PB94-963804
                                 EPA/ROD/R02-94/227
                                 July 1994
EPA  Superfund
       Record of Decision:
       Jumcos Landfill Site,
       Juncos, PR

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                          ROD FACT  SHEET
SITE
Name           :
Location/State :
EPA Region     :
HRS Score (date):
Juncos Landfill
Juncos, Puerto Rico
II
32.57  (8-2-82)
ROD
Date Signed:
Remedy/ies:

Operating Unit Number:
Capital cost:
Construction Time:
0 & M:
Present worth:
10-5-93
Natural Attenuation/ No Action/
Institutional Controls/ Monitoring
OU-2
$51,624
1 month
$42,250/yr
$603,112
LEAD
Remdial/Enforcement:
EPA/State/PRP:
Primary contact  (phone):
Secondary contact  (phone)
Main PRP(s):
PRP Contact  (phone)
Enforcement
EPA
Jose C. Font (809) 729-6951
Melvin Hauptman (212) 264-7681
Becton Dickinson,  Browning Ferris
Industries, General Electric Co.,
Chesebrough Ponds, Municipality of
Juncos,the Puerto Rico Land
Administration and the Puerto Rico
Development and Housing Improvement
Administration
Luis R. Lomba, P.E.  (809) 746-1735
WASTE
Type:
Medium:
Origin:
Est. quantity:
Metals, Chloroform
Groundwater
Landfill
Unknown

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                   UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                   REGION II           ---•        n   i

  DATE,  0 1 OCT  198          .                                   ^"

SUBJECT: Record of Decision  (ROD) for the Juncos Landfill Site

  FROM: George Pavlou, Acting Director
      Emergency and Remedial Response Division

   T°: William J. Muszynski, P.E.
      Acting Regional Administrator

     Attached for your approval is the ROD for the Juncos Landfill Site,
     located in the Municipality of Juncos, Puerto Rico.   This operable
     unit is the second of two operable  units  for the Site and focuses
     on  groundwater  contamination.   The  first  operable unit ROD, which
     selected capping of the landfill, was signed on September 24, 1991.
     Currently, the  first operable unit  remedy is in the design phase.

     The selected  remedial action  for the  second operable unit is no
     action/natural  attenuation for the groundwater,  a  recommendation
     that the  Commonwealth  of  Puerto  Rico  implement  institutional
     controls  restricting groundwater withdrawal in  the area  north of
     the landfill, and groundwater monitoring to ensure that contaminant
     levels  are decreasing.  If the  concentrations  of contaminants in
     the groundwater do not decrease over time, EPA may reevaluate this
     decision  to see if active groundwater  remediation is necessary.

     The remedial  investigation  and  feasibility  study  report  and  the
     Proposed  Plan were released for public comment on August 9, 1993.
     A public comment period on these documents were held from August 9,
     1993 through  September 7,  1993.   In addition,  a public meeting to
     discuss these documents and the preferred  no action  remedy was held
     on  August 25, 1993.   Comments received during  the  public comment
     period  indicated that the nearby residents are concerned about the
     impact  of the landfill on their health.

     The ROD  has  been  reviewed by  the Commonwealth of Puerto  Rico
     Environmental Quality  Board  (EQB), and  the appropriate  program
     offices within  Region II.   Their input and comments are reflected
     in  this document.   EQB has concurred  with the  selected no action
     remedy  for  the second operable  unit of  the  Juncos Site   (see
     Appendix  D of this document).

     If  you  have any questions or comments, I would be happy to discuss
     them with you at your convenience.

     Attachments

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              Declaration for the Decision Document
SITE NAME AND LOCATION

Juncos Landfill Site
Municipality of Juncos
Juncos, Puerto Rico
STATEMENT OF BASIS AND PURPOSE

This decision document presents  the selected remedial action for
Operable Unit Two (OU-II)  of the Juncos  Landfill  located in the
Municipality of Juncos, Puerto Rico, which was chosen in accordance
with the requirements of  the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA) ,  as amended by the
Superfund Amendments  and Reauthorization  Act of  1986 (SARA), and
the National  Oil and Hazardous  Substances  Pollution Contingency
Plan (NCP).  This decision  document  explains  the  factual and legal
basis for selecting the  remedy for this site.

The Commonwealth  of Puerto Rico Environmental Quality Board  (EQB)
concurs with the selected remedy.  A letter of concurrence  from EQB
is appended to this document (Appendix C).

The information supporting  this remedial action is contained in the
Administrative   Record   for  this  site.     The  index  to  the
Administrative Record is attached as Appendix E.
DESCRIPTION OF THE SELECTED REMEDY

This  operable unit is the  second of two operable  units for the
Juncos  Landfill  Site.   It  focuses  on groundwater contamination,
resulting from contaminant migration from the landfill.

The source control action selected under the Operable Unit One (OU-
I) remedy will cap the landfill and  reduce the potential  threat to
human  health  and the  environment by isolating  the  landfill and
reducing the  risk of contaminant  migration from the  landfill into
the groundwater.

The key components of  the OU-II remedy include the following:

      •    Natural attenuation/no  action for the groundwater.

      •    Recommendation that institutional controls  consisting of
          restrictions on groundwater withdrawal in the area north
          of  the landfill be implemented by the Commonwealth.

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     •    Groundwater monitoring to ensure that the concentrations
          of contaminants  in  the  groundwater  are decreasing over
          time.  It is estimated that approximately 16 wells will
          be sampled,  although the exact number and duration of the
          sampling will  be determined at a  later date.   If the
          concentrations of contaminants in the groundwater do not
          decrease over time, EPA may reevaluate this decision to
          see if active groundwater remediation is necessary.

The implementation of this selected remedy in conjunction with the
OU-I remedy will minimize or eliminate the potential carcinogenic
and noncarcinogenic  impacts  caused by ingestion of  groundwater
containing chloroform, carbon disulfide,  antimony,  manganese and
vanadium should it be used in the future.
DECLARATION OF STATUTORY DETERMINATIONS

The  selected  remedy  is  protective  of  human  health  and  the
environment and complies with federal and Commonwealth requirements
that are  legally applicable or  relevant  and appropriate  to the
remedial action, and is cost effective.  This is achieved through
the use  of a  single-barrier cap under OU-I  in  conjunction with
institutional  controls to preclude direct contact  and  access to
groundwater.  The surface controls  (implemented with capping) and
cap also  reduce leachate generation and  subsequent  groundwater
impacts.  The institutional controls will serve to restrict access
to the groundwater by residents in a potential future use scenario.
Current residents obtain  their drinking water from the municipal
public supply wells and surface water filtration plants.  Natural
attenuation will serve to  reduce the concentration of chloroform in
the groundwater  over time through  various physical and chemical
processes.

The components of the selected remedy in conjunction with the OU-I
remedy represent the maximum extent to which a permanent solution
and treatment technology  can be utilized in a  cost effective manner
for the site.

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A review  of  the remedial  action  pursuant to CERCLA  §121(c),  42
U.S.C.  §9621(c),  will  be  conducted within  five  years of  the
commencement of the remedial action and every five years thereafter
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.
    WilliamXHJ. MusztfrfsKi, P.E.                             Date
    Acting^Regional Aaministrator

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                        Table of Contents



DECISION SUMMARY                                             PAGE


I.    SITE LOCATION AND DESCRIPTION	1

II.   SITE HISTORY AND ENFORCEMENT ACTIVITIES 	 2

III.  HIGHLIGHTS OF COMMUNITY PARTICIPATION 	 4

IV.   SCOPE AND ROLE OF RESPONSE ACTION   	5

V.    SUMMARY OF SITE CHARACTERISTICS 	 6

VI.   SUMMARY OF SITE RISKS	8

VII.  DESCRIPTION OF ALTERNATIVES   	  11

VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES   ...  15

IX.   DESCRIPTION OF THE SELECTED REMEDY	19

X.    STATUTORY DETERMINATIONS	  20

XI.   DETERMINATION OF SIGNIFICANT CHANGES  	  21


ATTACHMENTS

APPENDIX A   	   FIGURES

APPENDIX B    	  TABLES

APPENDIX C   	 COMMONWEALTH OF PUERTO RICO ENVIRONMENTAL
                          QUALITY BOARD LETTER OF CONCURRENCE

APPENDIX D   	  RESPONSIVENESS SUMMARY

APPENDIX E   	   ADMINISTRATIVE RECORD INDEX

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               DECISION SUMMARY




             JUNCOS LANDFILL SITE




             SECOND OPERABLE UNIT




             JUNCOS, PUERTO RICO
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY




                  REGION  II




                   NEW YORK

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I.   SITE LOCATION AND DESCRIPTION

The Juncos Landfill Site (the  "Site" or "the Landfill") is located
in the Municipality of Juncos, Puerto Rico as illustrated in Figure
1.  The Site includes an inactive municipal landfill which occupies
approximately 17 to 20  acres  of  land.  The  northern perimeter of
the Landfill is bordered by a residential housing development as
illustrated in Figure 2. The  southern boundary of the Landfill is
bordered  by  a high point  which is nearly  70 feet  above  grade.
Outside  the  eastern  and  western  boundaries,  the  Landfill  is
bordered by two unnamed streams.  These streams flow to the north
and are tributaries to  the Quebrada Ceiba which  flows to the Rio
Gurabo.   The confluence of the unnamed tributaries with Quebrada
Ceiba  is approximately 2,000  feet  north of the  Landfill.    A
municipal public  water supply well field  is located  1.5  miles
northwest of the Site.

The Landfill  is approximately  10  to 30  feet thick with  a soil
cover, approximately 1.5 feet thick, and thick grassy vegetation.
Topographically,  the  Landfill  slopes  are  predominantly  low  to
moderate with a topographic high in the southwest quadrant of the
Site.    While  surficial   runoff  will   occur radially  off  the
topographic high,  the prevailing directions of runoff are  to the
east and west.  Surficial runoff from the  Landfill ultimately flows
into the  two unnamed tributaries of the  Quebrada  Ceiba.   Flow in
the  two  tributaries   is   intermittent  and is   dependent  on
precipitation events.   There are no apparent marshes or wetland
areas within 1 1/2 miles of the  Site.

The Juncos  Landfill is underlain  by Cretaceous  to Jurassic-aged
granodiorite, which is described  as a light to  medium-grey, medium-
grained  rock predominantly  composed  of  plagioclase,  quartz,and
othrocolase.   Overlying the  granodiorite just  to the  north and
northeast, and along the western quarter and northeastern limits of
the Landfill  are  piedmont fan and alluvial  terrace  deposits of
Quaternary Age, consisting  of  unconsolidated deposits of sand.  The
remaining deposits overlying  the bedrock in  the  vicinity  of the
Site  are comprised of  either manmade  fill material  or residual
derived from the decomposition and  weathering  of granodiorite.  As
a result  of weathering  and decomposition, a  friable bedrock unit
developed in place along the contact between the surficial deposits
and the granodiorite.

The predominant direction of  groundwater  flow  in the study area is
to the north-northeast.  There is no evidence of the existence of
a continuing unit between the  surficial deposits/weathered bedrock
unit and  the  underlying granodiorite  formation.   The predominant
horizontal  direction of  groundwater flow  is the  same for  the
surficial deposits and  bedrock unit, i.e., to the northeast.

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II.  SITE HISTORY AND ENFORCEMENT ACTIVITIES

The Landfill is owned by the Municipality of Juncos, Puerto Rico,
which operated the Landfill between the years 1957  and  1977.  The
Landfill was closed in 1981.  In addition to municipal wastes, the
Landfill received industrial waste  including mercury  thermometers,
waste acids and sodium hydroxide, off-specification  perfumes, and
electrical equipment.  These materials came from local industrial
facilities.

In April  1982,  the EPA Region II  Field  Investigation  Team (FIT)
initiated  sampling at  the Site.   The  presence  of mercury  was
reported in ambient air and soil headspace, but the  locations and
concentrations were not identified.

In September 1983, EPA conducted a Site inspection of the
Landfill.  During the Site  inspection,  mercury was detected in the
air and soil in the southwest portion of the Landfill, in off-site
leachate  samples,  and  in  soil  samples collected  in gardens  and
behind homes adjacent to the Site.   The FIT also conducted a more
extensive  air  survey   in   February  1983,  which  indicated  the
detection of volatile organic compounds.  Based on these findings,
EPA listed the Landfill on the National Priorities List (NPL).

On March  15,  1984, EPA entered  into an Administrative  Order  on
Consent with Becton Dickinson  (BD)  pursuant to  Section 106(a)  of
CERCLA, 42 USC  9606(a), which  called for BD to  perform immediate
corrective  actions  at  the Site   (which   included  some  access
restrictions and  a soil cover on  some portions of  the  Landfill
where wastes were  exposed) and for performance of a preliminary
investigation at the Site  to assess  the imminent  and significant
risks, if  any,  to  human health and the  environment  posed by the
mercury presence at the Landfill.

Pursuant to this  Order,  BD retained Fred C.  Hart  and  Associates
(HART) to conduct the investigation.  Results of this  investigation
are presented in the Preliminary Remedial Investigation of Juncos
Municipal  Landfill, dated  June  28   1984.    The   investigation
indicated  the  following:   mercury  vapors  were detectable  in  the
ambient air  at the Landfill and in subsurface soil pore spaces
adjacent  to  the   Landfill;   concentrations of   mercury  below
background  levels  were detected  in the  samples  of edible  fish
collected from the stream adjacent  to the Landfill; and no mercury
was  detected  in  soils or sediments  collected  from  off-site
locations.  In addition, mercury levels detected in the soils and
sediments collected from locations  near the  Landfill  were within a
range that is typical for  locations with no known point source of
mercury contamination.   The investigation also compared household
dust samples collected from residences directly adjacent to the
Landfill with background samples and found slightly higher levels
of  total  mercury   in  the household  dust.     Based  on  this
investigation, it was concluded that the Juncos Landfill was not a

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significant source of mercury exposure to off-site locations.  An
evaluation of the results made by the Centers for Disease Control
(CDC) ,  as  requested  by EPA,  concluded that  the  Site  posed  no
immediate threat to human health.

On October 9,  1984 BD entered into a second Administrative Order on
Consent  (AOC)  with  EPA, which required BD  to  conduct a Remedial
Investigation and Feasibility Study  (RI/FS)  at the Juncos
Landfill.   BD  retained HART  for this work.    Field activities
commenced  in  October of  1986  and continued at  various  times  in
1987.   Following EPA  comments  on the first  draft RI report, HART
conducted  additional  environmental  sampling and  analysis,  which
included leachate, air, shallow  soil, surface water, ground water
and municipal well sampling at and/or in the vicinity of the
Landfill.

In December 1989, HART submitted  an Addendum to  the Site Operations
Plan (SOP)  for additional field investigation activities to address
USEPA concerns regarding leachate characterization and biota uptake
of metals.   The SOP was  revised in February 1990 in response to EPA
comments, and was approved by EPA in  a letter to BD dated March 22,
1990.  Field investigation activities commenced in August 1990 and
were completed in January 1991.   A draft Phase II RI Report for OU-
II was  submitted in July 1991 and a  revised version was submitted
in November 1991 in response to  EPA  comments.  In March 1992, EPA
approved the November 1991 revised draft RI Report for the off-site
component  OU-II.   An OU-II revised Feasibility Study  (FS)  was
submitted to EPA in June 8, 1993.

In November 1990, EPA separated  the cleanup of the Site into two
operable units or phases.  The first operable unit (OU-I) focused
on the abatement of the source of Site contamination,  the Landfill
itself.  The second operable unit (OU-II),  focused on  the migration
of contaminated groundwater.

In April  1991,  Hart submitted the Draft FS  Report  for  OU-I.   In
June  1991,  EPA distributed the Proposed Plan for OU-I to solicit
public  comments regarding EPA's preferred  remedial  alternative.
The  public comment period began on June  1,  1991  and  continued
through July  31,  1991.   EPA signed the OU-I  Record of Decision
(ROD) on September 24,  1991.  The remedial action selected for OU-I
was closure of the Landfill by construction of a single barrier cap
with a  geomembrane liner;  installation  of a security  fence around
the  perimeter  of  the  Landfill,  a  leachate  control  system  as
necessary and a Landfill gas venting system; provision for erosion
and sediment control appurtenances; placing  institutional controls
on  the Landfill  property  in  an  attempt to  preclude  future
development  to  ensure the   integrity of  the  cap;  temporary
relocation of families living in homes located  along  the immediate
north  face of the Landfill during  the  construction  phase of the
remedial action; provision of  long-term operation and maintenance
of the Landfill cap and  long-term air, sediment, surface water, and

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leachate monitoring to evaluate the remedial action effectiveness.

From  1991 to  1992,  EPA  conducted  a search  to  locate  parties
responsible for contamination  at  the Landfill.   EPA subsequently
negotiated  with  these parties  to  implement  the OU-I  remedy.
Because negotiations were unsuccessful, on September 30, 1992, EPA
issued a  CERCLA Unilateral  Administrative Order to BD, Browning-
Ferris Industries,  Chesebrough-Pond's, General  Electric Company,
the Municipality  of Juncos,  the Puerto Rico Land Administration,
and   the   Puerto   Rico   Development  and   Housing   Improvement
Administration.

Additionally, on  August  14, 1991, EPA was notified by a citizen
adjacent to the Landfill that smoke was being released from the
Landfill.   Concern was  raised  about the  potential   release  of
contaminants from the Landfill through the smoke. EPA conducted an
investigation  on  August  16,  1991  which revealed  that an  area
approximately 50 feet by 100 feet on the oldest portion of the
Landfill had apparently subsided.  The grass  in  this area was dead
and  several cracks  in  the surface were  venting smoke.    The
prevailing winds carried smoke  in  a westerly direction parallel to
La Ceiba  Community.   The  smoke observed  during  the investigation
dissipated within 50 feet of the burned area.  Air sampling results
for   mercury  and    organic   compounds   showed   non-detectable
concentrations for  these chemicals.   However, EPA directed BD and
the  Municipality of Juncos  to  implement   immediate  corrective
actions at  the Site  that  included  covering the crevices  of the
Landfill  that  were  smoking with  fill material,  posting of signs
advising  potential  hazards  posed by the Site to trespassers and
repairing the fencing that currently  exists at the Site to prevent
unauthorized access.  During the implementation of the OU-I remedy,
additional actions may have to  be  taken if there is a reoccurrence
of fire.
III.      HIGHLIGHTS OP COMMUNITY PARTICIPATION

The RI report, Risk Assessment and the Proposed Plan for the Site
were released for public comment on August  9, 1993 pursuant to the
requirements set forth in CERCLA Sections 113(k)(2)(i-v) and 117.
These  documents  were  made  available  to  the  public  in  the
Administrative record file at the EPA Docket Room in Region II, New
York City  and the information repositories at  the EPA Region II
Caribbean Field Office in Santurce, Puerto Rico and the Juncos Town
Hall in  Juncos,  Puerto Rico.   A public notice was  published on
August  9,   1993   in  the  El  Nuevo Dia  and  the  San   Juan  Star
newspapers, announcing EPA's preferred remedy, the  availability of
these documents for review and notice of the August 25, 1993 public
meeting.

A public participation meeting was conducted by EPA on August 25,
1993,  at the  Municipal  Assembly Room  of  the  Juncos  Town  Hall,

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Juncos, Puerto Rico to discuss the Proposed Plan for OU-II and to
provide an opportunity  for  interested  parties and communities to
present oral comments and questions to EPA.

A summary of the significant comments related to the selection of
the remedy, received during the public meeting and public comment
period and EPA's responses to these comments are presented in the
Responsiveness Summary,  which  is part of  this  Decision Document
(attached as Appendix D). The Responsiveness  Summary and Decision
Document, along with the administrative record for the Juncos
Landfill  OU-II,  are  available  at  the  information  repositories
referenced above.
IV.   SCOPE AND ROLE OF RESPONSE ACTION

This OU-II ROD identifies EPA's selected no action alternative for
addressing potential  off-site  impacts resulting from contaminant
migration from the Landfill via groundwater.  This is  the second of
two operable units  for  the Site.   OU-I focused on source control
measures for the  Site.   EPA signed an OU-I  ROD on September 24,
1991  which  selected proper  landfill  closure utilizing  a single
barrier  cap with  geomembrane.   This selected remedy  for  OU-I
consisted of the following components:

•     Installment of a security fence  around  the perimeter of the
      Landfill property to restrict access at the Site.

•     Placing institutional controls on the landfill property  in an
      attempt to preclude future development to ensure  the integrity
      of the cap;

•     Installation  of  a  passive landfill  gas  venting system which
      could be converted  into an active system,  if necessary.  The
      decision to  convert to an active system will  be made after
      sampling of the gases is  completed;

•     Installation of a leachate control system, as necessary.  This
      will be decided during regrading operations for construction
      when  the  presence  and quantity of  leachate  will  be more
      apparent;

•     Clearing and  grubbing of  existing vegetation on the Landfill
      area,  as needed,  and regrading of the Landfill to provide a
      maximum slope  of 3H:1V;

•     Temporary relocation of families  living in homes  located along
      the   immediate  north  face  of  the  Landfill  during  the
      construction  phase  of this alternative;

•     Construction   of   a   single-barrier   cap  which   includes
      installation  of a fabric membrane liner  on  the top surface of

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     the Landfill to  reduce  surface  infiltration,  prevent direct
     contact, limit gas emissions, and control erosion;

•    Provision for erosion and  sediment  control appurtenances as
     needed  to  be in compliance  with any local requirements in
     Puerto Rico  and  best engineering practices.   This typically
     consists of drainage channels, stilling basins, and sediment
     basins;

•    Provision  of long-term operation  and  maintenance  of  the
     Landfill cap, including  routine  inspections and repairs; and

•    Provision  of long-term  air,  sediment,  surface  water,  and
     leachate   monitoring   to  evaluate   the  remedial   action
     effectiveness.

The  OU-I selected  remedy is  being  implemented  pursuant  to  a
Unilateral Administrative Order issued by  EPA to  the potentially
responsible parties on September 1992.  The implementation of this
remedy is currently in the remedial design phase.

OU-II addresses  the  measures that may be necessary  to mitigate
potential  off-site  impacts   resulting from  chloroform,  carbon
disulfide,  and  potentially  the metals antimony,   manganese,  and
vanadium  migration  via  groundwater.   While  the  Site has  been
separated into two operable  units, this  ROD considers the remedy
selected  for OU-I (Landfill capping component) as part of  the
overall evaluation of alternatives for OU-II.   The source control
action of capping the Landfill will reduce the potential threat to
human health and the environment  by isolating the  Landfill  and
reducing the risk of contaminant migration from the Landfill into
groundwater  which results   from  leachate generated   by  surface
precipitation.


V.   SUMMARY OF SITE CHARACTERISTICS

This  section only addresses groundwater.   For a  more detailed
discussion of all data related to the Site,  see the  RI report which
is located in the information repositories.

Groundwater in the vicinity of the Site occurs within hydraulically
connected overburden and bedrock units. The overburden consists of
predominantly  light   to  dark green/gray  organic  silt and  clay
interspersed with deposits of light brown and orange/brown fine to
medium-grained  sand,  silt  and clay.   A  zone  of deeply weathered
rock  (saprolite) separates   the  overburden  from  the fractured
bedrock.   The saprolite consists  mainly of  clays and partially
decomposed  grains of quartz  and feldspars.   The bedrock  unit is
granodiorite, defined as quartz rich rock  with  andesine plagioclase
as the dominant  feldspar and hornblende.   Groundwater  flow in the
bedrock  occurs along  fractures created by joining and  faulting.

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Groundwater in the overburden  aquifer  flows  radially away from a
north-trending central bedrock outcrop which forms a topographic
high.  North of the Landfill,  flow is generally toward the north-
northeast.   Similar  flow  directions  exists  in  the  underlying
bedrock aquifer.

Groundwater  flow within  the  overburden  aquifer  occurs  through
primary intergranular porosity.   The bedrock aquifer is massive,
and  flow  is restricted to discrete fractures created by jointing
and  faulting,  and to zones of fractured, highly  weathered rock
formed by the weathering of fault zones.

Groundwater  flow  in  the  bedrock  aquifer  also  occurs  along
individual  fault planes  located  at  various  depths.   Most occur
within discrete  mineralized fractures with  fiber  veins or fault
cast veins,  greatly reducing their permeability.  The slow recharge
observed  during development  and  sampling of the  RI  monitoring
wells, as well  as the  low calculated hydraulic conductivities,
indicate  that  minor  mineralized faults transmit  only  very small
quantities of groundwater.

A  total  of  23  groundwater monitoring wells were  installed and
sampled  during  the  RI  to  monitor the  overburden, intermediate
bedrock and deep bedrock  water-bearing units at locations around
the  Landfill, in the direction of groundwater flow.  See Figure 3
for  well  locations.

Sampling  of  the  groundwater  monitoring wells   indicates  that
chloroform concentrations exceeding the Federal Safe Drinking Water
Act  Maximum Contaminant Level  (MCL) of 100 parts per billion (ppb
or  ug/1)  have  been  detected  in  samples  collected north  of the
Landfill at the J-3,  J-7,  and J-10 well nest locations.   At the J-3
nest,  the MCL  was exceeded  in bedrock  wells J-3-1  and J-3-3.
Concentrations   ranged  between  770  ug/1  and  2,590  ug/1  in
intermediate bedrock well J-3-1 and between 190 ug/1 and 1,800 ug/1
in  deep   bedrock well J-3-3.   Chloroform was also  detected  at
concentrations below the MCL in the shallow overburden well J-3-2,
ranging in concentration from 14 ug/1 to 70.5 ug/1.   Chloroform was
detected  in bedrock wells J-7-2 and J-7-3  at  concentrations of 925
ug/1 and 330 ug/1,  respectively, but was not detected in overburden
J-7-1.  The MCL for chloroform  was also exceeded in  overburden well
J-10-1 and bedrock well J-10-2 at  concentrations of 1,090 ug/1 and
292  ug/1, respectively.   A summary  of the chloroform analytical
results  in  groundwater is presented  in Table  1.

Carbon disulfide was detected  in five of the  wells  sampled  (J-l-2,
J-3-1, J-3-3, J-4-2, J-6).  Well J-6,  which  contained the highest
detected  value  obtained  by Hart  (300  ug/1),  were  sampled by CDM
Federal  in  1991 and were not  found  to contain carbon disulfide.
Therefore,  the  compound's  presence  in these  wells can  not  be
confirmed.    J-4-2 is  screened  in  the  bedrock  aquifer  and  is
apparently  upgradient of  the landfill.  The  1989 Phase IA results

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can not be confirmed for wells J-3-1  and J-3-3- because these were
not resampled for carbon disulfide in subsequent sampling events.
These wells are both screened  in the bedrock aquifer.   It should be
noted that carbon disulfide was detected in the landfill leachate
sampled by Hart during the OU-I investigations.  A summary of the
groundwater analytical results is presented in Table 2.

There  are other potential  sources  of groundwater  contamination
which exist in the immediate area  of  the Site including discharges
from  septic  systems; discharges  of  wastewaters to  storm drains
including direct observation of a  discharge of what appeared to be
oil and spent degreasing fluids noted in a storm drain and traced
to a nearby home where  three  empty forty  gallon drums were found
next to the storm  sewer;  and, discharge  of household wastewaters
(presumably from washing machines.)

Metals  detected   at  elevated   concentrations   in   groundwater
throughout  the  RI  include  antimony,  manganese  and  vanadium.
Antimony was detected in five wells (J-2-2, J-3-2,3-1-1,3-1-2,J-l-2)
at levels  which exceeded the MCL of 6 ug/1.   Manganese was detected
in five of the wells from unfiltered groundwater samples.  There is
a  Secondary  MCL for manganese of  50 ppb  pursuant  to the  Safe
Drinking Water Act  which  is based on aesthetic factors only,  not
health.   This metal occurs  naturally within the Site  geology.
Vanadium  was  detected at three  wells at  concentrations  ranging
between 9.7 ug/1 and 267  ug/1 in  unfiltered groundwater samples.
There  is   no  MCL  for vanadium.   A summary  of the  inorganics
analytical results  in groundwater is presented in Table 3.

All operating wells within the Juncos municipal public water supply
well field were sampled and analyzed for leachate indicators,  EPA
priority  pollutants and major cations and anions.    No  volatile
organic  compounds  were  detected at  concentrations  above  the
detection limit, and all other parameters were below federal MCLs.
A  summary  of the   public  supply  wells   analytical  results  is
presented in Table  4.


VI.  SUMMARY OF SITE RISKS

Based upon the results of the  OU-II RI, a baseline Risk Assessment
was conducted to  estimate the risks associated  with  future Site
conditions.  The risks associated with current Site conditions were
not evaluated since groundwater within the Site is  not currently
used.  The baseline Risk Assessment estimates the human health and
ecological risk which could result from  the contamination at the
Site if no remedial  action were taken.

Human Health Risk Assessment

A  four-step process is  utilized for assessing site-related human
health risks  for  a reasonable maximum exposure scenario.   Hazard

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Identification -  identifies  the contamination 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,  the frequency
and duration of these exposures,  and  the pathways  (e.g., ingesting
contaminated well water)  by which humans are potentially exposed.
Toxicity  Assessment   -  determines the  types  of  adverse  health
effects associated with chemical exposures,  and  the relationship
between  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 assessment of site-related risks.

The  OU-II  Risk  Assessment   focused   on  contaminants  in  the
groundwater which are likely to pose significant  risks to human
health and  the environment.   Additional  data  had been collected
since the OU-I Risk  Assessment  was  conducted and these data  were
incorporated into the  OU-II Risk Assessment.   The summary of the
contaminants of  concern  (COC)   in sampled matrices  is listed in
Table 5.

The groundwater contaminant screening process for OU-II identified
34 chemicals of concern;  21 metals,  10 organics and  3 pesticides.
These  chemicals  of  concern  were   selected  because  they   were
identified  above  detection   limits  in   the  groundwater  sample
analysis from  the Juncos Landfill.   This is taken to be the  most
comprehensive basis for developing risk estimates.

Several  of  the  contaminants   of   concern,   including  arsenic,
beryllium,  chromium  and  chloroform are known  to  cause cancer in
laboratory animals and are suspected to be human carcinogens.

The  baseline Risk Assessment evaluated  the  health effects which
could result from future exposure to contamination as a result of
ingestion,  dermal  contact  (from  showering)  and  inhalation  (from
showering)   of   contaminated    groundwater.      Currently,   the
contaminated groundwater is not  in use.   Residents  currently obtain
their drinking water from  municipal  water supply wells which are
located approximately 1.5 miles  northwest of the Site and 2 surface
water filtration  plants.   These plants  are  located  at Ceiba Sur
Ward  in  Juncos and Quebrada  Grande  in  Las Piedras.  A summary of
the exposure pathways considered in the baseline Risk  Assessment is
presented in Table 6.  A potential  risk of exposure may exist in
the future if the contaminated groundwater flowing beneath the Site
becomes potable.

EPA's acceptable cancer risk  range is  10^  to 10"6  which  can be
interpreted  to mean  that  an  individual may  have a  one  in ten
thousand  to a  one  in a million increased  chance of developing
cancer as a result of site-related exposure to  a carcinogen over a
70-year  lifetime under the  specific exposure conditions  at the

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Site.    The carcinogenic  risk  for  potential  future  users  of
groundwater is estimated to be 4.9 x  10"4 for adults and 4.0 x 10*
for children.

To assess the overall potential for noncarcinogenic effects posed
by more  than one contaminant,  EPA has developed  a  Hazard Index
("HI").    This index  measures the  assumed exposures to  several
chemicals simultaneously at low concentrations which could result
in an adverse health effect.  When the HI exceeds one, there may be
concern for potential noncarcinogenic effects.  The HI for future
users of groundwater was estimated to  be 12.14  for  adults and 48.7
for children.

Table 6  to  12  present  the  results of  risk and noncancer health
effects calculations for ingestion, dermal contact and inhalation
exposures to groundwater beneath and downgradient of the Site.

The  results of the baseline Risk  Assessment  indicate that  the
contaminated  groundwater  at  the  Site  poses  an  unacceptable
carcinogenic and  noncarcinogenic  risk  to human health  under  the
groundwater future  use  scenario.   However,  any corrective action
implemented  at   the  Landfill   itself   is  expected  to   reduce
concentrations of hazardous substances  released.  The Landfill is
expected to  be capped by Fall 1995.  This  source  control action
will reduce the leachate generated from precipitation and should
thereby reduce the  source of the groundwater contamination.

Ecological Risk Assessment

Groundwater contamination does  not present a  risk to ecological
receptors at the  Site.  No correlation  was found to exist between
contaminants detected in groundwater and those  detected in surface
water and sediment samples.  Therefore,  for this operable  unit, no
complete  exposure  pathway   for  ecological  receptors  has  been
identified.

Uncertainties

The procedures and inputs used to  assess risks  in this evaluation,
as  in all  such  assessments, are  subject to  a wide variety of
uncertainties.    In  general,  the  main  sources  of  uncertainty
include:

     environmental  chemistry sampling and analysis
     environmental  parameter measurement
     fate and transport modeling
     exposure parameter estimation
     toxicological  data

Uncertainty  in environmental sampling  arises  in  part from  the
potentially uneven distribution of chemicals in the media sampled.


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Consequently, there  is  significant uncertainty as  to the actual
levels present.   Environmental  chemistry-analysis error can stem
from  several  sources  including  the  errors  inherent  in  the
analytical methods and characteristics of the matrix  being sampled.

Uncertainties in the exposure assessment are related to estimates
of how often an individual would actually come  in  contact with the
chemicals of concern, the period of time over which such exposure
would occur, and in the  models used to estimate the concentrations
of the chemicals of concern at the point of exposure.

Uncertainties  in  toxicological  data occur  in  extrapolating both
from animals to humans and from high to low doses of exposure, as
well  as  from  the difficulties  in assessing  the toxicity  of  a
mixture of chemicals. These uncertainties are addressed by making
conservative assumptions  concerning  risk and exposure parameters
throughout  the  assessment.   As  a  result,   the   Risk  Assessment
provides upper-bound estimates of the risks to populations near the
site,  and is  highly unlikely to  underestimate   actual  risks to
populations near the Site.

More specific information  concerning public health  risks, including
a - quantitative  evaluation of the  degree of  risk  associated with
various  exposure  pathways,  is   presented  in   the  OU-II  Risk
Assessment Report  for the Site.
VII.   DESCRIPTION OP ALTERNATIVES

CERCLA  §121  (b)  (1),  42  U.S.C. §9621(b)  (l),  mandates  that a
remedial  action  must be protective  of  human  health and  the
environment,  cost effective,  and utilize permanent solutions and
alternative   treatment   technologies   or   resource   recovery
technologies  to  the  maximum  extent  practicable.   Section 121  (b)
(1)  also  establishes  a  preference for  remedial  actions  which
employ,  as  a principal  element,  treatment  to  permanently  and
significantly reduce the  volume,  toxicity,  or mobility  of  the
hazardous  substances, pollutants  and  contaminants  at a  site.
CERCLA  §121(d),  42  U.S.C.  §9621(d),  further  specifies  that a
remedial action  must attain a  level or standard of  control of the
hazardous  substances, pollutants and contaminants,  which at least
attains Applicable or Relevant  and Appropriate Requirements  (ARARs)
under  federal and state  laws, unless a waiver  can be justified
pursuant to  CERCLA  (d) (4), 42 U.S.C. §9621  (d)  (4).

This  ROD  evaluates  in  detail  three  remedial  alternatives  for
addressing the contaminants associated with  the Second Operable
Unit of the Juncos Landfill Site. The time to implement a remedial
alternative   reflects  only  the  time  required  to  construct  or
implement  the remedy and  does not include the  time required to
design  the  remedy,  negotiate with the  potentially responsible
parties, procure contracts for design and construction,  or conduct

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operation and maintenance at the Site.

The remedial alternatives are:

Alternative I!  Natural Attenuation-No Action
Capital Cost:
Annual O & M:
Present Worth:
Construction Time:
$ 0
$ 0
$ 0
None
The  No  Action  Alternative provides  a point  of  comparison  for
remedial action alternatives and serves as a baseline against which
the  degree  of remediation  and  associated  cost of  the  other
alternatives can be compared.  Under this alternative, no activity
would  take   place  to  remediate  the   groundwater  containing
chloroform, but rather the contaminated groundwater would be left
to  naturally attenuate.   Natural  attenuation  is  based on  the
natural  ability   of  the   groundwater   to   decrease   chemical
concentrations through physical, chemical, and biological processes
until cleanup  levels  are met.   It  is  expected that it would take
approximately 13 years for  concentrations  to decrease.  Under this
alternative,  no monitoring of  the groundwater  or institutional
controls would be put in place.

Because this alternative would result in contaminants remaining on-
site above health-based levels, CERCLA requires  that the Site be
reviewed every  five years.   If  justified by the  review,  remedial
actions may be implemented to remove or treat the wastes.

Alternative II;Natural Attenuation-No Action/Institutional
               Controls/Monitoring
 Capital Cost:                                 $ 51,624

 Annual O&M:                                   $ 42,250

 Present Worth:                                $ 603,112

 Construction Time:                              1 month
This alternative is similar to Alternative I, in that it allows the
groundwater  to naturally  attenuate.   However,  this alternative
includes groundwater monitoring to track its direction and rate of
movement,  in  conjunction with  maintaining effective and reliable


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institutional controls to prevent the future use of groundwater.

Institutional controls would consist of restrictions on groundwater
withdrawal wells in the area north of the Landfill.  These controls
would be regulated by the Commonwealth of Puerto Rico Department of
Natural Resources under the Regulation for the Appropriation, Use,
Conservation  and Administration  of  the Waters  of Puerto  Rico,
September 1984, Department of State Regulation No.  3171, November
13, 1984.

For purposes  of cost  evaluation, it  is  assumed  that  groundwater
monitoring will  be conducted quarterly for  the  first  five years,
semi-annually  for years  six through  ten and annually  for  years
eleven through  thirty.   At  this time  the following 12  wells are
proposed for each round of sampling: J-2-1, J-2-2, J-2-3, J-3-1, J-
3-2, J-3-3, J-7-1, J-7-2, J-7-3, J-10-1, J-10-2,  and J-10-3.

In  addition,  one existing downgradient  off-site monitoring well
(USGS Water Resources Division Well # CJ-TW6) and a new, two-well
cluster, to  be installed between the  J-10  well  cluster and well
#CJ-TW6  would  be sampled at  the  same frequency.   Results  of
previous sampling by USGS indicated that well #CJ-TW6 is currently
not impacted.  As such, future  sampling of these wells would allow
monitoring  for migration of  compounds  of concern  from potential
upgradient sources.

The exact number  of wells that will  be sampled  will be finalized
prior to the design of the selected remedy.  A total of 22 samples
is  expected  to be taken  for each round  to  include  field blanks,
trip blanks, method blanks,  two duplicates per sampling round and
a  method spike.   These  samples will  be  analyzed for volatile
organic compounds, antimony,  manganese and vanadium.  Water level
elevations  will  also  be measured during  each sampling  event.
Monitoring requirements would be assessed every five (5) years and
revised as warranted.

Because this alternative  would result in contaminants remaining on-
site above  health-based  levels,  CERCLA requires  that  the Site be
reviewed every  five years.   If justified by the review, remedial
actions may be  implemented to remove or treat the wastes.
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Alternative III;  Groundwater Extraction/Metals Removal/Air
                  Stripping/Discharge/Institutional
                  Controls/Monitoring
 Capital Cost:                                  $ 867,802

 Annual O&M:                                    $ 490,071

 Present Worth:                                 $ 6,417,408

 Construction Time:                               12 months
Alternative III would consist of the installation of 15 overburden
extraction wells and 6 bedrock extraction wells along the northern
boundary of  the Site in order to create a hydraulic  barrier to
prevent the migration of groundwater away from the Landfill.  This
remedial alternative  assumes that each overburden  well extracts
groundwater at a rate of 5  gallons per minute (GPM), and that each
bedrock  well extracts  groundwater  at  a  rate  of  10  gpm.   The
combined total yield of the overburden and bedrock extraction wells
is estimated at 135 gpm.  The current estimates of extraction well
numbers,  locations  and  pumping  rates  are  derived  from  the
hydrogeologic data  generated at the  Site during the RI,  and are
reported in the FS for the sole purpose of evaluating anticipated
costs.  The exact number, locations and pumping rates of extraction
wells  would  be  determined   through  extensive  aquifer  testing
performed during the  remedial design.   The groundwater treatment
method considered in this alternative is air stripping  to remove
the  chloroform concentrations  and  oxidation,  precipitation and
sedimentation to remove  metals.   One  air  stripper can  be used to
lower the level of chloroform in the extracted groundwater to below
the  MCL of  100 ppb.   It  is unknown how  long  it  would  take to
remediate the  aquifer to the MCL, however it is expected to be
lengthy,  due  to  the uncertainty  of  completely   capturing  the
groundwater in this fractured bedrock  aquifer.  Metals removal has
been  included  to  account for the possibility  that  it  may be
required.  The results of groundwater  sampling will  be analyzed to
determine what, if any, metals treatment is required.  Monitoring
would be required for the entire  duration of this alternative.  A
schematic diagram for the treatment system  for this  alternative is
presented in Figure 3.

Treated waters must be discharged  to a surface water  body.  Surface
water bodies that could serve as recipients of treated water could
be  either  Ceiba  Creek  or  the  Gurabo River.   The   option of
discharging  treated waters to the Juncos publicly owned treatment
works  (POTW) is not practicable since  the volume of  treated waters
to be generated is too large  and will  exceed the current available
capacity of  the POTW.  Transporting  the treated water to another


                                14

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POTW by tank truck is also not  feasible due to the large volume of
treated water expected to be generated.

Institutional  controls   may   include   deed   extractions  and/or
groundwater restrictions for the duration of the remediation.

The long term monitoring program is as described  in Alternative II.

Because this alternative would result in  contaminants remaining on-
site above health-based levels, CERCLA  requires that  the Site be
reviewed every five  years.   If justified by  the review, remedial
actions may be implemented to remove or treat the wastes.


VIII.     SUMMARY OP 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
evaluating are as follows:

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

1.   o    Overall Protection of Human Health and the Environment
          addresses whether remedy provides adequate protection and
          describes  how  risks posed  through  each  pathway are
          eliminated, reduced,  or  controlled  through treatment,
          engineering controls, or  institutional controls.

2.   o    Compliance with Applicable, or  Relevant and Appropriate
          Requirements  (ARARs)  is used  to determine whether each
          alternative will meet all of its federal and state ARARs.
          When  an ARAR  is not met,  the detailed analysis should
          discuss  whether one  of  the  six statutory  waivers is
          appropriate.

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 Performance  focuses on any
          residual  risk remaining at the Site after the completion
          of  the  remedial  action.    This  analysis  includes
          consideration  of  the degree  of  threat  posed  by the

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          hazardous  substances  remaining  at  the  Site and  the
          adequacy of any  controls  (for example,  engineering and
          institutional) used  to manage the  hazardous substances
          remaining at the Site.

4.   o    Reduction  of  Toxicity, Mobility,  or  Volume  Through
          Treatment is the anticipated performance of the treatment
          technologies a remedial alternative may employ.

5.   o    short-Term  Effectiveness  addresses  the effects  of  the
          alternative during the construction  and implementation
          phase until the remedial response objectives are met.

6.   o    Implementability    evaluates    the    technical    and
          administrative feasibility of implementing an alternative
          and the availability of various  services and materials
          required during its  implementation.

7.   o    Cost  includes  estimated  capital,  and  operation  and
          maintenance costs, both translated  to a  present worth
          basis.  The detailed  analysis  evaluates and compares ,the
          cost  of  the   respective  alternatives,  but  draws  no
          conclusions  as  to   the  cost  effectiveness  of  the
          alternatives.   Cost  effectiveness is  determined  in the
          remedy selection phase, when cost is  considered along
          with the other balancing criteria.

Modifying  Criteria   - The  final 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 comment is received.

8.   o    State Acceptance reflects the statutory requirement to
          provide for substantial and meaningful State involvement.

9.   o    Community Acceptance refers to the community's comments
          on the remedial alternatives under consideration, along
          with  the  Proposed  Plan.  Comments received  during the
          public  comment period,  and  EPA's  responses  to  those
          comments,   are  summarized  in  the  Responsiveness Summary
         . which is attached to this ROD.
                        *
The following is a summary of  the comparison of each alternatives
strengths  and  weakness  with  respect  to the  nine  evaluation
criteria.

1.   Overall Protection of Human Health and the Environment

Both Alternatives I  and II would not  reduce  the potential future
risk posed  by the chloroform  concentrations in  the groundwater,
even though  the likelihood of  future  groundwater use is minimal.
Future demand for water within the Town of Juncos is projected to

                                16

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be  supplied  from  surface  water sources.   Alternative  II  would
minimize  the unlikely  risk  of future  groundwater use through
implementation of  institutional controls which would prevent any
future  withdrawal  of  groundwater  from  the  residential  area
downgradient of the Site.  Continued groundwater monitoring would
confirm that chloroform concentrations were naturally attenuating
over time. The degree to which Alternatives I and II would satisfy
this criterion is directly related to the successful implementation
of the OU-I selected remedy whereby the migration of contaminants
to  the  groundwater is  reduced.  The  groundwater extraction and
treatment  proposed  as  Alternative  III  would  offer   the  same
advantages  as  Alternative  II,  except  that  the  reduction  of
chloroform concentrations  would be  accelerated, although  it is
uncertain by how much,  through the capture of  impacted groundwater
at the Landfill boundary.

2.   Compliance with ARARs

Both Alternative  I and Alternative II  would  not be effective in
complying with ARARs in the short term because ARARs would continue
to  be  exceeded  for certain  compounds absent  taking  a remedial
action.    Based  on the  results  of  a  groundwater  contaminant
transport  model  for the overburden  aquifer  conducted  by McLaren
Hart, it is estimated that it will take approximately 13  years for
ARARs to be achieved in the aquifer after  capping of the landfill
is  completed.  However,  this  is only an estimate, and the actual
time frame may be  shorter or  longer.   Groundwater monitoring will
take place to make sure that concentrations are decreasing.  The
groundwater  extraction  and  treatment proposed as Alternative III
would be  effective in complying with  ARARs  because compounds of
concern  potentially  migrating away   from   the  Landfill  would
theoretically be captured by the extraction wells. However,  due to
the  complexities of pump and  treat  systems  in fractured bedrock
aquifers,  it  is  uncertain  how long  it would take for ARARs to be
met  in  the aquifer itself.  Tables 13 through 16 presents Federal
and  Commonwealth of Puerto Rico ARARs  and TBCs for OU-II of the
Juncos  Landfill Site.   They are presented  in groups  based on
whether they are chemical specific,  location  specific, or action-
specific.

3.   Long  Term Effectiveness  and Permanence

Alternative  I would not be an  entirely effective approach in the
long term because compounds  of concern  at the  Landfill  could
potentially continue to impact  the groundwater.  The no action and
the administering of institutional  controls  proposed  as part of
Alternative  II  would  be effective  in  the  long term  since the
institutional controls would restrict the withdrawal of groundwater
in  the  residential area  which  would  prevent exposure in the
unlikely event of future groundwater  usage in this area  for potable
purposes.  For both Alternatives I and II,  existing concentrations
of  compounds of  concern are expected to decline in the  long term

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due to  the natural  attenuation  process after the  OU-I remedial
action has been  completed.   Alternative III would accelerate the
removal  of  concentrations   of   compounds   of  concern  in  the
groundwater at the Site.  However, the ability of the groundwater
extraction system to effectively capture all impacted groundwater
in a fractured bedrock aquifer system is uncertain.

4.   Reduction of Toxicity, Mobility or Volume

Alternatives  I  and  II  would  not be  effective  in  reducing the
toxicity, mobility or volume of chloroform.   In the long term, the
volume  and toxicity  of chloroform  should   diminish due to the
natural  attenuation process  through adsorption  to  the  organic
carbon content of soil and its degradation to breakdown products.
Alternative III would have a similar effect except that the rate of
reduction in the toxicity and volume of compounds  of concern should
be accelerated due  to the  capture of groundwater at the Landfill
boundary.

5.     Short Term Effectiveness

There  is  no  current  risk  presented  by   impacted  groundwater
downgradient of the Site; the predominant concern  identified is the
potential future use of groundwater.  Alternative  I would not  be an
effective  short  term remedy because  compounds could potentially
continue to impact the groundwater.   Alternatives  II  and III would
be effective in the short term in that the institutional controls
would  immediately   restrict   the use   of   groundwater  in  the
residential area north of the Landfill, although groundwater is not
currently  used  in  this area.    The groundwater  extraction and
treatment  component  of Alternative III  may  have  a more immediate
impact  on  the  reduction  of  concentrations  of compounds  in the
groundwater, and therefore may be more effective  than Alternative
II in the  short term.  Alternative II would take  approximately 13
years to reduce chloroform concentrations to its MCL after the OU-I
remedial action has been completed.  The ability of the Alternative
III groundwater  extraction  system to effectively capture all the
impacted groundwater in a fractured  bedrock  aquifer  system  is
uncertain; however, it would certainly be  less than Alternative II
for the attainment of MCLs.

No adverse impacts on human health and the environment are expected
to result  during implementation of Alternatives I, II and III.

6.     Zmplementability

Alternative I has no implementation problems and Alternative II may
also be  readily implemented.   The establishment  of  institutional
controls   by  the  appropriate   Commonwealth  agencies  is  not
anticipated  to  be a problem because  there  are no wells used for
drinking water within one mile north  of  the  Landfill.  Alternative
III differs  markedly from Alternatives I and  II  with respect  to

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this evaluation criterion due to the difficulties anticipated for
the  implementation  of the  groundwater extraction  and treatment
system.  First, past  experiences  during implementation of the RI
indicate  that  obtaining  access   to   neighboring  properties  is
problematic.   Access  would be necessary at  a  large  number of
private properties in  order to install extraction  wells  as proposed
under Alternative  III.   Second, the high density  of residential
structures and the limited amount  of available  space would make it
extremely  difficult  to  construct  an  interconnected   system  of
extraction  wells  and  a  treatment plant.   Finally it would be
difficult to verify that complete capture of impacted groundwater
in the fractured bedrock  aquifer  is  occurring  due  to the complex
and random flow patterns in this type of  aquifer.

7.     Cost

The  cost  comparison   for  the  remedial  alternatives  evaluated
indicates a significant disparity  in  cost.   The  Capital Cost for
Alternative I is $0, Annual O&M of $0 and a 30-year present worth
of $0.  Alternative II has a Capital Cost of $51,624, Annual O&M of
$42,250 and a 30-year present worth of $603,112.   Alternative III
has a Capital Cost  of $867,802, Annual O&M of  $490,071 and a 30-
year Present Worth Cost of $6,417,408.

8.     Community Acceptance

All  comments submitted  during the  public  comment period  were
evaluated and are addressed in the attached Responsiveness Summary.
Based on the  comments received  during the public comment period,
EPA  believes that  the residents  and  town  officials  of  Juncos
generally supported EPA's  preferred  alternative  described in the
Proposed Plan.

9.     State  (Commonwealth) Acceptance

A  concurrence letter  from  EQB  on behalf of the Commonwealth of
Puerto Rico is attached to this Record of Decision as Appendix C.


IX.  DESCRIPTION OF THE SELECTED REMEDY

Based upon an evaluation of the  alternatives  and  comments received
from   the   public,   EPA   has    selected  Alternative   II,   No
Action/Institutional  Controls/Monitoring  for Operable  Unit II at
the Juncos  Landfill Site.

The major components  of the selected remedy are  as follows:

      •    Natural attenuation/No Action for the  groundwater.

      •    Recommendation that institutional controls consisting of
          restrictions on groundwater withdrawal  in the area north

                                19

-------
          of the Landfill be implemented by the Commonwealth.

     •    Groundwater monitoring to ensure  that the concentrations
          of contaminants in the groundwater are decreasing over
          time.  It is estimated the approximately 16 wells will be
          sampled, although the  exact  number and duration of the
          sampling will  be  determined at  a  later date.   If the
          concentrations of contaminants in the groundwater do not
          decrease over time,  EPA may reevaluate this decision to
          see if active groundwater remediation is necessary.


X.   STATUTORY DETERMINATIONS

As previously noted, CERCLA Sec.  121  (b)(1),  42  U.S.C.  Sec.  9621
(b)(1), mandates that a remedial action must be protective  of human
health and the environment,  cost effective, and utilize permanent
solutions  and  alternative  treatment  technologies  or   resource
recovery technologies to the maximum extent practicable.  Section
121(b)(1) also establishes a preference for remedial actions which
employ  treatment  to permanently  and  significantly reduce  the
volume,  toxicity,  or  mobility  of  the  hazardous  substances,
pollutants, or  contaminants at  a  site.    CERCLA  Sec.  121(d),  42
U.S.C. Sec. 9621(d),  further specifies  that a remedial action must
attain a degree of cleanup that satisfies  ARARs under federal and
state laws, unless a waiver can be justified pursuant  to CERCLA
Sec.  121(d)(4), 42 U.S.C. Sec.  9621(d)(4).

For  the reasons  discussed  below,  EPA has  determined that  the
selected remedy meets the  requirements of  CERCLA Sec.  121,  42
U.S.C. Sec.9621.

Overall Protection of Public Health and the Environment

Alternative II  (No  Action/Natural Attenuation/Monitoring)  is  a
remedial action which protects public health and the environment by
mitigating potential future risks  associated with utilization of
groundwater for  drinking  purposes.  This  is  achieved through the
use  of a  single-barrier cap  in conjunction with  institutional
controls to preclude direct contact and access to  groundwater.  The
surface  controls (implemented  with capping)  and  cap also reduce
precipitation  infiltration which  minimizes the  potential  for
subsequent groundwater impacts.   The  institutional controls will
serve  to restrict access  to  the  groundwater  by residents  in  a
potential future use exposure scenario. Current residents utilize
a  municipal   water  supply  for  drinking  purposes.     Natural
attenuation will serve to reduce the concentration of  chloroform in
the  groundwater over time through  various physical  and  chemical
treatment processes.

Utilization of Permanent Solutions and Alternative  Treatment or
Resource Recovery  Technologies to the  Maximum Extent Practicable

                                20

-------
The components  of Alternative II,  in conjunction with  the OU-I
remedy, represent the maximum extent to which a permanent solution
and treatment technology can be utilized in a cost-effective manner
for the Site.  The recommended alternative is consistent with the
NCP expectation  that containment technologies will  generally be
appropriate remedies  for  sites that  pose a  relatively low-level
threat  or  where  treatment  is impracticable.    This recommended
alternative provides  the  best balance of trade-offs in  terms of
long-term  effectiveness  and  permanence, reduction   in  toxicity
mobility and volume, short-term effectiveness, implementability and
cost.    The  success  of  more  active  groundwater  extraction  and
treatment  alternatives is uncertain  due to  their  inability  to
capture all the  impacted groundwater in a fractured  bedrock aquifer
system.

Compliance with ARARs

The recommended  alternative  will  comply with all applicable or
relevant and appropriate action and location specific requirements.
The extent  to which contaminant-specific ARARs  (e.g. chloroform)
can be met is uncertain due to the complexities  of groundwater flow
in fractured  bedrock  aquifer systems.

Cost Effectiveness

Alternative II effectively addresses the potential future-use risks
posed by the  Site.  This alternative affords the highest level of
overall effectiveness proportionate to  its  costs.   The increased
costs   of   the   other  alternatives  evaluated  do  not  provide
significantly greater protection  of   public  health  and  the
environment relative  to their costs.
XI.  DETERMINATION OF SIGNIFICANT CHANGES

There  are  no significant changes from  the preferred alternative
presented  in the Proposed Plan.
                                21

-------
APPENDIX A

-------
                                       ?r—•   ^>
                         *•«• ^^r,-;^& yx ^/c
                         '^^wfy^-^^^:
                         gg^/&.y ?
                                    .  '  .>^'r/j?G>/ E   1   B —A^*
                             ®fcS\ ^Approximate limits;^p^C~7^j4 I

                             •m ^s?f ^ wHndS^ShJ^- few.
      M^^^?>
      ,'(S-ir-s2>.^ >^i
      k'l 'TVr*-«<>.. . f^*~w -i /• (
T> -\VvN^%v-\V^)!^r-
                                                        *^-,\\» III v -^ -
                                                  •r^^^^
                                                   FJGURE  1



                                                SFTE LOCATION MAP
NOTE:

Base map it a portion of lh« Juncos Ouadfangla, 1967

pholorevued 1982. Contour interval is 10 me(er».

Dashed contouri represent 5 melar contour*.
  JUNCOS LANDFILL

JUNCOS. PUERTO RICO
                                           FRED C. HART ASSOCIATES, \HC.

-------
                                                              FIGURE  2
n
u
                                   O	^

                                                                                                                VMBO C. MART A3SOCIATB*. IMC

-------
                                                                                        '(2s^\{?1  iD~
 MAP SHOWING EXCEEDENCE3  OF
UMUM CONTAMINANT LEVELS 

                                         (XUAIf MrmtCO M

-------
APPENDIX B

-------
                                                      Table 1
                                     SUMMARY OF CHLOROFORM ANALYTICAL
                                              RESULTS IN GROUND WATER
                                  Round 1
                                                                             Round II
Monitoring Well

    J-l-1
    J-l-2
    J-2-1
    J-2-2
    J-2-3
    J-3-1
    J-3-2
    J-3-3
    J-4-1
    J-4-2
     J-5
     J-6
    J-7-1
    J-7-2
    J-7-3
    J-9-1
    J-9-3
    MO-1
    MO-2
    MO-3
    MM
    Ml-2
    Ml-3
                       March 1987

                           ND
                           ND
                           ND
                           ND
October 1987
2,590 (2,290)
70.5
-
-
-
-
***
***
***
***
*•*
***
•»*
*»*
*»*
*»»
***
~
1,750(1,090)
2.27
2.59
ND
ND
***
***
***
***
***
***
**•
***
***
***
414141
Jan/Feb. 1989

     ND
     ND
     ND
     ND
      «
     MOJ
     19J
    980J
     ND
     ND
     ND
     ND
     ***
April 1989
                                                                    ***
                                                                    ***
                                                                                     770(880)**
                                                                                        14**
                                                                                       190**
                                              ND**
                                              ND**
                                               »**
                                               ***
                                               ***
                                               ***
                                               ***
                                                                    *»*
                                                                    ***
                                                                    ***
                                                                    *#*
                                                                    ***
                                               *#•
                                               *»*
                                               4"**
                                               *»*
                                                   •
                                               **»
   Round III
January. 1991

      ND
      ND
      ND
      ND
      ND
      810
      26
     1800
      ND
      ND
      ND
      ND
      ND
      925
      330
    2.61B
      SB
     1090
      292
      4JB
   ND (ND)
    6.06 B
    6.03 B
I.    AH vtfctc* io oj/1 (mierofnnu per liter).
2.    Value* is < ) arc ruutu of  not urnplcd.
4.    ND mt»a* Nol Dclacuui.
5.    * Udir«i»i w«U mot wmpled 4iM to dry or nur-dry condUion*.
6.    •• l»l«m.» dkM *>!• ««ll wu nMmpUJ bM*UM VOC hoUIng llnw* w*ra «U
7.    J muni valuM an «nim»iad.
I.    ••• indicate* w«U not iiuulled at lime of aampling.
9.    B indicalei compound waa detected at aimilar concenlration* in blank aample.
                                                             fur UM liMi

-------
                                      TABLE  2

                  SUMMARY OF ANALYTICAL RESULTS OF GROUNDHATFR SAMPLES
     Parameter
Number
of
Samples
Number
Positive
IDs

Sample Range
Low High
                                            Sample
                                            Mean
                                              USEPA
                                             Drlnkln;
                                              Hater
                                             Standard
Inorganics;

Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Silver
Zinc

Organics:

Chloroform
Methylene Chloride
Chlorobenzene
Carbon Dlsulfide
Benzole add
Dl-n-butylphthalate
Phenol
           1
           8
      *****
      *****
11
11
             BOL   -
             BDL   -
0.098
0.035
           1
           4
          10
           8
             ALL SAMPLES HERE BDL
                                   *****
            BOL
            BOL
            BOL
            BOL
0.006
0.009
0.125
0.019
             ALL SAMPLES HERE BOL
                                   *****
  1          BDL   -    0.012
'*  ALL SAMPLES WERE  BDL   "
 11          0.023-    0.251
           3
           1
           1
           5
           1
           1
           1
BDL
BDL
BDL
BDL
BDL
BDL
BDL
-
_
_
.
.
_
-
0.825
0.0055
0.0005
0.300
0.002
0.002
0.004
0.
0.
  098
  009
0.
0.
 .006
 .007
0.034
0.007
             0.012

             0.105
                                    .343
                                    .0055
                                    .0005
                                    .090
                                  0.002
                                  0.002
                                  0.004
             0.
             0.
             0.
             0.
0.050
0,
0.
1.
0.
0.
010
050
000*
050
002
           0.05
          5.000*
          0.100
Footnotes;

1.  All results 1n mg/1.
2.  Results for metals are from filtered groundwater samples.   Therefore,  these
    results Indicate dissolved metals concentrations.
3.  Drinking water standards are Maximum Contaminant Levels (MCLs)  except  those
    designated with a ', which are secondary drinking  water standards.
4.  - Indicates that a value 1s not available.
5.  The value for chloroform 1s for total  trlhalomethanes,  the chemical  group  to  which
    chloroform belongs.
6.  The sample mean 1s based only on the samples  1n which the  parameter  was  detected,
    not the total number of samples.
7.  Results are for the second sampling round occurring  1n  January/February  and April,
    1989
8   Detected values for chloroform are from samples collected  April,  1989  (See Table
    7.2-3)

-------
                                                               Table  3


                                                 GROtfllDWATER INORGANICS ANALYTICAL RESULTS



PARAMETER
INORGANICS
Antinomy
Arsenic
•ariu*
•eryll it**
Cadaiua
Crtroauua (tool)
Copper
Lead
Manganese
Mercury
Molytadenua
Nickel
Vanaditai
2inc

NUMBER
OF
SAMPLES (t)

20
20
*
20
20
20
20
20
4
20
1
20
*
20

MUK8ER
OF
POSITIVES

4
9
4
5
2
11
16
11
4
5
1
U
2
17


SAMPLE
HIM

ML
IOL
25. a
•01
BDl
801
BDL
BOL
76.2
BOL
U
BOL
BOL
BOL


RANGE
MAX

219
41.1
1BJO
4.1
1.4
112
2B4
42.1
8595
4
u
SJ
216
647



MEAN

104
21.9
6S7
2.1
2.7
44.8
4B.8
IS. 8
2877
1.4
14
29.J
111
116



ARAR COMPARISON

MEAN/MAX>PMCIC.PMCL; MAX'fUQC
MEAN/MAX»FUQC.PRUQS(CU)
MAX>PRUQS(SU)
HE AN/MAX>PHCLC.PNCL . FMC ,PRMS( SU)
SEE 1ABLE 2-1 IOR PRUQSMCLC.MCL.PRUQS(SU)
SEE TABU 2-1 FOR PRUQS(SU); OlHERUISE --
MEAN/MAX>MCLG.HCl - SEE TABtE 2-1 FOR PRUOS(SU)
MEAM/MAX>PRUOS(SU)
MEAN>PRUaS(SU);MAX>MCLC.MCL.PRuaS(SU>
N/A
MCAN/MAK>ruQC, SEE TABLE 2-1 FOR PRUOS(SU)
N/A
MEAN/MAX>PRUaS(SU)
(1)  Rctultt «r« fro* ut(llt«r«d. doMngradient w«tU J-2. J-3. J-S.  J-6.  J-7. J-9. J-10 end J-11.
••  - ARMt not «iiCMO«l; N/A - Not Appt ic*bl*/No ARAR*.
                  fro. the calcuUllen of  th. «^s •• w.r. replic.tes
Rctultt are coabined for the three •aapllng roi«Jt.
PMCl •  Propotrd Maiiiui Contaaiinant level .
PMCli.   Proposed MailMJi ContMiirtant Level  Coat.
PRUQS • Puerto Rico wcter Ou*lity Standcrds; SU:  Surface Water.  CU:   Crounduitcr.
fuOC-MM -  Federal Ajrf>imt U.ier Ouallty Criteria adjured for drinking water only.
                                                                                      . value of «ero < J-4.J-4-J.J-5-10.J-11-11 and J-10 20).

-------
                                                                              TABLE  4

                                                              PHASE I MUNICIPAL WELL  SAMPLING RESULTS
leachate Indicator!
    Chloride
    Nitrate as N
    Sulfate at S04
    10X
    IOC
    Specific Conductance
    pH
    Acidity as CaCOj
    Alkalinity as CaC03
    Araonia as N
    Bicarbonate as CaCOj
    Carbonate as C»CO->
    BOO
    COO
    IDS

Hetals
    Copper
    Zinc
    Calcium
    Magnesium
    Sodium
    Potassium

Volatile Organic Compounds
    Ir i clil or of luorome thane

Base/Neutral Extractable
Organic Compounds
    Di-n-butyl  phthalate
eietnon
Limit
(Watetl-

1.0
.1
5
5
1.0
10
NA
5
C
.05
5
2
10
10
HARI Identifier - WJUNCOS 01
ETC Identifier - _.BBZZZ?__

34.1
,g
35
18. 20
1.8. 1.8
478. 482
7.16. 7.20
170
.09
170
NO
6JH
11
I70JH
WJUNCOS OS
_MZ2fii-


22.9
.7
26
16. 17
NO. NO
367. 368
6.82. 6.82
NO
13
NO
130
NO
2JH
NO
240JH
WJUNCOS 07
_BBZZ66-
2 7
£ • '
.5
51
19. 21
1.8. 1-9
581. 581
6.95. 6.96
NO
180
un
rtu
180
un
NU
6JH
13
370JH
WJUNCOS 08
_.i877jSZ_
34.5
.9
33
24. 27
5.3. 5.4
485. 491
6.66. 6.68
NO
170
.10
170
NO
5JH
NO
310JH
                      1.7
                    28
                    20
                    220
                    54
                    260
                    100
                     10
                     10-11
  NO
  NO
 BHOL
4)100
16200
32100
 2000
                                                  NO
                                                  NO
                                                                  1.4
                                                                  17
                                                                  NOB
                                                                32700
                                                                16600
                                                                20000
                                                                  730
                                                                    NO
                                                                    NO
 BHOL
  NO
 NOB
55700
15500
42200
 1100
                                                                            NO
                                                                             NO
 BHOL
 BHOL
 BHDL
41400
16300
33900
 1900
                                                                                           NO
                                                                                           BHOL
                                                                                                                 Field  Blank    Trip Blank
                                                                                                                 _.eezzz5_     _BBzzz3_
                                                          NU
                                                          NO
                                                          NO
                                                      14.  IB
                                                       NO. NO
                                                       NO. NO
                                                      7.15. 7.16

                                                          NO
                                                          NO
                                                          NO
                                                          NO
                                                         4JH
                                                          NO
                                                         92JM
BHDL
 NO
 22
BHDL
 68
540
BHOL
                                                                                                         BHOL
                                                                                                         NO
                                                                                                                         NO
                                                                                                                                      mg/1
                                                                                                                                      ng/l
                                                                                                                                      mg/1
                                                                                                                                      ug/l
                                                                                                                                      ng/1
                                                                                                                                      un/cn
                                                                                                                                      pH Units
                                                                                                                                      ng/1
                                                                                                                                      mg/1
                                                                                                                                      ng/1
                                                                                                                                      mg/1
                                                                                                                                      mg/1
                                                                                                                                      mg/1
                                                                                                                                      mg/1
                                                                                                                                      mg/1
ug/l
ug/l
ug/l
ug/l
ug/1
ug/l
ug/l
                                                                                                                                      ug/l
                                                                                                                                      ug/l
 NO
 BHOl

 JH

 NDB
Hot Detected
Below Method Detection Unit
Sjr.ple not analysed (or parameter
 ilua Is estimated becausa holding
   times were enceeded.
     10X  -  lotal  Organic  Halides
     IOC  -  Total  Organic  Carbon
     BOO  -  Biochemical  Oxygen Demand
     COO  -  Chemical Oxygen Demand
     IDS  -  Total  Dissolved Solids
                                                                                                       mg/1 - Hilligrams per liter
                                                                                                       ug/l - Hlcrograms per liter
Valua Is estimatea DCC«U>B nu.v..,..,
  times were exceeded.                                IDS  -  Total uissoivcu .»»..-.
Value Is reported as not detected because it was
found at concentrations lest than fiv*  times (ten  times  for conmon lab contaminants)  the  amount  In  any blank associated with sample.

WJUNCOS 08 is a replicate of WJUNCOS 01.
  (1350n-17)

-------
4/16/92
COPC.XtS
                          Table  5

CHEMICALS OF POTENTIAL CONCERN DETECTED AT THE JUNCOS LANDFILL SITE
        INORGANICS

           Aluminum*
           Antimony
           Arcanic
           Barium
           BaryUlum
           Cadmium
           Calcium*
           Chomkjm (III and VI)
           Cobalt*
           Copoar*
           Iron*
           Laad*
           Magnatlum*
           ManganaM
           Mercury
           Morybdanum
           Nk*al
           Poustiom*
           Sodium*
           Vanadium
           Zinc
 VOLATILE ORGANICS:

    ftonzana
    Carbon DiiulUa
    CMorobanzana
    Cntorofonn
    M-DkMoroarhan*
    Mathytona Chlorida
SEMIVOLATILE ORGANICS.

   BentotcAod
   Bi«<2-chtoroiMpn>pyl) attwr
4.4'DDT
Dieldrtn
Endrln
   Ft«*nol
           NOTES:
           * IndicaiM that tha chamlcal could not ba quantltattvaly avaluatad dua to a lack ol toxioily data.

-------
4/26/82
PWAYAS XLS
                                                                                  Table 6
                                                           PATHWAY ANALYSIS/PATHWAY :.: LECTION. JUNCOS LANDFILL SITE*
                                                                   Occurrence
 Groondwater
                       Rout*
Ingestion
                  Dermal Contact
                     (Shower)

                     Inhalation
                     (Shower)
                    Receptors
     RetktoMs
(Aduks and Children)

     Residents
                (AduktandChildnn)
Current        Fufeii*

  U             L


  U             L


  U             L
                                                                                       Comment
Groundwatcr l» not cutrvntly used for residential and/or industrial
application. There it potential lor its use in the luture.

Groundwater It not currently used lor residential and/or industrial
application. There is potential lor its use In the luture.

Groundwater Is not currently used lor residential and/or industrial
application. There is potential lor Us use In the luture.
Pathway RetauM
  lor Analysis

      Yes
                                                                                                                                        Yes
NOTES.
U .


-------
   TABLE  1  RISK CHARACTERIZATION FOR JUNCOS LANDFILL-
INGESTION EXPOSURE OF ADULTS TO CHEMICALS IN GROUNOWATER


(in0tQ-4tey) Cortotrttrfttoft
-_ ,, ^ w
mpt A

Watar
Chamcab Concentration
Barmana 3.006 -09
Chtorotonft, 0 . 59E+00
Matiytena Ctaviill 1 TM^ "?
*1 _,« _^_ __ 	 ... .t^.,.^. « JW»I? «.«
OiabMn 1 006 -OS
4.4--OOT 2 OOE-05
A**anc ' 1.6E10-02
BanAuM 9BOE-03
**vrvc
K Eipotur* X
ZOMay X SSOdayi^aar X

lAOMMM
Rata
20
20
20
20
20
20
20
20

EipOMir*
Fraquancy "
350
350
3 SO
350
350
350
350
350
Expottjr* X
Ourakon

CMPOMI*
Ounkon
30
30
30
30
30
30
30
30
1 X I
Body Waighi Avarapng T»na
1 X 1
70 kg
Body
Wat»M
70
70
70
70
70
70
70
70
25550 day*
Averaging
Twna
25SSO
25550
2555O
25550
25550
25550
25550
25550

OwomcDariy
Inuka (COl)
3SE-05
2 IE 02
l 5E 04
47E-05
126-07
23E-07
42E04
45E-05

CanoarStopa
Factor (CSf)
200602
6106-03
7506-O3
1 406-02
1606*01
340E-OI
teOEtOO
4306.00

RISK.
(COTCSF)
106-0*
4.3E-05
LIE-OS

1.06 -OS
• 0€-08
3.4E10-4
I.9E-04
                                                      TOTAL RISK.  3.9E-04

-------
 GW-M-ftf XLS
                                  TABLE  7 RISK CHARACTERIZATION FOR JUNCOS LANDFILL:
                                INGESTION EXPOSURE OF ADULTS TO CHEMICALS IN GROUNDWATER
MOMCAftOMOGCMS • GftOUNDWATCR MGESTtOM EXPOSURE
ChroMcO«*yinfc»W*.
(•vV4*y>
**
C*~*KJ**
CHoNJb*m*r+
OMOfOvQfM

I/bitten* CNrwirtt

faaaWH^fckwai.MGittWf.' •tfw
•*^">\«^*"a»^^^"BW*pM ••' f " ~ — ^"
A. .A -^ A. _ _ .*• _b.«. _•_«—
B»<2 ••if VMByl) plOTMMa
K^MfcM^M J^od
C^WWiH* PWMP
y^.— — — >
C«1B*^W
n lit in
^^••'•1
Csidm
4.4--OOT
AAMftony
Artarac
BariMM
Bao«aum
Cadmum
Chroma* (11)
(VI)
Uo^toda^um
Mavl
Ua>Ou«y
ZMC
Walaf X
Conoamrotoi
mod X
WaMT
COrtO^fl4TB^OI%
1.OOE02
0.59.00
1.00C-03
1.30C-02
2.02E-01
• 596O2
4OOEO3
2OOEO3
200EO3
100EO5
1O06O5
2O06O5
«; 7F-0?
J:6DE-02
t.a3E.OO
30OC-O3
3.40E-03
t.eOE-02
V60EO2
' • we.oo
140602
503E02
. 2.10EO3
2.16E-01
3&3E01
InOMtan X
Rala
20 Way X
tngMMn
Rat*
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
Eipocura ]
K E«po>ur« X
Frequency Dunfton
350dayvy«« X 30y«M» X
Eifxmira
Fraquancy
350
350
350
350
350
350
3 SO
350
350
350
350
35O
350
350
350
35O
350
350
350
350
350
350
350
350
350
Eipowr*
Dun Km
30
30
30
30
30
30
90
30
30
30
30
3O
30
30
30
30
30
30
30
30
30
30
30
30
30
1 >
[ 1



Body Waigttt Av*r apng T«na
1 X 1
70 kg
Body
WwoM
70
70
70
70
70
70
70
70
70
70
70
70
70
70
70
TO
70
70
70
70
70
70
70
70
70
10»SOd*y»
Avaragmg
TWna
10950
10050
10950
10950
I095O
10950
10950
10950
10950
10950
10950
10950
10950
10950
10950
10950
10950
10950
10950
10950
10950*
10050
10950
10950
10950
Chrome Daily
Intake (COD
27604
49E02
27E05
36EO4
55603
186O3
1 1604
55605
556O5
27E-07
27607
566-07
34603
996O4
60EO2
10EO4
93605
26EO3
4.4E-04
24E01
386O4
1. 46-03
58605
69603
99E03
Ralaraooa
DOM (RIO)
200602
100E02
100601
600€02
100601
400602
20O6O2
400E^X>
600EOI
$00605
300604
500604
400604
300604
7.00602
5006O3
5006O4
1006.00
500E-03
100601
4.00603
2. 006 O2
300EO4
700603
2006O1
HO.
covrvo
14EO2
1.62E+00
27E-04
59E03
55C-02
4SC-02
SSC-03
14E04
0 IE-OS
55E03
0.1E-O4
1.1E-O3
1 I 5E+00
72C-OI
2.1 £-02
1.0C-01
26EOJ
• Of -02
24E«00
06£02
• OC02
106O1
65EOI
&.OC-02
                                                                                      HAZARD INDEX-  1.2E+01

-------
OMOC-ftf )O*
                                TABLE  8  RISK CHARACTERIZATION FOR JUNCOS LANDFILL-
                   DERUAL EXPOSURE OF ADULTS TO CHEMICALS IN GROUNDWATER:SHOWER SCENARIO
                             XSMn
                      "V*    X 1*180010 X  cm*w   X 02lwfttoy X 33O d*y*/y«« X
                                                                                JC   X
                                                                               1000 cnO     70k«
                                 ATM
                                                                                FACMM
                                                                                                    Tnw
                                                                                                             InplKiCOl)
                                                                                                  MSK.
                                                                                                JCOTCSQ
•m !»,•>•>,•,,*.•..
4.4-DOT
                     4OOC-09
                     t OOE-OS
                     200CO3
IftIM
uiso
U13O
• 4E-04
• 4604
• 4EO4
02
O2
02
                                                             350
                                                             XU>
                                                             390
30
30
30
I 06 OJ
IOE01
10EOJ
70
70
70
                                                                                                    2SUO
72EO*
1 OC-1O
36£ 10
                                                I40C-02
                                                                                                                        J40COI
toc-o*
20600
126-10
                                                                                                                       TOTAL RISK. 40E4*
            $ - OMOUMOWATCM OCJtttAL CONTACT EXPOSURE

                      WMW   XShn&tftao* X I
                             X 18110on» X  cm«w
                              SMtSuftea*
                                 ATM
                                                                                Facto*
                                                                                 11
                                                                               1000 onO
                                                         70kg

                                                         Booy
         Conaun
                    Tvn*
                                                FMKW
                                                                    Tra
                                                                                         NO.
                                                                       (C0l>   Oo»»(RC>   COVHO



y^^^
Ota*M«
-
4.4- DOT
• 50C-Q8
400C-00
2OOE-O3
200C-09
1.0OE-OS
1 OO6-OS
20OC-O9
18110
18110
10190
1*190
18150
18 ISO
18190
• 4E-O4
• 4E-O4
• 4E-04
eiE-oj
• 4E-O4
• 4C-O4
8.4E-04
O2
02
02
O2
02
O2
O2
390
300
390
390
350
3OO
35O
30
30
30
30
30
30
30.
IOE-03
IOEO3
ioe-03
I.OE-03
IOE-03
IOE-03
10603
70
70
70
70
70
70
70 •
lOftSO
'lOftiO
10650
10AM
10450
10050
tOMO
28606
1.7E07
64E09
8.1607
4.2E-10
4.2E-10
8.4E-IO
40OEO2
2006-02
400£*00
6.006-01
6 OOE-OS
3.006 -O4
OOOE-04
606-05
• 46-06
2.IE-OS
136-08
• 46-04
1.46-06
1.7£[-08
                                                                                                                    HAZARD INDEX. ftOC-OS

-------
GWIta-DXLS
                              TABLE  9   RISK CHARACTERIZATION FOR JUNCOS LANDFILL
              INHALATION EXPOSURE OF ADULTS TO CHEMICALS IN GROUNDWATER: SHOWER SCENARIO
                                             Variable Valu«
-------
  IIM/O2

  GW-ftlfuvXLS
                                    TABLE  10  RISK CHARACTERIZATION FOR JUNCOS LANDFILL:
                                INGESTION EXPOSURE OF CHILDREN TO CHEMICALS IN GROUNDWATER
NONCARONOGENS - GROUNDWATER INGESTION EXPOSURE (0 - 6 YEARS)
                                      X   Exposure  X Exposure  X
Subcfaocac Daily lnlalu»-
(mg/Vg-day)
Chemicats 	
Chlorotenzen*
Okxoto/m
1.1-OicMoroethaAe
UcMhyten* CNonda
Carbon OisuJfcte
Bts(2-cMoro«sofvopyQ ether
Bis(2*t)ytttxy<) phlhalaie
BenzoicAcid
Pttenol
Oieldnn
Endnn
4.4'DOT
Antimony
A/santc
Barium
Berytbuflt
Cadmium
Chromium (111)

Manganese
UotybdMum
Nicfcai
Mercury
Vanadun.
Zinc
new «
Concentration
ing* *
Waier
1.00E-02
0.59E+00
10OE-O3
130E-02
202E-O1
6 59E-02
400E-03
200E-03
200E-03
100E-05
100E-OS
200E05
5.70E-02
1.60E-02
183E«00
380E-03
340E-03
960E-02
1.60E-02
859E.OO
140E-02
503E-02
210E-03
216E-01
363E-01
"•W""""" "
Raia
20 Vday X
Ingasiion
Rats
	 —
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
Frequency
350 days/year
Exposure
Frequency
350
350
350
350
350
350
350
350
350
350
350
350
350
350
350
350
350
350
350
350
350
350
350
350
350
Duration
X 6 years X
Exposure
Duration
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
Body Weigh! Averaging Tune
1X1
16kg
Body
Weight
16
16
16
16
16
16
16
16
16
16
16
16
16
16
16
16
16
16
16
16
16
16
16
16
16
2190 days
Averaging
Time
2190
2190
2190
2190
2190
2190
2190
2190
2190
2190
2190
2190
2190
2190
2190
2190
2190
2190
2190
2190
2190
2190
2190
2190
2190
Subchronic Daily
Intake (GDI)
1 2E-03
2 IE 01
1.2E-04
1 6E 03
24E02
79E03
4 BE 04
2.4E-04
2 4E-04
1 2E 06
1 2E06
24E06
1.5E-02
4 3E-03
22E01
4.6E-04
4 IE 04
1 2E-02
1.9E-03
10E.OO
1.7E-03
6.0E-03
2 5E-04
26E-02
4.3E02
Subchronic
Reference
Dose (RIO)
2.00E01
1 OOE 02
100E.OO
600E02
1 OOE 01
4 OOE 02
2 OOE 02
4 OOE .00
6 OOE 01
5 OOE 05
5 OOE 04
5 OOE 04
4 OOE 04
1.00E-03
5 OOE-02
5 OOE 03
500E04
1 OOE. 01
200E-02
100E01
4 OOE 03
2 OOE 02
300E-04
7.00E-03
2.00E-01
HAZARD INDEX -
HQ=
CDI/RIO
6 OE 03
6.9E+00
1.2E04
26E02
24EOI
2.0E-01
24E02
60E05
4 OE 04
24E02
2.4E-03
48E03
1.7E+01
1.9E+00
44E.OO
9 IE 02
8.2E-01
12E-03
96E-02
i oE.o;
42E01
3.0E01
ME^I
37E.;00
2.2E-01
4.7E+01

-------
                                  TABLE 10  RISK CHARACTERIZATION FOR JUNCOS LANDFILL:
                              1NGEST1ON EXPOSURE OF CHILDREN TO CHEMICALS IN QROUNDWATER
         . OAOUNOWATtR MGESTKM EXPOSURE (0 • • YEARS)

         >•>•           Watef   X  lno*ttan X  E«AOM*»   X EipOM*  X
CNorotcr*
4.4--OOT
«Q« X
w«.
Cm*j»**«*nn
3.00C-03
0.59+00
1.30C-02
l«to 4.0OE-03
IOOC-O5
200E-03
1.60E-02

Raw
2 Olfctey X
Ing***
Rat*
2O
20
20
20
20
20
20
20
Frequency Ourakon
3504*y«/yaa/ X 6yw*« X
EMKMUM
Fr«qu««icy
UO
350
350
350
350
350
350
350
EBpo-uw
Ourvkon
e
4
6
6
6
6
6
Body W*igM Avwftpng TMM
1 X 1
16 kg
Body
W*r
1 . HE-05
IOC 4)6
see -07
I6C06
70E-09
2.9E-04
1.7C-04
                                                                                          TOTAL RISK.  3.1E-04

-------
H/4/82
GW OC RF.XlS
                            TABLE 11  RISK CHARACTERIZATION FOR JUNCOS LANDFILL:
                DERMAL EXPOSURE OF CHILDREN TO CHEMICALS IN GROUNDWATERrSHOWER SCENARIO
CARCMOCEMS • CROUMDWATER DERMAL CONTACT EXPOSURE (0 • 6 YEARS)

 ClUonic Daily InteX*.
                   Watw   XSWn Sortaca X Pormoabilily X Exposure X  Exposure X Exposure X Conve«SK>n X_
imgmg-aay) uoncvmnuion A/«a Constant Time Frequency Duration Factor
mgA X 72OOcm2 X crtvhr X 0 2 hr/day X 350 days/year X 6 years X 11

Cnamcafe
Be(2«tl«y«t«*yl) phttkatato
OwUnn
4.4- DOT


WaM> SUnSurtac*
Concentnttan Area
4006-03 7200
1006-05 7200
200C-OS 7200


Pwmeabikly
Constant
84EO4
846-04
84EO4


Exposure
Tune
02
02
02


Exposure
Frequency
350
350
350


Exposure
Duration
6
6
6

1000 cm3
Conversion
Factor
1 06 03
1 06 03
1 OE 03

Body Weight Averaging Time
X 1 X 1
16kg
Body
Weight
16
16
16

25550 days
Averaging
Time
25550
25550
25550


Chronic Daily
Intake (GDI)
25608
626-11
1.26-10


Cancer Slope
Factor (CSF)
1 .406-02
1 606.01
340601
TOTAL RISK -

RISK .
(COrCSF)
35E 10
99E 10
426 11
1 4E09
NOMCARCMOOENS - OROUNOWATER DERMAL CONTACT EXPOSURE (0 • 6 YEARS)
SubctvofMC DAtty Iniak*"
(m9%04*y)




CheroM^aH
fi*5(?-^Kyo<>opfty>1) •tf***
flurr • itMrfK^wwft trfirttauM*
DB^4fc^W'y*|Wy*/ ^•••••••^•w
Benzoie Add
Pnenol
Dwktm
tndrm
4.4- DOT
Wate< XSfcin Surface X
Conceouainn Aiaa
mcyl X 7200 cm2 X


WaMi Stun Surtac*
Conovnttaiion Area
6 506 02 7200
40O6-O3 7200
200E03 7200
2006-03 7200
10O6-O5 7200
100605 7200
200605 7200
Parmeabikry X
Constant
cm/hr X


Parmaabikry
Constant
846O4
• 46-04
8.4604
81603
84EO4
84E04
84604
Exposure X
Tuna
Expo sore
Frequency
02 hr/day X 350 days/year


Exposure
Time
02
02
02
02
02
02
. 02


Exposure
Frequency
350
350
350
350
350
350
350
X Exposure X
Duration
X 6 years X


Exposure
Duration
6
6
6
6
6
6
6
Conversion
Factor
1 L
1000 crt>3

Conversion
Factor
1 06 03
1.06-03
1 OE 03
1.06O3
10603
10603
I.OE03
X 1
Body Weight
X 1
16kg

Body
Weight
16
16
16
16
16
16
16
X 1
Averaging Time
X 1
2 190 days

Averaging
Time
2190
2190
2190
2190
2190
2190
2190





Subchronic Daily
Intake (GDI)
4 BE 06
296-07
1 46-07
1 4606
726 10
726-10
1 46-09




Subchronic
Roloience
Dose (RID)
4006-02
2 006-02
4006.OO
6006-01
500605
5.00E-04
5.006-04





MO.
CDl/RtO
1 2E04
1 4E05
36608
23606
1 46 OS
1 4E 06
29E06
                                                                                                         HAZARD INDEX -  1 6E 04

-------
I1/4/W2
GWINH2XLS
                             TABLE 12  RISK CHARACTERIZATION FOR JUNCOS LANDFILL:
            INHALATION EXPOSURE OF CHILDREN TO CHEMICALS IN GROUNDWATER: SHOWER SCENARIO
                                             Variable Values
C(sa) - Concennbon in bathroom during showering (ug/m3)
C(w) - Concentration in shower water (ug/l)                95% UCL or maximum concentration (ug/l)
                                             400 tilers/hour
                                             090
                                             0.1 hour
                                             12 meterS
           FL
           VF
           I
           V
 Flow ntt ol shower watar (l/hr)
- Fraction ol contaminant voiatHued
 -Ona half duration of shower (hr)
. Batfwoom votunn (m3)
          EQUATION:

C(«a) .
FL X
C(w) X VF
(u9/rt»3) (l/hr) (ugrt)
C(sa):
Chloroform 4OO 1 784 0
Uethyiene Chloride 400 130
Carbon DisUfcd* 400 2020
Chloroberuana 400 100
Benzene 4OO 3.0
1.1 Dtchtoroethane 4OO 10
CARCINOGENS - GROUNDWATER INHALATION EXPOSURE (0 - 6 YEARS)
Chronic Oaiy Intake. Air X Inhalation X Exposure X
(mg/Vg-day)


Chemicals 	
Chloroform
UMhytana Chloride
Beruen*
Concentration
mg/m3 X

Av
Concenration
514E*00
370E^2
860C03
Rate
06m3/hr X

Inhalation
Rate
06
0.6
0.6
Time
02 hrs/day X

Exposure
Time
02
02
02
(unitless)
090
090
090
090
090
090
Exposure
Frequency
350 days/year

Exposure
Frequency
350
350
350
X 1
(hr)
01
01
0 1
01
01
0.1
X Exposure
Duration
X 6 years

Exposure
Duration
6
6
6
X 1
V
(1/m3)
008
008
008
008
008
008
X 1
Body Weight
X 1
16 kg
Body
Weight
16
16
16

5138
37
582
29
86
29
X t
Averaging Time
X 1
25550 days
Averaging
Time
25550
25550
25550




Chronic Daily
Intake (GDI)
3.2E-03
2.3E-05
5.3E-06




Cancor Slope
Factor (CSF)
8 10E 02
1 70E 03
290E-02
TOTAL RISK -




RISK-
(CDI-CSF)
8.6E-05
3 96 08
1 5E07
8.6E-05
NONCABONOGENS - GflOUNOWATER INHALATION EXPOSURE (0 - 6 YEARS)
Subchronic Dafty W»h*-
(me/ko-day)




1 . t • DiChloroethane
Uathyten* Chtooda
Carbon Oisulfcde
ChlorobertMne
Air X
Concentration
n\n/m1 t
mgrnw A

Atf
Cofkcontration
2AOE-03
3706-02
5826-01
29OE-02
Inhalation X
Rate
0 6 m3/hr X


Inhalation
Rata
06
06
06
06
Exposure X
Time
0.2 hrs/day X


Exposure
Time
02
02
02
02
Exposure
Frequency
350 days/year


Exposure
Frequency
350
350
350
1KH
3bO
X Exposure
Duration
X 6 years


Exposure
Duration
6
6
6

X 1
Body Weight
X 1
16kg

Body
Weight
16
16
16
16

X 1
Averaging Time
X 1
2190 days

Averaging
Time
2190
2190
2190
2190





Subchronic Oaily
Intake (GDI)
21E-05
27E-04
4 2E-03
2 IE 04



Subchronic
Reference
Dose (RID)
100E.OO
860601
2 90E 03
500E 02
HAZARD INDEX -




HO,
GDI/HID
2 IE 05
3 IE 04
1 4E>00
42E03
1 4E.OO

-------
                                                            TABLE  13

                          POTENTIAL FEDERAL CHEMICAL-SPECIFIC ARARs FOR THE JUNCOS LANDFILL
                 Parameters
                 Chloroform
100»
Adjusted FWQC For Drinking Water (2)
              0.19(3)
     Units arc parts per billion (ppb)

     *          MCL for (rihalomethanes as a class of compounds.  Includes chloroform, bromoform, bromodichloromethane and
               dibromochloromelhane.

     (1)        MCLs Fact Sheet: Drinking Water Regulations Under the Safe Drinking Water Act. May 1990.  Table 14.

     (2)        Federal Ambient Water Quality Criteria for protection of Human Health adjusted for drinking water only.

     (3)        FWQC corresponding to a 10E-6 risk level.
C658.1

-------
                                      TABLE 14
           POTENTIAL FEDERAL LOCATION-SPECIFIC ARARs FOR THE JUNCOS LANDFILL
LOCATION
Area effecting stream or
river.
Wetlands
Within area where action
may cause irreparable
harm. loss, or destruction
of significant artifacts.
Historic project owned or
controlled by Federal
agency
REQUIREMENT
Action to protect fish or
wildlife.
Action to avoid adverse
effects, minimize potential
harm and preserve, and
enhance tot he extent
possible.
Action to recover and
preserve artifacts.
Action to preserve historic
properties; planning of
action to minimize harm to
National Historic
Landmarks.
PREREQUISITE(S)
Diversion, channeling, or
other activity that modifies
a stream or river and
effects fish or wildlife.
Action involving
construction of facilities or
management of property in
wetlands.
Alteration of terrain that
threatens significant
scientific, prehistorical.
historical or archaeological
data.
Property included in or
eligible for the National
Register of Historic Places.
CITATION
Fish and Wildlife
Coordination Act (16 USC
641 et esq.); 40 CRF 6.302.
40 CFR Part 6, Appendix
A
National Historical
Preservation Act (16 USC
Section 469); 36 CFR Part
65.
National Historic
Preservation Act, Section
106 (16 USC 470 9Lm-);
36 CFR Part 800
COMMENTS
The Fish and Wildlife
Coordination Act requires
consultation with the
Department of Fish and
Wildlife prior to any
action that would alter a
body of water of the
United States.



CftSR.I

-------
                                                                                       TAlll.K I')
                                                       POTENTIAL FEDERAL ACTION-SPECIK1C ARAKs Ft>K jUNCOS LANDFILL
       Actions
                                     Requirement
                                                        Prerequisites
                                                                                                                     Ciuiion
                                                                                         Comments
Air Stripping
Duign system 10 provide odor free
operation.
                                             CAA Section 101*
                        File an Air Pollution Emission Notice
                        (Af EN) with the Sute to include
                        estimation of emission raics for each
                        pollutant erpected.
                                                                                      /d*y, 10 gal/day, or allowable cmiuion
                        levels from similar sources using
                        Reasonably Available Control
                        Technology (RACT).
                                         Source operation mutt be in an ozone
                                         nonattainmenl area.
                                                                                                              40 CFR sr
                        Verify through emission estimates and
                        dispersion modeling that hydrogen sulfide
                        emissions do not create an ambient
                        concentration greater than or equal to
                        0 10 ppm.
                                                                                                              40 CRF 6lk
                         Odor regulations are intended to limit nuisance
                         conditions from air pollution emissions.
                                                                      Stale wilt hive particular interest in emissions for
                                                                      compounds on Iheir hazardous, lone or odorous list.
                                                                      Preliminary meeting with state prior to Tiling APEN
                                                                      is recommended in the regulation. Meeting would
                                                                      identify additional issues of concern to the Stale.
                         State may identify further requirements for permit
                         issuance after first review. These provisions follow
                         the federal Prevention of Significant Deterioration
                         (PSD) framework with some modifications.
                         Additional requirements could include ambient
                         monitoring and emission control equipment design
                         revisions to match Lowest Achievable Emission
                         Requirements (LACK)

                         While a permit is not required for an onsile
                         CERCLA action, the substantive requirements
                         identified during the permitting process are
                         applicable.     	^^^
                                                                      The control technology review for this regulation
                                                                      (RACT) could coincide with the BACI" review
                                                                      suggested under the PSD program.
                        Verify that emissions of mercury, vinyl
                        chloride, and bcruenc do not exceed
                        levels eirpected from sources in
                        compliance with hazardous air pollution
                        regulations.
                                                                                      40 CFR 61'
                                                                      Regulation 8 indicates any source emitting the
                                                                      regulated compounds is subject to this regulation.
                                                                      However, come of the specific regulations further
                                                                      restrict the scope of applicability.
Direct Discharge of
Treatment System
E/flucat
Applicable federal water quality criteria
for the protection of aquatic life must be
complied with when environmental
factors are being considered.
Surface discharge of treated effluent.
SO PR 30784
(July 29. IMS).
        C658.1

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                                                                                        TABLE   15

                                                       POTENTIAL FEDERAL ACTION-SPECIFIC ARARj FOR JUNCOS LANDFILL
       Actioiu
              Requirement
               Prerequisites
                                                                                                                      Citation
                                                                                                                                                           Comment!
Direct Discharge of
Trcalmc*! System
Efliueaf (GMiinued)
Applicable federally approved Mite water
quality standards musl be complied with.
These standards may be in addition to or
more stringent than other federal
standards under the CWA.
Surface discharge of treated effluent.
40 CFR 122.44 and stale
regulations approved
under 40 CFR 191.
If slate regulations arc more stringent than federal
water quality standards, the state standardi will be
applicable to direct discharge.  The state his
authority under 40 CFR 131 to implement direct
discharge requirements within  the slate, and should
be contacted on a case by-case basis when direct
discharge* are contemplated.
                       The discharge musl be consistent with
                       the requirement of a Water Quality
                       Management plan approved by EPA
                       under Section 20B(b) of the Clean Water
                       Act.
                                                                                       CWA Section 206(6)
                                                                      Discharge must comply with substantive but not
                                                                      administrative requirements of the management plan.
                        Use of best available technology (BAT)
                        economically achievable is required to
                        control tone and nonconvcnlionil
                        pollutants.  Use of best conventional
                        pollutant control technology (BCT) is
                        required to control conventional
                        pollutants.  Technology based limitations
                        may be determined on a casc-by-casc
                        basis.
                                          Surface discharge of treated effluent.
                                             40 CPR 122.44 (a)
                          If treated effluent is discharged to surface waten,
                          these treatment requirements will be applicable.
                          Permitting and reporting requirements will be
                          applicable only if the effluent is discharged at an
                          offsite location.  The permitting authority should be
                          contacted on a case-by
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                                                        POTKNTIAI. KKDKKAL ACTION SPECIFIC AKAIU rX)R JUNCOS LANDFILL
       Action*
                                      Requirement
                                                          Pre requisite*
                                                                                                Citation
                                                                                                                                     Commcnii
Direct Di*charg« of
Treataneol Sytum
Effluent (Cociujaied)
 Approved leu method* for watte
 conatilueni* to be monitored  must be
 followed. Detailed requirement* for
 analytical procedure* and quality control*
 •re provided.

 Permit Application infotmation mutt be
•ubmitted. including a description  of
activities, titling of environmenul
permit*, etc.

Monitor and report remit* a* required by
permit (al lea*! annually).
                                                                                                               40CFR 122.2!
                                                                                                               40CFR I22.44(i)
                       Comply "UK additional permit condition*
                       •uch *•:

                           Duly to miligalc any advene effect*
                           of any discharge.

                           Proper operation and maintenance  of
                           treatment  aytiema.
                                                                                        40CFR I22.4l(i)
                       Develop and implement a Bert
                       Management Practice* (BMP)  program
                       and incorporate  in the NPDES permit to
                       prevent the  releate of toxic coiuiituenl*
                       to aurface water*.

                       The BMP program mun:

                           Eaubli*h tpeciric procedure* for the
                           control of toxic and hazardous
                           pollutant (pill*.

                           Include  a prediction of direction, rale
                           of flow, and loul quality of toxic
                           pollutant* where experience indicate*
                           a rea*on*ble potential for equipment
                           failure.

                           Aourt  proper management of toltd
                           and hazardou* waxe in accordance
                           with regultlioiu  promul^iled  under
                           RCRA
                                          Surface water diacnarge.
                                                                                                               40CFR 125.100
                                                                                        40 CFR 125.104
Theaa IUIMI are determined on a ct*e-by-c*»o ba*i*
by the NPDES permitting authority for any proposed
uirfac* diacharge of treated  waMcwaler.  Although a
CERCLA ail* remedialion  U oat  required to obtain
an NPOES permit for onaiu diachargca to aurface
water*, lh« *ub*unUvo requirement*  of the  NPDES
permit  program muat be met by the remediation
action if powible. The permitting  authority thould
be coiuuhed on • c**«-by-ca*e bail* to detarmine
BMP requirement*.
       C658.I

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                                                                                      TABU: > ^
                                                      rOTKNTIAI. FEDERAL ACTION-SPECIFIC ARARs K>K JUNCOS LANDFILL
       Actions
                                     Requirement
                       Simpk preservation procedures,
                       container materials, and maximum
                       allowable holding times are prescribed.
                                                        Prerequisites
                                          Surface water discharge.
                                                                                                                    Citation
                                                                                                            40 CFR 136.1-1364
                                            Comments
                         These requirements are generally incorporated into
                         pcimils, which are not required for onsile discharges.
                         The subsUnlive requirements are applicable ,
                         however, in that verifiable evidence mult be offered
                         that standards are being met. The permitting
                         authority should be consulted on a ease-by-case basis
                         to determine analytical requirements.
Discharge to POTW*
Pollutants that pass through the POTW
sludge are prohibited.
                       Specific prohibitions preclude the
                       discharge  of pollutants 10 POTWs that:

                       •   Create a Tire or explosion hazard in
                           the POTW.
                       •   Are corrosive (pi I <5 0)
                       •   Obstruct flow resulting in
                           interference.
                       •   Are discharged at a flow rale and/or
                           concentration that will result in
                           interference.
                       •   Increase the temperature of
                           waslewalcr entering the treatment
                           plant that would result in
                           interference, but in no case  raise the
                           POTW influent temperature above
                           1WF(40'C).

                       Discharge must comply with local POTW
                       prcirealmenl program, including POTW-
                       spccific pollutants, spill prevention
                       program requirements, and reporting and
                       monitoring requirements.

                       RCRA permit-by rule requirements must
                       be complied with for discharges of
                       RCRA hazardous wastes to POTWs by
                       truck, rail, or dedicated pipe.
40 CFR 403 5
If any liquid it discharged to a POTW, these
requirement* ire applicable. In accordance with
guidance, • discharge permit will be required even
for • onsile discharge, since permitting is the only
substantive control mechanism available to a POTW.
                                                                                      40 CFR 403 i and local
                                                                                      POTW regulations
                                                                                      40 CFR 264.71 and
                                                                                      40 CFR 264.72
                                                                                                              Categorical standards have not been promulgated for
                                                                                                              CERCLA sites, so discharge standards must be
                                                                                                              determined on a casc-by-casc basis, depending on the
                                                                                                              characteristic* of the waste stream and the receiving
                                                                                                              POTW. Some municipalities have published
                                                                                                              standards for non-categorical, non-domestic
                                                                                                              discharges. Changes in the composition of the wane
                                                                                                              stream due lo pretrealmcnl process changes or the
                                                                                                              addition of new waste streams will require
                                                                                                              renegotiation of the permit conditions.
        C658.1

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                                                                                         TABLE   15

                                                        POTENTIAL FEDF.KAL ACTION-SPECIFIC ARARj POK JUNCOS LANDFILL
       Actioa*
Requirement
                                                          Prerequisites
                                                                                                                        Citation
                                                                                                                                                             CommenU
Operatic* aad
Maialcaaaec (OAM)
 Post-closure ore 10 ensure thai site is
 maintained and monitored.
                                                                          40 CFR 264.1 IB
                                                                          (RCRA. Subp»rt G)
                         Post-closure requirements for openlion and
                         maintenance of municipal landfill sites are relevant
                         and approprUte to new disposal units with
                         nonhazardous waste, or existing units capped in
                         place.

                         In case* where municipal landfill site wastes arc
                         determined lo be hazardous wastes, and new disposal
                         units are created, the post-closure requirements will
                         be applicable.	
Trcatncal
Standard* for miscellaneous uniu (long-
term retrievable storage, thermal
treatment other than incinerators, open
burning, open detonation, chemical,
physical, and biological treatment units
using other than tanks, surface
impoundments, or land treatment units)
require new miscellaneous units to satisfy
environmental performance standards by
protection of groundwater, surface water,
and air quality, and by limiting surface
and subsurface  migration.
                            Use of the units for treatment of hazardous
                            wastes.  These uniu do not meet the
                            definitions for units regulated elsewhere
                            under RCRA.
40 CFR 264
(Subparl X)
The requirement will be relevant and appropriate to
the construction, operation, maintenance, and closure
of any miscellaneous treatment unit (a treatment unit
that U not elsewhere regulated) constructed on
municipal landfill site for treatment and/or disposal
of nonhazardous wastes.

These requirements would be applicable lo the
construction and operation of a miscellaneous
treatment unit for the treatment and/or disposal of
hazardous wastes.
                        Treatment of wastes subject to ban or
                        land disposal must attain levels
                        achievable by best demonstrated available
                        treatment technologies (BOAT) for each
                        hazardous constituent in each listed
                        waste.
                                          Effective date for CERCLA actions is
                                          November 8.1988. for POO I-POOS hazardous
                                          wastes, dioiin wastes, and certain * California
                                          List" wastes. Other restricted wastes have
                                          different effective dates as promulgated in 40
                                          CFR 268.
                                                                          40 CFR 268
                                                                          (Subpan D)
                         These regulations are applicable to the disposal of
                         any municipal landfill site waste that can be defined
                         as restricted wastes.

                         These requirements are relevant and appropriate to
                         the treatment prior to land disposal of any wastes
                         that contain components of restricted wastes in
                         concentrations that make the site wastes sufficiently
                         similar to the regulated wastes.  The requirements
                         specify levels of treatment thai must be attained
                         tprior to land disposal.
OperMioa and
Maintenance (O&M)
Post-closure can lo ensure that site is
maintained and monitored.
                                                                          40 CFR 264.118
                                                                          (RCTA, Subparl G)
                          Post-closure requirements for operation and
                          maintenance of municipal landfill sites are relevant
                          and appropriate lo new disposal units with
                          nonhazardous waste, or existing units capped in
                          place.

                          In cases where municipal landfill site wastes are
                          determined to be hazardous wastes, and new disposal
                          units are created, the post-closure requirements will
                          be  applicable.      	^^^
        C6581

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                                                         TABLE  16




                               POTENTIAL COMMONWEALTH ARAfU Md TBCi FOR THE JUNCOS LANDFILL
REQUIREMENT
OuMiml Prohibitions
General Solid Wast* Facility Prohibitions
Geaenl Prohibition Again* Contamination of Oroundwater
Rut* II • 106 tMlHMH t.rf.hj.k.l
Rule D - 114 Section* d.e.gji.i j
Kmit n-«06
Rut* 1201
General Water Quality Sundarda Ankle 2.1.1
Gcacnl Water Quality Siaadarda 6.1.1
Geiktnl Article 6.1. 2
CITATION
EQB Pact III
Rule 302
EQB Part III
Rule 304
EQB Part 111
Rule 305
OmundwaMr PniUctiim
Landfills
Permit 10 Operate a Nnn-Hazafdous Solid Waste Generating
Activity
Land Disposal Restrictions
Solids and Other Mailer
Pollution of the Waters of Puerto Rico
Discharge of Pollution
DESCRIPTION
General prohibitions and requirements for f enerstioo and handling
of solid wast*.
General prohibitions for solid wane facility r*g aiding floodplains,
endangered species, disease vector* and public safely.
Prohibitions all person* from causing or permitting the
contamination of existing or potential underground drinking water
source. t
Requirements frw gnMndwatar protection at facilities that met,
•lore, or dispose of hazardous waste; Includes sianJsrds,
identification of hazardous constituents, monitoring requirements
for detection and compliance, and corrective action.
General prohibition* tod requirement* for inspection, monitoring
•nd recordkecping, a* well a* disposal of ignitable or reactive
incompatible, bulk, and containerized waste landfills.
General requirement* for application and approval of Permit to
Operate non-hazardous waste generating activities.
Identification of hazardous waste* restricted from Land disposal at
definition of exception and treatment requircmenta.
Prohibits material attributable to discharges which will telile to
from objectionable deposits or which will float in amounts
sufficient to be unsightly or deleterious
Prohibitatpolluiionoflhe Waste of Puerto Rico. ,
Prohibits discharge of water pollution in violation of applicable
rules and regulation* established by Puerto Rko thsl prevents the
attachment of applicable water quality standards.
C6S8.I

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APPENDIX C

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SENT       ox  Telecopier 7021 !  i-28-83  I 3U3PM !          809799S900*            $5061031* 2

           COMMONWEALTH OF PUERTO RICO / OFFICE OF THE GOVERNOR
                          ENVIRONMENTAL QUALITY BOARD
                                SUPERFUND PROGRAM
                                                                September 28, 1993
      Mr. George Pavlou
      Director
      Emergency and Remedial Response Div.
      U.S. Envl;ciu.cntal Protection Agency
      26th Federal Plaza, Room 747
      New York, New York   10278
                                      RE:  ENVIRONMENTAL PROTECTION AGENCY
                                               ENVIRONMENTAL QUALITY BOARD
                                                         CONCURRENCE LETTER
                                                             DECISION SUMMARY
                                                        JUNCOS LANDFILL SITE
                                                         SECOND OPERABLE UNIT
                                                           JUNCOS, PUERTO RICO
      Dew Mr, Pavlou:
            The Puerto Rico Environmental Quality Board (PREQB) received the Decision Summary
      of -.he Juncos Landfill Site, Second Operable Unit or OU-n, Juncos, Puerto Rico on Friday,
      September 24, 1993.  On this document the United States Environmental Protection Agency
      (USEPA) proposed Alternative U: Natural Attenuation/Institutional Controls/Monitoring, as their
      preferred remedial action.

            PREQB's concurs with  this alternative based  primarily  ou the decisions made  on a
      meeting held on July 27,1993 between USBPA and PREQB personnel, PREQB's concurrence
      wa* already communicated to Eng. Jose* Font,  Remedial Project Manager  on a letter dated
      September 1, 1993.
                       Green forwto and cryitalllne water*, clean air and ctar dries,
                             (You protect life If you do bof conUmio*l«1
           NATIONAL BANK PLAZA / 431 PONCE DB LEON AVE. / HATO KEY, PUERTO RICO M917
  FROM C.P.O.-U.S.

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 IK
 :NT
                                                                                Page 2 of 2
            If you have any question regarding this matter please contact Bng, Francisco Qaudio Rfo»,
      Director, Air Quality Area, at phone number* (809) 767-8071 or 767*8056,
                                                                                  Cordially,
                                                                                  Chairman
      VR/inj
      xc:  Mr. Mclv;n Hauptman
          Eng. Carl-Axel P. Sodetberg
          Eng. Josd Pont
          Bng. Francisco Qaudio
FROM C.F.0.-U.S.   EPP
09/23/93  16:35     P.  2

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APPENDIX D

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                     RESPONSIVENESS SUMMARY
                            FOR THE
                         REMEDIAL ACTION
                             AT THE
            JUNCOS LANDFILL SITE,  JUNCOS, PUERTO RICO
                        TABLE OF CONTENTS


SECTION                                                      PAGE

Introduction	   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 Second Operable
         Unit for the Juncos Landfill Site 	   3

     B.  Summary of Written Questions and Responses Received
         During the Public Comment Period 	   9

ATTACHMENT

     Community Relations Activities at the Juncos Landfill Site

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                      RESPONSIVENESS SUMMARY
                       JUNCOS  LANDFILL SITE
                       SECOND  OPERABLE UNIT
                       JUNCOS, PUERTO RICO
INTRODUCTION

This Responsiveness  Summary  summarizes  the public's comments and
concerns and  the U.S. Environmental Protection  Agency's (EPA's)
responses to  those  comments regarding the  Proposed  Plan for the
Second Operable Unit at the Juncos Landfill Site (the Site or the
Landfill)  in  Juncos,  Puerto  Rico.    EPA's  preferred  remedial
alternative for operable unit two (OU-II) is comprised of natural
attenuation of the groundwater, institutional controls consisting
of restrictions on groundwater withdrawal in the  area north of the
landfill,   and  groundwater   monitoring  to   ensure   that   the
concentrations  of contaminants  are decreasing  over time.   EPA
signed a Record of Decision for the Site's first operable  unit (OU-
I) in 1991.  The selected remedy for OU-I is the  installation of a
single-barrier  cap  with a  geomembrane  to control  the  source  of
contamination.

EPA  held a  public   comment  period  from  August  9,  1993 through
September   7,   1993   to   provide  interested   parties  with  the
opportunity to  comment on the OU-II Proposed  Plan for the Juncos
Site.

EPA  held a public  information meeting  to  present its  preferred
remedial  action  alternative  for   addressing  the  groundwater
contamination  at the site.   EPA  held  this  meeting  for  local
residents  and officials  on August  25,  1993 at  7:00  p.m.  in the
Juncos Town Hall, Juncos, Puerto Rico.

EPA conducted the meeting in Spanish because Spanish is  spoken by
the majority  of the local residents.   An EPA Region II  Caribbean
Field Office  staff  member summarized  and translated into Spanish
questions   from  and  responses  to   non-Spanish   speaking  EPA
representatives who  attended the meeting.   EPA distributed copies
of  the  Spanish  Proposed Plan to the  citizens  who  attended the
meeting.  In addition, English and Spanish versions of the Proposed
Plan  were  made  available  to  the public  for  review in  the
information repository,  which is located  at the Juncos Town Hall in
Juncos, Puerto Rico and at EPA's Caribbean Field Office in Santurce
at 1413  Fernandez Juncos Avenue.

Based  on the  tone  of  the  comments  received during  the  public
comment period, EPA believes that the residents and town  officials
of  Juncos  and  the  Puerto  Rico Environmental Quality  Board were
responsive  to  the  Proposed  Plan  and  generally  supported EPA's
preferred alternative for addressing the groundwater contamination
at the Site.  At the public  meeting, citizens  and officials raised
no  major objections  to  the Proposed Plan  or  to EPA's  preferred
alternative.

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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 Juncos Landfill Site.

II.  COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS, COMMENTS, CONCERNS,
     AND RESPONSES;      This sections summarizes the comments EPA
     received during  the public  comment period.   Oral  comments
     received at the public meeting and written comments received
     during  the  public comment  period,  in addition  to  EPA's
     responses to those comments,  are included.

In addition to Sections  I and II, a list of EPA community relations
activities  conducted  at  the   Juncos Site  is  included  as  an
attachment to this Responsiveness Summary.  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 Juncos  has a total population of approximately
25,000 people and is  governed by  a mayor and municipal assembly,
all of whom are elected by ,the  community at  large  to serve four-
year terms.

Most of the industrial  facilities in Juncos are owned by Fomento,
a  Commonwealth  agency  also  known  as the  Puerto Rico Industrial
Development Company.    Fomento  leased the facilities  to  various
businesses, including pharmaceutical firms and other manufacturing
facilities.

Community  involvement regarding the Juncos Landfill  began in May
1971, when a local citizens group filed a  complaint with the Puerto
Rico Department  of Health regarding Landfill operations.  Residents
registered  complaints  of  exposed  waste  materials  and  on-site
burning of these materials.  In addition, residents complained of
mercury contamination  in 1976,  when, as  part of a  legal  action,
employees  reported  that  Becton   Dickinson  disposed  of  broken
thermometers  at  the  Site.   In  March  1976,  a local  newspaper
published  a  story concerning thermometer  waste materials  at the
Site.    Other  citizen  complaints  focused  on  burning  garbage,
windblown trash, air contamination,  Landfill  leachate, thermometer
wastes, and vehicular traffic generated by the Landfill.

In 1979, the Commonwealth of Puerto Rico began the development of
parcels  of  land  immediately   adjacent  to  the Landfill.    The
government sponsored  this  program to allow qualified citizens to
purchase  small  plots of land for minimal cost.   The government
assisted  these  citizens in constructing  homes  on  the parcels of
land.

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In May 1984, the Town of  Juncos  held a public meeting concerning
upcoming  remedial   activities  at  the  Site.    Approximately  70
residents attended the meeting and  expressed  a moderate level of
interest.   In  June 1986, EPA  conducted a public  meeting  at the
Juncos Town Hall to explain the nature of the Site and the scope of
the upcoming Remedial  Investigation  and Feasibility Study (RI/FS).
In June 1991, EPA held a  public meeting for citizens to comment on
the OU-I Proposed  Plan that was  prepared based on  the results of
the OU-I RI/FS.  Approximately 80 residents attended the meeting
and expressed a high level of interest.  In August 1993, EPA held
another  public meeting  for  citizens  to  comment  on the  OU-II
Proposed Plan presenting  EPA's preferred no action  alternative for
the groundwater.

II.  COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS. COMMENTS. CONCERNS
     AND RESPONSES

Public comments on the Proposed  Plan submitted between August 9,
1993 and September  7,  1993 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  into  a single  topic.   Individual commentors and their
questions are identified in the meeting transcript on file in the
information repository.
A.  SUMMARY OF ORAL QUESTIONS AND RESPONSES FROM THE PUBLIC MEETING
CONCERNING THE SECOND OPERABLE UNIT FOR THE JUNCOS LANDFILL SITE

1.   Concerns about the Preferred Alternative

Comment:   A citizen expressed a concern  regarding  the origin of
chloroform in the groundwater.

EPA Response:  Chloroform is one of  the degradation by-products of
landfill waste material.   It could be formed by the chlorination of
methane.    Other  potential  sources  of  groundwater  chloroform
contamination  within the  immediate  area of  the  Site  include,
discharges to  septic  systems,  discharges  of wastewaters to storm
drains including observation of a discharge of what appeared to be
oil  and  spent degreasing  fluids  noted   in  a  storm drain  and
discharge of household wastewater presumably from washing machines.
However,  based on the groundwater  sampling  results from various
locations  and depths, we can  conclude  that  the Landfill  is the
major contributor for the groundwater chloroform contamination.

Comment:   A citizen expressed his concern about the relationship
between capping the Landfill and the groundwater contamination.

EPA Response:  The  source control action under the first operable
unit  selected remedy  of capping  the  landfill  will  reduce  the
potential  threat to human health and the environment by isolating

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the landfill.  This  will  reduce precipitation infiltration which
minimizes  the  potential  for  subsequent  groundwater  impacts.
Natural attenuation will then serve to  reduce the concentration of
chloroform in the  groundwater over time through various physical
and chemical processes.

Comment:  A citizen expressed his concern regarding the potential
impact  of  groundwater contaminants  to the nearby  Public  Supply
Wells.

EPA Response:   The municipal  public water supply  well  field is
located approximately 1.5 miles northwest of the site.  This well
field provides approximately 25% of the drinking water consumed in
Juncos.  Groundwater flows to the north - northeast direction from
the Site.  All operational wells within the Juncos Municipal Public
Water  Supply  Well  Field were sampled and analyzed  for leachate
indicators, EPA priority pollutants  and major cations or anions.
No volatile organic compounds (including chloroform) were detected
at  concentrations  above  the  detection  limit,  and  all  other
parameters were below  federal Maximum Contaminant  Levels (MCLs).
In addition,  sampling of a USGS monitoring well located between the
RI monitoring wells and the Public  Supply Wells showed no presence
of chloroform.  Furthermore,  EPA's preferred  remedy requires the
installation of  a  two-well  cluster  located  between the RI  J-10
wells and the USGS monitoring wells, to serve as an early warning
for chloroform  migration towards  the  public  supply  wells,  even
though it is highly unlikely since the groundwater flow direction
within the site area is northeast.

2.   Length of Time for Remediation

Comment:   A citizen asked  how much  time will  be  required for
chloroform concentrations to reach the MCL after  the capping has
been imp1emented.

EPA Response:  Based on  the results of a groundwater contaminant
transport model  for the overburden  aquifer conducted  by McLaren
Hart, it is estimated that it will  take approximately 13 years for
chloroform concentration reduction  to the MCL  after the capping of
the landfill is completed.   However,  this is only an estimate, and
the  actual  time period  may be  shorter or longer.   Groundwater
monitoring will  take place to make  sure that concentrations are
decreasing.  This reduction will take place by natural attenuation.
Natural  attenuation is  a combination  of  physical  and chemical
processes by which the  toxicity of chloroform is reduced over time.

No  exposure  above  MCLs  will  take  place   since  the  proposed
institutional controls will restrict  access to the site groundwater
from residents in  a potential future use scenario until MCL's are
met.   In  addition, all water  is obtained  from the public supply
wells  locate 1.5 miles northwest of  the Site.

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3.   Groundwater Concerns

Comment:  A citizen requested  a  clarification on how groundwater
flow occurs within the bedrock aquifer.

EPA Response:  Groundwater flow in the bedrock aquifer occurs along
individual fault planes (i.e. fractures) heterogeneously located at
various  depths  below the  ground  surface.    Test  results  and
observations indicate that mineral growths along the fault planes
reduces the amount of ground water flow transmitted to a calculated
value of 5 gallons per minute.

4.   Health-Related Concerns

Comment:  Many  residents asked if  the Site presents a problem to
public health in its current condition.

EPA Response:   Since  1981 when the  Landfill was closed, several
studies have been conducted to evaluate the  nature  and extent of
contamination at  the  Site and to evaluate  any  potential health
threats posed by  the  Site,  specifically to nearby residents.  In
1984  the  Centers for  Disease  Control  (CDC)   assisted EPA  by
evaluating  the  data   collected  during a   preliminary  remedial
investigation geared to determine  if the Site poses an immediate
health  threat  to  nearby  residents.    This investigation  was
performed  under a CERCLA Administrative Order issued  by  EPA to
Becton Dickinson.  CDC's evaluation concluded that the Site posed
no immediate threat to human health.   Then, EPA continued with the
long-term  investigations at  the  site  by  conducting  an  RI/FS
pursuant to another CERCLA  Administrative  Order  issued to Becton
Dickinson.  This study was geared to define  the nature and extent
of  contamination  at  the  site and  included the performance of an
Endangerment Assessment or Risk Assessment which estimated the long
term human health risks which could result from the contamination
at the  site if  no remedial  action were taken under both operable
units  for  the  Site  (i.e.  landfill   source  control  actions,
groundwater remediation).

The Endangerment  Assessment for  both operable units for the Site
evaluated  several potential exposure pathways by which the public
may be  exposed  to contaminant releases from the  landfill under a
current land use scenario  (OU-I) and groundwater under a future use
scenario.

The  potential  exposure  routes   identified   for the   Site  OU-I
included:

•  exposure to contaminants  from ingestion and dermal contact of
contaminated surface soils at the Landfill.

•  inhalation exposure to mercury vapors  emitted from contaminated
soils.

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• hypothetical ingestion, inhalation and dermal contact exposure to
metals and organic compounds from contaminated groundwater beneath
the Site as a source of potable water.

The  potential  exposure  routes   identified  for  the  Site  OU-II
included:

• future exposure to contaminants as a result of ingestion, dermal
contact  (from  showering)   and  inhalation   (from  showering)  of
contaminated groundwater.

Results  of  the  Endangerment Assessments for  both operable units
indicate that under current Landfill conditions and future use of
the contaminated groundwater within the site, the entire Site poses
an  unacceptable carcinogenic  and noncarcinogenic risk  to  human
health.

Implementation  of the 1991 selected  remedy  for  OU-I   (landfill
capping)  and EPA's  preferred  remedy  under  OU-II   (groundwater
remediation)  will  reduce  those  risks  to  acceptable  levels,
therefore, resulting in the  site posing an acceptable risk to human
health and/or the environment.

Comment:  Many citizens claimed to be suffering Site related health
problems.  They  demanded a health study be performed to investigate
their health problems.

EPA Response:  Health effect studies are the responsibility of the
Puerto Rico Department of Health.  However, after the meeting, EPA
requested  assistance from  the Agency  for  Toxic  Substances  and
Disease Registry  (ATSDR)  in evaluating any connection between the
Site  and the health  problems claimed  to  be suffered by Juncos
residents.  ATSDR is already in the process of collecting available
information in preparation  for interviewing the allegedly affected
citizens.

5.   Concerns Regarding First Operable Unit Selected Remedy

Comment:  A citizen asked why EPA's selected alternative for OU-I
calls  for  capping  instead  of removing  the  contaminated  waste
material from the landfill.

EPA Response: The remedial  investigation conducted at the landfill
revealed that the contaminated waste material within the landfill
is heterogeneously distributed throughout; therefore removal of hot
spots was  not appropriate.   Generally,  EPA  does not  excavate and
remove entire landfills because it is technically impracticable and
the   costs   of   removing   such  a  large  volume   of  waste  are
prohibitively expensive.

Comment:  A citizen asked when is the  remedial action for operable
unit  one at the Site,  scheduled to start.

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EPA Response:   Construction of the Landfill  cap  is projected to
start during 1994 and be completed in 1995.

Comment:  Various citizens asked if air releases originating at the
Landfill represent a health problem.

EPA Response:   Air  sampling  for mercury  and priority pollutant
volatile organics was conducted during the  OU-I RI in the vicinity
of the  Juncos Landfill to  assess if the  Landfill  was impacting
ambient air.  Air sampling was also conducted at off-site locations
during drilling  for  health  and safety purposes.  Detected values
were compared to Threshold Limit Values  (TLVs), where applicable.
TLVs  are  concentrations  established  for  worker  safety  during
routine  8-hour  work days.    Three out of  twenty air  samples
indicated inorganic mercury downwind of the Landfill during normal
site conditions.   Concentrations  of inorganic mercury  in  these
three samples ranged from 0.5 -1.2 ug/m3 (for TLVs 0.05 mg/m3) .  All
detected  levels  of  inorganic mercury in  air samples collected at
off-site  locations during drilling activities were below TLVs.

In  addition,  ambient  air  levels  of volatile  organics  during
drilling were approximately one million times below TLVs.  Because
there  were  negligible  differences  between upwind  and  downwind
concentrations,  the  Landfill  does  not  appear to  be  impacting
ambient air  levels with volatile organics.

On August  14, 1991,  EPA was notified by  a  citizen adjacent to the
Landfill  that smoke  was being  released.  Concern was raised about
the potential release of contaminants from the Landfill through the
smoke.   EPA conducted an investigation  on August 16,  1991 which
revealed  that an area  approximately  50  feet by  100  feet  on the
oldest portion of the landfill had apparently subsided.  The grass
in  this  area  was dead and several cracks in the  surface were
venting smoke.   The prevailing winds carried smoke in a westerly
direction parallel  to  La  Ceiba  Community.    The  smoke  observed
during  the investigation dissipated within 50 feet of the burned
area.   Air  sampling results  for mercury  and organic compounds
showed non detectable concentrations for these chemicals.  However,
EPA directed Becton Dickinson and  the Municipality of Juncos to
implement immediate  corrective actions at the site that included
covering  the crevices of the Landfill that were smoking with fill
material.

Comment:   A citizen expressed concern regarding cattle access to
the  landfill  and how  this will  be  prevented to  maintain the
integrity of landfill cap.

EPA Response:  One of the components of the OU-I selected remedy is
the installation of a security fence around the perimeter of the
Landfill  property to restrict  access to  the site.

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6.   Other Concerns Not Related To The site

Comment:  A citizen expressed a concern regarding the potential for
chloroform to represent a problem at every landfill.

EPA Response:  Leachate is generated by water percolating through
a landfill.  The type of contaminants  found in leachate is usually
dependent upon physical, chemical and biological  influences as well
as the  type of  waste disposed.   Leachate usually does contain
hazardous  substances,  which may  or  may not  include  chloroform,
depending upon the type of waste disposed.

Comment:  A  citizen  expressed  a concern regarding the new Juncos
Landfill  (North of  the  site)   operation and  inquired about  EPA
involvement and/or actions taken at this facility. He mentioned an
incident  in  which  8  cows  died while at the new landfill and the
plans  for  converting  this municipal landfill  into  a  regional
facility by the Commonwealth of Puerto Rico.

EPA  Response:    The  U.S.  Environmental  Protection Agency  (EPA)
Region  II Superfund  Program   is  not currently  involved in  any
investigation regarding the  New Juncos Landfill.   This  is an active
solid waste facility  regulated  under the Resource Conservation and
Recovery  Act   (RCRA),  Subtitle  D  regulations  and  under  the
Commonwealth of Puerto Rico Environmental Quality Board regulations
for solid wastes.

In addition EPA has recently  promulgated the  revisions to  the
Criteria for Classification of  Solid Waste Disposal Facilities and
Practices  set  forth  in   40   CFR part  257.    This  regulation
establishes the federal minimum criteria  for municipal solid waste
landfills,  including location   restrictions,  facility design  and
operating criteria, groundwater monitoring requirements, corrective
action requirements,  financial  assurance requirements, and closure
and post  closure requirements.   This  new federal regulation will
become  effective on  October   9,  1993.   All  current and  future
activities at the New  Juncos Landfill will be  subjected  to these
regulations.

B.  SUMMARY OF WRITTEN QUESTIONS AND RESPONSES RECEIVED DURING THE
    PUBLIC COMMENT PERIOD

EPA received the following written comments from the Commonwealth
of Puerto Rico Agencies:

Comment:   Well  CJ-TW6  (USGS monitoring well)  is too  far  from the
site to serve as an early  warning  of contaminant migration towards
the Public  Supply Well Field.

EPA Response:  A well cluster  composed of two monitoring wells at
different  depths  is  required  to be installed  under the preferred
alternative in a location  between monitoring wells J-10 and CJ-TW6.

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This well cluster will better serve the purpose of an early warning
for groundwater plume migration towards the public supply wells.
It is unlikely for contaminants  in  groundwater originated at the
landfill to migrate toward the Public Supply Wells since they are
located northwest of  the site  and groundwater  flow direction is to
the northeast.

Comment:  EQB expressed concern about leachate flowing out of the
landfill.

EPA Response:  The OU-I selected remedy will address the leachate
generation issue in two ways.   First, by capping the landfill the
leachate generation  should be  significantly reduced by isolating
the  landfill . therefore  avoiding   the  infiltration  of  surface
precipitation.     Second,   the  selected   remedy   includes  the
installation of a leachate control system, as necessary.

Comment:  Chain of custody records were not followed correctly.

EPA Response:  All sampling data had been Quality Assure/Quality
Control  audited  and validated  according to  EPA  guidances  and
protocols established within the EPA approved  Site Operations Plan
for the Site.

Comment:   The Puerto Rico Aqueduct  and  Sewage Authority (PRASA)
does  not  endorse any remedial  action at a  Superfund  Site  which
proposes to use their systems.

EPA  Response:    The  preferred  remedy  under  OU-II  does  not
contemplate the use  of PRASA systems for discharge or disposal of
any waste streams originating from the Site since the groundwater
action only includes monitoring.

Comment:  The Puerto  Rico Department of Natural Resources requested
a more precise description of the area targeted for restrictions on
groundwater withdrawal.

EPA  Response:   The targeted  area  for groundwater  withdrawal
restriction includes groundwater in the area north of the Landfill
until it reaches the Gurabo River in the north direction with east
and west  boundaries  defined by the  two unnamed creeks running on
both  sides  to the  Landfill  towards  the  north.   The  southern
boundary  is determined by the landfill southern perimeter.

Comment:   The Commonwealth  of Puerto Rico Industrial Development
Company expressed concern regarding  the length of time required for
groundwater withdrawal  restrictions and  its impact  to the future
industrial development within the area.

EPA  Response:   The area  in which  the groundwater  withdrawal
restrictions  are to be imposed pursuant to  the OU-II selected
remedy  is already developed with housing projects.  Therefore, no

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impact to the  industrial  development of the  area  is expected to
result from this action.

Furthermore, according to PRASA, future demand for water within the
Municipality of  Juncos is projected  to be supplied through the
construction of a surface water reservoir and filtration plant at
the Valenciano River.
                                10

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                           ATTACHMENT

                  COMMUNITY RELATIONS  ACTIVITIES
                        AT JUNCOS  LANDFILL
Community relations  activities conducted at  the  Juncos Landfill
Site to date have included the following:


     •    EPA conducted community interviews with local officials
          and interested residents.   (April 1984)

     •    The Town of Juncos held a public meeting  at the Town Hall
          concerning  upcoming remedial  activities  at  the Site.
          Approximately  70  people attended,  including citizens,
          elected    officials,   and   technical    and    legal
          representatives of the responsible party.   (May  1984)

     •    EPA prepared a Revised Community Relations Plan  for the
          Juncos Landfill to reassess community concerns.   (August
          1984)

     •    EPA conducted a public meeting at the Juncos Town  Hall to
          explain  the nature  of  the Site  and the  scope  of the
          upcoming remedial investigation.  (June 1986)


First Operable Unit
          EPA established an information repository at the Juncos
          Town Hall.  Copies of documents at the  repository were
          placed  in files in  EPA's offices in  Santurce and New
          York.   (1988)

          EPA  made  Spanish  translations  of  the  Proposed  Plan
          available  for  public review and comment.   The Proposed
          Plan is in the information  repository.  (June  1991)

          EPA publicized and held a public meeting at the Juncos
          Town Hall to describe the RI/FS report  and Proposed Plan
          and to respond to citizen  concerns.  A Spanish transcript
          of the  proceedings of this meeting is available in the
          information repository.   (June 1991)

          At citizens'  requests,  EPA extended the public comment
          period  on  the Proposed  Plan.  The public  comment period
          lasted  60  days, from June 1,  1991 to July 30,  1991.
                                11

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          EPA prepared  a  Responsiveness Summary to  document its
          responses  to  all of  the public  comments  received  in
          writing and at the public meeting.  (August 1991)
Second Operable Unit
          EPA established an information repository at the Juncos
          City  Hall  in  Juncos,  Puerto  Rico.    Copies  of  the
          documents in the repository were also placed in files in
          EPA's offices in San Juan,  and New York (1993).

          EPA  made  Spanish  translation  of  the  Proposed  Plan
          available for public review and comment.   The Proposed
          Plan  is  part of  the  information  repository.   (August
          1993)

          EPA publicized and held a public  meeting  at the Juncos
          Town  Hall  to describe the  second operable  unit  RI/FS
          Report  and Proposed  Plan  and  to  respond to  citizen
          concerns.   A  Spanish transcript of the  proceedings of
          this meeting is available in the information repository.
          (August 1993)

          EPA prepared a Responsiveness Summary to  document its
          response  to all  of the  public  comments received  in
          writing and at the public meeting.  (September 1993)
                                12

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APPENDIX E

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                                             Final  05/19/93
                      JUNCOS LANDFILL SITE
                        OPERABLE UNIT TWO
                   ADMINISTRATIVE RECORD FILE
                       INDEX OF DOCUMENTS
1.0  SITE IDENTIFICATION

1.5  Previous Operable Unit Information

P.   100001-   Plan:  Remedial Design Work Plan for Selected
     100151    Remedial Alternative. Juncos Landfill Superfund
               Site. Juncos. Puerto Rico, prepared for
               Becton Dickinson Puerto Rico, Inc., Browning
               Ferris Industries of Puerto Rico, Inc., RCA
               Corporation/General Electric Company, prepared
               by McLaren/Hart Environmental Engineering
               Corporation, Pittsburgh, Pennsylvania, February,
               1993.

P.   100152-   Administrative Order for Remedial
     100191    Design/Remedial Action, September 30, 1992.

P.   100192-   News Release:  EPA Selects Remedies at Three
     100194    Superfund Sites in Puerto Rico,  as prepared by  EPA
               Region II,  for release:  Wednesday, October 23,
               1991.

P.   100195-   Letter to Ms. Kathleen  Callahan, Director
     100197    Emergency and Remedial  Response  Division,  United
               States Environmental Protection  Agency  (USEPA)
               Region II,  from Mr.  Pedro Maldonado,  Acting
               Chairman, Puerto Rico Environmental Quality Board
                (PREQB) , re:  Environmental  Protection Agency
                (EPA) Declaration  for Record of  Decision (ROD)
               of Juncos Landfill Site, Juncos, Puerto  Rico.
               PREQB concurs with USEPA  selected  alternative and
               requests specific  information on all  future
               activities  of the  site, September  10,  1991.

 P.    100198-  Letter  to Mr. Jose Font,  USEPA Caribbean Field
      100229   Office,  Santurce,  Puerto  Rico,  from Mr.  Edwin A.
               Hernandez,  Comite  Jungueno  Pro Rescate del Medio
               Ambiente, Juncos,  Puerto  Rico,  re:   Community
                organization's  recommendations for remedial  action
                (attached), July  29,  1991.   (Note:   Documents in
                Spanish).

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P.   100230-   Letter to United States Environmental Protection
     100231    Agency, Region II,  Emergency and Remedial Response
               Division, from Senora Carmen H., private citizen,
               re:  Response to lack of information from local
               authorities and request for cooperation and
               assistance, July 18, 1991.

P.   100232-   Index:  Operable Unit One, Juncos Landfill Site
     100261    Administrative Record.  This Administrative Record
               is located at Juncos Town Hall, Juncos, Puerto
               Rico;  United States Environmental Protection
               Agency Caribbean Field Office, 1413 Fernandez
               Juncos Avenue, Santurce, Puerto Rico, 00909;
               United States Environmental Protection Agency,
               Records Center, Room 2900, 26 Federal Plaza, New
               York, New York, 10278, June 20, 1991.

P.   100262-   Letter to Hon. Jose Font, Gerente de Proyecto,
     100264    Agencia Federal Proteccion Ambiental, from
               Senora Carmen H., private citizen, re:  Series of
               questions and concerns about declining land value,
               water contamination, and past harm resulting from
               her home's proximity to the site, June 20, 1991.
                (Note:  Document in Spanish).

P.   100265-   Transcript of public meeting on the Proposed
     100372    Superfund Remedial Action Plan  for Juncos Landfill
               Site, presided over by Mr. Jose Font, Remedial
               Project Manager, United States Environmental
               Protection Agency, Caribbean Regional Office, June
               15,  1991.   (Note:  Document in  Spanish).

P.   100373-   List of Attendees, re:  Proposed Remedial Action
     100378    Plan Public Meeting, June 15,  1991.

P.   100379-   Proposed  Plan for Juncos  Landfill  Site,  issued  by
     100393    United States Environmental Protection Agency,
               Region II, June, 1991.

P.   100394-    Letter to Mr.  Jose  Font,  Environmental  Engineer,
     100394     from Pedro A.  Maldonado Ojeda  Esq.,  Acting
                Chairman,  Puerto Rico Environmental  Quality Board,
                Santurce,  Puerto Rico,  re:  Environmental
                Protection Agency  (EPA),  "Proposed Preferred
                Alternative Plan",  Juncos Landfill Site, Juncos,
                Puerto Rico,  May 31,  1991.

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3.0  REMEDIAL INVESTIGATION

3.4  Remedial Investigation Reports

P.    300001-   Letter to Mr. Erwin Smieszek, TES V Regional
     300234    Project Officer, United States Environmental
               Protection Agency, from Mr. Scott Graber, COM
               Federal Programs Corporation, re:  Attached Final
               Endangerment Assessment. Juncos Landfill operable
               Unit Two. Juncos. Puerto Rico.  Attachment A:
               Letter to. Ms. Jill Naugle, COM Federal Programs
               Corporation from Mr. Jose C. Font, Environmental
               Engineer, re:  EPA's comments on the Draft
               Endangerment Assessment, Juncos Landfill OU2,
               October 19, 1992, November 10, 1992.

P.    300235-   Report:  Final Phase II Remedial Investigation
     300604    Report. Juncos Landfill. Juncos. Puerto Rico.
               prepared for Becton Dickinson Puerto Rico Inc.,
               Juncos, Puerto Rico, prepared by McLaren/Hart
               Environmental Engineering Corporation, Warren, New
               Jersey, July, 1991, REVISED November, 1991,
               REVISED April, 1992.
7.0  ENFORCEMENT

7.5  Affidavits

P.   700001-   Letter to Mr.  Jose  C.  Font,  Caribbean  Field
     700003    Office, United States  Environmental  Protection
               Agency, from Mr.  Luis  Lomba,  Country Manager,
               Micropette,  Inc., re:   Cecilio Miranda Sworn
               Statement.   September  21,  1992.   Attachment:
               Affidavit signed  by Cecilio  Miranda, September  21,
               1992.   (Note:   Document in Spanish).

P.   700004-   Witness Interview Summary  of Mr.  Jose  Martinez
     700004    Agosto, former landfill employee, now  retired.
               Conducted by Mr.  Jose  C. Font, site  RPM,  at
               witness residence in Juncos,  June 24,  1992.

P.   700005-   Witness Interview Summary  of Mr.  Carmelo Miranda,
     700005    former private waste hauler,  now retired.
               Conducted by Mr.  Jose  C. Font, Juncos  Landfill
               Site Remedial  Project  Manager (RPM), at Becton
               Dickinson plant in Juncos, June 10,  1992.

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       P.    700006-   Witness Interview Summary of Mr7 Luis Rogel
            700006    Mojica, former landfill employee, now retired.
                      Conducted by Mr. Jose C. Font,  site RPM,  at Beeton
                      Dickinson plant in Juncos, June 10, 1992.

       P.    700007-   Witness Interview Summary of Mr. Ismael Melendez
            700008    Arias, former landfill employee, now retired.
                      Conducted by Mr. Jose C. Font,  site RPM,  at Becton
                      Dickinson plant in Juncos, June 10, 1992.
       7.8  correspondence

       P.   700009-   Letter from Mr. Henry Guzman, Assistant Regional
            700011    Counsel, United States Environmental Protection
                      Agency Region II,' re:  CERCLA 106 Administrative
                      Order Juncos Landfill Site, Juncos, Puerto Rico,
                      October 9, 1992.  Attachment:  List of Addressees,

       P.   700012-   Letter to Mr. Gamaliel Rodriguez Mercado,
            700014    Executive Director, Administracion de Desarrollo y
                      Mejoras de Vivienda, Hato Rey, Puerto Rico, from
                      Mr. Henry Guzman, Assistant Regional Counsel,
                      USEPA Region II, re:  CERCLA 106 Administrative
                      Order for Remedial Design/Remedial Action
                      ("RD/RA"), Juncos Landfill Superfund Site, Juncos,
                      Puerto Rico, October 9, 1992.

       P.   700015-   Memorandum to Juncos Landfill OU2 Site file from
            700015    Mr. Jose C. Font, Environmental Engineer, Air and
                      Hazardous Substances Staff, re: Issuance of
                      unilateral order, Juncos Site OU2, for
                      implementation  of September, 1991 Record of
                      Decision, October 6, 1992.

       P.   700016-   Letters to Browning-Ferris Industries of Puerto
            700025    Rico, Inc.; RCA Barinquen, Inc.; Mr. Mathew
                      Bigley, Manager for  Safety and Loss Prevention,
                      Becton  Dickinson and Company; Prince Matchabelli
                      Co. c/o Chesebrough-Pond's,  Inc.; and Mr. Rafael
                      Betran  Pena, Mayor,  Municipality of Juncos, Puerto
                      Rico, from Ms.  Kathleen C. Callahan, Director,
                      Emergency and Remedial Response Division, USEPA
                      Region  II, re:   Special Notice for Remedial
                      Design/Remedial Action  ("RD/RA"), Juncos Landfill
                      Site, Juncos,  Puerto Rico, December 31,  1991.
O

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