Superfund: Information on the Program's Funding and Status (Letter
Report, 10/29/1999, GAO/RCED-00-25).

Pursuant to a congressional request, GAO provided information on the
Superfund program, focusing on the: (1) 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
the Environmental Protection Agency (EPA) for Superfund activities; (2)
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) cleanup status of the 640 nonfederal sites, as of April 1999, and
the estimated total and annual costs to complete cleanups of these
sites.

GAO noted that: (1) taxes paid into the Superfund trust fund totalled
about $13.5 billion from 1981 through 1998, and the unappropriated
balance in the Superfund trust fund was estimated to be $1.4 billion at
the end of fiscal year (FY) 1999; (2) a total of $940 million in program
funds was also deobligated for use on other Superfund projects for FY
1994 through FY 1999, but this total is not included in the
unappropriated trust fund balance; (3) expenditures from the trust fund
totalled $14.7 billion from FY 1987 through FY 1998, the most recent
year for which these data are available; (4) 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; (5) during the FY 1995 through FY
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; (6) from 1980 through
1998, responsible parties' total costs for cleanup activities at
National Priorities List sites was an estimated $15.5 billion; (7) about
17 percent of these costs occurred after the authority for Superfund
taxes expired in December 1995; (8) 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; (9) 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; (10) GAO estimated that cleanups will be
completed at 85 percent of the sites by the end of calendar year 2008;
(11) the remainder will not be completed until well after 2008; (12) GAO
estimated, in total, it will cost between $8.2 billion and $11.7 billion
more than already expended to clean up the 640 nonfederal sites; (13)
GAO's 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;
and (14) GAO also estimated that if EPA is to finish cleaning up 85
percent of the 640 sites by the end of FY 2008, its costs will average
$875 million annually through 2008.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-00-25
     TITLE:  Superfund: Information on the Program's Funding and Status
      DATE:  10/29/1999
   SUBJECT:  Environmental monitoring
	     Pollution control
	     Waste disposal
	     Environmental policies
	     Liability (legal)
	     Hazardous substances
	     Trust funds
	     Funds management
IDENTIFIER:  Superfund Program
	     EPA National Priorities List

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Cover
================================================================ COVER

Report to Congressional Requesters

October 1999

SUPERFUND - INFORMATION ON THE
PROGRAM'S FUNDING
AND STATUS

GAO/RCED-00-25

Superfund

(160494)

Abbreviations
=============================================================== ABBREV

  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

Letter
=============================================================== LETTER

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 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. 

   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

  -- Taxes paid into the Superfund trust fund totaled about $13.5
     billion from 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 sites\1 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 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. 

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

   BACKGROUND
------------------------------------------------------------ Letter :2

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 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. 

   STATUS OF THE SUPERFUND
   PROGRAM'S FUNDING AND
   EXPENDITURES
------------------------------------------------------------ Letter :3

Funding for the Superfund program is derived from taxes and other
revenues deposited in the Superfund trust fund and appropriations
made available from general revenues.  In total about $13.5 billion
in taxes was collected from 1981 through 1998.  Although the
authority for these taxes expired in December 1995, some taxes
continue 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.  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        $21     $40     $35     $38     $41      $2    $419    $503    $595
 and
 petrole
 um
Certain      107     204     196     224     233      13     216     196     288
 chemica
 ls
Corporat      \a      \a      \a      \a      \a      \a     196     313     292
 e
 environ
 mental
================================================================================
Annual      $128    $244    $230    $261    $273     $15    $831  $1,011  $1,175
 total
================================================================================
Cumulati    $128    $372    $602    $863  $1,136  $1,151  $1,982  $2,993  $4,168
 ve
 total
--------------------------------------------------------------------------------
                              (Dollars in millions)

                                       Fiscal year
          ----------------------------------------------------------------------
Tax         1990    1991    1992    1993    1994    1995    1996    1997    1998
--------  ------  ------  ------  ------  ------  ------  ------  ------  ------
Crude       $572    $547    $550    $569    $557    $576    $160      $1    $(3)
 and
 petrole
 um
Certain      246     262     268     256     250     291      94       7       2
 chemica
 ls
Corporat     461     591     380     886     653     612     382      68      79
 e
 environ
 mental
================================================================================
Annual    $1,279  $1,401  $1,197  $1,711  $1,459  $1,479    $636     $76     $79
 total
Cumulati  $5,447  $6,848  $8,045  $9,757  $11,21  $12,69  $13,33  $13,40  $13,48
 ve                                            6       5       1       7       6
 total
--------------------------------------------------------------------------------
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, 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 End of Fiscal
                               Year 1999

                                              Estimate for fiscal year
Unappropriated balance                                            1999
----------------------------------------  ----------------------------
Unappropriated balance at start of                      $2,056,248,000
 fiscal year
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                           233,982,377\a
Recoveries                                               307,082,270\a
Fines and penalties                                        4,096,417\a
Tax revenues                                              18,866,431\a
======================================================================
Total revenues                                          $564,027,495\a
======================================================================
Unappropriated balance at end of fiscal                 $1,445,275,495
 year
----------------------------------------------------------------------
\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 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. 

   Figure 1:  Superfund
   Expenditures for Fiscal Years
   1996-98, in Three Categories.

   (See figure in printed
   edition.)

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. 

                                Table 3
                
                Superfund Appropriations, Transfers, or
                 Allocations to Federal Agencies Other
                   Than EPA for Fiscal Years 1995-98

                         (Dollars in millions)

                                         Fiscal Year
                        ----------------------------------------------
Agency                        1995        1996        1997        1998
----------------------  ----------  ----------  ----------  ----------
Department of Justice        $32.2       $30.0       $30.0       $29.7
 (enforcement)

Other federal agencies
----------------------------------------------------------------------
Agency for Toxic              68.8        59.0        64.0        74.0
 Substances and
 Disease Registry
National Institute of         58.7        50.5        53.3        58.0
 Environmental Health
 Science
U.S. Coast Guard               4.8         4.4         4.8         4.8
National Oceanic and           2.2         2.0         2.2         2.4
 Atmospheric
 Administration
Federal Emergency              0.9         1.1         1.1         1.1
 Management Agency
Department of the              0.6         0.7         0.9         0.9
 Interior
Occupational Safety            0.3         0.3         0.5         0.7
 and Health
 Administration
======================================================================
Total, other federal        $136.3      $118.0      $127.0      $141.9
 agencies
======================================================================
Total                       $168.5      $148.0      $157.0      $171.6
----------------------------------------------------------------------
Source:  EPA's Budget Office. 

--------------------
\2 EPA's Fiscal Year 1998 Financial Statement, EPA, Office of the
Inspector General. 

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

\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). 

   RESPONSIBLE PARTIES' CLEANUP
   AND TRANSACTION COSTS
------------------------------------------------------------ Letter :4

According to EPA's estimates, the costs of site cleanup for work
performed by responsible parties totaled approximately $15.5 billion
from 1980, the year of CERCLA's enactment, through 1998.  During this
same period, EPA 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
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)

                               Responsible   EPA's costs
                                  parties'     recovered
                                 estimated          from
                                   cleanup   responsible
Time period                          costs       parties         Total
----------------------------  ------------  ------------  ------------
Before expiration of                 $11.1          $1.7         $12.8
 Superfund tax authority
 (1980-Dec. 1995)
After expiration of                    1.9           0.7           2.7
 Superfund tax authority
 (Jan. 1996-Sept. 1998)
======================================================================
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 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 Costs

                         (Dollars in billions)

                         Author of study/study's estimated percentage
                        ----------------------------------------------
                                 CBO               RAND        GAO
                        ----------------------  ----------  ----------
Time period                    17%         20%         32%         33%
----------------------  ----------  ----------  ----------  ----------
Before expiration of          $2.6        $3.2        $6.0        $6.3
 Superfund tax
 authority (1980-Dec.
 1995)
After expiration of            0.6         0.7         1.3         1.3
 Superfund tax
 authority (Jan. 1996-
 Sept. 1998)
======================================================================
Total                         $3.2        $3.9        $7.3        $7.6
----------------------------------------------------------------------
Source:  GAO's analysis of data from EPA. 

--------------------
\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. 

\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). 

   STATUS OF AND COST TO COMPLETE
   CLEANUPS OF 640 NONFEDERAL
   SITES
------------------------------------------------------------ Letter :5

As of mid-April 1999, EPA had 640 nonfederal NPL sites where the
construction of a cleanup remedy, such as a removal of contaminated
soil, had not been completed.  Of these sites, 59 percent, or 376,
were in the 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 Mid-
                               April 1999

                             Status of work in phase
                        ----------------------------------
                                                                 Total
Cleanup phase              Planned     Ongoing   Completed       sites
----------------------  ----------  ----------  ----------  ----------
Remedial investigation          54         238          84         376
 and feasibility study
Remedial design                 \a         107          26         133
Remedial action                 \a         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 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

   (See figure in printed
   edition.)

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. 

                                Table 7
                
                 Estimated Total Costs Needed by EPA to
                   Complete Cleanups at the 640 Sites

                         (Dollars in millions)

                                Estimated total cleanup and support
                                        costs for 640 sites
                              ----------------------------------------
                               High end of    Low end of
Type of cost                         range         range      Midpoint
----------------------------  ------------  ------------  ------------
Contractor cleanup                $3,111.0      $4,680.3      $3,895.6
Site-specific support\a            1,169.7       1,759.8       1,464.7
Subtotal                          $4,280.7      $6,440.1      $5,360.3
Non-site-specific support\b        2,641.2       3,973.6       3,307.4
Subtotal                          $6,992.0     $10,413.7      $8,667.7
Additional operation and           1,280.0       1,280.0       1,280.0
 maintenance\c
======================================================================
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. 

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. 

--------------------
\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. 

   AGENCY COMMENTS AND OUR
   EVALUATION
------------------------------------------------------------ Letter :6

We provided a copy of a draft of this report to EPA for its review
and comment.  EPA's comments are presented in appendix IV.  EPA
disagreed 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 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. 

---------------------------------------------------------- Letter :6.1

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. 

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

SUPERFUND EXPENDITURES FOR FISCAL
YEARS 1987-98
=========================================================== Appendix I

                         (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
----------------------------------------------------------------------

COST ASSUMPTIONS
========================================================== Appendix II

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.

  -- 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
     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. 

--------------------
\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. 

\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). 

ESTIMATED ANNUAL COSTS TO COMPLETE
85 PERCENT OF THE 640 NPL SITES,
OR 1,279 OPERABLE UNITS, BY 2008
========================================================= Appendix III

                               (Dollars in millions)

            Annual costs, assuming completion of 85 percent of OUs by 2008
    ------------------------------------------------------------------------------
                                  Subtotal
                                       for
Fi                                 cleanup      Non-  Subtotal
sc            Contract     Site-       and     site-       for
al   Percent        or  specific     site-  specific   cleanup
ye  of total   cleanup   support  specific   support       and               Total
ar     costs     costs     costs   support     costs   support       O&M     costs
--  --------  --------  --------  --------  --------  --------  --------  --------
20       9.4    $366.2    $137.7    $503.9    $310.9    $814.8     $12.0    $826.8
 00
20       9.4     366.2     137.7     503.9     310.9     814.8      24.0     838.8
 01
20       9.4     366.2     137.7     503.9     310.9     814.8      36.0     850.8
 02
20       9.4     366.2     137.7     503.9     310.9     814.8      48.0     862.8
 03
20       9.4     366.2     137.7     503.9     310.9     814.8      60.0     874.8
 04
20       9.4     366.2     137.7     503.9     310.9     814.8      72.0     886.8
 05
20       9.4     366.2     137.7     503.9     310.9     814.8      84.0     898.8
 06
20       9.4     366.2     137.7     503.9     310.9     814.8      96.0     910.8
 07
20       9.4     366.2     137.7     503.9     310.9     814.8     108.0     922.8
 08
20       7.7     300.0     112.8     412.7     254.7     667.4     118.0     785.4
 09
20       7.7     300.0     112.8     412.7     254.7     667.4     116.0     783.4
 10
20        \a        \a        \a        \a        \a        \a     104.0     104.0
 11
20        \a        \a        \a        \a        \a        \a      92.0      92.0
 12
20        \a        \a        \a        \a        \a        \a      80.0      80.0
 13
20        \a        \a        \a        \a        \a        \a      68.0      68.0
 14
20        \a        \a        \a        \a        \a        \a      56.0      56.0
 15
20        \a        \a        \a        \a        \a        \a      44.0      44.0
 16
20        \a        \a        \a        \a        \a        \a      32.0      32.0
 17
20        \a        \a        \a        \a        \a        \a      20.0      20.0
 18
20        \a        \a        \a        \a        \a        \a      10.0      10.0
 19
==================================================================================
To       100  $3,895.6  $1,464.7  $5,360.3  $3,307.4  $8,667.7  $1,280.0  $9,947.7
 t
 a
 l
----------------------------------------------------------------------------------
Note:  Totals may not add because of rounding. 

\a Cleanups completed except for O&M. 

Source:  GAO's analysis of estimates by EPA. 

(See figure in printed edition.)Appendix IV
COMMENTS FROM THE ENVIRONMENTAL
PROTECTION AGENCY
========================================================= Appendix III

(See figure in printed edition.)

(See figure in printed edition.)

SCOPE AND METHODOLOGY
=========================================================== Appendix V

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. 

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. 

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

\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). 

KEY CONTRIBUTORS TO THIS REPORT
========================================================== Appendix VI

RESOURCES, COMMUNITY, AND ECONOMIC
DEVELOPMENT DIVISION, WASHINGTON,
D.C. 

Allen Rogers, Director, Design, Methodology, and Technical Assistance
Group

Karen L.  Kemper, Evaluator-in-Charge

John Johnson, Senior Evaluator

CHICAGO OFFICE

John Wanska, Assistant Director

Rosemary Torres-Lerma, Senior Evaluator

RALEIGH OFFICE

Jim Hayward, Staff Evaluator

OFFICE OF GENERAL COUNSEL

Richard Johnson, Senior Attorney

*** End of document. ***