The federal Superfund program for cleaning up America's inactive toxic waste sites is noteworthy not only for its enormous cost - $15.2 billion has been authorized thus far - but also for its unique design. The legislation that created Superfund provided the Environmental Protection Agency with a diverse set of policy tools. Preeminent among them is a civil liability scheme that imposes responsibility for multimillion dollar cleanups on businesses and government units linked - even tangentially - to hazardous waste sites. Armed with this potent policy implement, the agency can order the parties who are legally responsible for the toxic substances at a site to clean it up, with large fines and damages for failure to comply. EPA can also offer conciliatory measures to bring about voluntary, privately financed cleanup; or it can launch a cleanup initially paid for by Superfund and later force the responsible parties to reimburse the government. In this book, Thomas W. Church and Robert T. Nakamura provide the first in-depth study of Superfund operations at hazardous waste sites. They examine six Superfund cleanups, including three regions and both 'hard' and 'easy' sites, to ask 'what works?' Based on detailed case studies, the book describes various strategies that have been applied by government regulators and lawyers and the responses to those different strategies by businesses and local government officials. The authors characterize the implementation strategies used by the EPA as prosecution, accommodation, and public works. They point out that the choice of strategy involves setting priorities among Superfund's competing objectives. They conclude that the best implementation strategy is one that considers the context of each site and the particular priorities in each case. Looking toward the reauthorization of Superfund, they also offer recommendations for improvements in the organization of the program and discuss proposals for change in its

" Under the Superfund program, EPA may address the long-term cleanup of certain hazardous waste sites by placing them on the NPL and overseeing the cleanup. To be eligible for the NPL, a site must be sufficiently contaminated, among other things. EPA regions have discretion to choose among several other approaches to address sites eligible for the NPL. For example, under the Superfund program, EPA regions may enter into agreements with PRPs using the SA approach. EPA may also defer the oversight of cleanup at eligible sites to approaches outside of the Superfund program. GAO was asked to review EPA's implementation of the SA approach and how it compares with the NPL approach. This report examines (1) how EPA addresses the cleanup of sites it has identified as eligible for the NPL, (2) how the processes for implementing the SA and NPL approaches compare, and (3) how SA agreement sites compare with similar NPL sites in completing the cleanup process. GAO reviewed applicable laws, regulations, and guidance; analyzed program data as of December 2012; interviewed EPA officials; and compared SA agreement sites with 74 NPL sites selected based on their similarity to SA agreement sites. "