Scope and Methodology
Because of a pending federal criminal case against W.R. Grace
(the company that owned the Libby vermiculite mine and some of the
facilities that processed ore from the mine), we designed our methodology
to minimize direct contact with EPA staff. To obtain information on the current
status of efforts to assess and address potential risks at each of the sites
identified as potentially receiving the Libby ore, we asked EPA to review
for accuracy and completeness a list of vermiculite sites that we originally
obtained from the Agency for Toxic Substances
and Disease Registry (ATSDR). This
list was largely based on site data that ATSDR had obtained from EPA. For each site,
the data included the location, type of facility, amount of ore received, and limited
information on the results of EPA’s evaluation. EPA officials located in the agency’s
headquarters and regional offices reviewed the list of sites and provided comments and
clarifications. We also submitted questions in writing to EPA to clarify some of the
information it provided, and EPA provided its responses in writing. Also,
we collected and analyzed relevant documentation about the sites from EPA’s
Superfund record centers, which are public repositories, and collected and analyzed
health consultation reports that ATSDR had prepared for selected sites. To the extent
possible, we used the information from the record centers and the health consultations
to verify the site information EPA provided. However, we did not independently
verify the information EPA provided.
We conducted this engagement from December 2007 to March 2009 in accordance with
all sections of GAO’s Quality Assurance Framework that are relevant to our objectives.
The framework requires that we plan and perform the engagement to obtain sufficient and
appropriate evidence to meet our stated objective and to discuss any limitations in our
work. We believe the information and data obtained, and the analysis conducted, provide
a reasonable basis for any findings and conclusions. A more detailed description of our
scope and methodology is presented in enclosure II of our report entitled Hazardous Materials:
Status of EPA’s Efforts to Assess Sites That May Have Received Asbestos-Contaminated Ore from Libby,
Montana GAO-09-6R (Washington, D.C.: March 10, 2009). For additional information
about EPA’s assessment of the sites, see our October 2007 report entitled Hazardous Materials: EPA May Need to Reassess Sites Receiving
Asbestos-Contaminated Ore from Libby, Montana, and Should Improve Its Public Notification Process,
(Washington, D.C.: October 12, 2007).
GAO-08-71.
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