oversight

Military Munitions: DOD Needs to Develop a Comprehensive Approach for Cleaning Up Contaminated Sites

Published by the Government Accountability Office on 2003-12-19.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                United States General Accounting Office

GAO             Report to the Honorable John D. Dingell
                Ranking Minority Member, Committee on
                Energy and Commerce, House of
                Representatives

December 2003
                MILITARY
                MUNITIONS
                DOD Needs to
                Develop a
                Comprehensive
                Approach for Cleaning
                Up Contaminated
                Sites




GAO-04-147
                a
                                                 December 2003


                                                 MILITARY MUNITIONS

                                                 DOD Needs to Develop a Comprehensive
Highlights of GAO-04-147, a report to the        Approach for Cleaning Up Contaminated
Honorable John D. Dingell, Ranking
Minority Member, Committee on Energy             Sites
and Commerce, House of Representatives




Over 15 million acres in the United              DOD has made limited progress in its program to identify, assess, and clean
States are suspected of being, or                up sites that may be contaminated with military munitions. While DOD had
known to be, contaminated with                   identified 2,307 potentially contaminated sites as of September 2002, DOD
military munitions. These sites                  officials said that they continue to identify additional sites and are not likely
include ranges on closing military               to have a firm inventory for several years. Of the identified sites, DOD had
installations, closed ranges on
active installations, and formerly
                                                 initially determined that 362 sites required no further study or cleanup action
used defense sites. Under the                    because it found little or no evidence of military munitions. For 1,387 sites,
Defense Environmental                            DOD either has not begun or not completed its initial evaluation or
Restoration Program, established                 determined that further study is needed. DOD has completed its assessment
in 1986, the Department of Defense               of 558 sites, finding that 475 of these required no cleanup action. The
(DOD) must identify, assess, and                 remaining 83 sites required some cleanup action, of which DOD has
clean up military munitions                      completed 23.
contamination at these sites. DOD
estimates these activities will cost             DOD does not yet have a complete and viable plan for cleaning up military
from $8 billion to $35 billion.                  munitions at remaining potentially contaminated sites. DOD’s plan is lacking
Because of the magnitude of DOD’s
                                                 in several respects, including the following:
cleanup effort, both in terms of
cost and affected acreage, as well               •   Essential data for DOD’s plan may take years to develop. Not all the
as the significant public safety,                    potential sites have been identified, and DOD has set no deadline for
health, and environmental risks                      doing so. Also, DOD intends to use a new procedure to assign a relative
that military munitions may pose,                    priority for the remaining 1,387 sites, but it will not complete the
you asked us to evaluate (1) DOD’s                   reassessments until 2012. Until these are done, DOD cannot be assured
progress in implementing its                         that it is using its limited resources to clean up the riskiest sites first.
program to identify, assess, and                 •   DOD’s plan relies on preliminary cost estimates that can change greatly
clean up military munitions sites                    and the reallocation of funds that may not be available. For example, the
and (2) DOD’s plans to clean up                      Air Force used estimated, not actual, acreage to create its cost estimates,
remaining sites in the future.                       limiting the estimate’s reliability and DOD’s ability to plan and budget
                                                     cleanup for these sites. Also, DOD expects additional funds will become
                                                     available for munitions cleanup as other DOD hazardous waste cleanup
We are recommending that DOD                         efforts are completed. However, some of these efforts are behind
develop a comprehensive approach                     schedule; therefore, funds may not become available as anticipated.
by revising its plan to (1) establish            •   DOD’s plan does not contain goals or measures for site assessment and
deadlines for completing its site                    cleanup. DOD recently established a working group tasked with
inventory and initial evaluations,                   developing agencywide program goals and performance measures, but
(2) reassess the timetable proposed                  not service-specific targets, limiting DOD’s ability to ensure that the
for completing its risk assessment
                                                     services are making progress in cleaning the potentially contaminated
reevaluations, and (3) establish
service-specific targets. We are                     sites and achieving the overall goals of the program as planned.
also recommending that after DOD
revises its plan, it should work with            Unexploded Military Munition
the Congress to develop budget
proposals that will allow timely
completion of cleanup activities.
www.gao.gov/cgi-bin/getrpt?GAO-04-147.

To view the full product, including the scope
and methodology, click on the link above.
For more information, contact Anu K. Mittal at
(202) 512-3841 or mittala@gao.gov.
Contents



Letter                                                                                                  1
                             Results in Brief                                                           4
                             Background                                                                 6
                             DOD Has Made Limited Progress in Its Program to Identify, Assess,
                               and Clean Up Potentially Contaminated Sites                              8
                             DOD Does Not Have a Complete and Viable Plan for Assessing and
                               Cleaning Up Potentially Contaminated Sites                              14
                             Conclusions                                                               18
                             Recommendations                                                           19
                             Agency Comments                                                           19


Appendixes
              Appendix I:    Safety, Environmental, and Human Health Risks                             22
             Appendix II:    Additional Details on Our Scope and Methodology                           25
             Appendix III:   Comments from the Department of Defense                                   27
             Appendix IV:    GAO Contacts and Staff Acknowledgments                                    30
                             GAO Contacts                                                              30
                             Acknowledgments                                                           30


Tables                       Table 1: Distribution of Military Munitions Response Program Sites
                                      by Service                                                        8
                             Table 2: Munitions Constituents of Greatest Concern                       23
                             Table 3: Potential Effects of the Munitions Constituents Closely
                                      Associated with Military Munitions                               24
                             Table 4: Districts Visited during Review                                  25


Figures                      Figure 1: Distribution of 2,307 Suspected Military Munitions
                                       Response Program Sites Identified by DOD                        10
                             Figure 2: Military Munitions Response Program Site Inventory
                                       (2,307 Sites)                                                   11
                             Figure 3: Military Munitions Response Program Sites Requiring
                                       Further Action                                                  12
                             Figure 4: Examples of Cleanup Actions at Military Munitions
                                       Response Program Sites                                          13




                             Page i                                          GAO-04-147 Military Munitions
Contents




Abbreviations


DOD          Department of Defense
Corps        U.S. Army Corps of Engineers
CERCLA       Comprehensive Environmental Response, Compensation,
             and Liability Act of 1980


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Page ii                                                    GAO-04-147 Military Munitions
A
United States General Accounting Office
Washington, D.C. 20548



                                    December 19, 2003                                                                               Leter




                                    The Honorable John D. Dingell
                                    Ranking Minority Member
                                    Committee on Energy and Commerce
                                    House of Representatives

                                    Dear Mr. Dingell:

                                    Over 15 million acres in the United States are known to be or are suspected
                                    of being contaminated with military munitions, which include unexploded
                                    ordnance, discarded military munitions, and munitions constituents such
                                    as propellants or other chemicals.1 These sites, which are no longer in use,
                                    include closed ranges on active installations, ranges on military
                                    installations that are being closed (closing sites), and formerly used
                                    defense sites.2 Much of the land on which these sites are located has been
                                    or will be converted to nonmilitary uses such as farming, residential or
                                    commercial development, and recreation. The Department of Defense
                                    (DOD) estimates that identifying, assessing, and cleaning up contamination
                                    from military munitions at such sites will cost from $8 billion to $35 billion
                                    and could take more than 75 years. Within DOD, cleanup of sites on active
                                    or closing installations is the responsibility of the military service—Air
                                    Force, Army, Navy, or Marine Corps—that currently owns the land. The
                                    U.S. Army Corps of Engineers (Corps) is responsible for executing the
                                    cleanup of formerly used defense sites.

                                    Military munitions can pose risks to public safety, human health, and the
                                    environment. Unexploded ordnance poses a potential explosive hazard and
                                    risk of personal injury to those who encounter it. The Environmental
                                    Protection Agency, in September 2001, using a DOD database and other
                                    sources, identified at least 126 incidents involving civilians who were




                                    1
                                     Unexploded ordnance, discarded military munitions, and munitions constituents are
                                    hereafter referred to as “military munitions” for the purpose of this report. Unexploded
                                    ordnance includes ordnance primed and fired but remain unexploded. For a more complete
                                    definition, see the National Defense Authorization Act for Fiscal Year 2004, Pub. L. No. 108-
                                    136, section 1042 (a)(2).
                                    2
                                     A formerly used defense site is a property that Department of Defense (DOD) formerly
                                    owned, leased, possessed, operated, or otherwise controlled, and was transferred from
                                    DOD prior to October 17, 1986.




                                    Page 1                                                       GAO-04-147 Military Munitions
exposed to unexploded ordnance over the past 83 years, which resulted in
65 fatalities and 131 injuries.3 The risk of such exposures is expected to
grow with an increase in development and recreational activities on land
once used by the military for munitions related activities (e.g., live fire
testing and training). In addition, human exposure to munitions
constituents such as trinitrotoluene (TNT) and perchlorate may cause long-
term health problems, such as cancer and damage to the heart, liver, and
kidneys. However, the link between such constituents and any potential
health effects is not always clear and continues to be studied. (See app. I
for a list of common munitions constituents and potential health effects.)
Military munitions may also pose an environmental risk because their use
and disposal may release constituents that could contaminate soil,
groundwater, and surface water. Former ranges on which munitions-
related activities were conducted and which are known or suspected to
contain military munitions are in a variety of locations, including near
ecologically sensitive wetlands, surface waters, and floodplains. While
many constituents have been an environmental concern to DOD for more
than 20 years, the current understanding of the causes, distribution, and
potential impact of constituent releases into the environment remains
limited. The nature of these impacts, and whether they pose an
unacceptable risk to human health and the environment, depend upon the
dose, duration, and pathway of exposure, as well as the sensitivity of the
exposed populations. Until recently, DOD has focused primarily on
mitigating the public safety risk associated with unexploded ordnance, but
it is now giving additional attention to environmental and health concerns
posed by munitions constituents.

Under the Defense Environmental Restoration Program, established in
1986, DOD is required to identify, investigate, and clean up environmental
contamination and other hazards at active and closing installations, as well
as at formerly used defense sites.4 The program is organized into three
categories that focus on DOD’s primary goals: (1) identification and
cleanup of contamination from hazardous substances, pollutants, and
contaminants; (2) demolition and removal of unsafe buildings and


3
 U.S. Environmental Protection Agency, Office of Solid Waste, Permits and State Programs
Division, UXO Incident Report (Revision 1), (Washington, D.C., 2001).
4
 The Defense Environmental Restoration Program was established by section 211 of the
Superfund Amendments and Reauthorization Act of 1986, which amended the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(CERCLA).




Page 2                                                     GAO-04-147 Military Munitions
structures; and (3) correction of other environmental damage, such as
detection and disposal of military munitions. Most of DOD’s past focus had
been on identifying and cleaning up contamination from hazardous
substances. To better focus DOD’s efforts on identifying, assessing, and
cleaning up sites containing military munitions, DOD established the
Military Munitions Response program in September 2001. Subsequently, in
December 2001, the Congress passed the National Defense Authorization
Act for Fiscal Year 2002, which among other things, required DOD to
develop an initial inventory of sites that are known or suspected to contain
military munitions and a comprehensive plan for cleaning up these sites. Of
the $1.9 billion budgeted by DOD for environmental cleanup in fiscal year
2002, approximately $113 million was designated for sites with military
munitions. In fiscal years 2003 and 2004, DOD designated approximately
$115 million and $89 million, respectively, for sites with military munitions.

In deciding what actions, if any, are needed to clean up a site identified as
potentially contaminated with military munitions, DOD generally follows
the process established for cleanup actions under the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980
(CERCLA). CERCLA, as amended, governs the cleanup of hazardous waste
sites, including contamination on military installations. After identifying a
potential military munitions site, the appropriate DOD military service or
the Corps performs a preliminary assessment, during which DOD
determines if military munitions may be present and if further study or
cleanup action is needed. If necessary, DOD may conduct a site
investigation to better identify the types and extent of potential hazards
present. For specific areas suspected to contain military munitions, DOD
surveys the land and evaluates and selects alternatives, in consultation
with stakeholders, for addressing the potential hazards. These cleanup
alternatives could include removing the military munitions, limiting public
contact with the site through signs and fences, or determining that no
further action with regard to the site is warranted. After implementing the
chosen cleanup alternative, DOD periodically monitors the site and reviews
the alternative chosen to ensure its continued effectiveness.

Because of the magnitude of DOD’s cleanup effort, both in terms of cost
and affected acreage, as well as the significant public safety, human health,
and environmental risks posed by military munitions, you asked us to
evaluate (1) DOD’s progress in implementing its program to identify,
assess, and clean up sites containing military munitions and (2) DOD’s
plans to clean up remaining sites in the future.




Page 3                                              GAO-04-147 Military Munitions
                   To evaluate DOD’s progress in identifying, assessing, and cleaning up
                   military munitions, we reviewed and analyzed DOD’s database for sites
                   identified under the Military Munitions Response program as of September
                   30, 2002, the end of their most recent reporting cycle. We assessed the
                   reliability of relevant fields in this database by electronically testing for
                   obvious errors in accuracy and completeness, reviewing information about
                   the data and the system that produced them, and interviewing agency
                   officials knowledgeable about the data. When we found inconsistencies, we
                   worked with DOD and military service officials to correct the discrepancies
                   before conducting our analyses. We determined that the data needed for
                   our analyses were sufficiently reliable for the purposes of our report. We
                   also reviewed project files from 38 of the 75 sites where, according to
                   DOD’s database, cleanup action is either complete or under way.5 These
                   files represented 52 percent of the 23 sites with a completed cleanup action
                   and 50 percent of the 52 sites with a cleanup action under way. We used our
                   file reviews to develop case examples of changes in estimated costs to
                   complete cleanup over time and cleanup actions taken. These case
                   examples are for illustration only. We conducted our work between
                   November 2002 and October 2003 in accordance with generally accepted
                   government auditing standards. More detail on the scope and methodology
                   of our review is presented in appendix II.



Results in Brief   DOD has made limited progress in its program to identify, assess, and clean
                   up sites that may be contaminated with military munitions. While DOD had
                   identified 2,307 potentially contaminated sites as of September 2002, DOD
                   officials said that the department is continuing to identify additional sites
                   and is not likely to have a firm inventory for several years. For example, the
                   Army had only surveyed and identified closed ranges on 14 percent of its
                   active installations. Of the total 2,307 identified sites, DOD had initially
                   determined that 362 sites required no further study or cleanup action
                   because there was little or no evidence of military munitions. However,
                   because these sites are formerly used defense sites, and the initial
                   evaluations conducted were less comprehensive than for other sites in the
                   program, the Corps has recently decided that some of these sites need to be
                   reassessed to determine if cleanup is needed. For 1,387 sites, DOD either
                   has not begun or not completed its initial evaluation or has determined that
                   further study is needed. DOD has completed its assessment of 558 sites,

                   5
                    There are an additional eight sites for which cleanup action is planned, but not yet begun.
                   These sites were not included in our file review process.




                   Page 4                                                        GAO-04-147 Military Munitions
finding that 475 sites required no cleanup action. The remaining 83 sites
required some cleanup action, of which DOD has completed 23.

DOD does not yet have a complete and viable plan for guiding its remaining
clean up activity at potentially contaminated sites. DOD’s plan is lacking in
several respects, including the following:

• Essential data for DOD’s plan may take years to develop. For example,
  not all the potential sites have been identified, and DOD has set no
  deadline for doing so. Because the inventory serves as the basis for
  other elements of the plan, such as budget development, the sites must
  first be identified before DOD can have a reasonable picture of the
  magnitude of the challenge ahead and plan accordingly. Furthermore,
  DOD intends to use new procedures to reassess the relative risk for the
  1,387 sites needing further study, but DOD is not scheduled to complete
  these reassessments until 2012. The resulting relative risk assessments
  will be a key component in determining cleanup priorities. Until the
  assessments are complete, DOD cannot be assured that it is using its
  limited resources to clean up those sites that pose the greatest risk to
  public safety, human health, and the environment.

• DOD’s plan relies on preliminary cost estimates that may change
  significantly and reallocated funds from other programs that may not be
  available as anticipated. For example, at Camp Maxey, Texas, the
  estimated cost for cleanup in 2000 was $45 million. However, in DOD’s
  Fiscal Year 2002 Defense Environmental Restoration Program Annual
  Report to Congress, the estimated cleanup cost had grown to $130
  million. A June 2003 cost estimate showed a decrease in total costs to
  $73 million. Furthermore, DOD expects that as other DOD hazardous
  substance cleanup efforts are completed, increased funds will become
  available for munitions cleanup. However, not all of these other DOD
  cleanup efforts are on schedule. For example, between fiscal years 2001
  and 2002, the schedule to complete hazardous, toxic, and radioactive
  waste cleanup at formerly used defense sites had slipped by more than 6
  years. As a result, anticipated funds from completing cleanups at these
  sites may not become available until 2021 or later.

• DOD’s plan does not yet contain goals or measures for site assessment
  and cleanup. In September 2003, 2 years after the establishment of the
  Military Munitions Response program, DOD established a working
  group tasked with developing agencywide program goals and
  performance measures. However, the working group is not expected to



Page 5                                             GAO-04-147 Military Munitions
                establish service-specific targets, therefore DOD will have limited
                assurance that the services and the Corps are (1) making progress in
                cleaning their Military Munitions Response program sites and (2) are
                contributing to achieving the overall goals of the program as planned.

             We are recommending that DOD revise its plan to (1) establish deadlines
             for completing its site inventory and initial evaluations; (2) reassess the
             timetable proposed for completing its reevaluation of sites, using the new
             risk assessment procedures; and (3) establish interim goals based on
             criteria, such as relative risk levels or cleanup phases, for the services and
             the Corps to target. We are also recommending that after DOD revises its
             comprehensive plan, it should work with the Congress to develop realistic
             budget proposals that will allow DOD to complete cleanup activities in a
             timely manner.

             In commenting on a draft of this report, DOD concurred with our
             recommendation to work with the Congress to develop realistic budget
             proposals that will allow DOD to complete cleanup activities on potentially
             contaminated sites in a timely manner. In addition, DOD partially
             concurred with our recommendations to (1) establish deadlines to
             complete the identification process and initial evaluations; (2) reassess the
             timetable proposed for completing the reevaluation of sites, using the new
             risk assessment procedure; and (3) establish interim goals for cleanup
             phases for the services and the Corps to target. DOD also suggested some
             technical changes throughout the report that we have incorporated as
             appropriate. DOD’s comments appear in appendix III.



Background   To better focus its munitions cleanup activities under the Defense
             Environmental Restoration Program, DOD established the Military
             Munitions Response program in September 2001. The objectives of the
             program include compiling a comprehensive inventory of military
             munitions sites, developing a prioritization protocol for sequencing work at
             these sites, and establishing program goals and performance measures to
             evaluate progress. In December 2001, shortly after DOD established the
             program, the Congress passed the National Defense Authorization Act for
             Fiscal Year 2002, which among other things, required DOD to develop an
             initial inventory of sites that are known or suspected to contain military
             munitions by May 31, 2003, and to provide annual updates thereafter. DOD




             Page 6                                              GAO-04-147 Military Munitions
provides these updates as part of its Defense Environmental Restoration
Program Annual Report to Congress.6

To clean up potentially contaminated sites, DOD generally follows the
process established for cleanup actions under CERCLA, which includes the
following phases and activities:

• Preliminary Assessment—Determine whether a potential military
  munitions hazard is present and whether further action is needed.

• Site Investigation—Inspect the site and search historical records to
  confirm the presence, extent, and source(s) of hazards.

• Remedial Investigation/Feasibility Study or Engineering
  Evaluation/Cost Analysis—Determine the nature and extent of
  contamination; determine whether cleanup action is needed and, if so,
  select alternative cleanup approaches. These could include removing
  the military munitions, limiting public contact with the site through
  signs and fences, or determining that no further action is warranted.

• Remedial Design/Remedial Action—Design the remedy and perform
  the cleanup or other response.

• Long-Term Monitoring—Periodically review the remedy in place to
  ensure its continued effectiveness, including checking for unexploded
  ordnance and public education.

For sites thought to be formerly used defense sites, the Corps also
performs an initial evaluation prior to the process above. In this initial
evaluation, called a preliminary assessment of eligibility, the Corps
determines if the property is a formerly used defense site. The Corps makes
this determination based on whether there are records showing that DOD
formerly owned, leased, possessed, operated, or otherwise controlled the
property and whether hazards from DOD’s use are potentially present. If
eligible, the site then follows the CERCLA assessment and cleanup process
discussed earlier. When all of these steps have been completed for a given
site and long-term monitoring is under way, or it has been determined that


6
 In the report issued on April 21, 2003, DOD provided aggregate high and low program cost
estimates for clean up of military munitions at Military Munitions Response program sites,
as well as operational ranges, to satisfy a one-time congressional reporting requirement.




Page 7                                                      GAO-04-147 Military Munitions
                           no cleanup action is needed, the services and the Corps consider the site to
                           be “response complete.”



DOD Has Made Limited       While DOD has identified 2,307 potentially contaminated sites as of
                           September 2002, the department continues to identify additional sites, and
Progress in Its Program    it is not likely to have a firm inventory for several years (see table 1 for the
to Identify, Assess, and   distribution of these sites by service). Of the identified sites, DOD
                           determined that 362 sites require no further study or cleanup action
Clean Up Potentially       because it found little or no evidence of military munitions. For 1,387 sites,
Contaminated Sites         DOD either has not begun or not completed its initial evaluation, or has
                           determined that further study is needed. DOD has completed an
                           assessment of 558 sites, finding that 475 of these required no cleanup
                           action. The remaining 83 sites require some cleanup action, of which DOD
                           has completed 23.



                           Table 1: Distribution of Military Munitions Response Program Sites by Service

                                                                               Closing ranges
                                                                                      on base
                                                          Closed ranges           realignment
                                                               on active          and closure Formerly used
                           Responsible service              installations        installationsa defense sites             Total
                           Army                                         105                    58                N/A        163
                           Navy                                         196                    16                N/A        212
                           Air Force                                    241                     0                N/A        241
                           Army Corps of                                N/A                  N/A               1,691      1,691
                           Engineers
                           Total                                        542                    74              1,691      2,307
                           Source: DOD.
                           a
                            The base realignment and closure program is a DOD program governing the scheduled closing of
                           DOD sites and includes a focus on compliance and cleanup efforts at military installations undergoing
                           closure or realignment.


                           DOD had identified 2,307 sites potentially contaminated with military
                           munitions, as of September 30, 2002, and it continues to identify additional
                           sites. (Fig. 1 shows the distribution of these sites by state.) DOD officials
                           acknowledge that they will not have a firm inventory for several years. For
                           example, as of September 30, 2002, the Army had not completed a detailed
                           inventory of closed ranges at 86 percent of active installations; the 105 sites
                           identified by the Army represented sites on only 14 percent of the Army’s



                           Page 8                                                             GAO-04-147 Military Munitions
installations. The Army is working to identify sites on the remaining
installations and plans to have 40 percent of its installations accounted for
by the next Defense Environmental Restoration Program Annual Report to
Congress in spring 2004. Similarly, the Corps recently identified 75
additional sites to be included in the inventory as a result of its effort to
reevaluate sites previously determined not to need further action after the
initial evaluation. Because not all of the sites have been identified, DOD has
only a preliminary idea of the extent of cleanup that will be needed. To help
complete the identification process, DOD has developed a Web site that
stakeholders, such as states, tribes, and federal regulators, can use to
suggest additions and revisions to the inventory. DOD plans to update the
inventory in its future Defense Environmental Response Program Annual
Report to Congress using, in part, the information collected from this Web
site.




Page 9                                              GAO-04-147 Military Munitions
Figure 1: Distribution of 2,307 Suspected Military Munitions Response Program Sites Identified by DOD




                      WA
                      48
                                                                                                                                          ME
                                     MT
                                                                                                                              VT 2        36
                                     16                    ND
                 OR                                         5             MN
                 17                                                        5                                                                   NH 10
                           ID
                                                                                         WI                                                    MA 72
                           20                                                                                                     NY
                                                           SD                            4               MI                       29
                                          WY               21                                            35                                    RI 24
                                          12
                                                                               IA                                            PA                CT 10
                      NV                                   NE                                                                30
                                                           28                   9
                      40                                                                                        OH                             NJ 33
                                UT                                                            IL    IN          10
                                19                                                            35    22
                                            CO                                                                        WV                       DE 9
               CA                           34                  KS                                                     3     VA
               376                                              62                  MO                                       66
                                                                                    25                   KY 3                                  MD 61
                                                                                                                             NC
                                                                                                   TN 25                     68                DC 31
                            AZ                                       OK
                                          NM                         38             AR                                 SC
                            138
                                          160                                       15                                 44
                                                                                              MS
                                                                                              23    AL           GA
                                                                                                    22           31
                                                           TX                       LA
                                                           139                      29
        HI 70

                                                                                                                       FL
                                                                                                                       148
                           AK
                           50


                                                                               American Samoa                    3
                                                                               Guam                             12
                                                                               Northern Mariana Islands          8
                                                                               Puerto Rico                      19
                                                                               U.S. Virgin Islands               3


Source: GAO.




                                                 Page 10                                                                   GAO-04-147 Military Munitions
Of the 2,307 sites identified, DOD has determined, based on an initial
evaluation, that 362 do not require any further DOD action (see fig. 2).
However, these 362 sites are formerly used defense sites, and the Corps’
evaluation of these sites was less comprehensive than other evaluations
conducted by DOD under the CERCLA process. 7 In making its
determinations, the Corps conducted a preliminary assessment of
eligibility and determined that the potential for military munitions hazard
was not present. As a result of this determination, the sites were not
evaluated further. The Corps is in the process of reviewing these
determinations with local stakeholders to ensure that there was a sound
basis for the original determination. It has recently decided that some of
these sites need to be reassessed to determine if cleanup is needed.



Figure 2: Military Munitions Response Program Site Inventory (2,307 Sites)


                            •                    No action required, based on
                         16%                     initial evaluations (362)




                           84% •                 Further action required (1,945)




Source: GAO.




7
 In previous GAO work, we estimated that the Corps lacked a sound basis for about 38
percent of its determinations, based on its preliminary assessment of eligibility, that sites
did not require any further DOD action; and we recommended that the Corps review these
files to determine if these properties should be reassessed. The 38 percent includes all
potential formerly used defense sites, including those suspected of containing military
munitions. As noted above, the Corps is in the process of reassessing the determinations.
See U.S. General Accounting Office, Environmental Contamination: Corps Needs to
Reassess Its Determinations That Many Former Defense Sites Do Not Need Cleanup, GAO-
02-658 (Washington, D.C.: Aug. 23, 2002).




Page 11                                                      GAO-04-147 Military Munitions
                                         Of the 1,945 sites that required further action, DOD has either not begun or
                                         has not completed its study, or has determined that further study is needed,
                                         for 1,387 sites (see fig. 3). For example, 241 Air Force and 105 Army sites at
                                         closed ranges on active installations have not been evaluated. For other
                                         sites, primarily formerly used defense sites, DOD has completed its initial
                                         evaluation and determined that further investigation is needed.



Figure 3: Military Munitions Response Program Sites Requiring Further Action

                                            Study not begun, study under way, or further study needed (1,387)

                                            Study completed (558)

               •
          71%

                                                                    No cleanup action needed (475)
                           29% •




                                                                    Cleanup action planned or under way (60)
                                                                    Cleanup action complete (23)


Source: GAO.



                                         DOD has completed its assessment of 558 sites, nearly all of which are
                                         ranges on formerly used defense sites or closing installations, and
                                         determined that no cleanup action was needed for 475; the remaining 83
                                         sites required some level of cleanup action. Of the 83 sites that required
                                         cleanup action, 60 have cleanup action planned or under way and 23 are
                                         complete. Actions taken at these 23 sites have been varied and include
                                         surface and subsurface removal of munitions, and institutional controls,
                                         such as the posting of warning signs or educational programs. See figure 4
                                         for examples of cleanup actions at Military Munitions Response program
                                         sites.




                                         Page 12                                                     GAO-04-147 Military Munitions
Figure 4: Examples of Cleanup Actions at Military Munitions Response Program
Sites


                              The former Baywood Park Training Area is an 8,810-acre site, located
                           along Morro Bay near San Luis Obispo, California. Currently, the land is
                                   used for residential, recreational, agricultural uses as well as for a
                               wildlife refuge. The Corps initially conducted a removal action on 166
                             acres. It cleared 96 beachfront acres to a depth of 3 feet; 17 acres less
                               susceptible to shifting and eroding sand were cleared to a depth of 2
                             feet; and 53 acres were cleared at the surface for munitions. Following
                            that work, the Corps also plans to implement institutional controls, such
                                   as putting up warning signs on primary trails and public education
                                                          programs, for additional portions of the site.



  Jefferson Barracks is located along the Mississippi River in Saint
  Louis County, Missouri. Throughout much of the 19th century, the
  disposal of munitions from this site into the river was a common and
  acceptable practice. Over time, this practice resulted in potentially
  hazardous munitions being readily accessible to the public walking
  along the riverbank. The Missouri Air National Guard currently has
  responsibility for this land, but because it was a formerly used
  defense site the Corps has responsibility for cleanup. The Corps
  evaluated several alternatives and chose an innovative solution --
  burying the potential hazard, located along approximately 650 linear
  feet of shoreline, under thousands of tons of rock.



                                        At Seneca Army Depot in Romulus, New York, the primary
                                      mission was the receipt, storage, maintenance, and supply of
                                        military items, including munitions. Congress approved the
                                        closure of this 10,587-acre site under the base realignment
                                             and closure process. The Army assessed the site and
                                      evaluated the alternatives to reduce the risk posed by military
                                          munitions. The alternatives selected included institutional
                                         controls (such as fencing, land use restrictions, and public
                                              education), subsurface removal of munitions, and the
                                                  excavation and sifting of soil to remove munitions.



  The Waikoloa Maneuver Area in Hawaii, a military training area
  and live fire range, actually consists of three sites -- Waikoloa
  Maneuver Area, Nansay, and Lalamilo Firing Range and Camp. In
  total, the three sites encompass more than 100,000 acres and are
  estimated to be the most expensive to clean up. The Corps has
  already instituted a number of institutional controls, including
  notification of 14,000 land owners, the development of an
  educational package, and the production of a public safety and
  health video. As the Corps continues to monitor and assess this
  land, additional cleanup actions, including subsurface removal of at
  least 680 acres, are planned.

Source: GAO.




Page 13                                                                GAO-04-147 Military Munitions
DOD Does Not Have a        In DOD’s Fiscal Year 2002 Defense Environmental Restoration Program
                           Annual Report to Congress, DOD identified several elements integral to the
Complete and Viable        success of the Military Munitions Response program: compiling a
Plan for Assessing and     comprehensive inventory of sites; developing a new procedure to assess
                           risk and prioritize sites; ensuring proper funding for accurate planning and
Cleaning Up                program execution; and establishing program goals and performance
Potentially                measures. While DOD has established the basic framework to address
Contaminated Sites         these elements, DOD’s plan is lacking in three key respects. First, essential
                           data for DOD’s plan may take years to develop. Second, DOD’s plan is
                           contingent upon preliminary cost estimates that may change significantly
                           and a reallocation of funds that may not be available. Finally, DOD’s plan
                           lacks specific goals and performance measures to track progress.



Essential Data for DOD’s   DOD’s inventory of potentially contaminated sites serves as the basis for
Plan May Take Years to     other elements of its plan, yet this inventory is incomplete. DOD’s inventory
                           of 2,307 sites includes only those identified through September 30, 2002. As
Develop                    previously discussed, according to DOD officials, this inventory is not final;
                           and DOD has not set a deadline to complete it. According to DOD, most of
                           the ranges on formerly used defense sites and on military installations that
                           are being closed have been identified and are being assessed or cleanup
                           action is under way. The ranges yet to be identified are primarily located on
                           active installations. For example, the Army, as of September 30, 2002, had
                           completed a detailed inventory of potentially contaminated sites on only 14
                           percent of its active installations. Because the inventory serves as the basis
                           for other elements of the plan, such as budget development and
                           establishing program goals, most sites must first be identified in order for
                           DOD to have a reasonable picture of the magnitude of the challenge ahead
                           and to plan accordingly.




                           Page 14                                             GAO-04-147 Military Munitions
                             Furthermore, DOD intends to use a new procedure to reassess the relative
                             risk and priority for 1,387 sites needing further study and any new sites
                             identified as part of the continuing inventory effort, but DOD is not
                             scheduled to complete these reassessments until 2012. DOD recently
                             developed this procedure for assigning each site in the inventory a priority
                             level for cleanup action, based on the potential risk of exposure resulting
                             from past munitions-related activities.8 Under this procedure, DOD plans to
                             reevaluate the 1,387 sites for three potential hazard types: (1) explosive
                             hazards posed by unexploded ordnance and discarded military munitions,
                             (2) hazards associated with the effects of chemical warfare material, and
                             (3) chronic health and environmental hazards posed by munitions
                             constituents. Once assessed, each site’s relative risk-based priority will be
                             the primary factor determining future cleanup order.9 DOD plans to require
                             assessment of each site on the inventory for at least one of these hazard
                             types by May 31, 2007, and for all three hazard types by May 31, 2012. Until
                             all three hazard types are fully assessed, DOD cannot be assured that it is
                             using its limited resources to clean up those sites that pose the greatest risk
                             to safety, human health, and the environment.



DOD’s Plan Relies on         DOD’s plan to identify and address military munitions sites relies on
Preliminary Cost Estimates   preliminary cost estimates that were developed using incomplete
                             information. The majority of the site estimates were developed using a
That Can Change              cost-estimating tool that incorporates variables, such as the affected
Significantly and a          acreage; types, quantity, and location of munitions; and future land use.
Reallocation of Funds That   These variables can have a significant impact on cost, according to DOD.
May Not Be Available         However, detailed site-specific information was not available for all sites.
                             For example, as mentioned earlier, 105 Army and 241 Air Force sites at
                             closed ranges on active installations have not had an initial evaluation. As a
                             result, the Air Force used estimated, not actual, acreage figures, including
                             assumptions regarding the amount of acreage known or suspected of
                             containing military munitions when preparing its cost estimates. Because
                             changes in acreage can greatly impact the final cost of site assessment and
                             cleanup action, the estimates produced for these sites are likely to change
                             when estimates based on more complete data or the actual cost figures are


                             8
                              DOD proposed a rule establishing this protocol on August 22, 2003, allowing 90 days for a
                             public comment period. 68 Fed. Reg. 50,900.
                             9
                              DOD recognized that other factors, such as economic, programmatic, and stakeholder
                             concerns, may affect the sequence in which sites are cleaned up.




                             Page 15                                                     GAO-04-147 Military Munitions
known. The following examples illustrate how cost estimates can change
during the life of the cleanup as better information becomes available:

• Camp Maxey was a 41,128-acre Army post in Texas used from 1942 to
  1945 for training infantry in live fire of weapons including pistols, rifles,
  machine guns, mortars, bazookas, and antitank guns. The Corps
  confirmed the presence of unexploded ordnance, and in 2000, estimated
  the cleanup cost for the land at $45 million. In DOD’s Fiscal Year 2002
  Defense Environmental Restoration Program Annual Report to
  Congress, the estimated total cost of cleanup had grown to $130 million.
  A June 2003 cost estimate showed a decrease in total cost to about $73
  million, but still 62 percent more than the original cost estimate in 2000.
  The main factors behind these shifting cost estimates, according to the
  project manager, were changes in the acreage requiring underground
  removal of ordnance and changes in the amount of ordnance found.

• Fort McClellan, Alabama, was among the installations recommended for
  closure under DOD’s base realignment and closure effort in 1995. This
  site had been used since the Spanish American War (1898), including as
  a World War I and II training range upon which grenades, mortars, and
  antiaircraft guns, were used. An April 2002 cost estimate prepared for
  one site on Fort McClellan requiring cleanup showed the anticipated
  cost of clearing the land of munitions as $11,390,250. A subsequent cost
  estimate prepared in May 2003, showed the cost of clearing this site at
  $22,562,200. According to the Army, the increase in estimated costs
  reflects a change in the final acreage recommended for clearance and
  the extent to which buried munitions would be searched for and
  removed.

Moreover, until DOD and stakeholders agree upon a cleanup action, it is
often difficult for them to predict the extent of the cleanup action required
and cost estimates can change because of the cleanup action implemented
at the site. For example, at the former Indian Rocks Range in Pinellas
County, Florida, the Corps identified 178 acres that were used as an air-to-
ground and antiaircraft gunnery range impact area from 1943 to 1947.
Munitions used on this shoreline site included bullets, aircraft rockets, and
small practice bombs. Much of the land had been developed, limiting the
Corps ability to pursue the alternative of searching for and removing buried
munitions. In 1995, the Corps analyzed a number of alternatives to address
munitions contamination at the site and developed cost estimates for these
alternatives. However, because the development was largely composed of
hotels, condominiums, and single-family residences, the Corps chose the



Page 16                                             GAO-04-147 Military Munitions
                            alternative of conducting a community education program. The total cost
                            of this alternative was $21,219. If the Corps had decided to search for and
                            remove the remaining munitions at this site, the cost could have
                            approached $3 million, according to the prepared cost analysis.

                            Furthermore, at an annual funding level of approximately $106 million (the
                            average amount budgeted or spent annually from fiscal year 2002 to fiscal
                            year 2004), cleanup at the remaining munitions sites in DOD’s current
                            inventory could take from 75 to 330 years to complete.10 To reduce this
                            timeline, DOD expects to use funds currently designated for hazardous,
                            toxic, and radioactive waste cleanup after these cleanups are complete.
                            However, these other cleanup efforts are not on schedule in all of the
                            services and the Corps. For example, between fiscal years 2001 and 2002,
                            the schedule to complete hazardous substance cleanups at formerly used
                            defense sites slipped by more than 6 years. As a result, anticipated funds
                            from completing hazardous substance cleanups at these sites may not
                            become available to clean up munitions sites until 2021 or later. This delay
                            is significant because, as of September 30, 2002, formerly used defense
                            sites account for over 85 percent of DOD’s total anticipated costs to
                            complete munitions cleanup, yet the Corps receives about 66 percent of the
                            total munitions cleanup funds. Delays in the availability of anticipated
                            funding from hazardous, toxic, and radioactive waste sites could greatly
                            impair DOD’s ability to accurately plan for and make progress in cleaning
                            up Military Munitions Response sites.



DOD’s Plan Does Not         DOD has yet to establish specific program goals and performance
Contain Goals or Measures   measures in its plan. Specifically, DOD has yet to identify interim
                            milestones and service-specific targets that will help it achieve overall
for Site Assessment and     program objectives. In September 2003, 2 years after the Military Munitions
Cleanup                     Response program was initiated, DOD established a workgroup tasked
                            with recommending overall goals and measures for the program, near-term
                            goals and measures to support its budgeting cycle for fiscal years 2006 to
                            2011, and a program completion date goal. DOD has asked the workgroup
                            to accomplish these objectives by the end of calendar year 2003. According
                            to DOD, these goals and measures, when developed, should help DOD
                            track the progress of sites through the cleanup phases, and ensure that
                            DOD responds to the sites with the greatest risk first. While it is important

                            10
                             This estimate is a conservative estimate because it was calculated based on annual funding
                            totals that include funding that is needed for program management and administration.




                            Page 17                                                     GAO-04-147 Military Munitions
              for DOD to establish goals and measures that will track overall program
              progress and ensure that the riskiest sites are assessed and cleaned up first,
              DOD will not have the information it needs to do this until 2012. As we
              discussed earlier, because DOD plans to reassess potentially contaminated
              sites using a new risk-based prioritization procedure, until these
              reassessments are complete, DOD will not have complete information on
              which of the sites pose the greatest risk. Consequently, goals and measures
              established in 2003 will be of limited use and may not reflect DOD’s true
              priorities.

              Moreover, according to DOD, the program goals and measures to be
              established by the workgroup will be agencywide, and not service-specific,
              although it may establish interim goals for the services and Corps.
              However, DOD has not yet decided what these goals will be based on, such
              as relative risk levels or cleanup phases. In the absence of service-specific
              goals, each service has implemented the program with a different level of
              effort. For example, the Air Force has not budgeted any funds to assess and
              clean up munitions sites, nor do they plan to do so through fiscal year 2004.
              As mentioned before, the Air Force also has not conducted initial
              evaluations on any of its 241 sites and has little site-specific information
              from which to create a reliable cost estimate. In contrast, the Army has
              undertaken a comprehensive inventory of ranges that will result in detailed
              site information, such as acreage and the types, quantity, and location of
              munitions, that can be used to, among other things, create more robust cost
              estimates. The Army has completed this comprehensive inventory on 14
              percent of its installations as of September 2002, and has set a goal to
              complete this effort by December 2003. This uneven effort in implementing
              the Military Munitions Response program could continue through various
              program phases, such as preliminary assessments and site investigations,
              making it difficult for DOD to assure that each of the services and the
              Corps are making progress in cleaning up their potentially contaminated
              sites and achieving the overall goals of the program.



Conclusions   DOD has made limited progress in identifying, assessing, and cleaning up
              sites known or suspected to contain military munitions. Accomplishing this
              long and arduous task in a timely manner that best protects public safety,
              human health, and the environment will require a comprehensive approach
              that includes effective planning and budgeting. However, DOD lacks the
              data needed—such as a complete inventory, up-to-date prioritization, and
              reliable cost estimates—to establish a comprehensive approach. Without
              such an approach for identifying, assessing, and cleaning up potentially



              Page 18                                            GAO-04-147 Military Munitions
                  contaminated sites, DOD will be hampered in its efforts to achieve the
                  program’s objectives.



Recommendations   To ensure that DOD has a comprehensive approach for identifying,
                  assessing, and cleaning up military munitions at potentially contaminated
                  sites, we recommend that the Secretary of Defense revise DOD’s plan to

                  • establish deadlines to complete the identification process and initial
                    evaluations so that it knows the universe of sites that needs to be
                    assessed, prioritized, and cleaned up;

                  • reassess the timetable proposed for completing its reevaluation of sites
                    using the new risk assessment procedures so that it can more timely
                    establish the order in which sites should be assessed and cleaned up,
                    thereby focusing on the riskiest sites first; and

                  • establish interim goals for cleanup phases for the services and Corps to
                    target.

                   In addition, after DOD has revised its comprehensive plan, we recommend
                  that it work with the Congress to develop realistic budget proposals that
                  will allow DOD to complete cleanup activities on potentially contaminated
                  sites in a timely manner.



Agency Comments   We provided DOD with a draft of this report for review and comment. In its
                  comments, DOD concurred with our recommendation to work with the
                  Congress to develop realistic budget proposals that will allow it to
                  complete cleanup activities on potentially contaminated sites in a timely
                  manner. DOD partially concurred with our recommendation to establish
                  deadlines to complete the identification process and initial evaluations so
                  that it knows the universe of sites. DOD stated that the military services
                  and the Corps have been working, and will continue to work, with
                  stakeholders to identify additional sites and add these sites to the inventory
                  as appropriate. DOD also stated that it believes most of the remaining sites
                  to be identified are located on active installations still under DOD control.
                  While we have clarified this point in the report, we note that the number of
                  formerly used defense sites identified has increased by about 75 sites since
                  the current inventory was completed and an unknown but possibly
                  significant number of sites may be added as the Army completes



                  Page 19                                            GAO-04-147 Military Munitions
identification of sites on 86 percent of its installations. These sites and
many others still need to undergo initial evaluations. Consequently, we
continue to believe that it is important for DOD to establish deadlines to
complete the identification and initial evaluations for all of the sites in its
inventory in order to establish a reasonable approximation of the future
workload it faces.

DOD also partially concurred with our recommendation to reassess the
timetable proposed for completing the reevaluation of sites using the new
risk assessment procedure. DOD stated that the military services and the
Corps would need sufficient time and resources to complete each risk
assessment. However, DOD stated that it had recently established 2010 as
the goal for completing the prioritization of sites, instead of 2012 which
was the original goal set forth in the proposed regulation. While we agree
that this is a step in the right direction, DOD should continue to look for
other opportunities to accelerate these inspections and the prioritization of
sites to help ensure that resources are being targeted toward the riskiest
sites first.

Finally, DOD partially concurred with our recommendation to establish
interim goals for cleanup phases for the services and the Corps. DOD
stated that it has established interim goals of completing all preliminary
assessments by 2007 and all site inspections by 2010, and that these goals
apply to all military components, thereby eliminating the need for separate
service-specific goals. However, DOD noted that it is working with each
military service to establish additional goals and measures to gauge
progress. While we are encouraged by DOD’s efforts in this area, we believe
that service-specific goals and measures, as they apply to the cleanup
phases, will be essential for DOD to ensure that each of the services and
the Corps are making progress in cleaning up potentially contaminated
sites and achieving the overall goals of the program.

In addition to its written comments on our draft report, DOD also provided
a number of technical comments and clarifications, which we have
incorporated in this report as appropriate. DOD’s written comments appear
in appendix III.


As agreed with your office, unless you publicly announce the contents of
this report earlier, we plan no further distribution until 30 days from the
report date. At that time, we will send copies of this report to the
appropriate congressional committees; the Secretary of Defense; Director,



Page 20                                              GAO-04-147 Military Munitions
Office of Management and Budget; and other interested parties. We will
also make copies available to others upon request. In addition, the report
will be available at no charge on the GAO Web site at http://www.gao.gov.

If you or your staffs have any questions, please call me or Edward Zadjura
at (202) 512-3841. Key contributors to this report are listed in appendix IV.

Sincerely yours,




Anu K. Mittal
Director, Natural Resources
 and Environment




Page 21                                            GAO-04-147 Military Munitions
Appendix I

Safety, Environmental, and Human Health                                                    Appendx
                                                                                                 ies




Risks                                                                                       Append
                                                                                                 x
                                                                                                 Ii




              Military munitions can pose risks to public safety, human health, and the
              environment. In terms of the explosive hazard, unexploded ordnance poses
              an immediate safety risk of physical injury to those who encounter it.
              Military munitions may also pose a health and environmental risk because
              their use and disposal may release constituents that may contaminate soil,
              groundwater, and surface water. Ranges contaminated with military
              munitions, especially those located in ecologically sensitive wetlands and
              floodplains, may have soil, groundwater, and surface water contamination
              from any of the over 200 chemical munitions constituents that are
              associated with the ordnance and their usage. When exposed to some of
              these constituents, humans potentially face long-term health problems,
              such as cancer and damage to heart, liver, and kidneys. Of these
              constituents, there are 20 that are of greatest concern due to their
              widespread use and potential environmental impact. Table 2 contains a
              listing of these munitions constituents, and table 3 describes some of the
              potential health effects of five of them.




              Page 22                                          GAO-04-147 Military Munitions
Appendix I
Safety, Environmental, and Human Health
Risks




Table 2: Munitions Constituents of Greatest Concern

Type of munitions constituents
Trinitrotoluene (TNT)
1,3-Dintrobenzene
Nitrobenzene
2,4-Dinitrotoluene
2-Amino-4,6-Dinitrotoluene
2-Nitrotoluene
2,6-Dinitrotoluene
4-Amino-2,6-Dinitrotoluene
3-Nitrotoluene
Octahydro-1,3,5,7-tetranitro-1,3,5,7-tetrazocine (HMX)
2,4-Diamino-6-nitrotoluene
4-Nitrotoluene
Hexahydro-1,3,5-trinitro-1,3,5-triazine (RDX)
2,6-Diamino-4-nitrotoluene
Methylnitrite
Perchlorate
1,2,3-Propanetriol trinitrate (Nitroglycerine)
Pentaerythritoltetranitrate (PETN)
1,3,5-Trinitrobenzene
N,2,4,6-Tetranitro-N-methylaniline (Tetryl) (White Phosphorus)
Source: DOD, Fiscal Year 2002 Defense Environmental Restoration Program Annual Report to Congress.


While many of these constituents have been an environmental concern to
the Department of Defense (DOD) for more than 20 years, the current
understanding of the causes, distribution, and potential impact of
constituent releases into the environment remains limited. The nature of
these impacts, and whether they pose an unacceptable risk to human
health and the environment, depend upon the dose, duration, and pathway
of exposure, as well as the sensitivity of the exposed populations. However,
the link between such constituents and any potential health effects is not
always clear and continues to be studied.




Page 23                                                                            GAO-04-147 Military Munitions
Appendix I
Safety, Environmental, and Human Health
Risks




Table 3: Potential Effects of the Munitions Constituents Closely Associated with
Military Munitions

Constituent                                Potential toxicity/effects
TNT                                        Possible human carcinogen, targets liver, skin irritations,
                                           and cataracts.
RDX                                        Possible human carcinogen, prostate problems, nervous
                                           system problems, nausea and vomiting. Laboratory
                                           exposure to animals indicates potential organ damage.
HMX                                        Animal studies suggest potential liver and central nervous
                                           system damage.
Perchlorate                                Exposure causes itching, tearing, and pain; ingestion may
                                           cause gastroenteritis with abdominal pain, nausea,
                                           vomiting, and diarrhea; systemic effects may follow and
                                           may include ringing of ears, dizziness, elevated blood
                                           pressure, blurred vision, and tremors. Chronic effects may
                                           include metabolic disorders of the thyroid.
White Phosphorus                           Reproductive effects. Liver, heart, or kidney damage;
                                           death; skin burns, irritation of throat and lungs, vomiting,
                                           stomach cramps, drowsiness.
Source: Environmental Protection Agency, Handbook on the Management of Ordnance and Explosives at Closed, Transferring, and
Transferred Ranges and Other Sites.




Page 24                                                                             GAO-04-147 Military Munitions
Appendix II

Additional Details on Our Scope and
Methodology                                                                                     Appendx
                                                                                                      Ii




               The objectives of our review were to evaluate (1) DOD’s progress in
               implementing its program to identify, assess, and clean up sites containing
               military munitions and (2) DOD’s plans to clean up remaining sites in the
               future. To evaluate DOD’s progress in identifying, assessing, and cleaning
               up military munitions sites, we analyzed data provided to us by DOD’s
               Office of the Deputy Undersecretary of Defense (Installations and
               Environment) Cleanup Office from its database for sites identified under
               the Military Munitions Response program. This information includes the
               status of studies or cleanup actions, as well as cost estimates. The data are
               complete as of September 30, 2002, DOD’s most recent reporting cycle, and
               were used to develop DOD’s Fiscal Year 2002 Defense Environmental
               Restoration Program Annual Report to Congress. We also analyzed
               additional data on the status of studies or cleanup actions provided to us by
               the Army Corps of Engineers (the Corps) from its database of formerly
               used defense sites. We assessed the reliability of relevant fields in these
               databases by electronically testing for obvious errors in accuracy and
               completeness, reviewing information about the data and the system that
               produced them, and interviewing agency officials knowledgeable about the
               data. When we found inconsistencies, we worked with DOD and military
               service officials to correct the inconsistencies before conducting our
               analyses. We determined that the data needed for our review were
               sufficiently reliable for the purposes of our report.

               We also reviewed 38 of 75 project files at seven Corps districts where,
               according to DOD’s database, site cleanup action is either complete or
               under way. (See table 4 for a listing of these districts).



               Table 4: Districts Visited during Review

                                              Total number Sites with cleanup Sites with cleanup
               Corps district                       of sites       completed          under way
               Baltimore                                   2                1                  1
               Fort Worth                                  3                0                  3
               Honolulu                                    2                0                  2
               Huntsville                                 12                4                  8
               Jacksonville                                8                2                  6
               Kansas City                                 4                3                  1
               Los Angeles                                 7                2                  5
               Total                                      38               12                 26
               Source: GAO.




               Page 25                                              GAO-04-147 Military Munitions
Appendix II
Additional Details on Our Scope and
Methodology




We selected these districts based on the number of sites where cleanup was
completed or under way and the estimated cost to complete cleanup, with
some consideration given for geographic distribution. These files
represented 52 percent of the 23 sites with a completed cleanup action and
50 percent of the 52 sites with a cleanup action under way. We used our file
reviews to develop case example of changes in estimated costs to complete
cleanup over time and cleanup actions taken. These case examples are for
illustration only.

To evaluate DOD’s plans for addressing the remaining sites, we analyzed
the plans, as well as the assumptions upon which those plans are based,
including cost and projected completion dates. In addition, we reviewed
policies and program guidance, analyzed financial data, and interviewed
program managers in DOD and the military services and the Corps. We
conducted our work between November 2002 and October 2003 in
accordance with generally accepted government auditing standards.




Page 26                                           GAO-04-147 Military Munitions
Appendix III

Comments from the Department of Defense                     Appendx
                                                                  iI




               Page 27          GAO-04-147 Military Munitions
Appendix III
Comments from the Department of Defense




Page 28                                   GAO-04-147 Military Munitions
Appendix III
Comments from the Department of Defense




Page 29                                   GAO-04-147 Military Munitions
Appendix IV

GAO Contacts and Staff Acknowledgments                                                         Appendx
                                                                                                     iIV




GAO Contacts      Ms. Anu K. Mittal, (202) 512-3841
                  Edward Zadjura, (202) 512-9914



Acknowledgments   In addition to those named above, Jack Burriesci, Elizabeth Erdmann,
                  Sherry McDonald, and Matthew Reinhart made key contributions to this
                  report. Also contributing to this report were Cynthia Norris, Rebecca Shea,
                  and Ray Wessmiller.




(360286)          Page 30                                          GAO-04-147 Military Munitions
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                         To order by Phone:     Voice: (202) 512-6000
                                                TDD: (202) 512-2537
                                                Fax: (202) 512-6061


To Report Fraud,         Contact:
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Waste, and Abuse in      E-mail: fraudnet@gao.gov
Federal Programs         Automated answering system: (800) 424-5454 or (202) 512-7470



Public Affairs           Jeff Nelligan, Managing Director, NelliganJ@gao.gov (202) 512-4800
                         U.S. General Accounting Office, 441 G Street NW, Room 7149
                         Washington, D.C. 20548
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