GAO-10-380, Superfund: EPA's Estimated Costs to Remediate Existing Sites Exceed Current Funding Levels, and More Sites Are Expected to Be Added to the National Priorities List


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Report to Congressional Requesters: 

United States Government Accountability Office: 
GAO: 

May 2010: 

Superfund: 

EPA's Estimated Costs to Remediate Existing Sites Exceed Current 
Funding Levels, and More Sites Are Expected to Be Added to the 
National Priorities List: 

GAO-10-380: 

GAO Highlights: 

Highlights of GAO-10-380, a report to congressional requesters. 

Why GAO Did This Study: 

At the end of fiscal year 2009, the Environmental Protection Agency’s 
(EPA) National Priorities List (NPL) included 1,111 of the most 
seriously contaminated nonfederal hazardous waste sites. Of these 
sites, EPA had identified 75 with unacceptable human exposure, 164 
with unknown exposure, and 872 with controlled exposure that may need 
additional cleanup work. EPA may fund remedial actions—long-term 
cleanup—from its trust fund, and compel responsible parties to perform 
or reimburse costs of the cleanup. GAO was asked to determine (1) the 
cleanup and funding status at currently listed nonfederal NPL sites 
with unacceptable or unknown human exposure; (2) what is known about 
EPA’s future cleanup costs at nonfederal NPL sites; (3) EPA’s process 
for allocating remedial program funding; and (4) how many NPL sites 
some state and EPA officials expect to be added in the next 5 years, 
and their expected cleanup costs. GAO analyzed Superfund program data, 
surveyed and interviewed EPA officials, and interviewed state 
officials. 

What GAO Found: 

At over 60 percent of the 239 nonfederal NPL sites with unacceptable 
or unknown human exposure, all or more than half of the work remains 
to complete the remedial construction phase of cleanup, according to 
EPA regional officials. By the end of fiscal year 2009, EPA had 
expended $3 billion on the 75 sites with unacceptable human exposure 
and $1.2 billion on the 164 sites with unknown exposure. Despite the 
relatively high level of expenditures at sites with unacceptable 
exposure, EPA officials told GAO that, in managing limited resources, 
some sites have not received sufficient funding for construction to be 
conducted in the most time and cost efficient manner. 

EPA’s future costs to conduct remedial construction at nonfederal NPL 
sites will likely exceed recent funding levels. EPA officials estimate 
that EPA’s costs will be from $335 to $681 million each year for 
fiscal years 2010 to 2014, which exceed the $220 to $267 million EPA 
allocated annually for remedial actions from fiscal years 2000 to 
2009. In addition, these cost estimates are likely understated, since 
they do not include costs for sites that are early in the cleanup 
process or for sites where a responsible party is currently funding 
remedial construction but may be unable to do so in the future. Also, 
according to EPA officials, EPA’s actual costs are often higher than 
its estimates because contamination is often greater than expected. 

EPA allocates funds separately for preconstruction activities-—such as 
remedial investigation and remedial design-—and remedial actions. EPA 
headquarters allocates funds for preconstruction activities to the 
regions for them to distribute among sites. For remedial actions, 
headquarters works in consultation with the regions to allocate funds 
to sites. EPA officials told GAO that EPA prioritized sites to receive 
the $582 million in American Recovery and Reinvestment Act funds in a 
manner similar to the way EPA prioritizes sites for remedial actions. 
Limited funding has delayed preconstruction activities and remedial 
actions at some sites, according to EPA officials. 

EPA regional officials estimated that from 101 to 125 sites-—about 20 
to 25 sites per year-—will be added to the NPL over the next 5 years, 
which is higher than the average of about 16 sites per year listed for 
fiscal years 2005 to 2009. Most of the 10 states’ officials GAO 
interviewed also expect an increase in the number of sites listed from 
their states. However, neither EPA regional officials nor state 
officials were able to provide cost estimates for cleaning up many of 
the sites. In addition, the number of sites eligible for listing could 
increase if EPA decides to assess the relative risk of vapor intrusion—
contaminated air that seeps into buildings from underground sources—a 
pathway of concern among EPA regional officials and state officials 
interviewed. Although sites with vapor intrusion can pose considerable 
human health risks, EPA’s Hazard Ranking System—the mechanism used to 
identify sites that qualify for NPL listing—does not recognize these 
risks; therefore, unless a site with vapor intrusion is listed on some 
other basis, EPA cannot clean up the site through its remedial program. 

What GAO Recommends: 

To better identify potential NPL sites, GAO recommends that the EPA 
Administrator determine the extent to which EPA will consider vapor 
intrusion in listing NPL sites and its effect on the number of sites 
listed in the future. In commenting on a draft of this report, EPA 
agreed with GAO’s recommendation and noted that the report contains 
substantial useful information. 

View [hyperlink, http://www.gao.gov/products/GAO-10-380] or key 
components. For more information, contact John Stephenson at (202) 512-
3841 or Stephensonj@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Considerable Work Remains at Most Nonfederal NPL Sites with 
Unacceptable or Unknown Human Exposure, and Some Site Cleanups Have 
Not Been Funded at the Most Efficient Level: 

EPA's Costs for Conducting Remedial Construction at Nonfederal NPL 
Sites Will Likely Exceed Recent Funding Levels for These Activities: 

EPA Allocates Remedial Program Funding Separately for Preconstruction 
Activities and Remedial Actions, and Limited Funding Has Caused Delays 
at Some Sites: 

Most EPA Regional and Selected State Officials Expect an Increase in 
the Number of Sites Added to the NPL over the Next 5 Years but Cannot 
Estimate the Cleanup Costs: 

Conclusions: 

Recommendation for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: GAO Survey of Superfund Sites: 

Appendix III: Sites with Unacceptable Human Exposure: 

Appendix IV: Sites Receiving Recovery Act Funding: 

Appendix V: Comments from the Environmental Protection Agency: 

Appendix VI: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: EPA Regional Officials' Estimates of Costs to EPA to Conduct 
Remedial Construction in the Most Efficient Manner at Nonfederal Sites 
on the NPL, as of September 30, 2009: 

Table 2: Comparison of the Number of Sites EPA Listed from Fiscal 
Years 2005 through 2009 and the Number of Sites Projected to Be Listed 
from Fiscal Years 2010 through 2014, by Region: 

Table 3: Comparison of the Number of Sites EPA Listed from Each of the 
10 States from Fiscal Years 2005 through 2009 and the Number of Sites 
State Officials Project May Be Listed from Fiscal Years 2010 through 
2014, by State: 

Table 4: Description of Human Exposure Risks, Fiscal Year Site was 
Listed on the NPL, and the Expected Fiscal Year Human Exposure Will Be 
Controlled at NPL Sites with Unacceptable Human Exposure, as of the 
End of Fiscal Year 2009: 

Table 5: Amount and Planned Use of Recovery Act Funds for Superfund 
Sites: 

Figures: 

Figure 1: Balance of the Superfund Trust Fund at the Start of Each 
Fiscal Year, Fiscal Years 1981 through 2009: 

Figure 2: EPA's Superfund Program Appropriation, Fiscal Years 1981 
through 2009: 

Figure 3: Phases of the Remedial Process at NPL Sites: 

Figure 4: Amount of Work Remaining to Complete Construction at the 75 
Nonfederal NPL Sites with Unacceptable Human Exposure: 

Figure 5: Amount of Work Remaining to Complete Construction at the 164 
Nonfederal NPL Sites with Unknown Risks of Human Exposure: 

Figure 6: Average Per-Site EPA Expenditures, Fiscal Years 1990 through 
2009: 

Figure 7: Media of Concern at the 75 Sites with Unacceptable Human 
Exposure: 

Abbreviations: 

CDC: Centers for Disease Control and Prevention: 

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

CERCLIS: Comprehensive Environmental Response, Compensation, and 
Liability Information System: 

EPA: Environmental Protection Agency: 

HRS: Hazard Ranking System: 

NPL: National Priorities List: 

PAHs: polycyclic aromatic hydrocarbons: 

PBB: polybrominated biphenyl: 

PCB: polychlorinated biphenyl: 

PCE: tetrachloroethylene: 

PCP: pentachlorophenol: 

ROD: record of decision: 

TCE: trichloroethylene: 

[End of section] 

United States Government Accountability Office:
Washington, DC 20548: 

May 6, 2010: 

The Honorable Barbara Boxer: 
Chairman: 
Committee on Environment and Public Works: 
United States Senate: 

The Honorable Frank R. Lautenberg: 
Chairman: 
Subcommittee on Superfund, Toxics and Environmental Health: 
Committee on Environment and Public Works: 
United States Senate: 

To protect human health and the environment from the effects of 
hazardous substances, Congress enacted the Comprehensive Environmental 
Response, Compensation, and Liability Act (CERCLA) in 1980, which 
established the Superfund program.[Footnote 1] The Environmental 
Protection Agency (EPA), the principal agency responsible for 
administering the Superfund program, has since identified more than 
47,000 hazardous waste sites potentially requiring cleanup. As of the 
end of fiscal year 2009, 1,269 of the most seriously contaminated 
sites were included on EPA's National Priorities List (NPL):[Footnote 
2] 1,111 nonfederal sites and 158 federal facilities.[Footnote 3] At 
the time of listing, EPA had determined that these sites posed 
relatively high risks to human health or the environment from releases 
or threatened releases of hazardous substances, such as lead and 
polychlorinated biphenyl (PCB). These substances can cause a variety 
of health issues--such as birth defects, cancer, and developmental 
disorders--in people exposed to them. Of the nonfederal sites listed 
on the NPL at the end of fiscal year 2009, EPA identified 75 that have 
"unacceptable human exposure"--actual or reasonably expected exposures 
of an individual to hazardous substances, pollutants, or contaminants 
at levels that present an unacceptable risk--to contaminants for 
people living, recreating, and/or working in the surrounding areas. In 
addition, another 164 of the sites listed on the NPL at the end of 
fiscal year 2009 may potentially pose serious risks since EPA does not 
yet know if there is unacceptable human exposure at these sites. 
[Footnote 4] At the remaining 872 sites, EPA has determined that human 
exposure has been controlled, but additional work to clean up the 
sites may still be needed. 

Cleanup efforts at NPL sites are typically expensive and can take many 
years. The cleanup process begins with site discovery or notification 
to EPA of the possible release of hazardous substances posing a threat 
to human health or the environment. Once a site is discovered, EPA, 
sometimes in conjunction with the state, conducts initial 
investigations to assess the potential threat. EPA then decides if it 
will list a site on the NPL based on a number of factors, usually 
including the site's score on the Hazard Ranking System (HRS), which 
is a tool used to determine a site's relative threat to human health 
and the environment based on potential pathways of contamination; the 
availability of alternative state or federal programs that could clean 
up the site; and state concurrence with the listing. Sites listed on 
the NPL are typically cleaned up through the Superfund remedial 
program.[Footnote 5] As part of this program, EPA conducts or arranges 
for a remedial investigation and feasibility study to (1) identify the 
nature and extent of contamination, (2) quantify the potential risks 
to human health and the environment, and (3) evaluate the potential 
remedies to achieve cleanup goals. EPA then selects a remedy and 
documents this decision in a record of decision (ROD). EPA then plans 
the selected remedy in the remedial design phase and implements it 
with construction activities in the remedial action phase. EPA 
designates a site as "construction complete" when all physical 
construction activities at a site are finished, all immediate threats 
have been addressed, and all long-term threats are under control. Of 
the 1,111 nonfederal sites listed on the NPL as of the end of fiscal 
year 2009, 695 had reached EPA's construction complete milestone, 
while the remaining 416 had not. However, even after sites have 
reached EPA's construction complete milestone, final cleanup at a site 
may not be achieved for many years, because it may take decades to 
clean up contamination to the selected standards. 

Responsible parties are liable for conducting or paying for site 
cleanup of hazardous substances.[Footnote 6] EPA is responsible for 
identifying potentially responsible parties and may take enforcement 
actions against these parties to compel them to clean up sites. In 
some cases, however, parties cannot be identified or may be unwilling 
or financially unable to perform the cleanup. In addition, federal 
agencies are responsible for funding the cleanup at the sites that 
they own. CERCLA also authorizes EPA to pay for remedial cleanups at 
sites on the NPL, as well as to seek reimbursement from the 
potentially responsible parties. To fund EPA-led cleanups at 
nonfederal NPL sites, among other Superfund program activities, CERCLA 
established the Hazardous Substance Superfund (trust fund). 
Historically, the trust fund was financed primarily by taxes on crude 
oil and certain chemicals, as well as an environmental tax on 
corporations based on their taxable income; however, the authority for 
these taxes expired in 1995, and shortly thereafter the balance in the 
trust fund started diminishing. Since 2001, appropriations from 
general revenues have been the largest source of funding for the trust 
fund. Superfund program appropriations have averaged about $1.2 
billion annually since 1981, although the annual level of these 
appropriated funds has generally declined in recent years when 
adjusted for inflation. By the start of fiscal year 2009, the balance 
of the trust fund had decreased in value from its peak of $5.0 billion 
in 1997 to $137 million. As part of the American Recovery and 
Reinvestment Act of 2009 (Recovery Act),[Footnote 7] EPA's Superfund 
remedial program received an additional $600 million.[Footnote 8] 

In this context, you asked us to determine (1) the cleanup and funding 
status at currently listed nonfederal NPL sites with unacceptable or 
unknown human exposure; (2) what is known about the future costs to 
EPA to conduct remedial actions at nonfederal NPL sites that are not 
construction complete; (3) the process EPA uses to allocate remedial 
program funding; and (4) the number of sites EPA and selected state 
officials expect will be added to the NPL over the next 5 years, and 
what they expect the costs of cleaning up those sites will be. 

To determine the status of cleanup and funding at nonfederal NPL sites 
with unacceptable or unknown human exposure and what is known about 
future EPA costs to conduct remedial construction at nonfederal sites, 
we conducted an electronic survey of branch chiefs from the 10 EPA 
regions to collect information about NPL sites relevant to these two 
objectives. We also interviewed these officials to obtain 
clarification and additional information regarding their responses, 
and we analyzed data on cleanup status and expenditures at these sites 
from EPA's Comprehensive Environmental Response, Compensation, and 
Liability Information System and Integrated Financial Management 
System. To describe EPA's process for allocating remedial program 
funding, we analyzed EPA guidance and planning documents and 
interviewed EPA headquarters and regional officials. To determine the 
number of sites that EPA and selected state officials expect will be 
added to the NPL over the next 5 years, and what they expect the costs 
of cleaning up those sites will be, we interviewed officials from 
EPA's 10 regions, 10 selected states--chosen to include one from each 
of EPA's regions and varying numbers of sites listed over the past 10 
years; as well as officials from the Association of State and 
Territorial Solid Waste Management Officials.[Footnote 9] In addition, 
we discussed all of these issues with officials from EPA headquarters. 
To assess the reliability of the data from EPA's databases used in 
this report, we analyzed related documentation, examined the data to 
identify obvious errors or inconsistencies, and worked with agency 
officials to identify data problems. We determined the data to be 
sufficiently reliable for the purposes of this report. A detailed 
description of our objectives, scope, and methodology is presented in 
appendix I. The questions from our electronic survey of branch chiefs 
from the 10 EPA regions are listed in appendix II. 

We conducted this performance audit from March 2009 to May 2010, 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: 

CERCLA was passed in late 1980, in the wake of the discovery of toxic 
waste sites such as Love Canal,[Footnote 10] and it created a 
mechanism for responding to existing contamination. CERCLA established 
a trust fund from which EPA receives annual appropriations for 
Superfund program activities. The Superfund trust fund has received 
revenue from four major sources: taxes on crude oil and certain 
chemicals, as well as an environmental tax assessed on corporations 
based on the taxable income; appropriations from the general fund; 
fines, penalties, and recoveries from responsible parties; and 
interest accrued on the balance of the fund. In the program's early 
years, dedicated taxes provided the majority of revenue to the 
Superfund trust fund. However, in 1995, the authority for these taxes 
expired and has not been reinstated.[Footnote 11] Since 2001, 
appropriations from the general fund have constituted the largest 
source of revenue for the trust fund. After the expiration of the tax 
authority, at the start of fiscal year 1997, the trust fund balance 
reached its peak of $5.0 billion; in 1998, the trust fund balance 
began decreasing. Figure 1 shows changes in the balance of the 
Superfund trust fund from fiscal years 1981 through 2009. At the start 
of fiscal year 2009, the trust fund had a balance of $137 million. 

Figure 1: Balance of the Superfund Trust Fund at the Start of Each 
Fiscal Year, Fiscal Years 1981 through 2009: 

[Refer to PDF for image: vertical bar graph] 

Constant 2009 dollars in millions: 

Fiscal year: 1981; 
Superfund Trust Fund balance: $0. 

Fiscal year: 1982; 
Superfund Trust Fund balance: $157.3. 

Fiscal year: 1983; 
Superfund Trust Fund balance: $440.7. 

Fiscal year: 1984; 
Superfund Trust Fund balance: $650.5. 

Fiscal year: 1985; 
Superfund Trust Fund balance: $498.2. 

Fiscal year: 1986; 
Superfund Trust Fund balance: $0. 

Fiscal year: 1987; 
Superfund Trust Fund balance: $15.5. 

Fiscal year: 1988; 
Superfund Trust Fund balance: $0. 

Fiscal year: 1989; 
Superfund Trust Fund balance: $382.8. 

Fiscal year: 1990; 
Superfund Trust Fund balance: $523.9. 

Fiscal year: 1991; 
Superfund Trust Fund balance: $495.5. 

Fiscal year: 1992; 
Superfund Trust Fund balance: $,1816.4. 

Fiscal year: 1993; 
Superfund Trust Fund balance: $2,404.9. 

Fiscal year: 1994; 
Superfund Trust Fund balance: $2,961.7. 

Fiscal year: 1995; 
Superfund Trust Fund balance: $3,681.5. 

Fiscal year: 1996; 
Superfund Trust Fund balance: $4,862.2. 

Fiscal year: 1997; 
Superfund Trust Fund balance: $5,001.9. 

Fiscal year: 1998; 
Superfund Trust Fund balance: $3,449.2. 

Fiscal year: 1999; 
Superfund Trust Fund balance: $2,742.1. 

Fiscal year: 2000; 
Superfund Trust Fund balance: $1,871.3. 

Fiscal year: 2001; 
Superfund Trust Fund balance: $1,539.1. 

Fiscal year: 2002; 
Superfund Trust Fund balance: $1,031.8. 

Fiscal year: 2003; 
Superfund Trust Fund balance: $662.9. 

Fiscal year: 2004; 
Superfund Trust Fund balance: $0. 

Fiscal year: 2005; 
Superfund Trust Fund balance: $0. 

Fiscal year: 2006; 
Superfund Trust Fund balance: $101.9. 

Fiscal year: 2007; 
Superfund Trust Fund balance: $180.4. 

Fiscal year: 2008; 
Superfund Trust Fund balance: $278.2. 

Fiscal year: 2009; 
Superfund Trust Fund balance: $137. 

Source: GAO analysis of data from the President’s Budget Appendixes. 

[End of figure] 

EPA's Superfund program receives annual appropriations from the trust 
fund, which is in turn supported by payments from the general fund. 
Since fiscal year 1981, the annual appropriation to EPA's Superfund 
program has averaged approximately $1.2 billion in noninflation 
adjusted (nominal) dollars. Since fiscal year 1998, however, 
congressional appropriations have generally declined when adjusted for 
inflation. Figure 2 shows appropriation levels in nominal and constant 
2009 dollars since fiscal year 1981. 

Figure 2: EPA's Superfund Program Appropriation, Fiscal Years 1981 
through 2009: 

[Refer to PDF for image: stacked vertical bar graph] 

Dollars in millions: 

Fiscal year: 1981; 
Nominal Appropriation: $68; 
Difference between Nominal Appropriation and Appropriation in constant 
2009 dollars: $77.94. 

Fiscal year: 1982; 
Nominal Appropriation: $200; 
Difference between Nominal Appropriation and Appropriation in constant 
2009 dollars: $201.7. 

Fiscal year: 1983; 
Nominal Appropriation: $219; 
Difference between Nominal Appropriation and Appropriation in constant 
2009 dollars: $202.4. 

Fiscal year: 1984; 
Nominal Appropriation: $410; 
Difference between Nominal Appropriation and Appropriation in constant 
2009 dollars: $350.6. 

Fiscal year: 1985; 
Nominal Appropriation: $620; 
Difference between Nominal Appropriation and Appropriation in constant 
2009 dollars: $494.2. 

Fiscal year: 1986; 
Nominal Appropriation: $900; 
Difference between Nominal Appropriation and Appropriation in constant 
2009 dollars: $680.8. 

Fiscal year: 1987; 
Nominal Appropriation: $1,411.3; 
Difference between Nominal Appropriation and Appropriation in constant 
2009 dollars: $1,003.2. 

Fiscal year: 1988; 
Nominal Appropriation: $1,128; 
Difference between Nominal Appropriation and Appropriation in constant 
2009 dollars: $741.8. 

Fiscal year: 1989; 
Nominal Appropriation: $1,410; 
Difference between Nominal Appropriation and Appropriation in constant 
2009 dollars: $839.9. 

Fiscal year: 1990; 
Nominal Appropriation: $1,575; 
Difference between Nominal Appropriation and Appropriation in constant 
2009 dollars: $849.1. 

Fiscal year: 1991; 
Nominal Appropriation: $1,616.2; 
Difference between Nominal Appropriation and Appropriation in constant 
2009 dollars: $780.4. 

Fiscal year: 1992; 
Nominal Appropriation: $1,600.1; 
Difference between Nominal Appropriation and Appropriation in constant 
2009 dollars: $712.3. 

Fiscal year: 1993; 
Nominal Appropriation: $1,573.5; 
Difference between Nominal Appropriation and Appropriation in constant 
2009 dollars: $651.4. 

Fiscal year: 1994; 
Nominal Appropriation: $1,465.9; 
Difference between Nominal Appropriation and Appropriation in constant 
2009 dollars: $564.0. 

Fiscal year: 1995; 
Nominal Appropriation: $1,435; 
Difference between Nominal Appropriation and Appropriation in constant 
2009 dollars: $510.8. 

Fiscal year: 1996; 
Nominal Appropriation: $1,313.4; 
Difference between Nominal Appropriation and Appropriation in constant 
2009 dollars: $433.8. 

Fiscal year: 1997; 
Nominal Appropriation: $1,394.3; 
Difference between Nominal Appropriation and Appropriation in constant 
2009 dollars: $427.1. 

Fiscal year: 1998; 
Nominal Appropriation: $1,500; 
Difference between Nominal Appropriation and Appropriation in constant 
2009 dollars: $434.8. 

Fiscal year: 1999; 
Nominal Appropriation: $1,492; 
Difference between Nominal Appropriation and Appropriation in constant 
2009 dollars: $407.3. 

Fiscal year: 2000; 
Nominal Appropriation: $1,400; 
Difference between Nominal Appropriation and Appropriation in constant 
2009 dollars: $347.7. 

Fiscal year: 2001; 
Nominal Appropriation: $1,272.8;
Difference between Nominal Appropriation and Appropriation in constant 
2009 dollars: $279.4. 

Fiscal year: 2002; 
Nominal Appropriation: $1,309.3; 
Difference between Nominal Appropriation and Appropriation in constant 
2009 dollars: $261.6. 

Fiscal year: 2003; 
Nominal Appropriation: $1,264.9; 
Difference between Nominal Appropriation and Appropriation in constant 
2009 dollars: $221.7. 

Fiscal year: 2004; 
Nominal Appropriation: $1,258; 
Difference between Nominal Appropriation and Appropriation in constant 
2009 dollars: $183.5. 

Fiscal year: 2005; 
Nominal Appropriation: $1,247.5; 
Difference between Nominal Appropriation and Appropriation in constant 
2009 dollars: $136.8. 

Fiscal year: 2006; 
Nominal Appropriation: $1,253.6; 
Difference between Nominal Appropriation and Appropriation in constant 
2009 dollars: $91.5. 

Fiscal year: 2007; 
Nominal Appropriation: $1,251.6; 
Difference between Nominal Appropriation and Appropriation in constant 
2009 dollars: $53.4. 

Fiscal year: 2008; 
Nominal Appropriation: $1,273.9; 
Difference between Nominal Appropriation and Appropriation in constant 
2009 dollars: $24.2. 

Fiscal year: 2009[A]; 
Nominal Appropriation: $1,285. 

Source: GAO analysis of appropriations laws and data from the 
President’s Budget Appendixes. 

[A] The fiscal year 2009 appropriation does not include the $600 
million in Recovery Act funds that the program received. 

[End of figure] 

The Superfund cleanup process begins with the discovery of a 
potentially hazardous site or the notification to EPA of possible 
releases of hazardous substances that may threaten human health or the 
environment. Citizens, state agencies, EPA regional officials, and 
others may alert EPA to such threats. EPA regional offices use a 
screening system, called the HRS, to numerically assess the potential 
of sites to pose a threat to human health and the environment. The HRS 
scores sites on four possible pathways of exposure: groundwater, 
surface water, soil, and air. Those sites with sufficiently high 
scores are eligible for proposal to the NPL. EPA regions submit sites 
to EPA headquarters for possible listing on the NPL on the basis of a 
variety of factors, including the availability of alternative state or 
federal programs that may be used to clean up the site. EPA has 
considered the NPL the "tool of last resort"; thus, EPA has looked to 
alternative EPA and individual state programs for hazardous waste 
cleanup before listing a site on the NPL. However, according to EPA 
headquarters officials, EPA's use of the NPL as a tool of last resort 
has recently changed, and EPA now views the NPL as one of a number of 
cleanup options and uses whichever option is most appropriate for site 
cleanup. In addition, EPA officials noted that, as a matter of policy, 
EPA seeks concurrence from the Governor of the state or environmental 
agency head in which the site is located before listing the site. 
Sites that EPA decides that it would like to list on the NPL are 
proposed for listing in the Federal Register. After a period of public 
comment, EPA reviews the comments and decides whether to formally list 
the sites as "final" on the NPL. 

Once EPA lists a site, it initiates a process to investigate the 
extent of the contamination, decide on the actions that will be taken 
to address contamination, and implement those actions. This process 
can take many years--or even decades. Figure 3 outlines the process 
EPA typically follows, from listing a site on the NPL through deleting 
it from the NPL. 

Figure 3: Phases of the Remedial Process at NPL Sites: 

[Refer to PDF for image: illustration] 

Milestone: NPL Listing; 
Phases: 
* Remedial Investigation; 
* Feasibility study. 

Milestone: Record of Decision; 
Phases: 
* Remedial design; 
* Remedial action. 

Milestone: Construction complete; 
Phases: 
* Postconstruction completion[A]. 

Milestone: Deletion from NPL. 

Source: GAO analysis of EPA data. 

Note: Phases of the remedial process may overlap, and multiple phases 
may be concurrently under way at a site. 

[A] Postconstruction completion includes activities such as operation 
and maintenance, long-term response actions, and 5-year reviews, which 
ensure that Superfund cleanup actions provide for the long-term 
protection of human health and the environment. 

[End of figure] 

Specifically, after a site is listed, EPA or a responsible party will 
begin the remedial process by conducting a two-part study of the site: 
(1) a remedial investigation to characterize site conditions and 
assess the risks to human health and the environment, among other 
actions, and (2) a feasibility study to evaluate various options to 
address the problems identified through the remedial investigation. 
The culmination of these studies is a ROD, which identifies EPA's 
selected remedy for addressing the site's contamination. Cleanup at a 
site is often divided into smaller units (operable units) by 
geography, pathways of contamination, or type of remedy. A ROD 
typically lays out the remedy for one operable unit at a site, and it 
contains the cost estimate for implementing the remedy. According to 
EPA guidance, EPA develops the cost estimate in the ROD to be within 
an accuracy range of minus 30 to plus 50 percent of the actual costs. 
[Footnote 12] EPA may develop earlier estimates of construction costs, 
but as the site moves from the study phase into the remedial action 
phase, the level of project definition increases, thus allowing for a 
more accurate cost estimate. EPA may develop more refined cost 
estimates after the ROD. Because more information is available during 
remedial design and remedial action, the accuracy of these estimates 
is expected to be greater than the accuracy of the ROD estimates. 
According to GAO's cost estimating and assessment guide, every cost 
estimate is uncertain because of assumptions that must be made about 
future projections, and cost estimates tend to become more certain as 
actual costs begin to replace earlier estimates.[Footnote 13] 

The selected remedy is then designed during remedial design and 
implemented with remedial actions, when actual cleanup of the site 
begins. When all physical construction at a site is complete, all 
immediate threats have been addressed, and all long-term threats are 
under control, EPA generally considers the site to be construction 
complete. Most sites then enter into the operation and maintenance 
phase when the responsible party or the state maintains the remedy, 
and EPA ensures that the remedy continues to protect human health and 
the environment. However, for certain remedial actions, additional 
work at a site may be required after construction is completed, such 
as continuing groundwater restoration efforts or monitoring the site 
to ensure that the remedy remains protective. For EPA-lead remedial 
actions that have a groundwater or surface water restoration 
component, EPA funds the necessary activities--known as long-term 
response actions--for up to 10 years before turning over these 
responsibilities to the state. Eventually, when EPA and the state 
determine that no further site response is needed, EPA may delete the 
site from the NPL. Although most sites progress through the cleanup 
process in roughly the same way, EPA may take different approaches 
based on site-specific conditions. 

In fiscal year 2009, EPA received about $1.29 billion for the 
Superfund program, of which $605 million was for the remedial program. 
Of this amount, EPA allocated $125 million for preconstruction 
activities--remedial investigation, feasibility study, and remedial 
design activities--as well as other nonconstruction activities, 
including conducting prelisting activities through cooperative 
agreements with states, oversight of all responsible party-lead 
activities, and providing general support and management. In addition, 
EPA allocated $267 million for remedial actions. EPA allocated the 
remaining $213 million for headquarters and regional personnel to 
implement and oversee the overall program; for site management; and 
for providing technical and analytical support for all non-NPL sites 
as well as proposed, final, and deleted NPL sites. 

In addition to remedial actions, the Superfund program conducts 
removal actions at both NPL and non-NPL sites that are usually short-
term cleanups for sites that pose immediate threats to human health or 
the environment. Examples of removal actions include excavating 
contaminated soil, erecting a security fence, or taking abandoned 
drums to a proper disposal facility to prevent the release of 
hazardous substances into the environment. CERCLA limits EPA removal 
actions paid for with trust fund money to actions lasting 12 months or 
less and costing $2 million or less, although these limits can be 
exceeded if EPA determines that conditions for such an exemption are 
met. 

To document and communicate environmental progress toward cleaning up 
Superfund sites, EPA adopted a human exposure indicator in fiscal year 
2002. The indicator was applied to Superfund to communicate progress 
made in protecting human health through site cleanup activities. In 
addition, EPA uses the indicator in its annual Government Performance 
and Results Act reporting. Specifically, on an annual basis, EPA 
reports the number of Superfund sites at which human exposure was 
controlled during the most recent fiscal year. EPA identifies a site 
as having unacceptable human exposure when data indicate that the 
level of contamination and the frequency or duration of human exposure 
associated with certain pathways--or routes of exposure--at the site 
present unacceptable risks to humans. EPA assesses human exposure on a 
site-wide basis; therefore, if any part of a Superfund site has 
unacceptable human exposure, EPA classifies the whole site as such. If 
sufficient and reliable information is not yet available to determine 
whether a site has unacceptable human exposure, the site is classified 
as having insufficient data to determine whether there is unacceptable 
human exposure, or "unknown." 

Threats to human health and the environment may be present in the four 
pathways scored on the HRS--groundwater, surface water, soil, and 
(outdoor) air; however, contaminants may also migrate from groundwater 
or soil and seep into the air of homes or commercial buildings. This 
movement of contaminants--typically from petroleum or chlorinated 
solvents--to indoor air is known as vapor intrusion and has been the 
subject of increasing research and scientific discussion since the 
1980s. Intrusion of contaminated gases into indoor air may lead to 
fire; explosion; and acute, intermediate, and chronic health effects. 
Though EPA conducts investigations of vapor intrusion for some sites 
on the NPL, the HRS does not include a separate pathway for scoring 
vapor intrusion threats. 

Considerable Work Remains at Most Nonfederal NPL Sites with 
Unacceptable or Unknown Human Exposure, and Some Site Cleanups Have 
Not Been Funded at the Most Efficient Level: 

At over 60 percent of the 75 nonfederal NPL sites with unacceptable 
human exposure, all or more than half of the work remains to complete 
remedial construction, as is the case with over 60 percent of the 164 
nonfederal NPL sites with unknown human exposure, according to EPA 
regional officials' responses to our survey. Moreover, while EPA has 
expended a total of $3 billion on the 75 sites with unacceptable 
exposure, EPA headquarters and regional officials told us that some of 
these sites have not received sufficient funding for cleanup to 
proceed in the most efficient manner. 

At Most Sites with Unacceptable Human Exposure, Less than Half of the 
Remedial Construction Work Has Been Completed: 

At 49 of the 75 nonfederal NPL sites that EPA has identified as having 
unacceptable human exposure, all or more than half of the work remains 
to complete remedial construction, according to EPA regional 
officials' responses to our survey (see figure 4).[Footnote 14] At 
each of the 15 sites where none of the remedial construction work has 
been completed, EPA or a responsible party has conducted at least one 
interim cleanup action, such as a removal, and has initiated or 
completed a remedial investigation; however, all of the construction 
work remains, and EPA has determined that human exposure risks 
continue at these sites. In addition, at the remaining 60 sites where 
some construction actions have been taken, EPA has determined that 
human exposure risks have not yet been controlled. For example, at the 
Lava Cap Mine site in California, EPA has eliminated the exposure to 
mine tailings--finely ground waste created in the ore extraction 
process--in the mine area by capping it; however, recreational users 
of the area downstream of the mine can be exposed to mine tailings in 
that area, potentially leading to incidental ingestion of arsenic in 
soil, inhalation of contaminated airborne particulates, or skin 
contact with contaminated sediments along the shoreline. According to 
EPA Region 9 officials, EPA is currently investigating methods to 
stabilize and cover these mine tailings to eliminate the risk of human 
exposure. 

Figure 4: Amount of Work Remaining to Complete Construction at the 75 
Nonfederal NPL Sites with Unacceptable Human Exposure: 

[Refer to PDF for image: pie-chart] 

All work remains: 15 (20%); 
More than half the work remains: 34 (45%); 
About half the work remains: 13 (17%); 
Less than half the work remains: 9 (12%); 
No work remains: 4 (5%). 

Source: GAO analysis of EPA regional officials’ responses to our 
survey. 

Note: EPA reported that four sites have no work remaining because 
these sites have already met EPA's construction completion milestone; 
however, EPA subsequently identified that these sites require 
additional work to reduce the level of contamination, and/or control 
the migration of contaminants. For example, the Commencement Bay, 
South Tacoma Channel site in Washington state reached construction 
completion status in 1999, but a 5-year review conducted in 2008 
indicated that the initial remedy was not protective and further risks 
remain from contaminated drinking water. Percentages do not add due to 
rounding. 

[End of figure] 

According to EPA regional officials' responses to our survey, EPA has 
plans to control human exposure at all of the 75 sites with 
unacceptable human exposure; however, our survey results also show 
that EPA regional officials expect 41 of the sites to continue to have 
unacceptable exposure until fiscal year 2015 or later.[Footnote 15] 
According to an EPA headquarters official responsible for overseeing 
the human exposure indicator, some sites will continue to pose 
unacceptable human exposure for a long time because of the type of 
contamination and cleanup required. For example, it may take several 
years for the risk of human exposure to be eliminated at the Sheboygan 
Harbor & River site in Wisconsin--which was listed on the NPL in 
fiscal year 1986--because of high PCB levels in fish. The site 
currently poses a risk of human ingestion of PCB and heavy metals, 
including arsenic, chromium, copper, lead, and zinc, in contaminated 
fish, which can cause health problems including cancer, liver disease, 
and problems with the immune and endocrine systems. There is a fish 
advisory in place, signs are posted in the area warning against fish 
consumption, and, for the last several years, there has been ongoing 
removal of sediment and soil contaminated with PCB and heavy metals. 
However, according to EPA, exposure to PCB may continue even after a 
significant amount of PCB is removed from the river, because it takes 
several years for PCB levels in fish to decline, and people continue 
to consume fish from the area. According to EPA headquarters 
officials, approximately one-third of the sites with unacceptable 
human exposure have been identified as such because of ongoing 
consumption of contaminated fish despite actions having been taken to 
prevent exposure. Appendix III contains a detailed description of the 
risks present at the 75 sites. 

Most Sites with Unknown Risks of Human Exposure Require Considerable 
Work to Complete Remedial Construction: 

Like the sites with unacceptable human exposure, over 60 percent, or 
105, of the 164 sites with unknown human exposure have all or most of 
the work to complete remedial construction remaining, according to EPA 
regional officials' responses to our survey (see figure 5). The 
majority of the 83 sites with unknown human exposure that have all of 
the work remaining to complete construction are in the remedial 
investigation phase, which is when EPA usually determines a site's 
human exposure status, according to EPA guidance. EPA may also 
designate a site as having unknown human exposure during the 
construction phase of work, or after a site has met the construction 
complete milestone, if new information suggests that there may be risk 
at the site, or if an investigation is under way to assess a potential 
exposure pathway not previously analyzed, such as vapor intrusion. For 
example, the Waite Park Wells site in Minnesota reached construction 
complete status in 1999 but, during a review of the continuing 
effectiveness of the remedy performed in 2005, EPA found potential 
exposure from vapor intrusion to businesses from trichloroethylene 
(TCE) in groundwater.[Footnote 16] EPA Region 5 officials told us that 
EPA designated this site as having an unknown risk of human exposure 
until it evaluates a vapor intrusion assessment conducted by 
responsible parties. EPA expects to determine whether there is 
unacceptable human exposure at most of the 164 sites by fiscal year 
2012. 

Figure 5: Amount of Work Remaining to Complete Construction at the 164 
Nonfederal NPL Sites with Unknown Risks of Human Exposure: 

[Refer to PDF for image: pie-chart] 

All work remains: 83 (51%); 
More than half the work remains: 22 (14%); 
About half the work remains: 13 (8%); 
Less than half the work remains: 12 (7%); 
No work remains: 32 (20%). 

Source: GAO analysis of EPA regional officials’ responses to our 
survey. 

Note: Two sites are not included in the figure because EPA officials 
indicated that they did not know how much work remained to complete 
remedial construction. 

[End of figure] 

According to EPA regional officials' responses to our survey, human 
exposure risks at the 164 sites may be posed by a variety of 
contaminants in various media, including soil, sediment, and fish. 
Beginning around 2003, EPA regions began performing investigations for 
vapor intrusion, which they saw as an emerging problem, according to 
EPA officials. Currently, according to EPA regional officials' 
responses to our survey, 60 of the 164 sites may pose risks because of 
vapor intrusion. At the Lusher Street Groundwater Contamination site 
in Indiana, for example, EPA has not yet evaluated the vapor intrusion 
pathway, but officials said that they know the site could pose a vapor 
intrusion risk to human health because a contaminated groundwater 
plume is present in a mixed residential and industrial area. 

Some Sites Have Not Been Funded at the Most Time and Cost Efficient 
Levels, According to EPA Officials: 

From the inception of the Superfund program through the end of fiscal 
year 2009, EPA expended a total of $3 billion in constant 2009 dollars 
on the 75 sites with unacceptable exposure;[Footnote 17] however, in 
managing limited resources, EPA regional officials noted that some of 
these sites did not receive funding to clean up the sites in the most 
time and cost efficient manner. According to EPA regional officials' 
responses to our survey, the estimated cost of completing construction 
at 36 of the 75 sites with unacceptable exposure at which EPA is 
funding remedial actions will be about $3.9 billion.[Footnote 18] EPA 
regional officials said that they could not provide cost estimates for 
an additional 7 sites because the sites are too early in the cleanup 
phase. For the remaining 32 sites, these officials do not expect EPA 
to incur remedial construction costs because they expect responsible 
parties to fully fund the remedial actions at 26 sites, have 
identified 4 sites as construction complete, and EPA has already fully 
funded the remedial actions with Recovery Act funds at 2 sites. In 
addition, EPA expended $1.2 billion in constant 2009 dollars on the 
164 sites where exposure is unknown. At 48 of the 164 sites with 
unknown human exposure, EPA regional officials estimated that the cost 
to complete construction will be about $601 million. These officials 
were not able to provide cost estimates for an additional 32 sites 
because the sites are too early in the cleanup phase. For the 
remaining 84 sites, these officials do not expect EPA to incur 
remedial construction costs because they expect responsible parties to 
fully fund the remedial actions at 52 sites and have identified 32 
sites as construction complete. 

Even though EPA officials noted that EPA does not use the human 
exposure indicator to determine risk or to prioritize sites for 
cleanup, average annual per-site expenditures for sites with 
unacceptable exposure have been considerably higher than for sites 
with unknown exposure or for sites where EPA has determined that human 
exposure is under control. For example, in fiscal year 2009, the 
average per-site expenditure for sites with unacceptable human 
exposure was $3.0 million, compared with $0.5 million for sites with 
unknown exposure and $0.2 million for sites where EPA has determined 
that human exposure is under control. Furthermore, this difference has 
been increasing over time, as shown in figure 6. One reason that 
average per-site expenditures are higher for sites with unacceptable 
human exposure than for other sites is that a larger percentage of 
these sites are megasites--sites with actual or expected total cleanup 
costs, including removal and remedial action costs, that are expected 
to amount to $50 million or more.[Footnote 19] While 47 percent of the 
sites with unacceptable human exposure are megasites, 13 percent of 
sites with unknown human exposure are megasites, and 8 percent of 
sites where human exposure is controlled are megasites. 

Figure 6: Average Per-Site EPA Expenditures, Fiscal Years 1990 through 
2009: 

[Refer to PDF for image: multiple line graph] 

Constant 2009 dollars in millions: 

Fiscal year: 1990; 
Average per-site expenditures for sites with unacceptable human 
exposure: $0.84; 
Average per-site expenditures for sites with unknown human exposure: 
$0.74; 
Average per-site expenditures for sites with human exposure under 
control: $0.58. 

Fiscal year: 1991; 
Average per-site expenditures for sites with unacceptable human 
exposure: $0.90; 
Average per-site expenditures for sites with unknown human exposure: 
$0.56; 
Average per-site expenditures for sites with human exposure under 
control: $0.71. 

Fiscal year: 1992; 
Average per-site expenditures for sites with unacceptable human 
exposure: $1.37; 
Average per-site expenditures for sites with unknown human exposure: 
$0.60; 
Average per-site expenditures for sites with human exposure under 
control: $0.69. 

Fiscal year: 1993; 
Average per-site expenditures for sites with unacceptable human 
exposure: $1.14; 
Average per-site expenditures for sites with unknown human exposure: 
$0.63; 
Average per-site expenditures for sites with human exposure under 
control: $0.64. 

Fiscal year: 1994; 
Average per-site expenditures for sites with unacceptable human 
exposure: $1.41; 
Average per-site expenditures for sites with unknown human exposure: 
$0.61; 
Average per-site expenditures for sites with human exposure under 
control: $0.67. 

Fiscal year: 1995; 
Average per-site expenditures for sites with unacceptable human 
exposure: $1.89; 
Average per-site expenditures for sites with unknown human exposure: 
$0.60; 
Average per-site expenditures for sites with human exposure under 
control: $0.63. 

Fiscal year: 1996; 
Average per-site expenditures for sites with unacceptable human 
exposure: $2.64; 
Average per-site expenditures for sites with unknown human exposure: 
$0.31; 
Average per-site expenditures for sites with human exposure under 
control: $0.55. 

Fiscal year: 1997; 
Average per-site expenditures for sites with unacceptable human 
exposure: $2.28; 
Average per-site expenditures for sites with unknown human exposure: 
$0.35; 
Average per-site expenditures for sites with human exposure under 
control: $0.43. 

Fiscal year: 1998; 
Average per-site expenditures for sites with unacceptable human 
exposure: $2.40; 
Average per-site expenditures for sites with unknown human exposure: 
$0.49; 
Average per-site expenditures for sites with human exposure under 
control: $0.43. 

Fiscal year: 1999; 
Average per-site expenditures for sites with unacceptable human 
exposure: $2.40; 
Average per-site expenditures for sites with unknown human exposure: 
$0.41; 
Average per-site expenditures for sites with human exposure under 
control: $0.56. 

Fiscal year: 2000; 
Average per-site expenditures for sites with unacceptable human 
exposure: $2.71; 
Average per-site expenditures for sites with unknown human exposure: 
$0.60; 
Average per-site expenditures for sites with human exposure under 
control: $0.46. 

Fiscal year: 2001; 
Average per-site expenditures for sites with unacceptable human 
exposure: $2.84; 
Average per-site expenditures for sites with unknown human exposure: 
$0.58; 
Average per-site expenditures for sites with human exposure under 
control: $0.36. 

Fiscal year: 2002; 
Average per-site expenditures for sites with unacceptable human 
exposure: $2.46; 
Average per-site expenditures for sites with unknown human exposure: 
$0.56; 
Average per-site expenditures for sites with human exposure under 
control: $0.33. 

Fiscal year: 2003; 
Average per-site expenditures for sites with unacceptable human 
exposure: $2.58; 
Average per-site expenditures for sites with unknown human exposure: 
$0.50; 
Average per-site expenditures for sites with human exposure under 
control: $0.36. 

Fiscal year: 2004; 
Average per-site expenditures for sites with unacceptable human 
exposure: $2.76; 
Average per-site expenditures for sites with unknown human exposure: 
$0.50; 
Average per-site expenditures for sites with human exposure under 
control: $0.34. 

Fiscal year: 2005; 
Average per-site expenditures for sites with unacceptable human 
exposure: $2.67; 
Average per-site expenditures for sites with unknown human exposure: 
$0.34; 
Average per-site expenditures for sites with human exposure under 
control: $0.29. 

Fiscal year: 2006; 
Average per-site expenditures for sites with unacceptable human 
exposure: $3.06; 
Average per-site expenditures for sites with unknown human exposure: 
$0.33; 
Average per-site expenditures for sites with human exposure under 
control: $0.24. 

Fiscal year: 2007; 
Average per-site expenditures for sites with unacceptable human 
exposure: $3.00; 
Average per-site expenditures for sites with unknown human exposure: 
$0.40; 
Average per-site expenditures for sites with human exposure under 
control: $0.22. 

Fiscal year: 2008; 
Average per-site expenditures for sites with unacceptable human 
exposure: $2.54; 
Average per-site expenditures for sites with unknown human exposure: 
$0.51; 
Average per-site expenditures for sites with human exposure under 
control: $0.16. 

Fiscal year: 2009; 
Average per-site expenditures for sites with unacceptable human 
exposure: $3.04; 
Average per-site expenditures for sites with unknown human exposure: 
$0.53; 
Average per-site expenditures for sites with human exposure under 
control: $0.26. 

Source: GAO analysis of EPA data. 

Note: These data exclude reimbursable and homeland security 
supplemental resources, but these data include Recovery Act resources. 
EPA provided these data in nominal dollars, and we used inflation 
adjusters to modify the data to fiscal year 2009 dollars. 

[End of figure] 

Despite the relatively high level of expenditures at sites with 
unacceptable human exposure, EPA regional and headquarters officials 
told us that construction has not been conducted in the most time and 
cost efficient manner at some of these sites because EPA had to 
balance annual resources among various program activities. For 
example, EPA officials told us that at the Bunker Hill Mining site in 
Idaho--where people can be exposed to metals in soil and sediments and 
where children's blood lead levels have been found to be above Centers 
for Disease Control and Prevention levels of concern--the pace of the 
cleanup had to be slowed down because of preconstruction and remedial 
action funding limitations. The site received between $13 million and 
$19 million per year from fiscal years 2003 to 2009, when, according 
to an EPA regional official, it could have used $30 million per year 
to clean up the site and control human exposure in the most efficient 
manner. Similarly, at the Eureka Mills site in Utah, people who are in 
contact with soil and dust contaminated with lead from mining 
activities face human health risks. From 2003 to 2008, the site 
received $6.6 million to $10 million a year for construction, even 
though regional officials said that an additional $3 to $5 million per 
year would have allowed them to complete construction at the site 3 to 
4 years earlier at a reduced overall cost. However, with the addition 
of $26.5 million for the Eureka Mills site in fiscal year 2009 from 
Recovery Act funding, officials said that they will be able to 
complete construction at least 1 year earlier than planned and control 
human exposure at the site. In response to our survey, EPA regional 
officials noted that they are using Recovery Act funding to partially 
or completely control the unacceptable human exposure at 20 NPL sites. 
However, despite EPA's use of Recovery Act funds to control human 
exposure at these sites, EPA officials noted that EPA's constrained 
funding had delayed the control of human exposure at some sites. 

EPA's Costs for Conducting Remedial Construction at Nonfederal NPL 
Sites Will Likely Exceed Recent Funding Levels for These Activities: 

EPA's annual costs for conducting remedial construction at nonfederal 
NPL sites that are not yet construction complete from fiscal years 
2010 through 2014--as estimated by EPA regional officials--exceed 
recent annual funding allocations for these activities. In addition, 
these estimates do not include costs for all remedial actions at all 
sites or costs for sites that have a responsible party who is 
currently funding remedial actions but may be unable to do so in the 
future. Furthermore, according to EPA officials, experience has shown 
that EPA's actual costs are almost always higher than its cost 
estimates. 

Estimated Costs for Conducting Future Remedial Actions Exceed Past 
Funding Levels: 

EPA's annual costs to conduct remedial construction in the most 
efficient manner at nonfederal NPL sites for fiscal years 2010 through 
2014 may range from $335 million to $681 million, according to EPA 
regional officials' estimates (see table 1).[Footnote 20] These 
estimates include EPA's costs to conduct remedial actions at 142 of 
the 416 nonfederal sites that are not construction complete. Of the 
remaining 274 sites, EPA regional officials were unable to provide 
cost estimates for 57 sites, expect responsible parties to fully fund 
remedial actions at 206 sites, and do not expect to incur additional 
costs to complete construction at 11 sites because these sites are 
already fully funded. 

Table 1: Table 1: EPA Regional Officials' Estimates of Costs to EPA to 
Conduct Remedial Construction in the Most Efficient Manner at 
Nonfederal Sites on the NPL, as of September 30, 2009: 

Dollars in millions: 

Fiscal year: 2010; 
Cost to conduct remedial construction: $412. 

Fiscal year: 2011; 
Cost to conduct remedial construction: $681. 

Fiscal year: 2012; 
Cost to conduct remedial construction: $520. 

Fiscal year: 2013; 
Cost to conduct remedial construction: $420. 

Fiscal year: 2014; 
Cost to conduct remedial construction: $335. 

Fiscal year: 2015 and beyond; 
Cost to conduct remedial construction: $3,036. 

Source: GAO analysis of EPA regional officials' responses to our 
survey. 

Note: These data include EPA's cost estimates for 142 of the 416 
nonfederal sites that are not construction complete. For the remaining 
274 sites, EPA was unable to provide annual cost estimates for 57 
sites, EPA indicated that responsible parties are fully funding 
remedial actions at 206 sites, and EPA does not expect to incur 
additional costs to complete construction at 11 sites. Unless 
otherwise specified, these numbers are as reported by EPA, and are not 
adjusted for inflation by GAO. 

[End of table] 

These annual cost estimates for remedial construction at these sites 
exceed past annual funding allocations for such actions. For example, 
EPA regional officials' cost estimates for remedial construction for 
the next 2 years--fiscal years 2011 to 2012--are $253 million to $414 
million greater than the $267 million in annual funding that EPA 
allocated for remedial actions in fiscal year 2009. From fiscal years 
2000 to 2009, EPA allocated $220 million to $267 million in annual 
funding for remedial actions. According to EPA headquarters officials, 
however, funds from additional sources--such as prior year funds, 
settlements with responsible parties, and state cost share agreements-
-may also be available to fund remedial construction from year to 
year. While the amount of funding available through these sources may 
vary substantially from year to year, according to EPA headquarters 
officials, approximately $123 to $199 million was available from 
additional sources for remedial actions in fiscal years 2007 to 2009. 
Our analysis indicates that, even if this level of funding was 
available in future years, it would not supplement EPA's annual 
funding allocation enough to cover the estimated costs for conducting 
remedial construction in fiscal years 2011 and 2012. Therefore, 
despite funding from additional sources, EPA's estimated costs to 
conduct remedial construction will exceed available funds if funding 
for remedial construction remains constant. 

Cost Estimates Are Likely Understated: 

EPA regional officials' cost estimates are likely understated. These 
officials were not able to provide annual construction cost estimates 
for 57 of the 416 nonfederal sites that are not yet construction 
complete because they are in the early stages of the remedial process, 
and EPA does not yet know the extent of the contamination and/or has 
not chosen a cleanup remedy for them.[Footnote 21] For example, EPA 
Region 9 officials said that, as of October 2009, the feasibility 
study for the Alark Hard Chrome site in California was just beginning 
and that no cost estimates were available for possible remedies. For 
some additional sites, EPA regional officials were unable to provide 
cost estimates for construction at some of the operable units at the 
site. For example, EPA Region 3 officials were able to provide a 
partial cost estimate for the Crossley Farm site in Pennsylvania and 
noted that this estimate did not include additional remedial 
construction funding that will be necessary for operable units that 
have construction work remaining. Finally, EPA regional officials' 
estimates did not include costs for conducting long-term response 
actions--such as operating groundwater treatment facilities--that are 
considered part of the remedial action or for performing 5-year site 
reviews, both of which EPA funds from its remedial action allocation 
and which would, therefore, increase the cost estimate for remedial 
actions. 

EPA's estimates also do not include construction costs for sites that 
currently have a potentially responsible party that may be unable to 
fund the cleanup. EPA officials told us that EPA has identified one or 
more potentially responsible parties at 206 of the 416 nonfederal NPL 
sites that are not yet construction complete. However, officials also 
said that they were slightly or not at all confident that a 
responsible party would fund future remedial actions at 27 of these 
sites. For example, EPA officials explained that the responsible 
parties at one site in EPA Region 4 entered into bankruptcy and that 
EPA is not at all confident that the responsible parties will be able 
to fund future remedial actions. While in some cases funds from a 
settlement agreement may be available for site cleanup,[Footnote 22] 
in several instances, EPA officials reported that responsible parties 
may be financially unable to perform the remedy or fund future 
cleanup. Without responsible parties to fund remediation costs at 
these sites, EPA is likely to bear the costs of future remedial 
actions. 

EPA headquarters and regional officials also told us that EPA's actual 
costs for construction are typically higher than its cost estimates 
because of a number of uncertainties they may encounter. Most 
importantly, according to EPA officials, the extent of contamination 
at a site may be greater than EPA expected when it developed the cost 
estimate, which can expand the scope of work and remedies needed and 
increase overall construction costs. For example, we recently reported 
that at the Federal Creosote Superfund site in New Jersey, the greater-
than-expected quantities of contaminated material contributed to a 
$111 million increase in construction costs over EPA's estimates. 
[Footnote 23] According to EPA officials, it is common for EPA to 
remove more soil than originally estimated at Superfund sites because 
of the uncertainty inherent in using soil samples to estimate the 
extent of underground contamination. Another factor that can increase 
construction costs is change in acceptable contaminant levels. For 
example, at the Arsenic Trioxide site in North Dakota, additional 
cleanup was necessary after the site had already been deleted from the 
NPL because EPA subsequently reduced the maximum contaminant level for 
arsenic in drinking water, which had the effect of changing the level 
at which the cleanup was considered protective of public health. In 
addition, according to an EPA official, the actual costs of goods and 
services--such as energy, construction materials, and labor--may 
increase above estimated prices, causing an increase in the actual 
construction cost. At the Escambia Woods site in Florida, for example, 
inclement weather, identification of additional contamination, and 
other unforeseen occurrences all contributed to increased cleanup 
costs of about $2.2 million. EPA officials noted that there may be 
some instances when construction costs are overestimated because, for 
example, there is less contamination at a site than previously thought 
or the prices of goods and services decrease; however, the officials 
commented that this is rare. 

Because of the many uncertainties in cost estimating, EPA officials 
told us that actual construction costs never equal the cost estimated 
in the ROD. According to EPA guidance, because of the inherent 
uncertainty in estimating the extent of site contamination from early 
investigation data, cost estimates prepared during the remedial 
investigation/feasibility phase are based on a conceptual rather than 
detailed idea of the remedial action under consideration. The guidance 
states that these estimates are, therefore, intended to provide 
sufficient information for EPA to compare alternatives on an "order of 
magnitude" basis, rather than an exact estimate of a particular 
remedy's costs. According to EPA headquarters officials, these 
estimates could vary by 100 percent from the actual costs of 
implementing a remedy. As EPA's estimates become more refined during 
the remedial design phase, estimates that vary from actual costs by 
100 percent are not common; however, variation by 20 to 40 percent is 
common, according to EPA headquarters officials. The frequent 
occurrence of additional unexpected costs further enhances the 
likelihood that EPA's costs for remedial actions over the next several 
years will exceed recent funding levels for these activities, and EPA 
may be forced to choose between funding construction at some sites in 
the most efficient manner or funding construction at more sites less 
efficiently. 

EPA Allocates Remedial Program Funding Separately for Preconstruction 
Activities and Remedial Actions, and Limited Funding Has Caused Delays 
at Some Sites: 

EPA headquarters allocates funds to the regions for preconstruction 
activities--remedial investigations, feasibility studies, and remedial 
design activities--which the regions then distribute among sites. For 
remedial action funding, headquarters works with the regions to 
allocate funds to sites. According to EPA headquarters and regional 
officials, the funds for both types of activities have not been 
sufficient to clean up some sites in the most time and cost efficient 
manner. 

EPA Headquarters Allocates Funding to the Regions for Preconstruction 
Activities for Distribution Among Sites and, in Consultation with the 
Regions, Allocates Remedial Action Funding on a Site-by-Site Basis: 

EPA headquarters determines the amount of resources that the Superfund 
program will allocate to the regions for preconstruction activities by 
using a model that distributes available funding based on a 
combination of historical allocations and a work-based scoring system 
that scores each region based on projects planned for the upcoming 
year.[Footnote 24] Regions then prioritize sites to receive funding 
for preconstruction activities primarily by considering the human 
exposure risks present at sites while, at the same time, attempting to 
provide some funding for all their sites to keep them progressing 
toward the construction phase, according to EPA regional officials. 
According to EPA's Superfund Program Implementation Manual, at the 
initiation of the planning process, headquarters provides general 
projections of funding for preconstruction activities that will be 
available to the regions. On the basis of these projections, each 
region then develops a plan for allocating these funds to sites. 
Before finalizing this plan, each region holds planning discussions 
with headquarters to discuss actions that can be accomplished during 
the year and alters its plans, as needed, based on refined projections 
of available funding from headquarters. 

To allocate funding for remedial actions, EPA headquarters, in 
consultation with the regions, determines funding priorities on a site-
by-site basis. EPA's Superfund Program Implementation Manual states 
that sites with ongoing construction receive priority for funding over 
new construction work. Headquarters develops the initial plan for 
ongoing construction based on regional funding requests, projections 
of available funding, and discussions with regional officials. As part 
of these discussions, EPA headquarters and regional officials 
determine whether and how to incrementally fund remedial actions, 
according to EPA headquarters officials. According to an EPA 
headquarters official, headquarters' goal in allocating funds is to 
ensure that all sites with ongoing construction continue to progress 
toward construction completion while also funding some new 
construction projects. EPA officials explained that demobilizing and 
remobilizing equipment and infrastructure at a site once construction 
has begun is costly and an inefficient use of resources. Therefore, if 
EPA cannot fully fund ongoing construction at a site, the agency 
attempts to fund the site at a level that maintains at least a minimal 
level of construction to avoid demobilizing equipment and 
infrastructure. In addition, EPA headquarters works with the regions 
to adjust the amount of funding provided to sites throughout the year 
as cleanup circumstances change. 

For new construction, EPA's National Risk-Based Priority Panel-- 
comprising EPA regional and headquarters program experts--evaluates 
the risk with respect to human health and the environment to establish 
funding priorities for all new construction projects in the remedial 
program. To evaluate sites, the panel uses five criteria and 
associated weighting factors to compare projects. These criteria are 
the extent of risks to the exposed human population; contaminant 
stability; contaminant characteristics; threat to a significant 
environment; and program management considerations, such as state 
involvement and high-profile projects. Using the priority ranking 
process ensures that funding decisions for new projects are based on 
the use of common evaluation criteria that emphasize risk to human 
health and the environment. 

In addition to annual funding, EPA's Superfund program received $600 
million in Recovery Act funds in fiscal year 2009 and allocated $582 
million for remedial cleanup activities. EPA officials explained that 
EPA prioritized these Recovery Act funds in a manner similar to that 
for annual remedial action funding, with funds targeted first toward 
sites with ongoing construction and then toward new projects that were 
construction-ready. According to EPA officials, when identifying sites 
to receive Recovery Act funding, EPA also considered additional 
factors, such as the jobs that could be created. However, EPA 
officials noted that identifying the number of jobs created was 
difficult and that the criteria in the Office of Management and 
Budget's initial guidance for disbursing Recovery Act funds were not 
clear on how to calculate the number of jobs created. Therefore, EPA 
officials said that they used the ability to spend funds quickly as a 
surrogate for creating and retaining jobs when prioritizing sites to 
receive Recovery Act funds. Furthermore, EPA officials noted that it 
is difficult to quantify the number of jobs created because, while 
contractors involved in site remediation reported data on jobs 
created, subcontractors did not. 

EPA ultimately chose 51 sites to receive Recovery Act funding. 
According to EPA, 25 of these sites received funding for ongoing 
construction, 24 received funding for new construction, and 2 received 
funding for both ongoing and new construction. EPA officials reported 
that the use of Recovery Act funding will decrease the overall cleanup 
costs at some sites and accelerate the pace of cleanup at a majority 
of the sites receiving this funding. At the Gilt Edge Mine site in 
South Dakota, for example, EPA officials noted that construction for a 
portion of the cleanup project should be completed 1 year ahead of 
schedule because EPA allocated $3.5 million in Recovery Act funds to 
the site. Appendix IV provides additional details about sites that 
received Recovery Act funding. 

Limited Funding Has Delayed Preconstruction Activities and Remedial 
Actions at Some Sites and Can Impact State Cleanup Programs: 

EPA officials from several regions told us that their regions 
currently receive about half or less than half of the funding they 
could use for preconstruction activities. For example, Region 2 
officials said that their region currently receives about half the 
preconstruction funding it could use and that officials try to be 
flexible and creative in using the funding the region does receive to 
conduct work in the most efficient manner possible. Several EPA 
officials noted that limited funding available for preconstruction 
activities not only extends the length of time it takes to prepare a 
site for construction, but it can ultimately increase the overall 
costs for cleaning up the site as well. According to our survey, which 
collected data on fiscal years 2000 through 2009, most regions have 
sites that have experienced delays in the preconstruction phase 
because of insufficient funding. For example, officials in Region 3 
noted that the Jackson Ceramics site located in Pennsylvania was 
delayed in fiscal year 2005 because, when prioritizing sites to 
receive funding for preconstruction activities, the Jackson Ceramics 
site was considered lower risk compared with other sites in the region 
and, therefore, received no funds. Instead, Region 3 funded other 
sites that posed a higher risk or were farther along in the 
preconstruction phase. In addition, Region 10 did not fully fund 
preconstruction activities at the Bunker Hill Mining site in Idaho 
from fiscal year 2003 to fiscal year 2009--which extended work 
schedules and stopped some design work--because of a lack of funding 
for preconstruction activities. Region 10 officials explained that the 
region reduced funding for preconstruction activities at this site so 
that the region could allocate funding across more sites in the region. 

As previously discussed for sites with unacceptable human exposure, 
sites with ongoing construction have experienced delays caused by 
limited funding, according to EPA officials. Since fiscal year 2000, 
most regions have experienced delays because of insufficient funding 
at one or more sites with ongoing construction, according to responses 
to our survey. For example, the Oronogo-Duenweg Mining Belt site in 
Missouri received $10 million a year in fiscal years 2008 and 2009 
instead of the $15 million that regional officials said they could 
have used to clean up the site in the most efficient manner. These 
officials reported that the limited funding has delayed the completion 
of the remedial action and resulted in significant cost increases. In 
addition, the New Bedford Harbor site in Massachusetts has received 
$15 million per year instead of the $50 to $80 million per year that a 
regional official said the region could use to complete construction 
in the most efficient manner. According to several EPA regional 
officials, delays in funding for sites with ongoing construction 
increase the length of time it takes to clean up a site; the total 
cost of cleanup; and, in some cases, the length of time populations 
are exposed to contaminants. 

In addition, funding limitations have caused delays at sites that were 
ready to begin new construction. According to EPA Superfund 
Accomplishment Reports, between fiscal years 2004 and 2008, 54 sites, 
or over one-third of all sites ready for new construction funding, 
were not funded in the year that they were ready to begin 
construction, and some sites were not funded for several years after 
they were construction-ready. For example, in Region 4, funding 
limitations caused a 2-year delay at the Sigmon's Septic Tank Service 
site in North Carolina--a site with potential exposure risks to 
residents and trespassers from contaminated soil--even though it was 
ready to begin construction in October 2007. EPA allocated Recovery 
Act funding to this site in September 2009, which allowed EPA to 
remove the contaminated soil, eliminating the threat of direct contact 
to nearby residents and trespassers at the site. According to EPA 
headquarters officials, 25 sites needing new construction funding in 
fiscal year 2009 would most likely not have received funding had 
Recovery Act funding not been available. A representative from the 
Association of State and Territorial Solid Waste Management Officials 
pointed to the Superfund program's ability to quickly absorb about 
$582 million in Recovery Act funds as evidence of limited funding for 
construction activities. 

Limited funding can also impact state cleanup programs, which 
sometimes take the lead in cleaning up seriously contaminated sites 
that are not listed on the NPL, according to EPA and state officials. 
A study conducted by the Association of State and Territorial Solid 
Waste Management Officials found that funding for prelisting 
activities offers benefits beyond the Superfund program by providing 
valuable data, such as the data obtained during prelisting site 
assessments and investigations, which help state cleanup programs 
remediate sites that are not listed on the NPL. Several state 
officials said that, because their states have received less funding 
from EPA for these investigations than in the past, the number of 
assessments they have been able to perform has been limited. 

Most EPA Regional and Selected State Officials Expect an Increase in 
the Number of Sites Added to the NPL over the Next 5 Years but Cannot 
Estimate the Cleanup Costs: 

Most of the EPA regional officials and state officials we interviewed 
told us they expect the number of sites listed on the NPL over the 
next 5 years will be greater than the number listed in the past 5 
years. However, neither EPA regional officials nor state officials 
were able to provide cost estimates for many of the sites they expect 
will be added to the NPL. 

EPA and State Officials Expect an Increase in the Number of Sites 
Listed over the Next 5 Years: 

EPA regional officials estimate that from 101 to 125 sites--an average 
of 20 to 25 sites per year--will be added to the NPL over the next 5 
years. This is higher than the 79 sites--an average of about 16 sites 
per year--added from fiscal years 2005 to 2009. Overall, our analysis 
of these estimates shows that listings could increase by 28 to 58 
percent. As table 2 shows, all EPA regions expect that the number of 
sites added to the NPL over the next 5 years from their region could 
increase. According to EPA headquarters officials, the number of sites 
proposed for listing over time has decreased as a result of the 
expanded use of other cleanup programs, including state programs. Most 
of the officials who expect an increase in listings noted that current 
economic conditions--which can limit states' abilities to clean up 
sites under their own programs and responsible parties' abilities to 
pay for cleanup--are a contributing factor to the expected increase in 
listed sites. 

Table 2: Comparison of the Number of Sites EPA Listed from Fiscal 
Years 2005 through 2009 and the Number of Sites Projected to Be Listed 
from Fiscal Years 2010 through 2014, by Region: 

EPA region: 1; 
Number of sites EPA listed from fiscal year 2005 through fiscal year 
2009: 3; 
Number of sites EPA regional officials project will be added to the 
NPL over the next 5 years: 3 to 5; 
Change in the number of sites listed: 0 to +2. 

EPA region: 2; 
Number of sites EPA listed from fiscal year 2005 through fiscal year 
2009: 12; 
Number of sites EPA regional officials project will be added to the 
NPL over the next 5 years: 15 to 20; 
Change in the number of sites listed: +3 to 8. 

EPA region: 3; 
Number of sites EPA listed from fiscal year 2005 through fiscal year 
2009: 8; 
Number of sites EPA regional officials project will be added to the 
NPL over the next 5 years: 10 to 15; 
Change in the number of sites listed: +2 to 7. 

EPA region: 4; 
Number of sites EPA listed from fiscal year 2005 through fiscal year 
2009: 14; 
Number of sites EPA regional officials project will be added to the 
NPL over the next 5 years: 20 to 25; 
Change in the number of sites listed: +6 to 11. 

EPA region: 5; 
Number of sites EPA listed from fiscal year 2005 through fiscal year 
2009: 14; 
Number of sites EPA regional officials project will be added to the 
NPL over the next 5 years: 20; 
Change in the number of sites listed: +6. 

EPA region: 6; 
Number of sites EPA listed from fiscal year 2005 through fiscal year 
2009: 9; 
Number of sites EPA regional officials project will be added to the 
NPL over the next 5 years: 10 to 15; 
Change in the number of sites listed: +1 to 6. 

EPA region: 7; 
Number of sites EPA listed from fiscal year 2005 through fiscal year 
2009: 8; 
Number of sites EPA regional officials project will be added to the 
NPL over the next 5 years: 10; 
Change in the number of sites listed: +2. 

EPA region: 8; 
Number of sites EPA listed from fiscal year 2005 through fiscal year 
2009: 4; 
Number of sites EPA regional officials project will be added to the 
NPL over the next 5 years: 5; 
Change in the number of sites listed: +1. 

EPA region: 9; 
Number of sites EPA listed from fiscal year 2005 through fiscal year 
2009: 4; 
Number of sites EPA regional officials project will be added to the 
NPL over the next 5 years: 3 to 5; 
Change in the number of sites listed: -1 to +1. 

EPA region: 10; 
Number of sites EPA listed from fiscal year 2005 through fiscal year 
2009: 3; 
Number of sites EPA regional officials project will be added to the 
NPL over the next 5 years: 5; 
Change in the number of sites listed: +2. 

EPA region: All regions; 
Number of sites EPA listed from fiscal year 2005 through fiscal year 
2009: 79; 
Number of sites EPA regional officials project will be added to the 
NPL over the next 5 years: 101 to 125; 
Change in the number of sites listed: +22 to 46. 

Sources: GAO analysis based upon EPA data and regional officials' 
projections. 

[End of table] 

Most of the officials we spoke with in the 10 selected states also 
expect that the number of sites listed from their states over the next 
5 years could increase above the number of sites listed over the past 
5 years, as table 3 shows. For example, officials from the Michigan 
Department of Natural Resources and Environment said that they expect 
EPA to list five sites from Michigan to the NPL over the next 5 years, 
even though no sites have been listed from their state since 1996. 
These officials noted that the Superfund program has traditionally 
been a program of last resort, but declining resources in their 
state's cleanup program have renewed Michigan's interest in cleaning 
sites up through the federal program. Similarly, while EPA did not 
list any sites from Maine over the past 5 years, officials from the 
Maine Department of Environmental Protection expect that one to two 
sites may be added to the NPL over the next 5 years. An official 
explained that potential bankruptcies by responsible parties at one 
site may require that the state seek assistance in cleaning up the 
site through the federal Superfund program. 

Table 3: Comparison of the Number of Sites EPA Listed from Each of the 
10 States from Fiscal Years 2005 through 2009 and the Number of Sites 
State Officials Project May Be Listed from Fiscal Years 2010 through 
2014, by State: 

State: Maine; 
Number of sites EPA listed from fiscal year 2005 through fiscal year 
2009: 0; 
Number of sites state officials project will be added from their 
states to the NPL over the next 5 years: 1 to 2; 
Change in the number of sites listed: +1 to 2. 

State: New Jersey; 
Number of sites EPA listed from fiscal year 2005 through fiscal year 
2009: 6; 
Number of sites state officials project will be added from their 
states to the NPL over the next 5 years: 15 to 25; 
Change in the number of sites listed: +9 to 19. 

State: Virginia; 
Number of sites EPA listed from fiscal year 2005 through fiscal year 
2009: 1; 
Number of sites state officials project will be added from their 
states to the NPL over the next 5 years: 1; 
Change in the number of sites listed: 0. 

State: Kentucky; 
Number of sites EPA listed from fiscal year 2005 through fiscal year 
2009: 0; 
Number of sites state officials project will be added from their 
states to the NPL over the next 5 years: 0 to 1; 
Change in the number of sites listed: 0 to +1. 

State: Michigan; 
Number of sites EPA listed from fiscal year 2005 through fiscal year 
2009: 0; 
Number of sites state officials project will be added from their 
states to the NPL over the next 5 years: 5; 
Change in the number of sites listed: +5. 

State: Louisiana; 
Number of sites EPA listed from fiscal year 2005 through fiscal year 
2009: 0; 
Number of sites state officials project will be added from their 
states to the NPL over the next 5 years: 1; 
Change in the number of sites listed: +1. 

State: Iowa; 
Number of sites EPA listed from fiscal year 2005 through fiscal year 
2009: 0; 
Number of sites state officials project will be added from their 
states to the NPL over the next 5 years: 0; 
Change in the number of sites listed: 0. 

State: Montana; 
Number of sites EPA listed from fiscal year 2005 through fiscal year 
2009: 1; 
Number of sites state officials project will be added from their 
states to the NPL over the next 5 years: 1 to 2; 
Change in the number of sites listed: 0 to +1. 

State: California; 
Number of sites EPA listed from fiscal year 2005 through fiscal year 
2009: 3; 
Number of sites state officials project will be added from their 
states to the NPL over the next 5 years: 5; 
Change in the number of sites listed: +2. 

State: Washington; 
Number of sites EPA listed from fiscal year 2005 through fiscal year 
2009: 2; 
Number of sites state officials project will be added from their 
states to the NPL over the next 5 years: 1 to 4; 
Change in the number of sites listed: -1 to +2. 

Sources: GAO analysis based upon EPA data and state agency officials' 
projections. 

[End of table] 

EPA and state officials noted that the number of sites actually listed 
over the next 5 years could vary from their projections because of a 
number of uncertainties. For example, all the EPA regional officials 
we spoke with told us that economic conditions can affect the number 
of sites added to the NPL, and several of these officials told us that 
the number of sites listed from their region could increase above 
their projection if economic conditions do not improve. Many EPA 
regional officials noted that sites currently being cleaned up under 
state programs and by responsible parties may require assistance 
through the federal Superfund program if these groups face financial 
hardship, such as bankruptcy. In addition, some EPA and state 
officials identified EPA's policy for obtaining state concurrence for 
listing as a factor that could limit the number of sites added to the 
NPL if EPA is unable to obtain this concurrence. Officials from 
several EPA regions noted that particular states are resistant to 
listing because of financial or political concerns, and a few EPA 
regional officials and state officials mentioned difficulty in 
obtaining state concurrence for some sites.[Footnote 25] 

In addition to the number of sites that could be listed, the number of 
sites eligible for the NPL could increase if EPA begins to assess, as 
a part of its listing process, the risk of vapor intrusion caused by 
subsurface hazardous substances that have migrated via the air into 
homes and commercial properties. Although sites with vapor intrusion 
can pose considerable human health risks, EPA's HRS--the mechanism 
used to identify sites that qualify for NPL listing--does not 
currently recognize these risks; therefore, unless a site with vapor 
intrusion is listed on some other basis--such as groundwater 
contamination, EPA cannot clean up the site using remedial program 
funding. Many EPA regional officials and state officials noted that 
vapor intrusion is a concern, and several of these officials told us 
that they believe additional sites would be eligible for listing if 
assessments of vapor intrusion are included as part of the listing 
process. According to an EPA headquarters official, based on recent 
discussions with regional officials, up to 37 sites could be eligible 
for NPL listing if EPA includes vapor intrusion assessments as part of 
the listing process. However, according to EPA headquarters officials, 
EPA must first determine whether or not it can consider the vapor 
intrusion pathway under its existing HRS regulations, and it has not 
yet made such a determination. While these sites are not currently 
eligible for NPL listing, the EPA headquarters official noted that EPA 
is addressing vapor intrusion at 13 of these sites through its 
Superfund removal program; however, this official also told us that, 
when conducting removal actions, EPA is limited in its ability to 
fully remediate the source of contamination. For example, according to 
an official from the Montana Department of Environmental Quality, 
preliminary data collected at the Billings PCE site--which the 
official noted is not eligible for NPL listing--indicated vapor 
intrusion in buildings, and EPA conducted a removal action at this 
site. However, according to this official, it is unclear whether the 
removal action was effective in mitigating the vapor intrusion 
contamination, and people may continue to be exposed. In addition, 
this official noted that Montana has many sites with vapor intrusion 
from contaminants such as chlorinated solvents, which can cause 
cancer. If EPA cannot list these sites on the NPL on another basis, 
EPA will not be able to fund remedial actions at these sites, and 
continued exposure to carcinogens is possible if other cleanup 
programs do not remove the risks at these sites. 

In November 2002, EPA issued draft guidance on evaluating vapor 
intrusion at NPL sites.[Footnote 26] However, a December 2009 EPA 
Inspector General's report found that EPA had not updated this 
guidance to reflect current science and recommended that EPA issue 
final guidance to establish current agency policy on the evaluation 
and mitigation of vapor intrusion risks.[Footnote 27] EPA headquarters 
officials told us that, in response to this report, EPA is beginning 
discussions to update the vapor intrusion guidance. 

EPA and State Officials Could Not Provide Cost Estimates for Many of 
the Sites They Expect Will Be Added to the NPL over the Next 5 Years: 

Neither EPA regional officials nor state officials we contacted were 
able to provide cost estimates for many of the sites they expect to be 
added to the NPL over the next 5 years. Furthermore, when these 
officials were able to provide cost estimates, most of them were 
imprecise figures based on limited knowledge and best professional 
judgment. For example, while New Jersey officials expect 15 to 25 
sites to be added to the NPL from their state over the next 5 years, 
these officials noted that most of these sites are not expected to be 
megasites and the average cost of cleaning up most of the sites will 
probably be around $10 to $25 million. Officials also explained that 
they could not provide cost estimates for some of the sites, because 
the type and extent of contamination is not yet known. In addition, 
some officials based their 5-year projection on past listings and have 
not identified the actual sites that may be listed. For example, 
officials with the Virginia Department of Environmental Quality noted 
that one site in Virginia could be listed over the next 5 years, but 
the officials could not provide an estimated cost for cleaning up this 
site because it has not yet been identified. Therefore, it is 
impossible to accurately estimate what the cost may be to clean up 
these unknown sites. While EPA regional officials and state officials 
were not able to provide cost estimates for many of the sites they 
expect to be added to the NPL, we reported in July 2009 that the 
average amount EPA spent to clean up individual sites has increased in 
recent years.[Footnote 28] In that report, we found that individual 
site costs may have increased because the sites on the NPL now are 
more complex than in the past, construction costs have been rising, 
and EPA has not been able to identify as many responsible parties to 
fund site cleanups as in the past, leaving a higher share for EPA to 
fund. 

Conclusions: 

Congress enacted CERCLA to decrease the risk to human health and the 
environment posed by hazardous waste sites. However, some sites that 
EPA has identified as among the most seriously contaminated have 
involved long and costly cleanups, leading to protracted risks of 
human exposure to hazardous substances. Not long after the authority 
for the taxes that served as its main source of revenue expired in 
1995, the Superfund trust fund started to diminish. Further, 
appropriated funding for cleanups has declined over time in real 
dollars, and the limited funding has caused delays in cleaning up some 
sites in recent years. The limited funding, coupled with increasing 
costs of cleanup, has forced EPA to choose between cleaning up a 
greater number of sites in a less time and cost efficient manner or 
cleaning up fewer sites more efficiently. 

Compounding these challenges, EPA may not be listing some sites that 
pose health risks that are serious enough that the sites should be 
considered for inclusion on the NPL. While EPA is assessing vapor 
intrusion contamination at listed NPL sites, EPA does not assess the 
relative risks posed by vapor intrusion when deciding which sites to 
include on the NPL. By not including these risks, states may be left 
to remediate those sites without federal assistance, and given states' 
constrained budgets, some states may not have the ability to clean up 
these sites on their own. Ultimately, assessing the relative risk of 
vapor intrusion could lead to an increase in the number of sites 
listed on the NPL and thereby place additional demands on already 
limited funds in the Superfund program. However, if these sites are 
not assessed and, if needed, listed on the NPL, some seriously 
contaminated hazardous waste sites with unacceptable human exposure 
may not otherwise be cleaned up. 

Recommendation for Executive Action: 

To better identify sites that may be added to the NPL, we recommend 
that the Administrator of EPA determine the extent to which EPA will 
consider vapor intrusion as part of the NPL listing process and how 
this will affect the number of sites listed in the future. 

Agency Comments and Our Evaluation: 

We provided a draft copy of this report to EPA for review and comment. 
We received a written response from the Assistant Administrator for 
the Office of Solid Waste and Emergency Response that also included 
comments from EPA's Office of Enforcement and Compliance Assurance and 
Office of the Chief Financial Officer. EPA agreed with our 
recommendation and noted that, while the agency currently considers 
vapor intrusion impacts in both the remedial and removal programs, EPA 
is evaluating whether vapor intrusion needs to be more specifically 
addressed in the HRS model. EPA also noted that our report contains 
substantial useful information on very important subjects relating to 
the Superfund Program. 

In its comments, EPA also noted two issues that it believed require 
additional clarification. First, regarding its human exposure measure, 
EPA stated that it is important to highlight that people are not 
typically in danger of immediate harm at sites with unacceptable human 
exposure. EPA explained that, when acute health threats are 
identified, the agency takes immediate action to address the threats 
using its removal authority and, in other situations, works to 
characterize the risks at these sites. We agree with EPA and note in 
our report that EPA conducts removal actions at sites that pose 
immediate threats to human health or the environment. We also note 
that EPA has plans to control human exposure at all sites with 
unacceptable human exposure. EPA also commented that it does not use 
the term "unknown" when referring to sites that it has identified as 
having "insufficient data to determine human exposure control status." 
EPA noted that this term does not reflect EPA's efforts in 
characterizing a site to determine whether people are exposed at 
unsafe levels at a site. While we recognize that EPA may have 
collected and analyzed some data regarding a site's human exposure 
status, EPA's determination of insufficient data to determine human 
exposure control status shows that it has not yet made a determination 
about a site's status. For this reason--and for ease of reporting--in 
this report we refer to EPA's determination of "insufficient data to 
determine human exposure control status" as "unknown" human exposure. 

Second, EPA recognized our report's finding that regional cost 
estimates are likely understated, since the estimates do not include 
funding for sites where a responsible party is currently funding 
remedial construction but may be unable to do so in the future. While 
EPA does not dispute that the regional cost estimates are likely 
understated, EPA believes that we should recognize that, in cases 
where responsible parties are conducting remedial construction under 
existing settlement agreements, those agreements require those parties 
to maintain financial assurance mechanisms to ensure that response 
actions are completed. In addition, EPA noted that it has made 
considerable efforts to ensure that these mechanisms are in place for 
existing and new response settlements, and these financial assurances 
would provide funding for cleanup under existing settlements. EPA also 
acknowledged, however, that for sites where potentially responsible 
parties are experiencing financial difficulty and have not yet reached 
a settlement with EPA, the parties may be unable to complete cleanups 
in the future, which would increase the burden on EPA's Superfund 
trust fund. We agree with EPA's assessment; however, in response to 
our survey, EPA regional officials told us that they were slightly or 
not at all confident that a responsible party would fund future 
remedial actions at 27 sites. We also state in our report that funds 
from a settlement agreement may be available for site cleanup at some 
sites, but regional officials told us that responsible parties may be 
financially unable to perform the remedy or fund future cleanup at 
other sites and, in those situations, EPA's trust fund may have to 
fund future cleanup. EPA's comments are presented in appendix V of 
this report. EPA also provided technical comments on the draft report, 
which we incorporated, as appropriate. 

As agreed with your offices, 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, Administrator of EPA, Director 
of the Office of Management and Budget, and other interested parties. 
The report also will be available at no charge on the GAO Web site 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 stephensonj@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 VI. 

Signed by: 

John B. Stephenson: 
Director, Natural Resources and Environment: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

This appendix provides information on the scope of work and the 
methodology used to determine (1) the cleanup and funding status at 
currently listed nonfederal National Priorities List (NPL) sites with 
unacceptable or unknown human exposure; (2) what is known about the 
future costs to the Environmental Protection Agency (EPA) to complete 
remedial actions at nonfederal NPL sites that are not construction 
complete; (3) the process EPA uses to allocate remedial program 
funding; and (4) how many sites EPA and selected state officials 
expect will be added to the NPL over the next 5 years, and what they 
expect the future costs of cleaning up those sites will be. 

To determine the cleanup and funding status at the 75 sites with 
unacceptable human exposure and the 164 sites with unknown human 
exposure, we surveyed branch chiefs from each of the 10 EPA regions 
and received responses from October 2009 through November 2009. 
Through our survey, we obtained and analyzed information from each of 
the regions on the cleanup work that remains, human exposure risks, 
short-term planned actions to reduce exposure, long-term actions 
needed to eliminate exposure, expected time until human exposure risks 
will be under control or known, future estimated costs of remedial 
actions, whether American Recovery and Reinvestment Act (Recovery Act) 
funding will be used to control human exposure, delays due to 
constrained funding, and the impact of any limited funding at these 
sites. In addition, we obtained some limited documentation to support 
regional officials' cost estimates provided in the survey. We also 
analyzed data from EPA's Comprehensive Environmental Response, 
Compensation, and Liability Information System (CERCLIS) to determine 
when sites were listed, what cleanup actions have been taken at sites, 
which sites are construction complete, and which sites are megasites. 
We analyzed expenditure (outlay) data from EPA's Integrated Financial 
Management System for all final and deleted nonfederal NPL sites to 
determine how much EPA has spent on these sites. Moreover, to obtain 
additional information on human exposure risks, we searched EPA's 
Superfund Site Information System. We analyzed data on exposure risks 
from our survey and the Superfund Site Information System to determine 
the types of contaminants present, the types of contaminated media 
present, and the exposed populations at the sites. We also discussed 
the human exposure indicator with EPA headquarters and regional 
officials and reviewed EPA guidance on this indicator. 

To determine what is known about future costs to EPA to complete 
remedial actions at nonfederal NPL sites, we collected data through 
our survey of all EPA regions to obtain information about the 416 
nonfederal sites that are not construction complete. Through our 
survey, we obtained and analyzed data on annual and total estimated 
costs to EPA to conduct remedial actions in the most efficient manner, 
the entity responsible for funding cleanup, and EPA's confidence in 
responsible parties' ability to fund future remedial actions. In 
addition, we obtained information on total funding amounts that EPA 
provided for remedial actions for fiscal years 2000 to 2009 from EPA's 
Office of Solid Waste and Environmental Response. Finally, we 
discussed the cost estimating process with EPA headquarters and 
regional officials and reviewed EPA's guidance on cost estimating. 

To determine how EPA allocates remedial program funding, we 
interviewed EPA headquarters officials and regional officials from 
each of the 10 EPA regions about the process they use to prioritize 
sites to receive funding. We also discussed the process EPA used to 
allocate Recovery Act funding for the Superfund program with 
headquarters officials. Additionally, we reviewed EPA guidance and 
planning documents to identify the process for assigning annual and 
Recovery Act funding. In addition, through our survey, we obtained and 
analyzed information from each of the 10 EPA regions on the 51 sites 
receiving Recovery Act funding to determine how much funding each site 
received and whether the use of the funding is decreasing costs of 
cleanup and/or accelerating cleanup. We also obtained data through our 
survey on delays at sites with ongoing construction. Moreover, to 
identify sites that were delayed when ready to begin construction, we 
reviewed Superfund Accomplishment Reports from 2004 through 2008. In 
addition, we spoke with representatives from the Association of State 
and Territorial Solid Waste Management Officials to obtain their 
perspectives on delays in cleanup. 

To determine how many sites EPA officials expect will be added to the 
NPL over the next 5 years and what they expect the cost of cleaning up 
those sites to be, we conducted semistructured telephone interviews of 
NPL coordinators in each EPA region. In addition, through these 
interviews, we obtained information about factors that have affected 
the number of listings in the past and factors that may affect the 
number of listings in the future. We also interviewed EPA headquarters 
officials to obtain their perspectives on future listings and factors--
including vapor intrusion--that may affect listings. Finally, to 
compare the projected numbers of future listings with past listings, 
we analyzed data from EPA's CERCLIS database on sites that have been 
listed to the NPL from each region. 

To determine how many sites selected state officials expect will be 
added to the NPL over the next 5 years and what they expect the cost 
of cleaning up those sites to be, we interviewed state hazardous waste 
agency officials from 10 states: California, Iowa, Kentucky, 
Louisiana, Maine, Michigan, Montana, New Jersey, Virginia, and 
Washington. We selected these states using a nonprobability sample, 
consisting of one state from each of EPA's 10 regions and selected to 
ensure that we would obtain information from states that vary in the 
total number of sites listed over the past 10 years. We conducted 
telephone interviews with officials from each of these states to 
obtain information about potential site listings from their state, the 
costs to clean up those sites, and factors that may affect the number 
of sites actually listed over the next 5 years. We also discussed the 
site assessment process, listing process, and potential future 
listings with an official from the Association of State and 
Territorial Solid Waste Management Officials. Finally, we compared the 
projected numbers of future listings with past listings by analyzing 
data from EPA's CERCLIS database on sites that have been listed to the 
NPL from each of the 10 states. 

To assess the reliability of the data from EPA's databases used in 
this report, we analyzed related documentation, examined the data to 
identify obvious errors or inconsistencies, and worked with agency 
officials to identify data problems. To ensure the reliability of the 
data collected through our survey of the 10 EPA regions, we took a 
number of steps to reduce measurement error, nonresponse error, and 
respondent bias. These steps included conducting three pretests prior 
to distributing the survey to ensure that our questions were clear, 
precise, and consistently interpreted; reviewing responses to identify 
obvious errors or inconsistencies; and conducting follow-up interviews 
with officials to review and clarify responses. We determined the data 
to be sufficiently reliable for the purposes of this report. 

We conducted this performance audit from March 2009 to May 2010, 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: GAO Survey of Superfund Sites: 

We surveyed regional officials from EPA's 10 regions using all of the 
questions below as stated here. We provided these questions to the 
regions in an Excel spreadsheet that identified the sites pertaining 
to each question. We have grouped the questions below to list all 
questions that pertain to a particular universe of sites. 

A. The following questions pertained to nonfederal NPL sites that were 
not construction complete, as of September 30, 2009. 

1. Who is currently leading remedial actions at this site? If the site 
has not yet had a remedial action, who is anticipated to lead remedial 
actions at this site? 

a. Potentially Responsible Party(s):
b. EPA (Fund-lead):
c. State:
d. Federal Facility:
e. Mixed (Potentially Responsible Party & Fund-lead):
f. Mixed (Potentially Responsible Party & State):
g. Mixed (Potentially Responsible Party & Federal): 

2. How confident are you that a viable Potentially Responsible 
Party(s) will fund future remedial actions at this site? 

a. Very confident:
b. Moderately confident:
c. Slightly confident:
d. Not at all confident/No viable Potentially Responsible Party(s):
e. Don't know: 

3. What is the projected fiscal year the site will be construction 
complete? 

a. FY 2009; 
b. FY 2010; 
c. FY 2011; 
d. FY 2012; 
e. FY 2013; 
f. FY 2014; 
g. FY 2015; 
h. FY 2016; 
i. FY 2017; 
j. FY 2018; 
k. FY 2019; 
l. FY 2020; 
m. FY 2021; 
n. FY 2022; 
o. FY 2023; 
p. After FY 2023. 

4. Given what is currently known about contamination at this site, how 
much work remains to complete construction? 

a. No work remains:
b. Less than half the work remains:
c. About half the work remains:
d. More than half the work remains:
e. All work remains:
f. Unknown: 

5. Given what is currently known about contamination at this site, 
what is the approximate projected cost to EPA to complete construction 
in the most efficient manner? (in millions of dollars) If there is no 
cost to EPA because a Potentially Responsible Party is funding ALL 
remedial actions at a site, please check the box for No Cost to EPA. 

No Cost to EPA: 
FY 2010: 
FY 2011: 
FY 2012: 
FY 2013: 
FY 2014: 
FY 2015 and beyond: 
Total Projected Cost: 

6. What information are you using to make these cost projections? 

7. If you cannot provide cost projections for one or more years, 
please explain why they are not available. 

8. Is a Long Term Remedial Action planned at this site? If yes, please 
provide the estimated total cost to EPA of the LTRA (in millions). 

B. The following questions pertained to nonfederal NPL sites with 
unacceptable human exposure, as of September 30, 2009. 

1. In what fiscal year did EPA determine that there was an 
unacceptable risk of human exposure at this site? 

a. Prior to FY 1999; 
b. FY 1999; 
c. FY 2000; 
d. FY 2001; 
e. FY 2002; 
f. FY 2003; 
g. FY 2004; 
h. FY 2005; 
i. FY 2006; 
j. FY 2007; 
k. FY 2008; 
l. FY 2009; 
m. Unknown. 

2. In what fiscal year do you expect human exposure to be controlled 
at this site? 

a. FY 2009: 
b. FY 2010; 
c. FY 2011; 
d. FY 2012; 
e. FY 2013; 
f. FY 2013; 
g. FY 2013; 
h. After FY 2015.
i. Unknown. 

3. Please provide a description of the actual or potential for human 
exposure. For each site, please describe the actual or potential for 
current human exposure, including the physical setting, populations 
affected, exposure pathways, contaminants, and health risks, if known. 

4. What are EPA or other parties doing in the short-term to contain 
the risk of exposure or the actual human exposure? 

5. What will EPA or other parties do in the long-term to eliminate the 
risk of exposure or the actual human exposure? 

C. The following questions pertained to nonfederal NPL sites with 
unknown human exposure, as of September 30, 2009. 

1. In what fiscal year did EPA determine that there was insufficient 
data to assess if there was an unacceptable risk of human exposure at 
this site? 

a. Prior to FY 1999.
b. FY 1999; 
c. FY 2000; 
d. FY 2001; 
e. FY 2002; 
f. FY 2003; 
g. FY 2004; 
h. FY 2005; 
i. FY 2006; 
j. FY 2007; 
k. FY 2008; 
l. FY 2009; 
m. Unknown. 

2. In what fiscal year do you expect to know whether human exposure is 
under control at this site? 

a. FY 2009: 
b. FY 2010; 
c. FY 2011; 
d. FY 2012; 
e. FY 2013; 
f. FY 2013; 
g. FY 2013; 
h. After FY 2015.
i. Unknown. 

3. Why is there insufficient data to determine whether human exposure 
is under control? 

4. Please describe the potential for human exposure at this site. 

D. The following questions pertained to nonfederal NPL sites (1) with 
unacceptable human exposure, (2) with unknown human exposure, and/or 
(3) that were not construction complete, as of September 30, 2009. 

1. From FY 2000 to FY 2009, for which years, if any, were pipeline 
activities delayed at this site due to constrained funding? 

2. Did this site receive funding to begin construction in the fiscal 
year when it was ready? If not, for how many years did the site not 
receive construction funding? 

a. Yes - site received funding when construction ready:
b. No - construction delayed 1 year:
c. No - construction delayed 2 years:
d. No - construction delayed 3 years:
e. No - construction delayed 4 years:
f. No - construction delayed 5 years:
g. No - construction delayed more than 5 years:
h. N/A - Site has not reached construction phase:
i. N/A - Construction funded by Potentially Responsible Party(s): 

If cleanup was not funded when the site was construction-ready, please 
describe the impacts, if any, of the delay. 

3. From FY 2000 to FY 2009, for which years, if any, were ongoing 
remedial actions delayed at the site due to constrained funding? 

a. For years in which ongoing remedial actions were delayed, how much 
funding was needed to clean up the site in the most efficient manner? 
(in millions). 

b. For years in which ongoing remedial actions were delayed, how much 
funding was received? (in millions). 

c. Please explain the source of the funding numbers in your responses 
for parts (a) and (b). 

d. What was the impact, if any, of the delay in cleanup? 

e. Have delays increased the total cost of construction at this site? 
Please briefly explain your response. 

E. The following questions pertained to nonfederal NPL sites which EPA 
designated to receive Recovery Act funds. 

1. How much Recovery Act, or stimulus funding, has or will this site 
receive? Please respond in millions of dollars. 

2. Will stimulus funds be used at this site for (1) beginning new 
construction at a site with no previous remedial actions, (2) 
beginning new construction at an operable unit at a site with previous 
remedial actions, and/or (3) supporting ongoing remedial actions? 

3. Would construction have been delayed in the absence of this 
stimulus funding? Please choose an option below and briefly explain 
your response.
a. Yes:
b. No:
c. Unknown: 

4. Will stimulus funds accelerate the pace of construction? Please 
choose an option below and briefly explain your response.
a. Yes:
b. No:
c. Unknown: 

5. Will the stimulus funds decrease the total cost of construction at 
this site? Please choose an option below and briefly explain your 
response.
a. Yes:
b. No:
c. Unknown: 

6. Will the use of stimulus funding control human exposure at this 
site? Please choose an option below and briefly explain your response.
a. Yes, completely:
b. Yes, partially:
c. No:
d. Not applicable:
e. Unknown: 

7. Please describe your region's involvement, if any, in identifying 
sites to receive stimulus funding. 

[End of section] 

Appendix III: Sites with Unacceptable Human Exposure: 

As of the end of fiscal year 2009, EPA identified 75 nonfederal sites 
on the NPL as having unacceptable human exposure. The human exposure 
at these 75 sites is due to a variety of contaminants that may be 
present in soil, groundwater, sediments, or other media at the site 
and may impact areas where people live, work, and recreate. As figure 
7 shows, the most common medium of concern at sites with unacceptable 
human exposure is soil, with 42 sites containing this medium of 
concern. The next most common media are fish or shellfish, sediment, 
and groundwater. Many sites had more than one medium of concern. For 
example, the Caldwell Trucking Co. site in New Jersey has four media 
of concern: soil, groundwater, surface water, and indoor air. At this 
site, groundwater contaminated with solvents is seeping onto surface 
soils and discharging into surface-water streams in a residential 
area, and the solvents may have potentially migrated from groundwater 
to indoor air, posing a risk of vapor intrusion. 

Figure 7: Media of Concern at the 75 Sites with Unacceptable Human 
Exposure: 

[Refer to PDF for image: vertical bar graph] 

Media of concern: Soil; 
Number of sites: 42. 

Media of concern: Fish; 
Number of sites: 28. 

Media of concern: Sediment; 
Number of sites: 15. 

Media of concern: Groundwater; 
Number of sites: 14. 

Media of concern: Surface water; 
Number of sites: 11. 

Media of concern: Dust; 
Number of sites: 9. 

Media of concern: Indoor air; 
Number of sites: 6. 

Source: GAO analysis of EPA regional officials' responses to our 
survey. 

Note: Sites with more than one medium of concern were counted in each 
applicable category. In addition to the categories above, there are 
other media of concern which were less common, including mine waste, 
debris, and plants. 

[End of figure] 

The contaminants that most commonly cause unacceptable human exposure 
are lead, polychlorinated biphenyl (PCB), arsenic, and metals other 
than lead. Some sites contained several contaminants, present in 
different media. For example, the Atlantic Wood Industries, Inc. site 
in Virginia contains polycyclic aromatic hydrocarbons (PAHs), 
pentachlorophenol (PCP), dioxins, and heavy metals present in soil and 
shellfish, as well as creosote present in sediments. As a result of 
the variety of contaminants and contaminated media, there are multiple 
risks at the site, including risks to (1) recreational users of the 
river who could come into direct contact with sediments contaminated 
with creosote, (2) consumers of large quantities of shellfish exposed 
to unacceptably high levels of contaminants, and (3) workers at the 
Atlantic Wood Industries concrete manufacturing business who are 
exposed to surface soils at the site. 

Residents of contaminated areas are the population most commonly 
exposed to unacceptable exposures at the 75 sites, with over half of 
the sites posing a contaminant risk to residents on or nearby the 
site, according to the data collected through our survey. In addition, 
contaminated waterways, including rivers, lakes, and harbors, pose 
unacceptable risks to those who consume contaminated fish caught from 
these areas. Risks to workers and other commercial tenants and those 
who recreate at contaminated sites are present at fewer sites. The 
exposed populations face different health risks based on the 
contaminants present at the site. For example, consuming PCB in fish 
may cause liver disease, problems with the immune and endocrine 
system, developmental problems, and cancer, while human health threats 
from arsenic include irritation of the stomach and intestines, blood 
vessel damage, reduced nerve function, and increased mortality rates 
in young adults. 

According to an EPA headquarters official responsible for overseeing 
the human exposure indicator, the indicator demonstrates a high 
potential for human exposure, but it does not always indicate that 
documented human exposure is occurring at a site. The official 
explained that it can be difficult to obtain evidence of actual human 
exposure; however, EPA has been able to document exposure at some 
sites. For example, the Big River Mine Tailings site contains lead- 
contaminated soils on residential properties, and blood tests have 
shown elevated lead levels in children. For some risks, however, such 
as consumption of contaminated fish, EPA may not have evidence of 
actual ingestion of contaminated fish but does have information 
suggesting that people are fishing in the area of concern. 

Table 4 provides a description of the human exposure risks at the 75 
sites, as well as the fiscal year that EPA estimates human exposure 
will be under control at those sites. 

Table 4: Description of Human Exposure Risks, Fiscal Year Site was 
Listed on the NPL, and the Expected Fiscal Year Human Exposure Will Be 
Controlled at NPL Sites with Unacceptable Human Exposure, as of the 
End of Fiscal Year 2009: 

State: CA; 
Site name: Lava Cap Mine; 
Description of human exposure risk: Recreational users of the area 
downstream of the mine (Lost Lake area) can be exposed to mine 
tailings, leading to incidental ingestion of arsenic in soil, 
inhalation of contaminated airborne particulates, or skin contact with 
contaminated sediments along the shoreline; 
Fiscal year site was listed on the NPL: 1999; 
Estimated fiscal year human exposure will be controlled: 2013. 

State: CA; 
Site name: McCormick & Baxter Creosoting Co; 
Description of human exposure risk: The potential for human exposure 
stems from the consumption of contaminated fish affected by 
contaminated sediments in the slough adjacent to the McCormick & 
Baxter property. The fishing population includes local recreational 
anglers and subsistence fishermen. Contaminants include dioxins and 
PAHs that entered the slough via runoff and seep from the site. The 
sediment remedy was completed in 2006 but it will take several years 
for fish tissue concentrations to decline to acceptable levels; 
Fiscal year site was listed on the NPL: 1993; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: CA; 
Site name: Modesto Groundwater Contamination; 
Description of human exposure risk: Humans are exposed to 
tetrachloroethylene (PCE) in indoor air in a building that houses two 
businesses: an operating dry cleaner and an auto parts dealership. Two 
sources of vapors are: (1) the operating dry cleaner and (2) subslab 
soil gas from historical leaks of PCE into soil and groundwater. EPA 
is primarily addressing indoor air risks to the auto parts dealer, 
since the dry cleaning business is subject to Occupational Safety and 
Health Administration regulations. EPA plans to install a subslab 
ventilation system in 2010 to address the vapor intrusion problem; 
Fiscal year site was listed on the NPL: 1989; 
Estimated fiscal year human exposure will be controlled: 2010. 

State: CA; 
Site name: Montrose Chemical Corp; 
Description of human exposure risk: Primarily Palos Verdes Shelf, 
operable unit 5, is the cause of the uncontrolled human exposure due 
to the potential for people to consume contaminated fish. EPA's 
institutional controls program is actively working to reduce this 
risk, but until the fish population is cleaner, it is not possible to 
completely control human exposure; 
Fiscal year site was listed on the NPL: 1990; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: CA; 
Site name: Omega Chemical Corp; 
Description of human exposure risk: Exposure occurs as a result of 
vapor intrusion at commercial buildings adjacent to the site. The 
initial vapor intrusion problem was identified in a public roller 
skating rink adjacent to the site (potential exposed population 
included children, adults and workers at the site); 
however, the skating rink has since been demolished. Office workers in 
two buildings adjacent to the site are the current exposed population. 
The primary contaminant of concern is PCE, for which current levels 
exceed long-term exposure criteria for industrial/commercial exposure. 
The installation of a soil vapor extraction system adjacent to the 
affected buildings in 2010 is expected to eliminate the vapor 
intrusion problem; 
Fiscal year site was listed on the NPL: 1999; 
Estimated fiscal year human exposure will be controlled: 2010. 

State: CA; 
Site name: Sulphur Bank Mercury Mine; 
Description of human exposure risk: Residents near the mine may be 
exposed to mine tailings or soils contaminated with mercury, arsenic, 
or antimony. In addition, residents and recreational users of Clear 
Lake may be exposed to fish and other biota contaminated with mercury, 
although fish advisories are in place, warning of the risks of eating 
fish; 
Fiscal year site was listed on the NPL: 1990; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: CA; 
Site name: United Heckathorn Co; 
Description of human exposure risk: The human health exposure is from 
subsistence fishing in the site area. The fishing and consumption 
pattern of the local Laotian communities is documented in "A Seafood 
Consumption Survey of the Laotian Community of West Contra Costa 
County, California" by Asian Pacific Environmental Network. The 
fishing pattern is catching all available fish and consuming whole 
fish. There is currently a state fish advisory for the area for 
certain fish species; 
Fiscal year site was listed on the NPL: 1990; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: CO; 
Site name: California Gulch; 
Description of human exposure risk: People can come in contact with 
historic mine waste. Mine waste is located across the site and is 
readily accessible to community members and recreational users. A 
potential exposure pathway exists for individuals interacting with 
mine waste or affected surface or groundwater. The site is composed of 
approximately 18 square miles of mountainous terrain. Historic mining, 
milling, and smelting activities resulted in the placement of mine 
wastes across the entire area. At the present time, warning signs are 
not posted in mine waste piles due to the large number of piles and 
community concerns associated with the signage. The primary 
contaminants of concern include lead and other metals; 
Fiscal year site was listed on the NPL: 1983; 
Estimated fiscal year human exposure will be controlled: 2013. 

State: CO; 
Site name: Central City, Clear Creek; 
Description of human exposure risk: Recreational users may come in 
contact with soil and water contaminated with heavy metals from 
historic mining activities. Contact with these source areas presents 
an unacceptable risk to recreational users and to ecological 
receptors. The Clear Creek watershed is a large area used widely by 
the community. The waste piles and the river are not posted due to the 
sprawling nature of the site; 
Fiscal year site was listed on the NPL: 1983; 
Estimated fiscal year human exposure will be controlled: 2013. 

State: CO; 
Site name: Standard Mine; 
Description of human exposure risk: The site is situated in a remote 
area outside of Crested Butte, CO. Recreational users, including 
hikers, snowmobile riders, and all-terrain vehicle riders, are known 
to visit the site throughout the year. This risk is primarily focused 
on children who ride all-terrain vehicles inhaling manganese dust at 
the site. EPA is currently studying the nature of contamination at the 
site and is developing a cleanup plan to address all human health 
risks; 
Fiscal year site was listed on the NPL: 2005; 
Estimated fiscal year human exposure will be controlled: 2013. 

State: CT; 
Site name: Raymark Industries, Inc; 
Description of human exposure risk: Unacceptable exposure pathways 
exist for individuals who come in contact with soil contaminated with 
lead, asbestos, PCBs, and other contaminants above acceptable levels 
at approximately 30 locations throughout the town of Stratford; 
Fiscal year site was listed on the NPL: 1995; 
Estimated fiscal year human exposure will be controlled: 2012. 

State: DE; 
Site name: Koppers Co., Inc. (Newport Plant); 
Description of human exposure risk: Trespassers come into contact with 
soils and sediments contaminated with creosote. Due to the presence of 
creosote nonaqueous phase liquid at the surface in both soils and 
sediments, there exists the potential for acute toxicity were a 
trespasser to be exposed to that material, as PAHs are a dermal 
irritant on contact; 
Fiscal year site was listed on the NPL: 1990; 
Estimated fiscal year human exposure will be controlled: 2013. 

State: ID; 
Site name: Bunker Hill Mining & Metallurgical Complex; 
Description of human exposure risk: The Bunker Hill Superfund site in 
northern Idaho and eastern Washington has been severely affected by 
more than 100 years of mining activities. Mining contamination has 
affected more than 166 river miles of the Coeur d'Alene River 
corridor, adjacent floodplains, downstream water bodies, tributaries, 
and fill areas. The risks are not hypothetical or potential future 
risks. Significant measurable risks currently exist to humans (e.g., 
children with blood lead levels above the national Centers for Disease 
Control and Prevention (CDC) standards). The contaminants are 
primarily metals, and the affected media are soil, sediment, surface 
water, and groundwater. Direct exposure to metals in soil and 
sediments is a source of risk for people, including recreational and 
subsistence users; 
Fiscal year site was listed on the NPL: 1983; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: IL; 
Site name: Kerr-McGee (Kress Creek/West Branch of DuPage River); 
Description of human exposure risk: The current unacceptable human 
exposure is from gamma radiation from thorium-contaminated soils and 
sediments in some areas of the bank of Kress Creek and the West Branch 
of the DuPage River. In some areas, there is residential property 
along the river bank with contamination above health-based limits. 
Studies on thorium workers have shown that breathing thorium dust may 
cause an increased chance of developing lung disease and cancer of the 
lung or pancreas many years after being exposed. Changes in the 
genetic material of body cells have also been shown to occur in 
workers who breathed thorium dust. Since thorium is radioactive and 
may be stored in bone for a long time, bone cancer is also a potential 
concern for people exposed to thorium. The presence of large amounts 
of thorium in one's environment could result in exposure to more 
hazardous radioactive decay products of thorium, such as radium and 
thoron, which is an isotope of radon; 
Fiscal year site was listed on the NPL: 1991; 
Estimated fiscal year human exposure will be controlled: 2013. 

State: IL; 
Site name: Ottawa Radiation Areas; 
Description of human exposure risk: The site includes 16 areas of 
concerns; 
some are adjacent to the original facility, and others are in the City 
of Ottawa where, in the past, site-contaminated materials were used as 
fill. Removal actions were completed at nine of the areas, and 
remedial actions were completed at two of the areas, but three of the 
five remaining areas are designated as "current human exposures not 
under control" because of potential exposure via direct contact, 
ingestion, and/or inhalation by trespassers, construction workers, 
and/or commercial/industrial workers to radium-contaminated soils. 
These three sites include a gravel parking lot, auto storage garage, 
and construction company. There is no clear evidence that long-term 
exposure to radium at the levels that are normally present in the 
environment (for example, 1 pico curie of radium per gram of soil) is 
likely to result in harmful health effects. However, exposure to 
higher levels of radium over a long period of time may result in 
harmful effects including anemia, cataracts, fractured teeth, cancer 
(especially bone cancer), and death. Some of these effects may take 
years to develop and are mostly due to gamma radiation. Radium gives 
off gamma radiation, which can travel fairly long distances through 
air. Therefore, just being near radium at the high levels that may be 
found at some hazardous waste sites may be dangerous to one's health; 
Fiscal year site was listed on the NPL: 1993; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: IL; 
Site name: Outboard Marine Corp; 
Description of human exposure risk: At Waukegan Harbor, the PCB levels 
in harbor-caught fish are too high to be protective of human health. 
EPA and others have observed both subsistence and sport fishing in the 
harbor area. The higher than recommended PCB levels in fish are caused 
by PCBs in the harbor sediment. People who eat PCB-contaminated fish 
can experience health problems, including cancer, liver disease, and 
problems with the immune and endocrine systems. During pregnancy and 
lactation, mothers can pass PCBs and other chemicals to their infants. 
Because these chemicals affect development, children through 
adolescence and women of childbearing age are more sensitive to their 
harmful effects and should be especially careful. At Outboard Marine 
Corp., Plant 2, the abandoned facility and some of the on-site soil, 
beach sand, and sediment are contaminated with PCBs above the levels 
recommended in the PCB spill cleanup policy. Although the grounds are 
generally secured by fencing and are sometimes patrolled by the City 
of Waukegan, there is ongoing evidence of trespassing and vandalism on 
the property; 
Fiscal year site was listed on the NPL: 1983; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: IL; 
Site name: Southeast Rockford Groundwater Contamination; 
Description of human exposure risk: Residents in the contaminated 
plume area are drawing drinking water from private wells contaminated 
with volatile organic compounds, such as trichloroethylene (TCE). 
Although the City of Rockford has provided municipal water service to 
hundreds of residents and businesses, there are still residents who 
will not voluntarily connect to the city water supply. EPA does not 
have any clear evidence that TCE alone in drinking water can cause 
leukemia or any other type of cancer in humans. However, in studies 
using high doses of TCE in rats and mice, tumors in the lungs, liver, 
and testes were found, providing some evidence that high doses of TCE 
can cause cancer in experimental animals. Based on the limited data in 
humans regarding TCE exposure and cancer, and evidence that high doses 
of TCE can cause cancer in animals, the International Agency for 
Research on Cancer has determined that TCE is probably carcinogenic to 
humans; 
Fiscal year site was listed on the NPL: 1989; 
Estimated fiscal year human exposure will be controlled: 2011. 

State: IN; 
Site name: Bennett Stone Quarry; 
Description of human exposure risk: PCBs are discharging from on-site 
springs into Stout's Creek, and recreational users of the creek can be 
exposed to unacceptable PCB levels due to direct contact with the 
surface water and/or through ingestion of fish. Although fish 
consumption advisories for Stout's Creek are in place by the State of 
Indiana, fishing has been observed in the creek. This is a rural 
community, and EPA believes the fish are being consumed. There is 
evidence of subsistence fishing from the river. People who eat PCB-
contaminated fish can experience health problems, including cancer, 
liver disease, and problems with the immune and endocrine systems. 
During pregnancy and lactation, mothers can pass PCBs and other 
chemicals to their infants. Because these chemicals affect 
development, children through adolescence and women of childbearing 
age are more sensitive to their harmful effects and should be 
especially careful; 
Fiscal year site was listed on the NPL: 1984; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: IN; 
Site name: Himco Dump; 
Description of human exposure risk: The current unacceptable human 
exposure is from direct contact (via showering and bathing) to arsenic 
and manganese in water from four private residential groundwater wells 
located east of the dump. This water is slightly above the acceptable 
risk range for direct contact exposure. Although low levels of 
manganese intake are necessary for human health, exposure to high 
manganese levels is toxic. Many reports indicate that oral exposure to 
manganese, especially from contaminated water sources, can produce 
significant health effects. These effects have been most prominently 
observed in children and are similar to those observed from inhalation 
exposure. The symptoms of manganese toxicity may appear slowly over 
months and years. Manganese toxicity can result in a permanent 
neurological disorder known as manganism with symptoms that include 
tremors, difficulty walking, and facial muscle spasms. These symptoms 
are often preceded by other lesser symptoms, including irritability, 
aggressiveness, and hallucinations. Some studies suggest that 
manganese inhalation can also result in adverse cognitive effects, 
including difficulty with concentration and memory problems. Human 
exposures to arsenic may cause irritation of the stomach and 
intestines, blood vessel damage, skin changes, and reduced nerve 
function. There is also some evidence that suggests that long-term 
exposure to inorganic arsenic in children may result in lower IQ 
scores. There is some evidence that exposure to arsenic in early life 
(including gestation and early childhood) may increase mortality in 
young adults and that inhaled or ingested inorganic arsenic can injure 
pregnant women or their unborn babies, although the studies are not 
definitive; 
Fiscal year site was listed on the NPL: 1990; 
Estimated fiscal year human exposure will be controlled: 2015. 

State: IN; 
Site name: Jacobsville Neighborhood Soil Contamination; 
Description of human exposure risk: The current unacceptable human 
exposure is from lead and arsenic in residential surface soils and 
soils at depth, greater than the site-specific, risk-based cleanup 
goals of 400 and 30 parts per million, respectively. There is a long- 
term threat to human health through direct contact to lead and arsenic 
contaminated soils. Human exposures to arsenic may cause irritation of 
the stomach and intestines, blood vessel damage, skin changes, and 
reduced nerve function. There is also some evidence that suggests that 
long-term exposure to inorganic arsenic in children may result in 
lower IQ scores. There is some evidence that exposure to arsenic in 
early life (including gestation and early childhood) may increase 
mortality in young adults. There is some evidence that inhaled or 
ingested inorganic arsenic can injure pregnant women or their unborn 
babies, although the studies are not definitive. An enormous amount of 
information is available on the health effects of lead on human 
health. The most sensitive targets for lead toxicity are the 
developing nervous system, the hematological and cardiovascular 
systems, and the kidneys. However, due to the multimodes of action of 
lead in biological systems, lead could potentially affect any system 
or organs in the body. Studies of lead workers suggest that long-term 
exposure to lead may be associated with increased mortality due to 
cerebrovascular disease. Blood lead levels also have been associated 
with small elevations in blood pressure; 
Fiscal year site was listed on the NPL: 2004; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: IN; 
Site name: Lemon Lane Landfill; 
Description of human exposure risk: There is a current unacceptable 
human exposure because PCBs are discharging from off-site springs into 
Clear Creek, and users of the creek can be exposed to unacceptable PCB 
levels through ingestion of fish. Fishing has been observed in the 
creek. This is a rural community, and EPA believes the fish are being 
consumed. People who eat PCB-contaminated fish can experience health 
problems, including cancer, liver disease, and problems with the 
immune and endocrine systems. During pregnancy and lactation, mothers 
can pass PCBs and other chemicals to their infants. Because these 
chemicals affect development, children through adolescence and women 
of childbearing age are more sensitive to their harmful effects and 
should be especially careful; 
Fiscal year site was listed on the NPL: 1983; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: IN; 
Site name: Neal's Landfill (Bloomington); 
Description of human exposure risk: There is a current unacceptable 
human exposure because PCBs are discharging from on-site springs into 
Conard's Branch and Richland Creek. Users of the creek can be exposed 
to unacceptable PCB levels through ingestion of fish. This is a rural 
community, and EPA believes the fish are being consumed. People who 
eat PCB-contaminated fish can experience health problems, including 
cancer, liver disease, and problems with the immune and endocrine 
systems. During pregnancy and lactation, mothers can pass PCBs and 
other chemicals to their infants. Because these chemicals affect 
development, children through adolescence and women of childbearing 
age are more sensitive to their harmful effects and should be 
especially careful; 
Fiscal year site was listed on the NPL: 1983; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: KS; 
Site name: Cherokee County; 
Description of human exposure risk: Human exposure is through contact 
with, or ingestion of, contaminated soil, groundwater, and surface 
water, in addition to consumption of affected fish and other 
receptors. The site is a large mining megasite that spans 115 square 
miles and has several million cubic yards of surficial mining wastes 
that have not been remediated. The site also contains affected 
sediments, surface water, and groundwater. The contaminants of concern 
are lead, cadmium, and zinc; 
Fiscal year site was listed on the NPL: 1983; 
Estimated fiscal year human exposure will be controlled: 2015. 

State: MA; 
Site name: Blackburn & Union Privileges; 
Description of human exposure risk: Residents at a residential lot 
near the site are reasonably anticipated to be exposed to lead and 
asbestos in soil in the floodplain of the Neponset River and the 
Former Mill Tailrace above acceptable levels. In addition, other 
nearby residents may come in contact with asbestos above acceptable 
levels in the sediment in Lewis Pond; 
Fiscal year site was listed on the NPL: 1994; 
Estimated fiscal year human exposure will be controlled: 2011. 

State: MA; 
Site name: Iron Horse Park; 
Description of human exposure risk: Exposure to lead contamination in 
surface soils in the rail yard area of the site presents a current 
unacceptable exposure. In addition, elevated blood lead levels are 
predicted for women of childbearing age based on occupational indoor 
exposures to dust from the outdoor lead-containing soil. Portions of 
the site that present unacceptable exposure pathways cannot be further 
controlled (by fencing, for example) prior to implementation of the 
remedy since the site contains an active rail yard; 
Fiscal year site was listed on the NPL: 1984; 
Estimated fiscal year human exposure will be controlled: 2011. 

State: MA; 
Site name: New Bedford; 
Description of human exposure risk: Unacceptable exposure pathways 
exist related to consumption of PCB-contaminated seafood. This Human 
Exposure Control determination is based on site-specific risk 
assessments that took the concentration of chemicals present and the 
frequency/duration of exposure to these chemicals, among other things, 
into account. EPA's full-scale dredging program began in 2004 and will 
continue for a number of years. Regarding the seafood consumption 
risk, signs are posted in multiple languages throughout the harbor 
describing the existing fishing ban. In addition, EPA has led an 
extensive outreach and education campaign called "Fish Smart." This 
campaign includes a wide variety of elements to dissuade the 
consumption of local PCB-contaminated seafood, including the education 
community, the medical community, social service providers, fact 
sheets, cable TV shows, newspaper notices, neighborhood meetings, and 
monthly meetings with stakeholders and local officials. However, EPA 
continues to receive reports that consumption of seafood from posted 
areas is ongoing; 
Fiscal year site was listed on the NPL: 1983; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: MI; 
Site name: Allied Paper, Inc./Portage Creek/Kalamazoo River; 
Description of human exposure risk: The Allied Paper, Inc./Portage 
Creek/Kalamazoo River site has fish in the river contaminated above 
health-based levels for human consumption due to PCB contamination. 
There is evidence of subsistence fishing from the river. People who 
eat PCB-contaminated fish can experience health problems, including 
cancer, liver disease, and problems with the immune and endocrine 
systems. During pregnancy and lactation, mothers can pass PCBs and 
other chemicals to their infants. Because these chemicals affect 
development, children through adolescence and women of childbearing 
age are more sensitive to their harmful effects and should be 
especially careful; 
Fiscal year site was listed on the NPL: 1990; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: MI; 
Site name: Velsicol Chemical Corp. (Michigan); 
Description of human exposure risk: Residents are likely in contact 
with soils contaminated with polybrominated biphenyls (PBB) in the 
residential area adjacent to the former chemical plant. PBB levels in 
the adjacent residential area show elevated risk and exceed the State 
of Michigan's promulgated standard for direct human contact for PBB, 
but not at levels which would require an emergency removal. The 
Velsicol site is also considered "current human exposures not under 
control" due to contaminants migrating from the site groundwater to 
the adjacent Pine River. The fish are contaminated with 
bioaccumulative compounds (dichlorodiphenyltrichloroethane and PBB) at 
levels that present a risk to humans from fish ingestion. Although 
fish consumption advisories are in place in the river by the State of 
Michigan, and warning signs are posted, fishing has been observed in 
the river, and EPA believes the fish are being consumed. In 1976, the 
Michigan Department of Public Health recruited many Velsicol workers 
for a PBB health study, which placed workers and their families in a 
registry to study the long-term effects of PBB exposure. The study, 
conducted in cooperation with the CDC, Food and Drug Administration, 
and EPA, was in operation at the time of the 1988 health assessment. 
Subsequent findings of this study included some evidence of an 
association between high PBB exposure with an elevated risk of cancers 
of the breast and the digestive system and of lymphomas. Because of 
the small number of cases, no definitive conclusions may be drawn from 
these findings. In addition, higher rates of neurologic, immunologic, 
dermatologic, and musculoskeletal health effects have also been 
observed in the registry cohort. However, no consistent pattern of an 
association between these health effects and serum PBB levels have 
been determined; 
Fiscal year site was listed on the NPL: 1983; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: MN; 
Site name: South Minneapolis Residential Soil Contamination; 
Description of human exposure risk: Residential soils are contaminated 
with high levels of arsenic originally believed to have come from a 
pesticide formulating plant. Human exposures to arsenic may cause 
irritation of the stomach and intestines, blood vessel damage, skin 
changes, and reduced nerve function. There is also some evidence that 
suggests that long-term exposure to inorganic arsenic in children may 
result in lower IQ scores. There is some evidence that exposure to 
arsenic in early life (including gestation and early childhood) may 
increase mortality in young adults. There is some evidence that 
inhaled or ingested inorganic arsenic can injure pregnant women or 
their unborn babies, although the studies are not definitive; 
Fiscal year site was listed on the NPL: 2007; 
Estimated fiscal year human exposure will be controlled: 2011. 

State: MO; 
Site name: Big River Mine Tailings/St. Joe Minerals Corp; 
Description of human exposure risk: The Big River Mine Tailings site 
consists of seven large lead mine waste piles in St. Francois County, 
Missouri. These piles have eroded into Big River and its tributaries. 
Lead-contaminated dust has blown from the piles to nearby residential 
areas. There is a risk of exposure to all age groups to lead in 
residential and recreational soils, surface water, sediment, and fish 
tissue; 
Fiscal year site was listed on the NPL: 1993; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: MO; 
Site name: Madison County Mines; 
Description of human exposure risk: Mine waste was used for fill and 
grading in residential settings where direct exposure is highly 
probable upon any disturbance of the soil. There are ongoing exposures 
to heavy metals. Surficial mine and mill waste is the source of the 
heavy metal contamination at the site, which has affected surface 
soil, sediment, surface water, groundwater, and fish tissue. The heavy 
metal of most urgent concern with regard to human health at the site 
is lead; 
Fiscal year site was listed on the NPL: 2003; 
Estimated fiscal year human exposure will be controlled: 2012. 

State: MO; 
Site name: Newton County Mine Tailings; 
Description of human exposure risk: People can be exposed to lead 
contamination through direct contact and ingestion of contaminated 
soil and dust. Uncontrolled mine waste piles containing high 
concentrations of lead and other heavy metals are located on 
approximately 1,000 acres of land throughout this county-wide site. 
These waste piles cause lead and other heavy metal contamination in 
surrounding soils, groundwater, and surface water resulting in 
potential exposure of people living on the site, drinking shallow 
groundwater, or recreating on the piles. EPA identified unacceptable 
levels of lead in the yard soil at approximately 300 residential 
properties in the site. The cleanup of those contaminated yards has 
been completed. However, many residences are located immediately 
adjacent to the uncontrolled mine waste piles. These piles are used 
for recreation by nearby residents including young children. The piles 
are also a continual source of contamination to nearby soil, including 
residential yards, and surface water through erosion and runoff; 
Fiscal year site was listed on the NPL: 2003; 
Estimated fiscal year human exposure will be controlled: 2014. 

State: MO; 
Site name: Oronogo-Duenweg Mining Belt; 
Description of human exposure risk: Uncontrolled mine waste piles 
containing high levels of lead, and other heavy metals, are located on 
approximately 7,000 acres of land throughout this county-wide site. 
These waste piles cause lead and other heavy metal contamination in 
surrounding soils, groundwater, and surface water resulting in 
potential exposure to people living in the site, drinking the shallow 
groundwater, or recreating on the waste piles. EPA identified 
unacceptable levels of lead in the yard soil at 2,700 residential 
properties in the site. The cleanup of those contaminated yards has 
been completed. Also, alternate sources of drinking water have been 
provided to homes with lead and cadmium-contaminated groundwater used 
as drinking water throughout the site. However, many residential 
properties are located immediately adjacent to lead contaminated mine 
waste piles. These piles are used for recreation by nearby residents 
including young children and are also a continual source of 
contamination to nearby soil and surface water through runoff. 
Significant development within the communities has also resulted in 
encroachment of new housing into contaminated mine areas with new 
homes being built very near mine waste piles; 
Fiscal year site was listed on the NPL: 1990; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: MO; 
Site name: Southwest Jefferson County Mining; 
Description of human exposure risk: Mine waste was used for fill and 
grading in residential settings where direct exposure is highly 
probable upon any disturbance of the soil. The lead contamination in 
soil exceeds health-based criteria in hundreds of residential 
properties. As of April 20, 2009, EPA has completed remediation of 
soil at 129 residences. Residential soil remediation is ongoing as an 
additional 294 properties have been identified with elevated lead 
contamination that will need to be addressed; 
Fiscal year site was listed on the NPL: 2009; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: MO; 
Site name: Washington County Lead District-Old Mines; 
Description of human exposure risk: The primary risk at the site is 
exposure to lead from contaminated soil and groundwater/drinking 
water. The setting is both small town and rural with numerous 
residential properties contaminated with lead in surface soil and/or 
private well water caused by historical mining activity. The site 
currently covers approximately 90 square miles; 
Fiscal year site was listed on the NPL: 2008; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: MO; 
Site name: Washington County Lead District-Potosi; 
Description of human exposure risk: The primary risk at the site is 
exposure to lead from contaminated soil and groundwater/drinking 
water. The setting is both small town and rural with numerous 
residential properties contaminated with lead in surface soil and/or 
private well water caused by historical mining activity. The site 
currently covers approximately 45 square miles; 
Fiscal year site was listed on the NPL: 2008; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: MO; 
Site name: Washington County Lead District-Richwoods; 
Description of human exposure risk: The primary risk at the site is 
exposure to lead from contaminated soil and groundwater/drinking 
water. The setting is both small town and rural with numerous 
residential properties contaminated with lead in surface soil and/or 
private well water caused by historical mining activity. The site 
currently covers approximately 45 square miles; 
Fiscal year site was listed on the NPL: 2008; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: MT; 
Site name: Libby Asbestos Site; 
Description of human exposure risk: Many areas of the site still need 
cleanup and present significant threats to public health. Vermiculite 
from the former Libby Mine contains a toxic form of naturally 
occurring amphibole asbestos. The site consists of 
residential/commercial properties in the towns of Libby and Troy, 
Montana, as well as the former vermiculite mine site. The former mine 
site is posted with warning signs. EPA has cleaned up over 1,000 
residential/commercial properties and major known source areas in the 
towns of Libby and Troy. Residential and commercial property cleanups 
will continue into the foreseeable future. EPA is working with the 
responsible party to determine the full nature and extent of 
contamination at and from the former mine site; 
Fiscal year site was listed on the NPL: 2003; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: MT; 
Site name: Upper Tenmile Creek Mining Area; 
Description of human exposure risk: People are likely to come into 
contact with arsenic, lead, and cadmium-contaminated soil and mining 
wastes in the community of Rimini and the Landmark subdivision, a 
small group of private homes approximately 10 miles from Rimini; 
Fiscal year site was listed on the NPL: 2000; 
Estimated fiscal year human exposure will be controlled: 2010. 

State: NC; 
Site name: Barber Orchard; 
Description of human exposure risk: There is uncontrolled access to 
contaminated soil at the site in a residential setting. The pathway of 
exposure is incidental ingestion of soil. Arsenic is the driving 
contaminant of concern--cancer and noncancer health risks exist; 
Fiscal year site was listed on the NPL: 2001; 
Estimated fiscal year human exposure will be controlled: 2013. 

State: NC; 
Site name: Ward Transformer; 
Description of human exposure risk: The source property is an 
industrial setting, but contaminants have migrated to wooded off-site 
areas including creeks and reservoirs. The site is in metro Raleigh, 
NC, which has a large population that is potentially affected via 
trespassing or fish ingestion. PCB is the contaminant of concern, 
posing a cancer health risk; 
Fiscal year site was listed on the NPL: 2003; 
Estimated fiscal year human exposure will be controlled: 2011. 

State: NE; 
Site name: Omaha Lead; 
Description of human exposure risk: Lead contamination in soil exceeds 
health-based cleanup criteria in hundreds of residential properties. 
As of December 2007, EPA has completed soil remediation at more than 
3,800 highly contaminated residential properties at the Omaha Lead 
site, and these actions are ongoing; 
Fiscal year site was listed on the NPL: 2003; 
Estimated fiscal year human exposure will be controlled: 2014. 

State: NH; 
Site name: Fletcher's Paint Works & Storage; 
Description of human exposure risk: Unacceptable current exposure 
exists from consumption of fish containing PCBs above acceptable 
levels from the Souhegan River; 
Fiscal year site was listed on the NPL: 1989; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: NJ; 
Site name: Caldwell Trucking Co; 
Description of human exposure risk: Contaminated groundwater continues 
to seep onto surface soils and discharge into surface water streams 
and into the Passaic River. Direct contact with the seep contamination 
is possible due to the location of the seep in a residential area. The 
contaminants of concern are volatile organic compounds, including TCE 
and 1,1,1 trichloroethane; 
Fiscal year site was listed on the NPL: 1983; 
Estimated fiscal year human exposure will be controlled: 2013. 

State: NJ; 
Site name: Martin Aaron, Inc; 
Description of human exposure risk: Soils are contaminated with 
arsenic and benzo[a]pyrene that pose a direct contact threat. Although 
the site is fenced, there is evidence of violation of temporary 
controls; 
Fiscal year site was listed on the NPL: 1999; 
Estimated fiscal year human exposure will be controlled: 2011. 

State: NJ; 
Site name: NL Industries; 
Description of human exposure risk: Recent sediment samples taken from 
a nearby stream, as part of the ongoing biological sampling 
requirements, showed that the lead levels exceeded the cleanup 
standard established for sediments and stream banks in a portion of 
the stream at this site; 
Fiscal year site was listed on the NPL: 1983; 
Estimated fiscal year human exposure will be controlled: 2010. 

State: NJ; 
Site name: Roebling Steel Co; 
Description of human exposure risk: Evidence shows repeated violations 
of temporary controls that have been established to prevent exposure 
to site-wide, contaminated soils. Soils are contaminated with elevated 
levels of heavy metals, including surficial lead at levels up to 
69,000 mg/kg, which well exceeds the health-based residential 
screening level of 400 mg/kg; 
Fiscal year site was listed on the NPL: 1983; 
Estimated fiscal year human exposure will be controlled: 2015. 

State: NJ; 
Site name: Universal Oil Products (Chemical Division); 
Description of human exposure risk: There is ongoing ingestion of fish 
and crabs from Berry's Creek and its tributaries. Fish tissue 
collected from these water bodies has been found to contain elevated 
levels of mercury; 
Fiscal year site was listed on the NPL: 1983; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: NJ; 
Site name: Ventron/Velsicol; 
Description of human exposure risk: There is ongoing ingestion of fish 
and crabs from Berry's Creek and its tributaries. Fish tissue 
collected from these water bodies has been found to contain elevated 
levels of mercury; 
Fiscal year site was listed on the NPL: 1984; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: NJ; 
Site name: Vineland Chemical Co., Inc; 
Description of human exposure risk: There is continuing direct contact 
exposure to arsenic-contaminated sediments and surface water in nearby 
wetlands and surface water bodies, as well as exposure to arsenic in 
fish. Key public areas have been posted with safety/security/public 
health signage while EPA collects additional data and works with the 
state on fish consumption advisories; 
Fiscal year site was listed on the NPL: 1984; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: NJ; 
Site name: Welsbach & General Gas Mantle (Camden Radiation); 
Description of human exposure risk: The cleanup of radiologically 
contaminated soil in residential neighborhoods is ongoing; 
Fiscal year site was listed on the NPL: 1996; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: NV; 
Site name: Carson River Mercury Site; 
Description of human exposure risk: People are likely consuming 
mercury contaminated fish. The Nevada Health Division advises that 
game fish and carp should not be consumed from most of the site. The 
Lahonton Reservoir, located roughly in the middle of the site, is one 
of Nevada's most popular sport fishing destinations. In 1998, a 
walleye caught in the Lahontan Reservoir had a record high mercury 
tissue concentration of 16 parts per million. Based on more recent 
sampling results, the state Health Officer issued a health advisory 
that fish from the Carson River from Dayton to the Lahontan Reservoir 
should not be consumed. At heavily used fishing locations in and 
around the reservoir, the state has posted warning signs that fish 
from the river and reservoir should not be consumed. Despite this new 
health advisory, in July 2007, two men were caught at the Lahonton 
Reservoir with 155 fish over the legal limit. This suggests that fish 
consumption from the Lahontan Reservoir is still continuing on an 
individual basis or through commercial sales; 
Fiscal year site was listed on the NPL: 1990; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: NY; 
Site name: Hudson River PCBs; 
Description of human exposure risk: There is ongoing ingestion of fish 
caught from the river. Fish tissue has been found to contain elevated 
levels of PCBs; 
Fiscal year site was listed on the NPL: 1984; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: NY; 
Site name: Onondaga Lake; 
Description of human exposure risk: There is ongoing ingestion of fish 
caught from the lake and its tributaries. Fish tissue has been found 
to contain elevated levels of mercury and PCBs, and New York State has 
issued fish consumption advisories; 
Fiscal year site was listed on the NPL: 1995; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: OH; 
Site name: Copley Square Plaza; 
Description of human exposure risk: The unacceptable human exposure is 
from vapor intrusion into the indoor air of residences adjacent to the 
site. The contaminants of concern are PCE and its degradation 
products. At high vapor concentrations, PCE is both a potent 
anesthetic agent and a cardiac epinephrine sensitizer; 
Fiscal year site was listed on the NPL: 2005; 
Estimated fiscal year human exposure will be controlled: 2011. 

State: OK; 
Site name: Tar Creek (Ottawa County); 
Description of human exposure risk: People may be exposed to lead in 
soils, chat piles, chat bases, and mill ponds. Tribal members live 
throughout the area and eat plants grown on, or animals feeding near, 
the contaminated areas, and some people continue to trespass and use 
the contaminated areas for recreational purposes. The contaminated 
area is vast, and it is not possible to prevent all access to the 
waste; 
Fiscal year site was listed on the NPL: 1983; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: OR; 
Site name: Portland Harbor; 
Description of human exposure risk: Portland Harbor includes 
approximately 11 river miles of the lower Willamette River located in 
the Portland metropolitan area (population over 1 million). The river 
is used extensively for transportation and recreation (i.e., boating 
and fishing) by area residents. Sediment contamination includes PCBs, 
dioxin, PAHs, metals, and pesticides. Exposure pathways include direct 
contact with beach and in-water sediment, as well as fish and 
shellfish consumption. Risks from consumption of resident fish are 
higher than other pathways, and the highest cancer and noncancer risk 
is associated with PCBs and dioxins; 
Fiscal year site was listed on the NPL: 2001; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: PA; 
Site name: Bally Groundwater Contamination; 
Description of human exposure risk: Chemicals in vapor form have been 
identified in indoor air at the industrial park, which is the source 
of contamination at the site. Indoor air samples revealed 
concentrations of TCE above acceptable limits; 
Fiscal year site was listed on the NPL: 1987; 
Estimated fiscal year human exposure will be controlled: 2010. 

State: PA; 
Site name: Crossley Farm; 
Description of human exposure risk: People may be exposed to TCE 
contaminated indoor air; 
Fiscal year site was listed on the NPL: 1993; 
Estimated fiscal year human exposure will be controlled: 2011. 

State: PA; 
Site name: Havertown PCP; 
Description of human exposure risk: A potential current human exposure 
threat exists for a residential area called the Recreation and Open 
Space area of the site. This area currently contains contaminated 
soils that are at or above cleanup action levels for PCP and dioxin. 
The contamination is located at the 4-to 8-foot below grade level; 
Fiscal year site was listed on the NPL: 1983; 
Estimated fiscal year human exposure will be controlled: 2010. 

State: PA; 
Site name: Price Battery; 
Description of human exposure risk: Lead contamination in soil and 
dust exceeds health-based cleanup criteria in residential yards and 
interiors; 
Fiscal year site was listed on the NPL: 2005; 
Estimated fiscal year human exposure will be controlled: 2013. 

State: PA; 
Site name: Salford Quarry; 
Description of human exposure risk: The site continues to impact 
groundwater and surface water with boron and volatile organic 
compounds, including TCE; 
Fiscal year site was listed on the NPL: 2009; 
Estimated fiscal year human exposure will be controlled: 2015. 

State: RI; 
Site name: Centredale Manor Restoration Project; 
Description of human exposure risk: Nearby residents and recreational 
users of the Woonasquatucket River are reasonably anticipated to be 
exposed to unacceptable levels of dioxin and other contaminants 
through contact with sediment in the river and floodplain. Ingestion 
of fish from the Woonasquatucket River also poses an unacceptable 
risk. The river and riverbank are active recreational areas; 
Fiscal year site was listed on the NPL: 2000; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: RI; 
Site name: Peterson/Puritan, Inc; 
Description of human exposure risk: Unacceptable exposure pathways 
exist for individuals known to trespass on the site. Unacceptable 
current risk is posed when people come in contact with soil and debris 
that is primarily contaminated with heavy metals and PAHs above 
acceptable levels at both the Nunes parcel and J.M. Mills landfill 
portions of the site. The Nunes and J.M. Mills landfill parcels are 
partially fenced and gated to restrict access to the extent 
practicable, but portions of the site abut a river where fencing is 
not practical. EPA is aware that regular, frequent trespassing occurs. 
EPA continues its efforts to dissuade entry to the site, including 
regular replacement of locks, signage, coordination with local law 
enforcement, etc. However, evidence of trespassing is routinely 
observed; 
Fiscal year site was listed on the NPL: 1983; 
Estimated fiscal year human exposure will be controlled: 2011. 

State: TX; 
Site name: Jones Road Groundwater Plume; 
Description of human exposure risk: Some residents are still dependent 
on private wells for their domestic water supply and can be exposed to 
tetrachloroethene (and other chlorinated solvent degradation products) 
in the groundwater. Approximately 150 residential and commercial users 
have been connected to a water supply system that was completed in 
2008. Even after installation of the water line was completed, some of 
the private well owners who have tetrachloroethene concentrations 
above the maximum contaminant level have not agreed to be connected to 
the water line. The Texas Commission on Environmental Quality will 
discontinue providing service for the filtration system to those well 
owners who have not chosen to be connected to the water line. After 
the water line is operational, and the infrastructure has been 
transferred to the water service provider, it will be the 
responsibility of each property/well owner to arrange for the 
installation of their own filtration system and filtration system 
maintenance; 
Fiscal year site was listed on the NPL: 2003; 
Estimated fiscal year human exposure will be controlled: 2012. 

State: TX; 
Site name: Petro-Chemical Systems, Inc. (Turtle Bayou); 
Description of human exposure risk: Current human exposure is 
considered not controlled for soil since the Monitoring Well-109 area 
of the site needs to be remediated, and the remedial action is planned 
in spring 2010. Human exposure is also considered not controlled for 
groundwater. The groundwater monitoring is under way by the 
responsible parties before the establishment of the technical 
impracticality waiver zone, after which contaminated groundwater 
migration will be considered to be under control; 
Fiscal year site was listed on the NPL: 1986; 
Estimated fiscal year human exposure will be controlled: 2010. 

State: UT; 
Site name: Davenport and Flagstaff Smelters; 
Description of human exposure risk: People can potentially come into 
contact with soil contaminated with lead and arsenic. Remediation has 
been completed at two of three operable units. The unremediated 
operable unit has unacceptable exposure risks to workers from 
contaminated soil in the commercial area and to trespassers in the 
undeveloped area; 
Fiscal year site was listed on the NPL: 2003; 
Estimated fiscal year human exposure will be controlled: 2011. 

State: UT; 
Site name: Eureka Mills; 
Description of human exposure risk: People are in contact with soil 
and dust contaminated with lead from mining activities. The site 
consists of residential and mining-impacted areas with limited access; 
Fiscal year site was listed on the NPL: 2002; 
Estimated fiscal year human exposure will be controlled: 2011. 

State: UT; 
Site name: Jacobs Smelter; 
Description of human exposure risk: There are two potential human 
health exposures to soil contaminated with lead and arsenic at the 
site: residential and recreational. The cleanup levels are focused on 
lead since addressing the lead contamination will also address the 
arsenic contamination. The residential exposure is expected to be 
limited to a relatively small number of residential lots known to have 
soil lead contamination above cleanup levels. The recreational 
exposure includes an undeveloped area. The exposures to recreational 
users would be caused by inhalation of contaminated dust from 
activities such as riding all-terrain vehicles that are known to occur 
at the site; 
Fiscal year site was listed on the NPL: 2000; 
Estimated fiscal year human exposure will be controlled: 2013. 

State: VA; 
Site name: Atlantic Wood Industries, Inc; 
Description of human exposure risk: The Atlantic Wood Industries 
Superfund site, located along the Elizabeth River in Portsmouth, 
Virginia, is a former wood-treating site that has extensive creosote 
contamination. The site also has heavy metals, PCP, and dioxin 
contamination. The site is considered "current human exposures not 
under control" because (1) recreational users of the river could come 
into direct contact with sediments contaminated with creosote 
nonaqueous phase liquid that could cause an acute impact with one 
exposure, (2) consumers of large quantities of shellfish are exposed 
to unacceptably high levels of contaminants, (3) Atlantic Wood 
Industries currently operates a prestressed, precast concrete 
manufacturing business at the site where workers are exposed to 
surface soils, and (4) workers at the Norfolk Naval Shipyard are 
exposed to surface soils when they trespass regularly to go from a 
parking area to their work areas; 
Fiscal year site was listed on the NPL: 1990; 
Estimated fiscal year human exposure will be controlled: 2014. 

State: WA; 
Site name: Commencement Bay, Near Shore/Tide Flats; 
Description of human exposure risk: There is direct human exposure to 
arsenic and lead as a result of contaminated yard soil. Almost all 
yards will be remediated within the next 2 years. Long-term controls 
will be required to prevent future exposure in unremediated areas. At 
other problem areas, consumption of contaminated fish and shellfish is 
the major issue. Although there is a "do not eat" fish advisory with 
signs posted throughout the site, this area is home to many low-income 
and non-English speaking people who are likely fishing anyway; 
Fiscal year site was listed on the NPL: 1983; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: WA; 
Site name: Commencement Bay, South Tacoma Channel; 
Description of human exposure risk: Well 12A is a City of Tacoma 
drinking water supply well that has been contaminated by releases from 
the Time Oil Superfund site. At this time, there is still considerable 
contaminant source material in the ground that provides an ongoing 
release to the drinking water aquifer. There is wellhead treatment at 
this well, but there are other supply wells in the area that the city 
plans to use more rigorously in the future. If they do this, they will 
pull the contaminant plume toward those wells; 
Fiscal year site was listed on the NPL: 1983; 
Estimated fiscal year human exposure will be controlled: 2015. 

State: WA; 
Site name: Lower Duwamish Waterway; 
Description of human exposure risk: Unacceptable risks are posed by 
consumption of contaminated fish and shellfish. Although there is a 
"do not eat" fish advisory with signs posted throughout the site, this 
area is home to many low-income and non-English speaking people who 
are likely fishing anyway. Also, there is a lower but not 
insignificant risk from direct contact with contaminated sediments; 
Fiscal year site was listed on the NPL: 2001; 
Estimated fiscal year human exposure will be controlled: After 2015. 

State: WA; 
Site name: Midnite Mine; 
Description of human exposure risk: The site includes an open pit 
uranium mine on an American Indian reservation and mine-impacted 
groundwater, surface water, and sediments. EPA assessed risk based on 
tribal members consuming wild-harvested plants, fish, and game and 
spending time (either as a visitor or a resident) on site, with 
associated exposures (for example, residents would be exposed to site 
radiation, radon in air, metals, and radionuclides in drinking water). 
The mine area is now fenced, but affected surface water and sediments 
are accessible to people and the plants/animals they consume. Health 
advisory information likely reduces their exposure, but exposure will 
only be under control when site conditions result in conditions that 
meet media cleanup levels and resulting risk reduction; 
Fiscal year site was listed on the NPL: 2000; 
Estimated fiscal year human exposure will be controlled: 2015. 

State: WI; 
Site name: Sheboygan Harbor & River; 
Description of human exposure risk: The current unacceptable human 
exposure is due to human ingestion of contaminated fish. Fish 
contaminants of concern are PCBs and heavy metals, including arsenic, 
chromium, copper, lead, and zinc. Fishing has been observed. Fish are 
taken off-site, and EPA believes the fish are being consumed. People 
who eat PCB-contaminated fish can experience health problems, 
including cancer, liver disease, and problems with the immune and 
endocrine systems. During pregnancy and lactation, mothers can pass 
PCBs and other chemicals to their infants. Because these chemicals 
affect development, children through adolescence and women of 
childbearing age are more sensitive to their harmful effects and 
should be especially careful; 
Fiscal year site was listed on the NPL: 1986; 
Estimated fiscal year human exposure will be controlled: 2015. 

Sources: EPA data and regional officials' responses to our survey. 

[End of table] 

[End of section] 

Appendix IV: Sites Receiving Recovery Act Funding: 

EPA identified 51 sites to receive Recovery Act funding. Table 5 
provides the amount of Recovery Act funds EPA allocated to each site 
and the planned use of these funds. 

Table 5: Amount and Planned Use of Recovery Act Funds for Superfund 
Sites: 

Dollars in millions: 

State: CA; 
Site name: Frontier Fertilizer; 
Amount of Recovery Act funds provided: $2.5; 
Description of the planned use of Recovery Act funds[A]: EPA is 
nearing completion of the design for an in-place electrical resistive 
heating system to treat pesticide-contaminated soil and groundwater to 
a depth of 80 feet below ground. However, recently collected data 
indicate much higher levels of contamination at greater depths, which 
will require additional infrastructure and power to treat. Given these 
additional needs, EPA will use Recovery Act funds to fund the 
expansion of the heating system and associated power costs to address 
the deeper contamination. EPA anticipates that this additional 
treatment will accelerate cleanup by removing greater contaminant mass 
in soil and, thereby, reducing the contaminants affecting groundwater 
resources, a potential source of drinking water. 

State: CA; 
Site name: Iron Mountain Mine; 
Amount of Recovery Act funds provided: $20.2; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to reduce the time needed to dredge, treat, and 
dispose of heavy metal-contaminated sediment located in the Spring 
Creek Arm of the Keswick Reservoir. This accelerated activity will 
take approximately 18 months to complete rather than the previously 
anticipated 3 years. EPA will construct pipelines and pump stations to 
move contaminated sediment from the Spring Creek Arm of Keswick 
Reservoir to a disposal cell. Removing these contaminated sediments 
will allow the Central Valley Project to produce $3 to $6 million of 
additional peak power per year. This additional power production will 
be possible because current operational constraints imposed to prevent 
contaminated sediment releases to the Shasta Dam and the Spring Creek 
Power House will no longer be needed. 

State: CA; 
Site name: Sulphur Bank Mercury Mine; 
Amount of Recovery Act funds provided: $1; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to start the cleanup of mine wastes. EPA's primary 
efforts will be planning and coordinating activities with the Elem 
Pomo Tribe; the procurement of a construction subcontractor; 
the initiation of work to provide temporary water supply, sewer 
service, and access for Elem Indian Colony residents during the 
cleanup; and planning efforts to assure the performance of mine waste 
excavation and disposal efforts. 

State: CO; 
Site name: Central City, Clear Creek; 
Amount of Recovery Act funds provided: $1.4; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to consolidate and cap additional mine waste piles, 
implement sediment control and drainage controls, and treat water to 
mitigate heavy metal impacts to Clear Creek. Reclaimed areas will be 
revegetated and restored. This work moves the project one step closer 
to completion by assisting in the recovery of aquatic life in the 
North Fork of Clear Creek. Work at the site will also reduce metal 
loads entering the watershed supplying water to Denver area residents. 

State: CO; 
Site name: Summitville Mine; 
Amount of Recovery Act funds provided: $17; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to construct the Summitville water treatment plant. 
The plant's construction is the final long-term cleanup activity 
planned at the site and will lead to achievement of the site-wide 
construction completion milestone ahead of schedule. 

State: DE; 
Site name: Standard Chlorine of Delaware, Inc; 
Amount of Recovery Act funds provided: $2.7; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to complete removal of the remaining 800 totes of 
bulk liquid chemicals. In addition to completing the tote removal, EPA 
will use the Recovery Act funds to upgrade the groundwater treatment 
system, which will reduce future years' funding needs. 

State: FL; 
Site name: Escambia Wood-Pensacola; 
Amount of Recovery Act funds provided: $3.5; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to speed up the ongoing cleanup of off-site 
properties and more quickly eliminate human exposure pathways to 
contaminants. The Recovery Act funding will also accelerate ongoing on-
site construction, which will lead to completion of the soil cleanup 
earlier. Speeding up the cleanup schedule will make the site available 
for earlier redevelopment. 

State: FL; 
Site name: Tower Chemical Co; 
Amount of Recovery Act funds provided: $8.5; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to speed up ongoing cleanup activities. The funds 
will support the excavation and off-site disposal of the remaining 
contaminated soils in the immediate areas surrounding the site's 
former wastewater pond and burn/burial area, sediments in a shallow 
drainage ditch, and sediments in two wetland areas. The work will also 
include backfilling and revegetation of excavated areas and wetland 
restoration. EPA expects that removal of these remaining source soils, 
estimated at 28,000 cubic yards, will expedite the cleanup. A follow-
up action for deeper groundwater contamination may be necessary to 
reach groundwater cleanup goals. 

State: FL; 
Site name: United Metals, Inc; 
Amount of Recovery Act funds provided: $7.4; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to begin the long-term cleanup action, which 
includes excavating contaminated soil and sediment. After excavation, 
EPA will treat the contaminated soil and sediment by solidification 
and stabilization. Treated soil and sediment will be placed in an on-
site containment cell. The excavated areas will be backfilled and 
revegetated. EPA will restore the nearby wetlands after the 
contaminated sediment is excavated. The Recovery Act funds will allow 
for completion of the soil containment system. 

State: GA; 
Site name: Brunswick Wood Preserving; 
Amount of Recovery Act funds provided: $8.3; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to speed up completion of the ongoing long-term 
construction, primarily to support the capping of the containment 
cells and groundwater treatment. EPA expects completion of these 
activities will eliminate the ongoing impacts to Burnett Creek. 

State: GA; 
Site name: Woolfolk Chemical Works, Inc; 
Amount of Recovery Act funds provided: $1.8; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to support the on-site work for the ongoing action 
at the former facility property. Specific work activities will consist 
of soil excavation, on-site soil treatment, backfilling, stockpiling 
for off-site disposal, grading, closure, and revegetating the property. 

State: ID; 
Site name: Bunker Hill Mining & Metallurgical Complex; 
Amount of Recovery Act funds provided: $15; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to expedite the Coeur d'Alene Basin residential 
cleanup program, which is a top priority for the site and key to 
protecting public health. EPA estimates that the basin residential 
cleanup will be completed in fiscal year 2015. With the Recovery Act 
funding, EPA believes that this aspect of the site's cleanup could be 
completed 2 years earlier, by the end of fiscal year 2013. 

State: IL; 
Site name: Outboard Marine Corp; 
Amount of Recovery Act funds provided: $18; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to conduct the demolition of a facility 
contaminated with PCBs and to excavate and dispose of off-site PCB-
contaminated soil and sediment. Demolition of the building will enable 
the property to be redeveloped, in accordance with the city's plans, 
while groundwater restoration steps are under way. 

State: IN; 
Site name: Continental Steel Corp; 
Amount of Recovery Act funds provided: $6; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to support cleanup actions related to the 
groundwater and slag processing area. To address the large portion of 
the aquifer contaminated with volatile organic compounds, EPA will use 
the Recovery Act funds to install groundwater extraction wells, 
operate the wells to contain the existing contaminant plume, and 
remove contaminated groundwater and send it off-site for treatment. 
EPA also will use the Recovery Act funds to regrade the slag pile and 
to install a protective soil cover over the area once the regrading is 
complete. 

State: IN; 
Site name: Jacobsville Neighborhood Soil Contamination; 
Amount of Recovery Act funds provided: $13; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to conduct all of the cleanup and restoration work 
at approximately 125 homes in the first operable unit. Lead and 
arsenic-contaminated residential soils will be excavated to the depth 
of elevated concentrations, a maximum depth of 2 feet. EPA will 
dispose of contaminated soil off-site. Yards will then be reseeded and 
returned to their original condition. This cleanup will be the start 
of the first long-term cleanup action at the site. Use of the Recovery 
Act funds will allow EPA to speed up the cleanup of the first operable 
unit, which will result in the reduced exposure of residents to 
contaminants. 

State: KS; 
Site name: Cherokee County; 
Amount of Recovery Act funds provided: $15; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to support cleanup activities at the Badger, 
Lawton, Baxter Springs, and Treece subsites. At the Badger and Lawton 
subsites, EPA will use the funds to support the initial base year of 
cleanup work consisting of excavation, consolidation, capping, and 
revegetation of approximately 120 acres or 700,000 cubic yards of mine 
waste. This activity will address all surface mine and mill wastes at 
these subsites. The funding will enable the project to be completed in 
a 3-year time frame. At the Baxter and Treece subsites, the Recovery 
Act funds will support the ongoing excavation, consolidation, capping, 
and revegetation activities associated with approximately 380 acres, 
or 2.1 million cubic yards, of mine waste. EPA anticipates that the 
funding will support the completion of these activities, which are 
addressing the final area of surface mine and mill waste at the site. 
EPA expects that Recovery Act funds will expedite the projected 10-
year cleanup. 

State: MA; 
Site name: Hatheway & Patterson; 
Amount of Recovery Act funds provided: $20; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to fully implement the comprehensive site remedy 
and achieve site-wide construction completion of the site. Cleanup 
construction activities will involve the excavation of approximately 
31,000 cubic yards of soil exceeding cleanup levels. Soils containing 
dioxin and oily material will be disposed of off-site at a licensed 
facility, while soils containing pentachlorophenol, semivolatile 
organic compounds, and arsenic will be consolidated on-site under a 
low-permeability cover. EPA expects that a portion of the site will be 
reused as a commuter railroad parking facility. Other areas of the 
site will also be made ready for future commercial uses and/or open 
space as a result of cleanup actions. 

State: MA; 
Site name: New Bedford Harbor; 
Amount of Recovery Act funds provided: $30; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to supplement existing funds for ongoing dredging 
efforts, which will accelerate cleanup activities. While the entire 
cleanup effort will extend beyond the use of this additional funding, 
the funds will speed up these efforts by allowing the dredging of a 
larger volume of contaminated sediment from the highly contaminated 
upper harbor. The accelerated cleanup will help facilitate the city's 
plans to develop shoreline public access, recreational boating, 
competitive rowing, and wetland restoration in the upper and lower 
harbor areas. 

State: MA; 
Site name: Silresim Chemical Corp; 
Amount of Recovery Act funds provided: $14; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to achieve site-wide construction completion for 
the Silresim site. The specific activities EPA will conduct with these 
funds include cleaning up contaminated soil using thermally enhanced 
soil vapor extraction, which involves heating 67,000 cubic yards of 
contaminated soil over an approximately 1.25-acre area, and removing 
and treating the contaminated vapor from these soils. EPA will also 
complete construction of the final cover on the Silresim property, 
which will make a portion of the site ready for potential future reuse. 

State: MN; 
Site name: South Minneapolis Residential Soil Contamination; 
Amount of Recovery Act funds provided: $20; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to conduct all cleanup and restoration work at the 
approximately 500 remaining residential properties with soils above 
the arsenic soil cleanup standard. The activities include the 
excavation and off-site disposal of all contaminated soil above the 
cleanup standard, with excavation to occur to a depth of 12 inches in 
lawn areas, and 18 inches in garden areas. If confirmation samples 
from the base of the excavation show arsenic levels above the acute 
arsenic cleanup standard, EPA will continue excavating soil until the 
acute standard is met or foundation depth is reach. Once excavation is 
complete, the properties will be restored to their original condition. 
The activities also include establishing institutional controls on 
properties where excavation is not possible due to access restrictions. 

State: MO; 
Site name: Madison County Mines; 
Amount of Recovery Act funds provided: $11.1; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to support ongoing excavation, replacement, and 
disposal of approximately 205,000 cubic yards of lead-contaminated 
residential soil at approximately 800 residential properties. 
Consistent with EPA's overall site cleanup approach, this activity 
will address the highest priority and greatest risk to human health at 
the site--exposure of young children to lead-contaminated residential 
soil. EPA anticipates that the Recovery Act funding will allow for the 
projected 4-to 5-year cleanup to be completed on an expedited schedule. 

State: MO; 
Site name: Oronogo-Duenweg Mining Belt; 
Amount of Recovery Act funds provided: $10; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to support excavation and disposal of the site's 
contaminated mining wastes, soils, and sediments. Recovery Act funds 
also will support capping of the disposal areas, backfilling and 
revegetating excavated areas, and constructing wetlands to improve 
surface water cleanup. The additional funding will expedite the 
ongoing cleanup action by addressing an additional 600 to 800 acres of 
contaminated mining waste and soil. 

State: MT; 
Site name: Upper Tenmile Creek Mining Area; 
Amount of Recovery Act funds provided: $6.5; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to expedite the ongoing cleanup and to start new 
work. Ongoing work to be supported by Recovery Act funds includes the 
removal of waste from residential yards in the community of Rimini and 
the Landmark subdivision, removal of waste at the Lee Mountain Mine, 
placement of waste in the Luttrell Repository, and additional 
stabilization and partial capping of the repository. New work to be 
performed with Recovery Act funds will be the removal of waste from 
the Rimini Road area. 

State: NC; 
Site name: GMH Electronics; 
Amount of Recovery Act funds provided: $1.5; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to extend the existing City of Roxboro's municipal 
drinking water line to the area affected by the contamination. 
Residences that have contamination attributable to the site in their 
private drinking water wells, or are located within a 500-foot buffer 
area of the contaminated groundwater plume, will be offered a 
connection to this public water supply. A follow-up action will be 
needed to address contaminated sources, contaminated groundwater, and 
any other contaminated media caused by the site. 

State: NC; 
Site name: Sigmon's Septic Tank Service; 
Amount of Recovery Act funds provided: $1; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to begin cleanup activities to excavate 
contaminated soil. After being excavated, EPA will dispose of the 
contaminated soil off-site. EPA will backfill and revegetate the 
excavated area. 

State: ND; 
Site name: Arsenic Trioxide Site; 
Amount of Recovery Act funds provided: $13.8; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to accelerate the project to bring safe drinking 
water to approximately 180 remaining rural households and to expand 
the water treatment and distribution facilities to handle the 
increased demand. EPA estimates that the project schedule will be 
accelerated by 1 year. Specific activities include drilling two 
additional water supply wells, installing an additional water 
treatment filter, constructing an additional reservoir and pump house, 
modifying four existing reservoirs, and extending water distribution 
lines. 

State: NE; 
Site name: Omaha Lead; 
Amount of Recovery Act funds provided: $25; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to significantly increase the pace of ongoing long-
term soil cleanup and lead-based paint stabilization activities. Small 
businesses with incentives to hire and purchase materials locally will 
conduct the work. While EPA will need to continue work at this site in 
future years, the funding will help expedite implementation of the 
final cleanup approach for the site, estimated to be completed in 5 to 
10 years. 

State: NH; 
Site name: Ottati & Goss/Kingston Steel Drum; 
Amount of Recovery Act funds provided: $2; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to support the next round of the ongoing in situ 
chemical oxidation work. 

State: NJ; 
Site name: Cornell Dubilier Electronics Inc; 
Amount of Recovery Act funds provided: $30; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to accelerate the cleanup of contaminated soil and 
debris. Contaminated soils will be treated on-site using low 
temperature thermal desorption. Soils that cannot be cleaned through 
on-site treatment will be transported off-site for disposal. 
Addressing the contaminated soils will allow redevelopment to begin at 
the industrial park, which is part of a Borough of South Plainfield- 
approved redevelopment plan. 

State: NJ; 
Site name: Emmell's Septic Landfill; 
Amount of Recovery Act funds provided: $3; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to accelerate the cleanup of PCB-contaminated soil 
remaining at the site. The funds will support the start of excavation 
and off-site disposal of contaminated soil, backfilling of the 
excavated soil, and revegetation of the affected area. This action 
will alleviate potential risks associated with direct contact with PCB-
contaminated soil and the potential inhalation of contaminated dust. 
While addressing the site's contaminated soil, EPA will begin interim 
cleanup activities to address groundwater, which calls for the on-site 
construction of a groundwater extraction and treatment system to 
control movement of the contaminated groundwater off of the site 
property. 

State: NJ; 
Site name: Horseshoe Road; 
Amount of Recovery Act funds provided: $5; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to accelerate the cleanup of the remaining on-site 
soils that act as a source of contamination to the groundwater and 
surface water, which drain into the Raritan River. 

State: NJ; 
Site name: Imperial Oil Co.; 
Inc./Champion Chemicals; 
Amount of Recovery Act funds provided: $25; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to accelerate the cleanup of the remaining 
contaminated soil components, which are the major source of 
contamination to the groundwater beneath the site. Accelerating the 
cleanup of the site soils is expected to reduce the overall site 
cleanup cost and hasten the reuse/redevelopment of the site. 

State: NJ; 
Site name: Monitor Devices; 
Amount of Recovery Act funds provided: $3; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to start groundwater cleanup activities. 

State: NJ; 
Site name: Price Landfill; 
Amount of Recovery Act funds provided: $16; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds for construction and operation of a groundwater 
extraction and treatment system near the site property. This system 
will control further migration of groundwater contamination. After 
implementation of the source control action, which includes capping of 
the landfill, a groundwater remedy will be put into place to address 
the down-gradient portion of the groundwater contaminant plume. The 
goal of this remedy is aquifer restoration. Accelerating the 
implementation of the source control action will reduce the cost 
associated with restoring the aquifer. 

State: NJ; 
Site name: Roebling Steel Co; 
Amount of Recovery Act funds provided: $27; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to remove approximately 242,000 cubic yards of 
contaminated sediments from the Back Channel Delaware River and Crafts 
Creek. The sediments are contaminated with varying degrees of metals, 
including, lead, copper and zinc, and PAHs. The project will include 
dredging and dewatering contaminated sediments, placement of sediments 
in the slag area, stabilization of Back Channel shoreline, and wetland 
restoration of affected areas. EPA expects that cleanup of the 
contaminated sediments will accelerate the overall site cleanup, which 
may increase reuse and redevelopment potential. 

State: NJ; 
Site name: Vineland Chemical Co., Inc; 
Amount of Recovery Act funds provided: $20; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to accelerate the cleanup of the remaining 
stretches of Blackwater Branch. The associated contaminated sediments 
are the major remaining source of arsenic contamination to the Maurice 
River (designated as a scenic river) and Union Lake (the second 
largest lake in New Jersey). EPA anticipates that accelerating the 
cleanup of the Blackwater Branch will reduce the overall cleanup of 
the site by approximately 2 years. 

State: NJ; 
Site name: Welsbach & General Gas Mantle (Camden Radiation); 
Amount of Recovery Act funds provided: $22; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to clean up the radiologically contaminated soils 
around the former General Gas Mantle facility in Camden. The EPA 
believes the cleanup of the General Gas Mantle property will serve as 
a catalyst for redevelopment of the area. 

State: NM; 
Site name: Grants Chlorinated Solvents; 
Amount of Recovery Act funds provided: $4; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to expedite the construction of the groundwater 
remedy, which includes the installation of wells for enhanced 
biological treatment, in situ chemical oxidation, and thermal 
desorption to destroy the chlorinated solvents in the groundwater. EPA 
will be flexible in constructing the individual components of the 
remedy at the site. Installation of the groundwater remedy will 
eliminate the source of the indoor air contamination and ensure that 
the vapor mitigation systems currently being installed on 14 houses 
above the groundwater plume function as intended. Installation of the 
groundwater remedy will also protect the source of the area's drinking 
water by preventing contamination from migrating to the deeper aquifer. 

State: NY; 
Site name: Lawrence Aviation Industries, Inc; 
Amount of Recovery Act funds provided: $5; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to implement a portion of the groundwater remedy 
for the site, which consists of an extraction and treatment system and 
the in situ chemical oxidation process. These actions, aimed at source 
control, will prevent the further migration of groundwater 
contaminants beyond the plant site boundary. Over time, the actions 
also will eliminate further contamination of down-gradient surface 
waters and sediments in Old Mill Pond and Old Mill Creek in Port 
Jefferson. 

State: NY; 
Site name: Old Roosevelt Field Contaminated GW Area; 
Amount of Recovery Act funds provided: $10; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to accelerate the cleanup of the contaminated 
groundwater and to protect two municipal well fields that extract 
water from the site's sole-source aquifer. EPA anticipates that 
accelerating the cleanup of the groundwater will eliminate the need 
for treatment of the public water supply in the future. Given the 
risks associated with chlorinated solvent contamination in 
groundwater, shortening the cleanup time frame will be protective of 
the more than 8,000 people who get their drinking water from the 
public water supply. 

State: OK; 
Site name: Tar Creek (Ottawa County); 
Amount of Recovery Act funds provided: $34.5; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to continue the ongoing voluntary relocation 
efforts of Picher, Cardin, and Hockerville residents. EPA projects 
that the relocations will be completed within 3 years. Additional 
funds will be used to accelerate the start of the chat excavation from 
the remote areas of the site and from area streams. Other additional 
work to be performed includes constructing a repository, providing 
alternate water supply to two rural residential properties, and 
conducting cleanup of rural residential yards. EPA is currently 
negotiating with several mining companies to complete the work on 
their operating areas of the site. EPA expects that the use of 
Recovery Act funds will accelerate the overall cleanup. As chat at Tar 
Creek is addressed, the land will become available for agricultural 
development. 

State: PA; 
Site name: Crossley Farm; 
Amount of Recovery Act funds provided: $6.5; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to start the construction necessary to begin the 
site's groundwater cleanup activities. Once this project is completed, 
and the plume is addressed, EPA will focus future cleanup efforts on 
the source area. 

State: PA; 
Site name: Havertown PCP; 
Amount of Recovery Act funds provided: $4.2; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to complete cleanup activities at the site. The 
remaining cleanup activities include work to improve the performance 
of the groundwater treatment system, which among other actions, will 
involve installing an additional deep recovery well. Other cleanup 
activities include excavating the open recreational area and 
backfilling it with clean soil, removing a portion of the abandoned 
sewer line, installing three new extraction wells and up to five new 
monitoring wells, and implementing ecological sampling to demonstrate 
habitat and fish community recovery. EPA also plans to implement 
institutional controls to protect the site's cleanup. 

State: SD; 
Site name: Gilt Edge Mine; 
Amount of Recovery Act funds provided: $3.5; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds at the Ruby Repository portion of the site to grout 
unlined portions of the clean-water ditches and to repair/replace 
existing liners. The repair of these ditches will reduce the volume of 
acid rock drainage collected and treated at the water treatment plant. 
The Recovery Act funding is expected to lead to a long-term cleanup 
completion of operable unit 3 and enable future funding to focus on 
the remaining site cleanup. 

State: TX; 
Site name: Garland Creosoting; 
Amount of Recovery Act funds provided: $6; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to expedite achievement of site-wide construction 
completion. 

State: UT; 
Site name: Bountiful/Woods Cross 5th S. PCE Plume; 
Amount of Recovery Act funds provided: $5; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to start the cleanup work at operable unit 2, which 
will consist of installing additional groundwater extraction and 
monitoring wells and constructing a water treatment system. 

State: UT; 
Site name: Eureka Mills; 
Amount of Recovery Act funds provided: $26.5; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to accelerate the cleanup of mine waste and 
residential areas by 1 year. Specific work to be performed includes 
the stabilization and capping of three large mine waste areas, 
construction of drainage control features to contain contaminated 
runoff so that cleaned up areas are not recontaminated, and the 
cleanup of the lead-contaminated soils at approximately 160 
residential properties. 

State: VA; 
Site name: Atlantic Wood Industries, Inc; 
Amount of Recovery Act funds provided: $3.7; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to start cleanup approximately 1 year earlier than 
expected. EPA anticipates that initial cleanup activities will include 
stabilization of creosote-soaked soils, construction of an earthen 
berm to contain some of the contaminated sediments that will be 
dredged in a future phase, shoreline stabilization work, soil 
excavation and consolidation, and wetland mitigation work. EPA expects 
that the work at this site will create job opportunities and create 
redevelopment opportunities once completed. 

State: VT; 
Site name: Elizabeth Mine; 
Amount of Recovery Act funds provided: $8; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to begin the final phase of a non-time critical 
removal action to control the three major source areas responsible for 
acid rock drainage and leachate. This work will contribute to the 
cleanup actions targeted to eliminate acid rock drainage from the 
site's waste piles and will also reduce the leachate generated by the 
tailing impoundments. The final phase is a 3-to 4-year project, a 
portion of which will be funded via the Recovery Act. This funding 
will allow EPA to begin and complete this phase sooner than planned, 
which will shorten the time period for improvement of water quality. 

State: WA; 
Site name: Commencement Bay, Near Shore/Tide Flats; 
Amount of Recovery Act funds provided: $5; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to support activities at the Ruston/North Tacoma 
study area, which encompasses approximately 950 acres located in a 1-
mile circle around the former Asarco Tacoma smelter. Both the smelter 
and the study area are part of the larger site. Recovery Act resources 
applied to this area will complete residential cleanup involving 
excavation of contaminated soils from residential yards, park lands, 
and rights-of-way. 

State: WA; 
Site name: Wyckoff Co./Eagle Harbor; 
Amount of Recovery Act funds provided: $2.3; 
Description of the planned use of Recovery Act funds[A]: EPA will use 
Recovery Act funds to upgrade and supplement existing groundwater 
extraction wells and to install an additional one. The funds will also 
be used to demolish existing structures at the site so that the sheet- 
pile wall can be completed, and the soil cap can be constructed. EPA 
projects that the entire containment remedy will be completed in 5 to 
7 years with assistance from the Recovery Act funds. 

Sources: EPA data and regional officials' responses to our survey. 

[A] EPA may currently be implementing these planned actions, and some 
actions may be complete. 

[End of table] 

[End of section] 

Appendix V: Comments from the Environmental Protection Agency: 

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

April 21, 2010: 

Mr. John B. Stephenson, Director: 
Natural Resources and Environment: 
Government Accountability Office: 
Washington, DC 20548: 

Dear Mr. Stephenson: 

Thank you for the opportunity to comment on the draft report entitled 
"EPA's Estimated Costs to Remediate Existing Sites Exceed Current 
Funding Levels, and More Sites Are Expected to be added to the 
National Priorities List (GAO-10-380)." We appreciate the collegial 
working relationship and dialogue with GAO as this report was 
developed. We also want to commend GAO for undertaking this important 
study with respect to budget issues in the Superfund Remedial Program. 

I am responding on behalf of the Office of Solid Waste and Emergency 
Response (OSWER) as well as the Office of Enforcement and Compliance 
Assurance (OECA) and the Office of the Chief Financial Officer (OCFO). 
Their comments have been incorporated into this consolidated EPA 
response. Below are our most significant comments on the report's one 
recommendation and on the information provided in the report itself. 
Other technical comments are included in the Enclosure. 

Recommendation: 

GAO recommends that "the EPA Administrator determine the extent to 
which EPA will consider vapor intrusion in listing NPL sites and its 
effect on the number of sites listed in the future". 

EPA agrees with this recommendation. While EPA currently does consider 
vapor intrusion impacts in both the remedial and removal cleanup 
programs, as part of its Integrated Cleanup Initiative, the Agency is 
evaluating whether vapor intrusion needs to be more specifically 
addressed in the Hazardous Ranking System (HRS) model, In addition, 
the Office of Solid Waste and Emergency Response is developing a final 
version of its Vapor Intrusion Guidance, establishing a vapor 
intrusion website, and producing technical papers to improve our 
ability to address this issue. 

General Comments: 

With respect to the overall funding situation, EPA's Administrator and 
the Administration face extremely difficult decisions about where to 
allocate scarce resources, and the funding level requested as part of 
the President's Budget request represents what the Administration 
believes is the best balance of funding decisions across many 
competing environmental priorities. We recognize that the Superfund 
remedial program has the capacity to use additional resources if and 
when they are available, as is evident in its utilization of the $600 
million provided through the American Reinvestment and Recovery Act 
(ARRA). The President's budget in both FY2010 and FY2011 proposed 
reinstating the Superfund tax, and that would provide additional funds 
for Congress to appropriate. Given currently available resources, EPA 
will continue to work to make sure that it uses its Superfund 
resources in the most effective manner possible to complete work at 
sites as expeditiously as possible with the funding we receive. 

In FY 2010, EPA launched the Integrated Cleanup Initiative (ICI) to 
increase the pace and efficiencies of EPA's land cleanup programs. As 
part of the ICI, we have committed to a new publicly reported 
performance measure of Superfund remedial action project completions. 
This new measure, which will begin in FY2011, will provide greater 
accountability and transparency of the detailed, incremental actions 
necessary to bring site cleanup to completion, and ultimately reuse. 
As part of the ICI, we will identify opportunities to maximize program 
resources and identify additional efficiencies. The ICI will evaluate 
all phases of our cleanup programs including 1) starting cleanups; 2) 
advancing cleanups and; 3) completing cleanups. 

There are, however, two issues that EPA has determined require more 
clarification within the report. First, it is important to highlight 
early in the report that people are not typically in danger of 
immediate harm at "sites with unacceptable human exposure," which we 
label Human Exposure Not Under Control sites or HE NUC sites. When 
acute health threats are identified, the Agency takes immediate action 
to address them using our time critical removal authorities. It should 
be noted as well that funding for these actions comes from a different 
part of the Agency's Superfund budget, so it is not in competition 
with the remedial program's budget. Otherwise, EPA is taking longer-
term actions to characterize the risks and/or address the threats to 
human health at these sites. In addition, it should be noted, that EPA 
does not use the word "unknown" when classifying a site as Human 
Exposure Insufficient Data (HE ID). We believe to label it as 
"unknown" fails to reflect the Agency's efforts to develop the site 
characterization necessary to determine whether people are exposed at 
unsafe levels at a site. 

In addition, GAO notes that the Regional cost estimates are likely 
understated, since they do not include funding for sites where a 
responsible party is currently funding remedial construction but may 
be unable to do so in the future. In this regard, GAO should recognize 
that in cases where responsible parties are conducting remedial 
construction under existing settlement agreements; those agreements 
require those parties to maintain financial assurance mechanisms to 
ensure that response actions are completed if the parties are unable 
to do so. Over the last several years, EPA has made considerable 
efforts to ensure that financial assurance mechanisms are in place for 
existing response settlements and to ensure that financial assurance 
mechanisms for all new response settlements are put in place in a 
timely fashion. Thus, in addition to Superfund appropriations, these 
financial assurance mechanisms are an additional potential source of 
funding for cleanup under existing response settlements. With respect 
to GAO's concerns about the effects on future funding, it is more 
likely that the Trust Fund would bear the cost of completing cleanups 
at sites where PRPs are experiencing financial difficulty but have not 
yet settled with EPA. They therefore may be unable to complete 
cleanups in the future, which would increase the burden on the Trust 
Fund. 

In closing, we believe that there is substantial useful information in 
this report and applaud GAO for looking into these very important 
subjects. We hope to build off of the cooperative nature in which this 
review was performed and continue to work with GAO to improve the 
Superfund program. If you have any questions or concerns regarding our 
comments or responses to recommendations, EPA would be happy to meet 
with you prior to GAO finalizing this report. Please feel free to 
contact me or Robin Richardson at 703-603-9048 if there is any 
additional follow up required. 

Sincerely, 

Signed by: 
Mathy Stanislaus: 
Assistant Administrator: 

Enclosure: 

cc: 
Barbara Bennett, OCFO: 
Cynthia J. Giles, OECA: 
Barry Breen, OSWER: 
Maryann Froehlich, OCFO: 
Catherine R. McCabe, OECA: 
James Woolford, OSRTI: 
Elliott Gilberg, OSRE: 
David Bloom, OCFO: 
Gwendolyn Spriggs, OECA: 
Bobbie Trent, OSWER: 
Johnsie Webster, OSWER: 

[End of section] 

Appendix VI: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

John B. Stephenson, (202) 512-3841, stephensonj@gao.gov: 

Staff Acknowledgments: 

In addition to the individual named above, Vincent Price, Assistant 
Director; Deanna Laufer; Barbara Patterson; Kyerion Printup; and Beth 
Reed Fritts made key contributions to this report. Elizabeth 
Beardsley, Nancy Crothers, Pamela Davidson, Michele Fejfar, Carol 
Henn, and Mehrzad Nadji also made important contributions. 

[End of section] 

Footnotes: 

[1] Pub. L. No. 96-510 (1980), codified, as amended, at 42 U.S.C. §§ 
9601-9675 (2010). 

[2] In addition to the 1,269 sites that were listed on the NPL at the 
end of fiscal year 2009, EPA had listed and subsequently deleted 333 
sites from the NPL because it determined, with state concurrence, that 
no further site response was needed. Additionally, 5 sites were 
proposed for listing but were deleted before being finalized on the 
NPL. As of the end of fiscal year 2009, there were a total of 1,607 
final and deleted NPL sites. 

[3] The 158 federal facilities are owned and operated by federal 
agencies, such as the Departments of Defense, Energy, and the Interior. 

[4] EPA refers to sites with unacceptable human exposure as “current 
human exposures not under control” and sites with unknown human 
exposure as “insufficient data to determine human exposure control 
status.” 

[5] In addition to sites listed on the NPL, some non-NPL sites may be 
cleaned up through the Superfund remedial program by using the 
Superfund alternative approach, under which responsible parties enter 
into an agreement with EPA to clean up the site. Remedial actions at 
these non-NPL sites are not funded by the Superfund trust fund. 

[6] 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. 

[7] The American Recovery and Reinvestment Act of 2009, Pub. L. No. 
111-5, was enacted with the purpose to promote economic recovery, make 
investments, and minimize and avoid reductions in state and local 
government services, among other things. 

[8] Of the $600 million, EPA allocated $582 million to remedial 
cleanup activities and $18 million to internal EPA activities related 
to the management, oversight, and reporting of Superfund Recovery Act 
funds. 

[9] We spoke with hazardous waste agency officials from the states of 
California, Iowa, Kentucky, Louisiana, Maine, Michigan, Montana, New 
Jersey, Virginia, and Washington. 

[10] Love Canal was a toxic waste site near Niagara Falls, New York, 
where housing was built upon a former landfill for toxic chemicals, 
and residents began developing cancer and other illnesses from the 
residual waste. In August 1978, President Carter announced a national 
emergency at Love Canal and called for the allocation of federal funds 
for the site. 

[11] The budget proposed by the administration for fiscal year 2011 
reflects legislative proposals to reestablish a tax to support the 
Superfund program. 

[12] EPA, A Guide to Developing and Documenting Cost Estimates During 
the Feasibility Study, EPA 540-R-00-002 (Washington, D.C.: July 2000). 

[13] GAO, GAO Cost Estimating and Assessment Guide: Best Practices for 
Developing and Managing Capital Program Costs, [hyperlink, 
http://www.gao.gov/products/GAO-09-3SP] (Washington, D.C.: March 2009). 

[14] In surveying EPA regional officials about the amount of work 
remaining to complete construction at a site, we specified that they 
should consider the scope of the work remaining, as opposed to the 
amount of time needed to complete the work. 

[15] Thirty of the 41 sites that EPA regional officials expect will 
continue to pose unacceptable risk until fiscal year 2015 or later are 
“teenager sites”-—sites that have been on the NPL for at least 13 
years. 

[16] TCE is a colorless liquid that is used as a solvent for cleaning 
metal parts. Drinking or breathing high levels of TCE may cause 
nervous system effects, liver and kidney damage, abnormal heartbeat, 
unconsciousness, and possibly death. 

[17] This total includes construction costs and all other appropriated 
site-specific Superfund expenditures through fiscal year 2009, except 
for reimbursable and homeland security supplemental expenditures. 

[18] Unless otherwise specified, these numbers are as reported by EPA, 
and are not adjusted for inflation by GAO. 

[19] These costs include both EPA costs, as well as costs paid by 
responsible parties for site cleanup. Although EPA’s data classified 
megasites and potential megasites separately, we grouped megasites and 
potential megasites together for purposes of this report. 

[20] Our survey asked EPA regional officials to provide the 
approximate projected costs to EPA to complete construction at a site 
in the most efficient manner, given what is currently known about 
contamination at a site. EPA regional officials provided cost 
estimates based on various information, including ROD estimates, 
estimates developed during remedial design or construction, and 
estimates developed during remedial investigations and feasibility 
studies. According to EPA officials, cost estimates for individual 
fiscal years for a site may change because of a number of factors, 
such as a site’s construction readiness and contracting delays. 

[21] For 9 of the 57 sites, EPA officials did provide a broad range of 
costs for construction, but we did not include those costs in our 
analysis because EPA officials were unable to provide more precise, 
annual cost figures for those sites. 

[22] EPA notes that when a responsible party enters a settlement 
agreement with EPA, financial assurance mechanisms are put in place to 
provide cleanup funds in the event that the party is no longer 
financially able to complete the cleanup. There are no financial 
assurances, however, for potentially responsible parties who have not 
yet entered a settlement agreement. 

[23] GAO, Superfund: Information on Cost and Other Issues Related to 
the Cleanup of the Federal Creosote Site, [hyperlink, 
http://www.gao.gov/products/GAO-10-277] (Washington, D.C.: February 
2010). 

[24] As part of this allocation, EPA headquarters includes funding for 
other nonconstruction activities, including conducting prelisting 
activities through cooperative agreements with states, oversight of 
all responsible party-lead activities, and providing general support 
and management. 

[25] CERCLA requires that states share the cost of any EPA-led remedy, 
specifically by requiring states to fund 10 percent of the remedial 
action and assume responsibility for a site’s operation and 
maintenance. Before EPA lists a site on the NPL, the state in which a 
site is located must provide assurance that it will do so. 

[26] The November 2002 draft guidance on vapor intrusion also applies 
to additional sites, such as Resource Conservation and Recovery Act 
Corrective Action and Brownfields sites, which are distinct from the 
Superfund program. 

[27] EPA, Office of Inspector General, Lack of Final Guidance on Vapor 
Intrusion Impedes Efforts to Address Indoor Air Risks, 10-P-0042 
(Washington, D.C.: December 2009). 

[28] GAO, Superfund: Litigation Has Decreased and EPA Needs Better 
Information on Site Cleanup and Cost Issues to Estimate Future Program 
Funding Requirements, [hyperlink, 
http://www.gao.gov/products/GAO-09-656] (Washington, D.C.: July 2009). 

[End of section] 

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