Analysis of Issues Concerning the Operating Industries Site

RCED-89-77: Published: Mar 30, 1989. Publicly Released: May 1, 1989.

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Pursuant to a congressional request, GAO examined the Environmental Protection Agency's (EPA) inclusion of a hazardous waste site on its National Priorities List (NPL), focusing on: (1) its inclusion of the entire site on NPL; and (2) the cost-effectiveness of its treatment of the site.

GAO found that EPA: (1) complied with applicable laws and regulations when it defined the site's boundaries for inclusion on NPL; (2) did not remove a portion of the site from NPL, as requested by a potential buyer as a precondition for sale, since regulations expressly prohibited such deletion pending cleanup; (3) is pursuing cleanup funds or actions from about 200 parties that owned or disposed of waste at the site; and (4) announced that over 100 companies had signed a consent decree, valued at about $66 million, to finance or conduct some of the site cleanup activities. GAO also found that the EPA feasibility study of on-site and off-site treatment approaches: (1) did not adequately analyze alternative treatment costs and certain hidden costs; (2) concluded that construction and operation of an on-site treatment plant could save $1.86 million over off-site treatment costs; (3) also considered such criteria as public health, environmental concerns, and engineering implementation and feasibility in selecting its treatment approach; and (4) evaluated five alternative plant sites and the feasibility of using two nearby existing commercial treatment plants.

Recommendation for Executive Action

  1. Status: Closed - Not Implemented

    Comments: EPA had planned to revise its feasibility study guidance by January 1991 to address hidden costs pursuant to changes in its National Contingency Plan (NCP), but EPA has since determined that this guidance does not need to be revised as a result of changes in NCP. It has new plans at this time to revise its guidance to provide for addressing hidden costs.

    Recommendation: To help ensure that feasibility studies at other Superfund sites are performed properly, the Administrator, EPA, should revise EPA guidance on feasibility studies to require that hidden costs, such as the imputed value of tax liabilities and liability insurance, be included in cost analyses.

    Agency Affected: Environmental Protection Agency


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