CERCLA SECTIONS 301(a)(l)(B) AND (D) HAZARDOUS SUBSTANCE RESPONSE TRUST FUND RECEIPTS, OBLIGATIONS, AND DISBURSEMENTS - FINAL REPORT - OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE U.S. ENVIRONMENTAL PROTECTION AGENCY December 4, 1984 ------- CERCLA SECTION 301(a)(l)(B) AND (D) THE HAZARDOUS SUBSTANCE RESPONSE TRUST FUND RECEIPTS, OBLIGATIONS, AND DISBURSEMENTS TABLE OF CONTENTS PAGE NUMBER I. INTRODUCTION 1 II. CERCLA SECTION 301(a)(l)(B) SUMMARY OF SUPERFUND RECEIPTS, OBLIGATIONS, AND DISBURSEMENTS 2 1. Trust Fund Receipts, Obligations, and Disbursements 2 2. Obligations and Disbursements By Superfund Activity 5 3. Interagency Support: 7 III. CERCLA SECTION 301(a)(1)(D)REVIEW OF COST RECOVERY ACTIONS 11 1. Superfund Cost Recovery Strategy 11 2. Summary of Cost Recovery Acti.ons 12 3. Cost Recovery Settlements/Judgments .... 13 4. Cost Recovery Actions Filed by DOJ 13 ------- I. INTRODUCTION The Comprehensive Environmental Response, Compensation, and Liability Act of. 1980 (CERCLA or Superfund) establishes Federal authority to respond to the release or potential release of hazardous substances, pollutants, or contaminants into the environment. The Act establishes the Hazardous Substance Response Trust Fund (Fund) to finance response activities. Under Executive Order 12326, the Environmental Protection Agency (EPA) was assigned primary responsibility for managing and implementing the hazardous substance release cleanup effort. Section 301{a)(1) of CERCLA requires the President to submit a series of studies to Congress on the experience with implementing the Act. The studies are intended to provide- Congress with an assessment of. the accomplishments and impacts of the Superfund program. Paragrapn (B) of section 301(a)(1) specifically requires "a summary of past receipts and disbursements from the Fund." Paragraph (D) requires a study of the Superfund program's "record-and experience in recovering Fund disbursements from liable parties." This report was designed to meet the requirements of sections 301(a)(l)(B) and (D). Paragraphs (B) and (D) have been combined into one study because both paragraphs, in effect, call for a review of the financial aspects of the Fund's uses and receipts. Since cost recoveries are receipts into the Fund, the cost recovery summary required by paragraph (D) supplements the summary of receipts required by paragraph (B). -1- ------- II. CERCLA SECTION 301(a)(1)(B) SUMMARY OF SUPERFUND RECEIPTS, OBLIGATIONS, AND DISBURSEMENTS The objective of the CERCLA section 301(a)(1)(B) study is to present descriptive reports summarizing past receipts into and disbursements from the Fund. 1. TRUST FUND RECEIPTS, OBLIGATIONS, AND DISBURSEMENTS Exhibit A on the following page summarizes Fund transactions by fiscal year and indicates: Receipts - comprised of excise taxes levied on various petrochemicals, inorganic raw materials, arid crude oil and petroleum products; interest on the invested balance of the Fund; recoveries from responsible parties of funds spent to cleanup hazardous suostance releases; appropriations from the General Fund; and a one-time transfer from a fund established by Section 311 of the Clean Water Act. Appropriations - the portion of the Trust Fund made available by Congress for' obligation. Obligations - legal commitments of the Fund for specific response activities. Disbursements - actual outlays of the Fund for work completed. By summarizing Fund receipts and disbursements, Exhibit A fulfills the mandate of CERCLA section 301(a)(1)(B). Exhibit A also includes appropriations because they represent the actual amount of the receipts available for use, and obligations because they indicate the entire amount of funds EPA is planning to disburse. The receipt and disbursement data in Exhibit A were compiled from the U.S. Department of Treasury monthly reports. The monthly data were aggregated yearly for all data elements except interest income. Since the Treasury reports do not show receipts until they are actually deposited into the Fund, they may not reflect the actual interest income earned for that month. Although interest on the Treasury Bill investments results from purchase of the Bill at a discount and is not received and recorded until the redemption (at the time of sale or maturity) of -2- ------- EXHIBIT A HAZARDOUS SUBSTANCE RESPONSE TRUST FUND RECEIPTS, OBLIGATIONS, AND DISBURSEMENTS (THOUSANDS OF DOLLARS) Unappropriated Balance, Start of Year. . . . Receipts Excise Taxes .... Interest'1* Fines and Recoveries Appropriations from the General Fund . 311 Fund Transfer Total Receipts .... Appropriations .... Obligations'3) .... Unappropriated Balance, End of Year .... Disbursements .... FY 1981 127,900 9,393 0 9,000 6,743 153,036 74,743 40,283 78,293 8,039 FY 1982 78,293 243,994 67,854 2,309 26,600 340,757 190,000 180,744 229,050 79,576 FY 1983 229,050 230,225 60,978 356 40,000 331,559 210,000 230,233 350,609 147,803 FY 1984 350,609 261,235 77,941 3,440 44,000 386,616 460,000 465,619 277,225 285,279 TOTAL 863,354 216, 166 6,106 <2> 119,600 6,743 1,211,969 <2> 934,743 916,879 277,226 (2) 520,697 FY 1985 (Estimate) 277,190 276,000 31,000 46,000 44,000 397,000 620,000 651,000 <4> 54,226 448,000 <4.> PROJECTED TOTAL END FY 1985 1,139,354 247, 166 52,106 163,600 6,743 1,608,969 1,554,743 1,567,879 54,226 968,697 Unexpended Balance Trust Fund . . . 144,997 406,178 589,934 691,271 <5> 691,272 <2> 640,272 640,272 (1) Includes unaraortized interest. (2) Total does not add due to rounding. (3) Does not include offsetting collections from other Federal agencies. (4) Preliminary number based on $620,000 appropriation. (5) Includes unamortized interest ($73.7 million) on investment maturing September 1985. -3- ------- the investment instrument, it is actually being earned throughout the period from purchase to redemption. The interest income reported in Exhibit A for a given fiscal year includes the amount of interest paid into the Fund during the fiscal year plus any unamortized interest (interest earned but not yet paid) minus the unamortized interest.included in the previous fiscal year. The appropriation- and obligation data: were acquired from EPA's Financial Management System. These totals are end-of-year figures which do not include offsetting collections from other Federal agencies or deobligations. CERCLA sections 221 and 303 provide for maximum auth- orizations for appropriations from the General Fund and excise tax collections of $220 million and $1.38 billion, respectively, by September 30, 1985. Exhibit A shows that as of September 30, 1984, $1.2 billion in total receipts had been deposited into the Fund and S520.7 million had been disbursed,, leaving a balance of $691.3 million. The greatest portion of receipts, $863.4 million or 71.2 percent, was derived from excise taxes. Annual tax collections reached a high of $261.2 million in FY 1984, with projections, for- FY 1985 of $276.0 million. Interest receipts totaled $21.6.2 million for-the- four fiscal years and at 17.8 percent were the second largest category of receipts. A total of $6.1 million, or .5 percent of total receipts, had been collected from responsible parties and deposited into the Fund as of September 30, 1984 with 56.3 percent of this total collected in FY 1984. EPA estimates $46 million in cost recoveries for FY 1985. No fines or penalties had been reported as Fund receipts. Appropriations from the General Fund totaled $119.6 million and comprised 9.9 percent of receipts during the four fiscal years while the 311 Fund transfer provided .6 percent of total receipts. Congress appropriated (i.e., made funds available for obligation) $934.7 million of the $1.2 billion in total receipts over the four fiscal years. Of the $934.7 million appropriated, $916.9 million was obligated for Superfund activities. EPA projects an estimated 39.8 percent increase in obligations in FY 1985. Disbursements also increased each year and totaled $520.7 million for the four fiscal years. The unexpended balance of the Fund projected for FY 1985 is $640.3 million. -4- ------- 2. OBLIGATIONS AND DISBURSEMENTS BY SUPERFUND ACTIVITY Exhibit B was developed to show how Fund money has been used. Exhibit B presents obligations and disburse- ments by Superfund activity. The obligation and dis- bursement data in this exhibit were acquired from EPA's Financial Management System (FMS). Both the obligation and.disbursement data were supplemented by data on transfer allocations (Transfer lAGs) of CERCLA funds reported by other Federal agencies with Superfund respon- sibilities (Interagency Support). Transfer lAGs are not reported in FMS since they are not considered obligations by EPA. Transfer lAGs are included in these exhibits because they are a use of Fund money and wrll be obligated and disbursed by the Federal agency to which the funds are transferred. Only the obligations and disbursements reported by the agency which received the transfer are included. Exhibit 3 indicates Superfund program obligations and disbursements by the following program activities: Hazardous Substance Response - This category includes all activities associated with removal and. remedial response actions. Removal actions are short-term responses designed to prevent or mitigate an immediate threat caused by the release or potential release of hazardous substances into the environment. Remedial actions are longer-term responses designed to provide a permanent remedy. Enforcement - This category includes adminis- trative and judicial efforts at specific sites designed to induce privately-financed cleanups and to reimburse the Fund for CERCLA-financed cleanup actions. Management and Support - This category includes overall program management and administrative support, training, and contingency planning. Research and- Development - This category includes scientific and technical support provided by EPA's Office of Research and Development such as the evaluation and field testing of equipment as well as techniques for discovering, assessing, preventing, removing, and disposing of hazardous substances releases. -5- ------- EXHIBIT B OBLIGATIONS AND DISBURSEMENTS BY SUPBRFUND ACTIVITY (THOUSANDS OF DOLLARS) ACTIVITY FY 1981 FY 1982 FY 1983 FY 1984 TOTAL Obligations* Hazardous Substance Response Enforcement Management and Support Research & Development Interagency Support Total 30,761.6 2,317.1 2,323.9 4,740.5 140.0 40,283.1 149,009.6 8,364.4 9,511.2 13,813.2 45.2 180,743.6 175,902.4 17,669.7 11,396.1 6,818.5 18,446.7 230,233.4 366,746.1 26,697.4 17,183.3 10,171.0 44,821.7 465,619.5 722,419.7 55,048.6 40,414.5 35,543.2 63,453.6 916,879.6 Disbursements Hazardous Substance Response Enforcement Management and Support Research & Development Interagency Support Total 6,144.3 753.4 1,006.7 132.6 1.7 8,038.7 58,903;0 6,619.7 7,701.2 6,283.3 69.2 79,576.4 109,993.2 11,389.1 10,712.2 10,994.2 4,714.6 147,803.3 209,656.1 17,553.7 15,003.1 9,402.2 33,664.2 285,279.3 384,696.5 36,315.9 34,423.2 26,812.3 38,449.7 520,697.6 ^Obligations do not Include offsetting collections from other Federal agencies. -6- ------- Interagency Support - This category includes ongoing Superfund activities performed by other Federal agencies. Total obligations increased 27.4 percent between FY 1982 and FY 1983 and more than doubled in FY 1984. Specifically, in FY 1984, Hazardous Substance Response obligations increased 108.5 percent. Interagency Support obligations increased each fiscal, year, along with the increase in Hazardous Substance Response. Obligations for Enforcement to induce privately-financed cleanup and cost recovery have also increased steadily since FY 1981. As of September 30, 1984, $520.7 million had been disbursed from the Fund for completed Superfund activities. The greatest portion of Fund disbursements, $384.7 million or 73.9 percent, were made for Hazardous Substance Response. Disbursements from the Fund for work completed increased 85.7 percent in FY 1983 and 93.0 percent in FY 1984. 3. INTERAGEHCY SUPPORT Exhibit C-l presents the total amount of CERCLA funds provided through Interagency Agreements (lAGs) to other Federal agencies for ongoing Superfund activities. The amount of each IAG and the amounts obligated and disbursed by the agency receiving the funds are shown. Exhibit C-2 presents the yearly distribution of the lAGs, -obligations, and disbursements. Two types of lAGs have been used to fund Interagency Support: Transfer lAGs and Reimbursable lAGs. Transfer lAGs have funded the following ongoing Federal support activities: Services by the Department of Justice (DOJ) to carryout portions of the Superfund program in- tended to facilitate private party cleanup and cost recoveries. Oversight and technical support of response actions in coastal and marine areas by the National Oceanic and Atmospheric Administration (NOAA). Temporary and/or permanent relocation of indivi- duals by the Federal Emergency Management Agency (FEMA). -7- ------- Implementation of the health-related authorities of CERCLA by the Department of-Health and Human Services {HHS). Response management activities by the Department of the Interior (DOI) which support EPA's spill and sine response. Protection of personnel at Super.fund. sites- by the- Occupational Safety and Health Administration (OSHA), including development of specific health and safety guidelines. Reimbursable lAGs have funded United States Coast Guard (USCG) on-site training, outfitting and enforcement activities, as well as maintenance of the National Response Center. Exhibit C-l indicates that a total of $67.0 million had been.provided to other Federal agencies for. Inter- agency Support, $b3.5- million.had. been obligated and $38.4 million had been disoursed as of September' 30, 1984.. FEMA received the greatest portion of funds (60.4 percent of the total) , HHS received 21.9 percent of the total, DOJ received. 8.4 percent of the total, and. USCG received 7.7 percent of the total-funds provided. Exhibit C-2 shows that "FY 1983 was the first fiscal year in which substantial Fund lAGs were made. Prior to FY 1983, DOJ was the only agency to receive CERCLA funds. -8- ------- *Reimbursable IAG. EXHIBIT C-l INTERAGENCY SUPPORT CUMMULATIVE TOTALS (THOUSANDS OE DOLLARS) FY 1981 THROUGH FY 1984 AGENCY DOJ NOAA FEMA HHS DO I OS HA USCG TAG 5,610.8 615.0 40,456.0 14,656.0 315.0 151.6 5,189.2* OBLIGATIONS 5,085.7 599.7 37,929.5 14,320.8 315.0 13.7 5,189.2 DISBURSEMENTS 4,497.2 410.2 27,834.0 3,987.3 242.1 5.6 896.1 Total All Agencies For All Fiscal Years 66.993.6 63.453.6 38.449.7 -9- ------- EXHIBIT C-2 INTERAGENCY SUPPORT BY FISCAL YEAR (THOUSANDS OF DOLLARS) FY 1981 FY .1982 AGENCY DOJ Total All Agencies per Fiscal Year AGENCY DOJ NOAA FEMA HHS DO I OSHA USCG<3> Total All Agencies per Fiscal Year IAG 175.0 175.0 IAG 2,008.4 365.0 13r461.5 9,656.0 0.0 0.0 1,514.8 27.005.7 OBLIGA- TIONS 140.0 140.0 FY 1983 OBLIGA- TIONSU) 1,987.2 348.3 7,455.5 7,140.9 0.0 0.0 1,514.8 18f446T7 DISBURSE- MENTS 1.7 Ld DISBURSE- MENTS*2) 1,482.8 133.4 1,464.1 1,634.3 0.0 0.0 0.0 4.714.6 IAG 60.0 60.0 IAG 3,367.4 250.0 26,994.5 5,000.0 315.0 151.6 3,674.4 39.752.9 OBLIGA- TIONS f*> 45.2 45.2 FY 1984 OBLIGA- TIONS^1 2,913.3 251.4 30,474.0 7,179.9 315.0 13.7 3,674.4 44.821.7 DISBURSE- MENTS ( 2) 69.2 iLa DISBURSE- MENTS (2) 2,943.5 276.8 26,911.6 2,353.0 277.6 5.6 896.1 33.664.2 ^ ^^|^ A. X^-f d t -fc V^l W *. I^X -b M *** V* h^ ^^»ii Vv ^ V» fc . J ^ w ^* » ^ - %r ^* »« -w ^ ^ 3 "~ ~* ~" "^ ^~ ~ (2) Disbursements include dollars obligated in previous fiscal years. (3) Reimbursable IAG. -10- ------- III. CERCLA SECTION 301(a)(l)(D} REVIEW OF COST RECOVERY ACTIONS The objective of. the CERCLA Section 301 (a) (1) (D) study is co present descriptive reports summarizing cost: recoveries from liable parties. Section 107 of CERCLA authorizes the recovery of costs incurred by the Fund. In general/ section 107 provides that past and present owners, operators, generators, and transporters of hazardous substances may be liable for the costs of removal or remedial actions undertaken at those sites and for damages to, or loss of, natural resources. Although the Agency generally favors actions that encour- age responsible party cleanup efforts, EPA is authorized to use CERCLA funds for removal or remedial cleanup actions.. For, Fund-financed cleanups, SPA attempts to document and recover the maximum practicaole amount: of money due to the Fund from responsible parties that may be liable under section 107 of CERCLA. Cost recovery includes any settlement or legal judge- ment whereby a responsible party deposits money into the Fund to cover CERCLA response cos-ts. In other words, a cost recovery includes (1) money from responsible parties that reimburses the Fund for actual cleanup costs incurred as well as (2) upfront payments into the Fund from respon- sible parties to finance cleanup actions. Exhibits D, E, and F of the 301(a)(1)(D) study do not include information on other private party response actions, where the parties either perform the cleanup activity or establish an escrow account to privately- finance the response activity. To date, the Agency has successfully negotiated private party responses worth an estimated $300 million. The 301(a)(l)(A) study which evaluates the overall effectiveness of the Superfund program provides a more comprehensive discussion of private party response actions. 1. SUPERFUND COST RECOVERY STRATEGY The figures presented here should be reviewed in the context of the Superfund cost recovery strategy. During the initial years of the Superfund program, cost recovery efforts were considered part of negotiations for a remedy. Cost recovery agreements, if pursued/ were generally incorporated as one part of broader settlement agreements or legal judgements. -11- ------- Cost recovery efforts were not priority activities in the initial years of the Superfund program for two reasons. First, initial Fund-financed removals were generally limited to emergencies that required a slow rate o: Fund expenditures, so cost recovery of these actions was not emphasized. Second, initial program policies resulted in a slow rate of Fund expenditures for remedial activities- EPA chose to wait until the remedial response was entirely or. substantially complete before initiating- remedial cost recovery efforts. Since remedial actions take several years to complete, cost recovery efforts have only recently been initiated for these actions. More recently, EPA began placing greater emphasis on the importance of cost recovery actions. In 1983, EPA increased the level of Fund-financed removal and remedial activity with greater reliance on cost recovery as a means of keeping the Fund solvent. The increased removal activity placed greater demands on the Fund which resulted in. gr.eater. emphasis on cost recovery efforts.. CERCL'A cost recovery efforts often involve complex and. lengthy legal procedures. Generally, these efforts in- clude three elements: documentation, issuance of a demand letter,- and settlement with responsible parties. Complete documentation requires that the.government document all costs it incurred, document any release or threat of release of a hazardous substance and the resultant lia'bility of the responsible parties, and provide doc- umentation to rebut the contention that site work was not consistent with the National Contingency Plan which implements CERCLA. EPA routinely issues a demand letter to parties liable for response costs summarizing the costs incurred and demanding payment for those costs. In response, liable parties may pursue negotiations for cost recovery settlement with EPA. If this approach fails, EPA refers the case to the Department of Justice (DOJ) for appropriate litigation. These legal procedures are often complicated by the presence of more than one responsible party. 2. SUMMARY OF COST RECOVERY ACTIONS Exhibit D summarizes successful CERCLA section 107 cost recovery civil actions, as well as those actions filed by DOJ, referred to DOJ, or in development (to be referred to DOJ) at the end of FY 1984. As of September 30, 1984, a total of 155 cost recovery actions had been initiated to recover funds valued at approximately $144.4 million. Of the 155 actions, 33 were -12- ------- successful cost recovery settlements/judgements for a total of $6,641,196. In addition, 77 section 107 actions had been filed, 26 actions were pending (had been referred to DOJ), and 19 actions were in development (to be referred to DOJ). The approximate dollar value of these actions are $117 million, $13 million, and $7 million, respectively. 3. COST RECOVERY SETTLEMENTS/JUDGEMENTS Exhibit E presents successful cost recovery actions by region, site and fiscal year. As indicated earlier, cost recovery settlements/judgements had been reached at 33 sites for a total of $6,641,196 as of September 30, 1984. During FY 1981, there was one cost recovery settlement/judgement for $30,000. During FY 1982, there were three cost recovery settlements/judgements for a total of $2,409,688 compared to 13 cost recovery settlements/judgements in FY 1983 for $2,155,133. During FY 1984, 16 settlements/judgements were reached to recover response costs of $2,046,375. Many of these successful cost recoveries represent only partial reimbursement by a portion of the responsible parties at each site. _The non-settling parties will generally be pursued for cost recovery. Of the 33 sites for which cost recovery has occurred, 23 sites are on. EPA's National Priorities List (NPL), and 18 sites (NPL and non-NPL) have had a removal action taken'. EPA reports successful cost recoveries when settlements/judgements are reached. Exhibit E indicates the sites where a portion of the cost recovery has not yet been received from the responsible parties (i.e., collections outstanding). 4. COST RECOVERY ACTIONS FILED BY DOJ Exhibit F provides an account of the actions filed by DOJ, including the site and approximate dollar value of recovery sought by EPA. As of September 30, 1984, there were 77 section 107 actions filed by DOJ. Of the 77 actions filed, 48 apply to sites on the NPL and 52 apply to sites (NPL and non-NPL) where a removal action has been taken. -13- ------- EXHIBIT D SUMMARY OF COST RECOVER₯ ACTIONS NUMBER OF ACTIONS Cost Recovery Settlements/Judgements 33 Cases filed by DOJ 77 Cases referred to DOJ 26 Cases in development 19 155 VALUE OF ACTIONS $ 6,641,196 117,688,300 (approx.) 13,006,300 (approx.) 7,049,200 (approx.) $144,384,996 -14- ------- EXHIBIT E COST RECOVERY SETTLEMENTS/JUDGEMENTS REGION 1 2 3 4 5 6 NPL * * * * * * * * * * * * * * * * * * * * * FISCAL YEAR .OF SETTLEMENT/ SITE/STATE JUDGEMENT Woburn, MA Lipari, NJ Batavia Landfill, NY Tybouts Landfill, DE ABM Wade, PA McAdoo , PA Glenside Chloride, PA Plastifax, MS Lenoir, NC Bluff Road, SC Chem Central, MI Chem Dyne, OH A&F Materials Olney, IL Enviro-Chem, IN 9th Avenue Dump, IN Velsicol, MI FMC, MN Oakdale, MN A&F Greenup, IL Johns Manville, IL East Bay Township, MI Waste Disposal Engineering, MN Allied Chemical, OH Union Carbide Dioxin Site, OH Cleve-Reber, LA Petro Processors, LA Pronto Services, NM 1982 1984 1984 1983 1983 1983 1984 1983 1984 1984 1982 1982 1983 1983 1983 1983 1983 1983 1984 1984 1984 1984 1984 1984 1983 1984 1984 AMOUNT RECOVERED ($) 60, 67, 42, 13, 635, 4, 14, 226, 113, 95, 140, 2,209, 61, 651, 15, 500, 10, 10, 340, 43, 144, 25, 35, 5, 7, 600, 26, 000 500 973 400 800 (1) 800 504 369 306 000 000 688 000 606 000 (2) 000 000 000 000 (3) 735 (3) 527 000 000 000 (3) 646 000 930 REMOVAL ACTION (S) TAKEN * * * * * * * * * * * * * -"15- ------- EXHIBIT E (Cont'd) COST RECOVERY SETTLEMENTS/JUDGEMENTS FISCAL YEAR OF SETTLEMENT/ REGION NPL SITE/STATE JUDGEMENT 7 * Aidex, IA Denny Farm, MO 8 Arlington, NY 9 General Disposal, CA Nickel Solution, CA 10 * American Surplus, HA TOTAL COST RECOVERIES TOTAL AMOUNT COLLECTED AMOUNT OF SETTLEMENTS 1983 1984 1983 19BI 1984 1984 OUTSTANDING AMOUNT RECOVERED ($) 12,967 155,000 (4) 6,545 30,000 199,500 136,400 $6,641,196 6,106,149 535,047 REMOVAL ACTION (S) TAKEN * * * * * (1) Agreement for $635,800; $605,753 paid as of September 30, 1984. (2) Agreement for $15,000; $10,000 paid as of September 30, 1984. (3) Agreement reached but uncollected as of September 30, 1984. (4) Court judgement but defendants have appealed decision; therefore, payment had not been collected as of September 30, 1984. -L6- ------- EXHIBIT F COST RECOVERY CASES FILED BY DOJ REGION 1 2 3 4 NPL * * * * * * * * * * * * * * * * * * * SITE/STATE Solvents Recovery, CT Baird & McQuire, MA New Bedford, MA Mottolo, NH Ottati & Goss, NH Goose Farm, NJ Prices Landfill, NJ Syncon Resins, NJ Berncolors, NY Love Canal, NY York Oil, NY Pine Valley Gulf Club, NJ Tybouts, DE Northeast, MD ABM Wade, PA Brodhead Creek, PA Bruin Lagoon, PA Drake, PA Glenside Chloride, PA Lehigh Electric, PA Roadside Dumping, PA Turco, PA Tyson's Disposal, PA Big John's Salvage, WV Holder Corp., WV Manila Creek, WV Taylor Road, FL Luminous Processes, GA Lenoir, NC Keith Farm Pond, KY APPROXIMATE $ VALUE OF SITES 25,000 1,000,000 971,000 550,000 2,100,000 2,500,000 7,600,000 100,000 550,000 20,000,000 893,000 35,000 200,000 1,000,000 4,800,000 684,000 1,222,400 950,000 14,500 1,500,000 100,000 286,000 869,800 819,000 170,000 260,000 80,000 760,000 113,000 198,600 REMOVAL ACTION (S) TAKEN * * * * * * * * * * * * * * * * * * * * * * -17- ------- EXHIBIT F (Cont'd) COST RECOVERY CASES FILED BY DOJ REGION NPL * * SITE/STATE Roadside PCB's, NC Bluff Road, SC Carolawn, SC Dreyfus Street, SC APPROXIMATE $ VALUE OF SITES 2,570,000 1,156,200 550,500 342,100 REMOVAL ACTION (S) TAKEN * * * * * A & F Greenup, IL A & F Olney, IL Environmental Dynamics, IL Hixon Plating, IL OMC, IL Enviro-Chem, IN Midco I & II, IN Seymour, IN Berlin & Farro, MI Chem Central, MI Liquid Disposal, MI Northernaire, MI Peerless Plating, MI Velsicol, MI (2 cases) Verona Wellfield, MI Isanti, MN (2 cases) Reilly Tar, MN Anaconda Road, OH Chem-Dyne, OH Greiner's Lagoon, OH Laskin/Poplar, OH T. P. Long, OH 1,143,700 99,000 152,200 43,000 2,000,000 1,000,000 1,391,900 5,500,000 1,100,000 240,000 2,300,000 163,700 130,000 1,000,000 27,000 889,600 940,300 40,000 4,000,000 155,400 2,065,900 37,000 * * * * * * * * * -18- ------- EXHIBIT F (Cont'd) COST RECOVERY CASES PILED BY DOJ REGION NPL 6 * * 7 9 * * 10 * * * SITE/STATE Vertac, AR Petro Processors, LA Argent, NM Homes take Mining, NM Hardage/Criner, OK Crystal Chemical, TX French Limited, TX Triangle, TX Horse Arenas, MO Denny Farm, MO Mountain View/Globe, AZ Occidental, CA General Disposal, CA Nickel Solution, CA Stringfellow, CA Pacific Recycling, ID Western Processing, WA American Surplus, WA Nortran, WA APPROXIMATE $ VALUE OF SITES 695,400 600,000 40,000 27,000 223,000 4,000,000 969,100 400,000 1,000,000 447,500 7,000,000 10,000,000 1,606,200 209,800 9,000,000 312,600 1,500,000 384,600 8,500 REMOVAL ACTION (S) TAKEN * * * * * * * * * * * * APPROXIMATE TOTAL DOLLAR VALUE: $117,688,300 TOTAL SECTION 107 ACTIONS FILED: 77 -19- ------- |