and Treatment with Internal Use of Treated
Water and Excedent Discharge to Gurabo Pump Station.
Thus alternative is a modification of Alternatives 3 and 4. As in Alternatives 3 and 4,
impacted groundwater will be pumped from the four recovery wells installed as part of the
interim remedial alternative (wells JE-1, JE-2R, JE-3 and W-2R) with the addition of wells
JE-4 and JE-5 installed during 1996 and existing well W-1 to the pumping regime. Wells
will be pumping at a minimum combined flow rate of 80 gpm up to a maximum of 160 gpm.
The difference is that the treated groundwater will be pumped to PRASA's Gurabo Pump
Station which pumps wastewaterto the Caguas Publicly Owned Treatment Works (POTW)
for treatment. The Caguas POTW discharges treated wastewater into the Rio Caguitas
which is a tributary to the Carraizo Reservoir.
Deed restrictions and well construction controls will restrict the installation of water supply
wells and limit the use of groundwater in the area during the implementation phase for this
alternative. 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 steam stripping unit and periodically collecting wellhead samples.
As in alternatives 2, 3 and 4, this alternative considers the quarterly sampling of forty-nine
(49) monitoring wells and six production wells to provide an assessment of the extent and
mobility of the VOCs. Sampling will be collected on a quarterly basis during the first five
years and then twice a year thereafter. The monitoring wells are installed in clusters
consisting of one, two, or three monitoring wells for a total of 49 wells. Samples will be
analyzed for the volatile fraction of the TCL plus other contaminants of concern not
included in that list. CLP protocols will be followed to assure the quality of the data. The
purpose will be to determine the present contaminants and their concentrations: Quarterly
status reports will be submitted to EPA and EQB.
The capital costs and O&M costs of this alternative are as follows:
Capital Cost $4,095,307
Annual O&M $595,969
10-year Present Worth $8,697,228
30-year Present Worth ' $13,256,823
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ALTERNATIVES FOR SOIL REMEDIATION
Alternative 1- No Action
The NCP requires that the No Action Alternative be evaluated at every site to provide a
baseline of comparison with the other alternatives. For this ROD the No Action alternative
considers that no additional actions, other than the initial response actions as described
in the Feasibility Study Report, will be performed for soils and that VOCs in soils in the
unsaturated zone above the water table will leach to groundwater and/or be naturally
degraded in the vadose zone.
The alternative relies upon the fact that contaminants of concern can reach groundwater,
and once in groundwater can be diluted or treated with one of the groundwater
alternatives.. The contaminants of concern trapped in the interstitial space of soils above
groundwater may be degradated to other compounds by natural reactions in a time period
until low concentrations are reached.
The capital and O&M cost for implementing this Alternative will be as follows:
Capital Cost $0
Annual O&M $0
10-year Present Worth $0
30-year Present Worth $0
Alternative 2 - Excavation and Disposal
This alternative involves the excavation and removal of soil containing concentrations of
chloroform and other VOCs.
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) will
have to be shipped to a permitted land burial facility in the continental United States.
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 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.
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The costs of this alternative are as follows: •
Capital Cost $62,036,987
Annual O&M $0
10-year Present Worth $62,036,987
30-year Present Worth $62,036,987
The time to implement this alternative is approximately five years.
Alternative 3 - Soil Vapor Extraction
The 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.
An SVE system was installed in the chemical plant building as part of the initial response
activities. The system consists of nine wells installed above the groundwater table. The
nine wells are connected to a manifold system that extract vapors from the unsaturated soil
zone by means of a blower and send the extracted vapors to a GAC treatment unit.
Treated vapors are emitted to the atmosphere using a stack. The system is operating
since 1993.
The costs associated with this alternative are as follows .-
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Capital Cost $250,538
Annual O&M $99,187
10-year Present Worth $1,016,438
30-year Present Worth $1,775,294
VIII. Summary 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.
i. o Overall Protection of Human Health and the Environment addresses
whether or not a remedy provides adequate protection and describes how
risks posed through each exposure pathways (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.
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
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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 Implementabilityevaluates 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.
GROUNDWATER
1. Overall Protection of Human Health and the Environment
Presently, VOC concentrations in groundwater underlying the Site present an
unacceptable risk to human health for chloroform, tetrahydrofuran, and 1,4-
dichlorobenzene. Groundwater Alternatives 1 and 2 are not protective of human health
and the environment because they do not eliminate, reduce or control the contaminants
at the Site. Since they do not meet this threshold criteria, these alternatives will not be
discussed further.
Alternatives 3 through 5 for the groundwater media would provide overall protection by
reducing the toxicity, mobility, and volume, permanently through the extraction and
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treatment of the impacted groundwater to meet Federal and Commonwealth standards.
The reduction of contaminants of concern (COG) to ARARs levels is expected to occur in
approximately nine years of operation of the system.
2. Compliance with ARARs
The groundwater underlying the Site is a potable water supply source, therefore, MCLs and
non-zero Maximum Contaminant Level Goals (MCLGs) are ARARs. The Puerto Rico
MCLs are relevant and appropriate for the cleanup of the aquifer. Alternatives 3 through
5 will comply with these ARARs.
Discharge of treated water for Alternatives 5 to the Gurabo Pump Station will comply with
the Puerto Rico Pretreatment Standards as per Public Law #9 of 1970, Regulation 4282,
which is applicable,as well as Federal Regulation CWA 402(a) which is an ARAR.
PRDNER regulations call 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. Alternative
3 would provide a beneficial use of the water by discharging treated groundwater to the
Mamey Creek. The Mamey Creek is a tributary of the Gurabo River which eventually
discharges to the Carraizo Reservoir, which is the main water supply for potable uses to
the San Juan Metropolitan Area. Alternative 4 would provide a beneficial use of the water
while recharging the aquifer with treated groundwater. Alternative 5 would provide a
beneficial use of the water by using treated groundwater for non-potable uses at the
Janssen Site. The remainder of the treated water would then be discharged to the Caguas
POTW, then the Rio Caguitas, and eventually the Carraizo Reservoir.
Discharge of treated water to Mamey Creek or by injection to the groundwater under
Alternative 3 or 4 will comply with the requirement of Federal and Commonwealth drinking
water standards.
Groundwater injection under Alternative 4 will comply with the Puerto Rico Underground
Injection Control Regulation and the Federal Underground Injection Control Regulations,
whichever is more stringent.
Discharge of treated water for Alternative 5 to the Gurabo Pump Station will comply with
the Puerto Rico Pretreatment Standards which is applicable as well as the federal
requirement under Section 402(a) of the Clean Water Act (CWA) which is an ARAR.
3. Long-Term Effectiveness
Alternatives 3 through 5 would all be effective in the long-term for controlling plume
migration. The implementation of Alternative 4 would provide the most reliable long-term
effectiveness, since it includes the reinjection of the treated water downgradient of the Site
causing a hydraulic barrier and reducing further off-site migration of the plume.
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4. Reduction of Toxicity, Mobility or Volume Through Treatment
Alternatives 3 through 5 would reduce the toxicity, mobility and volume permanently
through extraction and treatment of impacted groundwater. Alternatives 3,4, and 5 would
provide the best reduction of toxicity, mobility or volume because they can achieve lower
effluent concentration limits of all compounds found in the groundwater. The reinjection
of the treated water (Alternative 4) 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 through 5 are not expected to cause any short-term adverse impacts to the
community during the construction of the treatment systems. However, Alternatives 3 and
5 may be implemented almost immediately while alternative 4 will require longer
implementation schedules. Alternative 3 and 5 would provide for a shorter start-up time
for remediation. The reduction of COCs to ARARs levels is expected to occur in
approximately nine years of operation of the system.
6. Implementability
Deed restrictions for Alternative 2 through 5 would be obtained with the cooperation of
regulatory agencies although they may be 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. Both are demonstrated and common technologies used
to treat groundwater. Alternative 5 will require obtaining an agreement with PRASA for the
discharge to the Gurabo Pump Station. This agreement has already been obtained By
Janssen Inc. An agreement would have to be negotiated with DNER and EQB to
discharge the treated water to Mamey Creek or inject the water into the aquifer. Based on
information collected during the Rl, it has been determined that the naturally occurring
inorganics in the groundwater already exceed the water quality standards for discharge to
Mamey Creek.
7. Cost
Alternative 3 is the least costly with a Capital Cost of $4,220,695, Annual O&M of
$500,929, a 10-year present worth of $8,088,742 and a 30-year present worth of
$11,921,214. Alternative 4 h,as a Capital Cost of $4,497,540, Annual O&M of $500,929,
a 10-year present worth of $8,365,587 and a 30-year present worth $12,198,059.
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Alternative 5 has a Capital Cost of $4,095,307, Annual O&M Cost of $595,969, 10-year
present worth of $8,697,228 and a 30-year present worth of $13,256,823.
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.
SOILS
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. However in Alternative 2 a greater amount of soil will have
to be shipped to the continental U.S. Alternative 3 would also provide overall protection,
although it would take more time to remove contaminants from the soil. :
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) to ensure that the soils
comply with the RCRA Land Disposal Restrictions before the soils could be disposed of
off-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 the compounds have been removed from the soil to
prevent further leaching into the groundwater.
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4. Reduction of Toxicity, Mobility or Volume
Alternative 2 would not achieve a reduction in toxicity, mobility or volume of the
contaminants through treatment but would generate a large volume of soils that would
have to be disposed of in an approved facility in the continental United States. On the
other hand, Alternative 3 would meet this criterion effectively, and uses treatment in doing
so. Alternative 3 also generates small volumes of GAG 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
groundwater 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.
7. Cost
Alternative 2 has a Capital Cost of $62,036,987, no O&M and the 10-year and 30-year
present worth is $62,036,987. Alternative 3 has a Capital Cost of $250,538, Annual O&M
of $99,187, the 10-year present worth of $1,016,438 and a 30-year present worth of
$1,775,293.
8. State Acceptance
The concurrence letter from the EQB is attached to this Record of Decision as
Appendix C.
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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 Rl 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 is selecting Alternative 5 as the final alternative for the
groundwater medium and Alternative 3 for the soils, as the remedial choices for addressing
the contamination problem at the Janssen Site. It should also be noted that these
alternatives have been in operation as part of the Interim Record of Decision signed in
September 30, 1993. Specifically, the remedial alternative for the groundwater will involve
the following:
• Pumping of impacted groundwater from seven extraction wells at a flow rate
of between 80 gallons per minute (GPM) and 160 GPM in order to restore
the aquifer to maximum contaminant levels and to prevent the migration of
the contaminated groundwater;
• Treating the impacted groundwater by steam stripping;
• Implementing a system monitoring program which includes the collection and
analysis of influent and effluent from the steam air stripping unit on a monthly
basis and periodic collection of well-head samples;
• Implementing a monitoring program which includes the collection and
analysis of groundwater monitoring well samples on a quarterly basis during
the first five years and then twice a year thereafter; and
• Using the treated water at Janssen for nonpotable purposes, and
discharging the excess to the Gurabo Pump Station which is part of the
wastewater collection system operated by the Puerto Rico Aqueduct and
Sewer Authority (PRASA).
For the soil remedy, Janssen will continue to operate and maintain the interim Soil Vapor
Extraction (SVE) system as follows:
• Operating the SVE system to remove VOCs from soil until such time as.
VOCs can no longer be effectively removed. Soil vapors will be treated with
granular activated carbon (GAG) before being emitted to the atmosphere.
Emissions will be below the limits established by EQB of 15 pounds per day
or 3 pounds per hour.
25
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• Implementing a system monitoring program which includes the collection and
analysis of soil vapors before and after GAG treatment.
The goal of the groundwater remediation is to return the 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.
EPA believes that remedial Alternative 5 for the groundwater, and Alternative 3 for the soils
provides the best balance among the alternatives according to the evaluation criteria.
Groundwater Alternative 5, 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 groundwater. With
respect to the soils, Alternative 3 will provide the best overall protection because it would
eliminate the presence of VOCs at the Site through in-situ treatment until no residual
impacted soil remains at the Site. It also would be more practical to implement than soil
removal and disposal because the Chemical Plant Building would not have to be
dismantled and another one built. Furthermore, the 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 granted. 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
In order to meet the remedial objectives outlined in the previous section, the risk
associated with exposure to the contaminated groundwater must fall within the acceptable
risk range for carcinogens. Attainment of MCLs and proposed MCLs is also necessary to
ensure that the remedy is protective. The selected 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 5 will provide overall protection by reducing the toxicity,
mobility and volume of contamination, permanently, through treatment of the contaminated
water to meet federal and Commonwealth ARARs.
26
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With respect to the contaminated soils, Alternative 3 will provide the best overall protection
because it will eliminate the presence of VOCs at the Site through in-situ treatment until
no residual impacted soil remains. The operation of the SVE system will prevent further
migration of VOCs to the groundwater and as such will reduce the time to restore the
aquifer.
2. Compliance with Applicable or Relevant Requirements of Environmental Laws
The selected remedy will achieve compliance with chemical specific ARARs related to the
groundwater at the Site within the scope of this 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. Discharge of treated water for Alternative 5 to the Gurabo Pump Station will
comply with the Puerto Rico Pretreatment Standards as per Act No. 9, Regulation 4282,
which is applicable as well as Federal Regulation CWA 402(a) which is an ARAR. There
are no chemical specific cleanup standards for contaminated soils.
At the present time it is expected that air emissions from the steam stripping tower will not
be a problem. Air emissions will be monitored and if necessary, controls will be
implemented. ARARs related to air quality are established by the Puerto Rico Regulation
for the Control of Atmospheric Pollution (PRRCAP), Rule 419 (Volatile Organics
Compounds). The PRRCAP rule establishes emission limits of 3 Ib/hr of total VOCs and
15lbs/day.
3. Cost Effectiveness
EPA believes the selected remedy is cost-effective in mitigating the principal risk posed by
contaminated groundwater and soil beneath the Chemical Plant Building within a
reasonable period of time. Section 300.430(f)(1)(ii) (d) of the NCP requires EPA to
evaluate cost-effectiveness by comparing all the alternatives which meet the threshold
criterion of protection of human health and the environment, against the three additional
balancing criteria of long-term effectiveness and permanence; reduction of toxicity, mobility
or volume through treatment; and short-term effectiveness. The selected remedy meets
these criteria and provides for overall effectiveness in proportion to its cost. The selected
groundwater remedy has an estimated capital cost of $4,095,307, annual O&M of
$595,969, and 30-year present worth of $13,256,823. The selected soil remediation has
a capital cost of $250,538, annual O&M of $99,187 and 30-year present worth of
$1,775,293.
4. Utilization of Permanent Solutions and Alternative Treatment Technologies to the
Maximum Extent Practicable
By treating both the groundwater and the contaminated soils with innovative technologies,
EPA has determined that the selected remedy utilizes permanent solutions and alternative
27
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(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
groundwater.
5. Preference for Treatment as a Principal Element
The selected 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 selected remedy includes the installation and
operation of a groundwater 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
There are no significant changes from the selected alternative presented in the Proposed
Plan.
28
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FIGURES
JANSSEN INC. SITE
GURABO, PUERTO RICO
APPENDIX A
-------
T. 3:-i*-v i-'q;
LEGEND:
(T) ADMINISTRATION BUILDING
d) PHARMACEUTICAL BUILDING
(3) RECEIVING AREA
© TENNIS COURTS
@ PRE-TREATMET WWTP
(D ENVIRONMENTAL BUILDING
@ DRUMS WAREHOUSE
® TANK FARM
® RRE PROTECTION TANK
© MAINTENANCE BUILDING
© CAFETERIA
® CHEMICAL PLANT BUILDING
O CENTRAL GAS SCRUBBER (VARA)
Jj QA/OC BUILDING
l3 GUARD HOUSE
{& PARKING AREA
• EXTRACTION v«eu.
SCALE:
0 SO
FIGURE 1 - FACILITY LAY - OUT
FEASIBILITY STUDY REPORT. JANSSEN INC. SITE
-------
CD
1mB»
FIGURE 2 - SITE LOCATION MAP
FEASIBILITY STUDY REPORT. JANSSEN INC. SITE
GURABO. PUERTO RICO
0*TE:
0?-l«-97^ SC«lf: C.S. | DWG BY: DCC JRCVISCO: OF. FllC: fldURE 1 | JOB NO B9525-97
unaamamu. ecsounct nriotun.
-------
?%*li%***^pf^^
SCALE
I MIL;
1-ldUK'E ;i - SIIL LOCATION MAP
REMEDIAL INVESTIGATION REPORT. JANSSEN INC
GURADO. (PUERTO RICO
REVISED: OF. TILE: flCURE 2.1 I JOB NO 395->S
-------
<£>
REF (6)
MATCH LINE
REF (7)
MATCH LINE
SCALE
o
xso VXD 'oca
LEGEND :
Oa * Qal
ALLUVIUM
Oat = Oft = ALLUVIAL TERRACE
DEPOSITS
Kn = Qv = LOS NEGROS FORMATION.
VOLCANIC ROCKS
(inornri. 1001 AJIO SFIOERS. i9?i
FIGURE 4 - SURFICIAL GELOGICAL MAP
REMEDIAL INVESTIGATION REPORT. JANSSEN INC. SITE
GURABO. PUERTO RICO
OAlC 0)/>/9» | SCMt: CS | QwC Bt. 01" [«C»lStO Of. | f«t. flCUK{ ;.< [ JOB MO 395:s-9c
-------
SAN JUAN
MAYAJX'EZ
PONCE
MAP AREA
SAN JUAN
AUANT1C OCEAN
• ESPSrtU SANTO
BAYAMON RIVa BASIN
ANTON KVcB BASW
UK PLATA RNB»
BASIN
HUMACAO RVER EASN
GRANCS CE PATIOAS
FOVEH BASIN :'
LEGEND :
SCALES :
GUAYANSS BVE» BASM
01 23*367 KILOMCTEHS
012345 MILES
GRANDE C€ L3CA SJVE3
' UNIT BOUNi«r
.GLR*30 «V;3 UMT
8C-JNOAHY
FIGURE 5 - GU3SABO RIVER BASIN
REMEDIAL INVESTIGATION REPORT
JAXSSEN INC. SITE
GURA50, PUERTO RICO
SCA|_£; N.S.
OWG. BY: OLH j 3£V. :.?. I ."'.£:
E 2.5 JC3. NO.: J3...-96
-------
i rcn io :
I I MOSTLY ci AY
|,';";!( MO'JII.Y CUAVtl.
|~_~| 'JANU AMD SILT
L'^1 V/CATIIERCD ROCK
DEDROCK
N
APPROXIMATE LOCATION
OF JANSSEN SITE
500
1000
1500
200C
2500
3000
DISTANCE. IN FEIET. VERTICAL EXAGGERATION X 5
SCAI US :
HORIZONTAL
0 JSO 500 II.
VERTICAL
0 50 100 II
-••*— V/AICR TADLE r~^iBi* n (
flCIIRr <", - GCNIiRAL IIYDROGHOI.OGICAL CROSS
K-I:MI:DIAI. IMVIISTIGATION REPORT. JANSSEN INC.
CURABO. PUERTO RICO
IIAII : i»/:,/'ji, j ;;r;Air: o
C. I)V/0. II Y: Otll
RCV.: O.r. JFIIE: HCimE 2.G
SECTION
SITE
1 JOIJ NO.: 00525-00'
^fr^~^
,^^ylrp^\
( .---.- ^^^j^^) • f
v^^tj^l^ 1 V J j
-------
PRIMARY USE WCLLS :
DOMESTIC • STOCK
H-G.AUL-1. u °
0 1/2 1 inilo
°< / \ IRRIGATION 0 UNUSED
o / \ * "'IOUSrRIAL ° UHKHOWIJ
13 ^ « PUBLIC SUPPLY
FIGURE ? - WELLS INVENTORY
REMEDIAL INVESTIGATION REPORT, JANSSEN INC. SITE
GURAQO. PUERTO RICO
liAll: Vi/d?/'jr, SCAIG: OS. OY/C. IVf: OLII
REV.: OX. riLE: riCUHE 1.3 JOO MO.: 09525-00
^^T(^
n^ozalau^i^ 1 V f \
•^tiaaaaar SOU. TECM /
-------
PLUME RANGE tcatd
E3 OVER KX3.000
0 10.001 - 100.000
(HI toi - n.ooo
: Ji 5-100
FIGURE. 8 - CHLOROFORM PLUME CONFIGURATION OF JANUARY. 1994
REMEDIAL INVESTIGATION REPORT. JANSSoN INC. SiT£
PUERTO RICO
-------
LEOFND:
>. SHALLOW UONITORING WELL
PLUME RANCr footil
0 SO 100 UE1ER
eza OVER - lo.ooo
on 1.001 - lo.ooo
si too - i.ooo
FIGURE 9 - CHLOROFORM PLUME CONFIGURATION AUCUST.I99* SHALLOW MONITORING WELLS
REMEDIAL INVESTIGATION REPORT, JANSSEN INC. SITE
GURABO. PUERTO RICO
| HEV.: af
-------
PLUME
SC-*LE;
0 JO 100 U£TER
G3 OVER . 10. COO
am i.ooi - 10.000
ca too - t.:co
riCURE 10- CHLOROFORM PLUME CONFIGURATION AUCUSr.1994 IN7cRuEOurE UO-NITORlNC WELLS
- REMEDIAL INVESTIGATION REPORT. JANSSEN INC. SITE
GURA80. PUERTO RICO
oi/t/x ;CAU: es.
I DWC. OT: cut j -HEV.: of| F«*: neum • >• ! X« SO.: n>:}-
-------
LECEND:
- OEEP
SCALE:
0 SO 100 METER
PLUME RANf.F loob)
rnf OVER - 10.000
am i.ooi - la.ooo
aa 100 - LOCO
FIGURE I]. - CHLOROFORM PLUME CONFIGURATION AUCUST.1994 DEEP MONITCRINC '.VELLS
REMEDIAL INVESTIGATION REPORT. JANSSEN INC. SITE
G'JRABO, PUERTO RICO
I o«c. 8r:
X8 HO.:
-------
—O
r 12 -- LOCATION OF SOU. BORINGS INSIDF. CHEMICAL PLANT BLDG
m:MEDIAL INVESTIGATION REPORT, JANSSEN INC. SITE
GURADO. PUERTO RICO
PAID OVS/OC [ SCALE: OS. DWO. OY: M.II REV.: O.F. FIlE: TOURC 32 JOB NO.: 89525-96
SOIL TECH
-------
LEGEND;.
•/. II'. Vl/HV/'rt. I'iCAII':
nv/c. nv: n\\ ncv.: or.
FIIT: Fir.iillC 3.3 JOO HO.: 09525-06
SQIL TFCH
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TABLES
JANSSEN INC. SITE
GURABO, PUERTO RICO
APPENDIX B
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TABLE 1
WELLS INCLUDED IN INITIAL GROUND WATER SAMPLING
REMEDIAL INVESTIGATION REPORT
JANSSEN SITE
GURABO, PUERTO RICO
WELL ID
W-1
W-2
. W-2R
W-3P
W-4H
W-58
W-61
JE-1
JE-2
JE-3
EW-1
JW-4
JW-4A
JW-5
JW-5A
JW-6
JW-7
JW-7A
JW-8
JW-6A
JW-8B
JW-9
JW-9A
JW-10
JW-10A
JW-11
JW-12
JW-13
JW-14
CASU-IN
CASU-OUT
Legend:
W
.JE
EW-1
JW-£
JW-SA, B
CASU-IN
CASU-OUT
= Production Wells
= Extraction Weils (for ground water treatment)
= Early Warning Well
= Shallow Monitoring Well
= Deep Monitoring Well
= Conventional Air Stripping Unit Influent
= Conventional Air Stripping Unit Effluent
441096W.wpf
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TABLE 2
WELLS INCLUDED IN SECOND GROUND WATER SAMPLING
REMEDIAL INVESTIGATION REPORT
JANSSEN SITE
GURABO, PUERTO RICO
WELL ID
W-1
W-2
W-2R
W-3P
W-4H
W-58
W-61
JE-1
JE-2
JE-3
EW-1
JW-4
JW-4A
JW-S
JW-5A
JW-6
JW-6R
JW-7
JW-7A
JW-8
JW-8A
JW-8B
JW-9
. JW-9A
JW-10
JW-10A
JW-1 1
JW-1 2
JW-1 3
JW-1 4
JW-1 5
JW-1 51
JW-15R
JW-1 6
JW-1 61
JW-16R
JW-1 7
JW-171
JW-17R
. JW-1 8
JW-1 81
JW-18R
JW-1 9
JW-191
JW-19R
JW-20
JW-201
JW-21
JW-211
JW-21 R
JW-22
CASU-IN
CASU-OUT
Weil Legend:
W
JE
EW-1
JW-*
-Production Wells
= Extraction Wells (for ground water treatment)
= Early Warning Well
- Shallow Monitoring Well
= Intermediate Monitoring Well
JW-# A, B. R = Deep Monitoring Well
CASU-IN = Conventional Air Stripping Unit Influent
CASU-OUT = Conventional Air Stripping Unit Effluent
44109SX.wpf
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COMMONWEALTH OF PUERTO RICO
LETTER OF CONCURRENCE
JANSSEN INC. SITE
GURABO, PUERTO RICO
APPENDIX C
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PREQB-EMERG.RESP.OFF. 10:809-766-0150 SEP 29'97 15:06 No.008
COMMONWEALTH OF PUERTO KICO / OKKJCE OF THE GOVERNOR
ENVIRONMENTAL QUALITY BOARD
SUPERF1JNP PROGRAM
September 29, 1997
Hng. Adalbcrlo Basque
Remedial Project Manager
U.S. Unvironmental Prelection Agency
Region II, Caribbean Field Office
Suite 417, Ccntro Eurbpa
1492 Ponce de Lc6n Avc.
Santurce> Puerto Rico 00909
- /
Rli: DECLARATION FOR T11E RECORD OF DECISION
Janssen Site, Gurabo.PR
Dear Mr. Bosque:
The Puerto Rico Environmental Quality Board (PRRQB) received a copy of the Declaration for tho
Record of Decision for Junssen site on September 23,1997.
After reviewing the document, the PKliQB rcamimends Alternative 5 for the groundwater
(Groundwater )Jxtraciion and 'Ireatment with Internal Use of Treated Water and Discharge of lixccss
to Ourabo Pump Sudon) and Alternative 3 for the soil (Soil Vapor liXTraciion) as remedial
alternatives for the Janssen Site, Gurabo, P.R. The PREQB, therefbrc, agrees witli the United States
linvironmental ?rotectjoii Agency's preferred aliematrves.
Jf there are any questions regarding this matter, please contact Eny. Miguel A. RuDun, RPM for tile
site at 767-8181. extension 2237 or Mr. Miguel A. Maldonado, RPM and CORE Diviaiora Chief,
at extensions 2230 or 2229.
Cordially,
Hector Russe Martlnex
\Chairman
MRIi/lnj
Gtttnfonta* and ajaatttnn wMtn, den ilr Mtf fJtor tUn.
Yimpntnt H/e ifjn to not UKdutiKOIel
NAIIONALDANK fl^XAS431 PONCXMLLONAVR. SHATOKKY, rilKKTORKO00917
TOTftL P.02
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RESPONSIVENESS SUMMARY
JANSSEN INC. SITE
GURABO, PUERTO RICO
APPENDIX D
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RESPONSIVENESS SUMMARY
FOR THE
PROPOSED PLAN
. AT THE
JANSSEN INC. SITE, GURABO, PUERTO RICO
TABLE OF CONTENTS
SECTION PAGE
Introduction i 1
I. Background on Community Involvement and Concerns 2
II. Comprehensive Summary of Major Questions, Comments,
Concerns, and Responses : 3
A. Summary of Oral Questions and Responses from the
Public Meeting Concerning the Janssen Inc.
Site
B. Summary of Written Questions and Responses Received
During the Public Comment Period
ATTACHMENT
Community Relations Activities at the Janssen Inc. Site
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RESPONSIVENESS SUMMARY
JANSSEN INC. SUPERFOND SITE
GURABO, PUERTO RICO
INTRODUCTION
This Responsive Summary documents the public's comments and
concerns and the U.S. Environmental Protection Agency's (EPA's)
responses to those comments regarding the Proposed Plan (PP) for
the Janssen, Inc. Superfund Site ("Site") in Gurabo, Puerto Rico.
EPA's preferred remedial alternative addresses both contaminated
groundwater and soil at the Site. First, the remedy will continue
to address the potential spread of contaminated groundwater and
will include treatment of contaminated groundwater. Second, the
remedy will continue the treatment of the impacted soils beneath
the Chemical Plant building.
EPA. held a public comment period from August 28, 1997 through
September 27, 1997 to provide interested parties with the
opportunity to comment on the PP for the Site.
On September 10, 1997, EPA presented its preferred alternative for
the Site to the community. . EPA held a public meeting for the
general public at 7:00 p.m. in the Municipal Assembly Room of the
Gurabo Town Hall, Gurabo, Puerto Rico. Approximately 20 people
attended the meeting.
EPA conducted the meeting in Spanish because Spanish is spoken by
the majority of the local residents. EPA made English and Spanish
versions of the PP available prior to the public meeting. A Site
information repository was located at the Gurabo Municipal 'Library
on Andres Arus Street, Gurabo, Puerto Rico. The Puerto Rico
Environmental Quality Board (PREQB)and EPA's Caribbean
Environmental Protection Division Office at 1492 Ponce De Leon
Avenue in San Juan, also has copies of the PP available for review.
Based on the comments received during the public comment period,
EPA believes that the residents and town officials of Gurabo and
the Puerto Rico Environmental Quality Board (EQB) are in agreement
with the PP and support EPA's preferred alternative. At the public
meeting, citizens and officials raised no objections to the PP or
to EPA's preferred alternative.
This Responsiveness Summary is divided into the following sections:
I. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS: This section
provides the history of community concerns and describes community
involvement in the process of selecting a remedy for the Site.
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II. COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS, COMMENTS, CONCERNS,
AND RESPONSES: This section summarizes the written comments EPA
received during the public comment period and oral comments
received at the public meeting and EPA's responses to them.
In addition to Sections I and II, a list of EPA community relations
activities conducted at the Site is included as an attachment to
this Responsiveness Summary. Finally, a Spanish transcript of the
proceedings of the public meeting is available in the information
repository.
I. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
The Municipality of Gurabo is a large town with approximately
30,000 residents. Gurabo is governed by a Mayor and Municipal
Assembly, all of whom are elected by the community to serve four-
year terms.
Due to the Site's location in a non-residential area, there has
been limited local community interest in the Site. However, the
Site is situated immediately adjacent to Route P.R. 30 and Road 189
and activities at the Site are visible from these roads.
In April 1989, two on-site wells were sampled by Janssen and their
analyses indicated chloroform levels above drinking water
standards. These two wells, used for production and drinking water
for Janssen employees, were immediately restricted to production
use only.
Although there has been no public supply well affected by the
contaminants of concern, EPA files show that residents have
expressed concern over the following issues:
• Impact of Treated Water Discharge to the Creek: Residents and
local officials have expressed concern regarding the impact of
contamination to Mamey Creek.
• Aquifer Contamination: Local residents have expressed their
concern about the impact of groundwater contamination to a nearby
PRASA well.
II. COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS. COMMENTS. CONCERNS.
AND RESPONSES
Public comments on the PP submitted between August 28, 1997 and
September 27, 1997 are summarized and addressed below. EPA has
separated oral comments from written comments. EPA has categorized
the comments by topic and has consolidated similar comments on a
single topic. Individual commentors and their questions are
identified in the meeting transcript on file in the information
repository.
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A. SUMMARY OF ORAL QUESTIONS AND RESPONSES FROM THE PUBLIC
MEETING CONCERNING THE JANSSEN INC. SITE
Possible Impact to Mamey Creek
Comment: A citizen expressed his concern over the impact of Janssen
contamination on Mamey Creek.
EPA Response: Samples collected at the Creek indicate no
contamination in the Creek. Furthermore, the direction of
groundwater flow in that area is to the north, away from the Creek.
Impact of contamination to nearby PRASA wells
Comment: A citizen expressed his concern about the impact of
contamination on the Mamey Well owned by the Puerto Rico Aquaduct
and Sewer Authority (PRASA).
EPA Response: Janssen Inc. has reached an agreement with PRASA to
conduct sampling and analysis of PRASA wells located near the Site.
Groundwater samples collected by Janssen twice a year include the
Mamey well owned and operated by PRASA. Such agreement is
stipulated in the wastewater discharge permit GDA-97-606-090.
Sampling results have not detected any Volatile Organic Compounds
(VOCs) in the Mamey well nor other wells owned and operated by
PRASA.
Comment: A citizen expressed his concern between the relationship
of the early actions to remove the VOCs and the long term remedial
action.
EPA Response: Remedial actions implemented as per the Interim ROD
as well as the one presented in EPA's 1997 Proposed Plan address
the contamination in an expedited fashion. The Interim ROD
addressed expedited groundwater pumping to prevent the further
migration of contaminated groundwater. The current ROD includes
this groundwater remedy and is expected to return the aquifer to
its beneficial use.
B. Summary of Written Questions and Responses Received During the
Public Comment Period
EPA received written comments from the Puerto Rico Aqueduct and
•Sewer Authority (PRASA)
Comment: PRASA expressed a concern over the lack of knowledge on
the ammount of water and the concentration of contaminants in the
treated water to be discharged to the Caguas Treatment Plant.
PRASA would like EPA to include a wastewater characterization in
order to evaluate the parameters that might affect the processes at
the Treatment Plant.
-------
EPA.response : PRASA has granted Janssen a permit renewal which
copy has been provided to EPA. The permit is dated March 20, 1997
and allowed Janssen to discharge their wastewater including those
from the steam air stripper to the Caguas Treatment Plant.
Information pertaining to the ammount of water to be discharged as
well as the sampling parameters are included in the permit granted
by PRASA to Janssen.
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ATTACHMENT.1
COMMUNITY RELATIONS ACTIVITIES
AT JANSSEN INC. SUPERFUND SITE
Community relations activities conducted at the Janssen Inc.
Superfund Site to date have included the activities conducted in
1993 for the Interim ROD as well as the" activities currently taken
for this Final ROD. They include the following:
For the Interim ROD:
• EPA established an information repository at the Gurabo
Municipal Library on Andres Arus Rivera Street. Copies of the
documents in the repository were also placed in files in EPA's
offices in San Juan, and New York as well as at the
Environmental Quality Board Office (1993).
• EPA released the Summary Investigation Report and Focused
Feasibility Study report to allow the public an opportunity
for comment. These -reports are part of the information
repository (June 1993).
• EPA made Spanish translations of the PP available for public
review and comment. The PP is part of the information
repository (June 1993) .
• EPA publicized and held a public meeting at the Gurabo Town
Hall to describe the reports and PP and to respond to citizen
concerns. A Spanish transcript of the proceedings of this
meeting is available in the Site information repository (June
and August 1993).
• EPA held a public comment period on the PP. The public
comment period lasted 60 days, from June 8, 1993 to August. 9,
1993.
• EPA prepared a Responsiveness Summary to document its
responses to all of the public comments received in writing
and at the public meeting (September 1993) . ;
For the Final ROD;
• EPA established an information repository at the Gurabo
Municipal Library on Andres Arus Rivera Street. Copies of the
documents in the repository were also placed in files in EPA's
offices in San Juan, and New York as well as at the
Environmental Quality Board Office (1997).
• EPA released the Remedial Investigation (RI) and Feasibility
Study (FS) reports to allow the public an opportunity for
comment. These reports are part of the information repository
(August 1997) .
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EPA made Spanish translations of the PP available for public
review and comment. The PP is part of the information
repository (August 1997).
EPA, publicized and held a public meeting at the Gurabo Town
Hall to describe the report and PP and to respond to citizen
poncerns. A Spanish transcript of the proceedings of this
meeting is available in the Site information repository
(August and September 1997).
EPA held a public comment period on the PP. The public
comment period lasted 30 days, from August 27, 1997 to
September 27, 1997).
EPA prepared a Responsiveness Summary to document its
responses to all of the public comments received in writing
and at the public meeting (September 1997) .
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ADMINISTRATIVE RECORD INDEX
JANSSEN INC. SITE
GURABO, PUERTO RICO
APPENDIX E
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9/30/97
JANSSEN SITE
ADMINISTRATIVE RECORD FILE
INDEX OF DOCUMENTS
1.0 SITE IDENTIFICATION
1.3 Preliminary Assessment Report
Report: Preliminary Assessment/ Janssen, Inc.,
Gurabo, Puerto Rico, prepared by Environmental
Quality Board, Superfund PA/SI Program, September
30, 1989. (Note: This document is in the first
Janssen Site Administrative Record, p. 100001-
100203.)
1.4 Site Investigation Reports
Report: Summary Investigation Report, Janssen
Site, Gurabo, Puerto Rico, prepared by Soil Tech
Corporation, May 1991. (Note: This document is in
the first Janssen Site Administrative Record, p.
100204-100946.)
1.6 Correspondence
P. 100001- Letter to Mr. Santos Rohena, Chairman,
100002 Environmental Quality Board, from Mr. Hector
Totti, VP & General Manager, Janssen, Puerto Rico,
re: confirmation of the actions already discussed
in person that Janssen Pharmaceutical in Gurabo
has taken following detection of chloroform in two
on-site wells used for drinking and process water,
October 3, 1989.
JANSS2.FIN
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3.0 REMEDIAL INVESTIGATION
3.3 Work Plans
Report: Final Remedial Investigation/Feasibility
Study Work Plan for OMB Site, Gurabo, Puerto Rico,
prepared by Soil Tech Corporation, for OMB
Pharmaceutical Partners as Successor to Janssen,
Inc., December 21, 1992. (Note: This document is
in the first Janssen Administrative Record, p.
300001-300724.)
Report: Final Additional Response Work Plan, OMB
Site, Puerto Rico, prepared by Soil Tech
Corporation, for OMB Pharmaceutical Partners as
Successor to Janssen Inc., December 11, 1992.
(Note: This document is in the first Janssen Site
Administrative Record, p. 300725-301300.)
3.4 Remedial Investigation Reports
P. 300001- Report: Final Remedial Investigation Report,
300459 Volume I, Text, Janssen Site, Gurabo, Puerto Rico,
prepared by Soil Tech Corporation, prepared for
Johnson & Johnson Pharmaceutical Partners, May 9,
1996.
P. 300460- Report: Final Remedial Investigation Report,
301230 Volume II, Appendices A to L, Janssen Site,
Gurabo, Puerto Rico, prepared by Soil Tech
- Corporation, prepared for Johnson & Johnson
Pharmaceutical Partners, May 9, 1996.
P. 301231- Report: Baseline Risk Assessment, Janssen Site,
301275 Gurabo, Puerto Rico, prepared by ERTEC
(Environmental Resource Technologies), prepared
for U.S. EPA, Region II, August 8, 1995. .-
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4.0 FEASIBILITY STUDY
4.3 Feasibility Study Reports
P. 400001- Report: Final Feasibility Study Report, Janssen
400485 Site, Gurabo, Puerto Rico, prepared by ERTEC
(Environmental Resource Technologies), prepared
for Johnson & Johnson Pharmaceutical 'Partners,
April 15, 1997.
Report: Focused Feasibility Study, Janssen, Inc.
Site, Gurabo, Puerto Rico, prepared by Soil Tech
Corporation, prepared for OMB Pharmaceutical
Partners, May 17, 1993. (Note: This document is
in the first Janssen Site Administrative Record p,
400001-400095.)
P. 400486- Report: Janssen Site, Gurabo, Puerto Rico,
400519 Identification of Candidate Technologies
Memorandum, prepared by Soil Tech Corporation,
prepared for Janssen, Inc., July 31, 1991.
7.0 ENFORCEMENT
7.3 Administrative Orders
P. 700001-
700001
Letter to Mr. Jose Agrelot, Soil Tech, from Mr.
Juan Merced Mateo, P.E., .Environmental & Safety
Manager, Janssen Inc., Puerto Rico, re: enclosed
final EPA Order signed by Hector Totti (March 15,
1991), March 22, 1991. (Attachment: Administrative
Order on Consent for Remedial Investigation/
Feasibility Study, in the matter of The Janssen,
Inc. Site, Gurabo, Puerto Rico, Janssen Inc.,
Respondent, Index No. II CERCLA-10301, March 15,
1991.) (Note: This Administrative Order on
Consent is in the first Janssen Site
Administrative Record p. 700001-7000031.)
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10.0 PUBLIC PARTICIPATION
10.3 Public Notices
P. 10.00000- Public Notice: "The U.S. Environmental Protection
10.00000 Agency (EPA) Invites Public Comment on the
Proposed Plan for Janssen Inc., Site, Gurabo,
Puerto Rico," prepared by U.S. EPA, Region II,
September 27, 1997.
Public Notice: "La Agencia Federal de Proteccion
Ambiental (EPA) Invita a Comentario Publico Sobre
el Plan Propuesto Para la Limpieza del Area
Conocida en Ingles como "Janssen Inc. Site",
Gurabo, Puerto Rico, prepared by U.S. EPA, Region
II, September 27, 1997. (Note this document is
written in Spanish.)
Public Notice: "The U.S. Environmental Protection
Agency (EPA) Invites Public Comment on the
Proposed Remedial Action Plan for Janssen
Superfund Site, Gurabo, Puerto Rico," prepared by
U.S. EPA, Region II, June 8, 1993. (Note: This
document is in the first Janssen Site
Administrative Record p. 1000001-1000001.)
Public Notice: "La Agencia Federal de Proteccion
Ambiental (EPA) Invita a Comentario Publico sobre
el Propuesto Plan de Accion Remdiativa para la
Limpieza del Area Conocida en Ingles como ' '^ Janssen
Inc. Site,' Gurabo, Puerto Rico," prepared by U.S.
EPA, Region II, June 8, 1993. (Note this document
is written in Spanish.) (Note: This document, is '
in the first Janssen Site Administrative Record p.
1000002-1000002.)
10.9 Proposed Plan
P. 10.00001- Report: Superfund Proposed Plan, Janssen, Inc.
10.00022 Site, Gurabo, Puerto Rico, prepared by U.S. EPA,
Region II, August 28, 1997.
P. 10.00023- Report: Plan Propuesto del Superfundo, Sitio de
10.00044 Janssen, Inc., Gurabo, Puerto Rico/ prepared by
U.S. EPA, Region II, August 28, 1997. (Note: This
document is written in Spanish.)
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10.00045- Letter to Mr. Adalberto Bosque, Remedial Project
10.00045 Manager, U.S. EPA, Region. II, Caribbean Field
Office, from Mr. Hector Russe Martinez, Chairman,
Commonwealth of Puerto Rico/Office of the
' Governor, Environmental Quality Board, Superfund
Program, re: Superfund Proposed Plan, Janssen
Site, Gurabo, Puerto Rico, May 15, 1997.
Report: Superfund Proposed Plan, Janssen, Inc.,
Gurabo, Puerto Rico, prepared by U.S. EPA, Region
II, June 8, 1993. (Note: This document is in the
first Janssen Site Administrative Record p.
1000003-1000018.)
Report: Plan Propuesto del Superfundo, Janssen,
Inc., Gurabo, Puerto Rico, prepared by U.S. EPA,
Region II, June 8, 1993. (Note: This document is
written in Spanish.) (Note: This document is in
the first Janssen Site Administrative Record p.
1000019-1000038.)
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RECORD OF DECISION FACT SHEET
EPA REGION II
Site;
Site name: Janssen Site
Site location: Gurabo, Puerto Rico
MRS score: not scored
EPA ID Number: PRD980536049
Record of Decision;
Date signed: 9/30/97
Operable Unit: OU-1
Selected remedy: Soil Vapor extraction and Steam Air Stripper.
Estimated Construction Completion:
Capital cost: (in 1997 dollars) $4.2M
Annual 0 & M cost: $0.6M
Present-worth cost: $14.9M (5% discount rate for 30 years)
Lead;
U.S. Environmental Protection Agency Enforcement
Primary Contact: Adalbert© Bosque, (787) 729-6951 ext.. 236
Secondary Contact: Melvin Hauptman, (212) 637-3952
Main PRPs: Juan Merced , Johnson and Johnson Pharmaceutical
Partners, (787) 272-7425
Waste;
Waste type: Volatile Organics
Waste origin: Wastes generated during plant operation
Estimated waste quantity: not known
Contaminated medium: soil, groundwater
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