Hazardous Waste: Unaddressed Risks at Many Potential Superfund Sites
(Letter Report, 11/30/98, GAO/RCED-99-8).
Pursuant to a congressional request, GAO surveyed Environmental
Protection Agency (EPA) regions, other federal agencies, and states to:
(1) determine the number of sites classified as awaiting a National
Priorities List (NPL) decision that remain potentially eligible for the
list; (2) describe the characteristics of these sites, including their
health and environmental risks; (3) determine the status of any actions
to clean up these sites; and (4) collect the opinions of EPA and other
federal and state officials on the likely final disposition of these
sites, including the number of sites that are expected to be added to
the NPL.
GAO noted that: (1) on the basis of surveys of EPA regions, other
federal agencies, and states, GAO has determined that 1,789 of the 3,036
sites that EPA's database classified as awaiting a NPL decision in
October 1997 are still potentially eligible for placement on the list;
(2) GAO considered the 1,234 other sites as unlikely to become eligible
for various reasons; (3) the other sites do not require cleanup in the
view of the responding officials, have already been cleaned up, or have
final cleanup activities under way; (4) officials of EPA, other federal
agencies, and states said that many of the potentially eligible sites
present risks to human health and the environment; (5) the potentially
eligible sites are generally located in populated areas; (6) officials
of EPA, other federal agencies, and states said that about 17 percent of
the potentially eligible sites currently pose high human health and
environmental risks and that another 10 percent could also pose high
risks in the future if they are not cleaned up; (7) however, these
officials were unsure about the severity of risks for a large proportion
of the sites; (8) responding officials said that some cleanup actions
have taken place at 686 of the potentially eligible sites; (9) no
cleanup activities beyond initial site assessments or investigations
have been conducted, or no information is available on any such actions,
at the other 1,103 potentially eligible sites; (10) many of the
potentially eligible sites have been in states' and EPA's inventories of
hazardous sites for extended periods; (11) 73 percent have been in EPA's
inventory for more than a decade; (12) no cleanup progress was reported
at the majority of the sites that have been known for 10 years or more;
(13) responding officials did not indicate whether or how more than half
of the potentially eligible sites would be cleaned up; (14)
collectively, EPA and state officials believed that 232 of the
potentially eligible sites might be placed on the NPL in the future;
(15) however, EPA and the states agreed on the listing prospects of only
a small number of specific sites; (16) officials estimated that almost
one third of the potentially eligible sites are likely to be cleaned up
under state programs but usually could not give a date for the start of
cleanup activities; (17) officials of about 20 percent of the states
said that their state's enforcement capacity to compel responsible
parties to clean up potentially eligible sites is fair to very poor; and
(18) officials of about half of the states told GAO that their state's
financial capability to clean up potentially eligible sites is poor or
very poor.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: RCED-99-8
TITLE: Hazardous Waste: Unaddressed Risks at Many Potential
Superfund Sites
DATE: 11/30/98
SUBJECT: Federal/state relations
Hazardous substances
Industrial wastes
Pollution control
Environmental policies
Environmental monitoring
Surveys
Waste disposal
Health hazards
Liability (legal)
IDENTIFIER: EPA Comprehensive Environmental Response, Compensation, and
Liability Information System
EPA National Priorities List
Superfund Program
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Cover
================================================================ COVER
Report to the Ranking Minority Member, Committee on Commerce, House
of Representatives
November 1998
HAZARDOUS WASTE - UNADDRESSED
RISKS AT MANY POTENTIAL SUPERFUND
SITES
GAO/RCED-99-8
Hazardous Waste
(160386)
Abbreviations
=============================================================== ABBREV
CERCLA - Comprehensive Environmental Response, Compensation, and
Liability Act of 1980
CERCLIS - Comprehensive Environmental Response, Compensation, and
Liability Information System
EPA - Environmental Protection Agency
GAO - General Accounting Office
NPL - National Priorities List
PCB - polychlorinated biphenyl
SVOC - semivolatile organic compound
VOC - volatile organic compound
Letter
=============================================================== LETTER
B-280168
November 30, 1998
The Honorable John D. Dingell
Ranking Minority Member
Committee on Commerce
House of Representatives
Dear Mr. Dingell:
As of August 1998, there were about 1,200 hazardous waste sites on
the National Priorities List, the Environmental Protection Agency's
(EPA) list of seriously contaminated sites needing cleanup under its
Superfund program. According to EPA's Superfund database, the risks
of 3,036 additional sites have been judged on the basis of
preliminary evaluations to be serious enough to make the sites
potentially eligible for the National Priorities List and are
classified by EPA as "awaiting a National Priorities List decision."
EPA's top priority has been to complete cleanups at the sites already
on the list, and it has placed relatively few sites on the list in
recent years. Information about the nature and extent of the threat
that the sites awaiting a National Priorities List decision pose to
human health and the environment, the states' or EPA's cleanup
actions at the sites, and the states' or EPA's cleanup plans is
important to determining the future size of the Superfund program.
Therefore, you requested that we survey EPA regions, other federal
agencies, and the states to (1) determine the number of sites
classified as awaiting a National Priorities List decision that
remain potentially eligible for the list; (2) describe the
characteristics of these sites, including their health and
environmental risks; (3) determine the status of any actions to clean
up these sites; and (4) collect the opinions of EPA and other federal
and state officials on the likely final disposition of these sites,
including the number of sites that are expected to be added to the
National Priorities List. This report summarizes the information
obtained from our surveys. Also, as you requested, we are providing
information on each of the surveyed sites in a separate report to
you, Hazardous Waste: Information on Potential Superfund Sites
(GAO/RCED-99-22).
RESULTS IN BRIEF
------------------------------------------------------------ Letter :1
On the basis of surveys of EPA regions, other federal agencies, and
states,\1 we have determined that 1,789 of the 3,036 sites that EPA's
database classified as "awaiting a National Priorities List decision"
in October 1997 are still potentially eligible for placement on the
list.\2 We consider the 1,234 other sites as unlikely to become
eligible for various reasons. For example, some sites were
erroneously classified as awaiting a National Priorities List
decision or do not meet EPA's criteria for placement on the list.
Other sites do not require cleanup in the view of the responding
officials, have already been cleaned up, or have final cleanup
activities under way.\3
Officials of EPA, other federal agencies, and states said that many
of the potentially eligible sites present risks to human health and
the environment. According to these officials, about 73 percent of
the sites have caused contamination in groundwater, and another 22
percent could contaminate groundwater in the future. Furthermore,
about 32 percent of the sites caused contamination in drinking water
sources and another 56 percent could contaminate drinking water
sources in the future.\4 The potentially eligible sites are generally
located in populated areas: 96 percent are within a half mile of
residences or places of regular employment. Workers, visitors, or
trespassers may have direct contact with contaminants at about 55
percent of the sites. Officials of EPA, other federal agencies, and
states said that about 17 percent of the potentially eligible sites
currently pose high human health and environmental risks and that
another 10 percent could also pose high risks in the future if they
are not cleaned up. However, these officials were unsure about the
severity of risks for a large proportion of the sites. For about
one-third of the sites, the officials said that it was too soon to
determine the seriousness of the sites' risks or that they needed
more information to make a judgment, or provided no information on
the sites' risks.
Responding officials said that some cleanup actions--which they did
not characterize as full cleanup actions--have taken place at 686 of
the potentially eligible sites. These actions have been taken at
more than half of the sites that have been reported to currently or
potentially pose high risks, compared to about a third of the sites
that have been reported to currently or potentially pose average or
low risks. No cleanup activities beyond initial site assessments or
investigations have been conducted, or no information is available on
any such actions, at the other 1,103 potentially eligible sites.\5
Many of the potentially eligible sites have been in states' and EPA's
inventories of hazardous sites for extended periods. Seventy-three
percent have been in EPA's inventory for more than a decade. No
cleanup progress was reported at the majority of the sites that have
been known for 10 years or more.
Responding officials did not indicate whether or how more than half
of the potentially eligible sites would be cleaned up. Collectively,
EPA and state officials believed that 232 (13 percent) of the
potentially eligible sites might be placed on the National Priorities
List in the future. However, EPA and the states agreed on the
listing prospects of only a small number of specific sites.
Officials estimated that almost one third of the potentially eligible
sites are likely to be cleaned up under state programs but usually
could not give a date for the start of cleanup activities. State
officials stated that, for about two-thirds of the sites likely to be
cleaned up under state programs, the extent of responsible parties'
participation is uncertain. Nevertheless, officials of about 20
percent of the states said that their state's enforcement capacity
(including resources and legal authority) to compel responsible
parties to clean up potentially eligible sites is fair to very poor.
Furthermore, officials of about half of the states told us that their
state's financial capability to clean up potentially eligible sites,
if necessary, is poor or very poor.
--------------------
\1 In this report, unless otherwise noted, the term "states" includes
the 50 states, the District of Columbia, Guam, Midway Island, the
Northern Mariana Islands, Puerto Rico, and the Navajo Nation.
\2 We refer to these 1,789 hazardous waste sites as "potentially
eligible sites" because, on the basis of preliminary evaluations, EPA
has determined that the sites may be eligible for the National
Priorities List. Of these 1,789 sites, EPA and state officials
collectively identified only 232 sites as possible National
Priorities List candidates. Whether they are eventually listed
depends on, among other things, a final evaluation by EPA and the
states' concurrence. Except where otherwise stated, this report
discusses only the 1,789 potentially eligible sites.
\3 EPA may include on the National Priorities List a site that the
agency believes has not been satisfactorily cleaned up under state
authority.
\4 Groundwater and surface water each supply about 50 percent of the
nation's drinking water.
\5 Of the 1,103 sites for which no cleanup actions were reported,
both EPA and the states said that they had taken no cleanup actions
beyond initial site assessments at 719. For 336 sites, EPA officials
alone said that their agency had taken no cleanup actions, but the
states provided no information. California, Massachusetts, and New
Jersey accounted for about 85 percent of these sites. Similarly, for
6 sites, the states said that they had taken no action, but EPA
provided no information. Neither EPA nor the states provided
information on any cleanup actions that may have occurred at the
remaining 42 of the 1,103 sites.
BACKGROUND
------------------------------------------------------------ Letter :2
In 1980, the Congress passed the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA), which established
the Superfund program to clean up highly contaminated hazardous waste
sites. EPA administers the program, oversees cleanups performed by
the parties responsible for contaminating the sites, and performs
cleanups itself. State governments also have a role in the Superfund
process. States may enter into contracts or cooperative agreements
with EPA to carry out certain Superfund actions, including evaluating
sites, cleaning them up, and overseeing the cleanups. In addition,
most states have established their own hazardous waste programs that
can clean up sites independently of the federal Superfund program.
State cleanup programs include efforts to enforce state cleanup laws
on responsible parties and to encourage them to "voluntarily" clean
up contaminated sites.
CERCLA requires EPA to develop and maintain a list of hazardous
sites, known as the National Priorities List, that the agency
considers to present the most serious threats to human health and the
environment. These sites represent EPA's highest priorities for
cleanup nationwide. Although EPA may undertake cleanup actions at
contaminated sites not on the National Priorities List, the agency's
regulations stipulate that only sites placed on the list are eligible
for long-term cleanup ("remedial action") financed by the agency
under the trust fund established by CERCLA. Additional details on
EPA's process for placing sites on the National Priorities List are
included in appendix I.
The 3,036 sites that were awaiting a National Priorities List
decision as of October 1997 represent only a portion of the sites
that EPA has evaluated and classified over the history of the
Superfund program. According to EPA, as of November 1998, the
Superfund program had investigated over 40,000 potential hazardous
waste sites and made final decisions about whether or not to include
almost 35,000 sites on the National Priorities List. EPA also
reported that it has removed waste or taken other interim cleanup
actions at over 5,500 sites--most of which are not on the National
Priorities List--to address the most urgent risks and stabilize
conditions to prevent further releases of contamination. For the
more than 1,400 sites EPA has placed on the list,\6 it has completed
cleanup studies at most and has completed cleanup construction at
585. States have reported cleaning up thousands of sites under their
own programs and authorities.
To obtain information on the 3,036 sites that EPA identified as
awaiting a National Priorities List decision, we developed and mailed
two surveys for each nonfederal site and three surveys for each
federal facility. We sent surveys to site assessment officials in
EPA's 10 regional offices, and since state officials might have more
knowledge of some of the sites, we also sent surveys to the 50
states, the District of Columbia, Guam, Midway Island, the Northern
Mariana Islands, Puerto Rico, and the Navajo Nation (collectively
referred to as states in this report). In addition, if a federal
agency is responsible for cleaning up sites, we also sent surveys to
that agency: We surveyed 14 federal agencies for 157 of the 3,036
sites that are federally owned and/or operated. Because we did not
receive responses from some states and incomplete responses from
others, we sent follow-up surveys to state officials. In total, we
received one or more survey responses for 3,023 (99.5 percent) of the
3,036 sites identified by EPA as awaiting a National Priorities List
decision. We discuss our methodology in greater detail in appendix
II, and appendix III includes reproductions of our surveys.
--------------------
\6 About 200 of these 1,400 sites have been subsequently deleted from
the National Priorities List.
ABOUT 1,800 SITES CLASSIFIED AS
AWAITING A NATIONAL PRIORITIES
LIST DECISION REMAIN
POTENTIALLY ELIGIBLE FOR THE
LIST
------------------------------------------------------------ Letter :3
The responses to our surveys of officials of EPA, other federal
agencies, and states indicate that 1,789 of the 3,036 sites
classified by EPA's database as awaiting a National Priorities List
decision are potentially eligible for the list. Another 1,234 sites
are unlikely to become eligible for the Superfund program for various
reasons. First, EPA's database of potentially contaminated sites,
known as the Comprehensive Environmental Response, Compensation, and
Liability Information System (CERCLIS), inaccurately lists some sites
as awaiting a National Priorities List decision although they are not
eligible for listing. EPA regions reported that about 19 percent of
the 3,036 sites should not be considered eligible sites because (1)
they received preliminary hazard ranking scores below the qualifying
level or (2) EPA has already proposed them for the list or decided
not to propose them for the list. According to an EPA Superfund
program official, the incorrect data entries may have resulted from
regional program managers' misinterpretation of EPA's guidance on
CERCLIS coding.
We consider another 22 percent of the sites unlikely to become
eligible for the National Priorities List because, according to
responding officials, they either do not require any cleanup action
(183 sites), have already been cleaned up (182 sites), or are
currently undergoing final cleanup (304 sites) under state programs.
No information is available on the status of the remaining 13 sites
because of missing survey responses (see fig. 1).
Figure 1: Status of Hazardous
Waste Sites Identified by
CERCLIS as Awaiting a National
Priorities List Decision
(See figure in printed
edition.)
Legend
NPL = National Priorities List
Note: Figure does not include 13 sites for which completed survey
responses were not received.
We performed most of our analysis of site conditions, cleanup
activities, and plans for future cleanups for the 1,789 sites
remaining after we excluded the categories of sites that are shaded
in the figure. We refer to the remaining sites as potentially
eligible sites. They include 1,739 nonfederal sites and 50 federal
facilities.
MANY POTENTIALLY ELIGIBLE SITES
POSE RISKS
------------------------------------------------------------ Letter :4
Responses to our surveys indicate that many of the 1,789 sites that
are potentially eligible for the National Priorities List pose risks
to human health or the environment. Most of them threaten drinking
water sources or groundwater; they are generally located in populated
areas; and although many of the sites are fenced to prevent entry,
workers, visitors, and trespassers may have direct contact with
contaminants at more than half of the sites. The sites are
contaminated most often with metals, but other contaminants are also
present. Officials of EPA, other federal agencies, and states who
responded to our survey characterized the risks presented by about
two-thirds of the potentially eligible sites. They said that about
17 percent of the sites currently pose high human health and
environmental risks; another 10 percent of the sites potentially pose
high future risks. In addition, officials were unsure about the
severity of site conditions for a large proportion of potentially
eligible sites.
ADVERSE CONDITIONS CAUSED BY
CONTAMINATION AT THE SITES
---------------------------------------------------------- Letter :4.1
A large portion of the potentially eligible sites have contaminated
nearby groundwater, drinking water sources, or both. As figures 2
and 3 indicate, about 73 percent of the potentially eligible sites
have already contaminated groundwater, and another 22 percent of the
sites, approximately, could contaminate groundwater in the future.
In addition, about 32 percent of the potentially eligible sites have
already contaminated drinking water sources, and about 56 percent
more could contaminate drinking water sources in the future.
Figure 2: Percentage of
Potentially Eligible Sites With
Groundwater Contamination
(See figure in printed
edition.)
Figure 3: Percentage of
Potentially Eligible Sites With
Drinking Water Source
Contamination
(See figure in printed
edition.)
The contamination at many of the potentially eligible sites is also
resulting in a number of other adverse conditions. Table 1 shows the
percentage of potentially eligible sites that have experienced or
contributed to specific conditions. As the table also shows,
respondents to our surveys were uncertain whether the conditions were
present at a relatively large percentage of the potentially eligible
sites.
Table 1
Percentage of Potentially Eligible Sites
Contributing to Specified Adverse
Conditions and Percentage of Sites for
Which Conditions' Presence Is Uncertain
Percentage of
potentially
Number of Percentage of eligible sites for
Conditions resulting from potentially potentially which presence of
contamination at 1,789 eligible sites eligible sites condition is
potentially eligible sites with condition with condition uncertain
----------------------------- ------------------ ------------------ ------------------
Workers/visitors may have 981 55 21
direct contact with
contaminants
Trespassers may come into 969 54 20
direct contact with
contaminants
Fences/barriers/signs are 618 35 19
erected to keep residents or
others out of contaminated
areas
Residents/community have 548 31 35
concerns about contamination
or potential health effects
caused by this site
Fish could be unsafe to eat 486 27 29
Institutional restrictions\a 410 23 46
are necessary because of
site's contamination
Residents/others should avoid 355 20 23
exposure to contaminated
dust on some days
Sources of drinking water 215 12 20
permanently changed\b
Obnoxious odors are present 194 11 24
Residents advised not to use 150 8 20
wells
Fish, plants, or animals are 143 8 33
sick/dying
Residents, workers, etc. use 102 6 29
water (for bathing,
landscaping, etc.) that
fails to meet water quality
standards
Recreation (e.g., fishing, 85 5 23
swimming) is stopped or
restricted
Residents advised to use 75 4 21
filtered water
Residents advised to use 72 4 20
bottled water
Residents advised not to let 55 3 20
children play/dig in their
yards
Crops are irrigated with 52 3 29
contaminated water
Livestock drink contaminated 44 3 28
water
-----------------------------------------------------------------------------------------
\a Institutional restrictions include limitations on uses of a
property such as deed restrictions that limit a property to
industrial use or legal limits placed on the depth of a well at a
site.
\b For example, by connecting residents to municipal water supplies
in place of well water.
As figure 4 shows, the sites that are potentially eligible for the
National Priorities List are contaminated by a variety of pollutants.
Metals--primarily heavy metals such as lead, mercury, or cadmium--are
the principal contaminants at these sites. These metals can cause
brain and kidney damage and birth defects. The second most prominent
contaminants at these sites are volatile organic compounds (VOC).
VOCs are carbon-based compounds, such as benzene, that easily become
vapors or gases and can cause cancer, as well as damage to the blood,
immune, and reproductive systems. A large portion of the potentially
eligible sites are also contaminated by semivolatile organic
compounds (SVOC), which are similar to VOCs and can result in human
respiratory illnesses. Additional major contaminants at the sites
are pesticides, the most toxic of which can cause acute nervous
system effects and skin irritations and may cause reproductive system
effects and cancer; polychlorinated biphenyls (PCB), which can cause
skin irritations and other related conditions and may contribute to
causing cancers, liver damage, and reproductive and developmental
effects; dioxins, which are also a suspected human carcinogen; and
other unspecified contaminants. The potentially eligible sites are
generally located in populated areas: Ninety-six percent are within
a half mile of residences or places of regular employment.
Figure 4: Percentage of
Potentially Eligible Sites With
Specified Contaminants
(See figure in printed
edition.)
Note: Data are based on EPA's survey responses only. More than one
contaminant can be present at a site.
RESPONDENTS RANKED THE RISKS
OF ABOUT TWO-THIRDS OF THE
POTENTIALLY ELIGIBLE SITES
---------------------------------------------------------- Letter :4.2
We asked officials of EPA, other federal agencies, and states to rank
the relative risks of potentially eligible sites. The officials
responding to our surveys said that they could assess the current
risks of 67 percent of the sites and the potential risks of 68
percent of the sites. According to these officials, about 17 percent
of the potentially eligible sites currently pose high risks (see fig.
5), and another 10 percent of the sites (for a total of 27 percent)
could pose high risks in the future (see fig. 6) if they are not
cleaned up.\7
Figure 5: Percentage of
Potentially Eligible Sites With
High, Average, and Low Current
Risks
(See figure in printed
edition.)
Figure 6: Percentage of
Potentially Eligible Sites With
High, Average, and Low
Potential Risks
(See figure in printed
edition.)
--------------------
\7 The ranking of risks for about half of the potentially eligible
sites was based on the response of only one party, either an EPA or a
state official. In these cases, the other party either gave no
opinion on risk ranking or did not return a survey for that site.
When two or more respondents gave an opinion on risks at a site, they
agreed on about 45 percent of the sites and disagreed on about 55
percent. Most often, the disagreements involved sites that one party
believed represented average risks and the other party, high or low
risks. EPA and state officials' rankings of current risk strongly
disagreed for only 38 sites (i.e., when one respondent ranked risks
high and the other respondent ranked them low); their rankings of
potential risk strongly disagreed for 51 sites. Both sites posing
high risks and sites with unknown risks are concentrated in a few
states. Three states--California, Florida, and Illinois--account for
about 43 percent of the sites ranked as posing high risks and 24
percent of the 1,789 potentially eligible sites. Similarly, another
three states--Massachusetts, New Jersey, and New York--account for
about 54 percent of the sites for which officials did not estimate
risks and 20 percent of the total potentially eligible sites.
EPA'S AND STATES' CLEANUP
ACTIVITIES AT POTENTIALLY
ELIGIBLE SITES HAVE BEEN
LIMITED
------------------------------------------------------------ Letter :5
The 1,789 sites that are potentially eligible for the National
Priorities List include (1) 686 sites where some cleanup activities
have reportedly taken place or are currently being conducted but the
final cleanup remedies are not yet under way\8 and (2) 1,103 sites
where officials reported that no substantive cleanup activities
beyond initial site assessments or investigations have occurred or no
information on cleanup progress is available. Data on the year in
which each potentially eligible site was entered into EPA's
records--the "discovery date"--indicate that a significant portion of
these sites have been in EPA's and states' inventories of known
hazardous waste sites for more than a decade. Furthermore, 45
percent of the sites reported to have high current risks and 47
percent of the sites with high potential risks have not had any
cleanup activities, or no information on their cleanup progress is
available.
--------------------
\8 As indicated earlier, the 1,789 sites do not include any sites
that EPA or the states reported had been or were being fully cleaned
up.
ONLY LIMITED CLEANUP
ACTIVITIES HAVE BEEN
REPORTED FOR POTENTIALLY
ELIGIBLE SITES
---------------------------------------------------------- Letter :5.1
EPA, other federal agencies, and the states reported conducting some
cleanup actions at 38 percent of the potentially eligible sites.
Figure 7 shows the number and percentage of potentially eligible
sites at which federal and state agencies have undertaken some
cleanup activities or conducted other actions such as providing
alternative water supplies. (App. IV presents data on the
distribution of the sites with and without reported cleanup actions
among states and responsible federal agencies.)
Figure 7: Percentage of
Potentially Eligible Sites at
Which EPA, Other Federal
Agencies, and States Have
Conducted Cleanup Activities
(See figure in printed
edition.)
Note: The "Federal agency conducted cleanup actions" category
includes, among others, three sites at which both the state and the
responsible federal agencies have conducted cleanup actions, four
sites at which both EPA and the responsible federal agencies have
conducted some cleanup actions, and one site at which EPA, the other
federal agency, and the state all have conducted some cleanup
actions. The "Unidentified parties conducted cleanup actions"
category includes sites where cleanup actions--usually temporary or
permanent changes of drinking water supplies--were reported but the
party responsible for the actions was not specifically identified.
EPA, other federal agencies, and the states have completed removal
actions or interim, partial response actions (not characterized by
survey respondents as final cleanup solutions), including changing
the water supplies of affected residents, at 576 of the 686 sites
with cleanup actions. At the other 110 sites, responding officials
told us that some cleanup is under way, but they are not sure if it
will be a final response. EPA, other federal agencies, and the
states reported conducting no cleanup activities beyond site
assessments at the remaining 1,103 potentially eligible sites, or no
information on cleanup progress at these sites is available.
MOST HIGH-RISK SITES HAVE
UNDERGONE SOME CLEANUP
---------------------------------------------------------- Letter :5.2
One hundred and seventy (55 percent) of the 307 sites that are
estimated to currently pose high risks have undergone some cleanup
activities, while 137 (45 percent) of these sites reportedly have
seen no cleanup activities, or no information on cleanup progress is
available (see fig. 8). Similarly, 254 (53 percent) of the 476
sites said to potentially pose high risks\9 have undergone some
cleanup actions, and 222 (47 percent) have reportedly undergone none,
or information is lacking (see fig. 9).
Figure 8: Cleanup Actions at
Potentially Eligible Sites, by
Reported Current Risk Levels
(See figure in printed
edition.)
Figure 9: Cleanup Actions at
Potentially Eligible Sites, by
Reported Potential Risk Levels
(See figure in printed
edition.)
See appendix V for additional discussion of the sites at which
cleanup actions have been taken.
--------------------
\9 The 476 sites that potentially pose high risks include 304 of the
307 sites that also currently pose high risks. Of the remaining 172
sites that respondents estimated do not currently pose high risks but
may in the future, about half have undergone some cleanup activities
and about half have reportedly undergone none.
MOST SITES HAVE BEEN IN THE
CERCLIS INVENTORY FOR MORE
THAN A DECADE
---------------------------------------------------------- Letter :5.3
Most of the hazardous waste sites that are potentially eligible for
the National Priorities List were "discovered," that is, entered into
EPA's inventory of sites needing examination, more than a decade ago.
As table 2 indicates, 10 percent of the potentially eligible sites
were discovered in 1979 or earlier, and 42 percent were discovered
before 1985.
Table 2
Discovery Dates for 1,789 Potentially
Eligible Sites
Year of discovery Percentage of sites
---------------------------------------- ----------------------------
Prior to 1980\a 10
1980-84 32
1985-90 43
1991-96 15
======================================================================
Total (1,789 sites) 100
----------------------------------------------------------------------
\a Although the Superfund program was not established until 1980, the
CERCLIS database incorporates hazardous waste sites that were
identified before that date.
As shown in figure 10, one-third of the sites that have been known
for 10 to 14 years and another third of the sites that have been in
the inventory for 15 years or more have undergone some cleanup
activities. Conversely, the majority of the sites that have been
known for 10 years or more have reportedly made no cleanup progress,
or no information on cleanup progress is available.
Figure 10: Cleanup Status of
Potentially Eligible Sites by
Number of Years They Have Been
in the EPA's Inventory
(See figure in printed
edition.)
Note: Figure does not include data on five sites for which EPA did
not provide a discovery date.
According to the CERCLIS database, many of the potentially eligible
sites have not only been in the inventory for a long time but have
also been awaiting a National Priorities List decision for several
years. The CERCLIS database records the date of the "last action"
taken at the inventory sites, including, among other actions, the
completion of site inspections or expanded site inspections. These
dates generally can be used as an indication of when the sites became
potentially eligible for placement on the National Priorities List.
The last action recorded for 87 percent of the potentially eligible
sites is the completion of a site inspection. Another 12 percent of
the sites have completed or are undergoing expanded site inspections.
The data show that the last action at half of the potentially
eligible sites occurred in 1994 or earlier. The last action date for
24 percent of the sites is 1995, and for 27 percent, 1996 or later.
For 4 percent of the sites, the last recorded action took place
before 1990.
RESPONDENTS ARE UNCERTAIN ABOUT
FUTURE CLEANUPS AT MOST SITES
------------------------------------------------------------ Letter :6
It is uncertain whether most potentially eligible sites will be
cleaned up; who will do the cleanup; under what programs these
activities will occur; what the extent of responsible parties'
participation will be; and when cleanup actions, if any, are likely
to begin. Responding officials did not indicate the final outcome
for 53 percent of the 1,789 potentially eligible sites (see fig.
11). They estimated that 536 (30 percent) of the sites will be
cleaned up under state programs but usually could not give a date for
the start of cleanup or say whether responsible parties would
participate. Collectively, they believed that 232 (13 percent) of
the potentially eligible sites may be listed on the National
Priorities List and cleaned up under the Superfund program, but there
are few sites that both federal and state officials agreed would be
listed (see fig. 12).
Figure 11: Estimates of the
Likely Final Cleanup Outcome
for 1,789 Potentially Eligible
Sites
(See figure in printed
edition.)
CLEANUP ACTIONS UNDER STATE
PROGRAMS
---------------------------------------------------------- Letter :6.1
Respondents thought that the largest portion of the potentially
eligible sites for which they could predict a cleanup outcome--536
sites, or 30 percent of the 1,789 sites--are likely to be cleaned up
under state enforcement or voluntary cleanup programs. However,
state officials were able to estimate when they were likely to begin
cleaning up only 121 (23 percent) of the 536 sites. They expected to
begin cleanup activities at 84 of these sites before the end of 1998
and at 35 sites by the year 2000.
State officials also said that parties responsible for the waste at
the sites that are expected to be cleaned up under state programs are
likely to clean up only 172 (32 percent) of the 536 sites. Such
parties are unlikely to participate in cleanups at another 29 (5
percent) of these sites. For the remaining two-thirds of the sites
that states reported are likely to be cleaned up under state
programs, the extent of responsible parties' participation is
uncertain.
Our survey data also show that states are more likely to have cleanup
plans for the near future (within 5 years) if responsible parties are
available to pay for cleanups. If responsible parties are expected
to clean up a site, states are more than twice as likely to have
plans to begin work on the cleanup within the next 5 years (10
percent) as for a site at which cleanup by responsible parties is
unlikely (4 percent). Furthermore, states are most likely to have
plans to complete the cleanup within 5 years if responsible parties
are likely to clean up all or almost all of the site. Twenty-one
percent of the sites with such parties are expected to be completed
by 2003.
State officials also provided information about their state's
capabilities for compelling responsible parties to clean up
potentially eligible sites or to fund cleanup activities, if
necessary. Officials of 33 (75 percent) of the 44 states
participating in our telephone survey said that their state's
enforcement capacity (including resources and legal authority) to
compel responsible parties to clean up potentially eligible sites is
excellent or good. Officials of 5 (11 percent) of the participating
states believed that their state's enforcement capacity is fair, and
another 5 (11 percent) said that their state's enforcement capacity
is poor or very poor. The remaining state official was uncertain
about the state's enforcement capability. Furthermore, officials of
11 states (25 percent) told us that their state's financial
capability to clean up potentially eligible sites, if necessary, is
excellent or good. Officials of 7 (16 percent) of the states said
that their state's ability to fund cleanups is fair, and 23 (52
percent) said that their state's ability to fund these cleanups is
poor or very poor. The remaining three officials were uncertain
about their state's funding capability. (App. VI presents, by
state, officials' assessments of their state's ability to fund
cleanup activities at potentially eligible sites).
EPA officials told us that 43 potentially eligible sites are likely
to be cleaned up under other programs such as the Resource
Conservation and Recovery Act\10
program.
--------------------
\10 The Resource Conservation and Recovery Act of 1976 requires EPA
or authorized state programs to, among other actions, establish and
enforce regulations governing facilities that treat, store, and
dispose of hazardous waste.
CLEANUP ACTIONS UNDER EPA'S
SUPERFUND PROGRAM
---------------------------------------------------------- Letter :6.2
EPA or state officials\11 said that, in their opinion, as many as 232
(13 percent) of the potentially eligible sites may be listed on the
National Priorities List in the future. As shown in figure 12, EPA
and the states agreed on the possible listing of only a few sites.
Figure 12: EPA's and States'
Estimates of the Number of
Potentially Eligible Sites That
May Be Placed on the National
Priorities List
(See figure in printed
edition.)
Legend
NPL = National Priorities List
In general, EPA and state officials believed that those sites with
responsible parties who are likely to clean them up are less likely
candidates for placement on the National Priorities List. Of the 232
sites cited as possible National Priorities List candidates, 154 (66
percent) have no identified responsible party or no responsible party
who officials felt certain is able and willing to conduct cleanup
activities. Survey respondents considered such parties likely to
clean up all or almost all of only 22 (9 percent) of the 232 sites.
No information was provided on the likely extent of responsible
parties' participation in cleaning up the remaining 24 percent of
these sites.
High-risk sites are more likely to be cited as National Priorities
List candidates than others. One hundred twenty-nine (56 percent) of
the sites that may be listed on the National Priorities List
currently pose high risks, according to survey respondents. Another
45 (19 percent) of the sites pose average risks, and 12 sites (5
percent) pose low risks. Responding officials were unable to
estimate the risks of the remaining 46 (20 percent) of these sites.
In our telephone surveys, we asked state officials about the types of
sites that the states prefer to be placed on the National Priorities
List. Officials of 26 (60 percent) of the 44 states that
participated in the surveys told us that they are more likely to
support listing sites with cleanup costs that are very high compared
to those for other types of sites.
Although respondents from EPA, other federal agencies, and states
jointly believed that as many as 232 of the potentially eligible
sites may eventually be placed on the list, none of these sites has
yet been proposed for listing. EPA respondents cited several major
reasons that the agency has not yet decided whether to propose these
sites for the National Priorities List or remove them from further
consideration for listing. The most common reasons were that EPA
considers the state program to have the lead for cleanup or more data
on the current risks of the sites are needed. Other major factors
are shown in figure 13.
Figure 13: Principal Reasons
That EPA Has Not Yet Made a
Decision About Placing a Site
on the National Priorities
List, by Percentage of
Applicable Sites
(See figure in printed
edition.)
Legend
NPL = National Priorities List
Note: Respondents could select more than one reason for each site.
--------------------
\11 None of the other responsible federal agencies surveyed
identified potentially eligible sites under their jurisdiction that
they believe are likely to be placed on the National Priorities List.
CONCLUSIONS
------------------------------------------------------------ Letter :7
EPA has already made decisions about whether or not to place on the
National Priorities List most of the sites that have come into its
hazardous waste site inventory. However, decisions to list a large
number of sites potentially eligible to enter the Superfund program
or to exclude them from further consideration for listing have been
deferred, in many cases for over a decade.
Our surveys of officials of EPA, other federal agencies, and states
indicate that there is a need to decide on how to address these
potentially eligible sites. First, about a quarter of the sites may
pose high risks to human health and the environment, in the opinion
of officials responding to our surveys. Responding officials said
that they cannot rank the risks of another third of the sites.
Second, some cleanup activities were reported to have occurred at
only about half of the sites whose risks were rated high by survey
respondents. Third, although all 1,789 potentially eligible sites
included in our surveys may require cleanup, officials of EPA, other
federal agencies, and states are uncertain about what cleanup actions
will be taken at more than half of them and whether EPA or the states
should take these actions. Furthermore, some states have concerns
about their enforcement and resource capabilities for cleaning up
sites.\12 In view of the risks associated with many of the
potentially eligible sites and the length of time that EPA or the
states have known of them, timely action by EPA and the states is
needed to obtain the information required to assess the sites' risks,
set priorities for cleanups, assign responsibility to EPA or the
states for arranging the cleanups, and inform the public as to which
party is responsible for each site's cleanup. Also, as part of the
process, inaccurate or out-of-date information on sites that are
classified in the CERCLIS database as awaiting a National Priorities
List decision needs to be corrected.
--------------------
\12 Our April 1997 report, Superfund: Stronger EPA-State
Relationship Can Improve Cleanups and Reduce Costs (GAO/RCED-97-77,
Apr. 24, 1997), presents recommendations for EPA to address states'
technical and resource needs so that they may take a lead role in
cleaning up sites.
RECOMMENDATIONS
------------------------------------------------------------ Letter :8
Because of the need for current and accurate information on the risks
posed by the 1,789 sites that are potentially eligible for the
National Priorities List in order to set cleanup priorities and
delineate cleanup responsibilities, we recommend that the
Administrator, EPA,
-- in consultation with each applicable state, (1) develop a
timetable for EPA or the state to characterize and rank the
risks associated with the potentially eligible sites and (2)
establish interim cleanup measures that may be appropriate for
EPA and the state to take at potentially eligible sites that
pose the highest risks while these sites await either placement
on the National Priorities List or state action to fully clean
them up;
-- in consultation with each applicable state, (1) develop a
timetable for determining whether EPA or the state will be
responsible for cleaning up individual sites, taking into
consideration, among other factors, some states' limited
resources and enforcement authority, and (2) once a
determination is made, notify the public as to which party is
responsible for cleaning up each site; and
-- correct the errors in the CERCLIS database that incorrectly
classify sites as awaiting a National Priorities List decision
and prevent the recurrence of such errors so that the database
accurately reflects whether sites are awaiting a listing
decision.
AGENCY COMMENTS
------------------------------------------------------------ Letter :9
We provided copies of a draft of this report to EPA for its review
and comment. EPA provided written comments, which are reproduced in
appendix VII. Overall, EPA agreed with the basic findings and
recommendations of the report and stated that it believes that the
report will be useful to the Congress, the agency, states, and others
interested in the future of the Superfund program. EPA also said
that it has made National Priorities List decisions for many of the
sites in its hazardous waste site inventory and made significant
progress toward cleaning up listed sites. We have added this
information to the report. EPA also provided technical and
clarifying comments that we have incorporated in the report as
appropriate.
SCOPE AND METHODOLOGY
----------------------------------------------------------- Letter :10
We attempted to obtain information on all 3,036 sites that EPA has
identified as awaiting a National Priorities List decision, including
157 federal sites and 2,879 nonfederal sites. To obtain this
information, we developed surveys that we sent to officials in EPA's
10 regional offices, the 50 states, the District of Columbia, Guam,
Midway Island, the Northern Mariana Islands, Puerto Rico, the Navajo
Nation, and 14 other federal agencies with responsibility for sites
that are potentially eligible for the National Priorities List and
awaiting EPA's decision on their disposition. These agencies include
the departments of Agriculture, the Air Force, the Army, Defense,
Energy, the Interior, the Navy, and Transportation; the Bureau of
Land Management; the General Services Administration; the National
Aeronautics and Space Administration; the U.S. Army Corps of
Engineers; the U.S. Coast Guard; and the U.S. Forest Service. We
also conducted a telephone survey with officials in 44 states to
determine general information on their hazardous waste management
programs and sites within their jurisdiction. (App. II discusses
our scope and methodology in greater detail.)
We conducted our review between May 1997 and November 1998 in
accordance with generally accepted government auditing standards.
--------------------------------------------------------- Letter :10.1
As arranged with your office, unless you announce its contents
earlier, we plan no further distribution of this report until 30 days
after the date of this letter. At that time, we will send copies of
this report to the appropriate congressional committees; the
Administrator, EPA; and the Director, Office of Management and
Budget. We will also make copies available to others upon 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
VIII.
Sincerely yours,
Peter F. Guerrero
Director, Environmental
Protection Issues
THE ENVIRONMENTAL PROTECTION
AGENCY'S PROCESS FOR PLACING SITES
ON THE NATIONAL PRIORITIES LIST
=========================================================== Appendix I
The Environmental Protection Agency's (EPA) regulations outline a
formal process for assessing hazardous waste sites and placing them
on the National Priorities List (NPL). The process begins when EPA
receives a report of a potentially hazardous waste site from a state
government, a private citizen, or a responsible federal agency. EPA
enters a potentially contaminated site into a database known as the
Comprehensive Environmental Response, Compensation, and Liability
Information System (CERCLIS). EPA or the state in which the
potentially contaminated site is located then conducts a preliminary
assessment to decide whether the site poses a potential threat to
human health and the environment. (According to EPA, about half of
the assessments are conducted by states under funding from EPA.) If
the preliminary assessment shows that contamination may exist, EPA or
a state under an agreement with the agency may conduct a site
inspection, a more detailed examination of possible contamination,
and in some cases a follow-on examination called an expanded site
inspection.
Using information from the preliminary assessment and site
inspection, EPA applies its Hazard Ranking System to evaluate the
site's potential threat to the public health and the environment.
The system assigns each site a score ranging from 0 to 100 for use as
a screening tool to determine whether the site should be considered
for further action under Superfund. A site with a score of 28.5 or
higher is considered for placement on the NPL. Once EPA determines
that an eligible site warrants listing, the agency first proposes
that the site be placed on the NPL and then, after receiving public
comments, either lists it or removes it from further consideration.
EPA may choose not to list a site if a state prefers to deal with it
under its own cleanup program. Generally, EPA's policy is to not
list sites on the NPL unless the governor of the state in which the
site is located concurs with its listing.
OBJECTIVES, SCOPE, AND METHODOLOGY
========================================================== Appendix II
Our objectives in this review were to (1) determine the number of
sites awaiting an NPL decision that remain potentially eligible for
the list; (2) describe the characteristics of these sites, including
their health and environmental risks; (3) determine the status of any
actions to clean up these sites; and (4) collect the opinions of EPA
and other federal and state officials on the likely final disposition
of these sites, including the number of sites that are likely to be
added to the Superfund program.
EPA's CERCLIS database indicates that as of October 8, 1997, 3,036
sites were potentially eligible for the NPL on the basis of a
combination of criteria. These criteria include a preliminary
hazardous ranking system score of 28.5 or above, the completion of a
site inspection or the initiation of an expanded site inspection, and
a status that neither eliminates the site from consideration for the
NPL nor includes a proposal to list it. Because our objectives
require data for each site, we did not sample the sites but included
all 3,036 in our survey.
To obtain information on all 3,036 sites that EPA identified as
awaiting an NPL decision, we developed three mail surveys. These
surveys appear in appendix III. We sent the first of the surveys to
officials in EPA's 10 regional offices responsible for evaluating the
sites and making decisions about listing. Because state officials
may have closer contact with some of the sites, we sent the second
survey to officials in the 50 states, the District of Columbia,
Puerto Rico, Guam, the Northern Mariana Islands, Midway Island, and
the Navajo Nation (collectively referred to as states in this
report). In addition, we sent a third survey to federal agencies
that are responsible for cleaning up the 157 federally owned and/or
operated sites that were classified as awaiting an NPL decision. We
sent surveys on the 157 sites to 14 federal agencies, including the
departments of Agriculture, the Air Force, the Army, Defense, Energy,
the Interior, the Navy, and Transportation; the Bureau of Land
Management; the General Services Administration; the National
Aeronautics and Space Administration; the U.S. Army Corps of
Engineers; the U.S. Coast Guard; and the U.S. Forest Service. The
three surveys asked respondents for detailed information on the
conditions at each site, including the site's current and potential
risks, and their opinions on the involvement of potentially
responsible parties and the likely outcome for the site's cleanup,
including any potential for NPL listing.
We mailed our three surveys in November and December 1997 and
received the final survey responses in September 1998. We received
one or more survey responses for 3,023 (99.6 percent) of the 3,036
sites identified by EPA as awaiting an NPL decision. On the basis of
these responses, we identified 1,234 sites that are no longer
eligible for the NPL or no longer awaiting an NPL decision. Because
we received no survey responses for 13 sites, we could not determine
whether they are still eligible for the NPL; therefore, we excluded
these sites from our analyses. The remaining 1,789 sites are
analyzed in this report as potentially eligible sites. Of these
sites, 1,739 were nonfederal sites, and 50 were federally owned
and/or operated sites.
Through our surveys, we obtained information from both EPA and the
states on 1,319 (76 percent) of the 1,739 potentially eligible
nonfederal sites. This information includes 1,326 state responses
(76 percent) and 1,732 responses from EPA (99.6 percent). Similarly,
we obtained information from at least two of the three possible
respondents--EPA, other federal agencies, and states--for 45 (90
percent) of the 50 potentially eligible federal sites. Responsible
federal agencies provided information for 39 (78 percent) of the 50
potentially eligible federal sites, states provided responses for 26
(52 percent) of the federal sites, and EPA regions provided responses
for 49 (98 percent) of the federal sites.
Because 19 states--including California, Massachusetts, and New York,
which account for 19 percent of the 3,036 sites--did not fully
respond to our initial survey mailing, in July 1998 we sent a second
survey to these states. In order to minimize the effort required for
states to complete this follow-up survey, we eliminated sites that
EPA and other federal agencies had identified as no longer eligible
for the NPL. In addition, the follow-up survey included as a
starting point the information on each site that EPA regions had
provided in their responses. We asked state officials to confirm or
correct the information provided to us by EPA regions. In the
follow-up survey, we also repeated the original questions asked of
the states but not of EPA regions. The original state survey was
included as a reference source. This follow-up effort resulted in
our receiving an additional 85 completed surveys from some states.
However, despite numerous contacts, we received no survey responses
from California, Massachusetts, Nebraska, and the District of
Columbia. Rather than responding to our survey, California officials
suggested that we obtain their responses to a brief 1-page survey on
NPL-eligible sites conducted by the Association of State and
Territorial Solid Waste Management Officials. Similarly,
Massachusetts officials provided us copies of their responses to the
Association's survey. However, because of differences in the format,
specificity of answers, comparability of answers, and topics covered,
we could not incorporate the results of that survey into our
analyses. In addition, New York State officials agreed to respond to
only three survey questions for the sites in the state that EPA
classified as awaiting an NPL decision. The three questions asked
for information about whether sites would be listed on the NPL and
what state cleanup activities had occurred at the sites. The
responses to these questions were incorporated into our analyses.
While our overall survey response rate was high, our data for some
states are incomplete. We did not receive fully completed state
surveys for 491 of the 1,789 potentially eligible sites. Nearly
three-quarters of these sites are located in California (125 sites)
and Massachusetts (190 sites). In addition, we received only partial
information from New York for 54 of its 56 potentially eligible
sites. Table II.1 shows the 16 states that either did not respond to
our survey or responded only in part, and the number and percentage
of potentially eligible sites in each state for which we did not
receive fully completed surveys.
Table II.1
Number and Percentage of Potentially
Eligible Sites for Which Fully Completed
Surveys Were Not Received, by State
Potentially eligible
sites for which fully
completed surveys were
not received
----------------------
Number of
potentiall
y eligible
sites in
State\ state Number Percent
---------------------------------- ---------- ---------- ----------
Alabama 15 2 13%
Alaska 14 6 43%
California 125 125 100%
District of Columbia 1 1 100%
Florida 195 5 3%
Georgia 35 1 3%
Hawaii 5 1 20%
Idaho 11 4 36%
Maryland 12 5 42%
Massachusetts 190 190 100%
Navajo Nation 14 9 64%
Nebraska 19 19 100%
New Jersey 112 66 59%
New York\a 56 54 96%
Pennsylvania 38 1 3%
Washington 17 2 12%
======================================================================
Total, 16 states\ 859 491 57%
======================================================================
Total, all states 1,789 491 27%
----------------------------------------------------------------------
\a New York provided answers to three questions for 54 sites and
returned completed surveys for 2 additional sites.
EPA regions I and V notified us that because of time and resource
constraints, they had taken a generic approach to answering certain
survey questions: That is, they answered certain questions in a
standardized manner for all sites in the region rather than on a
site-specific basis. Questions addressed in this manner included,
among others, those relating to the likely placement of sites on the
NPL and the risks posed by the sites. For example, for most sites,
Region I answered our questions about the degree of human health or
environmental risks posed by each site by responding that it is "too
early to tell/more information is needed to answer" because,
according to Region I officials, "risk assessments are not conducted
for most CERCLIS sites, and thus the current risks posed by these
sites are difficult to determine." EPA Region II responded to key
survey questions in a similar manner. Consequently, because neither
EPA regions I, II, and V nor three states in those
regions---Massachusetts (190 sites), New Jersey (66 sites), and New
York (54 sites)--provided complete survey information, we could not
characterize the conditions at these sites with the same degree of
accuracy as for other sites. For example, these three states account
for 54 percent of the sites for which we could not obtain an
official's estimate of the risks to human health and the environment.
We conducted pretests of our surveys with officials in six states, at
two federal agencies, and in five EPA regional offices. Each pretest
consisted of a visit with an official by GAO staff.\13 We attempted
to vary the types of sites for which we conducted pretests and the
familiarity of the respondents with the sites. In some cases, the
respondent used only site records to answer our survey. In other
cases, the respondent knew most of the answers without consulting
records. The pretest attempted to simulate the actual survey
experience by asking the official to fill out the survey while GAO
staff observed and took notes. Then the official was interviewed
about the survey items to ensure that (1) the questions were readable
and clear, (2) terms were precise, (3) the survey was not a burden
that would result in a lack of cooperation, and (4) the survey
appeared independent and unbiased. We made appropriate changes to
the final survey on the basis of our pretesting. In addition to our
pretesting, we obtained views on our surveys from managers in EPA's
Office of Emergency and Remedial Response in Washington, D.C., which
oversees the Superfund program. We incorporated comments from these
reviews as appropriate.
In analyzing survey responses, we reviewed comments written by
respondents on the surveys, including marginal comments, comments at
the end of the survey, and comments when the respondents provided
explanations after checking "other." If a respondent's comment
explaining the selection of "other" could reasonably be interpreted
as another of the answer choices provided for the question, we
revised the response as appropriate. In some cases, respondents'
comments indicated a misunderstanding of our questions or answer
choices. In these cases, where possible, we revised the response to
reflect the appropriate answer. In other cases, respondents checked
more than one answer; we then selected, where possible, what we
considered to be the appropriate answer, on the basis of other
responses in the survey or our own judgment. The procedures used in
this editing process were documented in an internal 17-page document
provided to all of the GAO reviewers of the survey responses. At
least two reviewers analyzed each survey response, and the reviewers
coordinated their efforts to ensure that all reviewers followed the
established procedures. Both the original answers and the answers
revised by reviewers were recorded.
In our surveys of officials of EPA regions, states, and federal
agencies, some of the questions we asked about particular sites were
identical. We combined the responses to these questions where
possible in this report. If opinions differed, we used a set of
criteria to combine answers. Namely, we chose the answer that seemed
to reflect the most knowledge of the site. For site conditions, we
assumed that any affirmative answer was the more knowledgeable. For
example, if one respondent said that a site has groundwater
contamination and the other respondent was unable to comment on that
site's contamination, we recorded the site as having groundwater
contamination. We also sought to avoid understatement of the risks
posed by a site.\14 Therefore, if respondents disagreed on the level
of a site's risks, we selected the response indicating the more
severe threat. For example, sites scored by any respondent as
high-risk were recorded as high-risk sites. Furthermore, if a
respondent indicated in any survey response that a site might be
included on the NPL, we recorded the site as a possible candidate for
the NPL. Finally, when opinions about the most likely outcome for a
site were in conflict--for example, if the state thought that EPA
would clean up a site but EPA thought the state would conduct the
cleanup--we recorded the most likely outcome as unknown.
In addition to our mail surveys, we also conducted a telephone survey
with officials in 44 states to determine general information on their
hazardous waste management programs and sites within their states.
State officials in Idaho, New York, Missouri, Utah, Virginia, and
Wyoming declined to participate in our telephone survey.
We conducted our review between May 1997 and November 1998 in
accordance with generally accepted government auditing standards.
(See figure in printed edition.)Appendix III
--------------------
\13 For Puerto Rico and the Navajo Nation, we contacted officials by
telephone to conduct pretests.
\14 In our surveys, we did not define "high," "average," or "low"
risks; we left it to the officials of EPA, other federal agencies,
and states, who make such determinations, to rank sites' risks
according to their understanding of these terms.
GAO SURVEYS ON POTENTIALLY
ELIGIBLE SITES
========================================================== Appendix II
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
NUMBERS OF HAZARDOUS WASTE SITES
THAT MAY BE ELIGIBLE FOR PLACEMENT
ON THE NATIONAL PRIORITIES LIST
========================================================== Appendix IV
The 1,789 sites that are potentially eligible for the NPL include
1,739 nonfederal sites and 50 federal facilities. Among the 1,789
sites, there are (1) 686 sites at which some cleanup activities have
taken place or are currently being conducted, but the final cleanup
remedy is not yet under way, and (2) 1,103 sites for which no
substantive cleanup activities have been reported or no information
on cleanup progress is available.
STATE LOCATIONS OF SITES
POTENTIALLY ELIGIBLE FOR THE
NPL AND THEIR CLEANUP STATUS
-------------------------------------------------------- Appendix IV:1
The 1,789 sites that are potentially eligible for placement on the
NPL are located in 48 states, the District of Columbia, Puerto Rico,
and the Northern Mariana Islands and under the jurisdiction of the
Navajo Nation (hereinafter referred to as states). Table IV.1 shows,
for each state, the number of (1) sites classified in EPA's inventory
as awaiting an NPL decision as of October 8, 1997, (2) sites that our
surveys indicate are unlikely to become eligible for the NPL, (3)
potentially eligible sites at which some cleanup activities have been
conducted, (4) potentially eligible sites at which there has been no
reported cleanup progress or for which no information on cleanup
progress is available, and (5) sites for which we received no
surveys.
Table IV.1
Sites Classified as Awaiting an NPL
Decision in Each State, by Eligibility
for Listing and Status of Cleanup
Progress
Number of
Number of Number of Number of potentially
sites sites potentially eligible Number of
classified unlikely to eligible sites with sites for
as awaiting become sites with no reported which no
an NPL eligible for some cleanup cleanup surveys were
State decision the NPL activities activities received
------------------- ------------ ------------ ------------ ------------ ------------
Alabama 25 10 7 8 0
Alaska 28 14 8 6 0
Arizona 34 16 10 8 0
Arkansas 4 3 0 1 0
California\a 189 64 51 74 0
Colorado 30 12 10 6 2
Connecticut 290 74 98 118 0
Delaware 1 1 0 0 0
District of 1 0 0 1 0
Columbia\a
Florida 269 74 85 110 0
Georgia 74 39 8 27 0
Guam 2 2 0 0 0
Hawaii 17 12 4 1 0
Idaho 16 5 5 6 0
Illinois 207 95 43 69 0
Indiana 54 21 15 18 0
Iowa 33 29 4 0 0
Kansas 37 28 4 5 0
Kentucky 20 15 2 3 0
Louisiana 10 6 4 0 0
Maine 56 28 17 11 0
Maryland 20 8 4 8 0
Massachusetts\a 201 11 19 171 0
Michigan 50 22 18 10 0
Midway Island 1 1 0 0 0
Minnesota 17 6 6 5 0
Mississippi\ 9 4 1 2 2
Missouri 91 73 7 11 0
Montana 11 2 7 2 0
Navajo Nation 14 0 0 14 0
Nebraska\a 36 16 4 15 1
Nevada 12 8 3 1 0
New Hampshire 42 24 9 9 0
New Jersey 172 60 49 63 0
New Mexico 15 7 6 2 0
New York\a 192 135 15 41 1
North Carolina 57 18 21 18 0
North Dakota 4 2 1 1 0
Northern Mariana 1 0 1 0 0
Islands
Ohio 79 25 23 31 0
Oklahoma 7 4 1 2 0
Oregon 29 7 6 16 0
Pennsylvania 73 35 18 20 0
Puerto Rico 16 3 4 9 0
Rhode Island 121 14 23 84 0
South Carolina 45 32 8 5 0
South Dakota 8 6 2 0 0
Tennessee 102 51 19 32 0
Texas 21 18 1 2 0
Utah 48 17 8 16 7
Vermont 30 16 5 9 0
Virginia 22 8 2 12 0
Washington 28 11 8 9 0
West Virginia 11 7 4 0 0
Wisconsin 53 34 8 11 0
Wyoming 1 1 0 0 0
=========================================================================================
Total 3,036 1,234 686 1,103 13
-----------------------------------------------------------------------------------------
\a California, the District of Columbia, Massachusetts, and Nebraska
did not respond to our surveys. For these states, the data in table
IV.1 are based on EPA's survey responses alone and, for that reason,
may be less reliable than for states having responses from both EPA
and states. New York provided responses to only a few questions in
our survey.
FEDERAL AGENCIES RESPONSIBLE
FOR POTENTIALLY ELIGIBLE
FEDERAL FACILITIES
-------------------------------------------------------- Appendix IV:2
Under the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA), federal agencies are responsible, under EPA's
supervision, for evaluating and cleaning up properties under their
jurisdiction. As required by CERCLA, EPA has established a Federal
Agency Hazardous Waste Compliance Docket that lists federal
facilities awaiting evaluation for possible cleanup. Once a federal
facility is listed on the 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 there.
Ten federal agencies other than EPA have primary responsibility for
managing the 50 federal facilities that are potentially eligible for
the NPL. Table IV.2 presents for each agency the number of (1) sites
classified in EPA's inventory as awaiting an NPL decision as of
October 8, 1997, (2) sites that our surveys indicate are unlikely to
become eligible for the NPL, (3) potentially eligible sites at which
some cleanup activities have been conducted, and (4) potentially
eligible sites at which there has been no reported cleanup progress
or for which no information on cleanup progress is available.
Table IV.2
Federal Facilities That Are Classified
as Awaiting an NPL Decision Under Each
Agency, by Eligibility for Listing and
Status of Cleanup Progress
Number of Number of
potentially potentially
Number of sites Number of sites eligible sites eligible sites
classified as unlikely to with some with no reported
Responsible awaiting an NPL become eligible cleanup cleanup
federal agency decision for the NPL activities activities
----------------- ---------------- ---------------- ---------------- ----------------
Bureau of Land 4 2 1 1
Management
Corps of 1 1 0 0
Engineers
General Services 2 1 1 0
Administration
Department of 7 3 3 1
Agriculture
Department of the 41 29 8 4
Air Force
Department of the 28 19 5 4
Army
Department of 4 3 0 1
Defense
Department of 6 4 1 1
Energy
Department of the 11 8 1 2
Interior
Department of the 45 30 13 2
Navy
Department of 3 2 0 1
Transportation
National 3 3 0 0
Aeronautics and
Space
Administration
U.S. Coast Guard 1 1 0 0
U.S. Forest 1 1 0 0
Service
=========================================================================================
Total 157\a 107 33 17
-----------------------------------------------------------------------------------------
\a At least one survey response was received for each federal site.
ADDITIONAL INFORMATION ON
POTENTIALLY ELIGIBLE SITES THAT
HAVE UNDERGONE SOME CLEANUP
ACTIONS
=========================================================== Appendix V
We asked officials of EPA, other federal agencies, and states about
the cleanup actions that have been conducted at the potentially
eligible sites. These activities include interim measures to
mitigate the contamination, such as removing waste or taking action
to protect people against contaminated drinking water sources. These
actions were not considered by the officials to be final cleanup
remedies.
As figure V.1 shows, of the total 1,789 potentially eligible sites,
13 percent exhibit one or more of the conditions associated with
contaminated drinking water sources. The majority of these sites
have undergone some cleanup activities. Survey data indicate that
some cleanup activities have occurred at 77 percent of the sites for
which nearby residents are advised not to use wells and at 72 percent
of the sites for which residents are advised to use bottled water.
Figure V.1: Cleanup Status of
Potentially Eligible Sites With
10 Site Conditions
(See figure in printed
edition.)
Figure V.1 includes, among other factors, the five most prevalent
adverse conditions identified by officials responding to our surveys.
As this figure indicates, the majority of the sites with these
conditions reportedly have made no cleanup progress, or no
information on cleanup progress is available. No known cleanup
actions have been taken at (1) 56 percent of the sites at which
workers or visitors may come into direct contact with contaminants;
(2) 57 percent of the sites at which trespassers may come into direct
contact with contaminants; (3) 52 percent of the sites with fences,
barriers, and/or signs to prevent entry into contaminated areas; (4)
61 percent of the sites associated with fish that may be unsafe to
eat; and (5) 48 percent of the sites about which nearby residents
have expressed some health concerns.
STATES' FINANCIAL CAPABILITIES TO
CLEAN UP POTENTIALLY ELIGIBLE
SITES
========================================================== Appendix VI
During our telephone survey of officials in 44 states\15 to obtain
general information on their hazardous waste management programs,
officials gave their opinions about their state's capability to fund
cleanup activities if responsible parties were not willing or able to
pay for these actions. Officials of about a quarter of the
responding states told us that their state's financial capability to
clean up potentially eligible sites, if necessary, is excellent or
good, and more than half said that their state's ability to fund
these cleanups is poor or very poor. Table VI.1 presents, by state,
the responding officials' assessments of each state's ability to fund
cleanup activities at potentially eligible sites.
Table VI.1
State Officials' Assessments of States'
Financial Capabilities to Clean Up
Potentially Eligible Sites
State officials' assessment
of state's financial
capability to clean up
State\a potentially eligible sites
---------------------------------------- ----------------------------
Alabama Very poor
Alaska Excellent
Arizona Excellent
Arkansas Good
California Fair
Colorado Very poor
Connecticut Poor
Delaware Excellent
Florida Fair
Georgia Poor
Hawaii Fair
Illinois Fair
Indiana Very poor
Iowa Very poor
Kansas Very poor
Kentucky Good
Louisiana Poor
Maine Poor
Maryland Other\b
Massachusetts Fair
Michigan Excellent
Minnesota Good
Mississippi Very poor
Montana Very poor
Nebraska Very poor
Nevada Poor
New Hampshire Poor
New Jersey Good
New Mexico Very poor
North Carolina Poor
North Dakota Poor
Ohio Very poor
Oklahoma Very poor
Oregon Fair
Pennsylvania Excellent
Rhode Island Poor
South Carolina Good
South Dakota Other\b
Tennessee Poor
Texas Poor
Vermont Poor
Washington Fair
West Virginia Other\b
Wisconsin Excellent
----------------------------------------------------------------------
\a State officials in Idaho, New York, Missouri, Utah, Virginia, and
Wyoming declined to participate in our telephone survey.
\b "Other" indicates that the respondent was uncertain about the
state's financial capability.
(See figure in printed edition.)Appendix VII
--------------------
\15 State officials in Idaho, New York, Missouri, Utah, Virginia, and
Wyoming declined to participate in our telephone survey.
COMMENTS FROM THE ENVIRONMENTAL
PROTECTION AGENCY
========================================================== Appendix VI
MAJOR CONTRIBUTORS TO THIS REPORT
======================================================== Appendix VIII
James F. Donaghy, Assistant Director
Vincent P. Price, Senior Evaluator
Rosemary Torres Lerma, Staff Evaluator
Fran Featherston, Senior Social Science Analyst
Alice Feldesman, Assistant Director
*** End of document. ***