Federal Facilities: Consistent Relative Risk Evaluations Needed for
Prioritizing Cleanups (Letter Report, 06/07/96, GAO/RCED-96-150).

Pursuant to a congressional request, GAO reviewed how priorities are
being set for hazardous waste cleanups, focusing on: (1) whether the
Superfund program is identifying the highest-priority cleanup sites; and
(2) the Department of Defense (DOD), Department of Energy (DOE), and the
Department of the Interior approaches for ranking risks and prioritizing
sites for cleanup.

GAO found that: (1) the Superfund program does not completely and
consistently identify the federal facilities presenting the greatest
risks to public health and the environment; (2) without a complete
inventory of contaminated sites, adequate data on the risks at these
sites, and consistent policy guidance, agencies cannot fully prioritize
cleanup activities; (3) the National Priorities List (NPL) does not
include all eligible contaminated sites and the Hazard Ranking System
does not provide sufficient information to rank contaminated facilities
on the basis of risk; (4) federal agencies responsible for cleanups do
not use a consistent approach to assess relative risk; (5) to help set
cleanup priorities and make funding decisions, DOD developed a
risk-ranking tool to categorize contaminated sites; (6) DOE uses a
qualitative, facility-based approach to evaluate contaminated sites and
prioritize cleanups; (7) Interior uses a centralized priority-setting
mechanism in the later stages of the Superfund process to rank its
contaminated facilities; and (8) while individual agencies use their own
risk-assessment processes, it would be more cost-effective for agencies
to use a consistent, national approach to rank risks and identify
high-priority sites.

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

 REPORTNUM:  RCED-96-150
     TITLE:  Federal Facilities: Consistent Relative Risk Evaluations 
             Needed for Prioritizing Cleanups
      DATE:  06/07/96
   SUBJECT:  Federal facilities
             Site selection
             Environment evaluation
             Environmental monitoring
             Environmental policies
             Radioactive pollution
             Waste disposal
             Hazardous substances
             Waste management
             Interagency relations
IDENTIFIER:  Superfund Program
             EPA National Priorities List
             DOD Environmental Restoration Program
             DOE Environmental Management Program
             Central Hazardous Materials Fund
             EPA Hazard Ranking System
             DOD Base Realignment and Closure Account
             
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Cover
================================================================ COVER


Report to the Chairman, Committee on Government Reform and Oversight,
House of Representatives

June 1996

FEDERAL FACILITIES - CONSISTENT
RELATIVE RISK EVALUATIONS NEEDED
FOR PRIORITIZING CLEANUPS

GAO/RCED-96-150

Federal Facilities

(160296)


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

  CERCLA - Comprehensive Environmental Response, Compensation, and
     Liability Act
  DOD - Department of Defense
  EPA - Environmental Protection Agency
  GAO - General Accounting Office
  NPL - National Priorities List
  NSIAD - National Security and International Affairs Division
  RCED - Resources, Community, and Economic Development Division
  RCRA - Resource Conservation and Recovery Act

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


B-271787

June 7, 1996

The Honorable William F.  Clinger, Jr.
Chairman, Committee on Government
 Reform and Oversight
House of Representatives

Dear Mr.  Chairman: 

The number of federal facilities that will require hazardous waste
cleanups is growing, and the cost of these cleanups may rise to
nearly $400 billion.\1 These large expenditures highlight the
importance of targeting the available public funds to the
highest-priority cleanups. 

Both the Environmental Protection Agency (EPA) and federal agencies
that own or use contaminated property help assign priorities for
cleanups.  EPA administers the Superfund program, identifying
seriously contaminated facilities for cleanup under Superfund's
regulations.  Cleanups of federal facilities may also be subject to
other federal or state laws.  EPA and the responsible federal
agencies--chiefly the departments of Defense, Energy, and the
Interior, which have the largest cleanup problems--jointly set
priorities for cleaning up their facilities under the Superfund
program through interagency agreements.  In addition, the responsible
federal agencies influence priorities for all cleanups--Superfund and
non-Superfund--through their planning and budgeting processes. 
Concerned about how well priorities are being set for cleaning up
federal facilities, you asked us to assess (1) whether Superfund is
identifying the highest-priority federal sites for cleanup and (2)
what progress is being made by the departments of Defense, Energy,
and the Interior in establishing approaches for ranking risks and
setting priorities for cleaning up their facilities. 


--------------------
\1 This figure includes the Department of Energy's high-end estimate
of the costs of cleanup, waste treatment, storage, and disposal
activities (see app.  II). 


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

The Superfund program does not fully and consistently identify the
most contaminated federal facilities as the highest priorities for
cleanups for a number of reasons.  First, some federal agencies have
not finished identifying the universe of contaminated facilities and
preliminarily assessing the extent of their contamination.  In
addition, EPA's regions have not completed their evaluations of the
facilities that the agencies have reported to them, and EPA
headquarters has not developed guidance to ensure that the regions
consistently evaluate the most severely contaminated facilities
first.  According to EPA regional officials, the agency is
constrained in setting priorities for evaluation by limited resources
and by the poor quality of the data it receives from other federal
agencies.  Even after a region has evaluated a facility and
determined that it warrants inclusion on the National Priorities
List--EPA's list of the nation's highest priorities for further study
and possible cleanup--that facility may not be included if a state
does not agree to the listing or the facility is being cleaned up
under another legal authority.  Finally, EPA's evaluation is not
comprehensive enough to rank multiple contaminated sites at
individual facilities on the basis of relative risk. 

Federal agencies have made progress in establishing approaches for
ranking relative risks as an aid to setting priorities for cleanups. 
Both Defense and Energy have developed new priority-setting
approaches that consider the relative risks of sites, but neither has
fully compared the risks agencywide.  Defense's system does not
permit risk distinctions among many of its sites.  Energy has used
its approach primarily to set priorities among sites at individual
facilities.  Interior has developed a centralized process for setting
priorities among facilities on the National Priorities List, but its
individual bureaus remain responsible for setting priorities for the
studies and evaluations that precede listing.  Because the three
departments have independently developed different risk-ranking and
priority-setting approaches, interagency comparisons of risks are
difficult. 


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

Federal facilities have been contaminated with a wide range of
substances, including highly radioactive waste and toxic chemicals. 
As of April 1995, federal agencies had placed 2,070 facilities on the
federal facility docket, EPA's listing of the facilities awaiting
evaluation for possible cleanup.  EPA had placed 154 federal
facilities on the National Priorities List (NPL) (see table 1) and,
as of February 1996, had proposed another five facilities for
listing.  (For the status of the 2,070 facilities on the docket, see
app.  I.) EPA uses the NPL as an aid in determining which sites
warrant further investigation to assess public health and
environmental risks\2 and which sites merit cleanup. 



                                Table 1
                
                  Number of Federal Facilities on the
                 Docket as of April 1995 and on the NPL
                 as of February 1996, by Federal Agency

                                     Facilities on
Agency                                      docket   Facilities on NPL
------------------------------  ------------------  ------------------
Agriculture                                    148                   2
Defense                                        984                 127
Energy                                          90                  20
Interior                                       432                   2
Transportation                                 121                   1
All others                                     295                   2
======================================================================
Total                                        2,070                 154
----------------------------------------------------------------------
Source:  EPA. 

The Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA) of 1980, as amended, created the Superfund program to
govern cleanups of both private and federal hazardous waste sites. 
Cleanups of federal facilities are also subject to the Resource
Conservation and Recovery Act (RCRA) of 1976, as amended, which
governs, among other things, the treatment, storage, and disposal of
hazardous wastes.  This review focuses on the requirements that
CERCLA imposes upon federal facilities. 

The Superfund process for cleaning up federal facilities consists of
many steps involving both the responsible federal agencies and EPA. 
First, a responsible federal agency identifies a potentially
contaminated facility and reports it to EPA for listing on the
federal facilities docket.  The responsible agency then conducts a
preliminary assessment to gather data on the facility and performs a
site inspection, which may involve taking and analyzing samples, to
learn more about potential contamination.  An EPA region oversees the
agency's activities at each stage, and if the evidence indicates that
the facility is contaminated, EPA then decides when to evaluate the
facility to determine whether it qualifies for inclusion on the NPL. 
The evaluation scores the severity of the facility's contamination
using EPA's hazard ranking system.\3 Figure 1 depicts the stages in
the Superfund process leading to a facility's placement on the NPL. 

   Figure 1:  How Federal
   Facilities Get on the NPL

   (See figure in printed
   edition.)

Note:  Cleanup actions at sites that present an immediate danger to
the public health or welfare can occur at any time in this process. 

Source:  GAO's presentation of information from EPA. 

After EPA has placed a facility on the NPL, the responsible federal
agency is required, within 6 months, to begin a remedial
investigation to characterize the waste and a feasibility study to
evaluate the alternatives for cleaning up the facility.  With EPA's
oversight, the agency examines all the information gathered during
this process, selects a cleanup remedy, and prepares a record of
decision to document the analysis that led to the selection.  The
responsible agency must also enter into an interagency agreement\4
with EPA on a plan for cleaning up the facility.  Finally, the
responsible agency develops a detailed design and implements the
cleanup plan while EPA oversees the agency's implementation.  Figure
2 depicts the cleanup stages in the Superfund process. 

   Figure 2:  How Federal
   Facilities on the NPL Are
   Cleaned Up

   (See figure in printed
   edition.)

Note:  Cleanup actions at sites that present an immediate danger to
public health or welfare can occur at any time in this process. 

Source:  GAO's presentation of information from EPA. 

Although several federal agencies have significant numbers of
facilities on the federal facility docket (see table 1), the
departments of Defense and Energy have the largest budgets for
environmental restoration.  In comparison, Interior's cleanup program
is currently small, but it is expected to grow as the Department's
agencies--including the Bureau of Land Management, the Fish and
Wildlife Service, and the National Park Service--develop more
complete inventories of contaminated facilities, particularly
abandoned mines.  For fiscal year 1996, the appropriations for
hazardous waste cleanups at Defense, Energy, and Interior totaled
almost $4 billion.\5 (See table 2.)



                                Table 2
                
                 Funding for Hazardous Waste Cleanups,
                          Fiscal Years 1991-96

                         (Dollars in millions)

Fiscal year              Defense\a      Energy  Interior\b       Total
----------------------  ----------  ----------  ----------  ----------
1991                         1,373       1,185          59       2,617
1992                         1,681       1,379          70       3,130
1993                         2,128       1,830          64       4,022
1994                       2,490\c       1,802          65       4,357
1995                       2,105\c       1,643          69       3,817
1996                       2,093\c       1,785          73       3,951
======================================================================
Total                       11,870       9,624         400      21,894
----------------------------------------------------------------------
\a Includes amounts for the Defense Environmental Restoration
Account, which funds work at active Defense installations and
formerly used Defense sites, and the Base Realignment and Closure
Account, which includes some noncleanup funds related to closing
installations for fiscal years 1991 and 1992. 

\b Represents Interior's estimate for all activities carried out
under the Department's hazardous materials program, including
compliance and waste management. 

\c Does not include any reductions in funding that occurred during
the course of the budget year. 

Source:  Departments of Defense, Energy, and the Interior. 

The Federal Facilities Policy Group\6 estimates that the total cost
of cleaning up federal facilities could reach almost $400 billion
(see app.  II).  From the formal inception of federal environmental
cleanup programs through fiscal year 1996, the group reported that
federal agencies have budgeted nearly $54 billion for cleanups. 
According to the group, about two-thirds of the total budget has been
targeted for Energy facilities and includes amounts for ongoing waste
management. 

For the purposes of this report, we have defined a "site" as a
specific area of contamination and a "facility" as a geographically
contiguous area under an agency's ownership or control within which a
contaminated site or sites are located.  EPA generally includes all
contaminated sites at a federal facility--such as a military
installation--on the NPL.  Thus, a federal facility on the NPL may
contain from a few to hundreds of sites that require assessment and
possibly cleanup.\7

It is generally agreed that the magnitude of the risks to human
health posed by contamination at a federal facility should be a
primary factor in setting priorities for cleanups.  However,
according to the Federal Facilities Environmental Restoration
Dialogue Committee (a group composed of representatives from federal,
state, local, and tribal governments, as well as citizens' groups and
labor organizations), additional factors also warrant consideration. 
These include legal requirements; cost-effectiveness; the potential
future uses of decontaminated land; and other cultural, social, and
economic factors. 


--------------------
\2 As used in this report, risk refers to both the probability that
something will cause injury and the potential severity of that
injury. 

\3 The hazard ranking system evaluates the nature of the
contaminants, the pathways through which they can move (such as soil,
water, or air), and the likelihood that they may come into contact
with a receptor--for example, a person living nearby. 

\4 EPA may assess penalties for failure to comply with the terms and
schedules of the cleanup plan set forth in the agreement. 

\5 Amounts for the departments of Defense and Energy represent
funding for environmental restoration and cleanup efforts only and
not for waste management or environmental compliance activities. 

\6 The Federal Facilities Policy Group was convened by the Director
of the Office of Management and Budget and the Chair of the Council
on Environmental Quality to review the current status and future
course of environmental response and restoration at federal
facilities.  The group included officials from the departments of
Defense, Energy, Interior, and Agriculture; EPA; and others. 

\7 Because Interior's land holdings are so vast, EPA lists Interior's
sites rather than facilities on the NPL. 


   SUPERFUND PROCESS DOES NOT
   FULLY ESTABLISH CLEANUP
   PRIORITIES FOR FEDERAL
   FACILITIES
------------------------------------------------------------ Letter :3

The Superfund process does not fully and consistently identify for
possible cleanup the federal facilities presenting the greatest risks
to public health and the environment.  An incomplete inventory of
contaminated federal facilities and a backlog of unevaluated
facilities have limited the scope of priority-setting efforts. 
Furthermore, no national guidance ensures that EPA's regions use a
consistent approach in choosing which facilities to evaluate for
inclusion on the NPL from the backlog of facilities awaiting this
step.  Some facilities that qualify for inclusion are not being
listed, making listing an uncertain indicator of a facility's
relative risk.  In addition, EPA's evaluation process does not
produce enough information to rank sites on the basis of relative
risk. 


      PARTIAL INVENTORY,
      INCOMPLETE SITE ASSESSMENTS,
      AND LACK OF POLICY GUIDANCE
      HAMPER PRIORITY SETTING
---------------------------------------------------------- Letter :3.1

Agencies cannot fully set priorities without a complete inventory of
contaminated sites and adequate data on the risks at these sites.  As
we have reported in the past,\8 federal agencies have not yet
completed a comprehensive inventory of their potentially contaminated
sites.  Some agencies, such as Defense and Energy, have made
substantial progress toward completing their inventories, while
others, such as Interior, are still in the early stages of developing
theirs.  As of April 1995, Interior had 432 sites on the federal
facility docket, but a recent report\9 by the Federal Facilities
Policy Group estimates that Interior has 26,000 sites that may
require some cleanup.  The dimensions of Interior's future cleanup
responsibilities are uncertain.  Interior officials estimate that
only 1 or 2 percent of these sites may require major cleanup work. 
According to officials, the Department's legal liability for cleaning
up many sites has not been fully resolved. 

Interior officials told us that they are not planning to conduct a
comprehensive inventory of their potentially contaminated hazardous
waste sites, in part because they lack sufficient funding.  Instead,
they intend to rely on existing information, as well as on
discoveries made during the Department's regular activities, to
identify sites requiring cleanup.  In 1994, we reported on the
importance of a comprehensive federal site inventory\10 and
recommended, among other things, that the Congress amend CERCLA to
(1) require the agencies to submit plans for completing their
inventories of hazardous waste sites for EPA's review and approval
and (2) require EPA to report annually to the Congress on the
agencies' progress toward completing the inventories.  No action has
yet been taken on these recommendations. 

For many of the facilities and sites in their inventories, federal
agencies have not gathered sufficient data to set priorities for
further activities.  Information is incomplete for 1,040 of the 2,070
facilities listed on the federal facility docket.\11

For some, the agency has not completed the preliminary assessment or
site inspection; for others, the EPA region has not reviewed the
responsible federal agency's inspection or the site's status is
unknown.  As table 3 shows, 157 facilities have completed the early
assessment phases and are awaiting the final evaluation for inclusion
on the NPL.  At the current evaluation rate, this backlog could take
many years to clear.  According to EPA officials, the agency's budget
permits the agency to perform final evaluations for only five
facilities per year. 



                                Table 3
                
                Federal Facilities on the Docket Without
                 Final Site Assessment Decisions as of
                             February 1996

                          Awaiting            Awaiting
                          prelimin  Awaiting     final
                               ary      site       NPL    Status
                          assessme  inspecti  screenin  unknown\  Tota
Agency                          nt        on         g         a     l
------------------------  --------  --------  --------  --------  ----
Agriculture                     17        24         5        42    88
Defense                         84       138       119       222   563
Energy                           2         7         5        14    28
Interior                        18        37        16        57   128
Transportation                   2        21         3        10    36
All others                      35        13         9       140   197
======================================================================
Total                          158       240       157       485  1,04
                                                                     0
----------------------------------------------------------------------
\a The status of some facilities is unknown because the names in
EPA's evaluation records cannot always be reconciled with the names
in the federal facility docket. 

Source:  Comprehensive Environmental Response, Compensation, and
Liability Information System and EPA's federal facility docket. 

Despite the need for setting priorities to determine which sites in
the backlog to evaluate first for possible inclusion on the NPL, EPA
headquarters has not developed policy guidance to ensure that the
regions employ a consistent approach.  EPA has developed such
guidance for evaluating nonfederal NPL candidate sites but has not
extended its application to federal facilities.  Only 4 of EPA's 10
regions reported using such nonfederal guidance to help them
determine which federal facilities to evaluate first for possible
inclusion on the NPL.  In July 1993, we reported that EPA was not
evaluating federal facilities in a timely manner,\12 in part because
(1) it did not devote adequate resources to the task and (2) some
agencies were providing EPA with late or incomplete data.  Delays in
EPA's evaluation may postpone cleanups while responsible federal
agencies await EPA's decision on a facility's NPL status or may cause
rework after a facility has been listed.  These delays could increase
dangers to human health and the environment and raise costs.  Our
report recommended that EPA, in consultation with the regulated
agencies, develop a plan to address the backlog of unevaluated
federal facilities on the docket.  Such a plan, which could be used
to specify criteria for selecting the order in which facilities
should be evaluated for cleanup, has not been developed.  EPA
officials are concerned that the agency would not have the resources
to implement such a plan. 

EPA regional officials cited EPA's limited resources and poor data
from the responsible agencies as the main barriers to improving EPA's
ability to determine which sites to evaluate first.  Many regions
believed they did not have the staff resources or the funding needed
to adequately oversee the agencies' preliminary assessments and site
inspections.  In addition, 9 of EPA's 10 regional offices cited
inadequate data from other agencies on sites' risks as a significant
barrier to improving their own priority setting.  EPA officials said
that some federal agencies were slow to submit the results of their
investigations, the data were sometimes incomplete when submitted,
and EPA's guidance on data gathering was not being followed.  As a
result, some seriously contaminated facilities are not yet ready for
EPA's evaluation. 

To improve the quality and timeliness of the data it receives from
the regulated agencies, one EPA region reported making two
significant changes.  First, it dedicated a full-time position to
work exclusively with the agencies on assessment issues and answer
their questions.  Second, it trained the agencies' staff and
contractors to conduct preliminary assessments and site inspections. 
While the region believes these efforts have been very successful,
budget cuts may prevent it from continuing them. 


--------------------
\8 Federal Hazardous Waste Sites:  Opportunities for More
Cost-Effective Cleanups (GAO/RCED-95-188, May 9, 1995). 

\9 Improving Federal Facilities Cleanup (Oct.  1995). 

\10 Federal Facilities:  Agencies Slow to Define the Scope and Cost
of Hazardous Waste Site Cleanups (GAO/RCED-94-73, Apr.  15, 1994). 

\11 Of the remaining 1,030 facilities on the docket, EPA has placed
154 on the NPL and determined that 873 are not contaminated seriously
enough to be included on the NPL.  A cleanup remedy has been
constructed at eight facilities, five of which are still on the NPL
and three of which have been removed. 

\12 Superfund:  Backlog of Unevaluated Federal Facilities Slows
Cleanup Efforts (GAO/RCED-93-119, July 20, 1993). 


      THE NPL DOES NOT INCLUDE ALL
      ELIGIBLE FEDERAL FACILITIES
---------------------------------------------------------- Letter :3.2

The Congress and EPA have allowed the exclusion of certain federal
facilities from the NPL for various policy reasons.  Because of these
exclusions, some of the nation's most contaminated facilities do not
appear on the NPL.  Nine of EPA's 10 regional federal facility
cleanup coordinators\13 told us that some facilities in their regions
scored higher than the hazard ranking system's threshold but were not
placed on the NPL.  Reasons for these exclusions included a state's
not concurring with a listing or a facility's being cleaned up under
another authority. 

Until June 1995, EPA had the authority to include any qualifying
facility on the NPL.  In July 1995, legislation was enacted requiring
EPA, during fiscal year 1995, to seek a state's concurrence before
including a site on the NPL.  This provision, which effectively gave
governors the authority to veto EPA's listing decisions, may
significantly affect the consistency and comprehensiveness of the
NPL.  As of February 1996, EPA had sought state governors'
concurrence to list 14 federal facilities.  The governors refused to
concur with seven listings, approved four, and reached no decision on
three.  Furthermore, according to EPA officials, the impact of
requiring a state's concurrence is greater than these numbers would
indicate because EPA's regions will not move a facility forward in
the Superfund process if a governor's veto is expected.  EPA's 1996
appropriations language continues the requirement that EPA obtain a
state's concurrence for the remainder of the fiscal year or until
CERCLA is reauthorized. 

EPA's current policy is to include on the NPL federal facilities that
may be involved in hazardous waste cleanups regulated under RCRA.  In
establishing this policy, EPA argued that if the listing of such
facilities were deferred, very few facilities would be included on
the NPL.  According to EPA, most eligible facilities contain
hazardous waste units that are regulated under RCRA and therefore are
subject to its corrective action authorities.  Despite EPA's policy,
a regional official told us that if a RCRA corrective action is under
way at a federal facility, then the region may not pursue a listing
for that facility.  An EPA headquarters official acknowledged that a
site being cleaned up under RCRA will receive a low priority for
inclusion on the NPL.  Hence, in practice, the site may receive an
informal RCRA deferral. 

Similarly, according to an EPA regional official, a facility that is
already being cleaned up under Defense's Base Realignment and Closure
program will receive a low priority for inclusion on the NPL. 
Defense is closing or realigning over 400 installations. 


--------------------
\13 In this report, we have used the term "federal facility cleanup
coordinator" to refer to the EPA official who is responsible for
managing the federal facilities cleanup program in each regional
office.  The actual job title varies from office to office. 


      SCORING AND LISTING DO NOT
      PRODUCE ENOUGH INFORMATION
      TO RANK NPL SITES
---------------------------------------------------------- Letter :3.3

EPA's processes for scoring and listing do not produce enough
information to rank facilities or sites on the basis of risk.  When
EPA uses the hazard ranking system to determine whether a federal
facility should be included on the NPL, it typically evaluates only a
few major areas of contamination and does not score all contaminants
and pathways.  Because the system's evaluations are not
comprehensive, EPA cannot use its scores to compare the relative
severity of the contamination at NPL facilities. 

Generally, EPA places all contaminated portions of a federal facility
on the NPL.  While some of these facilities may contain hundreds of
individual sites whose contamination may vary widely in severity, the
sites are still designated as high priorities.  In our 1994 report on
setting priorities for cleanups at Defense,\14 we discussed the
problem of treating all sites at NPL facilities as high priorities
without considering how seriously they are contaminated, and we
recommended that the system for designating high-priority sites be
revised to reduce the number of such sites in Defense's high-priority
program.  As discussed below, Defense has established a system to
classify its sites into various risk categories. 


--------------------
\14 Environmental Cleanup:  Too Many High Priority Sites Impede DOD's
Program (GAO/NSIAD-94-133, Apr.  21, 1994). 


   FEDERAL AGENCIES RESPONSIBLE
   FOR CLEANUPS DO NOT USE A
   CONSISTENT APPROACH TO ASSESS
   RELATIVE RISK
------------------------------------------------------------ Letter :4

Both Defense and Energy have developed new approaches for setting
cleanup priorities, but neither agency has fully established
agencywide, risk-based funding priorities.  Defense has classified
most of its sites in one risk category without further refinement as
to rank.  Energy has used its new system primarily to rank sites at
individual facilities, rather than across many facilities or the
agency as a whole.  Interior has developed a centralized process for
setting priorities for NPL sites, but its bureaus set priorities
independently during the assessment stages that precede listing.  The
three departments have developed different risk-ranking and
priority-setting systems, making cross-agency comparisons of risks
and priorities difficult. 


      DEFENSE HAS DEVELOPED A
      RELATIVE RISK-RANKING
      PROCESS TO HELP SET
      PRIORITIES
---------------------------------------------------------- Letter :4.1

To improve its priority-setting processes, Defense introduced
evaluations of sites' relative risks in 1994 as a key element in
decisions about which of its contaminated sites should be cleaned up
first.  Defense's Relative Risk Site Evaluation Framework allows the
agency to place a potentially contaminated site within the Defense
Environmental Restoration Program into one of three relative risk
categories--high, medium, or low--on the basis of relative risks that
the site poses to human health and the environment.  The relative
risk framework evaluates the nature and concentration of the site's
contaminants, the possible pathways for the contaminants to move from
the site, and the opportunities for humans and ecological elements
(designated as "receptors") to come into contact with the
contaminants.  For example, at a highly contaminated site that poses
a hazard to groundwater, has an identifiable migration pathway, and
is located near a human receptor that uses the groundwater as a
source of drinking water, the risk ranking would be high. 
Conversely, at a site with minimal contamination, no migration
pathways, and no receptors, the risk ranking would be low. 

The relative risk ranking is a primary tool for setting cleanup
priorities and making funding decisions.  As of February 1996,
Defense had completed relative risk evaluations for approximately 75
percent of its 10,000 sites.  Not having such evaluations for the
remaining sites limits Defense's ability to set cleanup priorities
effectively.  Of the sites assigned categories, approximately 54
percent were rated as high relative risk, while the remaining 46
percent were rated as medium or low relative risk.  The sites ranked
as high risk were to receive 83 percent of Defense's projected fiscal
year 1996 funding for cleanups.  Generally, Defense does not rank
order sites within each relative risk category.  By not identifying
the worst sites among the large number in the high relative risk
category, Defense cannot ensure that its limited funds are being used
to clean up the worst sites first. 

In determining which sites to fund first, Defense assesses relative
risk information along with other considerations, such as the status
of legally enforceable cleanup agreements and the availability of
cleanup technologies.  According to Defense officials, individual
Defense facilities are responsible for performing these assessments,
the results of which are forwarded to higher organizational levels
for consideration in priority setting. 

Defense officials at facilities we visited generally said that the
relative risk evaluations had helped improve priority setting, even
though most of the contaminated sites at the facilities had been
categorized as high risk.  Nonetheless, the officials said they could
usually identify the worst sites among those with high risk ratings. 
However, Defense does not generally compare the relative severity of
contamination at high-risk sites across installations.  According to
the officials, the relative risk categorization process requires some
subjective judgments that make it difficult to compare sites at
different facilities on the basis of their risk category alone. 
However, they said that if representatives from various facilities
met to determine which sites should receive funds first for cleanups,
the relative risk information would be useful in helping set
priorities across facilities. 


      ENERGY HAS QUALITATIVELY
      EVALUATED RISKS AT
      FACILITIES REQUIRING CLEANUP
---------------------------------------------------------- Letter :4.2

Although nearly all of its largest facilities are on the NPL, Energy
must set priorities for the thousands of individual sites within
these facilities.  The congressional conference committee's report on
Energy's fiscal year 1994 appropriations bill directed the Department
to report on the risks at its contaminated sites and indicate how it
was ranking competing cleanup requirements.  Because Energy did not
have the data needed to answer these questions, it qualitatively
evaluated its environmental management activities, asking its field
office managers to (1) classify the risks addressed by its
environmental management activities (high, medium, or low) and (2)
assess the significance of legal compliance requirements (high,
medium, or low).\15 High risks presented immediate and very serious
threats, medium risks included significant hazards that should be
addressed expeditiously, and low risks encompassed conditions that
were not likely to cause serious problems in the near future. 
Compliance requirements were ranked as high if responses to laws or
agreements were needed within relatively short periods of time to
avoid penalties; rankings of medium and low indicated successively
longer periods for achieving compliance.  Energy officials then used
this information to evaluate the risk and compliance levels of
activities in the fiscal year 1996 budget request. 

In its draft 1995 report to the Congress,\16 Energy concluded that 49
percent of its fiscal year 1996 funding for the environmental
management activities that it reviewed (about $2.5 billion out of
$5.1 billion) addressed high risks to the public, workers, or the
environment and 88 percent addressed both high and medium risks.\17
The report also stated that 84 percent of the funding addressed high
compliance activities.  However, Energy noted that its qualitative
approach was limited because individual facilities used different
assumptions about risk, compliance, and future land use in preparing
their evaluations.  For example, some facilities assumed that the
current compliance agreements would remain largely unchanged, whereas
others assumed that certain agreements could be renegotiated.  Gaps
in the data also made comparisons across sites difficult, according
to the report. 

According to Energy, its qualitative evaluation is a first step in
understanding the link among risk, legal and regulatory compliance,
and budget.  Energy recognizes the need for a more integrated risk
assessment process that can become central to its priority setting. 
Such a process would go well beyond the current qualitative,
facility-based approach.  Among other things, it would identify and
quantify hazards, exposure, risk, and cost in the context of
reasonably anticipated future land use on a consistent basis for all
sites needing cleanup.  Energy officials emphasized that their
priority setting for cleanups should be evaluated in the context of
their other environmental management responsibilities.  For example,
Energy is responsible for stabilizing, treating, and disposing of
large quantities of hazardous and radioactive wastes. 

Officials at two of Energy's largest facilities--Hanford, Washington,
and Rocky Flats, Colorado--told us that information on relative risks
was considered in setting priorities.  In addition, information on
other factors, such as legally enforceable cleanup requirements, the
need for site maintenance activities, cleanup costs, and worker
safety, was considered.  However, each facility had independently
determined what information to evaluate and how to weight that
information in setting priorities.  Several agency officials
expressed concerns about how priorities are set, noting that funding
is allocated to sites on the basis more of historical funding levels
than of relative risk.  The officials added that the Department's
practice of dedicating funds to certain categories of activities
within the Environmental Management program, such as "waste
management" and "environmental remediation," instead of allowing the
funds to move between categories, limited the agency's ability to
ensure that funds were being directed to reduce the greatest risks. 
Energy officials told us that the agency was beginning to address
this concern.  They said, for example, that Rocky Flats was moving
funds from environmental remediation into waste management to respond
to greater risks. 

In 1995, we reported that Energy set cleanup priorities at individual
facilities largely on the basis of site-specific legal agreements.\18
We recommended that it set national priorities for cleaning up its
contaminated sites and attempt to renegotiate cleanup agreements that
no longer reflect such priorities.  Energy is now renegotiating some
of its agreements and attempting to balance concerns about risks at
its sites, compliance issues, and costs.  Additionally, the agency is
making an effort to impose a national set of criteria for allocating
budgeted funds to facilities.  We continue to believe that national
priorities should be set because the future progress that the agency
makes in cleaning up its facilities depends greatly on how
effectively it sets national priorities under increasingly
restrictive budgets.  The current practice of setting priorities at
individual facilities does not ensure that limited resources will be
allocated to reducing the greatest risks nationwide. 


--------------------
\15 Energy must comply with a wide variety of legal and regulatory
requirements for cleaning up contamination at its facilities. 
Compliance requirements appear in agreements with EPA or the states,
agreements with tribal nations, federal and state laws and
regulations, permits, and executive and departmental orders. 

\16 Risks and the Risk Debate:  Searching for Common Ground, "The
First Step," Office of Environmental Management (June 1995). 

\17 Energy reviewed only $5.1 billion of its fiscal year 1996
environmental management budget of $6.5 billion because the remaining
$1.4 billion was allocated for administrative activities that do not
directly reduce risk. 

\18 Department of Energy:  National Priorities Needed for Meeting
Environmental Agreements (GAO/RCED-95-1, Mar.  3, 1995). 


      INTERIOR CENTRALLY RANKS
      CLEANUPS IN THE LATER STAGES
      OF THE SUPERFUND PROCESS
---------------------------------------------------------- Letter :4.3

In 1993, Interior's Office of Inspector General reported problems in
the Department's management of hazardous materials cleanups.\19 The
report found, among other things, that sites were not always ranked
to ensure that the most severe contamination was addressed first. 
The report recommended that Interior develop and implement a
Department-wide ranking system to ensure the allocation of its
resources to the highest priorities.  Subsequently, Interior
established a centralized priority-setting mechanism. 

In 1995, the Congress established a Central Hazardous Materials Fund
for Interior to support activities in the later stages of the
Superfund process--remedial investigations, feasibility studies,
actual cleanups of hazardous substances, and other associated
activities.  To set priorities for funding projects, Interior
classifies sites on the basis of their legal and regulatory
requirements, ranks their risks, and considers other factors
affecting their needs for funding.  The Department has developed five
codes for categorizing contaminated sites according to the importance
and urgency of the laws and regulations affecting them.\20 Interior
has also developed multiple criteria for ranking sites' risks,
including the types of contaminants, their potential for movement,
and the relative threats they pose to human health and the
environment.  Finally, Interior established a Technical Review
Committee, which reviews requests for funding submitted by Interior's
bureaus.  This committee uses the information on legal requirements
and relative risk, along with information on the status of a site's
remediation, the involvement of other responsible parties, and any
unusual conditions, to determine which sites will receive funding
first. 

For fiscal year 1996, the committee recommended funding cleanup
activities at seven sites.  Five of these seven sites were classified
as higher priorities because they needed to meet significant legal
requirements.  Ninety percent of the recommended funding, or about $9
million, is targeted to these five sites.  At several other seriously
contaminated sites, requests for funding remedial investigations and
feasibility studies were not recommended.  One Interior bureau, the
Fish and Wildlife Service, has expressed concern that the Central
Fund's appropriation is not adequate to meet its cleanup needs.  The
Service reported needing $13.4 million from the fund in fiscal year
1996, more than the total amount available for the entire Department. 
For fiscal year 1997, the Service reported needing $24.2 million. 

Although Interior's approach to setting priorities is more
comprehensive now than it once was, it is still incomplete and may
not always direct funds to the greatest risks.  According to an
Interior official, the Department has not developed a centralized
system for setting cleanup priorities for sites in the earlier stages
of the Superfund process.  In addition, the official stated that
legal and regulatory agreements are an important factor in
determining which projects should receive funds first from the
Central Fund.  An Interior official told us that the sites with
legally binding cleanup agreements are also the sites with the
greatest risks, but the Department cannot document this
correspondence because it has not scored the risks for many projects
considered for funding from the Central Fund.  Furthermore, given
that EPA is not including all qualifying sites on the NPL, it may not
be appropriate to set priorities for funding largely on the basis of
a facility's legal status.  Some of Interior's sites, such as Pine
Creek Mills in Idaho, have scored high enough to qualify for
inclusion on the NPL but had not been listed as of February 1996. 


--------------------
\19 Management of Hazardous Materials by the Department of the
Interior, Report No.  93-I-873 (Mar.  1993). 

\20 Category A--sites with federal or state court orders mandating
actions and expenditures; Category B--NPL sites with statutory
requirements; Category C--sites with federal or state regulatory
agency orders or other actions that are not listed on the NPL;
Category D+--sites where Interior is conducting voluntary remediation
work but where a state regulatory agency is closely monitoring
progress or where NPL status is pending; and Category D--sites where
Interior is conducting voluntary remediation work to protect
resources of special concern. 


      CONSISTENT NATIONAL APPROACH
      TO RANKING RELATIVE RISKS
      CAN HELP IDENTIFY
      HIGHEST-PRIORITY SITES
---------------------------------------------------------- Letter :4.4

As discussed above, individual federal agencies use their own
approaches to classifying the risks at sites and setting priorities
for funding cleanups.  In addition, the agencies do not adequately
evaluate the relative risks of their sites agencywide.  Consequently,
there may not be a consistent relationship nationwide between the
level of danger posed by the contamination at a site and the priority
for funding its cleanup.  This fragmented approach may not be the
most cost-effective way to clean up contamination at federal
facilities nationwide. 

According to 9 of EPA's 10 regional federal facility cleanup
coordinators, it is important for federal agencies to use a
consistent approach in establishing cleanup priorities.  The
coordinators said a consistent approach is needed to ensure that (1)
important decision-making criteria are being addressed at all sites
and (2) limited funds are going to the highest-priority sites.  One
coordinator, noting that EPA's procedures call for a national
approach when prioritizing nonfederal Superfund sites for the cleanup
phase of the Superfund process, would like to see a similar approach
applied to federal facilities.  To rank private sites that are ready
to begin the costly remedial action phase of the Superfund process,
EPA relies on a panel of 10 representatives from EPA's regions and 5
from headquarters, who are given specific priority-setting criteria
to apply. 

All 10 of EPA's regional coordinators told us that the optimal level
for priority setting is broader than the individual facility.  While
acknowledging the importance of the local facility's input, the EPA
officials recognized that only a broader process--whether regional,
agencywide, or national--can efficiently distribute the nation's
cleanup resources.  In 1995, we reported on the need for a national
process to set priorities for funding federal facility cleanups.\21
In addition, the National Research Council recommended that the
government consider developing a unified national process to set
priorities for hazardous waste cleanups to replace the multiple
approaches now in use.\22 We believe that a consistent approach for
relative risk evaluations is an essential element in the process for
setting cleanup priorities nationally. 


--------------------
\21 Superfund Program Management (GAO/HR-95-12, Feb.  1995). 

\22 Ranking Hazardous-Waste Sites for Remedial Action (1994). 


      REGIONAL APPROACHES SHOW
      PROMISE
---------------------------------------------------------- Letter :4.5

The Naval Facilities Engineering Command, Southwest Division, in San
Diego, California, has taken steps to expand the scope of its
priority setting to identify the Navy's highest-priority sites on the
West Coast.  According to an EPA official, starting in fiscal year
1992, the Southwest Division invited staff from the California
Environmental Protection Agency and EPA Region 9 to participate in
discussions on funding priorities for Navy facilities in California. 
This group began to meet when the Navy and the state recognized that
NPL-caliber installations had not been placed on the NPL and needed
funding for cleanup. 

In fiscal year 1995, the California group invited representatives
from (1) the states of Alaska, Arizona, and Washington; (2) EPA
Region 10; and (3) each of the Navy's West Coast cleanup operations
and Navy headquarters to participate in discussions on budget
reductions.  According to an EPA official, during these discussions,
the group agreed on the highest priorities for funding cleanup
projects and transferred some funds across organizational boundaries. 
Navy officials at the installations we visited supported this
process.  They were generally satisfied with the extent of their
input into the ranking and said that their sites had been assigned
appropriate priorities for cleanup. 

An EPA regional official said that using the Navy's West Coast
approach has improved the priority-setting process by ensuring better
communication, expanding the geographical scope of the priority
setting, and ensuring that limited cleanup funds are allocated to the
highest-priority sites.  According to the EPA official, the West
Coast team works well at the current size because participants are
knowledgeable about local sites and trust can be developed; however,
in their view, the team might not function as well if it were larger. 
The EPA official believes the next step for the West Coast team would
be to involve community advisory boards in the priority-setting
process. 

We believe that regional priority-setting approaches involving
important stakeholders--such as EPA, the states, regulated agencies,
and affected local communities--hold promise for improving priority
setting.  To illustrate the importance of this participation,
officials from seven regions told us that EPA is additionally part of
a decision team that meets periodically with at least one regulated
federal agency in the region to establish priorities for funding
cleanups. 


   CONCLUSIONS
------------------------------------------------------------ Letter :5

Ultimately, priority setting is a matter of determining where
available appropriated resources--currently about $4 billion
annually--should be spent to clean up contaminated federal
facilities.  The Superfund process does not fully and consistently
establish national priorities for funding such cleanups, yet it is
the only nationwide priority-setting process.  To improve its
effectiveness, EPA and the regulated federal agencies need to work
cooperatively to identify and assess the most severely contaminated
federal facilities as an important step in establishing priorities
for funding cleanups.  Toward this end, we have previously
recommended that (1) regulated federal agencies finish inventorying
their sites and (2) EPA and the agencies develop a plan to reduce the
backlog of unevaluated federal facilities.  This plan should specify
criteria for selecting the order in which facilities should be
evaluated for cleanup.  We continue to believe that these
recommendations should be implemented. 

If agencies are to direct their resources to their most contaminated
facilities, they will need to develop information allowing them to
compare health and environmental risks across all the sites under
their jurisdiction.  While the major cleanup agencies have made
progress in incorporating risk considerations into priority setting,
they have not fully compared risks nationwide.  In addition,
consistency in measuring risks across agencies would increase the
value of risk as a factor in determining the relative priority each
agency's cleanup program should receive.  Because Defense, Energy,
and Interior have each developed their own risk-ranking approaches,
there is currently no assurance of consistency among their rankings
and no basis for assessing the relative severity of their cleanup
needs.  The Congress is currently considering bills to change and
reauthorize the Superfund program.  Although current law allows the
agencies to set their priorities on the basis of risk, the
reauthorization of Superfund offers an opportunity for the Congress
to strengthen the role of health and environmental risk in priority
setting. 


   MATTER FOR CONGRESSIONAL
   CONSIDERATION
------------------------------------------------------------ Letter :6

To facilitate the setting of risk-based priorities for cleaning up
hazardous waste sites, the Congress may wish to consider amending
CERCLA to

  -- require EPA, in consultation with the responsible federal
     agencies and other stakeholders, to develop a consistent process
     for assessing and ranking the relative risks of hazardous waste
     sites and

  -- require agencies to employ this process as a factor in setting
     priorities for federal hazardous waste cleanups nationwide. 


   AGENCY COMMENTS AND OUR
   EVALUATION
------------------------------------------------------------ Letter :7

We provided copies of a draft of this report to the departments of
Defense, Energy, and the Interior and to EPA for their review and
comment.  We met with officials of these agencies, including a
representative of the Office of the Under Secretary of
Defense-Environmental Security; the Director, Office of Strategic
Planning and Analysis, Department of Energy; the Team Leader for
Solid and Hazardous Waste Materials Management, Office of
Environmental Policy and Compliance, Department of the Interior; and
the Associate Director, Federal Facilities Restoration and Reuse
Office, EPA.  Overall, the agencies believed that our report was
factually accurate, but, as discussed below, they had some concerns
about the interpretation of some information and wanted us to include
some additional points.  Their principal comments are discussed
below.  In addition, the agencies provided technical and editorial
comments that we incorporated into the report as appropriate. 

Defense said that its Relative Risk Site Evaluation Framework
measured only the relative risks of sites and did not produce risk
data comparable to the data that would come from the risk assessments
performed for NPL sites.  We have indicated throughout our discussion
of Defense's system that it measures relative risk.  Defense also
said that its relative risk model was a national system whose results
were taken into account when priorities were set for funding.  We
have added this information to our report. 

Energy emphasized that in comparison with other federal agencies, it
has responsibility for addressing a greater variety of environmental
problems, including radioactive waste, and that the risks posed by
some of these problems are not easily comparable.  We have expanded
our description of Energy's environmental responsibilities and agree
that risk-based priorities can be set only for cleanup functions
whose relative risks can be compared.  Energy also said that setting
priorities requires considering factors other than risk.  Our report
indicates that issues other than risk, such as cost and other program
management considerations, can be considered in setting priorities. 
Energy further said that setting priorities for cleanups is made more
difficult because funding for Energy and other agencies comes from
different appropriations and congressional committees.  We agree but
think that consistency among federal agencies' evaluations of
relative risk would facilitate a broader view of priorities. 

Interior said that its cleanup program is much smaller than Defense's
or Energy's and that although there may be 26,000 potentially
contaminated sites on Interior's lands, the majority, in the
Department's view, do not pose significant human health or safety
concerns.  We have revised our report to indicate that Interior
officials believe that only a small portion of these sites will
require major cleanups.  Interior also said that the large number of
its "sites" should not be compared with the smaller number of other
agencies' "facilities," which can include many sites.  We have tried
to make the distinction between sites and facilities clear in our
report.  While agreeing that a complete inventory of sites is
required for the federal government to know whether its funds are
being spent on the highest-priority projects, Interior said that it
would need additional funding to complete its inventory of hazardous
waste sites and prioritize them for cleanup. 

EPA, like Energy, said that factors other than risk, such as cost and
concern for the equitable treatment of low-income or disadvantaged
individuals, should be considered in priority setting.  Our report
indicates that it is appropriate to set priorities on the basis of
risk and other considerations.  EPA also said that our report placed
too much emphasis on the role of risk in setting priorities.  We
believe that the cost-effective reduction of health and environmental
risks should be the predominant consideration in priority setting. 

The agencies also had some comments about our matter for
congressional consideration.  Interior and EPA officials expressed
some concern that agencies are forced to strike a balance between
evaluating and cleaning up sites and that they would need additional
resources to both fully evaluate relative risks and maintain their
current levels of cleanup.  Defense was concerned that the agencies'
individual needs be considered in the development of a consistent
national process for evaluating relative risks.  We have recognized
this concern by indicating that EPA should work with the agencies in
developing such a process.  EPA said that the states should be
involved in selecting a consistent process for evaluating relative
risks for federal priority setting.  We have revised our matter for
congressional consideration to indicate that EPA should consult with
stakeholders--including the states--in developing this process. 


---------------------------------------------------------- Letter :7.1

To respond to this report's objectives, we met with headquarters
officials from EPA, Defense, Energy, and Interior.  We reviewed
pertinent laws and regulations and examined EPA's policy guidance on
priority setting.  In addition, we visited several Defense and Energy
field installations and reviewed documentation on the
priority-setting approaches being used at Defense, Energy, and
Interior.  We also conducted telephone interviews with federal
facility cleanup coordinators in each of EPA's 10 regional offices. 
Appendix III contains additional information on our scope and
methodology. 

As arranged with your office, unless you announce its contents
earlier, we plan no further distribution of this report until 21 days
after the date of this letter.  At that time, we will send copies to
the Administrator of EPA

and the Secretaries of Defense, Energy, and the Interior.  We will
also make copies available to others on request.  Please call me at
(202) 512-6111 if you or your staff have any questions.  Major
contributors to this report are listed in appendix IV. 

Sincerely yours,

Peter F.  Guerrero
Director, Environmental
 Protection Issues


STATUS OF THE 2,070 FEDERAL
FACILITIES ON THE DOCKET
=========================================================== Appendix I



   (See figure in printed
   edition.)

Note:  Percentages do not total 100 percent because of rounding. 

\a A cleanup remedy has been constructed at five of the facilities. 

Source:  GAO's analysis of data from EPA. 


ESTIMATES OF TOTAL FUTURE COSTS TO
COMPLETE CLEANUPS AND NUMBER OF
POTENTIALLY CONTAMINATED FEDERAL
SITES
========================================================== Appendix II

                                  Potential number  Estimated cleanup
Agency                                    of sites  costs
------------------------------  ------------------  ------------------
Defense                                     15,000  $31 billion
Energy                                      10,000  $200 billion-$350
                                                     billion\a
Interior                                    26,000  $4 billion-$8
                                                     billion
======================================================================
Total                                       51,000  $235 billion-$389
                                                     billion
----------------------------------------------------------------------
\a Energy's figures include the costs of cleanup, waste treatment,
storage, and disposal activities.  Additionally, Energy's costs are
in fiscal year 1995 dollars, while the other agencies' estimates are
in fiscal year 1994 dollars. 

Source:  DOD and Improving Federal Facilities Cleanup, Report of the
Federal Facilities Policy Group (Oct.  1995). 


OBJECTIVES, SCOPE, AND METHODOLOGY
========================================================= Appendix III

We were asked to assess (1) whether Superfund is identifying the
highest-priority federal sites for cleanup and (2) what progress is
being made by the departments of Defense, Energy, and the Interior in
establishing approaches for ranking risks and setting priorities for
cleanups. 

To address our first objective, we gathered information on the extent
to which federal agencies had inventoried and assessed their
potentially contaminated facilities.  To determine the number of
facilities for which preliminary assessments and site inspections
have not yet been completed, we analyzed data from EPA's Superfund
database, the Comprehensive Environmental Response, Compensation, and
Liability Information System.  We met with EPA headquarters officials
to discuss the role of the hazard ranking system and the National
Priorities List in setting priorities, and we examined the policy
guidance from EPA headquarters on setting priorities and implementing
the Superfund program.  We also conducted telephone interviews with
federal facility cleanup coordinators in each of EPA's 10 regional
offices to obtain their views on the effectiveness of the Superfund
program in setting priorities. 

To address our second objective, we gathered policy guidance and
other documentation on the risk-ranking and priority-setting
approaches being used at each agency.  We also met with officials at
Defense, Energy, and Interior to obtain their views on the progress
they have made in establishing such approaches.  To assess how
priority setting was being implemented, we visited Defense's
Picatinny Arsenal in New Jersey and Portsmouth Naval Shipyard in
Maine and Energy's Hanford facility in Washington and Rocky Flats
facility in Colorado. 

We conducted our review from July 1995 through May 1996 in accordance
with generally accepted government auditing standards. 


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix IV

James F.  Donaghy, Assistant Director
Uldis Adamsons, Assistant Director
Stephen D.  Secrist, Evaluator-in-Charge
R.  Tim Baden, Senior Evaluator
Richard P.  Johnson, Attorney
Steve Pruitt, Senior Evaluator
Virgil N.  Schroeder, Senior Evaluator
John D.  Yakaitis, Senior Evaluator
Leo G.  Acosta, Evaluator
Raymond G.  Hendren, Evaluator


*** End of document. ***