Superfund: EPA Can Improve Its Monitoring of Superfund Expenditures
(Letter Report, 05/11/1999, GAO/RCED-99-139).
The Environmental Protection Agency (EPA) spends about $1.4 billion a
year on the Superfund program to remedy potential threats to human
health and the environment arising from hazardous waste sites. This is
the third in a series of GAO reports discussing Superfund expenditures.
This report analyzes Superfund data for fiscal years 1996, 1997, and
1998 to determine (1) the relative shares of Superfund expenditures for
contractor cleanup work, site-specific, and non-site specific support;
(2) the activities carried out with EPA's cleanup support spending; and
(3) EPA's efforts to monitor and analyze how its regions and
headquarters units spend Superfund resources.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: RCED-99-139
TITLE: Superfund: EPA Can Improve Its Monitoring of Superfund
Expenditures
DATE: 05/11/1999
SUBJECT: Contract costs
Environmental monitoring
Administrative costs
Pollution control
Waste disposal
Waste management
Budget outlays
Funds management
Hazardous substances
IDENTIFIER: Superfund Program
EPA National Priorities List
******************************************************************
** This file contains an ASCII representation of the text of a **
** GAO report. This text was extracted from a PDF file. **
** Delineations within the text indicating chapter titles, **
** headings, and bullets have not been preserved, and in some **
** cases heading text has been incorrectly merged into **
** body text in the adjacent column. Graphic images have **
** not been reproduced, but figure captions are included. **
** Tables are included, but column deliniations have not been **
** preserved. **
** **
** Please see the PDF (Portable Document Format) file, when **
** available, for a complete electronic file of the printed **
** document's contents. **
** **
** A printed copy of this report may be obtained from the GAO **
** Document Distribution Center. For further details, please **
** send an e-mail message to: **
** **
** **
** **
** with the message 'info' in the body. **
******************************************************************
United States General Accounting Office GAO Report
to Congressional Requesters May 1999 SUPERFUND EPA Can
Improve Its Monitoring of Superfund Expenditures GAO/RCED-99-139
GAO United States General Accounting Office
Washington, D.C. 20548 Resources, Community, and Economic
Development Division B-282352 May 11, 1999 Congressional
Requesters The Environmental Protection Agency (EPA) spends about
$1.4 billion a year on the Superfund program to address the
potential threats to human health and the environment resulting
from hazardous waste sites. While EPA relies on cleanup
contractors to study, design, and implement site cleanups, it
undertakes a number of activities and incurs expenses that support
the cleanups. Some of these support activities and costs are site-
specific in nature, such as supervising cleanup contractors,
performing laboratory analysis, and compelling private parties to
perform cleanups for which they are responsible. Other support
activities and costs are non-site-specific, such as management and
administrative activities and expenses for rent and computer
services. Each of EPA's 10 regional offices, as well as several
headquarters units, carry out these activities. This is the third
in a series of reports in which we have analyzed Superfund
expenditures. The first report discussed trends in Superfund
spending over a 10-year period.1 The second analyzed the portion
of Superfund spending that went to cleanup contractors.2 As agreed
with your offices, this report analyzes data for fiscal years
1996, 1997, and 1998 to determine (1) the relative shares of
Superfund expenditures for contractor cleanup work, site-specific
support, and non-site-specific support; (2) the activities carried
out with EPA's cleanup support spending, particularly its non-
site-specific spending; and (3) EPA's efforts to monitor and
analyze how its regions and headquarters units spend Superfund
resources, particularly the distribution of expenditures among
contractor cleanup work, site-specific support, and non-site-
specific support. Results in Brief Over the last 3 years, the
share of total Superfund expenditures for contractor cleanup work
was about 45 percent, but declined from about 48 percent in fiscal
year 1996 to about 42 percent in fiscal year 1998. Over this
period, expenditures for non-site-specific support were about 38
percent, whereas those for site-specific support were about 17
percent. However, we found substantial variation among EPA's
regions in the shares of their expenditures devoted to each of
these cost categories. For example, spending for non-site-specific
support ranged from a low of 14 percent in EPA's Boston region to
30 percent in EPA's San Francisco region. 1Superfund: Trends in
Spending for Site Cleanups (GAO/RCED-97-211, Sept. 4, 1997).
2Superfund: Analysis of Contractor Cleanup Spending (GAO/RCED-98-
221, Aug. 4, 1998). Page 1
GAO/RCED-99-139 Superfund B-282352 EPA spends its support funds
predominately on administrative activities. Although EPA
classifies its Superfund expenditures into over 100 separate
activity categories, we found that over 60 percent of all
Superfund support expenditures (both site-specific and non-site-
specific) were accounted for by three activities-general support
and management, general enforcement support, and remedial support
and management. Moreover, almost 80 percent of EPA's non-site-
specific spending was concentrated on these three administrative
activities. For the three regions that we reviewed in detail,
these non-site-specific expenditures were primarily personnel
expenses for activities such as management, administrative and
secretarial support, financial management, public affairs, and
contract management. For the three headquarters units that we
reviewed in detail, this spending was on items such as rent;
information management; facilities operations and maintenance;
program and policy development; and budgetary, financial, and
administrative support. EPA monitors the Superfund spending of its
regions and headquarters units in several ways, including tracking
whether funds are obligated at the expected rate and in compliance
with the approved operating plan, and monitoring program
accomplishments. However, EPA does not monitor or analyze the
expenditures of its regions and units in terms of the relative
shares of contractor cleanup costs, site-specific support costs,
and non-site-specific support costs. Conducting such analyses
would provide EPA with an additional tool to identify potential
cost savings in Superfund spending, and we are therefore
recommending that EPA regularly conduct such analyses. Background
In 1980, the Comprehensive Environmental Response, Compensation,
and Liability Act created the Superfund program to clean up highly
contaminated hazardous waste sites. Under the act, EPA is
authorized to compel the parties responsible for the contamination
to perform the cleanup. EPA may also pay for the cleanup and
attempt to recover the cleanup costs from the responsible parties.
When EPA pays for the cleanup, the work is conducted by a private
contractor who is directly hired by EPA, another federal entity,
or a state. Superfund contractors study and design cleanups, as
well as manage and implement cleanup actions at sites on the
National Priorities List (EPA's list of the nation's worst
hazardous waste sites) or at sites where there are immediate
threats from hazardous wastes. In our 1998 report on contractor
cleanup spending, we reported that for remedial action Page 2
GAO/RCED-99-139 Superfund B-282352 cleanups managed by EPA, about
71 percent of the costs charged by cleanup contractors was for the
subcontractors who physically performed the cleanups-such as
earthmoving and constructing treatment facilities. The remaining
29 percent went to the prime contractors for professional work,
such as construction management and engineering services, and
associated travel, overhead, and administrative costs and fees.
For the purpose of this report, contractor cleanup work includes
all Superfund spending for the study, design, and implementation
of cleanups. The remaining Superfund spending is classified as
cleanup support, which includes both site-specific and non-site-
specific support. Site-specific support consists of Superfund
activities linked to a specific hazardous waste site, such as
supervising cleanup contractors and conducting site analyses. Non-
site-specific support consists of activities related to the
overall Superfund program, rather than a specific site, and
includes activities such as financial management and policy
development. Most Superfund The share of total Superfund
expenditures for contractor cleanup work Spending Is for
declined from about 48 percent in fiscal year 1996 to about 42
percent in fiscal year 1998. Over the same period, spending for
site-specific support Support Activities increased from about
16 percent of total Superfund expenditures to about 18 percent.
Finally, the non-site-specific expenditures also increased from
about 36 percent to over 39 percent. (See fig. 1.) Page 3
GAO/RCED-99-139 Superfund B-282352 Figure 1: Superfund Spending
for Contractor Cleanup Work, Site-Specific Support, and Non-Site-
Specific Support, as a Percentage of Total Expenditures, Fiscal
Years 1996 Through 1998 Note: Not all fiscal year percentages add
to 100 percent because of rounding. Source: GAO's analysis of
EPA's data. As the figure shows, the share of Superfund
expenditures used for contractor cleanup work decreased between
fiscal year 1996 and fiscal year 1997, and again in fiscal year
1998. EPA officials could not explain these changes in detail
because they had not analyzed Superfund costs in this manner and
were unaware of this decline until we presented the results of our
analysis. Similarly, EPA officials were unaware of, and therefore
did not have an explanation for, the changes in the other cost
categories shown in figure 1 above. The actual expenditures for
contractor cleanup work, site-specific support, and non-site-
specific support for fiscal years 1996 through 1998 are shown in
table 1. Page 4
GAO/RCED-99-139 Superfund B-282352 Table 1: Superfund Expenditures
for Contractor Cleanup Work, Dollars in millions
Site-Specific Support, and Expenditure Non-Site-
Specific Support, Fiscal category FY 1996
FY 1997 FY 1998 Total Years 1996 Through 1998
Contractor cleanup work $685.4 $649.5
$595.3 $1,930.2 Site-specific support
230.4 241.7 253.9 726.0 Non-site-specific
support 524.9 559.6 553.9
1,638.4 Total $1,440.7 $1,450.8
$1,403.1 $4,294.6 Source: GAO's analysis of EPA's data.
Expenditure Mix Varies Over the 3-year period of
our analysis, the mix of spending for contractor Among Regions and
cleanup work, site-specific support, and non-site-specific support
varied Headquarters Units substantially among
EPA's regions and headquarters units. (See fig. 2.) Page 5
GAO/RCED-99-139 Superfund B-282352 Figure 2: Types of Superfund
Spending, by Regions and Headquarters, Fiscal Years 1996 Through
1998 Note: Not all regional percentages add to 100 percent because
of rounding. Source: GAO's analysis of EPA's data. As shown in
figure 2, the mix among contractor cleanup work, site-specific
support, and non-site-specific support is substantially different
between headquarters and the regions. This difference can be
expected because headquarters functions are more related to
administration and management, while the regions have primary
responsibility for overseeing the implementation of cleanups.
However, our analysis also identified Page 6
GAO/RCED-99-139 Superfund B-282352 substantial variation among the
regions in the mix of their expenditures. Specifically,
expenditures for contractor cleanup work ranged from a low of 42
percent in EPA's Kansas City region to a high of 72 percent in
EPA's Boston and New York regions. Site-specific support spending
ranged from a low of 12 percent in EPA's New York region to a high
of 29 percent in EPA's Kansas City region. Non-site-specific
support ranged from a low of 14 percent to a high of 30 percent
among EPA's regions. These differences in the relative shares of
expenditures among these categories-more than double in some
instances-raise questions about the factors underlying them. We
discussed these variations with EPA headquarters officials.
However, because EPA does not analyze Superfund expenditures in
this manner, they did not have an explanation for the specific
factors underlying these regional differences and whether they
warrant action. Most Superfund Personnel We also
examined EPA's Superfund personnel costs because they account
Spending Is for for a significant share of
all Superfund support costs. In total, over the last Non-Site-
Specific 3 years, about 21 percent of EPA's
Superfund personnel expenses have Functions
been for site-specific functions and 79 percent for non-site-
specific functions. As shown in figure 3, this breakdown varies
substantially between regional personnel spending and headquarters
personnel spending. Figure 3: Mix of Superfund Personnel Spending,
by Regions and Headquarters, Fiscal Years 1996 Through 1998
Source: GAO's analysis of EPA's data. Page 7
GAO/RCED-99-139 Superfund B-282352 Over the 3-year period of our
analysis, Superfund personnel spending totaled about $722 million.
Of this, about $547 million was for regional personnel spending,
and the remaining $175 million was for headquarters personnel
spending. Over this period, the breakdown between site-specific
and non-site-specific personnel spending within the individual
units (headquarters and each of the regions) remained relatively
constant from year to year. However, we found that there was
variation among the regions. For example, site-specific personnel
spending for the 3-year period ranged from a low of 22 percent in
one region to a high of about 33 percent in another region-a 50-
percent difference between the lowest and highest regions. Because
EPA headquarters does not analyze Superfund personnel costs in
terms of the amount of site-specific and non-site-specific
spending, the meaning of these differences is unclear. EPA's
Support In 1996, EPA implemented improvements to its
Superfund accounting Spending Is system to better track
Superfund expenditures. EPA expected that these improvements would
help it compile more detailed cost information to Predominately
for support the agency's efforts to recover costs from
responsible parties and Administrative to improve internal
tracking of Superfund financial data for management purposes.
These improvements introduced over 100 categories to account
Activities for the activities that are paid for with
Superfund money. Some of the categories capture activities that
are site-specific, such as monitoring and supervising cleanups
conducted by private parties, while other categories capture
activities that are more administrative, such as maintaining
automated data processing systems. We found that Superfund
spending is not evenly distributed among all the activity
categories. Three of the more than 100 categories accounted for
over 60 percent of all Superfund support costs (both site-specific
and non-site-specific). These three categories are defined by EPA
as follows: * General support and management-includes all
activities associated with managing and evaluating costs for site
characterization. Also includes the general support activities
required to operate and maintain the Superfund program. Activities
include, but are not limited to, the following contractual
services: establishing, maintaining, and revising automated data
processing systems, and conducting special studies to help
determine programmatic direction in future years. * General
enforcement support-includes all activities associated with
managing and evaluating the enforcement program. Activities
include, but are not limited to, the following contractual
services: establishing, Page 8
GAO/RCED-99-139 Superfund B-282352 maintaining, and revising
automated data processing systems, and conducting special studies
to help determine programmatic direction in future years. *
Remedial support and management-includes all activities associated
with managing and evaluating the remedial program. Figure 4 shows
EPA's spending for non-site-specific and site-specific support.
Figure 4: Categories of EPA's Superfund Support Expenditures,
Fiscal Years 1996 Through 1998 (Dollars in Millions) Source: GAO's
analysis of EPA's data. EPA's non-site-specific spending was more
concentrated in these three administrative categories than its
site-specific spending. Specifically, about 78 percent of EPA's
non-site-specific spending was in the three administrative
categories, compared to only 25 percent of the site-specific
spending. Given the concentration of non-site-specific spending
under Page 9
GAO/RCED-99-139 Superfund B-282352 these three categories, we
conducted a detailed analysis of 1 year's (fiscal 1997) non-site-
specific spending under these three administrative categories for
three EPA regions and the three headquarters offices that had the
highest amount of Superfund spending-the Office of Administration
and Resources Management, the Office of Enforcement and Compliance
Assurance, and the Office of Solid Waste and Emergency Response.
For the three regions, most of the non-site-specific spending was
on personnel items-such as management, administrative, and
secretarial support-and general support activities, such as
financial management, facility management, public affairs, and
contract management. We found that some of this spending
represented cost allocations to the Superfund program, while other
spending was more directly related to specific program activities.
For example, in all three regions we found that some of the non-
site-specific costs had been allocated to the Superfund program
for its share of expenses, such as the regional administrator's
management, clerical, and administrative costs, regional motor
pool expenses, and computer equipment and service costs. We also
identified a few instances in which non-site-specific expenditures
were more directly related to implementing cleanups, such as
expenditures on annual physical examinations for staff who conduct
field work at hazardous waste sites. Among the headquarters units,
the Office of Administration and Resources Management had non-
site-specific Superfund expenditures for items such as rent,
information management, and facilities operations and maintenance.
The Office of Enforcement and Compliance Assurance had non-site-
specific expenditures for items such as overall program direction;
policy development; and budgetary, financial and administrative
support. This Office also incurred expenses for criminal
investigations and for activities such as field sampling and
laboratory and forensic analyses in support of criminal cases.
These expenses were recorded as non-site-specific to protect the
confidentiality of ongoing criminal investigations. The Office of
Solid Waste and Emergency Response had non-site-specific
expenditures for personnel functions, such as developing national
strategy programs, technical policies, regulations and guidelines,
and for providing program leadership for such activities as
community involvement, program planning and analysis, contract
management, information management, and human and organizational
services. This Office also incurred non-site-specific expenditures
for contracted Page 10
GAO/RCED-99-139 Superfund B-282352 functions such as worker
training, analytic support for EPA's contract laboratory program,
and information management support. We also analyzed EPA's
spending for site-specific support activities for fiscal years
1996 through 1998. We found that about $184 million of the site-
specific spending was in the three administrative categories.
About $542 million was in the other more than 100 categories, for
activities such as developing information for enforcement cases,
overseeing cleanups at federal facilities, conducting site
analyses and studies, overseeing private party cleanups,
conducting laboratory analysis, and supervising cleanup
contractors. EPA's Monitoring and EPA regularly monitors and
performs analyses of Superfund spending. Analysis of Superfund
These analyses, however, do not examine the breakdown of Superfund
expenditures in terms of contractor cleanup work, site-specific
support, Expenditures and non-site-specific support.
The Director of the Superfund office responsible for resources and
information management provided a summary of the activities EPA
undertakes to manage Superfund spending, including: * monitoring
whether regions and units obligate funds at the expected rate and
in accordance with the agency's operating plan; * conducting
midyear reviews that focus on program accomplishments, contracts
and grants, and resources management; * reviewing contract
management issues in all regions on a 3-year cycle; and *
monitoring inactive contracts to identify and deobligate funds
that are no longer needed. EPA's 1996 memorandum announcing
improvements to its Superfund accounting system stated that one of
the main benefits of the improvements would be to enable managers
to more precisely account for site-specific and non-site-specific
costs. The memo also stated that Superfund financial and
programmatic managers would be able to track financial trends more
accurately due to the increased level of financial detail now
available in the accounting system. However, when we discussed our
analyses with EPA officials, they told us that they do not perform
the types of analyses we conducted. During the course of our work,
we noted that another federal agency that deals with the cleanup
of hazardous wastes-the Department of Energy-has been analyzing
its costs using a functional cost reporting Page 11
GAO/RCED-99-139 Superfund B-282352 system since 1994. This system
breaks costs down into functional categories-mission-direct and
several categories of support costs, including site-specific
support and general support. While not identical to the categories
we used in our analyses, Energy's functional cost categories are
similar. In essence, Energy's system compares the share of costs
in the different categories among the agency's operating units. If
a unit's costs in any given category vary significantly from the
other operating units', those costs are further analyzed to
determine whether the differences are appropriate or whether they
indicate areas for improvement. Department of Energy financial
officials stated that the functional cost reporting system has
resulted in support costs receiving increased attention by
management and has been a helpful tool that has contributed to
support costs declining faster than other costs-from 45 to 43
percent of total costs between fiscal years 1994 and 1997.
Conclusions Detailed analyses of expenditure trends over
time and among regions and headquarters units can be a valuable
tool in identifying potential cost savings. While EPA's Superfund
accounting system contains the data necessary to perform such
analyses, EPA has not done so, even though tracking site-specific
and non-site-specific costs more accurately was one of the major
benefits anticipated when the 1996 system improvements were made.
Given the variation in spending shares for contractor cleanup
work, site-specific support, and non-site-specific support among
EPA's regional and headquarters units, we believe that conducting
such analyses would be a valuable tool in helping the agency to
ensure that its Superfund resources are being used as wisely as
possible. Recommendation In order to better identify
opportunities for potential cost savings, we recommend that the
Administrator, EPA, require the Assistant Administrator for Solid
Waste and Emergency Response to expand the monitoring of Superfund
expenditures to regularly analyze the breakdown of expenditures in
terms of contractor cleanup work, site-specific spending, and non-
site-specific spending. These analyses should compare such
spending shares among EPA's regional and headquarters units, and
significant differences should be further analyzed to identify the
underlying causes and to determine whether cost-saving corrective
actions are warranted. Page 12
GAO/RCED-99-139 Superfund B-282352 Agency Comments We
provided EPA with copies of a draft of this report for its review
and and Our Evaluation comment. In a letter from EPA's Acting
Assistant Administrator for Solid Waste and Emergency Response,
EPA disagreed with our characterization that EPA's activities fall
into three groups-contractor cleanup costs, site-specific support,
and non-site-specific support-and stated that this division gives
the erroneous impression that site-specific and non-site-specific
support do not contribute substantially to the achievement of
cleanups. We do not believe that our categorization of Superfund
costs leads to this impression. In fact, the first paragraph of
the report explicitly states that EPA undertakes a number of
activities, both site-specific and non-site-specific, that support
cleanups, including supervising cleanup contractors, compelling
private parties to perform cleanups, and performing management and
administrative activities. Furthermore, the body of the report
provides numerous examples of the purposes served by both site-
specific and non-site-specific spending. We believe that these
examples demonstrate that many of the site-specific and non-site-
specific support activities contribute to the achievement of
cleanups. The purpose of our analyses was to disaggregate
Superfund expenditures to provide more detailed information on the
specific functions served by this spending. This analytic method
can be used (and is being used by the Department of Energy) to
identify cost category differences among operating units that can
lead to potential cost savings. Our report does not attempt to
define or determine which expenditures are "cleanup activities,"
but rather to describe the purposes for which Superfund money has
been expended. According to EPA, cleanup response spending
includes "lab analysis, engineering and technical analyses,
project manager salaries, State/Tribal activities, community
involvement activities, and oversight of responsible parties and
many other activities necessary to achieve cleanups." We agree
that these activities support the cleanup of sites, as stated in
this report. However, when these support costs are aggregated into
the larger category of cleanup response, it is unclear what share
of these costs are for work related to specific sites, as opposed
to general program expenditures. EPA also stated that our analyses
failed to recognize Superfund appropriations used by other federal
agencies. In fact, our analyses included Superfund expenditures by
other federal agencies, and these expenditures were included under
our site-specific and non-site-specific spending categories, as
appropriate. The only substantial expenditures excluded from our
review were made by the Agency for Toxic Substances Page 13
GAO/RCED-99-139 Superfund B-282352 and Disease Registry, because
these expenditures are made directly by that agency and are not
reported in EPA's Superfund accounting system. EPA further stated
that our analyses did not account for the expenditures private
parties make to clean up Superfund sites that are the result of
EPA's enforcement expenditures. We did not analyze private
parties' expenditures to clean up hazardous waste sites because
our focus was on federal Superfund expenditures. However, as part
of our work for this assignment, we found that more than half of
EPA's fiscal year 1997 enforcement expenditures was for management
and administrative activities. Notwithstanding EPA's concerns as
discussed above, the agency agreed to consider analyzing Superfund
spending in terms of site-specific and non-site-specific
obligations and expenditures, as we recommended. The full text of
EPA's comments is included as appendix II. We conducted our review
from September 1998 through April 1999 in accordance with
generally accepted government auditing standards. See appendix I
for our scope and methodology. 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 to other
congressional committees with jurisdiction over the Superfund
program, and to the Honorable Carol M. Browner, Administrator,
Environmental Protection Agency. We will also make copies
available to others upon request. If you have any further
questions about this report, please call me at (202) 512-6111.
Major contributors to this report are listed in appendix III.
David G. Wood Associate Director, Environmental Protection Issues
Page 14 GAO/RCED-99-
139 Superfund B-282352 List of Congressional Requesters The
Honorable Thomas J. Bliley, Jr. Chairman, Committee on Commerce
House of Representatives The Honorable Michael G. Oxley Chairman,
Subcommittee on Finance and Hazardous Materials Committee on
Commerce House of Representatives The Honorable Bud Shuster
Chairman, Committee on Transportation and Infrastructure House of
Representatives The Honorable Sherwood C. Boehlert Chairman,
Subcommittee on Water Resources and Environment Committee on
Transportation and Infrastructure House of Representatives The
Honorable James T. Walsh Chairman, Subcommittee on VA, HUD, and
Independent Agencies Committee on Appropriations House of
Representatives Page 15 GAO/RCED-
99-139 Superfund Contents Letter
1 Appendixes Appendix I: Scope and Methodology
18 Appendix II: Comments From the Environmental Protection
20 Agency Appendix III: Major Contributors to This Report
22 Table Table 1: Superfund Expenditures for Contractor
Cleanup Work, 5 Site-Specific Support, and Non-Site-
Specific Support, Fiscal Years 1996 Through 1998 Figures
Figure 1: Superfund Spending for Contractor Cleanup Work,
4 Site-Specific Support, and Non-Site-Specific Support, as a
Percentage of Total Expenditures, Fiscal Years 1996 Through 1998
Figure 2: Types of Superfund Spending, by Regions and
6 Headquarters, Fiscal Years 1996 Through 1998 Figure 3: Mix of
Superfund Personnel Spending, by Regions and 7
Headquarters, Fiscal Years 1996 Through 1998 Figure 4: Categories
of EPA's Superfund Support Expenditures, 9 Fiscal
Years 1996 Through 1998 Abbreviations EPA Environmental
Protection Agency GAO General Accounting Office IFMS
Integrated Financial Management System Page 16
GAO/RCED-99-139 Superfund Page 17 GAO/RCED-99-139 Superfund
Appendix I Scope and Methodology To determine the share of annual
Superfund spending for contractor cleanup work, site-specific
support, and non-site-specific support for fiscal years 1996
through 1998, we obtained information from the Environmental
Protection Agency's (EPA's) Integrated Financial Management System
(IFMS). Using the IFMS information, we classified the cleanup
support activities into spending for site-specific support and
non-site-specific support for these fiscal years. We confirmed
this classification with Office of Comptroller officials. In order
to give a complete representation of cleanup support activities,
we made one adjustment to the analyses included in our prior
reports. Specifically, we included the costs for EPA personnel who
supervise the cleanup contractors into the category for site-
specific support. In our two prior reports, we had included these
personnel in the contractor cleanup work category as EPA's
accounting system does. This change has the effect of reducing the
percentage of contractor cleanup work by about 1 percent from the
level we had previously reported. To determine what activities
were carried out with EPA's cleanup support spending, particularly
its non-site-specific spending, we used the IFMS information. We
categorized the spending by EPA's budget action codes, which
provided general activity descriptions for Superfund spending
under the more than 100 action codes. To obtain more specific
information for EPA's non-site-specific spending, we selected
three regional offices-Philadelphia, Chicago, and Kansas City-for
sampling. Among EPA's regions, the first two had the highest non-
site-specific spending and the third had the lowest, based on
fiscal year 1997 data, which was the most recent information for
which we had a breakdown of total support spending at the time we
made our selection. We also selected the three EPA headquarters
units-the Office of Solid Waste and Emergency Response, the Office
of Administration and Resources Management, and the Office of
Enforcement and Compliance Assurance-with the highest levels of
Superfund spending. We interviewed cognizant officials from the
three regional offices and three headquarters units about the
particular activities conducted under the various budget action
codes for the non-site-specific spending, and obtained greater
detail on the uses of this spending. In a 1995 report on the IFMS,
we found instances of inaccurate and incomplete data in the
system.3 While we did not consider these instances to be
representative of the overall integrity of the IFMS data, we
recommended that EPA conduct statistical testing of the data,
which EPA 3Superfund: System Enhancements Could Improve the
Efficiency of Cost Recovery (GAO/AIMD-95-177, Aug. 25, 1995). Page
18
GAO/RCED-99-139 Superfund Appendix I Scope and Methodology has
done. During the course of our current review, officials of EPA's
Office of Inspector General told us that in their opinion the IFMS
has not led to any material misstatements in EPA's 1996 and 1997
annual financial statements and that they believed that the IFMS
information was reliable for the purposes of our review. Finally,
in discussing spending activities with officials from EPA's
regional offices and headquarters units, we did not identify any
material variations between the IFMS information and the
underlying detailed records. To ascertain how EPA monitors and
analyzes its regions' and headquarters units' spending of
Superfund resources, particularly for contractor cleanup work,
site-specific support, and non-site-specific support, we met with
EPA headquarters officials. These officials included
representatives from EPA's Office of Solid Waste and Emergency
Response-which is responsible for the Superfund program-and the
Office of the Chief Financial Officer. We also obtained copies of
pertinent documents describing EPA's monitoring and analysis
procedures and related reports. In addition, we met with
Department of Energy officials and obtained documentation on their
Functional Cost Reporting System. Page 19
GAO/RCED-99-139 Superfund Appendix II Comments From the
Environmental Protection Agency Page 20 GAO/RCED-99-139
Superfund Appendix II Comments From the Environmental Protection
Agency Page 21 GAO/RCED-99-139
Superfund Appendix III Major Contributors to This Report
Resources, Chuck Barchok, Assistant Director
Community, and Patricia J. Manthe, Evaluator-in-Charge
Donald J. Sangirardi, Evaluator Economic Curtis
Groves, Operations Research Analyst Development Division Office of
General Richard P. Johnson, Senior Attorney Counsel (160459)
Page 22 GAO/RCED-99-139
Superfund Ordering Information The first copy of each GAO report
and testimony is free. Additional copies are $2 each. Orders
should be sent to the following address, accompanied by a check or
money order made out to the Superintendent of Documents, when
necessary. VISA and MasterCard credit cards are accepted, also.
Orders for 100 or more copies to be mailed to a single address are
discounted 25 percent. Orders by mail: U.S. General Accounting
Office P.O. Box 37050 Washington, DC 20013 or visit: Room 1100
700 4th St. NW (corner of 4th and G Sts. NW) U.S. General
Accounting Office Washington, DC Orders may also be placed by
calling (202) 512-6000 or by using fax number (202) 512-6061, or
TDD (202) 512-2537. Each day, GAO issues a list of newly available
reports and testimony. To receive facsimile copies of the daily
list or any list from the past 30 days, please call (202) 512-6000
using a touchtone phone. A recorded menu will provide information
on how to obtain these lists. For information on how to access GAO
reports on the INTERNET, send an e-mail message with "info" in the
body to: [email protected] or visit GAO's World Wide Web Home Page
at: http://www.gao.gov PRINTED ON RECYCLED PAPER United States
General Accounting Office Bulk Rate Washington, D.C.
20548-0001 Postage & Fees Paid GAO Permit No. G100 Official
Business Penalty for Private Use $300 Address Correction Requested
*** End of document. ***