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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
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SOUTHERN DIVISION. SUITE 276
1 373 PEACHTREE STREET. N.E.
ATLANTA. GEORGIA 3O3O9
REGIONAL OFFICE:
EARLE CABELL BLDG.. RM. 2F5O
DALLAS. TX 75242
(214) 767-2854 Auorr
(214) 767-9OO1 INVESTIGATIONS
September 30, 1588
MEMORANDUM
SUBJECT: Region 4 Review of Ranedial Investigation/
Feasibility Studies
Audit Report No. E5eH7- 04-0 29 3-89 019
FRCM: Kathryn M. Kuhl-lnclan
Divisional Inspector General for Audits
Southern Division
TO:
Greer C. Tidwell
Regional Adninistrator
Region 4
I" ... RooĞi 3404
401 H StrMt, S.W.
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SCOPE AND CBJECrrVSS
We have completed our review of the Remedial Investigation/Feasibility
Study (RI/FS) for the Whitehouse Waste Oil Pits, Whitehouse, Florida and
the Pioneer Sand Company, Pensacola, Florida, as required by the Superfund
Amendments and Reauthorization Act (SARA). Our review was limited to
completed State-lead Rl/FSs as of August 1987. Field work was performed
at Region 4, Atlanta, Georgia and the Florida Department of Environmental
Resources (FDER), Tallahassee, Florida, from September 8 to October 2,
1987. The Whitehouse site was inspected on September 22, 1987.
As a limited review, our work was not performed in accordance with the
Standards For Audit of Government Organizations, Programs, Activities, and
Functions issued by the Comptroller General of the United States. Our
objectives were to determine whether:
1) the RI/FS process provided an adequate technical basis for sound
decisions on remedial actions;
2) delays were associated with technical problems;
3) other problems existed that delayed the entire Remedial Action
Program; and,
4) the requirements of SARA had been fulfilled.
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To accomplish our review, we interviewed responsible officials at both
Region 4 and FDER. We also reviewed project files at both the Region and
State offices. We examined:
1} Remedial Investigation Reports and Addenduns;
2) Feasibility Studies and the supporting Engineering Status
Reports;
3) Remedial Design documents and correspondence; and,
4) Cooperative Agreements and Financial Status Reports (FSR).
We also reviewed the Preliminary Assesament/Site Investigation (PA/SI),
Hazardous Ranking and Scoring (MRS) and the Record of Decision (RCD) for
each site. A technical evaluation of the Whitehouse RI/FS was performed
by our Engineering Assistant Unit.
BACKGROUND
The Superfurd Amendments and Reauthorization Act (SARA), Public Law 99-
499 was enacted October 17, 1986. Ihe amendment of Section lll(K) of the
Comprehensive Environmental Response, Compensation and Liability Act of
1980 (CERCLA) mandated the Office of the Inspector General to examine a
sample of RI/FSs prepared for remedial actions. Congress wanted to be
sure that each RI/FS provided an adequate technical basis for sound decisions
on remedial actions.
Remedial actions under CERCLA generally involved the following process:
* Site discovery or notification?
* Preliminary Assessment and Site Investigation;
* Hazardous Ranking and Scoring (28.5 or greater);
* Listing on the National Priority List;
* Remedial Investigation/Feasibility Study; and
* Remedial Design/Remedial Action.
The Remedial Investigation is the data gathering activity undertaken to
determine the degree and extent of contamination associated with an uncontrolled
hazardous waste site. The objective is to collect sufficient data to
determine:
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1) the distribution and migration of contaminants;
2) identify cleanup criteria; and,
3) identify and support the remedial alternatives selected.
The Feasibility Study is generally defined as the process whereby remedial
alternatives are developed, screened and evaluated in a systematic manner.
The objective of the FS is to develop and evaluate the remedial action
alternatives with respect to technical, public health, environmental,
institutional, and cost considerations. The FS identifies: 1) the appropriate
type of response required at the site; 2) source control; 3) control of
the contaminants which may migrate off-site; and 4) removal of off-site
treatment and disposal. Alternative response actions are identified for
each type of response. The National Contingency Plan (NCP) requires a
detailed analysis and screening of alternative technology leading to the
identification of a preferred remedial action alternative. Once the
preferred alternative is selected and public comments have been reviewed,
a Record of Decision (ROD) is prepared. The ROD documents the entire
decision naking process including the cleanup standards and the time
table for inpleroentation. It is at this point that the RI/FS process is
considered conplete.
RESULT OF REVIEW
Our review of the Pioneer Sand site project files provided no evidence of
technical problon related to the RI/FS.
Our technical review of the Whitehouse Waste Oil Pits found the RI/FS to
be adequate. It satisfied the stated intent of the published program
guidance and criteria and selected an applicable alternative criteria for
site remediation.
The ROD for the Whitehouse site was signed on May 30, 1985.
The selected remedy consisted of:
* Construction of a slurry wall around the entire site;
* Fjctraction and treatment, of all contaminated
groundwater;
* Removal of contaminated sediments frcm the northeast
tributary of McGirts Creek; and,
* Grading of the site surface and recapping the area
with low permeability material.
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While the RI/FS was considered technically adequate, there were technical
problems that delayed the entire remedial action process. Controversy
surrounding the remedial alternative selected for the Whitehouse site was
generated when the remedial design engineer indicated that the groundwater
treatment process designated for the site was inappropriate. This resulted
f ran a treatability study which determined that the removal of non-volatile
organics utilizing carbon absorption was not feasible. In addition,
results of the study indicated that the Operation and ffeintenance (O&M)
costs had been substantially underestimated due to the quantities of
chemical additives required in the treatment process resulting in an
increase in the sludge volume. Additionally, the reliability of the
analysis of the shallow aquifer performed by the U.S. Geological Survey
(USGS) was questioned because of problems encountered during the pumping
test. Twenty four months after the ROD was signed, the design engineer
relayed three concerns to the U.S. Army Corps of Engineers (USOOE), EPA,
and FDER which resulted in suspension of further design activities until
additional studies were completed. These studies were to:
* Provide additional chemical characterization of the
groundwater, define the physical and chemical
properties of the waste oil sludge, and determine the
vertical and horizontal limits of the groundwater
plume and the sludge;
* Design, install and purp-test a test recovery well
within the contaminated area to determine the aquifer
contents and the time variations of contaminant
concentrations in the groundwaterr and,
* Investigate any "new cleanup technology" that might be
employed by the site,
When we inspected the site in September IS 87, we observed numerous areas
where the cap had eroded. We also noted (see pictures on page 6} two
locations where the hazardous waste had broken through the cap. The FDER
representative accompanying us stated the hot summer weather caused the
cap to crack allowing the material to "boil up" through the cap. Pictures,
shown in this rqport on pages 6, 7 and 8 illustrate the severity of erosion
problems and current site conditions and a need for some priority action
to be taken by EPA.
The information generated by the groundwater treatability study would
have been more useful and effective had it been accomplished during the
feasibility study. This would have resulted in less confusion and delays
in determining the ultimate groundwater treatment process to be utilized
thus eliminating the delays encountered by additional water treatment
studies.
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It was suggested by FDER that improvements in technology and cost, breakthroughs
in the field of hazardous waste clean up be investigated to determine if
a less costly remedial action was available to effect site clean up. AS
of September 1988, more than three years after the ROD was signed, no
decision has been made regarding final configuration of the remedial
design. The treatability study performed by the Office of Research and
Development (ORD) found solidification to be an appropriate remedy, however,
additional testing would be required. A treatability study for the Hume
Extraction Process, a new technology, is planned to begin within the next
month. Region 4 officials estimate a decision on the design configuration
will be made by February 1389.
RECOMMENDATION
Due to the existing site conditions and the fact that the ROD was signed
in May 1985, we recommend that Region 4 implement a high priority permanent
site remedy and escalate their evaluation of the new technologies to be
used at the Vfoitehouse site as required by SARA.
Additionally, we recommend a priority completion schedule be established
and closely monitored to complete any additional studies to allow resumption
of the remedial design so final remedial cleanup action can be accomplished.
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The hot weather creates problems. The
hazardous waste breaks ("Boils") up through
the cap. The most recent boll as of the
time of audit field work.
Summer 1987 - Closeup of materials breaking through cap.
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Cap breakthrough. Considered to be old since it had been
found on an inspection prior to 9/22/87.
Erosion around the two wells at the McGirt's Creek edge of
the site.
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Examples of numerous erosion areas found around the site perimeter.
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Appendix 1
DISTRIBUTION
Regional Office
Regioral Administrator, Region 4
Division Director, Waste Jtonaganent Division
Audit. Followup Coordinator
Action Official
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