TRAINING OPERATIONS: 

FLETC’s Actions To Reduce A 

Reported Material Weakness Associated 

With Operation of Its Outdoor 

Dirt Berm Ranges 

OIG-03-036 December 19, 2002 

Office of Inspector General

******* 

The Department of the Treasury 
Contents 

FLETC’s Actions To Reduce A Reported Material Weakness Associated 

With Operation of Its Outdoor Dirt Berm Ranges OIG-03-036 

Page 1 

 

Audit Report.................................................................................................. 2 

 Results in Brief............................................................................................. 3 

 Background ................................................................................................. 3 

 Finding and Recommendations....................................................................... 5 

FLETC Has Devoted Considerable Efforts to Remediate the Outdoor 

Dirt Berm Firing Ranges Material Weakness .............................................. 5 

 Recommendations.................................................................................. 12 

 Appendices

 Appendix 1: Objectives, Scope and Methodology ....................................... 14 

 Appendix 2: Management Comments........................................................ 15 

 Appendix 3: Major Contributors To This Report .......................................... 16 

 Appendix 4: Report Distribution................................................................ 17 

Abbreviations

 COE Army Corp of Engineers 

 EPA Environmental Protection Agency 

 EPD Environmental Protection Division 

 FLETC Federal Law Enforcement Training Center 

 FMFIA Federal Managers’ Financial Integrity Act 

 FY Fiscal Year 

 OIG Office of Inspector General 

 OMB Office of Management and Budget 

 Treasury Department of the Treasury 

 U. S. United States 

 
OIG Audit 

Report

The Department of the Treasury 

Office of Inspector General 

FLETC’s Actions To Reduce A Reported Material Weakness Associated 

With Operation of Its Outdoor Dirt Berm Firing Ranges OIG-03-036 

Page 2 

 

 December 19, 2002 

 Connie L. Patrick 

 Director 

 Federal Law Enforcement Training Center 

 

 This report presents the results of the Office of Inspector General’s 

 (OIG) review to determine whether the Federal Law Enforcement 

Training Center’s (FLETC) actions taken, since it reported a material 

weakness associated with its four outdoor dirt berm firing ranges, 

were sufficient to reduce it from a material weakness to a “second 

tier” reportable condition. 

Specifically, our review covered when and how actions were taken 

by FLETC from 1991 to the present. We conducted and 

documented physical observations and examinations at the 

FLETC’s Glynco, Georgia site in August 2002. We evaluated the 

environmental risks tests and safety reports results. These results 

were compiled at the request of FLETC by the United States (U.S.) 

Army Corp of Engineers (COE), by the Environmental Protection 

Agency (EPA), Georgia Environmental Protection Division (EPD), 

and by the University of Georgia’s College of Veterinary Medicine 

from 1992 to the present. As part of the evaluation process, we 

reviewed several internal reports generated by the FLETC. In 

addition, we assessed information obtained during the entrance 

conference, in our on-site interviews and from the discussions with 

FLETC officials and responsible personnel. 

FLETC serves as the Federal government’s leader for and provider 

of world-class law enforcement training. Through a series of 

carefully planned and coordinated activities, FLETC has continued 

efforts to monitor and manage potential safety and environmental 

hazards at its outdoor dirt berm firearms ranges, even as it has 

prepared for the ultimate resolution through deactivation and 

remediation of these ranges. We also believe that it is increasingly 
FLETC’s Actions To Reduce A Reported Material Weakness Associated 

With Operation of Its Outdoor Dirt Berm Ranges OIG-03-036 

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crucial that FLETC continues to demonstrate its concern and 

commitment to mitigating the risks inherent in operating these 

ranges until eventual closure in April 2005. 

Results in Brief 

FLETC has devoted considerable efforts and conducted significant 

actions since 1991 to rectify the material weakness associated 

with its outdoor dirt berm firing ranges. These efforts and actions 

have demonstrated a concern and a commitment to mitigating the 

inherent risks in the continued operation of the ranges. As a result 

of these measures, we believe, that FLETC has clearly 

demonstrated that the deficiency no longer rises to the level of a 

material weakness. Therefore, we conclude, that the weakness 

should be reduced to a second-tier reportable condition. 

However, along with that belief, we recommend that FLETC 

management provide assurances that the reportable condition will 

eventually be closed. This could be achieved by FLETC’s efforts to 

complete remediation of the four outdoor dirt berm firing ranges by 

the revised target date of April 2005, and a plan of action to fully 

address interim measures. 

Specifically, we found that FLETC has made several modifications 

over the years to the four outdoor dirt berm firing ranges to reduce 

the environmental and safety concerns associated with the 

operation of these ranges. These modifications included installation 

of barriers to prevent stray bullets from exiting the immediate range 

areas safety zones, installation of permanent groundwater wells to 

test for contaminants, construction of several new “state of the 

art” indoor/outdoor ranges, establishment of non-toxic ammunition 

use, implementation of restrictions on types of weapons used at 

the ranges and other operational modifications. 

Background 

In 1975, FLETC moved its operations to a 1,500-acre site near 

Brunswick, Georgia. To address requirements for firearms training, 
FLETC’s Actions To Reduce A Reported Material Weakness Associated 

With Operation of Its Outdoor Dirt Berm Ranges OIG-03-036 

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FLETC used a preexisting outdoor dirt berm firing range1

 that had 

been constructed by the Navy in the early 1950s. Over the next 

several years, FLETC built three additional dirt berm ranges to 

quickly provide needed training capacity. These ranges were the 

most common, efficient, and cost effective method of firing range 

construction. FLETC currently operates 17 firearms ranges at its 

principal training facility at Glynco, Georgia. Four of these firing 

ranges are outdoor dirt berm, which released lead into the 

environment. Overall, in FY 2001, 19,435 students were trained at 

the Glynco, Georgia site, using over 14.3 million rounds of 

ammunition. 

 

In an OMB Circular A-123 internal review conducted pursuant to 

the requirements of the Federal Managers’ Financial Integrity Act 

(FMFIA) and Treasury Directive 40-04, the FLETC’s Director’s 

annual assurance letter to the Secretary of the Treasury, in Fiscal 

Year (FY) 1991, identified as a high-risk area the “safety, noise, 

and environmental problem” associated with the outdoor dirt berm 

firing ranges. The decision to classify this deficiency as a material 

weakness was based on guidance contained in OMB Circular 

A-123. As stated, this designation requires judgment by agency 

managers as to the “relative risk and significance of deficiencies.” 

In hindsight, according to the current FLETC senior management, 

absent a compelling regulatory mandate to do so, it is questionable 

whether this was an appropriate designation and this condition may 

have been more properly reported as a second tier issue rather than 

a material weakness. 

The initial target date of 1998 for correcting this material 

weakness became unachievable because appropriations, projected 

at $22.5 million in 1991, were far short of the amounts required by 

FLETC. In FY 1993, the first year FLETC received an appropriation 

toward environmental remediation of the outdoor dirt berm firing 

ranges, trainees fired less than 6.5 million rounds of ammunition at 

the Glynco, Georgia facility. By FY 2001, over 14 million rounds 

of ammunition were fired at the Glynco facility. Accordingly, the 

 

1

 A dirt berm firearms range is one that uses a large mound of soil as a downrange 

 backstop for capturing bullets fired by the trainees. 
FLETC’s Actions To Reduce A Reported Material Weakness Associated 

With Operation of Its Outdoor Dirt Berm Ranges OIG-03-036 

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1998 target date for remediation was revised to December 2001. 

However, as the target date approached, increased demand for 

firearms training at Glynco, resulting in part from the events of 

September 11, 2001, coupled with the critical need to rehabilitate 

FLETC’s aging indoor firing ranges made that target date 

unachievable as well. According to FLETC officials, the increased 

demand for training, logistics and need for major maintenance on 

indoor ranges has inhibited the phasing out of the outdoor ranges. 

Since FLETC reported the material weakness in its 1991 Secretary 

of the Treasury’s Annual Assurance Letter, several revised target 

dates for completion were reported in the Department of the 

Treasury’s (Treasury) FY 1996, 1999 and 2001 Accountability 

Reports. Recently, FLETC established a new target date of April 

2005 for completion of remediation of the four outdoor dirt berm 

firing ranges. 

FINDING AND RECOMMENDATIONS 

Finding 1 FLETC Has Devoted Considerable Efforts to Remediate 

the Outdoor Dirt Berm Firing Ranges Material Weakness 

FLETC has devoted considerable efforts and notable actions since 

1991 to rectify the material weakness associated with its outdoor 

dirt berm firing ranges. In October 1991, in its annual assurance 

letter to the Secretary of the Treasury, the FLETC Director reported 

the high-risk problem as a material weakness. 2 

 2 Public Law 97-255, the Federal Managers Financial Integrity Act (FMFIA) of 1982, 

provides that by the end of each calendar year, the head of each executive agency shall 

prepare a statement that the agency’s systems of internal accounting and administrative 

control fully comply with the requirements. If not, then the agency must submit a report 

of any material weaknesses identified and a plan and schedule of actions for correcting 

any such weaknesses. In addition, Treasury Directive 40-04 provides: Bureau heads will 

be responsible for establishing priorities in identifying, correcting and reporting 

management control material weaknesses. OMB Circular A-123 prescribes: a deficiency 

should be reported if it is or should be of interest to the next level of management. A 

deficiency that the agency head determines to be significant enough to be reported 

outside the agency should be considered a material weakness. 
FLETC’s Actions To Reduce A Reported Material Weakness Associated 

With Operation of Its Outdoor Dirt Berm Ranges OIG-03-036 

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State of the art indoor/outdoor 

baffled range from the front 

shooting position 

Specifically, we found that since FLETC reported the weakness, it 

has made several modifications to the four outdoor dirt berm firing 

ranges to reduce the possibility of stray bullets from exiting the 

immediate range areas safety zones. It has installed, with the 

assistance of COE, permanent groundwater wells to test for 

contaminants in the immediate area of the ranges. Also, FLETC 

constructed several new “state of the art” indoor/outdoor ranges at 

a cost of $3.8 million dollars per 

range. 

In addition, FLETC has established 

the use of non-toxic ammunition and 

has implemented restrictions on the 

types of weapons used at the four 

outdoor dirt berm firing ranges along 

with other enhancements. We found 

that FLETC has provided for several 

studies to assess remediation of the 

outdoor dirt berm firing ranges and 

plans of actions. At its request, numerous environmental risk tests 

and studies were performed by the COE and the Georgia EPD of 

the groundwater wells and soils in the immediate areas for 

contaminants. Also, the University of Georgia’s College of 

Veterinary Medicine evaluated the exposure of wild birds and 

mammals to lead and zinc in the immediate vicinity of the outdoor 

dirt berm firing ranges. 

FLETC’s decision to classify the deficiency as a material weakness 

in October 1991 was based on guidance contained in OMB Circular 

A-123. In hindsight, according to the current FLETC senior 

management, absent a compelling regulatory mandate to do so, it 

is questionable whether or not this was an appropriate designation 

and this condition may have been more properly reported as a 

second tier issue rather than a material weakness. 

 

FLETC’s decision to reclassify the environmental condition was 

endorsed by the Georgia EPD. Specifically, the EPD stated that 

FLETC is operating its facilities including the outdoor firearms 
FLETC’s Actions To Reduce A Reported Material Weakness Associated 

With Operation of Its Outdoor Dirt Berm Ranges OIG-03-036 

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ranges, in substantial compliance with applicable hazardous waste 

laws. 

As a result of the above measures, it is our belief that the actions 

mentioned and taken by FLETC have clearly documented its case 

that the deficiency no longer raises to the level of a material 

weakness. In this regard, we believe, the reported material 

weakness should be lowered to a second tier reportable condition. 

However, we recommend that FLETC management should continue 

its efforts to complete remediation of the four outdoor dirt berm 

firing ranges by its newly revised target date of April 2005. Also, 

we recommend that the FLETC establish an action plan to achieve 

the completion and any additional tasks associated with the 

remediation. 

More detailed discussions of our assessment of the efforts and 

actions to address the material weakness are discussed in the two 

sections below: 

Physical Observations 

As part of our objective, we performed physical observations and 

examinations at the four outdoor dirt berm firing ranges at the 

Glynco, Georgia site on August 26-27, 2002. We also, conducted 

selected observations at several of the indoor firing ranges, 

particularly at one of eight indoor/outdoor baffled firing ranges3. 

According to FLETC management, the modifications at the four 

outdoor dirt berm firing ranges were made to reduce stray bullets 

from exiting the immediate range areas safety zones. Although this 

risk is undeniable, in 27 years of operation, according to FLETC’s 

management, no off-range injuries have resulted from the millions 

of rounds fired on the outdoor dirt berm ranges. 

Specifically, at the outdoor dirt berm firing ranges, we observed 

several physical modifications that were made to reduce stray 

 3

 Indoor/outdoor baffled ranges design incorporates bullet traps and air filtration systems 

that permits the recovery of all fired rounds and nearly all contaminants. 
FLETC’s Actions To Reduce A Reported Material Weakness Associated 

With Operation of Its Outdoor Dirt Berm Ranges OIG-03-036 

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bullets from exiting the immediate range. Most significantly 

observed were eyebrows4 installed above the backstops along the 

dirt berm tops, and steel reinforced wooden barriers have been 

installed above most firing positions. 

 Eyebrow at the top of the dirt berm 

range 

 Steel reinforced wooden barriers from 

inside of range looking at the firing 

position 

The purpose of both the eyebrows and the steel reinforced wood 

barriers is to prevent a bullet, which has been discharged at an 

improperly high angle of elevation from exiting the range. We were 

also told that the four outdoor dirt berm firing ranges had been 

resurfaced with additional soil in lieu of mining. This took place 

after a site visit by the EPA’s Waste Compliance Section and 

recommendation in October 1990. 

Additional significant efforts and actions noted since 1991 included 

the following: 

• Other than the outdoor ranges, all of Glynco ranges are 

designed to totally contain the bullets fired and to prevent 

any bullets from escaping the immediate range area, 

regardless of their trajectories. FLETC has constructed 

several of these outdoor/indoor baffled firing ranges, which 

were completed in 1995,1999 and 2001, as funds were 

made available. Specifically, we observed the structural 

engineering at one of eight newly designed “state of the 

art” indoor/outdoor baffled ranges, which cost $3.8 million 

each to construct. The new ranges are virtually completely 

 4

 Eyebrows are safety barriers installed above the backstops at the end of the 

 dirt berm firing ranges to stop a bullet that is discharged at an improperly 

 high angle of elevation. 
FLETC’s Actions To Reduce A Reported Material Weakness Associated 

With Operation of Its Outdoor Dirt Berm Ranges OIG-03-036 

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contained within four walls. Overhead fans blow the lead 

smoke away from the shooters. The bullet trap contains a 

vacuum system that draws in a large portion of the airborne 

particles along with the bullets, which are fired down range. 

The spent bullets are captured in waste drums that are 

checked daily, and when full, are properly labeled, sealed, 

and moved to a hazardous waste storage facility to await 

disposal. According to the FLETC environmental specialist, 

soil and groundwater conditions in the immediate vicinity of 

the new ranges have been assessed and will continue to be 

sampled periodically. FLETC officials also informed us that 

these ranges were intended for environmentally friendly 

non-toxic ammunition5

only. However, with permission and 

on a limited basis, some training classes are allowed to use 

leaded ammunition at these state of the art ranges. 

 Vacuum system outside state of the art 

range

 Non-toxic ammunition

• FLETC pioneered the use of non-toxic training ammunition in 

FY 1998. It has continued the use of non-lead ammunition 

in FY 2000 and has increased its use at Glynco, Georgia to 

nearly 60 percent of all bullets fired in FY 2001. In the first 

half of FY 2002, the use of non-toxic ammunition was 

approaching 75 percent. This marked the first time non-lead 

ammunition exceeded the use of lead ammunition. We 

observed the use of non-toxic ammunition at one of the four 

outdoor dirt berm firing ranges. In addition, we examined 

 5 Non-toxic ammunition is ammunition with bullets comprised primarily of metal that are 

 less environmentally hazardous than lead and that use other components that reduce 

 environmental contamination.
FLETC’s Actions To Reduce A Reported Material Weakness Associated 

With Operation of Its Outdoor Dirt Berm Ranges OIG-03-036 

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the non-toxic ammunition at the Firearms Division contractor 

site located in building 221. 

• Other significant observations included the beginning of 

renovation and refurbishment at building 221, which also 

houses several of the indoor computerized ranges. 

According to FLETC officials, lead contaminants and the 

deterioration of these ranges has prompted the need to 

refurbish these ranges to ensure sufficient training facilities 

are made available to meet the training needs of agencies. 

Evaluation of Studies, Test Results and Reports

FLETC’s actions since 1991 have been documented in numerous 

studies, test results and their own internal assessment reports. 

During our fieldwork, we evaluated and assessed studies, tests, 

and reports to determine when, how, and the results of actions 

taken since FLETC reported the material weakness. We found the 

following has occurred since FLETC reported the material weakness 

in its 1991 annual assurance letter: 

• At FLETC’s request, in August 1993, the COE agreed to 

pursue a course of action under the Comprehensive 

Environmental Response, Compensation, and Liability Act for 

the investigation and eventual remediation of the dirt berm 

outdoor firing ranges. Then in September 1994, the COE 

installed permanent groundwater monitoring wells in the 

vicinity of the outdoor dirt berm firing ranges. 

Groundwater monitoring well 
FLETC’s Actions To Reduce A Reported Material Weakness Associated 

With Operation of Its Outdoor Dirt Berm Ranges OIG-03-036 

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• At FLETC’s request, in December 1994, the COE issued its 

Site Inspection Narrative Report on FLETC’s outdoor dirt 

berm firing ranges, which indicated high levels of lead in the 

berms and range surfaces and high concentrations of lead in 

the lagoons or catch basins directly behind the ranges. 

However, lead contamination was restricted to surface soils 

and water, and catch basin sediments. Also, the results 

showed that lead and other ballistic by-products had 

migrated into the groundwater and air but was not detected 

at statistically significant levels. The COE has continued its 

tests of groundwater, from the monitoring wells and 

perimeter wells in 1996, 1997, 1998, and again in 2001, 

and confirmed the absence of contamination. 

• At FLETC’s request, in 1999, the University of Georgia’s 

College of Veterinary Medicine issued a study on the 

exposure of wild birds and mammals to lead and zinc in the 

immediate vicinity of the outdoor dirt berm ranges. The 

study determined that 17 percent of the animals sampled 

contained enough lead to produce clinical impacts. 

However, the study also concluded that the diversity and 

abundance of wildlife in the area was not curtailed. 

• A FLETC report issued in April 2001, titled What to Do 

About the Upcoming FLETC Firearms Range Shortfall, 

highlighted that FLETC could face critical decisions regarding 

the timing of the demolition and environmental remediation 

of its outdoor firearms range complex, and critically needed 

renovation of its indoor firearms training complex. Based on 

the April 2001 report, FLETC decided to delay until April 

2005, the remediation of the four outdoor dirt berm firing 

ranges until the new indoor firing ranges are completed. The 

COE and the EPD agreed with the delay citing the need to 

have sufficient firing ranges to accommodate closure of the 

four outdoor dirt berm ranges. 

• We observed and confirmed the beginning of the FLETC’s 

renovations, refurbishment, and phased construction at the 

Firearms Division, Building 221 during our site visit. 
FLETC’s Actions To Reduce A Reported Material Weakness Associated 

With Operation of Its Outdoor Dirt Berm Ranges OIG-03-036 

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According to FLETC, the challenge facing it is to balance the need 

to achieve its vital law enforcement training mission--made even 

more acute in light of the war on terrorism--with its responsibility 

to expeditiously rectify its material weakness and protect the 

environment. In another FLETC internal report titled, a Report on 

Possible Models for Rectifying the FLETC’s Material Weakness 

Under the FMFIA, issued May 30, 2002, it questioned whether the 

decision by its predecessors was properly exercised in 1991. 

As stated above, we agree that FLETC’s management has taken 

significant efforts and actions to address the material weakness 

reported in 1991. We found no instances that would impact the 

reduction of the weakness to a second tier reportable condition. 

However, we again recommend that FLETC should strive to 

achieve the newly revised target date for remediation of the ranges 

and set forth an action plan to do so. 

 

Recommendations

The FLETC Director should:

1. Continue efforts to complete the remediation of the four 

outdoor dirt berm firing ranges by its newly revised target date 

of April 2005. 

Management Comments

FLETC concurred with this recommendation. As a result, FLETC 

will continue its efforts to complete the remediation of the four 

outdoor dirt berm firing ranges. It is expected that total 

remediation can be completed by the target date of April 2005. 

 OIG Comments

The OIG believes that the actions taken and planned by FLETC 

meet the intent of our recommendation. 
FLETC’s Actions To Reduce A Reported Material Weakness Associated 

With Operation of Its Outdoor Dirt Berm Ranges OIG-03-036 

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2. Establish an action plan to achieve the completion of any 

additional tasks associated with the remediation, once the 

material weakness is reclassified as a second tier reportable 

condition and brought to closure.

 

 Management Comments

 

FLETC concurred with this recommendation. An action to 

achieve the complete remediation of the ranges is now in place. 

FLETC has ensured that the action plan will be closely 

monitored to ensure that due dates are met. 

OIG Comments

The OIG believes that the actions taken or planned by FLETC 

meet the intent of our recommendation. 

***** 

We would like to extend our appreciation to FLETC for the 

cooperation and courtesies extended to our staff during the review. 

If you have any questions, please contact me at (202) 927-5591, 

or a member of your staff may contact Ethel Taylor-Young, Audit 

Manager, at (202) 927-6453. Major contributors to this report are 

listed in Appendix 4. 

Alexander Best, Jr 

National Director, Enforcement Program Audits 
Appendix 1 

Objectives, Scope and Methodology 

FLETC’s Actions To Reduce A Reported Material Weakness Associated 

With Operation of Its Outdoor Dirt Berm Ranges OIG-03-036 

Page 14 

 

The objective of this audit was to evaluate FLETC’s actions to 

remediate the environmental and safety risks associated with its 

outdoor dirt berm ranges. Specifically, our review included FLETC’s 

efforts since it reported the material weakness in October 1991 

until the present. 

We conducted physical observations and examinations at selected 

sites at FLETC’s Glynco, Georgia facility in August 2002. Also, we 

held interviews and discussions with FLETC officials and 

responsible personnel. In addition, we evaluated the environmental 

risks and safety studies, test results, and reports. The United 

States Army Core of Engineers, the Georgia Environmental 

Protection Division and the University of Georgia’s College of 

Veterinary Medicine, conducted these studies and tests, at the 

request of FLETC. Also, we evaluated several internal assessment 

reports that were prepared by FLETC. 

Additional review work included physical observations at one of 

eight indoor/outdoor baffled ranges, several indoor ranges located 

in the Firearms Division’s building 221, examination of non-toxic 

ammunition and methods used to remove contaminants from the 

baffled ranges. An entrance conference was held with FLETC’s 

senior management on August 26, 2002. Our review was 

conducted from August 12, 2002 through September 30, 2002. 

We conducted our audit in accordance with generally accepted 

government auditing standards. 
Appendix 2 

Management Comments 

FLETC’s Actions To Reduce A Reported Material Weakness Associated 

With Operation of Its Outdoor Dirt Berm Ranges OIG-03-036 

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Appendix 3 

Major Contributors To This Report 

FLETC’s Actions To Reduce A Reported Material Weakness Associated 

With Operation of Its Outdoor Dirt Berm Ranges OIG-03-036 

Page 16 

 

 Alexander Best, Jr., National Director, Enforcement Program 

 Audits 

 Ethel Taylor-Young, Audit Manager 

 Eno Uhik, Staff Auditor 
Appendix 4 

Report Distribution 

FLETC’s Actions To Reduce A Reported Material Weakness Associated 

With Operation of Its Outdoor Dirt Berm Ranges OIG-03-036 

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 U. S. Department of the Treasury

 

 Under Secretary for Enforcement 

 Assistant Secretary for Enforcement 

Assistant Secretary for Legislative Affairs 

 Office of Strategic Planning and Evaluations 

 Office of Accounting and Internal Controls 

 Federal Law Enforcement Training Center

 

 Director 

 Director, Office of Compliance 

 

 Office of Management and Budget

 OIG Budget Examiner