United States General Accounting Office

GAO 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

GAO United States

General Accounting Office

Washington, D.C. 20548

Resources, Community, and

Economic Development Division

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 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

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.

Page 1 GAO/RCED-99-8 Hazardous Waste
B-280168 

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

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.

Page 2 GAO/RCED-99-8 Hazardous Waste
B-280168 

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.

Background 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

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.

Page 3 GAO/RCED-99-8 Hazardous Waste
B-280168 

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

6

About 200 of these 1,400 sites have been subsequently deleted from the National Priorities List.

Page 4 GAO/RCED-99-8 Hazardous Waste
B-280168 

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.

About 1,800 Sites

Classified as Awaiting

a National Priorities

List Decision Remain

Potentially Eligible for

the List

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).

Page 5 GAO/RCED-99-8 Hazardous Waste
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Figure 1: Status of Hazardous Waste

Sites Identified by CERCLIS as

Awaiting a National Priorities List

Decision

12% • Cleanup completed/no cleanup

required (365 sites)

19% • Screened out by EPA’s

evaluations (565 sites)

10% • Final cleanup under way (304

sites)

59%•

Sites potentially eligible for the

NPL (1,789 sites)

Sites unlikely to be placed on the NPL

Sites potentially eligible for the NPL

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

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

Page 6 GAO/RCED-99-8 Hazardous Waste
B-280168 

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

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.

Page 7 GAO/RCED-99-8 Hazardous Waste
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Figure 2: Percentage of Potentially

Eligible Sites With Groundwater

Contamination

73% • Actual groundwater contamination

(1,301 sites)

•22%

Potential groundwater

contamination (387 sites)

•

3%

No groundwater contamination

identified (48 sites)

•

3%

Unknown (53 sites)

No information available/no response

Page 8 GAO/RCED-99-8 Hazardous Waste
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Figure 3: Percentage of Potentially

Eligible Sites With Drinking Water

Source Contamination

32% • Actual drinking water

contamination (573 sites)

56%•

Potential drinking water

contamination (1,003 sites)

•

7%

No drinking water contamination

identified (132 sites)

•

5%

Unknown (81 sites)

No information available/no response

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.

Page 9 GAO/RCED-99-8 Hazardous Waste
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Table 1: Percentage of Potentially Eligible Sites Contributing to Specified Adverse Conditions and Percentage of Sites for

Which Conditions’ Presence Is Uncertain

Conditions resulting from contamination at

1,789 potentially eligible sites

Number of potentially

eligible sites with

condition

Percentage of potentially

eligible sites with

condition

Percentage of potentially

eligible sites for which

presence of condition is

uncertain

Workers/visitors may have direct contact with

contaminants

981 55 21

Trespassers may come into direct contact

with contaminants

969 54 20

Fences/barriers/signs are erected to keep

residents or others out of contaminated areas

618 35 19

Residents/community have concerns about

contamination or potential health effects

caused by this site

548 31 35

Fish could be unsafe to eat 486 27 29

Institutional restrictionsa are necessary

because of site’s contamination

410 23 46

Residents/others should avoid exposure to

contaminated dust on some days

355 20 23

Sources of drinking water permanently

changedb

215 12 20

Obnoxious odors are present 194 11 24

Residents advised not to use wells 150 8 20

Fish, plants, or animals are sick/dying 143 8 33

Residents, workers, etc. use water (for

bathing, landscaping, etc.) that fails to meet

water quality standards

102 6 29

Recreation (e.g., fishing, swimming) is

stopped or restricted

85 5 23

Residents advised to use filtered water 75 4 21

Residents advised to use bottled water 72 4 20

Residents advised not to let children play/dig

in their yards

55 3 20

Crops are irrigated with contaminated water 52 3 29

Livestock drink contaminated water 44 3 28

aInstitutional 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.

bFor 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.

Page 10 GAO/RCED-99-8 Hazardous Waste
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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.

Page 11 GAO/RCED-99-8 Hazardous Waste
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Figure 4: Percentage of Potentially

Eligible Sites With Specified

Contaminants

Percent of potentially eligible sites

0

10

20

30

40

50

60

70

80

90

100

Metals

Volatile organic

compounds (VOC)

Semivolatile organic

compounds (SVOC)

Pesticides

Polychlorinated

biphenyls (PCB)

Dioxins

Other contaminants

Major contaminants

79

71

53

28 27

3

9

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

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

Page 12 GAO/RCED-99-8 Hazardous Waste
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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

17% • High current risks (307 sites)

25% • Average current risks (455 sites)

25%•

Low current risks (443 sites)

•33%

Unknown (584 sites)

Sites for which no risk data are available

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.

Page 13 GAO/RCED-99-8 Hazardous Waste
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Figure 6: Percentage of Potentially

Eligible Sites With High, Average, and

Low Potential Risks

27% • High potential risks (476 sites)

22% • Average potential risks (392 sites)

19%•

Low potential risks (348 sites)

•32%

Unknown (573 sites)

Sites for which no risk data are available

EPA’s and States’

Cleanup Activities at

Potentially Eligible

Sites Have Been

Limited

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 way8

 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.

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Only Limited Cleanup

Activities Have Been

Reported for Potentially

Eligible Sites

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.)

Page 15 GAO/RCED-99-8 Hazardous Waste
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Figure 7: Percentage of Potentially

Eligible Sites at Which EPA, Other

Federal Agencies, and States Have

Conducted Cleanup Activities

•

6%

EPA conducted cleanup actions

(109 sites)

16% • State conducted cleanup actions

(282 sites)

•

3%

Both EPA and state conducted

cleanup actions (55 sites)

62%•

No cleanup actions reported/no

data available (1,103 sites)

1%

Federal agency conducted

cleanup actions (23 sites)

•12%

Unidentified parties conducted

cleanup actions (217 sites)

No cleanup actions reported/no data available

Some cleanup actions reported

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.

Page 16 GAO/RCED-99-8 Hazardous Waste
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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

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 risks9

 have

undergone some cleanup actions, and 222 (47 percent) have reportedly

undergone none, or information is lacking (see fig. 9).

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.

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Figure 8: Cleanup Actions at

Potentially Eligible Sites, by Reported

Current Risk Levels

Number of potentially eligible sites

0

100

200

300

400

500

600

700

800

High current risks

Average current risks

Low current risks

Unknown current risks

Estimated risks of sites

No cleanup actions reported/no data available

Some cleanup actions reported

Page 18 GAO/RCED-99-8 Hazardous Waste
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Figure 9: Cleanup Actions at

Potentially Eligible Sites, by Reported

Potential Risk Levels

Number of potentially eligible sites

0

100

200

300

400

500

600

700

800

High potential risks

Average potential risks

Low potential risks

Unknown potential risks

Estimated risks of sites

No cleanup actions reported/no data available

Some cleanup actions reported

See appendix V for additional discussion of the sites at which cleanup

actions have been taken.

Most Sites Have Been in

the CERCLIS Inventory for

More Than a Decade

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.

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Table 2: Discovery Dates for 1,789

Potentially Eligible Sites Year of discovery Percentage of sites

Prior to 1980a 10

1980-84 32

1985-90 43

1991-96 15

Total (1,789 sites) 100

aAlthough 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.

Page 20 GAO/RCED-99-8 Hazardous Waste
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Figure 10: Cleanup Status of

Potentially Eligible Sites by Number of

Years They Have Been in the EPA’s

Inventory

Number of potentially eligible sites

0

100

200

300

400

500

600

700

800

Less

than 5

years

5 to 9

years

10 to 14

years

15 to 19

years

20

years or

more

Number of years between discovery date and 1998

No cleanup actions reported/no data available

Some cleanup actions reported

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.

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Respondents Are

Uncertain About

Future Cleanups at

Most Sites

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).

Page 22 GAO/RCED-99-8 Hazardous Waste
B-280168 

Figure 11: Estimates of the Likely Final

Cleanup Outcome for 1,789 Potentially

Eligible Sites

53% • Sites for which final outcome is

uncertain (946) 30%•

Sites likely to be cleaned up under

state programs (536)

•

2%

Sites likely to be cleaned up under

other EPA programs (43)

•13%

Sites that might be placed on the

NPL (232)

1%

Sites that either EPA or state

programs may clean up (13)

1%

Sites that are reportedly unlikely to

be cleaned up (19)

Cleanup Actions Under

State Programs

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

Page 23 GAO/RCED-99-8 Hazardous Waste
B-280168 

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 Act10 program.

10The 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.

Page 24 GAO/RCED-99-8 Hazardous Waste
B-280168 

Cleanup Actions Under

EPA’s Superfund Program

EPA or state officials11 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

1%

Sites EPA and states agree might

become NPL sites (26)

• 6%

Sites EPA identified as possible

• NPL sites (106)

6%

Sites states identified as possible

NPL sites (100)

87%•

Sites not identified as possible

NPL sites (1,557)

Sites that might be placed on NPL

Legend

NPL = National Priorities List

11None 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.

Page 25 GAO/RCED-99-8 Hazardous Waste
B-280168 

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.

Page 26 GAO/RCED-99-8 Hazardous Waste
B-280168 

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

Percent of 232 possible NPL sites

0

5

10

15

20

25

30

35

40

45

50

State has lead responsibility for site

Data on current risks are needed

Site is awaiting further site

investigation

State is conducting cleanup actions

Hazard ranking documentation being prepared

State is planning cleanup

Site is undergoing investigation

EPA is awaiting

additional state information

EPA funds for NPL

placement are limited

EPA cleanup funds are limited

Factors affecting EPA’s NPL placement decision

35 34

27

13 13

11 10 9 8 7

Legend

NPL = National Priorities List

Note: Respondents could select more than one reason for each site.

Conclusions 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

Page 27 GAO/RCED-99-8 Hazardous Waste
B-280168 

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.

Recommendations 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.

12Our 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.

Page 28 GAO/RCED-99-8 Hazardous Waste
B-280168 

Agency Comments 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

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.

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

Page 29 GAO/RCED-99-8 Hazardous Waste
B-280168 

your staff have any questions. Major contributors to this report are listed

in appendix VIII.

Sincerely yours,

Peter F. Guerrero

Director, Environmental

 Protection Issues

Page 30 GAO/RCED-99-8 Hazardous Waste
Page 31 GAO/RCED-99-8 Hazardous Waste
Contents

Letter 1

Appendix I 

The Environmental

Protection Agency’s

Process for Placing

Sites on the National

Priorities List

36

Appendix II 

Objectives, Scope,

and Methodology

37

Appendix III 

GAO Surveys on

Potentially Eligible

Sites

43

Appendix IV 

Numbers of

Hazardous Waste

Sites That May Be

Eligible for Placement

on the National

Priorities List

68

State Locations of Sites Potentially Eligible for the NPL and Their

Cleanup Status

68

Federal Agencies Responsible for Potentially Eligible Federal

Facilities

70

Page 32 GAO/RCED-99-8 Hazardous Waste
Contents

Appendix V 

Additional

Information on

Potentially Eligible

Sites That Have

Undergone Some

Cleanup Actions

72

Appendix VI 

States’ Financial

Capabilities to Clean

Up Potentially Eligible

Sites

74

Appendix VII 

Comments From the

Environmental

Protection Agency

76

Appendix VIII 

Major Contributors to

This Report

77

Tables Table 1: Percentage of Potentially Eligible Sites Contributing to

Specified Adverse Conditions and Percentage of Sites for Which

Conditions’ Presence Is Uncertain

10

Table 2: Discovery Dates for 1,789 Potentially Eligible Sites 20

Table II.1: Number and Percentage of Potentially Eligible Sites

for Which Fully Completed Surveys Were Not Received, by State

39

Table IV.1: Sites Classified as Awaiting an NPL Decision in Each

State, by Eligibility for Listing and Status of Cleanup Progress

68

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

71

Page 33 GAO/RCED-99-8 Hazardous Waste
Contents

Table VI.1: State Officials’ Assessments of States’ Financial

Capabilities to Clean Up Potentially Eligible Sites

74

Figures Figure 1: Status of Hazardous Waste Sites Identified by CERCLIS

as Awaiting a National Priorities List Decision

6

Figure 2: Percentage of Potentially Eligible Sites With

Groundwater Contamination

8

Figure 3: Percentage of Potentially Eligible Sites With Drinking

Water Source Contamination

9

Figure 4: Percentage of Potentially Eligible Sites With Specified

Contaminants

12

Figure 5: Percentage of Potentially Eligible Sites With High,

Average, and Low Current Risks

13

Figure 6: Percentage of Potentially Eligible Sites With High,

Average, and Low Potential Risks

14

Figure 7: Percentage of Potentially Eligible Sites at Which EPA,

Other Federal Agencies, and States Have Conducted Cleanup

Activities

16

Figure 8: Cleanup Actions at Potentially Eligible Sites, by

Reported Current Risk Levels

18

Figure 9: Cleanup Actions at Potentially Eligible Sites, by

Reported Potential Risk Levels

19

Figure 10: Cleanup Status of Potentially Eligible Sites by Number

of Years They Have Been in the EPA’s Inventory

21

Figure 11: Estimates of the Likely Final Cleanup Outcome for

1,789 Potentially Eligible Sites

23

Figure 12: EPA’s and States’ Estimates of the Number of

Potentially Eligible Sites That May Be Placed on the National

Priorities List

25

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

27

Figure V.1: Cleanup Status of Potentially Eligible Sites With 10

Site Conditions

73

Page 34 GAO/RCED-99-8 Hazardous Waste
Contents

Abbreviations

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

Page 35 GAO/RCED-99-8 Hazardous Waste
Appendix I 

The Environmental Protection Agency’s

Process for Placing Sites on the National

Priorities List

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.

Page 36 GAO/RCED-99-8 Hazardous Waste
Appendix II 

Objectives, Scope, and Methodology

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

Page 37 GAO/RCED-99-8 Hazardous Waste
Appendix II 

Objectives, Scope, and Methodology

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

Page 38 GAO/RCED-99-8 Hazardous Waste
Appendix II 

Objectives, Scope, and Methodology

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

State

Number of

potentially

eligible sites in

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 Yorka 56 54 96%

Pennsylvania 38 1 3%

Washington 17 2 12%

Total, 16 states 859 491 57%

Total, all states 1,789 491 27%

aNew York provided answers to three questions for 54 sites and returned completed surveys for 2

additional sites.

Page 39 GAO/RCED-99-8 Hazardous Waste
Appendix II 

Objectives, Scope, and Methodology

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

13For Puerto Rico and the Navajo Nation, we contacted officials by telephone to conduct pretests.

Page 40 GAO/RCED-99-8 Hazardous Waste
Appendix II 

Objectives, Scope, and Methodology

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

14In 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.

Page 41 GAO/RCED-99-8 Hazardous Waste
Appendix II 

Objectives, Scope, and Methodology

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.

Page 42 GAO/RCED-99-8 Hazardous Waste
Appendix III 

GAO Surveys on Potentially Eligible Sites

Page 43 GAO/RCED-99-8 Hazardous Waste
Appendix III 

GAO Surveys on Potentially Eligible Sites

Page 44 GAO/RCED-99-8 Hazardous Waste
Appendix III 

GAO Surveys on Potentially Eligible Sites

Page 45 GAO/RCED-99-8 Hazardous Waste
Appendix III 

GAO Surveys on Potentially Eligible Sites

Page 46 GAO/RCED-99-8 Hazardous Waste
Appendix III 

GAO Surveys on Potentially Eligible Sites

Page 47 GAO/RCED-99-8 Hazardous Waste
Appendix III 

GAO Surveys on Potentially Eligible Sites

Page 48 GAO/RCED-99-8 Hazardous Waste
Appendix III 

GAO Surveys on Potentially Eligible Sites

Page 49 GAO/RCED-99-8 Hazardous Waste
Appendix III 

GAO Surveys on Potentially Eligible Sites

Page 50 GAO/RCED-99-8 Hazardous Waste
Appendix III 

GAO Surveys on Potentially Eligible Sites

Page 51 GAO/RCED-99-8 Hazardous Waste
Appendix III 

GAO Surveys on Potentially Eligible Sites

Page 52 GAO/RCED-99-8 Hazardous Waste
Appendix III 

GAO Surveys on Potentially Eligible Sites

Page 53 GAO/RCED-99-8 Hazardous Waste
Appendix III 

GAO Surveys on Potentially Eligible Sites

Page 54 GAO/RCED-99-8 Hazardous Waste
Appendix III 

GAO Surveys on Potentially Eligible Sites

Page 55 GAO/RCED-99-8 Hazardous Waste
Appendix III 

GAO Surveys on Potentially Eligible Sites

Page 56 GAO/RCED-99-8 Hazardous Waste
Appendix III 

GAO Surveys on Potentially Eligible Sites

Page 57 GAO/RCED-99-8 Hazardous Waste
Appendix III 

GAO Surveys on Potentially Eligible Sites

Page 58 GAO/RCED-99-8 Hazardous Waste
Appendix III 

GAO Surveys on Potentially Eligible Sites

Page 59 GAO/RCED-99-8 Hazardous Waste
Appendix III 

GAO Surveys on Potentially Eligible Sites

Page 60 GAO/RCED-99-8 Hazardous Waste
Appendix III 

GAO Surveys on Potentially Eligible Sites

Page 61 GAO/RCED-99-8 Hazardous Waste
Appendix III 

GAO Surveys on Potentially Eligible Sites

Page 62 GAO/RCED-99-8 Hazardous Waste
Appendix III 

GAO Surveys on Potentially Eligible Sites

Page 63 GAO/RCED-99-8 Hazardous Waste
Appendix III 

GAO Surveys on Potentially Eligible Sites

Page 64 GAO/RCED-99-8 Hazardous Waste
Appendix III 

GAO Surveys on Potentially Eligible Sites

Page 65 GAO/RCED-99-8 Hazardous Waste
Appendix III 

GAO Surveys on Potentially Eligible Sites

Page 66 GAO/RCED-99-8 Hazardous Waste
Appendix III 

GAO Surveys on Potentially Eligible Sites

Page 67 GAO/RCED-99-8 Hazardous Waste
Appendix IV 

Numbers of Hazardous Waste Sites That

May Be Eligible for Placement on the

National Priorities List

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

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

State

Number of sites

classified as

awaiting an NPL

decision

Number of sites

unlikely to

become eligible

for the NPL

Number of

potentially

eligible sites with

some cleanup

activities

Number of

potentially

eligible sites with

no reported

cleanup activities

Number of sites

for which no

surveys were

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

Californiaa 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 Columbiaa 1 0 0 1 0

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

(continued)

Page 68 GAO/RCED-99-8 Hazardous Waste
Appendix IV 

Numbers of Hazardous Waste Sites That

May Be Eligible for Placement on the

National Priorities List

State

Number of sites

classified as

awaiting an NPL

decision

Number of sites

unlikely to

become eligible

for the NPL

Number of

potentially

eligible sites with

some cleanup

activities

Number of

potentially

eligible sites with

no reported

cleanup activities

Number of sites

for which no

surveys were

received

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

Massachusettsa 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

Nebraskaa 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 Yorka 192 135 15 41 1

North Carolina 57 18 21 18 0

North Dakota 4 2 1 1 0

Northern Mariana Islands 1 0 1 0 0

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

(continued)

Page 69 GAO/RCED-99-8 Hazardous Waste
Appendix IV 

Numbers of Hazardous Waste Sites That

May Be Eligible for Placement on the

National Priorities List

State

Number of sites

classified as

awaiting an NPL

decision

Number of sites

unlikely to

become eligible

for the NPL

Number of

potentially

eligible sites with

some cleanup

activities

Number of

potentially

eligible sites with

no reported

cleanup activities

Number of sites

for which no

surveys were

received

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

aCalifornia, 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

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.

Page 70 GAO/RCED-99-8 Hazardous Waste
Appendix IV 

Numbers of Hazardous Waste Sites That

May Be Eligible for Placement on the

National Priorities List

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

Responsible federal

agency

Number of sites

classified as awaiting

an NPL decision

Number of sites

unlikely to become

eligible for the NPL

Number of potentially

eligible sites with some

cleanup activities

Number of potentially

eligible sites with no

reported cleanup

activities

Bureau of Land

Management 4 2 1 1

Corps of Engineers 1 1 0 0

General Services

Administration 2 1 1 0

Department of Agriculture 7 3 3 1

Department of the Air Force 41 29 8 4

Department of the Army 28 19 5 4

Department of Defense 4 3 0 1

Department of Energy 6 4 1 1

Department of the Interior 11 8 1 2

Department of the Navy 45 30 13 2

Department of

Transportation 3 2 0 1

National Aeronautics and

Space Administration 3 3 0 0

U.S. Coast Guard 1 1 0 0

U.S. Forest Service 1 1 0 0

Total 157a 107 33 17

aAt least one survey response was received for each federal site.

Page 71 GAO/RCED-99-8 Hazardous Waste
Appendix V 

Additional Information on Potentially

Eligible Sites That Have Undergone Some

Cleanup Actions

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.

Page 72 GAO/RCED-99-8 Hazardous Waste
Appendix V 

Additional Information on Potentially

Eligible Sites That Have Undergone Some

Cleanup Actions

Figure V.1: Cleanup Status of

Potentially Eligible Sites With 10 Site

Conditions

Number of potentially eligible sites with condition

0

100

200

300

400

500

600

700

800

900

1000

Workers/visitors may contact contaminants

Trespassers may contact contaminants

Fences to prevent entry to contaminated areas

Fish may be unsafe to eat

Residents have concerns about site

Residents advised not to use wells

Residents advised to use bottled water

Residents use below-standard water

Crops irrigated with

contaminated water

Livestock drink contaminated water

Site conditions due to contamination

No cleanup actions reported/no data available

Some cleanup actions reported

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.

Page 73 GAO/RCED-99-8 Hazardous Waste
Appendix VI 

States’ Financial Capabilities to Clean Up

Potentially Eligible Sites

During our telephone survey of officials in 44 states15 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 Statea

State officials’ assessment of state’s

financial capability to clean up

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 Otherb

Massachusetts Fair

Michigan Excellent

Minnesota Good

Mississippi Very poor

Montana Very poor

(continued)

15State officials in Idaho, New York, Missouri, Utah, Virginia, and Wyoming declined to participate in

our telephone survey.

Page 74 GAO/RCED-99-8 Hazardous Waste
Appendix VI 

States’ Financial Capabilities to Clean Up

Potentially Eligible Sites

Statea

State officials’ assessment of state’s

financial capability to clean up

potentially eligible sites

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 Otherb

Tennessee Poor

Texas Poor

Vermont Poor

Washington Fair

West Virginia Otherb

Wisconsin Excellent

aState 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.

Page 75 GAO/RCED-99-8 Hazardous Waste
Appendix VII 

Comments From the Environmental

Protection Agency

Page 76 GAO/RCED-99-8 Hazardous Waste
Appendix VIII 

Major Contributors to This Report

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

(160386) Page 77 GAO/RCED-99-8 Hazardous Waste
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