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 B-276616 $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). Page 3 GAO/NSIAD-97-135 Environmental Protection B-276616 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, AAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAA and an identified receptor AAAAAAAAAAAAAAAAAAAAAAAA AAAA AAAAAAAA AAAAAAAA AAAAAAAAAAAAAAAAAAAA AAAA AAAAAAAA AAAAAAAA AAAAAAAA AAAAAAAA AAAAAAAA AAAAAAAA AAAA AAAAAAAA AAAA AAAA AAAAAAAA AAAA AAAA AAAAAAAA AAAA AAAAAAAA AAAAAAAA AAAAAAAA AAAA AAAAAAAAAAAAAAAAAAAAAAAA AAAA AAAAAAAA AAAAAAAA AAAAAAAAAAAAAAAAAAAA AAAAAAAAAAAAAAAAAAAAAAAA AAAA AAAAAAAA AAAAAAAA AAAAAAAAAAAAAAAAAAAA AAAA AAAAAAAA AAAAAAAA 27% AAAA AAAAAAAAAAAAAAAAAAAAAAAA AAAA AAAA AAAA AAAA AAAA AAAAAAAA AAAA AAAA AAAAAAAAAAAAAAAAAAAA AAAAAAAA AAAA AAAA AAAA AAAA 52 high-risk sites with significant contamination, a AAAAAAAAAAAAAAAAAAAAAAAA AAAA AAAAAAAA AAAAAAAA AAAAAAAAAAAAAAAAAAAA AAAAAAAA AAAA AAAAAAAA AAAAAAAA AAAAAAAA AAAAAAAA AAAAAAAA AAAAAAAA AAAA AAAAAAAA AAAAAAAA AAAAAAAA AAAAAAAA AAAAAAAAAAAA AAAAAAAAAAAA AAAA confirmed pathway, and an identified receptor 20 high-risk sites with minimal AAAAAAAA AAAAAAAA AAAA AAAA AAAA AAAA AAAA AAAA AAAA AAAA AAAA AAAA AAAAAAAA AAAAAAAA 20%AAAAAAAA AAAAAAAA AAAAAAAA contamination, a confirmed AAAA AAAAAAAA AAAA AAAA AAAAAAAA AAAA AAAAAAAA AAAA AAAA AAAA AAAA AAAAAAAA AAAAAAAA AAAA AAAA AAAA AAAA AAAA AAAA AAAAAAAA AAAA AAAAAAAA AAAA AAAA AAAA AAAAAAAA AAAA AAAA AAAAAAAA AAAA AAAAAAAA AAAAAAAA AAAAAAAA AAAA AAAA AAAAAAAA AAAA AAAA AAAAAAAA AAAA AAAAAAAA AAAA AAAA AAAA AAAA AAAAAAAA AAAAAAAA AAAA AAAA AAAA AAAA AAAA AAAA AAAAAAAA AAAA AAAAAAAA AAAA AAAA AAAA AAAAAAAA AAAA AAAA AAAAAAAA AAAA AAAAAAAA AAAAAAAA AAAAAAAA AAAA pathway, and an identified AAAAAAAA AAAAAAAA AAAA AAAA AAAA AAAA AAAA AAAA AAAA AAAA AAAA AAAA AAAAAAAA AAAAAAAA AAAA receptor AAAA 7% AAAA AAAAAAAA AAAA AAAA AAAA AAAA AAAA AAAA AAAA AAAA AAAA AAAA AAAAAAAA AAAAAAAAAAAAAAAAAAAA AAAAAAAA AAAA AAAA AAAA AAAA AAAA AAAAAAAA AAAA AAAA AAAAAAAA AAAA AAAAAAAA AAAA AAAA AAAA AAAA AAAAAAAA AAAAAAAA AAAA AAAA AAAA AAAA AAAA AAAA AAAAAAAA AAAA AAAA AAAA AAAA AAAA AAAAAAAA AAAA AAAA AAAAAAAAAAAAAAAAAAAA AAAAAAAA AAAA AAAA AAAA AAAA 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 Ordering Information The first copy of each GAO report and testimony is free. Additional copies are $2 each. 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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)