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
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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
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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.
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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.
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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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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
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INITIALS
DATE
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