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United States Government Accountability Office: 
GAO: 

Report to the Ranking Member, Subcommittee on Environment and the 
Economy, Committee on Energy and Commerce, House of Representatives: 

January 2015: 

Hazardous Waste: 

Agencies Should Take Steps to Improve Information on USDA's and 
Interior's Potentially Contaminated Sites: 

GAO-15-35: 

GAO Highlights: 

Highlights of GAO-15-35, a report to the Ranking Member, Subcommittee 
on Environment and the Economy, Committee on Energy and Commerce, 
House of Representatives. 

Why GAO Did This Study: 

USDA and Interior manage over 600 million acres of land, including 
sites contaminated from prior uses or events, such as mining or toxic 
spills. These lands are managed by five Interior agencies, including 
BLM and the National Park Service, and five USDA agencies, including 
the U.S. Forest Service. These agencies must identify and report to 
EPA certain facilities that may threaten human health or the 
environment and, under some circumstances, clean them up. They must 
also report cost estimates for addressing contamination at certain 
sites, called environmental liabilities. 

GAO was asked to review the status of USDA’s and Interior’s 
potentially contaminated sites. This report examines USDA’s and 
Interior’s (1) efforts to identify these sites, (2) funding to address 
the sites, (3) reported environmental liabilities, and (4) EPA’s role 
in addressing the sites. GAO reviewed relevant laws and government 
accounting standards; examined agencies’ policies, site inventory data 
from September 2013 to July 2014, and financial statements; and 
interviewed EPA, Interior, and USDA officials. 

What GAO Found: 

The U.S. Department of Agriculture (USDA) and the Department of the 
Interior (Interior) have identified many contaminated and potentially 
contaminated sites, but neither agency has a complete inventory. As of 
April 2014, USDA had identified 1,491 contaminated sites and many 
potentially contaminated sites, including landfills and shooting 
ranges. However, USDA does not have a reliable, centralized site 
inventory or plans and procedures for completing one, in particular, 
for abandoned mines. Without a reliable inventory or plans and 
procedures for developing one, USDA cannot effectively manage its 
cleanup programs. As of April 2014, Interior had an inventory of 4,722 
sites with confirmed or likely contamination. In addition, Interior’s 
Bureau of Land Management (BLM) had identified over 30,000 abandoned 
mines that were not yet assessed for contamination, and this inventory 
is not complete. BLM is working to improve the completeness and 
accuracy of its inventory. 

In fiscal year 2013, USDA allocated over $22 million for environmental 
cleanup efforts, and Interior allocated over $13 million. 
Specifically, in fiscal year 2013, USDA allocated about (1) $3.7 
million for cleanup projects department-wide, primarily for one large 
site; (2) $4.3 million to mitigate contamination at grain silos and 
foreclosure properties; and (3) approximately $14 million for the U.S. 
Forest Service to assess and clean up sites. In fiscal year 2013, 
Interior allocated almost $10 million for cleanup projects department-
wide, the National Park Service allocated an additional $2.7 million 
and the Fish and Wildlife Service allocated over $800,000 for 
environmental assessment and cleanup projects. In addition, BLM 
allocated more than $34 million to its hazardous waste management and 
abandoned mine programs. 

Both USDA and Interior report probable and reasonably estimable 
environmental liabilities on their financial statements. In fiscal 
year 2013, USDA reported environmental liabilities of $176 million, 
most of which was for asbestos cleanup. Interior reported 
environmental liabilities of $192 million to address 434 sites. 
Interior also disclosed that it will incur $62 million to $139 million 
in cleanup costs at government-acknowledged sites—sites with damage 
caused by nonfederal entities. The majority of the costs Interior 
disclosed were for cleanup activities at 85 abandoned mines. As USDA 
and Interior complete their inventories and assess them for 
contamination, it might be expected that related environmental costs 
for both agencies will increase as additional sites are considered.
The Environmental Protection Agency’s (EPA) role with regard to USDA 
and Interior sites is to maintain a list of potentially contaminated 
sites based on data from these agencies, take steps to assure that the 
agencies assess these sites for contamination, determine whether the 
sites should be proposed for the National Priorities List, and oversee 
certain cleanup activities. EPA has compiled a docket list of 260 USDA 
sites and 528 Interior sites that may pose health or environmental 
risks, most of which have been assessed. Disagreement with USDA and 
Interior over their need to assess the remaining sites and differing 
information on whether this requirement has been met at some sites 
means EPA cannot assure that the assessments are conducted in a timely 
manner and, ultimately, that sites most in need of remediation are 
addressed. 

What GAO Recommends: 

GAO recommends that USDA develop plans and procedures for completing 
its site inventories and that EPA clarify which USDA and Interior 
sites need an environmental assessment. Interior and EPA generally 
agreed with GAO’s findings. USDA disagreed that its incomplete 
inventory affects the effectiveness of its cleanup programs, but GAO 
continues to believe that effective program management requires 
reliable data. 

View [hyperlink, http://www.gao.gov/products/GAO-15-35]. For more 
information, contact J. Alfredo Gómez at 202-512-3841 or 
gómezj@gao.gov. 

Contents: 

Letter: 

Background: 

USDA and Interior Have Identified Thousands of Contaminated and 
Potentially Contaminated Sites, but Neither Agency Has a Complete 
Inventory of Abandoned Mines: 

USDA and Interior Use Funds from a Variety of Sources to Assess and 
Clean Up Sites: 

USDA and Interior Report Over $350 Million in Environmental 
Liabilities in Their Annual Financial Statements: 

EPA's Primary Actions with Regard to Interior and USDA Sites Are 
Maintaining a List of Potentially Hazardous Sites and Overseeing the 
Cleanup at One NPL Site: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Number of and Cleanup Costs for Formerly Used Defense 
Sites on Department of the Interior and U.S. Department of Agriculture 
Properties: 

Appendix III: Cleanup Status of Department of the Interior's 
Environmental and Disposal Liability Sites: 

Appendix IV: USDA and Interior National Priorities List Sites: 

Appendix V: Comments from the U.S. Department of Agriculture: 

Appendix VI: Comments from the Environmental Protection Agency: 

Appendix VII: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: BLM's Contaminated or Potentially Contaminated Sites 
Identified as of April 2014: 

Table 2: Potentially Contaminated and Contaminated Sites for Selected 
Agencies: 

Table 3: USDA's Reported Preliminary Assessment Status of Disputed 
Docket Sites: 

Table 4: Interior Reported Preliminary Assessment Status of Disputed 
Docket Sites: 

Table 5: USDA and Interior NPL Sites, as of May 2014: 

Figures: 

Figure 1: Known BLM Abandoned Mine Sites in the Western United States: 

Figure 2: USDA's Hazardous Materials Management Appropriations (HMMA), 
Fiscal Years 2003-2013: 

Figure 3: Forest Service Environmental Compliance and Protection 
(ECAP) Funding Amounts, Fiscal Years 2003-2013: 

Figure 4: Number of Environmental and Disposal Liabilities (EDL) Sites 
in Each Stage of the Cleanup Process, as of Fiscal Year 2013: 

Abbreviations: 

AML: Abandoned Mine Lands: 

APHIS: Animal and Plant Health Inspection Service: 

ARS: Agricultural Research Service: 

BLM: Bureau of Land Management: 

CCC: Commodity Credit Corporation: 

CEE: Center for Environmental Excellence: 

CERCLA: Comprehensive Environmental Response, Compensation, and 
Liability Act: 

CHF: Central Hazardous Materials Fund: 

Corps: U.S. Army Corps of Engineers: 

DOD: Department of Defense: 

ECAP: Environmental Compliance and Protection: 

EDL: Environmental and Disposal Liability: 

EMD: Environmental Management Division: 

EPA: Environmental Protection Agency: 

FASAB: Federal Accounting Standards Advisory Board: 

FSA: Farm Service Agency: 

FUDS: Formerly Used Defense Sites: 

HMMA: Hazardous Materials Management Appropriation: 

HRS: Hazard Ranking System: 

Interior: Department of the Interior: 

NDAI: no DOD action indicated: 

NFS: National Forest System: 

NPL: National Priorities List: 

NPS: National Park Service: 

OIG: Office of Inspector General: 

OMB: Office of Management and Budget: 

PRP: potentially responsible party: 

RCRA: Resource Conservation and Recovery Act: 

SFFAS: Statement of Federal Financial Accounting Standards: 

USDA: U.S. Department of Agriculture: 

[End of section] 

United States Government Accountability Office: 
GAO:
441 G St. N.W. 
Washington, DC 20548: 

January 16, 2015: 

The Honorable Paul D. Tonko: 
Ranking Member: 
Subcommittee on Environment and the Economy: 
Committee on Energy and Commerce: 
House of Representatives: 

Dear Mr. Tonko: 

Agencies within the U.S. Department of Agriculture (USDA) and the 
Department of the Interior (Interior) manage over 700 million acres of 
land that include national parks, national forests, research centers, 
and laboratories. This vast acreage includes land that may be 
contaminated with hazardous waste[Footnote 1] from prior uses or 
events, such as landfills or toxic spills. In addition, abandoned 
mines from private mining activities on Interior and USDA lands can 
present major environmental cleanup challenges and expenses for the 
federal government. These lands are managed by five agencies within 
Interior, including the Bureau of Land Management (BLM) and the 
National Park Service (NPS), and five agencies within USDA, including 
the Forest Service and the Agricultural Research Service. 

The Comprehensive Environmental Response, Compensation, and Liability 
Act (CERCLA) of 1980 requires the Environmental Protection Agency 
(EPA) to compile a list of contaminated and potentially contaminated 
federal facilities. This list, known as the Federal Agency Hazardous 
Waste Compliance Docket (docket) is based on information that agencies 
are required by CERCLA and the Resource Conservation and Recovery Act 
(RCRA) of 1976 to report to EPA. In addition, the Chief Financial 
Officers Act of 1990[Footnote 2] requires and Office of Management and 
Budget (OMB) Circular A-136 and the Federal Accounting Standards 
Advisory Board's (FASAB) Statement of Federal Financial Accounting 
Standards (SFFAS) No. 5[Footnote 3] direct federal agencies to include 
environmental liabilities in their annual financial statements. 

In 1987 and 1994, GAO found that Interior and USDA were slow to 
complete an inventory of potentially contaminated sites for which they 
were responsible because of the size of their landholdings and limited 
resources.[Footnote 4] GAO's past work has also shown that BLM and 
Forest Service, the two principal agencies that manage federal lands 
available for hardrock mining, had no definitive estimates of the 
number of abandoned mines on their lands.[Footnote 5] 

You asked us to review the status of USDA's and Interior's potentially 
contaminated sites. This report examines (1) USDA's and Interior's 
efforts to develop an inventory of their contaminated and potentially 
contaminated sites, (2) funding levels for addressing their 
contaminated sites, (3) the amount of environmental liabilities the 
agencies report on their financial statements, and (4) EPA's role with 
regard to these sites. 

To conduct this work, we reviewed relevant inventory data covering the 
period of September 2013 to June 2014 from 10 agency sources and 
budget data related to environmental cleanup projects for fiscal years 
2003 through 2013. We also reviewed department and agency documents; 
government accounting standards and laws; and interviewed EPA, USDA, 
and Interior officials. To determine the status of USDA's and 
Interior's efforts to identify the universe of potentially 
contaminated sites on lands they manage, we reviewed each agency's 
policies and guidance on identifying new sites, and we interviewed 
agency officials on the completeness of their inventories. We 
collected data on both the number of contaminated sites in each 
agency's inventory, as well as the number of sites each agency has 
identified that could potentially be contaminated but have not yet 
been assessed to confirm contamination. Agencies with small 
inventories provided site numbers or a list. For the other agencies 
with more extensive inventories, we obtained information from a number 
of databases. To assess the reliability of the inventory lists from 
the agency databases, we reviewed available documents to determine the 
source of the information, data entry steps, and the completeness of 
the inventory, and interviewed agency officials. We found that some of 
the databases had inaccuracies and were not complete, but we 
determined that the data systems represented the available inventory 
identified and used by the agency and, therefore, were sufficiently 
reliable for our purposes of reporting USDA's and Interior's known 
contaminated sites. However, we do not feel that USDA's data on 
potentially contaminated sites was sufficiently reliable for the 
purpose of reporting the number of known potentially contaminated 
sites. To determine the funding levels for addressing the agencies 
sites in recent years, we selected the last decade as a reasonable 
period for analysis and, therefore, we collected and reviewed budget 
data for fiscal years 2003 through 2013. We also interviewed agency 
officials regarding estimated costs to address the abandoned mines on 
these agencies' properties. To determine the amount of environmental 
liabilities Interior and USDA report, we reviewed these departments' 
financial statements and interviewed officials in USDA's and 
Interior's Offices of Chief Financial Officer, USDA's Office of 
General Counsel, and Interior's Office of Solicitor. In addition, we 
collected and reviewed department and agency guidance on environmental 
liabilities and cost estimating. At Interior, we reviewed information 
from the Environmental and Disposal Liability (EDL) database. We 
reviewed the Chief Financial Officers Act of 1990, OMB Circular A-136, 
and the Federal Accounting Standards Advisory Board's (FASAB) 
Statement of Federal Financial Accounting Standards (SFFAS) No. 5 to 
better understand the applicable criteria.[Footnote 6] To determine 
the role of EPA with regard to these sites, we interviewed EPA 
officials with the Federal Facilities Restoration and Reuse Office and 
reviewed data from EPA's Comprehensive Environmental Response, 
Compensation, and Liability Information System on the status of USDA 
and Interior sites, as of December 2013. To assess the reliability of 
EPA's data on the status of the sites, we also obtained information 
from USDA and Interior on the status of their sites and documented any 
differences; we found the data to be sufficiently reliable for the 
purposes of this report. Finally, for all four objectives, we reviewed 
relevant laws--in particular, CERCLA and RCRA--and associated 
regulations and directives. Appendix I provides a detailed description 
of our objectives, scope, and methodology. 

We conducted this performance audit from April 2013 to January 2015 in 
accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Background: 

Federal law requires agencies to identify and report certain 
facilities where there is or has been hazardous waste activity or a 
release of hazardous substances. In addition, federal accounting 
standards direct federal agencies to develop cost estimates for 
certain environmental liabilities and report those estimates on their 
financial statements. 

Federal Agency Inventory Requirements: 

Federal agencies began developing inventories of contaminated and 
potentially contaminated sites in response to laws passed in the 
1980s. In 1980, Congress enacted CERCLA to respond to problems caused 
by improper disposal of hazardous substances in the past. Under 
CERCLA, responsible parties are liable for conducting or paying for 
site cleanup of hazardous substances, or for reimbursing others who 
conduct cleanups on their behalf, including federal agencies.[Footnote 
7] Furthermore, by June 1981, all such facility owners and operators 
were required to notify EPA of the existence of their facilities, as 
well as known, suspected, or likely releases of hazardous substances. 
These liability and notification provisions applied to the federal 
government and its contractors and lessees as well. 

Beginning in 1986, RCRA required agencies to undertake a continuing 
program to identify and report to EPA those facilities that the 
agencies own or operate--or previously owned or operated--that 
involved the treatment, storage, or disposal of hazardous wastes. 
These inventories must be updated biennially. RCRA does not set a 
deadline for completing the inventories. 

Reporting Environmental Liabilities on Agency Financial Statements: 

Federal accounting standards direct agencies responsible for cleaning 
up contamination to estimate cleanup costs and report those estimates 
on their financial statements as environmental liabilities. The 
Federal Accounting Standards Advisory Board's (FASAB) Statement of 
Federal Financial Accounting Standards (SFFAS) No. 5[Footnote 8] 
outlines standards based on whether events are government-related or 
government-acknowledged. Government-related events, or sites, involve 
interaction between federal entities and their environment, and 
include hazardous waste spills on federal property caused by federal 
operations. Government-acknowledged events are sites that are of 
financial consequence to the federal government because it chooses to 
respond to the event, and include toxic waste damage caused by 
nonfederal entities. SFFAS No. 5 directs an agency to report as a 
liability on its financial statements an amount for probable and 
reasonably estimable future costs associated with cleaning up 
contamination associated with these events, and to disclose the nature 
of the contingency, an estimate of the possible liability or the range 
of the possible liability, or a statement that such an estimate cannot 
be made for reasonably possible future costs in the notes to the 
financial statements. 

Guidance for implementing the standards[Footnote 9] indicates that 
there are two ways a federal agency's environmental liabilities may 
meet the "probable" cost criteria. The first way is when contamination 
is known, government-related, and represents a legal liability. The 
second way is when the contamination is known, government-
acknowledged, and funds have been appropriated for a cleanup or an 
event has occurred causing another party to expect payment (e.g., a 
contractor has performed cleanup of a site). 

The "reasonably estimable" criteria relates to an agency's ability to 
reliably estimate possible future costs associated with the cleanup of 
a contaminated site. In making such estimates, the agency is to 
consider several key factors, such as whether remedial investigations 
or feasibility studies have been conducted, prior experience with 
similar sites or conditions, and the availability of technology 
required to conduct cleanup operations. 

If a liability is probable, but a reasonable estimate of costs can 
only be expressed as a range, SFFAS No. 5 directs the agency to report 
the low end of the range on the face of the financial statement and 
disclose the complete range in the notes of its financial 
statement.[Footnote 10] Similarly, if a liability is "reasonably 
possible"--that is, the probability of future expenditures for a given 
site is less than probable but greater than remote--then SFFAS No. 5 
directs disclosure of the range of possible liability or a statement 
that such an estimate cannot be made. 

USDA and Interior Have Identified Thousands of Contaminated and 
Potentially Contaminated Sites, but Neither Agency Has a Complete 
Inventory of Abandoned Mines: 

USDA and Interior have identified many contaminated and potentially 
contaminated sites[Footnote 11], but neither agency has a complete 
inventory of sites, in particular, abandoned mines. There are 
approximately 1,491 USDA sites with confirmed contamination. However, 
USDA has not compiled a reliable, centralized inventory of known sites 
that are potentially contaminated and does not have plans or 
procedures for developing one. In particular, considerable work 
remains to identify abandoned mines on National Forest System (NFS) 
lands.[Footnote 12] Interior has identified 4,722 sites with confirmed 
or likely contamination on land it manages. Interior officials believe 
that this inventory is largely complete, except for abandoned mines. 
In this regard, Interior's BLM has over 30,000 abandoned mines in its 
inventory that it has not yet assessed for contamination, but the 
inventory is not complete. For example, BLM has estimated that there 
may be about 100,000 additional sites in California, Nevada, and Utah 
that have not yet been located, included in the inventory, and 
assessed for contamination. BLM has a centralized inventory database 
of its sites and has been taking steps to improve its data quality and 
completeness. 

USDA: 

According to our analysis of several USDA data sources,[Footnote 13] 
as of April 2014, there were at least 1,491 contaminated sites on land 
currently or previously managed by USDA. These sites include 1,422 
Forest Service sites--primarily abandoned mines--2 Animal and Plant 
Health Inspection Service (APHIS) sites, 3 Agricultural Research 
Service (ARS) sites, 61 former grain storage sites once managed by 
Commodity Credit Corporation (CCC), and 3 foreclosure properties 
belonging to the Farm Service Agency (FSA).[Footnote 14] 

In addition to sites with confirmed contamination, USDA agencies have 
also identified some potentially contaminated sites. ARS has 
identified 3 sites that are potentially contaminated. The Forest 
Service maintains multiple inventories of potentially contaminated 
sites that include landfills, shooting ranges, and cattle dip vats. 
However, there is no centralized database of these sites and no plans 
or procedures for developing one; the inventories are maintained at 
the regional level. A number of Forest Service officials we spoke with 
believe that most potentially contaminated sites in these categories 
have been identified but, for the reasons discussed below, they were 
unable to provide us with inventory numbers for all these sites. 

These various inventories do not provide a complete picture of the 
extent of USDA's potentially contaminated sites. For example, there 
are an unknown number of potentially contaminated former grain storage 
sites in the 29 states where the CCC previously used carbon 
tetrachloride. This number is unknown because the CCC relies on the 
states to notify it of potential contamination, and 25 of the 29 
states have not yet reported whether there is suspected contamination 
at their former CCC grain storage sites. The Forest Service also deals 
with various other types of hazardous waste sites, such as 
methamphetamine laboratories, roadside spills, and waste dumps. Forest 
Service officials said that, since these types of sites may involve 
illegal activities and are, therefore, not routinely reported, it is 
not possible to develop a comprehensive inventory of these types of 
sites.[Footnote 15] 

In addition, the Forest Service has not developed a complete, 
consistent, or usable inventory of abandoned mines and has no plans 
and procedures for developing such an inventory. The Forest Service 
estimates that there are between 27,000 and 39,000 abandoned mines on 
its lands[Footnote 16]--approximately 20 percent of which may pose 
some level of risk to human health or the environment, based on the 
professional knowledge and experience of its staff. Such risks may 
include chemicals and explosives, acid mine drainage, and heavy metal 
contamination in mine waste rock. However, because the Forest Service 
does not have a complete inventory of abandoned mine sites, the actual 
number of abandoned mines on NFS lands is unknown. Forest Service 
officials told us that they do not have the resources to complete a 
comprehensive inventory of all potentially contaminated abandoned 
mines on the agency's lands. However, without a comprehensive 
inventory of such sites or plans and procedures for developing one, 
USDA and the Forest Service will not have reasonable assurance that 
they are prioritizing and addressing the sites that pose the greatest 
risk to human health or the environment. 

The universe of abandoned mines on NFS lands is unknown for several 
reasons. According to a USDA official, USDA attempted to create a 
national inventory of NFS mines in 2003, with the creation of the 
Center for Environmental Excellence (CEE) database. This inventory 
pulled data from regional Forest Service inventories and currently 
shows 20,401 potentially contaminated abandoned mine or mill sites. 
[Footnote 17] However, these data are not complete or current and are 
therefore not usable for purposes of identifying a complete and 
accurate number of potentially contaminated abandoned mines currently 
on NFS lands. The Forest Service established the Abandoned Mine Lands 
(AML) database in 2008 to aggregate all available data on abandoned 
mines on NFS lands. The AML database drew data on pending abandoned 
mine sites from the CEE database and Forest Service regional 
inventories, as well as from the U.S. Geological Survey and various 
other federal, state, and local databases. USDA officials said that, 
once the AML database was established, the purpose of CEE shifted away 
from maintaining an AML inventory to tracking sites that entered into 
the CERCLA process.[Footnote 18] 

However, the AML database also has a number of shortcomings. For 
example, the data migration from multiple inventories led to data 
redundancy issues, such as some mine sites being listed multiple times 
under the same or different names. In addition, USDA officials told us 
that there is a lot of variation in the accuracy and completeness of 
the data on these mine sites, but a quality assurance review has not 
yet been performed. One Forest Service official said that, because of 
these problems, the data in the AML database are currently unusable 
for purposes of compiling a complete and accurate inventory of 
abandoned mines. In 2012, the Forest Service tried to obtain agency 
resources necessary to clean up the database. Even though the Forest 
Service rated this project as "critical," the project did not receive 
any resources because other projects were deemed more important, 
according to a Forest Service official. 

Similarly, there are several problems with the Forest Service's 
regional abandoned mine inventories.[Footnote 19] First, some regional 
inventories are incomplete. For example, officials in Forest Service 
Region 10, which is composed solely of the state of Alaska, believe 
that their inventory of active mine sites is largely complete, but 
they said that there may be some abandoned mines scattered throughout 
Tongass and Chugach National Forests that have not yet been 
inventoried. They said that Forest Service Region 10 does not have 
enough staff to assess all abandoned mines across such a large area. 
[Footnote 20] 

Second, several Forest Service regional inventories contain inaccurate 
data. For instance, Forest Service Region 1's inventory data include 
all mine records from the state of Montana--including those not on 
Forest Service lands. Forest Service Region 8 maintains several 
different abandoned mine databases, and one official told us that 
there are multiple redundancies across these databases. 

Third, the Forest Service's regional offices maintain their 
inventories differently. Some regional offices maintain their own 
inventories of potentially contaminated sites, whereas other regional 
offices utilize state or local agencies' inventories. In at least one 
instance, these inventories were not easily accessible. Specifically, 
Forest Service Region 2 relies heavily on various state and local 
inventories, but officials in that region did not provide us with data 
from those inventories when we requested them, instead they suggested 
we contact the state agencies.[Footnote 21] 

Finally, the type of data on abandoned mines varies from region to 
region and is therefore difficult to consolidate into a coherent 
national database. Some regional offices track mines at the site 
level, some by their features--such as mine shafts, pits, ore piles, 
or machinery--and some use both approaches.[Footnote 22] For example, 
officials in Forest Service Region 3 told us that they have identified 
over 3,000 abandoned mine sites, whereas officials in Forest Service 
Region 4 told us that they have identified approximately 2,000 mine 
features but have not yet consolidated these features into mine sites. 

Despite the lack of a complete inventory of potentially contaminated 
sites, the Forest Service said that the highest risk sites are well-
known due to their historic nature and past production of metal 
resources. According to the Forest Service, the abandoned mines that 
have not yet been identified include many small, poorly documented 
mines. The Forest Service said that many of these mines did not ever 
produce any ore and thus were only exploratory mines. Because of the 
high risk potential, the abandoned mine sites with the greatest human 
visitation and/or sensitive ecological receptors have been given 
priority for assessment, according to Forest Service officials. These 
officials said that only sites with significant risk are funded. 

Interior: 

Interior has identified 4,722 sites with confirmed or likely 
contamination. These include 4,098 BLM sites that the agency reports 
have confirmed contamination or require further investigation to 
determine whether remediation is warranted. The majority of these 
sites are abandoned mines. NPS has identified 417 sites with likely or 
confirmed contamination, the Bureau of Indian Affairs, 160; the Fish 
and Wildlife Service, 32; and the Bureau of Reclamation, 15. These 
agencies have identified additional locations of concern that require 
verification or initial assessment to determine if there are 
environmental hazards at the sites. Except for BLM, agency officials 
told us that they believe they have identified all sites with likely 
environmental contamination. The total number of sites BLM may 
potentially have to address is unknown, due primarily to incomplete 
and inaccurate data on abandoned mines on land managed by the agency. 

BLM accounts for the largest number of contaminated sites and sites 
that need further investigation in Interior's inventory. Table 1 shows 
the number of contaminated or potentially contaminated sites in BLM's 
inventory as of April 2014. 

Table 1: BLM's Contaminated or Potentially Contaminated Sites 
Identified as of April 2014: 

Requires further investigation and/or remediation; 
Hazardous materials sites: 346; 
Abandoned mines with potential environmental contamination: 2,853; 
Total sites: 3,199. 

Has remediation measures planned or underway; 
Hazardous materials sites: 546; 
Abandoned mines with potential environmental contamination: 353; 
Total sites: 899. 

Has been remediated; 
Hazardous materials sites: 1373; 
Abandoned mines with potential environmental contamination: 886; 
Total sites: 2,259. 

Requires no further action; 
Hazardous materials sites: 88; 
Abandoned mines with potential environmental contamination: 568; 
Total sites: 656. 

Total; 
Hazardous materials sites: 2,353; 
Abandoned mines with potential environmental contamination: 4,660; 
Total sites: 7,013. 

Source: Bureau of Land Management's (BLM) Abandoned Mine Lands/Site 
Cleanup Inventory database. GAO-15-35. 

Note: According to BLM, the Abandoned Mine Lands/Site Cleanup 
Inventory database is the agency's source of information regarding the 
inventory and status of abandoned mine and hazardous materials sites. 
BLM has not yet assessed all the sites on the ground, and the agency 
is constantly reviewing and updating the data. 

[End of table] 

As table 1 shows, BLM identified 2,353 hazardous materials sites as of 
April 2014, including underground storage tanks or landfills. Of these 
2,353 sites, 892 sites may still need to be addressed; 546 sites have 
confirmed contamination with remediation measures planned or under 
way, and 346 sites may potentially be contaminated and require an 
initial or further assessment to determine whether remediation is 
warranted.[Footnote 23] 

In addition, BLM identified 45,312 abandoned mine sites in its 
inventory database. As of April 2014, BLM identified that 4,660 
abandoned mine sites have or likely have environmental contamination. 
Of these 4,660 environmentally contaminated mine sites, 353 have 
remediation measures planned or under way, and 2,853 require further 
investigation to determine whether remediation is warranted. BLM 
reports that 40,652 of the 45,312 abandoned mine sites pose only 
physical safety hazards. However, 30,553 of these 40,652 physical 
safety sites need verification or initial assessment to determine 
whether environmental hazards are present. 

The number of potentially contaminated mines may be larger than BLM's 
inventory indicates because BLM has not identified all of the 
abandoned mines on the land it manages. BLM estimates that there may 
be approximately 100,000 abandoned mines that have not yet been 
inventoried in three selected states, and that it would take 2 to 3 
years to complete the estimates for the other nine BLM states. BLM 
estimates that it will take decades to complete the inventory. To 
inventory a site, BLM field staff must visit the site to collect data, 
research the land ownership and extent of mining activity that 
occurred, and record the information in BLM databases. 

The reliability of BLM's inventory of abandoned mines has been a long-
standing concern. In 2005, Interior's Office of Inspector General 
(OIG) reported that BLM's national inventory of abandoned mines was 
incomplete, inaccurate, and inconsistent.[Footnote 24] In addition, 
the OIG found that the BLM field office staff responsible for 
abandoned mines was not identifying or entering known, high-priority 
abandoned mine sites into the inventory database. Many of the sites 
listed in the database were obtained from old Bureau of Mines data 
that was never verified by site visits. Given the limited funds 
available, the OIG noted that it was important that the inventory 
include current and credible information needed for program management 
of significant sites. On this basis, the OIG recommended that BLM 
validate existing inventory data and develop procedures for ongoing 
data collection to ensure that data in the inventory is complete, 
accurate, and consistent. 

BLM agreed with the recommendation and has made an effort to improve 
data quality and the inventory's completeness. BLM has an ongoing 
effort to estimate the number of abandoned mines and mine features 
that have not yet been inventoried on BLM lands and the approximate 
cost to complete the inventory. BLM established inventory teams in 
several states to go out and identify sites.[Footnote 25] In addition, 
BLM began an initiative in California to determine the number of sites 
that need to be inventoried after the state provided the agency with 
digitized maps of potential mine sites and verified a sample of the 
sites. For California, BLM estimated that 22,728 sites and 79,757 
features need to be inventoried. Of these, BLM estimated that 
approximately 2,600 sites will have environmental hazards. BLM 
estimates that it will cost approximately $120 million to confirm the 
inventory of 22,728 sites. BLM has estimated approximately 69,000 and 
4,000 sites remain to inventory in Nevada and Utah, respectively, on 
BLM land. BLM officials told us that they expect to provide a report 
to Congress on the inventory work remaining in these three states in 
2015. The nine remaining states with BLM land do not have the digital 
geographic data available that BLM has been using for California, 
Nevada, and Utah, according to BLM officials, making it difficult for 
BLM to develop similar estimates for these states.[Footnote 26] BLM 
officials told us that the U.S. Geological Survey is working on an 
effort to develop datasets similar to those used to estimate the 
number of abandoned mines on the BLM land in California, Nevada, and 
Utah. 

In addition, BLM has provided a contractor approximately $1 million to 
assist with entering additional sites in its database from records 
stored in local BLM offices. The contractor has also been working to 
clean the database of duplicate records, ensuring location data is 
correct, adding names to unnamed records, and conducting field 
verification of sites. According to BLM, the inventory of abandoned 
mines in the database was 19,000 in 2008, and it has increased to over 
45,000. Figure 1 shows the known BLM abandoned mine sites in the 
western United States. 

Figure 1: Known BLM Abandoned Mine Sites in the Western United States: 

[Refer to PDF for image: 2 maps] 

Depicted on the maps: 

Bureau of Land Management (BLM) lands; 
Known BLM abandoned mine lands sites. 

Source: BLM. GAO-15-35. 

[End of figure] 

After BLM, the NPS is the Interior agency with the largest number of 
potentially contaminated and contaminated sites. Like BLM, NPS has 
hazardous materials sites, such as landfills and underground storage 
tanks, and abandoned mine sites. NPS has identified 377 hazardous 
materials sites where the presence or likely presence of contamination 
is at concentrations significant enough to require further assessment 
or cleanup. NPS also has identified 96 locations of concern. These are 
sites where contamination is suspected based on known past activities 
or observed and reported physical indicators but which require further 
assessment. Nearly half of these are old dump sites. 

In 2013, NPS completed a system-wide inventory and assessment project 
to identify abandoned mines on lands they manage and entered this 
information in their "Abandoned Mineral Lands Database." NPS used 
specialists trained in natural sciences with knowledge of mining and 
exploration methods, equipment, and impacts to develop the inventory. 
[Footnote 27] NPS's inventory identified 37,050 mine features at 3,421 
sites on NPS land. Of the total inventory, NPS believes that 3,841 
features at 1,270 sites still require some level of effort to address 
human health and safety and/or environmental concerns. According to 
the NPS, there are 1,270 sites that require action, there are 227 
sites in 76 parks that have or may have environmental contamination: 
40 sites are confirmed, and 187 sites are locations of concern. 
According to NPS officials, these locations of concern require 
verification or initial assessment to determine if there are 
environmental hazards. According to the NPS, the remaining 1,043 
abandoned mine sites pose physical safety hazards rather than 
environmental hazards. As a result of this effort, officials with 
NPS's Abandoned Mineral Lands Program told us that they now believe 
that their inventory of all potentially contaminated sites is largely 
complete. 

Bureau of Indian Affairs, Bureau of Reclamation, and Fish and Wildlife 
Service also have sites with environmental contamination. Officials 
from each of these agencies told us that they believe their 
inventories of sites with environmental contamination are complete. In 
addition to contaminated sites, the Fish and Wildlife Service has a 
number of potentially contaminated locations of concern at wildlife 
refuges and hatcheries that need to be investigated to determine if 
contamination exits. Table 2 below notes the number of contaminated 
and potentially contaminated sites for each of these agencies. 

Table 2: Potentially Contaminated and Contaminated Sites for Selected 
Agencies: 

Agency: Bureau of Indian Affairs; 
Locations of concern: 4; 
Sites with known or suspected contamination: 160. 

Agency: Bureau of Reclamation; 
Locations of concern: [A]; 
Sites with known or suspected contamination: 15. 

Agency: Fish and Wildlife Service; 
Locations of concern: 394[B]; 
Sites with known or suspected contamination: 32. 

Sources: Locations of concern data was provided by each individual 
agency. The source of contamination known or suspected is from 
Interior's Environmental and Disposal Liability database as of the 
close of fiscal year 2013. GAO-15-35. 

[A] The Bureau of Reclamation's inventory of locations of concern is 
maintained in its regional offices, and we did not collect this 
information because we determined that it was impractical to do so 
given the relatively small amount of land managed by this agency. 

[B] The U.S. Fish and Wildlife Service's field stations (refuges and 
hatcheries) have identified locations of concern at 394 locations. 
This does not equate to 394 locations of concern; rather, it is the 
number of field stations identifying a location of concern. 

[End of table] 

USDA and Interior Use Funds from a Variety of Sources to Assess and 
Clean Up Sites: 

USDA and Interior use funding from annual appropriations to assess and 
to clean up sites. In addition, one of the USDA agencies uses funds it 
is authorized to borrow to carry out assessment and cleanup 
activities. USDA and Interior have also used one-time Recovery Act 
funds[Footnote 28] for these purposes. In addition, both USDA and 
Interior seek cost recovery funds from potentially responsible parties 
to help offset cleanup costs at sites where those parties caused or 
contributed to contamination. 

USDA: 

In fiscal year 2013, USDA allocated over $22 million to environmental 
cleanup efforts. Specifically, USDA allocated (1) $3.7 million for 
department-wide cleanup projects, the majority of which were for 
cleanup at USDA's Beltsville site and to cover legal expenses; (2) 
$4.3 million in funds to mitigate contamination at former grain 
storage sites; and (3) approximately $14 million for the Forest 
Service to conduct environmental assessments and cleanup activities. 
[Footnote 29] 

USDA's funds for environmental cleanup programs declined annually for 
fiscal years 2003 through 2013--with the exception of 2009, when USDA 
used Recovery Act funds for this purpose. USDA's funds over this 
period were composed of USDA's department-wide Hazardous Materials 
Management Appropriation (HMMA), the Forest Service's Environmental 
Compliance and Protection (ECAP) funds, funds the CCC is authorized to 
borrow, and one-time Recovery Act funds for the Forest Service. 
[Footnote 30] 

* HMMA is USDA's department-wide account that is available to pay for 
cleanup activities, among other things.[Footnote 31] Of USDA's three 
annual sources of environmental cleanup funding, the HMMA account has 
experienced the most precipitous decline. According to USDA, HMMA 
funds declined from $15.7 million in fiscal year 2003 to $3.7 million 
in fiscal year 2013--a decrease of over 76 percent (see fig. 2). As a 
result, USDA has been able to fund fewer cleanup activities. In fiscal 
year 2003, USDA funded 110 cleanup and support activities at 81 sites 
and USDA offices with HMMA funds. In contrast, in fiscal year 2013, 
USDA was only able to fund 4 cleanup and support activities with HMMA 
funds. USDA officials said that these funds have decreased as a result 
of decreases in appropriations. 

Figure 2: USDA's Hazardous Materials Management Appropriations (HMMA), 
Fiscal Years 2003-2013: 

[Refer to PDF for image: line graph] 

Fiscal year: 2003: $15.7 million. 

Fiscal year: 2004: $15.6 million. 

Fiscal year: 2005: $15.5 million. 

Fiscal year: 2006: $12 million. 

Fiscal year: 2007: $12 million. 

Fiscal year: 2008: $4.9 million. 

Fiscal year: 2009: $5.1 million. 

Fiscal year: 2010: $5.1 million. 

Fiscal year: 2011: $4 million. 

Fiscal year: 2012: $3.6 million. 

Fiscal year: 2013: $3.7 million. 

Source: USDA. GAO-15-35. 

[End of figure] 

* The ECAP program is the primary source of funding for the Forest 
Service's environmental cleanup programs. The Forest Service allocates 
approximately $500,000 a year to each of its nine regional offices for 
a variety of activities including preliminary assessments, site 
inspections, and small cleanups. The Forest Service awards the 
remaining funds to its regional offices for larger, high-priority 
assessments and cleanups on a priority basis. The ECAP program has 
also experienced a decline in recent years. USDA officials said that 
these funds have also decreased as a result of decreases in 
appropriations. ECAP funds have declined from $28 million in fiscal 
year 2003 to $14.4 million in fiscal year 2013--a decrease of 48 
percent.[Footnote 32] The ECAP program does not have historical 
records on ECAP projects going back to fiscal year 2003, so we were 
not able to compare the number and type of cleanup projects from that 
time with similar projects in recent years. However, in fiscal year 
2013, the ECAP program funded 61 projects, including assessments, 
cleanup activities, PRP oversight, and maintenance activities. Figure 
3 shows the decline in funds. 

Figure 3: Forest Service Environmental Compliance and Protection 
(ECAP) Funding Amounts, Fiscal Years 2003-2013: 

[Refer to PDF for image: line graph] 

Fiscal year: 2003: $28.0 million. 

Fiscal year: 2004: $26.7 million. 

Fiscal year: 2005: $24.2 million. 

Fiscal year: 2006: $17.4 million. 

Fiscal year: 2007: $13.6 million. 

Fiscal year: 2008: $9.5 million. 

Fiscal year: 2009: $16.6 million. 

Fiscal year: 2010: $16.3 million. 

Fiscal year: 2011: $16.2 million. 

Fiscal year: 2012: $16.2 million. 

Fiscal year: 2013: $14.4 million. 

Source: USDA. GAO-15-35. 

[End of figure] 

* The CCC uses up to $5 million annually from funds it is authorized 
to borrow,[Footnote 33] and it also requests HMMA or other funds when 
needed. CCC uses these funds to mitigate contamination at its former 
grain storage sites. CCC officials told us that contamination at the 
former grain storage sites tends to be widespread, making cleanup 
difficult, expensive, and time-consuming. For fiscal years 2003 
through 2013, CCC assessed 31 sites, and it initiated or completed 
cleanup at 9 sites. Twelve sites also received No Further Action 
status. 

* The Forest Service also allocated approximately $20 million in one-
time Recovery Act funds in fiscal year 2009 to cleanup activities at 
14 sites located on, or directly impacting, land managed by the Forest 
Service. 

In addition to these four funding sources, USDA seeks recovery of 
cleanup costs and natural resource damages under CERCLA from 
potentially responsible parties, such as owners and operators of a 
site, to help offset cleanup costs at sites where they caused or 
contributed to contamination.[Footnote 34] Cost recovery amounts vary 
from year to year. Between fiscal years 2003 and 2013, USDA typically 
recovered $30 million or less. However, according to agency documents, 
USDA successfully recovered over $170 million from a single mining 
company as part of a bankruptcy case in 2009. These funds were used to 
conduct cleanup activities at 13 mine sites located on NFS lands. In 
fiscal year 2011, USDA recovered $65 million from another mining 
company for restoration of injured natural resources in the Coeur 
d'Alene River Basin NPL site in Idaho. 

Currently, the majority of USDA's environmental cleanup funds are 
spent cleaning up ARS's Beltsville NPL facility and abandoned mines 
and landfills on NFS lands, as well as mitigating potential 
groundwater contamination from activities at former CCC former grain 
storage sites. In 2003, USDA established the CEE database to track 
progress on all hazardous waste cleanup projects funded with HMMA 
funds. However, a series of budget cuts led USDA to scale back and 
repurpose the database. Currently, CEE serves to gather accomplishment 
data--such as site identification efforts, assessments, and cleanup 
activities--for the Forest Service, regardless of funding source. 
Because most of USDA's contaminated sites are located on land managed 
by the Forest Service, CEE data provide an important snapshot of 
USDA's historical accomplishments. A review of CEE data and Forest 
Service Region 10 data show that the Forest Service has conducted at 
least 714 assessments[Footnote 35] and cleaned up 371 sites[Footnote 
36] between fiscal years 2003 and 2013. EMD issued an accomplishment 
report in 2011 and 2012 based on CEE data and supplemental agency 
data, such as data from its annual call letter. According to a USDA 
official, EMD plans to continue issuing such reports on an annual 
basis.[Footnote 37] 

Interior: 

In fiscal year 2013, Interior allocated about $13 million for 
environmental cleanup efforts. Specifically, Interior allocated $10 
million for cleanup projects department-wide, NPS allocated an 
additional $2.7 million and the Fish and Wildlife Service allocated 
over $800,000 for environmental assessment and cleanup projects. In 
addition to these project funds, BLM allocated more than $34 million 
to its hazardous management and abandoned mine programs. BLM provided 
over $18 million of these funds to its state offices; however, the 
amount of these funds specifically used for environmental cleanup 
projects was not readily available. 

From fiscal years 2003 through 2013, Interior allocated over $148 
million in Central Hazardous Materials Fund (CHF) resources to its 
agencies to support response actions undertaken at contaminated sites 
under CERCLA. This amount includes over $49 million in CHF "cost 
recoveries"--that is, funds recovered from or paid in advance to 
Interior by potentially responsible parties for past or future cleanup 
costs. To be eligible for CHF funding under agency policy, a site must 
have a completed preliminary assessment/site inspection, pose a 
significant risk to human health or the environment, and have a 
potentially responsible party search initiated or completed, among 
other things. Interior's agencies nominate projects for CHF funding. A 
technical review committee evaluates the project nominations and 
recommendations are forwarded to the Deputy Assistant Secretary for 
Policy and International Affairs for approval. Interior's agencies 
undertook 101 projects with CHF funding during fiscal years 2003 
through 2013. These projects support a range of activities, from 
project oversight to advanced studies (e.g., remedial investigations, 
feasibility studies, engineering evaluations, and cost analyses) to 
removal and remedial actions. The majority of sites receiving CHF 
funding were abandoned mines, landfills, and former industrial 
facilities. In fiscal year 2013, Interior allocated $10 million to the 
CHF. 

As previously noted, within Interior, BLM has the largest inventory of 
sites with potential environmental contamination and contaminated 
sites. BLM has two programs that address environmental contamination, 
among other things. The Abandoned Mine Lands Program works to address 
both environmental contamination and physical safety issues at mines. 
The Hazardous Materials Management and Resource Restoration Program 
addresses environmental issues across all BLM-managed lands, and it 
may help address environmental issues at high-priority abandoned mine 
sites. In fiscal year 2013, BLM allocated over $34 million to these 
two programs. Specifically, in fiscal year 2013, BLM allocated $16 
million to the Hazardous Management and Resource Restoration Program. 
Funding for the program has fluctuated between approximately $16 
million and $17 million each fiscal year since 2003. Funding for the 
Abandoned Mine Lands Program increased by almost $6.5 million in 
fiscal year 2009, and the program has retained these increased funds. 
In fiscal year 2013, BLM allocated $18.7 million to the Abandoned Mine 
Lands Program. 

Of the $18.7 million funds allocated in fiscal year 2013, BLM provided 
over $4.5 million to BLM state offices for hazardous waste projects at 
mines.[Footnote 38] Using funds received from both the Hazardous 
Materials Management and Resource Restoration Program and Abandoned 
Mine Lands Program, BLM provided over $14 million to the BLM state 
offices to cover program operations, expenses, and projects. According 
to BLM officials, after the BLM state offices fund program operations 
and expenses, they spend the remainder of the funds on (1) physical 
safety projects at abandoned mines and (2) environmental projects at 
abandoned mines or other sites needing cleanup. However, BLM 
headquarters does not compile information on the amount of funds each 
BLM state office had for such projects, the number of projects state 
offices conducted, or the amount spent on projects. As such, 
headquarters officials could not provide us with information on the 
amount of funds spent on environmental projects versus physical safety 
projects. 

BLM also spent over $27 million in one-time Recovery Act funds on 
physical safety and/or environmental remediation projects at 76 
locations. According to BLM, there were 31 projects for environmental 
activities. 

BLM officials told us that the current funding levels are not 
sufficient to complete the inventory and address the physical and 
environmental hazards at abandoned mines. In its 2014 and 2015 budget 
justifications, Interior described proposals to charge the hardrock 
mining industry fees and use the funds to address abandoned mines. 
Interior proposes to levy a fee on all uranium and metallic mines on 
both public and private lands. The proposed fee would be charged per 
volume of material displaced. The fees collected would be distributed 
to two sets of funds, one for federal lands and another for nonfederal 
lands. The Secretary would disperse the share of non-federal funds to 
each state and tribe based on need. Each state and tribe would select 
its own priority projects using established criteria. 

NPS allocates an average of $2 to $3 million each year to its own 
cleanup fund, and it allocated $2.7 million in fiscal year 2013. NPS 
uses a combination of risk factors to rank sites for receiving these 
funds, including human risk, ecological risk, and the potential for 
leveraging funds from other responsible parties. An NPS official told 
us that the agency has inadequate funding to address its over 400 
potentially contaminated and contaminated sites. The agency has been 
able to address its highest risk sites with funding from the CHF. If 
there is a very significant risk, NPS can usually obtain funds to 
address the portion of the site that has the highest risk, if not the 
site as a whole. According to NPS officials, NPS has not selected 
response actions for almost 300 sites because current funding levels 
are not sufficient to address them. 

The Fish and Wildlife Service uses project funds from its Refuge 
Cleanup Fund. The National Wildlife Refuge System set aside $1.7 
million in annual appropriations in fiscal year 2003, but these funds 
have decreased over the last decade to $834,000 in fiscal year 2013. 
The Fish and Wildlife Service uses a portion of these funds for 
environmental compliance work. For example, in fiscal year 2013, the 
Fish and Wildlife Service approved funding of about $700,000 for 11 
projects such as an underground storage tank remediation and a site 
investigation at a firing range. Fish and Wildlife Service officials 
review proposals for cleanup projects on national wildlife refuges and 
select sites for the funds using a ranking system based on risk to 
human health and the environment, legal requirements, and regional 
priorities. For emergency response to chemical and hazardous material 
accidents or immediate removal, Fish and Wildlife officials said the 
agency can use funds from an emergency construction account. 

Interior tracks the progress of cleanup at sites listed as 
environmental and disposal liabilities in the Environmental Management 
Information System on a quarterly basis. The stage of cleanup for 756 
sites is provided in appendix III. 

USDA and Interior Report Over $350 Million in Environmental 
Liabilities in Their Annual Financial Statements: 

USDA and Interior reported environmental liabilities of $176 million 
and $192 million, respectively, in their fiscal year 2013 financial 
statements. These liabilities represent what the agencies have 
determined to be the probable and reasonably estimable future costs to 
address 100 USDA sites and 434 Interior sites, as required by federal 
accounting standards. 

In its fiscal year 2013 financial statements, USDA reported a total of 
$176 million in environmental liabilities. The $176 million amount 
included: $165 million to address asbestos contamination,[Footnote 39] 
$8 million for up to 76 CCC former grain storage sites in the Midwest 
that are contaminated with carbon tetrachloride,[Footnote 40] and $3 
million for 24 Forest Service sites, including guard stations, work 
centers, and warehouses, among others.[Footnote 41] USDA also reported 
$40 million in contingent liabilities[Footnote 42] for environmental 
cleanup at four phosphate mine sites in Southeast Idaho.[Footnote 43] 

Interior reported $192 million in environmental liabilities in its 
fiscal year 2013 financial statements. This number reflects the low 
end of a range of probable future costs for completing cleanup 
activities at 434 sites. These activities include studies or removal 
and remedial actions at sites where Interior has already conducted an 
environmental assessment and where Interior caused or contributed to 
the contamination or has recognized its legal obligation for 
addressing the site. Interior also disclosed in notes to its financial 
statements the estimated cost range for completing cleanup activities 
at these sites. The cost range disclosed was approximately $192 
million to $1.3 billion. The difference between the upper and lower 
ends of the range ($1.1 billion) reflects the additional potential 
cost for addressing these sites. 

Interior also disclosed the estimated costs for government 
acknowledged sites where it was reasonably probable that cleanup costs 
would be incurred. In fiscal year 2013, Interior disclosed in the 
notes to its fiscal year 2013 financial statements a cost range for 
these activities to be approximately $62 million to $139 million. 
[Footnote 44] The majority of this cost range was related to 
addressing 85 abandoned mine sites. 

As USDA and Interior complete their inventories and assess them for 
contamination, it might be expected that related environmental costs 
for both agencies will increase as additional sites are considered. 

EPA's Primary Actions with Regard to Interior and USDA Sites Are 
Maintaining a List of Potentially Hazardous Sites and Overseeing the 
Cleanup at One NPL Site: 

EPA's primary roles with regard to contaminated and potentially 
contaminated sites under USDA's or Interior's jurisdiction include (1) 
placing the sites on the docket, (2) taking steps to assure that 
assessments of the sites are conducted, (3) determining whether the 
sites should be proposed for listing on the NPL, and (4) overseeing 
the cleanup of sites placed on the NPL. From information provided by 
the federal agencies, EPA has compiled a docket of federal sites that 
may pose a risk to human health and the environment, including 260 
USDA sites and 528 Interior sites. Furthermore, EPA continues to 
review new information provided by USDA and Interior to determine if 
any additional sites should be added to the docket. EPA also is 
responsible for ensuring that USDA and Interior assess these sites for 
contamination; USDA and Interior have assessed the majority of these 
sites. EPA has also placed a number of USDA and Interior sites on the 
NPL and is currently overseeing the ongoing cleanup of one USDA NPL 
site. 

EPA Is Responsible for Placing Certain Sites on the Federal Agency 
Hazardous Waste Compliance Docket: 

EPA is responsible for compiling a list of potentially contaminated 
federal facilities reported by agencies under certain provisions of 
RCRA or CERCLA. This list is the Federal Agency Hazardous Waste 
Compliance Docket (docket). EPA compiled the first docket in 1988 and 
CERCLA requires EPA to publish a list of any new sites added to the 
docket in the Federal Register every 6 months. EPA updates the docket 
after receiving and reviewing notices from federal agencies concerning 
the generation, transportation, treatment, storage, or disposal of 
hazardous wastes or release of hazardous substances. Specifically, 
section 120(c) of CERCLA requires the agency to update the docket with 
information submitted by federal agencies under the following 
statutory provisions: 

* Section 3005 of RCRA, which requires owners and operators of 
facilities where hazardous waste is treated, stored, or disposed ("TSD 
facilities") to provide certain information to EPA when applying for 
permits. 

* Section 3010 of RCRA, which requires owners and operators of TSD 
facilities, as well as generators and transporters of hazardous waste, 
to notify EPA of their hazardous waste activities. 

* Section 3016 of RCRA, which requires federal agencies to prepare a 
biennial inventory of hazardous waste sites currently or previously 
owned or operated. 

* Section 103(a) of CERCLA, which requires facility owners/operators 
to notify the National Response Center of any reportable releases of 
hazardous substances. 

EPA officials told us if agencies fail to comply with hazardous waste 
self-reporting requirements and do not report a site, it is difficult 
for EPA to know about the site to list it. However, if EPA learns 
about a site that has had a release or threat of a release of 
hazardous substances through other means, EPA will list the site on 
the docket. 

It is EPA's policy to exclude certain categories of sites from docket 
listing. For instance, small quantity generators of hazardous waste 
(less than 1,000 kilograms in any month) are excluded from docket 
listing unless they have reported releases.[Footnote 45] While EPA 
lists some abandoned mines on the docket, in 2003, EPA issued a policy 
statement that mines with "mixed ownership"--mines located partially 
on private land and partially on public land--should typically not be 
included on the docket. Instead, individual mines should be evaluated 
on a case by case basis. Under this approach, EPA has listed a number 
of mixed ownership mines on the docket. 

EPA has published 26 updates of the docket as of September 2014, but 
the agency has not consistently met the 6-month reporting requirement. 
Agency officials said that they have not met this requirement in 
recent years due to staff efforts to include as many facilities as 
possible in each docket publication by enabling longer quality 
assurance reviews of facilities that were identified as potential 
docket sites. Prior to 2014, the effort to compile and monitor the 
docket listings was a manual process. However, in 2014, EPA 
implemented revised docket procedures with a computer based process 
that is to compile potential docket listings from agency notices by 
searching electronic records. According to EPA officials, the first 
docket update with the new system will be published by the end of 
fiscal year 2014. EPA officials said that they expect the new system 
to allow them to update the docket in a more timely way in the future. 

Since 1988, EPA has listed 260 USDA sites and 528 Interior sites on 
the docket. However, EPA, Interior, and USDA officials disagree over 
whether some of these sites should have been listed. EPA and Interior 
officials disagree about the overall approach of listing sites on the 
docket that are not reported to EPA by an agency. Interior officials 
believe that CERCLA does not give EPA the discretion to list sites 
unless Interior reports the sites to EPA and that EPA should limit its 
listing of sites on the docket to those reported by an agency under 
one of the provisions specifically noted in CERCLA. Interior and USDA 
officials also believe that abandoned mines should not be listed on 
EPA's docket because the agencies did not cause the contamination, 
and, therefore, the sites should not be considered federal sites. 
However, EPA officials believe that, regardless of whether USDA and 
Interior are legally liable for addressing these sites, they have an 
independent responsibility under Executive Order 12580[Footnote 46] 
and CERCLA as land management agencies owning the sites to address 
them. 

EPA's docket and USDA's and Interior's inventory lists differ in a 
number of ways. First, the docket includes a historical record of 
potentially contaminated sites that typically have been reported to 
EPA by the agencies. Because it includes a historical record, sites 
that subsequently were found to not be contaminated and sites that the 
agencies may have addressed are still included on the docket. 
Furthermore, agency inventories may include potentially contaminated 
sites that the agency is not required to report to EPA for inclusion 
on the docket. For example, an abandoned mine that is not known to 
have had a reportable release of a hazardous substance may not have to 
be reported to EPA. 

EPA Is Responsible for Taking Steps to Assure That Preliminary 
Assessments Are Conducted for Docket Sites: 

After a site is listed on the docket, CERCLA requires EPA to take 
steps to assure that a preliminary assessment is conducted. EPA has 
established 18 months as a reasonable time frame for agencies to 
complete the preliminary assessment. However, EPA cannot enforce the 
requirement or penalize agencies for not completing a preliminary 
assessment within the 18-month time frame. As of February 2014, both 
Interior and USDA had conducted a preliminary assessment of the 
majority of their sites on EPA's docket. However, EPA, Interior, and 
USDA have differing information on the status of preliminary 
assessments for their docket sites. 

Our analysis of data in EPA's Comprehensive Environmental Response, 
Compensation, and Liability Information System showed that USDA had 
completed preliminary assessments for 186 of the 260 USDA sites on the 
docket and submitted a preliminary assessment for 24 sites where EPA 
has yet to make a decision about whether the preliminary assessment is 
complete. According to EPA's data, USDA still needs to conduct a 
preliminary assessment at 50 docket sites. We reviewed the 50 sites 
with USDA officials. These officials told us that they believe no 
further action is required at 48 of these sites. They noted that 
preliminary assessments had been conducted at 34 of the sites, 
including locations where USDA's records indicate that a preliminary 
assessment was provided to EPA, cleanup actions were completed, or 
USDA had notifications from EPA or state environmental agencies that 
no further action is required. Of the remaining 16 sites, USDA 
officials said that a time critical removal of hazardous waste was 
conducted at 4 sites in lieu of a preliminary assessment. USDA 
officials said that they had no plans to conduct a preliminary 
assessment at 8 of the sites because a hazardous release had not 
occurred. These sites are listed on the docket because of their past 
or present operation as a disposal facility--not because of any 
identified release of hazardous waste--that triggered a notice to 
EPA.[Footnote 47] According to USDA, these sites are listed on the 
docket because of their past or present operation as a one time or 
periodic large quantity RCRA generator, not because of any identified 
release of hazardous waste. USDA said that it does not believe that 
facilities in good standing that handle hazardous waste and generate a 
manifest under RCRA should then have to conduct a preliminary 
assessment as a result of a docket listing. A preliminary assessment 
is to be conducted for sites listed on the docket, however.[Footnote 
48] USDA believes that two sites are listed in error-
-one does not belong to USDA, and the other USDA believes is a 
duplicate listing. Table 3 shows the preliminary assessment status 
USDA provided on these 50 sites. 

Table 3: USDA's Reported Preliminary Assessment Status of Disputed 
Docket Sites: 

Status: Preliminary assessment complete; 
Number of sites: 34. 

Status: No release occurred[A]; 
Number of sites: 8. 

Status: Time critical removal in lieu of preliminary assessment; 
Number of sites: 4. 

Status: Undetermined; 
Number of sites: 2. 

Status: Other[B]; 
Number of sites: 2. 

Status: Total; 
Number of sites: 50. 

Sources: USDA and GAO analysis of EPA data. GAO-15-35. 

[A] These sites are listed on the docket because of their past or 
present operation as a disposal facility, not necessarily because of 
any identified release of hazardous waste. 

[B] USDA believes one of these sites is the responsibility of another 
agency and that one is a duplicate docket listing. 

[End of table] 

Based on our analysis of EPA data, Interior has conducted preliminary 
assessments at 442 of 528 docket sites. In addition, EPA has received 
7 preliminary assessments from Interior that they are still reviewing. 
According to EPA's data, Interior still needs to conduct a preliminary 
assessment at 79 docket sites. We reviewed the status of the remaining 
79 docket sites with Interior officials. These officials told us they 
believe they have met the preliminary assessment requirement at 47 of 
the 79 sites. According to Interior officials, these include sites 
where remedial investigations have been conducted, sites where cleanup 
activities are ongoing, and sites where cleanup activities are 
completed. In addition, the officials said that 1 site had a 
preliminary assessment in progress, and 3 of the docket sites still 
need a preliminary assessment. Interior officials do not have plans to 
conduct a preliminary assessment at 26 sites for a number of reasons. 
Interior reported that cleanup at 13 of the sites was the 
responsibility of another agency. According to Interior, three sites 
are small quantity generators, and the agency believes the sites 
should have been excluded from the docket. Interior does not have 
plans to conduct a preliminary assessment at 4 sites because they 
disagree with the listing. For some of these 4 sites, NPS officials 
said that they had no knowledge of a release at the site and that the 
agency had not provided any type of notice to EPA regarding the site. 
Table 4 shows the preliminary assessment status of the 79 docket sites 
as reported by Interior. 

Table 4: Interior Reported Preliminary Assessment Status of Disputed 
Docket Sites: 

Status: Preliminary assessment conducted; 
Number of sites: 47. 

Status: Responsibility of DOD or U.S. Army Corps of Engineers; 
Number of sites: 13. 

Status: Unknown site[A]; 
Number of sites: 6. 

Status: Disagreement with docket listing; 
Number of sites: 4. 

Status: Preliminary assessment needed; 
Number of sites: 3. 

Status: Small quantity generator; 
Number of sites: 3. 

Status: Other[A]; 
Number of sites: 2. 

Status: Preliminary assessment in progress; 
Number of sites: 1. 

Status: Total; 
Number of sites: 79. 

Sources: Interior and GAO analysis of EPA data. GAO-15-35. 

[A] Unknown sites are sites listed on the docket that did not list a 
responsible agency name. We sent a list of these sites to the Interior 
agencies and no agency recognized or claimed these sites. Other 
includes two docket sites for the U.S. Geological Survey that we did 
not include in the scope of this review. 

[End of table] 

According to EPA officials, USDA and Interior have different opinions 
on the status of a preliminary assessment for a number of reasons. 
First, USDA and Interior may have conducted preliminary assessment 
work and submitted information to EPA, but EPA officials may not have 
concurred that the work was sufficient to meet the preliminary 
assessment requirement. Second, the agencies may not have submitted 
information to EPA about the preliminary assessment at the site. 
Third, while EPA carefully considers USDA and Interior comments 
regarding proposed docket sites before listing, USDA and Interior do 
not always agree with final docket listings. USDA and Interior 
generally do not perform a preliminary assessment if they do not agree 
with EPA's determination that a facility should have been added to the 
docket. For example, EPA officials said that, even if an agency 
removes hazardous waste from a site, the site may still meet the legal 
requirements for being added to the docket, and a preliminary 
assessment at the site may still be needed to determine if there is 
additional contamination. 

EPA officials said that they have an ongoing initiative to verify the 
status of federal sites in EPA's database. In EPA's 2014 and 2015 
budget request, EPA stated that it will begin working cooperatively 
with states and federal facilities on a multiyear effort to complete 
outstanding facility assessments and close the compliance gap. 
However, EPA officials with the Federal Facilities and Restoration and 
Reuse Office told us that they received 20 percent less funds in 
fiscal year 2014 and that this may negatively affect their completion 
of this effort. 

Without accurate and consistent information from USDA and Interior on 
the status of their sites, EPA cannot determine whether additional 
work is needed to complete the preliminary assessments required by 
CERCLA and update its records. Furthermore, unless EPA informs USDA 
and Interior of its determination that preliminary assessments are not 
complete, USDA and Interior will not be aware of EPA's expectations 
that additional work is necessary for the preliminary assessments to 
be complete. As a result, EPA cannot effectively assure that 
preliminary assessments are being conducted in a timely manner and, 
ultimately, that sites most in need of remediation are addressed. 

EPA Is Responsible for Evaluating Whether Federal Sites Should: 

Be Placed on the National Priorities List: 

After the agency conducts the preliminary assessment, EPA reviews it 
to determine whether the information is sufficient to assess the 
likelihood of a hazardous substance release, a contamination pathway, 
and potential receptors. EPA may determine that the site does not pose 
a significant threat and requires no further action.[Footnote 49] 

If further investigation is needed, EPA may request that the agency 
conduct a site inspection to gather more detailed information. If on 
the basis of the site inspection, EPA determines that hazardous 
substances, pollutants, or contaminants have been released at the 
site, EPA will use the information from the preliminary assessment and 
site inspection to calculate and document a site's preliminary Hazard 
Ranking System (HRS) score, which indicates a site's relative threat 
to human health and the environment based on potential pathways of 
contamination. The HRS scores sites on four possible pathways: 
groundwater migration, surface water migration, soil exposure, and air 
migration. Sites with an HRS score of 28.50 or greater become eligible 
for listing on the NPL. According to EPA, in order to maintain close 
coordination with the states and tribes in the NPL listing decision 
process, EPA's policy since 1996 has been to determine the position of 
the states and tribes on sites that EPA is considering for listing. 

To list a site on the NPL, EPA must publish a proposed regulation and 
give the public notice and an opportunity for comment before 
finalizing it. According to EPA officials, EPA and OMB have determined 
that the NPL rulemakings do not fall under Executive Order 12866 
requiring review by OMB.[Footnote 50] However, EPA informally submits 
both NPL proposed and final rulemaking packages to OMB for review. 
During its review process, OMB will discuss the package with the 
federal agency that manages the site and other federal agencies. Some 
proposed sites do not proceed past this step and do not become NPL 
sites. 

After OMB concurs with the listing package, EPA publishes a notice of 
proposed rulemaking in the Federal Register, obtains public comments 
during the specified period, reviews the comments received, responds 
to comments, and makes a final listing decision. The final listing 
decision process includes input from states and tribes and concurrence 
from OMB. EPA publishes the final rule in the Federal Register, 
formally adding the site to the NPL. 

According to EPA, the majority of USDA and Interior sites on the 
docket have not required further action from EPA after review of the 
preliminary assessment. However, a number of sites have been eligible 
for listing on the NPL. As of September 2014, two USDA sites and two 
Interior sites were on the NPL. In 2009, EPA considered proposing one 
Interior site, Red Devil Mine in Alaska, but it was ultimately never 
proposed for NPL listing. BLM objected to the listing, arguing that 
the mercury mine was abandoned before federal land managers had any 
practical regulatory authority over this type of site,[Footnote 51] 
and that listing these sites as "federal facilities" on the NPL would 
impede BLM's efforts to hold private parties responsible for cleanup 
at similar mine sites. As an alternative to listing, EPA and BLM 
entered into negotiations for an agreement that would clarify the 
roles and responsibilities of BLM, EPA, and the state of Alaska. 
According to EPA officials, EPA's goal is to establish a framework for 
cleanup that satisfies CERCLA regulatory requirements. Specifically, 
EPA wants the agreement to provide for (1) public participation and 
community involvement; (2) meaningful participation by local tribes, 
including appropriate opportunities for tribal consultation; (3) EPA 
concurrence on cleanup choices, in consultation with the state, as 
well as concurrence on work plans, reports, and other decision 
documents; (4) enforceable milestones; and (5) a formal dispute 
resolution process in which all parties accept EPA's final decision. 
BLM objects to the enforceability and dispute resolution provisions. 
For this and other reasons, since 2009, BLM and EPA have not been able 
to reach an agreement. The state of Alaska asked EPA to list the site 
on the NPL in 2012 and 2013. BLM continues to work at the site and 
informally coordinate with EPA and the Alaska Department of 
Environmental Conservation. 

EPA Oversees Cleanup of NPL Sites, and Work at Most USDA and Interior 
NPL Sites Is Complete: 

Once a site is on the NPL, EPA oversees the cleanup. As part of its 
oversight responsibility, EPA works with the agency to evaluate the 
nature and extent of contamination at a site. The federal agency must 
then enter into an interagency agreement with EPA that includes: (1) a 
review of remedial alternatives and the selection of the remedy; (2) 
schedules for completion of each remedy; and (3) arrangements for the 
long-term operation and maintenance of the site. According to EPA, the 
agreements also provide a process for EPA and the federal agency to 
resolve any disagreements related to implementing the cleanup remedy, 
with EPA being the final arbiter of such disputes. Once the agency and 
EPA agree on a cleanup remedy, the agency implements the remedy at the 
site. Afterwards, the agency must conduct long-term monitoring to 
ensure the remedy remains protective of human health and the 
environment. For sites where hazardous substances, pollutants, or 
contaminants were left in place above levels that do not allow for 
unlimited use and unrestricted exposure, every 5 years following the 
initiation of the remedy, the agency must conduct a formal review of 
the site and provide it to EPA. EPA determines whether the selected 
remedy is still protective of human health and the environment. 

For three of the four USDA and Interior sites on the NPL, cleanup 
remedies have been selected, and construction completed or 
implemented. EPA has conducted at least one 5-year review at each of 
these three sites and determined that the site's selected cleanup 
remedy is still protective of human health and the environment. Of the 
four NPL sites, only USDA's Beltsville Agricultural Research Center 
site is undergoing active cleanup. Appendix IV provides additional 
information on these four NPL sites. 

Conclusions: 

Interior and, to a lesser extent, USDA have made progress in 
identifying contaminated and potentially contaminated sites on lands 
they manage. However, neither agency has completed the task, primarily 
because of the significant effort required to locate abandoned mines 
on their vast acreages. Interior agencies have developed separate 
national inventories of contaminated and potentially contaminated 
sites, and BLM continues to take steps to expand the number of sites 
in its abandoned mine database and improve the accuracy of its data. 
Continuing progress in this effort should help Interior develop a more 
comprehensive inventory that it needs to most effectively manage its 
cleanup programs. USDA, on the other hand, has no reliable national 
inventory of potentially contaminated sites or plans and procedures 
for developing one. In particular, USDA's data on the potentially 
contaminated abandoned mines on its lands is unreliable. Without a 
comprehensive, reliable, and easily accessible inventory of 
potentially contaminated sites on lands managed by USDA, including 
abandoned mines, and plans and procedures for developing such an 
inventory, USDA cannot either effectively manage the department's 
cleanup programs or ensure that limited funds are targeted to clean up 
those sites that may pose the greatest threats to human health or the 
environment. However, given USDA's decreasing funding for 
environmental restoration programs, current funding may be inadequate 
to both complete this inventory effort and continue cleanup efforts on 
sites with known contamination. 

Under CERCLA, EPA is responsible for assuring that preliminary 
assessments are conducted at agency sites listed on the docket. 
However, EPA, USDA, and Interior disagree over how many docket sites 
need a preliminary assessment, and the agencies have differing 
information on whether this requirement has been met at a number of 
sites. Without accurate and consistent information from USDA and 
Interior, EPA cannot resolve whether additional work is needed and 
update its Superfund Enterprise Management System database. More 
importantly, without this information, EPA cannot effectively assure 
that preliminary assessments are being conducted in a timely manner 
and that sites most in need of remediation will be addressed. 

Recommendations for Executive Action: 

To ensure that USDA has the information needed to better identify 
potentially contaminated sites--particularly abandoned mines--on 
properties it manages and, thereby, help minimize possible risks to 
human health and the environment, GAO recommends that the Secretary of 
Agriculture direct the heads of the department's land management 
agencies to develop plans and procedures for completing their 
inventories of potentially contaminated sites. 

To help resolve disagreements between EPA and USDA and Interior 
regarding which remaining docket sites require preliminary 
assessments, GAO recommends that the Administrator of EPA direct the 
Office of Federal Facilities Restoration and Reuse to take the 
following three actions: 

* review available information on USDA and Interior sites where EPA's 
Superfund Enterprise Management System indicates that a preliminary 
assessment has not occurred to determine the accuracy of this 
information, and update the information, as needed; 

* after completing this review, inform USDA and Interior whether the 
requirement to conduct a preliminary assessment at the identified 
sites has been met or if additional work is needed to meet this 
requirement; and: 

* work with the relevant USDA and Interior offices to obtain any 
additional information needed to assist EPA in determining the 
accuracy of the agency's data on the status of preliminary assessments 
for these sites. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to Interior, USDA, and EPA for 
review and comment. Interior, USDA, and EPA also provided technical 
comments, which we incorporated, as appropriate. 

In an e-mail we received December 1, 2014, Interior's Audit Liaison 
stated that Interior generally concurred with our findings. 

USDA submitted written comments, included in appendix V, stating that 
the department did not agree with the key findings in our draft 
report. With regard to our finding that USDA does not have a complete, 
consistent, or usable centralized inventory of abandoned mines and has 
no plans or procedures for developing one, USDA stated that it does 
have a centralized inventory and that this inventory is in a 
transition phase as a result of reduced funding levels. USDA also 
stated that it has taken a number of actions to manage its inventory 
in a more cost-effective manner, reduce operating costs, and eliminate 
data collection redundancies across USDA agencies. 

Although USDA asserts that it has a centralized site inventory, USDA 
could not provide us with up-to-date information on sites across the 
department. Instead we had to obtain information from USDA's 
individual agencies. Furthermore, USDA stated that it relies on data 
from outside sources, such as states and other federal agencies, to 
supplement this information. However, because these data are from a 
variety of sources and not part of a centralized USDA database, USDA 
may not be able to ensure the quality, completeness, consistency, or 
reliability of this information. 

USDA acknowledged that abandoned mine lands make up the bulk of its 
inventory of contaminated and potentially contaminated sites. USDA 
also recognized that its inventory of potentially contaminated sites 
is not complete. USDA stated that, given limited funding resources, it 
is utilizing abandoned mine data from all existing sources and 
developing collaborative partnerships with federal and state agencies. 
USDA strongly disagreed that an incomplete inventory leads to 
ineffective management of the program. 

We continue to believe that USDA's inventory of contaminated and 
potentially contaminated sites--in particular, abandoned mines--is 
insufficient for effectively managing USDA's overall cleanup program. 
In our report, we note that USDA has a list of contaminated sites, but 
its inventory of potentially contaminated sites is incomplete and 
unreliable. For example, the Commodity Credit Corporation's list of 
potentially contaminated sites is incomplete because many states have 
not yet reported whether there is suspected contamination at former 
grain storage sites. In addition, USDA officials told us that because 
the data in both USDA's department-wide CEE database, and its AML 
database maintained by the Forest Service, are incomplete and contain 
inaccurate information, USDA could not provide a reliable number of 
the potentially contaminated sites the agency has identified. On this 
basis, we concluded that USDA does not have a complete, consistent, or 
usable inventory of potentially contaminated sites, in particular, 
abandoned mines. We continue to believe that, without reliable data, 
USDA cannot effectively manage its cleanup program or ensure that its 
limited funds are targeted to clean up sites that may pose the 
greatest threats to human health or the environment. 

In its letter, USDA also expanded on its position with regard to its 
continuing disagreements with EPA over the need to assess certain USDA 
sites on the federal facilities docket. To the extent that the 
information USDA provided helps to clarify the department's position 
on this issue, we incorporated it into the report, as appropriate. 
Specifically, we added USDA's explanation of why it does not perform 
preliminary assessments if it does not agree with EPA's determination 
that these assessments are needed. In its letter, USDA stated that 
this situation generally relates to sites listed on the docket 
pursuant to RCRA. USDA stated that these sites are listed on the 
docket because of their past or present operation as a one time or 
periodic large quantity RCRA generator, not because of any identified 
release of hazardous waste. USDA said that it does not believe that 
facilities in good standing that handle hazardous waste and generate a 
manifest under RCRA should then have to conduct a preliminary 
assessment as a result of a docket listing. A preliminary assessment 
is to be conducted for all sites listed on the docket, however. 

In written comments, reproduced in appendix VI, EPA generally agreed 
with our findings, conclusions, and recommendations. With regard to 
our recommendation that EPA review the status of USDA and Interior 
sites on the docket in order to identify whether a preliminary 
assessment is still needed, EPA stated that it will compare the site 
data provided by USDA and Interior during the review of existing 
Superfund Enterprise Management System data in order to identify sites 
that still need a preliminary assessment. With regard to our 
recommendation that EPA inform USDA and Interior whether the 
requirement to conduct a preliminary assessment has been met, or if 
additional work is needed, EPA stated that it will use the data 
collected from USDA and Interior to inform these agencies of their 
statutory requirements to complete site assessment work. Finally, as 
we recommended, EPA agreed to work with USDA and Interior to obtain 
additional information to determine the accuracy of EPA's data on the 
preliminary assessments for sites on the federal facilities docket. 
EPA stated that it believes that our recommendations will help to 
address the 50 USDA sites and 79 Interior sites with a preliminary 
assessment status that is being disputed; moreover, additional actions 
may be needed for other contaminated or potentially contaminated sites 
on USDA and Interior lands because EPA says it cannot compel agencies 
to comply with requests for preliminary assessments to be completed. 

As agreed with your office, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies to the 
appropriate congressional committees, the Secretary of the Interior, 
the Secretary of Agriculture, the Administrator of EPA, and other 
interested parties. In addition, the report will be available at no 
charge on the GAO website at [hyperlink, http://www.gao.gov]. 

If you or your staff members have any questions about this report, 
please contact me at (202) 512-3841 or gomezj@gao.gov. Contact points 
for our Offices of Congressional Relations and Public Affairs may be 
found on the last page of this report. GAO staff who made major 
contributions to this report are listed in appendix VII. 

Sincerely yours, 

Signed by: 

J. Alfredo Gómez: 
Director, Natural Resources and Environment: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

This appendix details the methods we used to examine the Department of 
Agriculture's (USDA) and the Department of Interior's (Interior) 
efforts to identify and to clean up hazardous waste sites. We were 
asked to review the status of USDA's and Interior's efforts in this 
area. Specifically, this report examines: (1) the status of efforts to 
develop an inventory of potentially contaminated and contaminated 
sites, (2) the funding levels for addressing these contaminated sites, 
(3) the amount of environmental liabilities reported on agency 
financial statements, and (4) EPA's role in cleaning up these sites. 

This review addresses the activities of five agencies within USDA: the 
Agriculture Research Service (ARS), Animal and Plant Health Inspection 
Service (APHIS), Commodity Credit Corporation (CCC), the Farm Service 
Agency (FSA), and the Forest Service. Within Interior, this review 
addresses the activities of five agencies: the Bureau of Indian 
Affairs (BIA), Bureau of Land Management (BLM), Bureau of Reclamation, 
Fish and Wildlife Service, and the National Park Service (NPS). We 
selected these agencies because they manage USDA and Interior lands. 

Developing Inventories: 

To describe the status of efforts to develop an inventory of 
potentially contaminated and contaminated sites and determine the 
number of sites in each agency's inventory, we identified and analyzed 
current legal requirements for federal identification and reporting of 
potential hazardous waste sites, including the Comprehensive 
Environmental Response, Compensation, and Liability Act (CERCLA) and 
the Resource Conservation and Recovery Act (RCRA). We also obtained 
and reviewed USDA and Interior policies on identifying potentially 
hazardous waste sites. We interviewed agency officials from each 
agency identified above regarding efforts to identify potentially 
contaminated or contaminated sites, and the extent to which their 
inventories are complete. We reviewed relevant inventory data ranging 
from the period of September 2013 to June 2014 from 10 agency sources. 
Agencies with small inventories provided site numbers or a list. For 
the other agencies with more extensive inventories, we obtained 
information from a number of databases. Because the work to identify 
sites is conducted in the field offices of most of these 10 agencies, 
it was not practical for us to determine the extent to which agency 
field staff are following policies and procedures. 

In addition, we obtained information from the agencies that ranged 
from September 2013 to June 2014 on the number of sites in each 
agency's inventory that the agency had identified as potentially 
contaminated but may not have visited yet to determine whether 
contamination exists, as well as the number of contaminated sites. We 
included sites that the agencies have identified as being on land 
managed or leased by USDA and Interior, including grain storage sites 
formerly leased by the CCC. We included CCC grain storage sites in our 
scope because USDA is currently expending funds to clean up these 
sites and has reported them as environmental liabilities on their 
annual financial statements. 

USDA: 

To determine the number of contaminated and potentially contaminated 
sites for USDA's ARS, we obtained a list of all ARS facilities as of 
November 2013 and discussed the list with ARS officials. Because the 
list did not indicate which of ARS's facilities were contaminated or 
potentially contaminated, we relied on ARS officials to identify those 
facilities with known or possible contamination. ARS officials 
identified three contaminated and three potentially contaminated 
sites. Similarly, for APHIS, we relied on testimonial evidence from 
APHIS officials. According to APHIS officials, the agency does not own 
or operate many sites that deal with hazardous waste, so APHIS does 
not track its sites in a database or spreadsheet. However, based on 
their knowledge of APHIS sites, they identified two sites with known 
contamination and none that are potentially contaminated. For FSA and 
CCC (which is located within FSA), we met with an official 
representing FSA and CCC and reviewed the agency's Environmental and 
Disposal Liability spreadsheet, which tracks their inventory of former 
grain storage sites. Because there are only three foreclosure 
properties remaining in FSA's inventory, however, they do not track 
their foreclosure sites in a database or spreadsheet. We requested 
that FSA/CCC officials identify the former grain storage sites and 
foreclosure properties in their inventory that had confirmed or 
possible contamination. 

Finally, for the Forest Service, we met with officials within the 
agency's headquarters office and all nine regional offices, as well as 
officials from USDA's EMD. Because Forest Service does not maintain an 
inventory of contaminated sites at the headquarters level, we 
requested and obtained data from EMD's Center for Environmental 
Excellence (CEE) database--which contains the agency's most current 
data on Forest Service sites in Regions 1 through 9. The CEE database 
does not track all of the agency's docket sites, however, or have 
current inventory data on contaminated sites in Forest Service Region 
10. We, therefore, supplemented the CEE inventory data with data from 
EMD's Docket Status Spreadsheet and an inventory spreadsheet from 
Region 10 to calculate the Forest Service's total inventory of 
contaminated sites. To evaluate the reliability of these data and 
determine its limitations, we reviewed the data obtained from EMD and 
Forest Service Region 10, and we interviewed EMD and Forest Service 
officials. We analyzed related documentation, examined the data to 
identify obvious errors or inconsistencies and compared the data we 
received with other published data sources, such as USDA's annual 
environmental restoration accomplishment report. On the basis of our 
evaluation of these data, we concluded that the CEE data, Docket 
Status spreadsheet, and Forest Service Region 10 data we collected and 
analyzed were sufficiently reliable for the purpose of compiling a 
complete and accurate inventory of the Forest Service's contaminated 
sites. We also attempted to obtain Forest Service's inventory of 
potentially contaminated sites and requested information from the 
Forest Service regional offices, as well as data from CEE and USDA's 
Abandoned Mine Lands database. However, for the reasons described 
earlier in the report, we did not find the data to be reliable for 
purposes of calculating the Forest Service's inventory of potentially 
contaminated sites and, therefore, did not use the data for our report. 

Interior: 

At Interior, we obtained the number of contaminated sites for BIA, the 
Bureau of Reclamation, the Fish and Wildlife Service, and NPS's 
hazardous materials sites from Interior's Environmental and Disposal 
Liability (EDL) database. These data were current as of September 30, 
2013, and were the most recent data available at the time they were 
collected. We determined the data were sufficiently reliable for the 
purpose of reporting the agencies' 4,722 contaminated and potentially 
contaminated sites based on our review of Interior and agency 
handbooks and interviews with agency officials. 

For the number of contaminated abandoned mines and potentially 
contaminated abandoned mines, we obtained data from NPS's Abandoned 
Mine and Site Cleanup Module database. We interviewed agency officials 
on the development of the database and reviewed the data entry 
instructions. We determined the data were sufficiently reliable for 
representing the 40 contaminated abandoned mines in NPS's abandoned 
mine inventory. To identify the number of sites in BLM's inventory, we 
obtained and analyzed data from BLM's Abandoned Mine Lands/Site 
Cleanup Inventory database as of April 28 and 29, 2014. In 2005, 
Interior's Office of Inspector General (OIG) found that this inventory 
data were not complete and reliable and recommended that BLM validate 
existing inventory data and develop procedures for ongoing data 
collection to ensure that data in the inventory are complete, 
accurate, and consistent. The Interior OIG has not yet closed this 
recommendation. According to BLM, these data are an authoritative 
source of information regarding the inventory and status of sites. 
According to BLM's website, BLM is constantly reviewing and updating 
its data. In addition, the majority of sites were reported during the 
initial inventory efforts from various sources, but they have not been 
assessed on the ground by BLM. 

We also collected information from the U.S. Army Corps of Engineer's 
Formerly Used Defense Sites (FUDS) Management Information Systems on 
former defense sites located on land managed by USDA and Interior. We 
are reporting the inventory number that is currently in that system. 
To determine whether the data were sufficiently reliable for reporting 
the number of USDA and Interior FUDS sites, we provided the inventory 
lists to USDA and Interior officials, who confirmed that the data 
accurately reflected their FUDS inventories. Because the data from the 
U.S. Army Corps of Engineers (Corps) were not used to support any 
findings, conclusions, or recommendations in our report, we did not 
review how the Corps developed its inventory list. 

Funding: 

To describe the funding levels for identifying and addressing 
contaminated sites, we collected budget and expenditure data for 
fiscal years 2003 through 2013 from responsible agency officials. 
Specifically, we collected funding data and project lists for the 
following: 

* USDA's department-wide Hazardous Materials Management Appropriations 
account; 

* Forest Service's Environmental Compliance and Protection program, as 
well as USDA's one-time Recovery Act funds and cost recovery funds; 

* funds the CCC is authorized to borrow; 

* Interior's department-wide Central Hazardous Materials Fund; 

* BLM's Abandoned Mine Lands subactivity account; 

* BLM's Hazardous Materials Management subactivity account; 

* NPS's cleanup fund; and: 

* the Fish and Wildlife Service's Refuge Cleanup Fund. 

To better understand how USDA's environmental restoration funds were 
used, we interviewed officials from each of USDA's responsible 
agencies. At Interior, we met with officials from Interior's Office of 
Environmental Policy and Compliance, Environmental Cleanup and 
Liability Management. We also interviewed officials with BLM, NPS, and 
Fish and Wildlife Service about their cleanup funds. We reviewed 
policies for awarding cleanup project funds and lists of project 
funding. We also collected data, as of September 30, 2013, from 
Interior's EDL database on the stage of cleanup of each site in the 
system. Finally, we interviewed agency officials regarding efforts to 
develop a comprehensive estimate of the cost to address environmental 
contamination at abandoned mines on Forest Service, BLM, and NPS lands. 

Environmental Liabilities: 

To describe the amount of environmental liabilities USDA and Interior 
reported on its financial statements, we reviewed the Chief Financial 
Officer's Act of 1990 and the Federal Accounting Standards Advisory 
Board's Statement of Federal Financial Accounting Standards 5: 
Accounting for Liabilities of the Federal Government (SSFAS No. 5) and 
its supplemental guidance, Technical Release 2: Environmental 
Liabilities Guidance.[Footnote 52] We reviewed the policies, 
procedures, and methodologies the departments provide their agencies 
to estimate their environmental liabilities. When available, we 
reviewed the policies and procedures for estimating and reporting 
environmental liabilities from each agency or bureau. In addition, we 
interviewed officials in both Interior's and USDA's Office of the 
Chief Financial Officer, Interior's Office of the Solicitor, and 
USDA's Office of General Counsel. Furthermore, we reviewed the fiscal 
year 2013 consolidated financial statements of both USDA and Interior. 
Because USDA's fiscal year 2013 financial statements were audited by 
the USDA OIG, and Interior's 2013 financial statements were audited by 
an independent public accounting firm and determined to be reliable, 
we reviewed the statements but did not perform additional audit 
procedures to verify the completeness or accuracy of the amounts 
reported. We met with officials from ARS, CCC, and the Forest Service 
to understand their process for selecting sites for inclusion as 
environmental liabilities on their annual financial statements. At 
Interior, we reviewed information from the EDL database and 
interviewed officials with Interior's Office of Environmental Policy 
and Compliance, Environmental Cleanup and Liability Management. This 
office develops the environmental liability policy for Interior and 
maintains the EDL database for documenting liabilities. We also 
reviewed Interior's Environmental and Disposal Liabilities 
Identification, Documentation and Reporting Handbook and agency 
handbooks for implementing the process. 

EPA's Role: 

To determine EPA's role with regard to USDA and Interior sites, we 
obtained and reviewed relevant laws, regulations, and agency policies. 
We interviewed officials with EPA's Federal Facilities Restoration and 
Reuse Office and USDA and Interior headquarters officials on the 
procedures for listing federal sites on the docket and efforts to take 
steps to assure that agencies conduct preliminary assessments and any 
other cleanup-related activities. We selected three EPA regions with 
the most USDA and Interior sites on the docket to interview about the 
process for listing federal sites. However, we did not interview EPA 
docket officials in California because the docket coordinator had 
retired. We documented the cleanup status of the four USDA and 
Interior NPL sites. 

EPA published the original docket in 1988 and has published additions, 
deletions, and corrections 26 times. EPA provided a copy of the 
spreadsheet it has compiled that lists the USDA and Interior docket 
sites. EPA recently compared the spreadsheet with each docket 
publication. In addition, it provided the compiled docket to each EPA 
regional office for our review. Because of this recent verification, 
we believe the docket is sufficiently reliable for reporting the 
number of docket sites EPA has published. We also obtained each 
updated docket EPA has published in the Federal Register to determine 
how often EPA has made such updates. 

To determine whether the USDA and Interior agencies have conducted 
preliminary assessments of sites on EPA's docket, we collected and 
analyzed data from the Comprehensive Environmental Response, 
Compensation, and Liability Information System as of February 2014. 
Because of the age of the data and its potential unreliability, we 
asked Interior and USDA to review the data in EPA's database relating 
to sites that EPA had not noted had met the preliminary assessment 
requirement. Both USDA and Interior noted the sites that they believed 
had met the preliminary assessment requirement. Because we are 
reporting the information currently in the system--and also providing 
data on the discrepancies USDA and Interior report with regard to this 
data--we believe the information is sufficiently reliable for 
reporting. 

Finally, for all four objectives, we reviewed relevant laws--in 
particular, CERCLA and RCRA--and associated regulations and directives. 

We conducted this performance audit from April 2013 to January 2015 in 
accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: Number of and Cleanup Costs for Formerly Used Defense 
Sites on Department of the Interior and U.S. Department of Agriculture 
Properties: 

The Department of the Interior (Interior) and the U.S. Department of 
Agriculture (USDA) both manage lands that contain formerly used 
defense sites (FUDS). Specifically, FUDS are defined as properties 
that were under the jurisdiction of the Department of Defense (DOD) 
and owned by, leased to, or otherwise possessed by the United States 
at the time of actions leading to contamination by hazardous 
substances or other hazards prior to October 17, 1986. Under the 
Defense Environmental Restoration Program, DOD is required to carry 
out a program of environmental restoration activities at FUDS. 
[Footnote 53] Authority for cleaning up FUDS was delegated to the 
Department of the Army, which in turn delegated it to the U.S. Army 
Corps of Engineers (Corps). According to Army officials, the Corps 
may, as appropriate, address FUDS located on lands managed by Interior 
and USDA in consultation with these two departments.[Footnote 54] As 
of the end of fiscal year 2012, the Corps had identified 735 and 236 
eligible and approved FUDS projects on Interior and USDA properties, 
respectively. About 46 percent of these projects were designated as 
"no DOD action indicated" (NDAI). According to Corps officials, NDAI 
signifies a FUDS property or project that meets any of these 
conditions: (1) is not eligible for FUDS program consideration; (2) is 
categorically excluded from the FUDS program; (3) contains hazards 
that were not the result of DOD actions on or before 17 October 1986, 
pose no threat to human health or safety or the environment, and 
require no additional environmental restoration activities; and (4) 
for which the required response action has been completed.[Footnote 55] 

FUDS projects generally fall under one of three program categories: 
Installation Restoration Program, Military Munitions Response Program, 
and Building Demolition/Debris Removal Program.[Footnote 56] 

* Installation Restoration Program. This program category includes 
FUDS with (1) hazardous, toxic, and radioactive waste and (2) 
containerized hazardous, toxic, and radioactive waste, such as 
aboveground and underground storage tanks. Projects under this program 
category focus on addressing releases of hazardous substances or 
pollutants and contaminants; petroleum, oil, or lubricants; DOD-unique 
materials; hazardous wastes or hazardous waste constituents; low-level 
radioactive materials or low-level radioactive wastes; and explosive 
compounds released to soil, surface water, sediments, or groundwater 
as a result of ammunition or explosives production or manufacturing at 
ammunition plants. The Corps categorized 317 FUDS projects on Interior 
properties and 102 FUDS projects on USDA properties under this 
program, as of the end of fiscal year 2012.[Footnote 57] Of these 
projects, 190 and 67, respectively, were designated NDAI. 

* Military Munitions Response Program. This program category includes 
FUDS with munitions and explosives of concern, munitions constituents, 
and recovered chemical warfare materiel.[Footnote 58] The Corps 
categorized 367 FUDS projects on Interior properties and 106 FUDS 
projects on USDA properties under this program, as of the end of 
fiscal year 2012.[Footnote 59] Of these projects, 91 and 36, 
respectively, were designated NDAI. 

* Building Demolition and Debris Removal Program. Projects under this 
program category focus on the demolition and removal of unsafe 
buildings and structures and the removal of unsafe debris from 
eligible FUDS properties. To be eligible, the property's conditions 
must have been hazardous as a result of prior DOD use and must have 
been inherently hazardous (i.e., present a clear danger, likely to 
cause, or have already caused, death or serious injury to a person 
exercising ordinary and reasonable care) when the property was 
transferred by DOD. The Corps categorized 47 FUDS projects on Interior 
properties and 23 FUDS projects on USDA properties under this program, 
as of fiscal year 2012. Of these projects, 39 and 20, respectively, 
were designated NDAI. 

The Corps reports cleanup costs of over $405 million at FUDS on 
Interior properties and $223 million at FUDS on USDA properties over 
the past decade. These amounts include costs expended during fiscal 
years 2003 through 2012 and costs allocated for fiscal year 
2013.[Footnote 60] The Corps estimates it will cost an additional $3.3 
billion to complete FUDS projects on Interior properties and $1.4 
billion on USDA properties. Both past and future costs are for cleanup 
activities at FUDS that have undergone a preliminary assessment and 
where further action is warranted.[Footnote 61] According to Corps 
officials, a FUDS site or project area may have several landowners or 
property managers; therefore, FUDS develops and reports costs on a 
site specific or project specific basis, regardless of landowner. This 
means that the costs reported above may overestimate the actual 
cleanup costs on DOI or USDA properties as an individual project may 
only be partially located on federally managed land. 

[End of section] 

Appendix III: Cleanup Status of Department of the Interior's 
Environmental and Disposal Liability Sites: 

Department of the Interior's (Interior) bureaus are directed to record 
[Footnote 62] their environmental and disposal liabilities (EDL) in 
the EDL database module of the department's Environmental Management 
Information System on a quarterly basis.[Footnote 63] In order for 
Interior and its bureaus to track the progress of cleanup at EDL 
sites, the database prompts the bureaus to record the current stage of 
the cleanup process for each EDL site. One of five stages, as 
described by Interior below, can be recorded. 

* Due care only. An EDL site is recorded as having "due care only" 
when no activity beyond an environmental assessment has been completed 
at the site.[Footnote 64] 

* Study. This stage of the cleanup process is associated with an EDL 
site that has had due care completed and where the level of 
contamination is significant enough to warrant further study or future 
cleanup. During this stage, bureaus may complete a preliminary 
assessment/site investigation, remedial investigation/feasibility 
study, or other investigation study at the EDL site. Such studies are 
used, for example, to determine the nature and extent of 
contamination, assess the treatability of site contamination, and 
evaluate the potential performance and cost of treatment technologies. 

* Cleanup/remediation/removal. This stage of the cleanup process is 
associated with a cleanup response action (removal or remedial) at an 
EDL site. 

* Operation and maintenance. This stage of cleanup process is 
associated with an EDL site requiring operation and maintenance of, 
for example, cleanup systems dedicated to a cleanup response action. 
Operation and maintenance is applicable after the remedial action has 
achieved cleanup action goals and is determined to be operational and 
functional, or 1 year after construction (whichever is earlier) except 
for water treatment alternatives.[Footnote 65] 

* Long-term monitoring. This stage of the cleanup process is 
associated with an EDL site that requires monitoring to minimize and 
control the contamination. For example, the monitoring of groundwater 
may be required to ensure capture or natural attenuation is occurring. 

As of the end of fiscal year 2013, about 40 percent of the bureaus' 
756 EDL sites were recorded as being in the study stage of the cleanup 
process. The second and third highest recorded stages, respectively, 
were cleanup/remediation/removal (22.9 percent), followed by due care 
only (18.9 percent). The number of EDL sites in each stage of the 
cleanup process is shown below in figure 4. 

Figure 4: Number of Environmental and Disposal Liabilities (EDL) Sites 
in Each Stage of the Cleanup Process, as of Fiscal Year 2013: 

[Refer to PDF for image: pie-chart] 

Stage: Study; 
Percentage: 39.9%; 
Number of EDL sites: 302. 

Stage: Cleanup/remediation/removal; 
Percentage: 22.9%; 
Number of EDL sites: 173. 

Stage: Due care only; 
Percentage: 18.9%; 
Number of EDL sites: 143. 

Stage: Operation and maintenance; 
Percentage: 8.3%; 
Number of EDL sites: 63. 

Stage: Long-term monitoring; 
Percentage: 5.0%; 
Number of EDL sites: 38. 

Stage: Not recorded[A]; 
Percentage: 4.9%; 
Number of EDL sites: 37. 

EDL = Environmental and Disposal Liability. 

Source: GAO analysis of Department of the Interior data and its 
responses to follow-up data questions. GAO-15-35. 

[A] According to bureau officials, of the 37 EDL sites with no cleanup 
stage recorded, 1 site required no further action; 1 site is in 
multiple stages of the cleanup process; and 35 sites were input into 
the database before the standards for due care were established but 
the responsible bureau is currently in the process of hiring an 
engineering contractor to conduct due care to either establish or 
refute the contamination liability at the sites. 

[End of figure] 

[End of section] 

Appendix IV: USDA and Interior National Priorities List Sites: 

This appendix provides the cleanup status of the two U.S. Department 
of Agriculture (USDA) sites and two Department of the Interior 
(Interior) sites currently on the National Priorities List (NPL). (See 
table 5.) 

Table 5: USDA and Interior NPL Sites, as of May 2014: 

USDA NPL sites: 

Agricultural Research Service (ARS); Beltsville Agricultural Research 
Center; 
This site is a large agricultural research complex spanning 6,500 
acres in Beltsville, Maryland. The site was listed on the NPL due to 
contamination as a result of past disposal practices. Contaminants 
include polychlorinated biphenyl, pesticides, metals, radioactive 
materials, and solvents in soil and groundwater. In 1998, USDA and 
Environmental Protection Agency (EPA) finalized a Federal Facility 
Agreement under which they agreed to, among other things, establish a 
process for investigating areas of concern, identify response actions 
for these contaminated areas, and clean them up. USDA originally 
identified 167 areas of concern. As of February 2014, 13 such areas 
remain where assessment or cleanup is anticipated. 

Forest Service; White King/Lucky Lass, Oregon; 
This site is the location of two abandoned uranium mines located 
approximately 1 mile apart. The site encompasses approximately 140 
acres affected by uranium mining activities that occurred during the 
1950s and 1960s. The site is contaminated with arsenic and 
radionuclides in water-filled excavation pits (ponds) and stockpiled 
mineralized waste piles. EPA listed the site on the NPL in 1995. That 
same year EPA and Forest Service entered into an Administrative Order 
on Consent with several private sector potentially responsible parties 
(PRP). PRPs subsequently performed investigations and remedial actions 
at the site. EPA and the Forest Service also signed a Memorandum of 
Understanding in 1995. A group of private PRPs constructed the remedy 
under a 2005 Consent Decree. Construction of all remedies at the site 
is complete. In 2010, EPA conducted a Five Year Review at the site and 
noted that the remedial actions at the site are complete and protective 
of human health and the environment. 

Interior NPL sites: 

Bureau of Land Management (BLM); Lee Acres Landfill, New Mexico; 
In 1962, BLM leased a portion of land to San Juan County to operate a 
county landfill. The landfill disposed of liquid waste in lagoons. In 
1985, a lagoon was breached. The county closed the landfill and 
covered a lagoon on site with soil. Volatile organic compounds were 
found in three domestic water supply wells in a nearby subdivision. BLM 
distributed bottled water to some local residents and ultimately 
connected them to the town water supply. EPA listed the site on the NPL 
in 1990. Contaminants of concern include nickel, vinyl chloride, 
trichloroethene, and manganese. In 1993, BLM, EPA and the New Mexico 
Environmental Department entered into a technical Memorandum of 
Understanding for completion of a remedial investigation. After further 
study and approved plans, EPA and Interior signed an interagency 
agreement in 2004. The remedy construction was completed at the site in 
2005 with the construction of a landfill cover and monitoring wells. 
The groundwater is to be restored through natural attenuation. In 2009, 
BLM prepared a Five Year Review of the site. The remedial actions 
performed at the site are considered to be protective of human health 
and the environment. BLM has plans to conduct a second 5 year review in 
2014. 

Fish and Wildlife Service; Crab Orchard National Wildlife Refuge, 
Illinois; 
The site was a location of a bomb and explosive plant during World War 
II and was established by the federal government as a refuge in 1947. 
Industries continued to lease the site, and some used unlined 
landfills and dumps to dispose of waste from their operations. The 
site has polychlorinated biphenyl, cadmium, and lead contamination. 
EPA listed it on the NPL in 1987. In 1991, EPA, Illinois EPA, 
Interior, and the Department of the Army signed a Federal Facility 
Agreement. A number of cleanup remedies have been implemented at the 
site, including the excavation and treatment of contaminated soils, 
the installation of a pump and treat system for one groundwater plume, 
and monitoring of a second plume for natural attenuation. In June 
2011, EPA signed the fourth Five Year Review report for the site and 
concluded that the site is expected to protect human health and the 
environment. 

Sources: GAO analysis of documents from USDA and Interior. GAO-15-35. 

[End of table] 

[End of section] 

Appendix V: Comments from the U.S. Department of Agriculture: 

United States Department of Agriculture: 
Office of the Assistant Secretary for Administration: 
Office of Procurement and Property Management: 
300 7th Street Southwest, Room 302 Reporters Building; 
Washington, DC 20024-9300: 

Mr. Vincent Price: 
Assistant Director, Natural Resources and Environment: 
Government Accountability Office: 
Washington, DC 20548: 

Dear Mr. Price: 

The U.S. Department of Agriculture (USDA) appreciates the opportunity 
to respond to the U.S. Government Accountability Office (GAO) draft 
report concerning hazardous waste sites on USDA and Interior Lands, 
dated January 2015. 

USDA does not agree with the key findings in the GAO draft report. We 
are providing (1) a narrative that clarifies USDA's position on the 
key findings (Attachment 1) and (2) a comment matrix with suggested 
word changes for the final report (Attachment 2). 

Thank you again for the opportunity to review and respond to the GAO 
draft report. 

Sincerely, 

Signed by: 

Lisa M. Wilusz: 
Director: 
Office of Procurement and Property Management: 

Attachment 1: 

USDA Response to GAO Key Findings from Draft Report Concerning 
Hazardous Waste Sites on USDA and Interior Lands: 

This document describes the status of the USDA centralized hazardous 
waste site inventory and presents USDA views on GAO findings related 
EPA and USDA responsibilities associated with the identification of 
the cleanup of contaminated sites. 

GAO’s Inventory-Related Findings: 

(1) The GAO report states that “USDA does not have a centralized site 
inventory or plans and procedures for completing one, in particular, 
for abandoned mines on some USDA lands” (“Introductory/Preface” page). 
Page 7 of the report similarly states that USDA “has not developed a 
complete, consistent, or usable inventory of abandoned mines and has 
no plans and procedures for developing an inventory”. 

USDA Response: 

As USDA staff explained during interviews with GAO staff related to 
this report, the USDA centralized inventory is in a transition phase 
as a result of reduced funding levels. USDA experienced significant 
yearly budget cuts from $15.7 million to $3.7 million, amounting to a
76 percent reduction over the past ten years. These budget cuts 
significantly affect the way we manage our program and forced us to 
answer some very difficult questions. For example: 

* Can we afford a centralized inventory? 

* What benefits will a centralized inventory provide? 

* Based on historical funding, how can we afford to identify every 
potentially contaminated mine site on Forest Service Managed lands? 

In answering these questions, USDA decided to maintain the database, 
which contains our centralized inventory, but modify it in an effort 
to reduce operating costs.[Footnote 1] We also looked at the most cost 
effective way to house the data. As a result, we moved this database 
to a cloud environment, instead of dedicated servers. Finally, we 
looked at ways to reduce redundancy in data collection across USDA 
agencies. When looking at the data, we found that abandoned mine lands 
(AML) make up the bulk of the potentially contaminated sites 
inventory. We also recognized that AML pose a multitude of diverse 
challenges such as protection of bat habitats and physical safety 
hazards. Moreover, only a subset of this entire inventory will result 
in contamination levels which will require a cleanup action. 

With these issues in mind, as well as Forest Service efforts to 
develop their own agency-wide database to address some of these other 
challenges associated with AML, USDA decided to move the AML portion 
of the centralized inventory to the Forest Service. This decision
represents a significant cost savings for USDA and reduces redundant 
data collection. USDA will continue to track any sites within the USDA 
database where cleanup is deemed necessary. Despite some difficulties 
with this transition plan, USDA is moving forward with it. USDA agrees 
that our centralized inventory requires some updating due to this 
transition; however a centralized inventory in need of some updating 
is nonetheless an existing centralized inventory. 

(2) The GAO conclusions further state (p. 33): “Without a 
comprehensive, reliable, and easily accessible inventory of 
potentially contaminated sites on lands managed by USDA, including
abandoned mines, and plans and procedures for developing such an 
inventory, USDA cannot either effectively manage the department’s 
cleanup programs or ensure that limited funds are targeted to cleanup 
those site that may pose the greatest threats to human health or the
environment”. 

USDA’s Response: 

USDA is effectively managing its cleanup program within the given 
constraints of limited resources. Although, we recognize that our 
potentially contaminated inventory is not complete, we strongly 
disagree that an incomplete inventory leads to ineffective management
of the program, as stated in the GAO report. 

USDA recognizes that resources are not, nor are they likely to become, 
available to complete an on-the-ground inventory of all USDA-managed 
lands in the foreseeable future. Therefore, the USDA AML inventory 
strategy includes utilizing data from all existing sources and 
development of collaborative partnerships with Federal and State 
agencies. Inventory and cleanup efforts are focused on State and/or 
local priority areas, such as high-visitation areas and threatened 
watersheds. Cleanup efforts are initiated at sites with the most acute 
public safety and/or environmental hazards. 

A more focused USDA AML inventory and cleanup approach also supports 
the Department's strategic plan with respect to protecting and 
enhancing America’s water resources. As water continues to become a 
more valuable resource, we believe that an effort made towards 
cleaning up priority watersheds is the best use of limited resources. 
A holistic watershed approach unifies all stakeholders (including 
private interests groups and Native American Tribes) in the 
identification, prioritization, and cleanup of important drinking 
water supplies, fisheries, and wildlife habitat within an entire 
watershed. Such partnerships have been instrumental in the progress 
achieved to date. 

Focusing our future AML inventory efforts in areas determined to be 
high priorities through coordination and collaboration reduces costs 
through leveraging funds. Such efforts also achieve effectiveness in 
facilitating solutions to address mixed ownership issues, avoid
duplication of efforts and conflicting actions, and assist in 
identifying those sites that pose the highest potential for harm to 
public health and safety. 

GAO Findings with Respect to EPA and USDA Responsibilities: 

(1) The GAO report states that “Disagreements with USDA and Interior 
over their need to assess the remaining sites and differing 
information on whether this requirement has been met at some sites 
mean EPA cannot assure that the assessments are conducted in a timely 
manner and, ultimately, that sites most in need of remediation are 
addressed” (preface & page 33). 

USDA’s Response: 

USDA has delegated CERCLA authority with respect to land under its 
jurisdiction, custody, or control except that EPA retains authority in 
cases of emergencies and for remedial actions at sites that are listed 
on the National Priorities List (NPL). Therefore USDA, not EPA, sets
the priority for response actions at non-NPL sites on USDA-
administered land. Specifically the disagreements referenced in the 
report occur in cases where (1) there is no evidence that a release 
has occurred, (2) the site location is not defined by EPA to the 
extent feasible to do an assessment (i.e., docketing an entire 
national Forest), and (3) EPA did not provide USDA with enough 
information to identify the location of the site. USDA acknowledges 
the need to improve coordination with EPA with respect to these 
situations, and has already begun face-to-face meetings with each EPA 
Region to address these issues. Disagreements between EPA and USDA, 
however, do not ever delay needed remediation work. 

(2) The report also states that “USDA and Interior generally do not 
perform preliminary assessment if they do not agree with EPA’s 
determination that a facility should have been added to the docket” 
(Page 29). 

USDA’s Response: 

With regard to the failure to perform preliminary assessments at 
disputed sites on the EPA docket, it is important to understand how 
sites get listed on EPA’s docket. The docket contains information 
submitted to EPA by federal agencies under the following authorities:
CERCLA Section 103 and the Resource Conservation and Recovery Act 
(RCRA) Sections 3005, 3010, and 3016. GAO’s comments about USDA not 
performing preliminary assessments if they do not agree with EPA’s 
determination generally relate to sites listed on the docket pursuant 
to RCRA. While we acknowledge EPA’s authority to place these sites
on the docket, USDA does not believe that facilities in compliance 
with RCRA, which must generate waste disposal manifests, should be 
required to conduct CERCLA investigations as a result of docket 
listing, particularly where there is no record of a release of hazardous
substances into the environment. The result of this practice would be 
unnecessary expense with essentially no benefit. As a matter of 
policy, EPA should develop an alternative, less wasteful process. In 
almost all cases, these sites have not had a release of hazardous
substances and, therefore, do not pose a threat to the environment, 
human health, or safety. 

(3) In addition, the report explains how sites are scored by EPA and 
categorized (pages 30-31) without adequately defining what a no 
further action determination by EPA means to other federal agencies. 

USDA’s Response: 

For docket purposes, a no further remedial action planned (NFRAP) 
letter from EPA means that EPA has determined the site does not 
require NPL listing. The vast majority of USDA sites do not warrant 
NPL listing and a docket NFRAP letter does not preclude USDA from
taking action. The threat may be significant and cleanup by USDA 
warranted. In those cases, USDA prioritizes its sites and proceeds 
with cleanup using its delegated CERCLA authorities with little or no 
EPA involvement. 

Footnote: 

[1] The USDA centralized inventory referenced in the GAO report 
contains 1,491 contaminated sites (page 6, line 3) and 20,401 
potentially contaminated sites (page 8, 2nd paragraph, line 4). 

[End of section] 

Appendix VI: Comments from the Environmental Protection Agency: 

United States Environmental Protection Agency: 
Office of Solid Waste and Emergency Response: 
Washington, D.C. 20460: 

December 9, 2014: 

Mr. Alfredo Gomez: 
Acting Director: 
Natural Resources and Environment: 
U.S. Government Accountability Office: 
Washington, DC 20548: 

Dear Mr. Gomez: 

Thank you for the opportunity to review and comment on GAO's draft 
report, "Hazardous Waste: Agencies Should Take Steps to Improve 
Information on USDA and Interior's Potentially Contaminated Sites" 
(GAO-15-35). 

The purpose of this letter is to provide the Environmental Protection 
Agency's response to your recommendations. The EPA generally agrees 
with the GAO's findings, conclusions, and recommendations. 

In its review, GAO found that the Departments of Agriculture and the 
Interior do not have complete inventories of contaminated or 
potentially contaminated sites on their properties. Both Departments'
estimates of their financial liabilities for land cleanup were found 
to be reasonable. GAO found that the EPA's primary role is to maintain 
a list of potentially contaminated sites on USDA and Interior land,
based on data provided by the agencies; to ensure the agencies assess 
the sites; and to oversee cleanup as needed. The report states that 
the EPA's ability to ensure that preliminary assessments are conducted 
in a timely manner and that sites in most need of remediation are 
addressed is inhibited by disagreement from the two agencies about 
what cleanup work is necessary and whether the preliminary assessment
requirement has been met. The report also noted that the EPA has an 
ongoing initiative to work with states and federal agencies on 
completing outstanding assessments. 

The EPA believes that the recommendations contained within this report 
will help to address the 50 USDA sites and 79 Interior sites whose 
status is being disputed; moreover, more may be needed for
other contaminated or potentially contaminated sites on USDA and 
Interior lands, as the EPA cannot compel agencies to comply with 
requests for site assessments to be completed. 

GAO Recommendations: 

* Review available information on USDA and Interior sites where the 
EPA's Superfund Enterprise Management System indicates that a 
preliminary assessment has not occurred to determine the accuracy of 
this information, and update the information, as needed; 

* After completing this review, inform USDA and Interior whether the 
requirement to conduct a preliminary assessment at the identified 
sites has been met or if additional work is needed to meet this 
requirement; and; 

* Work with the relevant USDA and Interior offices to obtain any 
additional information needed to assist the EPA in determining the 
accuracy of the agency's data On the status of preliminary assessments 
for these sites. 

EPA Response: 

The EPA agrees with the recommendation to review the status of USDA 
and Interior sites to identify if a preliminary assessment is still 
needed. The EPA will compare the site data provided by USDA and 
Interior during the review to existing Superfund Enterprise Management 
System data in order to identify these sites. 

The EPA agrees with the recommendation to inform USDA and Interior 
whether the requirement to conduct a preliminary assessment has been 
met or if additional work is needed. The EPA will use the data 
collected in response to the first executive recommendation to inform 
the other Federal agencies of their statutory requirements to complete 
site assessment work. 

The EPA agrees with the recommendation to work with USDA and Interior 
offices to obtain additional information to determine the accuracy of 
the agency's data on the status of preliminary assessments for these 
sites. 

Comments about terminology and phrasing in the report have been 
included separately in the document itself (enclosed). 

During the EPA's Federal Facility Cleanup Dialogue held with the 
Department of the Interior and Department of Agriculture on, October 
21, 2010, the EPA encouraged USDA and DOI to work with the EPA on the 
need to promote transparency, greater collaboration and joint problem 
solving; have a conversation about challenges of federal facility 
cleanups; clarify federal roles and responsibilities; and develop a 
longer-term strategy for addressing key issues. The EPA also 
recommended that DOI and USDA should consider the Department of 
Defense, Department of Energy, and other agencies to determine what 
lessons learned and best practices can be adapted to their issues. The 
EPA also recognized the need for DOI and USDA to establish baseline 
facts and develop an inventory of known sites in order to advance site 
cleanup. 

On behalf of the EPA, I would like to thank you for the opportunity to 
review the draft report. If you require further information, please 
contact Ellen Treimel at (703) 603-0720. 

Sincerely, 

Signed by: 

Marty Stanislaus: 
Assistant Administrator: 

Enclosure: 

cc: 
EPA GAO Liaison Team; 
Barry Breen; 
Nitin Natarajan; 
Becky Brooks; 
Charlotte Bertrand; 
Paul Leonard; 
Charles Openchowski; 
Lora Culver; 
Bobbie Trent; 
Johnsie Webster; 
Gwendolyn Spriggs; 
Kecia Thornton; 
Nick Hilosky; 
Holly Fliniau; 
Mark Howard; 
Willie Taylor; 
Lisa Wilusz. 

[End of section] 

Appendix VII: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

J. Alfredo Gómez, (202) 512-3841 or gómezj@gao.gov: 

Staff Acknowledgments: 

In addition to the individual named above, Vincent P. Price (Assistant 
Director), Antoinette Capaccio, John Delicath, Paul Kinney, Heather 
Salinas, Esther Toledo, and Leigh White made key contributions to this 
report. 

[End of section] 

Footnotes: 

[1] In this report, we use the term "hazardous waste" to refer 
generally to material that is or may be harmful to human health or the 
environment, although the term has specific meaning under the Resource 
Conservation and Recovery Act (RCRA) and the Comprehensive 
Environmental Response, Compensation, and Liability Act (CERCLA). 
Under RCRA, "hazardous waste" generally refers to materials 
specifically listed by the Environmental Protection Agency or which 
demonstrate certain hazardous characteristics. A "hazardous waste" 
under RCRA is also among the substances defined as a "hazardous 
substance" under CERCLA. 

[2] Pub. L. No. 101-576, 104 Stat. 2838 (codified as amended in 
scattered sections of 5, 31, 28, and 42 U.S.C.). 

[3] Federal Accounting Standards Advisory Board's Statement of Federal 
Financial Accounting Standards (SFFAS) No. 5, Accounting for 
Liabilities of the Federal Government (Dec. 20, 1995). 

[4] GAO, Superfund: Civilian Federal Agencies Slow to Clean Up 
Hazardous Waste, RCED-87-153 (Washington, D.C.: July 24, 1987) and 
Status of Civilian Federal Agency Efforts To Address Hazardous Waste 
Problems on Their Lands, [hyperlink, 
http://www.gao.gov/products/RCED-84-188] (Washington, D.C.: Sept. 28, 
1984). 

[5] GAO, Hardrock Mining: Information on Abandoned Mines and Value and 
Coverage of Financial Assurances on BLM Land, [hyperlink, 
http://www.gao.gov/products/GAO-08-574T] (Washington, D.C.: Mar. 12, 
2008); Abandoned Mines: Information on the Number of Hardrock Mines, 
Cost of Cleanup, and Value of Financial Assurances, [hyperlink, 
http://www.gao.gov/products/GAO-11-834T] (Washington, D.C.: July 14, 
2011); and Hardrock Mining: BLM Needs to Revise Its Systems for 
Assessing the Adequacy of Financial Assurances, [hyperlink, 
http://www.gao.gov/products/GAO-12-189R] (Washington, D.C.: Dec. 12, 
2011). 

[6] Reporting is also referred to as recognizing a liability. 

[7] Under CERCLA, potentially responsible parties include current or 
former owners or operators of a site or the generators and 
transporters of the hazardous substances. For purposes of this report, 
we use the term responsible parties to refer to those potentially 
responsible parties who are accepting liability or for whom liability 
is proven. 

[8] Federal Accounting Standards Advisory Board, Statement of Federal 
Financial Accounting Standards (SSFAS), No. 5, Accounting for 
Liabilities of the Federal Government (Dec. 20, 1995). 

[9] Federal Accounting Standards Advisory Board, Federal Financial 
Accounting and Auditing Technical Release 2, Determining Probable and 
Reasonably Estimable for Environmental Liabilities in the Federal 
Government. 

[10] Disclosure refers to information in the notes regarded as 
integral to the financial statements. 

[11] In addition, certain Formerly Used Defense Sites (FUDS) are now 
under USDA or Interior's jurisdiction. These sites were once under the 
jurisdiction of the Department of Defense and may be contaminated. 
They include firing ranges, and industrial facilities. Appendix II 
provides information on FUDS. 

[12] The National Forest System (NFS) is a national system of 
federally owned units of forest, range, and related land that are 
administered by the Forest Service or designated for administration 
through the Forest Service. 

[13] These sources include the Environmental Management Division's 
(EMD) Center for Environmental Excellence (CEE) database for Forest 
Service sites in Regions 1 through 9, a spreadsheet of Forest Service 
sites for Region 10, USDA's Docket Status Spreadsheet, and statements 
from officials of the Animal and Plant Health Inspection Service 
(APHIS), Agricultural Research Service (ARS), and Commodity Credit 
Corporation (CCC). 

[14] However, Forest Service officials said that some landfills and 
underground storage tanks may not be captured by this number. The 
Forest Service tracks most of its sites with confirmed contamination 
in the CEE database. In general, sites brought into "active" status 
within CEE have known contamination, but the degree and extent of that 
contamination has yet to be determined. Active sites are those at 
which USDA plans to perform (or has performed) a CERCLA preliminary 
assessment to eliminate from further consideration those sites that 
pose no threat to public health or the environment, to determine the 
need for further response actions, and to set priorities for further 
response actions. 

[15] Forest Service officials said that these types of sites are 
sometimes addressed through time-critical removal actions and are 
cleaned up shortly after their discovery, depending on the specific 
circumstances. 

[16] According to USDA officials, this estimate is derived from a 1995 
USDA report that acknowledged uncertainties associated with the date 
used to generate the estimate. For some states, the data are fairly 
accurate but, in other cases, the data are incomplete or missing. 

[17] In CEE, sites that are marked as "pending" have not yet been 
assessed and are therefore potentially contaminated. CEE shows that 
there are 20,401 "pending" mine or mill sites. 

[18] USDA officials said that CEE still contains the original 
abandoned mine lands inventory and will do so until the AML database 
is completed. However, additional inventory work has been performed 
during the transition to the AML database, and the completeness of the 
data varies across the regions. Therefore, the abandoned mine data 
within CEE represent a subset of the data in the AML database. 

[19] According to Forest Service officials, the Forest Service 
regional offices conducted inventory efforts in the 1980s and 1990s. 
Officials noted, however, that each regional office inventoried its 
sites differently, and some inventory efforts were more comprehensive 
than others. 

[20] Officials in Forest Service Region 10 said that their region's 
focus has been on cleanup of known priority sites rather than 
completing their inventory of potentially contaminated sites. 

[21] Forest Service Region 2 has helped states in its region, most 
notably Colorado, develop their own inventories of abandoned mines, 
but Forest Service Region 2 does not maintain inventory data at the 
regional level and was only able to provide inventory data from CEE--
which contains a more limited data set. To provide a full inventory of 
sites in the region, one Forest Service official told us that it would 
have to get the data, much of it in hard copy, from each ranger 
district--a very time-consuming task. Officials in Forest Service 
Region 2 added that their management approach is to spend their 
limited resources working with other state and federal agencies to 
address agreed-upon areas of concern rather than completing their 
inventory efforts. 

[22] A mine feature is a single human-made object or disturbance 
associated with mining. A mine site can be composed of one or more 
features. 

[23] The remainder of the hazardous materials sites has been 
remediated or requires no further action. 

[24] U.S. Department of Interior Office of Inspector General, Audit 
Report: Abandoned Mine Lands in the Department of the Interior, July 
2008, C-IN-MOA-0004-2007. 

[25] In May 2013, BLM published a report that summarizes recent 
inventory efforts titled Abandoned Mine Lands: A New Legacy. 

[26] BLM has 12 state offices located in Alaska, Arizona, California, 
Colorado, Idaho, Montana, Nevada, New Mexico, Oregon, Utah, Wyoming, 
and an eastern states office. 

[27] NPS published interim results in Interim Inventory and Assessment 
of Abandoned Mineral Lands in the National Park System, Natural 
Resource Technical Report NPS/NRSS/GRD/NRTR-2013/659, January 2013. 
Complete results, as shown above, will be published in a comprehensive 
report to be released later in 2014. 

[28] American Recovery and Reinvestment Act of 2009, Pub. L. No. 111-
5, 123 Stat. 115. 

[29] This total includes overhead costs; $11.85 million was for site 
projects in fiscal year 2013. 

[30] Several USDA agencies may also use agency specific funds for 
environmental cleanup activities, but those expenditures are usually a 
small percentage of the total budget and are therefore excluded from 
our analysis. For example, APHIS's Environmental Protection Program 
may fund some environmental cleanup projects. However, one APHIS 
official told us that APHIS does not receive any specific 
appropriation for environmental cleanup efforts, and that most of the 
funds in this program actually go toward disposal of hazardous waste 
from operating facilities. FSA also funds its cleanup of foreclosure 
properties through the Farm Loan Program. According to one FSA 
official, in fiscal year 2013 FSA spent approximately $1.47 million on 
cleanup of its three foreclosure properties out of the Farm Loan 
Program's $4.8 billion budget. 

[31] EMD provides funds to the Office of the General Counsel (OGC) to 
support USDA cleanup efforts. EMD officials said that OGC has been 
successful in bringing additional money into the HMMA program by, 
among other things, identifying potentially responsible parties (PRP), 
such as owners and operators of a site, that may help pay for cleanup 
activities and by pursuing cost recovery actions against these PRPs. 
These officials added that--unlike Interior, which pays for staff 
salaries out of general appropriations--USDA pays for its staff 
salaries out of program specific accounts. 

[32] These funds include overhead costs; for example, in fiscal year 
2013, $11.85 million was for cleanup projects. 

[33] 15 U.S.C. § 713a-4 (2012). 

[34] USDA's cost recovery amounts include (1) costs already incurred 
by USDA and reimbursed by a PRP, (2) funds that a PRP has agreed to 
provide for future cleanup work, and (3) the value of cleanup work 
directly performed by the PRP. 

[35] USDA officials noted that this figure only includes assessment 
activities conducted after 2003. USDA officials told us that the 
agency assessed and cleaned up many sites prior to the establishment 
of CEE that have not been recorded in that database. 

[36] According to USDA officials, this number represents the number of 
CERCLA cleanup actions in CEE, as well as certain RCRA or UST sites. 
Several sites had more than one cleanup activity. 

[37] EMD also issued accomplishment reports prior to 2011. However, 
according to agency officials, in 2011, EMD changed the format of the 
report to include background information to reach a broader audience 
and serve as a program education tool for individuals not familiar 
with the cleanup program. 

[38] BLM has 12 state offices located in Alaska, Arizona, California, 
Colorado, Idaho, Montana, Nevada, New Mexico, Oregon, Utah, Wyoming, 
and an eastern states office. 

[39] USDA did not report asbestos cleanup liabilities prior to fiscal 
year 2013. As a result, USDA only reported $10 million in 
environmental and disposal liabilities in fiscal year 2012. 

[40] CCC reported a cost range of $8 million to $55 million on its 
agency financial statements. 

[41] These 24 Forest Service sites do not include any abandoned mines. 

[42] A contingent liability is an existing condition, situation, or 
set of circumstances involving uncertainty as to possible loss to an 
entity that will ultimately be resolved when one or more future events 
occur or fail to occur. 

[43] USDA reported $120 million in contingent liabilities in its 
fiscal year 2013 financial statements; the $40 million in 
environmental liabilities is a portion of the total reported. The $40 
million represents the lower end of a range of cleanup costs for these 
four mine sites. The mining company that leases these sites sued the 
U.S. government to recover its response costs incurred in connection 
with the remediation of the four mines, which are located on federal 
land. The court ultimately approved a settlement under which the 
mining company would pay 67 percent, and the government would pay 33 
percent of all past and future costs. In court documents, the United 
States noted that the total cleanup costs for the sites are unknown, 
but preliminary estimates are in the hundreds of millions of dollars. 
Nu-West Mining, Inc. v. United States, 2013 U.S. Dist. LEXIS 32747, D. 
Idaho (2013). Forest Service officials noted that, absent the 
completion of feasibility studies and the development of remediation 
cost estimates on these sites, any cost estimates are highly 
speculative. 

[44] USDA did not disclose any similar costs in its fiscal year 2013 
financial statements. 

[45] According to EPA, the agency also does not include previously 
owned federal facilities or sole transporters of hazardous waste. 

[46] Exec. Order No. 12580, Superfund Implementation, 52 Fed. Reg. 
2,923 (Jan. 29, 1987). 

[47] We note that the only trigger for the preliminary assessment 
requirement is inclusion on the docket, not whether a release occurred 
or whether that release is thought to be low-risk. 

[48] 42 U.S.C. § 9620(d)(1) (2012). 

[49] These sites may still need cleanup. In those cases, the federal 
agencies proceed with cleanup using delegated CERCLA authority. 

[50] Executive Order 12866 applies to "significant regulatory actions-
-which include, among other things, actions expected to (1) have an 
annual effect of $100 million or more on the economy or (2) raise 
novel legal or policy issues. 

[51] Specifically, BLM noted that prior to BLM's implementation of the 
Federal Land Policy and Management Act of 1976, private operators of 
mine sites like Red Devil had broad rights to enter and locate mining 
claims on public lands and to control surface use and activities 
without federal oversight. 

[52] Federal Accounting Standards Advisory Board's Statement of 
Federal Financial Accounting Standards (SSFAS) No. 5, Accounting for 
Liabilities of the Federal Government; Federal Financial Accounting 
Standards 5: Accounting for Liabilities of the Federal Government, 
Technical Release 2: Environmental Liabilities Guidance. 

[53] The Defense Environmental Restoration Program was established by 
section 211 of the Superfund Amendments and Reauthorization Act of 
1986 which amended CERCLA. In implementing this program, DOD is 
required to carry out its activities addressing hazardous substances, 
pollutants, or contaminants in a manner consistent with section 120 of 
CERCLA. 

[54] The Army, Interior, and USDA are signatories to the Statement of 
Principles for Collaborative Decision Making for Cleanup of Formerly 
Used Defense Sites on Federal Lands, in which the agencies agreed to 
coordinate on FUDS preliminary assessments, and Interior and USDA 
agreed to consult with DOD on cleanup activities. 

[55] Specifically, the Corps designated 320 of the 735 FUDS projects 
on Interior properties as NDAI, and 123 of the 236 FUDS projects on 
USDA properties as NDAI. 

[56] In addition, the Corps categorized 4 FUDS on Interior properties 
and 5 FUDS on USDA properties as "community relations" projects. Such 
projects are associated with public involvement activities and do not 
fall under one of the three FUDS program categories. 

[57] These numbers include "potentially responsible party/hazardous, 
toxic, and radioactive waste" projects. The Corps defines such 
projects as FUDS where HTRW cleanup requirements exist, and parties 
other than DOD are potentially responsible parties for the hazardous 
substances, pollutants, or contaminants. 

[58] Munitions and explosives of concern include unexploded ordnance; 
discarded military munitions, as defined in 10 U.S.C. § 2710(e)(2); or 
munitions constituents (e.g., TNT, RDX) present in high enough 
concentrations to pose an explosive hazard. Munitions constituents are 
defined by 10 U.S.C. § 2710(e)(4) as materials originating from 
unexploded ordnance, discarded military munitions, or other military 
munitions, including explosive and nonexplosive materials, and 
emission, degradation, or breakdown elements of such ordnance or 
munitions. 

[59] These numbers include "potentially responsible party/military 
munitions response" projects. The Corps defines such projects as FUDS 
where Military Munitions Response Program cleanup requirements exist, 
and parties other than DOD are potentially responsible parties for 
disposal of the Military Munitions Response Program materials. 

[60] A U.S. Army official said the expenditures data the Corps 
provided to GAO was reported in the last published Defense 
Environmental Programs Annual Report to Congress, which reflected data 
as of the end fiscal year 2012. The report for fiscal year 2013 has 
not yet been submitted to Congress, and, therefore, the cost data for 
that year still reflects allocations or planned costs. 

[61] During the preliminary assessment, the Corps uses available 
information, including a search of historical records, to determine 
whether the property was ever under the jurisdiction of DOD and owned 
or controlled by the United States, and if hazards caused by DOD's use 
may be present. If the Corps determines that the property was under 
the jurisdiction of DOD and owned or controlled by the United States, 
but it does not find evidence of any hazards caused by DOD, it 
designates the property as NDAI. If, however, the Corps determines 
that hazards caused by DOD prior to October 17, 1986, may be present, 
then the Corps begins further study. 

[62] Interior uses the term "record" to refer to the information 
documented in the department's EDL database module. 

[63] In 2005, Interior's Office of Inspector General recommended that 
the Office of Environmental Policy and Compliance develop a management 
information system that captures consistent and accurate data for all 
hazardous materials sites. To implement this recommendation, the 
Office of Environmental Policy and Compliance created the 
Environmental Management Information System. The EDL module of the 
database was implemented in the third quarter of fiscal year 2006 and 
is used by the department in preparing its quarterly and annual 
financial statements. 

[64] Interior defines environmental assessment or due care as the 
process followed by a bureau or office to use reasonable effort to 
examine a location of concern--an area on department lands that is 
suspected to be contaminated based on known past activities or 
observed and reported physical indicators--to identify the presence or 
likely presence of contamination at concentrations significant enough 
to require further study or cleanup. 

[65] According to Interior's Environmental and Disposal Liabilities 
Identification, Documentation and Reporting Handbook v 3.0, 
groundwater and surface water treatment actions to restore water 
quality to a protected level are considered part of the remedial 
action for the first 10 years of operation and operation and 
maintenance for any additional years. 

[End of section] 

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