oversight

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)

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
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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