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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Catalyst for Improving the Environment
Early Warning Report
Observed Conditions at
Five Deleted Superfund Sites
Report No. 11-P-0433
Augusts, 2011
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Report Contributors: Rick Beusse
Kevin Good
Jim Hatfield
Michael Young
Abbreviations
ARCHER Airborne Real-time Cueing Hyperspectral Enhanced Reconnaissance
EPA U.S. Environmental Protection Agency
I-RBC Industrial risk-based concentration
NPL National Priorities List
OIG Office of Inspector General
PPM Parts per million
R-RBC Residential risk-based concentration
USGS U.S. Geological Survey
XRF X-ray fluorescence
Cover photo: U.S. Air Force Civil Air Patrol airplane equipped with the Airborne Real-time
Cueing Hyperspectral Enhanced Reconnaissance System (ARCHER).
(USGS photo)
Hotline
To report fraud, waste, or abuse, contact us through one of the following methods:
e-mail: OIG Hotline@epa.gov write: EPA Inspector General Hotline
phone: 1-888-546-8740 1200 Pennsylvania Avenue NW
fax: 703-347-8330 Mailcode 8431P (Room N-4330)
online: http://www.epa.gov/oig/hotline.htm Washington, DC 20460
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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
11-P-0433
Augusts, 2011
Catalyst for Improving the Environment
Why We Did This Review
We initiated this evaluation to
assess whether the U.S.
Environmental Protection
Agency (EPA), Office of
Inspector General, can use
hyperspectral imaging data as a
feasible oversight tool to assess
the effectiveness of prior
Superfund remediations, or to
target areas for assessment.
Background
The Office of Inspector General
entered into an interagency
agreement with the U.S.
Geological Survey, Eastern
Geographic Science Center, to
develop and test hyperspectral
remote sensing technologies for
the detection of fugitive and
residual contamination at
deleted Superfund waste sites.
Subsequently, the U.S.
Geological Survey entered into
an interagency agreement with
the U.S. Air Force Civil Air
Patrol to use its remote sensing
system to collect hyperspectral
imagery at five deleted former
National Priorities List sites in
Maryland and Virginia.
For further information,
contact our Office of
Congressional, Public Affairs and
Management at (202) 566-2391.
The full report is at:
www.epa.qov/oiq/reports/20117
20110803-11-P-0433.pdf
Observed Conditions at Five Deleted
Superfund Sites
What We Found
Conditions at two of the five sites we visited in EPA Region 3, which had been
remediated and deleted from the National Priorities List, may warrant additional
attention from EPA. Hyperspectral imaging data, on-site testing, and/or soil
samples revealed issues at the Middletown Road Dump site in Annapolis,
Maryland, and the Matthews Electroplating site in Roanoke County, Virginia.
We do not believe conditions at the other three sites visited warrant additional
consideration from EPA.
The Middletown Road Dump site, formerly a dump for construction waste, was
found to have expanded in size since EPA's latest Five-Year Review.
Hyperspectral imaging data identified an anomaly that proved to be leachate
coming from the landfill. Our on-site testing also indicated hydrocarbons
pooling in surface waters, and soil samples collected at the site contained
arsenic, chromium, mercury, and antimony at levels exceeding established
residential risk-based concentrations.
The Matthews Electroplating site, formerly a chrome-plating operation,
contained waste metal, empty drums, and containers. Soil samples taken at the
site contained arsenic, nickel, and antimony at levels exceeding EPA's
established risk-based concentrations for residential areas. We also observed
that the current landowner had started building a residence on the site.
We did not make any conclusions regarding potential health risks or the
effectiveness of EPA's prior remediation efforts, or the usefulness of
hyperspectral imaging data as an oversight tool. We are presenting our results in
this early warning report so Region 3 can review the information on the sites
and take further action if appropriate. Additional work is ongoing to assess the
usefulness of remote sensing technology as an OIG oversight tool.
What We Recommend
We recommend that EPA Region 3's Office of Superfund Site Remediation add
the information in this report to the appropriate site-specific case files and assess
whether any additional action is warranted for the Matthews Electroplating and
Middletown Road Dump sites. The Agency agreed with our recommendations,
stating that it has added the information to the case files and requested more
detailed sampling information to assist it in evaluating the two deleted sites. The
region's ongoing and planned actions meet the intent of our recommendations.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
Augusts, 2011
MEMORANDUM
SUBJECT: Observed Conditions at Five Deleted Superfund Sites
Report No. ll-P-0433
FROM: Arthur A. Elkins, Jr.
Inspector General
TO: Ronald Borsellino
Director, Hazardous Site Cleanup Division, EPA Region 3
This is our report on the subject evaluation conducted by the Office of Inspector General (OIG)
of the U.S. Environmental Protection Agency (EPA). This report contains findings that describe
the problems the OIG has identified and corrective actions the OIG recommends. This report
represents the opinion of the OIG and does not necessarily represent the final EPA position.
Final determinations on matters in this report will be made by EPA managers in accordance with
established audit resolution procedures.
Action Required
In accordance with EPA Manual 2750, you are required to provide a written response to this
report within 90 calendar days. You should include a corrective actions plan for agreed-upon
actions, including milestone dates. Your response will be posted on the OIG's public website,
along with our memorandum commenting on your response. Your response should be provided
as an Adobe PDF file that complies with the accessibility requirements of Section 508 of the
Rehabilitation Act of 1973, as amended. The final response should not contain data that you do
not want to be released to the public; if your response contains such data, you should identify the
data for redaction or removal. We have no objections to the further release of this report to the
public. We will post this report to our website at http://www.epa.gov/oig.
If you or your staff have any questions regarding this report, please contact Wade Najjum,
Assistant Inspector General for Program Evaluation, at 202-566-0832 or najjum.wade@epa.gov;
or RickBeusse at 919-541-5747 or beusse.rick@epa.gov.
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Observed Conditions at Five Deleted Superfund Sites 11 -P-0433
Table of Contents
Purpose 1
Background 1
Scope and Methodology 1
Results of Review 3
Conclusions 9
Recommendations 9
Agency Response and OIG Comment 9
Status of Recommendations and Potential Monetary Benefits 11
Appendices
A Middletown Road Dump, Location and Results of Samples 12
B Matthews Electroplating, Location and Results of Soil Samples 13
C Dixie Caverns Landfill, Location and Results of Soil Samples 14
D Rhinehart Tire Fire Dump, Location and Results of Soil Samples 15
E Mid-Atlantic Wood Preservers, Location and Results of Soil Samples 16
F Region 3 Response to Draft Report 17
G Distribution 19
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Purpose
We initiated this evaluation to assess whether the U.S. Environmental Protection
Agency (EPA), Office of Inspector General (OIG), can use hyperspectral imaging
data as a feasible oversight tool to assess the effectiveness of prior Superfund
remediations, or to target areas for assessment. This early warning report presents
information obtained during the interim phase of our work. Additional work is
ongoing to assess the usefulness of remote sensing technology as an OIG
oversight tool.
Background
EPA OIG Report No. 2007-P-00039, Limited Investigation Led to Missed
Contamination at Ringwood Superfund Site, issued September 25, 2007,
documented problems with insufficient characterization of contamination and
cleanup at the Ringwood, New Jersey, National Priorities List (NPL) Superfund
site. One of the key findings of the report was that the extent of contamination at
the Ringwood site might have been detected earlier if EPA had made greater use
of available aerial photographs. Morphological characteristics of the landscape
and landscape changes, as documented on historical aerial photographs, could
have detected the much larger extent of paint sludge and contamination than was
thought to exist after the initial remedial investigation.
Based on the results of the Ringwood report, the OIG decided to evaluate whether
remote sensing technologies could be an effective tool for the OIG in assessing
long-term remediation conditions at Superfund sites deleted from EPA's NPL.
Remote sensing is the acquisition of information on an object by use of a sensing
device(s) not in physical contact with the object. Hyperspectral imaging, an
advanced form of remote sensing, records reflected and emitted electromagnetic
energy in hundreds of very narrow wavelengths, resulting in data that can be
analyzed with chemical spectroscopic techniques. Hyperspectral imaging may be
able to detect the electromagnetic signatures of pollutants in vegetation at deleted
Superfund sites, which could be indicative of residual or previously undetected
contamination.
Scope and Methodology
The OIG entered into an interagency agreement with the U.S. Geological Survey
(USGS), Eastern Geographic Science Center, to develop and test hyperspectral
remote sensing technologies for the detection of fugitive and residual
contamination at deleted Superfund waste sites. Subsequently, USGS entered into
an interagency agreement with the U.S. Air Force Civil Air Patrol to use its
Airborne Real-time Cueing Hyperspectral Enhanced Reconnaissance (ARCHER)
system to collect hyperspectral imagery at the following five deleted NPL sites in
Maryland and Virginia:
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1. Middletown Road Dump, Annapolis, Maryland
2. Matthews Electroplating, Roanoke County, Virginia
3. Dixie Caverns Landfill, Roanoke County, Virginia
4. Rhinehart Tire Fire Dump, Frederick County, Virginia
5. Mid-Atlantic Wood Preservers, Harmans, Maryland
A primary factor in selecting these sites was the availability of the U.S. Air Force
Civil Air Patrol to use its ARCHER system to collect remote sensing data in the
region. We also considered geographic information, such as where the
predominance of sites existed and proximity of sites to one another; the media and
type of contaminant; and the size, original condition, and cleanup costs of the site.
The ARCHER system provides:
• Spectral signature matching—by comparing reflected
electromagnetic radiation against a library of spectral signatures to
identify specifically targeted objects.
• Anomaly detection—by comparing reflected electromagnetic
radiation against a continuously calculated background spectrum.
Spectral anomalies are flagged as potential targets for further
evaluation.
• Change detection—by conducting a pixel-by-pixel comparison of
ground conditions between current and past images.
After collecting and analyzing the ARCHER data, USGS and OIG representatives
visited all five sites to collect soil and sediment samples. USGS analyzed the
samples for hydrocarbons and organic signatures using an Analytical Spectral
Devices full range spectrometer, and analyzed the samples for metals using x-ray
fluorescence (XRF) technology.
This report presents information obtained during the interim phase of our work
and does not present OIG conclusions regarding the effectiveness of the prior
remediations or the potential environmental impact of current conditions at the
five sites. Additional work is planned to assess the usefulness of remote sensing
technology as an OIG oversight tool. However, the work performed provides a
reasonable basis to inform EPA as to the conditions observed at the sites
reviewed. The observations and findings in this report rely on technical analyses
of soil samples and hyperspectral imaging data conducted by USGS under
interagency agreement with the OIG. The results of USGS's analyses were
published in two reports;
1. Slonecker, E.T. and Fisher, G.B, 2011. Evaluation of Traditional and
Emerging Remote Sensing Technologies for the Detection of Fugitive
Contamination at Selected Superfund Hazardous Waste Sites.
USGS Open File Report 2011-1050
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2. Slonecker, E.T. and Fisher, G.B, 2011. Graphic Products Used in the
Evaluation of Traditional and Emerging Remote Sensing Technologies for
the Detection of Fugitive Contamination at Selected Superfund
Hazardous Waste Sites. USGS Open File Report 2011-1068.
We also relied on unpublished data provided to us by USGS. This data was
primarily background in nature. All test results reported herein were based on
peer-reviewed published USGS data obtained under interagency agreement with
the OIG.
We conducted our review in accordance with generally accepted government
auditing standards. Those standards require that we plan and perform the
evaluation to obtain sufficient, appropriate evidence to provide a reasonable basis
for our findings and conclusions based on our evaluation objectives. We believe
that the evidence obtained provides a reasonable basis for the information
presented in this report.
Results of Review
We collected hyperspectral imaging data for five sites in Virginia and Maryland.
These sites had been remediated and deleted from the NPL. We visited the sites to
collect soil samples and to follow up on anomalies disclosed by the hyperspectral
imaging data. Conditions noted at two sites may warrant attention from EPA
Region 3:
• The Middletown Road Dump site, formerly a dump for construction
waste, had been expanded since the last Five-Year Review conducted
by EPA. Hyperspectral imaging data identified an anomaly that proved
to be leachate coming from the landfill. Our on-site testing indicated
hydrocarbons in surface waters. In addition, soil samples collected at
the site contained arsenic, chromium, mercury, and antimony at levels
exceeding EPA's established residential risk-based concentrations (R-
RBCs).
• At the Matthews Electroplating site, formerly a chrome-plating
operation, hyperspectral imaging data identified anomalies that proved
to be scrap auto bumpers, empty metal containers, and other materials.
We also observed that the current landowner was building a residence
on the property. Results of our soil sampling showed the presence of
arsenic, nickel, and antimony at levels that exceeded EPA's R-RBC.1
At two other sites, Dixie Caverns Landfill and Rhinehart Tire Fire Dump, soil
sampling showed the presence of some heavy metals that exceeded the R-RBCs
for soil samples. However, these sites were generally secured from public access.
1 Region 3 uses risk-based concentrations as screening levels to determine whether a site may warrant further
investigation or cleanup. The levels do not represent cleanup standards.
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The other site we visited, Mid-Atlantic Wood Preservers, was located in a
commercial/industrial setting and was found to be in reuse. The site had been
paved since the Superfund remedy was accomplished. Analysis of soil samples
around the edge of the paved area did not disclose concentrations of metals that
exceeded the industrial risk based concentration (I-RBC) for industrial soil
samples. Below are the details of conditions found at each of the five sites we
reviewed.
Middletown Road Dump Site, Annapolis, Maryland
The Middletown Road Dump is located in a residential area of Anne Arundel
County. It is surrounded by residential homes on three sides and has a landscaping
business located immediately adjacent to the southeast border of the site
boundary.
The Middletown Road Dump was shut down by the State of Maryland in 1981
because it was found to be in violation of state water pollution and hazardous
waste laws. The site was placed on EPA's NPL in September 1983 after it was
found to contain ground and surface water contamination. Following removal
actions that were completed by the state and EPA Region 3 in December 1983
and subsequent additional soil testing by the state in 1985, a record of decision
was issued stating no further remedial action was needed at the site. The site was
removed from the NPL in April 1988.
An initial review of the historical aerial photographs, maps, and reports of the site,
and a comparison with our results from January 2010, indicated that the site area
has been expanded along the northern border since the last Five-Year Review.
Anomalies detected in the hyperspectral analysis proved to be areas of a leachate
discharge coming from the landfill that impacted an unnamed surface stream
north of the site. Also, drums and other debris were located in this area, although
soil readings for metals were not elevated in this area.
A site visit was conducted at the Middletown Road Dump on April 13, 2010.
Upon visiting the site, we observed an area of jagged terrain consisting of debris
that had been covered over with soil, and one empty barrel located in a ravine
near a stream running through the property.
We collected 32 soil samples and analyzed them for metals and other elements
such as arsenic and antimony. We compared the results to EPA Region 3's
residential screening levels, since residences were located on three of the site's
boundaries. Table 1 shows the samples that exceeded the R-RBCs.
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Table 1: Middletown Road Dump, soil samples exceeding R-RBCs
R-RBC
MRD-1
MRD-2
MRD-3
MRD-8
MRD-9
MRD-1 6
MRD-21
MRD-30
MRD-32
Arsenic
22ppm
-
-
93.65
-
-
-
-
-
Chromium
230ppm
-
-
433.24
-
-
-
-
-
-
Mercury
5.6ppm
-
-
-
-
-
-
7.24
-
9.67
Antimony
31ppm
37.65
32.95
-
35.98
40.34
48.45
-
35.37
-
Source: Slonecker, E.T. and Fisher, G.B, 2011. Graphic Products Used in the Evaluation
of Traditional and Emerging Remote Sensing Technologies for the Detection of Fugitive
Contamination at Selected Superfund Hazardous Waste Sites. USGS Open File Report
2011-1068, 12 p.
Note: ppm = parts per million.
Appendix A shows the location of samples exceeding the R-RBCs. In addition,
laboratory spectral analysis of very dark soils and dark liquids on the ground
along the northeast corner of the site indicated the presence of organic
hydrocarbons.
Matthews Electroplating Site, Roanoke County, Virginia
The Matthews Electroplating site is approximately 3 and one-half miles southwest
of the city of Salem. The property was the site of an automobile bumper repair
and plating facility from 1972 to 1976. According to EPA's Five-Year Review
report conducted in June 2004, there were approximately 150 residences within
4,000 feet of the site. In 1995, the site was rezoned from industrial to residential.
A residential home is currently under construction on the site, east of the location
of the former electroplating shop.
In 1975, the Commonwealth of Virginia, State Water Control Board, identified
Matthews Electroplating as a potential source of drinking water contamination
and began monitoring approximately 30 wells within the area for total chromium,
hexavalent chromium, nickel, and cyanide. Three residential wells and the
original on-site well had total chromium concentrations exceeding Virginia's
drinking water quality standard (at that time) of 50 micrograms per liter. The
Matthews Electroplating site was added to EPA's NPL in September 1983 and
was deleted in January 1989.
Hyperspectral imagery of the Matthews Electroplating site was collected on
November 24, 2009. An initial review of the historical aerial photographs, maps,
and reports of the site, and a comparison with the recently acquired ARCHER
imagery, indicated that all of the previous buildings on the site have been
11-P-0433
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removed and that a small residential structure is being constructed near the center
of the site. Several anomalies were detected: one in the northwest corner of the
property and several small anomalies along the southeast area of the property.
A site visit to Matthews Electroplating was conducted on April 14, 2010. As
identified by the hyperspectral imagery, a residence is under construction at the
site with several small outbuildings. Old automobile bumpers were still located on
the property, as well as tanks and other metal debris left from the electroplating
operation. These were identified as the hyperspectral anomalies along the
southeast section of the property that correlated with the outbuildings and the
waste metal tanks.
We collected 44 soil samples at the Matthews Electroplating site and analyzed
them for metals, and other elements such as arsenic and antimony. Table 2 shows
the samples that exceeded the R-RBCs.
Table 2: Matthews Electroplating, soil samples exceeding R-RBCs
R-RBC
ME-5
ME-9
ME-16
ME-19
ME-24
ME-30
ME-32
ME-36
ME-40
Arsenic
22 ppm
25.58
-
-
-
-
-
-
26.52
-
Nickel
1600 ppm
-
3104
-
1828.5
-
-
-
-
1928.4
Antimony
31 ppm
-
-
42.9
-
41.1
32.2
38.6
-
-
Source: Slonecker, E.T. and Fisher, G.B, 2011. Graphic Products Used in the
Evaluation of Traditional and Emerging Remote Sensing Technologies for the
Detection of Fugitive Contamination at Selected Superfund Hazardous Waste
Sites. USGS Open File Report 2011-1068.
Note: ppm = parts per million.
Appendix B shows the location of samples exceeding the R-RBCs. Laboratory
hyperspectral analysis of the soils from Matthews Electroplating showed no
evidence of hydrocarbons.
Dixie Caverns Landfill Site, Roanoke County, Virginia
The Dixie Caverns Landfill site is located near the city of Salem. The site
operated as a municipal solid waste disposal area for Roanoke County from June
1965 through July 1976. The site was added to EPA's NPL in October 1989 and
was deleted in September 2001.
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Hyperspectral imagery of the Dixie Caverns Landfill was collected on
September 24, 2009. Several anomalies were detected in the area but were
explained during the field visit. The most unique of these were the last few
concrete blocks that were formed as part of the remedial process. Remote sensing
analysis for potential hydrocarbons in the soil did not identify any hydrocarbons
in the samples.
The site visit was conducted on April 16, 2010. Thirty-one soil samples were
collected and analyzed in the laboratory with XRF analysis. Table 3 shows the
samples that exceeded the R-RBCs.
Table 3: Dixie Caverns Landfill, soil samples exceeding R-RBCs
R-RBC
DCL-1
DCL-2
DCL-3
DCL-4
DCL-5
DCL-6
DCL-8
DCL-9
DCL-1 0
DCL-21
DCL-23
DCL-24
DCL-25
Lead
400
ppm
-
-
-
-
-
-
-
-
-
510.6
-
-
-
Arsenic
22 ppm
-
-
-
42.1
27.4
22.9
26.6
-
36.8
26.0
25.7
26.5
-
Mercury
5.6 ppm
-
-
-
-
-
-
-
8.71
-
-
-
-
-
Cobalt
23 ppm
-
202.5
154.0
-
-
-
149.8
153.1
-
-
-
-
-
Manganese
1800 ppm
2456.5
Chromium
230 ppm
-
-
-
-
-
-
-
-
-
-
-
249.4
-
Antimony
31 ppm
-
-
-
-
-
-
-
-
-
-
-
-
31.8
Source: Slonecker, E.T. and Fisher, G.B, 2011. Graphic Products Used in the Evaluation of
Traditional and Emerging Remote Sensing Technologies for the Detection of Fugitive
Contamination at Selected Superfund Hazardous Waste Sites. USGS Open File Report 2011-1068.
Note: ppm = parts per million.
Appendix C shows the location of samples exceeding the R-RBCs. Although soil
sampling showed the presence of some heavy metals that exceeded the R-RBCs,
this site was secured from public access.
Rhinehart Tire Fire Dump Site, Frederick County, Virginia
The Rhinehart Tire Fire Dump site is located in a rural setting near Winchester.
Site security is provided by the enclosed nature of the land parcel, and
surrounding access is limited by private property. The site was used as a tire
disposal area from 1972 to 1983. The site was added to EPA's NPL in June 1986
and was deleted in September 2005.
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Hyperspectral imagery of the Rhinehart Tire Fire Dump site was collected on
October 19, 2009. The only significant anomaly detected proved to be concrete
structures related to the abandoned treatment facility and incinerator.
A site visit was conducted on April 20, 2010. Old tires were discovered in the
wooded area to the immediate north of the site. We collected and analyzed 52 soil
samples at the site. Table 4 shows the samples that exceeded the R-RBCs.
Table 4: Rhinehart Tire Fire, soil samples exceeding R-RBCs
R-RBC
RTF-7
RTF-8
RTF-10
RTF-11
RTF-12
RTF-13
RFT-24
RTF-25
RTF-27
RTF-32
RTF-35
RTF-36
RTF-38
RTF-41
RTF-42
RTF-45
RTF-51
Arsenic
22 ppm
-
-
26.4
26.4
26.7
27.3
-
46.2
-
-
-
-
-
-
-
-
22.5
Mercury
5.6 ppm
-
-
-
-
-
-
-
-
-
-
-
-
9.5
9.2
-
-
-
Cobalt
23 ppm
118.7
123.4
-
-
679.7
290.5
-
-
-
-
-
-
-
-
-
-
-
Manganese
1800 ppm
-
-
-
-
-
-
-
1815.0
-
-
2330.4
2547.4
-
-
-
-
2349.2
Antimony
31 ppm
-
-
58.0
34.6
32.0
-
41.8
45.0
35.1
31.1
-
-
31.2
39.0
37.5
32.7
54.8
Source: Slonecker, E.T. and Fisher, G.B, 2011. Graphic Products Used in the Evaluation of
Traditional and Emerging Remote Sensing Technologies for the Detection of Fugitive Contamination
at Selected Superfund Hazardous Waste Sites. USGS Open File Report 2011-1068.
Note: ppm = parts per million.
Appendix D shows the location of samples exceeding the R-RBCs. Although soil
sampling showed the presence of some heavy metals that exceeded the R-RBCs,
this site was generally secured from public access due to the enclosed nature of
the land parcel and surrounding access limited by private property.
Mid-Atlantic Wood Preservers Site, Harmans, Maryland
For the Mid-Atlantic Wood Preservers site, surrounding land use is mixed
industrial and residential. The site is paved over with asphalt. Adjacent properties
contain asphalt parking lots and light industrial buildings. A private residence is
located approximately 500 feet south of the site. The Mid-Atlantic Wood
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Preservers site was used from 1974 to 1993 as a chromated copper arsenate
waterborne wood treatment facility. The site was listed on EPA's NPL in June
1986 and was deleted in July 2000.
Hyperspectral imagery of the Mid-Atlantic Wood Preservers site was collected on
January 18, 2010. Since the Superfund remedy was implemented, the site has
been almost completely paved over. No remote sensing analysis of vegetation
stress, anomalies, or chemical contamination identification could be effectively
performed. Imagery does show the site to be actively engaged in transportation
operations, with numerous tractor trailers and large vehicles parked on the
property.
A site visit was conducted on August 5, 2010. Fifteen samples were collected
around the edges of the pavement to determine whether any residual
contamination was present. None of the sample measurements exceeded the
I-RBCs at the Mid-Atlantic Wood Preservers site. Appendix E shows the
locations of soil samples collected at this site.
Conclusions
Site conditions and soil sampling results at two sites may warrant EPA's
attention. Soil samples at these two sites exceeded risk-based screening levels for
certain metals. One of the sites was still being used as a landfill, and the current
owner of the other site was constructing a residence at the site. Conditions at the
other three sites did not appear to present significant concerns, but the results of
our analyses and observations are presented in this report for EPA's information.
Recommendations
We recommend that the Director, Hazardous Site Cleanup Division, EPA
Region 3, instruct the Associate Director, Office of Superfund Site Remediation,
EPA Region 3, to:
1. Add the information in this report to the appropriate site-specific case
files for each of these sites.
2. Assess whether any additional action is warranted for the Middletown
Road Dump and Matthews Electroplating sites.
Agency Response and OIG Comment
The region agreed with our recommendations. For recommendation 1, the region
stated that it has reviewed the information and added the OIG's early warning
report to the two site-specific files on June 20, 2011. For recommendation 2, the
region requested more detailed site information from us to help the region assess
whether additional action is warranted for the Middletown Road Dump and
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Matthews Electroplating sites. We provided Region 3 with additional information
regarding these two deleted sites on July 7, 2011. Region 3 stated that it would
complete recommendation 2 by October 2011. The region's planned actions meet
the intent of our recommendations. As such, we are closing recommendations 1
and 2 upon report issuance in our tracking system. The Agency's full response is
in appendix F.
11-P-0433 10
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Status of Recommendations and
Potential Monetary Benefits
POTENTIAL MONETARY
RECOMMENDATIONS BENEFITS (in SOOOs)
Claimed Agreed-To
Amount Amount
Rec.
No.
Page
No.
Subject
Status1
Action Official
Planned
Completion
Date
Instruct the Associate Director, Office of C Director, Hazardous Site 06/20/11
Superfund Site Remediation, EPA Region 3, Cleanup Division,
to add the information in this report to the EPA Region 3
appropriate site-specific case files for each of
these sites.
Instruct the Associate Director, Office of 0 Director, Hazardous Site October
Superfund Site Remediation, EPA Region 3, to Cleanup Division, 2011
assess whether any additional action is EPA Region 3
warranted for the Middletown Road Dump and
Matthews Electroplating sites.
0 = recommendation is open with agreed-to corrective actions pending
C = recommendation is closed with all agreed-to actions completed
U = recommendation is undecided with resolution efforts in progress
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Appendix A
Middletown Road Dump,
Location and Results of Samples
Middletown Road Dump
Soil Sampling Results
Exceeds RBC Level for As
Exceeds RBC Level for Cr
Exceeds RBC Level for Hg
Exceeds RBC Level for Sb
Hydrocarbons Detected
Location for Soil Samples
Landfill Expansion
Source: Imagery produced by USGS using the Civil Air Patrol's ARCHER technology.
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Appendix B
Matthews Electroplating,
Location and Results of Soil Samples
Matthews Electroplating I
Soil Sampling Results
A, Exceeds R-RBC Level for As
Exceeds R-RBC Level for Ni
Exceeds R-RBC Level for Sb
Location for Soil Samples
Source: Imagery produced by USGS using the Civil Air Patrol's ARCHER technology.
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Appendix C
Dixie Caverns Landfill,
Location and Results of Soil Samples
Dixie Caverns Landfill
Soil Sampling Results
Exceeds R-RBC Level for As
Exceeds R-RBC Level for Co
Exceeds R-RBC Level for Cr
Exceeds RBC Level for Hg
(•) Exceeds R-RBC Level for Mn
Exceeds R-RBC Level for Pb
Exceeds R-RBC Level for Sb
Location for Soil Samples
Source: Imagery produced by USGS using the Civil Air Patrol's ARCHER technology.
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Appendix D
Rhinehart Tire Fire Dump,
Location and Results of Soil Samples
Rhinehart Tire Fire
Soil Sampling Results
A Exceeds R-RBC Level for As
Exceeds R-RBC Level for Co
Exceeds R-RBC Level for Mn
6 Exceeds R-RBC Level for Sb 164
Source: Imagery produced by USGS using the Civil Air Patrol's ARCHER technology.
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Appendix E
Mid-Atlantic Wood Preservers,
Location and Results of Soil Samples
Mid-Atlantic Wood Preservers
Soil Sampling Results
® Location for Soil Samples
Source: Imagery produced by USGS using the Civil Air Patrol's ARCHER technology.
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Appendix F
Region 3 Response to Draft Report
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION III
1650 Arch Street
Philadelphia, Pennsylvania 19103-2029
June 21, 2011
MEMORANDUM
TO: Wade T. Najjum
Assistant Inspector General for Program Evaluation
FROM: Ronald J. Borsellino
Director, Hazardous Site Cleanup Division, EPA Region 3
SUBJECT: Response to Evaluation Report: Draft Early Warning Report: Observed
Conditions at Five Deleted Superfund Sites
Project No. 2008-0 J23, May 23, 2011
Attached is the Region Ill's response to the Office of Inspector General ("OIG") Draft Early
Warning Report, Observed Conditions at Five Deleted Superfund Sites, Project No. 2008-
0123,dated May 23, 2011. Outlined below are the Region's responses to the recommendations
and a corrective action plan for agreed upon actions, including estimated milestone timeframes.
OIG Recommendation #1
Add the information in the Early Warning Report to the appropriate site-specific case files for
the Middletown Road Dump and the Matthews Electroplating Sites.
Corrective Action
Region 3 has reviewed the information and added the Early Warning report to the site-specific
files for the two Sites on June 20, 2011. However, the Region requests the full data reports
including the exact location, depth, etc. of the soil samples collected.
OIG Recommendation #2
Assess whether any additional action is warranted for the Middletown Road Dump and
Matthews Electroplating Sites.
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Corrective Action
Middletown Road Dump. The Remedial Project Manager and Risk Assessor assigned to the Site
reviewed the OIG Report. Upon review of the data reported in Table 1 and the map attached in
Appendix A, there doesn't appear to be any pattern or specific area where the detections are
noted. One sample indicated the detections of arsenic and chromium. Two of the sample
locations indicated the detections of mercury and the remaining six sample locations detected
antimony. The map includes no information on depth or concentration.
However, based on the general information provided in the Early Warning Report, the Region
believes further evaluation of the data is warranted and additional sampling may be conducted.
However, the full data reports along with field notes are requested so that the Region can make
the final determination as to whether additional follow-up sampling is necessary.
Matthews Electroplating: The Remedial Project Manager assigned to the Site reviewed the OIG
Report. Upon review of Table 2 and the map attached in Appendix B, the closest 'hits' to what
appears to be the residential building are two locations approximately 40 feet from the structure
where nickel exceeded its R-RBC. The closest hits for arsenic and antimony were approximately
80 and 100 feet away, respectively. The map includes no information on concentration or depth.
However, based upon the OIG findings, the Region believes further evaluation of the data with
the regional toxicologist is warranted. Please provide the Region with the following information:
• All data from the soil sampling effort, including depths of soil where samples were
taken and results of any samples of the contents (if any) of drums reportedly found.
• All field notes/data on the automotive bumpers, drums, other artifacts and debris
found during the site visit.
Upon receipt of the above information the Region will then determine if further sampling of
Matthews Electroplating is warranted.
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Appendix G
Distribution
Office of the Administrator
Assistant Administrator for Solid Waste and Emergency Response
Regional Administrator, Region 3
Deputy Regional Administrator, Region 3
Agency Followup Official (the CFO)
Agency Followup Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for External Affairs and Environmental Education
Director, Hazardous Site Cleanup Division, Region 3
Associate Director, Office of Superfund Site Remediation, Region 3
Audit Followup Coordinator, Region 3
Audit Followup Coordinator, Office of Solid Waste and Emergency Response
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