oversight

Environmental Protection: Information Used for Defense Environmental Management

Published by the Government Accountability Office on 1997-06-11.

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

                   United States General Accounting Office

GAO                Report to the Chairman, Committee on
                   National Security, House of
                   Representatives


June 1997
                   ENVIRONMENTAL
                   PROTECTION
                   Information Used for
                   Defense
                   Environmental
                   Management




GAO/NSIAD-97-135
             United States
GAO          General Accounting Office
             Washington, D.C. 20548

             National Security and
             International Affairs Division

             B-276616

             June 11, 1997

             The Honorable Floyd Spence
             Chairman, Committee on National Security
             House of Representatives

             Dear Mr. Chairman:

             As you requested, we are providing information on certain aspects of the
             Department of Defense’s (DOD) environmental compliance and cleanup
             activities. This report discusses (1) the extent to which DOD components
             are meeting requirements to provide data on the cost and status of
             compliance projects and (2) the relative risk characteristics DOD uses to
             determine priorities for site cleanup.


             Like private industry, DOD is subject to environmental, safety, and health
Background   laws and regulations. To meet the requirements of these laws and
             regulations at its installations, DOD has organized its environmental
             program into five areas: compliance, cleanup, conservation, pollution
             prevention, and technology. This report covers the two largest of these
             areas—compliance and cleanup,1 which at $2 billion each, account for
             more than 88 percent of DOD’s fiscal year 1997 environmental budget of
             $4.6 billion. (See a list of GAO related products at the end of the report.)

             Compliance focuses on operating and maintaining military installations in
             accordance with environmental laws and regulations of federal, state, and
             local jurisdictions. A number of federal laws protect the environment.
             According to DOD, those laws that most affect DOD’s funding for
             compliance are (1) the Clean Air Act; (2) the Federal Water Pollution
             Control Act (Clean Water Act); and (3) the Solid Waste Disposal Act, as
             amended by the Resource Conservation and Recovery Act (RCRA) of 1976.
             The Environmental Protection Agency (EPA) is the primary agency
             responsible for implementing environmental laws, but it may authorize
             states to administer some programs, including RCRA.

             Cleanup includes identification, investigation, and actual cleanup of
             existing contamination from hazardous substances and waste on active
             and closing installations and formerly used defense sites. According to
             DOD’s fiscal year 1996 annual report to Congress, DOD plans to spend about


             1
              Funding for cleanup includes $724 million appropriated in the Base Realignment and Closure account,
             as discussed in Military Bases: Potential Reductions to the Fiscal Year 1997 Base Closure Budget
             (GAO/NSIAD-96-158, July 7, 1996).



             Page 1                                            GAO/NSIAD-97-135 Environmental Protection
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                   $27 billion for site cleanup at DOD installations beginning in fiscal
                   year 1997, through the time period represented in the Future Years
                   Defense Plan, and well into the next century. In restoring contaminated
                   sites, DOD must comply with two major federal environmental laws—RCRA
                   and the Comprehensive Environmental Response, Compensation, and
                   Liability Act of 1980 (CERCLA), as amended—as well as applicable state
                   laws and regulations.

                   In this report, we use the term “standard” to define levels of contamination
                   and the term “element” to refer to the three factors used by DOD and EPA to
                   determine risk levels. Risk considers the following elements: (1) site
                   contamination—the pollutants that are present and their concentrations;
                   (2) an identified receptor—the people or ecosystems that could be
                   harmed; and (3) an evident pathway—the medium through which the
                   contaminant could reach the receptor. We use the term “characteristics” to
                   describe the various combinations of risk elements and levels of
                   contamination that we analyzed.2


                   Not all the information that DOD, EPA, and Congress have identified as
Results in Brief   required for compliance oversight is being provided. DOD components do
                   not provide detailed expenditure data on compliance activities. DOD’s
                   reports to EPA do not provide such information as whether compliance
                   projects address existing or expected noncompliance. In addition, some
                   data in DOD’s latest report to Congress were not complete or correct.

                   DOD  used a relative risk site evaluation methodology in designating 4,472 of
                   8,534 sites as high risk.3 Our analysis of reported data on 407 high-cost
                   sites—including 266 considered high risk—indicates that DOD includes a
                   range of site characteristics within its high-risk category. At 54 percent of
                   the sites that were designated as high risk, all three elements used by DOD
                   to make priority determinations were reported present. At the remaining
                   46 percent of the sites one or two of the elements, but not all three, were
                   reported present. In addition, the reported levels of contamination at 58 of



                   2
                    DOD describes the elements of the relative risk site evaluation as follows: “(1)contamination hazard
                   factor (CHF)—contaminant concentrations compared to comparison values (comparison values differ
                   from cleanup standards and are typically two orders of magnitude higher than cleanup standards);
                   (2) migration pathway factor (MPF)—is contamination moving or likely to move; and (3) receptor
                   factor—are humans or sensitive environments currently or likely to be affected.” Additional
                   information on how DOD applies its relative risk methodology is included in appendix IV.
                   3
                    Based on data as of September 30, 1995. DOD summary data as of September 30, 1996, designates
                   4,100 of 8,084 sites as high risk, but did not yet have supporting detail available for our analysis.



                   Page 2                                               GAO/NSIAD-97-135 Environmental Protection
                     B-276616




                     the 407 sites we analyzed were less than the standard DOD used to
                     determine whether a site is contaminated.


                     DOD, EPA,  and Congress have established requirements for the defense
Required Data for    components to provide certain environmental data. The Office of the
Compliance           Secretary of Defense (OSD) has developed information requirements that
Management Are Not   are designed to help DOD manage its wide-ranging environmental
                     compliance activities and cost. DOD must provide its environmental
Always Available     program plans to EPA, and certain data on its environmental compliance
                     activities to Congress. However, not all of the required data are being
                     provided. In addition, our May 1997 report addresses, among other related
                     issues, DOD’s need for and efforts toward uniform tracking and
                     management for programs involving DOD’s compliance with laws and
                     regulations.4


DOD Reporting        We and OSD have noted that DOD’s budget execution and financial reporting
                     do not provide DOD or Congress with the information needed to provide for
                     oversight of compliance. In 1995, the Deputy Under Secretary of Defense
                     for Environmental Security began an environmental quality data initiative
                     to promote consistency in compliance definitions, categories, and
                     requirements. Under the initiative, DOD made changes to the classes it uses
                     to prioritize nonrecurring (one time) compliance projects and added a new
                     class “0” for recurring costs not related to one-time projects. DOD’s changes
                     also permitted recurring and nonrecurring costs for compliance,
                     conservation, and pollution prevention to be reported separately. After
                     these changes, funds used for activities such as personnel, training,
                     permits, fees, and hazardous waste disposal were to be reported as
                     recurring costs, and funds used for activities such as underground storage
                     tank replacement and stormwater system upgrades were to be reported as
                     nonrecurring costs.


EPA Reporting        EPA has developed guidance for environmental data reporting under a
                     system now called FEDPLAN, which replaced the reporting that had
                     previously been required under the Office of Management and Budget




                     4
                      Environmental Protection: Status of Defense Initiatives for Cleanup, Technology, and Compliance
                     (GAO/NSIAD-97-126, May 29, 1997).



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                              Circular A-106.5 According to EPA headquarters officials, DOD stopped
                              reporting A-106 information to EPA in 1994. OSD officials told us they had
                              recommended canceling the circular’s reporting requirements because EPA
                              was not using submissions and reporting did not help improve DOD’s
                              environmental compliance program. According to EPA officials, DOD’s
                              environmental data are important. In September 1996, DOD began
                              submitting data files used to produce its annual environmental quality
                              report to Congress. DOD officials told us they believe that the data files are
                              more informative than previous data because they are linked to current
                              budgets.

                              For FEDPLAN system reporting, EPA requests that agencies, including DOD,
                              provide information on 47 data elements related to environmental
                              compliance activities. EPA ranks the importance of all required data
                              elements on a three-point scale. Of the 47 data elements, EPA officials
                              determined that 21 elements are critical to making the FEDPLAN system
                              function effectively because a project cannot be entered into the system
                              without them. EPA’s critical elements include federal facilities
                              identification numbers, compliance status, compliance codes, and
                              statutory authority. (Some elements, such as cleanup site data, may not
                              apply to compliance activities.)


Congressional Reporting       Congress requires DOD to provide data on its environmental compliance
                              activities. The Office of the Deputy Under Secretary of Defense for
                              Environmental Security provides the data to Congress each year in a
                              report entitled Defense Environmental Quality Annual Report to Congress.
                              For the upcoming fiscal year 1996 report, OSD asked the defense
                              components to provide data on planned recurring spending for fiscal
                              years 1998 through 2002. Required report information was requested for
                              the following categories:

                          •   appropriation,
                          •   major command,
                          •   installation,
                          •   federal facilities identification number,
                          •   state,
                          •   country, and
                          •   budget year.

                              5
                               The Office of Management and Budget Circular A-106 was issued in December 1974 and rescinded in
                              April 1996. Executive Order 12088 (42 U.S.C. 4321 note), promulgated in 1978, requires federal
                              agencies to provide a pollution control plan. According to EPA officials, FEDPLAN fulfills that
                              requirement.



                              Page 4                                           GAO/NSIAD-97-135 Environmental Protection
                             B-276616




                             For fiscal year 1998 only, OSD also asked the defense components to
                             provide information on nonrecurring projects costing over $300,000. In
                             addition to the previous categories, DOD asked for the following
                             information:

                         •   project description,
                         •   legal requirement, and
                         •   compliance class.

                             Appendix I contains a more complete list and explanation of the reporting
                             requirements.



Extent to Which Data         Most of DOD’s data involving future-year budget estimates for compliance
Requirements Are Being       activities are reported by the components, but details on actual
Met                          expenditures are not. Also, the project data in DOD’s most recent report to
                             Congress were not complete or accurate. Subsequent to our draft report,
                             DOD provided additional fiscal year 1998 budget data to Congress.6


                             DOD also did not provide complete data to EPA in its submission of fiscal
                             year 1997 data for environmental quality projects. The defense
                             components’ submissions accounted for $422 million (18 percent) of DOD’s
                             reported $2.33 billion total. The Army reported 36 percent of its total
                             environmental quality budget, the Air Force reported 27 percent, and the
                             Navy reported 6 percent. Marine Corps officials stated that, although they
                             submitted data through the Navy to OSD for incorporation into DOD’s
                             environmental quality report, for unknown reasons the same data did not
                             reach EPA. That data showed projects estimated to cost $300,000 or more
                             were valued at $39.5 million (25 percent) of the Marines Corps’ total fiscal
                             year 1997 environmental quality budget of $157.6 million.

                             Also, for those activities that DOD components reported to EPA, not all the
                             details requested by EPA were provided. Some, but not all, DOD components
                             provided information on 15 of 47 data elements. For the 21 elements
                             identified by EPA as critical, the components provided at least partial data
                             on 12. An EPA official stated and EPA guidance indicated that, without those
                             data elements, EPA could not assess DOD’s overall compliance status or

                             6
                              The additional data provided by DOD in its budget submission contain information on the obligation
                             of prior-year funds by component, appropriation, pillar (compliance, pollution prevention, and
                             conservation), and functional area (e.g., permits and fees, waste disposal, Clean Air Act, and Clean
                             Water Act). DOD officials stated that there is currently no requirement that DOD’s annual quality
                             report to Congress contain project-level obligation data.



                             Page 5                                             GAO/NSIAD-97-135 Environmental Protection
                          B-276616




                          address the relative importance of the projects DOD is undertaking. In
                          addition to DOD not providing data adequate for EPA’s analysis, an EPA
                          official told us that it was received too late in the budget cycle for EPA to
                          request additional data from DOD. (See app. II for a detailed breakdown of
                          the data EPA requires and the information DOD provided.)

                          DOD officials stated that they do not believe EPA has provided useful
                          feedback on the environmental compliance data DOD has provided. Also,
                          DOD officials stated that they are required to report only those projects
                          estimated to cost $300,000 or more and that this requirement partially
                          accounts for the difference between DOD’s total compliance budget and the
                          amounts reported to EPA.

                          In its fiscal year 1995 report, provided to Congress in December 1996, DOD
                          accounted for only $2.33 billion of the $2.58 billion fiscal year 1997
                          environmental quality program reported in the President’s budget for 1998.7
                           Also, the report’s breakout of projects costing $300,000 or more omitted
                          some projects. DOD officials told us they were aware of the difference
                          between the report and the budget and would correct this amount in
                          future reports.


                          To direct resources to cleanup sites that pose the greatest risk to human
Relative Risk             health and the environment, DOD has developed a methodology for
Characteristics at        evaluating the relative risk at its sites. DOD stated that the methodology
DOD’s Cleanup Sites       provides a quantifiable basis for justifying requirements and allocating
                          funds. On the basis of the degree of contamination and the potential
                          exposure, DOD assigns each site a relative risk rating of high, medium, or
                          low. According to DOD criteria, a site can be characterized as high if it has
                          significant contamination or if it has lesser contamination that could
                          potentially affect human health or the environment.

                          DOD’sfiscal year 1995 report showed that relative risk assessments had
                          been completed for 8,534 of 15,240 sites. Of the completed assessments,

                      •   4,472 (52.4 percent) were reported as high,
                      •   1,913 (22.4 percent) as medium, and
                      •   2,149 (25.2 percent) as low.



                          7
                           DOD officials stated that the environmental quality program is divided into six major functions:
                          planning, compliance, pollution prevention, conservation, education and training, and environmental
                          technology.



                          Page 6                                             GAO/NSIAD-97-135 Environmental Protection
B-276616




We analyzed data on 91 installations that had a total of 407 sites that met
our criteria for being a high-cost site.8 DOD components reported that these
sites had estimated combined cleanup costs of $5.1 billion for fiscal year
1996 to completion. We identified those sites having similar
characteristics. For example, we grouped the high-risk sites by the degree
of identified contamination: significant, moderate, or minimal.9 We also
grouped those sites having an identified means of contact between
contaminants and people, animals, or plants and an evident pathway
through which the contaminants could travel.

Our review of DOD’s risk data worksheets for the 266 high-risk sites of the
407 total sites indicated that 20 percent reported significant contamination
with a confirmed pathway and identified receptors. In addition, 54 percent
reported all three elements of risk: contamination above standard, an
identified receptor, and an evident pathway.10 (We did not visit the sites or
determine the basis for cleanup in any of these cases.) Figure 1 shows the
results of our analysis. The estimated cost to complete cleanup of the 266
high-risk sites is $4.3 billion.




8
 The site data were requested from installations for which DOD’s annual report showed more than
$20 million in planned funding during fiscal years 1996-98 or more than $100 million in projected costs
from fiscal year 1996 to completion.
9
 With a contaminant ratio (called a “comparison value”) of 1 signifying the standard, DOD designated
sites whose contaminant ratios totaled over 100 as having significant contamination. DOD designated
sites whose contaminant ratios totaled from 2 to 100 as having moderate contamination. DOD
designated sites whose contaminant ratios totaled less than 2 as having minimal contamination.
10
  DOD uses the same basic elements of risk as EPA but applies these elements in a simplified manner.
For example, rather than a quantified score for the degree to which a pathway may exist for
contaminants to reach receptors, such as people, DOD categorizes the pathway by whether it is
“evident,” “potential,” or “confined.”



Page 7                                              GAO/NSIAD-97-135 Environmental Protection
                                                        B-276616




Figure 1: Our Analysis of DOD Sites With High Relative Risk


                 71 high-risk sites with moderate
                 contamination, a confirmed pathway,
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                 and an identified receptor
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                                                                         AAAAAAAA AAAA AAAA AAAA AAAA 52 high-risk sites with significant contamination, a
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                                                               46%




                                                                                                 123 high-risk sites with one or more
                                                                                                 DOD elements of risk unconfirmed




                                                        In our sample of 407 sites, we also identified those sites in all three relative
                                                        risk categories (high, medium, and low) that had contamination, as
                                                        reported by DOD, within the standards that DOD used. Of the 407 sites, 58
                                                        reported contamination levels that were less than the standard that DOD
                                                        used. These 58 sites have estimated cleanup costs of about $443 million.
                                                        (See app. III.)

                                                        In discussing relative risk data, DOD and service officials stated that the
                                                        ranking system is an initial screening method and only one of the factors
                                                        considered by decisionmakers in determining whether to fund cleanup at
                                                        specific sites. The officials stated that the final decisions are supported by
                                                        detailed site assessments made in accordance with regulations.11 Also,


                                                        11
                                                          According to DOD, reuse is a major factor in prioritizing and funding decisions for sites at BRAC
                                                        [Base Realignment and Closure] installations. For example, DOD stated that ANAD-48, an Army site on
                                                        the first line of the appendix III table, is only in the fiscal year 1998 budget for $1,107,000, compared to
                                                        the $118,457,000 cost to complete estimate shown in the table.



                                                        Page 8                                                   GAO/NSIAD-97-135 Environmental Protection
                  B-276616




                  they noted that the existence of an estimated cost of completion does not
                  mean that a site has in fact been funded for fiscal year 1998.


                  DOD  had no comments on the overall report message but they did suggest
Agency Comments   some technical and editorial changes. We made those suggested changes
                  where we felt it was appropriate. We reprinted DOD’s comments in their
                  entirety in appendix IV, as well as our comments on specific points.


                  To address compliance data needs, we interviewed and reviewed data
Scope and         from officials at EPA headquarters; DOD’s Office of the Deputy Under
Methodology       Secretary of Defense for Environmental Security; and Army, Navy, Air
                  Force, and Marine Corps headquarters. To address the risk-related
                  characteristics of cleanup sites funded by DOD, we requested and analyzed
                  407 relative risk worksheets for selected high-cost sites at 91 high-cost
                  installations identified from DOD’s 1995 annual report to Congress.12 The
                  site data were requested from installations for which DOD’s annual report
                  showed more than $20 million of planned funding during fiscal
                  years 1996-98 or more than $100 million of projected costs from 1996 to
                  completion. From each installation, we requested relative risk data
                  worksheets for up to five sites: the three highest cost high-risk sites and
                  the highest cost medium-risk and low-risk sites. We did not visit these
                  sites, assess the relative risk standards DOD used, or determine the basis
                  for cleanup in these cases.

                  We conducted our review from November 1996 to March 1997 in
                  accordance with generally accepted government auditing standards.


                  Unless you publicly announce its contents earlier, we plan no further
                  distribution of this report until 30 days from its issue date. At that time, we
                  will send copies to other appropriate congressional committees; the
                  Secretaries of Defense, the Army, the Navy, and the Air Force; the
                  Commandant, Marine Corps; and the Directors, Office of Management and
                  Budget and Defense Logistics Agency. We will also make copies available
                  to others on request.




                  12
                    Defense Environmental Restoration Program Annual Report to Congress for Fiscal Year 1995.



                  Page 9                                            GAO/NSIAD-97-135 Environmental Protection
B-276616




If you or your staff have any questions concerning the report, please
contact me on (202) 512-8412. Major contributors to this report are listed
in appendix V.

Sincerely yours,




David R. Warren, Director
Defense Management Issues




Page 10                               GAO/NSIAD-97-135 Environmental Protection
Page 11   GAO/NSIAD-97-135 Environmental Protection
Contents



Letter                                                                  1


Appendix I                                                             14

Compliance Data
Requirements for the
Department of
Defense 1996 Annual
Environmental
Quality Report to
Congress
Appendix II                                                            15

EPA FEDPLAN Data
Requirements and
DOD Service
Submissions
Appendix III                                                           17

High-Cost Sites With
Reported
Contamination Levels
That Do Not Exceed
Standard
Appendix IV                                                            19

Comments From the
Department of
Defense




                       Page 12   GAO/NSIAD-97-135 Environmental Protection
                        Contents




Appendix V                                                                                         26

Major Contributors to
This Report
Related GAO Products                                                                               27


Table                   Table III.1: Sites Reported                                                17


Figure                  Figure 1: Our Analysis of DOD Sites with High Relative Risk                 8




                        Abbreviations

                        CERCLA     Comprehensive Environmental Response, Compensation,
                                        and Liability Act
                        DOD        Department of Defense
                        EPA        Environmental Protection Agency
                        OSD        Office of the Secretary of Defense
                        RCRA       Resource Conservation and Recovery Act


                        Page 13                              GAO/NSIAD-97-135 Environmental Protection
Appendix I

Compliance Data Requirements for the
Department of Defense 1996 Annual
Environmental Quality Report to Congress

              Requirement                                          Description
              Recurring cost data category
              Appropriation                                        Operation and maintenance; military
                                                                   construction; procurement; the Department
                                                                   of Defense (DOD) working capital fund; or
                                                                   research, development, test, and
                                                                   evaluation.
              Major command                                        “Self-explanatory.”
              Installation                                         “Self-explanatory.”
              Federal facilities identification number             Unique number used to identify the
                                                                   installation.
              State                                                “Self-explanatory.”
              Country                                              “Self-explanatory.”
              Budget years 1997 through 2001                       Dollar value, in thousands, of each of the
                                                                   5 budget years for an installation.
              Nonrecurring cost data category a
              Project name                                         Descriptive name of the unique project
              Legal requirement                                    A five-digit code corresponding to the
                                                                   appropriate statutory requirement. For
                                                                   example, the Clean Air Act (CAA) would
                                                                   be represented by CAA, and the Resource
                                                                   Conservation and Recovery Act (RCRA)
                                                                   (subtitle C) would be represented by
                                                                   RCRAC.
              Compliance class                                     The priority code associated with the
                                                                   project.
              Project budget                                       FY97 projected dollar value of the project,
                                                                   in thousands.
              a
                This category includes appropriation, major command, installation, and federal facilities
              identification number.




              Page 14                                             GAO/NSIAD-97-135 Environmental Protection
Appendix II

EPA FEDPLAN Data Requirements and
DOD Service Submissions


                                                     Element              Service submission
              Data element description            importance     Army        Navy          Air Force
              Federal facilities identification           1      YES                       YES
              number
              Department/agency name                      1      YES         YES           YES
              Bureau/major command name                   1      YES         YES           YES
              Name of facility                            1      YES         YES           YES
              Street mailing address                      1
              City name                                   1
              Country                                     1                  YES
              EPA region                                  1
              Agency project number                       1                  YES
              Project name                                1      YES         YES           YES
              Project city name                           1
              Multiple installations                      1
              Progress code                               1
              Total cost estimate                         1      YES         YES           YES
              Federal agency funding                      1      YES         YES           YES
              account code
              Estimated project cost                      1      YES         YES           YES
                                                                                 a
              Statutory authority                         1      YES         YES           YES
              (law/regulation)
              Environmental category code                 1
              Compliance status                           1
              Compliance class                            1      YES         YES           YES
              Priority score                              1
              Zip code (facility location)                2
              National Priority List site                 2
              Ownership type                              2
              Project name contact                        2
              Project contact telephone                   2
              number
              Project street address                      2
              Zip code (project location)                 2
              Year funding required                       2                  YES
              Funded/unfunded                             2                  YESa
              Major program area                          2      YES         YESa
              Pollution prevention                        2
              Description                                 2
                                                                                             (continued)




              Page 15                                          GAO/NSIAD-97-135 Environmental Protection
Appendix II
EPA FEDPLAN Data Requirements and
DOD Service Submissions




                                        Element                  Service submission
Data element description             importance        Army         Navy             Air Force
Operable unit/activity data                   2,3
sheet
Installation latitude/longitude                  3
Building number                                  3
Room number                                      3
Project site latitude/longitude                  3
Project milestones                               3
Reasons for discontinuance                       3
Federal agency program                           3
element code
Office of Management and                         3
Budget appropriation
account identification code
Type of cost                                     3
Local priority                                   3
Bureau/major command                             3
priority
Geographic initiative                            3
Reason for initiation                            3

Legend for EPA element importance category

1 = Project cannot be entered into the system without this data. Input must be completed or
corrected immediately.
2 = Project will be entered into the system. However, missing or inaccurate data should be
completed or corrected within 45 days.
3 = Project will be entered into the system. Missing or inaccurate data should be corrected during
the next update.

Note: EPA—Environmental Protection Agency.
a
    Data provided were incomplete.

Source: Federal Agency Environmental Management Program Planning Guidance, EPA,
October 1994, and DOD and service submissions to EPA.




Page 16                                              GAO/NSIAD-97-135 Environmental Protection
Appendix III

High-Cost Sites With Reported
Contamination Levels That Do Not Exceed
Standard
                              From DOD’s fiscal year 1995 cleanup report to Congress, we identified
                              installations that reported more than $20 million in planned total spending
                              during fiscal years 1996 through 1998, or more than $100 million in
                              estimated cost from fiscal year 1996 to completion. We requested data for
                              each installation’s three highest cost sites with a high-relative risk ranking
                              and the highest cost sites with medium- and low-relative risk rankings. We
                              received data for 91 installations as of March 27, 1997. In table III.1, “risk
                              rating” is the overall relative risk assigned on each site’s worksheet,
                              “contamination” is the DOD-prescribed contaminant hazard factor
                              calculated for the site, and “cleanup cost” is the estimated cost to
                              complete from fiscal year 1996 to completion.

Table III.1: Sites Reported
                              Dollars in thousands
                              Service                Risk rating           Contamination        Cleanup cost
                              Army                   High                            0.02            $118,457
                              Army                   High                            0.04                 639
                              Army                   High                            0.15              18,626
                              Army                   High                            0.24                 471
                              Navy                   High                            0.03              36,293
                              Air Force              High                            0.44              23,257
                              Air Force              High                            0.94               1,001
                              Army                   Medium                          0.09               3,362
                              Army                   Medium                          0.09               3,379
                              Army                   Medium                          0.13                 402
                              Army                   Medium                          0.23              55,948
                              Army                   Medium                          0.03              49,331
                              Navy                   Medium                             0                 643
                              Navy                   Medium                          0.28               2,300
                              Air Force              Medium                             0              14,434
                              Air Force              Medium                          0.29               2,518
                              Air Force              Medium                          0.32                 296
                              DLA                    Low                             0.02                  41
                              DLA                    Low                             0.47                 317
                              Army                   Low                                0               6,341
                              Army                   Low                                0               9,868
                              Army                   Low                                0                 430
                              Army                   Low                             0.07               1,321
                              Army                   Low                             0.19               4,179
                              Army                   Low                             0.32               4,847
                              Army                   Low                             0.34               2,254
                                                                                                   (continued)


                              Page 17                                GAO/NSIAD-97-135 Environmental Protection
Appendix III
High-Cost Sites With Reported
Contamination Levels That Do Not Exceed
Standard




Dollars in thousands
Service                 Risk rating            Contamination         Cleanup cost
Army                    Low                               0.79               1,409
Army                    Low                               0.83               1,930
Navy                    Low                                  0               4,546
Navy                    Low                                  0               8,341
Navy                    Low                               0.01                 557
Navy                    Low                               0.01                 632
Navy                    Low                               0.10                 573
Navy                    Low                               0.10               2,164
Navy                    Low                               0.10                 392
Navy                    Low                               0.11               2,734
Navy                    Low                               0.16                  80
Navy                    Low                               0.20               1,520
Navy                    Low                               0.29               2,431
Navy                    Low                               0.04                 920
Navy                    Low                               0.50                  57
Navy                    Low                               0.60               1,004
Navy                    Low                               0.17                 906
Air Force               Low                                  0               1,240
Air Force               Low                                  0                 572
Air Force               Low                                  0              14,129
Air Force               Low                                  0                 816
Air Force               Low                               0.02                 721
Air Force               Low                               0.04                 383
Air Force               Low                               0.11               4,155
Air Force               Low                               0.14               1,826
Air Force               Low                               0.33               1,390
Air Force               Low                               0.43                 510
Air Force               Low                               0.49              15,614
Air Force               Low                               0.53               3,707
Air Force               Low                               0.63               4,855
Air Force               Low                               0.63                 100
Air Force               Low                               0.78               1,601
Total                                                                     $442,770

Note: DLA—Defense Logistics Agency.




Page 18                                   GAO/NSIAD-97-135 Environmental Protection
Appendix IV

Comments From the Department of Defense


Note: GAO comments
supplementing those in the
report text appear at the
end of this appendix.




See comment 1.




See comment 2.




                             Page 19   GAO/NSIAD-97-135 Environmental Protection
                 Appendix IV
                 Comments From the Department of Defense




See comment 3.




See comment 4.




Now on p. 2.
See comment 4.




Now on p. 2.
See comment 3.




                 Page 20                                   GAO/NSIAD-97-135 Environmental Protection
                 Appendix IV
                 Comments From the Department of Defense




Now on p. 2.
See comment 5.




See comment 5.




Now on p. 3.
See comment 1.




Now on p. 5.
See comment 3.




Now on p. 5.
See comment 6.




Now on p. 6.
See comment 7.




                 Page 21                                   GAO/NSIAD-97-135 Environmental Protection
                  Appendix IV
                  Comments From the Department of Defense




Now on p. 6.
See comment 6.


Now on p. 7.
See comment 3.




Now on p. 7
See comment 3.



Now on p. 7.
See comment 3.



Now on p. 8.
See comment 8.




Now on p. 8.
See comment 9.




Now on p. 8.
See comment 10.




                  Page 22                                   GAO/NSIAD-97-135 Environmental Protection
                  Appendix IV
                  Comments From the Department of Defense




Now on p. 8.
See comment 10.




See comment 3.




                  Page 23                                   GAO/NSIAD-97-135 Environmental Protection
               Appendix IV
               Comments From the Department of Defense




               The following are GAO’s comments on the DOD’s letter dated May 16, 1997.


               1. Our draft report cited a 1994 working group that the Deputy Comptroller
GAO Comments   in the Office of the Secretary of Defense established to develop budgeting
               procedures for compliance activities. We deleted reference to that
               working group because DOD officials stated that they intended the
               authorization for an environmental security working group to be limited to
               cleanup activities.

               2. The results in brief and relative risk sections address the relative risk
               site characteristics that DOD reported in its fiscal year 1995 annual report
               to Congress. Our report recognizes in the section on relative risk
               characteristics that the ranking system is an initial screening method that
               is only one of the factors considered by decisionmakers in determining
               whether to fund cleanup at specific sites. Our report recognizes other
               factors and therefore does not imply that relative risk evaluation is a
               substitute for a risk assessment.

               3. We have modified our report in response to DOD’s comment.

               4. We included these additional DOD data and conclusions in a footnote on
               page 2.

               5. Our statement refers to distinctions such as the difference between
               “identified” receptors and “potential” or “limited” receptors.

               6. The cited paragraph is intended only to introduce the subject.

               7. DOD acknowledged that the total costs shown in its annual report,
               $2.33 billion, did not reflect all of the defense agencies’ projects. However,
               DOD indicated that it understated the figure by only $40 million, not the
               $250 million we reported. Even though DOD’s annual report lists technology
               as one of its six major environmental quality program functions, DOD
               officials told us they did not consider technology as part of the
               environmental quality program and thus excluded such amounts from
               reported totals. Our calculations, showing a difference of $250 million
               between the President’s budget and the annual report, included totals for
               the defense agencies and technology programs that DOD omitted. The 1998
               President’s budget for fiscal year 1997 totaled $2.58 billion, including
               technology. The $2.37 billion cited by DOD included defense agencies but
               excluded technology. Since the President’s budget included technology



               Page 24                                   GAO/NSIAD-97-135 Environmental Protection
Appendix IV
Comments From the Department of Defense




programs and the annual report did not indicate that technology programs
were being excluded from reported totals, we have not changed our
calculations.

8. We added the modifier “identified” to the first three notes. We did not
add “potential” to the note for the 46 percent segment because we noted
that other combinations, including confined pathways and limited
receptors, were present.

9. We did not delete the term “standard” because our draft specified the
term as defining levels of contamination and each of DOD’s relative risk
worksheets used the term “standard” in this context.

10. We did not replace “determining whether to fund” with “prioritizing”
but did add the additional information supplied by DOD.




Page 25                                   GAO/NSIAD-97-135 Environmental Protection
Appendix V

Major Contributors to This Report


                        Charles I. Patton, Jr.
National Security and   Uldis Adamsons
International Affairs   Richard Meeks
Division, Washington,   Joanne Jurmu

D.C.
                        Virgil Schroeder
Kansas City Field       Steve Pruitt
Office                  Ben Douglas


                        Lynn Gibson
Office of the General
Counsel




                        Page 26                  GAO/NSIAD-97-135 Environmental Protection
Related GAO Products


              Environmental Protection: Status of Defense Initiatives for Cleanup,
              Technology, and Compliance (GAO/NSIAD-97-126, May 29, 1997).

              Federal Facilities: EPA’s Penalties for Hazardous Waste Violations
              (GAO/RCED-97-42, Feb. 28, 1997).

              DOD   Problem Disbursements (GAO/AIMD-97-36R, Feb. 20, 1997).

              Environmental Cleanup: Inadequate Army Oversight of Rocky Mountain
              Arsenal Shared Costs (GAO/NSIAD/AIMD-97-33, Jan. 23, 1997).

              Military Base Closures: Reducing High Costs of Environmental Cleanup
              Requires Difficult Choices (GAO/NSIAD-96-172, Sept. 5, 1996).

              Environmental Protection: Status of Defense Initiatives for Cleanup,
              Compliance, and Technology (GAO/NSIAD-96-155, Aug. 2, 1996).

              Military Bases: Potential Reductions to the Fiscal Year 1997 Base Closure
              Budget (GAO/NSIAD-96-158, July 7, 1996).

              Environmental Compliance: Continued Need for Guidance in
              Programming Defense Construction Projects (GAO/NSIAD-96-134, June 21,
              1996).

              Federal Facilities: Consistent Relative Risk Evaluations Needed for
              Prioritizing Cleanups (GAO/RCED-96-150, June 7, 1996).

              Military Bases: Closure and Realignment Savings Are Significant, but Not
              Easily Quantified (GAO/NSIAD-96-67, Apr. 8, 1996).

              Environmental Protection: Issues Facing the Energy and Defense
              Environmental Management Programs (GAO/T-RCED/NSIAD-96-127, Mar. 21,
              1996).

              Environmental Protection: Challenges in Defense Environmental Program
              Management (GAO/T-NSIAD-95-121, Mar. 24, 1995).

              Military Bases: Environmental Impact at Closing Installations
              (GAO/NSIAD-95-70, Feb. 23, 1995).

              Environmental Cleanup: Case Studies of Six High Priority DOD Installations
              (GAO/NSIAD-95-8, Nov. 18, 1994).



              Page 27                                GAO/NSIAD-97-135 Environmental Protection
           Related GAO Products




           Pollution Prevention: Status of DOD’s Efforts (GAO/NSIAD-95-13, Nov. 9, 1994).

           Environment: DOD’s New Environmental Security Strategy Faces Barriers
           (GAO/NSIAD-94-142, Sept. 30, 1994).

           Environmental Compliance: DOD Needs to Better Identify and Monitor
           Equipment Containing Polychlorinated Biphenyls (GAO/NSIAD-94-243, Aug. 24,
           1994).

           Environmental Cleanup: Better Data Needed for Radioactively
           Contaminated Defense Sites (GAO/NSIAD-94-168, Aug. 24, 1994).

           Natural Resources: Defense and Interior Can Better Manage Land
           Withdrawn for Military Use (GAO/NSIAD-94-87, Apr. 26, 1994).

           Environmental Cleanup: Too Many High Priority Sites Impede DOD’s
           Program (GAO/NSIAD-94-133, Apr. 21, 1994).

           Environmental Compliance: Guidance Needed in Programming Defense
           Construction Projects (GAO/NSIAD-94-22, Nov. 26, 1993).




(709222)   Page 28                                 GAO/NSIAD-97-135 Environmental Protection
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