Superfund: More Emphasis Needed on Risk Reduction (Testimony, 05/08/96,
GAO/T-RCED-96-168).

GAO discussed the Superfund Program's effectiveness. GAO noted that: (1)
the Environmental Protection Agency (EPA) has not adequately emphasized
risk reduction in site selection or cleanup schedules; (2) EPA regional
offices have used other factors besides risk reduction to select sites
or prioritize cleanups; (3) EPA has too often inappropriately assumed
that contaminated sites' future uses will include residential purposes,
which substantially increases cleanup costs; (4) Superfund costs could
be reduced by as much as $1.7 billion over the program's life if EPA
used its less costly accelerated cleanup procedures; (5) health hazards
would also be reduced with accelerated procedures; (6) statutory cost
and time limitations on removal actions and an inflexible funding
arrangement limit EPA use of non-time-critical removals; and (7) in
1995, EPA initiated procedural and organizational changes to include
better risk and land-use assessments and community involvement in the
program, but it is too soon to tell if the changes will result in
permanent program improvements.

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

 REPORTNUM:  T-RCED-96-168
     TITLE:  Superfund: More Emphasis Needed on Risk Reduction
      DATE:  05/08/96
   SUBJECT:  Environmental monitoring
             Cost control
             Pollution control
             Health hazards
             Hazardous substances
             Environmental engineering
             Site selection
             Waste disposal
IDENTIFIER:  Superfund Accelerated Cleanup Model
             Superfund Program
             EPA National Priorities List
             
******************************************************************
** This file contains an ASCII representation of the text of a  **
** GAO report.  Delineations within the text indicating chapter **
** titles, headings, and bullets are preserved.  Major          **
** divisions and subdivisions of the text, such as Chapters,    **
** Sections, and Appendixes, are identified by double and       **
** single lines.  The numbers on the right end of these lines   **
** indicate the position of each of the subsections in the      **
** document outline.  These numbers do NOT correspond with the  **
** page numbers of the printed product.                         **
**                                                              **
** No attempt has been made to display graphic images, although **
** figure captions are reproduced.  Tables are included, but    **
** may not resemble those in the printed version.               **
**                                                              **
** 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.                         **
******************************************************************


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


Before the Subcommittee on National Economic Growth,
Natural Resources and Regulatory Affairs, Committee
on Government Reform and Oversight,
House of Representatives

For Release
on Delivery
Expected at
9:00 a.m.  EDT
Wednesday
May 8, 1996

SUPERFUND - MORE EMPHASIS NEEDED
ON RISK REDUCTION

Statement of Stanley J.  Czerwinski,
Associate Director, Environmental Protection Issues, Resources,
Community, and Economic
Development Division

GAO/T-RCED-96-168

GAO/RCED-96-168T


(160353)


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

  EPA - x
  CERCLA - x
  NPL - x

============================================================ Chapter 0

Mr.  Chairman and Members of the Subcommittee,

We are pleased to present our views on improving the effectiveness of
the Superfund program.  The size and cost of the program have
expanded significantly over the years.  Today, there are almost 1,300
Superfund sites, and by some estimates, as many as 3,200 more sites
could enter the program in the future.  The estimated cost of
cleaning up the nation's hazardous waste problem has also grown--to
$75 billion for nonfederal sites and up to $400 billion for federal
facilities.  In the face of such staggering costs and increasingly
constrained governmental resources, the Congress faces a major
challenge in finding a way to improve the Superfund program's
cost-effectiveness while protecting public health and the
environment.  A key to meeting this challenge is managing the
Superfund program to reduce human health and environmental risks to
the greatest possible extent within the available resources.  Much of
our recent work has focused on how the program has dealt with risk
reduction issues. 

In summary, our work has shown that the cost-effective reduction of
risks has not received adequate emphasis in several aspects of the
program, including the following: 

  -- The selection of sites for cleanup and the order established for
     their cleanup have not been driven sufficiently by the risks at
     sites.  Even though EPA has a policy of addressing the "worst
     sites first," its regional offices set priorities using other
     factors, such as the amount of work required to clean up a site. 

  -- EPA's decisions on whether and how much to clean up a site are
     affected by the agency's forecasts of how the site will be used
     in the future.  EPA has been criticized for assuming too often
     that sites will be used for residential purposes, thereby
     driving up the costs of cleanup unnecessarily.  Our work has
     shown how important land-use assumptions are.  EPA judged that
     half of the sites in a group we reviewed needed cleanup only
     because the agency assumed the sites' uses would change,
     increasing human exposure to contaminants in the future. 

  -- EPA can reduce the risks at sites more quickly and economically
     by using its accelerated cleanup procedures, where appropriate,
     instead of its more expensive and time-consuming traditional
     techniques.  If the accelerated techniques were used more
     consistently, we estimate that the federal government's and
     private sector's Superfund costs could be reduced by as much as
     $1.7 billion over the life of the program. 

In 1995, EPA began to address these concerns.  For example, EPA (1)
created a system to establish national cleanup priorities based on
the risks at sites and other factors; (2) instructed its Superfund
project managers to gather more data and meet with local officials
and other interested parties when predicting future land uses; and
(3) made organizational changes to facilitate the use of accelerated
cleanup procedures.  It is too early to tell whether these procedural
and organizational changes will result in permanent improvements to
the program.  Our past reviews have shown that without management
follow-through, initiatives like these can be short-lived. 


   BACKGROUND
---------------------------------------------------------- Chapter 0:1

The Congress passed the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), commonly known as
Superfund, in 1980 authorizing EPA to clean up hazardous waste sites
that pose a threat to human health and the environment and to order
responsible parties to clean up these sites.  The act created a $1.6
billion trust fund, financed primarily by taxes on crude oil and
certain chemicals, for EPA to implement the program and pay for
cleanups.  Also, EPA can hold the parties responsible for the
contamination liable for cleanup costs.  The program was extended
twice, in 1986 and 1990, and its spending authority now totals $15.2
billion. 

EPA maintains an inventory of hazardous waste sites awaiting
evaluation for possible inclusion on the National Priorities List
(NPL), the list of the most highly contaminated sites.  After a site
is placed on the NPL, EPA conducts an investigation to determine more
fully the nature and extent of the contamination and the appropriate
way to clean it up.  One component of this investigation is a
baseline risk assessment that evaluates the health risks the site
would pose if no cleanup occurred.  At each site, EPA assesses the
risk of cancer and other adverse health effects posed by the
contaminants in different media (e.g.  groundwater, soil, air) to
determine if these risks warrant cleanup.\1 EPA evaluates these
health risks under both current and alternate future land-use
conditions to account for possible changes in the site's use. 

EPA responds to hazardous contamination at Superfund sites through
"removal" and "remedial" actions.  Removal actions are generally
shorter-term (less than 1 year), lower-cost (under $2 million)
measures intended to address actual or potential releases of
hazardous substances that pose a threat to human health or the
environment.\2 By contrast, remedial actions are longer-term and
generally more expensive measures to implement final cleanup plans at
sites.  Removals derive many of their advantages, in terms of both
time and cost, from their abbreviated planning and design phases. 

As of April 1996, EPA had placed 1,284 sites on the NPL and removed
98 sites that no longer threaten human health and the environment. 
In addition, cleanup remedies, such as groundwater pumps, are in
place and operating at 346 sites. 

Now I would like to discuss in more detail some problems affecting
EPA's treatment of risk issues in the Superfund program. 


--------------------
\1 In general, EPA decides to clean up a site if the risk of cancer
is greater than 1 in 10,000, if the site poses a risk of other
serious forms of illness, or if there is some environmental risk,
such as a threat to wetlands. 

\2 EPA classifies its removals as (1) "emergency removals" for
threats requiring immediate action, (2) "time-critical removals" for
threats requiring action within 6 months, and (3) "non-time-critical
removals" for threats where action can be delayed for at least 6
months in order to adequately plan for cleanup. 


   EPA HAS NOT EMPHASIZED RISK IN
   SETTING PRIORITIES
---------------------------------------------------------- Chapter 0:2

The risks posed by sites have not played a large enough role in the
selection of sites for the Superfund program or in the scheduling of
their cleanups after they have been selected.  Although EPA's policy
since 1989 has called for addressing the "worst sites first," the
agency's regional offices have not implemented this policy in a way
that emphasizes the risks at sites. 

First, factors other than risk primarily determine which sites EPA's
regions evaluate first for placement on the NPL.  We found that the
regions typically evaluate the sites they have known about the
longest or the sites for which they have the most complete
information.  EPA regional officials told us that they do not have
the resources necessary to perform detailed studies to determine
which sites being evaluated for inclusion on the NPL pose the
greatest risks. 

In addition, the risks that NPL sites pose relative to each other
play little role in determining which of them are cleaned up first. 
According to a study conducted by the Center for Technology, Policy,
and Industrial Development at the Massachusetts Institute of
Technology,\3 evaluations of sites' risks are given little attention
when setting priorities.  For example, officials from one EPA region
told us that they generally discuss with the states in the region
which sites should be cleaned up first and attempt to fund equal
numbers of sites in each state.  In October 1995, EPA announced a set
of administrative reforms that includes setting national risk-based
priorities for funding cleanups at sites in accordance with the
principle of cleaning up the worst sites first.  Under the new
procedures, a panel of EPA officials meets to identify the worst
sites by applying five criteria:  (1) risks to humans, (2) ecological
risks, (3) the stability of contaminants, (4) the characteristics of
contaminants, and (5) economic, social, and program management
considerations.  According to an EPA official, the panel has met and
is emphasizing current risks and, to a lesser extent, potential risks
in deciding which projects to fund. 


--------------------
\3 Breaking the Backlog:  Improving Superfund Priority Setting
(Cambridge, Mass.:  Feb.  1992). 


   FUTURE LAND-USE ASSUMPTIONS ARE
   KEY TO CLEANUP DECISIONS
---------------------------------------------------------- Chapter 0:3

Our work has demonstrated the importance to cleanup decisions of
assumptions about future land uses and the need to make these
decisions in the most informed way possible.  Forecasts of future
land use are crucial in estimating the potential for human exposure
to the contaminants at sites.  Formerly, EPA often assumed in its
risk assessments that land would be used in the future for
residential rather than industrial purposes.  Such assumptions led to
calculations of greater exposure to contaminants in the future than
in the present.  EPA then selected a more stringent and costly
cleanup method in accordance with this calculation of future risk. 

We recently reported that about one-third (71) of the sites included
in an EPA database of 225 nonfederal Superfund sites\4 posed health
risks serious enough to justify their cleanup under the current
land-use assumptions.\5 About one-half (119) of the sites in this
database did not pose such health risks under the current land-use
assumptions, but EPA estimated that they could pose such risks if
they were used for alternative purposes in the future.  For example,
a site used exclusively for industrial purposes might not pose a
threat to human health under its current classification but might be
considered as posing a threat if EPA assumed the land would be used
for residential purposes in the future.\6 EPA's risk assessment
guidance recommends that personnel performing risk assessments assume
that a site's future use will be residential even if no one lives at
the site now.  Parties responsible for cleanups have complained that
this policy results in unnecessarily expensive cleanups. 

In addition, we found some apparent inconsistencies in the risk
assessments' forecasts of future use.  For example, our review of the
risk assessments for three landfill sites demonstrates the potential
for inconsistent judgments about future land uses.  All three sites
had similar conditions, including inadequate covering over the
landfill.  Although landfills seem unlikely sites for residential
development, the risk assessments for the Hercules 009 Landfill in
Georgia and the Woodstock Landfill in Illinois concluded that people
would build homes on the sites in the future and the residents would,
then, be exposed to contaminated soil and water.  In contrast, the
risk assessment for the Strasburg Landfill in Pennsylvania concluded
that the site would not be developed but that occasional trespassers
would come in contact with contamination at the site.  While the risk
assessments for the Hercules 009 and Woodstock landfills indicated a
need for cleanup, the risk assessment at the Strasburg site did not. 

In response to charges that its land-use assumptions were
unrealistic, EPA in May 1995 instructed its risk assessment teams to
consult with local communities on such issues as zoning and the use
of adjacent land in making early determinations of future land uses. 
We have not assessed the effect of this new guidance on the selection
of cleanup remedies. 


--------------------
\4 These sites were contained in an EPA database on health risks from
Superfund sites--the most comprehensive automated information
available as of early 1995, when we did our work.  These sites
constitute most of the sites where EPA made cleanup decisions between
1991 and mid-1993. 

\5 EPA usually took action, such as removing contaminants that
presented an immediate threat to human health, at these sites. 

\6 The remaining sites did not have a current or future human health
risk high enough to justify cleanup on the basis of the risk
assessment.  However, these sites could be slated for cleanup to
comply with other federal or state standards or to eliminate a threat
to the environment, such as contamination endangering wetlands. 


   EPA'S REMOVAL AUTHORITY CAN BE
   USED FOR FASTER, MORE
   ECONOMICAL RISK REDUCTION
---------------------------------------------------------- Chapter 0:4

A cleanup method must reduce site risks to assure overall protection
of human health and the environment.  When choosing among methods
that meet this goal, EPA balances several factors, including
long-term effectiveness and cost, in arriving at a decision.  In
response to criticism that cleanups were too costly and too
time-consuming, EPA in 1992 announced a program to streamline its
Superfund procedures.  One initiative was to make greater use of
removal techniques to accomplish cleanups.  Because removals require
less extensive study and design, they can accomplish cleanups more
quickly and less expensively than remedial actions.  Traditionally,
EPA used removal techniques to respond to emergency conditions.  The
1992 initiative encouraged the use of removals at sites where cleanup
problems can be managed through removals and circumstances permit EPA
to spend at least 6 months planning the cleanups.  These latter
removals are called "non-time-critical" removals. 

EPA could use non-time-critical removals at appropriate segments of
virtually all the 1,000 sites currently on the NPL awaiting cleanup
as well as at sites that could be added in the future.  Often at
these site segments, EPA can readily determine the types of
contamination present and decide on the appropriate cleanup methods
without conducting extensive studies and designs.  EPA estimates that
the non-time-critical removals conducted to date have reduced the
cleanup time from 2 years to 4 years, on average.  In addition, they
have saved approximately $500,000 from an average total cleanup cost
of $4 million per site.  For example, at a former industrial landfill
in Cedar Rapids, Iowa, Rockwell International, the site owner,
estimated that using a non-time-critical removal reduced cleanup
costs by at least half (over $2 million) while preventing groundwater
contamination. 

We believe that using non-time-critical removals rather than remedial
actions could save the federal government and private parties from
$1.2 billion to $1.7 billion over the life of the Superfund program. 
In addition, using both removals and remediation at entire sites can
stop the spread of contamination more quickly than using remediation
alone.  The potential disadvantages of removals--that they can
require more oversight from EPA and decrease the proportion of the
cleanup costs states are required to cover--do not appear to outweigh
the benefits. 

However, limitations in CERCLA on the cost and time allowed for
removal actions and inflexible funding arrangements are limiting
EPA's use of non-time-critical removals.  In addition, EPA's regions
have varied widely in the extent to which they have used these
actions.  Some have used removals only once or twice.  We will
further discuss EPA's use of non-time-critical removals in a report
to be issued later this year. 


   CONCLUSIONS
---------------------------------------------------------- Chapter 0:5

Mr.  Chairman, on the basis of our work over the past few years, we
believe the Superfund program could benefit from an increased
emphasis on reducing the risks to human health and the environment
more quickly and cost-effectively.  In this time of fiscal
constraint, we believe that EPA could achieve more cost-effective
cleanups by basing its priorities for funding cleanups on the
principle of risk reduction.  Realistic land-use assumptions are also
important for using Superfund resources to maximize the protection of
public health and the environment.  In addition, we believe that the
increased use of EPA's removal authority could result in quicker,
more cost-effective, and more focused actions at hazardous waste
sites while better protecting human health and the environment.  We
applaud EPA's recent efforts to set priorities for the use of
Superfund resources by emphasizing the health risks at sites and to
develop realistic forecasts of sites' future uses.  Sustained
management attention and follow-through are needed to ensure that
EPA's initiatives produce lasting changes. 

That concludes my statement, Mr.  Chairman.  I will be glad to
respond to any questions. 

RELATED GAO PRODUCTS

State Cleanup Standards (GAO/RCED-96-98R, Apr.  24, 1996). 

Superfund:  Non-Time-Critical Removals as a Tool for Faster and Less
Costly Cleanups (GAO/T-RCED-96-137, Apr.  17, 1996). 

A Superfund Tool for More Efficient Cleanups (GAO/RCED-96-134R, Apr. 
15, 1996). 

Superfund:  How States Establish and Apply Environmental Standards
When Cleaning Up Sites (GAO/RCED-96-70FS, Mar.  20, 1996). 

Superfund:  Information on Current Health Risks (GAO/RCED-95-205,
July 19, 1995). 

EPA's Use of Risk Assessments in Cleanup Decisions
(GAO/T-RCED-95-231, June 22, 1995). 

Superfund:  Risk Assessment Assumptions and Issues
(GAO/T-RCED-95-206, May 23, 1995). 

Superfund:  The Role of Risk in Setting Priorities
(GAO/T-RCED-95-161, Apr.  5, 1995). 

Superfund:  Improved Reviews and Guidance Could Reduce
Inconsistencies in Risk Assessments (GAO/RCED-94-220, Aug.  10,
1994).  Superfund:  Reauthorization and Risk Prioritization Issues
(GAO/T-RCED-94-250, June 24, 1994). 

Relative Risk in Superfund (GAO/RCED-94-233R, June 17, 1994). 

Superfund:  Risk Assessment Process and Issues (GAO/T-RCED-93-74,
Sept.  30, 1993). 


*** End of document. ***