£
<
33
O
\
Mi.
O
¦z
LLi
CD
PRO^C
-------
Report Contributors:	Rick Beusse
Dwayne Crawford
Kevin Good
Jim Hatfield
Rodney Rice
Abbreviations
ARCHER Airborne Real-time Cueing Hyperspectral Enhanced Reconnaissance
ATV	All-terrain vehicle
EPA	U.S. Environmental Protection Agency
HSI	Hyperspectral imaging
OIG	Office of Inspector General
USGS	U.S. Geological Survey
XRF	X-ray fluorescence
Cover photo: Left: Hyperspectral image of vegetation stress at the Taylor Borough Dump site,
Taylor, Pennsylvania. (USGS-created image from ARCHER hyperspectral data)
Right: Aerial photo of the Taylor Borough Dump site. (Fifth Five-Year Review
Report for the Taylor Borough Dump Superfund Site, June 2013)
Are you aware of fraud, waste or abuse in an
EPA program?
EPA Inspector General Hotline
1200 Pennsylvania Avenue, NW (2431T)
Washington, DC 20460
(888) 546-8740
(202) 566-2599 (fax)
OIG Hotline@epa.gov
More information at www.epa.gov/oiq/hotline.html.
EPA Office of Inspector General
1200 Pennsylvania Avenue, NW (2410T)
Washington, DC 20460
(202) 566-2391
www.epa.gov/oig
Subscribe to our Email Updates
Follow us on Twitter @EPAoig
Send us your Project Suggestions
-------
^tDsr-%
• B \
U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
15-P-0013
November 10, 2014
Why We Did This Review
We conducted this review to assess
whether hyperspectral imaging (HSI)
data can be used to assess stress in
vegetation as an indication of
pollutant concentrations at deleted
Superfund sites. This work was part
of an effort by the U.S.
Environmental Protection Agency
(EPA) Office of Inspector General
(OIG) to assess the feasibility of the
OIG using remote sensing
technologies to assess the
effectiveness of EPA cleanup
actions. We reported on this
separately in September 2014.
We collected and analyzed HSI data
and soil sample results, and
conducted site visits at deleted
Superfund sites in three states
located in EPA Region 3. Deletion of
sites from the National Priorities List
may occur once all response actions
are complete and all cleanup goals
have been achieved. In August
2011, we reported on our
observations regarding five sites in
Maryland and Virginia. This report
presents our observations for 11
sites in Pennsylvania and results of
an OIG review of actions the EPA
took in response to our 2011 report.
This report addresses the
following EPA goal or
cross-agency strategy:
• Working to make a visible
difference in communities.
Send all inquiries to our
public affairs office at (202) 566-2391
or visit www.epa.gov/oiq.
The full report is at:
www.epa.qov/oiq/reports/2014/
20141110-15-P-0013.pdf
No Significant Residual Contamination Found at
Deleted Superfund Sites, But Security Fences
Were Damaged at Some Sites
What We Found
HSI indicated vegetation stress at three
Pennsylvania sites, but the results of soil
testing at these sites did not always
confirm that the stress was due to
elevated metals. We did not identify any
significant residual soil contamination at
the 11 Pennsylvania sites reviewed.
However, lead exceeded the EPA risk-
based screening level for industrial land
use in one sample collected at the Taylor
Borough Dump site, Taylor, Pennsylvania. In addition, on-site observations
found significant amounts of debris, metal equipment, and other discarded
material at two sites—the Taylor Borough Dump and the Hranica Landfill,
Buffalo Township, Pennsylvania.
When we visited the sites, we noted operations and maintenance concerns
at the Taylor Borough Dump site and the Lackawanna Refuse site,
Old Forge, Pennsylvania. Operations and maintenance procedures are
designed to ensure a Superfund remedy remains protective of human health
and the environment when hazardous materials are left on-site. At the
Taylor site, the fence surrounding the remediated areas was damaged and
the site showed evidence of trespassing and vandalism. The un-remediated
portions of the site contained considerable amounts of trash and debris from
the prior landfill operations and showed indications of all-terrain vehicle
(ATV) use. This site also showed signs of continued dumping of new trash.
Since our visit to the site, the EPA completed a 5-year review of the Taylor
Borough Dump. That review noted that the damaged fences had been
repaired. At the Lackawanna site, the fence was damaged and portions of it
had been removed. The site showed evidence of ATV use and vandalism.
Region 3's actions were sufficient to address the intent of recommendations
from our 2011 report.
Recommendations and Planned Agency Corrective Actions
We recommend that Region 3 establish procedures for ensuring that
corrective actions have been completed before attesting to its completion in
the EPA's tracking system, place the results of our reviews for the 11
deleted Superfund sites in their respective case files, and verify whether
repairs were made to the damaged fence at the Lackawanna site. Region 3
has taken action to address our recommendations. All recommendations
are resolved and closed.
Generally, pollutant levels
were within acceptable
levels, but continued security
breaches at some sites could
impair the effectiveness of
the remedy to protect human
health and the environment
and could expose
trespassers to safety or
health risks.
-------
^£DSX
* £ -
£	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
O	I	WASHINGTON, D.C. 20460
PRO"^

THE INSPECTOR GENERAL
November 10, 2014
MEMORANDUM
SUBJECT: No Significant Residual Contamination Found at Deleted Superfund Sites,
But Security Fences Were Damaged at Some Sites
Report No. 15-P-0013
FROM: Arthur A. Elkins Jr.
TO:	Shawn M. Garvin, Regional Administrator
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.
EPA Region 3 offices having primary responsibility over the issues discussed in this report are the
Office of Superfund Site Remediation within the Hazardous Site Cleanup Division, and the Grants and
Audit Management Branch within the Office of Policy and Management.
Action Required
All recommendations are resolved and closed. Therefore no further response is needed on the final
report. Should you choose to provide a response to this final report, 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.
We will post this report to our website at http://www.epa.gov/oig.
-------
No Significant Residual Contamination Found at
Deleted Superfund Sites, But Security Fences
Were Damaged at Some Sites
15-P-0013
Table of C
Purpose		1
Background		1
Responsible Offices		2
Scope and Methodology		2
Prior Report and Follow-Up		3
Results of Follow-Up to Assess Completion of
Prior Report Recommendations		4
Results of OIG Confirmatory Sampling forXRF Samples
Taken in Maryland and Virginia		4
Hyperspectral Imaging and Soil Testing Results and Observations		5
Site Operations and Maintenance Observations		6
Conclusions		7
Recommendations		8
Agency Comments and OIG Evaluation		8
Status of Recommendations and Potential Monetary Benefits		9
Appendices
A Soil Testing Results for Pennsylvania Sites		10
B Soil Testing Results for Maryland and Virginia Sites		12
C Region 3 Response to Draft Report		14
D Distribution		16
-------
Purpose
This work was initiated to determine whether hyperspectral imaging (HSI) data
can be used to assess stress in vegetation as a potential indication of pollutant
concentrations at deleted Superfund sites. Efforts to address this objective by the
Office of Inspector General (OIG) of the U.S. Environmental Protection Agency
(EPA) were reported in September 2014.1
Background
On September 25, 2007, the OIG issued a report, Limited Investigation Led to
Missed Contamination at Ringwood Superfund Site, which documented problems
of insufficient characterization of contamination and cleanup at the Ringwood,
New Jersey, Superfund site. One of the key findings of the report was that
hazardous waste was missed during the initial site investigation, and could have
been detected earlier if the EPA had made greater use of available aerial
photographs. Based on the results of the 2007 Ringwood report, the OIG decided
to evaluate whether HSI could be an effective tool for the OIG in our oversight of
the effectiveness of the EPA's cleanup actions.
HSI is a type of remote sensing2 that collects and processes information from
across the electromagnetic spectrum. HSI, or imaging spectroscopy, combines the
power of digital imaging and spectroscopy. For each pixel in an image, a
hyperspectral camera acquires the light intensity (radiance) for a large number
(typically, from a few tens to several hundreds) of contiguous spectral bands. By
comparison, the human eye processes light in three spectral bands. Every pixel in
the image thus contains a continuous spectrum (in radiance) and can be used to
characterize the objects in the scene with great precision and detail.
Researchers have used HSI to detect and map a wide variety of materials. For
example, geologists have used HSI to detect soil properties including moisture,
organic content and salinity. Vegetation scientists have used HSI to identify
vegetation species, study plant canopy chemistry and detect vegetation stress.
Vegetation stress can be from natural causes such as drought, but can also be
indicative of other stressors. In most cases, soil or groundwater contaminants—
such as hydrocarbons, heavy metals and organic chemicals—will have negative
effects on the metabolism and growth of typical cover vegetation, such as trees or
grasses.
1	Hyperspectral Imaging Can Be a Useful Evaluation Tool for Office of Inspector General Reviews Focused on
Contaminated Land (Report No. 14-N-0360, September 26, 2014), http://www.epa. gov/oig/reports/2014/20140926-
14-N-0360.pdf
2	Remote sensing is the science of obtaining information about objects or areas from a distance.
15-P-0013
1
-------
Responsible Offices
EPA Region 3 offices having primary responsibility over the issues discussed in
this report are the Office of Superfund Site Remediation within the Hazardous
Site Cleanup Division, and the Grants and Audit Management Branch within the
Office of Policy and Management.
Scope and Methodology
The OIG entered into an interagency agreement with the U.S. Geological Survey
(USGS), Eastern Geographic Science Center, to test hyperspectral remote sensing
technologies for the detection of fugitive and residual contamination at deleted
Superfund sites. To obtain HSI data for this assignment, the USGS entered into an
interagency agreement with the U.S. Air Force Civil Air Patrol to collect HSI for
the deleted National Priorities List sites in Pennsylvania using the Air Patrol's
Airborne Real-time Cueing Hyperspectral Enhanced Reconnaissance (ARCHER)
system. 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.
The USGS processed and analyzed the HSI data to identify vegetation stress and
site anomalies. After analyzing the ARCHER data, USGS and OIG
representatives visited the 11 sites (see Table 1) 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. USGS sent 16 soil
samples to a commercial laboratory for confirmatory analysis of metals by the
inductively coupled plasma - atomic emission spectrometry method. Appendix 1
presents the confirmatory results for the 16 soil samples. The USGS used and
followed the Quality Assurance Project Plan3 that was developed during the first
phase of the work.
We conducted our review from March 2012 to July 2014. Site visits were
conducted from April to September in 2012 (see Table 1).
3 Research Implementation and Quality Assurance Project Plan: An Evaluation of Hyperspectral Remote
Sensing Technologies for the Detection of Fugitive Contamination at Selected Superfund Hazardous Waste Sites
(USGS Open-File Report # 2009-1048).
15-P-0013
2
-------
Table 1: Deleted National Priorities List sites in Pennsylvania reviewed by OIG4
Site name
Site ID
Location
Date of on-site visit
and collection of
soil samples
Aladdin Plating
PAD075993378
Clarks Summit
April 30, 2012
Berkley Products Co. Dump
PAD980538649
Denver
September 17, 2012
Berks Landfill
PAD000651810
Sinking Springs
September 17, 2012
Brodhead Creek
PAD980691760
Stroudsburg
August 31, 2012
Bruin Lagoon
PAD980712855
Bruin
April 19, 2012
Hranica Landfill
PAD980508618
Buffalo Township
April 18, 2012
Lackawanna Refuse
PAD980508667
Old Forge
May 2, 2012
McAdoo Associates
PAD980712616
McAdoo
September 18, 2012
Publicker Industries
PAD981939200
Philadelphia
September 19, 2012
Taylor Borough Dump
PAD980693907
Taylor
May 1 and 2, 2012
Wade (ABM)
PAD980539407
Chester City
September 19, 2012
Source: OIG and USGS.
We conducted this performance audit in accordance with generally accepted
government auditing standards. Those standards require that we plan and perform
the audit to obtain sufficient, appropriate evidence to provide a reasonable basis
for our findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
Prior to conducting work at the Pennsylvania sites, we conducted similar work at
five sites in Maryland and Virginia. We issued an early warning report,
Observed Conditions at Five Deleted Superfund Sites, Report No. 1 l-P-0433,
August 3, 2011, presenting our observations for those five sites. The agency
conducted corrective actions in response to the 2011 report. This report presents
our observations at the 11 sites in Pennsylvania and the results of our review of
Region 3's corrective actions in response to our 2011 report.
Prior Report and Follow-Up
In our 2011 early warning report, we recommended that EPA Region 3's Office
of Superfund Site Remediation add information from the report to the appropriate
site-specific case files and assess whether any additional action was warranted for
two of the deleted sites we visited. Region 3 agreed with our recommendations
and stated that it would add the information provided by the OIG to the Matthews
4 We collected HSI data for an additional four Pennsylvania sites. We did not visit these four sites because we were
unable to obtain timely site access at three sites (Hebelka Auto Salvage Yard, Lansdowne Radiation Site, and
Metropolitan Mirror & Glass) and, for the fourth site, the remote sensing equipment failed during the flyover of the
site (Voortman Farm). As a result, these four sites are not discussed further in this report. Additionally, we
conducted site visits at the two operable units of the McAdoo Associates site (the McAdoo-Blaine and McAdoo-
Kline units). These two operable units, shown as separate sites in USGS' report, are parts of the same facility and
reported as one site in this report.
15-P-0013
3
-------
Electroplating and Middletown Road case files, and also determine whether
additional work was warranted at these sites.
Results of Follow-Up to Assess Completion of Prior Report
Recommendations
We conducted a follow-up review to assess Region 3's corrective actions taken in
response to our prior report's two recommendations. EPA Manual 2750
establishes agency policies and procedures, and assigns agency responsibilities,
for audit management and follow-up within the EPA. Manual 2750 identifies
requirements for the timely, efficient and effective resolution of OIG audit
findings and recommendations. Audit Follow-Up Coordinators located in every
EPA national program and regional office are responsible for coordinating audit
management activities within their organizations, maintaining records, and
entering data on audit follow-up activities in the EPA's Management Audit
Tracking System.
Our 2011 final report was added to the appropriate case files during our follow-on
review in July 2013. Therefore, the corrective action for Recommendation 1 is
complete. However, Region 3 certified in the agency's Management Audit
Tracking System that this action was completed in June 2011. The OIG will
address this record keeping and documentation matter during the upcoming
review of EPA Manual 2750.
The Remedial Project Managers and a Region 3 Toxicologist reviewed the
information in our 2011 report, as well as additional data provided by the OIG. The
Remedial Project Managers and the Toxicologist determined that no further action
was needed at either the Middletown Road Dump or Matthews Electroplating sites.
Given that the OIG relied upon the expertise of Region 3 personnel, we consider
the corrective action for Recommendation 2 to be complete.
Results of OIG Confirmatory Sampling forXRF Samples Taken in
Maryland and Virginia
Our early warning report included the results of soil samples analyzed by XRF
technology. XRF is considered a screening method and is not an EPA-approved
analytical method for making Superfund site characterizations or determinations.
After issuing our early warning report, USGS conducted confirmatory laboratory
analyses for metals on 10 soil samples using USGS method ICP40. USGS
Method ICP40 employs inductively coupled plasma - atomic emission
spectrometry analysis. We computed the correlation coefficient for these two sets
of samples to assess the comparability of the XRF screening results to the ICP40
method. A moderate to strong positive correlation was observed between the XRF
and the confirmatory results for arsenic (0.91), strontium (0.77), and manganese
15-P-0013
4
-------
(0.76). A moderate negative correlation was observed for total chromium (-0.66).5
Also, during our Pennsylvania work, we discovered that an instrument calibration
error caused the XRF unit to produce elevated antimony readings. This likely
explains the high antimony readings indicated by the XRF unit for the Maryland
and Virginia sites.
Hyperspectral Imaging and Soil Testing Results and Observations
HSI data showed little indication of vegetation stress or anomalies at eight of the
11 sites in Pennsylvania we visited. On-site observations showed these sites to be
generally free of substantial residual debris that would be detected by the
ARCHER anomaly detection routine. Further, soil sample results indicated that
these sites contained low levels of metal concentrations that were below the
appropriate EPA risk-based screening levels.
HSI analysis detected vegetation stress and/or anomalies at the Taylor Borough
Dump, Hranica Landfill and Bruin Lagoon sites. On-site observations found
substantial amounts of debris, metal equipment and other discarded material at the
Taylor Borough Dump and FIranica Landfill. The following images provide an
example of the correlation between FISI-detected anomalies and debris at the
Taylor Borough Dump.
»*42S6-W
Photo at left is of debris at the Taylor Borough Dump. These areas of debris correlated
to the anomalies identified by the light blue-colored areas on the HSI image on the right.
(Photo and image from USGS)
HSI imaging indicated vegetation stress and anomalies at the Bruin Lagoon site.
The reasons for the hyperspectral anomalies at the site were not revealed during
on-site observations. Sampling results from these areas indicated low residual
amounts of metals, which would not be expected to cause the anomalies. A
5 The numbers in parentheses represent the correlation coefficient between the two analytical methods. The
correlation coefficient measures the strength of the linear relationship between two values. A value of+1 indicates a
perfect positive linear relationship: as one value increases the other value increases in an exact linear rule.
Conversely, a value of-1 indicates a perfect negative linear relationship: as one value increases the other values
decrease in an exact linear rale.
15-P-0013
5
-------
hyperspectral re-flight was done for the site after soil samples were collected and
analyzed, which revealed only slight anomalies that were less visible than those in
the previous HSI analysis. Staff from the Pennsylvania Department of
Environmental Protection visited this site and found the conditions to be normal.
USGS analysis was not conclusive in identifying reasons for the HSI vegetation
stress and anomalies.
We did not identify any significant residual contamination at the 11 Pennsylvania
sites where soil samples were collected. However, both the XRF and confirmatory
laboratory results indicated that one soil sample taken from the Taylor Borough
Dump site exceeded the EPA risk-based screening level for lead at industrial sites.
Site Operations and Maintenance Observations
We observed operations and maintenance
concerns at two sites—the Taylor
Borough Dump and the Lackawanna
Refuse site. The EPA's guidance states,
"Adequately addressing operation and
maintenance issues throughout the life of
a Superfund remedy is critical to the
successful implementation of the
Superfund program."6 Operations and
maintenance procedures are designed to
ensure a Superfund remedy remains
protective of human health and the
environment.
The EPA turned over the operation and
maintenance of the Taylor Borough
Dump site to the city of Scranton in 2011. The site comprises approximately
125 acres. About 20 acres were addressed during the remediation, which included
removal of drums and contaminated soil, and the placement of a ground cover
over the remediated areas. At the time of our visit in May 2012, the fences
surrounding the remediated areas were damaged and the site showed evidence of
trespassing and vandalism. The larger unfenced portions of the site contained
considerable amounts of trash and debris from prior landfill operations and
showed indications of all-terrain vehicle (ATV) use. These areas also showed
signs of continued dumping of new trash. The EPA completed a 5-year review of
the Taylor Borough Dump site in June 2013, after our visit. The review noted that
the damaged fences had been repaired.
At the Lackawanna Refuse site, the site owner is responsible for operations and
maintenance with oversight from the Pennsylvania Department of Environmental
6 Operation and Maintenance in the Superfund Program, OSWER 9200.1-37FS. EPA 540-F-01-004; May 2001.
Protective rock mound installed around a damaged
gas vent (see arrow) at the Lackawanna Refuse
site. (USGS Photo.)
15-P-0013
6
-------
Protection. The fence surrounding the site was damaged and portions of it had
been removed. The site showed evidence of ATV use and vandalism, which has
been a recurring problem as noted in the 2009 5-year review. For example, the
tops of the plastic off-gas vents appeared to have been shot off. Consequently, the
Pennsylvania Department of Environmental Protection had built mounds of rock
around the base of the vents to protect them from further damage. This remedy
appeared to be successful in protecting the remaining undamaged portions of the
vents. Table 2 summarizes the results of our work for the 11 Pennsylvania sites
we visited.
Table 2: Summary of site review for Pennsylvania deleted Superfund sites



Elevated


Site name
HSI
anomalies
Vegetation
stress
soil sample
results
O&M
concerns*
Comments
Aladdin Plating
No
No
No
No

Berkley Products
No
No
No
No

Co. Dump





Berks Landfill
No
No
No
No

Brodhead Creek
No
No
No
No

Bruin Lagoon
Yes
Yes
No
No
HSI indicated vegetation
stress and anomalies, but
unable to confirm with soil
samples or on-site
observations.
Hranica Landfill
No
Yes
No
Yes
Significant amounts of
debris
Lackawanna Refuse
No
No
No
Yes
Damaged fence, evidence of
ATV use and vandalism.
McAdoo Associates
No
No
No
No

Publicker Industries
No
No
No
No

Taylor Borough
Dump
Yes
Yes
Yes
Yes
Significant amounts of
debris at the site. Debris
corresponded to anomalies
detected by HSI. One soil
sample exceeded the lead
industrial risk-based
screening level.
Wade (ABM)
No
No
No
No

Source: OIG and USGS.
* O&M: Operations and maintenance
Conclusions
Region 3 has taken the corrective actions it agreed to take to address the
recommendations in our 2011 report on five deleted sites in Maryland and
Virginia. However, Region 3 did not have documentation supporting that all of
the actions were completed prior to their certification in the agency's
Management Audit Tracking System.
15-P-0013
7
-------
Although HSI indicated vegetation stress at three Pennsylvania sites, the results of
soil testing at these sites did not always confirm that the stress was due to elevated
metals. We found only one soil sample that exceeded an appropriate EPA risk-
based screening level. We have not made any conclusions regarding the adequacy
or effectiveness of these prior remedial actions. However, security at some sites
was breached and could potentially impair the continued effectiveness of the
remedial actions if not addressed.
Recommendations
We recommend that the Regional Administrator, Region 3:
1.	Establish procedures for ensuring that corrective actions have been
completed in accordance with EPA Manual 2750 before the Audit
Follow-Up Coordinator attests to this information in the EPA's
Management Audit Tracking System.
2.	Document the results of our reviews for the 16 sites in their respective
case files so that they can be considered for future reference and during
any subsequent 5-year reviews.
3.	Verify whether repairs were made to the damaged fence at the
Lackawanna site.
Agency Comments and OIG Evaluation
We received comments from the Director of the Region 3 Hazardous Sites
Cleanup Division. The region's full response is in Appendix C.
Region 3 agreed with Recommendations 2 and 3, and provided corrective actions
taken which meet the intent of the recommendations. Recommendations 2 and 3
are therefore considered resolved and closed.
In its response to Recommendation 1, Region 3 stated that our early warning
report was placed in the two site files—Middletown Road Dump and Matthews
Electroplating—prior to the region's certification that all actions in response to
the report were completed. Thus, Region 3 did not believe additional procedures
were needed to address its audit follow-up and certification process in the
agency's Management Audit Tracking System. Based on the region's response,
we are closing Recommendation 1 because actions were completed. However,
because the region did not maintain documentation enabling us to verify that this
corrective action occurred prior to the region's certification, the OIG will address
this matter in our upcoming review of EPA Manual 2750.
15-P-0013
8
-------
Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
Rec.
No.
No.
Subject
Status1
Action Official
Establish procedures for ensuring that corrective
actions have been completed in accordance with
EPA Manual 2750 before the Audit Follow-Up
Coordinator attests to this information in the EPA's
Management Audit Tracking System.
Document the results of our reviews for the 16 sites
in their respective case files so that they can be
considered for future reference and during any
subsequent 5-year reviews.
Verify whether repairs were made to the damaged
fence at the Lackawanna site.
Planned
Completion
Date
Regional Administrator, 7/16/13
Region 3
Regional Administrator, 8/19/14
Region 3
Regional Administrator, 7/25/142
Region 3
POTENTIAL MONETARY
BENEFITS (in $000s)
Claimed
Amount
Ag reed-To
Amount
1	0 = Recommendation is open with agreed-to corrective actions pending.
C = Recommendation is closed with all agreed-to actions completed.
U = Recommendation is unresolved with resolution efforts in progress.
2	As noted in the Region 3 response to our draft report, fence repair is a recurring issue and presents an ongoing maintenance requirement.
15-P-0013
9
-------
Appendix A
Soil Testing Results7 for Pennsylvania Sites
Sample No.
Latitude
Longitude
Units
AP-6
AP-26
BC-15
BL-1
BL-3
BP-6
HR-9
HR-15
41.49103
41.49156
40.98897
41.05103
41.05122
40.25558
40.67686
40.67761
-75.66522
-75.66281
-75.18692
-79.72506
-79.72547
-76.15286
-79.74775
-79.74789
mg/kg (ppm)
mg/kg (ppm)
mg/kg
(ppm)
mg/kg
(ppm)
mg/kg (ppm)
mg/kg (ppm)
mg/kg
(ppm)
mg/kg (ppm)
Antimony
6.59
<4.51
<4.52
<4.52
<4.30
<4.39
<4.61
<4.37
Arsenic
20.7
6.33
<5.42
<5.42
<5.16
9.52
<5.54
<5.25
Barium
70.7
95.7
216
42.2
85.5
50.2
112
58.3
Beryllium
< 1.12
< 1.08
< 1.08
< 1.08
< 1.03
< 1.05
< 1.11
< 1.05
Cadmium
2.69
3.61
6.18
3.57
3.42
3.46
5.99
4.58
Chromium
11.1
13.6
33.9
525
11.1
18.1
21.3
32.2
Cobalt
7.85
10.2
7.14
25.5
8.05
7.56
9.21
7.84
Copper
27.6
13.6
399
99.4
15.6
<8.79
27.2
26.4
Lead
30.5
19.6
379
36.3
31.1
25.4
127
92.3
Mercury
<8.83
<8.57
<8.59
<8.59
<8.17
<8.35
<8.76
<8.31
Molybdenum
8.63
<4.51
<4.52
10.7
<4.3
<4.39
<4.61
<4.37
Nickel
14.7
21.6
25.6
318
13.6
9.59
16.7
45.6
Selenium
<3.25
<3.16
<3.16
<3.16
<3.01
<3.08
<3.23
<3.06
Silver
<9.3
<9.02
15.4
<9.04
<8.6
<8.79
<9.23
<8.75
Thallium
<2.88
<2.80
<2.80
<2.80
<2.67
<2.72
<2.86
<2.71
Vanadium
5.4
4.16
6.37
37.8
6.97
20.1
2.93
5.28
Zinc
54.4
67.9
592
91.4
66.2
50.1
179
140
AP-6 =	Aladdin Plating sample #6
AP-26 =	Aladdin Plating sample #26
BC-15 =	Brodhead Creek sample #15
BL-1 =	Bruin Lagoon sample #1
BL-3 = Bruin Lagoon sample #3
BP-6 = Berkley Products sample #6
HR=9 = Hranica sample #9
HR-15 = Hranica sample # 15
7 These soil samples were analyzed by a commercial laboratory using EPA methods 3050 and 6010.
15-P-0013
10
-------
Sample No.
Latitude
Longitude
Units
LR-4
MK-1
MB-4
TB-5
TB-12
TB-22
W-1
W-2
41.3745
40.87775
40.90361
41.40722
41.40458
41.41008
39.83308
39.83283
-75.75678
-76.00275
-75.99847
-75.71828
-75.72372
-75.71725
-75.37597
-75.36714
mg/kg
(pptn)
mg/kg
(pptn)
mg/kg
(ppm)
mg/kg
(ppm)
mg/kg
(ppm)
mg/kg
(ppm)
mg/kg
(ppm)
mg/kg
(ppm)
Antimony
<4.40
<4.74
<4.33
<4.63
<4.62
<4.52
<4.54
<4.74
Arsenic
<5.28
<5.69
<5.20
<5.55
<5.54
<5.42
<5.45
<5.69
Barium
30.2
40.2
73.3
584
27.3
259
163
185
Beryllium
< 1.06
< 1.14
< 1.04
< 1.11
< 1.11
< 1.08
< 1.09
<1.14
Cadmium
1.55
< 1.61
2.62
7.91
2.30
7.60
3.84
4.1
Chromium
7.14
7.78
11.8
11.2
5.15
65.7
35.2
38.6
Cobalt
5.20
3.49
6.17
7.71
5.22
10.5
13.5
13.7
Copper
<8.80
32.3
12.0
51.7
<9.23
107
54.7
42
Lead
8.94
21.3
45.1
318
14.7
1,580
46.4
60.2
Mercury
<8.36
<9.01
<8.23
<8.79
<8.77
<8.58
<8.63
<9.00
Molybdenum
<4.40
<4.74
<4.33
<4.63
<4.62
<4.52
<4.54
<4.74
Nickel
9.94
5.97
11.6
23.6
10.5
107
22.4
20.1
Selenium
<3.08
<3.32
<3.03
<3.24
<3.23
<3.16
<3.18
<3.32
Silver
<8.80
<9.49
<8.66
<9.25
<9.23
<9.04
<9.08
<9.48
Thallium
<2.73
<2.94
<2.68
<2.87
<2.86
<2.80
<2.82
<2.94
Vanadium
1.38
9.91
8.17
<0.925
<0.923
2.22
35.2
39.9
Zinc
26.9
47.4
74.0
557
40.2
505
91.6
125
LR-4 = Lackawanna Refuse sample # 4
MK-1 = McAdoo Assoc. Kline operable unit sample # 1
MB-4 = McAdoo Assoc. Blaine operable unit sample # 4
TB-5 = Taylor Borough sample # 5
TB-12 = Taylor Borough sample # 12
TB-22 = Taylor Borough sample #22
W-1 = Wade sample #1
W-2 = Wade sample #2
15-P-0013
11
-------
Appendix B
Soil Testing Results for Maryland
and Virginia Sites8
Sample No.
Latitude
Longitude
Units
DC-5
MR-2
MR-8
MR-13
MR-17
37.26028
39.029611
39.029944
39.029667
39.029778
-80.1921
-76.46192
-76.46169
-76.46153
-76.46114
mg/kg (ppm)
mg/kg (ppm)
mg/kg
(ppm)
mg/kg
(ppm)
mg/kg
(ppm)
Arsenic (As)
20
< 10
< 10
10
10
Barium (Ba)
442
240
155
288
225
Chromium (Cr)
19
17
23
32
32
Cobalt (Co)
18
4
4
7
6
Copper (Cu)
22
16
12
14
11
Lead (Pb)
23
16
19
31
31
Manganese (Mn)
267
160
172
268
253
Molybdenum (Mo)
<2
<2
<2
<2
<2
Nickel (Ni)
19
19
20
15
12
Strontium (Sr)
82
113
62
58
37
Uranium (U)
< 100
< 100
< 100
< 100
< 100
Vanadium (V)
49
38
75
94
101
Zinc (Zn)
101
56
62
63
60
DC-5 = Dixie Caverns Landfill sample # 5
MR-2 = Middletown Road sample # 2
MR-8 = Middletown Road sample # 8
MR-13 = Middletown Road sample # 13
MR-17 = Middletown Road sample # 17
8 We previously reported the results of XRF screening analysis for these sites in OIG Report No. 1 l-P-0433,
Early Warning Report: Obser\>ed Conditions at Five Deleted Super fund Sites, issued August 3, 2011. This table
presents the results of confirmatory analysis conducted by USGS' Crustal Geophysics and Geochemistry Science
Center using the USGS method ICP40. These results were not available at the time we issued our prior report.
15-P-0013
12
-------
Sample No.
Latitude
Longitude
Units
MA-1
MA-4
MA-8
MA-11
MA-14
39.16131
39.16194
39.16203
39.16164
39.16180
-76.6981
-76.6975
-76.6982
-76.6988
-76.7002
mg/kg (ppm)
mg/kg
(ppm)
mg/kg (ppm)
mg/kg (ppm)
mg/kg (ppm)
Arsenic (As)
< 10
< 10
20
30
40
Barium (Ba)
171
96
173
109
146
Chromium (Cr)
5
29
26
13
13
Cobalt (Co)
3
2
7
4
5
Copper (Cu)
17
30
30
22
38
Lead (Pb)
22
26
22
23
41
Manganese (Mn)
137
83
245
109
164
Molybdenum (Mo)
<2
<2
<2
<2
<2
Nickel (Ni)
15
12
20
51
30
Strontium (Sr)
30
19
33
51
76
Uranium (U)
< 100
< 100
< 100
< 100
< 100
Vanadium (V)
33
33
47
22
49
Zinc (Zn)
49
74
362
56
101
MA-1 = Mid-Atlantic Wood Preservers sample # 1
MA-4 = Mid-Atlantic Wood Preservers sample # 4
MA-8 = Mid-Atlantic Wood Preservers sample # 8
MA-11 = Mid-Atlantic Wood Preservers sample # 11
MA-14 = Mid-Atlantic Wood Preservers sample # 14
15-P-0013
13
-------
Appendix C
Region 3 Response to Draft Report
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
September 4, 2014
MEMORANDUM
SUBJECT: Response to Office of Inspector General Draft Report No. OPE-FYII -0026 "No
Significant Residual Contamination Found at Deleted Superfund Sites, But Security
Fences Were Damaged at Some Sites" dated July 31, 2014
FROM: Cecil Rodrigues, Director
Hazardous Sites Cleanup Division
TO:	Carolyn Copper, Assistant Inspector General
Thank you for the opportunity to respond to the issues and recommendations in the subject audit
report. No Significant Residual Contamination Found at Deleted Superfund Sites, But Security
Fences Were Damaged at Some Sites (Project No OPE-FYI I -0026) dated July 3 1, 2014. For the
report recommendations with which the agency agrees, we have provided either high-level intended
corrective actions and estimated completion dates to the extent practicable, or reasons why we are
unable to provide high-level intended corrective actions and estimated completion dates at this time.
For the report recommendations with which the agency does not agree, we have explained our
position on the recommendations.
Disagreement
No.
Recommendation
Agency
Explanation/Response
Proposed Alternative
I
Establish procedures for ensuring
corrective actions have been completed in
accordance with EPA Manual 2750.
We do not believe
additional procedures
are needed to the
existing process.
None.
EPA Region 3 placed the early warning report in the two site files, Middletown Road Dump and
Matthews Electroplating, in response to the draft early warning report entitled. Observed Conditions
at Five Deleted Superfund Sites, Report No. I I -P-043 3, May 23, 201 I. The Region documented this
action in our June 21, 201 I memorandum from Ronald Borsellino, Director of the Hazardous Site
Cleanup Division, to Wade Najjum, Assistant Inspector General for Program Evaluation. When the
final report was issued on August 3, 2011, the "At a Glance" document indicated that the Region's
"ongoing and planned actions meet the intent of our recommendations."
When the auditors began their follow-up review in June 2013, their initial memorandum indicated
that they wanted to verify whether Region 3 had added the early warning report to five site files:
15-P-0013
14
-------
Middletown Road Dump, Matthews Electroplating, Dixie Caverns, Rh in eh art Tire, and Mid-Atlantic
Wood Preservers. Although our interpretation of the recommendation in the early warning report,
and what was accepted by the IG, was that the IG only wanted the report added to two site files, we
added the report to the five site files electronically on July 16, 2013. Our program provided a
document report number (Doc ID 2173266) and access to SDMS for the IG auditors to verify the
report was filed in the five site files. Since the early warning report was placed in the site files
(Middletown Road and Matthews Electroplating) in 2011, we do not believe that additional
procedures need to be incorporated into our existing process.
The Grants and Audit Management Branch (GAMB) agrees with the Hazardous Site Cleanup
Division that the process established for assuring that corrective actions are complete is acceptable,
and is accurately reported in the Management Audit Tracking System. Region 3 does not agree that
we prematurely attested to adding the information to the case files, as we contend that the IG draft
report 1 l-P-0433 was added to the sites files Middletown Road Dump and Matthew Electroplating in
June 2011.
Agreement
No.
Recommendation
High-level Intended Corrective Actions
Estimated
Completion bv
Quarter and FY
2
Document the result s of the
reviews in 16 site files.
Report No. OPE-FY11 -0026 was added to
the 16 files on August 19, 2014
Completed
3
Verify whether repairs were
made to the damaged fence
at the Lackawanna Site
The fence has been repaired on several
occasions and boulders were brought in to
discourage trespassers. However, this is an
ongoing issue and will require additional
attention.
Ongoing
maintenance
requirement.
The Report No Significant Residual Contamination Found at Deleted Superfund Sites, But Security
Fences Were Damaged at Some Sites (Project No OPE-FYI1-0026) dated July 31, 2014, was added
to the following 16 site files (document id number 2195330): 1) Aladdin Plating, 2) Berkley Products
Co Dump, 3) Berks Landfill, 4) Brodhead Creek, 5) Bruin Lagoon, 6) Hranica Landfill, 7)
Lackawanna Refuse, 8) McAdoo Associates, 9) Publicker Industries, 10) Taylor Borough Dump, 11)
Wade (ABM), 12) Middletown Road, 13) Matthews Electroplating, 14) Dixie Caverns, 15) Rhinehart
Tire, and 16) Mid-Atlantic Wood Preservers on August 19, 2014.
15-P-0013
15
-------
Appendix D
Distribution
Office of the Administrator
Assistant Administrator for Solid Waste and Emergency Response
Regional Administrator, Region 3
Agency Follow-Up Official (the CFO)
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Deputy Regional Administrator, Region 3
Director, Hazardous Site Cleanup Division, Region 3
Associate Director, Office of Superfund Site Remediation, Region 3
Audit Follow-Up Coordinator, Region 3
Audit Follow-Up Coordinator, Office of Solid Waste and Emergency Response
15-P-0013
16
-------