UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                  OFFICE OF THE INSPECTOR GENERAL FOR AUDITS
                                WESTERN DIVISION

                             21 1  Main Street, Suite 220
                              San  Francisco, CA 94105
                                   415 974-7084
                                    ;EC
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    SUBJECT:  Special Report No. E5e47-09-0225-89000        '  "
^K            Special Review of On Scene Coordinator Activities
X            Del Norte County Pesticide Storage Area Site
^            Crescent City, California

                               ":~""-'-  .  -,-    / . s " •---
            /                        •S   /''  '     '
    FROM:   •.  Truman R. Beeler '   -
              Divisional Inspector General for Audits
              Western Division

    TO:        John VJise
              Acting Regional Administrator
              EPA Region 9
    SCOPE AND OBJECTIVES

    We  conducted a special review of the controls exercised by  the EPA
    Region 9 On Scene Coordinator (OSC) over the Superfund immediate removal
    action to the Del Norte County Pesticide Storage Area Site, Crescent
    City,  California.  The overall purpose of this limited review was to
    determine whether the EPA OSC was exercising adequate controls over the
    removal action.   The specific objectives of our review were to evaluate
    the:

         *  Adequacy of the OSC's controls in monitoring the cleanup work
    and on-sita spending; and

         *  The^type of technical assistance provided by the Technical
    Assistance Team (TAT) contractor.

    The review was conducted in accordance with the Office of the Inspector
    General Annual Audit Wbrkplan (unannounced Visit to Immediate Removal
    Sites)  and consisted of on site observations of the removal action and
    a review of the  records being maintained by the OSC and support personnel,
    The review was conducted between August 27, 1987 and November 26, 1987.
    Other  than the observations discussed in the Results of Review section
    of  this report,-.nothing further came to cur attention that  warrants
   Examination by this office.

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   CO                             HEADQUARTERS LIBRARY
                                 ENVIRONMENTAL PROTECTION AGENCY
   £                             WASHINGTON, D.C, 20460

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                                        Report No. E5e47-09-0225-39000
 RESULTS OF REVIEW

 In general, .this special review disclosed that the OSC conducted the
 on-site activities in a reasonable manner and generally in compliance
 with existing Agency guidance for Superfund Removal Operations.  The
 auditor's observations pertaining to the OSC's activities are detailed
 in the following paragraphs for the Region's consideration.

 ERGS Costs:  We noted that  the OSC disputed certain Health and Safety
 (H&S) charges billed by the Emergency Response Cleanup Services (ERCS)
 contractor.  The OSC questioned these charges because they exceeded the
 amount of effort authorized on the CERCLA Daily Hbrk Order.  It was
 also noted that the OSC communicated the information on the disputed
 charges to the EPA Contracting Officer when the ERCS public voucher was
 processed.

 In addition to the H&S charges that the OSC questioned, the costs
 invoiced  by the ERCS contractor,  on the first public voucher, included
 various charges for small tools,  equipment maintenance itans and general
 office  supplies that also should  have been questioned by the OSC.  The
 questionable itans include  computer paper, pipe fittings, broom, shovels,
 and  a hand  saw.   Costs for  small  tools, equipment maintenance items and
 general office supplies,  are properly excludable fron the contract
 direct  charges.  They should be included in the ERCS contractor's indirect
 costs and should not be direct charged to the EPA contract.

 The  OSC was not aware that  these  costs were questionable and attributed
 it to the fact that the Region had not received any formal training on
 the  new ERCS Zone 4 contract terms and conditions.  The EPA Contracting
 Officer visited Region 9  during the first quarter for FY 1988 to discuss
 the  contract terms.   The  IG's Office attended the meeting with the OSCs
 and  Contracting Officer.  This meeting and training session should
 improve the OSCs ability  to properly review and approve charges to the
 removal actions.

 Site Records:   The OSC, or  his on-site support personnel, were maintaining
 the  logs  recommended by the Removal Cost Management Manual and the ERCS
 Users'  Manual.   The logs  being maintained for the removal action included
 an Incident Obligation Log;  personnel, equipment and materials log; and
 site access (in/out)  leg.

On-site Controls and Organization:  The OSC had prepared a removal
 action  organizational structure that included the OSC, U.S. Coast
Guard,  ERCS contractor and  Technical Assistance Team (TAT).  Removal
action  records showed that  the OSC released one ERCS employee and one
TAT employee at the end of  the first week, because the level of work
did not require  their presence during the second week of operations.
CXiring  the  period that the  ranoval action was observed by  the auditor,
the U.S. Coast Guard personnel were responsible for site safety, site
access  and  cost tracking  activities.  The TAT representative was
                                  -2-

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                                         Report N'o. F:5e47-09-0225-89000
 responsible for physical oversight  of  ERGS  removal activities, site
 monitoring and sampling activities.  Assigned duties were generally
 being accomplished.
 RECOMMEMDATEONS

 We recommend that the Regional  Administrator:

      1.   Assure that all Regional OSCs  receive training on the ERCS
 contract provisions.

 ACTION REQUIRED

 Since the Toxics & Waste Management  Division, Emergency Response
 Section,  subsequently improved  the OSCs working knowledge of the ERCS
 contract terms, by the EPA Contracting Officer's visit to discuss the
 provisions of  the ERCS contract with the OSCs.  The Region's actions
 are considered to be responsive to  the  review recommendation.  Therefore,
 no follow-up action  is required of the Action Official.

 SITE BACKGROUND

 The Del  Norte  Pesticide Storage Area Site  is located northwest of
 Crescent City,  California and consists of  less that one acre of rural
 land.  The site,  owned by Del. Norte  County, was established and operated
 by the County  Agricultural Commissioner.   It served, from 1970 to 1981,
 as a county wide collection point for interim or emergency storage of
 empty and partially  empty pesticide  and herbicide containers from
 agricultural and forestry related industries.  A sump, 20 feet long by
 15 feet wide,  was constructed to receive wastes and rinse water from
 the containers.

 In October 1981,  the North Coast Regional  Water Quality Control Board
 (NCRWQCB)  issued a Cleanup and  Abatement Order requiring the removal
 of  all hazardous wastes frcra the site.  The order also required that
 the County determine  the  extent of potential contamination.  In
 November  1981,  the County submitted  a proposed site closure plan to
 the NCRWQCB.   The County  removed approximately 1,600 containers from
 the site  between January  and April 1982.   The NCRWQCB conducted limited
 soil and ground water sampling  in September 1982 and early 1983.
 Because  the^County was unable to fund further investigative work, the
 site was nominated for the Federal Superfund List in the fall of 1983.

 EPA completed  a  remedial  investigation of  the site in September 1985.
The EPA Record of Decision recommended excavation of the contaminated
 soil as well as extraction and  treatment of contaminated ground water.
The U.S. Army Corps of Engineers/ on October 12, 1986, awarded a
 contract  to SCS  Engineers for the design of remedial actions at the
site.

                                  -3-

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                                        Report "o. E5e-i7-09-0225-890CO
 In early  1987, the EPA Region 9 Superfund Programs Branch requested the
 assistance of  the Emergency Response Section (ERS) to perform a renoval
 action at the site as a short term site stabilization measure.  In May
 1937, a preliminary assessment of the site was conducted by the ERS.
 The ERS assessrtent was concluded with the issuance of an Immediate
 Aemoval Funding Request, dated August 11, .1987.  This funding request
 stated that the "OSC has determined that the Del '-forte County Pesticide
 Storage Area Sits presents an unacceptable risk to both human health
 and to the environment, consistent with the criteria of: sect. 300.65 of
 tha National Contingency Plan."  The proposed immediate removal action
 included the excavation and disposal of contaminated soils.  Excavated
 areas v.vsre to be backfilled to prevent accumulation of rain water and
 to reduce the potential for lateral and vertical migration of subsurface
contamination.  Excavated soil not contaminated with PCP and TCP were
 to be disposed of a CERCLA approved landfill while soil containing
 these substances were to be contained and storei on site until treatment
studies were completed.  The immediate removal action on the site was
started on August 24, 1987 and completed by September 3, 1987.
                                  -4-

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                                  Report  Mo.  E5e47-09-0225-39000
                                  Attachrrent  1
                              DISTRIBUTION
 Regional Office

 Ac t i r>}  Reg i o na 1 Ad mi n i s t r a to r
 Director, Toxics & Waste Management  Division
 Director, Office of  Policy and Management
 Audit Follow-i:p Coordinator

 Office  of tho_ Inspector General

 Meadquarters  Office
 Chief,  Programs Assistance Unit  {HQTRS)
 Divisional Office

 Headquarters  Offices

Comptroller (PM-225)
 Director, Office of  Einargency and Remedial
     Response (Superfund)  (WH-548)
Agency  Follow-up Official (PM-225)
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