8’ < ,? b United States General Accounting Office ,- Report to Congressional Requesters s GAO July 1990 COASTGUARD Additional Efforts Needed to Clean Up Hazardous Waste Sites GAO United States General Accounting Office Washington, D.C. 20548 - Resources, Community, and Economic Development Division H-239748 July 6, 1990 The Honorable Walter B. Jones Chairman, Committee on Merchant Marine and Fisheries House of Representatives The Honorable W. J. Tauzin Chairman, Subcommittee on Coast Guard and Navigation Committee on Merchant Marine and Fisheries House of Representatives The Honorable Robert W. Davis Ranking Minority Member Committee on Merchant Marine and Fisheries House of Representatives The Honorable Don Young Member, Subcommittee on Coast Guard and Navigation Committee on Merchant Marine and Fisheries House of Representatives This responds to your request that we update information on the Coast Guard’s progress in carrying out its environmental responsibilities under the Resource Conservation and Recovery Act of 1976 (RCRA) and the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCI,A), commonly referred to as the Superfund Act. In 1986 and 1987, we issued two reports on the slow progress of federal agencies, including the Coast Guard, in meeting these environmental responsibilities.’ As agreed with your offices, this report describes the status and cost of the Coast Guard’s efforts to comply with (1) CERCLA and HCKAto identify, evaluate, and clean up its hazardous waste loca- tions where past contamination occurred and (2) KCKA environmental requirements for hazardous waste currently being generated at Coast Guard facilities. We testified on the preliminary results of our work before the Subcommittee on Coast Guard and Navigation, House Com- mittee on Merchant Marine and Fisheries, on November 1, 1989.’ ‘Hazardous Waste: Federal C I “’ ^ ..I’. .. -. ‘:? : RCED-B-76, May 6. 19X6) a Wastr (GAO/RCED-87-1.53. .,u,,v il. ,.,<,e ,. ‘The Coast Guard’s Cleanup <of I I.aardous Waste Sites (GAO/VRCED-90-06,. Nov. 1, 1989). Page 1 GAO/RCED90164 Cleaning Up Hazardous Waste Sites B-239748 Executive Order 12088, issued on October 13, 1978, requires each fed- eral agency to ensure that all necessary actions are taken for the pre- vention, control, and abatement of environmental pollution at its facilities. Under this order, the Coast Guard is responsible for requesting adequate funding for pollution controls and for developing solutions to environmental problems. To comply with this order, in 1985, the Coast Guard instructed its field commands to report information on environ- mental violations and the related costs of correcting the violations, including cleanup and litigation costs. to its headquarters program office. The Congress, expressing concern about the Coast Guard’s efforts to clean up hazardous waste contamination at its facilities and to respond to other environmental compliance requirements, recently enacted legis- lation to establish a new environmental program in the Coast Guard.’ The program will have a new budgetary account to fund “in-house” environmental activities and will require annual progress reports to the Congress on the implementation of the program. The program is designed to provide increased emphasis and visibility for an expanded agency effort to clean up its hazardous waste sites and to comply with environmental laws. The Coast Guard has made progress, since our 1987 report, in identi- Progress in Cleaning fying and investigating potential hazardous waste locations, but most of Up Past Hazardous its cleanup work still remains to be done. The Coast Guard estimates Waste Contamination that its hazardous waste cleanup effort will take decades to complete and will cost millions of dollars. Since we issued our 1987 report, 39 additional potential hazardous waste locations have been identified, bringing the total to 67. Of these 67 locations, the Coast Guard determined that 27 did not require cleanup. While minor cleanup at 4 locations was completed, bringing the total locations cleaned up to 14, the number of locations still requiring cleanup increased from 15 to 20. In addition, six potential hazardous waste locations still need to be investigated. Although the Coast Guard plans to complete its remaining investigations during fiscal years 1990- 199 1 and to complete minor cleanups by 1993, the agency estimates that cleanup efforts at four major locations could take up to 30 years to com- plete. Total estimated costs to clean up the four major cleanup loca- tions-Air Station Traverse City, Michigan; Air Station Brooklyn, New ‘Coast Guard Authorization Al’t of 1989 (P.I. 10X225), Dec. 12, 1989. Page 3 GAO/RCED-90-164 Cleaning Up Hazardous Waste Sites 5239748 Coast Guard instructions require that environmental violations and the related costs of correcting violations are reported to the headquarters’ program office, but the field commands are not reporting most of this information. The headquarters’ environmental section chief told us that, in his opinion, the information is generally not being provided because field staff are either not aware of the reporting requirement or do not have the time to comply with it. In addition, a 1987 Coast Guard reor- ganization, which occurred after the issuance of its reporting instruc- tions, shifted the environmental functions from the field commands that had been responsible for reporting the information to another field com- mand level. As a result, the Coast Guard is unable to assess its actual environmental compliance costs and is hindered in its ability to estimate long-term funding needs for compliance with environmental laws. At our request, the Coast Guard surveyed its field commands to deter- mine the number of KCFUenvironmental inspections and violations cited at its facilities. The survey showed that, of 37 Coast Guard facilities inspected during a recent 3-l/2 year period, almost half were cited for a total of approximately 125 RCRA violations. Agency officials told us that the most frequent violations were storing wastes for longer than the authorized period of time (usually 90 days) and not maintaining the records that RCRArequires. As of August 1989, according to the Coast Guard, it had corrected most of the violations, and 29 violations remained to be corrected. Most of the remaining 29 uncorrected violations are at 2 locations where major haz- ardous waste cleanup efforts are needed-Elizabeth City and Kodiak. The Coast Guard believes that the violations are serious. For example, violations in a land disposal facility’s groundwater monitoring system could result in releases of hazardous wastes to the environment. (See app. II.) In our November 1989 testimony and in subsequent discussions with Coast Guard officials, we expressed concern that the Coast Guard did not have needed information to effectively evaluate its environmental program and to request appropriate budgetary funding. Coast Guard headquarters officials noted that they planned to reissue the environ- mental reporting instructions to the field commands and to reemphasize the importance of reporting environmental violations and related costs. Subsequently, on May 29, 1990, the Coast Guard headquarters’ program office issued a notice instructing its field commands to report informa- tion concerning environmental violations. Page 5 GAO/RCED-90164 Cleaning Up Hazardous Waste Sites B-239748 To determine the status and cost of the Coast Guard’s efforts to clean up its hazardous waste locations and to comply with current environmental regulations, we interviewed officials at Coast Guard headquarters in Washington, D.C. We also contacted a Coast Guard official in Alameda, California, Environmental Protection Agency (EPA) officials, and Kodiak Electric Association officials and attorneys regarding cleanup of polychlorinated biphenyl (PCB) at the Kodiak facility. In addition, we reviewed relevant reports and documents, including those of the Depart- ment of Transportation and its Inspector General, pertaining to the Coast Guard’s environmental compliance activities. Information on envi- ronmental inspections and violations was derived from a Coast Guard survey of its facilities done at our request. We conducted our work from May 1989 through May 1990 in accordance with generally accepted gov- ernment auditing standards. As arranged with your offices, unless you publicly announce its contents r,arlier, we plan no further distribution of this report until 30 days after the date of this letter. At that time, we will send copies to the Secretary of Transportation, the Commandant of the Coast Guard, and other inter- csted parties. This work was conducted under the direction of Kenneth M. Mead, Director of Transportation Issues, who may be reached at (202) 275-1000 if you or your staff have any questions. Other major contributors to this report are listed in appendix III. Y J. Dexter Peach Assistant Comptroller General / Page 7 GAO/RCED-90-164 Cleaning Up Hazardous Waste Sites Abbreviations AC&I Acquisition, Construction, and Improvements CERCLA Comprehensive Environmental Response, Compensation, and Liability Act EPA Environmental Protection Agency ux4i% Long-range aid to navigation OE Operating Expense RCUA Resource Conservation and Recovery Act page 9 GAO/RCED-SO-164 Cleaning Up Hazardous Waste Sites Appendix I Progress in Cleaning Up Past Hazardous waste c!ontamimtion other minor cleanups. In addition, OE funds are used for the administra- tive and operational phases of investigating and monitoring major cleanup locations and to pay the Coast Guard’s share of the investiga- tion costs for third-party hazardous waste sites. The Coast Guard uses AC&I funds primarily for investigating and cleaning up its long-term and high-cost major hazardous waste locations such as those at Elizabeth City, North Carolina and Kodiak, Alaska. Such projects usually require a significant period of time (as much as 20 to 30 years) to complete cleanup efforts. Since our July 1987 report, the Coast Guard has identified many addi- Status of Activities tional potential hazardous waste locations. agency officials believe that they have identified all of their hazardous waste locations but acknowl- edge that a few additional minor locations could still be identified. In any case, agency officials do not expect to discover any locations needing major cleanup not currently under investigation. The following table summarizes the Coast Guard’s progress in identi- fying, investigating, and cleaning up its hazardous waste locations since the date of our last report. Table 1.1: Summary of Coast Guard’s Potential Hazardous Waste Locations As of Identified, Investigated, and Cleaned Up Cleanup activities 1997 reporta April 1990 Potential hazardous waste locahons ldenhfled 28 67 lnvestlgatlon needed 3 6 LocatIons west~gated 25 61 No cleanup required 0 27 Cleanup completed 10 14 Cleanup required 15 20 “As reported by the Coast Guard in September 1986 As table I. 1 shows, since our earlier report, the number of potential haz- ardous waste locations identified and investigated has more than doubled, and the number of locations still requiring cleanup has increased. The Coast Guard expects to complete all investigations during fiscal years 1990-1991 and to complete minor cleanup actions at 15 of 20 locations that require cleanup by 1993. The Coast Guard has not yet estimated the cleanup date for one other minor location. Page 11 GAO/RCED-S&164 Cleaning Up Hazanious Waste Sites Appcdix I Progress in Cleaning Up Past Hazardous Waste Cbntamhation expense, and a lawsuit on this issue led to a settlement agreement. The Coast Guard’s cleanup efforts started in 1984, and cleanup and moni- toring activities are expected to continue until the year 2005. The agency has already been appropriated about $7 million through fiscal year 1989 and estimates that cleanup costs will total about $20 million. Brooklyn Air Station The second major cleanup location, the Brooklyn Air Station, has groundwater contamination caused by leaking aviation fuel that was discovered in the early 1980s. In addition, contaminated soil has been excavated. The Coast Guard’s cleanup efforts started in 1983, and cleanup and monitoring activities are expected to continue until the year 2000. Costs to date have totaled about $500,000, but total estimated cleanup costs are still unknown. Further investigation of possible groundwater cleanup similar to that at Air Station Traverse City is pres- ently being explored by the Coast Guard. Elizabeth City Support The third major cleanup location, the Elizabeth City Support Center, has two hazardous waste sites that were identified in 1985. The major Center problem at these sites is groundwater contamination caused by a leaking hazardous waste lagoon and by leaking storage tanks and a fuel spill at a fuel farm. The investigation of these sites has been underway for over 2 years. According to the Coast Guard, there have been several unantici- pated delays in starting the cleanup effort at Elizabeth City. These delays include changes in the requirements by EPA and the state of North Carolina as to the extent of cleanup needed, the need to hire a new assessment contractor, increased state requirements for assessment and RCRA permits, and slow turnarounds from commercial laboratories testing groundwater contamination. The Coast Guard plans to begin cleaning up the groundwater in fiscal year 1991 and expects that the cleanup and monitoring will require about 25 years to complete. Its appropriated funds used for investiga- tion and cleanup activities through fiscal year 1989 have totaled about $5.8 million, and it estimates that total cleanup costs will range from $10 million to $30 million. Kodiak Support Center The fourth major cleanup location, the Kodiak Support Center, has 19 potential hazardous waste sites that were identified between 1980 and Page 13 GAO/lUXD4O-164 Cleaning Up Hammlous Waste Sites Appendix I Pmqess in Cleaning Up Past Hazardous waste Contamination Twenty-Seven Potential Point Spencer Dump, Alaska Base Yerba Buena Island, Calif. Hazardous Waste Station Ft MacArthur, Calif. Locations Investigated and IDRAN Station Middletown, Calif. Found to Need No Cleanup Support Center Alameda, Calif. Action: Support Center San Pedro, Calif. Base Mayport, Fla. Station Key West, Fla. Station St. Petersburg, Fla. Support Center New Orleans, La. Base South Portland, Maine Base Woods Hole, Mass. South Weymouth Buoy Depot, Mass. Station Charlevoix, Mich. Station Munising, Mich. Group Duluth, Minn. Support Center New York, N.Y. Aids to Navigation Team Saugerties, N.Y. Station Fort Macon, N.C. Aids to Navigation Team Coos Bay, Oreg. Base Astoria, Oreg. Marine Safety Station Portland, Oreg. Air Station Borinquen, P.R. (Formerly Ramey AFB) Depot Corpus Christi, Tex. Support Center Portsmouth, Va. Support Center Seattle, Wash. Base Milwaukee. Wis. Page 16 GAO/ECEENO-164 Clerning Up Hazardous Warae Sites Appendix1 Prom in Cleaning up Paa Ihmrdous waste contamiMtion Cleanup Total Estimated Locations estimated cost completion date Support Center Kodrak, Alaska $10,000,000 50,000,0~~ 2020 Base Mtamr Beach, Fla 350,000 Unknown Arr Statron Traverse Crtv. Mrch 20.000.000 2005 Whtte Shoal LT”, Mrch 100,000 1991 Soectacle Reef LT”, Mrch - - ~~-~ - - - 50.000 1993 Statron Portage, Mich. 38,000 1990 Statron Saqrnaw, Mrch 52,000 1990 Statron Manistee, Mich 34,000 1990 St Martins Island LTa, Mrch ” 70,000 1993 Summer Island LT”. Mrch 30.000 1993 Granite Island LT”, Mrch. 30,000 1993 Poverty Island LT”, Mich. 30,000 1993 Crrsp Pornt LT”, Mrch 57,000 1993 Thunder Bay Island LT”, Mrch 105,000 1993 Middle Island LT”, Mrch 50,000 1993 Statron Ft Totten, N Y Unknown 1990 to 1991 Air Statron Brooklyn, N Y Unknown 2000 Support Center Elizabeth Crty N C 10.000,000 30,000,0d~ 2015 Statron Ashtabula. Ohio 130,000 1990 Base Galveston, Tex 20.000 1990 ‘AIds to nawgatlon such as a navigational light or a lighthouse ‘This lo~atm also contams a site that was cleaned up (see table 12) Source U S Coast Guard In addition to investigating and cleaning up its own hazardous waste Third-Party Sites locations, the Coast Guard is also responsible for paying its portion of the investigation and cleanup costs for sites that are primarily public and private landfills used by it and other parties (third-party sites). Individual costs for the Coast Guard’s share of third-party sites are based on the amount and toxicity of hazardous waste which the Coast Guard sent to the site. Either EPA or the state identify all potentially responsible parties (anyone with any connection to the site) and request information on what hazardous waste material each party sent to the site. Once individual contributions to the site are known, a percentage of the total volume is determined and a dollar figure assigned to each party-that party’s share of the cost to investigate and cleanup the site. page17 GAO/RCED-90.164 Cleaning Up Hazardous Waste Sites Appendix 1 Progress in Cleaning Up Past Hazardous Waste Contamination The Coast Guard believes that its past and current appropriated funding Funding-- of Hazardous levels for hazardous waste cleanup activities and compliance with envi- Waste Cleanup ronmental laws, which averaged about $6.8 million annually for fiscal Locations years 1988 through 1990, have been and remain adequate for its present stage of work-mainly investigating potential hazardous waste loca- tions, investigating and cleaning up major locations, and cleaning up minor locations. While the agency recognizes a need to increase future funding for cleaning up major hazardous waste locations, it will be unable to more precisely project the total long-term funding needed until it completes investigations at all hazardous waste locations. During fiscal years 1988 through 1990, the Coast Guard’s appropriated AC&I funds for cleanup activities averaged about $3.4 million annually and its appropriated OE funds also averaged about $3.4 million annually. The Coast Guard believes that such funding levels are adequate for its present stages of investigation and cleanup work. During 2 of the past 3 fiscal years, the Coast Guard did not spend all of the AC&I hazardous waste cleanup funds that it planned to and reprogrammed the funds for other uses. For example, because of the unanticipated delays experi- enced by the Coast Guard in starting its cleanup effort at Elizabeth City, about $4.7 million of the $5.3 million of AC&I funds appropriated in fiscal years 1987 and 1988 was reprogrammed from hazardous waste cleanup to ship repairs. Although the Coast Guard believes that its future funding levels will need to be increased to clean up the major locations, it does not yet know what levels of long-term funding will be needed because it is still investigating major cleanup locations. According to Coast Guard offi- cials, in the future, Department of Defense funds may also be available for investigating and cleaning up some of the Coast Guard’s hazardous waste sites that were formerly Defense-owned properties. Defense funding would depend on the Coast Guard and Defense agreeing that both parties had contributed to the contamination at these sites. To respond to the problem of hazardous waste contamination at present and former Coast Guard facilities, in December 1989, the Coast Guard Authorization Act of 1989 was enacted to establish an environmental compliance and cleanup program and a new budgetary account to fund the agency’s environmental activities, including its environmental com- pliance activities that are discussed in appendix II. The act was designed to emphasize the need to respond to the problem of hazardous waste Page 19 GAO/ItCELNO-164 Cl- Up -ona Warate sites Appendix II Compliance With EkwironmentaJ Requirements at Coast Guard Facilities Currently Generating Hazardous Waste The Coast Guard’s field commands are not reporting information to the headquarters’ program office, as required, on environmental violations at its facilities that currently handle hazardous waste and the related costs of correcting the violations. The absence of this information hin- ders the Coast Guard’s ability to evaluate the effectiveness of its envi- ronmental compliance program, to estimate its long-term funding needs, and to provide meaningful progress reports to the Congress as required by P.L. 101-225. A Coast Guard survey, done at our request, showed that of the agency’s 172 facilities that currently handle hazardous waste, almost half of the 37 facilities inspected were cited for violating hazardous waste regula- tions. While the Coast Guard has corrected most of the violations, the majority of the uncorrected violations are concentrated at two locations where major cleanup actions are needed. tinder KCRA regulations, the Coast Guard is responsible for the safe man- Background agement and control of hazardous wastes currently being generated at its facilities. The Coast Guard operates hundreds of facilities, many of which handle hazardous waste materials. The primary types of haz- ardous waste that Coast Guard facilities handle include used batteries and spent solvents and paints. As shown in Figure II. 1, most (about 76 percent) of the agency’s 172 facilities that have been identified as handling hazardous waste are small quantity generators that handle small amounts-less than 2,200 pounds per month, or the equivalent of about five full 55-gallon drums. The Coast Guard also has generators that handle hazardous waste amounts greater than 2,200 pounds per month and treatment, storage, and disposal facilities that can accumulate hazardous waste for more than 90 days. Two of the Coast Guard’s largest handlers-the support centers in Elizabeth City, North Carolina and Kodiak, Alaska-are treatment, storage, and disposal facilities that are scheduled for major cleanup work. Page 21 GAO/RCED90-164 Cleaning Up Hazardous Waste Sites Appendix II Compliance With Environmental Requirements at Coast Guard Facilities Currently Generating Hazardous Waste agency’s regulations concerning hazardous waste management. For instance, several aboveground fuel storage tanks did not have fuel overfill protection devices to detect and prevent problems with toxic and hazardous waste storage. In its Semiannual Report to Congress for the period ending September 30, 1989, the Department of Transportation Inspector General noted that in the past it had reported on the Coast Guard’s problems relating to the removal of hazardous waste materials from its facilities. The Inspector General also pointed out that ongoing work has shown that the Coast Guard will not be in compliance with state and local require- ments for managing and monitoring underground fuel storage tanks. The report further stated that the agency’s abatement plan for under- ground leaking storage tanks is incomplete because it does not include all the projects that need to be done and all the costs associated with implementing the plan. The report explained that if the Coast Guard did not implement an effective underground storage tank program, Coast Guard facilities will be placed in noncompliance with EPA'S release detec- tion requirements that, took effect in December 1989. Coast Guard instructions require that environmental violations at its Inspections and facilities be reported to headquarters; however, headquarters does not Violations at Coast have complete data on violations cited at its facilities because the Coast Guard Facilities That Guard’s field commands have not always provided it. The information presented below is from a recent Coast Guard headquarters’ survey of Currently Handle its facilities that was done at our request. Hazardous Waste Figure II.2 shows that of the Coast Guard’s 172 facilities that handle hazardous waste, about 22 percent (37) were inspected from January 1, 1986, through June 1, 1989, by either EPA or the states in which the facilities were located. Treatment, storage, and disposal facilities were the most frequently inspected, and small quantity hazardous waste gen- erators were the least frequently inspected. Page 23 GAO/RCED-90.164 Cleaning Up Hazardous Waste Sites Appendix II Compliance With Environmental Requirements at Coast Guard Facilities Currently Generating Hazardous Wast.e tinder Executive Order 12088, the Coast Guard and other federal agen- More Complete ties are responsible for ensuring that their facilities comply with envi- Information Needed ronmental pollution control laws and for ensuring that sufficient funds for Estimating for compliance are requested in the agency budget. IJnder this order, the Coast Guard is responsible for cooperating with EPA, state, and local Compliance Program agencies in meeting its pollution control responsibilities and submitting Funding Requirements pollution control plans to the Office of Management and Budget through EPA. To comply with the requirements of the executive order, in 1985, the Coast Guard instructed its district commanders to report information on environmental violations and the related costs of noncompliance to its headquarters program office. Reports are required immediately after being cited for a violation, on an annual basis, and after completing cor- rective actions. This data was to be used to evaluate program effective- ness and to request appropriate budgetary funding to cover costs incurred because of noncompliance with environmental laws. In addi- tion, the field commands are required to provide an annual report to the Coast Guard headquarters summarizing the total costs incurred each year from correcting violations. After completing corrective actions, the field commands are required to provide headquarters with a description of the actions taken to remedy the violation, the proposed action to be taken to prevent similar violations in the future, and an accounting of all costs incurred. Despite these reporting requirements, complete information on viola- tions and the costs incurred in correcting them was unavailable at the headquarters’ environmental office that manages these activities because field offices arc not reporting most of the data on environ- mental violations and related costs. The headquarters’ environmental section chief told us that, in his opinion, this information is generally not being provided for a variety of reasons, including field staff who are unaware of the reporting requirement, inadequate staff time to comply with the requirement. and staffing turnover. In addition, he explained that after the reporting instructions were issued, a 1987 Coast Guard reorganization that transferred the agency’s environmental functions from district commands, which had been responsible for reporting the information, to maintc>nance and logistics commands and shore mainte- nance detachments, may have caused confusion concerning the reporting requirement. The official said that the insufficiency of this information may have, affected the Coast Guard’s budget requests for environmental complianc~r. He added that having this information may help the agency obtain nc>cdt>dfunding in the future. Page 25 GAO/RCED-90-164 Cleaning Up Hazardous Waste Sites Appendix III Major Contributors to This Report John W. Hill, Jr., Associate Director Resources, Emi Nakamura. Assistant Director Community, and Steven R. Gazda, Assignment Manager James I,. Dishmon, Jr., Evaluator-in-Charge Economic Development Division, Washington, D.C. (344454) Page 27 GAO/RCED-90164 Cleaning Up Hazardous Waste Sites Requests for copies of GAO reports should be sent to: U.S. General Accounting Office Post Office Box 6015 Gaithersburg, Maryland 20877 Telephone 202-275-6241 The first five copies of each report are free. Additional copies are $2.00 each. There is a 25% discount on orders for 100 or more copies mailed to a single address. Orders must be prepaid by cash or by check or money order made rly 1" wry ~~p~~wlflnu" IIF pu 11=1mwy Appendix II Compliance With Environmental Requirements at Coast Guard Facilities Currently Generating Hazardous Waste On May 29, 1990, the Coast Guard headquarters’ program office issued a notice to the field commands instructing them to report information on environmental violations. Because of inadequate reporting and responses from field commands to headquarters’ requests for this infor- mation in the past, we believe reemphasis of this reporting requirement is necessary. The Coast Guard should take follow-up action to ensure that this program information is properly reported because it is vital for evaluating the program, estimating funding needs, and providing mean- ingful progress reports to the Congress as required by P.L. 101-225. Page 26 GAO/RCED-90-164 Cleaning Up Hazardous Waste Sites Appendix II Compliance With Environmental Requirements at Coast Guard Facilities Currently Generating Hazardous Waste Waste Handlers Inspected Handlers inspected - 37 Handlers not inspected - 135 Note Inspected during the pemd I/1/66 lo 6/l/89 Source U S Coast Guard About half of the Coast Guard facilities inspected (17 of 37), were cited for a total of approximately 125 KCRA violations. According to Coast Guard officials, the specific types of environmental violations ranged widely. The violations included improper record keeping, storage, dis- posal, and labeling; not testing wastes to confirm or deny classification as hazardous waste; and the absence of contingency plans designed to minimize hazards from fires, explosions, or any unplanned release of hazardous waste. Agency officials told us that the two most frequent types of violations were storing wastes for longer than the authorized period of time (usually HOdays) and not maintaining the records that HcR4 requires. According to the Coast Guard, most of the violations have been cor- rected and 29 violations, or about 23 percent of the total, remained uncorrected at four facilities as of August 1989. Twenty-four of the 29 uncorrected violations are at two locations where major cleanup efforts for past contamination are needed-Elizabeth City, North Carolina and Kodiak, Alaska. ‘I%? Coast Guard believes that the majority of the uncorrected violations, some of which have been uncorrected for more than 1 year, arc probably the type that the EPA considers serious-for example, a land disposal facility with violations of requirements for groundwater monitoring. Page 24 GAO/RCED-90-164 Cleaning Up Hazardous Waste Sites Appendix II Compliance With Environmental Requirements at Coast Guard Facilities Currently Generating Hazardous Waste Figure 11.1:Categories of Coast Guard Hazardous Waste Handlers Treoatment, Storage and/or Disposal ( ELilit y Generator Small Quantity Generator Source U S Coast Guard Coast Guard facilities handling hazardous wastes are subject to environ- mental inspections by either EPA or a state agency to determine if they comply with KCKAregulations on record keeping and reporting, contin- gency planning, personnel training, and other activities. The RCFLA requirements for treatment, storage, and disposal facilities are more extensive than the requirements for other hazardous waste handlers. For example, treatment, storage, and disposal facilities must take appro- priate steps to ensure that hazardous wastes are contained within their facilities and do not seep or leak into underground water supplies or outside the boundaries of their facilities. In its December 1989 Financial Integrity Act Report to the President, the Secretary of Transportation listed two Coast Guard material weaknesses associated with safety and environmental issues that pose a danger or threat to human lifr. the environment, or both. The agency’s first mate- rial weakness was noncompliance with State and Federal laws relating to underground fuel storage facilities, and its second was noncompliance with regulations concerning aboveground fuel storage tanks. The Secre- tary’s report not.4 t,hat various Coast Guard facilities’ staff were not knowledgeable or familiar with EPA and other state/local regulations on underground storage) tank inventory procedures for leak detection. The report also noted that various Coast Guard facilities did not follow the Page 22 GAO/RCED-90-164 Cleaning Up Hazardous Waste Sites Appendix I Progress In Cleaning Up Past Hazardous Waste Contamination contamination at Coast Guard facilities across the country and to envi- ronmental compliance activities. The legislation also requires the Secre- tary of Transportation to submit an annual report to the Congress describing the Coast Guard’s progress in implementing the program. The new Coast Guard program and budgetary account will be estab- lished in fiscal year 199 1 and no-year appropriated funds placed in the account will remain available until expended. This contrasts to the 5 year AC&I funding method now in use for the Coast Guard’s environ- mental hazardous waste cleanup activities. To carry out its environ- mental compliance and restoration activities for fiscal year 199 1, the Coast Guard has requested appropriation funding of $7 million for the new budgetary account and $4 million for the OEaccount. Currently, these activities are funded through either the AC&I or OE budgetary accounts. Under recently introduced legislation (H.R. 4609), the Coast Guard Authorization Act of 1989 (P.L. 101225) would be amended to provide $15 million for the Coast Guard’s in-house environmental activi- ties for fiscal year 1991. Page 20 GAO/RCED-90-164 Cleaning Up Hazardous Waste Sites Appendix I Progress in Cleaning Up Past Hazardous Waste Contamination As shown in table 1.4, the Coast Guard is responsible for a portion of the investigation and cleanup costs at 20 third-party sites. These sites are still in the investigation phase. Table 1.4: Coast Guard’s Twenty Third- Party Sites Federal sites (19) Location .- Yaworskr Lagoon Canterbury, Conn Dubose 011 ----~Escambb%County, Fla Petroleum Products, Inc Hiiywood, Fla -- Sidney Mane ~~~-.- Htllsborouqh County, Fla Yellow Water Road Baldwin, Fla -- .- Marine Shale Processors Amelia, La Unwon Chemtcal South .LHobe. Marne Spectron Elkton, Md. Aerovox Sate Boston, Mass Cannon Engtneenng” Mass and N H. Charles -. -~ George ~~ Tyngsboro, Mass Liquid Drsposal Inc Utica, Mich Drsposal Systems Inc (Owned by Dubose BIIOXI, MISS Oih Glenwood Landrng Glenwood Landrno, N.Y Shore Realty Sate Macon Sate Rrchmond, N.C Commercial 011Services Oreaon. Ohro North Smrthfteid North Smrthfield. R I. Western Processrng Kent Countv Wash. State Sites (1) Oak Grove Pans, Term “The Coast Guard consrders thls thrrd-party act~cn that involves two states as one federal site Source U S Coast Guard In the past 2 fiscal years, the Coast Guard’s share of the investigative and administrative costs for third-party sites totaled about $2 million, and agency officials are uncertain of future costs. The headquarters’ environmental section chief told us that the agency had neither esti- mated the total costs for third-party sites, nor had it estimated when cleanup could be completed because the extent of contamination is still being investigated. The official acknowledged that in some cases, such as groundwater contamination, the cleanup and monitoring could take up to 30 years to complete. Page 18 GAO/RCED-II@164 Cleaning Up Ham.rdous Waste Sites Appendix I Progress in Clew Up Past Hazardous Waste C!antamination Table 1.2: Fourteen Locations That Have Been Cleaned Up Locations Estimated costs Station Michtgan City, Ind $15,000 Crisfteld, Md. ______ Unknown Aberdeen Proving Ground, Md. Unknown Elk River/Back Creek, Md ___~ Unknown St Martms Island LTa, Mtch 25,000 Manitou __. Island LT”, Mich. 25,000 Statton Grand Haven, Mtch 10,000 Station Ludington, Mlch 25,000 Station Alex Bay, N Y 5,000 Station Oswego, N Y 3,000 Statlon Marblehead, Ohlo 5,000 Station Erie, Pa 30,000 LaPotnte LT”, Wis. 3,000 Statlon Sheboygan, WIS 45,000 “AIds to navtgatlon such as a navlgatmal light or a lkghthouse page 16 GAO/RCEB90164 Cleaning Up Hazardous Waste Sites Appendix I Progressin cleaningup Past Hazardous Waste Contamination 1989. The Coast Guard is currently investigating six sites where haz- ardous wastes-primarily solvents and petroleum products-were dis- posed of or leaked into the ground. This investigation has been underway for about 2 years. The agency plans to start cleanup actions in fiscal year 1990 or 1991 and believes that cleanup and monitoring will take about 30 years to complete. It estimates that appropriated funds for fiscal years 1987 through 1989 will total about $2 million and that total cleanup costs will range from about $10 million to $50 million. The total estimated cleanup costs shown above include cleaning up the PCB contamination at the Kodiak facility. Although the Coast Guard sold the facility’s electrical distribution system-including poles, cables, and transformers-to the Kodiak Electric Association in November 1984, the land and structures containing the electrical equipment remain the property of the Coast Guard. In June 1985, EPA found PCB contami- nation at the facility. According to the headquarters’ environmental sec- tion chief, the Coast Guard currently estimates costs of about $1 million to remove PCB contaminated equipment and to clean up PCB contami- nated land and structures. The Kodiak Electric Association believes that the cleanup of the PCB contamination in transformers and cables could cost $5 million to $25 million, not including long-term monitoring costs. On November 27, 1989, EPA and the Coast Guard entered into a memo- randum of agreement concerning the cleanup of PCB contamination of land, structures, and transformers at Support Center Kodiak. Under the terms of the agreement, the PCB cleanup work is scheduled to be com- pleted in 1991. The following two lists and tables I.2 and I.3 provide information on the status of investigation and cleanup activities for the Coast Guard’s 67 potential hazardous waste locations. For the 14 locations that have been cleaned up and the 20 locations that require cleanup, agency estimates of cleanup costs and completion dates are also provided. Six Potential Hazardous Base Ketchikan, Alaska Waste Locations That St. Paul IDRAN (long-range aid to navigation) Station, Alaska Back Creek Rear Range Structure, Md. Need to Be Investigated: Coast Guard Yard, Md. Station Sandy Hook, N.J. Support Center Seattle Annex, Wash. Page 14 GAO/&cED-90164 Cledng Up khzardous Wm.&z Sites Appendix I Progreaa in cleaning up Past Hmm-dous waste tintamination The table also shows that the Coast Guard has cleaned up 14 locations. These locations required relatively minor cleanup-such as the excava- tion of buried waste, tanks, and/or contaminated soil, or the removal of used batteries. The Coast Guard could not provide actual costs for cleaning up each location. However, the agency estimated that the costs for each location ranged from about $3,000 to $45,000. Estimated costs for the remaining three locations were unknown. The Coast Guard estimates that of the 20 locations requiring cleanup, relatively minor actions at 16 locations will cost about $1.1 million (costs were unknown for 1 of the 16 minor locations) and that all but one of these efforts should be completed by 1993 (completion date was unknown for 1 of the 16 locations). According to the Coast Guard head- quarters’ environmental section chief, the agency was hindered in its efforts to clean up these minor locations earlier because of an inade- quate number of staff with either environmental or contracting exper- tise necessary for performing the cleanup work or contracting out the effort. The remaining four major locations that need cleanup will require extensive actions at significant cost. The cleanups required at these locations are considered major because they involve potentially extensive groundwater and soil contamination. Regarding its four locations requiring major cleanup-Air Station Trav- Status of Major erse City, Michigan; Air Station Brooklyn, New York; Support Center Cleanup Efforts Elizabeth City, North Carolina; and Support Center Kodiak, Alaska-the Coast Guard has begun cleaning up hazardous waste at its Traverse City and Brooklyn locations; however, the Coast Guard is exploring whether further investigation of the Brooklyn location is needed. The other two major locations are being investigated to determine the types and levels of contaminants that arc present. The Coast Guard hopes to begin cleanup efforts at these two locations in fiscal year 1990 or 199 1. Agency-appropriated funds through fiscal year 1989 have amounted to about $15 million, and it currently estimates total costs of about $40 million to over $100 million to investigate and clean up the four loca- tions over the next 10 to 30 years. Traverse City Air Station At the Traverse City Air Station, groundwater contamination was iden- tified at two sites. The first, identified in 1980, was caused by a 1969 aviation fuel spill; the second, identified in 1985, was caused by three leaking fuel tanks. As a result of this groundwater contamination, local residents’ water supplies were connected to city water at Coast Guard Page 12 GAO/KCELHO-164 Cleaning Up Hazardous Waste Sites Appendix I Progress in Cleaning Up I%st Hazardous Waste Contamination Since the early 1980s the agency has identified 67 potential hazardous waste locations, investigated most of them, and found that over half of the locations required some cleanup action. However, most of the Coast Guard’s cleanup work remains to be done. Of the 34 locations found to require cleanup actions, the Coast Guard has cleaned up 14 minor loca- tions at estimated costs ranging from $3,000 to $45,000, and it plans to complete additional minor cleanups at 16 locations by 1993 at a total cost of about $1.1 million (completion date was unknown for one of the locations). The Coast Guard estimates that cleaning up the four major locations will take up to 30 years to complete and could cost over $100 million. The Coast Guard is also responsible for paying its portion of the investi- gation and cleanup costs for 20 other hazardous waste locations, which are primarily landfills, used by the Coast Guard and other parties. The agency’s share of investigation costs totaled about $2 million during the past two fiscal years; however, agency officials are uncertain of future costs because the locations are still being investigated and the extent of the cleanup has not been determined. Similar to its own hazardous waste locations, some of these sites may also take up to 30 years to clean up. When the Coast Guard identifies a potential hazardous waste location, it Background employs a three-step process to evaluate and, if necessary, to clean up the location where contamination may have occurred. The first step, a preliminary assessment/site investigation, is a study to determine whether hazards to the public health or the environment exist at the location. The second step, a remedial investigation/feasibility study, is a comprehensive investigation of the location’s individual hazardous sites identified in the first step to determine the nature and extent of contam- ination and the appropriate remedial actions. The third step, remedial design/remedial action, entails designing and implementing the remedial actions chosen to address the location’s problem sites. Through fiscal year 1990, the Coast Guard’s environmental cleanup and compliance activities will continue to be funded through two budgetary accounts-the Operating Expense (on) and the Acquisition, Construc- tion, and Improvements (AC&I) accounts. OE funding is used (1) for rou- tine environmental compliance activities, such as the disposal of currently generated hazardous waste; (2) to support projects to test, remove, and replace existing underground storage tanks; and (3) to per- form low-cost and short-term cleanup actions (under $200,000 and gen- erally less than 6 months) associated with storage tank removals and Page 10 GAO/RCEDW-104 CICSII&I Up lhzardow Waste Sites Contents Letter Appendix I 10 Progress in Cleaning Background 10 Status of Activities 11 Up Past Hazardous Status of Major Cleanup Efforts 12 Waste Contamination Third-Party Sites 17 Funding of Hazardous Waste Cleanup Locations 19 Appendix II 21 Compliance With Background 21 Inspections and Violations at Coast Guard Facilities That 23 Environmental Currently IIandlc Hazardous Waste Requirements at Coast More Complete Information Needed for Estimating 26 Compliance Program Funding Requirements Guard Facilities Currently Generating Hazardous Waste Appendix III 27 Major Contributors to This Report Tables Table I. 1: Summary of Coast Guard’s Potential Hazardous 11 Waste Locations Identified, Investigated, and Cleaned IJP Table 1.2: Fourteen Locations That Have Been Cleaned Up 16 Table 1.3: Twenty Locations That Require Cleanup 17 Table 1.4: Coast Guard’s Twenty Third-Party Sites 18 Figures Figure II. 1: Categories of Coast Guard Hazardous Waste 22 Handlers Figure 11.2:Coast Guard Hazardous Waste Handlers 24 Inspected Page 8 GAO/RCED-90-164 Cleaning Up Hazardous Waste Sites R-239748 While the Coast Guard has made progress in cleaning up its hazardous Conclusions waste sites and in complying with environmental requirements, it still has most of its hazardous waste cleanup work to do. This effort will cost millions of dollars and will take decades to complete. The Congress, con- cerned about the Coast Guard’s efforts, recently enacted legislation to establish a new Coast Guard environmental compliance and restoration program. We believe this program, if appropriately and aggressively implemented, should help the Coast Guard in its efforts to clean up its hazardous waste locations and to comply with environmental regula- tions. However, to effectively implement the new program and to facili- tate the required annual progress reports to the Congress, the Coast Guard will need information on environmental violations and the related costs of correcting the violations, including cleanup costs, at its facili- ties In the past, most of this information has not been provided by the Coast Guard’s field commands, which hindered the Coast Guard’s efforts to evaluate the effectiveness of its environmental program and to estimate its program funding needs. The Coast Guard headquarters recently issued a notice to its field commands that reemphasized the importance of reporting information on environmental violations. How- ever, because of noncompliance with previous reporting instructions, the Coast Guard will need to follow up to ensure that this information is properly reported. To improve the information available to the Coast Guard to evaluate its Recommendation to compliance with environmental laws, estimate environmental funding the Secretary of needs, and provide meaningful progress reports to the Congress Transportation required by P.L. 101-225, we recommend that the Secretary of Trans- portation direct the Commandant, 1J.S.Coast Guard, to take follow-up action to ensure that field commands comply with the recently issued notice requiring that information on environmental violations and the related costs of correcting the violations are reported to Coast Guard headquarters. We discussed the results of our review, as reported in our November Agency Comments 1989 testimony and this report, with Coast Guard officials directly responsible for the program. They generally agreed with the data presented and the recommendation, and we incorporated their com- ments where appropriate. IIowever, as requested, we did not obtain offi- cial agency comments on the testimony or this report. Page 6 GAO/RCED-90-164 Cleaning Up Hazardous Waste Sites B-239748 York; Support Center Elizabeth City, North Carolina; and Support Center Kodiak, Alaska-range from $40 million to over $100 million. In addition to being responsible for cleaning up its own hazardous waste locations, the Coast Guard must pay its portion of investigation and cleanup costs for 20 third-party sites that are primarily landfills used by several parties, including the Coast Guard. During the past two fiscal years, the agency’s share of the investigation and administrative costs totaled about 52 million. However, agency officials are uncertain of its future costs for these third-party sites because they are still being inves- tigated and the extent of cleanup has not yet been determined. If groundwater contamination has occurred. the Coast Guard estimates that cleanup actions may take 30 years or more to complete. The Coast Guard believes that its past and current appropriation funding levels for in-house environmental activities, which averaged about 56.8 million annually during fiscal years 1988 through 1990, have been and remain adequate for its present stage of work-mainly investi- gating potential hazardous waste locations, investigating and cleaning up locations with major problems, and cleaning up locations with minor problems. While the agency recognizes that its future funding for cleaning up major hazardous waste locations will need to be increased, it said that it will be unable to more precisely project its total funding needs for cleaning up its hazardous waste locations where past contami- nation has occurred until investigations are completed at all locations. (See app. I.) The Coast Guard headquarters does not have needed information on Compliance With environmental violations or the costs of correcting the violations, which Environmental would enable it to effectively evaluate the program and to request Requirements at Coast appropriate budgetary funding. Our 1986 report also noted that federal agencies, including the Coast Guard, had been slow in developing an Guard Facilities awareness and understanding of their responsibilities under RCRA and in Currently Generating establishing programs to carry out the act’s requirements. In late 1989, both the Secretary of Transportation and the Inspector General also Hazardous Waste expressed concern that the Coast Guard is not in compliance with RCRA and/or state environmental regulations for managing and monitoring underground and aboveground fuel storage tanks. The Secretary of Transportation reported that these problems constitute material weak- nesses associated with safety and environmental issues that pose a danger or threat to human life, the environment, or both. Page 4 GAO/RCED90-164 Cleaning Up Hazardous Waste Sites Is239748 Since our 1987 report, the Coast Guard has made progress in identifying Results in Brief and investigating its potential hazardous waste locations, but most of its cleanup work remains to be done. The Coast Guard has identified a total of 34 hazardous wast.e locations that need to be cleaned up. Since our earlier report, the Coast Guard has completed minor cleanups at 4 addi- tional sites bringing the total to 14 locations cleaned up. However, the number of Coast Guard locations still requiring cleanup has increased from 15 to 20. The Coast Guard estimates that, among the 20 locations requiring cleanup, major cleanup at 4 of its most contaminated sites will take decades to complete and could cost over $100 million. The agency, however, does not have total cost information on all sites requiring cleanup because investigations to determine the nature and extent of contamination and the appropriate remedial action are still ongoing. The Coast Guard does not have most of the information on the nature of environmental violations at its facilities that currently handle hazardous waste or the costs of correcting the violations. Because the Coast Guard’s field commands generally are not reporting complete informa- tion, the agency is not in a good position to evaluate whether its overall environmental program complies with KCKAor to estimate long-term funding needed for environmental compliance. The Coast Guard, as well as other federal agencies, and private entities Background are subject to CE:KCI,~,KCKA, and other environmental laws that require them to regulate and manage t,heir hazardous waste currently being gen- erated and to clean up sites where improper disposal of hazardous waste occurred in the past. CEKCLA provides for the cleanup and management of hazardous wastes or substances disposed of in the past that have been abandoned or left uncontrolled. Among other things, under CEKCL&past and present owners and operators of facilities where hazardous waste was treated, stored, or disposed of, are required to identify such locations and per- form or pay for any necessary cleanup efforts. RCRA provides for the safe management and control of wastes currently being generated and for cleanup of any resulting contamination. The Coast Guard operates hundreds of facilities, many of which currently handle hazardous waste materials regulated under KCRA.The primary types of hazardous waste or substances being handled at Coast Guard facilities include used batteries and spent solvents and paints, Page 2 GAO/RCED-99-164 Cleaning Up Hazardous Waste Sites
Coast Guard: Additional Efforts Needed to Clean Up Hazardous Waste Sites
Published by the Government Accountability Office on 1990-07-06.
Below is a raw (and likely hideous) rendition of the original report. (PDF)