oversight

Superfund: Progress, Problems, and Future Outlook

Published by the Government Accountability Office on 1999-03-23.

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

                          United States General Accounting Office

GAO                       Before the Subcommittee on Finance and
                          Hazardous Materials, Committee on
                          Commerce, House of Representatives


For Release on Delivery
Expected at 2 p.m., EST
Tuesday,
                          SUPERFUND
March 23, 1999




                          Progress, Problems,
                          and Future Outlook
                          Statement of Peter F. Guerrero, Director, Environmental Protection
                          Issues, Resources, Community, and Economic Development Division




GAO/T-RCED-99-128
PAGE2   GAO/XXXX-98-??? NAME OF DOCUMENT
Mr. Chairman and Members of the Committee:

Thank you for the opportunity to discuss the current status and
management of the Superfund program and the outlook for the program’s
future. My comments today are based on a number of reports we have
issued in recent years that relate to three specific issues: (1) progress
made toward cleaning up sites in the program, (2) continuing management
problems, and (3) factors affecting Superfund’s future workload. In
summary, our work has shown the following:

• In the past, we have called attention to the slow pace of cleanups in the
  Superfund program. For example, we reported that cleanups completed
  in 1996 took an average of over 10 years.1 However, now, 17 years after
  sites were first placed on the Superfund list, many of the sites have
  progressed a considerable distance through the cleanup process.
  Decisions about how to clean up the great majority of these sites have
  been made, and the construction of cleanup remedies has been
  completed at over 40 percent of the sites. EPA’s goal is to complete the
  construction of remedies at 1,200 sites by 2005. Work to clean up
  groundwater will continue at many sites after remedies are constructed.
• Despite the progress that Superfund has made toward site cleanups,
  certain management problems persist. These problems include the
  difficulty in controlling contract costs, the failure to recover certain
  federal cleanup costs from the parties who are responsible for the
  contaminated sites, and the selection of sites for cleanup without
  assurance that they are the most dangerous sites to human health and
  the environment. These problems have caused us to include the
  program on our list of federal programs vulnerable to waste and abuse.
  Furthermore, our analysis indicates that the costs of on-site work by
  cleanup contractors represent less than half of the spending in the
  program.
• There is considerable uncertainty about the future workload of the
  Superfund program. Resolving this uncertainty depends largely on
  deciding how to divide responsibility for the cleanup of sites between
  EPA and the states. The number of sites that have entered the
  Superfund program in recent years has decreased as EPA has focused
  its resources on completing work at existing sites and the states have
  developed their own programs for cleaning up sites. However,


1 Superfund:  Times to Complete the Assessment and Cleanup of Hazardous Waste Sites (GAO/RCED-97-
20, Mar. 31, 1997).




Page 1                                                                     GAO/T-RCED-99-128
                    according to EPA and state officials who responded to our survey, a
                    large number of sites in EPA’s inventory of potential Superfund sites are
                    contaminating groundwater and drinking water sources and causing
                    other problems and may need cleanup. We have recommended that EPA
                    work with the states to assign responsibility for these sites among
                    themselves. The Superfund reauthorization process gives the Congress
                    an opportunity to help guide EPA and the states in allocating
                    responsibility for addressing these sites.



Background   In 1980, the Congress passed the Comprehensive Environmental Response,
             Compensation, and Liability Act (CERCLA), creating the Superfund
             program to clean up highly contaminated hazardous waste sites. CERCLA
             authorizes EPA to compel the parties responsible for the contaminated
             sites to clean them up. The law also allows EPA to pay for cleanups and
             seek reimbursement from the parties. EPA places sites that it determines
             need long-term cleanup action on its National Priorities List (NPL). As of
             early 1999, there were 1,264 sites on or proposed for the NPL. Another 182
             sites had completed the cleanup process or were determined not to need
             cleanup and had been deleted from the NPL. Once listed, the sites are
             further studied for risks, and cleanup remedies are chosen, designed, and
             constructed. EPA relies extensively on contractors to study site conditions
             and conduct cleanups.

             Cleanup actions fall into two broad categories: removal actions and
             remedial actions. Removal actions are usually short-term actions designed
             to stabilize or clean up hazardous sites that pose an immediate threat to
             human health or the environment. Remedial actions are usually longer
             term and more costly actions aimed at permanent remedies.

             According to a 1998 report by the Environmental Law Institute,2 all 50
             states have established their own cleanup programs for hazardous waste
             sites. In addition to handling less dangerous sites, some of the state
             programs can handle highly contaminated sites, whose risks could qualify
             them for the Superfund program. Some states initially patterned their
             cleanup programs after the Superfund program but over the years, in an
             effort to clean up more sites faster and less expensively, have developed
             their own approaches to cleaning up sites.



             2 An   Analysis of State Superfund Programs: 50-State Study, 1998 Update, Environmental Law Institute.




             Page 2                                                                          GAO/T-RCED-99-128
                       States accomplish cleanups under three types of programs: (1) voluntary
                       cleanup programs that allow parties, who are often interested in increasing
                       sites’ economic value, to clean them up without state enforcement actions;
                       (2) brownfields programs that encourage the voluntary cleanup of sites in
                       urban industrial areas to enable their reuse; and (3) enforcement programs
                       that oversee the cleanup of the most serious sites and force uncooperative
                       responsible parties to clean up their sites. States generally use their
                       voluntary and brownfields programs to clean up less complex sites by
                       offering various incentives to responsible parties, such as reduced state
                       oversight. States maintain that these programs accomplish site cleanups
                       quickly and efficiently.

                       Some states also maintain cleanup funds to pay all or a portion of the costs
                       of cleanups at sites for which responsible parties that are able to pay for
                       full cleanups cannot be found. The states vary greatly in the resources that
                       they have devoted to cleanups. For example, the 1998 Environmental Law
                       Institute study determined that states had cleanup funds totaling $1.4
                       billion as of the end of the states’ 1997 fiscal year, with 6 states having fund
                       balances of $50 million or more and 26 states having fund balances of less
                       than $5 million. The study also reported that states spent a total of $565
                       million on their cleanup programs in fiscal year 1997, 3 with 2 states
                       spending $50 million or more and 27 states spending less than $5 million.



Superfund Has Made     Even though cleanups have taken a long time to accomplish, if it maintains
                       its current pace, the Superfund program will complete the construction of
Progress Cleaning Up   cleanup remedies at the great majority of current NPL sites within the next
Sites                  several years. In our March 1997 report, we said that cleanups completed
                       in 1996 took an average of 10.6 years. Much of the time taken to complete
                       cleanups was spent during the early planning phases of the cleanup process
                       during which cleanup remedies are selected. We said that less time had
                       been spent on actual construction work at sites than on the selection of
                       remedies.




                       3 Six   states did not report on their spending.




                       Page 3                                                        GAO/T-RCED-99-128
Now, however, most NPL sites have been in the cleanup process for a long
time and have moved beyond the remedy selection phase. Last year, we
reported that EPA had completed the selection of remedies at about 70
percent of the NPL sites as of the end of fiscal year 1997.4 It had plans to
complete, by the end of fiscal year 1999, remedies for about 67 percent of
the federally owned or operated sites and 95 percent of the nonfederal sites
that were listed as of the end of fiscal year 1997. EPA reports that it has
completed the construction of cleanup remedies at 585 sites as of January
1999; will complete construction at 85 sites in each of fiscal years 1999 and
2000; and will finish a total of 1,200 sites by 2005. Groundwater cleanups
will continue at many of these sites after the completion of remedy
construction.

These completion rates reflect EPA’s decision to make the completion of
construction at existing sites the Superfund program’s top priority and to
reduce new entries into the program. About 89 percent of the NPL sites
were placed on the list between 1982 and 1990. Figure 1 shows the number
of sites listed on the NPL and the number of sites where the construction of
the cleanup remedy was completed during the years 1986 through 1998.




4 Superfund:   Information on the Status of Sites (GAO/RCED-98-241, Aug. 28, 1998).




Page 4                                                                          GAO/T-RCED-99-128
                       Figure 1: Numbers of Sites Listed on the NPL and for Which the Construction of
                       Final Cleanup Remedies Were Completed, 1986 Through 1998
                          Number of sites
                           300

                           250

                           200

                           150

                           100

                            50

                              0
                                  1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999

                                                     NPL listings           Construction completions


                       Source: Compiled by GAO from Environmental Protection Agency data.


                       Under the Superfund program, in addition to its remedial work, EPA has
                       conducted removals at 595 NPL sites and 2,591 other contaminated sites.
                       Cleanup work has also been conducted at sites where construction of the
                       final cleanup remedy has not yet been completed. At the request of this
                       committee, we are conducting a review to determine the extent of this
                       ongoing cleanup activity.



Uncorrected Problems   For several years, GAO has included the Superfund program on its list of
                       federal programs that pose significant financial risk to the government and
Make Superfund A       the potential for waste and abuse. We included Superfund on the list
High-Risk Program      because of (1) problems with the management of cleanup contractors, (2)
                       insufficient recovery of cleanup costs from responsible parties, and (3) the
                       absence of risk-based priorities for site cleanups.5 EPA has corrected some
                       of these problems, but enough remain that we have not yet been able to
                       remove Superfund from the high-risk list. I would like to review these
                       problems and EPA’s response.


                       5 High-Risk Series:
                                        Superfund Program Management (GAO/HR-93-10, Dec. 1992, GAO/HR-95-12, Feb.
                       1995, GAO/HR-97-14, Feb. 1997, and GAO/OCG-99-17, Jan. 1999).




                       Page 5                                                                  GAO/T-RCED-99-128
Contract Management   First, we raised concerns about several contracting practices. We said that
                      EPA had a backlog of more than 500 audits of its Superfund contracts. The
                      purpose of these audits is to evaluate the adequacy of contractors’ policies,
                      procedures, controls, and performance. The audits are necessary for
                      effective management and are a key tool for deterring and detecting waste
                      and abuse. The agency has now almost eliminated its backlog of contract
                      audits.

                      We also found that EPA was approving contractors’ cleanup cost proposals
                      without estimating what the work should cost. As a result, the agency
                      could not negotiate the best contract price for the government. In
                      response, EPA is now developing its own cost estimates and using them to
                      guide its price negotiations with contractors. However, EPA was still
                      having problems developing accurate estimates in about half the cases we
                      recently reviewed. Furthermore, many of the cost estimators in the EPA
                      regions told us that they lacked the experience and historical data they
                      needed to do a better job at developing these estimates. EPA has requested
                      the U.S. Army Corps of Engineers, an agency with extensive contracting
                      experience, to conduct an assessment of EPA’s cost-estimating practices
                      and recommend potential improvements. The assessment is still ongoing
                      and will be completed in mid 1999. Unless EPA ensures that its regions
                      implement and sustain corrective measures resulting from this review,
                      problems can reoccur. EPA has taken similar corrective actions in the past,
                      yet we continue to find problems with estimates.

                      Lastly, with respect to contracting, we reported that EPA had difficulty
                      controlling the overhead, or program support costs, of its contractors. To
                      ensure that it had enough contractors to conduct cleanups, EPA hired a
                      large number of contractors—more, it turned out, than it actually needed.
                      Even though it did not have enough cleanup work to keep them all busy, it
                      had to pay their overhead costs (i.e., the costs of their maintaining the
                      capacity to respond to work assignments--such as office space). Although
                      EPA cut in half the number of contractors that it keeps in place, our recent
                      work indicates that this reduction may not have been enough. We found
                      that, for the majority of contracts we reviewed, EPA continues to pay
                      overhead costs ranging from 16 percent to 76 percent of the overall
                      contract’s costs, exceeding EPA’s 11 percent target. In addition, persistent
                      high overhead costs and uncertainty about the future size of the program
                      raise broader questions about the type and the number of contracts EPA
                      really needs to have in place.




                      Page 6                                                      GAO/T-RCED-99-128
Cost Recovery      Even though CERCLA makes parties who are responsible for contaminated
                   sites liable for cleanup costs, we have repeatedly reported that EPA has not
                   charged responsible parties for certain costs of operating the cleanup
                   program--mainly indirect program costs, such as personnel and facilities.
                   EPA has excluded about $3 billion—about 20 percent of the $15 billion it
                   has spent on Superfund through fiscal year 1997—in indirect costs from
                   final settlements with responsible parties. In the early years of the
                   program, EPA took a conservative approach to allocating indirect costs to
                   private parties because it was uncertain which indirect costs the courts
                   would agree were recoverable if parties legally challenged EPA. The
                   agency could lose the opportunity to recover at least a half billion dollars
                   more if it does not soon reverse this practice. Recently, Superfund program
                   officials have developed a new way to determine recoverable indirect costs
                   that could increase EPA’s cost recoveries, but the Superfund program has
                   not yet used this new method because it is waiting for approval from EPA
                   and the Justice Department.


Priority Setting   The final Superfund issue that we discussed in our high-risk series is the
                   absence of a system for prioritizing sites for cleanup based on the risk they
                   pose to human health and the environment. EPA has partially corrected
                   this problem. In 1995, it created the National Prioritization Panel to help it
                   set funding priorities for sites at which remedies had been selected and that
                   were ready for cleanup. The panel, which is composed of regional and
                   headquarters cleanup managers, ranks all of the sites ready for cleanup
                   construction nationwide on the basis of the health and environmental risks
                   and other project considerations, such as cost-effectiveness. EPA then
                   approves funding for projects on the basis of these priority rankings.

                   EPA, however, does not use relative risk as a major criterion when deciding
                   which of the eligible sites to place on the NPL.6 In our discussions with
                   EPA managers responsible for assessing sites for Superfund consideration,
                   we found that the agency relies on the states to choose which of the eligible
                   sites to refer to EPA for placement on the NPL. States refer sites after
                   selecting those that they will address through their own enforcement or
                   voluntary cleanup programs. The EPA cleanup managers with whom we
                   talked expect that future sites placed on the NPL will not necessarily be the

                   6
                    A site is eligible for the NPL if it scores sufficiently high on EPA's Hazard Ranking System, which
                   evaluates a site's potential risk to public health and the environment.




                   Page 7                                                                           GAO/T-RCED-99-128
most risky but, rather, those that the states find to be large, complex, and
therefore costly, or those without responsible parties willing and able to
pay for the cleanup.

Because EPA does not usually track the status of cleanups that take place
outside of the Superfund program, EPA does not know if the worst sites in
the nation are being addressed first. Some EPA regions are encouraging
their states to voluntarily provide EPA with information on the cleanup
status of the sites that the states are addressing and that EPA considers as
potentially posing significant risk.

In addition to our work on the high-risk aspects of the Superfund program,
we have conducted detailed analyses of spending in the program7. In
summary, we have reported that the share of Superfund expenditures that
go to cleanup contractors for the study, design, and implementation of
cleanups increased from fiscal years 1987 through 1996, but declined in
fiscal year 1997. We also reported that between fiscal years 1996 and 1997,
EPA’s Superfund costs for administration and support activities
correspondingly increased (see fig. 2). As you know, we are currently
conducting additional analysis of the Superfund program’s expenditures for
this Committee and others. We plan to report on the results of this work in
May.




7 Superfund: Trends in Spending for Site Cleanups (GAO/RCED-97-211, Sept. 4, 1997) and Superfund:
Analysis of Contractor Cleanup Spending (GAO/RCED-98-221, Aug. 4, 1998).




Page 8                                                                       GAO/T-RCED-99-128
                       Figure 2: Superfund Spending for Contractor Cleanup Work and Other Program
                       Activities, Fiscal Years 1996-97, Dollars in Millions


                                        1996                                                    1997

                                                                         Other costs                           Cleanup
                                               Cleanup
                          Other costs                                    $432                                  actions $588
                                               actions $614
                          $417                                           29.8%                                 40.5%
                                               43.5%
                          29.6%




                                                                                Admin./
                         Admin./                                                Support
                         Support                 Study/                                                     Study/
                                                                                $355                        Design $76
                         $299                    Design $81
                                                                                24.4%                       5.3%
                         21.2%                   5.7%



                       Note: “Other costs” includes costs for enforcement activities, research and development/laboratories,
                       and other directly related costs.
                       Source: Superfund: Analysis of Contractor Cleanup Spending (GAO/RCED-98-221, Aug. 4, 1998).




The Future Direction   EPA’s inventory of potential NPL sites contains sites that have been
                       awaiting a decision for several years or more on whether they should be
Of Superfund Is        listed on the NPL. EPA and state officials believe that many of these sites
Uncertain              need cleanup work, but the respective cleanup responsibilities of EPA and
                       the states have not been established.

                       As of the end of fiscal year 1997, EPA’s Superfund database indicated that
                       the risks of over 3,000 sites had been judged on the basis of preliminary
                       evaluations to be serious enough to make the sites potentially eligible for
                       the NPL. EPA classified these sites as “awaiting an NPL decision.”
                       Information about the nature and the extent of the threat that these sites
                       pose to human health and the environment, the extent of states' or EPA's
                       cleanup actions at the sites, and the states' or EPA's cleanup plans for the
                       sites is important to determining the future size of the Superfund program.

                       We surveyed EPA regions, other federal agencies, and the states to (1)
                       determine how many of the over 3,000 sites remain potentially eligible for
                       the NPL; (2) identify the characteristics of these sites, including their health



                       Page 9                                                                         GAO/T-RCED-99-128
and environmental risks; (3) determine the status of any actions to clean up
these sites; and (4) collect the opinions of EPA and other federal and state
officials on the likely final disposition of these sites, including the number
of sites that are expected to be placed on the NPL. We reported the results
of our surveys in two November 1998 reports.8

On the basis of our surveys, we determined that 1,789 of the 3,036 sites that
EPA's database classified as “awaiting an NPL decision” in October 1997
are still potentially eligible for placement on the list.9 EPA, other federal
agency, and state officials responding to our survey said that many of these
sites presented risks to human health and the environment. According to
these officials,

• about 73 percent of the sites have caused contamination in groundwater
  and another 22 percent could contaminate groundwater in the future;
• about 32 percent of the sites caused contamination in drinking water
  sources and another 56 percent could contaminate drinking water
  sources in the future;
• 96 percent of the potentially eligible sites are located in populated areas
  within a half-mile of residences or places of regular employment; and
• workers, visitors, or trespassers may have direct contact with
  contaminants at about 55 percent of the sites.

We asked officials of EPA, other federal agencies, and states to rank the
risks of the potentially eligible sites. These officials collectively said that
about 17 percent of the potentially eligible sites currently pose high risks to
human health and the environment, and another 10 percent of the sites (for
a total of 27 percent) reportedly may also pose high risks in the future if
they are not cleaned up (see fig. 3). For about one-third of the sites, the
officials said that it was too soon or they needed more information to
determine the seriousness of the sites' risks, or they provided no risk
characterization.


8 Hazardous Waste: Unaddressed Risks at Many Potential Superfund Sites (GAO/RCED-99-8, Nov. 30,
1998, and Hazardous Waste: Information on Potential Superfund Sites (GAO/RCED-99-22, Nov. 30,
1998).

9
 We refer to these 1,789 hazardous waste sites as "potentially eligible sites." We consider the 1,234 other
sites as unlikely to become eligible for various reasons. For example, some sites were erroneously
classified as awaiting an NPL decision or do not meet EPA’s criteria for placement on the list. Other
sites do not require cleanup in the view of the responding officials, have already been cleaned up, or
have final cleanup activities underway. Whether potentially eligible sites are eventually listed depends
on, among other things, a final evaluation by EPA and the states' concurrence.




Page 10                                                                            GAO/T-RCED-99-128
Figure 3: Number of Potentially Eligible Sites With High, Average, and Low Potential
Risks


                                                                   High potential risks
          Unknown risks (573
                                                                       (476 sites)
                sites)
                                                                          27%
                32%




                                                             Average potential
                 Low potential risks                          risks (392 sites)
                    (348 sites)
                                                                    22%
                       19%

Source: Hazardous Waste: Unaddressed Risks at Many Potential Superfund Sites         (GAO/RCED-99-8,
Nov. 30, 1998).


Officials responding to our surveys said that some cleanup activities
(which they stated were not final cleanup actions) have taken place at 686
of the potentially eligible sites. These actions were taken at more than half
of the sites that were reported to currently or potentially pose high risks,
compared to about a third of the sites that have been reported to currently
or potentially pose average or low risks. No cleanup activities beyond
initial site assessments or investigations have been conducted or no
information is available on any such actions at the other 1,103 potentially
eligible sites.10 Many of the potentially eligible sites have been in state and
EPA inventories of hazardous sites for extended periods. Seventy-three
percent have been in EPA's inventory for more than a decade. No cleanup
progress was reported at the majority of the sites that have been known for
10 years or more.

It is uncertain whether most potentially eligible sites will be cleaned up;
when cleanup actions, if any, are likely to begin; who will do the cleanup;
under what programs these activities will occur; and what the extent of


10Of the 1,103 sites for which no cleanup actions were reported, both EPA and the states said that they
had taken no cleanup actions beyond initial site assessments at 719 of them. For 336 sites, EPA officials
alone said that their agency had taken no cleanup actions, but the states provided no information.
California, Massachusetts, and New Jersey accounted for about 85 percent of these sites. Similarly, for
six sites, the states said that they had taken no action, but EPA provided no information. Neither EPA
nor the states provided information on any cleanup actions that may have occurred at the remaining 42
of the 1,103 sites.




Page 11                                                                           GAO/T-RCED-99-128
responsible parties' participation will be. We did not receive enough
information from our survey to determine what cleanup actions will be
taken at more than half of the 1,789 potentially eligible sites and whether
EPA or the states will take these actions (see fig. 4). We are making no
forecast of the number from the group of 1,789 potentially eligible sites that
will be added to the NPL in the future. However, EPA and state officials
collectively believed that 232 (13 percent) of the potentially eligible sites
might be placed on the NPL in the future.11 Officials estimated that almost
one third of the potentially eligible sites are likely to be cleaned up under
state programs but usually could not give a date for the start of cleanup
activities. State officials stated that, for about two-thirds of the sites likely
to be cleaned up under state programs, the extent of responsible parties'
participation is uncertain. This is important because officials of about half
of the states told us that their state's financial capability to clean up
potentially eligible sites, if necessary, is poor or very poor. In addition,
officials of about 20 percent of the states said that their enforcement
capacity (including resources and legal authority) to compel responsible
parties to clean up potentially eligible sites is fair to very poor.




11However,   EPA and the states agreed on the listing prospects of only 26 specific sites.




Page 12                                                                            GAO/T-RCED-99-128
Figure 4: Estimates of the Likely Final Cleanup Outcome for 1,789 Potentially
Eligible Sites

                                                             Sites that might be
                            Other sites (75)                 placed on the NPL
                            4%                               (232)
                                                             13%
                  Sites likely to be
                  cleaned up under
                  state programs
                  (536)
                                                                Sites for which final
                  30%                                           outcome is uncertain
                                                                (946)
                                                                53%


Note: “Other sites” includes sites likely to be cleaned up under other EPA programs (43), sites that
either EPA or state programs may clean up (13), and sites that are reportedly unlikely to be cleaned up
(19).
Source: Hazardous Waste: Unaddressed Risks at Many Potential Superfund Sites        (GAO/RCED-99-8,
Nov. 30, 1998).


Our November report recommends that EPA review its inventory of
potential NPL sites to determine which of them need immediate action and
which will require long term cleanup action and, in consultation with the
states, develop a timetable for taking these actions.


In conclusion, Mr. Chairman, despite the long durations of cleanups in the
past, Superfund is within sight of completing the construction of cleanup
remedies at most of the sites on the NPL. While recognizing this
accomplishment, we believe that management problems and cost control
issues we have reported on for several years remain to be solved. Because
few sites have been admitted to the program in recent years, the NPL
pipeline is clearing out. On the other hand, there are many sites in EPA’s
inventory of potential NPL sites that still need attention and possible
cleanup, but EPA and the states have postponed decisions, sometimes for
up to 10 years or longer, on how to address them.

Over the last two decades, the states have built up the capacity to deal with
site cleanups to varying degrees. Some have substantial programs, but
others have limited resources and report that their ability to pay for
cleanups is poor. Furthermore, not all of the states have adequate
enforcement authority to force responsible parties to pay for cleanups.



Page 13                                                                         GAO/T-RCED-99-128
                   Because states generally now have the lead for screening sites for NPL
                   consideration, future NPL sites may disproportionately represent complex
                   cleanups for which responsible parties cannot be found or are unwilling to
                   ante up the full cost of the cleanup. We have recommended that EPA work
                   with the states to assign responsibility among themselves for these sites.
                   The Superfund reauthorization process gives the Congress an opportunity
                   to help guide EPA and the states in allocating responsibility for addressing
                   these sites.

                   Mr. Chairman, this concludes my prepared statement. I will be happy to
                   respond to your questions or the questions of committee members.




(160479)   Leter   Page 14                                                    GAO/T-RCED-99-128
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