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 A 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. o CO HEADQUARTERS LIBRARY ENVIRONMENTAL PROTECTION AGENCY £ WASHINGTON, D.C, 20460 ------- 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- ------- 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- ------- 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- ------- 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) Copies 2 2 1 1 5 1 3 O u I 0 o -5- ------- TRANSMITTAL SLIP From Reference or Collection D.cvt staff to Cataloging REFERENCE COLLECTION GENERAL COLLECTION EPAX COLLECTION HAZARDOUS WASTE COLLECTION REF GENERAL WATER COLLECTION REF GENERAL EPAX INTERNATIONAL COLLECTION REF GENERAL EPAX MANAGEMENT POLLUTION PREVENTION I ADP !,. • 'r i-.' INITIALS DATE ------- |