oversight

Department of Defense Management of Hazardous Materials

Published by the Government Accountability Office on 1990-06-28.

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

                    United   States General Accounting    OfKce

          I         Testimony




For Release          Department      of Defense     Management       of
on Delivery          Hazardous      Materials
Expected    at
9:30 a.m. EDST
Thursday
June 28, 1990




                      Statement   of
                      Norman J. Rabkin
                      Associate   Director,       Air Force      Issues
                      National   Security      and International
                         Affairs  Division

                      Before    the
                      Subcommittee     on Environment,      Energy
                         and Natural    Resources
                      Committee     on Government    Operations
                      House of Representatives




GAO/T-NSIAD-90-51
                        otaess/f+
                              1LQ’Li
Mr.      Chairman                 and         Members             of     the         Subcommittee:



I     am pleased                  to      be here               today          to     testify            on      our         work             on

Decontamination                           Solution                2,     commonly               referred               to         as     DS2.           The

Department                   of     Defense                (DOD)         purchases                 DS2 for             decontaminating

equipment                in        the         event        of     chemical                 warfare,                 This          is         the      only

stated         use           of     DS2.             In     conjunction                     with       our       testimony,                         we are

releasing                a report                   on DS21             today.              The     Army         is         the         principal              user

of     DS2.             Our        testimony                discusses                 the       major         issues               in         our      DS2 report

in     the         context               of        DOD’s        hazardous               waste          programs                   and         our      other

reports2                on        DOD’s            hazardous             materials                 and       hazardous                   waste           programs.



RESULTS             IN        BRIEF



Over         the        past           17 months                 we have             reported            on      DOD’s             hazardous

materials                and           hazardous                 waste         programs             and         made         recommendations                              to

improve             DOD’s              efforts             to     reduce             the      amount            of      hazardous                     waste         it

generates                and           disposes             of.          We recommended                         that         DOD minimize                       the

amount             of    hazardous                   materials                  it     purchases;                manage                 its         inventories

of     hazardous                   materials                properly;                  reuse,          recycle,                   and         treat

hazardous                waste                to    minimize              the        amount         of       waste            that            has      to      be




IHazardous    Materials:       DOD Should                                                  Eliminate             DS2 From                     Its      Inventory
of Decontaminants        (CAO/NSIAD-90-10,                                                     Apr.       25,          1990).

2Hazardous     Waste:        DOD Efforts      to Reduce      Waste (CAO/NSIAD-89-35,
Feb.    7, 1989).       Hazardous     Waste:      Attention      to DOD Inventories                                                                                      of
Hazardous     Materials       Needed     (CAO/NSIAD-90-1       1, Nov.  6, 1989).
Hazardous     Waste:       Inadequate      Safeguards       Over Sales    Pose Health                                                                                    and
Environmental        Dangers     (CAO/NSIAD-90-70,          Feb.   12, 1990).
disposed                  of;        and      dispose            of      excess           hazardous                  materials                and

hazardous                  wastes             properly.



Our      report                 on     DS2 provides                    a case           study          of     most           of      these          concerns,

Effective,                      less         toxic        substitutes                   for        DS2 are             available                  and       are

being              used         by     the      Air       Force          and      the         Navy      but          not      the         Army        or     the

Marine              Corps.              The          Army’s          storage            facilities                   for      DS2 did               not      comply

with          regulations,                      and       the        Defense            Logistics               Agency               was      selling

excess              DS2 to             the      public           without              providing                information                    on      its

potential                   danger             and      the      safety           precautions                       that      need         to       be taken

when        using               DS2.           We recommended                     that         the      Army           and         the     Marine            Corps

use      a substitute                          for      DS2 and           that          the        Defense             Logistics                  Agency           not

sell          DS2 to             the         general            public          and       restrict                  sales          to     recyclers.



BACKGROUND



DOD purchases                          and       uses         a large           quantity               of      hazardous                  materials                in

its      industrial                     and          maintenance                operations.                         A sigrtficant                     percent

of      the         hazardous                  materials               become           hazardous                   waste.               DOD reported

that          it     generates                   over         400,000           tons          of      hazardous                   waste       each          year

from          its         industrial                  processes                used       primarily                   to     repair           and          maintain

weapon              systems.



The      military                    services              estimate             that          they          have       procured               a total              of

about              5 million                 gallons            of     DS2 since                the         early           1960s.              The        Army

has      purchased                     the       largest              amount.             From         November                   1986       to     November


                                                                                  2
1988,          the       services               requisitioned                     a total                  of         772,000              gallons             of      DS2.

(DS2       procurement                    records               earlier           than         November                      1986          were         not

required               to      be retained.)                       Of     this         amount,                   the         Army          requisitioned

about          666,000             gallons,               or     86 percent;                   the          Marine                 Corps

requisitioned                      about           104,000             gallons,              or         about               13     percent;              and         the

Air      Force           and       the         Navy       requisitioned                      about               2,000             gallons,              or         less

than          l/2      of      1 percent.                    The       cost       of       DS2 varies                            from      about         $14         to

$28      per         gallon.



National               concern            about           the       threat            of     environmental                               damage          posed             by

the      disposal                 of     hazardous                waste         has        resulted                    in         the      enactment                 of

various              environmental                      laws,          including                  the           Resource                 Conservation                      and

Recovery               Act        of     1976,          as      amended,              and         the           Hazardous                  and       Solid

Waste          Amendments                  of      1984.            The       1984         law          requires                    that       organizations

that       generate                hazardous                   waste      have          programs                      in         place       that        minimize,

to      the         extent         practicable,                     the       generation                        of     hazardous                  waste.               In

response               to      this        requirement,                   DOD delegated                               responsibility                          for

developing                   and        implementing                   such          programs                   to         the      Army,         the         Navy,

and      the--         i;-     Force.



Large           quantities                 of      hazardous              materials                     and           hazardous                waste            must         be

disposed               of      each        year.               Disposal              can     be costly                           because          of

procedures                   required              to     minimize               the        risk           to         humans             and       the

environment.                           To avoid           disposal               costs,             DOD has                      adopted          programs                  to

reduce              hazardous              waste          generation                   and         limit              the         amount           of     hazardous

materials                   and        waste       that         must       be        disposed                   of.              These       include


                                                                                 3
minimizing                  the         use      of       hazardous                 materials;                    managing                its         hazardous

material            inventory                       better;           reusing,                   recycling,                  and         treating

hazardous             materials                      and        waste;            and        disposing                  of     excess             hazardous

materials             properly.



In      our    report              on DS2 we                    noted            that,           depending               on        its         use,         DS2 can

be hazardous                      to        humans             and    the         environment.                          DS2 has                many         adverse

effects:               it         is        toxic          and       highly              corrosive                and        can         cause          severe

chemical             burns;                 stricture                of     the          esophagus;                 damage               to      the        liver,

cornea         of      the             eye,         and        central             nervous             system,               and         may cause

adverse         reproductive                            effects             and          birth         defects.                    Protective

clothing             must              be worn             when          handling                DS2 to           prevent                contact                 with    the

skin.          DS2          is         so     corrosive,                  storage                containers                   may leak                 after

slight         damage                  or     during             extended                storage            periods.



We also          noted                 that         DS2 is           incompatible                      with         most           metals.                  It

corrodes             aluminum,                      cadmium,              tin,           and       zinc.            It        can        also          damage

electronics,                      rubber              sealants,                  fabrics,              and        plastics,                     which            can

affect         the          readi.              ss        of     military                 equipment,                such           as         tanks,             and    is

difficult               to        store.



HAZARDOUS               WASTE REDUCTION



 DOD has            initiated                   some           efforts             since            the       mid-19809                   to     minimize               the

 amount        of       hazardous                      materials                 that          have        to      be        disposed                 of,        such        as

 source        reduction                       techniques                   and          improved               inventory                 management.                        The


                                                                                         4
services          set       a goal             of     reducing                 hazardous                 waste               generation                   by      50

percent         by       1992.           Despite                these         efforts,                  hazardous                  materials                    still

have       to   be       disposed              of     unnecessarily.



Minimizing      Hazardous                       Materials   During
the Acquisition        of                     Weapon Systems



Although          the       services                 could         consider                  minimizing                      the     use        Of

hazardous            materials                 in      the       acquisition                      of        weapon             systems,               we

reported           in      February                 1989        that      they            had         not        yet         integrated                   such

considerations                    but         had      taken            some          initial               steps.                 For     example,                     the

Air    Force            Systems           Command               had      outlined                 a plan               to      reduce           the           use        of

hazardous            materials                 during             the         early             stages           of         a weapon            system’s

development.                    In      its         comments             on      that            report,               DOD advised                       us      that

the    Air       Force          has       begun            a strategy                   of       assigning                   personnel                   with

technical               expertise,                  including                 personnel                  with           expertise               in

hazardous               waste        minimization,                       to      each            of      its       weapon                system           program

acquisition                offices.                  A May             1988      Navy            directive                   included                a

requirement                that         the         acquisition                  process                 for          all      weapons               and

support          systems              consider               in’ zardous                waste            minimization.                          The            Army

had       no    formal           procedures,                    but      DOD advised                        us        that         regulations                      will

assign          responsibilities                           to     investigate                         opportunities                       for
 minimization.
Source        Reduction                     Techniques



In    the     mid-1980s,                      the        services                 began         programs              to      minimize                 the

amount        of          hazardous                 waste            they      generate                through              optimum           use            Of

hazardous                 materials.                     At      the        19 installations                          we      visited,                 officials

made        some          changes             to        production,                    maintenance,                   and        repair            processes

to    minimize               the        amount             of        hazardous                 waste        they        produced.                      For

example,             one        installation                         had      installed                an    on-line               recovery

process             for      solvents                   used         during            production.                    Other         installations

had    also          substituted                        hazardous                 materials               with         less        hazardous                  ones;

for       example,              water-based                       paint           primers            were        used         rather              than        toxic

primers.



The       services              will          have            difficulty                 monitoring                their           progress                  in

meeting             their          goal            to     reduce             hazardous               waste         generation                     by     50

percent             because             their             data         are        unreliable.                    In        our     February                  1989

report,             we recommended                            that         DOD establish                    a standard                   methodology

for       collecting                   and         reporting                 hazardous               waste         generation                     data            so   the

services              would            have         more          accurate,                    3nsistent,                  and     comparable                      data

to    monitor               how        successfully                        they        meet       their          minimization                      goals.

In    response                to       our         recommendation,                         DOD initiated                         a study           to

determine                 how      to        better             report            on     its      hazardous                 waste          minimization

programs              and       how          well         the        services              are       accomplishing                        their          goals.



Army        units           throughout                    the        continental                  United              States         and          overseas

are       continuing                   to     purchase                 large            quantities               of        DS2,      even          though


                                                                                    6
Army      tests             have        shown           that          DS2 can                  damage             current              weapon               systems,

making        them            inoperable.                      The          Army’s               DS2 storage                      facilities                   did         not

conform           to        DOD regulations,                            resulting                      in        potential                 danger             to

humans        and           the       environment.



The      Training                 and        Doctrine              Command                   has        recommended                    that           the       Army

replace           DS2 with                   a less          damaging                    decontaminant.                               The        Army’s             tests

have       indicated                   that       household                      bleaches                   were          just        as     effective                    as

DS2.        Nevertheless,                         the        Army            continues                      to      buy      DS2,          and        its

technical               manual               continues                 to        instruct                   personnel                 to     use        it.

Because           of         the       many       problems                   associated                      with           DS2,       the        Air         Force             and

the      Navy          are         using        effective,                       less           toxic            alternatives.                          The         Air

Force       uses             hot,        soapy          water           as         its         overall               decontaminant,                           and         the

Navy       uses         a hypochlorite                          (a          bleaching                   agent)              to     decontaminate                          its

ships.



Inventory               Management                    Techniques



During          fiscal               years           1986        through                     1988,          DOD purchased                        an      average                 of

about        $250            million            per         year            of     hazardous                     mat         l ials         in     the         13        stock

classes           we reviewed,                         which           include                  paints,                  adhesives,

preservatives,                          batteries,                    and         chemicals.                        If      these           materials                    are

not       properly                  stored           and       managed                 while            in        the       inventory,                   they            may

become          surplus                 to     the      services’                      needs,               their           containers                      may     become

damaged,               or      their           shelf           life              may         expire.                If      the       materials                    are         not




                                                                                         7
used      by another                      government                        agency              or         sold           to         the       public,             they            will

be disposed                      of     as        hazardous                     waste.



At     10 installations                                   we visited,                    we found                       that          40 percent                   of         the

hazardous               materials                         to      be      disposed                    of     were              unused.                 Some hazardous

materials               had            very           short             shelf        lives,                  and          if         they       were         not         used

before          their             useful                  life          expired,                they              would              be     transferred                       to        the

disposal               process                  in        an      unused           condition.                             A number                  of     exceptions

permit          newer                 materials                   in      the      inventory                        to         be      issued             before              some            of

the      older           materials                        whose           useful               life          may expire                        sooner.                  The

condition                of           hazardous                   materials                    was          not         always                evaluated                 during

extended               storage                  or        before            the         materials                       were           transferred                      for

disposal               to        see       if         their              shelf          life               can      be         extended.



In      our      November                    1989              report,            we recommended                                    that       the        Secretary                     of

Defense               issue            instructions                         to      the          services                      to      provide             special

attention                   to        inventory                   management                     procedures                          for       hazardous

materials                that            will             minimize                the          hazardous                       waste           generation                     from

hazardous                material                     inventories.                             DOD has                   advised               us        t’ 1.t it

concurred                with            our          recommendation                             and          that             it      will          publish             a new

shelf          life           policy                 in        July        1990,          which                  will          permit             activities                       to

place          orders                 directly                   with        vendors                  for          items             with         short         shelf               life

for      direct               delivery                     to      the       user.               It         also           stated               that        exceptions                        to

the      first-in                     first-out                   issue           control                   technique                      were          evaluated                  at        a

DOD meeting                       in     March                  1990       and       that              internal                     management                 controls

were          developed                   in         February                1990          to         ensure               that            material             whose               shelf


                                                                                           8
life        can        be extended                      will           be        inspected                 and        tested            in      accordance

with        storage              standards.                         We have                 not         obtained              any       information                    from

DOD on           these           actions,                 because                 you,            Mr.      Chairman,                  have       requested

specific               details               on     these              matters.



All      five          of     the           Army         facilities                     we visited                     in     the       United           States

stored            DS2 improperly.                                The        DS2 was                 stored             in     open-sided                 sheds,

shipping               containers,                       wall          lockers,                   or      buildings                 that        do      not         conform

to     regulations,                         none         of      which            meet            the      DOD’s             requirements                     for

hazardous                material                  storage.                      In      addition,                    we found               deteriorating

and      leaking               cans          at     every              installation                         and        depot           we visited.                     Some

of     our        findings                  are     listed               below.



--     At       Fort         Sill,           Oklahoma,                   four            units            in      one        battalion                 had        leaking

       DS2 cans,                 and         one         unit          had            stored            DS2 with               supertropical

       bleach.                 DS2 can                  ignite              on        contact             with         supertropical                      bleach,

       and        an        explosion                   may result.



 --    At       port         Lewis,               Washington,                         one      battalion                    was       storing           cans           o

       DS2 in               a shed           without                walls,               exposing                    them      to      weather            elements.

       Some of               the        cans            were        wrapped                  in        plastic,              which           caused           moisture

       to       condense                and        could            have              hastened                 the     deterioration                         of     the

       cans.                Some        of        the          other         units             were            also         storing             DS2 in

       buildings                     that         did         not      conform                 to        DOD regulations                         for         storing

       hazardous                     materials.
--     At     Fort             Hood,         Texas,                1,383               l-l/j-quart                     cans       and        57        5-gallon

       cans          of        DS2 were                 found           to        be      leaking.                     The      III        Corps          Chemical

       Officer                 stated,             in         a June              8,          1989,         memorandum                 to     the         Commander

       of     III          Corps,            that             proper              facilities                     for      DS2 storage                     were           not

       available.                        The       officer                 also               stated          that        DS2 storage                     at        Fort

       Hood          during            peacetime                     is       unnecessary.



The       Army            depots            we visited                       in        Europe              stored         DS2 under                    conditions

that         violate               Army           directives                       regarding                  DS2 storage                    in        both         outside

and         indoor             facilities.                         In        Cermersheim,                        West          Germany,                DS2 cans                were

stored              in     a structure                        with           a roof                but      no      walls,            thus         exposing                 the

cans         to      weather                elements,                     such           as        temperature                  changes,                 rain,           and

snow.               This         was        in         violation                   of         a 1978          memorandum                    issued             by     the

21st         Theater               Area           Army          Command,                      which          stated            that         DS2 must                be

stored              in     a manner                    that        prevents                    the         deterioration                     of        cans         from

exposure                  to     weather                 elements.                       It        was       also        in      violation                 of       a 1982

 letter             issued             by        the       Armament,                     Munitions,                    and       Chemical                Command,

which          stated              that           to       prevent                 can          deterioration,                        DS2 should                    not        be

stored              ina damp, humid  environment.                                                            According                to     a March                 1988
                           -/
Army         Materiel     Command report,     most                                                    of     the       corrosion                  to     DS2 cans                 in

 Germersheim                     occurred                  during                 the         summer          when            changes             in     temperature

 caused             the        metal             cans         to        sweat.




                                                                                              10
SALES OF HAZARDOUS
MATERIALS TO THE PUBLIC



Despite              efforts                    to         reduce            the      amount            of       hazardous                 materials

originally                     bought                 and           to     manage         hazardous                  materials                 in     its

inventories                         better,                 DOD transfers                        large           amounts              of     hazardous

materials                     to      the            disposal                process             every           year.           The         disposal                process

for       hazardous                       materials                       includes           reuse            within            the         procuring                agency,

transfer                 to         another                  federal               agency,          or        donation                to     state

governments                         or         other          authorized                   nongovernment                        entities.                    If      no      use

is      found            for             the         materials,                    they      are         considered                   surplus              and       can      be

sold         to         the         public.                    If         the      materials                 are     not        sold          to     the          public,

they         will             have             to      be      transferred                   for         disposal,



During              fiscal                years              1986           through          the         first           half         of      1989,          DOD sold

surplus                 hazardous                         materials                with      an        acquisition                    value          of      over           $104

million                 to         the         public.                    Although           the         net       proceeds                 from       these            sales

were         only             $5         million,                   DOD avoided                  the         expense            of         paying           $170

million                 for         hazardous                       w--te          disposal.                   Also,        DOD officials                           stated

t-hat        by         selling                     the      materials,                   they         prevented                a resource                   from           being

sent         to         disposal.


Lack         of Regulations    and                                        Controls
Over         Sales  of Hazardous                                          Materials



 There            are         virtually                      no          statutory           or        regulatory                    restrictions                     over

 DOD sales                    of         hazardous                       materials,              including                 limits             on who              can       buy

 the      materials.                                We found                instances              in        which         DOD sold                 some

                                                                                           11
hazardous             materials               to      buyers             who        have         improperly                    transported,

handled,            used,          stored,            or     disposed                 of        the      materials.



The     Federal/Property                          and       Administrative                            Services            Act         of     1949,         as

amended,            states           that         surplus            federal               property                 can        be     made

available             to      the        public            through           sales.                   The        hazardous                materials

sold        by     DOD ranged                from        common             paint          and         lubricants,                    similar             to

those        that       can         be bought               in      local           hardware                 stores,            to         DS2.



DOD officials                   told         us     that          they        interpret                  the        act        to     mean         that        they

cannot           restrict            anyone             from        buying             surplus               property,                including

hazardous              materials.                    They         believe              that           any        restrictions                     placed        on

buyers,            except           on      those          that      are         not        responsible                    or        not

responsive3,                  would          be contrary                    to      the         intent             of     the        act.



The        Environmental                    Protection                Agency’s                  environmental                        regulations

restrict             the      sales          of      hazardous                 waste,             but        they         do        not     restrict             the

sales         of     hazardous               materials.                     Department                      of     Transportation

regulations                  require              transporters                   qf        hazardous                 waste           but      not

transporters                  of       hazardous                 materials                 to     obtain             an Environmental

Protection                  Agency          identification                       number.




3Buyers        that     are not responsible                                     buyers       are those        who, for    example,
have     failed       to pay for   previous                                   sales       or have       been convicted       of
criminal         negligence     as a result                                   of their         actions      in a prior      sale.
Buyers       that     are not responsive                                    are those         who submit          bids that    do
not conform           with  the government’s                                      invitation          for   bids.

                                                                              12
Controls            Over the Sales   and
Handling            of Hazardous   Materials



DOD has           some           internal                  controls                over           the        sale          of         hazardous

materials.                    For        hazardous                     materials                    sold        through                    DOD’s            national

sales           program,                contracts                    contain              a clause                  granting,                     as        a condition

of      sale,       the          right          of         government                      surveillance                         over          the           use        and

disposal            of          the       materials.                         DOD also                 requires                  the         contracting

officer            to     survey               potential                     buyers            to       determine                     if      the           buyer          is

responsible                     before          a sale                 is        made.              The       potential                      buyer           must          also

submit           a Statement                        of     Intent,                which             states            what             the        buyer             plans             to

do      with       the          material.                       This         statement                  is      reviewed                     by     DOD,            and,         if

a negative                determination                              is      made,            the       sale          is         to        be rejected.



The       Defense               Reutilization                          and        Marketing                   Offices                  reserve                the       right,

by      a clause                in      the         sales            contract,                   to     inspect                  the         buyer’s

transportation                          equipment                    that         will         be       used          to        remove              the           hazardous

materials                as      well          as         the        treatment,                     storage,                or         disposal

facilities.                          We were              told            that       the         sale         can          be     canceled                    or

terminated                 if         the      inspection                        discloses                   thai          the         buyer            is        not

responsible.



DOD sales                program               officials                     stated              that         their              surveys                of        potential

buyers           consist                largely                 of        no more             than           a desk              review                of     the

Statement                of          Intent              submitted                by       the        highest               bidder                and,            as    we

observed,                are          seldom              documented.                         We noted                that             some            Statements                     of

Intent            submitted                   for         DOD’s             review            contained                    only            the         potential

                                                                                         13
buyer’s             signature                 with           no        other          information                         filled             in,         but          no

action            was         taken         by        the        DOD officials                             to     question                  the        potential

buyers’             responsibility.



Even         though            DOD regulations                               require                 surveys              of        potential                   buyers

and         follow-up                reviews                of     buyers,                 DOD officials                            told          us     that            they

are         not      sure           they      have           a legal                 basis             for         doing            post-award

surveillance.                          They           also         stated                 that         this          may be one                     reason               why

some         of      the        surveillance                        is        not         done.



The         Defense             Logistics                   Agency,                 the         responsible                     agency              within               the

Department                    of      Defense               for          selling                excess             property,                    told       GAO it

believed                it      had        no authority                        to         restrict                 or      limit            private                  entities

or     individuals                     from           buying                 hazardous                 materials                     such         as      DS2.              Once

hazardous                    materials                were          sold,            the             agency          did        not         ensure              that            the

buyers             were            provided             with             information                       on how              to     use          the         materials

properly.                     For      example,                   the         agency                 was        selling              DS2 to              the         general

public             without             providing                       the     Material                    Safety              Data         Sheet              for         DS2,

      ich         identifies                health                and         environmental                          hazards                a      iociated                 with

DS2.              (Data            sheets         are            available                     for      all         hazardous                   government-owned

 material.               >         Consequently,                         buyers             were           not          being             informed              of         the

 potential                   dangers             of     DS2 and                 of        the         safety              precautions                     that             need        to

 be      taken          when          using           DS2,             for      example,                    wearing                 the      protective

 equipment                   specified                 in        the         data          sheets.                  However,                 on        February                  13,

 1990,            the        Commander,                 Defense                 Reutilization                             and        Marketing                   Service,




                                                                                          14               *
testified                before            you          that             future             sales            of     DS2 will                  be        restricted                      to

recyclers.



Initiatives                  to          Improve
Safeguards                 for           Sales



DOD has             implemented                        or      plans            to      implement                   changes                  in     its            hazardous

material                sales            and      handling                     procedures                    to     avoid             similar                 incidents

in     the     future.                    For          example,                 DOD is                no     longer             selling                 hazardous

materials                locally,                 it         is        limiting                its         sales          to      the         national

program             where           it         can      have             improved                assurance                  that             buyers                are         better

informed                about            the      use             of     the       materials.                       Also,              DOD now                permits

buyers             to     screen               their              purchases                 and         take         only         what             they            want             from

any      sales            lot.            This          will             minimize                the         amount             of          hazardous

materials                 the       buyers              may             discard             because                they         have              no use                for         them.



In     our       February                  1990,             report,                 we recommended                            that          DOD,            in

cooperation                      with          the          General               Services                 Administration,                               implement

stronger                    feguards                   to         ensure             that        all         buyers             of          hazardous

materials,                  especially                       buyers               of      extremely                  hazardous                     materials,                        (1)

are      aware            of      the          dangers                  associated                    with         such         materials                         and         the

special             handling                   and          disposal                 requirements                     and             (2)         are        able             to

handle             the      material                   properly                   after              the     sale.               DOD concurred                                with

this         recommendation                            and             has     issued                revised           procedures                         that           were

effective                 March            1,        1990.                These           include                 a requirement                           that            the

descriptions                       of      items             being             sold          include               information                          on        its         known

use,         the         Department                    of         Transportation                           hazardous                   material

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classification,                       and        relevant                storage                  data.              Pre-award                    procedures

were      expanded,               and        reinforced                   and          post-award                         surveillance                      audits

are    conducted.                     In      addition,                  the      Defense                   Reutilization                           and

Marketing            Service                implemented                    various                  reviews                 to       ensure             compliance.



DS2 Sales



Our      report          on       DS2 noted                examples                   of     sales              of        DS2.             These          are      listed

below.



-0
         On August                17,       1988,          43 5-gallon                        cans          of        DS2 were                   sold        by    DOD’s

         surplus            sales           office            at     Mountain                     Home Air                  Force             Base,          Idaho,               to

         an    individual.                       The       chief           of         the         sales              office             did         not      know           the

         buyer’s            intended                use       for         the         DS2,          and          both            the        chief         and         the

         office’s             environmental                         specialist                      said             they            were        unaware              of     the

         hazards            of        DS2 to          humans              or     the          environment.                                 The      buyer         also

         was       not      aware           of       the      hazards.                      According                      to        the      chief,            the

         Material             Safety              Data        Sheet             for         DS2 was                  not         available.



         The       buyer          said         he       believed                he         was       purchasing                        an alkali

         substance                that         could          be         mixed             with           water            and         used         as    a

         degreaser.                     DS2 becomes                      corrosive                   when            it         is     mixed          with        water.

         The        buyer         said         he       was        not         aware          of          the        hazards                of      using         DS2;

         however,                he     had       not       used          any          of     it.               At        his        request,             the         DOD

         sales           office            picked           up      the         DS2 and                   refunded                   his         purchase             price

         of       $30.


                                                                                 16
-0
            On January                      12,         1988,          an      individual                        purchased                    from          the      surplus

           sales           office                 at     DOD’s          Kirtland                      Air        Force            Base,             New Mexico,                      37

            5-gallon             cans              and         274      l-1/3              quart             cans,              or     about               275      gallons,

            of      DS2.          The             buyer          said          that         he         did        not           know         what           he      was       buying

            and      that         the             sales          office              did         not         provide                  him        with         the          Material

            Safety             Data             Sheet           for     DS2.               The          buyer              also        told            us     that          when           he

            went          to    pick              up      the         DS2,          he     believed                   it        might            be dangerous                        and

            did      not        want              to     accept              it.           However,                   contrary                   to        DOD

            regulations,                          the         sales          office              personnel                      told          him          that       if      he        did

            not      take            it,          they          would              remove             his        name           from          the          bidders            list

            and      he would                     be      barred             from          bidding                at         future              auctions.



            According                      to     the         buyer,               two     of         the        DS2 cans                   were           leaking            when

            he      picked                 them         up.           He said              the          cans,              which            were           stored            at      his

            home,          subsequently                           started                fuming,                 so        he        watered               them       down.                He

            later          gave             all         of      the     DS2 to               another                  individual                       who,         according

            to      the        buyer,                  intended              to      use         it         to    kill               weeds.



 RECOMMENDATIONS                                ON DS2



 In        our      report                 we recommended                           that         the         Secretary                      of      Defense                direct

     the    Army          and        the          Marine              Corps           to        use         a substitute                         for         DS2 and              all

     services             to    eliminate                       DS2 from                 their              inventory                   of       decontaminants

 and        direct             the          Director,                  Defense                  Logistics                    Agency,                  to    ensure




                                                                                           17
that      DS2 is                 not        available                      to     the      general                public           and     that          DS2 sales

are      restricted                      to        recyclers.                       DOD,        in         commenting                on    our         February

12,      1990         report,                 confirmed                     what         was         told         to     your       Subcommittee                         on

February              13,             1990,         that            all          sales        of      DS2 are              now restricted                          to

purchasers                      that        will           be       distilling                  the         DS2 into               its     primary

components                      for      commercial                        use.



During          our             review             of      DS2,            we also            noted            that        units          were         receiving

DS2,          even         though             regulations                         stated             that         they         should           not          be

receiving                  it         and     that             purchases                 were          being            made       even         though

serviceable                       DS2 was                being             turned          in        for       disposal.                  We sent                 a letter

to      the     Secretary                     of         the        Army           in    June          1989            pointing           out         these

matters              to         him      and            that        about           $46.4            million              of      DS2 purchases                         were

being          made             or     pending                 at         the      same time                 disposals               were           taking              place.

We have              not          received                 a reply                 to    that          letter.




This          concludes                  my prepared                            statement,                  Mr.        Chairman.                I     will         be

pleased              to         answer             any         questions                 you         mLp       have.




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