Hazardous Waste Cleanup: StarLink Logistics, Inc. in Barceloneta, Puerto Rico
On this page:
- Cleanup Status
- Site Description
- Contaminants at this Facility
- Site Responsibility
While there are currently no cleanup or remediation activities occurring at the StarLink Logistics Site, RCRA corrective measures are in place at a closed land-based unit known as the Old Landfill. Pursuant to StarLink’s RCRA Permit Corrective Action requirements, the Site must maintain the cover on the Old Landfill, secure the Old Landfill with fencing and appropriate signage, maintain financial assurance for these corrective measures, and perform periodic inspections of the Old Landfill.
The StarLink Logistics Inc. (StarLink) facility is located at Road #2 km. 56.7, Trinidad Ward in the Municipality of Barceloneta, Puerto Rico. The facility is located approximately three miles south of the Atlantic Ocean and 38 miles due west of San Juan. The site is bordered by industries to the north and west, and “mogotes” (undeveloped large, round hills with steep sides formed by erosion of natural limestone) surround the remainder of the property.
The StarLink facility is located where the former Merck, Sharp & Dohme Quimica (MSDQ) facility existed since 1971 as an operating pharmaceutical manufacturing plant. For over forty years, MSDQ manufactured human and animal health products, including anti-hypertensives, beta-blockers, diuretics, and anti-parasitic drugs at this site. As part of such manufacturing operations, MSDQ generated hazardous wastes, including chlorinated and non-chlorinated solvents, solid and sludge wastes containing heavy metals, and residues from waste incineration operations.
MSDQ’s hazardous waste activities have been authorized since November 1988, when the first RCRA permit was issued by EPA. As the previous and long-time facility owner and operator of this facility, MSDQ renewed its RCRA Hazardous Waste Management (Part B) Permit several times. The most recent permit renewal cycle occurred in August 2006, when MSDQ renewed its Permit for a period of ten years (2006-2016). The 2006 permit authorized MSDQ to operate two hazardous waste container storage areas, seven aboveground hazardous waste storage tanks, and two hazardous waste incinerators. The emissions of the incinerators were regulated under both RCRA and Clean Air Act (CAA) permits.
In November 2010, due to a corporate restructuring, MSDQ’s operations of the facility were transferred, and the facility’s name changed, to MSD International GmbH (Puerto Rico Branch) LLC (MSD International). In or about 2014, MSD International suspended all manufacturing of active ingredients at the former MSDQ Facility, continuing only its pharmaceutical formulation and packaging operations. At and leading up to this time, these changes in operations resulted in the shutdown or suspension of operations of the Original Facility’s hazardous waste management units (“HWMUs”).
MSD International operations at this site ceased all together in late 2014, when the facility was acquired by Merial Barceloneta (Merial). In 2015, the facility’s RCRA Permit was transferred from MSD to Merial via a permit modification. Then, in 2016, as part of a corporate transaction between Merial and Boehringer-Ingelheim (BI) for the acquisition of the facility, a new corporate entity, StarLink, assumed ownership of the parcel located at the easternmost portion of the then Merial facility, which encompassed two former landfill units (i.e., the Old and Secure Landfills). Merial retained ownership of the western portion of the former MSDQ facility. StarLink was added to the Permit and the facility became known as the Merial/StarLink facility.
Merial continues to conduct pharmaceutical manufacturing operations on the western side of the former MSDQ property, which it owns.
In 2019, EPA expects to issue a Corrective Action Permit to StarLink. Due to the approved completion of corrective measures on the portion of the StarLink/Merial facility owned by Merial, this Permit renewal will be limited to the portion of the existing facility containing a closed landfill unit, known as the Old Landfill, that is owned by StarLink and subject to corrective action.
Contaminants at this Facility
Pharmaceutical operations at this site began in 1971, when regulations for the management of hazardous wastes were not yet in place. As part of its manufacturing operations, MSDQ generated hazardous wastes such as chlorinated and non-chlorinated solvents, solid and sludge wastes containing heavy metals, and residues from waste incineration.
The assessments conducted under the RCRA Corrective Action Program at this site identified a number of Solid Waste Management Units (SWMUs). Specifically, the 1986 RCRA Facility Assessment (RFA) determined that five (5) out of thirty-seven (37) SWMUs initially identified required further investigation due to the presence of low-level soil contamination. The remaining thirty-two (32) SWMUs were determined to require no further action or investigation.
A RCRA Facility Investigation (RFI) was conducted in 1989 at the site to further assess the remaining five (5) SWMUs. The 1989 RFI was focused on soil gas and soil contamination; no groundwater studies were conducted. The 1989 RFI identified residual toluene contamination in soil as the main potential environmental threat posed by this site.
Soils contaminated with toluene at the Old Landfill, specifically, were found to exceed EPA’s health-based criteria (EPA’s Region 9 Preliminary Remediation Goals or PRGs for Industrial Soil). The remaining four (4) SWMUs, including a second landfill unit known as the Secure Landfill (SWMU #2), showed no residual soil contamination and were determined to require no further action or investigation. Therefore, the Old Landfill (SWMU #1), which was in service from 1971 to 1981, remain the only unit at the site subject to corrective action requirements.
Starting in 1990, MSDQ conducted further investigations at the Old Landfill under the Corrective Measures Study (CMS) phase of the RCRA Corrective Action Program to evaluate treatment alternatives to remediate remaining soil toluene contamination. In-Situ Remediation/Intrinsic Biodegradation was determined to be the most suitable treatment alternative and was proposed by MSDQ for further evaluation. More recent assessments performed by Merial, however, (i.e., the May 2016 Sampling and Analysis Plan Implementation Report) concluded that the Old Landfill did not require further remediation as long as the unit’s use remains restricted to industrial through the establishment of certain Institutional Controls (i.e., file the appropriate deed restrictions, secure the unit and restrict access, provide maintenance, etc.). Subject to public notice, EPA accepts these findings.
The revised Permit, which EPA expect to issue to StarLink in 2019, will require the above referenced institutional controls, as well as certain corrective actions relating to the Landfill, such as requiring StarLink to maintain the cover on the Old Landfill, secure the Old Landfill with fencing and appropriate signage, maintain financial assurance for these corrective measures, and perform periodic inspections of the Old Landfill.
Site Responsibility at this Facility
EPA is currently renewing the RCRA Part B Permit for this facility. The RCRA Permit that was issued in August 2006 to MSDQ was a RCRA Hazardous Waste Management Permit for an active RCRA Treatment, Storage and Disposal Facility (TSDF). As of 2014, the facility completed its closure requirements and ceased actively managing hazardous waste. The facility however is still subject to certain corrective action requirements related only to the Old Landfill.
As indicated above, StarLink Logistics is currently the owner of the parcel located at the easternmost portion of the Merial/StarLink facility, which was subdivided (i.e., segregated) from the real property then owned by Merial. StarLink’s eastern parcel contains the site’s two former landfill units, including the Old Landfill (the only RCRA unit still subject to corrective action requirements), and the Secure Landfill (a RCRA clean-closed landfill unit that was removed from the 2006 Permit). Merial retained ownership of the remaining property (i.e., the western parcel) in which it currently conducts pharmaceutical manufacturing activities.
Upon application of Merial and StarLink and in recognition of the foregoing history, EPA will, subject to public comment, issue a renewed Permit applicable solely to the subdivided eastern portion of the Merial/StarLink Facility, now solely owned and operated by StarLink (hereafter the subdivided portion is referred to as the “StarLink Facility” or “Facility”). Further, Merial’s status as co-permittee will be terminated, and the Permit is transferred to StarLink as sole permittee (hereinafter, “Permittee”). StarLink shall be responsible for implementing all terms of this Permit, including implementing any off-site corrective action related to activities at the former Merial/StarLink Facility (now identified as the Original facility).
The StarLink Facility Permit is a Corrective Action Permit. The Permit’s corrective action requirements include but are not limited to maintaining the cover on the Old Landfill, securing the Old Landfill with fencing and appropriate signage, maintaining financial assurance for these corrective measures, and performing periodic inspections of the Old Landfill.
RCRA Permit and Corrective Action activities at the Site are overseen primarily by EPA although the Puerto Rico Environmental Quality Board (EQB) provides technical support and assistance to EPA.