oversight

Superfund: Information on the Program's Funding and Status

Published by the Government Accountability Office on 1999-10-29.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                 United States General Accounting Office

GAO              Report to Congressional Requesters




October 1999
                 SUPERFUND
                 Information on the
                 Program’s Funding
                 and Status




GAO/RCED-00-25
      United States
GAO   General Accounting Office
      Washington, D.C. 20548

      Resources, Community, and
      Economic Development Division

      B-283841

      October 29, 1999

      The Honorable Trent Lott
      Majority Leader
      United States Senate

      The Honorable Robert Smith
      Chairman, Subcommittee on Superfund,
        Waste Control, and Risk Assessment
      Committee on Environment and
        Public Works
      United States Senate

      Nearly 20 years after the establishment of the Superfund program and total
      expenditures of over $14 billion for cleanups, about 42 percent of the
      approximately 1,400 hazardous waste sites that the Environmental
      Protection Agency (EPA) has designated as national priorities for
      environmental cleanup do not have completed cleanup remedies. The sites
      that EPA has placed on its list of severely contaminated sites, the National
      Priorities List, are located on both federal and nonfederal property. As of
      April 1999, 838 sites still required cleanup actions; 640 of these were
      nonfederal sites. The pace and cost of this cleanup effort have been the
      subjects of long-standing congressional debate.

      Cleanup actions fall into two broad categories: removal actions and
      remedial actions. Remedial actions usually take longer, cost more, and are
      designed to provide a permanent remedy. These actions progress through
      several steps that can be grouped in three phases: the remedial
      investigation and feasibility study phase, the remedial design phase, and
      the remedial action phase. Together, these phases have historically taken
      10 or more years to complete and often cost millions of dollars. Half of
      these sites also require a fourth phase—operation and maintenance—for
      long-term cleanups of groundwater or surface water. This phase can take
      over 30 years. Removal actions are usually shorter-term cleanups for sites
      that pose immediate threats to human health or the environment. EPA has
      the authority to require the parties responsible for a site’s contamination
      to pay for its cleanup. These responsible parties may include, among
      others, the site’s current and former owners and parties that transported
      waste to the site. Responsible parties incur legal costs, called “transaction
      costs,” to allocate the cleanup expenses among themselves, to settle with
      the government, and to litigate liability for cleanups. EPA may also pay for




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site cleanups using funds from the Hazardous Substance Superfund
(commonly referred to as the Superfund trust fund).

The Superfund trust fund, which has also financed among other things, the
Superfund program’s administrative expenses, has been financed primarily
by a tax on crude oil and certain chemicals, together with an
environmental tax on corporations. Although the authority for these taxes
expired in December 1995, some taxes continued to be received into the
trust fund because of private-sector arrears and corrections made by the
U.S. Treasury when adjusting allocations made to various federal trust
funds. The trust fund also continues to receive revenue from interest
accrued on the unexpended invested balance, recoveries of cleanup costs
from responsible parties, and collections of fines and penalties. Since
1995, the program has been funded primarily from the trust fund’s
remaining balances, supplemented by appropriations from general
revenues (i.e., from Treasury’s General Fund). Superfund moneys may be
appropriated, transferred, or allocated to other federal agencies to
accomplish Superfund activities. In addition, EPA relies heavily on
contracts and assistance agreements to accomplish Superfund work.
When EPA awards a contract or enters into an assistance agreement, it
obligates federal funds to cover the cost of the planned work. In some
instances, obligated but unspent Superfund moneys may be deobligated
and used for other Superfund activities because congressional
appropriations for the Superfund program remain available for use until
expended.

Because of your interest and the interest of the late Senator John Chafee,
Chairman, Senate Committee on Environment and Public Works, in the
financial status of the Superfund program and the status and cost of
cleanups at the 640 nonfederal sites already on the National Priorities List,
you asked us to provide information on (1) the status of the program’s
funding and expenditures, including information on the Superfund trust
fund to date and the moneys appropriated from it to federal agencies other
than EPA for Superfund activities; (2) the costs to responsible parties for all
site cleanups and these parties’ related transaction costs from 1980
through 1998, categorized before and after December 1995, when the
authority for Superfund taxes expired; and (3) the cleanup status of the
640 nonfederal sites, as of April 1999, and the estimated total and annual
costs to complete cleanups of these sites.




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                   •   Taxes paid into the Superfund trust fund totaled about $13.5 billion from
Results in Brief       1981 through 1998, and the unappropriated balance in the Superfund trust
                       fund we estimated to be $1.4 billion at the end of fiscal year 1999. A total
                       of $940 million in program funds was also deobligated for use on other
                       Superfund projects for fiscal years 1994 through 1999, but this total is not
                       included in the unappropriated trust fund balance. Expenditures from the
                       trust fund totaled $14.7 billion from fiscal year 1987 through fiscal year
                       1998, the most recent year for which these data are available. From 1996
                       through 1998, approximately 45 percent of all expenditures were for
                       contractor cleanup costs; 17 percent were for on site-specific cleanup
                       support costs, such as supervising cleanup contractors; and 38 percent
                       were for non-site-specific cleanup support costs, such as financial
                       management and policy development activities. During fiscal years 1995
                       through 1998, about 10 percent of the funds appropriated annually for the
                       Superfund program were appropriated from the trust fund, transferred or
                       allocated to federal agencies other than EPA. For example, the Department
                       of Justice receives funds to provide EPA with enforcement assistance.

                   •   From 1980 through 1998, responsible parties’ total costs for cleanup
                       activities at sites on the National Priorities list was an estimated
                       $15.5 billion. About 17 percent of these costs occurred after the authority
                       for Superfund taxes expired in December 1995. The total estimated
                       transaction costs from 1980 through 1998 incurred by responsible parties
                       ranged from $3.2 billion to $7.6 billion, according to several studies of
                       these costs.

                   •   Of the 640 nonfederal sites on the National Priorities List, 376 were in the
                       remedial investigation and feasibility study phase, 133 were in the
                       remedial design phase, and 131 were in the remedial action phase, as of
                       mid-April 1999. We estimate, on the basis of EPA’s projections for some
                       sites1 and actual experience at others, that cleanups will be completed at
                       85 percent of the sites by the end of calendar year 2008. The remainder
                       will not be completed until well after 2008. We estimate that, in total, it
                       will cost between $8.2 billion and $11.7 billion more than already
                       expended to clean up the 640 nonfederal sites. Our estimate is based on
                       EPA’s estimated cleanup costs and includes contractor cleanup costs,
                       site-specific support costs, non-site-specific support costs, and operation
                       and maintenance costs, including costs to maintain long-term remedies,
                       such as pumping and treating groundwater. We also estimate that if EPA is



                       1
                        See Superfund: Half the Sites Have All Cleanup Remedies in Place or Completed (GAO/RCED-99-245,
                       July 30, 1999).



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                      to finish cleaning up 85 percent of the 640 sites by the end of fiscal year
                      2008, its costs will average $875 million annually through 2008.


                      In 1980, the Congress passed the Comprehensive Environmental
Background            Response, Compensation, and Liability Act (CERCLA), creating the
                      Superfund program to clean up highly contaminated hazardous waste
                      sites. CERCLA requires EPA to develop and maintain a list of sites, known as
                      the National Priorities List (NPL), that the agency considers the most
                      hazardous to human health or the environment. Regulations for the
                      program are set forth in the National Contingency Plan, which provides
                      specific guidance concerning the selection and performance of cleanup
                      remedies.

                      Under these regulations, sites undergoing remedial action progress
                      through several stages in the cleanup process. In the remedial
                      investigation stage, a site’s contamination is assessed in terms of type,
                      extent, and associated risks to human health or the environment. A
                      feasibility study is done concurrently with the remedial investigation and
                      focuses on the development and analysis of cleanup alternatives for the
                      site. A preferred remedy is then set forth in a proposed plan that is
                      released for public comment. After the public comments are considered, a
                      record of decision (ROD) is prepared describing the site and the chosen
                      remedy. Next, the site proceeds to the remedial design phase, where
                      technical plans are prepared for the chosen remedy. Finally, the site enters
                      the remedial action phase where construction work is performed as
                      indicated in the remedial design. When the chosen remedy has been
                      constructed and inspected by EPA, the agency considers the site to be
                      “construction complete.” At this point some sites proceed to an operation
                      and maintenance stage, where additional measures are taken to maintain
                      the implemented remedy.


                      Funding for the Superfund program is derived from taxes and other
Status of the         revenues deposited in the Superfund trust fund and appropriations made
Superfund Program’s   available from general revenues. In total about $13.5 billion in taxes was
Funding and           collected from 1981 through 1998. Although the authority for these taxes
                      expired in December 1995, some taxes continue to be received into the
Expenditures          trust fund because of private-sector arrears and corrections made by the
                      U.S. Treasury when adjusting allocations made to various federal trust
                      funds. The trust fund also continues to receive revenue from interest
                      accrued on the unexpended invested balance, recoveries of cleanup costs



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                                          from responsible parties, and collections of fines and penalties. Table 1
                                          summarizes the Superfund taxes, by category and year.


Table 1: Taxes Paid Into the Superfund Trust Fund, by Category, Fiscal Years 1981-98
Dollars in millions
                                                                              Fiscal year
Tax                             1981          1982         1983       1984          1985         1986          1987            1988     1989
Crude and petroleum              $21           $40          $35         $38          $41            $2         $419            $503     $595
Certain chemicals                107           204          196         224          233            13          216             196      288
                                     a             a            a           a            a             a
Corporate environmental                                                                                         196             313      292
Annual total                    $128          $244         $230       $261          $273           $15         $831       $1,011       $1,175
Cumulative total                $128          $372         $602       $863        $1,136       $1,151        $1,982       $2,993       $4,168



Dollars in millions
                                                                              Fiscal year
Tax                             1990          1991         1992       1993          1994         1995          1996            1997     1998
Crude and petroleum             $572          $547         $550       $569          $557         $576          $160              $1       $(3)
Certain chemicals                246           262          268         256          250           291            94              7         2
Corporate environmental          461           591          380         886          653           612          382              68       79
Annual total                  $1,279     $1,401          $1,197     $1,711        $1,459       $1,479          $636             $76      $79
Cumulative total              $5,447     $6,848          $8,045     $9,757      $11,216       $12,695      $13,331       $13,407      $13,486
                                          Note: The taxes paid from the three sources may not add to the totals shown because of
                                          rounding.
                                          a
                                              Not applicable.

                                          Source: EPA’s Budget Division.



                                          The Superfund trust fund balance at the end of fiscal year 1999 is
                                          estimated to be about $1.4 billion. This balance is available for
                                          appropriation in fiscal year 2000. EPA’s audited financial statements for
                                          fiscal year 1998 show that, as of September 30, 1998, the trust fund had an
                                          unappropriated balance of $2.06 billion.2 For fiscal year 1999, the Congress
                                          made $1.5 billion available to the Superfund program ($1.2 billion from the
                                          trust fund and $0.3 billion from general revenues), leaving $0.9 billion
                                          available for future appropriations. The fund continues to receive revenue,
                                          primarily from interest on the unexpended balance and recoveries from
                                          responsible parties that have reimbursed EPA for its cleanup costs at
                                          hazardous waste sites. There is a lag between the appropriation of funds,

                                          2
                                           EPA’s Fiscal Year 1998 Financial Statement, EPA, Office of the Inspector General.



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                                       the obligation of funds, and the actual disbursement of funds. Until funds
                                       are actually disbursed, they remain in the trust fund earning interest. The
                                       total undisbursed balance in the trust fund as of July 31, 1999, was
                                       $4.6 billion. We estimate that the trust fund will receive approximately
                                       $0.6 billion in additional revenues during fiscal year 1999. See table 2.

Table 2: Unappropriated Superfund
Trust Fund Balance Estimated for the   Unappropriated balance                                                Estimate for fiscal year 1999
End of Fiscal Year 1999                Unappropriated balance at start of fiscal
                                       year                                                                                $2,056,248,000
                                       Appropriated from general revenues                                                     325,000,000
                                       Subtotal                                                                            $2,381,248,000
                                       Appropriated to Superfund program                                                   (1,500,000,000)
                                       Total unappropriated balance                                                         $881,248,000
                                       Revenues
                                       Interest on unexpended balance                                                         233,982,377a
                                       Recoveries                                                                             307,082,270a
                                       Fines and penalties                                                                      4,096,417a
                                       Tax revenues                                                                            18,866,431a
                                       Total revenues                                                                       $564,027,495a
                                       Unappropriated balance at end of fiscal
                                       year                                                                                $1,445,275,495
                                       a
                                           Projections based on actual Treasury data current as of July 31, 1999.

                                       Source: GAO’s analysis of data from Treasury and EPA.



                                       For fiscal years 1994 through 1998, EPA deobligated $772 million in
                                       Superfund moneys. For fiscal year 1999, we projected that EPA would
                                       deobligate another $168 million, for a total of $940 million, in fiscal years
                                       1994 through 1999. Although deobligated funds do not affect the
                                       unappropriated balance of the trust fund, they do affect its unobligated
                                       balance and the amounts EPA can obligate in any particular year. EPA
                                       obligates appropriated Superfund moneys for contracts to clean up and
                                       oversee the cleanup of Superfund sites. If these contracts expire or are
                                       canceled and unexpended obligated funds remain, EPA is allowed to
                                       deobligate these funds and use them for other projects. EPA begins to
                                       identify Superfund moneys for deobligation early in each fiscal year so
                                       that it can use the moneys during the same fiscal year. We previously
                                       reported that EPA had opportunities to identify and recover additional
                                       Superfund moneys.3 Additionally, EPA’s Office of Inspector General has

                                       3
                                        See Environmental Protection: Funds Obligated for Completed Superfund Projects
                                       (GAO/RCED-98-232, July 21, 1998).



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reported weaknesses in the deobligation process and found that overall
improvements in EPA’s deobligation process would result in additional
funds being made available to the agency for environmental goals.4

For the 12-year period from fiscal year 1987 through fiscal year 1998, EPA’s
expenditures for the Superfund program totaled $14.7 billion. Appendix I
provides information on expenditures by year for this period. For fiscal
years 1996 through 1998, the program’s expenditures totaled $4.3 billion,
and data were readily available for allocating these expenditures among
three general categories—contractor cleanup work, site-specific support,
and non-site-specific support.5 For the years before fiscal year 1996,
expenditure data could not readily be allocated among these three general
categories. As figure 1 shows, 45 percent of the $4.3 billion spent from
fiscal year 1996 through fiscal year 1998 was for contractor cleanup work,
17 percent was for site-specific support costs, and 38 percent was for
non-site-specific support costs.




4
  See Audit of EPA’s Fiscal Year 1998 Financial Statements, EPA, Office of Inspector General, Report
No. 99B0003 (Sept. 28, 1999).
5
See Superfund: EPA Can Improve Its Monitoring of Superfund Expenditures (GAO/RCED-99-139,
May 11, 1999).



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Figure 1: Superfund Expenditures for
Fiscal Years 1996-98, in Three             Dollars in millions
Categories.
                                                                                     Contractor cleanup work




                                                                          38% •      Non-site specific support
                                            • 45%
                                                                          ($1,638)
                                          ($1,930)




                                                             17% •                   Site-specific support
                                                                 ($726)




                                       Source: GAO’s analysis of data from EPA.




                                       The total Superfund moneys appropriated, transferred, or allocated to
                                       other federal agencies ranged from 9 percent to 11 percent of the total
                                       Superfund appropriations for fiscal years 1995 through 1998. The Congress
                                       appropriates funding from the Superfund trust fund to federal agencies
                                       other than EPA for Superfund activities. EPA does not routinely track
                                       expenditures of Superfund moneys by these agencies; however, it does
                                       track appropriations and transfers of program funds to these other federal
                                       agencies. The other federal agencies with important Superfund
                                       responsibilities include the Department of Justice, which provides
                                       enforcement assistance; the National Institute of Environmental Health
                                       Sciences, which provides research on human health effects for individual
                                       chemicals and is a National Institute of Health within the Department of
                                       Health and Human Services; and the Agency for Toxic Substances and
                                       Disease Registry, which provides overall health assessments for individual
                                       Superfund sites and is within the Public Health Service of the U.S.
                                       Department of Health and Human Services. Table 3 displays the annual
                                       Superfund appropriations, transfers, or allocations for these agencies for
                                       fiscal years 1995 through 1998.



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Table 3: Superfund Appropriations,
Transfers, or Allocations to Federal   Dollars in millions
Agencies Other Than EPA for Fiscal                                              Fiscal Year
Years 1995-98
                                       Agency                          1995     1996             1997            1998
                                       Department of
                                       Justice
                                       (enforcement)                   $32.2    $30.0            $30.0           $29.7
                                       Other federal agencies
                                       Agency for Toxic
                                       Substances and
                                       Disease Registry                 68.8     59.0             64.0            74.0
                                       National Institute
                                       of Environmental
                                       Health Science                   58.7     50.5             53.3            58.0
                                       U.S. Coast Guard                  4.8      4.4              4.8             4.8
                                       National Oceanic
                                       and Atmospheric
                                       Administration                    2.2      2.0              2.2             2.4
                                       Federal
                                       Emergency
                                       Management
                                       Agency                            0.9      1.1              1.1             1.1
                                       Department of
                                       the Interior                      0.6      0.7              0.9             0.9
                                       Occupational
                                       Safety and Health
                                       Administration                    0.3      0.3              0.5             0.7
                                       Total, other
                                       federal agencies               $136.3   $118.0           $127.0         $141.9
                                       Total                          $168.5   $148.0           $157.0         $171.6
                                       Source: EPA’s Budget Office.




                                       According to EPA’s estimates, the costs of site cleanup for work performed
Responsible Parties’                   by responsible parties totaled approximately $15.5 billion from 1980, the
Cleanup and                            year of CERCLA’s enactment, through 1998. During this same period, EPA
Transaction Costs                      recovered about $2.4 billion from responsible parties for cleanup work it
                                       performed, as shown in table 4. EPA principally relies on data collected
                                       from settlement agreements reached with responsible parties to estimate
                                       these recoveries. Because responsible parties are not required to publicly
                                       report the cleanup and related transaction costs they incur, the actual
                                       dollar amount that responsible parties have expended for site cleanups is
                                       unknown. EPA principally relies on standard cost assumptions or
                                       information contained in RODs to estimate the value of cleanup work



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                                       performed by responsible parties. Specifically, these are estimates of the
                                       value of the cleanup work to be performed over the life of the cleanup,
                                       which, in some cases, can take over 30 years to complete. As a result, the
                                       actual costs incurred by responsible parties may occur well after the ROD
                                       or settlement date. Additionally, the ROD estimates do not take into
                                       account cost growth that may occur between the selection of remedies
                                       and actual cleanups or, alternatively, cost savings that responsible parties
                                       may realize when conducting cleanups more efficiently than EPA had
                                       projected.

Table 4: Estimated Responsible
Parties’ Site Cleanup Costs, 1980-98   Dollars in millions
                                                                                                   EPA’s costs
                                                                            Responsible         recovered from
                                                                      parties’ estimated           responsible
                                       Time period                        cleanup costs                 parties                   Total
                                       Before expiration of
                                       Superfund tax authority
                                       (1980-Dec. 1995)                             $11.1                    $1.7                 $12.8
                                       After expiration of
                                       Superfund tax authority
                                       (Jan. 1996-Sept. 1998)                          1.9                    0.7                    2.7
                                       Total                                        $13.0                    $2.4                 $15.5
                                       Source: EPA’s Office of Site Remediation Enforcement.



                                       In addition to cleanup costs, responsible parties incur transaction costs,
                                       which include the legal expenses associated with cleanups, such as the
                                       costs incurred during negotiations or litigation with EPA, other responsible
                                       parties, or insurance companies. Although a number of independent
                                       studies have attempted to estimate transaction cost amounts, their
                                       respective results differ, in part because of differing methodologies. The
                                       transaction costs estimated in these studies ranged between 17 and
                                       33 percent of responsible parties’ total expenditures. In a 1995 testimony,
                                       the Congressional Budget Office (CBO), estimated that transaction costs
                                       could range between 17 and 20 percent of responsible parties’ total
                                       expenditures.6 In 1994, the RAND Institute for Civil Justice estimated that
                                       responsible parties’ transaction costs were approximately 32 percent of




                                       6
                                        Statement of Jan Paul Acton, Assistant Director, Natural Resources and Commerce Division,
                                       Congressional Budget Office, on the Comprehensive Environmental Response, Compensation, and
                                       Liability Act of 1980, before the Subcommittee on Water Resources and Environment, Committee on
                                       Transportation and Infrastructure, U.S. House of Representatives, June 22, 1995, p. 9.



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                                       total expenditures.7 Also in 1994, we estimated that transaction costs
                                       could account for about 33 percent of responsible parties’ total
                                       expenditures at NPL sites.8 These estimates, however, could change
                                       depending on, among other things, EPA’s actions or future Superfund
                                       legislation. Specifically, the estimates were conducted before EPA initiated
                                       reforms to the Superfund program that were intended to facilitate
                                       settlements with responsible parties and reduce transaction costs.

                                       Using these estimates and the responsible parties’ cleanup costs presented
                                       in table 4, we estimate that responsible parties incurred $3 billion to
                                       $8 billion in transaction costs from 1980 through 1998, as shown in table 5.
                                       These estimates are calculated as percentages of total cleanup costs,
                                       including both cleanup costs and transaction costs. Responsible parties’
                                       costs before the authority for Superfund taxes expired in 1995 are
                                       estimated to range between $15 billion and $19 billion for the period 1980
                                       through 1995. After the authority for Superfund taxes expired, the costs
                                       range between $3 billion and $4 billion for the period 1996 through 1998.
                                       Responsible parties’ total estimated costs at NPL sites from 1980 to 1998
                                       (for both cleanup costs and transaction costs) are estimated to range
                                       between $19 billion and $23 billion.

Table 5: Estimated Transaction Costs
as a Percentage of Total Cleanup       Dollars in billions
Costs                                                                   Author of study/study’s estimated percentage
                                                                             CBO                          RAND                    GAO
                                       Time period                        17%                 20%                 32%                   33%
                                       Before expiration
                                       of Superfund tax
                                       authority
                                       (1980-Dec. 1995)                   $2.6                $3.2                $6.0                  $6.3
                                       After expiration of
                                       Superfund tax
                                       authority (Jan.                     0.6                                                           1.3
                                       1996-Sept. 1998)                                        0.7                 1.3
                                       Total                              $3.2                $3.9                $7.3                  $7.6
                                       Source: GAO’s analysis of data from EPA.




                                       7
                                        Lloyd S. Dixon, Fixing Superfund: The Effect of the Proposed Superfund Reform Act of 1994 on
                                       Transaction Costs (Santa Monica, California: RAND, 1994), p.xvi.
                                       8
                                        See Superfund: Legal Expenses for Cleanup-Related Activities of Major U.S. Corporations
                                       (GAO/RCED-95-46, Dec. 23, 1994).


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                                        As of mid-April 1999, EPA had 640 nonfederal NPL sites where the
Status of and Cost to                   construction of a cleanup remedy, such as a removal of contaminated soil,
Complete Cleanups of                    had not been completed. Of these sites, 59 percent, or 376, were in the
640 Nonfederal Sites                    remedial investigation and feasibility study phase; 21 percent, or 133, were
                                        in the design phase; and 20 percent, or 131, were in the remedial action
                                        phase. In each phase, the work may be planned, ongoing, or completed. As
                                        shown in table 6, at the 376 sites in the remedial investigation and
                                        feasibility study phase, the work is planned for 54, ongoing for 238, and
                                        completed for 84. Each site consists of one or more operable units that
                                        correspond to different areas within the site or different environmental
                                        media, such as soil and groundwater. At the 8 sites shown as completed in
                                        the remedial action phase, all operable units had been completed, but EPA
                                        had not yet finished all steps required to designate the sites as
                                        “construction complete.” We classified each site’s progress by the operable
                                        unit in the least advanced phase of the Superfund process. The 640
                                        nonfederal sites included a total 1,279 operable units.

Table 6: Status of Sites Based on the
Least Advanced Operable Units, as of                                        Status of work in phase
Mid-April 1999                          Cleanup phase                Planned             Ongoing             Completed      Total sites
                                        Remedial
                                        investigation and
                                        feasibility study                   54                 238                  84             376
                                                                               a
                                        Remedial design                                        107                  26             133
                                                                               a
                                        Remedial action                                        123                   8             131
                                        Total sites                         54                 468                 118             640
                                        a
                                        Sites completing an earlier cleanup phase will move to this phase.

                                        Source: EPA.



                                        In contrast, if a site’s progress is based on the operable unit in the most
                                        advanced stage of the Superfund process, then 33 percent, or 212 sites,
                                        were in the remedial investigation and feasibility study phase; 18 percent,
                                        or 112 sites, were in the design phase; and 49 percent, or 316 sites, were in
                                        the remedial action phase.

                                        On the basis of EPA’s schedule for completing work at 364 sites and our
                                        application of EPA’s average estimated cleanup completion times as of
                                        April 1999 for the remaining 276 sites, we estimate that 85 percent, or 545,
                                        of the 640 sites will be cleaned up from April 1999 through calendar year
                                        2008. EPA estimates that the average time to complete a site’s cleanup is 8




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                                   years.9 The agency emphasizes, however, that this is an average cleanup
                                   time, with some sites taking less time and others taking more. In addition,
                                   although the average includes any waiting time between cleanup phases,
                                   future average cleanup times could be different, depending on the
                                   complexity of the sites and EPA’s budget constraints. EPA also believes that
                                   completing construction at some of the remaining 15 percent of sites may
                                   take well beyond 2008, as indicated in figure 2.


Figure 2: GAO’s Estimate of Site
Completions, by Year
                                       Sites to Be Completed


                                                                                                                    600

                                                      545
                                                                                                                    400
                                                                                                                              Number
                                                                                        95                                      of
                                                                                                                    200        sites


                                                                                                                    0
                                        1999                        2008-2050

                                               Year


                                   Source: GAO’s analysis of data from EPA and estimates from site managers.




                                   We estimated that the total cost to complete cleanups at the 640 sites
                                   ranges from $8.2 billion to $11.7 billion, with a midpoint cost of
                                   $9.9 billion. The midpoint cost is calculated and used to present the middle
                                   value in the range and to illustrate annual costs. The total cleanup cost
                                   includes support costs and operation and maintenance costs, as indicated
                                   in table 7.

                                   9
                                    For this report, we used EPA’s estimate of the average time to complete each cleanup phase—3.1
                                   years for the remedial investigation/feasibility study, 2.8 years for the remedial design, and 2.1 years
                                   for the remedial action, for a total cleanup time of 8.0 years. We also used Superfund: Half the Sites
                                   Have Cleanup Remedies in Place and Completed (GAO/RCED-99-245, July 30, 1999). In 1997, we
                                   reported that the average cleanup time for nonfederal sites was 10.6 years. See Superfund: Times to
                                   Complete the Assessment and Cleanup of Hazardous Waste Sites (GAO/RCED-97-20, Mar. 31, 1997).
                                   EPA testified in Mar. 1999 before the Subcommittee on Finance and Hazardous Materials, Committee
                                   on Commerce, that the pace of cleanups had accelerated significantly in fiscal years 1997 and 1998.



                                   Page 13                                                                  GAO/RCED-00-25 Superfund
                                        B-283841




Table 7: Estimated Total Costs Needed
by EPA to Complete Cleanups at the      Dollars in millions
640 Sites                                                                Estimated total cleanup and support costs for 640 sites
                                        Type of cost                    High end of range        Low end of range                  Midpoint
                                        Contractor cleanup                          $3,111.0                $4,680.3                $3,895.6
                                                               a
                                        Site-specific support                         1,169.7                 1,759.8                1,464.7
                                        Subtotal                                    $4,280.7                $6,440.1                $5,360.3
                                        Non-site-specific supportb                    2,641.2                 3,973.6                3,307.4
                                        Subtotal                                    $6,992.0               $10,413.7                $8,667.7
                                        Additional operation and
                                        maintenancec                                  1,280.0                 1,280.0                1,280.0
                                        Total                                       $8,202.0               $11,693.7                $9,947.7
                                        a
                                         Estimated by multiplying contractor cleanup costs by 0.376. This multiplier is based on total
                                        Superfund support expenditures for fiscal years 1996-98.
                                        b
                                         Estimated by multiplying contractor cleanup costs by 0.849. This multiplier is based on total
                                        Superfund support expenditures for fiscal years 1996-98.
                                        c
                                         Calculated for operable units currently on the NPL that are not construction complete and are
                                        projected to be funded by EPA.

                                        Source: GAO’s analysis of EPA data.



                                        We calculated that the estimated contractor cleanup costs for the 640 sites
                                        would range from a low of $3.1 billion to a high of $4.7 billion, with a
                                        midpoint cost of $3.9 billion. When site-specific support costs are added,
                                        this estimate becomes $4.3 billion to $6.4 billion, with a midpoint cost of
                                        $5.4 billion. Site-specific support costs include site analysis studies and
                                        EPA’s costs to oversee cleanups led by responsible parties. Adding
                                        non-site-specific support costs results in estimates of $6.9 billion to
                                        $10.4 billion, with a midpoint cost of $8.7 billion. Non-site-specific support
                                        costs include EPA’s financial management and policy analysis costs.
                                        Finally, adding operation and maintenance costs brings the range for total
                                        costs from $8.2 billion to $11.7 billion, with a midpoint cost of $9.9 billion.
                                        Operation and maintenance costs include EPA’s costs to operate and
                                        maintain cleanup remedies after they have been constructed. A remedy to
                                        pump and treat groundwater, for example, can take 30 years or longer. At
                                        sites where EPA conducts the cleanup, the agency assumes responsibility
                                        for remedies designed to restore groundwater or surface water for up to
                                        the first 10 years; afterwards, the state is responsible for operating and
                                        maintaining the cleanup remedy. Appendix II provides a summary of our
                                        assumptions in preparing these cost estimates.




                                        Page 14                                                                GAO/RCED-00-25 Superfund
                     B-283841




                     We estimated that the annual costs for cleaning up these 640 sites would
                     range from about $827 million to $923 million per year through 2008—an
                     average of $875 million annually. Annual costs are presented by cost
                     category (contractor support, site-specific and non-site-specific support
                     costs, and operation and maintenance) in appendix III.

                     These annual cost estimates assume that 85 percent of the 640 sites will be
                     cleaned up by 2008. After 2008, the total cost for the remaining 15 percent
                     is $1.6 billion, but the time required to complete cleanups at these sites is
                     difficult to project. Our July 1999 report on the completion of cleanup
                     remedies indicated that EPA remedial managers projected completion
                     dates extending to 2050. Although we allocated the costs for these
                     cleanups to 2009 and 2010, the costs may extend beyond 2010.


                     We provided a copy of a draft of this report to EPA for its review and
Agency Comments      comment. EPA’s comments are presented in appendix IV. EPA disagreed
and Our Evaluation   with our characterization of the Superfund program’s costs and future
                     funding needs and with our presentation of the status of the program’s
                     accomplishments. Specifically, EPA believes that our draft report greatly
                     understates both. For example, according to EPA, our draft report neglects
                     to consider the hundreds of millions of dollars required annually to protect
                     communities from threats posed by sites not currently on the NPL, the cost
                     of sites that will be placed on the NPL in the future, and what full funding
                     for the Superfund program should be. As we state in our objectives, our
                     report does not address the issues EPA raises. It presents information on
                     the financial status of the Superfund program—in particular, the cost of
                     completing the cleanup of the 640 nonfederal sites already on the NPL. EPA
                     also stated that the draft report misrepresents the status of the Superfund
                     program’s accomplishments as indicated by EPA’s progress in cleaning up
                     sites to date. EPA believes that it has made more significant strides to
                     complete work at current NPL sites than our draft report suggested. We
                     revised our draft report to clarify the percentage of sites where the
                     cleanup was not completed. EPA further stated that our draft report
                     primarily describes the status of cleanups at Superfund sites by the least
                     advanced operable unit and that these data do not describe the full
                     progress that the agency has made at these sites. This assertion is not
                     correct. Our draft report presents the progress of site cleanups by both the
                     least advanced and the most advanced operable unit.

                     EPA also stated that we did not account for resources allocated to some of
                     its offices, such as its Office of Inspector General and Office of Research



                     Page 15                                              GAO/RCED-00-25 Superfund
B-283841




and Development, as well as resources transferred to certain other federal
agencies that carry out some of the Superfund program’s responsibilities,
including the Agency for Toxic Substances and Disease Registry and other
agencies. We disagree. This information appears in our discussion on the
status of the program’s funding and includes the amounts of funds
appropriated, transferred, and allocated to these other agencies from fiscal
year 1995 through fiscal year 1998. While our draft report does not provide
data on the funds appropriated to EPA’s Office of Inspector General, we
believe the overall impact of this exclusion is insignificant because these
funding amounts are relatively small. The funds transferred to several
other federal agencies are also included in the overhead cost estimates
that we present for the 640 nonfederal sites.

EPA also asserted that our draft report mischaracterizes the Superfund
program’s activities and expenditures by categorizing them as contractor
cleanup costs, site-specific support costs, and non-site-specific support
costs. EPA states that these categories are overly broad and have limited
use in evaluating and managing the program. Moreover, according to EPA,
using generic terms such as overhead fails to recognize the actual work
that takes place to accomplish the cleanups that are the mandate of the
Superfund program. We used these categories in a prior report on
Superfund expenditures and believe that our categories are appropriate
for defining the program’s expenditures and accurately indicating how
funds are spent for cleanups.

EPA also stated that our draft report inaccurately characterized responsible
parties’ expenditures for cleanup work. It said our estimate of these costs
represented the parties’ commitments for future cleanup work rather than
expenditures to date. We revised the report to clarify this point.


We conducted our review from June 1999 through November 1999 in
accordance with generally accepted government auditing standards. Our
scope and methodology are presented in appendix V.

As arranged with your offices, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days after the
date of this letter. At that time, we will send copies of the report to other
congressional committees; the Honorable Carol M. Browner,
Administrator, EPA; the Honorable Jacob Lew, Director, Office of
Management and Budget; and other interested parties. We will also make
copies available to others on request.



Page 16                                                GAO/RCED-00-25 Superfund
B-283841




Should you need further information, please call me (202) 512-6111. Key
contributors to this report are included in appendix VI.




David G. Wood
Associate Director, Environmental
  Protection Issues




Page 17                                            GAO/RCED-00-25 Superfund
Contents



Letter                                                                                         1


Appendix I                                                                                    20

Superfund
Expenditures for
Fiscal Years 1987-98
Appendix II                                                                                   21

Cost Assumptions
Appendix III                                                                                  24

Estimated Annual
Costs to Complete 85
Percent of the 640
NPL Sites, or 1,279
Operable Units, by
2008
Appendix IV                                                                                   25

Comments From the
Environmental
Protection Agency
Appendix V                                                                                    28

Scope and
Methodology
Appendix VI                                                                                   30

Key Contributors to
This Report
Tables                 Table 1: Taxes Paid Into the Superfund Trust Fund, by Category,         5
                        Fiscal Years 1981-98




                       Page 18                                           GAO/RCED-00-25 Superfund
          Contents




          Table 2: Unappropriated Superfund Trust Fund Balance                      6
           Estimated for the End of Fiscal Year 1999
          Table 3: Superfund Appropriations, Transfers, or Allocations to           9
           Federal Agencies Other Than EPA for Fiscal Years 1995-98
          Table 4: Estimated Responsible Parties’ Site Cleanup Costs,              10
           1980-98
          Table 5: Estimated Transaction Costs as a Percentage of Total            11
           Cleanup Costs
          Table 6: Status of Sites Based on the Least Advanced Operable            12
           Units, as of Mid-April 1999
          Table 7: Estimated Total Costs Needed by EPA to Complete                 14
           Cleanups at the 640 Sites

Figures   Figure 1: Superfund Expenditures for Fiscal Years 1996-98, in             8
            Three Categories.
          Figure 2: GAO’s Estimate of Site Completions, by Year                    13




          Abbreviations

          CERCLA     Comprehensive Environmental Response, Compensation,
                          and Liability Act
          CBO        Congressional Budget Office
          EPA        Environmental Protection Agency
          GAO        General Accounting Office
          NPL        National Priorities List
          O&M        operation and maintenance
          OU         operable unit
          RA         remedial action
          RD         remedial design
          RI/FS      remedial investigation/feasibility study
          ROD        record of decision


          Page 19                                             GAO/RCED-00-25 Superfund
Appendix I

Superfund Expenditures for Fiscal Years
1987-98


               Dollars in millions
               Fiscal year                 Total expenditures
               1987                                   $529.9
               1988                                     790.3
               1989                                     948.9
               1990                                   1,127.0
               1991                                   1,365.7
               1992                                   1,367.4
               1993                                   1,334.4
               1994                                   1,449.7
               1995                                   1,475.2
               1996                                   1,411.7
               1997                                   1,450.8
               1998                                   1,403.1
               Total                                $14,654.1




               Page 20               GAO/RCED-00-25 Superfund
Appendix II

Cost Assumptions


                  We made the following assumptions and took the following steps to
                  calculate the cost of completing cleanups at 640 nonfederal sites on the
                  National Priorities List (NPL).

              •   We calculated the cost of completing cleanups of 1,279 operable units (OU)
                  at the 640 nonfederal sites that the Environmental Protection Agency (EPA)
                  had not designated as “construction complete” as of mid-April 1999.10 We
                  did not include sites placed on the NPL after this time.

              •   Each OU was classified by EPA by cleanup phase—remedial
                  investigation/feasibility study (RI/FS), remedial design (RD), or remedial
                  action (RA)—and by status—planned, ongoing, or completed.

              •   Next, we determined what proportion of the OUs’ cleanups would be
                  funded by EPA. For OUs in the RI/FS phase (planned, ongoing and
                  completed) we assumed, on the basis of interviews with EPA officials and
                  our reviews of EPA documents, that 55 percent would be funded by EPA.

              •   Using EPA’s data for ongoing and completed cleanups of OUs in the RA
                  phase, we calculated that EPA had funded 40 percent. Therefore, we
                  assumed that EPA would fund 40 percent of future/planned RAs. EPA
                  officials understood the basis for this assumption but stated that their goal
                  still remains to have 70 percent of the sites funded by responsible parties.
                  Furthermore, the officials provided statistics indicating that, for sites
                  funded by responsible parties during fiscal years 1996 through 1998, over
                  70 percent of the remedial designs and remedial actions are being
                  performed by responsible parties.

              •   Because the same party usually performs both the remedial design and the
                  construction, we assumed EPA would also fund 40 percent of the remedial
                  designs.

              •   To estimate the cost of the EPA-funded cleanups of OUs in each respective
                  cleanup phase, we multiplied the number of OUs by a range of costs
                  provided by EPA. According to EPA, these cost ranges considered OUs where
                  no action is required and no remediation costs are incurred.




                  10
                    In its presentations to the Senate Committee on Environment and Public Works in June 1999, EPA
                  reported that there were 1,261 OUs at 649 nonfederal NPL sites, as of mid-April 1999. EPA officials told
                  us that nine sites have been transferred to other cleanup programs and that 18 OUs were not counted
                  because of errors in coding data. The officials agreed that the figures should be 640 sites and 1,279
                  OUs.



                  Page 21                                                                 GAO/RCED-00-25 Superfund
    Appendix II
    Cost Assumptions




•   For OUs that were ongoing (rather than planned or completed) in each
    cleanup phase, we assumed the action had already been
    partially—50 percent—funded and therefore used 50 percent of the
    respective cost estimate.

•   We used site-specific remedial action cost estimates from records of
    decision (ROD) available for 65 of 116 ongoing EPA-fund cleanups of OUs
    and added 20 percent for cost growth, as estimated by the Congressional
    Budget Office (CBO).11

•   We estimated the number and cost of removals remaining to be funded at
    the 640 sites using data from our recent survey of 609 of the 640 sites.12 We
    estimated that 100 sites would require removal actions and that EPA would
    fund these actions at 61 sites. Assuming 3.5 removal actions per site and a
    cost of $0.8 million for each removal action, we estimated $174 million as
    the total remaining removal cost at the 640 sites.

•   In a recent report, we categorized cleanup costs as contractor cleanup
    costs (about 45.5 percent of the total) and cleanup support
    costs—site-specific and non-site-specific. Site-specific cleanup support
    costs are equal to 37.6 percent of contractor cleanup costs.
    Non-site-specific cleanup support costs are equal to 84.9 percent of
    contractor cleanup costs. These percentages were used to determine
    support costs.13

•   Operation and maintenance (O&M) costs were calculated for all EPA-funded
    cleanups of OUs that EPA expects will require long-term funding. For
    example, EPA funds up to 10 years of O&M costs for OUs with remedies
    designed to restore groundwater or surface water. States then fund the
    remaining O&M costs for these OUs. EPA predicts that 50 percent of all OUs
    will have remedies requiring up to 10 years of expenditures for O&M,
    estimated by EPA to be $0.5 million per OU annually.

•   To estimate annual costs, we used the midpoint for each range of
    estimates for contractor cleanup, site-specific support, and


    11
     EPA officials told us that a recently completed EPA study, done in conjunction with the U.S. Army
    Corps of Engineers, projects the cost growth between contract award and contract completion at 16 to
    37 percent.
    12
     See Superfund: Half the Sites Have All Cleanup Remedies in Place or Completed (GAO/RCED-99-245,
    July 30, 1999).
    13
     See Superfund: EPA Can Improve Its Monitoring of Superfund Expenditures (GAO/RCED-99-139,
    May 11, 1999).



    Page 22                                                              GAO/RCED-00-25 Superfund
    Appendix II
    Cost Assumptions




    non-site-specific support costs and then evenly apportioned 85 percent of
    these costs over the period from 2000 to 2008, which is the 9-year period
    needed to complete 85 percent of the cleanups. Thus, about 9.4 percent of
    the total costs are incurred for each of these 9 years. Because it may take
    many years to complete cleanups of the remaining 15 percent of OUs, we
    simply allocated the costs for these sites evenly between 2009 and 2010.
    Thus, we assigned about 7.7 percent of the total cost to each of these 2
    years.

•   The annual O&M costs for the 640 sites were estimated by equally
    distributing the costs for 85 percent of the OUs projected to require federal
    O&M funding over the years 2000-2008 and evenly distributing the costs for
    the remaining OUs over 2009 and 2010. Each OU was estimated to cost
    $0.5 million annually, and these costs were projected to continue for 10
    years.




    Page 23                                               GAO/RCED-00-25 Superfund
Appendix III

Estimated Annual Costs to Complete 85
Percent of the 640 NPL Sites, or 1,279
Operable Units, by 2008

Dollars in millions
                                          Annual costs, assuming completion of 85 percent of OUs by 2008
                                                           Site- Subtotal for         Non-site-
                                    Contractor          specific cleanup and           specific Subtotal for
                      Percent of      cleanup           support site-specific          support cleanup and
Fiscal year           total costs        costs            costs      support             costs     support            O&M     Total costs
2000                         9.4        $366.2           $137.7          $503.9          $310.9       $814.8         $12.0        $826.8
2001                         9.4         366.2             137.7           503.9           310.9       814.8          24.0         838.8
2002                         9.4         366.2             137.7           503.9           310.9       814.8          36.0         850.8
2003                         9.4         366.2             137.7           503.9           310.9       814.8          48.0         862.8
2004                         9.4         366.2             137.7           503.9           310.9       814.8          60.0         874.8
2005                         9.4         366.2             137.7           503.9           310.9       814.8          72.0         886.8
2006                         9.4         366.2             137.7           503.9           310.9       814.8          84.0         898.8
2007                         9.4         366.2             137.7           503.9           310.9       814.8          96.0         910.8
2008                         9.4         366.2             137.7           503.9           310.9       814.8         108.0         922.8
2009                         7.7         300.0             112.8           412.7           254.7       667.4         118.0         785.4
2010                         7.7         300.0             112.8           412.7           254.7       667.4         116.0         783.4
                                a            a                   a               a               a          a
2011                                                                                                                 104.0         104.0
                                a            a                   a               a               a          a
2012                                                                                                                  92.0          92.0
                                a            a                   a               a               a          a
2013                                                                                                                  80.0          80.0
                                a            a                   a               a               a          a
2014                                                                                                                  68.0          68.0
                                a            a                   a               a               a          a
2015                                                                                                                  56.0          56.0
                                a            a                   a               a               a          a
2016                                                                                                                  44.0          44.0
                                a            a                   a               a               a          a
2017                                                                                                                  32.0          32.0
                                a            a                   a               a               a          a
2018                                                                                                                  20.0          20.0
                                a            a                   a               a               a          a
2019                                                                                                                  10.0          10.0
Total                        100      $3,895.6         $1,464.7        $5,360.3        $3,307.4      $8,667.7      $1,280.0     $9,947.7
                                                 Note: Totals may not add because of rounding.
                                                 a
                                                 Cleanups completed except for O&M.

                                             Source: GAO’s analysis of estimates by EPA.




                                             Page 24                                                            GAO/RCED-00-25 Superfund
Appendix IV

Comments From the Environmental
Protection Agency




              Page 25             GAO/RCED-00-25 Superfund
Appendix IV
Comments From the Environmental
Protection Agency




Page 26                           GAO/RCED-00-25 Superfund
Appendix IV
Comments From the Environmental
Protection Agency




Page 27                           GAO/RCED-00-25 Superfund
Appendix V

Scope and Methodology


             To determine the taxes paid into the Superfund trust fund, we obtained
             data from EPA on Superfund taxes, by year, for fiscal years 1981 through
             1998. For the estimated balance for the Superfund trust fund at the end of
             fiscal year 1999, we obtained an income data statement from the
             Department of the Treasury, which was current as of July 31, 1999. For
             deobligated Superfund amounts, we obtained data from EPA on these
             amounts for fiscal years 1994 through July 1999. Using the monthly
             averages for fiscal year 1999 deobligations, we projected deobligations for
             the remaining months of the fiscal year to arrive at an estimated total
             through fiscal year 1999. For Superfund expenditure information, we
             obtained annual expenditure data from EPA for fiscal years 1996 through
             1998 and allocated the expenditures among three categories presented in
             our May 1999 report.14 For program funds appropriated to other federal
             agencies, EPA provided us with Superfund appropriation data for fiscal
             years 1995 through 1998.

             To provide information on the costs to responsible parties for site
             cleanups and related transaction costs, we obtained EPA’s estimates of
             these parties’ cleanup costs, which were based on the value of the cleanup
             work stated in RODs and standard cost assumptions. In addition, EPA
             provided data from settlement agreements with responsible parties for
             past cleanup work performed by EPA. These costs were summed and
             categorized for the periods before and after the authority for Superfund
             taxes expired in December 1995. To determine the cleanup transaction
             costs incurred by responsible parties, we obtained estimates of these costs
             from CBO, RAND, and our studies of transaction costs. Using each estimate
             as a percentage of cleanup costs, we calculated transaction cost estimates.

             To obtain information on the cleanup status of the 640 nonfederal sites on
             the NPL that were not construction complete as of mid-April 1999, we
             obtained data from EPA on the cleanup status of the operable units at the
             sites. The 640 sites contained 1,279 operable units. Each site consists of
             one or more operable units, and we classified a site’s overall progress by
             the operable unit in the least advanced stage of the Superfund process. For
             example, we classified a site with three operable units—one in the
             remedial design phase and two in the remedial investigation/feasibility
             study phase—as in the remedial investigation/feasibility study phase. We
             also classified each site’s progress by the operable unit in the most
             advanced phase of the Superfund cleanup process.



             14
              Superfund: EPA Can Improve Its Monitoring of Superfund Expenditures (GAO/RCED-99-139, May 11,
             1999).



             Page 28                                                          GAO/RCED-00-25 Superfund
Appendix V
Scope and Methodology




To determine the estimated completion dates for Superfund sites, we used
two information sources. First, we used the site-specific completion
estimates that we collected from EPA’s site managers for our recent review
of the status of cleanups at NPL sites.15 Second, when such an estimate was
not available, we calculated the estimated completion date using EPA’s
standard completion time for each phase in the Superfund process—3.1
years for the remedial investigation/feasibility study, 2.8 years for the
remedial design, and 2.1 years for remedial action, for a total of 8 years
once a site is on the NPL.

To obtain information on the costs to clean up the 640 sites, we obtained
ranges of cost estimates from EPA for completing each phase of the
remedial action process. We used these cost ranges to calculate an overall
cleanup cost, and we estimated remaining removal costs at the 640 sites
using EPA’s estimates of removal costs and removals already conducted at
these sites. To determine overhead costs, we calculated overhead rates for
site-specific overhead and non-site-specific overhead costs. We derived
these rates from EPA’s Superfund expenditure data for fiscal years 1996
through 1998, as we reported in May 1999.16 We applied these overhead
rates to the total cost of remedial and removal actions to derive the total
site-specific and non-site-specific overhead amounts. To determine the
annual cleanup costs, we allocated costs by year according to the year of
estimated completion.




15
 See Superfund: Half the Sites Have All Cleanup Remedies in Place or Completed (GAO/RCED-99-245,
July 30, 1999).
16
 Superfund: EPA Can Improve Its Monitoring of Superfund Expenditures (GAO/RCED-99-139, May 11,
1999).



Page 29                                                            GAO/RCED-00-25 Superfund
Appendix VI

Key Contributors to This Report


                        Allen Rogers, Director, Design, Methodology, and Technical Assistance
Resources,              Group
Community, and
Economic                Karen L. Kemper, Evaluator-in-Charge

Development             John Johnson, Senior Evaluator
Division, Washington,
D.C.
                        John Wanska, Assistant Director
Chicago Office
                        Rosemary Torres-Lerma, Senior Evaluator


                        Jim Hayward, Staff Evaluator
Raleigh Office
                        Richard Johnson, Senior Attorney
Office of General
Counsel




(160494)                Page 30                                           GAO/RCED-00-25 Superfund
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