Department of Defense Air Pollution Control: Progress and Delays

Published by the Government Accountability Office on 1977-07-18.

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

                         DOCUMENT RESUME
02793 - [A2033111]

Department of Defense Air Pollution Control: Progress and
Delays. LCD-77-305; B-166506. Jujy 18, 1977. 25 pp. + 3
appendices (6 pp.).
Report to the Congress; by Elmer B. Staats, Comptroller General.

Issue Area: Facilities and Material Management: Operation and
    Maintenance of Facilities (708); Environmental Protection
    Programs: Environmental Protection Standards (2201).
Contact: Logistics and Communications Div.
Budget Function: National Defense: Department of Defense -
    Mil.tary (except procurement S contracts) (051).
crganization Concerned: Department of Defense; Environmental
    Protection Agency.
Congressional Relevance: house Committee on Armed Services;
    Senate Committee on Armed Services; Congress.
Authority: Clean Air Act of 1963 (77 Stat. 392). Air Quality Act
    of 1967 (81 Stat. 485). Clean Ai.r Act Amendments of 1970 (84
    Stat. 1676). Resource ConseLvation and Recovery Act of 1976
    (90 Stat. 2799). Hancock v. Train, 426 U.S. 167. H. Rept.
    95-294. Executive Order 1 282. Executive Order 11507.
    Executive Ordc   11752.
          Pollution from stationary sources at some Department of
 Defense (DOD) installations will continue to pollute the
 Nation's air for several years. Federal agencies had until July
 1, 1973, in most areas of the country, to comply with Federal
air pollution sta.~dards. Findings/Conclusions: While some steps
 have been taken to control air pollution, DOD needs to do much
 more to comply with emission control standards. DOD and its
 military services did not know, as of July 1, 1975, if their
installations were complying with air pollution standards. More
DOD installations could have been in compliance by the deadline
if the services had evaluated the status of their installations
sooner. The controllable causes of delayed compliance by the
military services were long delays in deciding how to control
emissions and lengthy project design phases. The uncontrollable
causes were the erergy crisis, the lack of technology, and the
unforeseen construction delays. Several State and local
officials were uncertain whether they should be involved in
consent agreements and whether they could enforce coapli'.e
commitments under such agreements. The Army and the Air Force do
not have a procedure to guarantee that environmental protection
recommendations are carried out. Recommendations: The Secretary
of Defense should require the Army, Navy, and Air Force to:
evaluate current air pollution emission surveys to isolate
violations of stationary source standards; develop the funding
program needed to attain full comFliance by the new deadline;
and make a thorough inspection to identify sources not in
compliance with new standards and take the necessary corrective
actions; and establish procedures to isolate and monitor
controllable causes which delayed control projects. The Army ani
the Air Force should be required to adopt a system of scheduled
surveys and establish procedures for monitoring installations'
actions on survcy team recommenlations. (Author/QM)


Department Of Defense
Air Pollution Control:
Progress And Delays
Ai- pollution control standards were sup-
posed to be met by July 1, 1975. The
Department of Defense nas made progress
but about 30 percent of the major pollu-
ting installations were still not complying
with the standards in January 1977. Some
of these may not comp'v for several more

GAO recommends steps to avoid delays in
correcting violations. it also discloses the
questionable status of jet engine test cells
under existing clean air legislation, which the
Congress should clarify.

L(CD-77-306                                       JULY 18, 1977
                           WASWHINTON, D.C.   te6s


To the President of the Senate an< the
Speaker of the House of Representatives

     This report discussed the status of major Defense
installations in relation to air quality standards and air
control authorities. The information should be useful in
gaging how clean air legislation is working in Federal

     A previous report to the Congress on August 23, 1973
(B-166506), discussed the Federal and State reluctance to
enforce air pollution control laws and regulations,

     We made the review pursuant to the Budget and Accoutlting
Act, 1921 (31 U.S.C. 53), ard the Accounting and Auditing Act
of 1950 (31 U.s.C. 67).

     We are sending copies of this report to the
Office of Management and Budget; the Secretary of Director,
and the Administrator, Environmental Protection Agency.

                                   omptroller General
                                  of the United States
                                            PROGRESS AND DELAYS

              Pollution from stationary sources (all sources
              except vehicles) at some Department of Defense
              installations will continu tro pollute the
              Nation's air for several years. While some
              steps have been taken to control harmful air
              emissions, Defense needs to do much more to
              comply with emission control requirements.
              (See ch. 2.)

             The Clean Air Amendments of 1970 require
             Federal facilities to comply with Federal,
             State, and local air pollution standards. On
             April 30, 1971, the Environmental Protection
             Agency published air quality standards for
             sulfur oxide, nitrogen oxide, carbon monoxide,
             particulate matter, hydrocarbons, and photo-
             chemical oxidants. Federal agencies had until
             July 1, 1975, in most areas of the country to
             comply with Federal standards. The Congress
             is considering extending the deadline.   (:'ee
             pp. 1 and 2.)
             California has filed suit to stop the Navy
             from violating air pollution standards.
             The dispute is whether the Clean Air Act,
             as amendeC, makes jet engines tested in
             test cells subject to stationary-source
             air pollution requirements.  (See ch. 4.)
             The Congress should amend the law to
             clarify the situation.

             WHAT CAN BE DONE

             Defense and its military services did not
             know as of July 1, 1975, if their installa-
             tions were complying with air pollution

            The Environmental Protection Agency in July
            1975 c-assified 269 Defense installations
            as major air pollution emitters. Major

Tur Sheet. Upon removal, the report
cover date should be noted hereon.    i               LCD-77-305
emitte[s can discharge at least 100 tons of
a single air pollutant each year. About
70 percent of Defense's major emitters were
in compliance in January 1977. More in-
stallations could have been in compliance by
the deadline if the services had evaluated
the status of their installations sooner.
(See pp. 3 to 6.)
In recognition of pending legislation to ex-
tend the d&adline, the Secretary of Defense
should require the Army, Navy, and Air Force

-- evaluate current air pollution emnission
   inventories to isolate violatioi, of sta-
   tionary source standards,
-- develop the funding program needed to
   attain full compliance by the new deadline,

-- make a thorough inventory,if and when addi-
   tional standards are issued, to identify
   sources not in compliance and take the ac-
   tions necessary to meet new standards in a
   timely manner.
Defense agrees with the recommendations and
feels it has always acted quickly to attain
full compliance but that the Government bud-
get system takes 3 years tc move an abate-
ment project from inception to approval.
(See p. 6.)


At five installations visited, the military
services could not control about half of the
causes which delayed them from complying with
the standards. The most time-consuming causes
of delays could have bee, controlled.

The controllable causes were long delays in
deciding how to control emissions and lengthy
project design phases. The uncontrollable
causes were (1) the energy crisis, (2) the
lack of technology, and (3) the unforeseen
construction delays.   (See p. 10.)

             The Secretary of DefensF should require the
             Army, Navy, and Air Force to establish pro-
             cedures to isolate and monitor controllable
             causes which delayed control projects.
             Defense agrees with this recommendation.
             (See p. 14.)

             Consent agreements between Federal agencies
             and the Environmental Protection Agency make
             the agencies comply with air pollution con-
             trol standards by an established date.
             States are encouraged to take part in the
             compliance process. Several State and local
             officials were uncertain whether they should
             be involved in consent agreements and whether
             they could enforce compliance commitments
             under such agreements.
            The Congress is considering amending the Clean
            Air Act to clarify

             --whether and when Federal agencies are bound
               by Federal, State, interstate, and local
               procedural requirements and
            -- who is authorized to enforce compliance with
               air quality standards.  (See p. 17.)

            Navy makes regular technical environmental
            surveys of its installations and requires
            feedback on recommended actions. The Artay
            and the Air Force survey installation prob-
            lems on request and do not have a procedure
            to guarantee thdt recommendations are carried
            out.  (See ch. 5.)
            Defense said that inspections will be made
            where warranted and it did not comment on
            need for monitoring the bases' actions on
            recommendations by Army and Air Force environ-
            mental teams.
            The Secretary of Defense should require the
            Army and Air Force to adopt a system of sched-
            uled surveys and establish procedures for
            monitoring installations' actions on survey
            team recommendations. (See p. 24.)

ITer Shot                        iii
                         Co n ten    ts
           AIR POLLUTION LAWS                                   1
               Compliance with stationary source emis-
                 sion standards                                 3
               Cost estmnates for full compliance               4
               Conc.usions, recommendations, and agency
                 comments                                   6
               Reasons for missing July 1, 1975, com-
                 pliance deadline: controllable and
                 uncontrollable                            'O
               Conclusions, recommen6ation, and agency
                 comments                                  14
               Reasons for lack of operating agreements    15
               Emission control problems                   18
               Litigation in process
               Recommendation to the Congress              19
   5       INTERNAL REVIEWS                                22
               Environmental surveys                       22
               Internal audits                             23
               Conclusions, agency comments, and
                 recommendation                            24
   6       SCOPE OF REVIEW                                 25
   I       Letter dated March 23, 1977, from Acting
            Assistant Secretary of Defense (Installa-
             tions and Logistics)
 II        Letter dated March 17, 1977, from Acting
             Assistant Administrator for Planning and
             Management, Environmental Protection
             Agency                                        28
III        Principal officials responsible for activi-
             ties discussed in this report                 31

DOD   Department of Defense

EPA   Environmental Protection Agency

GAO   General Accounting Office

                          CHAPTER 1
                     AIR POLLUTION LAWS
     Miilions of tons of harmful pollutants are gradually
saturating the atmosphere each year. The Council on
Environmental Quality estimated the 1975 nationwide cost
for controlling air pollution to be $11.6 billion.

     In 1955 the Congress passed the first ail pollution
control act authorizing the Surgeon General to examine the
nature and extent of the Nation's air pollution problems.
The Clean Air Act of 1963 (77 Stat. 392) authorized grants
to State and local agencies for developing control programs
and provided the Federal Government authority to act against

     The Air Quality Act of 1967 (81 Stat. 485) required
(1) identifying geographical regions where air pollution
was a problem, (2) publishing air quality criteria for those
pollutants that may le harmful to a person's health or wel-
fare, and (3) publishing information on the techniques which
could be used to control the sources of those pollutants.
The States were required to develop standards for the pollut-
ants and plans for implementing the standards subject to Fed-
eral review and approval.

     The Clean Air Amendments of 1970 (84 Stat. 1676) expanded
the Federal Goverrndent's role by requiring the Administrator,
Environmental Protection Agency (EPA), to establish national
ambient air quality standards. Ambient air is that portion
of the atmosphere external to buildings and accessible to the
general public. Such standards apply to the total allowable
concentration of pollutants in the atmosphere from all emis-
sion potints.

     On April 30, 1971, EPA published standards for six air
pollutants--sulfur oxide, nitrogen oxide, carbon monoxide,
particulates, hydrocarbons, and photochemical oxidants.
EPA's Office of Air Quality Planning and Standards said that
additional research is being done on other po.llutants, sucr
as lead, sulfates, and nitrates, and that standards for these
pollutants may be established by the late :.970s or early

     The 1970 amendments also require States to adopt plans
for implementing, maintaining, and enforcing national ambient
air quality standards. The plans are to include emission
limitations for pollution sources (e.g., power plants,

incinerators) and timetables for complying with the national
standards. Pollutant emission standards to protect public
health were to be attained, in most cases, within 3 years
after EPA approved the State plans. EPA's 1976 enforcement
progress report states that ambient air quality standards
were to be met by May 31, 1975, except for portions of
15 States where an extension up to 2 years has been granted
for one or more polil'tants. EPA guidelines for Federal
agencies specified Ju.v 1, 1975, as the deadline for most
areas of the country to comply with the standards but did
not discuss enforcement (see pp. 15-17). The 95th Congress
is considering amendments that would extend the deadline up
to 5 years. A prior bill to revise the 1970 amendments died
on the final day of the 94th Congress.

     The 1970 amendments specifically require Federal Acili-
ties to comply with air pollution control requirements to
the same extent any person is subject to such requirements.
Executive Orders 11282, 11507, and 11752, dated May 26, 1966,
February 4, 1970, and December 17, 1973, respectively, re-
affirmed Federal agencies' responsibilities to comply with
applicable standards and required them to provide leadership
in attaining such standards.

     The last order required the heads of Federal agencies
(1) to make certain that facilities under their jurisdiction
are designed, constructed, managed, operated, and maintained
to conform to Federal, State, interstate, and local standards,
(2) to cooperate with EPA, State, interstate, and local agen-
cies in the prevention, control, and abatement of environ-
mental pollution, and (3; to provide information, in accord-
ance with EPA guidelines, necessary to determine installation

                             CHAPTER 2

                      TOWARD COMPLIANCE
     The Environmental Protection Agency defines major air
pollution emitters as facilities capable of emitting at
least 100 tons of a single air pollutant a year. The major
emitters account for about 80 percent of all stationary
source air pollutants in the United States.

     The Department of Defense (DOD) and its military serv-
ices have made progress in abating air pollution from sta-
tionary sources (all sources other than vehicles). However,
as of the July 1, 1975, deadline, they did not know if their
installations were complying with air pollution standards.
Requirements were established as early as August 1966 to
identify pollution sources and to periodically report on
progress in abating the pollution. Yet, in July 1976 or
1 year after the deadline, the services said that their
reporting requirements and other management controls did not
provide assurance that all air pollution problems requiring
corrective action had been identified.


     On May 6, 1975, EPA published guidelines for Federal
agencies' use in (1) determining the compliance status of
all Federal stationary sources subject to Federal, State,
and local emission limitations and (2) establishing com-
mitments to correct deficiencies. Air pollution sources
and related emissions data necessary to determine compliance
had to be reported to EPA and the State control agencies on
the air pollutant emissions report. The guidelines provide
for a three-phase (major emitters, minor emitters in highly
polluted areas, and all other) program for determining com-
pliance. The guidelines do not stipulate target dates for
submitting the air emission inventory.

     Service officials said the inventory's results will
help them to (1) manage their air pollution control programs
by providing, for the first time, a baseline of all air pollu-
tion sources under their control and (2) identify any non-
complying sources for which no corrective action is planned.

     We asked EPA for information on the status of compliance
by military installation3 at July 1, '975. Through its 10 re-
gional offices, EPA identified 269 DOD installations as major

air pollution emitters. EPA's regional officials    pointed out
that they were not sure of  the accuracy of the statistics   and
that the compliance status of many  installations  was  unknown
because there were not enough (1) source tests, (2) State and
EPA inspections, and (3) established procedures   for obtaining
necessary data from Federal  facilities.  The table  below sum-
marizes EPA's estimate of DOD's overall  progress  in  comply-
ing with air pollution standards by the deadline.
                           July-l-195, compliance status-
Military      Major         Per -       Per-           Per-
service     emitters     In cent   Out  cent  Unknown  cent

Army           84        34   40      31   37      19       23
Navy           79        31   39      36   46      12       15
              104        51   49      28   27      25       24
Air Force
  Agency         2        -    -      -1   50       1       50

    Total      269      116   43      96   36      57       21

     DOD and EPA said (see apps. I and II) that about
                                                     by Janu-
70 percent of the major emitters were in compliance installa-
ary 1977. EPA  said that it has classified 263 DOD
tions as major emitters, and 21 more installations are on the
borderline between major and minor emitters. Tc clarify
relative impact of DOD installations on attainment of cleaner
air, EPA noted that the 284 installations represented 1.3 per-
cent of the 22,140 major emitters which EPA has identified
at January 1, 1977.
     To comply with air quality standards during fiscal years
1971-77, the services requested $256 million and received
$234 million for controlling air pollution and estimated that
an additional $101 million would be needed to correct air
pollution problems beyond fiscal year 1977.
     The Clean Air Amendments of 1970 authorize the President
to exempt any executive bzanch emission source from compli-
ance if he determines it to be in the paramount interest of
the United States. No exemption, however, can be granted due
to lack of appropriation unless the President has specifically
requested such appropriation and the Congress has denied it-.
     The following table shows that the Congress generally
has supported the military construction budget requests
for air pollution control projects.
                    hi                          qi   Ff                     -                °               1

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     We believe that many of the installations out of
compliance or in an unknown status could have complied by
the deadline had the services taken earlier actions to
determine the status of the installations.

     The lack of emissions data from which compliance deter-
minations can be made appears t b'e resolved. The EPA air
pollutant emissions reports, when completed for all emitters,
should provide the data necessary for the services to deter-
mine the compliance status of their installations and to
monitor actions necessary to correct deficiencies.

     In recognition of pending legislation to extend the
deadline (see p. 2), we recommend that the Secretary of De-
fenae require the Army, Navy, and Air Force to
     -- evaluate the current air pollution emission inven-
        tories to isolate violations of stationary source
        emission standards,

     -- develop the funding program needed to attain full
        compliance by the new deadline, and

     -- make a thorough inventory, if and when additional
        standards are issued, to identify sources not in
        compliance and take the actions necessary to meet
        new standards in a timely manner.

     DOD said (see app. I) it is in the process of identify-
ing those stationary sources which do not meet emission
standards and is continuously monitoring this effort through
semiannual and annual reports. DOD believes it has always
taken timely action to attain full compliance but that one
problem is that the Federal Government's budget system takes
3 years to move an abatement project from inception to

     DOD also said that it is closely monitoring the pub-
lication of revised standards and the issuance of new
standards to effect timely implementation. As a followup,
it is insuring that appropriate projects are added to the
deficiency list which is updated on a semiannual basis
and that the projects are properly programed.

                         CHAPTER 3


     The Environmental Protection Agency considered six of
the eight industrial installations we visited to be out of
compliance on July 1, 1975. The status of one installation
was in dispute (see ch. 4), and State authorities were re-
viewing the emission sources at McClellan Air Force Base,
      The table on the following page shows that these in-
stallations (excluding McClellan AFB) had identified
44 sources which needed corrective measures. Of this num-
ber, 22 were complying with applicable requirements and 22
were not. Of the 22 sources not in compliance on July 1,
1975, 14 had control projects in process, and three were
already in compliance at the time of our visit. All but
four of the sources are expected to be in compliance be ire

                       Status of StationarY Sources of Air Pollutants
                  at     selected   nustra-                  n
                                                             nsatone atary
                                              Comp'.iance    Actual (A)/         facility
                                                stateus     expected (3)        operating
                 Sources emitting              07/01/75      compliance      under agreements
Installation      air pollutants                                dat-e           with State

Radford Army     Powerhouse *1                       1        (B) 06/77            Yes
Plant,           Powerhouse #2                        1       (E) 04/77             ast
Va.              Open burning of
                 explosive con-                                                    Not
                 taminated waste                      1       (A) 05/76         applicable

                  Open burning of
                  waste propellants                   1       (A) 03/77            N/A

                  Nitric acid/sulfuric
                  acid concentrators                  1       (E)    06/77         No

                  plants                              1       (E' 07/77            No

                a/Acid tanks                          1       (E) 07/77            No

                  Oleum plant                   1             (A) 01/73            N/A

                  Ammonia oxidation
                  plant                         1             (A) 01/73            N/A

                                                2     7                             2

Holston Army      Ammonia oxidation
Ammunition        process                             1       (E) 01/79            Yes
                  Nitric acid con-
                  centrator:                          1       (E) 01/79            Yes

                  Boilers-Areas A&B                   2       (E) 11/77            Yes

                  Gas-producing plant                 1       (E) 06/80            No

                  Open burning of ex-
                  plosive and explo-
                  sive contaminated
                  waste                               1             (b)            No

                  Open burning of
                  solid waste                   1             (A) 11/74            N/A

                                                 1    6                             4

Letterkenny       Bo:ilers                       1            (A) 1973             N/A
Army Depot,
Chambersburg,     Open burning of
Pa.               waste                               1       (A) 08/75            N/A

                                                 1    1                             0
                                         Compliance     Actual (Aj/       Facility
                                           status      expected (E)      operating
                  Sources emitting        07/01/75      compliance
 Installation      air pollutants                                     under agreement
                                           n   Out         date          with State
 Alameda Naval   Heati;g and steam
 Air Station,    plants (2 buildings)         2
 Alameda,                                                (A) 1974          N/A
 Calif.          Liquid storage
                 tanks                        2          (A) 1967
                 (3 buildings)                                             N/A
                                              1          (A) 1973          N/A
                 Firefighting school          1          (A) 1967          N/A
                 Industrial sources           6          (A) 1973
                 (7 buildings)                                             N/A
                                              1          (A) 1974          N/A
                                          13      0                          0
 Philadelphia    Foundry
 Naval Base,                                      1     (A) 08/76          N/A
 Philadelphia,   Abrasive blast                   1        (c)             No
 Pa.             facility
                 Test boilers                     1     (A) 07/76          N/A
                 Firefighting school       1            (A) 04/75          N/A
                 Training boilers                 1     (A) 11/75          N/A
                                          1       4                          0

Charleston       Main power plant                 1
Naval Base,                                             (E) 18/79          No
Charleston,      Classified waste
S.C.                                              1     (A) 10/75          N/A
                 incinerators (2)                 1        (d)             N/A
                 Boilers (4 buildings)    4             (A) 10/70          N/A
                                          4       3                         0

Tinker Air        Paint hanger                    1     (E) 09/77         No
Force Base,
Oklahoma               (e)

                                          0       1                        0
    Total                               22   22                           6
a/This project has Deen completed; however, compliance
  until the pollutant controls are connected to         will not be attained
  acid concentrators and nitrocelluIose plants the new nit-ic acid/sulfuric
                                                under construction.
b/Control technology is not available.
c/City of Philadelphia officials consider this
  take action against the base unless a complaintminor source and will not
                                                  is received.
d/One incinerator was deactivated in March 1975.
e/Tinker had not identified all of its air pollutant
                                                       sources; therefore, the
  number of sources emitting air pollutants and
  unknown.                                       their  compliance status were

     About half the reasons delaying compliance at five
installations visited were controllable and about half were
uncontrollable by the lailitary services. We categorized the
controllable reasons as (1) lengthy decisionmaking processes
on controlling emissions and (2) prolonged project design
phases. The uncontrollable reasons included (1) the energy
crisis, (2) the lack of technology, and (3) the unforeseen
construction delays.
     The status and problems of the five installations may
not be indicative of the causes for noncompliance and delays
in attaining compliance at other facilities since we selected
the five because of their industrial activities. DOD said
that many of its 67 noncomplying .Iajor emitters are out of
compliance because of uncontrollable reasons, and corrections
have been programed for the few emitters which are out of com-
pliance because of controllable reasons.
     The following table summarizes the reasons delaying com-
pliance for 16 sources at 5 installations.


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                                                             aa-I a O                                                C             aa                  o         v, 01~~~~~uMI                      n                    3
     In March 1973, local pollution authorities formally
requested Tinker Air Force Base to provide a comprehensive
emissions inventory to determine the inptallation's compli-
ance status. As of March 1976, Tinker had not identified
and quantified all of its air pollut!on sources and had not
provided Federal, State, or local authorities with the in-
formation necessary to determine its air pollution status.
EPA, State, and local officials said that the installation
had not emphasized the importance of air pollution control.
DOD said that Tinker reported its emissions inventory to EPA
in June 1976 and, as of January 1977, had not received the
results of EPA and local officials' review.

Lengthy decisionmaking-process
     Bringing 10 sources at four installations into compliance
was delayed while officials at various levels spent consider-
able time in reviewing and approving control plans. The
decisionmaking processes sometimes require6 3 years or more.
The following examples illustrate the delays.
     Powerhouse No. 1 is Radford Army Ammunition Plant's
largest source of pollution and is capable of emitting about
41 tons of particulate matter daily. The primary reason for
the powerplant not being in compliance by the deadline was
the prolonged delay (39 months) in deciding how to control
the pollution. The energy crisis accounted for 10 months
of the delay. After the decision was made, it took another
21 months to design the control project.

     In December 1969, the powerhouse was identified as an
air pollution source needing correction. In March 1970,
a fuel study recommended that the powerhouse continue using
coal with appropriate air pollution control devices. The
Army requested and the Congress appropriated fiscal year 1971
funds to install an electrostatic precipitator (a control
device which separates suspended particulates from a gas
stream via electrical charges) and a 300-foot stack. However,
a fuel study in September 1971 indicated that savings could
be achieved by converting the powerhouse to burn oil and gas,
G-d a fuel conversion project was submitted in place of the
precipitator and stack. DOD i'sapproved the fuel conversion
project in April 1972 because of a natural gas shortage. The
army returned to its original plans and completed the prelimi-
nary design in November 1972. Because the drawings indicated
cost overruns, officials delayed additional design work and
submitted a revised fuel study for approval. DOD again dis-
approved fuel conversion and, in February 1973, the Army

resumed designing the precipitator. The project is expected
to be completed in June 1977--2 years after the deadline.
     The Charleston Naval Base main powerplant was identified
as a pollution source in March 1967. Although   tests did not
reveal whether violations existed, the base began  installing
air pollution control devices in June 1970 but  canceled  the
project. In March 1971, the base initiated  a  project to  con-
vert the powerplant from coal to oil and natural  gas.   In
August 1973, DOD required that all fuel conversion projects
(from coal to gas or oil) be canceled because of the energy
crisis. The base restudied the matter and submitted a request
for particulate controls in June 1975. The controls werein
expected to be funded in fiscal year 1978 and completed
July 1979--4 years after the deadline. DOD now expects proj-
ect funding to be deferred to fiscal year 1979.
     Charleston Naval Base officials said that a major problem
was the low priority assigned to environmental matters. Offi-
cials of the Naval Facilities Engineering Command, Southern
Division, and State of South Carolina agreed that the instal-
lation did not emphasize environmental matters enough.
Prolonged design phases
     Extensive time to design control projects delayed seven
sources at three installations from complying with air pollu-
tion regulations. Some projects took 4 years to design.
Reasons for the prolonged design periods were project scope
changes, design changes, and prolonged review and approval
of designs by various military levels. A project at Holston
Army Ammunition Plant illustrates the design delays.
      According to State officials, Tennessee issued its Pollu-
tion Control Regulations for particulate matter in August
1969. A surrey conducted at l'olston Army Ammunition Plant
during May and June 1970 indicated that particulate emissions
from its stoker boilers s'hould .te reduced. The Army requested
air pollution control funds to install electrostatic precipi-
tators, and the Congress appropriated these funds for fiscal
year 1973. The design contract was awarded in May 1972, and
concept design was completed in December 1972. However, the
Corps of Engineers required the architect/engineer firm to
completely rework the design because it had the precipita-
tors inside the building rather than outside. The revised
concept design was completed in September 1973. The
architect/engineer finished the final design in April 1974.
The review and approval process was finished in February 1975,
 33 months after awarding the design contract. Construction
 is expected to be completed in November 1977--28 months after
 the deadline.

Energy crisis

     Three installations planned to correct their air pollu-
tiH  problems by converting to cleaner burning fuels. How-
ever, fear of oil and gas shortages from the energy crisis
caused these plans to be canceled. The installations had to
reduce emissions by installing control devices such as elec-
trostatic precipitators which delayed compliance at Charleston
Naval Base, Philadelphia Naval Base, and Radford Arm'/ Ammuni-
tion Plant.

Lack of technology
     Lack of technology to control emissions primarily af-
fected explosive waste disposal at Army ammunition plants.
Because open burning of waste propellants at. the Radford Army
Ammunition Plant violated State regulations, the Army re-
quested funds for a waste propellant incinerator, and the
Congress appropriated the funds for fiscal year 1972. Due
mainly to lack of technology, the Army spent about 4 years
deciding how to control the emissions and design the project.
Radford had a prototype incinerator operating in May 1972 and
monitored its operation over a 14-month period. The results
provided the criteria to design the waste propellant incinera-
tor which was completed in March 1977--20 months ;after the

Construction delays

     Four sources at two installations failed to meet the com-
pliance deadline because of unforeseen construction delays.
These included a labor strike, bid protests, disputes with the
contractor over loss of equipment and material, and the time
needed to complete a high priority operational requirement.

     We believe that the most time-consuming causes for not
meeting the compliance deadline were controllable. Quicker
decisions on controlling emissions and more timely project
designs would have allowed several DOD sources to attain
compliance by the deadline.

     We recommend that the Secretary of Defense require the
Army, Navy, and Air Force to establish procedures to isolate
and monitor controllable factors delaying control projects
so that pollution sources can be brought into compliance and
necessary actions taken to meet any authorized extension of
the compliance deadline.

     DOD agreed (see app. I) and said that it is giving
greater attention to this area during semiannual review of
the overall program, during the budget review procesas, and
during staff visits to selected commands and installations.
      EPA guidelines for Federal agencies require consent (or
operating) agreements to be signed by representatives of
each Federal facility, EPA, and if possible, concurred with
by the State air pollution control agency. Consent agree-
ments state the conditions under which the facility will
operate and the schedule under which the facility will be
brought into compliance. Each agreement will identify the
source, the applicable standard, proposed control method, and
a timetable for attaining compliance.

     The timetable represents the Federal facility's commit-
ment to achieve compliance and gives the progress dates for
(1) completing the design, (2) initiating and completing con-
struction of control devices or process modifications, and
(3) achieving final compliance. EPA and State inspections,
as resources permit, verify the facility's progress.  Informa-
tion on source compliance status and progress will be pub-
lished in the State Implementation Plan Progress Report. The
guidelines do not discuss enforcement methods or procedures.

     EPA said that of the 68 major emitters which DOD cur-
rently reports as out of compliance

     -- 24 are on compliance schedules set forth in consent
        agreements between EPA and the installations,
     -- 22 are the subject of current negotiations which
        should produce consent agreements, and

     -- 22 are so close to complying or making such satis-
        factory progress toward compliance that EPA does not
        believe that consent agreements are needed.

     Five of the installations visited did not have operating
agreements with State pollution control authorities for
10 noncomplying sources. State and local authorities pro-
vided various reasons for not having operating agreements
with the installations.

      Radford Army Ammur.ition Plant does not have an operating
 agreement with Virginia for three of its noncomplying sources
 because the sources emit nitrogen oxides which, a State offi-
 cial said, are not a problem in the Radford area.

      Holston Army Ammunition Plant had operating agreements
 with Tennessee for its ammonia oxidation process and nitric
 acid concentrators until February 1976. Through an oversight,
 these agreements expired withouc the State's knowledge and
 Holston did not request extensions. In reply to our draft,
 DOD said that Holston was granted extensions in January 1977.
 The plant had also been granted a permit for its open burning
 of explosive wastes. However, this permit had also expired
 without the State's knowledge or without Holston requesting a
 renewal. Holston's gas-producing plant wis not on an operat-
 ing agreement because State officials had little knowledge
 of this source and did not know what pollutants weie being

      City of Philadelphia officials prefer to deal with Fed-
 eral facilities informally because they are not certain that
 operating agreements with Federal facilities are legally en-
 forceable. Conseauently, operating agreements have not been
 negotiated with tha Philadlphia Naval Base.

      DOD said that EPA and the Navy entered into an operating
 agreement durino May 1976 outlining steps for the main power-
 plant at Charleston Naval Base to achieve final compliance
 in July 1979. South Carolina refused to grant an agreement
 to the base because it believed that such an agreement with
 Federal facilities only represented a publicly stated goal
 and was not legally binding. South Carolira also feared that
 an agreement would jeopardize its position against the base
 if the State is given authority to enforce its regulations
 against Federal facilities. State officials also believed
 that an operating agreement with Charleston Naval Base would
 set a bad example for other polluters in the State.

      Tinker Air Force Base has not requested an operating
 agreement for its paint hanger. The Oklahoma City-County
 Health Department said that it is not their responsibility
 to convince Tinker to request an agreement and that such a
,request depends upon the base's initiative. Furthermore,
 local officials believe that thel could not legally enforce
 the agreement.

     The State of Kentucky appealed a judgment of the Sixth
Circuit Court of Appfals to the Supreme Court regarding the
State's authority to require Federal installations to secure

operating permits. The Supreme Court in a 7 to 2 decision
on June 7, 1976, ruled that the Clean Air Act obligates Fed-
eral installations discharging air pollutants to joi;i with
hon-fder-alitailtiei    in compI  i-nwith- State conrol and
abitement requirements, but obtaining a perit-ifom-a state
is not among such requirements. The Court said that any clear
and unambiguous declaration by the Congress that Federal in-
stallations may not operate without a State permit cannot be
f£,und in the act nor derived from the legislative history of
t['e Clean Air Amendments of 1970. The Court said that should
it be the decision of the Congress to subject Federal instal-
lations to State permit requirements, the Congress need only
amend the act to make its intention evident (Hancock vs.
Train, 426 U.S. 167).
     The Congress in its October 1976 revision of solid waste
legislation provided in the Resource Conservation and Recovery
Act of 1976 (90 Stat. 2795) that Federal installations are
subject to all Federal, State, interstate, and local require-
ments, both substantive and procedural including any require-
ments for permits.
     The Congress is considering amending the Clean Air Act
to clarify t:[e status of Federal agencies regarding Federal,
State, interstate, and local requirements both substantive
and procedural and the authority to enforce compliance by
Federal agencies with the ambient air quality standards.
     The House Report accompanying the proposed Clean Air Act
Amendments of 1977 states that the new section on Federal fa-
cilities is intended to overturn the Hancock case; to end any
furt.er delays, excuses, or evasions by Federal agencies; and
to mandate complete compliance, except as express Presidential
exemption may otherwise permit in the interests of national
security. (House 3eport No. 95-294, May 12, 1977).

                            CHAPTER 4


     The Navy and the State of California have different
opinions concerning whether the Clean Air Act, as amended,
makes emissions from jet engines tested in test cells sub-
ject to the State's stationary source air pollution standards.
Consequently, California has filed suit against the Depart-
ment of the Navy for violating visible emission stationary
source standards by jet engine test cells at four naval air
stations. The outcome of this controversy could cost millions
of dollars. The Navy's defense is that the Federal Government
has preempted the field of aircraft and aircraft engine emis-
sions and has not issued regulations for testing military air-
craft and aircraft engines. Under section 233 of the Clean
Air Act, State and local authorities cannot act until the
Administrator of EPA has promulgated such regulations.

     The Bay Area Air Pollution Control District notified the
Naval Air Station, Alameda, that one of its jet engine test
cell facilities was violating local visible emission air pol-
lution regulations in July 1970. Test cells are buildings
which house jet engines during testing operations. The Navy
has been trying to develop technology to control the particu-
late emissions from test cells. However, the Navy does not
believe current technology provides a method, at a reasonable
cost, to assure that jet engine test cells comply with sta-
tionary source air pollution regulations.

     Three control methods are being examined--test cell
modification, engine modification or replacement, and jet
engine fuel modification. The Navy believes wet-packed
cross flow scrubber systems (a device which uses water to
remove particulate matter) will reduce engine test emissions
to within existing stationary source particulate standards.
Four new test cells at two naval air stations are being con-
structed with the scrubber systems. However, the modification
of an existing cell requires structural redesign. The Navy
estimates that a scrubber system can be installed on an exist-
ing test cell for about $1.9 million. Increased utility costs
are about $88,000 a year, based on two tests per day, 250 days
per year.

     We were told that, in some cases, adequate supplies of
electrical power for the scrubbers may not be readily obtain-
able and that an obligation exists to analyze the relative

value and impact against the conservation of limited supplies
of energy and water, especially in areas affected by drought.
Consequently, the Naval Facilities Engineering Commasnd,
Western Division, does not consider the installation of
scrubbers at Alameda to be a reasonable solution. Other
methods of test cell modifications, such as installing ther-
mal converters (afterburners which reburn emissions before
entering the atmosphere) or electrostatic precipitators,
have also been rejected or are still being examined.
     Engine modifications and new engine procurements are
partial solutions in controlling test cell emissions. All
new model jet aircraft engines being purchased are smokeless.
The Navy also has a $38 million program underway to modify
certain existing jet engines. Although these converted
engines will essentially be smokeless, that change may in-
crease certain other emissions. Two of the four engine models
at Alameda which have been cited as violating local visible
emission standards are being converted.

     The third method being considered is modifying fuel with
additives. Alameda uses a ferrocene additive which, to some
degree, effectively controls visible emissions from some of
its jet engines during testing. For the one engine model
consistently cited for violations, however, the additive is
used for only 45 minutes of the normal 4- or 8-hour tests.
Alameda officials stated that the long testing time is due
to the highly technical and complicated nature of military
engines, especially turbofan engines, and the degree of pre-
cision required for combat engines. Officials also said that
the fuel additive could not be used beyond 45 minutes because
iron deposits begin collecting on the engines' internal parts
and degrade performance. Personnel of a major airline agreed
that there are many complications with highly technical en-
gines and that the Navy may be justified in testing its en-
gines for longer periods and restricting fuel additive use.


     In January 1976, the California Air Resources Board and
Bay Area Air Pollution Control District filed suit in U.S.
District Court against the Department of the Navy and Com-
manding Officers at the Naval Air Station, Alameda, and three
other Department of the Nevy installations in California for
operating jet engine test cells that exceed State and local
air pollution standards for stationary sources. The Board's
suit contends:

     -- Section 118 of the Clean Air Act provides that Federal
        facilities must comply with duly promulgated Federal,
        State, and local requirements respecting control and
        abatement of air pollution.

     -- The cells where the jet engine testing takes place
        "constitute stationary sources within the meaning of
        the Clean Air Act, the California Implementation Plan
        and applicable local rules and regulations."
     --UWder the California Implementation Plan and local
       regulations, persons who operate stationary sources
       must comply with specific visible emission standards.

     -- Emissions from test cell stacks at Alameda and the
        other three installations exceed local visible emis-
        sion standards.

     -- State oi local agencies have not granted the installa-
        tions a variance for test cell operations which would
        allow them to exceed the visible emission regulations.

     The Navy disagrees with the pollution/State authorities'
opinion that the test cells are out of compliance.  It pro-
vides the following arguments:

    -- The test cells do not, of themselves, produce air
       pollutants. Rather, the aircraft engines constitute
       the sole source of the air pollutants emitted from the
       test cells.

    -- The effect of engines in test cell emissions on air
       quality has been determined by use of EPA computer
       models to be insignificant.

    --Only the Administrator of EPA, not State or local gov-
      ernments, is empowered, under the Clean Air Act, as
      amended, to prescribe and enforce emission standards
      and limitations with respect to the enissions from
      military aircraft and aircraft engines, regardless of
      where such engines are located.

    --"* * * Consequently, aircraft engine test cells are
      considered not to be 'stationary sources' of air
      pollutants within the meaning of the Clean Air Act,
      as amended."

Because of this belief, the military has voluntarily adopted
aircraft engine emission design goals for new engines being
procured. These goals are essentially equivalent to existing
EPA standards for commercial aircraft engines.
     Because of the current suit, EPA does not want to give
an opinion on whether test cells are exempt from stationary
source emission regulations. Until the court decides, EPA
prefers "to acquiesce in DOD's treatment of test facilities
as non-regulated sources" and considers jet engine test cell
facilities operated by DOD "not deficient."
     It is currently disputed whether the Clean Air Act, as
amended, subjects jet engine test cells to stationary source
air pollution requirements. The suit brought by California
authorities seeks a court order to force the Navy to stop
violating air pollution laws and asks that $500 be paid to the
State for each day violations occur. According to DOD's liai-
son officer at EPA, the Army, Navy, and Air Force have 191 jet
engine test cells at installations located in 32 States. The
liaison officer estimated that it would cost $356 million for
these cells to meet stationary source emiscior. requirements.
     We recommend that the Congress amend the law to clarify
the issue.

                            CHAPTER 5

                         INTERNAL REVIEWS

     The Army Environmental Hygiene Agency and the Air Force
Environmental Health Laboratory make surveys at the request
of base commanders to help solve specific problems. They
have also made a limited number of comprehensive surveys of
all air pollution sources at some bases to determine if they
comply with applicable regulations. Although there is no
procedure to guarantee that bases carry out the survey team's
recommendations, Army and Air Force officials said that it is
to the bases' advantage to do so because the commanders asked
for their help.
     The Navy has recognized the need for scheduled environ-
mental surveys to monitor the compliance status of its instal-
lations and has initiated actions to make certain that recom-
mended corrective actions are taken. The Army and Air Force
have not established such a prepram.

     Regional environmental teams from the Navy's Engineering
Field Divisions regularly survey installations to identify
all pollution problems and recommend corrective action. To
assure that base commanders implement the survey recommenda-
tions, the Chief of Naval Operations requires all activities
to report to the major commands and to his of ice on actions
Survey results

     We selected and reviewed environmental surveys issued
in a 2-year period which ended July 1976 and summarized the
survey results in the following table.

                               Total    Army   Navy   Air Force
Surveys reviewed                79       32    35        12
Bases in compliance             26       10    14         2
Bases with minor sources
  out of compliance             26      10     14         2
Bases with major sources
  out of compliance             27      12       7        8
     This summary showing that over half of the surveyed bases
were out of compliance may not be considered representative
because all bases were not surveyed, and the Army and Air
Force bases were usually surveyed when the base commanders
suspected specific pollution problems.


     The Arm} %udit Agency reported in May 1973 that the
installations ad not identified all pollution sources in
reports to higi.  command levels and regulatory bodies. The
agency recommenc I that the major commands begin high prior-
ity programs to i 'ntify and solve all pollution problems
and report them to eadquarters. The Deputy Chief of Staff
for Logistics agree wsith the audit recommendations.

     In December 1975 the Air Force Audit Agency recommended
that Air Force headqua -ers formalize funding procedures to
guarantee prompt accomp '.shment of pollution projects requir-
ing operation and mainte ince funds. Air Force officials
agreed with the audit aget y's recommendations.
     On May 28, 1976, the oefense Audit Service issued a re-
port on the financial management of environmental projects.
The DOD auditors found that only 45 percent of the projects
would be completed on time and concluded that DOD could be
subject to lawsuits, unless exemptions arc obtained. They
recommended several actions to the Assistant Secretary of De-
fense for Installations and Logistics such as issuing specific
guidance on the Executive Order 11752 budgetary requirements.

     On June 3, 1977, the Defense Audit Service, with the
assistance of the military services' internal audit agencies,
issued a report assessing DOD's progress towards reducing air
and water pollution and actions taken by management on its
May 28, 1976, report. The report stated that the management
of DOD's pollution abatement program was generally effective.
It said that some problems noted in each military department's
identification, evaluation, and funding of pollution projects
should be corrected by implementing the services' audit agen-
cies recommendations.
     The auditors reported that about 52 percent of the pollu-
tion projects they reviewed were expected to be completed by
the required compliance dates, noting this as a slight im-
provement over she status shown in their May 1976 report.
They said that funding constraints and base restructuring
studies have delayed DOD from complying with environmental
laws. They said that the decision to reduce the fiscal year
1978 budget for pollution abatement (to about $30 million)
presents some risk-s to DOD since failure to comply with
requirements could result in lawsuits or curtailment of


     We proposed to the Secretary of Defense that the Army
and Air Force adopt the Navy's system of scheduled surveys
of bases by environmental teams together with procedures for
enforcing the team's recommendations to improve pollution
control management. DOD said (see app. I) that it cannot
fully concur with this proposal because it limits management
flexibility. DOD said that decentralization is the most prac-
tical, efficient, and economical means to manage the function
because of the different compliance strategies which are
tailored to specific problems in various parts of the country.
DOD said that the installation commander is responsible for
environmental monitoring and compliance, and has sufficient
resources for those purposes. DOD said, however, that in
some instances periodic inspections by independent teams are
warranted and inspections will be made in such cases.

     Although DOD said that inspections will be made when
warranted, it indicated that the purpose of such inspections
would be to assist installation commanders which is not very
different from what the Army and Air Force have been doing in
the past. Further, DOD did not comment on the need for proce-
dures to see that the bases carry out Army and Air Force en-
vironmental teams' recommendations.

     Accordingly, we recommend that the Secretary of Defense
require the Army and the Air Force to adopt a system of sched-
uled environmental surveys or inspections designed to monitor
installations' compliance with pollution abatement require-
ments and to establish procedures for monitoring installa-
tions' actions on survey team recommendations.

                         CHAPTER 6
                      SCOPE O uREVIEW

    We reviewed the Department of Defense's implementation
of the 1970 Clean Air Amendments and the progress and prob-
lems selected industrial-type installations have encountered
in meeting standards for stationary air pollution sources.
     The review was made at the Office of the Secretary of
Defense; the Departments of the Army, Navy, and Air Force;
various district and field offices of the Army Corps of En-
gineers and Naval Facilities Engineering Command; and eight
industrial-type installations identified in chapter 3. We
visited EPA headquarters, Washington, D.C.; its 10 regional
offices; its Health Effects Research Laboratory, Research
Triangle Park, North Carolina; and its Office of Air Quality
Planning and Standards, Durham, North Carolina. We also
visited air pollution control agencies in California, Penn-
sylvania, South Carolina, Tennessee, and Virginia, and con-
tacted air pollution officials in 34 other States.
     We reviewed reports and records and interviewed various
officials concerning the status and problems of DOD installa-
tions in meeting applicable air pollution standards.

APPENDIX I                                                                    APPENDIX I

                               ASIIYAITAT S            OF DUW
                                      WAUINSYO,   B.     lSI

                                                                    I a /A W'
*WmlAlWNW    ANM

            Mr. Fred J. Shafer
            Director, Logistics .nd
            Communications Division
            U. S. General Accounting Office
            Washington, D.C. 20548

            Dear Mr. Shafer:
                                                                       the Secre-
            This is in reply to your letter dated January 10, 1977, to
                                                                        and Delays
            tary of Defense regarding your draft report on "Progress
                                                                    "  OSD
            in Air Pollution Control by the Department of Defense,
            Case #4155-B, GAO code number 945262.
                                                                           air pol-
            The report recommends steps to avoid delays in correcting
                                                             status of jet engine
            lution violations and discloses the questionable
            test cells pursuant to regulations under  the Clean Air Act.

                                                                        the Clean
            The Department of Defense has done much to comply with
                                          implemented   a continuing,  vigorous
            Air Act requirements and has
            compliance program. Generally, your recommendations
                            already have on-going.  As  such,  they will serve to
            actions that we
            support and supplement our efforts to attain full compliance.
                                                                          namely, (1)
            We fully concu. with three of the five recommendations:
                                                                         in a timely
            to seek full compliance, (2) to implement new standards
                                                                        Since   your
            manner, and (3) to improve our monitoring programs.
                                                                     been done   to imple-
            survey began over two years ago, much has already
                                                               are  closely  monitoring
            ment those recommendations. To this end, we
            the issuance of new and revised standards to effect timely
                                                            and have   corrected   many
            We have completed the compliance inventory
                                                        early correction.     In addi-
            deficiencies or have programed for their
            tion, we have taken steps to reduce the lead time to effect
                                                  are  beginning  to  mature   based on
             The fruits from this on-going effort
             a review of our current compliance   data.

APPENDIX I                                                                    APPENDIX I


   Concerning your recommendation to comply with health-related
   standards, we/believe that it would be more accurate to state that
   compliance is to be effected with air emission limitations since they
   are the standards which appl, to all sources, civilian and military.

   We cannot fully concur in your recommendation to require periodic
   inspections by independent teams. Currently, the installation com-
   mander is held responsible for environmental monitoring and com-
   pliance. He is provided sufficient full-time and part-time resources
   to accomplish this task. We do believehowever, that there are
   instances where the recommended inspections are warranted, and we
   will use them in such cases. The recommendation as written limits
   our management flexibility, and we have suggested a revision in the

   Our specific comments are contained in the enclosure. In addition,
   we have provided a completely rewritten Chapter 4 which pertains to
   the jet engine test cell issue. TLis issue is under litigation, and we
   wish to insure that your report is accurate so as to not prejudice the

   We appreciate the opportunity to comment, on this draft report and
   trust that our comments will be helpful to you. Should you have ques-
   tions on our comments, please call Mr. George Marienthal or
   Cdr. Tom Thoureen on 695-0222.

                                              Since rely,

                                 Actin    Act:.        .    .:;   o nDefens

  QAO note:   We have omitted the *nclosure because we inocr-
              porated the specific co    nts and conformed the
              cbhapter on jet engine test cells with 000'
              proposed modtfications to the extent we deemed

APPENDIX II                                                             APPENDIX II

 N4k~G                     WASHINGTON. D.C.   20460

                                                       17 Mar 1977
                                                                        OFFICE OF THE

Mr. Henry Eschwege
Community and Economic Development Division
United States General Accounting Office
Washington, D.C.   20548
Dear Mr. Eschwege:

As requested in your transmittal letter of January 15, 1977,
we have reviewed the draft report to the Congress entitled,
"Progress and Delays in Air Pollution Control by the Department
of Defense," and offer -he following comments. In summary,
our comments cast a mo' · favorable light on the status of
compliance at Defense installations.

         ° The main weakness of the report in our view is its
           reliance on 1975 estimates of compliance provided
           by our regional offices as the basis for the
           conclusions and recommendations. The accuracy of
           those statistics is highly questionable as noted
           on pages 4 and 5. More recent and reliable data
           are available now, and we suggest that in fairness
           they be substituted in the report for the earlier
           estimates, because they indicate that more Defense
           installations are in compliance than we had originally

          Accordingly, we suggest that the table on page 6
          be revised to show the following January 1977
          Department of Defense figures:

                                                Compliance Status
     Military Service     No. of Major Emitters In   %   Out   %
     Army                          120                 79   (66)   41     (34)
     Navy                           65                 51   (78)   14     (22)
     Air Force                      43                 33   (77)   10     (23)
     Defense Logistics              12                  9   (75)    3     (25)
     Totals                        240                172   (72)   68     (28)

APPENDIX II                                                APPENDIX II


         This table contains data reported by DOD. EPA's
         compliance data differ slightly but agree substantially.
         EPA has classified 263 Defense installations as major
         emitters,* and EPA has identified 21 additional
         Defense install'tiors which might be major emitters.
         The difference li. che number of major emitters listed
         by the two ac -ci,*   ie due to differing classifications
         of certain inL     .ations which are on the borderline
         between major or minor emitters (100 tons per year).

     o   As now written, the report is somewhat misleading as
         to the relative impact of Defense installations
         on the attainment of cleaner air and the Defense
         Department's overall compliance with the Clean Air
         Act. The opening paragraph of Chapter 2 cites this
         Agency's definition of major emitters as being those
         installati.ons capable of emitting 100 tons a year of
         a single air pollutant and states that major emitters
         account fox 85 percent of all stationary source air
         pollutants in the United States. Within that context,
         it should be noted that as of January 1, 1977, the
         Environmental Protection Agency has identified 22,140
         major emitters of which 284 or 1.3% are Defense installa-

         An installation is classified as a major or minor
         emitter on the basis of the total emissions from all
         sources of air pollutants 'ozated within that installa-
         tion. A significant number of the 284 Defense
         installations reported by this Agency are classified
         as major emitters because they consist of several
         minor sources of air pollutants which, in aggregate,
         emit more than 100 tons of the pollutant per year.
         Those installations are similar to small communities,
         but equivalent private communities are not classified
         as major emitters on the same basis.

         The Department of Defense reports that at the 240
         Defense installations which they have designated as
         major emitters there are 1,243 major sources of air
         pollutants and 229 or 18% of those individual sources
         are out of compliance.  This indicates a higher level of
         compliance than the data in the table discussed earlier.
         Of the 127,877 total individual sources (major and
         minor) at Defense installations, only 354 or 0.3%
         have been identified by the Department of Defense as
         not in compliance. We can verify the status of the
         major sources but not the minor sources at this time.

* 186 (71%) are in compliance and 77 (29%) are out of compliance.

APPENDIX II                                                    APPENDIX II


     ° Chapter 3 deals with the significant problems of
       eight selected major emitters which are out of
       compliance and gives the impression that those
       problems are indicative of the causes of non-compliance
       and of the delays in attaining compliance at the
       other Defense installations. The records of the
       Defense Department as well as those of our regional
       offices reveal that overall, the Defense installations
       are making better progress in correcting air
       pollution problems than the report indicates.
       Currently, the Defense Department is reporting 68
        (28%) of i.ts major emitters out of compliance of which
       22 (9%) are out because of non-complying minor sources
       of air pollutants which are now being corrected.
       1,e remaining 46 (19%) involve non-complying major
       sources 'Jf air pollutants (including several unique
       problems such as open burning of munitions) which
       the Defense Department is attempting to correct.

      We are also pleased to inform you that of the sixty-
      eight major Defense installations still out of compliance:

      - Twen,:y-four are on compliance 3chedules set forth
        in Consent Agreements between EPA and the installations;

      - Twenty-two are the subject of carrent negotiations
        which should soon produce Consent Agreements; and

      - Twenty-two are so close to compliance or making
        such satisfactory progress toward comp'iance that
        w? do not believe that Consent Agreemei.ts are needed.

Thank you for giving us this opportunity to review the drafc
report and we hope that our comments will be useful.
                                     Sincerely yours,

                                   Richard Red niu
                           Acting Assistant Administrator
                             for Planning and Management

  GAO note:   Page references in the af.endix may not correspond
              to page numbers in the final report.

APPENDIX III                                       APPENDIX III



                   DISCUSSED IN THIS REPORT

                                        Tenure of office
                                        From          To
    Harold Brown                     Jan.   1977    Present
    Donald H. RumBfeld               Nov.   1975    Jan. 1977
    James R. Schlesinger             July   1973    Nov. 1975
    Clifford L. Alexander           Feb.    1977    Present
    Martin R. Hoffmann              Aug.    1975    Feb. 1977
    Norman R. Augustine (acting)    July    1975    Aug. 1975
    Howard H. Callaway              May     1973    July 1975
    W. Graham Claytor, Jr.          Jan.    1977    Present
    J. William Middendorf 11        Apr.    1974    Jan. 1977
    John W. Warner                  May     1972    Apr. 1974
    John C. Stetson                 Mar.    1977    Present
    Thomas C. Reed                  Dec.    1975    Mar. 1977
    John L. McLucas                 May     1973    Dec. 1975