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| U.S. ENVIRONMENTAL PROTECTION AGENCY
PRO^t& OFFICE OF INSPECTOR GENERAL
EPA Has implemented
Corrective Actions to improve
Conditions at Asheville,
North Carolina Superfund Site
Report No. 12-P-0362	March 21, 2012
This Water May Be Unsafe.
AVOID CONTACT.
DO NOT DRINK THE WATER.
For details contact the On-Scene Coordinator
for the Mills Gap Contamination Site at (404) 562-8705

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Report Contributors:	Carolyn Copper
Kathryn Hess
Barry Parker
Jill Trynosky
Meghan Wilson
Abbreviations
AOC
Administrative Order on Consent
CIP
Community Involvement Plan
EPA
U.S. Environmental Protection Agency
MOU
Memorandum of Understanding
NPL
National Priorities List
OIG
Office of Inspector General
TCE
Trichloroethylene
Cover photo: Warning sign observed during OIG August 2011 site visit. (EPA OIG photo)
Hotline
To report fraud, waste, or abuse, contact us through one of the following methods:
e-mail:	OIG Hotiirie@epa.aov	write: EPA Inspector General Hotline
phone:	1-888-546-8740	1200 Pennsylvania Avenue NW
fax:	202-566-2599	Mailcode 2431T
online:	http://www.epa.aov/oig/hotline.htm	Washington, DC 20460

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*. U.S. Environmental Protection Agency	12-P-0362
-	\ Office of Inspector General	March 21,2012
22 /
w* yyt a Q|ance
Why We Did This Review
The purpose of this evaluation
was to determine whether
U.S. Environmental Protection
Agency (EPA) Region 4
implemented agreed to actions
in response to our May 2010
report concerning
improvements needed at the
CTS Superfund site located in
Asheville, North Carolina.
Background
In response to a congressional
request, the Office of
Inspector General (OIG)
issued in May 2010 a final
report to EPA Region 4 with
10 recommendations to
improve aspects of
environmental sampling and
community involvement at the
site. Region 4 agreed to take
action on all the final report
recommendations and certified
in November 2010 that the
recommendations were
complete.
EPA Has Implemented Corrective Actions to
Improve Conditions at Asheville, North Carolina
Superfund Site
What We Found
Region 4 took actions to implement all recommendations made in EPA OIG
Report No. 10-P-0130, EPA Activities Provide Limited Assurance of the Extent of
Contamination and Risk at a North Carolina Hazardous Waste Site,
May 17, 2010. The region completed 8 of the 10 recommendations. Further
actions are needed to complete 2 OIG recommendations. Specifically:
	The region modified letters to residents communicating well water
sampling results by including a supplemental fact sheet in the letters.
However, the sheet does not conform to Region 4 standard operating
procedures created in October 2010.
	The region revised the site's Community Involvement Plan in April 2010.
However, the plan did not include a specific communication strategy.
Additionally, the plan does not reflect the site's current National Priorities
List status and recent site activities.
Three additional issues came to our attention during this review:
	The region did not have controls in place to ensure the site's public
informational repository is being kept up to date and maintained.
	The region did not complete a report on a removal action pilot study, nor
provide a fact sheet to the community on the results as planned.
	The region did not timely bill responsible parties approximately $175,000
in federal government costs incurred at the site. The billing lapse was an
oversight, which has since been corrected.
For further information,
contact our Office of
Congressional and Public
Affairs at (202) 566-2391.
The full report is at:
www.epa.gov/oiq/reports/2012/
20120321-12-P-0362.pdf
What We Recommend
We recommend that the Region 4 Administrator implement the following actions:
	Revise an information sheet on the results of private well sampling.
	Revise the Community Involvement Plan.
	Create and maintain an index for the site informational repository.
	Complete the final report on the removal action pilot study and fact sheet
for the community on the results of the study.
Region 4 provided a corrective action plan with milestone dates to address all of
the report recommendations.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
March 21, 2012
MEMORANDUM
SUBJECT: EPA Has Implemented Corrective Actions to Improve Conditions at Asheville,
North Carolina Superfund Site
Report No. 12-P-0362
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.
Action Required
Because you have provided a corrective action plan with milestone dates, you are not required to
provide a written response to this final report. Should you choose to provide a response, 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 Elizabeth Grossman
at (202) 566-0838 or grossman.elizabeth@,epa. gov, or Carolyn Copper at (202) 566-0829 or
copper, carol vn@,epa. gov.
FROM:
Arthur A. Elkins, Jr.
Inspector General
TO:
Gwendolyn Keyes Fleming
Regional Administrator, EPA Region 4

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EPA Has Implemented Corrective Actions to Improve	12-P-0362
Conditions at Asheville, North Carolina Superfund Site
	Table of Contents	
Purpose		1
Background 		1
Scope and Methodology		1
Results of Review		2
Recommendations Needing Further Actions		2
Additional Issues Found During Our Review		3
Conclusions		5
Recommendations		5
Agency Response and OIG Evaluation		5
Status of Recommendations and Potential Monetary Benefits		6
Appendices
A Agency Response to Draft Report		7
B Distribution		8

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Purpose
The Office of Inspector General (OIG) initiated a review of corrective actions
implemented by U.S. Environmental Protection Agency (EPA) Region 4 in
response to our Report No. 10-P-0130, EPA Activities Provide Limited Assurance
of the Extent of Contamination and Risk at a North Carolina Hazardous Waste
Site, May 17, 2010. We sought to determine whether actions agreed to by
Region 4 in response to our May 2010 report had been implemented. Additional
issues that came to our attention related to environmental or human health risks,
or weak Superfund site management controls, were also addressed in this
follow-up review.
Background
In response to a congressional request, the OIG issued in May 2010 a final report
to EPA Region 4 with 10 recommendations to improve aspects of environmental
sampling and community involvement at the CTS of Asheville Superfund site.
Region 4 agreed to all recommendations and certified in November 2010 that
actions to meet these recommendations were complete.
The CTS of Asheville Superfund site is located in Buncombe County, North
Carolina. The site was formerly known as the Mills Gap Road Groundwater
Contamination Superfund site. The site was operated as an electronic components
manufacturing and electroplating facility from 1952 until 1985. Trichloroethylene
(TCE), a chemical now known to be carcinogenic to humans, was used in
manufacturing processes and released through drains in the facility. Groundwater
and soil sampling investigations have revealed high concentrations of TCE.
Nearby springs and private drinking water wells have been found to be
contaminated with TCE.
Some activities are ongoing at the site as directed under a 2012 administrative
order on consent (AOC) between EPA and CTS of Asheville, Inc. The site was
proposed for the Superfund National Priorities List (NPL) on March 10, 2011. In
a March 15, 2012 Federal Register final rule, EPA added the CTS of Asheville
Superfund site to the NPL.
Scope and Methodology
The scope of this evaluation was limited to a review of actions agreed to by
Region 4 in response to EPA OIG Report No. 10-P-0130. Region 4 agreed to take
action on all the final report recommendations. Additional issues that came to our
attention related to environmental or human health risks, or weak Superfund site
management controls, were also addressed in this follow-up review.
We conducted this follow-up evaluation from August 2011 through
February 2012 in accordance with generally accepted government auditing
12-P-0362
1

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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 objective. We believe that the
evidence obtained provides a reasonable basis for our findings and conclusions
based on our evaluation objective.
We reviewed Agency documents and data in OIG and Agency information
systems to assess the status of the Agency's corrective actions. We interviewed
EPA Region 4 Superfund division staff and officials involved with site activities.
We interviewed EPA Office of Superfund Remediation and Technology
Innovation staff regarding the progress of the proposal to include the site on the
NPL. We visited the site in August 2011.
Results of Review
Region 4 took actions to implement all recommendations made in the OIG's 2010
report. Region 4 completed 8 of the 10 recommendations. Region 4 will need to
complete further actions for 2 recommendations. Specifically:
	The region modified letters to residents communicating well water
sampling results by including a supplemental fact sheet in the letters.
However, the sheet does not conform to Region 4 standard operating
procedures created in October 2010.
	The region revised the site's Community Involvement Plan in April 2010.
However, the plan did not include a specific communication strategy.
Additionally, the plan does not reflect the site's current NPL status and
recent site activities.
Additional issues that came to our attention during this follow-up review include:
	The region did not have controls in place to ensure the site's public
informational repository is being kept up to date and maintained.
	The region did not complete a report on a removal action pilot study, nor
provide a fact sheet to the community on the results as planned.
	The region did not timely bill responsible parties approximately $175,000
in federal government costs incurred at the site. The billing lapse was an
oversight, which has since been corrected.
Details on the two recommendations needing further actions and additional issues
identified are discussed below.
Recommendations Needing Further Actions
Region 4 partially implemented 2 of the 10 prior report recommendations.
Additional actions are needed to complete these recommendations. Table 1
summarizes actions taken on OIG recommendations and further actions needed.
12-P-0362
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Table 1: Status of OIG recommendations needing further actions
OIG recommendation Region 4's corrective actions Further actions needed
2c.
Modify future letters that
communicate results of drinking
water sampling to inform
residents if testing cannot
determine whether a compound
was present in their well water at
a drinking water standard or a
risk-based screening level.
Region 4 took steps to lower
reporting limits for compounds
to more closely approach
health screening levels.
The region also modified its
letters by including a
supplemental information sheet
in its May 2010 letters to
residents to address this
recommendation.
The region needs to modify the
supplemental information sheet
on the results of private well
sampling to conform to the model
provided in the region's October
2010 Standard Operating
Procedure, "Communicating
Environmental Data to Property
Owners and Tenants."
The region should also implement
controls to ensure that residents
are aware of the revised
supplemental information sheet.
6.
Develop a new Community
Involvement Plan [CIP] that
addresses all ongoing site
activities and the community's
issues, needs, and concerns.
The plan should identify specific
activities, outreach products, or
programs Region 4 will use to
address the community's
concerns, and include a
communication strategy for
disseminating information to the
public.
Region 4 revised the CIP in
April 2010 in response to this
recommendation. The CIP
included many specific
communication activities.
The April 2010 CIP did not
include a specific communication
strategy, which the region agreed
to implement.
The region needs to develop a
revised CIP to include a specific
communication strategy for
disseminating information to the
public.
Additionally, the CIP should
include revisions to reflect the
site's current NPL status and
recent site activities.
During our review this site's
Community Involvement
Coordinator outlined specific
areas of the CIP that will be
revised. The region intends to
finalize the CIP by July 30, 2012.
Source: OIG analysis.
Additional Issues Found During Our Review
Region 4 Can Not Ensure the Site Informational Repository is Complete
The CIP identifies the location of the informational repository for site records
and documents. The CIP identifies the informational repository as a community
involvement activity that will be maintained. Our review found controls are
lacking to ensure the repository is maintained and includes all official
documentation and pertinent information for the site. Such controls could have
12-P-0362
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included an index, as provided for in the Superfund community involvement
guidance or periodic reviews, to ensure the repository is maintained.
Report on Removal Action Pilot Study Needs Completion
In comments included in our May 2010 report, the region committed to
providing a final report and fact sheet on the pilot system installed to destroy
contaminants emanating from springs on property adjacent to the site.
Specifically, the region stated "once the Draft Report of Removal Action Pilot
Study becomes final, a fact sheet will be distributed to the community to
inform them of the event and outcome." However, the final report and a fact
sheet have not been completed.
Region 4 Did Not Timely Bill the Government's Costs for Work at the
Site
Region 4 did not timely bill approximately $175,000 in federal government
costs for the period May 2003 through May 2009. Region 4 incurred federal
government oversight costs pursuant to a 2004 AOC that directed the
responsible parties to conduct a removal action at the site. EPA interim
guidance1 states, "where PRPs [potentially responsible parties] have entered
into agreements with EPA to pay oversight costs, EPA will strive to issue
timely (e.g., annual) oversight bills based on known or available costs at the
time of billing." However, the region's first demand for payment for costs was
in September 2009 for $665,392. CTS Corporation disputed all but $70,211 of
the bill. EPAreceived payment of $70,211 in January 2011. In November 2011,
EPA submitted a revised bill to the responsible parties for $175,472. In the
revised bill, EPA noted "there may be other costs incurred during this period
which are not yet reflected in our financial systems for this billing. Therefore,
additional costs may appear in future bills for this current billing period."
Region 4 informed us that the billing lapse was due to an oversight. A copy of
the AOC was not furnished to the finance office until sometime in 2009.
Region 4 informed us that the site is now listed in the finance office's annual
inventory. The finance office is scheduled to issue annual oversight bills, and
billing will occur until the enforcement program directs the site be removed
from the finance office's inventory. Region 4 further informed us that in order
to address all sites in general requiring oversight billing, the region signed a
memorandum of understanding (MOU) on May 31, 2010. The MOU provides
that the finance office will receive a copy of an AOC or Consent Decree once
it becomes effective. Under the MOU, the region's finance office will
schedule and issue all of the Superfund Division's oversight bills.
1 EPA Office of Solid Waste and Emergency Response Directive No. 9200.0-32P, Interim Guidance on
Implementing the Superfund Administrative Reform on PRP Oversight, May 17, 2000.
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In September 2011, Region 4 also sent "special notice letters" to the
responsible parties in an attempt to reach a settlement and resolve
responsibility for other cleanup activities at the site. These letters informed the
responsible parties that EPA is seeking to recover unreimbursed response
costs identified through August 8, 2011, of approximately $6.5 million.
Conclusions
Region 4 took actions to implement all recommendations made in the OIG's 2010
report. Most of the recommended corrective actions have been completed. Further
actions needed include revisions to the supplemental information sheet on results
of private well sampling and the CIP. Three additional areas came to our attention
during our follow-up review. Corrective actions are needed for two of these areas.
The region needs to implement controls to ensure the site informational repository
is maintained and kept up to date. A final report and fact sheet for the community
summarizing the results of a removal action pilot study also need completion. The
region has already implemented controls to prevent additional lapses in annual
billing procedures for the third area.
Recommendations
We recommend that the Regional Administrator, Region 4:
1.	Revise the supplemental information sheet for site-related private well
sampling to conform to the model provided in the region's October 2010
Standard Operating Procedure, "Communicating Environmental Data to
Property Owners and Tenants." In addition, the region should implement
controls to ensure that residents are aware of the revised sheet.
2.	Develop an updated CIP to include a specific communication strategy for
disseminating information to the public. Additionally, the CIP should
include revisions to reflect the site's current NPL status and recent site
activities.
3.	Create an index for the site informational repository and schedule periodic
reviews of the index to ensure it is maintained and up to date.
4.	Complete the final report on the removal action pilot study and fact sheet
for the community that summarizes the results of the study.
Agency Response and OIG Evaluation
The Agency provided a corrective action plan with milestone dates to address all
of the report recommendations. All recommendations are open with agreed-to
actions pending. The Agency's response is included in appendix A.
12-P-0362
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
POTENTIAL MONETARY
BENEFITS (in $000s)





Planned


Rec.
Page



Completion
Claimed
Agreed-To
No.
No.
Subject
Status1
Action Official
Date
Amount
Amount
Revise the supplemental information sheet for site-
related private well sampling to conform to the
model provided in the region's October 2010
Standard Operating Procedure, "Communicating
Environmental Data to Property Owners and
Tenants." In addition, the region should implement
controls to ensure that residents are aware of the
revised sheet.
Develop an updated CIP to include a specific
communication strategy for disseminating
information to the public. Additionally, the CIP
should include revisions to reflect the site's current
NPL status and recent site activities.
Create an index for the site informational repository
and schedule periodic reviews of the index to
ensure it is maintained and up to date.
Complete the final report on the removal action
pilot study and fact sheet for the community that
summarizes the results of the study.
Regional Administrator,
Region 4
06/15/2012
Regional Administrator,
Region 4
Regional Administrator,
Region 4
Regional Administrator,
Region 4
07/30/2012
06/30/2012
05/30/2012
1 O = 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
12-P-0362
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Appendix A
Agency Response to Draft Report
OIG CTS of Asheville - Region 4 Response
Recommendation
Region 4 Response
Date of Completion
Updating the
Supplemental
Information Sheet
Supplemental sheet being revised by TSS staff.
Will be included in the mailing of sampling
results from the March 2012 sampling event.
Nardina Turner and Glenn Adams added to
the distribution list due to their involvement
with assisting in this effort.
N/A

Supplemental Fact Sheet Revised and
provided to home owners.
June 15, 2012
Revise Community
Involvement Plan
Region 4 personnel are revising the current
CIP.
July 30, 2012
Information Repository
Inventory
Region 4 personnel will visit the Information
Repository in Asheville during the next
sampling event and begin making an
inventory.
**lt is unclear how many documents are at
the information repository. If there are a large
number of documents, it may take more than
one visit to Asheville to complete this task. R4
personnel will prepare an inventory list. It will
be sent with future documents to the
repository.
March 19, 2012

Anticipated completion of this
recommendation.
June 30, 2012
Ozonation Pilot Study
A Final Report has been drafted for the
Ozonation Pilot Study. R4 personnel are
reviewing the study and are in the process of
finalizing. The final report will be provided,
accompanied by an attachment by MACTEC,
describing the results of the pilot study.
May 30,2012
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Appendix B
Distribution
Office of the Administrator
Assistant Administrator for Solid Waste and Emergency Response
Regional Administrator, Region 4
Agency Follow-Up Official (the CFO)
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for External Affairs and Environmental Education
Audit Follow-Up Coordinator, Office of Solid Waste and Emergency Response
Audit Follow-Up Coordinator, Region 4
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