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No Significant Residual 

Contamination Found at 

Deleted Superfund Sites, 

But Security Fences Were 

Damaged at Some Sites

Report No. 15-P-0013 November 10, 2014

U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL

Cleaning Up Communities
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)

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 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/oig.

The full report is at:

www.epa.gov/oig/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 riskbased 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. 

U.S. Environmental Protection Agency

Office of Inspector General

At a Glance

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.
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.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

THE INSPECTOR GENERAL
No Significant Residual Contamination Found at 15-P-0013

Deleted Superfund Sites, But Security Fences

Were Damaged at Some Sites

Table of Contents

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 for XRF 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
15-P-0013 1

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 sensing2that 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 2

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 Plan3that 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 3

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. 11-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 McAdooKline 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 4

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 for XRF 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 5

(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 Hranica Landfill. The following images provide an 

example of the correlation between HSI-detected anomalies and debris at the 

Taylor Borough Dump. 

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 rule.

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)
15-P-0013 6

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 7

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

Site name

HSI 

anomalies

Vegetation 

stress

Elevated

soil sample 

results

O&M 

concerns* Comments

Aladdin Plating No No No No

Berkley Products 

Co. Dump

No No No No

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 8

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 riskbased 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 9

Status of Recommendations and 

Potential Monetary Benefits

RECOMMENDATIONS

POTENTIAL MONETARY 

BENEFITS (in $000s)

Rec. 

No.

Page 

No. Subject Status1 Action Official

Planned 

Completion 

Date

Claimed 

Amount

Agreed-To 

Amount

1 8 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.

C Regional Administrator,

Region 3

7/16/13

2 8 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.

C Regional Administrator,

Region 3

8/19/14

3 8 Verify whether repairs were made to the damaged 

fence at the Lackawanna site.

C Regional Administrator,

Region 3

7/25/14 2

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.

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 10

Appendix A

Soil Testing Results7for Pennsylvania Sites

Sample No. AP-6 AP-26 BC-15 BL-1 BL-3 BP-6 HR-9 HR-15

Latitude 41.49103 41.49156 40.98897 41.05103 41.05122 40.25558 40.67686 40.67761

Longitude -75.66522 -75.66281 -75.18692 -79.72506 -79.72547 -76.15286 -79.74775 -79.74789

Units 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 BL-3 = Bruin Lagoon sample #3 

AP-26 = Aladdin Plating sample #26 BP-6 = Berkley Products sample #6

BC-15 = Brodhead Creek sample #15 HR=9 = Hranica sample #9 

BL-1 = Bruin Lagoon sample #1 HR-15 = Hranica sample # 15

 

7 These soil samples were analyzed by a commercial laboratory using EPA methods 3050 and 6010.
15-P-0013 11

Sample No. LR-4 MK-1 MB-4 TB-5 TB-12 TB-22 W-1 W-2

Latitude 41.3745 40.87775 40.90361 41.40722 41.40458 41.41008 39.83308 39.83283

Longitude -75.75678 -76.00275 -75.99847 -75.71828 -75.72372 -75.71725 -75.37597 -75.36714

Units 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 < 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 TB-12 = Taylor Borough sample # 12

MK-1 = McAdoo Assoc. Kline operable unit sample # 1 TB-22 = Taylor Borough sample #22 

MB-4 = McAdoo Assoc. Blaine operable unit sample # 4 W-1 = Wade sample #1 

TB-5 = Taylor Borough sample # 5 W-2 = Wade sample #2 
15-P-0013 12

Appendix B

Soil Testing Results for Maryland

and Virginia Sites8

Sample No. DC-5 MR-2 MR-8 MR-13 MR-17

Latitude 37.26028 39.029611 39.029944 39.029667 39.029778 

Longitude -80.1921 -76.46192 -76.46169 -76.46153 -76.46114

Units 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. 11-P-0433, 

Early Warning Report: Observed Conditions at Five Deleted Superfund 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 13

Sample No. MA-1 MA-4 MA-8 MA-11 MA-14

Latitude 39.16131 39.16194 39.16203 39.16164 39.16180

Longitude -76.6981 -76.6975 -76.6982 -76.6988 -76.7002

Units 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 14

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-FYl1-0026 "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-FYl1-0026) dated July 31, 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

1 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. 11-P-0433, May 23, 2011. The Region documented this 

action in our June 21, 2011 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 15

Middletown Road Dump, Matthews Electroplating, Dixie Caverns, Rhinehart 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 11-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 by

Quarter and FY

2 Document the results 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-FYl1-0026) 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 16

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