Superfund
Information on the Nature and Costs of Cleanup Activities at Three Landfills in the Gulf Coast Region Gao ID: GAO-11-287R February 18, 2011The Environmental Protection Agency (EPA) estimates that one in four Americans lives within 3 miles of a contaminated site, many of which pose serious risks to human health and the environment. The Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) provided the federal government with authority to respond to releases or threatened releases of hazardous substances and created a trust fund to provide for certain cleanup activities. Under CERCLA, EPA established the Superfund program to address the threats that contaminated sites pose. Although EPA has paid for the cleanup of many of these sites through the Superfund program, funding for these cleanups has diminished in recent years. In 2010, we reported that EPA's estimated costs to clean up existing contaminated sites exceed the Superfund program's current funding levels and that some sites have not received sufficient funding for cleanup to proceed in the most cost-efficient manner. Additionally, in July 2009, we reported that EPA does not collect sufficient information on the cost of cleanup activities at Superfund sites and recommended, among other things, that EPA assess and improve the data it collects on the status and cost of cleanups. EPA coordinates the cleanup of Superfund sites by identifying sites potentially requiring cleanup action and placing eligible sites on its National Priorities List (NPL). EPA may compel the parties responsible for contaminating these sites to clean them up, or the agency may, using resources from the trust fund established by CERCLA, conduct cleanups itself and seek reimbursement from responsible parties. In some cases, EPA may not be able to obtain reimbursement because the agency cannot identify a responsible party or the responsible party or parties may be insolvent or may no longer exist. One category of contaminated sites--landfills and other waste disposal facilities--made up more than one-third of the 1,397 sites EPA placed on the NPL from 1983 through 2007, and EPA's expenditures at these 511 sites totaled about $3.6 billion through fiscal year 2007. According to EPA, landfill sites on the NPL generally share similar characteristics and present similar threats to the environment. For example, these sites generally exhibit contamination in various media, such as soil, surface water, or groundwater, and many landfills at Superfund sites contain hazardous waste that may contaminate nearby soil or water. Further, some have argued that landfills used for the disposal of debris created by disasters may also contain hazardous waste that could have long-term, negative environmental impacts. Consequently, concerns have been raised by various studies and environmental groups about the potential for such landfills to become Superfund sites. For instance, in the aftermath of Hurricane Katrina, a Louisiana emergency order authorized some potentially hazardous materials to be disposed of in landfills permitted to receive construction and demolition debris rather than in landfills with liners approved for such waste. Studies by a Louisiana State University research institute and an environmental engineering firm found that these categories of waste can introduce hazardous materials into landfills, increasing the likelihood of pollution. In this context, Congress asked us to review issues related to the cost to clean up the Agriculture Street Landfill Superfund site, which received debris from Hurricane Betsy in 1965, and other Superfund sites involving landfills in the Gulf Coast region where cleanup has been completed. Our objectives were to determine (1) what is known about the nature and costs of the cleanup activities at Superfund landfill sites and (2) the costs to clean up the Agriculture Street Landfill site and two additional selected Superfund landfill sites in the Gulf Coast region, and the key factors that influenced these costs.
While cleanup activities at Superfund landfills depend largely on the nature and extent of the contamination at each site, these activities generally include extraction, treatment, and containment. Extraction is the removal of contaminated substances from a site. At landfill sites, extraction may involve excavating contaminated soil and other landfill contents from the site and disposing of these materials at an off-site facility that is permitted to receive such products. According to EPA, extraction is the most expensive cleanup approach used at Superfund landfill sites. Treatment is the reduction of contaminated substances at a site and involves processing contaminated media, either on- or off-site, to reduce the toxicity, mobility, or volume of contamination. For example, EPA and responsible parties may remove groundwater from a Superfund site and chemically process it to remove contaminants at an off-site facility, or they may install a system at the site to treat the contaminated water in place. While treatment is a lower-cost alternative to extraction, it is a high-cost cleanup approach. Finally, containment involves leaving contaminated media on-site and installing measures to prevent human exposure to hazardous substances. For instance, containment at a Superfund landfill site may include installing a cover over landfill contents and establishing institutional controls, such as legal access restrictions, to limit exposure to the contaminated material. Containment is generally the least expensive method of addressing Superfund landfills. Limited data are available on the actual costs of cleanup activities conducted at Superfund landfill sites for two main reasons. First, EPA does not maintain a central tracking system for the costs of such cleanup activities. While EPA tracks its expenditures at Superfund sites, this information does not include the cost associated with each cleanup activity conducted at a site. Rather, EPA's Superfund cost information focuses on the total cost of each contract under which multiple cleanup activities may have been conducted. Second, cost data are limited because no requirements exist for responsible parties--including private companies, states, and local governments--to maintain or disclose their cleanup costs at Superfund sites. Private companies generally consider their cleanup costs as information that they have a right to keep confidential. While state and local governments are generally required to collect cleanup cost data under public accounting standards, these standards generally do not address maintenance of the data. While only limited cleanup cost data are available, we estimated that the costs to clean up three Superfund landfill sites in the Gulf Coast region--the Agriculture Street, Beulah, and Taylor Road landfill sites--ranged from about $13 million to about $55 million. This range is largely the result of differences among the sites in such factors as site geology and proximity to residential areas.
GAO-11-287R, Superfund: Information on the Nature and Costs of Cleanup Activities at Three Landfills in the Gulf Coast Region
This is the accessible text file for GAO report number GAO-11-287R
entitled 'Superfund: Information on the Nature and Costs of Cleanup
Activities at Three Landfills in the Gulf Coast Region' which was
released on February 18, 2011.
This text file was formatted by the U.S. Government Accountability
Office (GAO) to be accessible to users with visual impairments, as
part of a longer term project to improve GAO products' accessibility.
Every attempt has been made to maintain the structural and data
integrity of the original printed product. Accessibility features,
such as text descriptions of tables, consecutively numbered footnotes
placed at the end of the file, and the text of agency comment letters,
are provided but may not exactly duplicate the presentation or format
of the printed version. The portable document format (PDF) file is an
exact electronic replica of the printed version. We welcome your
feedback. Please E-mail your comments regarding the contents or
accessibility features of this document to Webmaster@gao.gov.
This is a work of the U.S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed
in its entirety without further permission from GAO. Because this work
may contain copyrighted images or other material, permission from the
copyright holder may be necessary if you wish to reproduce this
material separately.
GAO-11-287R:
United States Government Accountability Office:
Washington, DC 20548:
February 18, 2011:
The Honorable James M. Inhofe:
Ranking Member:
Committee on Environment and Public Works:
United States Senate:
Subject: Superfund: Information on the Nature and Costs of Cleanup
Activities at Three Landfills in the Gulf Coast Region:
Dear Senator Inhofe:
The Environmental Protection Agency (EPA) estimates that one in four
Americans lives within 3 miles of a contaminated site, many of which
pose serious risks to human health and the environment. The
Comprehensive Environmental Response, Compensation, and Liability Act
of 1980 (CERCLA) provided the federal government with authority to
respond to releases or threatened releases of hazardous substances and
created a trust fund to provide for certain cleanup activities. Under
CERCLA, EPA established the Superfund program to address the threats
that contaminated sites pose. Although EPA has paid for the cleanup of
many of these sites through the Superfund program, funding for these
cleanups has diminished in recent years. In 2010, we reported that
EPA's estimated costs to clean up existing contaminated sites exceed
the Superfund program's current funding levels and that some sites
have not received sufficient funding for cleanup to proceed in the
most cost-efficient manner.[Footnote 1] Additionally, in July 2009, we
reported that EPA does not collect sufficient information on the cost
of cleanup activities at Superfund sites and recommended, among other
things, that EPA assess and improve the data it collects on the status
and cost of cleanups.[Footnote 2]
EPA coordinates the cleanup of Superfund sites by identifying sites
potentially requiring cleanup action and placing eligible sites on its
National Priorities List (NPL). EPA may compel the parties responsible
for contaminating these sites to clean them up, or the agency may,
using resources from the trust fund established by CERCLA, conduct
cleanups itself and seek reimbursement from responsible parties. In
some cases, EPA may not be able to obtain reimbursement because the
agency cannot identify a responsible party or the responsible party or
parties may be insolvent or may no longer exist.
One category of contaminated sites--landfills and other waste disposal
facilities--made up more than one-third of the 1,397 sites EPA placed
on the NPL from 1983 through 2007, and EPA's expenditures at these 511
sites totaled about $3.6 billion through fiscal year 2007.[Footnote 3]
According to EPA, landfill sites on the NPL generally share similar
characteristics and present similar threats to the environment. For
example, these sites generally exhibit contamination in various media,
such as soil, surface water, or groundwater, and many landfills at
Superfund sites contain hazardous waste that may contaminate nearby
soil or water.
Further, some have argued that landfills used for the disposal of
debris created by disasters may also contain hazardous waste that
could have long-term, negative environmental impacts. Consequently,
concerns have been raised by various studies and environmental groups
about the potential for such landfills to become Superfund sites. For
instance, in the aftermath of Hurricane Katrina, a Louisiana emergency
order authorized some potentially hazardous materials to be disposed
of in landfills permitted to receive construction and demolition
debris rather than in landfills with liners approved for such waste.
Studies by a Louisiana State University research institute and an
environmental engineering firm found that these categories of waste
can introduce hazardous materials into landfills, increasing the
likelihood of pollution.[Footnote 4]
In this context, you asked us to review issues related to the cost to
clean up the Agriculture Street Landfill Superfund site, which
received debris from Hurricane Betsy in 1965, and other Superfund
sites involving landfills in the Gulf Coast region where cleanup has
been completed. Our objectives were to determine (1) what is known
about the nature and costs of the cleanup activities at Superfund
landfill sites and (2) the costs to clean up the Agriculture Street
Landfill site and two additional selected Superfund landfill sites in
the Gulf Coast region, and the key factors that influenced these costs.
To determine what is known about the nature and costs of the cleanup
activities at Superfund landfill sites, we reviewed relevant statutes
and EPA regulations, guidance, and studies. We also interviewed EPA
officials and responsible parties' representatives. To determine the
costs to clean up the three Superfund landfill sites in the Gulf Coast
region and the key factors that influenced these costs, we first
obtained data from EPA's Comprehensive Environmental Response,
Compensation, and Liability Information System, and we also
interviewed EPA officials to identify landfills (1) that are located
within 10 miles of the Gulf of Mexico, (2) that have reached
construction complete status or have been deleted from the NPL, and
(3) for which cleanup cost data are available. In addition to the
Agriculture Street Landfill in Louisiana, the Beulah and Taylor Road
landfills in Florida met these criteria. Second, we obtained cleanup
cost data from EPA and responsible parties and analyzed them to
determine the total cleanup costs and the key factors that influenced
those costs at each site. We also reviewed relevant documentation and
interviewed EPA and responsible party officials to assess the
reliability of the cleanup cost data for each site. We tried to obtain
supporting explanations and documentation to verify these data but
were unable to obtain complete information for all three sites.
Consequently, we have varying confidence in the reliability of cost
data from the three sites: while we believe that most of the data
components are sufficiently reliable for the purposes of this report,
we were unable to fully determine the reliability of some components
of the Taylor Road Landfill cleanup cost data. Nevertheless, because
these are the only available data, we included them in our estimated
cleanup costs at the site. Finally, we interviewed EPA officials and
responsible parties' representatives about the history, contamination,
cleanup activities completed, and current status of each of the three
landfills, and we visited each site. See enclosure I for a more
detailed description of our scope and methodology.
We conducted our work from April 2010 to February 2011 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 objectives and to discuss any limitations in our
work. We believe that the information and data obtained, and the
analysis conducted, provide a reasonable basis for any findings and
conclusions in this product.
Background:
Under the Resource Conservation and Recovery Act of 1976, as amended,
(RCRA), EPA regulates hazardous solid wastes from cradle to grave and
may authorize a state's hazardous waste program to operate in lieu of
the federal RCRA program. Specifically, EPA regulations provide
standards for the generation; transportation; and treatment, storage,
and disposal of hazardous wastes. EPA monitors compliance through,
among other things, facility inspections, and may exercise a number of
administrative and civil actions to bring a facility into compliance.
However, under RCRA, nonhazardous solid waste is predominantly
regulated by state and local governments. Specifically, states develop
state solid waste programs and ensure compliance through permits and
other approval systems. EPA promulgates guidelines for state solid
waste management plans and has established minimum design and
operating criteria for municipal solid waste disposal facilities
(generally referred to as landfills). For instance, EPA regulations
generally provide that landfills must comply with groundwater
monitoring and other requirements. Although RCRA authorizes EPA to
require facility owners or operators to address certain environmental
problems at their facilities, in general, RCRA provides EPA with
limited authority to address environmental problems at solid waste
landfills.
When landfills and other contaminated sites release or threaten to
release hazardous substances into the environment, EPA may use its
authorities under CERCLA to clean up such sites under the Superfund
program. Contaminated sites may result from a number of activities,
including when a facility does not comply with EPA regulations or when
a facility was active before RCRA was enacted in 1976. The Superfund
cleanup process begins when a potentially contaminated site is
discovered or EPA is notified of possible releases of hazardous
substances that may threaten human health or the environment.
Citizens, state agencies, and others may alert EPA to such threats.
EPA uses a screening system, called the Hazard Ranking System, to
numerically assess the relative potential of sites to pose a threat to
human health and the environment. Those sites with sufficiently high
scores are eligible for inclusion on the NPL. EPA assesses sites 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. As a matter of policy, EPA also
seeks concurrence from the governor of the state in which a site is
located. When EPA decides that a site warrants being listed on the
NPL, the agency proposes the listing in the Federal Register. After a
period of public comment, EPA reviews the comments and decides whether
to list the site. In general, once EPA formally 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 1 shows the process EPA typically follows, from
listing a site on the NPL through deleting it from the list.
Figure 1: Milestones and Phases of Superfund Cleanups:
[Refer to PDF for image: illustration]
Milestone: NPL Listing;
Phase: Remedial Investigation;
Phase: Feasibility Study.
Milestone: Record of Decision;
Phase: Remedial Design;
Phase: Remedial Action.
Milestone: Construction Complete;
Phase: Postconstruction Completion[A].
Milestone: Deletion from NPL.
Source: GAO analysis of EPA data.
Note: Phases of Superfund cleanups 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, EPA or a responsible party begins 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 things, and (2) a
feasibility study to evaluate various options to address the problems
identified through the remedial investigation. The culmination of
these studies, which include public participation, is a record of
decision that identifies EPA's selected remedy for addressing the
site's contamination and contains a cost estimate for implementing the
remedy. According to EPA guidance, this cost estimate is to be within
an accuracy range of minus 30 to plus 50 percent of the actual costs.
[Footnote 5] 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. Eventually, when EPA and
the state determine that no further site response is needed, EPA may
delete the site from the NPL.
In addition to remedial actions, the Superfund program conducts
removal actions--often short-term cleanups--to mitigate time-sensitive
threats to human health or the environment at both NPL sites and
unlisted sites. Because these actions typically address immediate
threats, they may occur at NPL sites before EPA issues a record of
decision that identifies its selected remedy for the site. 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.
Landfill sites that are placed on the NPL are generally large and
contain a variety of contaminants, which may interact with the
environment in three main ways. First, precipitation or liquid waste
in a landfill can interact with other materials in the landfill to
form a liquid called leachate, which can travel through soils and into
groundwater. Second, surface water, such as rainfall, can run through
a landfill and carry chemicals from the landfill contents into nearby
lakes, streams, or wetlands. Third, the degradation of landfill
contents produces landfill gas, which generally contains methane--
sometimes in potentially explosive concentrations--carbon dioxide,
nitrogen, and other toxic contaminants. Figure 2 shows how landfill
sites can present such threats to human health and the environment.
Figure 2: Threats Landfill Sites Can Present to Human Health and the
Environment:
[Refer to PDF for image: illustration]
The illustration depicts the following:
Landfill contents;
Groundwater table;
Release mechanism:
* Leaching;
* Surface runoff;
* Dust and landfill gas.
Source: GAO analysis.
[End of figure]
In addition, many landfills listed on the NPL began operating before
the publication of RCRA regulations that govern the disposal of
hazardous (1980) and nonhazardous (1979) waste. As a result, these
landfills generally accepted and codisposed of nonhazardous wastes--
including household yard and food waste and commercial plastics,
glass, and metals--and hazardous wastes, but EPA officials said that
records documenting the various materials that were disposed of in
these landfills are limited. Further, according to EPA officials,
these landfills generally did not meet current federal landfill
requirements, such as location restrictions and the inclusion of
systems and other features to prevent contamination.
Further, because the emergency nature of disaster response efforts may
result in the disposal of hazardous products into landfills that are
not equipped to safely receive them, concerns have been raised by
academic studies as well as community and environmental groups about
the potential for landfills containing disaster debris to contaminate
the surrounding environment and become Superfund sites. For instance,
in the aftermath of Hurricane Katrina, a Louisiana emergency order
authorized some potentially hazardous materials, including furniture,
carpeting, painted or stained lumber from demolished buildings, and
"incidental asbestos-contaminated waste that cannot be extracted from
demolition debris," to be disposed of in "construction and demolition"
debris landfills rather than in landfills with liners approved for
such waste. Studies by a Louisiana State University research institute
and an environmental engineering firm found that these categories of
waste can introduce hazardous materials into landfills, increasing the
likelihood of pollution.[Footnote 6] In 2007, we also reported that
EPA conducted a technical analysis of one of these landfills, the
Gentilly Landfill, in response to concerns that federal agencies could
become liable to pay cleanup costs if the landfill were to become a
Superfund site. EPA's report concluded that there is no way to protect
against Superfund liability absolutely--particularly for a landfill--
and that the use of the landfill appeared to be consistent with the
types and volumes of wastes for which it was designed and permitted by
the state.
Cleanup Activities at Superfund Landfill Sites Depend Largely on the
Nature and Extent of Contamination, and Limited Data Are Available on
the Costs of These Activities:
While cleanup activities at Superfund landfills depend largely on the
nature and extent of the contamination at each site, these activities
generally include extraction, treatment, and containment. Extraction
is the removal of contaminated substances from a site. At landfill
sites, extraction may involve excavating contaminated soil and other
landfill contents from the site and disposing of these materials at an
off-site facility that is permitted to receive such products.
According to EPA, extraction is the most expensive cleanup approach
used at Superfund landfill sites. Treatment is the reduction of
contaminated substances at a site and involves processing contaminated
media, either on-or off-site, to reduce the toxicity, mobility, or
volume of contamination. For example, EPA and responsible parties may
remove groundwater from a Superfund site and chemically process it to
remove contaminants at an off-site facility, or they may install a
system at the site to treat the contaminated water in place. While
treatment is a lower-cost alternative to extraction, it is a high-cost
cleanup approach. Finally, containment involves leaving contaminated
media on-site and installing measures to prevent human exposure to
hazardous substances. For instance, containment at a Superfund
landfill site may include installing a cover over landfill contents
and establishing institutional controls, such as legal access
restrictions, to limit exposure to the contaminated material.
Containment is generally the least expensive method of addressing
Superfund landfills.
EPA selects the appropriate cleanup activities for each Superfund
landfill site based on the nature and extent of contamination at the
site. Generally, EPA selects extraction when low to moderate volumes
of highly mobile or highly toxic contamination exist at the
site.[Footnote 7] For example, EPA may identify severely contaminated
soil or landfill contents that must be removed from the site to
eliminate threats they pose to human health and the environment. EPA
generally selects treatment when low to moderate volumes of
contaminated material exist in a discrete, accessible location at the
site. For example, treatment may be used to clean up small bodies of
surface water, including on-site ponds or lagoons, but treatment is
not a practical cleanup activity for contamination in large bodies of
surface water, such as rivers or streams. Containment is generally
used when contaminants at the site pose a low-level, long-term threat.
According to EPA guidance, containment is often the most appropriate
cleanup activity for contamination at Superfund landfill sites because
landfills generally cover large areas and include a variety of
contaminants, which often make extraction and treatment impractical.
Limited data are available on the actual costs of cleanup activities
conducted at Superfund landfill sites for two main reasons. First, EPA
does not maintain a central tracking system for the costs of such
cleanup activities. While EPA tracks its expenditures at Superfund
sites, this information does not include the cost associated with each
cleanup activity conducted at a site. Rather, EPA's Superfund cost
information focuses on the total cost of each contract under which
multiple cleanup activities may have been conducted. EPA collects and
maintains this information for use as evidence of the agency's
expenditures when seeking reimbursement from a responsible party at a
particular site. Further, we have previously reported on weaknesses in
EPA's data on the cost of cleanups at Superfund sites.[Footnote 8] In
2009, we found that EPA's data on the status and cost of Superfund
cleanups were not consistently comprehensive, reliable, or capable of
being aggregated to provide clear program-wide information, and we
recommended, among other things, that EPA assess and improve the data
it collects on the status and cost of cleanups. In July 2010, EPA
officials said they were studying how best to improve the
comprehensiveness and reliability of their Superfund data and were
considering options for aggregating cost and other data that would be
of most use to the Congress as well as how to best communicate that
data. Second, cost data are limited because no requirements exist for
responsible parties--including private companies, states, and local
governments--to maintain or disclose their cleanup costs at Superfund
sites. Private companies generally consider their cleanup costs as
information that they have a right to keep confidential. While state
and local governments are generally required to collect cleanup cost
data under public accounting standards, these standards generally do
not address maintenance of the data. According to EPA officials, the
agency obtains limited information on the costs of cleanup activities
that responsible parties fund at Superfund sites. Specifically, EPA
obtains cost information from responsible parties on (1) estimated
costs to conduct the remedy selected in the record of decision, (2)
annual costs to maintain the selected remedy after construction
completion, and (3) the costs of any fines or payments made to the
federal government.
Although cost data are limited, we identified several major components
of Superfund landfill site cleanup costs: pre-record of decision
costs, capital costs, annual operations and maintenance costs, and
periodic costs.[Footnote 9] As shown in figure 3, the major components
of the costs to clean up Superfund landfill sites correspond with the
phases and milestones of the Superfund cleanup process. More
specifically, pre-record of decision costs are costs associated with
early activities that occur before the record of decision is issued,
such as the costs of certain studies and investigations as well as any
removal actions that occur during this time. Capital costs are costs
for activities required to implement the selected remedy. These costs
include all labor, equipment, materials, and professional and
technical services associated with construction activities, such as
installation of a groundwater treatment system. Annual operations and
maintenance costs are costs for postconstruction activities, such as
soil or groundwater monitoring, that ensure or verify the continued
effectiveness of the selected remedy. The costs of these activities
are generally estimated on an annual basis. Finally, periodic costs
are costs for activities that occur only every few years after the
remedy has been selected and documented in the record of decision.
Periodic costs may be incurred for either construction activities,
such as equipment replacement, or periodic operations and maintenance
activities, such as occasional site reviews.
Figure 3: Milestones, Phases, and Major Cost Components of Cleanups at
NPL Sites:
[Refer to PDF for image: illustration]
Milestone: NPL Listing;
Phase: Remedial Investigation;
Phase: Feasibility Study;
Cost Components: Pre-record of decision costs.
Milestone: Record of Decision;
Phase: Remedial Design;
Phase: Remedial Action;
Cost Components: Capital costs; Periodic costs.
Milestone: Construction Complete;
Phase: Postconstruction Completion[A];
Cost Components: Annual operation and maintenance costs; Periodic
costs.
Milestone: Deletion from NPL.
Source: GAO analysis of EPA data.
[End of figure]
Although Available Cleanup Cost Data Are Limited, Estimated Cleanup
Costs for Three Gulf Coast Superfund Landfill Sites Varied Largely on
the Basis of Site-Specific Factors:
While only limited cleanup cost data are available, we estimated that
the costs to clean up three Superfund landfill sites in the Gulf Coast
region--the Agriculture Street, Beulah, and Taylor Road landfill
sites--ranged from about $13 million to about $55 million (see figure
4).[Footnote 10] This range is largely the result of differences among
the sites in such factors as site geology and proximity to residential
areas.
Figure 4: Locations of Three Gulf Coast Superfund Landfills:
[Refer to PDF for image: map of the Gulf Coast]
The map depicts the location of:
Agricultural Street Landfill (Louisiana);
Beulah Landfill (Florida);
Taylor Road Landfill (Florida).
Source: Mapinfo (map).
[End of figure]
Emergency Removal Actions Represented Almost One-Half of the $55
Million Cleanup Costs at the Agriculture Street Landfill Superfund
Site:
EPA spent about $55 million to clean up the Agriculture Street
Landfill Superfund site in New Orleans, Louisiana. Because EPA found
that extensive lead contamination in soil at the site posed an
immediate risk to nearby residents, the agency completed most of its
cleanup activities as removal actions. We estimated that these
actions--which included removing contaminated playground equipment,
excavating contaminated soil, placing a landfill cap, and installing
clean soil--represented approximately 50 percent of EPA's cleanup
costs at the site. Available documentation shows that the remaining
costs were related to litigation and community relations activities,
among other things.
The City of New Orleans operated the Agriculture Street Landfill as a
disposal area for household and commercial waste from about 1909 until
the late 1950s. Elevations at the landfill range from 5 feet below to
10 feet above sea level, and a layer of clay serves as the base of the
landfill. While little information exists regarding what early
operators deposited in the landfill, available information suggests
that the landfill received municipal garbage, construction debris, and
incinerator ash. In addition, the area was routinely sprayed with DDT,
a persistent organic chemical--and a probable human carcinogen
according to EPA--from the 1940s until 1957, when the city constructed
new incinerators to manage its waste and ended operations at the
Agriculture Street Landfill. The landfill was reopened after Hurricane
Betsy in 1965 for 1 year to receive debris from destroyed buildings
and ash from municipal incinerators. In the 1970s and continuing into
the late 1980s, portions of the site were developed with private and
public housing units, an elementary school, a community center, a
small business complex, and a recreational building. Following health
concerns among residents in the area, EPA initiated investigations at
the site in 1986, ultimately identifying elevated levels of lead,
arsenic, and carcinogenic polycyclic aromatic hydrocarbons.[Footnote
11] Analyses of the health effects of these contaminants led EPA to
place the site on the NPL in 1994.
While assessing the site for placement on the NPL, EPA initiated
emergency removal actions to prevent exposure to the contaminants
found at the site. Specifically, EPA installed a fence to restrict
public access to an undeveloped portion of the site and removed
contaminated playground equipment and soil from a children's play area
located at the on-site community center. EPA's site investigations
found that lead concentrations in soil at the children's play area
were well above the current screening level--an EPA-defined level of
contamination that is protective of public health--for lead in soil.
Figure 5 shows where, prior to EPA's cleanup activities, lead
concentrations existed above this screening level in surface soil at
the site.
Figure 5: Lead Concentrations in Surface Soil at the Agriculture
Street Landfill:
[Refer to PDF for image: illustrated map]
The map depicts the following:
Lead concentration, above EPA screening level;
Original landfill;
Undeveloped area;
Elementary school and playground.
Source: GAO analysis.
[End of figure]
While performing these emergency removal actions, EPA conducted
additional site investigations and determined that the following
cleanup activities were necessary to address remaining threats at the
site: excavation of contaminated soil from residential and undeveloped
areas; addition of clean soil; placement of a landfill cap and grass;
and replacement of fences, driveways, and sidewalks. Additionally, EPA
determined that removal actions, rather than remedial actions, were
the appropriate mechanism for conducting the remaining cleanup
activities at the site because contamination at the site posed an
immediate risk to those living and working nearby.[Footnote 12] EPA
completed these cleanup activities at the Agriculture Street Landfill
Superfund site in 2001 and designated the site as construction
complete in 2002. In 2003 and 2008, EPA conducted reviews of the site
and found that the cleanup actions were functioning as intended and
that EPA's actions at the site remained protective of human health and
the environment. When we met with EPA officials in September 2010,
they said the agency had recently initiated the process to delete the
Agriculture Street Landfill Superfund site from the NPL.
EPA officials identified the presence of a residential community on-
site as a key factor affecting the Agriculture Street site's cleanup
costs for three main reasons. First, human health risks are one of the
major factors EPA considers when evaluating a Superfund site to
determine what cleanup actions are necessary at the site, and EPA's
initial investigations found that lead in the soil posed an
unacceptable risk to residents and workers at the site. While EPA
guidance identifies the less costly alternative of containment as the
preferred remedy to address contamination at Superfund landfills, EPA
concluded that excavation of the contaminated soil was necessary to
protect those living and working on the site. Second, the presence of
residences on-site required EPA to obtain permission from homeowners
to access their properties to conduct soil tests; remove contaminated
soil and replace it with a landfill cap; and add clean soil, grass,
and other landscaping. According to EPA officials, some homeowners
were reluctant or unwilling to allow EPA and its contractors access to
their properties, and EPA incurred legal fees for activities aimed at
gaining access to these properties. Finally, the presence of a
residential community at the site required EPA to use removal actions
to address contamination in a timely manner. According to EPA
officials, because removal actions are performed before site
investigations have fully identified the extent of contamination at
the site, the time frames and scope of these actions often change,
resulting in changes to the costs of the actions. As shown in table 1,
almost 50 percent of the cleanup costs at the Agriculture Street site
were related to time-critical and non-time-critical removal actions.
Table 1: Total Estimated Costs to Clean Up Agriculture Street Landfill
Superfund Site, by Major Cost Component:
Major cost component: Pre-record of decision costs: Time-critical
playground equipment removal and fence installation;
Actual cost (nominal dollars): $303,895;
Adjusted cost (constant 2010 dollars): $405,840.
Major cost component: Pre-record of decision costs: Non-time-critical
contaminated soil removal and landfill cap placement;
Actual cost (nominal dollars): $20,981,215;
Adjusted cost (constant 2010 dollars): $25,492,749.
Major cost component: Pre-record of decision costs: Community
relations;
Actual cost (nominal dollars): $778,620;
Adjusted cost (constant 2010 dollars): $989,688.
Major cost component: Pre-record of decision costs: Litigation;
Actual cost (nominal dollars): $248,035;
Adjusted cost (constant 2010 dollars): $315,065.
Major cost component: Pre-record of decision costs: Site investigation
and testing[A];
Actual cost (nominal dollars): $5,408,063;
Adjusted cost (constant 2010 dollars): $7,343,909.
Major cost component: Pre-record of decision costs: Other support
activities[B];
Actual cost (nominal dollars): $13,586,695;
Adjusted cost (constant 2010 dollars): $19,041,284.
Major cost component: Capital costs;
Actual cost (nominal dollars): $0;
Adjusted cost (constant 2010 dollars): $0.
Major cost component: Annual operations and maintenance costs;
Actual cost (nominal dollars): $0;
Adjusted cost (constant 2010 dollars): $0.
Major cost component: Periodic costs[B];
Actual cost (nominal dollars): $1,509,237;
Adjusted cost (constant 2010 dollars): $1,690,854.
Major cost component: Total cleanup costs;
Actual cost (nominal dollars): $42,815,760;
Adjusted cost (constant 2010 dollars): $55,279,391.
Source: GAO analysis of EPA data.
Note: Component costs may not add to totals because of rounding. See
enclosure I for additional information on the reliability of the
available cost data for the Agriculture Street Landfill.
[A] This amount includes the costs of site investigations that EPA
conducted in 1986 prior to listing the site on the NPL because EPA
considers these costs as part of its total site cleanup costs.
[B] This amount includes EPA's indirect costs, which are costs for
general administrative, management, and support activities that
indirectly support site-specific cleanup activities.
[End of table]
Because EPA did not conduct remedial actions or operations and
maintenance activities at the site, the agency did not incur any
capital costs or annual operations and maintenance costs. Rather, EPA
spent the remaining 50 percent of its cleanup costs on other
activities, such as site investigations, community relations, and
litigation, to support the removal actions, and periodic activities,
such as reviews of the site and legal actions to seek reimbursement
from the parties responsible for contaminating the landfill. According
to EPA documents, because the responsible party for the site--the City
of New Orleans--was unable to reimburse EPA for these cleanup
activities, EPA used funds from the CERCLA-established trust fund to
pay for cleanup of this site.
Cleanup of the Beulah Landfill Superfund Site Cost About $12.5
Million, in Part, because It Included Costs to Formally Close the
Landfill:
We estimated that cleanup of the Beulah Landfill Superfund site near
Pensacola, Florida, cost Escambia County--the responsible party for
the site--about $12.5 million.[Footnote 13] The cleanup activities we
identified included formally closing two landfill areas that lacked
caps to prevent storm water from mingling with the landfill contents.
According to Escambia County officials, a major component of the
closure costs was the clay and synthetic material needed to adequately
cap these landfill areas. Available county documents show that these
cap materials cost approximately $4 million; the county spent the
remaining $8.5 million on, among other things, management and
oversight of the landfill closure as well as annual operations and
maintenance activities.
The Beulah Landfill Superfund site operated as an unlined, municipal
landfill from 1966 through 1984, when the state of Florida raised
concerns about contamination and ordered the county to close the
landfill. A creek divides the site into northern and southern waste
disposal areas and merges with another creek that empties into Perdido
Bay and, eventually, the Gulf of Mexico, as shown in figure 6. During
the municipal landfill's operation, the southern area received
domestic septage and wastewater treatment sludges in addition to
municipal waste.[Footnote 14] These wastes were deposited as much as
35 feet below the surface, and surface elevations at the landfill
range from 25 to 65 feet above sea level. After the county ended all
landfill operations in 1984, it covered the northern area with a layer
of soil but left the southern area uncovered. EPA conducted testing at
the site in 1985, discovered that some contaminants exceeded
regulatory standards for soil and groundwater, and placed the Beulah
Landfill on the NPL in 1990.
Figure 6: Bodies of Water Located Near the Beulah Landfill:
[Refer to PDF for image: illustrated map]
The map depicts the following bodies of water:
Coffee Creek;
Eleven Mile Creek;
Perdido Bay;
Pensacola Bay;
Gulf of Mexico.
Source: GAO analysis.
[End of figure]
EPA identified Escambia County as one of several parties responsible
for contaminating the site, and under an agreement among these
parties, the county was responsible for cleaning up the site. In 1992,
the county initiated its remedial investigation and feasibility study,
which included testing samples from various media across the site.
These tests found low levels of soil and surface water contamination
and identified pentachlorophenol in groundwater as a contaminant of
concern.[Footnote 15] However, the site risk assessment found that the
contaminants did not pose an unacceptable risk to human health or the
environment because, among other things, no one lived in the immediate
vicinity of the landfill and animals had limited exposure to the
contaminants. As a result, EPA issued a record of decision in 1993
that only required Escambia County to perform regular groundwater
monitoring to ensure the site risks remained below regulatory
standards and to proceed with its plans to formally close the landfill
in accordance with Florida's state regulations.
In 1994, Escambia County initiated activities to close the Beulah
Landfill. In an effort to save money, the county used inmate labor to
conduct activities such as clearing the landfill areas of trees and
other vegetation and constructing a berm to prevent surface water from
running into the northern section of the landfill. However, the county
realized it lacked the labor and equipment resources to complete the
closure of the landfill in a timely manner and hired a contractor to
conduct the remaining closure activities--installing a landfill gas
management system, capping the northern and southern landfill areas,
and constructing a storm water management system for the southern
area. In April 1998, EPA determined that no further actions were
necessary at the site, and in June 1998, after a period of public
comment, it formally deleted the landfill from the NPL. Currently, a
model airplane park, including runways and a covered area with picnic
tables, occupies the northern portion of the site. Upon learning of
the landfill's deletion from the NPL, local model airplane enthusiasts
began working with EPA and Escambia County to design the recreational
facility, and these groups continue to collaborate today to ensure the
recreational activities do not affect the integrity of the cleanup
activities conducted at the site.
According to county officials, a key factor contributing to the costs
to clean up the Beulah Landfill Superfund site was the clay and
synthetic material needed to adequately cap the northern and southern
landfill areas. These officials said that the county had initially
planned to use clay and other soils located on-site to cap the
landfill; however, testing of on-site soils revealed that they did not
meet the state of Florida's requirements for landfill cap materials.
As a result, the county paid over $1.5 million for clay and other
materials to cap the northern landfill area--the costs of which
included its transportation to the site--and about $2.5 million for a
synthetic cover and related materials to cap the more severely
contaminated southern area. Escambia County spent the remaining $8.5
million on, among other things, landfill gas and storm water
management systems, management and oversight of the landfill closure,
and annual operations and maintenance activities. Table 2 shows the
allocation of these cleanup costs--in nominal dollars and adjusted for
inflation--across the major Superfund cost components.
Table 2: Total Estimated Costs to Clean Up Beulah Landfill Superfund
Site, by Major Cost Component:
Major cost component: Pre-record of decision costs;
Actual cost (nominal dollars): $380,810;
Adjusted cost (constant 2010 dollars): $538,055.
Major cost component: Capital costs: Closure permit fees;
Actual cost (nominal dollars): $750;
Adjusted cost (constant 2010 dollars): $992.
Major cost component: Capital costs: Site assessment and engineering
services;
Actual cost (nominal dollars): $699,962;
Adjusted cost (constant 2010 dollars): $911,313.
Major cost component: Capital costs: Closure activities conducted by
county inmate labor;
Actual cost (nominal dollars): $1,472,275;
Adjusted cost (constant 2010 dollars): $1,923,964.
Major cost component: Capital costs: Closure activities conducted by
contractor;
Actual cost (nominal dollars): $6,189,212;
Adjusted cost (constant 2010 dollars): $7,966,441.
Major cost component: Capital costs: Other testing and monitoring
during closure;
Actual cost (nominal dollars): $382,929;
Adjusted cost (constant 2010 dollars): $509,268.
Major cost component: Annual operations and maintenance costs[A];
Actual cost (nominal dollars): $64,500;
Adjusted cost (constant 2010 dollars): $75,738.
Major cost component: Periodic costs;
Actual cost (nominal dollars): $580,137;
Adjusted cost (constant 2010 dollars): $769,957.
Major cost component: Total cleanup costs;
Actual cost (nominal dollars): $9,770,575;
Adjusted cost (constant 2010 dollars): $12,695,729.
Source: GAO analysis of Escambia County data.
Note: Component costs may not add to totals because of rounding. See
enclosure I for additional information on the limitations of the
available cleanup cost data for the Beulah Landfill.
[A] Escambia County completed closure of the Beulah Landfill in 1999,
after EPA deleted the site from the NPL. As a result, these costs
represent the county's estimated costs to operate and maintain the
site for 1 year after its closure.
[End of table]
Since EPA deleted the site from the NPL in 1998, the county has spent
almost $700,000 on activities that ensure the site remains protective
of human health and the environment. For instance, a 2003 EPA review
of the site identified contamination in a nearby creek, and the state
required the county to conduct studies to determine whether Beulah
Landfill was the source of the contamination. These studies cost the
county approximately $50,000 and concluded that the most likely source
of contamination in the creek was an industrial site located upstream
of the landfill.
Cleanup of the Taylor Road Landfill Superfund Site Cost at Least $19.7
Million, and Site Geology Influenced These Costs:
According to available documents, Hillsborough County, Florida, spent
at least $19.7 million to clean up the Taylor Road Landfill site
outside Tampa.[Footnote 16] The county official responsible for the
landfill said that the site's geology influenced these cleanup costs
because the landfill is located above an aquifer that residents in the
area were using for drinking water when it became contaminated.
Hillsborough County documents show that cleaning up the aquifer
contamination cost approximately $6.1 million and that the remaining
$13.6 million paid for the design and installation of a landfill cap
and landfill gas management system, as well as regular monitoring and
maintenance of the site.
Hillsborough County began operating the Taylor Road Landfill in 1976
as the main landfill in the county for residential, commercial, and
industrial waste. The landfill was constructed without a liner or
leachate collection system, and it is located directly above the
Floridan Aquifer, which was a primary source of drinking water for
area residents. A layer of sand serves as the base of the landfill,
and this permeable layer allows landfill contents to seep into the
underlying aquifer. EPA documents show that the landfill received a
total of 620,000 tons of waste, including an unknown quantity of
hazardous waste. According to one Hillsborough County official, the
landfill received medical waste from nearby hospitals and medical
clinics, and, at one point, the body of a circus elephant was disposed
of in the landfill.
In 1979, EPA tested water samples from wells on-site and nearby the
Taylor Road Landfill as part of a nationwide groundwater sampling
program and found concentrations of some metals and volatile organic
compounds that exceeded regulatory standards. In early 1980, the
county ended operations at the landfill and began delivering bottled
water to 180 homes and businesses in the immediate vicinity of the
landfill. In October 1980, according to EPA documents, EPA filed suit
against Hillsborough County alleging that groundwater contamination at
the landfill site violated RCRA and the Safe Drinking Water Act, and
EPA amended the lawsuit in April 1983 adding a complaint under CERCLA.
The lawsuit resulted in a consent decree between EPA and Hillsborough
County that required the county to perform specific cleanup activities-
-upgrade the landfill cap, construct ditches to manage storm water,
install a methane gas control system, monitor groundwater, and offer
to connect nearby residents to county water lines--at the
site.[Footnote 17] While finalizing the consent decree, EPA was in the
process of establishing the newly created Superfund program, and the
agency began collecting the information it needed to pursue a
Superfund cleanup of the site. In September 1983, EPA placed the
Taylor Road Landfill on the original NPL and, eventually, identified
Hillsborough County as the responsible party for the site.
While completing the cleanup activities required by its 1983 consent
decree with EPA, Hillsborough County initiated the remedial
investigation and feasibility study for the site, which found that
additional cleanup activities were necessary to prevent contaminated
groundwater from migrating to nearby areas. Consequently, EPA issued a
record of decision in 1995 describing the remedial actions
Hillsborough County would take, including (1) restricting property
owners from constructing drinking water wells that would extract water
affected by the landfill, (2) increasing the frequency of groundwater
monitoring for wells on-site and nearby, (3) extending county water
lines to about 20 additional residences near the site, (4) installing
additional groundwater monitoring wells as needed, and (5) collecting
and treating contaminated groundwater if testing showed an increase in
contaminant levels. Hillsborough County completed the required cleanup
activities during the next few years, and in 1999 EPA designated the
Taylor Road Landfill Superfund site as construction complete.
Although, as of January 2011, EPA had not deleted the site from the
NPL, the agency selected Hillsborough County for the 2010 Excellence
in Site Reuse award for its creative reuse of the site, which
currently houses county offices, a recycling center, and a flying
field for a local model airplane club, among other things.
According to the Hillsborough County official responsible for cleanup
of the site, the Taylor Road Landfill site's geology largely
influenced its cleanup costs because a significant portion of cleanup
activities conducted at the landfill were related to contamination of
the Floridan Aquifer. Specifically, Hillsborough County spent
approximately $2 million on studies of groundwater contamination,
about $1.8 million to design and construct water lines to provide
county water to residents affected by the contaminated aquifer, about
$2.3 million on water bills for those residents, and about $75,000 to
install groundwater monitoring wells. Hillsborough County spent about
$5.5 million to install and maintain a landfill cap, storm water
management system, and landfill gas management system. According to
county documents, the remaining $8.1 million paid for activities such
as the remedial investigation and feasibility study and regular
monitoring and maintenance of the site. Although we were unable to
fully determine the reliability and completeness of some of the data
we used to estimate the Taylor Road Landfill cleanup costs, we
included them in our analysis because these are the only available
data. See table 3 for the allocation of these estimated costs--in
nominal dollars and adjusted for inflation--across the major
components of Superfund cleanup costs.
Table 3: Total Estimated Costs to Clean Up Taylor Road Landfill
Superfund Site, by Major Cost Component:
Pre-record of decision costs:
Major cost component: Water for affected residents;
Actual cost (nominal dollars): $703,396;
Adjusted cost (constant 2010 dollars): $1,096,371.
Major cost component: Studies of water quality;
Actual cost (nominal dollars): $873,274;
Adjusted cost (constant 2010 dollars): $2,019,691.
Major cost component: Design and construction of new water lines;
Actual cost (nominal dollars): $866,654;
Adjusted cost (constant 2010 dollars): $1,713,890.
Major cost component: Design and construction of landfill cap and
methane gas system;
Actual cost (nominal dollars): $1,187,469;
Adjusted cost (constant 2010 dollars): $2,203,946.
Major cost component: Improvements to landfill gas and storm water
management systems;
Actual cost (nominal dollars): $1,147,314;
Adjusted cost (constant 2010 dollars): $1,661,284.
Major cost component: Payroll, equipment, and other supplies;
Actual cost (nominal dollars): $1,985,493;
Adjusted cost (constant 2010 dollars): $3,191,176.
Major cost component: Litigation;
Actual cost (nominal dollars): $508,000;
Adjusted cost (constant 2010 dollars): $973,572.
Major cost component: Remedial investigation and feasibility study;
Actual cost (nominal dollars): $1,126,266;
Adjusted cost (constant 2010 dollars): $1,526,333.
Capital costs:
Major cost component: Installation and repair of groundwater
monitoring wells;
Actual cost (nominal dollars): $58,947;
Adjusted cost (constant 2010 dollars): $75,069.
Major cost component: Design and construction of water lines to
additional homes;
Actual cost (nominal dollars): $35,108;
Adjusted cost (constant 2010 dollars): $44,710.
Major cost component: Annual operations and maintenance costs;
Actual cost (nominal dollars): $1,112,328;
Adjusted cost (constant 2010 dollars): $1,282,764.
Periodic costs:
Major cost component: Water for affected residents;
Actual cost (nominal dollars): $998,626;
Adjusted cost (constant 2010 dollars): $1,181,482.
Major cost component: Improvements to landfill gas and storm water
management systems;
Actual cost (nominal dollars): $1,373,896;
Adjusted cost (constant 2010 dollars): $1,613,274.
Major cost component: EPA reimbursement for response and oversight
costs;
Actual cost (nominal dollars): $673,186;
Adjusted cost (constant 2010 dollars): $869,907.
Major cost component: Miscellaneous professional services and supplies;
Actual cost (nominal dollars): $215,042;
Adjusted cost (constant 2010 dollars): $265,036.
Total cleanup costs:
Actual cost (nominal dollars): $12,864,999;
Adjusted cost (constant 2010 dollars): $19,718,504.
Source: GAO analysis of Hillsborough County documents.
Note: Component costs may not add to totals because of rounding. See
enclosure I for additional information on the limitations of the
available cleanup cost data for the Taylor Road Landfill.
[End of table]
We provided relevant sections of this report to EPA, Escambia County,
and Hillsborough County for review and incorporated their technical
comments, as appropriate.
We are sending copies of this report to appropriate congressional
committees, the Administrator of EPA, and other interested parties. In
addition, this report will be available at no charge on the GAO Web
site at [hyperlink, http://www.gao.gov].
If you or your staff have any questions about this report, please
contact me at (202) 512-3841 or trimbled@gao.gov. Contact points for
our Offices of Congressional Relations and Public Affairs may be found
on the last page of this report. Key contributors to this report
include Vince Price (Assistant Director), Avrum Ashery, Kevin Bray,
Shareea Butler, Nancy Crothers, Barbara El Osta, Kristin Hughes, and
Kirsten Lauber.
Sincerely yours,
Signed by:
David C. Trimble:
Acting Director, Natural Resources and Environment:
[End of section]
Enclosure I: Objectives, Scope, and Methodology:
This enclosure provides information on the scope of work and
methodology used to determine (1) what is known about the nature and
costs of the cleanup activities at Superfund landfill sites and (2)
the costs to clean up the Agriculture Street Landfill site and two
additional selected Superfund landfill sites in the Gulf Coast region,
and the key factors that influenced these costs. It also provides
information on the limitations of the cost data presented in this
report.
To determine what is known about the nature and costs of the cleanup
activities at Superfund landfill sites, we reviewed relevant statutes
and EPA regulations, guidance, and studies. We also interviewed
officials from EPA's Office of Solid Waste and Emergency Response and
representatives of responsible parties about cleanup activities that
occur at Superfund landfill sites. In addition, we conducted a
literature review to identify available information on the costs of
cleanup activities at Superfund landfill sites. Specifically, we
reviewed government agency publications, academic research databases,
and news media articles.
To determine the costs to clean up the three Superfund landfill sites
in the Gulf Coast region and the key factors that influenced these
costs, we analyzed data from EPA's Comprehensive Environmental
Response, Compensation, and Liability Information System and
interviewed officials from EPA's Region 4 Superfund Division in
Atlanta, Georgia, and EPA's Region 6 Superfund Division in Dallas,
Texas, to identify landfills (1) that are located within 10 miles of
the Gulf of Mexico, (2) that have reached construction complete status
or have been deleted from the National Priorities List (NPL), and (3)
for which cleanup cost data are available.[Footnote 18] We found that,
in addition to the Agriculture Street Landfill in New Orleans,
Louisiana, the Beulah and Taylor Road landfills in Florida met these
criteria.
We obtained cleanup cost data from EPA Region 6 for the Agriculture
Street Landfill; from Escambia County, Florida, for the Beulah
Landfill; and from Hillsborough County, Florida, for the Taylor Road
Landfill. We analyzed the available data to determine the cost to
clean up each site as follows.
Agriculture Street Landfill. To determine the costs to clean up this
site, we used data from EPA's Superfund Cost Recovery Package Imaging
and On-Line System (SCORPIOS) for site costs incurred from 1986
through May 14, 2010. The SCORPIOS data provided specific dates of
when EPA incurred costs, but for some costs, especially those related
to cleanup activities performed by contractors, the data did not
provide detailed information on why EPA incurred the costs. As a
result, we used EPA project status reports and contactor-generated
project summary reports to obtain more detailed information on the
reasons for incurring certain costs. To determine site costs in
constant 2010 dollars, we applied the Bureau of Economic Analysis's
Fiscal Year Chain-Weighted Gross Domestic Product Price Index to
SCORPIOS data for the particular fiscal year in which EPA incurred the
costs.
Beulah Landfill. We primarily used data from a county-generated
summary report to determine the costs to clean up the site. To
determine the completeness and reasonableness of the data in this
report, we compared it with information from multiple sources.
Specifically, we used documents from the state of Florida for cost
data on permit fees; contractor-generated documents for cost data on
site assessments, closure activities, and site testing and monitoring;
EPA documents, including the 5-year review reports for the site, for
cost data on annual operations and maintenance costs; and county and
EPA documents for cost data on fines the county paid to EPA. We found
that these sources corroborated the information in the county-
generated summary report. We applied the Bureau of Economic Analysis's
Calendar Year Chain-Weighted Gross Domestic Product Price Index for
the particular calendar year in which the county incurred the costs
for each activity to determine site costs in constant 2010 dollars.
Taylor Road Landfill. To determine the costs to clean up this site, we
primarily used data from Hillsborough County's Financial Accounting
and Management Information System (FAMIS) for site costs incurred from
1980 through September 30, 2010. However, FAMIS data from fiscal years
1980 through 1994 were aggregated to include costs for activities at
the Taylor Road Landfill and a separate landfill nearby--the
Hillsborough Heights Landfill. To determine the portion of these
aggregated costs that could be allocated to the Taylor Road Landfill,
we multiplied each annual cost figure by the percentage of total
acreage represented by the Taylor Road Landfill.[Footnote 19] In
addition, the 1980 through 1994 FAMIS data included costs related to
payroll, professional services, equipment, and other supplies but did
not include costs for construction activities that occurred at the
site during that time. Consequently, we used county-generated site
summary reports for data on costs incurred for construction activities
that occurred from 1980 through the end of fiscal year 1994. Because
of changes in the county accounting system, we were unable to obtain
FAMIS data for costs incurred from fiscal year 1995 through August
1998.[Footnote 20] However, EPA and county documents indicate that few
cleanup activities occurred during that time. We also used data from
EPA 5-year review reports to identify some of the annual operations
and maintenance costs for the site, and we used data from legal
documents for fees the county paid EPA to reimburse the agency for its
response and oversight costs at the site. To determine these estimated
site costs in constant 2010 dollars, we applied the Bureau of Economic
Analysis's Fiscal Year Chain-Weighted Gross Domestic Product Price
Index for the particular fiscal year in which the county incurred the
costs.
To allocate the total cleanup costs for each site across the major
Superfund cost components, we used the date of the particular cleanup
activity for which costs were incurred. For example, we identified
costs for activities performed after NPL listing and before record of
decision issuance as pre-record of decision costs. To distinguish
periodic costs from capital costs and annual operations and
maintenance costs, we analyzed the nature of the activity for which
the costs were incurred. Finally, we interviewed EPA and responsible
party officials and analyzed the cleanup costs to identify the key
factors that influenced costs at each selected site.
We also reviewed relevant documentation and interviewed EPA and
responsible party officials to assess the reliability of the cleanup
cost data for each site. We tried to obtain supporting explanations
and documentation to verify these data but were unable to obtain
complete information for all three sites. On the basis of these
efforts, we have varying confidence in the reliability of cost data
from the three sites. More specifically, to assess the reliability of
the cost data for the Agriculture Street Landfill, we interviewed EPA
Region 6 officials about data quality control procedures and reviewed
relevant documentation, such as the SCORPIOS user manual, and
determined that the cost data were sufficiently reliable for the
purposes of this report. Next, to assess the reliability of the cost
data for the Beulah Landfill, we reviewed Escambia County documents
that contained cleanup cost data and compared the information in these
documents with EPA-and contractor-generated documents and with
information we obtained from Escambia County officials to determine
data consistency and reasonableness, but we were unable to use these
documents to determine the completeness of the cost information from
Escambia County. As a result, the potential exists for our estimated
cleanup costs for the site to be incomplete. However, based on these
efforts, we believe the information we obtained is sufficiently
reliable for this report. Last, to assess the reliability of cost data
for the Taylor Road Landfill, we interviewed Hillsborough County
officials and reviewed relevant documentation from the county. On the
basis of our efforts, we were unable to fully determine the
reliability of the data on costs for payroll, professional services,
equipment, and other supplies for fiscal years 1980 through 1994. In
addition, we were unable to fully determine the reliability or
completeness of data from county-generated reports on costs incurred
during fiscal years 1995 through 1998 because we were unable to obtain
corroborating documentation. Nevertheless, because these are the only
available data, we used them to estimate the minimum amount that
Hillsborough County spent to clean up the site.
Finally, we interviewed officials from EPA Regions 4 and 6, Escambia
County, and Hillsborough County about the Agriculture Street, Beulah,
and Taylor Road landfills, respectively, to obtain information on the
history, contamination, cleanup activities completed, and current
status of the landfills, and we visited each site.
We conducted our work from April 2010 to February 2011 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 objectives and to discuss any limitations in our
work. We believe that the information and data obtained, and the
analysis conducted, provide a reasonable basis for any findings and
conclusions in this product.
[End of section]
Footnotes:
[1] GAO, 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, [hyperlink,
http://www.gao.gov/products/GAO-10-380] (Washington, D.C.: May 6,
2010).
[2] 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 15,
2009). In July 2010, EPA officials said that they were studying how
best to improve the comprehensiveness and reliability of their
Superfund data and were considering options for aggregating and
communicating Superfund cost data.
[3] These numbers do not include NPL sites that are owned and operated
by federal agencies, such as the Departments of Defense, Energy, and
the Interior.
[4] EPA efforts to manage the disposition of hurricane debris included
establishing a plan to segregate, collect, and properly dispose of
debris such as household hazardous waste and electronic waste; working
with local officials to establish collection and drop-off sites for
debris that may contain hazardous materials; and establishing debris
staging areas for sorting and categorizing household hazardous waste
that EPA and its contractors had collected.
[5] EPA, A Guide to Developing and Documenting Cost Estimates During
the Feasibility Study, Office of Solid Waste and Emergency Response
Directive 9355.0-75 (Washington, D.C., July 2000).
[6] GAO, Hurricane Katrina: EPA's Current and Future Environmental
Protection Efforts Could Be Enhanced by Addressing Issues and
Challenges Faced on the Gulf Coast, [hyperlink,
http://www.gao.gov/products/GAO-07-651] (Washington, D.C.: June 25,
2007).
[7] EPA describes "low to moderate volumes of waste" as waste masses
smaller than 100,000 cubic yards. See EPA, Conducting Remedial
Investigations/Feasibility Studies for CERCLA Municipal Landfill
Sites, Office of Solid Waste and Emergency Response Directive 9355.3-
11 (Washington, D.C., February 1991).
[8] [hyperlink, http://www.gao.gov/products/GAO-09-656].
[9] According to EPA guidance, capital, annual operations and
maintenance, and periodic costs are the major components of the costs
to construct and maintain the selected remedy for a site. See EPA
Directive 9355.0-75.
[10] Unless otherwise noted, all cleanup costs are in constant 2010
dollars. In addition, we have varying confidence in the reliability of
cost data from the three sites: while we believe that most of the data
components are sufficiently reliable for the purposes of this report,
we were unable to fully determine the reliability of some components
of the Taylor Road Landfill cleanup cost data. Nevertheless, because
these are the only available data, we included them in our estimated
cleanup costs at the site.
[11] Acute exposure to polycyclic aromatic hydrocarbons can cause red
blood cell damage and may suppress immune system function.
[12] According to EPA guidance, removal actions are typically used
where a site presents a relatively time-sensitive, noncomplex problem
that can and should be addressed relatively inexpensively, and
remedial actions are typically used to address complex site problems
that will likely require a costly, complicated response. However,
decisions regarding the use of removal or remedial actions are based
on site-specific issues, including time sensitivity, complexity, and
cost.
[13] See enclosure I for information on the limitations of available
cleanup cost data for the Beulah Landfill.
[14] Domestic septage is liquid or solid material removed from a
septic tank cesspool, portable toilet, or similar system that receives
household, noncommercial, or nonindustrial sewage.
[15] Drinking water containing pentachlorophenol may lead to liver and
kidney problems and may increase cancer risk.
[16] Because we were unable to obtain complete data on Hillsborough
County's 1994 through 1998 expenditures at the Taylor Road Landfill
Superfund site, we estimated that the county spent a minimum of $19.7
million to clean up the site. See enclosure I for more information on
the limitations of the cleanup cost data.
[17] Consent decrees are court-approved settlement agreements between
EPA and responsible parties arising from EPA enforcement actions.
[18] For the purposes of this review, we defined the Gulf Coast region
as the portions of Alabama, Florida, Louisiana, Mississippi, and Texas
that are within 10 miles of the Gulf of Mexico.
[19] According to Hillsborough County officials and documents, the
county used this same methodology to determine the amount owed to the
county by other parties EPA identified as responsible for
contamination of the Taylor Road Landfill Superfund site. However, the
officials said that this approach may result in an over-or
underestimate of costs incurred at the Taylor Road Landfill from 1980
through 1994.
[20] Hillsborough County officials told us that the county moved to a
new version of FAMIS in 1998 and did not maintain complete records
from the older version. According to the county official responsible
for managing the Taylor Road Landfill, no requirements exist for the
county to maintain such records.
[End of section]
GAO's Mission:
The Government Accountability Office, the audit, evaluation and
investigative arm of Congress, exists to support Congress in meeting
its constitutional responsibilities and to help improve the performance
and accountability of the federal government for the American people.
GAO examines the use of public funds; evaluates federal programs and
policies; and provides analyses, recommendations, and other assistance
to help Congress make informed oversight, policy, and funding
decisions. GAO's commitment to good government is reflected in its core
values of accountability, integrity, and reliability.
Obtaining Copies of GAO Reports and Testimony:
The fastest and easiest way to obtain copies of GAO documents at no
cost is through GAO's Web site [hyperlink, http://www.gao.gov]. Each
weekday, GAO posts newly released reports, testimony, and
correspondence on its Web site. To have GAO e-mail you a list of newly
posted products every afternoon, go to [hyperlink, http://www.gao.gov]
and select "E-mail Updates."
Order by Phone:
The price of each GAO publication reflects GAO‘s actual cost of
production and distribution and depends on the number of pages in the
publication and whether the publication is printed in color or black and
white. Pricing and ordering information is posted on GAO‘s Web site,
[hyperlink, http://www.gao.gov/ordering.htm].
Place orders by calling (202) 512-6000, toll free (866) 801-7077, or
TDD (202) 512-2537.
Orders may be paid for using American Express, Discover Card,
MasterCard, Visa, check, or money order. Call for additional
information.
To Report Fraud, Waste, and Abuse in Federal Programs:
Contact:
Web site: [hyperlink, http://www.gao.gov/fraudnet/fraudnet.htm]:
E-mail: fraudnet@gao.gov:
Automated answering system: (800) 424-5454 or (202) 512-7470:
Congressional Relations:
Ralph Dawn, Managing Director, dawnr@gao.gov:
(202) 512-4400:
U.S. Government Accountability Office:
441 G Street NW, Room 7125:
Washington, D.C. 20548:
Public Affairs:
Chuck Young, Managing Director, youngc1@gao.gov:
(202) 512-4800:
U.S. Government Accountability Office:
441 G Street NW, Room 7149:
Washington, D.C. 20548:
