UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF THE INSPECTOR GENERAL
EASTERN AUDIT DIVISION
J F. KENNEDY FEDERAL BUILDING
Room 1911
Boston. Massachusetts 02203-1911
(617) 565-3160
FTS 8-835-3160
NEW YORK OFFICE
90 Church Street
Suite 802
New York NY 10007
(212)264-5730
June 28, 1989
MEMORANDUM
SUBJECT: Report on Unannounced On-Site Audit of Region I
Immediate Removal Activities at Waterboro Patent
Leather Site, Waterboro, Maine
Audit Report No. E1S9F9-01-0144-9100338
FROM: y<^C Paul D. McKechnie ^-;/?-"' " C" J -?/<•: .4-•• >
x Divisional Inspector General
Eastern Audit Division
TO: Paul G. Keough
Deputy Regional Administrator
Region I
SCOPE AND OBJECTIVES
We have performed an unannounced on-site audit of Region I's
immediate removal activities at the Waterboro Patent Leather
Site, Waterboro, Maine, under delivery order Number 7445-01-024
for the period of March 9, 1989 through May 1, 1989. Audit field
work was performed from April 12, 1989 through May 4, 1989. We
conducted the Unannounced site visit on April 12, 1989.
The objectives of the review were to determine:
1. The On-Scene Coordinator's (OSC) compliance with
prescribed directives and guidance governing immediate
removal actions?
2. The adequacy of the OSC's controls in monitoring the
cleanup work and on-site spending; and,
3. The adequacy of the technical assistance provided by
the Technical Assistance Team (TAT) contractor.
We performed the review in accordance with the Standards for
Audit of Governmental Organizations, Programs, Activities, and
Functions issued by the Comptroller General of the United States,
and included tests of accounting records and other auditing
procedures we considered necessary.
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We reviewed action memoranda, delivery orders, pollution reports
(POLREP), daily work orders, contractor cost reports {EPA Form
1900-55), site entry/exit logs daily work summaries and any other
related site logs or documents to ensure conformance with
prescribed directives and guidance. In addition we conducted an
interview with the OSC and had discussions with the Contractor
Response Manager and the TAT Representatives. The review was
conducted at the Waterboro Patent Leather Site, Waterboro, Maine
and at Region I Emergency Response Division in Lexington,
Massachusetts.
RESULTS OF REVIEW
We found that the On-Scene Coordinator utilized and applied the
appropriate directives and guidance to control and monitor the
site removal activity. The OSC was also found to be adequately
monitoring the cleanup work, efficiently controlling the on-site
spending, and was conscientious in coordinating and directing the
site response activity.
The review also found the Technical Assistance Team (TAT)
contractor to be providing adequate technical assistance for the
cleanup effort.
ACTION REQUIRED
Since no findings or recommendations are contained in this
report, no response is required from the action official.
BACKGROUND
Section 104 of the Comprehensive Environmental Response and
Liability Act (CERCLA) of 1980 requires EPA to take removal or
remedial action whenever there is a release into the environment
of any hazardous substances which may present any imminent and
substantial danger to the public health,welfare, or the
environment. Removal action represents short-term responses
designed to alleviate imminent threats while remedial action
represents responses of longer duration leading to permanent
restoration of the site.
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Removal actions are generally requested by an EPA OSC located in
the Region. An OSC is the Federal official designated to
coordinate and direct Federal responses at the site. After an
immediate removal action is approved, the OSC has the
responsibility to: (1) issue delivery orders to the ERCS
contractor? (2) monitor and coordinate activities at the site;
(3) report progress to local community and Agency officials; and
(4) determine when the immediate removal action is completed.
Pursuant to section 104 (c) (1) of CERCLA as amended, removal
actions are limited to twelve months in duration or $2 million in
cost. Exemptions to the aforementioned limits, however may be
granted by the Regional Administrator and the Assistant
Administrator, Office of Solid Waste and Emergency Response, {AA
OSWER) respectively.
The Waterboro Patent Leather site is located close to the center
of the town, off of Goodwin Miles Road in Waterboro, Maine, in a
residential area. The Waterboro Town Health Advisor estimated
that 500 people live within a quarter mile of the site.
The area of concern that is currently under investigation is
approximately 2 acres in size. A large fire occurred at the site
on June 10, 1988, burning a number of buildings in which asbestos
had been used for insulation. Due to the intense heat of the
fire, the asbestos has broken down into it's present friable
condition and large amounts of it are scattered about the site.
In addition, there are tanks and other containers holding
solvents and chemicals yet to be identified.
The EPA was asked to look at this site by the Hazardous Waste
Site Coordinator with the Maine Department of Environmental
Protection (DEP). The State of Maine is currently investigating
and monitoring for groundwater contamination. The State of Maine
DEP asked for Federal Assistance to help in abating the present
asbestos threat. The EPA has experience and capabilities in
emergency removal actions relating to asbestos in the environment
for the above mentioned actions. At the time of this request,
the State of Maine had no funds immediately available for an
asbestos related removal cleanup.
On March 3, 1989, an action memorandum for $450,000 was submitted
and approved by the Regional Administrator for removal activities
at the Waterboro site. On March 9, 1989, a delivery order for
$150,000 was issued to the ERCS contractor. The ERCS Contractor
obligation was raised to $220,000 on March 30, 1989 and EPA and
the ERCS Contractor were mobilized on April 3, 1989. As of April
14, 1989 $111,589 had been expended.
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APPENDIX 1
Distribution
Office of Inspector General
Regional Office
Deputy Regional Administrator
Director, Environmental Service Division
Audit Followup Coordinator
Headquarters
Comptroller (PM - 225)
Agency Followup Official (PM-208)
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