GAO

United States General Accounting Office

Report to Congressional Committees

March 2000 DOD COMPETITIVE 

SOURCING

Potential Impact on 

Emergency Response 

Operations at 

Chemical Storage 

Facilities Is Minimal

GAO/NSIAD-00-88

Page 1 GAO/NSIAD-00-88 DOD Competitive Sourcing

Contents

Letter 3

Appendixes Appendix I: The A-76 Process 14

Appendix II: Comments From the Department of Defense 18

Appendix III: GAO Contacts and Staff Acknowledgments 20

Tables Table 1: Installation Emergency Response Team Organization 7

Table 2: Positions With Emergency Response Duties Potentially

Affected by Competitive Sourcing Studies 9

Figures Figure 1: Original Stockpile of Chemical Agents and Munitions in the 

United States 6

Figure 2: Overview of the A-76 Process 15
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United States General Accounting Office

Washington, D.C. 20548

National Security and

International Affairs Division

B-284636 Letr

March 28, 2000

The Honorable John Warner

Chairman

The Honorable Carl Levin

Ranking Minority Member

Committee on Armed Services

United States Senate

The Honorable Floyd Spence

Chairman

The Honorable Ike Skelton

Ranking Minority Member

Committee on Armed Services

House of Representatives

The Army maintains eight industrial facilities in the continental United 

States whose mission in whole or in part involves the storage of chemical 

agents and munitions that are required to be disposed of over the next 

several years. Some of these facilities have other missions such as 

ammunition storage, manufacturing, and maintenance of some chemical 

defense equipment. While the Army considers the likelihood of a chemical 

release at one of these facilities to be extremely small, the health effects of 

an accident could be severe. Before constructing or operating a chemical 

weapon destruction facility, the Army must obtain permits to comply with 

federal, state, and local environmental laws and regulations. These permits 

require facilities to maintain emergency response plans. Accordingly, Army 

officials, working with state and local officials, have developed emergency 

response plans for the unlikely event of a chemical accident. Government 

employees at the eight locations typically have collateral emergency 

response duties assigned under the emergency response plans. 

Five of the eight facilities that store chemical munitions are participating in 

the Army’s program to study whether functions currently performed by 

federal employees could be performed more cost effectively in-house or by 

the private sector. As part of this program, the Army is conducting studies, 

known as competitive sourcing studies, in accordance with guidance 

established by the Office of Management and Budget Circular A-76. (See 

app. I for a description of the A-76 process). Once the studies are complete, 

each installation will develop a plan to transition from the current 
B-284636

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organizational structure to either a most efficient government organization 

or a contractor workforce. The plans are designed to minimize disruption 

and adverse impacts.

However, several members of Congress have expressed concern about the 

impact of competitive sourcing on emergency response capabilities at the 

chemical storage facilities and the impact on manufacturing capabilities 

related to chemical and biological defense. The National Defense 

Authorization Act for Fiscal Year 20001

 required that we assess the Army’s 

competitive sourcing study plans at the five facilities and the potential 

operational impact. Accordingly, this report addresses (1) Army plans for 

competitive sourcing studies at the five facilities and the extent to which 

emergency response or chemical defense industrial positions are included 

in the competitive sourcing studies and (2) the status of the Army’s 

assessment and our assessment of how competitive sourcing would impact 

emergency response capabilities and environmental permits associated 

with the destruction of the chemical agents and munitions.

Results in Brief The Army has competitive sourcing studies underway at five of the eight 

facilities where chemical munitions are stored, but only a relatively small 

number (ranging from 0 to 12 percent) of the activities being studied at 

these locations include emergency response duties. These studies focus 

principally on base operations support functions such as facilities 

maintenance, supply, and information management. The Army had plans to 

study activities involving manufacturing positions at only one of these 

facilities, Pine Bluff Arsenal, Arkansas, but canceled those plans in 

November 1999.

The Army has not completed its assessment of how the transition from the 

current organizational structure to either a most efficient government 

organization or contractor workforce would affect emergency response 

capabilities. However, our analysis indicates that there should be minimal 

potential for a degradation of emergency response capabilities because of 

the small number and types of positions with emergency response duties 

potentially affected. In addition, the Army should be able to mitigate any 

degradation of emergency capability by requiring that transition plans 

provide for adequate training and phasing in of any replacement personnel 

1

 Public Law 106-65, section 142.
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who will be performing emergency response duties. Army officials believe 

that the scope of the competitive sourcing studies should not affect 

environmental permits as long as the Army maintains its emergency 

response capabilities.

We are making a recommendation to the Secretary of Defense to require 

that the Army’s transition plans include provisions to identify and train 

replacement personnel at each of the affected installations to ensure the 

continuity and viability of emergency response capabilities as the results of 

the competitive sourcing studies are implemented.

Background Since World War I, the United States has maintained a stockpile of chemical 

weapons and agents. The stockpile consists of rockets, bombs, projectiles, 

spray tanks, and bulk containers that contain various chemical agents. 

Most of the stockpile is stored at eight facilities in the continental United 

States, as seen in figure 1.
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Figure 1: Original Stockpile of Chemical Agents and Munitions in the United States

Note: As of December 31, 1999, Deseret Chemical Depot, Utah had destroyed 325,459 items and 

4,636 tons of agent.

Source: Program office for chemical demilitarization.
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In November 1985, the Congress directed the Department of Defense to 

destroy the U.S. stockpile of chemical agents and munitions in a manner 

that would provide maximum protection for the general public and the 

environment.2

 The Army is responsible for this program. The Army has 

weapons destruction activities underway or planned over the next several 

years at each of the eight facilities. Although the Army considers the 

likelihood of an accident at its storage facilities extremely small, it has 

developed a contingency emergency response plan with a trained 

emergency response team at each of the sites. Installation emergency 

response teams serve as the initial response force for any chemical 

accident or incident. The teams are organized into command, response, 

and support groups, as shown in table 1.

Table 1: Installation Emergency Response Team Organization

Source: Department of the Army.

Typically, personnel in the response group are referred to as first line 

responders. The teams vary in size, depending on the type and quantity of 

chemical munitions and agents stored as well as the potential threat. They 

are staffed with personnel from the chemical activity at each site whose 

primary jobs are to monitor the stockpile. Other personnel who provide 

day-to-day base operations services, such as public works and information 

management, are also team members on a part-time basis. All team 

members participate in quarterly exercises and receive training to ensure 

they are prepared to respond to a chemical accident or incident.

2

 Department of Defense Authorization Act, 1986, P.L. 99-145, section 1412, codified at

50 U.S.C. 1521.

Group Role Functions

Command Perform command and control. Legal, public affairs, safety, and chaplain.

Response Apply and control emergency response 

resources.

Toxic material handlers, hotline and contamination 

control, firefighters, and security.

Support Provide services and supplies to the 

emergency force.

Administration, communications, transportation and 

engineering.
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At five of the storage facilities—Aberdeen, Anniston, Blue Grass, Pine 

Bluff, and Tooele—the Army is conducting competitive sourcing studies of 

the base operation functions to determine if government employees or a 

contractor workforce is the most cost-effective means of obtaining these 

services. Currently, the Army has no plans to conduct competitive sourcing 

studies at the other three storage facilities. The functions being studied 

include supply operations, storage and warehousing, and information 

management. Some of the activities being studied at each location, with the 

exception of Aberdeen Proving Ground, are sources of personnel for the 

emergency response teams in the event of a chemical accident or incident. 

The study at Aberdeen Proving Ground does not include any positions with 

emergency response duties. The competitive sourcing studies at 

Aberdeen,3

 Anniston, Blue Grass, and Tooele are scheduled for completion 

in fiscal year 2000; and Pine Bluff in fiscal year 2002.

The Army has obtained the required environmental permits to construct 

and operate chemical weapons destruction facilities at Aberdeen Proving 

Ground, Anniston Army Depot, Pine Bluff Arsenal, and Tooele Army Depot. 

However, the Army has not obtained the required permits at Blue Grass 

Army Depot because the method that will be used to dispose of the 

chemical munitions has not been agreed upon.

Limited Number of 

Emergency Response 

Positions Potentially 

Affected

Competitive sourcing studies are underway at the five storage facilities, 

and only a limited number of positions with emergency response duties are 

now potentially affected by the studies. These studies focus on base 

operations support activities such as facilities maintenance, supply, and 

information management. Further, those positions under study with 

collateral emergency response duties generally are not first line emergency 

responders but rather provide administrative and communications support 

and operate heavy equipment if needed in the event of an accident. In 

November 1999, the Army decreased the scope of the study at Pine Bluff 

Arsenal, which significantly reduced the number of positions potentially 

affected.

3

 The Army completed its competitive sourcing study at this location, but the results were 

protested to GAO. Aberdeen Technical Services, B-283727.2, Feb. 22, 2000. GAO found that 

the Army’s cost comparison was done improperly and recommended that the Army either 

revise the in-house cost estimate or reopen the competition.
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The Army had initially planned to study base operations functions at all five 

facilities and other base functions, including manufacturing operations, at 

Pine Bluff Arsenal. The broader study at Pine Bluff would have potentially 

affected 106 positions with collateral emergency response duties or about 

44 percent of Pine Bluff’s emergency response capability. However, in 

November 1999, the Commander, Army Materiel Command, decided to 

study only base operation functions at Pine Bluff because of concern about 

the potential impact on readiness of competing the manufacturing 

operations. Currently, the number of positions with collateral emergency 

response duties potentially affected by the competitive sourcing studies 

range from 3 at Tooele Army Depot to 22 at Pine Bluff Arsenal, as shown in 

table 2.

Table 2: Positions With Emergency Response Duties Potentially Affected by Competitive Sourcing Studies

Source: Army data.

The table reflects the number of positions with emergency response duties 

that could be affected if a contractor workforce were to replace the 

existing government employees. Army officials noted that, if a contractor 

becomes responsible for base operation activities, the actual number of 

affected positions with these duties could be higher depending on the 

number of government personnel who retire and take early out incentives,4

and the results of a reduction-in-force,5

 if required. On the other hand, the 

Number of positions

Installation

With emergency

response duties

Included

in study

Percentage potentially

affected

Aberdeen 78 0 0

Tooele 611 3 1

Blue Grass 117 15 13

Anniston 451 21 5

Pine Bluff 243 22 9

4

 These incentives could include voluntary early retirement and voluntary separation 

incentive pay.

5

 Under a reduction-in-force, personnel included in the competitive sourcing study may have 

seniority to take positions not included in the study that also could be part of the emergency 

response force.
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Army officials stated that the number of affected positions with emergency 

response duties could be less if government employees continue to 

perform the base operation functions as a most efficient organization.

We found that the majority of the relatively few positions with emergency 

response duties are not first line responders. Rather these positions involve 

providing administrative and communications support or operating heavy 

equipment such as backhoes or cranes in the event of a chemical accident. 

For example, the emergency response duties of 6 of the 15 positions at Blue 

Grass Army Depot under study provide administrative support in the 

emergency operations center, and the emergency response duties of 8 of 

the 21 positions at Anniston Army Depot involve heavy equipment 

operators. Likewise, the emergency response duties of the affected 

positions at Pine Bluff primarily involve heavy equipment operation, 

driving, and administrative support. Whatever the outcome of the 

competitive sourcing study, these duties will continue to be performed 

either by the government’s most efficient organization or by the contractor 

work force.

With Adequate 

Planning, the Outcome 

of the Studies Should 

Not Affect Emergency 

Response Capability or 

Environmental Permits

The Army has not completed its assessment of the potential impact that the 

competitive sourcing studies will have on emergency response capabilities. 

However, our assessment indicates that there should be minimal potential 

for a degradation of emergency response capabilities because of the small 

number of positions with emergency response duties involved. In addition, 

the Army should be able to mitigate any degradation of emergency 

capability by ensuring that transition plans provide for adequate training 

and phasing in of any replacement personnel, whether government or 

contractor, who will be performing the emergency response duties. Army 

officials also believe that the competitive sourcing studies should not affect 

environmental permits as long as the Army maintains its emergency 

response capabilities.

The Commanding General of the Army Materiel Command directed his 

staff to assess the potential impact the competitive sourcing studies would 

have on the emergency response capabilities at the installations that store 

chemical munitions. The assessment should be completed in March 2000. 

Officials preparing the Army assessment believe that there is minimal 

potential for degradation of emergency response capabilities at the 

chemical storage installations undergoing competitive sourcing studies. 

They stated that there might not be sufficient numbers of trained personnel 

during the transition to either a most efficient government organization or a 
B-284636

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contractor workforce. However, they indicated that they could mitigate any 

potential degradation of capabilities by transition planning addressing the 

training and phasing in of any replacement personnel with emergency 

response duties. As previously noted, we found that only a relatively small 

number of positions with emergency response duties would likely be 

affected by the competitive sourcing studies. Also, the initial training for 

the majority of these positions is limited to a one-week course, and can 

thus be readily accomplished by replacement personnel, whether 

government or contractor.

Once the results of the competitive sourcing studies are known, each 

installation is required to develop a plan to transition from the current 

organizational structure to either a most efficient government organization 

or a contractor workforce. Office of Management and Budget Circular A-76 

provides broad guidance that states these plans should be designed to 

minimize disruption and adverse impacts of transitioning to a new 

workforce. Army officials intend to develop plans to transition the base 

operations functions to the replacement workforce, whether government 

or contractor. However, to avoid any possible gaps in emergency response 

coverage, we believe these plans should also include strategies to train 

personnel who would replace any existing emergency responders. 

Army officials stated that the environmental permits the Army has obtained 

to construct or operate facilities to destroy chemical weapons should not 

be affected by the studies. An official in the Office of Program Management 

for Chemical Demilitarization at Anniston Army Depot stated that he does 

not anticipate any problems with permits because either government or 

contractor personnel can perform the required emergency response 

functions. Likewise, an official in the Office of Program Management for 

Chemical Demilitarization at Tooele Army Depot stated that the permits 

would not be affected because only 3 of 611 emergency response positions 

are potentially affected by the study of base operation functions.

Finally, an official in the Office of Program Management for Chemical 

Demilitarization at Pine Bluff Arsenal stated that the permit for chemical 

demilitarization activities at that facility should not be affected by the 

outcome of the competitive sourcing study. This official stated that the 

permit requires the Army to have and maintain certain equipment, such as 

backhoes, in the event of a chemical accident. He stated that as long as this 

type of equipment is available and maintained, regardless of whether by a 

government of contractor workforce, the permit should not be affected.
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Conclusion Available information indicates that the competitive sourcing studies 

should not affect the Army’s emergency response capabilities at the 

chemical storage facilities as long as there is adequate advanced transition 

planning. The Army’s transition plans for implementing the results of the 

competitive sourcing studies should include the proper designation and 

training of replacement personnel, whether government or contractor, to 

fill emergency response positions, as needed, to ensure that there are no 

possible gaps in emergency response capabilities.

Recommendation To ensure that adequate emergency response capabilities are maintained 

when competitive sourcing studies are being conducted at installations that 

store chemical munitions, we recommend that the Secretary of Defense 

require that the Army’s transition plans contain a strategy for training 

personnel to fill emergency response positions affected by those studies.

Agency Comments In written comments on a draft of this report, the Department of Defense 

concurred with our recommendation. The Department’s comments are 

reprinted in their entirety in appendix II.

Scope and 

Methodology

To determine the extent to which emergency response positions were 

included in the competitive sourcing studies, we compared the emergency 

response positions to the positions included in the study universe at each 

installation. We obtained data on the positions included in the study 

universe from Army officials at Aberdeen Proving Ground, Maryland; 

Anniston Army Depot, Alabama; Blue Grass Army Depot, Kentucky; Pine 

Bluff Arsenal, Arkansas; and Tooele Army Depot, Utah. We also obtained a 

list of emergency response positions from the chemical activities at each 

location. To determine the potential impact on industrial missions, we 

verified that only base operation functions were being studied at each 

location and also obtained documentation to support the Army’s decision 

not to study the manufacturing operation at Pine Bluff Arsenal.

To determine if the Army had conducted risk assessments, we interviewed 

officials at the Army Materiel Command headquarters, Alexandria, Virginia, 

and the Soldier and Biological Chemical Command, Aberdeen, Maryland. 

Our assessment was based upon our review of the risk assessments 

conducted by the Soldier and Biological Chemical Command, the Blue 
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Grass Army Depot, the Pine Bluff Arsenal, and the Tooele Army Depot, and 

our analysis of the numbers and types of emergency response positions 

included in the competitive sourcing studies. Aberdeen Proving Ground 

and Anniston Army Depot did not prepare risk assessments. To determine 

the potential impact on environmental permits, we interviewed officials in 

the Office of Program Management for Chemical Demilitarization at each 

site.

We conducted our review from October 1999 through February 2000 in 

accordance with generally accepted government auditing standards.

We are sending copies of this report to the Honorable William S. Cohen, 

Secretary of Defense; the Honorable Louis Caldera, Secretary of the Army; 

and the Honorable Jacob Lew, Director, Office of Management and Budget. 

Copies will also be available to others upon request.

If you or your staff have any questions concerning this report, please 

contact me at (202) 512-8412. Key contributors are listed in appendix III.

David R. Warren

Defense Management Issues
Page 14 GAO/NSIAD-00-88 DOD Competitive Sourcing

Appendix I

The A-76 Process ApApenednxidexiIs

In general, the A-76 process consists of six key activities: (1) developing a 

performance work statement and quality assurance surveillance plan; 

(2) conducting a management study to determine the government’s most 

efficient organization; (3) developing an in-house government cost estimate 

for the most efficient organization; (4) issuing a Request for Proposals or 

Invitation for Bids; (5) evaluating the proposals or bids and comparing the 

in-house estimate with a private sector offer or an interservice support 

agreement and selecting the winner of the cost comparisons; and 

(6) addressing any appeals submitted under the administrative appeals 

process, which is designed to ensure that all costs are fair, accurate, and 

calculated in the manner prescribed by the A-76 handbook.

Figure 2 shows an overview of the process. The solid lines indicate the 

process used when the government issues an Invitation for Bids or Request 

for Proposals requesting bids or proposals on the cost of performing a 

commercial activity. This type of process is normally used for more routine 

commercial activities such as grass cutting or cafeteria operations, where 

the work process and requirements are well defined. The dotted lines 

indicate the additional steps that take place when the government wants to 

pursue a negotiated, “best value” procurement. This type of process is often 

used when a commercial activity involves high levels of complexity, 

expertise, and risk.
Appendix I

The A-76 Process

Page 15 GAO/NSIAD-00-88 DOD Competitive Sourcing

Figure 2: Overview of the A-76 Process

Source: Air Force Air Education and Training Command Documents.

The circular requires the government to develop a performance work 

statement. This statement, which is incorporated into either the Invitation 

for Bids or Request for Proposals, serves as the basis for both government 

estimates and private sector offers. Each private sector company develops 

and submits a bid or proposal, giving its price for performing the 

Issue performance 

work statement 

and RFP or IFB

Compare selected 

Best Value and MEO

technical proposals

Prepare in-house 

cost estimate

Revise

MEO 

Revise 

in-house 

cost estimate 

Compare 

costs/select 

contractor

Most Efficient Organization (MEO) activities

 Government technical evaluation activities

MEO

management study

Select lowest

cost alternative

Additional steps required for request for 

proposals (RFP)

Process for invitation for bid (IFB)

Prepare technical

proposal

Conduct technical 

evaluation of MEO

Conduct technical

evaluation of 

bids/proposals

Accept 

contractor

bids/proposals
Appendix I

The A-76 Process

Page 16 GAO/NSIAD-00-88 DOD Competitive Sourcing

commercial activity. The government activity performs a management 

study to determine the most efficient and effective way of performing the 

activity with in-house staff. On the basis of this “most efficient 

organization,” the government develops a cost estimate and submits it to 

the selecting authority. The selecting authority concurrently opens the 

government’s estimate and the bids or proposals of all the private sector 

firms.

According to Office of Management and Budget’s A-76 guidance, the 

activity will be converted to performance by the private sector if the private 

sector offer is either lower by an amount equal to 10 percent of the direct 

personnel costs of the in-house cost estimate or is $10 million less over the 

performance period than the in-house estimate, whichever is less. The 

Office of Management and Budget established this minimum cost 

differential to ensure that the government would not convert performance 

for marginal estimated savings.

If a best value process is used, the Federal Acquisition Regulation and the 

A-76 supplemental handbook require several additional steps. The private 

sector offerors submit proposals that often include a technical 

performance proposal as well as the price. The government prepares an

in-house management plan and a cost estimate that are based strictly on 

the performance work statement. On the other hand, private sector 

proposals can offer a higher level of performance or service. The 

government’s selection authority reviews the private sector proposals to 

determine which one represents the best overall value to the government 

based on such considerations as (1) performance levels, (2) proposal risk, 

(3) past performance, and (4) price. After the completion of this analysis, 

the selection authority prepares a written justification supporting its 

decision. This includes the basis for selecting a contractor other than the 

one that offered the lowest price to the government. Next, the authority 

evaluates the government’s estimate and determines whether it can achieve 

the same level of performance and quality as the selected private sector 

proposal. If not, the government must then make changes to meet the 

performance standards accepted by the authority. This is to ensure that the 

in-house cost estimate is based upon the same scope of work and 

performance levels as the best value private sector offer. After determining 

that the government estimate and selected private offer are based on the 

same level of performance, the estimated costs are compared.
Appendix I

The A-76 Process

Page 17 GAO/NSIAD-00-88 DOD Competitive Sourcing

Following an A-76 cost comparison decision, participants in the cost 

comparison may appeal the selection authority’s decision if they believe the 

costs submitted by one or more of the participants were not fair, accurate, 

or calculated in compliance with the requirements and procedures of A-76. 

Appeals must be submitted in writing and within 20 days after the date that 

all supporting documentation is made publicly available. The appeal period 

may be extended to 30 days if the cost comparison is particularly complex. 

Appeals are supposed to be adjudicated within 30 days after they are 

received.
Page 18 GAO/NSIAD-00-88 DOD Competitive Sourcing

Appendix II

Comments From the Department of Defense ApendxiI
Appendix II

Comments From the Department of Defense

Page 19 GAO/NSIAD-00-88 DOD Competitive Sourcing

Now on p. 12.
Page 20 GAO/NSIAD-00-88 DOD Competitive Sourcing

Appendix III

GAO Contacts and Staff Acknowledgments ApendxiI

GAO Contacts Barry Holman, (202) 512-5581

William Crocker, (202) 512-4533

Acknowledgments In addition to those named above, Michael Kennedy, Paul Newton, John 

Brosnan, and Adam Vodraska made key contributions to this report.

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