TAPI Puerto Rico, Inc.

Other (Former) Names of Site: SK&F Lab Co., Chemsource Corp., API Industries

EPA Identification Number:	PRD090613357
Location:	Carr #3, Km. 143.0, Guayama, Puerto Rico
EPA Contact:	Ariel Iglesias, (787) 977-5890, iglesias.ariel@epa.gov
Last Updated:	September 2007
Environmental Indicator Status:	Human Exposures Under Control [PDF 48.04 KB, 14 pp] has been verified. Groundwater Contamination Under Control: No status has been recorded.

Site Description

The TAPI Puerto Rico Inc. facility is located at State Road No. 3, km 143, in Guayama, Puerto Rico. The property encompasses 45 acres. Twenty-five acres have been developed for industrial purposes. The remaining land is undeveloped and is temporarily used as a material storage area, a machine shop area, and an office area. The Phillips Petroleum Refinery is located to the east of the TAPI property. The AES Puerto Rico electric cogeneration facility is located to the south of the TAPI property. Undeveloped land is adjacent to the property to the north and west.

The TAPI facility is located on the southeastern coastal plain of Puerto Rico. The facility is about 1.1 miles north of the Caribbean Sea and 3.5 miles south of the foothills of the Cordillera Central Mountains. The Town of Guayama is located approximately 2.2 miles to the northeast and Puente Jobos Ward is located approximately one mile to the northwest. The Town of Reunión is located about 0.7 miles to the northeast. An EPA Superfund site (Fibers Public Supply Wells) is located approximately one mile to the northeast.

From 1978 to 1996, SK&F Lab Company, a subsidiary of Smith Kline Beecham Chemical Division, operated a bulk pharmaceutical products facility at the site. Since 1997, the facility has been successively owned and operated by Chemsource, API Industries, and TAPI. TAPI manufactures bulk active pharmaceutical ingredients. Facility operations include chemical manufacturing processes with related support operations. The primary on-site structures include four separate bulk chemical manufacturing process plants, a RCRA hazardous waste storage and incineration area, laboratory facilities, warehouses, a process wastewater treatment facility, and administrative and other support buildings. The three main manufacturing buildings are identified as Guayama I, II, and III.

Site Responsibility

The cleanup at this facility is being addressed by TAPI with oversight from the U.S. Environmental Protection Agency (EPA), under the authority of the Resource Conservation and Recovery Act (RCRA). However, the Puerto Rico Environmental Quality Board (EQB) also participates with EPA in cleanup decision-making and oversight.

Threats and Contaminants

By letter dated April 16, 2002, EPA notified the facility that data gathered from a Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) study of the Fibers Public Supply Wells Superfund Site indicated a potential impact to groundwater at the facility. Groundwater sampling of two of the facility's production wells tentatively identified di-isopropyl ether (IPE) in groundwater at concentrations up to 1700 micrograms per liter (ug/L). Based on this groundwater results, EPA required the facility to implement a SWMU Assessment Plan in accordance with Condition III.E of the facility's RCRA Permit.

An Environmental Site Assessment consisting of a soil and groundwater investigation is currently being conducted to delineate the extent of the contamination at the TAPI facility in accordance with the provisions of an EPA-approved SWMU Assessment Work Plan, dated June 2004. Phase 1 of the site assessment completed in July 2005, in which the groundwater contamination was confirmed, and warranted further corrective action investigation to be carried out.

In addition to IPE, benzene, chlorobenzene, ethylbenzene, methylene chloride, naphthalene, antimony, arsenic, lead, thallium, and vanadium were detected at levels in excess of screening levels. Phase 2 of the site assessment was completed in June 2007. The sampling results of Phase 2 investigation indicate that further groundwater investigation is necessary to complete the delineation of impacted groundwater at the facility.

Cleanup Approach

Cleanup Status/Corrective Action
The site is being addressed by TAPI, under EPA oversight, through various measures including Interim Corrective Measures (ICM), Corrective Measure Study (CMS) and long-term corrective measures directed at cleanup of the entire site.

Response Action Status
In 1987, the Puerto Rico Environmental Quality Board (EQB) conducted a RCRA Facility Assessment (RFA) at the facility. The Final RFA Report was dated March 11, 1988. The RFA identified 62 Solid Waste Management Units (SWMU) and Areas of Concern (AOC) associated with facility operations. The RFA concluded that there was no evidence of release of hazardous wastes and hazardous constituents from these units and that no further corrective action is required.

By letter dated April 16, 2002, the United States Environmental Protection Agency, Region II (EPA) notified the facility that data gathered from a CERCLA study of the Fibers Public Supply Wells Superfund Site indicated a potential impact to groundwater at the facility. Groundwater sampling of two of the facility's production wells tentatively identified di-isopropyl ether (IPE) in groundwater at concentrations up to 1700 micrograms per liter (ug/L). Based on this groundwater results, EPA required facility to implement a SWMU Assessment Plan in accordance with Condition III.E of the facility's RCRA Permit. An Environmental Site Assessment consisting of a soil and groundwater investigation is currently being conducted to delineate the extent of the contamination at the TAPI facility in accordance with the provisions of an EPA-approved SWMU Assessment Work Plan, dated June 2004.

Cleanup Progress

An Environmental Site Assessment consisting of a soil and groundwater investigation is currently being conducted to delineate the extent of the contamination at the TAPI facility. Phase 1 of the site assessment completed in July 2005, in which the groundwater contamination was confirmed, and warranted further corrective action investigation to be carried out. Phase 2 of the site assessment was completed in June 2007. The sampling results of Phase 2 investigation indicate that a further groundwater investigation is necessary to complete the delineation of potentially impacted groundwater at the facility. Based on the results of the Phase 1 and Phase 2 of the investigation so far, EPA has concluded that groundwater is the only media contaminated.

In Phase 1, groundwater samples were collected from 13 direct-push sampling locations, deep well MW-1B, and two operating production wells SKF-721 and SKF-722. At the direct-push locations, the shallow groundwater was sampled; at wells MW-1B, SKF-721, and SKF-722, the deeper groundwater was sampled. The samples were analyzed for volatile organic compounds (VOCs) including diisopropylether (IPE), base neutral/acid extractable compounds (BNAs), and metals. Deep well MW-1B, which was installed in April 2005, is screened from 30 to 40 ft below ground surface (bgs).

In Phase 2, groundwater samples were also collected from nine monitoring wells screened in the shallow groundwater. Three of the monitoring wells were installed in April 2005 and six in March 2007. The samples were analyzed for constituents of concern (COCs) detected in shallow groundwater above screening levels during first phase of site assessment. The COCs were IPE, benzene, chlorobenzene, ethylbenzene, methylene chloride, naphthalene, antimony, arsenic, lead, thallium, and vanadium. Also deep well MW-1B and production wells SKF-721 and SKF-722 were re-sampled for IPE.

Groundwater results from the various phases of investigation were compared to groundwater screening levels. Groundwater screening levels were obtained from EPA Maximum Contaminant Levels (MCLs) and, where MCLs were not available, EPA Region 3 tap water RBCs (EPA Region 3, April 2007) were used. Texas Risk Reduction Program (TRRP) protective concentration levels (PCLs)(TRRP, June 2007) were used for groundwater screening levels for IPE, as MCLs, Region 3 tap water RBCs, or EPA Region 9 PRGs were not available.

Permit Status

The original RCRA Operating Permit was issued to the former owner of the facility, SK&F Lab in 1989. The 1989 RCRA Permit authorized SK&F to store hazardous waste in containers, and in above-ground tank systems, and to treat hazardous waste in incinerator units.

In 1997, the ownership of the facility was transferred to Chemsource. In 2001 ownership of the facility was transferred to API, and then again transferred to TAPI in 2007. Now TAPI is the sole owner and operator of the Guayama facility, and therefore responsible for managing the facility pursuant to the terms of the operating permit and all applicable RCRA requirements.

A permit renewal application was submitted to EPA in March 1999, which was recently public noticed (PN #: PR-2007-02) on August 14, 2007. If issued, this RCRA Permit renewal will authorize TAPI to manage one (1) hazardous waste container storage area and eight (8) existing hazardous waste tank systems (tank system numbers: 408, 430, 436, 450, 451, 452, 453 and 604). In addition, there are certain requirements for the operation of two existing (2) hazardous waste incinerators.

The air emissions of the both incinerators are now regulated under the Maximum Achievable Control Technology (MACT) rule promulgated under the Clean Air ACT (CAA).

TAPI is permitted to manage spent halogenated and non-halogenated solvents (EPA Hazardous Waste Numbers/waste codes: F001, F002, F003, F005) and ignitable waste (D001) in its hazardous waste management facilities. The Permit additionally contains requirements for on-going corrective action activities as described above.

Site Repository

Copies of supporting technical documents and correspondences cited in this fact sheet are available for public viewing at the following location.

U.S. Environmental Protection Agency, Region 2
RCRA Records Center
290 Broadway, 15th Foor, Room 1538
New York, NY 10007-1866
Telephone: (212) 637-3043

The inspection of some of the documents cited in the site fact sheet may require a formal request under the United States Freedom of Information Act (FOIA).