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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
13-P-0207
March 28, 2013
Why We Did This Review
The U.S. Environmental
Protection Agency (EPA) Office
of Inspector General (OIG)
received a hotline complaint
alleging that residential properties
near the former National Zinc
Company smelter, Cherryvale,
Kansas, were not addressed by
previous cleanup activities. We
sought to determine whether
EPA's actions identified and
addressed all residential
properties contaminated with
heavy metals that presented an
imminent and substantial threat
to the public health.
The National Zinc Company site
was once the location of a lead
and zinc smelter. In March 2001,
a state evaluation determined
that soils at residential properties
adjacent to the site were
contaminated with heavy metals,
including lead. EPA classifies
lead as a probable human
carcinogen and a cumulative
toxicant. Although the effects of
lead exposure are a concern for
all humans, young children are
particularly at risk.
This report addresses the
following EPA Goal or
Cross-Cutting Strategy:
• Cleaning up communities
and advancing sustainable
development.
For further information, contact
our Office of Congressional and
Public Affairs at (202) 566-2391.
The full report is at:
www.epa.qov/oiq/reports/2013/
20130328-13-P-0207.pdf
Review of Hotline Complaint Regarding Residential
Soil Contamination in Cherryvale, Kansas
What We Found
EPA Region 7 screened residential properties for soil contamination during its
2001-2002 removal activities near the former National Zinc Company smelter, but
could not provide us with complete documentation for all properties. We found over
35 residential properties with lead contamination that, according to samples taken
during the 2001-2002 removal action, exceeded the action level. However, it was
unclear which of these properties were excavated because some EPA records
were missing or incomplete. Over a 6-month period, we made over 10 separate
inquiries for the missing information. After receiving our draft report, Region 7
provided some of the missing information. Despite the new information, there are
still inconsistencies and gaps in the site records. For example, in contrast to
positions stated earlier in our review, Region 7 now says that some properties with
contamination at or above the action level were not excavated based on
discussions with property owners and the State of Kansas. Without complete
documentation, neither EPA nor the OIG can confirm EPA's assertion that all lead
contamination presenting an imminent and substantial endangerment to public
health at this site was fully identified and addressed. As a result, we cannot confirm
or dismiss the allegations raised in the complaint.
Recommendations and Planned Agency Corrective Actions
We recommend that Region 7 review all site records and documents to determine
whether there is an imminent and substantial endangerment to public health at the
National Zinc Company site. To support this determination, Region 7 should revise
or prepare an addendum to the Removal Action Summary Report that contains an
accurate and complete account of EPA activities at the site as well as fully
document and timely communicate any actions taken to the public. We further
recommend that, as needed, Region 7 work with the State of Kansas to ensure
appropriate action is taken to respond to any imminent and substantial
endangerment to public health at the site. In addition, we recommend that Region 7
document the costs to develop and implement the work necessary to address our
recommendations.
Region 7 disagreed with recommendation 1. It believes that it has addressed all
imminent and substantial endangerment at residential properties that met removal
action criteria. Because the region was unable to provide us with the information
necessary to confirm its assertion, this recommendation is unresolved. After we
provided additional clarification, Region 7 agreed with recommendation 2. It also
agreed with recommendation 3. However, the region did not include planned
completion dates along with its planned corrective actions for these
recommendations. Therefore, all three recommendations are unresolved. Region 7
will have an additional opportunity to provide information in response to this report.
The OIG and Region 7 should begin the resolution process immediately.

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