oversight

Environmental Cleanup Costs: NASA Is Making Progress in Identifying Contamination, but More Effort Is Needed

Published by the Government Accountability Office on 1997-06-27.

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

                  United States General Accounting Office

GAO               Report to Congressional Requesters




June 1997
                  ENVIRONMENTAL
                  CLEANUP COSTS
                  NASA Is Making
                  Progress in Identifying
                  Contamination, but
                  More Effort Is Needed




GAO/NSIAD-97-98
             United States
GAO          General Accounting Office
             Washington, D.C. 20548

             National Security and
             International Affairs Division

             B-276548

             June 27, 1997

             The Honorable J. Dennis Hastert
             Chairman
             The Honorable Thomas Barrett
             Ranking Minority Member
             Subcommittee on National Security,
               International Affairs, and Criminal Justice
             Committee on Government Reform and Oversight
             House of Representatives

             This report responds to the request of the former Chairman and ranking
             minority member that we review the National Aeronautics and Space
             Administration’s (NASA) environmental cleanup costs. The report expands
             on information provided in our September 1996 testimony on NASA
             infrastructure1 and provides an assessment of NASA’s (1) determination of
             the extent of contamination it may be responsible for cleaning up and
             progress in its cleanup program, (2) cost estimates for accomplishing
             cleanup, and (3) efforts to determine whether “potentially responsible
             parties” should share in cleanup costs.


             Like other entities, including federal agencies, NASA must comply with
Background   federal environmental laws, including the Resource Conservation and
             Recovery Act (RCRA) of 1976 and the Comprehensive Environmental
             Response, Compensation, and Liability Act (CERCLA) of 1980, as amended.
             RCRA regulates the generation, transportation, storage, disposal, and
             cleanup of hazardous wastes. CERCLA creates a framework for carrying out
             cleanups, particularly for sites that have been abandoned and sites that
             pose the most severe environmental threat. The Environmental Protection
             Agency (EPA) administers RCRA and CERCLA, and it may authorize state
             agencies to implement all or part of RCRA responsibility. To carry out its
             responsibility, therefore, NASA needs to work with multiple regulators.

             In our 1991 report,2 we stated that NASA had not adequately implemented
             its policy to prevent, control, and abate environmental pollution. As a
             result of our 1991 report, NASA developed an environmental strategic plan
             and established an Environmental Management Division at the


             1
              NASA Facilities: Challenges to Achieving Reductions and Efficiencies (GAO/T-NSIAD-96-238, Sept. 11,
             1996).
             2
              Environmental Protection: Solving NASA’s Current Problems Requires Agencywide Emphasis
             (GAO/NSIAD-91-146, Apr. 5, 1991).



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headquarters level. The environmental strategic plan includes a goal of
remediating contaminated sites to protect human health and the
environment as quickly as funds allow. To carry out this plan, NASA uses a
decentralized management approach. Its field facility directors are
responsible for day-to-day environmental matters, including remedial
activities. The Environmental Management Division is the focal point for
environmental matters. In our 1994 follow-up report,3 we stated that NASA’s
environmental program still lacked implementation schedules and, if
funding levels at that time continued, remedial activities would take longer
than the 20 years NASA had predicted.

On the basis of its March 1996 site inventory, NASA identified 913
potentially contaminated sites at 22 of its field facilities in 10 states (see
fig. 1).4




3
 Environmental Management (GAO/NSIAD-94-264R, Sept. 21, 1994).
4
 The NASA March 1996 inventory of 913 potentially contaminated sites was updated in August 1996.
The update shows 919 sites. We did not believe that the increase from 913 to 919 significantly changed
the March data; therefore, our analyses are based on the March 1996 inventory.



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Figure 1: Location of NASA Field Facilities Having Potentially Contaminated Sites




                                                                                                           Plum Brook
                                                                                                           Lewis




                                                                                                                                  Goddard


                                                                                                                                  Wallops
                                                                                                                                  Main Base

                                                                                                                                  Wallops
                                                                                                                                  Island




                  NASA Industrial Plant                                                                                     Langley
                  JPL-Gold Stone
                  JPL-Pasadena                                                                  Marshall
                  JPL-Edwards
                  Dryden                                                                Yellow Creek
                  Santa Susana
                  Ames                                            Johnson
                                          El Paso                                     Stennis
                                          White Sands                                                                   Kennedy
                                                                 Ellington            Michoud




                                           Source: NASA’s hazardous site inventory database, dated March 1996.




                                           Appendixes I, II, and III discuss specific data on NASA’s cleanup costs at
                                           selected facilities (1) owned and operated by NASA, (2) owned by NASA and
                                           operated by a NASA contractor, and (3) owned and operated by a NASA
                                           contractor.




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                                       Although NASA began identifying sites nearly 10 years ago, it did not
Results in Brief                       complete a comprehensive hazardous site inventory database until 1993.
                                       NASA officials said that they now consider their inventory of 913 potentially
                                       contaminated sites to be about complete. However, the extent of
                                       environmental contamination is not yet fully known, and NASA facilities
                                       have a long way to go to effect cleanup of the contaminated sites. Figure 2
                                       shows the percentage of potentially contaminated sites by cleanup status.


Figure 2: Percentage of Potentially
Contaminated Sites by Cleanup Status
                                          Investigating 42%




                                                                                                   Cleaning 3%
                                                                                                     Other   4%




                                         No planned action      51%



                                       Source: NASA’s hazardous site inventory database, dated March 1996.




                                       NASA is also in the early stages of determining what it will cost to clean up
                                       those sites that require remediation. However, NASA needs better data
                                       before it can reliably estimate its cleanup cost. NASA headquarters had
                                       estimated its total cleanup costs would be $2 billion to clean up all its
                                       potentially contaminated sites over a 20-year period. It later lowered the
                                       estimate to $1.5 billion by eliminating sites where it believed no further
                                       action was needed. This estimate assumed that all sites of the same type
                                       would cost the same, regardless of variances in the extent of
                                       contamination. At our request, NASA field facilities developed estimates of




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remediation costs totaling $636 million based on actual costs, local quotes,
and input from other federal facilities. However, the field facilities’
estimates excluded some of the 383 sites that had not been studied.
Neither the headquarters nor the field estimates included long-term
operation and maintenance costs5 or considered NASA’s potential costs for
remediation at its contractor facilities. Furthermore, neither estimate
considered the potential effect of infrastructure changes that could
increase remediation cost. For example, depending on planned future use
after facility closure, regulators could require NASA to clean up to a higher,
more costly residential-use standard rather than the lower, industrial-use
standard currently being applied to NASA facilities. Although NASA’s overall
budget is projected to decline over the next few years, NASA headquarters
is projecting that environmental funding will remain about level in fiscal
year 1998, then increase somewhat over the following 4 years. However,
some field facilities indicated they were planning to request major
environmental funding increases. As a result, NASA will need to consider
how it will prioritize the various funding requests.

CERCLA  allows federal agencies and other entities that carry out cleanup
activities to seek cost sharing or cost recovery from the potentially
responsible parties whom the law would hold liable, such as past owners,
operators, and contractors. CERCLA cost recovery can also be available to a
party conducting a cleanup under RCRA corrective action requirements.
Despite the availability of a cost recovery mechanism, NASA headquarters
has not had a policy for determining whether to seek contributions from
other parties. NASA is paying the remediation costs for virtually all of its
field facilities. Except for a few cases involving contractor negligence,
NASA facilities have not identified if there are opportunities for recovering
costs from potentially responsible parties. After we discussed the
preliminary results of our review with NASA officials, they reported that
they are now developing a policy statement addressing the issue of
identifying and pursuing potentially responsible parties where appropriate.




5
 Subsequent to our field work, NASA headquarters used a new cost model that considers site
differences, and at least 5 years of long-term operation and maintenance costs. Using preliminary data
in the new model, NASA estimated that the future cleanup cost would be $1.4 billion for an estimated
679 sites potentially requiring remediation.



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                             NASA officials said that their inventory of potentially contaminated sites is
Further Investigations       now considered complete; however, further investigations are needed to
Are Needed to Fully          determine the extent of required cleanup for most sites. The actual
Determine the Extent         cleanup of some sites is just beginning.

of Contamination and
Cleanup Is Just
Beginning
Extent of Contamination Is   In 1988, NASA headquarters began efforts to identify contaminated sites at
Not Fully Known              most of its facilities.6 However, a comprehensive hazardous site inventory
                             database was not completed until 1993. NASA officials said that they have
                             identified practically all of their potentially contaminated sites. One
                             exception is the NASA Industrial Plant at Downey, California. The Downey
                             facility was not part of NASA’s overall inventory effort because the facility
                             was not disposing of hazardous waste and was not a large generator of
                             hazardous waste. A recently completed study shows that four of the six
                             parcels comprising the Downey facility require no remediation. A contract
                             to study the other two parcels is underway. These two parcels are more
                             likely to contain contaminated sites, but pending the completion of the
                             study, the number of such sites will not be known.

                             Figure 3 shows NASA’s reported number of sites in the cleanup phase or
                             potentially requiring remediation (447) as well as the number of sites that
                             have no planned action (466) for each of the NASA field facilities.




                             6
                              NASA field facilities have been identifying potentially contaminated sites since the 1980s. For
                             example, the George C. Marshall Space Flight Center and the Michoud Assembly Facility identified
                             some sites in the early 1980s, and the John F. Kennedy Space Center identified 21 sites in the
                             mid-1980s.



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Figure 3: Breakdown of the Number of Sites in the Cleanup Phase or Potentially Requiring Remediation and of Sites Having
No Planned Action

Number of sites
200

       161
150


                    109
100
                              78
                                      63 63 61
                                                                   51
 50                                                                               42 41
                                                                                                           35 33 33 32
                                                                                                                                                     25 23 22
                                                                                                                                                                                             15 12
                                                                                                                                                                                                                           7                  4           2         1
   0
                                                                                                                                                                         Wallops Main Base
                                                                   Yellow Creek
         Marshall




                                               Johnson
                                                         Stennis


                                                                                  White Sands
                    Kennedy




                                                                                                Pasadena
                                                                                                           Santa Susana




                                                                                                                                           Edwards
                                                                                                                                                     Langley




                                                                                                                                                                                                                           Industrial Plant
                                                                                                                          Ames




                                                                                                                                                                                             Plum Brook
                              Lewis




                                                                                                                                 Michoud




                                                                                                                                                               Goddard




                                                                                                                                                                                                                                                          El Paso
                                                                                                                                                                                                                                              Ellington
                                                                                                                                                                                                          Wallops Island
                                      Dryden




                                                                                                                                                                                                                                                                    Goldstone



                                                               Potential remediation                                                       No planned action


                                                                                     Source: NASA’s hazardous site inventory database, dated March 1996.




                                                                                     NASA’s  potentially contaminated sites were often identified through various
                                                                                     activities. For example, at the John F. Kennedy Space Center in Florida,
                                                                                     one of the contamination problems was discovered when workers became
                                                                                     ill while digging holes for telephone poles during the late 1980s. At the
                                                                                     Santa Susana Field Laboratory in California, groundwater contamination



                                                                                     Page 7                                                                                                               GAO/NSIAD-97-98 NASA’s Cleanup Costs
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                                        problems were discovered during an investigation of site water supply
                                        wells in 1984. At the Langley Research Center in Virginia, contamination of
                                        a creek bed was discovered during a 1988 study of marine life in the area.

                                        Some NASA sites are on the National Priorities List of highly polluted sites
                                        established by EPA under CERCLA. NASA’s Dryden Flight Research Center in
                                        California, the Langley Research Center in Virginia, and the George C.
                                        Marshall Space Flight Center in Alabama have been placed on the list and
                                        are jointly listed with collocated Department of Defense (DOD) sites. The
                                        Jet Propulsion Laboratory in Pasadena, California, is also on the list. The
                                        national priorities designation requires that these sites follow the CERCLA
                                        process during remediation. Other NASA facilities had the choice of
                                        following either CERCLA or RCRA processes to clean up contaminated sites.
                                        NASA states that because the facilities that are being cleaned up have RCRA
                                        permits, RCRA is the cleanup authority it will use.


Cleanup Is in Early Stages              The status of NASA’s potentially contaminated sites is summarized in
and Estimates for                       table 1.
Completion Are Unreliable

Table 1: Status of NASA’s Potentially
Contaminated Sites                      Status                                                                    Number         Percent
                                        No planned action
                                        Closed without need for remediation                                              57           6
                                                                    a
                                        No further action planned                                                      200           22
                                        Need inspection upon closure                                                   209           23
                                            Subtotal                                                                   466           51
                                        Potential remediation
                                        Remediated or being remediated                                                   31           3
                                        Classified as “other”                                                            33           4
                                        Needing investigation/being investigated                                       383           42
                                            Subtotal                                                                   447           49
                                        Total                                                                          913           100
                                        a
                                         NASA’s August 1996 update shows that 35 of the 200 sites requiring no further action were
                                        placed in categories requiring further action, therefore reducing the 200 to 165.



                                        The sites with no planned action (466) were sites where there was thought
                                        to be some contamination; however, preliminary reviews of the sites
                                        showed no contamination or a level of contamination within EPA’s



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acceptable limits. For example, one site identified from an aerial
observation at the Langley Research Center proved to be simply an area
where vehicles had been washed and not a site containing contamination.

Of the sites NASA classifies as potentially requiring remediation (447), a
large number of sites (383) still require investigating or are being
investigated to evaluate the extent of contamination and the need for
cleanup. NASA headquarters officials said that these investigations are not
scheduled to be completed until the end of 1997, but some field facilities
expect the investigations to be completed later. For example, the Marshall
Space Flight Center is slated to complete its investigations in mid-1998, the
Michoud Assembly Facility in Louisiana does not plan to complete its
investigation until 1999, and the Kennedy Space Center does not expect to
complete its investigation until the end of 1999. Until these investigations
are completed, the type and extent of contamination and the need for
cleanup are uncertain.

Although NASA headquarters estimates a 20-year period for cleaning up
contaminated sites, it is not well-supported. For example, neither it nor its
field facilities have a detailed time schedule for accomplishing the
cleanup. Only 31 contaminated sites, or 3 percent, have been or are being
remediated.

Field facility officials cited other reasons, in addition to the relatively slow
start, for not being further along in the remediation process. For example,
there have been difficulties in dealing with multiple federal and state
agencies and getting them to agree on the level of cleanup necessary. The
Langley Research Center, in its attempts to get concurrence on the level
and method of cleanup required for one of its sites, has been giving data to
a number of different regulators and has been responding to questions
relative to this cleanup for over 8 years. A chronology of correspondence
shows that the regulators and Langley have exchanged over 100
documents during this period.




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                         NASA  field facilities reported spending $117 million through fiscal year 1995
Better Data Are          for remedial activities, not including management costs.7 Most of these
Needed Before            funds were used for precleanup activities. Making accurate estimates of
Reliable Cleanup Cost    NASA’s additional cleanup cost is not possible because the extent of
                         contamination for most sites that may require remediation has not been
Estimates Can Be         determined. At the time of our field work, NASA headquarters estimated
Made                     that remediation would cost $1.5 billion.8 NASA field facilities provided
                         estimates totaling $636 million. However, the two estimates are not
                         comparable. The headquarters’ estimate considers all sites of the same
                         type to cost the same, regardless of variances in extent of contamination,
                         and the field facilities’ estimates do not include all potential sites such as
                         those still being studied. Neither estimate includes all long-term operations
                         and maintenance costs nor any costs for NASA’s potential remediation
                         liability at its contractor facilities. The estimates also do not consider
                         potential effects of infrastructure changes. Any of these costs could
                         significantly increase the potential remediation cost. Accordingly, it is
                         likely that NASA will have to make priority decisions on cleanup
                         expenditures.


Past Expenditures Were   Most of the $117 million spent to date on remedial activities ($83 million)
Predominantly for        has been spent on such preliminary activities as investigations or studies.
Precleanup Activities    For example, information provided by the Pasadena facility showed that
                         all of its expenditures ($11 million) had been spent on precleanup
Rather Than Cleanup      activities, and information provided by the White Sands Test Facility in
                         New Mexico showed that virtually all of its expenditures ($28 million) had
                         been spent on precleanup activities. Only three field facilities—Ames
                         Research Center in California, Lewis Research Center in Ohio, and
                         Michoud Assembly Facility in Louisiana—spent more on cleaning up than
                         on conducting studies and investigations.




                         7
                          Management costs include NASA’s cost for personnel who manage the remediation program. DOD
                         designates such costs as remediation costs, while NASA cannot accurately break out or identify these
                         costs as remediation.
                         8
                          Subsequent to our field work, NASA headquarters, using a new cost model that considers site
                         differences, estimated that the future cleanup cost would be $1.4 billion for an estimated 679 sites
                         potentially requiring remediation.



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Accurate Estimates of     NASA’s  site inventory, which is maintained by headquarters and updated by
Future Cost Are Not       the field facilities, should list cleanup cost estimates developed by each
Possible Without Better   facility for each of its sites. However, NASA’s inventory contained
                          site-specific cost estimates for only 19 percent of the sites9 that may
Data                      require remediation because the process of developing such data is in the
                          early stages at most facilities. Moreover, many of the cost estimates are
                          only for the early stages of the remediation process and may not include
                          the total cleanup cost.

                          Using parts of a DOD cost model, which involved an average cleanup cost
                          of 17 separate classes of environmental problems, NASA headquarters
                          developed the remediation estimates used at the time of our field work.
                          The average cost of the specific class was multiplied by the number of
                          sites within the class. For example, one contamination class was
                          “contaminated sediment,” which had an average remediation cost of
                          $2.7 million per site. Therefore, the model required multiplying the number
                          of NASA’s contaminated sediment sites by the $2.7 million. NASA said that
                          the model may have overstated its remediation estimate because most DOD
                          sites were larger and probably more polluted than NASA sites. According to
                          NASA officials, the DOD model was the best available approach in 1993.


                          NASA’s estimate of $1.5 billion was a reduction of $500 million from its
                          original estimate of $2 billion. The reduction resulted from a NASA
                          headquarters’ decision to eliminate all sites that are classified as requiring
                          no further action from the original cost estimate. This reduction appeared
                          appropriate based on available data.

                          NASA recognizes that some classes of sites, such as landfills and water
                          treatment facilities, may require annual operation and maintenance
                          expenses; however, such costs were not included in NASA headquarters’
                          estimate of $1.5 billion.10 An example is contaminated groundwater that
                          may be remediated through a process known as “pump and treat,” where
                          contaminated water is extracted from the ground, treated, and then
                          reinjected. This process can be continued for decades, thereby requiring
                          continued operations and maintenance expenditures. For these sites,
                          significant post-cleanup costs could last indefinitely. DOD has found that


                          9
                           Subsequent to our field work, a NASA headquarters’ contractor, using a new cost model, updated the
                          site cost estimates to include all sites that NASA expects to clean up. NASA believes that this new
                          model, when fully implemented, will provide significantly improved cost estimates for its cleanup
                          costs.
                          10
                            Included in NASA’s new cost model is an estimate for at least 5 years of operation and maintenance
                          for those sites that NASA currently projects will require such activities.



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annual operation and maintenance costs can be as high as 25 to 30 percent
of cleanup costs.

To determine if a more reliable cost estimate could be developed, we
visited a number of NASA field facilities and sent requests for data to other
facilities. From data that the field facilities provided, we compiled a total
cost estimate of $636 million for past ($117 million) and future
($519 million) remediation costs.

The field facilities’ estimates were significantly lower than the
headquarters’ estimate. For example, for one of the facilities with the most
potentially contaminated sites (Kennedy Space Center), the headquarters’
estimate of $379.6 million significantly exceeds the facility’s estimate of
$86.2 million. According to Kennedy officials, their estimates are based on
actual costs, local quotes, input from other federal facilities, and
information from the Remedial Action Engineering and Requirements
System, which is an environmental cost estimating system based on
site-specific data. Although the Kennedy estimate may be more accurate
than the headquarters’ estimate for the sites investigated to date, Kennedy
has not yet completed cleaning up any of its sites or investigating many of
its sites and the facility’s estimate only includes sites that are projected for
cleanup through 2002, although remediation is not expected to be
completed until 2008.

Two facilities with fewer sites than Kennedy that are further along in
studying contaminated sites also show a much lower estimate than the
headquarters’ estimate. The Langley Research Center shows a projected
total cleanup cost of $6.2 million compared to the headquarters’ estimate
of $29.3 million, while the Ames Research Center shows a total projected
cleanup cost of $19.6 million compared to the headquarters’ estimate of
$44.2 million.

Although NASA field facilities currently estimate future remediation will
cost $519 million, some facilities are negotiating with federal and/or state
regulators on the extent of cleanup needed. The results of such
negotiations will affect the amount needed for cleanup. For example, the
Langley Research Center has been negotiating with EPA for years on the
level of cleanup for one of its sites. Depending on the level agreed to,
Langley’s cleanup cost for this one site could range from $2 million to
$100 million.




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                                        Figure 4 shows the amount of money that selected field facilities spent
                                        through fiscal year 1995 compared to the amount they expect to spend in
                                        the future.



Figure 4: Amount of Money Spent Through Fiscal Year 1995 Compared to Projected Expenditures


                2.5
 Edwards                                                                           78


                2.7
Kennedy                                                                                  83.5


                 3.8
 Marshall                                                                                83.7


                       11.2
Pasadena                                                                                          92.8



            0                 20          40                60                    80                 100             120
                                                    Millions of dollars

                                               Past cost      Future cost




                                        Source: NASA’s hazardous site inventory database, dated March 1996.




Potential Costs for                     Other costs not captured in NASA’s remediation cost estimates need to be
Cleanup at Contractors’                 considered. For example, NASA has not determined how much it is or could
Facilities Could Be                     be paying through overhead charges to clean up contaminated facilities
                                        owned and operated by its contractors or what its potential future cleanup
Significant                             costs are at contractor-owned sites. To develop such estimates, we sent a
                                        request to 20 of NASA’s largest contractors and asked for (1) NASA payments
                                        to them during the past 2 years for their cleanup costs and (2) their
                                        estimates of future cleanup costs at their facilities.



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                             Of these 20 contractors, 16 responded. NASA has paid $22 million to clean
                             up environmental contamination at these contractor plants during the past
                             2 years through reimbursing contractors’ overhead charges. In terms of
                             future cleanup costs, these contractors expected such costs to be over
                             $1 billion. This estimate, however, did not include the costs for NASA’s
                             largest contractor because it did not provide future costs. That contractor
                             has NASA contracts worth over $35 billion.


Cost Impact of Potential     An additional uncertainty regarding NASA’s future remediation cost is the
Infrastructure Changes Is    potential impact if any field facilities are closed and cleanup is to a higher
Uncertain                    land-use standard. In our September 1996 testimony on NASA
                             infrastructure,11 we stated that the impact of environmental cleanup
                             requirements on NASA’s property disposal decisions is not yet well known.

                             CERCLA requires that the government clean up property before selling or
                             transferring it to others. Typically, this requires that the future use of the
                             property be established and cleanup be done in accordance with the
                             planned use. Most NASA facilities are currently used for industrial activity.
                             As might be expected, the cleanup standard for industrial use property is
                             lower than what would be required for residential use. NASA officials
                             believe that if the agency chooses to dispose of a property, regulators
                             could require NASA to clean up to a residential use as opposed to an
                             industrial-use standard. Although field facilities had not prepared actual
                             cost estimates, about half of the facilities contacted believed that if their
                             facilities were closed, cleanup costs would increase significantly. For
                             example, the White Sands Test Facility estimated costs could nearly
                             double; the Marshall Space Flight Center believed they could triple; and
                             the Lewis Research Center believed they could quintuple. However,
                             ultimately the effect of closures on cleanup costs would have to be
                             decided on a case-by-case basis.


Future Funding Will          According to the NASA fiscal year 1998 budget estimate to the Congress,
Require Priority Decisions   NASA’s overall budget is projected to decline by nearly 4 percent over the

on Cleanup                   next 5 years. This decline is even more dramatic when the projected
                             available funds are adjusted for inflation. In terms of 1997 dollars, the
                             decline is projected to be over 20 percent over the 5-year period. NASA’s
                             environmental budget line, which is $33 million for fiscal year 1997, is
                             currently projected to remain at about the same level in fiscal year 1998,

                             11
                              NASA Facilities: Challenges to Achieving Reductions and Efficiencies (GAO/T-NSIAD-96-238,
                             Sept. 11, 1996).



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                           then increase to an average of about $50 million over the following 4 years.
                           Considering inflation, this amount will be worth less in later years.

                           NASA  does not separately identify remediation in its environmental budget.
                           In fiscal years 1993 and 1994, remediation was about 50 percent of the
                           environmental budget. By 1996, remediation had grown to about 65
                           percent, and it is expected to remain at that level in the future. Since
                           NASA’s two facilities with the greatest number of contaminated
                           sites—Kennedy Space Center and Marshall Space Flight Center—are
                           intensifying their remediation efforts, it is likely that NASA will have to
                           prioritize environmental remediation expenditures as remediation efforts
                           intensify. This is further demonstrated by NASA’s change in the projected
                           environmental budget for the year 2000, or a decline from $70 million in its
                           fiscal year 1996 estimate to $52 million in its fiscal year 1998 estimate.


                           Although CERCLA allows NASA to recover cleanup costs from past and
Policy Is Needed to        present owners and operators and from other potentially responsible
Determine Whether          parties, NASA headquarters has not yet developed an overall policy relating
Other Parties Should       to determining the potential for recovery of costs. To date, NASA field
                           facilities have only made limited efforts to determine whether there may
Be Sharing Cleanup         be opportunities to recover cleanup costs. Except for other federal
Costs                      agencies and a few contractor negligence situations, NASA generally has not
                           identified whether potentially responsible parties should be sharing costs.
                           However, field facility officials said that opportunities for doing so may
                           exist.


Cost Recovery Policy Has   Two federal environmental laws, RCRA and CERCLA, require remedial action
Not Been Developed         to clean up property contaminated with hazardous substances that pose a
                           threat to health or the environment.12 Both RCRA and CERCLA impose a
                           responsibility for cleanup on the owner and/or operator of a facility. Under
                           CERCLA, the party carrying out a cleanup may seek cost reimbursement
                           from other persons whom the law would hold liable. Persons include past
                           owners, operators, contractors, and a broad range of other potentially
                           responsible parties. CERCLA cost recovery can also be available to a party
                           conducting a cleanup under RCRA.13


                           12
                            Which law governs depends on the circumstances, including whether the site is on the National
                           Priorities List.
                           13
                             42 U.S.C. 9607(a)(4)(A) allows a federal agency to recover cleanup costs for removal or remedial
                           actions “not inconsistent with the National Contingency Plan.” EPA regulations on cost recovery are
                           found in 40 C.F.R. § 300.700(c).



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                           Despite the potential for cost recovery, NASA has not issued a policy or
                           guidance to field facilities to govern the recovery of cleanup costs where
                           appropriate. However, the agency is in the process of drafting a policy
                           statement requiring the identification of potentially responsible parties
                           from whom contributions might be sought.


Cost Recovery Efforts to   We noted two situations where NASA identified contractor negligence
Date                       resulted in contamination requiring cleanup. In these cases, NASA
                           recovered some of the cost from the contractors involved. One situation
                           occurred at the Ames Research Center in 1992. A contractor left a fueling
                           operation unattended and spilled about 2,500 gallons of jet fuel. NASA
                           pursued the contractor for negligence and negotiated a recovery of
                           $204,000 of the cleanup cost from the contractor. In the second situation, a
                           support services contractor at the Lewis Research Center dumped lead
                           paint on the ground, resulting in a cleanup bill for Lewis of $100,000. The
                           entire sum was withheld from the contractor’s payment on its support
                           services contract.

                           Another situation where NASA’s cleanup cost is likely to be shared involves
                           groundwater treatment at NASA’s Ames Research Center. NASA, as a named
                           party in a record of decision that EPA issued in 1989, is in the process of
                           finalizing an agreement with other potentially responsible parties,
                           including private companies operating on adjacent property, that would
                           require NASA to pay the companies $1.4 million of the estimated
                           $5.5 million cleanup costs. Thereafter, the private firms, and not NASA,
                           would pay for and conduct the groundwater cleanup.


NASA Is Paying Costs of    During our review, we found a number of other situations in which NASA
Ongoing Cleanups           has paid or is paying to clean up contamination that involved other parties.
                           In one example, a 1966 spill of 16,000 gallons of trichloroethylene at the
                           Michoud Assembly Facility seeped into groundwater and created
                           significant contamination. NASA has historical records to identify the
                           contractor that operated the facility at the time of the spill as well as other
                           contractors on the property at the time. However, a 1993 search of
                           contract and insurance records from the 1960s did not produce any
                           contractual documentation. According to Michoud officials, because of the
                           lack of documentation and because the contamination occurred during the
                           1960s, NASA will probably not try to recover costs from the past
                           contractors.




                           Page 16                                     GAO/NSIAD-97-98 NASA’s Cleanup Costs
B-276548




Another example involves the Kennedy Space Center. Until our review,
Kennedy had not searched for contractors or other responsible parties to
contribute to costs. According to Kennedy officials, the conventional view
has been that, as the owner and operator of its facility, NASA oversees
contractor operations and is, therefore, responsible for any contamination.

As a result of our inquiries, Kennedy’s legal office and Environmental
Management Office officials said that they plan to be more aggressive in
determining whether there are cost recovery opportunities. For example,
Kennedy officials believe that they may be able to obtain reimbursement
for cleanup costs attributable to the actions of a former landowner that
operated a private business on the site that contaminated groundwater.
Kennedy has constructed a water treatment facility ($265,000) that pumps
and treats contaminated groundwater, and it is paying for the operation
and maintenance of the facility ($168,000 a year since 1991). Kennedy
officials said they plan to continue the present cleanup strategy until
contamination is reduced to acceptable levels and, following treatment,
they will attempt to determine whether to pursue the former landowner. In
another case, Kennedy plans to clean up fuel oil contamination that
occurred when a storage tank leaked gasoline or diesel fuel at its visitor’s
center. Cleanup involves removing and aerating soil at the site. At the time
of the contamination, a private company leased the visitor’s center.
Kennedy officials believe that the lessee had control of the situation and
should be held responsible. According to Kennedy officials, the lessee paid
for the remedial investigation at the site before Kennedy assumed control
of the cleanup. Kennedy took over the cleanup because another lessee
now occupies the center. Kennedy’s projected remediation cost for the
visitor’s center is $3.5 million. After the cleanup is completed, Kennedy
will decide whether the former lessee should be asked to reimburse the
government.

The Santa Susana Field Laboratory is another situation where NASA
officials need to decide whether it should pursue cost sharing. NASA owns
some of the land at Santa Susana, but most of the facility is a
contractor-owned and -operated plant. The major problem at the Santa
Susana facility is groundwater contaminated with trichloroethylene. The
contamination, according to a NASA-funded study, occurred primarily in the
1950s as a result of contractor rocket testing for the Air Force. That testing
was carried out by the same contractor that still owns the facility and most
of the land. NASA has paid for groundwater treatment on its property, and it
has tried over the past few years to get the Air Force to pay more of the
cleanup costs. To date, the Air Force has refused, pointing to the



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                         B-276548




                         contractor as the party principally responsible for the contamination.
                         While the debate continues over who should contribute and how much,
                         NASA is paying the largest portion of the groundwater treatment costs.



                         We recommend that the NASA Administrator
Recommendations
                     •   establish facility-based, implementation schedules for completing cleanup
                         of contaminated sites;
                     •   estimate probable future costs by (1) identifying all site-specific costs,
                         including operation and maintenance costs, for sites believed to require
                         remediation, (2) requesting contractors’ remediation cost estimates for
                         cleaning up contamination at contractor facilities that could represent
                         future costs for NASA and taking any necessary contract action to require
                         such estimates in the future, (3) identifying infrastructure changes, such as
                         planned property use and applicable cleanup standards that are consistent
                         with requirements for the Annual Accountability Report, and documenting
                         the impact of facility closure decisions on environmental cleanup costs;
                     •   prioritize the application of environmental funds in its cleanup efforts; and
                     •   issue a policy statement concerning potentially responsible parties and
                         cost recovery.


                         NASA generally concurred with our recommendations, except for questions
Agency Comments          in two areas—(1) requiring contractors to provide remediation cost
and Our Evaluation       estimates for cleaning up contamination at contractor facilities that could
                         represent future costs for NASA and (2) identifying infrastructure changes,
                         such as planned property use and applicable cleanup standards, and
                         documenting the impact of facility closure decisions on environmental
                         cleanup costs.

                         NASA   said that estimates of contractor cleanup costs that would be
                         allowable and allocable under future contracts would be speculative. We
                         agree that such estimates would not be firm, but we believe that even a
                         preliminary estimate of the total amount NASA could be paying to
                         contractors in the form of indirect costs would help to provide a more
                         complete picture of its environmental cleanup costs. As we note in the
                         report, NASA’s remediation cost estimates do not show the amount that it is
                         paying through overhead charges to clean up contaminated contractor
                         facilities or its potential future costs at such facilities. NASA also stated that
                         it is not clear if it can require contractors to estimate the costs of future
                         cleanup at contractor facilities. To the extent that existing contracts do



                         Page 18                                      GAO/NSIAD-97-98 NASA’s Cleanup Costs
B-276548




not support such a requirement, we believe that, when an opportunity
arises, NASA should include in its contracts the authority to require
estimates of future cleanup costs. In the meantime, NASA at least needs to
ask contractors for such estimates. All but one of the contractors
responding to our survey provided that information to us, and contractors
also have provided environmental cost estimates to DOD. We have modified
our recommendation accordingly.

NASA  agreed that environmental costs need to be identified as soon as
possible but believed our recommendation to identify infrastructure
changes and costs go well beyond requirements to identify costs for its
Annual Accountability Report, using best available data. Our
recommendation did not intend to recommend identifying cost impacts
where changes are not yet planned, so we modified our recommendation
to clarify our intent.

NASA comments are reprinted in full in appendix V. NASA also provided
suggested editorial and technical changes and supplied updated
information. We have incorporated this additional information in the
report where appropriate.

We performed our review from October 1996 through May 1997 in
accordance with generally accepted government auditing standards. The
scope and methodology for our review are discussed in appendix IV.


Unless you publicly announce its contents earlier, we plan no further
distribution of this report until 30 days after its issue date. At that time, we
will make copies available to interested congressional committees; the
Administrators, National Aeronautics and Space Administration and the
Environmental Protection Agency; and the Director, Office of Management
and Budget. We will also make copies available to others on request.




Page 19                                     GAO/NSIAD-97-98 NASA’s Cleanup Costs
B-276548




If you have any questions on this report, please call me on (202) 512-8412.
Major contributors to this report are listed in appendix VI.




David R. Warren, Director
Defense Management Issues




Page 20                                   GAO/NSIAD-97-98 NASA’s Cleanup Costs
Page 21   GAO/NSIAD-97-98 NASA’s Cleanup Costs
Contents



Letter                                                                                             1


Appendix I                                                                                        24
                        Background                                                                24
John F. Kennedy         Extent of Contamination                                                   25
Space Center            Cost to Clean Up Contamination                                            27
                        Cost Sharing Efforts                                                      28

Appendix II                                                                                       30
                        Background                                                                30
Michoud Assembly        Extent of Contamination                                                   31
Facility                Cost to Clean Up Contamination                                            32
                        Cost Sharing Efforts                                                      34

Appendix III                                                                                      35
                        Background                                                                35
Santa Susana Field      Extent of Contamination                                                   38
Laboratory              Cost to Clean Up Contamination                                            40
                        Cost Sharing Efforts                                                      41

Appendix IV                                                                                       43

Scope and
Methodology
Appendix V                                                                                        45

Comments From the
National Aeronautics
and Space
Administration
Appendix VI                                                                                       51

Major Contributors to
This Report
Tables                  Table 1: Status of NASA’s Potentially Contaminated Sites                   8
                        Table I.1: Remediation Status of Kennedy’s Sites                          26




                        Page 22                                  GAO/NSIAD-97-98 NASA’s Cleanup Costs
          Contents




          Table I.2: Kennedy’s Projected Remediation Costs for Fiscal              28
            Years 1996 Through 2002
          Table III.1: Remediation Status of NASA-owned Sites                      39
          Table IV.1: Locations and Organizations Responding to Our Data           44
            Request

Figures   Figure 1: Location of NASA Field Facilities Having Potentially            3
            Contaminated Sites
          Figure 2: Percentage of Potentially Contaminated Sites by                 4
            Cleanup Status
          Figure 3: Breakdown of the Number of Sites in the Cleanup Phase           7
            or Potentially Requiring Remediation and of Sites Having No
            Planned Action
          Figure 4: Amount of Money Spent Through Fiscal Year 1995                 13
            Compared to Projected Expenditures
          Figure I.1: Location of the Kennedy Space Center                         24
          Figure II.1: Location of the Michoud Assembly Facility                   30
          Figure III.1: Location of the Santa Susana Field Laboratory              36




          Abbreviations

          CERCLA     Comprehensive Environmental Response, Compensation,
                          and Liability Act
          DOD        Department of Defense
          EPA        Environmental Protection Agency
          NASA       National Aeronautics and Space Administration
          RCRA       Resource Conservation and Recovery Act


          Page 23                                 GAO/NSIAD-97-98 NASA’s Cleanup Costs
Appendix I

John F. Kennedy Space Center



Background

Site Description and                  The John F. Kennedy Space Center is a government-owned,
Mission                               government-operated facility located on the east coast of Florida on
                                      Merritt Island near the Cape Canaveral Air Force Station (see fig. I.1).
                                      Kennedy contains the Merritt Island wildlife preserve and the Cape
                                      Canaveral National Seashore.


Figure I.1: Location of the Kennedy
Space Center


                                                                                              Jacksonville
                                                               Tallahassee




                                                                                                           Kennedy




                                                                                                                     Miami




                                      Source: NASA Real Property Locations by Accountable Reporting Installations.




                                      Kennedy is the National Aeronautics and Space Administration’s (NASA)
                                      main facility for launching space vehicles, and it also serves as a landing
                                      site. Kennedy’s role in the space program includes the assembly, checkout,
                                      and launch of payloads and space vehicles. Currently, it is focused on the



                                      Page 24                                               GAO/NSIAD-97-98 NASA’s Cleanup Costs
                     Appendix I
                     John F. Kennedy Space Center




                     space shuttle and on preparing for the integration and launch of space
                     station elements.


Regulatory Process   In the 1980s, Kennedy began its remediation process by determining if any
                     contamination posed hazards to human health or the environment, as
                     required by the Comprehensive Environmental Response, Compensation,
                     and Liability Act (CERCLA). Kennedy officials said, however, at that time
                     there was little or no focus on cleaning up sites. In 1986, Kennedy elected
                     to proceed with cleanup under the Resource Conservation and Recovery
                     Act (RCRA) corrective action process. RCRA regulates hazardous waste from
                     its origin through its ultimate treatment, storage, or disposal.

                     The Environmental Protection Agency (EPA) and Florida’s Department of
                     Environmental Protection are responsible for monitoring Kennedy’s
                     compliance with environmental law. Kennedy works with the concerned
                     regulatory agency to reach agreements on the types of remediation
                     activities and on the dates they will be carried out.


                     Within NASA, Kennedy has the second largest inventory of potentially
Extent of            contaminated sites. According to Kennedy officials, their site inventory
Contamination        should be about complete, and they expect to complete site remediation
                     by 2008 and operation of water treatment facilities by 2015.


Contaminated Sites   In performing its mission, Kennedy has generated waste that includes
                     petroleum, metals, solvents, adhesives, and sandblast residues. This waste
                     is considered to be ignitable, corrosive, and/or toxic. It has contaminated
                     the soil and groundwater and may be a danger to human health.
                     Contamination usually results from improper disposal, leaks, or spills.

                     Although NASA headquarters’ March 1996 inventory of potentially
                     contaminated sites shows that Kennedy has 109 sites, Kennedy records
                     show that it has 127 sites. According to a Kennedy official, the disparity
                     occurred because Kennedy included all potential release sites in its
                     inventory. It will not report some of these sites to headquarters as
                     potentially contaminated sites until it conducts further investigations.

                     Seven of the sites are on the Cape Canaveral Air Force Station where
                     Kennedy has operated in the past. Kennedy’s sites were identified (1) by
                     routine sampling, (2) at areas where spills were not completely cleaned



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                                   Appendix I
                                   John F. Kennedy Space Center




                                   up, or (3) in response to a concern voiced by an employee or a regulatory
                                   agency. Kennedy officials believe that all potential sites have been
                                   identified.


Cleanup Status and                 The remediation status of Kennedy’s 127 potentially contaminated sites is
Schedule                           shown in table I.1.

Table I.1: Remediation Status of
Kennedy’s Sites                    Status                                                               Number
                                   Cleanup in progress                                                         1
                                   Risk assessment completed                                                   6
                                   Being investigated                                                        20
                                   No further action contemplated                                            31
                                   Need to be investigated                                                   69
                                   Total                                                                    127

                                   The only contaminated site that Kennedy is currently cleaning up is the
                                   Wilson Corners site. The Wilson Corners site was where a previous
                                   landowner operated a component cleaning facility from the late 1950s
                                   through 1963. Kennedy purchased the site in 1963, and according to
                                   Kennedy officials, the prior landowner continued to operate the cleaning
                                   facility until 1965 when all operations ceased. According to Kennedy
                                   officials, most of the contamination occurred before Kennedy purchased
                                   the site. The contaminants are trichloroethylene and its degradation
                                   products. Kennedy started remediation in 1989 when it constructed a
                                   water treatment system. Remediation now entails pumping groundwater
                                   from 23 recovery wells and treating it. Kennedy monitors the influent,
                                   treated effluent, and the recovery wells. The cleanup completion for this
                                   pump and treat procedure usually takes years and sometimes is not
                                   completely successful. The site is now vacated and surrounded by a fence.

                                   According to Kennedy officials, by 1991, hazardous waste releases causing
                                   contamination stopped. They said that current schedules project
                                   remediation, on an average, of nine projects a year, and they estimate
                                   remedial actions may be completed at all sites by 2008. They said,
                                   however, water treatment facilities may need to be operated for about
                                   7 additional years. Thus, Kennedy’s cleanup effort may be completed by
                                   2015.




                                   Page 26                                  GAO/NSIAD-97-98 NASA’s Cleanup Costs
                   Appendix I
                   John F. Kennedy Space Center




                   NASA  headquarters estimates that it will cost $379.6 million to clean up
Cost to Clean Up   Kennedy’s contaminated sites. This estimate was derived from selected
Contamination      portions of a Department of Defense (DOD) cost model that multiplies the
                   average cost for a type of cleanup by the number of sites estimated to
                   require cleanup of that type. Kennedy’s estimate of $86.2 million is much
                   less than NASA headquarters’ estimate and is based on site-specific data.
                   Kennedy’s estimate, however, only includes sites that are projected for
                   cleanup through 2002, while the headquarters estimate includes all sites
                   potentially requiring cleanup.


Historical Costs   Kennedy spent a total of $2.7 million through fiscal year 1995 from NASA’s
                   construction of facilities funds and from Kennedy’s program mission
                   support funds on remediation. According to Kennedy officials, NASA’s
                   construction of facilities funds for environmental remediation can be held
                   and spent in any year, and local annual program mission support funds can
                   be used during the budget year, as needed, for remediation activities such
                   as site investigations and long-term operations and maintenance.

                   For fiscal years 1990 through 1995, NASA headquarters authorized about
                   $5.5 million from its environmental construction of facilities funds for
                   remediation at Kennedy. From these funds, Kennedy has spent $1.6 million
                   through fiscal year 1995 on remedial investigations. It has not spent any
                   construction of facilities funds on remedial design or remedial action
                   projects. For the one site being cleaned up (Wilson Corners), Kennedy is
                   using its local program mission support funds. Thus far, the cost of this
                   remedial action has been about $1.1 million. It consists of the construction
                   of a water treatment facility ($265,000) and the facility’s operations and
                   maintenance ($168,000 annually since 1991). Kennedy officials said plans
                   to use authorized construction of facilities funds have been delayed
                   because of slow regulatory reviews.

                   In regard to off-site contamination, Kennedy has not been involved in the
                   cleanup of any contractor-owned or third-party contaminated sites.
                   Additionally, officials said that they are not aware of any overhead charges
                   being added to their contracts because of environmental cleanups at
                   contractor facilities.


Future Costs       Kennedy estimates that it will spend $83.5 million for fiscal years 1996
                   through 2002 on 42 contaminated sites (see table I.2). According to
                   Kennedy officials, the remaining sites (85) have not been investigated



                   Page 27                                   GAO/NSIAD-97-98 NASA’s Cleanup Costs
                                         Appendix I
                                         John F. Kennedy Space Center




                                         enough to estimate remediation costs or, moreover, to determine if they
                                         require cleanup.


Table I.2: Kennedy’s Projected Remediation Costs for Fiscal Years 1996 Through 2002
Dollars in millions
                                                                    Fiscal year
Remediation phase                1996        1997           1998           1999            2000           2001           2002           Total
Investigation                    $3.8         $4.6           $2.5           $1.0           $0.2               0              0         $12.1
Design                             0.1         0.8            1.1             0.7            1.0          $0.2               0               3.9
Action                             1.1         5.4           14.1           15.5           12.8           15.9            $2.7           67.5
Total                            $5.0        $10.8         $17.7           $17.2          $14.0          $16.1            $2.7         $83.5

                                         Kennedy has not projected remediation costs beyond 2002, although the
                                         cleanup is not expected to be completed until 2015. Kennedy officials said
                                         they will not have complete and accurate cost estimates until 1999. To do
                                         this, they will have to obtain data on the amount and type of
                                         contamination at each site and determine the risks associated with the
                                         location, amount, and contaminant types.


                                         Neither NASA headquarters nor Kennedy has developed any definitive
Cost Sharing Efforts                     guidance in terms of pursuing potentially responsible parties to share
                                         cleanup costs. To date, Kennedy has not pursued any potentially
                                         responsible parties.


Cost Sharing Policy                      CERCLA allows a party conducting a cleanup to recover cost from
                                         potentially responsible parties. These parties may include present and past
                                         owners, operators, and contractors, among others.1 NASA headquarters,
                                         however, has not yet provided any written guidance to Kennedy on sharing
                                         remediation costs. Accordingly, Kennedy has not issued a written policy
                                         on recovering of remediation costs from potentially responsible parties.

                                         Kennedy’s Chief of the Environmental Management Office said that
                                         potentially responsible parties should be pursued in appropriate cases and
                                         believes that the potentially responsible party issue needs to be resolved at
                                         the NASA headquarters level. When a potentially responsible party can be
                                         found, Kennedy’s stated policy is to conduct the cleanup and then decide
                                         whether to seek reimbursement.

                                         1
                                          A federal agency conducting a RCRA corrective action can qualify for CERCLA cost recovery if its
                                         cleanup actions are “not inconsistent with the National Contingency Plan.”



                                         Page 28                                                   GAO/NSIAD-97-98 NASA’s Cleanup Costs
                         Appendix I
                         John F. Kennedy Space Center




Cost Sharing Practices   NASA has always considered environmental contamination on Kennedy’s
                         property to be the result of its activities because NASA operates its facility
                         and oversees its contractors. According to Kennedy officials, however,
                         contractors should assume some responsibility for their actions and
                         should participate in cost sharing agreements for remediation because
                         contractors perform the vast majority of industrial operations at Kennedy.

                         We discussed cases in which Kennedy will pay cleanup costs, and
                         Kennedy officials said that they may pursue cost sharing in two. These
                         cases involved a former landowner and a former lessee. In regard to the
                         former landowner, Kennedy officials said that they will consider action
                         against the former landowner of the Wilson Corners site, which involves
                         groundwater contamination. To date, Kennedy has spent $1.1 million
                         remediating this site and will spend $168,000 per year to pump and treat
                         for the foreseeable future. In the case involving the former lessee,
                         Kennedy plans to spend about $3.5 million to clean up fuel oil
                         contamination at its visitor’s center (Spaceport USA). Cleanup involves
                         removing and aerating soil at the site. At the time of the contamination, the
                         visitor’s center was operated by a lessee. A storage tank leaked gas or
                         diesel fuel and contaminated the soil. Kennedy officials believe that the
                         lessee had control of the situation and should be held responsible.
                         However, there is currently no cost sharing agreement in place. According
                         to Kennedy officials, the former lessee paid for the remedial investigation
                         at the site before Kennedy assumed control of the cleanup. Kennedy
                         officials said that they took over the cleanup of the site because the lessee,
                         which had operated the visitor’s center, lost the lease to another company
                         now operating the center. After the cleanup is completed, Kennedy will
                         decide whether the former lessee will be asked to reimburse the
                         government.




                         Page 29                                    GAO/NSIAD-97-98 NASA’s Cleanup Costs
Appendix II

Michoud Assembly Facility



Background

Site Description and                   The Michoud Assembly Facility is a government-owned,
Mission                                contractor-operated component of the George C. Marshall Space Flight
                                       Center. The facility has been owned by NASA and operated by a contractor
                                       since its acquisition by NASA in 1961. Michoud is located in New Orleans,
                                       Louisiana, on about 830 acres of government-owned land (see fig. II.1).


Figure II.1: Location of the Michoud
Assembly Facility




                                                  Shreveport




                                                                                              Baton Rouge



                                                                                               New Orleans
                                                                                                        Michoud




                                       Source: NASA Real Property Locations by Accountable Reporting Installations.




                                       Page 30                                               GAO/NSIAD-97-98 NASA’s Cleanup Costs
                     Appendix II
                     Michoud Assembly Facility




                     Michoud’s mission is to support the continuing development and
                     operations of the NASA space shuttle program. Specifically, Michoud
                     provides the design and assembly of the external tank for the space
                     shuttle.


Regulatory Process   Contaminated sites at Michoud are being addressed under the RCRA
                     corrective action process. On January 23, 1995, the remediation program,
                     including all decision-making authority, was transferred to the state of
                     Louisiana because the state received authorization from EPA to implement
                     the RCRA program. EPA’s current responsibility is to provide oversight to the
                     state and to monitor the groundwater program.



Extent of
Contamination

Contaminated Sites   As a manufacturing facility, past waste management disposal practices and
                     accidents have contaminated Michoud’s soil, surface water, and
                     groundwater with trichloroethylene, volatile organic compounds, metals,
                     diesel fuel, and other contaminants. According to Michoud officials and
                     the operating contractor, it appears the vast majority of contamination
                     resulted from NASA’s Apollo program after the site was transferred to NASA
                     in 1961. According to Michoud and the operating contractor,
                     trichloroethylene in the groundwater presents the greatest risk, and the
                     likely major cause of the groundwater contamination was a 16,000-gallon
                     trichloroethylene spill that occurred in 1966. The contamination appears
                     to be limited to the upper 45 feet of groundwater and soil in only a few
                     areas.

                     The operating contractor first discovered environmental contamination at
                     Michoud in November 1982. The RCRA facility assessment in August 1986
                     identified 57 potentially contaminated sites. According to the operating
                     contractor, more detailed evaluations by the state and EPA determined 46
                     of these sites required no further action. The remaining 11 sites, plus two
                     additional ones identified and 10 petroleum-related sites added by the
                     regulators, comprise the 23 potential sites being investigated. NASA
                     headquarters’ March 1996 inventory of sites lists 33 sites for Michoud.
                     Twenty of these are already closed sites (13); nonleaking, above-ground
                     active petroleum storage tanks (4); or sites recommended for no further



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                     Appendix II
                     Michoud Assembly Facility




                     action (3). The operating contractor was unable to reconcile individual
                     differences between the NASA headquarters’ inventory of sites and the 23
                     sites it is currently investigating.


Cleanup Status and   A phase II RCRA facility investigation report was sent to regulators for
Schedule             review and approval. A phase III and phase IV RCRA facility investigation
                     will finish delineating the extent of contamination at areas not covered by
                     the phase II RCRA. Phases III and IV may extend through 1999 and could
                     include actions that range from implementing corrective measures that
                     result in clean closure to monitoring contaminants to ensure containment
                     within Michoud’s boundaries. A corrective measures study will then be
                     performed to identify cleanup alternatives and could be completed in 2001
                     or 2002. According to Michoud officials, they cannot estimate when
                     remediation will be completed until they have negotiated cleanup
                     standards with the state and EPA.

                     All of the areas suspected of being contaminated have been evaluated;
                     therefore, the inventory for Michoud should be complete. The operating
                     contractor does not currently plan to completely clean up about half of
                     Michoud’s contaminated areas because of the technical and/or economic
                     impracticability of cleaning the contaminated groundwater to pristine
                     condition. This plan is due to Michoud’s dense nonaqueous phase
                     groundwater contamination.1 According to the operating contractor, a
                     significant portion of the released trichloroethylene will remain in the soil
                     at the end of all remediation activities. The operating contractor’s cleanup
                     strategy is subject to state approval.


                     NASA headquarters estimates that it will cost $54 million to clean up
Cost to Clean Up     Michoud’s contaminated sites, not including operations and maintenance.
Contamination        Michoud’s operating contractor estimates it will cost $16.5 million, not
                     including long-term operations and maintenance or costs prior to 1988.
                     Different estimating methodologies were used to develop the estimates. If
                     all Michoud sites were required to be cleaned to the highest standard, the
                     operating contractor noted it could cost over $800 million.


Historical Costs     For fiscal year 1988 through fiscal year 1995, Michoud received
                     $6.5 million in construction of facilities funds for remediation activities, of

                     1
                      According to EPA, dense nonaqueous phase liquids often are difficult to locate and remove from the
                     subsurface. Their ability to sink through the water table and penetrate deeper portions of aquifers is
                     one of the properties that makes them very difficult to remediate.



                     Page 32                                                   GAO/NSIAD-97-98 NASA’s Cleanup Costs
               Appendix II
               Michoud Assembly Facility




               which $1.9 million was used for investigations or studies and $4.6 million
               was used for cleanup activities. All remediation and related projects since
               1988 have been funded out of NASA’s construction of facilities budget and
               have been directly charged to Michoud’s operations contract. According to
               the operating contractor, NASA’s external tank operations budget was used
               to fund all remediation activities from 1982 to 1988 and costs associated
               with these activities cannot be segregated in accounting records.


Future Costs   The operating contractor’s total cost estimate of $16.5 million is about 70
               percent lower than NASA headquarters’ estimate of $54 million. According
               to a Michoud official, NASA headquarters’ estimate could be overstated
               because it was developed using parts of a DOD cost model that treats
               contaminated sites at different locations the same regardless of their size
               or extent of contamination.

               From fiscal year 1996 to fiscal year 2003, the operating contractor
               estimates that remediation activities will cost $10 million, but this amount
               does not include long-term operations and maintenance costs. According
               to the operating contractor, operation and maintenance of all remedial
               systems will continue throughout the external tank program at Michoud
               and costs cannot be accurately estimated. However, the operating
               contractor’s risk-based assumptions used in preparing the estimates were
               all subject to state approval.

               It is unknown whether future funding levels will be a problem, according
               to the operating contractor. Requirements and cleanup standards are
               currently unclear and will likely result in increased funding needs.
               According to a Michoud official, the estimated cost to complete
               remediation will depend heavily on the results of the RCRA facility
               investigation, the corrective measures study, the corrective measures plan,
               and the mandated cleanup standards.

               In addition to remediation costs, Michoud reimburses the state of
               Louisiana for the cost of regulating its hazardous and solid waste, as well
               as its groundwater program. Michoud paid the state $28,500 in 1995 for a
               total of approximately $200,000. EPA is not reimbursed for its work.
               Because off-site contractors have not worked for Michoud, it will not incur
               any additional costs for cleanup at contractor-owned locations.




               Page 33                                   GAO/NSIAD-97-98 NASA’s Cleanup Costs
                       Appendix II
                       Michoud Assembly Facility




                       There are no cost sharing agreements in place for cleanup activities at
Cost Sharing Efforts   Michoud. According to Michoud officials, remediation efforts are primarily
                       addressing contamination from government activities from the early 1960s.
                       To determine the potential of recovering environmental remediation costs
                       (either from contractors or insurance companies), Michoud officials
                       searched for copies of contracts and insurance policies for three
                       contractors that operated at Michoud during the 1960s. At the time the
                       16,000-gallon trichloroethylene spill occurred, Michoud officials said that
                       the Boeing Corporation was the operating contractor. An April 1993
                       memorandum shows that Michoud could not find the contracts or
                       insurance policies. NASA has not conducted similar searches for the current
                       production contractor because the majority of the contamination existed
                       before the contractor came on site.




                       Page 34                                  GAO/NSIAD-97-98 NASA’s Cleanup Costs
Appendix III

Santa Susana Field Laboratory



Background

Site Description and   The Santa Susana Field Laboratory occupies about 2,700 acres in the
Mission                southeast corner of Ventura County, California, about 29 miles northwest
                       of Los Angeles near the crest of the Simi Hills (see fig. III.1).




                       Page 35                                  GAO/NSIAD-97-98 NASA’s Cleanup Costs
                                      Appendix III
                                      Santa Susana Field Laboratory




Figure III.1: Location of the Santa
Susana Field Laboratory




                                                              San Francisco




                                                                             Santa Susana
                                                                              Los Angeles




                                      Source: NASA Real Property Locations by Accountable Reporting Installations.




                                      Page 36                                               GAO/NSIAD-97-98 NASA’s Cleanup Costs
                   Appendix III
                   Santa Susana Field Laboratory




                   Most of the land adjacent to the Santa Susana facility is undeveloped
                   mountainous land. The nearest residential developments are located about
                   a mile from the facility. There are a few acres of avocado orchards and one
                   apiary; both are on private property immediately adjacent to the facility.

                   Since 1947, Santa Susana activities have included research, development,
                   and testing of rocket engines, water jet pumps, lasers, liquid metal heat
                   exchanger components, nuclear energy, fossil fuel projects, and related
                   technologies. The principal activity has been the testing of large rocket
                   engines. Six major liquid rocket engine test areas operated simultaneously
                   in the late 1950s and early 1960s.


Organization       Rockwell International Corporation, Seal Beach, California (formerly
                   North American Aviation), has been the sole-operating contractor at Santa
                   Susana since the facility was established. It currently operates the facility,
                   primarily for NASA.

                   Since 1958, the federal government, first the Air Force and since 1972 NASA,
                   has owned a portion of the facility. NASA’s Marshall Space Flight Center is
                   responsible for overseeing the environmental remediation activities on the
                   NASA-owned property at Santa Susana. Rockwell, as part of its operating
                   contract with NASA, is responsible for

               •   preparing environmental work plans;
               •   negotiating with the California Department of Toxic Substances Control
                   and EPA regulators;
               •   preparing overall status and groundwater monitoring reports;
               •   awarding subcontracts to perform studies and interim corrective
                   measures;
               •   overseeing subcontractor performance; and
               •   maintaining all cleanup-related records, including cost records for the
                   NASA-owned property at Santa Susana.


                   Rockwell subcontracts studies and investigations, interim corrective
                   measures, and water sampling and maintenance of monitoring wells.

                   Rockwell deals with environmental issues related to the property it owns
                   as well. Environmental expenses related to its property are passed to NASA
                   as well as other customers—primarily DOD and the Department of
                   Energy—through overhead charges on contracts it has with them.




                   Page 37                                    GAO/NSIAD-97-98 NASA’s Cleanup Costs
                     Appendix III
                     Santa Susana Field Laboratory




Regulatory Process   Santa Susana is subject to the RCRA corrective action process. Under RCRA,
                     EPA has authorized the California Department of Toxic Substances Control
                     to manage the hazardous waste and corrective action programs in
                     California. Since Santa Susana is an operating site, the Department of
                     Toxic Substances Control has the lead agency role in regulating the site,
                     and it reviews and approves the work plans for the proposed investigation
                     and remediation procedures. The Los Angeles Regional Water Quality
                     Control Board is also involved on an advisory basis.



Extent of
Contamination

Contaminated Sites   Environmental contamination was first identified at the Santa Susana
                     facility when Rockwell found trichloroethylene during an investigation of
                     site water wells in 1984. Rockwell notified the water board about the
                     detected groundwater contamination, and the board requested that
                     Rockwell further investigate the water quality and hydrogeologic
                     conditions at Santa Susana. In response, Rockwell initiated a phased
                     investigation. Based on Rockwell’s preliminary characterization efforts,
                     the board recommended implementing interim remedial measures for the
                     contaminated groundwater.

                     EPA conducted a RCRA facility assessment in 1990 of the entire Santa
                     Susana facility and identified a number of potentially contaminated sites.
                     The Department of Toxic Substances Control issued a stipulated
                     enforcement order to Rockwell on November 12, 1992, requiring that it
                     prepare a draft RCRA facility investigation work plan. Rockwell submitted a
                     work plan to the Department of Toxic Substances Control for its review in
                     March 1995.

                     Santa Susana has a number of specific potentially contaminated sites, but
                     the overriding contamination problem is the trichloroethylene
                     contamination of the groundwater that encompasses a large portion of the
                     facility. The RCRA facility investigation work plan, dated March 1995,
                     identifies 82 potentially contaminated sites and areas of concern for all
                     areas of Santa Susana. NASA headquarters’ March 1996 inventory for the
                     NASA-owned property lists 2 petroleum sites and 33 contaminated sites.
                     The remaining sites (47) are on Rockwell-owned property.




                     Page 38                                   GAO/NSIAD-97-98 NASA’s Cleanup Costs
                                     Appendix III
                                     Santa Susana Field Laboratory




                                     Historically, the principal use of trichloroethylene was to decontaminate
                                     the large engines to prevent the risk of explosion during testing. About
                                     97 percent of the trichloroethylene was released from 1954 through 1961.
                                     In 1961, Rockwell began reclaiming trichloroethylene. Most
                                     trichloroethylene has been reclaimed at all large test areas. Except for one
                                     test area, the use of trichloroethylene at the site was discontinued in 1977.
                                     A reclamation system for used trichloroethylene is currently maintained at
                                     this test area. DOD was Rockwell’s principal customer prior to 1961 with
                                     such programs as the Navaho, Atlas, Jupiter, and Thor rocket engines. A
                                     1993 records search and trichloroethylene release assessment report
                                     prepared by a contractor for NASA stated that 530,358 gallons of
                                     trichloroethylene were released to the ground at Santa Susana.


Cleanup Status and                   The current remediation status of the 35 NASA-owned sites at Santa Susana
Schedule                             is shown in table III.1.

Table III.1: Remediation Status of
NASA-owned Sites                     Status                                                                 Number
                                     Investigating                                                               14
                                     No further action                                                           11
                                     Monitoring                                                                   5
                                     Closed                                                                       2
                                     Other                                                                        3
                                     Total                                                                       35

                                     The Department of Toxic Substances Control has not yet agreed to the no
                                     further action decision for the 11 sites. Rockwell officials were not sure
                                     whether additional sites will be identified. Some of the groundwater
                                     contamination migrated off site to the north and northeast, and Rockwell
                                     is monitoring and will decide what actions are required.

                                     While Santa Susana has soil and surface water contamination, the
                                     groundwater contamination is the major concern and, accordingly, is the
                                     focus of Rockwell’s efforts. After detecting trichloroethylene in water
                                     samples from water supply wells in 1984, a phase I investigation was
                                     conducted to develop a plan for field investigations. Field investigations,
                                     including well construction, water sampling, photogeologic assessment,
                                     and well testing, were conducted in the phase II groundwater
                                     investigation. Groundwater conditions at the facility were evaluated based
                                     on data compiled from 231 wells that included 202 monitoring wells




                                     Page 39                                    GAO/NSIAD-97-98 NASA’s Cleanup Costs
                   Appendix III
                   Santa Susana Field Laboratory




                   constructed at or adjacent to the facility, 13 facility water supply wells,
                   and 16 private off-site wells and springs.

                   A groundwater reclamation system began operating at the facility in 1987
                   to extract degraded groundwater and to minimize the off-site movement of
                   degraded water by modifying and controlling groundwater gradients. A
                   contractor report stated that about 138 gallons of volatile organic
                   compounds (mostly trichloroethylene) were removed through
                   groundwater treatment operations for fiscal year 1988 through the first
                   quarter of 1996.

                   After Rockwell completes the RCRA facility investigation, it plans to
                   perform a corrective measures study to recommend the final corrective
                   action(s). A Rockwell official estimates that the corrective measures study
                   will begin in late 1997 to early 1998.



Cost to Clean Up
Contamination

Historical Costs   Through fiscal year 1995, a total of $21.1 million—$15.6 million by NASA
                   and $5.5 million by others, including DOD—had been spent or authorized to
                   clean up Santa Susana through direct and indirect overhead charges. NASA
                   pays either directly for cleanup costs on the property it owns or through
                   overhead charges for the property owned by Rockwell.

                   For direct charges, NASA headquarters authorized $6.2 million in
                   construction of facilities funds for remediating groundwater in the
                   NASA-owned portion for fiscal years 1990 through 1995. In addition, it
                   authorized $1.5 million of construction of facilities funds that were
                   designated as RCRA corrective action for (1) soil cleanup and closure and
                   (2) decontamination of surface impoundments in area II and the
                   NASA-owned portion of area I.


                   For fiscal years 1983 through 1995, Rockwell included $13.4 million in
                   overhead charges for study and remediation costs primarily for
                   groundwater in areas I and III. NASA paid $7.9 million of this total, DOD paid
                   $1.7 million, and others, including the Department of Energy, paid the
                   remainder.




                   Page 40                                     GAO/NSIAD-97-98 NASA’s Cleanup Costs
                       Appendix III
                       Santa Susana Field Laboratory




                       For fiscal year 1996, NASA authorized $1 million in construction of facilities
                       funds for groundwater remediation and $900,000 for RCRA corrective action
                       of soil and surface impoundments.


Future Costs           Based on the portions of the DOD cost model that NASA used to project
                       cleanup costs, NASA headquarters estimates that it will cost $93 million to
                       clean up the contaminated sites on the NASA-owned property at Santa
                       Susana, exclusive of the operations and maintenance cost to run the pump
                       and treat system for groundwater remediation. In contrast, Rockwell
                       estimates cleanup costs at $11.1 million, of which $9.6 million has already
                       been obligated or spent. Neither estimate includes the operation and
                       maintenance costs of the groundwater reclamation system for fiscal years
                       1997 through 2037, which NASA estimates at $58.5 million.

                       Rockwell estimates it will pass on $7.2 million through overhead charges
                       for the portion of Santa Susana that it owns. Based on current contracts,
                       NASA expects to pay $4.4 million, or about 60 percent, of this total.
                       However, Rockwell will not estimate costs beyond the year 2000,
                       significantly understating the amount NASA will have to pay through
                       overhead charges.


                       At this time, no final arrangements have been made for the current and
Cost Sharing Efforts   past owners or operators of Santa Susana to share costs. The portion of
                       Santa Susana that NASA currently owns is considered a “formerly used
                       defense” site. Therefore, the Corps of Engineers, Omaha District, tried to
                       determine how the liability for environmental cleanup should be divided
                       among NASA, Rockwell, and DOD.

                       In April 1989, Rockwell requested authorization for a defense
                       environmental restoration project that would be funded through the DOD
                       defense environmental restoration program. The Corps of Engineers is
                       representing DOD in evaluating Rockwell’s request, and it used a contractor
                       to investigate the environmental contamination at the facility. The study
                       concluded that Rockwell was responsible for 92 percent of the
                       groundwater contamination, while the Air Force and NASA were each
                       responsible for 4 percent. In a January 7, 1990, memorandum to Rockwell,
                       the Corps concluded that Rockwell activities at the site failed to comply
                       with the applicable requirements of the national oil and hazardous
                       substances pollution contingency plan. Therefore, the Corps decided any




                       Page 41                                    GAO/NSIAD-97-98 NASA’s Cleanup Costs
Appendix III
Santa Susana Field Laboratory




past or future costs incurred by Rockwell cannot be reimbursed from
DOD’s defense environmental restoration program.


Since the Corps of Engineers’ decision, Rockwell, NASA, and the Corps
have been discussing the cleanup situation and potential liability, and NASA
has been paying the cleanup costs on the NASA-owned property. A
NASA-funded study concluded that most of the groundwater contamination
could be attributed to DOD. The NASA study showed that 88 percent related
to DOD and 12 percent related to NASA. In a November 9, 1994, letter, NASA’s
counsel said that NASA disagreed with the Corps. NASA believes it has been
paying a much larger portion than is fair and equitable. Also, NASA believes
DOD should have a larger share of the liability.


In a March 3, 1995, memorandum to NASA, the Corps stated that although
NASA and DOD support a three-party agreement, it is not confident that
Rockwell is willing to participate in an agreement. Further, the Corps
stated that if Rockwell is unwilling to either enter into such an agreement
or provide adequate assurances that it will not seek cost sharing later, it is
appropriate for NASA as a current landowner to take the legal action to
involve Rockwell in the agreement.

Corps officials said that they have not recently discussed the cost sharing
issue with NASA. Marshall Space Flight Center officials, who are
responsible for managing the NASA parcels of the Santa Susana facility, said
that they elevated further negotiations to NASA headquarters in a March 21,
1995, letter. NASA headquarters has reviewed the case and given some input
to Marshall relative to the case. Marshall requested NASA’s Inspector
General to review the case, and the Inspector General is in the process of
conducting a review.




Page 42                                    GAO/NSIAD-97-98 NASA’s Cleanup Costs
Appendix IV

Scope and Methodology


                  We reviewed applicable laws and regulations, but we did not
                  independently determine compliance with laws or the merits of cost
                  sharing at individual facilities. We also reviewed policies, procedures, and
                  documents, including NASA databases on potentially contaminated sites.
                  We used NASA’s March 1996 inventory to determine the extent of
                  contamination and the status of cleanup. While there was an update during
                  our field work, we did not believe the update significantly changed the
                  March 1996 data.

                  We also interviewed officials and reviewed supporting documentation at
                  NASA and EPA headquarters in Washington, D.C., and at selected NASA field
                  facilities throughout the country to obtain data on cleanup costs. The field
                  facilities visited were

              •   Ames Research Center, Moffett Field, California;
              •   George C. Marshall Space Flight Center, Huntsville, Alabama;
              •   Jet Propulsion Laboratory, Pasadena, California;
              •   John C. Stennis Space Center, Mississippi;
              •   John F. Kennedy Space Center, Florida;
              •   Langley Research Center, Hampton, Virginia;
              •   Michoud Assembly Facility, New Orleans, Louisiana;
              •   NASA Industrial Plant, Downey, California; and
              •   Santa Susana Field Laboratory, Ventura County, California.

                  To obtain supplemental information, we sent data collection instruments
                  to the other NASA field facilities and 20 of NASA’s largest contractors. Table
                  IV.1 lists the NASA facilities and the 16 contractors that responded to our
                  request.




                  Page 43                                     GAO/NSIAD-97-98 NASA’s Cleanup Costs
                                       Appendix IV
                                       Scope and Methodology




Table IV.1: Locations and
Organizations Responding to Our Data   Location                 Organization
Request                                NASA                     Dryden Flight Research Center, Edwards, California
                                                                Goddard Space Flight Center, Greenbelt, Maryland
                                                                Lewis Research Center, Cleveland, Ohio
                                                                Lyndon B. Johnson Space Center, Houston, Texas
                                                                Wallops Flight Facility, Wallops Island, Virginia
                                                                White Sands Test Facility, Las Cruces, New Mexico
                                       Private contractor       Allied Signal, Inc., Morriston, New Jersey
                                                                BAMSI, Inc., Titusville, Florida
                                                                Boeing Company, Seattle, Washington
                                                                CAE Link Corporation, Binghamton, New York
                                                                Computer Sciences Corporation, El Segundo, California
                                                                EG&G Florida, Inc., Florida
                                                                General Electric Company, Inc., Fairfield, Connecticut
                                                                GM Hughes Electronics Company, Los Angeles, California
                                                                Lockheed Martin Corporation, Bethesda, Maryland
                                                                Loral Corporation, New York, New York
                                                                McDonnell Douglas Corporation, Saint Louis, Missouri
                                                                Northrop Grumman Corporation, Los Angeles, California
                                                                Rockwell International Corporation, Seal Beach, California
                                                                Thiokol Corporation, Odgen, Utah
                                                                TRW, Inc., Cleveland, Ohio
                                                                United Technologies Corporation, Hartford, Connecticut

                                       Starting in fiscal year 1998, federal accounting standards will require
                                       liability estimates for hazardous materials such as mission equipment
                                       rockets, launchers, and space exploration equipment. We did not examine
                                       NASA’s potential liabilities for such mission equipment in this review.




                                       Page 44                                     GAO/NSIAD-97-98 NASA’s Cleanup Costs
Appendix V

Comments From the National Aeronautics
and Space Administration

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




See pp. 18-19.



See pp. 18-19.




                             Page 45   GAO/NSIAD-97-98 NASA’s Cleanup Costs
                      Appendix V
                      Comments From the National Aeronautics
                      and Space Administration




Now on pp. 10-12.
See comment 1.


Now on pp. 4 and 6.
See comment 2.




Now on p. 8.
See comment 2.



Now on p. 11.
See comment 1.



Now on p. 11.
See comment 3.

Now on p. 42.
See comment 4.




                      Page 46                                  GAO/NSIAD-97-98 NASA’s Cleanup Costs
                 Appendix V
                 Comments From the National Aeronautics
                 and Space Administration




See pp. 18-19.




See pp. 18-19.



See pp. 18-19.
See comment 5.




                 Page 47                                  GAO/NSIAD-97-98 NASA’s Cleanup Costs
                 Appendix V
                 Comments From the National Aeronautics
                 and Space Administration




See pp. 18-19.




See comment 6.




                 Page 48                                  GAO/NSIAD-97-98 NASA’s Cleanup Costs
                 Appendix V
                 Comments From the National Aeronautics
                 and Space Administration




See pp. 18-19.




See pp. 18-19.




                 Page 49                                  GAO/NSIAD-97-98 NASA’s Cleanup Costs
               Appendix V
               Comments From the National Aeronautics
               and Space Administration




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


               1. Our report recognizes that NASA has updated the information on cleanup
GAO Comments   costs by using a new cost model that includes a cost for each site believed
               to require cleaning up. The cost information developed using the new
               model, however, is not complete because 90 additional sites are to be
               added. Also, most sites are still being investigated by the NASA field
               facilities. Because the new model’s interim cost data total only about
               10 percent less than the prior cost data and additional sites will be added,
               we did not change the cost information in the report. Cost information
               shown in our appendixes was gathered directly from NASA’s field facilities
               and was not related to either the new or old model.

               2. We revised our report to more clearly identify NASA’s actions and status.

               3. We included footnote 10 in the report text to recognize that the new cost
               model will include at least 5 years of long-term operation and maintenance
               costs for applicable sites.

               4. We updated the information in appendix III to reflect the most current
               status of the Santa Susana case.

               5. We modified the recommendation to state that NASA should obtain the
               necessary information.

               6. NASA’s stated position is consistent with the intent of our
               recommendation. We do not go beyond the requirement stated by NASA to
               identify remediation cleanup liabilities for reporting. We recommended
               identifying infrastructure changes and associated cost impact, such as for
               changes planned at the Downey facility. We did not intend to recommend
               identifying changes that are not planned, so we modified our
               recommendation to make this distinction clear.




               Page 50                                   GAO/NSIAD-97-98 NASA’s Cleanup Costs
Appendix VI

Major Contributors to This Report


                        Brad Hathaway
National Security and   Charles I. Patton, Jr.
International Affairs   Uldis Adamsons
Division, Washington,
D.C.
                        Patricia Foley Hinnen
Denver Field Office
                        Edwin J. Soniat
Norfolk Field Office    Johnnie Phillips
                        Raul S. Cajulis


                        David P. Marks
Dallas Field Office     R.E. Erdman


                        Gary W. Kunkle
Los Angeles Field
Office




(709215)                Page 51                  GAO/NSIAD-97-98 NASA’s Cleanup Costs
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