PB96-963817
EPA/ROD/R02 96/284
December 1996
EPA Superfund
Record of Decision:
Barceloneta Landfill Site,
(Florida Afuera Ward), Barceloneta, PR
7/5/1996
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RECORD OF DECISION
Barcelonets Landfill Site
Barceloneta, Puerto Rico
United States Environmental Protection Agency
Region II
New York, New York
July 1996
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DECLARATION FOR THE RECORD OF DECISION
SfTTE NAME AND LOCATION
Barcelooeta Landfill
Florida Afuera Ward
Barceloneta, Puerto Rjco
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) documents the U.S. Environmental Protection Agency's (EPA's) selection
of the remedial action for the Barceloneta Landfill Site in accordance with the requirements of the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), as
amended, and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This
decision document summanzes the factual and legal basis for selecting the remedy for this Site.
The Puerto Rico Environmental Quality Board (EQB) concurs with the selected remedy (see Appendix
IV).
An administrative record for the Site contains the documents that form the basis for EPA's selection of the
remedial action, the index for which is attached as Appendix III.
ASSESSMEm- OF THE SITE
Actual or threatened releases of hazardous substances from the Site, if not addressed by implementing
the response action selected in this ROD, may present an imminent and substantial endangerment to
public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The primary objective of this remedy is to control the source of contamination at the Site and to reduce
and minimize the migration of contaminants into Site media thereby minimizing any health and
environmental impacts.
The major components of the selected remedy include the following:
Installing a lew permeability cover system for the three landfill cells meeting the requirements of
the Resource Conservation and Recovery Act Subtitle D and Puerto Rico's Regulations Governing
Landfill Gosune . This cover system or landfill cap(s) will further reduce infiltration of precipitation
water into the landfill and reduce teachate generation thus mitigating impacts to ground water.
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Regrading the Site and installing storm water management improvements at the Site to reduce
infiltration of storm water into the landfill and reduce leachate generation.
Conducting long term ground water and surface water monitonng to evaluate the effectiveness
of the cover system. It is anticipated that monitoring will be conducted on a quarterly basis for
the first year, semi-annually for the next four years, and then annually. Monitoring will include
the eight existing monitoring wells. Initially, the wells will be sampled for a broad parameter list.
The list was developed based on constituents detected above Safe Drinking Water Act Maximum
Contaminant Levels in the Remedial Investigation and cm the requirements erf the Resource
Conservation arid Recovery Act Subtitle D and Puerto Rico's Regulation Governing Landfill
Closure (RMNHSVV). After the first five years, the parameter list would be reviewed and those
parameters not detected above standards would be omitted. The exact long term ground water
monitonng program will be further defined during remedial design (RD)
Conducting a landfill gas survey dunng predesign to determine the necessity of a landfill gas
collection system. The appropriate type erf system, if necessary, will be determined during RD.
Implementing a long term operation and maintenance program for the cover system which will
include inspection of the system and provision for repair.
Recommending to appropriate authorities that institutional controls be empiaced. Institutional
controls are recommended in order to protect the integrity of the landfill cover system and to
reduce potential exposure to landfill contents. The institutional controls will include recommend-
ing that zoning restrictions be applied to the Site to limit future land use and recommending that
a deed restriction be established to limit future land and ground-water use.
Installing a penmeter fence with signs to restrict access.
Reevaluating Site conditions at least once every five years to determine if a modification of the
selected remedy is necessary.
DECLARATION OF STATUTORY DETERMINATIONS
The selected remedy is protective erf human health and the environment, complies with federal and state
requirements that are legally applicable or relevant and appropriate to the remedial action, and is cost
effective. This remedy utilizes permanent solutions and alternative treatment technologies to the
maxMTMTi exiert practicable, gven the scope of the action. However, because the contaminant source,
the Site itself, could not be effectively excavated and treated as a result of the volume of waste and the
absence of hot-spcc representing major sources of contamination, the selected remedy does not satisfy
the statutory preference for treatment as a principal element of the remedy. Since this remedy will allow
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hazardous substances, pollutants, or contaminants to remain on-site above health-based levels, a review
of this remedy will be conducted at least once every five years after the initiation of the remedial action
to ensure that the remedy continues to provide adequate protection of human health and the
environment.
Jeanne M. Fox ,
Regional Administrator'
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RECORD OF DECISION FACT SHEET
EPA REGION II
Site:
Site name: Barceloneta Landfill
Site location: Barceloneta, Puerto Rico
HRS score: 62.5 dated August 3, 1982.
listed on the NPL: September 1st, 1983.
Record of Decision:
Date signed:
Selected remedy: Containment
Estimated Construction Completion: two years
Capital Cost: $5,453,200
O & M Cost: $236,207/yr
Present-worth O&M Cost (5% discount rate for 30 years): $4,836,800
Total Cost: $10,290,000
lead:
U.S. Environmental Protection Agency (enforcement lead)
"Primary Contact: Luis E. Santos (787) 729-6951
Secondary Contact: Melvin Hauptman (212)637-3952
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Main PRPs:
Abbot Laboratories,
American Cyanamid Company,
Browning-Ferris Industries of Puerto Rico, Inc,
E.I. Du Pont de Nemours & Company,
Merck & Company, Inc.,
Roche Products, Inc.,
Schering Pharmaceuticals Corp.,
Sterling Pharmaceuticals Inc.,
Town of Barceloneta,
Union Carbide Corporation &
Upjohn Manufacturing Co.
Waste:
Waste type: municipal solid waste with metals and volatile organics
Waste origin: households and industries
Estimated waste quantity: 500,000 yd5
Contaminated medium: ground water
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RECORD OF DECISION
DECISION SUMMARY
Barceloneta Landfill
Barceloneta, Puerto Rico
United States Environmental Protection Agency
Region II
New York, New York
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TABLE OF CONTENTS
PACE
SITE NAME, LOCATION AND DESCRIPTION 1
SITE HISTORY AND ENFORCEMENT ACTIVITIES 2
HIGHLIGHTS OF COMMUNITY PARTICIPATION . 2
SCOPE AND ROLE OF RESPONSE ACTION 3
SUMMARY OF SITE CHARACTERISTICS 4
SUMMARY OF SITE RISKS 7
REMEDIAL ACTION OBJECTIVES 8
DESCRIPTION OF REMEDIAL ALTERNATIVES 8
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES .13
SELECTED REMEDY 17
STATUTORY DETERMINATIONS 18
DOCUMENTATION OF SIGNIFICANT CHANGES 19
ATTACHMENTS
APPENDIX I.
APPENDIX II.
APPENDIX III.
APPENDIX IV.
APPENDIX V.
FIGURES
TABLES
ADMINISTRATIVE RECORD INDEX
STATE LETTER OF CONCURRENCE
RESPONSIVENESS SUMMARY
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SITE NAME. LOCATION AND DESCRIPTION
The Barceloneta Landfill,an active non-hazardous domestic and industrial waste facility, is
located in Barceloneta, Puerto Rico on the north coast of the island, approximately 20 miles
due west of San Juan. The Landfill is about 4.5 kilometers south of the town of Barceloneta
in Florida Afuera Ward. The entire property which comprises the Barceloneta Landfill is
approximately 32.6 hectares (60.6 acres) in size and is owned by the Municipality of Barc-
eloneta. The Landfill is surrounded by a tropical forest. The Quebrada Cimarrona, a
tributary of the Rio Grande de Manati, is located 0.8 kilometers north of the landfill. A
small residential area of approximately 150 residences in Barrio Bajura Adentro is located
approximately one kilometer east of the Site. Approximately two kilometers north of the
Site, in an area with more gentle topographic relief, there are a series of manufacturing
facilities. The nearest village is Cruce Magueyes, located approximately two kilometers to
west-north-west of the Site. The residences in the area of the landfill are served by a
public supply system that uses ground water as a source.
The Site comprises three separate waste disposal areas (the northern, southern, and
southeastern), a borrow area, and a dirt access road. The northern disposal area (NDA) is
separated into two sections by the access road, the southern disposal area is also known
as the Superfund disposal area (SFDA) or "El Superfondo". Both the northern and southern
disposal areas are filled and inactive. The southeastern disposal area (SDA) is still active,
and is expected to reach capacity in another 2 years, depending on final grading plans.
Although the southern disposal area is known as the SFDA, all three areas are considered
to be part of the Superfund National Priorities List (NPL) site. The three waste disposal
areas comprise approximately six hectares (15 acres). Each disposal area is located in a
depression referred to as a "sumidero" (sinkhole) that is surrounded by conical limestone
hills referred to as "mogotes". See Figure 1.
The Landfill is located in a belt of rugged karst topography that extends along the north
coast from 30 kilometers (19 miles) east of San Juan to the west of the island. In the
vicinityof the Site, this belt is located from about one kilometer south of the coast to about
20 kilometers (12 miles) inland. North (seaward) of this rugged karst region is a belt of
relatively flat coastal plain sediments. South (landward), the rugged karst terrain transitions
into the central mountainous core of the island. Features of this karst landscape include
numerous sumideros, steep scarp cliffs on the mogotes and adjoining ridges which
surround the sumideros, and a lack of surface streams or drainage features associated with
individual sumideros.
The Site is underlain by the northern limestone province of Puerto Rico which consists of
blanket deposits, the Aymamon Limestone, the Aguada Limestone, the Cibao Formation,
and the Lares Formation. Groundwater exists under unconfined conditions in the Aymamon
and Aguada Limestones and under confined conditions in the Cibao and Lares Formations.
Groundwater flow is to the north.
Groundwater in this area of the northern province discharges to the Rio Grande de Manati
(river) and the Cano Tiburones (wetlands) which are 2.7 kilometers (1.7 miles) north of the
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Site. Groundwater also feeds the Ojo de Guiilo spring located 1 kilometer (0.6 miles)
northeast of the Site.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The 32,6-hectare (80.6 acres) area where the Barceloneta Landfill is located was purchased
by the municipality of Barceloneta as three separate parcels during the early 1970s.
Preparation of the Site for landfill use began in April 1972, and the landfill operations com-
menced in August 1973. During operation of the landfill from 1973 to date, three
depressions have been used for waste disposal. Reportedly, the landfill was initially
approved to receive both municipal and industrial waste. (Ebasco Services, Inc. June 1990).
Beginning in 1975, disposal in the Landfill was restricted to municipal waste only. However,
disposal of industrial wastes reportedly continued. Specific dates of active fillingin each of
the three disposal areas are difficult to determine given the lack of record keeping at the
Site. The EQB has information which indicates that the entire Landfillwas used in the late
1970's (prior to the passage of the Resource Conservation and Recovery Act) for disposal
of wastes which contained hazardous substances.
Personnel from EQB and the Department of Health conducted numerous inspections of the
Site and listed various violations. These violations included insufficient cover material;
allowing refuse to burn; the presence of flies, rats and mosquitoes; allowing unlimited
access to the landfill, and allowing people to inhabit structures in the landfill.
The Site was proposed for inclusion on the NPlin December 1982, and was subsequently
approved and listed as an NPLsite in September 1983. In 1984, a Remedial Action Master
Plan (RAMP) was prepared by an EPA contractor for the Site (NUS, 1984). Based on the
RAMP, a Remedial Investigation and Feasibility Study ( RI/FS) Work Plan was developed
(Ebasco Services, Inc., June 1990). In September 1990, the Consent Order was signed in
which the potentially responsible parties (PRPs) agreed to perform the RI/FS for the Site.
Pursuant to the Work Plan, sampling of subsurface soils, ground water and surface water
was completed. The first phase of the Rl was completed in 1992 and the second phase
of the Rl field work was completed in January 1994. A final Rl report was received by EPA
in March 1995 and the streamlined Risk Assessment (Abbreviated Risk Assessment) was
completed in May 1995. An abbreviated FinalFS was conducted in accordance with EPA's
Presumptive Remedy approach (this is discussed in further detail in the "Scope and Role
of Response Action" section). The FS was received by EPA in September 1995.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Rl report, FS report. Abbreviated Risk Assessment and the Proposed Plan for the Site
were released to the public for comment on December 27,1995. These documents were
made available to the public in the administrative record file at four information repositories
maintained at the Sixto Escobar Municipal Library, Barceloneta, P.R.; U.S. Environmental
Protection Agency, Caribbean Field Office, Centro Europa Building; U.S. Environmental
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Protection Agency, Region II Office Superfund Record Center in New York City; and Puerto
Rico Environmental Quality Board. The notice of availability for the above-referenced
documents was published in the San Juan Star, El Nuevo Dia on December 27, 1995 and
El Periodico El Norte on December 28, 1995. The public comment period on these
documents was held from December 27, 1995 to January 26, 1996. In addition, over the
last four years EPA has conducted numerous public meetings and maintained contact with
local concerned groups as well as the community at large.
On January 18, 1996, EPA conducted a public meeting at the Tosas Ward's Christian
Pentecostal Church, to inform local officials and interested citizens about the Superfund
process, to present the Proposed Plan for the Site including the preferred alternative for
remediation of the Site, and to respond to any questions from area residents and other
attendees. The comments received at the public meeting generally focused on drinking
water contamination, implementation schedule, and Site-related risks. Responses to the
comments received at the public meeting and in writing during the public comment period
are included in the Responsiveness Summary (see Appendix V).
SCOPE AND ROLE OF RESPONSE ACTION
The primary objectives of the selected action are to control the source of contamination at
the Site, and reduce and minimize the migration of contaminants into Site media thereby
minimizing any health and ecological impacts.
EPA is considering containment as the appropriate technology to address conditions at the
Site based on the findings of the Rl study. The Abbreviated Risk Assessment showed levels
of contaminants found at the Site pose a relatively low long-term threat to public health and
the environment. A municipal landfill, such as the Barceloneta Landfill, is a type of site
where removal of waste is not practical because of the large volumes of waste and the
diverse mixture of waste, e.g., municipal waste with industrial waste. The National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), which prescribes the rules for
implementing the Superfund Law, provides for the use of engineering controls, such as
containment at sites where the waste poses a relatively low long-term threat or where
treatment is not practical.
Under ordinary circumstances, EPA would have conducted an FS as the next step in the
Superfund process to evaluate alternative cleanup methods (remediation) for the Site. In
the case of the Barceloneta Landfill,which is a municipal landfiIIand where treatment is not
practical, an abbreviated FS was conducted in accordance with EPA's Presumptive Remedy
approach. Presumptive remedies are preferred technologies for common categories of sites,
based on historical patterns of remedy selection and EPA's scientific and engineering
evaluation of performance data on technology implementation. For CERCLA municipal
landfills, containment is the presumptive remedy. Containment under the Presumptive
Remedy approach may include the following components: landfillcap, control of affected
groundwater at the perimeter of the Landfill,leachate collection and treatment, and landfill
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gas collection arid treatment. A complete description of the Presumptive Remedy Guidance
for municipal landfill sites can be found in EPA's Directive No, 9355.0-49FS. EPA 54Q-F-93-
035. Presumptive Remedy for CERCLA Municipal Landfill Sites, dated September 1993.
SUMMARY OF SITE CHARACTERISTICS
The R! was conducted in two phases. Phase I of the Rl was conducted from 1991 through
1992 by Paul C. Rizzo Associates (Rizzo), and is described in the Site Characterization
Summary Report (SCSR) dated September 1992. Phase II of the Rl was conducted during
1993 through 1994 and is described in the Revised SCSR dated May 1994. Phase II of the
Rl was initiated by Rizzoand was completed by Colder Associates.
The objectives of Phase I of the Rl were to evaluate the nature and extent of potential
impact from site waste materials and to characterize potential contaminant migration
pathways. Therefore, the Phase I investigation focused on characterizing geologic and
hydrogeologicsite conditions, evaluating the characteristics and extent of waste materials,
and collecting representative samples to characterize soils and groundwater conditions at
the Site. Specific field investigation efforts conducted at the Site included the following
activities:
- Waste delineation borings;
-Leachate sampling;
-Vadose zone soil sampling;
-Drillingand monitoring well installation;
-Water level measurements;
-Groundwater sampling and analysis;
-Spring survey;
-Public and private well survey; and
-Topographic mapping and site surveying.
After the results of Phase I were reviewed, EPA determined that additional investigations
(Phase II) were necessary in order to provide enough information to complete the Rl.
The additional activities performed during Phase II included:
-Redevelopment of monitoring wells;
-Additional measurement of groundwater elevations;
-Collection of two rounds of groundwater samples from eight on-site monitoring wells, the
Ojo de Guillo spring and one off-Landfill well;
-Performance of slug tests on the eight monitoring wells to evaluate the hydraulic
conductivity of the two water bearing units identified;
-Collection of 15 additional background soil samples for chemical analyses;
-Collection of 3 soil samples for geotechnical analyses; and
-Performance of further waste delineation in the Superfund Disposal Area.
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This section summarizes the findings of the Rl. A summary of the analytical data collected
for the Site, listed by chemical and medium, can be found in Appendix II.
Waste Characterization
The SDA is locally called " El Superfondo". The disposal area encompasses approximately
0.9 hectares (2.2 acres) of surface area. During the Phase I Site Characterization
Investigation (Rizzo,Sept. 1992), four soil borings ( S5-11, SS-11 A, SS-11B, and SS-12) were
installed in this disposal area to delineate the extent of waste material. Soil boring SS-12,
drilled in the southeastern portion of the depression, encountered waste to a depth of 15.3
meters (50 feet). No waste material was encountered in the other three soil borings, which
were located in the northwestern portion of the depression. Apparently, waste fillingwas
restricted to the deeper part of the asymmetric depression in the southeastern portion of
the depression. To verify this, additional waste delineation activities were performed during
the Phase II Site Characterization Investigation, including excavation of two trenches and
installation of five shallow soil borings to define the northwestern extent of waste in the
depression. The two trenches extended from near the northern and western mogote walls
toward the center of the sumidero to the location where waste was encountered. Three
of the soil borings (SB-1 to SB-3) encountered native soil with no waste material. The
southern most soil boring(SB-4) encountered waste material. Soil boring SB-5 encountered
non-waste fill material.
The waste material in the SDA was reported, based on visual observations of drilling
materials and superficial wastes, to include glass vials, syringes, personal protective
equipment, various types of wire and other metallic waste, and sludges (Rizzo, September
1992). Other waste materials encountered were wood, cardboard, cloth, and plastic. An
estimated waste volume for this disposal area was calculated to be approximately 40,000
cubic meters (52,000 cubic yards), based on waste delineation activities conducted during
the Phase I Site Characterization Investigation.
The NDA encompasses approximately 3.7 hectares (9.1 acres). The depth to the base of
waste in two soil borings installed during the Phase I Site Characterization Investigation (i.e.,
SS-7 and SS-8) averaged 7.6 meters (25 feet). Much of the northern disposal area is
revegetated, with intermittent waste materials located at the ground surface.
The waste material in the NDA was reported, based on visual observations, to include
paper, plastic, metal, wood, glass, rubber tires, and cloth, with trace amounts of slag and
sludge materials (Rizzo, September 1992). An estimated waste volume for this disposal
area was calculated to be approximately 250,OOOcubic meters (340,000 cubic yards) based
on waste delineation activities conduct during the Phase I Site Characterization Investiga-
tion.
The SDA is currently being used for disposal of primarily municipal wastes. The disposal
area encompasses approximately 1.5 hectares (3.6 acres). The depth to the base of the
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waste based on two soil borings installed during the Phase I Site Characterization
Investigation ( SS-9 and SS-10) averaged 6.2 meters (20.5 feet). No data is available to
determine the thickness of waste placement since the Phase I soil borings were conducted.
Given the active status of the disposal area, very little vegetation is located within the
depression.
The waste material in the SDA was reported, based on visual observations, to include
plastic, cloth, paper, wood, metal, and glass, with trace amounts of leather and rubber
(Rizzo, September 1992). An estimated waste volume for this area was calculated to be
approximately 81,000 cubic meters (111,000 cubic yards), based on waste delineation
activities conducted during the Phase I Site Characterization Investigation. No data is
available to estimate the volume of waste placed since completion of the Phase I Site
Characterization Investigation.
Soil and Leachate Sampling
To determine the chemical nature of the source areas, samples of sub-waste soil and
leachate were collected. Sub-waste soil samples were collected during Phase I of the Rl
from five locations. Two sub-waste soil samples were collected in each of the northern and
southeastern disposal areas, and one sample was collected from the Superfund disposal
area. The analysis of soils indicate that sub-waste soils were marginally impacted by waste
disposal activities at the Site. Few organic contaminants and no pesticides or polychlorina-
ted biphenyls (PCBs) were detected in sub-waste soils.
During sampling of sub-waste soils, leachate was encountered in only one boring located
in the northern disposal area. The analysis of this sample indicated a leachate with a
moderately high inorganic loading, but with few VolatileOrganic Compounds (VOCs). The
VOCs which were reported in the leachate sample included benzene, chlorobenzene,
ethylbenzene and xylene. The temperature of the leachate was also high (38°C), indicating
probable microbial or thermal degradation occurring in the landfill mass. Analysis of the
leachate sample was found to be typical of municipal solid waste leachate as referenced
in literature and studies conducted by EPA.
Groundwater and Spring Sampling
Groundwater in the Barceloneta area primarily occurs in the following principal water
bearing units that comprise much of the northern limestone province: the Aymamon
Limestone, the Aguada Limestone, the Cibao Formation and the Lares Formation.
Groundwater is typically found under unconfined (water table) aquifer conditions in the
Aymamon and Aguada Limestones and under confined (artesian) conditions in parts of the
Cibao and Lares Formations. A confining unit (aquitard) at the top of the Cibao Formation,
consisting of calcareous marl, separates and confines groundwater in underlying units of the
Cibao Formation from the unconfined units above. Perched and/or semi-confined
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conditions may also occur locally within the Aymamon and Aguada Limestones, as a result
of localized low permeability strata retarding groundwater flow.
At the Site, precipitation which falls on the blanket sands and eventually recharges the
aquifer either flows overland directly to the more permeable limestone mogotes, or
infiltrates into the waste and then flows laterally to the limestone mogotes. In the
limestone, the infiltrated water drains downward through the porous media and solution
features to the perched water table zone and/or the unconfined regional aquifer.
Groundwater flow is toward the north in both the localized perched water table and the
unconfined regional aquifer.
As part of Phase I of the RI, groundwater samples were collected from the eight monitoring
wells installed around the three landfill disposal areas during two sampling events. An off-
site water supply was also sampled. The results of the groundwater sample events
demonstrated that groundwater has been locally impacted by the disposal areas. Chloride
and Total Dissolved Solids (TDS), typical municipal landfill indicators, were detected below
EPA's Secondary MCLs. However, 1,1-dichloroethane was detected in MW-3 located near
the northern disposal area during the groundwater sampling events at concentrations
ranging from 11 to 42 fg/l which exceeds the MCL of 7 ^g/l. Chloroform and trichloroeth-
ane (TCE) were also detected in MW-6 at levels below the MCL.
Groundwater analytical results from Phase II of the RI indicated metal detections above
MCL concentrations. In MW-3 manganese was detected at 92.9 fvg/l which exceeds the
SMCL of 50 yg/l. In MW-4 mercury was detected at concentrations ranging from 6.1 to
13.1 which exceeds the MCL of 2 yg/1. In MW-5 chromium was detected at 826 ^g/t
which exceeds the MCL of 100/ig/I. In MW-6 chromium was detected at 106yg/l which
slightly exceeds the MCL. In MW-7 nickel was detected at 101 /vg/l which slightly exceeds
EPA's health advisory level of 100yg/l. In MW-8 nickel was also detected at concentrations
ranging from 125 to 175 pg/\ in filtered and unfiltered samples which exceeds EPA's health
advisory level, and chromium was detected at 204 pg/\ which exceeds the MCL.
An additional monitoring well, MW-9, was installed 2500 feet downgradient of the Landfill
in early 1995, and analytical results from that monitoring well indicated no exceedances of
MCLs. Therefore, although ground water is impacted on-site, the quality of groundwater
off-site has not been found to be impacted.
During the RI, the Ojode GuilloSpring was sampled on three occasions because it was a
viable location to collect groundwater which could be impacted by the Site. The results
jof the sampling indicated that only iron was detected slightly above the Secondary
Maximum Contaminant Level (MCL) in one sample.
SUMMARY OF SITE RISKS
Based upon the results of the RI, a baseline risk assessment was conducted to estimate the
risks associated with current and future Site conditions. 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.
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Consistent with EPA's Presumptive Remedy approach, EPA conducted a streamlined
baseline risk assessment by comparing the levels of contaminants in ground water to MCLs.
These levels were exceeded, indicatingthat the Landfill is a source of contamination to the
ground water and therefore remedial measures are necessary to protect human health and
the environment. EPA's Abbreviated Risk Assessment evaluated any potential adverse
effects to human health from exposure to chemical contamination present in the vicinity
of the Site groundwater. The reasonable maximum human exposure was used. The
results indicate that the levels of contaminants present in the groundwater pose a relatively
low long-term threat to human health. However, if no action is taken with respect to the
Landfill,the continued release of contaminants into ground water could potentially result
in a greater risk at some point in the future. Therefore, based on the results of the
Abbreviated Risk Assessment, EPA has determined that actual or threatened releases of
hazardous substances from this Site, if not addressed by implementing the response action
selected in this ROD, may present a current or potential threat to public health, welfare,
or the environment.
REMEDIAL ACTION OBIECT1VES
Remedial action objectives are specific goals to protect human health and the environment.
The primary objectives of this remedy are to control the source of contamination at the Site
and to reduce and minimize the migration of contaminants into Site media thereby
minimizing any health and ecological impacts.
The following remedial action objectives were established for the Site:
to prevent direct contact with waste material;
to reduce or eliminate the potential for the Landfill disposal areas to release
hazardous substances to ground water;
to reduce or eliminate the potential for migration of hazardous substances to ground
water downgradient of the Landfill;
to prevent the migration of and control Landfill gas; and
to minimize any potential future impacts of hazardous substances that may migrate
into environmental media.
DESCRIPTION OF REMEDIAL ALTERNATIVES
The Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(CERCLA) as amended, 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. It 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. CERCl>
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 ot
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relevant and appropriate requirements (ARARs) under federal and state laws, unless a
waiver can be justified.
The FS report evaluates in detail six remedial alternatives for addressing the contamination
associated with the Site. The implementation time 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 responsible parties, procure contracts for design and
construction, or conduct operation and maintenance ("O&M") at the Site.
In addition, in accordance with Section 121 of CERCIA, EPA must review any remedial
action that leaves hazardous substance above health based levels at a site at least once
every five years to assure that the remedy selected continues to be protective of human
health and the environmental. All of the alternatives presented will require such a five year
review. If justified by the review, remedial actions may be implemented to remove or treat
the wastes, or to otherwise change the remedial action selected in this ROD.
Alternative 1: No Action
The Superfund program requires that the "No-Action"alternative be considered at every site
to provide a baseline of comparison among alternatives. The No Action alternative means
that no remedial actions would be conducted for any of the media of concern at the Site.
This does not achieve all the remedial action objectives. While the existing soil and
vegetative cover reduces potential exposure to on-site soil contaminants by direct contact,
ingestion, and/or inhalation, it does not prevent such exposure. The potential migration
of contaminants from on-site waste materials into the ground water from water infiltration
through the waste materials or surface water runoff and erosion would not be prevented
or minimized and the release of landfill gas would not be controlled. The potential for
continued access to the Site would exist thereby allowing potential exposure to on-site
waste materials and direct contact, ingestion, and/or inhalation. The potential for future
airborne releases from exposed waste areas would not be prevented. The leachate genera-
tion and/or groundwater contamination from waste areas would also not be prevented.
In accordance with Section 121 of CERCIA, remedial actions that leaves hazardous
substances at a Site are to be reviewed at least once every five years to assure that the
remedial action is protective of human health and the environmental. There are no costs
associated with the No Action alternative.
Capital Cost: $0
.Operation and Maintenance Cost: $0
Present-Worth Cost: $0
Implementation Time: None
Alternative 2: Site -Wide Area Institutional Controls
This alternative provides that institutional controls be implemented on a site-wide basis. The
institutional controls are to be used to minimize the potential for human exposure to the
waste and to monitor leachate generation and groundwater contamination at the Site. The
controls include:
9
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1. Recommending that zoning restrictions be applied to the Site, limiting future land
use;
2. Recommending that a deed restriction be applied to the Site, limiting future land and
groundwater use; and
3. Groundwater monitoring after the Landfill ceases accepting wastes and installing
perimeter fencing and sign posting to restrict access;
Access restrictions will be implemented in the form of fences and signs around the Site.
The existing fence will require inspection and upgrading, as necessary, to ensure that the
existing fence completely surrounds the Site. Signs indicating that the landfill is a
Superfund site (with EPA's telephone number for information) would be posted on the
fence or at other appropriate locations; language on the signs would be in both Spanish and
English. On-going maintenance of the fence and signs would also be required.
Restrictions on future use of the Site include zoning and/or deed restrictions directed
toward the prevention of the construction of new drinking water supply wells and
prohibition of construction at the Site to prevent excavation. Restrictions willbe placed on
the property deed to assure the long-term maintenance of the Site.
This alternative also includes site-wide groundwater monitoring for the period after the
landfill is closed (O & M period). The groundwater monitoring program willbe developed
during the Remedial Design (RD) phase. The groundwater monitoring system is anticipated
to include the eight existing monitoring wells, and groundwater sampling is anticipated to
be conducted quarterly for the first year, semi-annually for the next four years, followed by
annual sampling for the remainder of the 30-year O&M period. Initially, the wells would
be sampled for a broad parameter list. The list was developed based on constituents
detected above MCls in the Rl and on the requirements of the Resource Conservation and
Recovery Act (RCRA) Subtitle D and Puerto Rico's Regulation Governing Landfill Closure
(RMNHSW). After the first five years, the parameter list will be reviewed and those
parameters not above standards would be omitted. The initial parameter list includes:
* Site VolatileOrganicCompounds of Concern (only 1,1-dichloroethane was detected
above MCLs during the Rl. However, to be more conservative, the complete EPA
Method scan for volatileorganiccompounds willbe analyzed in accordance with 40
CFR, Part. 258, Appendix. I & II).
* Site Metals of Concern (only mercury, chromium, and nickel were detected above
MCLs during the Rl. However, to be more conservative, the complete EPA method
scan for metals compounds will be analyzed in accordance with 40 CFR, Part. 258,
Appendix. I & II).
* Chloride
* Total Dissolved Solids
* Total Suspended Solids
* pH (field measurement)
* Specific Conductivity (field measurement).
This alternative by itself does not provide for the prevention of leachate generation and
protection of the ground water.
10
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Capital Cost: $779,00
Operation & Management Cost: $73,207/yr
Present Worth O&M Cost: $1,628,000
Total Cost: $2,407,000
Implementation Time: six months
Alternative 3A: SFDA Partial Soil Cover System
This alternative addresses the SFDA or southern disposal area, and includes a soil cover
which would be placed or combined with portions of the existing cover (to be at least one-
half meter thick) in the areas which have exposed debris or an inadequate existing cover
system. The soil cover will be properly graded and vegetated to control surface water flow
and erosion. The existing grades will generally be the final grades for the partial cover,
changing only in the areas requiring partial cover.
For the purposes of the FS, the area requiring a partial cover is assumed to be approximate-
ly 25% of the total area, but the exact area will need to be further evaluated as part of the
RD process. This alternative was evaluated because most of the SFDA is covered and the
cover has substantial vegetation. However, there are some limited areas where debris,
such as broken glass vials, are exposed on the surface. These areas are limited in size and
the exposed waste appears to present only a physical hazard (not a chemical hazard).
Also, the majority of the disposal area appears to have an adequate cover with substantial
vegetation. Therefore, this option was considered because it would allow disturbance of
only a portion of the disposal area and thereby limit the potential short-term exposures
and/or releases. However, this alternative does not provide reasonable protection against
leachate generation and groundwater contamination.
Capital Cost: $76,000
Operation & Management Cost: $5,500/yr
Present Worth O&M Cost: $168,500
Total Cost: $244,500
Implementation Time: one month
Alternative 3B: SFDA Subtitle D Cover System
This alternative includes placing a cover system consistent with Resource Conservation and
Recovery Act (RCRA) Subtitle D and the Puerto Rico's Regulations Governing LandfillClosure
(RMNHSW) over the entire Superfund Disposal Area. The Subtitle D cover system
proposed for this disposal area under this alternative consists of an 18-inch-thick layer of
clay, placed to have a maximum permeability of 1x10 s cm/s, and a 6 inch vegetative layer
to help control erosion. Existing vegetation in the area will initially be cut (less than 6
inches) and the area regraded so that minimum grades can be obtained. The regrading
may include the re-distribution of some of the existing cover materials and/or waste
materials. In particular, there is an area of waste disposal which is outside the property
line. This waste will be relocated to the disposal area. Additionally,a layer of general fill
material will be utilized, as needed, to obtain grades.
The general fill grades for this alternative will have surface water runoff directed generally
from southwest to northeast and north into a low area where a retention pond will be
11
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constructed. The grades are generally 5% across the Landfill, with a 3H:1V slope at the
northern end for tying into the retention pond area. Therefore, adequate erosion control
for the surface water system will need to include reinforcement of slopes and/or channels.
The perimeter ditches will also be designed to divert surface water from off the Landfill to
the retention pond area. These ditches are also anticipated to require reinforcement.
Consistent with the RMNHSW, a landfillgas survey will be required as part of a predesign
investigation to determine if a gas collection system is necessary. The appropriate type of
system and system design would require further evaluation as part of the RD process.
Capital Cost: $889,000
O & M Cost: 120,500/yr
Present Worth O&M Cost: $445,000
Total Cost: $1,334,000
Implementation Time: six months
Alternative 4: NDA Subtitle D Cover System
This alternative for the NDA includes a cover system consistent with RCRA Subtitle D and
RMNHSW. The Subtitle D cover system proposed for the NDA under this alternative
consists of an 18-inch-thick layer of clay, placed to have a maximum permeability of 1x105
cm/s, and a 6 inch vegetative layer which includes vegetation to help control erosion. The
area will be regraded so that minimum grades can be obtained; this may include the
redistribution of some of the existing cover materials and/or waste materials. A layer of
general fill material will be utilized as needed, to obtain grades. The regrading and general
fill placement will allow a uniform cover system to be placed, as described below, while
maintaining the grades needed for control of surface water flow and erosion.
The grading for the NDA is anticipated to be generally from the west towards the east and
from the south to the north. All surface water will be directed over the surface of the
Landfill and/or to perimeter ditches towards the low area to the north where a retention
pond will be constructed. The perimeter ditches are also anticipated to divert surface water
from off the NDA to the retention pond area. This retention pond area is anticipated to be
sufficient to control and infiltrate the water from a 25-year, 24-hour storm from the entire
drainage area. Because the maximum grade on the NDA is 5%, adequate erosion control
for the surface water system may include reinforcement of slopes and/or channels,
particularly in the perimeter ditches.
¦Consistent with the RMNHSW, a landfillgas survey will be required as part of a predesign
investigation to determine if a gas collection system is necessary. The need for the gas
system and/or the appropriate type of system and system design would require further
evaluation as part of the RD process.
Capital Cost $2,878,000
O&M Cost: $78,000/yr
Present Worth O&M Cost: $1,507,000
Totla Cost: $4,385,000
Implementation Time: one year
12
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Alternative 5; SPA Subtitle D Cover System
This alternative for the SDA includes a cover system consistent with RCRA Subtitle D and
RMNHSW. The subtitle D cover system for the SDA under this alternative consists of an
18-indvthick layer of clay, placed to have a maximum permeability of lxlQ"5 cm/s, and a
6 inch vegetative layer which includes vegetation to help control erosion. The fillingof this
area is currently ongoing and will be tailored for the installation of the final cover. A general
fill layer (assumed to be 2 feet in thickness) will be placed to obtain the final grades for
surface water flow and erosion control.
The grading for the SDA is anticipated to generally be from west to east draining to a
retention pond. The retention pond is expected to be sufficient to control and infiltrate the
water from a 25-year, 24-hour storm event. The slope on the SDA is anticipated to be
approximately 3%, therefore, erosion control will not likely require much reinforcement
other than vegetation, although the perimeter ditches may require additional protection
such as rip rap.
Consistent with the RMNHSW, a landfill gas survey will be required as part of a predesign
investigation to determine if a gas collection system is necessary. The need for the system
an/or the appropriate type of system and system design would require further evaluation
as part of the RD process.
Capital Cost: $907,200
O & M Cost: $64,500/yr
Present Worth O&M Cost: $1,256,800
Total Cost: $2,164,000
Implementation Time: six months
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In accordance with the NCPa detailed analysis of each alternative is required. The detailed
analysis consists of an assessment of the individual alternatives against each of nine
evaluation criteria and a comparative analysis focusing upon the relative performance of
each alternative against those criteria.
The following"thresholdn criteria must be satisfied by any alternative in order to be eligible
for selection:
•1. Overall protection of human health and the environment addresses whether or not
a remedy provides adequate protection and describes how risks posed through each
exposure pathway (based on a reasonable maximum exposure scenario) are
eliminated, reduced, or controlled through treatment, engineering controls, or institu-
tional controls.
2. Compliance with ARARs addresses whether or not a remedy would meet all of the
applicable (legally enforceable), or relevant and appropriate (requirements that
pertain to situations sufficiently similar to those encountered at a Superfund site
such that their use is well suited to the Site) requirements of federal and state
13
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environmental statutes and requirements or provide grounds for invoking a waiver.
The following-primary batancingMcriteria are used to make comparisons and to identify the
major trade-offs between alternatives:
3. long-term effectiveness and permanence refers to the abilityofa remedy to maintain
reliable protection of human health and the environment over time, once cleanup
goals have been met. it also addresses the magnitude and effectiveness of the
measures that may be required to manage the risk posed by treatment residuals
and/or untreated wastes.
4. Reduction of toxicity, mobility, or volume via treatment refers to a remedial
technology's expected ability to reduce the toxicity, mobility,or volume of hazardous
substances, pollutants or contaminants at the Site.
5. Short-term effectiveness addresses the period of time needed to achieve protection
and any adverse impacts on human health and the environment that may be posed
during the construction and implementation periods until cleanup goals are
achieved.
6. Implementabilitv refers to the technical and administrative feasibility of a remedy,
including the avai lability of materials and services needed.
7. Cost includes estimated capital and operation and maintenance costs, and the
present-worth costs.
The following "modifying" criteria are considered fully after the formal public comment
period on the Proposed Plan is complete:
8. State acceptance indicates whether, based on its review of the RI/FS report and the
Proposed Plan, the Commonwealth supports, opposes, and/or has identified any
reservations with the preferred alternative.
9. Community acceptance refers to the public's general response to the alternatives
described in the Proposed Plan and the Rl/FS reports. Factors of community
acceptance to be discussed include support, reservation, and opposition by the
community.
-A comparative analysis of the remedial alternatives based upon the evaluation criteria noted
above follows.
* Overall Protection of Human Health and the Environment
All of the alternatives except Alternative 1 (No Action) and Alternative 2 {Institutional
Controls) provide general protection of human health and the environment since they all
provide for the landfill cover system. Alternative 1 does not meet the remedial action
objectives. This alternative does not provide protection of the public health and the
environmental because the potential risks associated with the Site are not mitigated. The
existing source and exposure pathways remain. Alternative 2 minimizes the potential
14
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exposure to waste and ground water with Site restrictions and a drillingban. The existing
exposure pathways inside the area would remain and no mitigation of risks associated with
the Landfillwould take place. This alternative by itself does not provide for the prevention
of ieachate generation and groundwater protection from leachate nor for landfillgas control.
Alternative 3A is somewhat protective of human health by reducing the potential exposure
to waste and leachate generation. It provides only limited protection of the ground water
since it does not adequately prevent infiltration because of the poor impermeability of the
cap soil. Alternatives 3B, 4 and 5 are protective by minimizingpotential exposure to waste
and providing for the protection of ground water by controlling leachate generation. They
also prevent the accumulation and potential migration of landfill gas, reduce infiltration,
minimize migration of contaminants into ground water, and provide vector control (insects
and rodents).
• Compliance with ARARs
The principal action-specific ARARs for this Site include the Resource Conservation and
Recovery Act (RCRA) Subtitle D and Puerto Rico's Regulation Governing Landfill Closure
(RMNHSW) requirements, which require the installation of a cover system.
Alternative 1, No Action, does not meet federal or Commonwealth ARAR'sestablished for
the Site. It allows the Site to continue to be a source of contamination. Alternative 2
would meet the ARARs for groundwater monitoring but by itself does not comply with
federal or Commonwealth RCRA Subtitle D closure ARAR's, allowingthe landfillto remain
without a cover system. Alternative 3A provides a cap with minimum requirements. This
proposed cap does not comply with federal and Commonwealth ARAR's capping/closure
requirements for the Site. Alternatives 3B, 4 and 5, provide for the closure of the landfill
with a full RCRA Subtitle D cap at all units. This cap meets federal and Commonwealth
ARAR's for capping/closure of the Site.
• Long-Term Effectiveness and Permanence
The No Action alternative provides no long-term effectiveness or permanence for the Site.
The remedial action objectives would not be met and the potential risks established for the
Site would not be mitigated. Alternative 2 which provides for institutional controls,
groundwater monitoring and fencing would not by itself be effective in reducing the risks
that the Site presents over the long term because leachate would continue to be generated
thereby causing groundwater contamination. Alternative 3A does not provide long-term
control for leachate generation, migration of contaminants and groundwater protection. It
•is not completely effective in reducing the risks that the Site presents.
The capping requirements under Alternatives 3B, 4, and 5 provide a long-term effective
remedial approach if the systems are properly maintained. Long-term cap maintenance
requirements include inspections, vegetation maintenance, and cap system repair. Mainte-
nance is critical to the long-term effectiveness and permanence for containment because
the landfill contents remain at the Site. Essentially, the capping alternative and component
technologies are equally effective in providing a permanent containment of the waste.
15
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• Reduction in Toxicity. Mobility, or Volume via Treatment
The No Action alternative would allow for the continued release of leachate to the ground
water and thus does not meet this criterion. Alternative 2 would not by itself address this
criterion at all.
For all the evaluated alternatives, no treatment technologies were proposed to reduce the
toxicity, mobility or volume because there were no identified hot spots in the Landfill that
would be amenable to treatment. However, there would be a reduction in the mobility of
leachate to ground water as a result of the installation of surface controls and a cap which
would reduce precipitation infiltration for all capping alternatives. Alternative 3A however,
would result in the least reduction of leachate generation as compared to Alternatives 3B,
4 and 5 because Alternative 3A would employ an inferior cap only addressing those areas
where waste materials are exposed.
• Short-Term Effectiveness
The No Action alternative does not have any other significant public health and environ-
mental impacts associated with implementation. Alternative 3A is anticipated to have the
next least short term effects because it has the smallest area to cap. All of the other
capping alternatives (3B, 4, and 5) are anticipated to have similar short-term effects. During
regrading operations related to installing a RCRA cap, a short-term risk to the on-site
workers, the local residents in close proximity to the landfill, and the environment would
exist. Health and safety measures would be implemented during construction to minimize
these short term risks.
The capping alternatives would have the same short term effectiveness considerations
during clearing and grubbing, erosion and sediment control construction and gas manage-
ment system installation. Other short-term effectiveness considerations are related to
increased vehicular traffic and noise during the construction.
Alternative 3A could be constructed in the least amount of time (one month), followed by
Alternative 2, 3B and 5 each with six months. Alternative 4 has the longest construction
time of one year.
• Implementabilitv
All of the alternatives involve the use of commercially available products and accessible
technology. Alternatives 3B, 4 and 5 are easily implemented technically. The RCRASubtitle
-D soil cap alternatives would be simple to construct and maintain. The local availabilityof
the clay has been tentatively confirmed with the Soil Conservation Service in San Juan,
Puerto Rico. There are several construction companies in Puerto Rico constructing RCRA
Subtitle D soil caps at municipal landfills. The availabilityof soils and construction
companies capable to construct the required cap makes these alternatives fully imple-
mentable.
16
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• Cost
The combination of Alternative 2 (SWA Institutional Controls) with Alternative 3B (SFDA
Subtitle D Cover System), Alternative 4 (NDA Subtitle D Cover System) and Alternative 5
(SDA Subtitle D Cover System) provide the balance of trade-offs among alternatives with
respect to the evaluation criteria, Followingare the alternatives in order of total cost:
Alternative 1: $0
Alternative 2: $2,407,000
Alternative 3A: $244,500
Alternative 3B: $1,334,000
Alternative 4; $4,385,000
Alternatives: $2,164,000
Alternatives 2, 3A,4 & 5: $10,290,000
• State Acceptance
The Environmental Quality Board concurs with the selected remedy for the Barceloneta
Landfill, A letter of concurrence is attached to this ROD as Appendix IV.
• Community Acceptance
All significant comments submitted during the public comment period were evaluated and
are addressed in the attached Responsiveness Summary which is included as Appendix V.
SELECTED REMEDY
EPA has determined, after reviewing the alternatives and public comments, that the
combined Alternatives 2,3B,4 and 5 (RCRAsubtitle D Cover System/Institutional Controls)
is the appropriate remedy for the Site because it best satisfies the requirements of CERCLA
and the NCP's nine evaluation criteria for remedial alternatives.
The major components of the selected remedy are as follow:
Installing a low permeability cover system for the three Landfill cells meeting the
requirements of the RCRA Subtitle D and Puerto Rico's Regulations Governing
Landfill Closure . This cover system or landfill cap(s) will further reduce infiltration
of precipitation water into the landfilland reduce leachate generation thus mitigating
impacts to ground water.
Regradingthe Site and installing storm water management improvements at the Site
to reduce infiltrationof storm water into the Landfilland reduce leachate generation.
Conducting long term ground water and surface water monitoring to evaluate the
effectiveness of the cover system. It is anticipated that monitoring will be conducted
on a quarterly basis for the first year, semi-annually for the next four years, and then
annually. Monitoring will include the eight existing monitoring wells. Initially, the
wells will be sampled for a broad parameter list. The list has been developed based
on constituents detected above Safe Drinking Water Act Maximum Contaminant
17
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Levels in the Remedial Investigation and on the requirements of the RCRA Subtitle
Dand Puerto Rico's Regulation Governing LandfillClosure (RMNHSW), After the first
five years, the parameter list would be reviewed and those parameters not detected
above standards would be omitted. The exact long term ground water monitoring
program will be further defined during remedial design (RD).
Conducting a landfill gas survey during predesign to determine the necessity of a
landfillgas collection system. The appropriate type of system, if necessary, will be
determined during RD.
Implementing a long term operation and maintenance program for the cover system
which will include inspection of the system and provision for repair.
Recommending to appropriate authorities that institutional controls be emptaced.
Institutional controls are recommended in order to protect the integrity of the landfill
cover system and to reduce potential exposure to landfillcontents. The institutional
controls will include recommending that zoning restrictions be applied to the Site
to limit future land use and recommending that a deed restriction be established to
limit future land and ground-water use.
Installing a perimeter fence with signs to restrict access.
Reevaluating Site conditions at least once every five years to determine if a
modification of the selected remedy is necessary.
STATUTORY DETERMINATIONS
As previously noted, CERCLA mandates that a remedial action must be protective of human
health and the environment, be cost effective, and utilize permanent solutions and
alternative treatment technologies or resource recovery technologies to the maximum
extent practicable. CERCLAalso 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. CERCLAfurther 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.
For the reasons discussed below, EPA has determined that the selected remedy meets the
requirements of CERClAand provides the best balance of trade-offs among alternatives with
jrespect to the evaluation criteria.
Protection of Human Health and the Environment
The selected remedy is protective of human health and the environment. Contact with
landfill waste materials will be eliminated through capping the three disposal areas. In
addition, capping will prevent further degradation of the groundwater from the leaching of
contaminants into the groundwater.
18
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Compliance with ARARs
The selected remedy will be in compliance with all ARARs. Action-specific ARARs for the
selected remedy include RCRA and Puerto Rico's Regulations Governing Landfill Closure.
Cost-Effectiveness
The selected remedy is cost-effective because it has been demonstrated to provide overall
effectiveness proportional to its cost. The combination of Alternatives 2, 3B, 4 and 5
contain critical components in meeting the remedial action objectives and satisfying the
statutory criteria. The present worth cost of the selected remedy is $10,290,000.
Utilizationof Permanent Solutions and Alternative Treatment Technologies to the Maximum
Extent Practicable
The selected remedy utilizes permanent solutions and treatment technologies to the
maximum extent practicable. However, because the contaminant source, the Site itself,
could not be effectively excavated and treated as a result of the large volume of waste and
the absence of hot-spots representing major sources of contamination, the remedy does
not satisfy the statutory preference for treatment as a principal element. The selected
remedy provides the best balance of trade-offs among the alternatives with respect to the
evaluation criteria.
DOCUMENTATION OF SIGNIFICANT CHANGES
There are no significant changes from the preferred alternative presented in the Proposed
Plan.
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APPENDIX I - FIGURES
FIGURE I. SITE LOCATION MAP
FIGURE 2. SITE SKETCH WITH MONITORING WELLS LOCATIONS
FIGURE 3. SPATIAL DISTRIBUTION OF CONSTITUENTS REPORTED ABOVE MCL's
OR SMCL's IN GROUNDWATER DURING THE R1
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FIGURE 3
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APPENDIX II - TABLES
TABLE 1.
Summary of Threatened or Endangered Species
TABLE 2.
Soil Headspace Results
TABLE 3.
Soil Borings Drilling Summary
TABLE 4.
Summary of Waste Delineation Borings
TABLE 5.
Target Compound List
TABLE 6.
Target Compound List
TABLE 7.
Monitoring Well Construction Data
TABLE 8.
Groundwater elevation Data
TABLE 9.
Monitoring Well Redevelopment Summary
TABLE 10.
Summary of Slug Test Results
TABLE 1 1.
Summary of Soil Geotechnical Data
TABLE 12.
Groundwater Flow of the North Coast Limestones
TABLE 13.
Background Soil Analytical Results - Summary of Detected Parameters
TABLE 14.
Sub-waste Soil Analytical Results - Summary of Detected Parameters
TABLE 15.
Leachate Analytical Results - Summary of Detected Parameters
TABLE 16.
Groundwater and Spring Analytical Results - Summary of Detected Parameters
-------
March 1995
933-3926
TABLE 1
SUMMARY OF THREATENED OR ENDANGERED SPECIES
Barceloneu Landfill Site
Barceloneta, Puerto Rico
SpacJaa occurring en tfw main 1 aland ol Puerto Rico and contfdarad by
tha Common with ol Puarto Rico Dapartmant ol Nalu'al Raioutcat to
ba thraatanad or andangarad.
COMMON NAMt
SCIENTIFIC NAME
status
CLASS AMPHIBIA
Puarto Rican Ciaitad Toad
P»tiOf>hryn$ Itmur
T-
Enaida't Coqul
Eleuthsfodictyius tnt/ds*
T
Goldan Coqul
EJouthtrodictylui
V
Karl Schmidt't Coqul
El+uth0rad*c(y1ut ksrltchmtdti
T
CLASS REPTILIA
OryUnd Anola
Anoin cooki
T
Puarto Rican Boa
Eptcfsttt inornslut
E'
Shan't Sfcink
Msbuy$ mtbvy*
T
CLASS AVES
Sharp-«hmnad Hawk
Accipifr ttritlui vmnatc*
T'
Arctic Paragrina Falcon
Fslco p+r+grinut tundr/ut
E*
PLANTS
CLASS DICOTYLEDON
Vahl's Boxwood
&UXU9 V9hhi
E'
Palo d« Ramon
Bsnsrs V9nd0ft>itiii
E'
Spaciac likaly to occur in tha Barcalonau araa and con«id«r*d by tha
Unitad Siataa Fit* and Wildlila Sarvica to ba thraatanad or andangarad.
COMMON NAME
SCIENTIFIC NAME
STATUS
BIROS
Arctic Paragrina Falcon
F*kx> p4/0$nnus tundriut
T
REPTILES
Puarto Rican Boa
EpB3>-382»VUbla«\SPECtES.WK1
Golder Associates
-------
March 1995
9C
53-3928
TABLE 2
SOIL HEADSPACE RESULTS
Barcelonela Landfill Site
iarceloneta, Puerto Rico
DEPTH Of
DEPTH OP
80RIN0
BOBINO
boring
BORING
BORING
80WNQ
0ORINO
80WNQ
BORING
BORINO
BORINQ
BORINQ
BORING
SAMPLE
6 AMPLE
88-1
es-i
flS-5
SS-4
SS-S
ss-e
SS-T
SS-I
ss-»
SS-1B
SS-11
SS-I IB
ss-u
(mitiri)
((•it)
(ppmX.I
(ppm)
(ppm)
(ppm)
(ppm)
(ppm)
(ppm)
(ppm)
(ppm)
(ppm)
(ppm)
(ppm)
(ppm)
0-1. S
0-5
NA{b)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1.S-3.0
5-10
NA
NA
0(c)
...
NA
0
NA
NA
10
NA
NA
0.2
NA
3.0-4.6
10-15
0
0
7.5(C)
...
...
0
NA
NA
NA
NA
...
NA
4.6-8.1
15-20
...
...
...
...
...
4
NA
NA
NA
10
...
...
0
6.1-7.6
20-25
—
...
...
...
...
0
NA
7
NA
NA
...
...
0
1
7.6-1.1
25-30
—
...
...
...
...
6
15(c)
11(c)
41(c)
0
...
...
0
9.1-10.7
30-35
...
...
...
...
...
...
...
...
...
...
...
...
18
10.7-12.2
35-40
—
...
...
...
...
...
...
...
...
—
...
...
3
12.2-13.7
40-45
...
...
...
...
...
...
...
...
...
...
...
...
8
13.7-15.2
45-50
—
...
—
...
...
...
...
—
...
...
...
...
NA
15.2-16.0
50-55
—
—
...
...
...
...
...
...
...
—
...
...
18) NA - No headspace VOC measurement recorded.
(c) Value reported 1$ averaoe HNU reading lor depth Interval.
— - Boring not advanced to this depth.
No headspace VOC measurements were recorded lor soil borings SS-13 through SS-22 because they represent background conditions
and metals were the only analytical parameters ol concern.
*N;\Ot«MiM-»MW»W«\H6A08PC.WKI
Qoldtr Associates
-------
Maich )995
333-2825"
TAOLE 3
SOIL BORING DRILLING SUMMARY
Barceloneta Landfill Site
Barceloneta. Puerto Rico
MAXIMUM
-
TOTAL
ELEVATION AT
HEADSPACE
LABORATORY
DATE
DEPTH OF
AT TOP OF
VOC
SAMPLE
BORING I.D.
DRILLING
BORING
BORING
CONCENTRATION
INTERVAL
DRILLEO
METHOD
{meters)
(meters MSL)
(ppm)
(meters)
SS-1
2/11/92
HSA
3.5
ii6,9
0
3 0-3.5
SS-2
2/11/92
HSA
3.5
132.0
0
3.0-3.5
SS-3
2/12/92
HSA
4.0
127.9
7.5
3.0-3.5
SS-4
2/12/92
HSA
1.5
145.5
NA
NS
SS-5
2/12/92
HSA
2.4
141.0
NA
NS
SS-6
1/17/92
HSA
8,5
145.1
8
7.6-8.1
SS-7
1/06/92-1/10/92
HSA/RW
8.5
139.5
15
7.6-8.1
SS-8
1/08/92-1/13/92
HSA/RW
9.1
142.3
11
8.2-8.7
SS-9
1/08/92-1/14/92
HSA/RW
8.5
119.2
41
7.6-8.1
SS-1Q
1/09/92-1/14/92
HSA/RW
9.3
118.3
10
9.0-9,3
SS-11
1/09/92-1/15/92
HSA/RW
2 3
125.3
NA
NS
SS-11A
1/15/92-1/16/92
HSA/RW
2,3
125 4
NA
NS
SS-118
1/15/92-1/16/92
HSA
2.3
125.4
0.2
NS
SS-12
1/15/92-1/16/92
HSA/RW
166
127.3
18
15 2-15.7
SS-13A
1/12/94
HSA
4.0
NA
NA
0.6-1,2
SS-i 38
1/12/94
HSA
4.0
NA
NA
3.0-4.0
SS-14
1/11/94
HA
1.2
NA
NA
0.6-1.2
SS-15A
1/11/94
HA
1,2
NA
NA
0.6-1.2
SS-lSB
1/13/94
HSA
4.0
NA
NA
3.0-4.0
SS-i 6
1/13/94
HA
1.2
NA
NA
0.6-1.2
SS-1?
1/11/94
HA
1.2
NA
NA
0.6-1.2
SS-18
1/12/94
HA
1.2
NA
NA
0.6-1.2
SS-19
1/12/94
HA
1.2
NA
NA
0.6-1.2
SS-20
1/12/94
HA
1.0
NA
NA
0.6-0.9
SS-21A
1/12/94
HSA
4.0
NA
NA
0.6-1.2
SS-21B
1/12^94
HSA
4,0
NA
NA
3,0-4.0
SS-22A
1/13/94
HA
4.0
NA
NA
0.6-1.2
SS-22B
1/13/94
HA
4.0
NA
NA
3.0-4.0
NOTES.
NA - N« Available
meters - meters below ground surface
NS - No Sample Collected
meters MSL
- meters above mean sea level
HSA - Hollow Stem Auger
(Him - pans per million
RW - Rotary Wash (water)
VOC - Volatile Organic Compounds
MA - Hand Auger
m;taskW33-3ait1Ubimsm2MOfl WKt
Golder Associates
-------
Mireh 1995
933-3928
TABLE 4
SUMMARY OF WASTE DELINEATION BORINGS
Barcelofleli Landfill Siie
Bircclonett, Puerto Rico
' $0>< , /*
/ ; " :
TOTAL
ELEVATION AT
ELEVATION AT
THICKNESS
; SUB-WASTE-V
' \ -«
*waste
DEPTH OF-
TOP OF
BASE OF
OF .
SOIL SAMPLE :' ;",
- ','¦*{¦ '>
DISPOSAL
BOREHOLE
BORJNG
WASTE'
WASTE',-
I ;'glNT^y/;$|
', BORINC i.b.';
•-/ AREA
(mcien bes)
(meters MSL)
(mcte/» MSL)
(mclefj)
(meter* b*s) , v'
SS-7
Northern
8.5
139.5
132.3
6.7
7.6-8.1
SS-I
Northern
9,1
142.3
134.1
7.3
1.2-1.7
SS-9
Southeastern
15
119 3
112.2
6 1
7.6-8.1
SS-10
Soulhcaitem
9 3
118 3
112.S
5.3
9.0-9.3
SS-I I
Supcrfund
2 3
125.3
NA
0(1)
NS
SS-I 1A
Superfund
2 3
125.4
NA
0(1)
NS
SS-I IB
Supcrfund
2,3
125 4
NA
0(1)
NS
SS-12
Supcrfund
10.6
127.3
112.2
15,2
I5.2-IJ.7
SB-1
Supcrfund
1.0
117(2)
NA
0
NS
SB-2
Superfund
10
H5 (2)
NA
0
NS
SD-3
Siipcrftind
06
115(2)
NA
0
NS
SB-4
Supcrfund
12
H0(2)
NA
0.3(3)
NS
SB-S
Superfund
0 5
110(2)
NA
0
NS
MOTH:
|f| » •*#%** M-M, • IA *ft# #S-' 19 **'* **#•'«•#¥ 4'**l lmm**il»ly if th* 5vp«f'uri< *'•«
m4 *t*t tw «u«»t.ll»» it mm w«i» •<•••<«>«•>»< >1 SS-I t »t 1.0 imMi k«« ¦ nt II 0.1 t§> In SS-I IA iM 5V) II.
Ill • |lin«M •< t«» »l kaihf llfcnit«< U»1| IM «»•(•»»>»• mip »>•»•'•< %i tout C. Kill* »«< Akmkim ISCS*. IMII.
131 • llM •( well* Ml p«n*t>«t«4.
HA • N#t Av*l*fcl«
fc«« • fliliil t«taw fmmt •*#!•««
"*•!«»• MSI • mtltrt ffcev* mean **• Mvtl
Golder Associates
-------
M*di t995
933-392f
Table s
r»tc i «f4
TARGET COMPOUND LIST
lUmlMHb La*4ftB SH«
BtrrtWi, FWrit RJco
CONITOUNDS - -
cas tx>>T^crJf rf<
K •' N 5®^-? "-T ¦ RBQtnto^f. % coktakunaKt'^
QUANTITATION XEVELCwfl);
• '¦ UMiTtecA) «•' * -r •
volatile compounds
ChlommnhAAC
n-n-s
10
DromomciKwr
74-13-9
10
VtfiyJ Qrionde
75-01-4
10
2
CWoroethine
"75-00-3
10
Methylene Chloride
75-09-3
10
6
Acetone
67-64-)
10
Carbon Disulfide
75-15-0
10
IJ-OicWorodivcnc
75-35-4
10
7
1.1 -DidKloroetium
75-34-3
10
1,2-DMAJorocthcrwc (toUl)
540-59-0
10
100
Chloroform
«?-66-3
10
100
1J• Dic$iiorocth*fie
107-06-2
10
5
1-BuUnone
71-93-3
10
I, I. I -T richlor octK&ne
71-55-6
10
200
C*rtx*i Tetrahtarirfe
56-23-5
10
5
Bromo4idy«romcthane
75-27-4
10
100
1,2«Dichloropropare
7g-r?-J
10
s
cijk I ,3• DidhJoropropcnc
10041-01-5
10
Trictiloroclhcnc
79-01-6
10
J
DibramochlOTorifMahaftc
I24-4S-I
10
100
1,U TrichlorocthMK
79-00-J
10
5
Benzene
71-43-3
10
5
Iran*-13-D>chkorapropeDe
10061-02-6
10
.
Bromoform
75-23-2
10
100
4-Methy4-2-pe«Ui*w*
lot-io-i
10
-
2-Hennow
m-tt-6
10
TetfftditaroeChate
127-11*
10
5
Tofocnc
iot-n-3
10
1000
1,1,1^-TetrmAJorocthaiw
7M4-5
10
_
CWorofcenx^
1OM0-7
10
•
Ethyl Benzene
100-41-4
10
TOO
Slyrcnc
100-42-5
10
100
Xylenes (leul)
1310-20-7
10
10,000
FN:\IXikW33-J92ruUaWa*o.il.
Golder Associofes
-------
March m$
9J1-J92K
tables
r«t. i,(4
target comtouno list
BarciiMMU Landfall £t«
IiriImiu, Pwm Rjc#
CO.SO"OUNUS*<• CaS NUMM;- .^f"CONTIUCr:t'K-': J^MAmtUM
•* * * . " ,",isrJ; V-. )*|8s§h-
; , -A. 3rV
SEMIVOI^TRX
COMTOUNIK
HvcmE
108-95-2
10
tw»-C-Qilar©cihjl) cihcjr
ltt-44-t
10
2-Otlorof^cAo!
95-374
10
.
1,3 •DkblorobciU£&e
S41.-3J-1
10
600
1,4- Dicfel«ret»c azeac
106-16-7
10
75
1 J2-Didblofobduue»«
93-50-1
10
600
2-Mdi)r!(^eaot
9S-4J-7
10
2,2"o*ybn (l -Cblorv|>fo|MLDc)
ICS-60-1
10
.
4-Mcihylf*he«ol
106-44$
10
N'HiireaoHdi'S-ffop^Umiftc
621-M-7
to
-
Keucbloroesfc*&e
67-72-1
10
Niirohcfttf o<
9S.JJ. J
10
,
Ifrophoroac
71-59-1
10
2N>Lrop4w>ol
U 75-5
10
2.4-Di meshy Ip&eool
SOS-67-9
10
-
bit-Cl-OloroexKoxy) fdmc
1H-9I-I
10
2.^Didb!orophc4»ot
12043-2
10
.
IJ! ,4 -Trk& 1 orafauuMe
12042-1
10
70
N*pfeUt»Jc«c
91-20-J
10
4-€&iorMAili&e
106-474
10
-
H e xacMorobw ud icac
17-61-5
10
4"Qilofo3-mclfc)flphe»o3
$9-50-7
10
.
2-Mobyto*(&tfea3aK
*1-57-6
10
.
Hcxjhchkwnocy elope* I»d i cot
77-47-4
10
50
2,4 .fr-T rkfc Img&caot
M-06-2
10
-
2,4 ricii lorephesol
»$-»$-«
25
50
f 1-51-7
10
2-NttrMailiac
((¦74-1
25
Di»gtyl(i>nfcal««r
Ul-ll-J
10
Acr«aptlkykc«c
21*-964
10
•
l.H>i«iim»l»i«i
<06-20-2
10
3*N**a»arliae
*9-09-2
23
AccaafMbcac
OS2-9
10
2,4-Diatun^caol
51-M-J
13
m
*-N*roj*e»ol
100-02-7
15
-
Geld«r Associates
-------
1995
933-3928
TAI1I.E S
1'aiic 3 of 4
TAKCfrr COM!*OUND LIST
Barecloneta LanSfilJ Site
Rarceloneu. Puerto Rico
*',» ."'-'Z V"*'' - MAXIMUM *«
- : -REQUIRED:.
. CONTAMINANT *,
.... •
QUANTITATION
LEVEL (m$/D
* . . ' ; ¦ -
, LIMIT 0-sO).
+ «* "¦ • .\V
SEMI-VOLATILE
COMI*OUNDS (cont'd)
DibeorofursD
132-64-9
10
2,4-Otna/oioluene
121-14-2
10
Dicihylphihalue
84-66-2
10
„
4-Chlorophcnyl -phcryl cihcr
7005-72-3
10
„
Ruorcne
86-73-7
10
-
4-Nitrouiilic
191-24-2
10
-
FN :M3isk$33>392fttab!eiWsea j«I*
Golder Associates
-------
M*rch 1995
933-3928
TAHLli 5
l*«£t 4 of 4
TARGET COMl-OUNO LIST
narcelonrta Landfill Site
Uarceloncu, fueno Rico
'W-/COfmucr^
: r.•.*•-' .¦#?;•:' .'REQUIBEO\/r'-F'TONT^IlNANTl
; ¦' V;r'.y;r-.-¦.<'• '¦ •;'¦¦. : * quantitation V level&«m. '
r"'-'-,r-... . ' LIMIT V
I'ESTl CI DES/AROCLOKS
*)ph«-BHC
319146
0.05
beu-BHC
3I9S5-7
0.05
.
dcJu-BHC
319-86-1
0.05
.
gunmt-BHC (Lindane)
58-89-9
0.05
0.2
HcpuchJor
76-44-8
0.05
0.4
Aldrin
309-O&-2
0 05
Heptachlor epoxide
1024-57-3
0 05
0 2
Eadolsulfafie 1
959 9$ S
0.05
Dieldrin
60-57-1
0 1
4.4 -DDE
72-55-9
0.1
•
Ejidrin
72-20-8
0.1
2
Endotulfane 11
33213-65-9
0.1
4-4'-DDD
72-54-8
0.1
Eadotulfajte tulf&ic
1031-07-8
0.1
4-4--DDT
SO- 29-3
0.1
-
McUtoxyehlor
72-43-5
0 05
40
Endrir ketone
53494-70-5
0.1
Eadrm aldehyde
7421-36-3
0.1
.
alpha-Chlordane
5103-71-9
0.05
2
gantma-CMordanc
5103-74-2
0.05
2
Toxapbeae
8001-35-2
5
3
Aroclor-1016
12674-11-2
1
.
Aroclar-1221
11104-28-2
2
.
Aroclor-1232
11141-16-5
I
Arocter-1242
53469-21 -9
1
.
Aroclor-124S
12672-29-6
1
Aroelor-1254
11097-69-1
1
2
A/oelor-1260
11096-82-5
I
NoU: - - No MCL baa bee# established for this compound.
FN ADisk\933-392S1iables\un»«njd»
Golder Associates
-------
March 1995
933-3928
TABLE 6
TARGET ANALYTE LIST
Baccloncta Landfill Site
BarceJoncu,
Puerto Rico
"/- .*.v ^l '
«'?.CONTRACT^- ,
*:} v - M AX! MXJM "<=;
* SECONDARYV
^ANALVTE
. > •; REQU1 RED V
¦lcomAMMmr%
dctection"
LEVEL (MCL) ^
CONTAMTNENT
P ¦ " LIMIT
p o«g/D-
LEVEL
-------
March 199S
833-3928
TABLE 7
MONITORING WELL CONSTRUCTION DATA
Barceloneia Landfill Site
Barcelonala. Puerto Rico
MONfTORING
SURFACE
ELEVATION ! .
. , BORING
DEPTH
TOTAL DEPTH
OF WELL
DEPTH TO TOP OF
BENTONITE SEAL
OEPTH TO TOP OF
SANO PACK
SCRECNEO
INTERVAL
OEPTH TO TOP OF
SUMP(a)
well Number
(meters)
(tee!)
(meters)
(feet)
(meters)
(leel)
(meiers)
(leet)
(meiers)
(leet)
(meters)
(feet)
(meiers)
(leet)
MW-i
146.09
479.29
103.6
340.0
81.9
269
67,5
221.5
7t.2
233,5
74.4-80.5
244-264
80.5
264.0
MW-2
127.51
418.33
73,2
240.0
69.8
229
56.4
185,0
58 8
1930
62.2-68.3
204-224
68.3
224.0
MW-3
120.78
422.50
65.3
280.0
80.8
265
67.1
220.0
68.3
224,0
73.2-79.2
240-260
79.2
260.0
Kftf-4
145.50
477,36
65.3
280.0
80 8
265
m
(0)
70.1
230.0
73.2-79.2
240-260
79,2
260.0
MW-S
141.01
462.63
91.4
300.0
83.8
275
71.9
236.0
74.1
243.0
76 2-82.3
250-270
82.3
270.0
MW-6 ,
145.08
475.98
118.9
390.0
98.5
318
84.0
275.5
06,9
205.0
90.8-96.9
298-318
96.9
318.0
WW-7
140.53
461.05
109.7
360.0
105.5
346
92.5
303.5
96.0
315.0
99.4-105.5
326-346
(c)
-------
March 1995
TABLE B
(Page 1 or 3)
GROUNDWATER ELEVATION DATA
Barceloneia Landfill Site
Barceloneta, Puerto Rico
933-3928
MONlTORINd
WELL-
NUMBER
TOC(«)
ELEVATION
(malar*)
TOC
ELEVATION
(faaij
OROUNDWATER
ELEVATION
(molar •)
GROUNDWATER
ELEVATION
(lost)
GROUNDWATER
ELEVATION
(molm)
OROUNOWATER
ELEVATION
(fool)
GROUNDWATER
ELEVATION
(mttari)
GROUNDWATER
ELEVATION
GROUNDWATER
ELEVATION
(matari)
GROUNDWATER
ELEVATION
(Ml)
1/27/1992(b)
2/18/1992(b)
3/12/1992(0)
3/l9-25/92(b)
MW-1
146.570
400.87
69.995
229.64
69.931
229.43
76.177(c)
249.92 (c)
77.527(c)
254.35(c)
MW-2
127,980
419.88
—
...
60.608
199 50
60.696
199.13
60.619
198,88
MW-3
129,310
424.24
...
...
...
...
60.107
197.20
60.208
197.53
MWf4
146.040
479.13
...
...
71.638
235.03
...
...
71.089
233.23
MW-5
141.620
464.63
...
...
...
...
...
...•
...
MW-B
145.690
477.98
...
...
54.825
179.87
54.560
179.00
54.596
179.12
MW-?
141.130
463.02
...
...
...
...
40.228
131.98
40.210
131.92
MW-8
136.200
446.84
...
41.953
137.64
40.609
133.23
40.551
13304
NOTES:
— a Water l*wl dtla not fa«ord«d.
Elavallon data arc provldad r«l»r»nc»d le malara and laal «bov» maan taa lavtl.
(~) ¦ TOC tl Iha lopolcaalng from which waltr (aval maaiuiamanli wara ra«xdad
(~) • Walar lavali maaai/rad ptlw (e davalopmanl.
|e) • Oroundwalaf alantton maaturamant may haw* baan aftaclad by watat on Iha ilda of caiing (Rino. Saplambar, its?).
m:\UlkV33-3tUWvdtfr w* f
Ooldtr A»»oclate»
-------
March 1995
933-3928
TABLES
(Page 2 of 3)
GROUNDWATER ELEVATION DATA
Barceloneta Landfill Site
Barceioneia, Puerto Rico
MONltdRINtS
WELL
NUMBER
TOC{8) toc
ELEVATION ELEVATION
(molars) (test)
GROUNDWATER
ELEVATION
(meters)
GROUNDWATER
ELEVATION
(feet)
GROUNDWATER
ELEVATION
(meters)
GROUNDWATER
ELEVATION
(feel)
GROUNDWATER
ELEVATION
(meters)
GROUNDWATER
ELEVATION
(feet)
GROUNDWATER
ELEVATION
(meters)
GROUNDWATER
ELEVATION
(feet)
4/13-14/92
5/13-15/92
5/18-20/92
7/24/93
MW-1
148.570 480.87
69.974
229 57
69.974
229 57
69.989
229.62
72.090
236.51
MW-2
127.980 419.88
60.686
199.10
60.500
198.49
60.860
199.67
65.050
213.42
MW-3
129.310 424.24
59.449
195.04
59.357
194.74
59 543
195.35
64.080
210.23
1
MW-4
146.040 479.13
71,324
234.00
71.342
234.06
71.333
234.03
71.240
233.72
MW-5
141.620 464,63
66.121
2)6.93
66.091
216,83
66 270
217.42
66.390
217.81
MYV-8
145.690 477,98
54.584
179.08
54.584
179.08
54.612
179.17
55.010
180,«7
MW-?
141,130 463.02
40.182
131 83
40.167
131.78
40.152
131.73
40.090
134.18
MW-8
136.200 446.84
40.438
132.67
40.094
131.54
40.338
132.34
41.920
137.06
NOTES:
—-» wiler level data not recorded.
Elevation data are provided referenced to meters and leet above mean sea level.
a. TOC Is Ihe loo of well casino from which water level measurements were recorded.
b. Water levels measured prior to development.
c. Groundwater elevation measurement may have been affected by water on the sids of casing
-------
March 199S
§33-3520
TABLE 8
Page 3 ot 3
GROUNDWATER ELEVATION DATA
Barcelonela Landfill Site
Barceloneia, Puerto Rico
Monitoring
well
NUMBER
TOC(a)
ELEVATION
(meters)
. TOC
elevation
(leet)
GROUNDWATER
ELEVATION
(meters)
GROUNDWATER
ELEVATION
(feet)
GROUNDWATER
ELEVATION
(meiers)
GROUNDWATER
ELEVATION
fleet)
11/11
-17/93
1/13/94
MW-1
146.570
480.8?
—
—
70.110
230.01
MW-Z
127,980
419.88
63.880
20958
64.180
210,56
MW-3
129.310
424.24
64.760
212.46
63.090
207.00
MW-4
146.040
479.13
71.730
235.32
71.660
235.12
MW-5
141.620
464.63
66 020
21659
66.070
216.76
MW-8
145.690
477.98
54.660
179.33
54,490
178.76
MW-7
141.130
463.02
40640
133 32
40.167
133.06
MW-8
136.200
446.84
41.320
135.55
40.094
13S.32
NOTES:
— . water leval data not recorded.
Elevation data are provided referenced to meters and (set above mean sea level.
a. TOC Is the lop of well casing from which water level measurements were recorded.
b. Water levels measured prior to development.
c. Groundwater elevation measurement may have been aiiected by water on the side
of casing (RImo, September, 1992).
fN:taikWi3-3euV»bl0ll0M*l*3.*llt
Oolder Associates
-------
March 1995 933-3928
TABLE 9
MONITORING WELL REDEVELOPMENT SUMMARY
Barceloneia Landfill Site
Barceloneia, Puerto Rico
DEPTH
TOTAL
WELL
TO
CASING
DISCHARGE
VOLUME
STABILIZED FIELD PARAMETERS
TURBIDITY
WELL
'• -
DEPTH
WATER
VOLUME
RATE
DISCHARGED
pH
sp. Cond.
Tamp
INITIAL
[ FINAL
NO.
•DATE
(meters bos)
(meters toe)
(oal)
(gpm)
(Oa0
(S.U.)
fc/mhos/cm)
(C)
(NTU)
(NTU)
METHOD
MW-1
7/12/93
81.9
75.16
14.6
1.6-3
270
7.02
703
269
124
<1
SS PUMP
MW-2
6/17/93
69.8
64.75
10.8
NA
60
6.88
605
26.4
990
>1000
SS BAILER
6/22/93
NA
NA
NA
12
7.02
550
26.7
125
904
SS BAILER
8/30/93
64.65
11.0
1
185
7.05
542
39.8
>1000
195
SS PUMP
7/1/93
NA
NA
NA
NA
NA
NA
NA
NA
NA
SURGE BLOCK
11/10-11/93
64.10
11.1
NA
190
6 20
567
29 0
>1000
463
PUMP/SURGE
MW-3
6/17-18/93
80.8
66.92
29.7
1-6
600
7.01
547
26.4
432
>1000
SS PUMP
6/21/93
66.92
29 7
NA
180
7.03
568
25.8
>1000
>1000
SS BAILER
11/10/93
64.55
34.7
NA
too
5.77
5C1
26.3
10
>1000
PUMP/SURGE
MW-4
6/23/93
80. B
73.76
15.0
<1
80
6.73
1741
32.4
28
NA
PUMP/BAILER
6/29/93
NA
NA
NA
NA
NA
NA
NA
NA
NA
SS PUMP
MW-S
7/13/93
83 J
75.28
18.3
2-6
265
6.85
710
27.8
110
6
SS PUMP
7/15/93
NA
NA
<1
35
NA
NA
NA
NA
NA
SS BAILER
MW-6
7/14-15/93
88.5
90.56
4.4
<1
43
6.74
732
27.5
>1000
>1000
SS BAILER
7/21/93
NA
NA
NA
65
6.40
650
27.0
>1000
32
SS PUMP
MW-7
7/2/93
105.5
100.23
11.0
<1
285
6.78
742
27.9
>1000
33
SS PUMP
7/7/93
NA
NA
<1
40
7.03
739
25.3
>1000
>1000
SS BAILER
Mvv-e
7/8/93
99.1
NA
13.7
1
245
6 99
620
28.2
>1000
95
SS PUMP
NOTES: bgt ¦ mtitrtb#lowground lurlie*
C - 0»gr»#»C«lclu*
mtltit loe« b«low lop olMllng NTU « N«ph«tom»ltlc lubldlijr unln
gil » gtllont S$ Pump • Slalnlttt il«tl lubmtrdbl* pump
gpm • gtllont pit mlnul# NA • Not »vilt«bl«
S.U, * 5Und«rd pH unit#
Sp. Cord, m 6p«cl5o Conductine*
umho«/cm m fnleromhoi p»f ctnUmtlif
miOMVM-jmUtblttlrnmi. w* I
©oldat Associates
-------
March 199S
933-3928
TABLE 10
SUMMARY OF SLUG TEST RESULTS
Barcelona landfill Site
Barceloneta, Puerto Rico
BOUWER AND RICE METHOD
HVOBSLEV METMOO
FALLING HEAD TEST
HYDRAULIC CONDUCTIVITY
RISING MEAOTEST
HYORAULIC CONDUCTIVITY
FALLING HEAO TEST
HYDRAULIC CONDUCTIVITY
RISING HEAO TEST
HYDRAULIC CONDUCTIVITY
WILL NO.
(CMfSEC)
(FT/DAY)
(CM/SEC)
(FT/DAY)
(CM/SECJ
{FT/OA Y)
(CMfSEC)
(FT/DAY)
MW-t
NA
NA
a4E-04
its
NA
NA
I.3E-03
371
MW-f
NA
NA
57E-05 .
o.t$
NA
NA
T»E-OS
023
MW-1
• 7E-04
190
47E-04
t 33
7 6E-04
2 ie
S.3E-04
1.S0
MW-4
NA
NA
3 OE-OJ
0 01
NA
NA
4 IE-OS
0.12
MW-I
• 06-04
2 U
«SE-04
2 TO
1 tE-03
3 ?S
1 26-03
3 48
MW-*
NA
NA
#11-04
5 51
NA
NA
1 2E-0J
342
Mw-r
NA
NA
I.2E-04
0.14
NA
NA
I7E-04
0.47
MW-I
NA
NA
63E-05
Oil
NA
NA
• OE-OS
0.2S
GEOMETRIC MEAN
2IE-04
0 79
38E-04
1 04
NOTE: Qaonatile mean Includaa both falling hoad tail and rlalng haad tad data.
NA ¦ Nnl AvalliMa. No telling haad Wat raiulta art rapwlid lot lha Willi In which
-------
m«<* ias»
»313«2S
TABU 1!
SUMMARY Of SOU. OEOTCCHMCAL DATA
B«ro*lon«ta Landfll SK*
Raterionata, Puarto Met
SBBSa
2.8E-07
3JE-OB
4.AE-08
3.ee«a
2.0E-08
65-J
CEO-1
GEO-3
GfO-J
GEO-2
lo,7
17.07
41,11
9S.B
100.0
100.0
NA
118.J
107 ,•
Mil
os-i.e
ss-io
8S-50I1I
100.0
88-11
net
111 S«i Sampl* GEO-J wa« ra-»«tl«
-------
March 1986
TABUE12
GROUNDWATER FLOW OF THE
NORTH COAST LIMESTONES
Barcelomta LandfiB Sit*
Bareetoneta. Puerto Rloo
I3MI28
1 MwfSS3|^^SIfeJeS7t^KiS3! i KPiw
Sr?g
V«qa Alts-La Plats
Aymamon Lknaftona
Aguada Umnw
CBtaa Llfta#®ifloa
Imw. Utimmi
Total
•0
7#
190
130
0.0007S
OJOOOfOM
0J002BU1
0«»*a)
0.1
0A2
0.002
o.ooos
0.04S
0.011
0.006
0.0O2
OjOS7-O.BO»or 12km
M anatf-Tortuguero
Afm»man Lfrnaftona
Aguada UnwnorM
CAm UmoHono
Una Uranoit
Told
•0
to
no
110
0.00057
O.OOOS7
O.OOIt
0.0028
C.I
OJOOS
0.0005
0JDQ02
0.0910
0.0020
0.0034
0.0008
0.06#0«0.*7 par 1tta«
A/»a"bo-&aro«Ion*u
Aymamon Umtnont
Aguada Umoatona
ynnfiofw
LjMM UrrMMRMW
Joft
so
100
ISO
TS
0.0OO9S
0A009S!o)
0.0021
0.0021
Q2
0J02
0.001
0.0002
0.11*0
0.0190
OjOISO
OjOOOJ
0.15Z3-2.2»«or ISkffl
Carm*y-A/'ea*b©
Ayma/rKft* UrrottOA*
Aeu#d« Ltfmrww
CSfeao Urr+t\oem
Lim yrfHMOni
Told
to
to
200
300
O.OOl
OJO0!
OMM
OjOOSia)
OjOS
0.002
0.001
OjOOOI
0.0300
o.ooia
0.0051
0.001*
O.Stt-0.43 for 11km
Guftjstacft-CamuY
Aymamon Unanona
AguM* li«Mtano
Obas Ltnanono
Ural
T.taJ
•0
•0
200
390
OjOQMm)
0-C01la>
0.003)
{a)*Ectimatad
cnVv ¦ Mfltfrrwtara^feMond
mS/» ear km m mMe awiM vme aaoend par UenaMr of aoUfar witfOv
FN.iDMcW33-3a20UMHV*«wfle.WK1
-------
March 1995
TABLE 13
933-3923
BACKGROUND SOIL ANALYTICAL RESULTS -
SUMMARY OF DETECTED PARAMETERS
BafCfilon#ia UndiHt Silt
Oarceioneia, Puerto Rico
|*C10«OUM9
MHCOM'iOlMCt
• AHPltV
H-tW
ll-l»l
»I~I«A
•l-lll
IS-I«A
II.IM
•i~ii«
• MM
11-90*
ll-MCfM ll>|IA
• l-lll
It'ttA
it-n»
IIM
II-)
tt*9
IM
UWHI OATf
IM1MI
tmtt*
•IMVtl
~mini
HUM*
IKI2/I4
lift***
|l»»l/U
•Kl»l«
i»ny»4
»invi4
mn%m
•Iflftlf
»aaamctia mm
VMt$
*«*¦*•»»
•I'M
xm
*«!••
VMM
met
tno*
l»»M
HIM
}(M0
IMM
t«M»
I'Mtt
IMM
»IM
IMM
IMM
HMO
WM
mot
IMOOf
•1 tu
Hi W WW)
MfTtf
<1 U
?Wt
nut
• u»
9 411
t*J9
• tit
«IU
/•
ft U
€t tj
1 1/1
1 U
«»u
1 1*9
f u
tut
«• 41
IIM
ill
04 1
§***•
•01
• ••
tut
till
SOI
Ml
Ml
»)l
Ml
If 11
f <1
t «•
1911
t< II
II St
IIII
IM
It It
n
1 )•
ii i
Ji i
1) )•
If ••
M
Of
If 1
If*
IIII
HI
U 4
••
Id
C««H«
Ml
*t i
41 f
**!
*1 1
Iff
U J
III
If I
If W
IIM
II w
II u
Ml
•««i
1
•01
Mil
ITU
!
• *1
•
1 II
< M
« 1!
< *1
« It
I Ml
«•
It
4 •<
4IH
«S tl
<0«l
4IMU
MC
••AM
•ftl
MM
!» <1
•1 »
H II
» «•
• 1 »•
fi «l
!»!•
II
• I 10
• < ••
If <•
*f ft
II 11
SHI
1JM
MM
MM
H>W
rtMMW*
•01
« H
•01
M4I
I'W
N'^
»IU
(•O
nxi
liw
1ILI
nu
J tu
JIU
Ulf
M«
Ml
IHJ
IM
•01
l«
Ml
fit
Ml
IP 1
«•
II •
10 1
III
M •
If f
Hi
MI
II 1
III
III
III
HI
1) ii
Mf
WXAT«.U
0«XWC»
KMfiNf
«0«
Mt
Ml
Ml
MS
Nf
Mi
Ml
Mt
N|
Ml
Ml
Ml
M»
M|
MS
4»J
<11
•**•#>•« tm iBBT*»
< • !»*• MH INi »WNf< IMP*iM wmn M ICAMI •» MMhm *MW»Ml •«• iCAOtJ
4 - VW ftVAftMf «•** «M MWWlM M • t»Ml «f Mil MlMinM
H>|l« «•«* M • f«wll «i *M •«•*<**
• • «N» ««IM to ar««l«r *»• 0m Mmnto* M {IflHJ W Imm *•* hw CftGl
* - ft»« t%0 |Ml KM «MI *»tt** M • ** MIMfMl BSlMltM** *#»• W* to«r»t l«**U4 * M»>a*
HA • MM
Mt'NR «»«*M
•I | .IHI1 nwm ••• MM *4%* • »*»»*4I»» • >« *mhkn «¦>*< ¦
*•••»•», »* t—m—oUmi b
•6 • MM *» M N«K JM>4*«»t» «l IM«IMKW v«fc MMHlMMflNf *•*«•
IM», •*M%oMM*toM44 l**«i*IHPCI»t •
aiMMi* hm •».!, tt-t. ii-i. **• l»«t •«» mXhfN im* tcift.
m« >»—ii k»h« lit"* whiw>i m fftct»i •<•*•
#M^i*ti»-Mi«f*iui*tACKMri w«t "
Ooldar Associates
-------
Mdic 1* 1&9S
933-3921
TAOLE 14
sub-waste soil analytical results - SUMMARY OF OrrtCTGO parameters
Barcoloneia Landfill Sila
Batcalonala. Puarto Rice
BACKGROUND
parameters
UNITS
6S-?
.• ss-i
ss-«
SS-10
SS-12
•5* CONFIDENCE
SAMPLE DATE
01/10/92
01/13/92
01/14/92
01/14/92
01/14/92
01/16/92
PREDICTION
METALS
INTERVAL
ALUMINUM
mg/kg
15300
1S900
22400
22300
NS
19200J
43254
ARSENIC
mg/kg
•1J
49J
14.7J
23 iJ
NS
37.«J
94.6
BARIUM
mg/kg
12.38
1 6B
11 48
14 6B
NS
24.38
101
BERYLLIUM
mg/kg
O.ltB
0.528
IB
0 92
NS
1.2
2.77
CADMIUM
mgfltg
10.3
11J
s.a
1.1
NS
14.7J
• 12
CALCIUM
mg/kg
itao
• 6CB
• 670
5730
NS
1S50J
11600(1)
CHROMIUM
mg/kg
2»2
273
its
1*7
NS
161J
42«
COBALT
mo/kg
4B
6.2B
11 93
12 9
NS
14.1
200
COPPER
mg/kg
31.U
51.3J
42J
3* 7J
NS
41 3J
66.6
IRON
mg/kg
70500J
77700J
665G0J
6SS0CJ
NS
65500J
133217
LEAD
mg/kg
6.9J
7.9J
1 «J
a u
NS
13 7
21.6
MAGNESIUM
m g/kg
636B
' 3SSB
769S
7*2B
NS
442BJ
1140 (IS
MANGANESE
mg/Vo
247
193
510
597
NS
1570J
4S44
MERCURY
mg/kg
<0.11
<0,11
0.3SJ
<0 12
NS
0.15J
1 ?«
NICKEL
mg/kg
1#
13«
21.4
IB *
NS
15 4
37.1
POTASSIUM
mg/kg
591 Bb
744Bb
47560
rttottn
NS
7416
sot
SILVER
mgtkg
<0.54
2.IB
1 39
<0.55
NS
<0 62J
NC
SODIUM
mgtkg
2660J
3070J
2410J
23S0J
NS
2E30J
2680 (1)
THALLIUM
mg/kg
0.278
0.29B
0 413
0 37B
NS
0.69JB
NC
VANADIUM
mg/kg
232
325
232
239
NS
209J
411
ZINC
mg/kg
7a. t J
»5 4J
124 J
102J
NS
•3.2J
99,7
VOLATILE ORG ANICS
ACETONE
720J
<170
9900J
BfcOOJ
<1200
15000J
NC
BENZENE
9
78b
<7
<510
<520
<8 SO
<1700
NC
SEMI VOLATILE ORGANICS
BIS(2-ETHYLHEXYL)PHTHALATE
M}*9
750
100B
7 SB
468
NA
<420
NC
butylbenzyi pmtmalate
*9*9
• IB
<440
<450
<420
NA
<420
NC
2-METHYLPHENOL
<430
<440
<450
<420
NA
53B
NC
«-«ethylpmenol
*0*0
<430
<440
<450
<420
NA
3300
NC
PHENOL
«*9
<430
<440
<4S0
<4M
NA
4760
NC
NOTES:
¦ - duplicate umpl* of SS-9
pQ/kg - microgram p*> kilogram
mg/kg - milligram par kilogram
< - I*m than Om contract raquirad dataction ttmrt (CRDL) or contract r«qu«ad quantitation limh (CROL).
J - th» Kpon>d **li» w«< •tumalad at a raault oi data validation.
R-tha data was rajactad at a faau# el data validation.
B - tha valua «ti graatar than lha Mathod Datactioii Umit (MOD but ¦«*« ttun tlw CRDL or CRQL.
b -notdalactad cubaantiallyabowalava!rapartadin thalaboratory0»(aid blank*.
NA - not *ppUcabla
NS - not aamplad
(t) - Tha •§ par cant confidanca production imarval *ai net caleulalad dua to tn« tack e< a dafinabia population distribution and
apparani spatial wialMlHjr. Howavar. tha highatt background concentration i« «tc
Ml.
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Golder Associates
-------
Match IMS
•33-3921
TABLE IS
LEACHATE ANALYTICAL RESULTS
SUMMARY OF DETECTED PARAMETERS
Batcalonala Landfill Siis
Baicalonota. Puarlo Rico
MSWLF
UNDFILL
METALS CONCENTRATION
LEACHATE
LEACHATE
(mg/lj
(mQ/1!
-------
March IMS
tjj-3jai
TABLE IB
(PAOE 1 OF 7)
QROUNOWATER AND SPRING ANALYTICAL RESULTS
- SUMMARY OF DETECTED PARAMETERS
BARCELONETAtANOFUl site
BARCELONETA. PUERTO RICO
UNITS
MW-1
MW-tA (a|
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MW-1
MW-1
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MW-2
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MW-3
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SAMPLE DATE
04/11*2
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04/15/92
05/20/02
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11/17*3
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-------
March IBM
(33-3921
TABLE 18
(PAGE J OF 7)
QROUNOWATER AND SPRINO ANALYTICAL RESULTS - SUMMARY OF DETECTED PARAMETERS
BARCELONETALANOFILL SITE
BARCELON6TA, PUERTO RICO
SAMPLE OATS •
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(PAOE J OF 71
GROUNDWATER ANO SPRINd ANALYTICAL RESULTS - SUMMARY OF DETECTED PARAMETERS
BARCELONETA LANDFILL SITE
BARCELONETA, PUERTO RICO
UNITS
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APPENDIX III
ADMINISTRATIVE RECORD INDEX
-------
BARCELONETA LANDFILL SITE
ADMINISTRATIVE RECORD FILE
INDEX OF DOCUKENTS
X.O SITE IDENTIFICATION
X.2 Notification/Site Inspection Reports
P. 100001 - Report: Open Dump Inventory Report, prepared by
100003 U.S. EPA, September 15, 1980.
X.3 Preliminary Assessment
P. 100004 - Report: Potential Hazardous Waste Site.
100007 Identification and Preliminary Assessment.
prepared by Mr. Wayne Pierre, U.S. EPA, September
14, 1981.
1.4 Site Investigation Reports
P. 100008 - Report: Potential Hazardous Waste Site. Site
100017 Inspection Report, prepared by Mr. David Lipsky,
Assistant Field Investigation Team Leader, Fred C.
Hart Associates, prepared for U.S. EPA, August 6,
1981.
P. 100018 - Report: Potential Hazardous Waste Site. Site
100036 Inspection Report, prepared by Mr. David Lipsky,
Assistant Field Investigation Team Leader, Fred C.
Hart Associates, prepared for U.S. EPA, August 6,
1981.
P. 100037 - Report: Potential Hazardous Waste Site. Site
100042 Inspection Report, prepared by Mr. Dave Lipsky,
Assistant Field Investigation Team Leader, Fred C.
Hart Associates, prepared for U.S. EPA, March 2,
1982.
P. 100043 - Report: Barceloneta Landfill. Site Investigation.
100058 Barceloneta. Puerto Rico, prepared by Ms. Kristen
K. Stout, Imagery Analyst, The Bionetics
Corporation, prepared for U.S. EPA, August, 1982.
P. 100059 - Report: Hazardous Ranking System Package, prepared
100094 by Mr. David Lipsky, Assistant Field Investigation
Team Leader, Fred C. Hart Associates, prepared for
U.S. EPA, August 3, 1982.
1
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3.0 REMEDIAL INVESTIGATION
3.1 Sampling and Analysis Plans
P. 300001 - Plan: Revised Sampling and Analysis Plan,
300158 Remedial Investigation/Feasibility Study, Part 2:
Slug Testing, Background Soil Sampling,
Barceloneta Landfill Site, Barrio Florida Afuera,
Barceloneta, Puerto Rico, prepared by Paul C.
Rizzo Associates, Inc., prepared for Barceloneta
Landfill Site PRP Group, March, 1993.
P. 300159 - Plan: Revised Sampling and Analysis Plan,
300335 Remedial Investigation/Feasibility Study. Part 1:
Groundwater Sampling. Barceloneta Landfill Site,
Barrio Florida Afuera, Barceloneta. Puerto Rico,
prepared by Paul C. Rizzo Associates, Inc.,
prepared for Barceloneta Landfill Site PRP Group,
June, 1993.
3.4 Remedial investigation Reports
P. 300336 - Report: Revised Site Characterization Summary
300611 Report. Barceloneta Landfill Site. Barceloneta.
Puerto Rico, prepared by Golder Associates Inc.,
prepared for Barceloneta Landfill PRP Group, c/o
Mr. Gordon Spradley, Browning-Ferris Industries,
Inc., May 1994.
P. 3 00612 - Guidance Document: Drinking Water Regulations and
300623 Health Advisories, prepared by Office of Water,
U.S. EPA, May 1994.
P. 300624 - Report: Remedial Investigation Report.
301340 Barceloneta Landfill Site. Barceloneta. Puerto
Rico, Volume 1 of 2, prepared by Golder Associates
Inc., prepared for Barceloneta Landfill PRP Group,
c/o Ms. Susan Gilliland, DuPont Corporate
Remediation, March 1995.
P. 301341 - Report: Remedial Investigation Report.
302177 Barceloneta Landfill Site. Barceloneta. Puerto
Rico, Volume 2 of 2. prepared by Golder Associates
Inc., prepared for Barceloneta Landfill PRP Group,
c/o Ms. Susan Gilliland, DuPont Corporate
Remediation, March 1995.
302178 - Report: Abbreviated Risk Assessment. Barceloneta
302180 Landfill, Barceloneta. Puerto Rico, prepared by
U.S. EPA, Region II, May 4, 1995.
2 7-
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3.5 Correspondence
P. 302181 - Letter to Ms. Carole Petersen, Chief, New
302435 York/Caribbean Superfund Branch II, U.S. EPA, from
Mr. Marc E. Dillon, P.G., Project Hydrogeologist,
Golder Associates Inc., Mr. Mark J. Jordana, P.G.,
Senior Project Manager, Golder Associates Inc.,
and Mr. Donald J. Miller, P.E., Associate, Golder
Associates Inc., re: Responses to EPA Comments,
Revised Site Characterization Summary Report,
Barceloneta Landfill Site, Barceloneta, Puerto
Rico, December 9, 1994. (Attached: tables and
chain of custody forms)
P. 302436 - Letter to Barceloneta Landfill PRP's Group, c/o
302436 Ms. Susan K. Gilliland, P.G., DuPont Specialty
Chemicals, Corporate Remediation, from Ms. Carole
Petersen, Chief, New York/Caribbean Superfund
Branch II, U.S. EPA, re: Approval of a New
Monitoring Well Location and Procedures Described
in March 31, 1995 Letter, April 12, 1995.
P. 302437 - Facsimile transmittal sheet to Mr. Luis Santos,
302444 U.S. EPA, Mr. Mel Hauptman, U.S. EPA, Mr. Genaro
Torres, Ms. Ivette Ortiz de Vega, Mr. Lisandro
Reyes, and Ms. Linette Velez Rodrigues, from Mr.
Don Miller, Golder Associates Inc., re:
Barceloneta Landfill Site, Letter Regarding
Filling Options for the Southeastern Disposal
Area, April 20, 1995. (Attached letter to Mr. Mel
Hauptman, Chief, New York/Caribbean Superfund
Branch, U.S. EPA, Region II, from Mr. Donald J.
Miller, P.E., Associate, Golder Associates Inc.,
re: Southeastern Disposal Area Fill Options,
Barceloneta Landfill Site, April 19, 1995.)
3^
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302445 - Facsimile transmittal sheet to Ingeniero Carlos
302449 Oneill, U.S. EPA, and Mr. Luis Santos, U.S. EPA,
from Honorable Sol Luis Fontanes Olivo, Alcalde,
Gobierno Municipal, Barceloneta, Puerto Rico, re:
Copias de Convocatoria y Resolucion a Discutirse
en la Asamblea Municipal, April 20, 1995. (Note:
This document, is written in Spanish.) (Attached:
1. Letter to Ingeniero Carlos Oneill, U.S. EPA,
from Honorable Sol Luis Fontanes Olivo, Alcalde,
Gobierno Municipal, Barceloneta, Puerto Rico, re:
copias de la convocatoria y resolucion que
discutiremos el miercoies 26 de abril a las 7:30
P.M. en la Asamblea Municipal de Barceloneta,
April 20, 1995. (Note: This document is written
in Spanish.) 2. Letter to Asamblea Municipal de
Barceloneta, from Honorable Sol Luis Fontanes
Olivo, Alcalde, Gobierno Municipal, Barceloneta,
Puerto Rico, re: Convocatoria a Sesion
Extraordinaria, undated. (Note: This document is
written in Spanish.) 3. "Agenda, Sesion
Extraordinaria, 26 de abril de 1995", prepared by
Oficina del Alcalde, Gobierno Municipal,
Barceloneta, Puerto Rico, undated. (Note: This
document is written in Spanish.) 4. Resolution
regarding the Barceloneta Landfill, undated.
(Note: This document is written in Spanish.))
3024 50 - Letter to Mr. Luis Santos, Remedial Project
302450 Manager, U.S. EPA, Region II, Caribbean Field
Office, from Mr. Genaro Torres Leon, Director,
Emergency Response and Superfund Area,
Commonwealth of Puerto Rico/Office of the
Governor, Environmental Quality Board, Superfund
Program, re: Prospective Closure Plan,
Barceloneta Landfill, April 25, 1995.
302451 - Letter to Honorable Sol L. Fontanes Olivo,
302452 Alcalde, Municipio de Barceloneta, from Mr. Israel
Torres Rivera, Director Interino, Area Control de
Contaminacion de Terrenos, Gobierno de Puerto
Rico, Oficina del Gobernador, Junta de Calidad
Ambiental, re: Plan de Cierre Prospectivo
Vertedero de Barceloneta, April 26, 1995. (Note;
This document is written in Spanish.)
4
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P. 302453 - Letter to Mr. Luis E. Santos, U.S. EPA, Region II,
302762 Caribbean Field Office, from Mr. Donald J. Miller,
P.E., Office Manager/Associate, Golder Associates
Inc., re: Monitoring Well Installation,
Barceloneta Landfill Site, Barceloneta, Puerto
Rico, April 27, 1995. (Attached: 1. Report:
Comprehensive Quality Assurance Plan, prepared by
and for Savannah Laboratories and Environmental
Services, Inc., December, 1994. 2. Report:
Statement of Qualifications, prepared by Savannah
Laboratories & Environmental Services, Inc.,
undated.)
5 ^
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P. 302763 - Letter to Ms, Sara Cortez, Departamiento de
302786 Recursos Naturales, from Mr. Donald J. Miller,
Associate, P.E., Golder Associates Inc., re:
Monitoring Well Installation at Barceloneta
Landfill, May 12, 1995. (Attached: 1. Figure:
"Well Location", prepared by Golder Associates
Inc., April 4, 1994. 2. Attachment 1: Letter to
Barceloneta Landfill PRP« s Group, c/o Ms. Susan
Gilliland, Superfund Manager, DuPont Corporate
Remediation, from Ms. Carole Petersen, Chief, Hew
York/Caribbean Superfund Branch II, U.S. EPA,
Region II, re: January 31, 1995 Meeting Summary
and Modified RI/FS Schedule, Barceloneta Landfill -
Superfund Site, February 23, 1995. 3. Attachment
2: Letter to Mr. Luis E. Santos, U.S. EPA, Region
II, Caribbean Field Office, from Mr. Donald J.
Miller, P.E., Office Manager/Associate, Golder
Associates Inc., re; Monitoring Well
Installation, Barceloneta Landfill Site,
Barceloneta, Puerto Rico, March 31, 1995. 4.
Map: "Approximate Off Site Well Location",
prepared by Golder Associates Inc., 4/4/95. 5.
Report excerpt: "Monitoring Well Installation",
prepared by Paul C. Rizzo Associates, Inc.,
November 25, 1991. 7, Attachment 3: Letter to
Barceloneta Landfill PRP's Group, c/o Ms. Susan K,
Gilliland, P.G., DuPont Specialty Chemicals,
Corporate Remediation, from Ms. Carole Petersen,
Chief, New York/Caribbean Superfund Branch II,
U.S. EPA, re: Approval of the New Monitoring Well
Location and Procedures Described in the March 31,
1995 Letter, April 18, .1995. 8. Attachment 4:
Letter to Mr. Marc Dillon, Golder Associates Inc.,
from Honorable Sol Luis Fontanes Olivo, Mayor,
Gobierno Municipal, Barceloneta, Puerto Rico, and
Mr. Lisandro Reyes, Environmental Director,
Gobierno Municipal, Barceloneta, Puerto Rico, re:
Permit to Drill a Sampling Water Well in City's
Properties, May 10, 1995.)
4.0 FEASIBILITY STUDY
4.3 Feasibility Study Reports
P. 4 00001 - Guidance Document: Presumptive Remedies: Policy
400008 and Procedures. Quick Reference Fact Sheet.
prepared by Office of Solid Waste and Emergency
Response, U.S. EPA, September 1993.
6
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P. 400009 - Guidance Document: Presumptive Remedy for CERCLA
400023 Municipal Landfill Sites. Quick Reference Fact
Sheet, prepared by Office of Solid Waste and
Emergency Response, U.S. EPA, September 1993.
4.6 Correspondence
P. 400024 - Letter to Hr. Melvin Hauptman, P.E., Chief,
400025 Eastern Hew York/Caribbean Superfund Section II,
U.S. EPA, Region II, from Mr. Donald J. Miller,
P.E., Associate, Golder Associates Inc., re:
Draft Feasibility Study Report, Barceloneta
Landfill Site, June 14, 1995.
7.0 ENFORCEMENT
7.3 Administrative Orders
P. 700001 - Administrative Order on Consent, in the matter of
700039 the Barceloneta Landfill Site, Index No. II
CERCLA-00304, September 28, 1990
7.7 Notice Letters and Responses
P. 700040 - Request for Information letter to Abbott
700043 Laboratories, from Mr. Conrad Simon, Director, Air
and Waste Management Division, U.S. EPA, re:
Request for Information regarding the Barceloneta
Landfill, Barceloneta, Puerto Rico, June 15, 1983.
P. 700044 - Request for Information letter to Browning-Ferris
700048 Industries of Puerto Rico, from Mr. Conrad Simon,
Director, Air and Waste Management Division, U.S.
EPA, re: Request for Information regarding the
Barceloneta Landfill, Barceloneta, Puerto Rico,
June 15, 1983.
P. 700049 - Request for Information letter to Pfizer
700053 Pharmaceuticals, Inc., from Mr. Conrad Simon,
Director, Air and Waste Management Division, U.S.
EPA, re: Request for Information regarding the
Barceloneta Landfill, Barceloneta, Puerto Rico,
June 15, 1983.
7
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700060
700064
700054 - Request for Information letter to Carsera Foods,
700059 Inc., from Mr. Conrad Simon, Director, Air and
Waste Management Division, U.S. EPA, re: Request
for Information regarding the Barceloneta
Landfill, Barceloneta, Puerto Rico, June 15, 1983.
(Attached letter to Mr. Conrad Simon, Director,
Air and Waste Management Division, U.S. EPA,
Region II, from Mr. Miguel Pagan, Chase Specialty
Metals Corporation, re: Response to Request for
Information regarding Barceloneta Landfill,
Barceloneta, Puerto Rico, September 198 3.)
Request for Information letter to Pfizer Disks
Inc., from Mr. Conrad Simon, Director, Air and
Waste Management Division, U.S. EPA, re: Request
for Information regarding the Barceloneta
Landfill, Barceloneta, Puerto Rico, June 15, 1983.
P. 700065 - Request for Information letter to Sterling
7 00069 Products International, Inc., from Mr. Conrad
Simon, Director, Air and Waste Management
Division, U.S. EPA, re: Request for Information
regarding the Barceloneta Landfill, Barceloneta,
Puerto Rico, June 15, 1983.
P. 700070 - Request for Information letter to Winthrop
700074 Laboratories, Inc., from Mr. Conrad Simon,
Director, Air and Waste Management Division, U.S.
EPA, re: Request for Information regarding the
Barceloneta Landfill, Barceloneta, Puerto Rico,
June 15, 1983.
P. 700075 - Letter to Mr. William K. Sawyer, Office of
700077 Regional Counsel, U.S. EPA, Region II, from Mr.
Steven J. Cieciura, Ph.D., Director of
Engineering, Research and Technical Services,
Schering Corporation, Puerto Rico, re: Response
to Request for Information regarding Barceloneta
Landfill, Barceloneta, Puerto Rico, June 24, 1983,
P. 700078 - Letter to Mr. William K. Sawyer, Office of
700079 Regional Counsel, U.S. EPA, Region II, from Mr.
Jose E. Casas, Environmental Engineer, Abbott
Chemicals, Inc., re: Response to Request for
Information regarding Barceloneta Landfill,
Barceloneta, Puerto Rico, July 6, 1983.
8
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700080 - Request for Information letter to E.I. DuPont de
700083 Nemours & Company, Inc., from Mr. Conrad Simon,
Director, Air and Waste Management Division, U.S.
EPA, re: Request for Information regarding the
Barceloneta Landfill, Barceloneta, Puerto Rico,
July 7, 1983.
700084 - Letter to Mr. William Sawyer, Office of Regional
700085 Counsel, U.S. EPA, Region II, from Mr. Candido
Jimenez, President, Warner Lambert, Inc., Response
to Request for Information regarding Barceloneta
Landfill, Barceloneta, Puerto Rico, July 11, 1983.
(Attached letter to Mr. William Sawyer, Office of
Regional Counsel, U.S. EPA, Region II, from Mr.
Candido Jimenez, President, Warner Lambert, Inc.,
Response to Request for Information regarding
Barceloneta Landfill, Barceloneta, Puerto Rico,
July 18, 1983.)
700086 - Letter to William K. Sawyer, Esquire, Office of
700094 Regional Counsel, U.S. EPA, Region II, from Ms.
Carol Dudnick, Union Carbide Corporation, re:
Response to Request for Information regarding
Barceloneta Landfill, Barceloneta, Puerto Rico,
July 13, 1983.
700095 - Letter to Wayne N. Pierre, Hazardous Waste Site
700099 Branch, U.S. EPA, Region II, from Mr. Othoniel
Garcia, Quality Assurance Manager, USV
Laboratories, Inc., re: Response to Request for
Information regarding Barceloneta Landfill,
Barceloneta, Puerto Rico, July 19, 1983.
(Attached Request for Information letter to USV
Laboratories, from Mr. Conrad Simon, Director, Air
and Waste Management Division, U.S. EPA, re:
Request for Information regarding the Barceloneta
Landfill, Barceloneta, Puerto Rico, July 7, 1983.)
700100 - Letter to Mr. William K. Sawyer, Office of
700114 Regional Counsel, U.S. EPA, Region II, from Mr.
John L. Ashby, Vice President and General Manager,
Merck Sharp & Dohme Quimica de Puerto Rico, Inc.,
re: Response to Request for Information, July 20,
1983.
700115 - Letter to Mr. Wayne H. Pierre, Hazardous Waste
700117 Site Branch, U.S. EPA, Region II, from Mr. W.A.
Adams, President, DuPont Agrichemicals Caribe,
Inc., re: Response to Request for Information
regarding Barceloneta Landfill, Barceloneta,
Puerto Rico, August 1, 1983.
9
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P. 700118 - Letter to Mr. Wayne N. Pierre, Hazardous Waste
700120 Site Branch, U.S. EPA, Region II, from Mr. I. J.
Ferrer, Vice President and General Manager,
Bristol Alpha Corporation, re: Response to
Request for Information regarding Barceloneta
Landfill, Barceloneta, Puerto Rico, August 2,
1983.
P. 700121 - Letter to Mr. Wayne N. Pierre, Hazardous Waste
700122 Site Branch, U.S. EPA, Region II, from Mr. Manuel
L. Hormaza, Engineering and Maintenance Group
Manager, The Upjohn Manufacturing Company, re:
Response to Request for Information regarding
Barceloneta Landfill, Barceloneta, Puerto Rico,
August 4, 1983.
P. 700123 - Letter to Mr. Wayne N. Pierre, Hazardous Waste
700123 Site Branch, U.S. EPA, Region II, from Mr. Frank
Lequerica, Vice President & General Manager,
Cyanaraid Agricultural de P.R., Inc., re;
Response to Request for Information regarding
Barceloneta Landfill, Barceloneta, Puerto Rico,
August 9, 1983.
P. 700124 - Second Request for Information letter to Bristol-
700126 Alpha Corporation, from Mr. Stephen D. Luftig,
Director, Emergency and Remedial Response
Division, U.S. EPA, Region II, re: Second Request
for Information Pertaining to the Barceloneta
Landfill, Barceloneta, Puerto Rico, December 1,
1987.
700127 - Second Request for Information letter to American
700129 Cyanamid Company, from Mr. Stephen D. Luftig,
Director, Emergency and Remedial Response
Division, U.S. EPA, Region II, re: Second Request
for Information Pertaining to the Barceloneta
Landfill, Barceloneta,
1987.
Puerto Rico, December 1,
P. 700130 - Second Request for Information letter to Upjohn
700132 Manufacturing, Company, from Mr. Stephen D.
Luftig, Director, Emergency and Remedial Response
Division, U.S. EPA, Region II, re: Second Request
for Information Pertaining to the Barceloneta
Landfill, Barceloneta, Puerto Rico, December 1,
1987.
10 „
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700133 - Second Request for Information letter to Roche
700135 Products, Inc., from Mr. Stephen D. Luftig,
Director, Emergency and Remedial Response
Division, U.S. EPA, Region II, re: Second Request
for Information Pertaining to the Barceloneta
Landfill, Barceloneta, Puerto Rico, December 1,
1987.
700136 - Second Request for Information letter to Sterling
700138 Pharmaceuticals, Inc., from Mr. Stephen D. Luftig,
Director, Emergency and Remedial Response
Division, U.S. EPA, Region II, re: Second Request
for Information Pertaining to the Barceloneta
Landfill, Barceloneta, Puerto Rico, December 1,
1987.
700139 - Second Request for Information letter to Warner
700141 Lambert, Inc., from Mr. Stephen D. Luftig,
Director, Emergency and Remedial Response
Division, U.S. EPA, Region II, re: Second Request
for Information Pertaining to the Barceloneta
Landfill, Barceloneta, Puerto Rico, December 1,
1987.
700142 - Second Request for Information letter to Schering
700144 Pharmaceuticals Corporation/Schering Corporation,
from Mr. Stephen D. Luftig, Director, Emergency
and Remedial Response Division, U.S. EPA, Region
II, re: Second Request for Information Pertaining
to the Barceloneta Landfill, Barceloneta, Puerto
Rico, December 1, 1987.
700145 - Letter to Mr. Jose C. Font, Project Manager, U.S.
700145 EPA, Caribbean Field Office, from Mr. C. M.
Jimenez Barber, Environmental Compliance Manager,
Schering Industrial Development Corporation, re:
extension of deadline to submit response to the
Request for Information, December 8, 1987.
11
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Letter to Andrew L. Praschak, Esquire, Office of
Regional Counsel, U.S. EPA, Caribbean Field
Office, from Ms. Laurel D. Breitkopf, Senior
Attorney, Office of General Counsel, Abbott
Laboratories, re: extension of time to respond to
Second Information Request, December 23, 1987.
(Attached: 1. Letter to Andrew L. Praschak,
Esquire, Office of Regional Counsel, U.S. EPA,
Caribbean Field Office, from Ms. Laurel D.
Breitkopf, Senior Attorney, Office of General
Counsel, Abbott Laboratories, re: request for
extension of time to respond to Second Information
Request, December 16, 1987. 2. Letter to Mr. Jose
C. Font, Project Manager, U.S. EPA, Caribbean
Field Office, from Mr. Brian J. Smith, Division
Counsel, Office of General Counsel, Abbott
Laboratories, re: Response to Second Request for
Information, February 1, 1988.)
Letter to Mr. Jose C. Font, Project Manager, U.S.
EPA, Caribbean Field Office, from Ms. Yazmin I
Reyes, Environmental Manager, Bristol-Myers
Barceloneta, Inc., re: enclosed certified
document, January 4, 1988. (Attached: 1.
"Attachment 3, Certification of Answers to Request
for Information", prepared by Mr. Tibor A. Racz,
General Manager, Bristol-Myers Barceloneta, Inc.,
prepared for U.S. EPA, January 4, 1988. 2. Letter
to Mr. Jose C. Font, Project Manager, U.S. EPA,
Caribbean Field Office, from Mr. Tibor A. Racz,
General Manager, Bristol-Myers Barceloneta, Inc.,
re: Response to Second Request for Information,
December 22, 1987.)
Letter to Mr. Jose C. Font, Project Manager, U.S.
EPA, Caribbean Field Office, from Mr. Don
Woodhouse, General Manager, Sterling
Pharmaceuticals, Inc., re: Response to Request
for Information regarding Barceloneta Landfill,
Barceloneta, Puerto Rico, January 12, 1988.
Letter to Mr. Jose C. Font, Project Manager, U.S.
EPA, Caribbean Field Office, from Mr. Edward A.
MacMullan, Vice President of Manufacturing
Operations, Roche Products, Inc., re: Response to
Request for Information regarding Barceloneta
Landfill, Barceloneta, Puerto Rico, January 13,
1988.
12-r-
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700776 - Letter to Mr. Jose C. Font, Project Manager, U.S.
700781 EPA, Caribbean Field Office, from Mr. Bernabe
Martir, Manager, Environmental Affairs, The Upjohn
Manufacturing Company, re: Response to Second
Request for Information, January 14, 1988.
7 007 82 - Letter to Mr. Jose C. Font, Project Manager, U.S.
700897 EPA, Caribbean Field Office, from Dr. Richard S.
Bowles, III, General Manager, Merck Sharp & Dohme
Quimica de Puerto Rico, Inc., re: Response to
Second Request for Information regarding the
Barceloneta Landfill, Barceloneta, Puerto Rico,
January 21, 1988. (Note: Pages 700891 - 700895
of this document are CONFIDENTIAL. They are
located at U.S. EPA Remedial Records Center, 290
Broadway, New York, New York, 10007)
700898 - Second Request for Information letter to Mr.
700904 Candido Jimenez, President, Warner Lambert, Inc.,
from U.S. EPA, Region II, re: Second Request for
Information Pertaining to Barceloneta Landfill,
Barceloneta, Puerto Rico, January 26, 1988.
700905 - Letter to Mr. Jose C. Font, Project Manager, U.S.
700910 EPA, Caribbean Field Office, from Mr. Frank
Lequerica, Vice President and General Manager,
Cyanamid Agricultural de Puerto Rico, Inc., re:
Response to Second Request for Information,
January 28, 1988. (Attached letter to Mr. Wayne
N. Pierre, Hazardous Waste Site Branch, U.S. EPA,
Region II, from Mr. Frank Lequerica, Vice
President & General Manager, Cyanamid Agricultural
de Puerto Rico, Inc., re: Response to Request for
Information regarding Barceloneta Landfill,
Barceloneta, Puerto Rico, August 9, 1983.)
700911 - Letter to Mr. Jose Font, U.S. EPA, from Mr.
700913 Eduardo Negron-Navas, Fiddler, Gonzalez &
Rodriguez, Attorneys and Counsellors at Law, re:
enclosed Certification of Answers to Request for
Information, February 1, 1988. (Note: This
document is written in Spanish.) (Attached:
"Attachment 3, Certification of Answers to Request
for Information", prepared by Mr. Frank Lequerica,
Vice President and General Manager, Cyanamid
Agricultural de Puerto Rico, Inc., prepared for
U.S. EPA, January 29, 1988)
13
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P. 700914 - Letter to Andrew L. Praschak, Esquire, Office of
700914 Regional Counsel, U.S. EPA, fro® Mr. William F.
Kirchoff, Assistant Counsel, Regulatory and
Governmental Affairs, Warner Lambert Company, re:
Request for Information regarding Barceloneta
Landfill, Barceloneta, Puerto Rico, February 8,
1988.
700915 - Letter to Mr. Jose C. Font, Project Manager, U.S.
700938 EPA, Caribbean Field Office, from Mr. Frank
Lequerica, Vice President and General Manager,
Cyanamid Agricultural de Puerto Rico, Inc., re:
Additional Information Regarding the Second
Request for Information, February 12, 1988.
700939 - Letter to Mr. Jose C. Font, Project Manager, U.S.
701050 EPA, Caribbean Field Office, from Mr. Carlos M.
Jimenez Barber, Environmental Compliance Manager,
Schering Industrial Development Corporation, re:
Response to Second Request for Information
regarding Barceloneta Landfill, Barceloneta,
Puerto Rico, February 12, 1988.
P.
701051 - Letter to Mr. Jose C. Font, Project Manager, U.S.
701070 EPA, Caribbean Field Office, from Ms. Donna L.
Kolar, Attorney, Browning-Ferris Industries of
Puerto Rico, Inc., re: Response to Request for
Information, February 17, 1988.
701071 - Letter to Mr. Jose Font, U.S. EPA, from Mr.
701073 Eduardo Negron Navas, Fiddler, Gonzalez &
Rodriguez, Attorneys and Counsellors at Law, re:
enclosed Certification of Answers to Request for
Information, February 17, 1988. (Note: This
document is written in Spanish) (Attached;
"Attachment 3, Certification of Answers to Request
for Information", prepared by Mr. Carlos M.
Jimenez Barber, Environmental Compliance Manager,
Schering Industrial Development Corporation,
February 16, 1988.)
701074 - Letter to Mr. Jose C. Font, Project Manager, U.S.
701107 EPA, Caribbean Field Office, from Mr. William G.
Speenburgh, Manager, Environmental Control,
Warner-Lambert Company, re: Response to Request
for Information regarding Barceloneta landfill,
Barceloneta, Puerto Rico, March 4, 1988.
14
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701108 - Letter to Mr. Jose C. Font, Project Manager, U.S.
701133 EPA, Caribbean Field Office, from Mr. Michael A.
Miller, Manager, Remedial Engineering, Corporate
Environmental Programs, General Electric Company,
re: Response to Request for Information regarding
Barceloneta Landfill, Barceloneta, Puerto Rico,
March 4, 1988.
701134 - Notice letter to Abbott Pharmaceuticals, E.I.
701136 DuPont de Hemours & Company, Honorable Sol Luis
Fontanez, Mayor, Town of Barceloneta, Merck Sharp
& Dohme Quimica de Puerto Rico, Inc., and Upjohn
Manufacturing Company, re: Request to perform
RI/FS at the Barceloneta Landfill, Barceloneta,
Puerto Rico, June 18, 1990.
701137 - Notice Letter to Union Carbide Corporation, from
701139 U.S. EPA, Region II, re: Request to perform RI/FS
at the Barceloneta Landfill, Barceloneta, Puerto
Rico, and notification of PRP status, August 16,
1990.
701140 - Facsimile transmittal sheet to Mr. Jose Font, U.S.
701180 EPA, Region II, Caribbean Field Office, from Mr.
Jim Doyle, Office of Regional Counsel, U.S. EPA,
Region II, re: enclosed letter from Hoffmann-
LaRoche regarding Barceloneta Landfill, October 4,
1990. (Attached: 1. Letter to James Doyle,
Esquire, Office of Regional Counsel, U.S. EPA,
from Mr. John D. Alexander, Senior Counsel,
Hoffmann-LaRoche, Inc., re: Ammendment to 104(e)
response, September 25, 1990. 2. Analytical
results, prepared by Analytikem, prepared for
Hoffmann-LaRoche, Inc., July 31, 1987.)
701181 - Letter to Mr. Jose C. Font, New York/Caribbean
701181 Compliance Branch, U.S. EPA, from Ms. Laurel D.
Breitkopf, Division Counsel, Office of General
Counsel, Abbott Laboratories, re: Updated
Response to Request for Information, Barceloneta
Landfill, Barceloneta, Puerto Rico, October 18,
1990.
701182 - Second Request for Information letter to Browning-
701192 Ferris Industries of Puerto Rico, Inc., from Mr.
Stephen D. Luftig, Director, Emergency and
Remedial Response Division, U.S. EPA, Region II,
re: Second Request for Information Pertaining to
the Barceloneta Landfill, Barceloneta, Puerto
Rico, undated.
15
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701193
701201
P.
701202
701209
701210
701337
Second Request for Information letter to Abbott
Chemicals, Inc., from Mr. Stephen D. Luftig,
Director, Emergency and Remedial Response
Division, U.S. EPA, Region II, re: Second Request
for Information Pertaining to the Barceloneta
Landfill, Barceloneta, Puerto Rico, undated.
Second Request for Information letter to Roche
Products, Inc., from Mr. Stephen D. Luftig,
Director, Emergency and Remedial Response
Division, U.S. EPA, Region II, re: Second Request
for Information Pertaining to the Barceloneta
Landfill, Barceloneta, Puerto Rico, undated.
"Answers to Attachment 2, EPA's Second Request for
Information on the Barceloneta Landfill", prepared
by E.I. DuPont DeNemours & Company, prepared for
U.S. EPA, undated.
P. 701338 - Second Request for Information letter to E.I.
70134 6 DuPont de Nemours & Company, from Mr. Stephen D.
Luftig, Director, Emergency and Remedial Response
Division, U.S. EPA, Region II, re: Second Request
for Information Pertaining to the Barceloneta
Landfill, Barceloneta, Puerto Rico, undated.
P. 701347 - Second Request for Information letter to Merck,
701355 Sharp and Dohme Quimica de Puerto Rico, Inc., from
Mr. Stephen D. Luftig, Director, Emergency and
Remedial Response Division, U.S. EPA, Region II,
re: Second Request for Information Pertaining to
the Barceloneta Landfill, Barceloneta, Puerto
Rico, undated.
10.0 PUBLIC PARTICIPATION
10.2 Community Relations Plan
P. 1000001 - Letter to Ms. Catherine E. Moyik, TES Regional
1000034 Project Officer, U.S. EPA, from Mr. Scott B.
Graber, TES V Regional Manager, CDM Federal
Programs Corporation, re: Final Community
Relations Plan Revision for Barceloneta Landfill,
May 26, 1992. (Attached report: Final Community
Relations Plan. Community Relations Work
Assignment. Barceloneta Landfill. Barceloneta.
Puerto Rico, prepared by Booz-Allen & Hamilton
Inc., prepared for Office of Waste Programs
Enforcement, U.S. EPA, May 26, 1992.)
16
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10.3 Public Notices
P. 1000035 - Public Notice: "Aviso de Reunion Publica sobre
1000035 Limpieza por Superfondo del Vertedero de
Barceloneta Martes, 9 de Julio de 1991 - 6:30
P.M., Casa Alcaldia de Barceloneta", prepared by
U.S. EPA, undated. (Note: This document is
written in Spanish.)
P. 1000036 - Public Notice: "Aviso de Reunion Publica sobre
1000036 Limpieza por Superfondo del Vertedero de
Barceloneta Martes, 7 de Enero de 1992 - 6:30
P.M., Barrio Tosas, Barceloneta, Puerto Rico",
prepared by U.S. EPA, undated. (Note: This
document is written in Spanish.)
10.6 Fact Sheets and Press Releases
P. 1000037 - Fact Sheet: "Hoja de Datos Superfondo, El
1000038 Vertedero de Barceloneta, Puerto Rico", prepared
by U.S. EPA, Region II, July 1991. (Note: This
document is written in Spanish.)
P. 1000039 - Fact Sheet: "Superfund Fact Sheet, Barceloneta
1000040 Landfill Site, Barceloneta, Puerto Rico", prepared
by U.S. EPA, Region II, July, 1991.
P. 1000041 - Fact Sheet: "Superfund Fact Sheet, Barceloneta
1000042 Landfill Site, Barceloneta, Puerto Rico, EPA
Considers Containment as Presumptive Remedy for
Barceloneta Landfill", prepared by U.S. EPA,
Region II, Caribbean Field Office, undated.
P. 1000043 - Fact sheet: "Hoja de Ihformacion del Superfondo,
1000044 Vertedero de Barceloneta, Barceloneta, Puerto
Rico, La EPA Considera la Contencion Como Remedio
Presuntivo para Vertedero de Barceloneta",
prepared by U.S. EPA, Region II, Caribbean Field
Office, undated.
17
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APPENDIX IV
PUERTO RICO ENVIRONMENTAL QUALITY BOARD
LETTER OF CONCURRENCE
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APPENDIX V
RESPONSIVENESS SUMMARY
ATTACHMENT A
LETTERS SUBMITTED DURING THE PUBUC COMMENT PERIOD
-------
Golder Associates Inc.
8913 Western Woy. SUIe 12
Jacksonville, H USA 32256
Telephone (<*») 363-3430
Fox (9CM) 363-3445
Pf? Golder
Associates
January 24, 1996
933-3928
Mr, Luis Santos
Project Manager
U.S. Environmental Protection Agency
Centro Europa Building, Suite 417
1492 Ponce de Leon Avenue, Stop 22
San Juan, Puerto Rico 00907
RE: TECHNICAL COMMENTS CONCERNING
EPA'S PROPOSED PLAN FOR THE
. BARCELONETA LANDFILL, PUERTO RICO
Dear Luis:
On behalf of the Barceloneta Landfill PRP Group, Golder Associates Inc. submits the following
technical comments to the agency's proposed plan for the above referenced site.
1. In the third paragraph of the left-hand column on the first page, the agency makes specific
reference to the Ri report dated March 1995 and the FS report dated September 1995. However,
the Risk Assessment is not similarly identified. Specific reference to the Abbreviated Risk
Assessment produced in May of 1995 should be made.
2. In the last paragraph of the right-hand column on page 3, the proposed plan describes the results
of the risk assessment activities at the site. In the paragraph, the proposed plan indicates that
consistent with the presumptive remedy approach, the risk assessment was conducted by
comparing groundwater concentrations to MCLs and because MCLs were exceeded, remediation
is necessary. However, the presumptive remedy guidance only states that if ARARs are
exceeded, remedial action is generally warranted. This statement in the proposed plan should be
modified to reflect that remediation is generally warranted
The fourth senteace is the last paragraph of the right-hand column on page 3 continues by
describing that a reasonable maximum human exposure was used. However, as stated above, the
risk assessment simply used the presumptive remedy approach of comparing monitoring well
results with MCLs. This sentence should be deleted.
The sixth sentence in the last paragraph of the right-hand column on page 3 (continuing to the top
of the left-hand column on page 4) is not discussed in the Abbreviated Risk Assessment. If this
statement represents the agency's belief, it should be stated as such by beginning the sentence in
question with the statement, "However, it is EPA's belief that if no action is taken...."
OffC£S IN AUSTRALIA CANADA. GERMANY. WJNGAflY. ftAlY. SWEDEN. UNITED KINGDOM. UNITED STATES
-------
U.S. Environmental Protection Agency
Attn: Mr. Luis Santos
-2-
January 24, 1996
933-3928
3. In the first and second bullets of the left-hand column on page 5, the agency proposes a suite of
analytes for the long term groundwater monitoring program for the site. This suite of analytes is
different than that described in the FS document. In the FS document, a suite of volatile organic
compounds (VOCs) analyzed by EPA Method 601 along with mercury, chromium, and nickel
were proposed (along with the parameters listed in the last five bullets). In the proposed plan, the
agency substituted volatile organic compounds and metals in accordance with 40 CFR Pan 258,
Appendices I and II, even though Appendix II is not r.pplicable for detection monitoring (such as
the long term groundwater monitoring proposed for this site). The only reason provided for the
different parameter group from that proposed in the FS is to be more conservative. As described
below, the parameter group proposed in the FS is already consevative.
As part of the R1 for this site, a very broad suite of anaJytical parameters was used to determine
which constituents were present and at what concentrations. This broad suite included the
complete target compound list and target analyte list (149 different parameters). As a result of
four rounds of groundwater sampling using this broad parameter list (149 different parameters),
the only organic compound detected above MCL was 1,1-dichloroethene. Similarly, only a few
metals were detected above MCL (mercury, chromium, and nickel) in the last two rounds of
groundwater sampling, and of these, only mercury was detected above MCLs in the dissolved
metal analyses. It is unreasonable for the proposed plan to include so many parameters with this
much data available.
The parameter group proposed in the FS document is a conservative suite of initial parameters for
the long term monitoring program for the site. The proposed parameters includes 29 VOCs (EPA
Method 601), three metals (mercury, chromium, and nickel), chloride, Total Dissolved Solids
(TDS), Total Suspended Solids (TSS), pH, and Specific Conductivity. Chloride, TDS, TSS, pH,
and Specific Conductivity historically are common landfill indicator parameters. The 29 VOCs
included on EPA's Method 601 list are sufficient to monitor the historical detections as well as
provide ample assurance of detecting any other organic impact. The three metals (mercury,
chromium, and nickel) were proposed because these parameters were detected above MCLs and it
is appropriate to monitor the trend of these compounds over time. Consequently, the Barceloneta
Landfill PRPs do not believe the expansion of the parameter list to include Appendices I and II
volatile organic and metal constituents is necessary or appropriate for this site.
4. In the second paragraph under the Short-Term Effectiveness bullet on the left-hand column on
page S, mention is made of a leachate control system. Leachate was only detected in one of seven
borings that were drilled through the waste disposal areas at the site. The leachate was analyzed
and found to be typical of, or less concentrated than, landfill leachate referenced by EPA and
others in the literature (see references in the RI Report (Freeze and Cherry (1979) and NUS
Gold«r Associates
-------
U.S. Environmental Protection Agency
Attn: Mr. Luis Santos
.3.
January 24, 1996
933-3928
Corporation (1988)). Consequently, none of the remedies proposed in the FS include a provision
for the installation of a leachate control system. The reference to a leachate control system should
be deleted.
Should you have any questions concerning any of these comments, please call.
Very truly yours.
GOLDER ASSOCIATES INC
Donald J. Miller, P.Er.g
Principal
cc: Barceloneta Landfill PRP Group
Geldsr Associates
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Pitney, Hardin, Kipp & Szuch '
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January 25, 1996
VIA FEDERAL EXPRESS
Mr. Luis Santos
Project Manager
U.S. Environmental Protection Agency
Centro Europa Building, Suite 417
14 29 Ponce de Leon Avenue, Stop 22
San Juan, Puerto Rico 00907
Re: Comments to USEPA's Proposed Plan
for the Barceloneta Landfill
Barceloneta. Puerto Rico
Dear Mr. Santos;
On behalf of the Barceloneta Landfill PRP Group (the "PRP
Group")1, we submit the following comments to the United States
Environmental Protection Agency's (USEPA) Proposed Remedial Action
Plan (PRAP) for the Barceloneta Landfill (the "Site").
The PRP Group concurs with the proposed selected remedies
for the Northern Disposal Area (NDA) and the Southern Disposal
.Area, also known as the Superfund Disposal Area (SFDA) , subject to
*The members of the Barceloneta Landfill PRP Group included
the following: Abbott Laboratories, American Home Products Corp.,
Browning-Ferris Industries, E.I. duPont de Nemours & Co., Merck &
Co. Inc., Nycomed, Inc., Roche Products, Inc., Schering-Plough
Corporation, Union Carbide Chemical & Plastics Co., Inc., and
Upjohn Manufacturing. The PRP Group does not include the City of
Barceloneta, which has failed to pay for any of the Remedial
Investigation/Feasibility Study (RI/FS) activities undertaken by
the PRP Group pursuant to the AOC.
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NOU-08-19% 14:51 FROM EPfi
TO
82126374360 P.02
Pitney. Hardin. Kipp & Siuch
Mr. Luis Santos
January 25, 1996
Page 2
the technical comments regarding the details of the selected
remedies, submitted by the PRP Group's environmental consultant,
Golder Associates Inc.2
These comments focus on the Southeastern Disposal Area
(SDA) as part of the "Superfund National Priorities List (NPL)
site", as defined in the third paragraph in the left column on page
3 of the PRAP. USEPA's efforts to include the SDA as part of a
Record of Decision (ROD) is beyond its legal authority and
impractical. The scope of the ROD should be limited to the NDA and
SFDA only.
I. USEFA Has Wo Authority to Include the SDA As Part of the site
USEPA cannot properly include the SDA as part of the NPL
listed site. The Site was proposed for inclusion on the Superfund
NPL in December 1982, and was subsequently approved and listed as
an NPL site in September 1983. Approval for listing the Site on
the NPL was premised on the findings of the Hazardous Ranking
System (HRS) score in accordance with the National Contingency Plan
(NCP).
The HRS scoring for the Barceloneta site was only
prepared for the areas identified as the NDA and the SFDA. The HRS
was prepared for only these two areas because the SDA did not exist
as a disposal area in 1982. In fact, the USEPA and Puerto Rico
Environmental Quality Board (PREQB) allowed the SDA to be opened
and operated by the City of Barceloneta after the landfill was
listed on the NPL. To date, the USEPA continues to allow the City
of Barceloneta to dispose of waste in the SDA, which is
inconsistent with the mandates of CERCLA.
An NPL site includes all releases evaluated as part of
the HRS3 analysis. 55 Fed. Reg. 6154 (1990). Furthermore, "HRS
2The PRP Group, however, does not concede or agree that it is
fully responsible for implementing the selected remedy for the NDA
or SFDA.
3The HRS serves as a screening device to evaluate the relative
potential of uncontrolled hazardous substances to cause harm to
human health or the environment. The HRS score is calculated by
estimating risks presented in three potential pathways of human or
environmental exposure: groundwater, surface water, and air.
Within each pathway, the HRS considers factors which indicate the
presence or likelihood of a release to the environment; the nature
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Pitney, Hardin, Kipp & Szucm
Mr. Luis Santos
January 25, 1996
Page 3
data upon which the NPL placement was based will, to some extent,
describe which release is at issue." United States Environmental
Protection acency, superfund Facility (Site) Boundaries (1995). Thus,
since the HRS did not include the SDA, the SDA cannot be considered
part of the NPL listed site.
Also, USEPA cannot justify inclusion of the SDA simply
because it is within the boundaries of the property owned by the
Municipality of Barceloneta on which it conducted landfilling
activities. A CERCLA site is not defined by its property
boundaries. CERCLA defines the terra "facility" as "...
impoundment, ditch, landfill, ... or any site or area where a
hazardous substance has been deposited, stored, disposed of, or
placed, or otherwise come to be located." CERCLA §101(9), 42
U.S.C. § 9601(9). While there is no dispute that portions of the
Barceloneta Landfill constitute a facility under CERCLA, there is
an issue as to the extent of the facility.
In Nurad, Inc. v. William E, Hooper & Sons Co., 966 F. 2d
837 (4th Cir. 1992), the Fourth Circuit held that "facility" was
properly confined to the area in and around designated underground
storage tanks since that was the only area where hazardous
substances had "come to be located." The court specifically noted
that this was true even though the tanks were part of a larger
piece of property.
The USEPA recently issued guidance regarding the
definition of a facility which is essentially the same as the Nurad
holding. United States Environmental Protection Agency, Superfund Facility
(Site) Boundaries (1995). The guidance specifies that only waste
disposal areas of a installation are considered Superfund sites,
even if the site name suggests that the entire installation or
property boundary is covered. Thus, as a legal matter, the site is
not coextensive with the property boundaries of an installation.
In addition, by attempting to include the SDA in the NPL
Site requiring CERCLA remediation, USEPA has failed to comply with
the notice and comment requirements for rulemaking under ths
and quantity of the substances presenting the potential threat; and
the human or environmental targets potentially at risk from the
site. The factors are assigned a numerical value which is used to
compute a final score for the site; if the score is 28.50 or
greater, the site is eligible for listing on the NFL. See 40
C.F.R. Part 300, Appendix A (1994).
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Pitney. Hardin, Kipp & Szuch
Mr. Luis Santos
January 25, 1996
Page 4
Administrative Procedure Act (APA) , 5 U.S.C. S 553(c). It is
elementary that a hazardous waste site can only be placed on the
HPL after rulemaking by notice and comment. Anne Arundel County,
Md. v. United States Environmental Protection Agency, 963 F.2d 412,
414 (D.C. Cir. 1992). See Administrative Procedure Act ("APA"), 5
U.S.C. S 553 (c). To list a site, the USEPA must make a
determination to include the site on the HPL, notice its intent to
list the site, accept comment and make a final determination.
Administrative determinations, which are not made in the manner set
forth in the APA, are void. Indeed, if the USEPA determines a site
should be included on the NPL, the USEPA must (1) publish the
proposed rule in the Federal Register and solicit comments through
a public comment period and (2) publish the final rule in the
Federal Register and make available a response to each significant
comment or new data submitted during the comment period. 40 C.F.R.
S 300.425(d)(5) .4
In sum, the Barceloneta Site should not include the SDA
as part of the HPL listed site for remediation. The SDA was not
included in the HRS process to allow for proper inclusion on the
NPL, nor was it included in USEPA's proposal to list the area on
the HPL. It is hardly dispositive that the Barceloneta Landfill
site name has, in the past, commonly been used to refer to the
4The only exception to this rule.is if EPA determines that the
SDA poses an imminent and substantial endangerment caused by and
actual or threatened release. CERCLA, § 106, 42 U.S.C. S9606,*
United States Environmental Protection Agency, OSWER Directive No. 9833.0-1A,
guidance on CERCLA Section 106(a) Unilateral Administrative Orders for Remedial
Designs and Remedial Actions (1990).
No data supports a claim that this area poses an imminent
and substantial endangerment. The Remedial Investigation data
would not support such an administrative determination by USEPA.
The Final Feasibility Study does not indicate that there are
observed releases of hazardous substances that can be clearly
attributed to the SDA. Also, USEPA's abbreviated risk assessment
concluded that the site poses a low level long-term threat. In
fact, USEPA's PRAP clearly refutes that this area poses a imminent
hazard because it provides for this area to remain open for waste
disposal for a period of two and one half years to six years, as
stated in the third paragraph in the left column on page 9 of the
PRAP. Clearly, the SDA poses, little, if any, risk to human health
and the environment. Any minimal risks can and should be addressed
under local programs, not through the Superfund program.
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Pitney, Hardin, Kipp & Szuch
Mr. Luis Santos
January 25, 1996
Page 5
entire parcel of land owned by the City of Barceloneta. Rather,
according to the CERCLA definition of a "facility" and USEPA's
guidance, only the two disposal areas operational at the time of
NPL listing comprise the Superfund site; i.e., the NDA and SFDA.5
If USEPA chooses to list the SDA on the NPL in the future
and to bring it within the regulatory sphere of Superfund, the
USEPA will have to comply with the administrative procedures set
forth above for listing a release on the NPL. Since it has not
complied with the procedures, the SDA cannot be included as part of
the NPL listed site subject to remediation. Presently, the USEPA
does not have authority to include the SDA within the NPL listed
site based on the administrative record, nor does it have authority
to issue a proposed remedial action plan for the SDA prior to
complying with the proper administrative procedures.
II• The Citv of Barceloneta is Responsible for Closure of the SDA,
Which Should be Done as a Separate Unit Under Puerto Rican Law
Under Section 107(a) of CERCLA, a party can be held
responsible for cleanup of a Superfund site if a prima facie cause
of action consisting of five elements can be made: (1) the party
falls within one of the four classes of responsible parties defined
in CERCLA Section 107(a); (2) the site is a facility; (3) there is
a release or threatened release of hazardous substances at the
facility; (4) the release or threaten release of hazardous
substances must cause response costs to be incurred; and (5) the
costs and response actions are consistent with the NCP promulgated
under CERCLA, See 42 U.S.C. §9607(a); B.F. Goodrich Company, et
al. v. Harold Murtha, et al., 958 F.2d 1192 (2d Cir. 1992). Most
of the prima facie elements have not been satisfied to hold the
sNor is it of any significance that the PRPs addressed the SDA
as part of the RI/FS. The proposed plan states in the third
paragraph of the left column on page 3, that the PRPs signed an AOC
in September 1990 in which the PRP Group agreed to perform the
RI/FS (Remedial Investigation/Feasibility Study) for the three
areas. The only reason an RI/FS was conducted for the SDA by the
PRP Group was because the private PRPs were ordered by USEPA to do
so even though the Group disputed that the SDA was part of the
listed NPL site. In fact, City of Barceloneta believed that the
SDA was its responsibility. The City of Barceloneta retained an
environmental consultant to prepare a closure plan for the SDA and
NDA and relied on the PRP Group to prepare the FS for the NDA and
the SFDA.
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Pitney, Hardin, Kipp & Szucm
Mr. Luis Santos
January 25, 1996
Page 6
private PRPs responsible for the SDA as addressed above, i.e.,
elements (l)-(3) and (5).
Members of the PRP Group did not dispose of hazardous
waste in the SDA. The SDA was opened for waste disposal after
Resource Conservation and Recovery Act (RCRA), 42 U.S.C. §§ 6901 et
seq. was in effect. Any hazardous waste from the members of the
PRP Group were disposed in accordance with RCRA regulations. At
the most, some members of the PRP Group may have continued to
dispose of solid waste, i.e., office and cafeteria trash.
Moreover, the burden of proof to hold a PRP liable for solid waste
disposal requires a showing that hazardous substances are contained
in the solid waste; such a showing for office and cafeteria trash
is extremely difficult and indeed similar cases have been dismissed
on motions for summary judgment. See B. F. Goodrich v. Murtha, 840
F. Supp. 180 (D. Conn. 1993).
Indeed, the City of Barceloneta should be responsible for
the management, care, and coordination of the proper closure of the
SDA in conjunction with the requirements of the local agencies
responsible for closure of municipal landfills. In addition to the
fact that the SDA has not been properly designated as part of the
Site to bring it within CERCLA regulation, courts have held that
parties are only liable under CERCLA for costs of remediation
caused by hazardous substances. In Barnes Landfill, Inc. v. Town
of Highland, 802 F. Supp. 1087 (S.D.N.Y. 1992), the court held that
"[o]rdinary closing or clean-up costs not pertaining to hazardous
substances, incurred under state law or otherwise, would not be a
basis for holding defendants responsible under CERCLA" and that the
owner/operator was responsible for those costs. Jd. at 1088.
Consistent with the Barnes decision, the district court in City of
Seattle v. Amalgamated Services, Inc., 1994 WL 869839, *2 (W.D.
Wash. March 4, 1994), held that as a matter of law, "costs required
to meet the minimum functional standards required by State and
local law in the closure" of a landfill are excluded from CERCLA
Section 107(a)(4) costs and that the owner/operator of a landfill
may not seek to recover those costs. See also Town of Wallkill v.
Tesa Tape, Inc., 891 F. Supp. 955 (S.D.H.Y. 1995).
The City of Barceloneta is the party that owns and
operates the SDA as a municipal landfill and should be required to
close the landfill in accordance with Puerto Rican laws and
regulations. Presently, the SDA is the only solid waste unit the
City has to dispose for its residents' wastes. It has clear
liability under Puerto Rican law to close the landfill. P.R. Laws
Ann. tit. 12, $1301 et. seq. (1980). The private PRPs should not
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Pitney, Hardin, Kipp & Szuch
Mr. Luis Santos
January 25, 1996
Page 7
be required to close this area merely because of their potential
ability to finance the closure of a municipal landfill.
There are many reasons to support why the SDA should be
under the jurisdiction of Puerto Rican officials. First, the SDA
was opened upon approval of the USEPA, PREQB and/or PRSWMA after
the HDA and SFDA were listed on the NPL. Second, the PREQB and/or
PRSWMA continued to allow the City of Barceloneta to dispose of
wastes. Third, the City of Barceloneta has virtually admitted it
is responsible for closure of the SDA by hired its own
environmental consultant to prepare a closure plan for the SDA and
NDA, which closure plan was submitted to the Puerto Rican agencies
and the USEPA. Fourth, the City of Barceloneta is required under
Puerto Rican laws and regulations to close the SDA. Fifth, the
selected remedy for closure of the SDA in the PRAP is appropriate
and consistent with Puerto Rico's Solid Waste Management Authority
Act and regulations promulgated thereto. Sixth, there is a no need
for the SDA to be closed under the Superfund program because EPA
has concluded that the Site "poses a relatively low long-term
threat to public health and the environment." {PRAP at page 20.)
Moreover, this area is not properly included in the NPL listed site
because legally-mandated administrative procedures were not
followed, as stated in Point I above.
There are additional reasons to let Puerto Rican
officials remediate and close the SDA. That is, once a ROD is
issued, USEPA will look to the PRP Group and the City of
Barceloneta to finance the closure. The City of Barceloneta has
shown no indication or ability to finance this project. As a
result, the private PRPs, if not also the City of Barceloneta, will
look to the Fund for reimbursement of the costs not attributed to
the PRP Group for which there is a reasonable basis.6 USEPA could
6The PRP Group will seek a tefund for the costs for closure of
the SDA because they are not responsible for those costs and the
divisibility of harm can be established resulting in a reasonable
basis for apportioning the liability for the SDA solely to the City
of Barceloneta. In U.S. v. Mean Aluminum Corp., 964 F.2d 252 {3d
Cir. 1992), the Court relied on Sections 433A and 881 of the
Restatement on divisibility of liability among tortfeasors. The
Alcan court reasoned that joint and several liability for clean up
of an entire site can be avoided if the parties can establish the
divisibility of the harm caused by each party's waste and there is
a reasonable basis for apportioning the damages Incurred as a
result of that harm.
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Pitney, Hardin. Kipp & Szuch
Mr. Luis Santos
January 25, 1996
Page 8
avoid having to reimburse settling parties for the closure costs of
the SDA, if it does not include the SDA as part of the HPL listed
site.
In further support of giving supervision over the closure
of the SDA to the Puerto Rican authorities, Puerto Rico has been
given federal grants to help fund closure of municipal landfills.
These funds are disbursed by PRSWMA based on need. A large number
of municipal landfills in Puerto Rico need funding to get into
compliance and/or closure. PRSWMA has advised the PRP Group and
the City of Barceloneta that it will not provide its limited grant
funding to the City of Barceloneta for closure of the SDA because
the SDA is regulated under the Superfund program. Thus, by
including the SDA in the NPL listed site, a significant source of
funding for the City of Barceloneta to properly close the SDA will
be lost. The result will be to increase the burden on the already
taxed Superfund for the closure costs for the SDA.
In sum, it is more advantageous to the City of
Barceloneta and the USEPA for the SDA to be deferred to the PRSWMA
and PREQB to oversee closure in accordance with Puerto Rico's
regulations. The City of Barceloneta would have a great
probability of obtaining federal grant funds from PRSWMA for the
closure of the SDA and the Superfund would not be subject to
funding the orphan share. In addition, the level of protection to
human health and the environment would be the same if the SDA was
deferred to the local agencies because the Puerto Rico Solid Waste
Management Authority Act and applicable regulations would require
the landfill to be closed in the same manner as the proposed remedy
in the PRAP and there is only a "relatively low long-term threat to
public health and the environment". (PRAP at 2.) While EPA would
like the private PRPs to close the SDA, due to their "deep
pockets", this clearly is unfair in the extreme since the private
PRPs did not contribute hazardous waste to this disposal area and
are not responsible for its closure.
III. The PRAP is Not Practical to Implement
The USEPA states in paragraph 2 of the right column on
page 2 of the PRAP, that it "will require the coordinated closure
of all areas of the Site." Hot only is it unclear what USEPA is
suggesting by this statement, but it is also impractical to
coordinate the closure of the three areas the USEPA designates as
the site because USEPA is proposing to close two of the three areas
immediately and allow the City of Barceloneta to continue disposing
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Pitney. Hardin, Kipp & Szucm
Mr. Luis Santos
January 25, 1996
Page 9
waste in the SDA for two and one half to six years. (See PRAP at
9.)
Significantly, the PRAP does not provide a plan for how
such on-going disposal activity can be coordinated with closure of
the two inactive areas. The private PRPs do not own or operate the
municipal landfill. They have no authority to control the City of
Barceloneta's landfill operations, nor does EPA have the ability to
provide the private PRPs with such authority. The private PRPs
will not undertake to operate a municipal landfill even if such
authority is granted to them. Such a legal obligation is beyond
the scope of CERCLA. Clearly, USEPA's vision of how the
coordination of the closure of the two areas that comprise the NPL
listed site will work, along with and the on-going operation of the
SDA, should be more comprehensive in the proposed plan.
In addition, the PRAP, as drafted, would require the
mobilization and construction of landfill caps for the NDA and SFDA
and then demobilization. Two and one half to six years later,
closure of the SDA would required remobilization and construction
of a cap once USEPA determines that it should be closed, and then
demobilization for a second time after capping is complete. Hot
only is this not a cost-effective approach to remediation, it is
not a logical approach for closure of landfills. A significant
portion of the remedial costs are associated with mobilization and
demobilization. Indeed, the term "arbitrary and capricious" well
describes this process.
Furthermore, the surrounding area will be subject to
short-term disturbances, such as increased vehicular traffic and
noise during the construction phase. To plan to unnecessarily
create these types of disturbances twice is a burden on the
surrounding area with little resulting benefit because there is a
negligible threatened risk from the NPL listed portion of the
landfill. In fact, the USEPA' abbreviated risk assessment
concluded that the site poses a "relatively low long-term health
threat".
Also, USEPA states in the fifth paragraph in the left
column on page 8, that the alternatives are "easily implemented
technically." While capping a landfill is usually not technically
difficult to implement, the proposed plan for the on-going
operation of the SDA results in difficult technical
implementability issues, such as access to the SDA during and after
closure of the NDA. Presently, access to the SDA is through the
middle of the NDA. During and once a cap is constructed for the
NDA, access to the SDA will have to be constructed and maintained.
Give the steep slope on the NDA a stable, all weather road will
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Pitney, Hardin, Kipp & Szuch
Mr. Luis Santos
January 25, 1996
Page 10
most likely need to be constructed on top of the cap which would be
expensive and increase the cost of capping the NDA which is not
addressed in the PRAP. It should not be the burden of PRPs whose
obligation under CERCLA is to cleanup a NPL listed site and not to
provide on-going access for waste disposal. Thus, USEPA's
"coordination" must be clearly articulated.
Furthermore, the PRP Group does not have control over the
landfill to prevent intrusion into the NDA cap once it is
constructed. That is, the cap could be damaged by operators using
the soil cap for daily cover. In addition, as trucks enter the
landfill, it is likely that debris from the trucks will spill while
crossing the NDA cap resulting in additional operations and
maintenance problems and costs not anticipated in the FS and
resulting in a great burden to USEPA and the PRP Group.
The practical solution for coordinating the closure of
the entire landfill is to defer closure of the NDA and SFDA until
the SDA is no longer an active waste disposal facility. In the
interim, the selected site wide institutional controls can be
implemented by restricting access to further reduce any potential
risk the NDA and SFDA may pose by restricting access. Once the SDA
is no longer active, the PRPs can coordinate with the City of
Barceloneta and mobilize once to properly and completely close the
NDA and SFDA. Any short-term disturbances to the surrounding
community, such as increased vehicular traffic and noise will only
occur once, as opposed to the proposed plan to carry out this
activity twice, with no coordination between the proposed closure
plan and the on-going waste disposal. In addition, this solution
is a more cost effective remedial proposal than that presently
proposed by the USEPA. USEPA should reconsider and abandon the
concept set forth in the PRAP for a more practical approach of
allowing the implementation of the closure of the NDA and SFDA to
occur concurrently with the closure of the SDA.
IV. Conclusion
We request the USEPA to reconsider the scope of the PRAP
because the SDA cannot be included in the ROD. USEPA did not
follow administrative procedures to include the SDA as part of the
NPL listed site, and thus, it is not properly regulated under
CERCLA. Moreover, the SDA cannot be included as part of the NPL
listed site because the EPA allowed the SDA to be opened and
operated by the City of Barceloneta after the NDA and SFDA were
listed on the NPL. In addition, the remedy selected for the NDA
and SFDA is not practical to perform until the SDA ceases to take
in additional wastes. Finally, a coordinated closure of the NDA
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Pitney, Hardin, Kipp & Szucm
Mr. Luis Santos
January 25, 1996
Page 11
and SFDA concurrent with the City of Barceloneta's closure of the
SDA is a more practicable, cost effective approach without
jeopardizing overall protection of human health and the environment
because, as USEPA states, the NPL listed site poses a relatively
low level long-term threat.
Respectfully submitted,
PJH
Enclosures
cc: James Doyle, Assistant Regional Counsel
Melvin Hauptmann, P.E., Chief, Eastern New York/Caribbean
Superfund Section II
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COMITE TIMON CALIDAD AMBIENTAL DE MANATI
i> ¦ n» **!!>
MANATI • VEGA BAJA • CIAUES • MOROV1S • FLORIDA • BARCEIONETA
OficinaCentralManati 8M-2110 ext.35
P.O. Box 1459. Manatf. Pucrio Rico 00674
Sr. Luis Santos, Gerente de Proyecto
Agenda Federal de Protecci6n Ambiental
Oficina Regional del Caribe
Edificio Centro Europa 417
1492 Avenida Ponce de Le6n
26 de enero de 1996
San Juan, Puerto Rico 00907-4127
H r
d JAN 2 9 REC'O
VOv
Estimado senor Santos:
Como Presidente del Comit6 Tim6n de Calidad Ambiental (COTICAM)
entendemos que la decisi6n tomada por la Junta de Calidad Ambiental
y muy en particular por la E.P.A, sobre el cierre del vertedero de
Barceloneta ubicado en el Barrio Florida Afuera es muy acertada.
Consideramos que es un poco tardia por las consecuencias ya
ocasionadas a la naturaleza de esta Srea y muy especialmente a
nuestro suelo y nuestras aguas subterrSneas.
Dentro de esa decisi6n que respaldamos tenemos que seftalar que
entre las opciones y decisiones que se puedan implantar en ese
cierre las mejores serian la remocidn y restauraci6n de esa Srea o
de esos terrenos.
Si la otra opcidn de encapsulacidn nos garantiza que ahora y en el
futuro no nos crearfi problemas ni riesgos m&s allS de los ocurridos
entonces la respaldamos.
Tambi^n d6nde se incluyen los medios de cierre solicitamos que se
analicen hasta donde sea posible y se restablezcan las Sreas que
han sido afectadas si es que las hay. Vertederos de esa naturaleza
son improcedentes en un futuro.
Entendemos que se requiere un sisterna de monitoreo bien detallado
de los pozos. Se debe tener adem&s un plan de contingencia para
que de surgir algto problems este se puede atacar a tiempo.
Sugerimos que se ubiquen ademSs de los pozos de observaci6n algunos
pozos de extracci6n para recoger, concentrar y extraer el
contaminante que pudiera surgir evitando as! que los lixibiados
vayan gradiente abajo de surgir la situacidn.
TRABAJANDO POR UN AMBIENTE
L1MP10 Y SANO PARA TODOS
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NOU-0B-193& 14=51 FROM £P«
TO
82126373360 P.03
Sr. Luis Santos, Gerente de Proyecto
26 de enero de 1996
pigina 2
Nosotros como coroinidad lo que podemos decir es que confiamoe en
que ustedes los que tienen en bus manos la potestad de tomar
decisiones lo hagan lo m&s justamente posible. Esperantos que
tengan en cuenta que la Justicia Ambiental debe eer aplicada en
este caso y en otros que no vienen a lo we J or directamente a estar
relacionados con el problema que trataroos de reBolver con el
referido vertedero.
SI toe gustaria recibir de ustedes informaci6n y orientaci6n sabre
deberes y derechos que tenemos las comunidades tnenos privilegiadas
y que es tamos acosadas diariamente con los vertederos clandestinos
que por ende est&n causando los mismos problemas por los cuales se
cierra fiste. Dichoa vertederos abundan y crecen gigantemente en
Puerto Rico y en estos mementos existen en esa misma jurisdiccidn
en diCerentes sectores y pueblos de la regi6n. Entre otros est&n
el de la carretera 167 del Bo. Cortfes de Manati y el de 3 millas y
media en la carr. 672 del Bo. Palo Alto Sector Hoyos y Calderas
(Goto Sur) de Manati.
Si es que andamos buscando proteger nuestras aguas subterrineas en
estos vertederos donde hay miles de toneladas de chatarra y toda
clase de desperdicios cubriendo o rodeando un sin ndmero de
sumideros que sirven de recarga a nuestro acuifero Aymam6n. Bstas
contaminaciones han sido seftaladas por la Junta de Planificacifin en
su Plan de Mane jo de la Laguna Tortuguero pues la misma esti
seriamente inqpactada por los problemas que estamos seflalando.
Convo representantes y miembros de las comunidades, le informamos y
le solicitamos con urgencia que se tome acci6n sobre nuestra
solicited. Tenemos infoimes en nuestro poder donde la Junta de
Calidad Ambiental en el 1992 le solicit6 a Recursos Haturales que
declarara esta zona crltica por los hallazgos encontradoa a trav§s
de sus investigaciones al igual que tenemos seftalaraientos de otros
estudios y entre ellos el de Conservacifin de Suelos Federal. Estos
estudios tienen base y justif ican lo que sefialan pues se. han
cerrado diferentes pozos en estas jurisdicciones por contaminacifin
de nitrato y otros contaminantes que siguen llegando a travfes de
escorrentias que llegan a los sumideros y de ellos a nuestras aguas
potables.
TOTAL P.03
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Sr. Luis Santos, Gerente de Proyecto
26 de enero de 1996
pSgina 3
Es preocupante y hay momentos de desesperaci6n y con£usi6n pues si
esto contintia sin control podemos un dia quedar sin agua lintpia y
no serla tan tarde si la acci6n no se toma ahora pues hace
alrededor de cuatro aftos el Sr. Arturo Torres, Subdirector de
Servicios Geol6gicos dijo en una reuni6n de esta organizaci6n que
de no aetuar y buscarle soluciones de litnpieza y prevencidn a estas
fuentes podriamos estar sin ese precioso llquido en o antes de 10
afios, Esto suena alarroante pero mientras sigan las autoridades y
las fuentes que hemos seflalado sin una accidn positiva entonces no
tendremos otros recursos a donde recurrir que no sea aquel que
/FranxCoss
Presidente
COTICAM
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Center Office Manatl
P.O. Box 1459, Manatl(
Puerto Rico 00674
881-6083 8S4-2110
axt. 35
January 26, 199S
Mr. Luis Santos, Proyect Manager
Environmental Protection Agency
Caribbean Fiel Office
Centro Europa Building,Suite 417
1492 Ponce De Leon Ave.
San Juan, Puerto Rico 00907-412?
Dear Mr. Santos;
As the President of Coroit6 Tim6n de Calidad Ambiental
(COTICAM) we understand that decision took by Enviromental Quality
Board and in particular by EPA about the close of Barceloneta
landfill in Barrio Florida Afuera is correct.
We consider that it's late for the consecuences wich cause by
the nature in this area and very especial in our soil and our
ground waters.
In that decision we support, we have to point between the options
and the decisions that can implant in the close landfill, the
improvements maybe the removal and restauration of those areas in
the soil.
Is the other option of containment can Warranty that now and in the
future not will create problems, no risk beyond of the success that
we support.
Where Also is include the medium to close, We apply to be analysis
until be possible and reestablish the areas that have been affected
it is presumed, the Landfills of that nature are improper for
future.
- We understand that require a monitor system full detail in the
well. Is should be have a contingency plan for the posible problems
to be attack at time. We suggetts to place futhermore of the
observation wells. The extract wells to pickup, containt, and take
out the posible pollutan avoid the leacheat go down to be occur
that situation.
We as the comunitty can argue that we trust in you who have the
power to make desicions, do as fairly posible. we expect that take
in mind the Environmental Justice, is should be apply in this case
and in other that might be not related with this case that we tray
.to resolve with the mention landfill.
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I like to receive information and advice about the rights and
duties that have the least privilege comunitty and we are pursuit
by the ilegal solid-wastes. In order to the same problems, that
landfills abundant and grow up bigger in Puerto Rico. At this
moment exits in the jurisdiction. In different sectors and towns in
the region. Among theirs at the road 167 at Bo. Cort6s de Manati
and the 3 miles in half at the road 672 in th Bo. Palo Alto, Sector
Hoyos y Calderas (Coto Sur) of Manati.
We are looking to protect the ground waters in those landfills
there are miles of tons of Scrap iron and every type of disposal
that cover around many sewer that overload to our aquifer Aymam6n.
this pollutant have been point by the Planning Board in their
managment plan of the Laguna Tortuguero. Because that have a great
impact like the above.
As the represant and menbers of the comunnitty we inform and we
apply urgently take action about our demand. We have files in our
hands where the Environmental Quality Board in 1992, aplied to
Natural Resources (DRNA) to declared critic zone by the finding
trowght of their investigation and also we have signs of other
studies and between the Soil Conservation Service. That studies
have a base and justification that means the close of diferents
wells in that jurisdiction by pollutant of nitrate and other
pollutants that follow arrival across storm waters that comming to
the sewer from their to our potable waters.
Is to worry and moment exasperating and confussion because if that
continue without control some day will don't have clean water and
will be not late if the action dont take place now. Because four
years ago Mr. Arturo Torres, Subdirector of the Geological Survey
said in a meeting that this organization if don't took action and
find solution about clean up and prevent at this emition we culd be
without this preciuos liquid in or before ten years. That sound is
alarmant,but a while the autorities continue and the eraitions above
describe withouth a positive action then we will haven't other
resources where to go that not been that came from the humanity.
Sincerely
Frank Coss
Presidente
COTICAM
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APPENDIX V
RESPONSIVENESS SUMMARY
BARCELONETA LANDFILL SUPERFUND SITE
BARCELONETA, PUERTO RICO
A. INTRODUCTION 1
B. OVERVIEW 1
C. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS 1
D. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES 3
Part I - SUMMARY AND RESPONSE TO LOCAL COMMUNITY
CONCERNS 3
Part II - COMPREHENSIVE RESPONSE TO SPECIFIC WRITTEN
LEGAL AND TECHNICAL ISSUES > 6
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Attention Readers:
This section of the Record of Decison for Baceloneta Landfill has been incorrectly numbered. The
index page was numbered page 2 Page 3 should be page Ml, page MA should be page #3, page MS
should be page #4 and so on and so on.
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RESPONSIVENESS SUMMARY
BARCELONETA LANDFILL SUPERFUND SITE
BARCELONETA, PUERTO RICO
A. INTRODUCTION
A Responsiveness Summary is required by Superfund policy. It
provides a summary of citizens' comments and concerns received
during the public comment period, and the responses of the United
States Environmental Protection Agency ("EPA") to those comments
and concerns. All comments summarized in this document have been
considered in EPA's final decision of a remedial action for the
Barceloneta Landfill Superfund Site (the "Site").
EPA held a public comment period from December 27, 1995 through
January 26, 19 96 to provide interested parties with the opportunity
to comment on the RI/FS and Proposed Plan for the Site. A public
meeting was held on January 18, 1996 to discuss the remedial
alternatives described in the FS and to present EPA's preferred
remedial alternatives for controlling contamination at the Site.
The meeting was held at the Tosas Ward's Christian Pentecostal
Church in Barceloneta, Puerto Rico.
B. OVERVIEW
At the time of the public comment period, EPA had already selected
a preferred alternative for the Site. EPA's recommended
alternative addressed the three landfill disposal areas and called
for capping the disposal areas pursuant to promulgated federal and
commonwealth regulations governing closure of municipal landfills.
The selected remedy described in the Record of Decision is the
combination of Alternatives 2, 3B, 4, and 5 which specifies a RCRA
Subtitle D Cover System, as well as institutional controls.
Comments received during the public comment period were supportive
of capping the disposal areas although the majority of concerns
raised by the public at the public meeting focused on the issue of
contamination to the groundwater.
C. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
Community interest in the Site appears to be relatively high. In
general, most concerns are related to the potential for
contamination of the groundwater (and drinking water) and the
length and complexity of the Superfund process.
EPA performed a number of community relations related activities at
the Site. EPA met with local officials and interested citizens to
initiate community involvement and discuss their concerns regarding
the Site. A Community Relations Plan {"CRP") was formulated,
including an outline of community concerns, a listing of required
and suggested community relations activities, and a comprehensive
list of federal, state, and local contacts. A written CRP was
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finalized and Site information repositories were established, one
at the EPA Region II office in New York City, one at the EPA.
Caribbean Field Office in Santurce, one at the Environmental
Quality Board ("EQB") in Hato Rey, and one locally at the Sixto
Escobar Municipal Library in Barceloneta. The information
repositories, which contain the RI/FS Report and other relevant
documents, were updated periodically. Additionally, the EPA
Proposed Plan, describing the Agency's proposed remedial action for
the Site, was sent to the information repositories and distributed
for review to citizens and officials on EPA's Site mailing list.
To obtain public input on the RI/FS and proposed remedy, EPA
established a public comment period from December 27, 1995 to
January 26, 1996. A public meeting notice appeared in the December
27, 1995 edition of the San Juan Star, 11 Nuevo Dia, and in the
December 28, 1995 edition of the El Peri6dico El Norte. A public
meeting was held on January 18, 1996. Approximately 40 people
attended the meeting. The audience consisted of local business
people, residents, and commonwealth and local government officials.
The question and answer session lasted approximately 30 minutes,
during which time comments and questions were presented pertaining
to the following issues: drinking water contamination, cleanup
schedule, remedy implementation, and Site-related risks. A summary
of these comments/questions is provided in Section D, Part I,
below.
D. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
AND EPA RESPONSES
Part I - SUMMARY AND RESPONSE TO LOCAL COMMUNITY CONCERNS
The following are verbal questions and comments from the public
meeting held at the Tosas Ward's Christian Pentecostal Church in
Barceloneta, Puerto Rico on January 18, 1996.
1. A resident in the vicinity of the Landfill asked and
commented: The wells that have been drilled are on the
periphery of the Site and the waste. Would it be advisable to
drill a well at the center of the Site through the largest
amount of waste, so that the strata of limestone rock could be
seen as well as any contamination?
EPA Response: Monitoring wells have been located inside the
perimeter of the landfill property to determine groundwater flow
and to define the nature and extent of contamination. The
hydrogeologic evaluation and analytical results indicate that the
monitoring wells are sufficient to define the geology and to
characterize contamination originating from the Site. A monitoring
well was not drilled into the center of the landfill for several
reasons. Monitoring wells are not generally drilled through waste
because of health and safety concerns. Also, monitoring wells are
used to define the geology of the area, and to determine the nature
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and extent of groundwater contamination. The geology of the area
has already been defined through interpretation of the monitoring
well data. The nature and extent of contamination has been
evaluated using monitoring well data. It is unlikely that a
monitoring well located at the center of the landfill would provide
any additional information regarding the source of the
contamination, the nature and extent of contamination, or the
geology of the area.
2. A resident in the vicinity of the Landfill asked and
commented: There is some concern about the locations and
depths where groundwater samples were obtained. It seems that
in order to determine the impact on drinking water, ground
water samples were obtained from great depths. However, the
aquifers existing beneath the Barceloneta Landfill are not one
big aquifer, but several aquifers, existing like pockets of
water not related to one another. Are the monitoring wells
strategically placed so that all areas of contamination have
been discovered? Should not they be place throughout the
Landfill. It seems as though the waste initially brought to
the Landfill could have been disposed in an area where a well
does not exist.
EPA Response: Monitoring wells have been strategically placed to
determine the geological and hydrogeologic properties of the
aquifers beneath the Site. The wells were drilled at varying
depths and various locations to define the aquifer and aquifer
properties. EPA believes that a sufficient number of wells were
installed at various locations to adequately define the nature and
extent of the contamination in the aquifers beneath the Site.
3. A resident in the vicinity, of the Landfill asked and
commented: It is agreed that a combination of alternatives,
as in EPA's preferred remedy, is the best choice for the
Barceloneta Landfill, where all the disposal areas will be
remediated similarly at the Superfund site. It is not known
exactly what type of wastes were brought in by truck for
disposal in the landfill. It is also not known exactly in
what areas of the landfill this waste was disposed. In
addition, it is suggested that the clay cap should be 24
inches and not 18 inches thick.
EPA Response: The combination of alternatives selected for the
Site include placing a cover system consistent with RCRA Subtitle
D and Puerto Rico's Regulations Covering Landfill Closure over the
three disposal areas. The RCRA Subtitle D and Commonwealth
regulations indicate that the cover should minimize infiltration
and promote runoff. These regulations state that the cover system
should include a barrier layer with a maximum permeability of 1x1 Q"5
cm/s, which must be at least 18 inches in thickness. Calculations
to estimate the infiltration were performed using USEPA's
Hydrologic Evaluation of Landfill Performance model. The model
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evaluated two cover systems, both including 6 inches of vegetative
cover and one with 18 inches of lxlO"5 cm/s clay, and one with 24
inches of lxlO"5 cm/s clay. The model indicated that there was no
significant reduction in the infiltration for the cover with 24
inches of clay as compared to the cover with 18 inches of clay.
Therefore, the 18 inch clay layer provides performance
substantially equivalent to the 24 inch clay layer and is
considered sufficient to meet the performance requirements the
regulations.
4. A resident in the vicinity of the Landfill asked and
commented: Regarding the retention pond, will it be water-
tight or will water be able to filter through it?
EPA Response; Once the landfill is capped, the movement of
contaminants will be halted. The contaminants are able to move by
way of runoff and also infiltration, which is water passing through
the wastes creating what is referred to as leachate. The leachate
eventually reaches the aquifer and contaminates the groundwater.
Therefore, in order to lower the contaminant levels in the
groundwater, the landfill is capped so that water cannot infiltrate
it. However, when it rains, it will be necessary to divert surface
water away from the landfill. Because there is no surface water
body, and the water cannot be discharged into a stream or a river,
it will have to go to another sinkhole in the area that will serve
as a recharge point to the underlying aquifer. The runoff diverted
to the sinkhole will be non-contact runoff which will not contain
landfill constituents.
5. A resident in the vicinity of the Landfill asked: Have you
determined whether water migration in that area is horizontal
or perpendicular?
EPA Response: It has been determined that the landfill is located
in the recharge area of the aquifer; therefore it feeds the
aquifer. This zone feeds the confined and unconfined aquifer, so
there are both kinds of movement, vertical as well as horizontal.
6. A resident in the vicinity of the Landfill commented;
Although the wastes are capped, the leaching will continue to
occur, because the waste will continue to decompose. Even if
the water does not filter through, the decomposition will
continue, resulting in leachate with less liquid, because it
will not receive any rainwater.
EPA Response; The rate of leachate generation will diminish over
time once the caps are constructed over the disposal areas. By
preventing the water from penetrating the wastes, the mechanism for
leachate transport will be also be minimized. Nevertheless,
groundwater sampling is part of the remedy selected in the ROD to
closely monitor the ground water. The groundwater monitoring will
demonstrate how the implemented remedy is functioning for the Site.
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The Superfund law calls for evaluation of remedies like this one to
be performed at least once every five years and the ROD calls for
such evaluation.
7. A resident in the vicinity of the Landfill asked: What will
happen to this project, if the United States Congress cuts
funds allocated for environmental use?
EPA Response: It is expected that the PRPs will implement this
remedy following negotiations with EPA. If not, the Remedial
Design could be conducted using EPA funds. In order for the
Remedial Action to funded by EPA, in accordance with the Super fund
law, the Commonwealth of Puerto Rico must contribute up to 50% of
the funding for construction of the remedy. At this time, the
Commonwealth does not have funding to provide this matching share.
Part II - COMPREHENSIVE RESPONSE TO SPECIFIC WRITTEN COMMENTS
The following correspondence (see Attachment A) was received during
the public comment period:
-January 24, 1996 letter from
Associates.
-January 25, 1996 letter from Peter
Kipp & Szuch,
-January 26, 1996 letter from Frank
Calidad Ambiental de Manati")
Donald J. Miller of Golder
J. Herzberg of Pitney, Hardin,
Coss of COTICAM ("Comite Timon
EPA also received a letter dated April 25, 1996 from Sheila D.
Jones of Cutle & Stanfield representing the Municipality of
Barceloneta. The letter responded to and commented upon the
January 25, 1996 Peter J. Herzberg letter and said that in the
1970's, the Southeastern Disposal Area had begun to be used for
disposal. The letter went on to discuss the definition and
relevant case law regarding the definition of "site". This letter
was not submitted during the public comment period, but EPA has
reviewed the letter and intends to include it in the administrative
record supporting this ROD.
1. The following technical comments were received by EPA from
Golder Associates in a letter dated January 24, 1996, commenting on
EPA's Proposed Plan for the Barceloneta Landfill, Barceloneta,
Puerto Rico.
1. Comment: The commenter requests that specific reference
be made to the May 1995 Abbreviated Risk Assessment.
EPA Response: The ROD references the Abbrreviated Risk Assessment
that was utilized in the decision making process and this risk
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assessment is the only risk assessment document that was utilized
in the decision making process.
2. Coasnent: The commenter (a) states that a statement in the
Proposed Plan is not consistent with the presumptive
remedy guidance, (b) recommends the deletion of a
sentence in the Proposed Plan regarding the reasonable
maximum human exposure, and (c) recommends that EPA
qualify a statement in the Proposed Plan regarding the
risk potential if no action is taken as "EPA's belief"
rather than as a conclusion.
EPA Response: Since the Proposed Plan has already been issued, and
there is no reason to reissue it, the recommended modifications can
not be made. However, EPA accepts the substance of the underlying
technical comments presented and they are reflected in the ROD.
3. Coaaaent: The commenter states that the parameter list
for ground water sampling be limited to those volatiles
and metals detected above MCLs in the RI and recommends
that it is not necessary or appropriate to expand the
list for this Site.
EPA Response: Initially, the wells will be sampled for a broad
parameter list. This list was developed based on parameter list
requirements of RCRA Subtitle D and Commonwealth regulations.
After the first five years, the parameter list will be reviewed and
those parameters not detected above standards will be omitted. EPA
believes that the expanded list of parameters is warranted.
4. Comments The commenter states that the reference in the
Proposed Plan to a leachate control system is
inappropriate.
EPA Response: This observation is correct and no reference to a
leachate control system is in the ROD.
2. The following written comments were received by EPA from Peter
J. Herzberg, Pitney, Hardin, Kipp & Szuch in a letter dated January
25, 1996, commenting on EPA's Proposed Plan for the Barceloneta
Landfill, Barceloneta, Puerto Rico.
1. Comment; EPA has not properly included the Southeastern
Disposal Area ("SDA") as part of the NPL listed site for
the Barceloneta Landfill. As a result, EPA may not
"bring it Cthe SDA] within the regulatory sphere of
Superfund* to require remediation and does not have
authority to issue a proposed remedial action plan for
the SDA.
The Barceloneta Landfill site was listed on the NPL based
on the findings of the Hazard Ranking System ("HRS")
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package which was prepared only for the areas known as
Northern Disposal Area ("NDA") and Superfund Disposal
Area ("SFDA"} . ¦ The SDA did not exist in 1982. In
addition, EPA and the EQB allowed the SDA to be opened
after the listing of the Landfill. This operation is
allowed to continue to this date, which is inconsistent
with the mandates of CERCLA.
Furthermore, the SDA cannot be included just because it
is within the boundaries of the property owned by the
Municipality of Barceloneta. According to CERCLA, a
facility is defined as an area where a hazardous
substance has been deposited, stored, or disposed of or
placed, or otherwise come to be located. Therefore,
there is some dispute as to the extent of the property
owned by the Municipality of Barceloneta that actually
constitutes a facility. EPA guidance indicates that only
the waste disposal areas of an installation are
considered Superfund sites, even though the site name may
suggest that the entire installation or property boundary
is covered.
Also, legally mandated administrative procedures were not
followed to include SDA as part of the NPL-listed site.
By attempting to include the SDA as part of the NPL
listed site, EPA has failed to comply with the notice and
comment requirements for rule making under the
Administrative Procedure Act, 5 U.S. C. §8553 (C) .
EPA Response: This comment reflects a misunderstanding of the
purposes of the NPL as stated in the NCP. The NPL status of the
SDA does not affect EPA's authority to include it in the ROD for
the Barceloneta Landfill or to issue orders to responsible parties
to clean it up. A release is "within the regulatory sphere of
Superfund" regardless of its NPL status. NPL listing is not a
precondition to planning for remediation activities or to requiring
remediation by responsible parties.
Section 425(b)(4) of the NCP states,
Conclusion on the NPL is not a precondition to action . . .
under CERCLA sections 106 or 122 or to action under CERCLA
section 107 for recovery ... of Fund-financed costs other
than Fund-financed remedial construction costs.
40 C.F.R. s 300.425(b)(4). Further, "[r]emoval actions (including
remedial planning activities. Rl/FSs, and other actions taken
pursuant to CERCLA section 104(b)) are not limited to NPL sites."
40 C.F.R. § 300.425(b)(1) [emphasis added].
The NPL is used primarily for informational purposes as a list
of priority releases for long-term remedial evaluation and
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response. See 40 C.F.R. § 300.425(b). NPL listing is one of a
number of factors to guide allocation of Superfund resources among
releases. 40 C.F.R. § 300.425(b)(2). EPA may pursue other
appropriate authorities to address releases, including CERCLA
enforcement actions. Id- The sole legal effect of NPL listing is
that only NPL-listed releases are eligible for Fund-financed
remedial action. 40 C.F.R. § 300.425(b)(1).
For information purposes EPA provides, below, a general
explanation of issues that relate to the extent of the NPL site.
This explanation is merely an attempt to clarify EPA's NPL listing
process for the benefit of the commenter.
In support of its argument that failure to include a portion of the
Barceloneta Landfill site on the NPL precludes Superfund
jurisdiction, the commenter cites an EPA guidance document
("Superfund Facility (Site) Boundaries"). However, the substance of
the guidance document does not support the commenter's conclusion.
The guidance document articulates a policy that the geographic
boundaries of a property do not define a site, but that it is the
nature and extent of contamination which does. A site is not
limited to those releases identified at the time of the listing.
Portions of the text of that guidance which pertain to EPA policy
regarding the areas included in a "site" follow;
The National Priorities List does not describe releases
in precise geographical terms; it would be neither
feasible nor consistent with the limited purpose of the
NPL (as the mere identification of releases), for it to
do so.
CERCLA section 105(a) (8) (B) directs the Environmental
Protection Agency to list national priorities among the
known "releases or threatened releases." Thus, the
purpose of the NPL is merely to identify releases that
are priorities for further evaluation. Although a CERCLA
"facility" is broadly defined to include any area where
a hazardous substance release has "come to be located"
(CERCLA section 101(9)), the listing process itself is
not intended to define or reflect the boundaries of such
facilities or releases. Of course, HRS data upon which
the NPL placement was based will, to some extent,
describe which releases are at issue. That is, the NPL
site would include all releases evaluated as part of that
HRS analysis (emphasis added).
When a site is listed, it is necessary to define the release
(or releases) encompassed within the listing. The
approach generally used is to delineate a geographical
area (usually the are within the installation or plant
boundaries) and define the site by reference to that
area. As a legal matter, the site is not coexistensive
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with that area, and the boundaries of the installation or
plant are not the "boundaries" of the site. Rather, the
Sxte consists of all contaminated areas w^thxn the area
used to define the site, and any other location to which
contamination from that area has come to be located
{emphasis added).
While geographic terms are often used to designate the
site {e.g., the "Jones co. plant site") in terms of the
property owned by the particular party, the site properly
understood is not limited to that property {e.g., it may
extend beyond the property due to contaminant migration),
and conversely may not occupy the full extent of the
property (e.g., where there are uncontaminated parts of
the identified property, they may not be, strictly
speaking, part of the "site") . The "site" is thus
neither equal to nor confined by the boundaries of any
specific property that may give the site its name, and
the name itself should not be read to imply that the site
is coexistensive with the entire area within the property
boundary of the facility or plant. The precise nature
and extent of the site are typically not known at the
Lime Of listing {emphasis added).
EPA regulations provide that the "nature and extent of
the threat presented by a release" will be determined by
an RI/FS as more information is developed on site
contamination. During the RI/FS process, the release may
be found to be larger or smaller than was originally
thought, as more is learned about the source and the
migration of the contamination.
However, this inquiry focuses on an evaluation of the
threat posed; the boundaries of the release need not be
defined. MoreaY..&X.. . it .generally is impossible to
discover the full extent of where the contamination "has
come to be located" before all necessary studies and
remedial work, are completed ,at, a, site. indeed, the
boundaries of the contamination can be expected to change
over time {emphasis added) . Thus, in most cases, it will
be impossible to describe the boundaries of a release
with certainty.
For these reasons, the NPL need not be amended if further
research into the extent of the contamination expands the
apparent boundaries of the release...
Guidance Document Entitled, "Clarification of NPL Listing Process,"
dated August 3, 1995.
Also, in Washington State Department of Transportation v. EPA. 917
F.2d 1309 (D.C. Cir. 1990), the court held that, "[a) source not
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mentioned in the listing package could later be treated as part of
the Site if it is later found to be contributing to the listed
contaminated."
Thus, in general there is no need for IPA to amend the NPL if
subsequent investigation reveals more precise boundaries of the
release. Further, because the extent of the NPL listing has no
effect on any of the activities proposed in the ROD, there is no
reason to reopen the rulemaking, since it would serve no useful
purpose. Nor, apparently, is the commenter requesting such a
reopening.
Nevertheless, there are many indications which suggest that
the facts cited by the commenter are not correct regarding the
extent of the NPL listing. Because of the questions regarding the
operation of the Landfill, it cannot be conclusively stated that
the HRS package was limited to the NDA and the SFDA. The HRS
package mentions "the landfill" in general (described as a 20 acre
area) and sinkholes and disposal areas, in plural, and it does not
mention the specific number of disposal areas, never mind the NDA
and the SFDA in particular. Therefore, if the SDA existed in 1982,
it is possible that the NPL rulemaking considered the SDA in its
evaluation.
Moreover, evidence that has come to light since the NPL rulemaking
confirms this fact. First, there are questions concerning the
operation of the Landfill between 1972 and 1982. While the
commenter states that the SDA did not exist in 1982, the
Municipality of Barceloneta, which operated the Landfill, asserts
that disposal of waste occurred in the SDA prior to 1982, and as
early as the late 1970's. Also, in an October 29, 1975 report by
an inspector for the Junta de Calidad Ambiental (EQB) the Site is
described as containing large amounts of industrial wastes and
chemical products, and three different disposal areas are
specifically mentioned. Consequently, we cannot conclude that the
SDA was not receiving waste nor in existence prior to 1982, as the
commenter asserts.
Any place where hazardous substances have come to be located
constitute the full extent of releases subject to the NPL. Even
though the full extent may have been discovered after the NPL
listing determination, such releases are still part of the Site.
Finally, further evaluation during the investigation of remedial
options confirms the risks from the SDA, since the RI/FS revealed
that all three disposal areas pose a risk at the Site. The entire
landfill is likely the source of groundwater contamination. The
commenter does not dispute this. Capping only the NDA and the SFDA
areas will not effectively reduce the flow of contamination to
groundwater. Therefore, it is appropriate for all three disposal
areas to be remediated.
Furthermore, contrary to the commenter's assertion, EPA*s position
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of not objecting to a municipality continuing to operate part of a
solid waste landfill at a CERCLA site is not inconsistent with the
mandates of CERCLA because it is necessary that the Southeastern
Disposal Area be filled up to surrounding grade so it can be
capped. If it were not filled up and remained as a depression
below grade and then capped below grade, rain water would pool in
the depression and that would require the additional operation and
maintenance of pumping that water out. In addition, the pooled
water would facilitate the infiltration of water through the cap
causing further groundwater contamination.
2. Comment: As the owner, the Municipality of Barceloneta
should be responsible for closure of the SDA as a
separate unit in accordance with Puerto Rican laws and
regulations. The SDA was opened for waste disposal after
RCRA was in effect, and although some members of the PRP
Group may have continued to dispose of solid waste, such
as office and cafeteria trash, none of the members of the
PRP Group disposed of hazardous waste in the SDA.
Furthermore, any hazardous waste from the PRP Group was
disposed in accordance with RCRA regulations. In one
court case, it was noted that closing or clean-up costs
not related to hazardous substances should be the
responsibility of the owner/operator (the Municipality of
Barceloneta).
The rationale to support why the SDA falls under Puerto
Rican jurisdiction is as follows:
1. the SDA was opened when approval was granted by the
EPA, the EQB, and/or Puerto Rico Solid Waste
Management Authority ("SWMA") and after the NDA and
SFDA were listed on the NPL;
2. EQB and/or SWMA continued to allow the Municipality
of Barceloneta to dispose of wastes;
3. the Municipality of Barceloneta has essentially
admitted it is responsible for the closure of the
SDA by hiring an environmental consultant to
prepare a closure plan;
4. the Municipality of Barceloneta is required under
the local laws and regulations to close the SDA.
5. the preferred remedy set forth in the PRAP for
closure of the SDA is appropriate and consistent
with Solid Waste Management Act and its regula-
tions;
6. there is no need to close the SDA tinder the
Superfund program because EPA has concluded that
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the Site "poses a relatively low long-term threat
to public health and the environment."
7. as already noted, the SDA is not properly included
in the NPL-listed Site because legally-mandated
administrative procedures were not followed.
Additionally, because the private PRPs will seek
reimbursement from the Superfund for costs associated
with the closure of the SDA, EPA can avoid having to
provide reimbursement for those costs if it does not
include the SDA as part of the NPL-listed Site.
Furthermore, Puerto Rico has been given federal grants
for closure of landfills located in Puerto Rico, and SWMA
has indicated that monies will not be available for the
closure of the SDA because it is regulated under the
Superfund program. By including the SDA in the Site, a
significant source of funding for the closure of the SDA
will be lost.
EPA Response: Many of the issues raised by the commenter are in
dispute. It is known that several parties deposited solid waste
which may have contained hazardous constituents. As stated above,
EPA and the EQB have information which indicates that the entire
Landfill (all three disposal areas) was used in the late 1970's
(prior to RCRA) for disposal of wastes which may have included
hazardous waste. The information, which includes aerial
photographs, suggests that the NDA was partially filled prior to
filling the SFDA and all areas were used simultaneously in the late
1970's.
The fact alleged by the PRP Group that their wastes were disposed
in accordance with RCRA regulations is not a defense to CERCLA
liability. It is also not relevant to the appropriateness of the
proposed response action.for the Site.
The statement that the Municipality of Barceloneta is obligated to
close or finance the clean-up of the non-hazardous substances at
the Landfill is also not relevant to the appropriateness of the
proposed response action for the Site. The commenter's point
focuses not on the proposed response action but on who should
perform the action, an issue upon which the Proposed Plan is
silent. Addressing the SDA is necessary to protect human health
and the environment.
In response to the rationale to support the SDA falling under
Puerto Rican jurisdiction":
1. The date of the commencement of disposal in the SDA has
not been demonstrated to be subsequent to NPL listing,
but regardless, EPA, EQB, and/or SWMA approval or
subsequent approval is not relevant to the
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appropriateness of the proposed response action for the
Site.
2. The fact that EQB and/or SWMA's has allowed the continued
operation is not relevant to the appropriateness of the
proposed response action for the Site.
3. The fact that the Municipality may have been prudent in
hiring an environmental consultant to prepare a closure
plan is wholly irrelevant to CERCLA or the Site, and
especially the appropriateness of the proposed response
action for the Site.
4. The fact that the Municipality of Barceloneta may be
required under the local laws and regulations to close
the SDA is not relevant to CERCLA or the appropriateness
of the proposed response action for the Site.
5. EPA agrees that the proposed response action for the SDA
is consistent with Solid Waste Management Act and its
regulations. They are ARARs.
6. The distinction being made as to whether to close the SDA
under the Superfund program or the Commonwealth
regulations is confused; the risk assessment supports the
conclusion that the SDA must be closed, and CERCLA
mandates that ARARs, including in this instance the
Commonwealth landfill closure regulations, be satisfied.
Landfill closure is governed by federal regulations,
including RCRA, Subtitle D, and Puerto Rican regulations.
The three cells, which reports indicate received similar
wastes, will all be closed. It is not an instance where
one or the other will be satisfied, but both.
7. Whether or not the SDA is properly included in the NPL-
listed site HRS package was addressed previously. EPA
did follow the correct procedures in listing the Site.
The HRS package mentions "the landfill" in gefteral
(described as a 20 acre area) and sinkholes and disposal
areas, in plural.
Lastly, the commenter's two points concerning the PRPs intention to
"seek reimbursement from the Superfund and the potential impact the
proposed remedy may have on federal grant monies are not relevant.
Again, while the EPA's selection of a remedy under the NCP does not
include a cost-benefit analysis, such factors are considered when
comparing different remedial approaches. EPA does not consider
potential external financial implications in evaluating what is the
appropriate remedy for a Site.
3. Comment: The PRAP is not practical to implement. EPA
states that it "will require the coordinated closure of
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all areas of the Site." First, it is not clear what EPA
is suggesting by this statement. In addition, it is
impractical to coordinate the closure of the three areas
designated as the Site because EPA is proposing the
immediate closure of two of the three areas followed by
the closure of the SDA 2M to 6 years later. The PRAP
does not present a plan showing how the continuing
disposal activity at SDA can be coordinated with closure
of the two inactive areas. It is recommended that EPA's
plan for coordinating the closure of the two NPL-listed
areas along with the continuing operation of the SDA be
included in the Proposed Plan.
Another point is that the PRAP would require
mobilization, construction of landfill caps for the NDA
and the SFDA, and then demobilization. Closure of the
SDA, which would happen 2M to 6 years later, would
require remobilization, construction of a cap, and
demobilization once EPA determines that the SDA should be
closed. This is not a cost-effective approach to
remediation, and it is not a logical approach for closure
of landfills. A significant portion of the remedial
costs are associated with mobilization and
demobilization. This is arbitrary and capricious. In
addition, subjecting the surrounding area twice to short-
term disturbances, such as increased vehicular traffic
and noise during the construction phase, is a burden with
little resulting benefit since the NPL-listed portion of
the Site presents a low risk.
A final point is that the PRAP stated that the
alternatives are "easily implemented technically."
However, the plan for continuing the operation of the SDA
results in difficult implementability issues, such as
access to the SDA during and after closure of the NDA.
Currently, access to the SDA is through the middle of the
NDA. Once closure of the NDA is complete, access to the
SDA will have to be constructed and maintained, possibly
on top of the NDA cap. Therefore, the cost of capping
the NDA will be increased, which is not addressed in the
Proposed Plan. It should not be the burden of the PRP
Group to provide on-going access for waste disposal.
Furthermore, the PRP Group will not be able to prevent
damage to the NDA cap once it is constructed because they
do not have control over the landfill.
It is suggested that closure of the NDA and SFDA be
deferred until the SDA is no longer an active waste
disposal facility. In the interim, site wide
institutional controls could be implemented, such as site
access restrictions.
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EPA Response: The Feasibility Study recommends site-wide
institutional controls along with a Subtitle D cover system for
each of the three disposal areas. It is therefore necessary to
continue filling the SDA with solid waste until it is at a level
that can be successfully capped so that all rainwater can be
collected in an area which is not contaminated. The Commonwealth
has concurred with these decisions. The Municipality has agreed to
fill the active cell and EPA, EQB and SWMA have agreed to allow the
continued operation of the SDA until it is ready for closure, which
has been estimated to be approximately eighteen months.
The commenter suggests that, because of logistical obstacles, only
the site wide institutional controls be implemented until the SDA
area is suitable for closure, and then we proceed with the closure.
The design period associated with the closure of multiple disposal
areas is routinely two years in length. This design would proceed
after negotiations for design and construction have been concluded ;
these negotiations should last for 120 days. While all of this
time is elapsing (two and one-quarter years, optimistically) , the
SDA will continue to be utilized.
3. The following written comment was received by EPA from Frank
Coss, President, COT1CAM ("Comite Tim6n Calidad Ambiental de
Manatl") Oficina Central Manatl, commenting on the Proposed Plan
for the Barceloneta Landfill dated January 26, 1996.
1. Comment: Another option to the preferred alternative is
removal of the soil and restoration of the affected
areas.
EPA Response: Removal of the affected soil would not be cost
effective or practical due to the volume and heterogeneity of the
waste in the Landfill. The preferred alternative will adequately
contain the contamination within the landfill area. In addition,
this remedy is consistent with EPA policy. EPA issued a directive
titled, "Presumptive Remedy for CEKCLA Municipal Landfill Sites" in
September 1993 and that policy calls for containment of municipal
landfills.
2. Comsat; If the option of capping the landfill can guarantee
that no problems or risks will be created now or in the
future, then the preferred alternative is supported. However,
restoration of the affected areas is preferred.
EPA Response: As noted above, removal of the affected soil and
restoration of the affected areas would not be cost effective or
practical because of the volume and heterogeneity of the waste in
the Landfill. Therefore, the preferred alternative which includes
capping the affected soil, thus minimizing contamination of the
groundwater, was chosen rather than restoring the affected areas.
3. Comment: It is understood that a monitoring system is
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required at the site. However, a contingency plan is
suggested, such as more observation wells and extraction
wells to recover, contain, and remove the possible
contaminants.
EPA Response: The preferred alternatives include a comprehensive
monitoring plan at the Site which should be sufficient to determine
the effectiveness of the preferred alternatives. If problems are
encountered, the alternatives will be reevaluated. At this time,
it is expected that the selected alternatives will be protective of
human health and the environment. Thus, further remediation such
as groundwater extraction wells is not planned at this time.
4. Comment: It is expected that EPA will not forget
Environmental Justice, and will apply it in this case and
in any other case that is not related to this case. In
addition, the COTICAM Oficina Central Manati (Manati
Office) would like to receive more information concerning
the rights and duties of communities that are in pursuit
of illegal solid waste disposal. It seems that landfills
are more abundant and grow larger in Puerto Rico.
Currently, there are two in this jurisdiction. One is
located at Road 167 at Bo. Cort6s de Manati. The other
is located at mile 3M, road 672 in Bo. Palo Alto, Sector
Hoyos y Calderas (Coto Sur) de Manati.
EPA Response: The EQB has responsibility for regulating non-
hazardous waste landfills and overseeing other solid waste regula-
tions under the RCRA program. EPA and the local government coordi-
nate landfill closures with the EQB. However, the EQB is
responsible for the day-to-day solid waste requirements under RCRA.
We will forward this information to EQB, and the COTICAM Oficina
Central Manati (Manati Office) should contact EQB for more specific
information regarding the communities rights and duties with
respect to illegal solid waste disposal.
5. Comment: The COTICAM Oficina Central Manati (Manati
Office) is concerned about protecting the groundwater in
the vicinity of the landfills in the area. There are
miles of tons of scrap iron and every other type of waste
disposed in and around the sewer systems which has leaked
in the past and discharged to the aquifer Aymam6n. This
contamination was discussed in the Planning Board's
Management Plan for the Laguna Tortuguero.
Reports exist which indicate that various wells in the
Manati area are contaminated with nitrates and other
pollutants. It is a concern that these pollutants could
be migrating via storm waters through the sewer system
and from there to the potable waters.
It is of great concern to the Manati area that some
action is taken to clean up the landfills (specificlaly
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the Manati and prevent the contamination of the
groundwater. It has been stated that without action the
groundwater could be completely contaminated within 10
years.
EPA Response: As stated above, EPA understands the concerns of the
COTICAM Oficina Central Manati (manati Office). The Puerto Eico
EQB has responsibility for regulating non-hazardous waste landfills
and overseeing other solid waste regulations under the RCRA
program. EPA and the local government coordinate landfill closures
with the EQB. However, the EQB is responsible for the day-to-day
solid waste requirements under RCRA. Again, we will forward this
information to EQB, and the COTICAM Oficina Central Manati (Manati
Office) should contact EQB for more specific information regarding
these issues.
With regards to the Barceloneta Landfill, EPA determined that
active remediation of the groundwater was unnecessary. The results
of EPA's Abbreviated Risk Assessment indicated that the levels of
contaminants present in the ground water pose a relatively low
long-term threat to human health. However, if the Landfill is not
capped,the continued release of contaminants into ground water
could potentially result in a greater risk at some point in the
future.
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