EPA's Expenditures to Clean Up the Bunker Hill Superfund Site	 
(28-MAR-01, GAO-01-431R).					 
								 
In April 1995, the Environmental Protection Agency (EPA) and the 
state of Idaho signed an agreement to clean up a mining area	 
known as Bunker Hill. The agreement estimated that the total cost
of the cleanup would be $126 million, with the state's share	 
capped at $12.6 million. This correspondence focuses on (1) EPA's
actual expenditures for cleanup activities and how these	 
expenditures differ from the estimate set forth in the agreement 
and (2) the reasons for any major differences between actual and 
estimated cleanup expenditures. As of September 30, 2000, EPA had
expended about $212 million for various cleanup and management	 
support activities within the Bunker Hill Superfund site. About  
$101 million of the expenditures was for cleanup-related	 
activities not covered by the EPA/state agreement and therefore  
not included in the 1995 cost estimate. These activities included
the study and design of cleanup activities, emergency removals of
contaminated materials, enforcement of responsible party cleanup 
activities, and indirect management support. The remaining $111  
million was expended on cleanup work covered by this agreement.  
EPA and the state of Idaho expect that the cleanup work covered  
by the agreement will be completed by about the end of 2002 at a 
projected final cost of about $140 million. EPA also expects that
the agreement will be modified to cover the future costs of	 
improving the site's existing water treatment plant, estimated to
range from $16 million to $33 million. For the components of the 
cleanup work where contractors were hired to conduct the work,	 
the projected final costs range from $4.7 million less to $6.1	 
million more than the amounts originally estimated. The $4.7	 
million cost savings occurred as a result of improved contractor 
performance in response to contractual incentives. Cost increases
resulted primarily from (1) higher-than-anticipated quantities of
contaminated materials requiring removal, (2) greater handling of
materials to dry them before disposal, and (3) floods that	 
recontaminated areas that had already been cleaned.		 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-01-431R					        
    ACCNO:   A00685						        
    TITLE:   EPA's Expenditures to Clean Up the Bunker Hill Superfund 
             Site                                                             
     DATE:   03/28/2001 
  SUBJECT:   Budget outlays					 
	     Cost analysis					 
	     Environmental monitoring				 
	     Federal/state relations				 
	     Hazardous substances				 
	     Pollution control					 
	     Waste disposal					 
	     EPA National Priorities List			 
	     Idaho						 
	     Superfund Program					 
	     Bunker Hill Superfund Site (ID)			 

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GAO-01-431R

Bunker Hill Superfund Site United States General Accounting
Office

Washington, DC 20548

March 28, 2001 Congressional Requesters Subject: EPA's Expenditures to Clean
Up the Bunker Hill Superfund Site This letter responds to your request that
we review the Environmental Protection Agency's (EPA) expenditures for the
Bunker Hill Superfund site, a mining area in the Coeur d'Alene River Basin
in northern Idaho. In 1980, the Comprehensive Environmental Response,
Compensation, and Liability Act created the Superfund program to clean up
highly contaminated hazardous waste sites. In 1983, EPA listed Bunker Hill
on the National Priorities List- the agency's list of the nation's most
contaminated sites- because contamination from heavy metals and other
materials posed a severe risk to human health and the environment. EPA's
Bunker Hill cleanup activities have focused on a 21- square- mile area
(referred to as “the box”) located in the center of the 1,500-
square- mile river basin.

Originally, some of the mining companies responsible for the contamination
agreed to conduct the cleanup work. However, EPA and the state of Idaho took
over the majority of the cleanup effort following the bankruptcy of a major
responsible party. In April 1995, EPA and the state of Idaho signed an
agreement setting out a cleanup strategy with an estimated total cost of
$126 million; the agreement also capped the state's share of these expenses
at $12.6 million. 1 To implement this agreement, EPA segmented the cleanup
work into various components- such as the demolition of industrial complex
structures, removal of contaminated soil in gulches and creeks, revegetation
of hillsides, and treatment of wastewater- and hired contractors to do the
work. You asked us to determine (1) EPA's actual expenditures for the
cleanup activities at Bunker Hill and how these expenditures differ from the
estimate set forth in the agreement and (2) the reasons for any major
differences (defined as $2 million or more) between the actual and estimated
Bunker Hill cleanup expenditures for each component.

1 Any change to this share would require an amendment to the agreement.

GAO- 01- 431R Bunker Hill Superfund Site 2 In summary, we found the
following:

As of September 30, 2000, EPA had expended about $212 million for various
cleanup and management support activities within “the box” area
of the Bunker Hill Superfund site. About $101 million of the expenditures
was for cleanuprelated activities not covered by the EPA/ state agreement
and therefore not included in the 1995 cost estimate. These activities
included the study and design of cleanup activities, emergency removals of
contaminated materials, enforcement of responsible party cleanup activities,
and indirect management support. The remaining $111 million was expended on
cleanup work covered by the agreement. EPA and the state of Idaho expect
that the cleanup work covered by the agreement will be completed by about
the end of 2002 at a projected final cost of about $140 million- or about
$14 million more than the $126 million estimate in the agreement. EPA also
expects that the agreement will be modified to cover the future costs of
improving the site's existing water treatment plant, estimated to range from
$16 million to $33 million.

For the components of the cleanup work where contractors were hired to
conduct the work, the projected final costs range from $4.7 million less to
$6.1 million more than the amounts originally estimated. The $4.7 million
cost savings occurred as a result of improved contractor performance in
response to contractual incentives. Cost increases resulted primarily from
(1) higher- thananticipated quantities of contaminated materials requiring
removal, (2) greater handling of materials to dry them before disposal
(because they were excavated from below groundwater levels), and (3) floods
that recontaminated areas that had already been cleaned.

Background

In 1980, the Comprehensive Environmental Response, Compensation, and
Liability Act created the Superfund program to clean up highly contaminated
hazardous waste sites. EPA, the federal agency responsible for implementing
the act, places sites that pose a sufficiently serious threat to human
health or the environment on the National Priorities List for possible
remedial action under the program.

EPA employs a multistage process to clean up hazardous waste at sites on the
National Priorities List. EPA first conducts a remedial investigation and
feasibility study to review and consider site conditions, cleanup problems,
and alternative cleanup methods. During this study phase, EPA may also
initiate emergency removals of highly contaminated materials to quickly
address the most severe health or environmental threats. Following the
remedial investigation and feasibility study, a Record of Decision is
published to document the selected cleanup remedy and estimated costs. EPA
may compel the parties responsible for the contamination to clean it up or
EPA itself may hire contractors to conduct the site cleanup and try to
recover the cleanup costs from the responsible parties later.

GAO- 01- 431R Bunker Hill Superfund Site 3 When responsible parties perform
the cleanup, they develop the detailed design plans

and conduct the cleanup either directly or through hired contractors. In
addition, the responsible parties perform and pay for any necessary long-
term operations and maintenance actions. EPA oversees the entire process and
ensures that the cleanup meets federal requirements.

When EPA performs the cleanup, it must first enter into an agreement with
the respective state involved. Among other things, the agreement must
provide that the state in which the Superfund site is located match 10
percent of the site's cleanup costs. The cleanup costs that the state must
match include the cost of the remedial actions as well as any associated on-
site support costs specifically to manage the agreed- upon cleanup actions.
Under the EPA/ state agreement, Idaho is not required to match site study,
emergency removals, remedial design, enforcement, or indirect EPA costs. In
addition, EPA regulations provide that the state is generally responsible
for long- term operations and maintenance costs once the cleanup is
complete.

After reaching an agreement with the state, EPA develops technical drawings
and specifications for each component of the cleanup in a phase called
“remedial design.” With these specifications, EPA, or an agency
designated by EPA, negotiates with and hires contractors to perform various
components of the cleanup work. Once the cleanup is complete, EPA and the
state evaluate the remedial actions employed to determine if they are
operational and functional. Once this determination is made, EPA regulations
provide that the state is generally responsible for long- term operations
and maintenance costs.

EPA listed Bunker Hill on the National Priorities List in 1983. Subsequent
to this listing, EPA chose a two- pronged approach to the cleanup- one for
the populated areas and one for the nonpopulated areas. In an August 1991
Record of Decision, EPA published the cleanup actions for the populated
areas of the site with an estimated cost of about $41 million. In a second
Record of Decision, published in September 1992, EPA laid out the cleanup
actions for the nonpopulated areas of the site- as well as some portions of
the populated areas not included in the August Record of Decision- and
included a cleanup estimate of about $57 million. The responsible parties
initially implemented the cleanup actions for both records of decision. The
responsible parties are about two- thirds finished with the cleanup of the
populated areas. However, EPA and the state of Idaho took over the majority
of the cleanup effort in 1994 for the nonpopulated areas following the
bankruptcy of a major responsible party. In April 1995, EPA and the state of
Idaho signed an agreement laying out a new strategy for cleaning up the
nonpopulated areas at an estimated cost of $126 million. The new agreement
formally capped the state's share of the cost for cleaning up the
nonpopulated areas at $12.6 million (10 percent of the agreed- upon cost
estimate). Under this agreement, Idaho is also responsible for longterm
operations and maintenance once the cleanup is complete.

According to EPA and the state of Idaho, the increase in total estimated
cost, from the $57 million in the 1992 Record of Decision for nonpopulated
areas to the $126 million in the 1995 EPA/ state agreement, resulted
primarily from a change in strategy.

GAO- 01- 431R Bunker Hill Superfund Site 4 EPA agreed with Idaho to change
the cleanup strategy to minimize the costs

associated with long- term site operations and maintenance and thus reduce
the costs' impact on the state. Doing this, however, required additional
cleanup actions and expenditures. Instead of removing some contaminated
material and maintaining many impoundment areas, as described in the 1992
Record of Decision, the new strategy would require removing significantly
more contaminated material and consolidating that material into a few, large
impoundment areas that are lined and covered to prevent infiltration. In
addition, the agreement provided a 37- percent contingency cost factor for
unknown conditions in an effort to establish the best estimate possible,
given the phase in which the estimates were made- prior to remedial design-
and the information available at the time. 2 Finally, significant cost
increases were incurred because EPA and the state had to pay wage rates that
were estimated to be about 40 percent more than the wage rates the
responsible parties were paying. Unlike projects funded by responsible
parties, federally- funded construction projects are subject to prevailing
wage rates under the Davis- Bacon Act. 3

EPA Expects Actual Cleanup Costs to Exceed Estimates by About $14 Million

As of September 30, 2000, EPA had expended about $212 million for various
cleanup and management support activities within “the box” area
of the Bunker Hill Superfund site. 4 About $101 million was for cleanup-
related activities for the populated and nonpopulated areas not covered by
the EPA/ state agreement and therefore not included in the 1995 estimate.
These activities included the study and design of cleanup activities,
emergency removals of contaminated materials, enforcement of responsible
party cleanup activities, and indirect management support. The remaining
$111 million was expended to accomplish cleanup work included in the 1995
agreement. EPA and the state of Idaho expect that the cleanup work covered
by the agreement will be completed by about the end of 2002, at a projected
final cost of about $140 million- or about $14 million higher than the $126
million estimate. (See enc. I for a comparison of Bunker Hill's cleanup
costs to those of other Superfund sites.) EPA expects most of the
anticipated $14 million cost increase to be offset by about $11 million in
settlement funds received from responsible parties. In addition, Idaho has
informally agreed to increase its contributions to the EPA/ state agreement
to cover 10 percent of the remaining $3 million.

2 According to the American Society of Civil Engineers, it is common
practice to add 20 percent or more to the estimated probable total project
cost at the completion of the study and report phase (prior to remedial
design). In addition, larger or more complex projects sometimes require
higher contingencies. 3 The Davis- Bacon Act, enacted in 1931, and related
legislation require employers on federally funded construction

projects valued at more than $2, 000, or on federally assisted projects, to
pay their workers, at a minimum, wages that the Secretary of Labor has
determined to be “prevailing” for corresponding classes of
workers on similar projects in the same locality. 4 In addition to the
cleanup costs incurred by EPA and the state of Idaho, responsible parties
and others, including

the U. S. Department of Justice, the Bureau of Mines, and the Agency for
Toxic Substances and Disease Registry, have incurred costs related to the
cleanup of the Bunker Hill site.

GAO- 01- 431R Bunker Hill Superfund Site 5 According to our analysis of the
component cleanup costs incurred to date and EPA's

estimates of the cleanup activities yet to be completed, the $14 million
cost increase is the result of several factors.

First, according to EPA officials, many cleanup areas that require
“capping”

(covering contaminated areas with a layer of soil or other material) were
thought to be within the mining companies' area of responsibility at the
time the EPA/ state agreement was signed. Subsequent to signing the
agreement, EPA and the state identified areas needing capping that were not
within the mining companies' area of responsibility and added them to the
components in the EPA/ state agreement. In addition, because of different
property uses, the type of cap required for many of these added areas will
be changed from a 6- inch layer of gravel to a more costly 24- inch layer of
gravel, asphalt, or concrete.

Second, EPA expects greater- than- anticipated costs for the maintenance and
security of the site overall. For example, in an effort to complete the
cleanup work quickly, EPA and the state directed the cleanup contractors to
work during winter conditions, thus increasing road maintenance needs in the
winter. Also, heightened vandalism and trespassing concerns have increased
security costs.

Finally, component cleanup work near completion is expected to cost about $6
million more than was originally estimated primarily because more
contaminated material had to be removed than anticipated. The component
cleanup work is discussed in more detail under the following section heading
of this letter.

In addition to the estimated $140 million that will be expended to implement
the 1995 EPA/ state agreement, EPA anticipates significant expenditures to
upgrade and operate the existing water treatment plant. EPA and the state of
Idaho took over the site's water treatment plant in November 1994 after the
mining company that owned and operated the plant went bankrupt. The 1992
Record of Decision- which outlined the cleanup work that needed to be done
and was the basis of the April 1995 agreement- did not consider owning and
operating the water treatment plant. Thus, such costs were not included in
the remedial investigation and feasibility study process. However, after
taking over the treatment plant's operation, EPA and the state recognized
that they would incur some costs in operating the plant, so they included
estimated costs in the agreement for interim treatment plant operations
(until the cleanup work under the agreement was completed). In March 2001,
EPA completed a 2-ï¿½- year- long remedial investigation and feasibility study
for the treatment plant that estimated necessary remedial action costs of
$16 million to $33 million and 30- year operating costs of $26 million to
$37 million. Estimated remedial actions include (1) decreasing the amount of
water needing treatment by reducing water flows through the Bunker Hill
Mine, (2) replacing and upgrading plant facilities (which are at the end of
their useful life), and (3) constructing new areas for sludge disposal.
Under EPA regulations, EPA and the state share the cost of operating the
water treatment plant. EPA is responsible for up to 10 years of water
treatment before the state takes over operation and maintenance
responsibilities. EPA expects to amend the 1992 Record of Decision for the
water treatment plant work by about

GAO- 01- 431R Bunker Hill Superfund Site 6 the end of 2001 and will require
an amended EPA/ state agreement before

implementing the work. Finally, additional cleanup costs may be incurred if
the cleanup strategies employed throughout the site under the EPA/ state
agreement ultimately do not improve surface and groundwater quality to the
levels outlined in the 1992 Record of Decision. However, according to EPA
officials, this determination cannot be made until all cleanup activities
have been completed and the site's environment has been allowed to
stabilize. EPA officials said that within 5 years, EPA and the state of
Idaho would evaluate whether additional remedial actions are needed.

Component Cost Increases Are Primarily Due to Underestimated Contamination
and Cleanup Complexity

After reaching agreement in 1995 for cleaning up the nonpopulated areas, EPA
and the state of Idaho began the remedial design phase, including the
development of technical drawings and specifications for the cleanup. Using
these specifications, EPA negotiated with and hired contractors to conduct
the cleanup work for a majority of the cleanup components. 5 These
components include the demolition of industrial complex structures, removal
of contaminated soils in gulches and creeks, revegetation of hillsides, and
wastewater treatment. For the implemented components, the projected final
costs range from $4.7 million less to $6.1 million more than the original
estimates, with a net increase of about $6 million, as shown in table 1.

Table 1: Comparison Between Component Contract Estimates and Projected
Completion Estimates for the Bunker Hill Site

Dollars in millions

Components a Component contract estimates Projected

completion estimates Expected increase or decrease b

Overlapping work area I:

Industrial Complex Government Gulch Magnet Gulch Bunker Creek

$43.6 $38.9 ($ 4.7)

Overlapping work area II:

Central Impoundment Area Smelterville Flats

37.2 43.3 6. 1 Milo Creek 3. 8 6.4 2. 5 Hillsides 8.9 9. 2 0.3 Interim water
treatment 4.4 6. 3 1.8

Total $97.9 $104. 1 $6.1

a Some components are grouped because negotiated cleanup contracts often
involved work in more than one component area. b Totals may not add because
of rounding.

Source: GAO's analysis of EPA's data.

5 Contractors have not yet been hired to implement all of the projected
cleanup work in the EPA/ state agreement.

GAO- 01- 431R Bunker Hill Superfund Site 7 Completion costs for the work
area encompassing the Industrial Complex,

Government Gulch, Magnet Gulch, and Bunker Creek areas are expected to be a
net $4.7 million less than the negotiated contract estimates. A cost
reduction of $11.5 million was achieved when a large contractor increased
the efficiency of its industrial complex work in response to a set of
financial incentives. On the other hand, a cost increase of $6.8 million for
this component resulted when higher- than- expected quantities of
contaminated soils were encountered in both gulches and in Bunker Creek and
when adverse weather affected the flow of work, as described below:

The quantity of contaminated soil removed was over 30 percent more than the
amount in the contract estimate.

Because of excessive rains, the contractor conducted more erosion control
measures than anticipated in the contract estimate.

A flood caused the recontamination of some areas around Bunker Creek that
had just been cleaned, thus requiring some areas to be recleaned.

Because of increases in material handling and weather delays, crews worked
overtime to complete the work on schedule.

The net effect of these events was a decrease of $4.7 million for the
projected cost of this work area ($ 11.5 million, saved as a result of new
contractor incentives, less the $6.8 million in cost increases).

Completion costs for the Central Impoundment and Smelterville Flats areas
are expected to be $6.1 million more than the negotiated contract estimates.
The cost increase is due primarily to an increase in dewatering (material
drying) efforts and a state- requested change in the grading design. To
ensure adequate compaction, material located several feet below the
groundwater level needed to be dewatered prior to disposal in the Central
Impoundment Area, as described below:

Unanticipated dewatering costs resulted when the original plan for disposing
of the extracted water had to be changed. The negotiated contract estimate
assumed that the extracted water was of a quality that would allow for its
discharge directly into the nearby South Fork of the Coeur d'Alene River.
However, the state of Idaho determined that the contaminant level of the
extracted water was greater than what was allowed for direct discharge into
the river. Thus, the extracted water had to be stored in specially
constructed ponds that allowed the extracted water to slowly infiltrate back
into the ground.

Increased dewatering costs also resulted from the additional handling of the
excavated materials in the Central Impoundment Area. To ensure adequate
compaction, the material needed to be thoroughly dried by fluffing and
pushing it into thin layers prior to final grading.

GAO- 01- 431R Bunker Hill Superfund Site 8

Increased grading costs resulted from changes in the site grading design.
After the work began, the state of Idaho requested that the grading of the
Central Impoundment Area be changed so that the area could accommodate a
golf course in the future. According to Idaho officials, this change would
enhance the area's potential use in an economically depressed area.

The completion costs for the Milo Creek component are expected to be $2.5
million more than the original estimate. The cost increase is due primarily
to flooding (a different storm from the one that flooded the Bunker Creek
area), which recontaminated areas that had already been cleaned and
destroyed the existing storm water control infrastructure. An entirely new
storm water control system with sufficient capacity to handle floods had to
be constructed.

Finally, while the difference in dollars is less than $2 million, the
interim water treatment component is expected to cost $1.8 million, or 41
percent, more than the contract estimate owing to the replacement of the
main water line to the treatment plant. After the main water line- the line
that carries water from the Bunker Hill Mine to the Central Treatment Plant-
became clogged, EPA determined that replacing the line would be cheaper than
repairing it because of the water line's age of almost 30 years and
location.

Agency Comments

We provided EPA and the state of Idaho with a draft of this report for
review and comment. Both EPA and the state of Idaho agreed with the
information contained in the report and provided technical comments, which
we incorporated into the report as appropriate.

Scope and Methodology

Our review focused on the 21- square- mile Bunker Hill area, known as
“the box,” located in the center of the 1,500- square- mile
Coeur d'Alene River Basin in northern Idaho. We performed our work at EPA's
Region 10 office in Seattle, Washington, and the Corps of Engineer's project
office (EPA's general contractor for the cleanup) in Kellogg, Idaho. In
addition, we obtained data from Idaho's Department of Environmental Quality
in Boise, Idaho.

To determine actual and estimated costs for “the box” as of
September 30, 2000, we obtained and analyzed cost data from EPA's (1)
Integrated Financial Management System on the type and amount of actual
spending and (2) “SCORPIO” system on indirect costs. In
addition, we obtained and analyzed various documents associated with the
cleanup, including the two records of decision, the EPA/ state agreement,
negotiated contracts for cleanup work, and the Corps of Engineer's Project
Control Summary Report. We also conducted site visits to familiarize
ourselves with the site and the completed work.

To determine the reasons for differences between actual costs and estimates,
we obtained and analyzed documents relating to the changes to the original
negotiated

GAO- 01- 431R Bunker Hill Superfund Site 9 contract amounts for those work
areas with material differences (defined as $2

million or more). We also interviewed officials from EPA, the Corps of
Engineers, and Idaho's Department of Environmental Quality to discuss
changes from estimates.

- - - - If you have any questions about this report, please contact me at
(202) 512- 3841. Other key contributors to this report were Keith Oleson and
Ruth Anne Decker.

David G. Wood Director, Natural Resources

and Environment Enclosure

GAO- 01- 431R Bunker Hill Superfund Site 10

List of Congressional Requesters

The Honorable Larry Craig United States Senate

The Honorable Mike Crapo United States Senate

The Honorable C. L. “Butch” Otter House of Representatives

Enclosure I

GAO- 01- 431R Bunker Hill Superfund Site 11

Comparison of Bunker Hill's Categorized Costs to Those of Other Superfund
Sites

To provide some perspective on Bunker Hill's cleanup costs, we compared the
ratio of three cost categories for Bunker Hill with the ratios experienced
by other Superfund sites that we previously reviewed- Raymark in Stratford,
Connecticut; Sharon Steel in Midvale, Utah; United Creosoting in Conroe,
Texas; and NL Industries in Granite City, Illinois. 6 The three cost
categories are “actual cleanup” (remedial and removal actions);

“study and design;” and “other,” which includes both
the Environmental Protection Agency's (EPA) direct and indirect support
costs. Direct support costs include enforcement, oversight, remedial
support, general administrative management, and research and development
costs. Indirect support costs are overhead costs that EPA headquarters
allocates to all Superfund sites. 7

As shown in figure 1, as of September 30, 2000, about 68 percent of EPA's
Bunker Hill costs were devoted to actual cleanup activities, about 9 percent
went toward study and design activities, and about 23 percent went to other
activities (17 percent for direct support and 6 percent for indirect
support).

Figure 1: Categorized Costs for Bunker Hill as of September 30, 2000

Source: GAO's analysis of EPA's data.

The 68 percent for actual cleanup costs is lower than that experienced by
the other Superfund sites we recently reviewed. The percentage of costs
devoted to actual cleanup at the other Superfund sites ranged from 74
percent at Sharon Steel to 86

6 See Superfund: Analysis of Costs at Five Superfund Sites (GAO/ RCED- 00-
22, Jan. 28, 2000). 7 To comply with new cost accounting standards issued by
the Federal Accounting Standards Advisory Board, EPA

began using a new methodology for allocating indirect support costs to
Superfund sites during our review. Under this new methodology, indirect
costs increased from about $10 million to $57 million, raising cleanup costs
as of September 30, 2000, from about $165 million to $212 million. However,
to provide a meaningful comparison, we used the old methodology to determine
the amount of indirect costs and compute the cost ratios for Bunker Hill.

23% Other (EPA direct and indirect support)

? 9%

Study/ design 68% ?

Actual cleanup

Enclosure I

GAO- 01- 431R Bunker Hill Superfund Site 12 percent at NL Industries, as
shown in table 2. 8 According to EPA, Bunker Hill's actual

cleanup cost ratio is lower than that of the other Superfund sites because
EPA has incurred significant enforcement and oversight costs related to the
work performed by the responsible parties in both the populated and
nonpopulated areas of the site. Such enforcement and oversight costs are
included in the other cost category. Thus, the impact is a lower ratio for
actual cleanup costs and a higher ratio for Bunker Hill's other costs when
compared with those of other Superfund sites.

Table 2: Comparison Between Bunker Hill's Categorized Costs and Those of
Other Superfund Sites Categorized costs under old indirect cost allocation
method Cost categories a Bunker Hill

(13,440 acres) Raymark (33 acres) Sharon Steel

(570 acres) United Creosoting (100 acres) NL Industries

(16 acres)

Actual cleanup (remedial & removal actions) 68% 75% 74% 85% 86%

Study/ design 9% 11% 14% 8% 7% Other (EPA direct and indirect support) b 23%
14% 13% 7% 8%

a Bunker Hill's costs are those incurred as of September 30, 2000. Raymark's
costs are those incurred for the industrial site. (Raymark had seven other
work areas surrounding the site that were not completed at the time of our
previous review.)

b “Other” includes (1) directly related EPA support and
management, site assessments, enforcement, oversight of responsible parties,
research and development, lab analysis, and technical assistance grants and
(2) indirectly related EPA support and management costs consisting of EPA's
headquarters costs that are allocated among all Superfund sites.

Note: Percentages may not add because of rounding. Source: GAO's analysis of
EPA's data.

According to EPA, Bunker Hill's large size and complexity resulted in high
costs for oversight activities and negotiating settlements. Therefore, the
23 percent shown for Bunker Hill's “other” category is larger
than the percentages shown for the other sites.

(160542) 8 Although the fifth site, Newmark, which is located in San
Bernardino, California, had 53 percent of its total costs devoted to actual
cleanup, the cleanup was only half- complete at the time of our previous
review and, thus, was excluded from our comparison.
*** End of document ***