On this page:

• Cleanup Status
• Site Description
• Contaminants at this Facility
• Site Responsibility

Cleanup Status

In 1990, the Puerto Rico Environmental Quality Board (PREQB) conducted a RCRA Facility Assessment (RFA) at the facility and a full RFA report was issued in December 1990. Two visual site inspections (VSI) were conducted by PREQB staff as part of the 1990 RFA (October 1 and November 9, 1990). The main hazardous waste streams identified as generated by the Cyanamid manufacturing operations were as follows:

• Filter cakes impregnated with toluene (D001, F005)
• Filter bags
• Solvent mixture and residues from chemical testing (F003, F005, D001)
• Still bottoms of toluene recovery (F005)
• Spent toluene (F005, D001)
• Waste oil.

PREQB identified eleven (11) Solid Waste Management Units (SWMUs) and four (4) Areas of Concern (AOCs) during the 1990 RFA, as follows:

• SWMU #1 – Old Hazardous Waste Container Storage Area
• SWMU #2 – New Hazardous Waste Container Storage Area
• SWMU #3 – Incinerator
• SWMU #4 – Underground Storage Tank
• SWMU #5 – Aboveground Storage Tank
• SWMU #6 – Solvent Recovery Area
• SWMU #7 – Cargo Tank
• SWMU #8 – Process Drain Tank
• SWMU #9 – Satellite Area I
• SWMU #10 – Satellite Area II
• SWMU #11 – Waste Oil Storage Area
• AOC #1 – Raw Material Storage Area I
• AOC #2 – Raw Material Storage Area II
• AOC #3 – Raw Material Storage Area III
• AOC #4 – Loading/Unloading Area.

The 1990 RCRA Facility Assessment (RFA) recommended no further action for all SWMUs and AOCs except for the SWMU #6-Solvent Recovery Area, where further sampling was recommended due to observation of dark stains on the distillation tank’s surface and on the trench surface. The RFA Report identified the tars from the toluene distillation process (F005, D001) as the most likely source of such dark stains, and of releases to the soil, at the Solvent Recovery Area.

In April 29, 2009, EPA notified in writing to BASF that the facility was subject to RCRA Corrective Action requirements, including submission of a RCRA Facility Investigation (RFI) to fully characterize releases of hazardous waste at SWMU #6 based on the findings and recommendations of the December 1990 RCRA Facility Assessment (RFA) Report.

In letter dated May 20, 2009, BASF replied to EPA’s April 29, 2009 notification of the RFI Work Plan requirement by submitting a copy of an Environmental Site Assessment (ESA) Report prepared by Malcolm Pirnie for the facility in March 2, 2000. This ESA was commissioned by AHPC to assess the environmental conditions of the facility and its compliance status regarding environmental regulations.

The ESA Report was an internal due diligence assessment and not a compliance document, and as such, it was not submitted to EPA or PREQB for review. As part of the ESA effort, soil sampling was conducted to further assess the potential environmental issues identified at the Solvent Recovery Area (SWMU #6), as well as at the former Drum Storage Area and the Tank Farm.
 
The ESA also included sampling of the sediments at the nearby sinkhole as well as groundwater sampling from both D&G’s process water production wells. Therefore, the ESA did address the recommendations made by the December 1990 RFA Report to further sample the soil in the Solvent Recovery Area.

In correspondence dated April 29, 2009, EPA notified BASF about the applicability of RCRA Corrective Action requirements to the facility, specifically the need for BASF to submit an RFI Work Plan to address findings and recommendations of the December 1990 RFA Report. EPA had subsequent communications with BASF representatives to obtain additional information on the status of the Facility’s corrective action obligations. 

Site Description

BASF Agricultural Products (BASF) of Puerto Rico facility manufacturing operations have been dedicated to the formulation of liquid herbicides since February 2009. As the facility is currently operating, access to its premises is controlled by security at all times.

Manufacturing operations occupy approximately 21.41 acres of a total of 27.37 acres of land owned by BASF. BASF acquired the purchased the facility in July 1, 2000 from the American Home Products Corporation (AHPC). AHPC had purchased the facility from Cyanamid Agricultural de PR, Inc. (Cyanamid or CAPRI) in November 24, 1994.

The land uses in the area surrounding the facility included: from the north and west by residential (and some commercial); from the south by undeveloped land to the south, including a large sinkhole located adjacent to the facility; and from the east by industries, having Davis & Geck (D&G) manufacturing facility as fence-line neighbor.

The nearest major surface water body is the Rio Grande of Manati, located approximately 1.25 miles southwest. A sinkhole located on an adjacent 7.2 acre plot of land lies approximately 300 feet southwest of the facility. No groundwater wells are located on the facility premises; however, the facility’s process (and fire) water is provided by two groundwater extraction wells located at the adjoining D&G facility. Potable water for the facility is provided by the Puerto Rico Aqueduct and Sewer Authority (PRASA).

The facility is located over a sensitive karst aquifer, comprised of the Aguada and Aymamón limestone formations, which is an important water source for PRASA, industries and agricultural users in the region. This aquifer system is closely related to the nearby Tortugero Lagoon; its normal groundwater flow direction is north-north east toward the lagoon.

The facility is located outside the 100-year flood zone. Storm water from the facility is collected by storm sewers for discharge into a natural sinkhole that lies southwest of the facility; the sinkhole is permitted as a Class VI injection well to receive storm water runoff from the facility under permit UIC 870036.

Contaminants at this Facility

A 1990 Resource Conservation and Recovery Act (RCRA) Facility Assessment (RFA) Report recommended further sampling at a Solid Waste Management Unit (SWMU) # 6-Solvent Recovery Area due to an observation of dark stains on a distillation tank’s surface and on a trench surface. The RFA identified tars from the facility’s toluene distillation process as the most likely source of such dark stains, and of potential releases to the soil, in the facility’s Solvent Recovery Area.

Site Responsibility at this Facility

The former Cyanamid facility filed a Part A Permit application in November 19, 1980. It operated as a permitted hazardous waste Treatment, Storage and Disposal (TSD) facility from late 1980 until late 1983, when the facility requested to withdraw the Part A application and terminate interim status.

During such period the facility operated a liquid hazardous waste incinerator unit (down-fired thermal model LV-10), until September 30, 1982, when the incinerator was taken out of service. In December 15, 1983, PREQB approved the declassification of the facility from TSD to generator.

In April 30, 1984, EPA issued the facility a notification of interim status termination, effective in May 30, 1984. Since 1984, the facility has operated as a Small Quantity Generator (SQG) of hazardous waste.