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            UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                       OFFICE OF INSPECTOR GENERAL
                           NORTHERN DIVISION
                              10W. JACKSON BLVD.. 4TM FLOOR
                                CHICAGO. ILLINOIS eoeo4 •
        OFFICE OF AUDIT
        3(2/333-2486
                                   June 29, 1990
                                             OFFICE OF INVESTIGATION
                                             312/333-2SO7
         MEMORANDUM
           Special Report ElSHGO-05-0192-0400023
           Unannounced Site Review of Removal Aption
           Better Brite Zinc Sfyop in DePere, Wisconsin
                                         eneral for Audits
         SUBJECT:
 FROM:     Anthony C. Carrollo
           Divisional Inspector
           Northern Division

 TO:        Valdas V Adamkus     .
           Regional Administrator
           Region 5

      We visited the Better Brite Zinc Shop Superfund removal site
 located in DePere, Wisconsin to perform an unannounced site
 review.   We were at the site from February 26 to February 28,
 1990.  At the time of our visit,-the site was inactive because it
 was  a "potential responsible party" (PRP) site and the consent
 order had not been approved.

      During our site visit, we observed a former shop employee
 entering the site.  When talking to EPA officials about this
 situation,  we were informed that EPA was not in control of this
 site at  the time.   Therefore, the PRP had access to the site and
 apparently could let others onto the site at its discretion.

      We  also observed children playing at the site.  Part of the
 removal  action included removing contaminated soil.  There were
 no fences or ropes controlling access to the contaminated soil.
 The  on-scene coordinator said that the.concentration of con-
 taminants did not  warrant fencing.  The Agency for Toxic Sub-
 stances  and Disease Registry is re-evaluating the data to deter-
mine the extent of any possible public health risk.

      A removal was warranted at the zinc shop because the condi-
 tions at the site  met the criteria in the National Contingency
Plan (NCP),  40 CFR 300.65.  The NCP states that if a removal
action is appropriate,  actions shall begin as soon as possible to
prevent,  minimize, or mitigate the threat to public health or
welfare  or  the environment.  The NCP provides a list of removal
actions  which may  be appropriate in some situations.  One pos-
sible removal action is to put fences, warning signs, or other
security or site control precautions where humans or animals have
access to the contaminant.
           o
                      HEADQUARTERS LIBRARY
                      ENVIRONMENTAL PROTECTION AGENCY
                      WASHINGTON, D.C. 20460

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Recommenda t ion

     Our observations of the man entering, and the children
playing at the site show that there is unrestricted access to the
site.  Therefore, we recommend that Region 5 consider posting
warning signs at this site to alert the public of the potential
for health risk.                                   .             .

Action Required

     In accordance with EPA Directive 2750, the action official
is required to provide this office with a written response to
this report within 90 days of the report date.

   •  If you have any questions, please contact me or Michael
Rickey.
Distribution:

     Regional Administrator (5RA)
     Chief, FAS (5MFA)
     Inspector General (A109)

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