Report: The EPA Should Improve Oversight of Physical Access and Institutional Controls at the Escambia Wood Superfund Site

Report # 24-E-0046, June 12, 2024

Why We Did This Report

While conducting an evaluation of American Creosote Works Inc. in Pensacola, Florida, to determine whether the U.S. Environmental Protection Agency implements and oversees institutional controls, we noted the proximity of the Escambia Wood Treating Company, another Infrastructure Investment and Jobs Act-funded Superfund site. To optimize the value of our site visit, we drove past this site and observed insufficient engineering controls and poorly enforced institutional controls. 
 

Summary of Findings

The EPA is not providing sufficient oversight of the maintenance of engineering controls, specifically physical access controls, and institutional controls to protect human health and the remedy addressing soil contamination at the site. According to site documents, camping and trespassing have been ongoing issues since at least March 2007. However, the EPA did not work with state and local partners to enforce the established institutional controls or take administrative action to ensure this unauthorized use did not continue even though the protectiveness of the remedy depends on it. It is the site’s remedial project manager’s opinion that encampments of homeless persons at the site do not pose an unacceptable risk despite the site’s restrictive covenants. This opinion conflicts with the EPA’s official site decision documentation. Further, the poorly maintained physical access controls and conflicting zoning enable continued camping and trespassing

Report Materials

• At a Glance- 24-E-0046 (pdf) (1.37 KB)
• Full Report - 24-E-0046 (pdf) (1.37 KB)