Report to Congressional Requesters

United States General Accounting Office

GAO

July 2001 ENVIRONMENTAL

CONTAMINATION

Cleanup Actions at

Formerly Used

Defense Sites

GAO-01-557
Page i GAO-01-557 Cleanup at Formerly Used Defense Sites

Letter 1

Results in Brief 2

Background 3

Most Potential FUDS Properties Are Ineligible or Do Not Require

Cleanup 8

Geographic Distribution and Status of Potential FUDS Properties 12

Conclusions 17

Recommendations 17

Agency Comments and Our Evaluation 18

Scope and Methodology 18

Appendix I Properties Identified for Potential Inclusion

in the FUDS Cleanup Program 20

Appendix II Cleanup Projects on FUDS Properties 21

Tables

Table 1: Reasons That Potential FUDS Properties Were Ineligible 8

Table 2: Eligibility and Status of 9,171 Potential FUDS Properties

by Geographic Location 14

Figures

Figure 1: Decision Tree Flow Chart for the Preliminary Assessment

of Eligibility Phase 5

Figure 2: Decision Tree Flow Chart for the Site Inspection Through

Long-Term Monitoring Phases 7

Figure 3: Breakout of 9,171 Potentially Eligible FUDS Properties 9

Figure 4: Status of 3,736 FUDS Cleanup Projects 11

Figure 5: Distribution of 9,171 Potential FUDS Properties 13

Contents
Page ii GAO-01-557 Cleanup at Formerly Used Defense Sites

Abbreviations

CERCLA Comprehensive Environmental Response, Compensation

 and Liability Act of 1980

DERP Defense Environmental Restoration Program

DOD Department of Defense

FUDS Formerly Used Defense Sites

GAO General Accounting Office

SARA Superfund Amendments and Reauthorization Act of 1986
Page 1 GAO-01-557 Cleanup at Formerly Used Defense Sites

July 31, 2001

The Honorable John D. Dingell

Ranking Minority Member

Committee on Energy and Commerce

House of Representatives

The Honorable Tom Sawyer

House of Representatives

The U. S. Army Corps of Engineers (Corps) estimates that it will spend at

least $15 billion to $20 billion to clean up contamination and other hazards

(hereafter hazards) at thousands of properties that were formerly owned,

leased, possessed, or operated by the Department of Defense (DOD) or its

components. These properties, located throughout the United States, are

known as formerly used defense sites (FUDS). The properties may contain

hazardous, toxic, and radioactive wastes in the soil and water or in

containers such as underground storage tanks. Such wastes can contribute

to mortality and serious illness, or pose a threat to the environment. Other

hazards, including unexploded ordnance and unsafe buildings, may also be

present on the properties. As of October 1, 2000, the Corps, states, and

other parties had identified 9,171 properties for potential inclusion in the

FUDS cleanup program. The Corps is responsible for cleaning up the

hazards, including removing underground storage tanks, and demolishing

unsafe structures.

Concerned about the ongoing presence of defense-related hazards on

property that is no longer controlled by DOD, you asked us to determine

(1) how many properties identified for potential inclusion in the FUDS

cleanup program are actually eligible for cleanup under the program and

require or have required cleanup and (2) the geographic distribution, by

state, of the potentially eligible FUDS properties and their locations,

type(s) of hazard, including unexploded ordnance, and cleanup status. For

those properties with unexploded ordnance, you also asked us to indicate

if they are former training ranges, which often have large amounts of

ordnance present after many years of use and may be costly to clean up.

Our review of these issues encompassed all potentially eligible properties

included in the Corps’ FUDS inventory as of the end of fiscal year 2000.

United States General Accounting Office

Washington, DC 20548
Page 2 GAO-01-557 Cleanup at Formerly Used Defense Sites

Most of the 9,171 properties identified as potential candidates for cleanup

as formerly used defense sites are either not eligible for such cleanup or, if

eligible, do not require it according to the Corps. Approximately 2,700

properties are eligible and may have one or more areas with hazards; the

Corps has identified almost 4,500 individual cleanup projects to address

these contaminated properties. According to the Corps’ database, 2,382 of

these projects were considered complete as of the end of fiscal year 2000.

However, over 57 percent of the projects reported as complete were

closed as a result of a study or administrative action without performing

any actual cleanup action. In fact, nearly 800 of these projects were ones

that the Corps initially thought were eligible but later determined were

ineligible, usually because the contamination was caused by other parties

after DOD relinquished control of the properties. The Corps classified

these projects as complete as a way of closing them out. If DOD, in its

annual report to the Congress on the status of its cleanup efforts,

segregated projects that did not require cleanup from those projects where

actual cleanup actions were required, it would provide a more accurate

depiction of cleanup activity and progress. Specifically, our analysis

indicates that the number of projects requiring cleanup would decline by

about a third, and the relative portion of projects completed would drop

from over half of all projects to less than a third. We are therefore making

a recommendation to improve the clarity of DOD’s reporting on the results

of the FUDS cleanup program by excluding from the cleanup list those

projects that were either closed as the result of a study or determined to

be ineligible and by reporting such projects separately. In commenting on

our report, DOD stated that it did not agree with the need to remove such

projects from the list of completed projects but agreed to clarify in future

annual reports that such projects were not cleaned up but were completed

by other means.

The 9,171 potential FUDS properties currently identified are distributed

across every state, the District of Columbia, and six U.S. territories and

possessions. However, certain states have greater concentrations of these

properties than others. For example, 10 states account for almost 52

percent of all potential FUDS properties. Unexploded ordnance and other

explosive wastes may contaminate over 1,600 FUDS properties, of which

about 750 are associated with former military training ranges according to

a recent DOD survey. However, our review of the approximately 850 other

FUDS properties that were not designated by the Corps as training ranges

showed that at least 200 of these properties may be training ranges that

should be included in DOD’s range survey results. To improve the

accuracy of DOD’s range survey, we are making a recommendation that

the Corps review these additional FUDS properties to determine which of

Results in Brief
Page 3 GAO-01-557 Cleanup at Formerly Used Defense Sites

them are former training ranges and should be included in the range

survey results. DOD agreed with this recommendation.

Information on individual potential FUDS properties, by state, and their

locations, type(s) of hazard, and cleanup status is contained in appendix I.

Detailed information on individual cleanup projects at these properties, by

state, is contained in appendix II. Appendixes I and II are available only on

the Internet at http://www.gao.gov/GAO-01-1012SP/.

Identification, investigation, and cleanup of hazardous substances under

DOD’s FUDS program are authorized by the Defense Environmental

Restoration Program (DERP). Such actions must be carried out consistent

with the Comprehensive Environmental Response, Compensation, and

Liability Act of 1980 (CERCLA) as amended by the Superfund

Amendments and Reauthorization Act of 1986 (SARA), which established

DERP. The goals of the program also include the correction of

environmental damage. To fund the program, SARA set up the Defense

Environmental Restoration Account.

DOD has established specific goals for the cleanup of properties, including

FUDS, that have hazardous, toxic, and radioactive wastes in the soil and

water. These goals include having an approved cleanup process in place or

cleanup complete at 100 percent of all such properties by the end of fiscal

year 2014. DOD has not yet set any goals for projects involving hazardous,

toxic, and radioactive waste in containers, unexploded ordnance, other

explosive wastes, or unsafe building demolition.

Total spending for the FUDS cleanup program since fiscal 1984 is $2.6

billion. During the most recent past five fiscal years (1997-2001), annual

program funding for FUDS cleanup averaged about $238 million, with

program funding in fiscal year 2001 of $231 million. The Corps’ estimate of

the additional cost to complete cleanup of the 4,467 currently identified

projects is about $13 billion, not including program management or

support costs or inflation beyond fiscal year 2007. Also omitted from the

estimated cost is a revised cost projection for the cleanup of unexploded

ordnance, which resulted from a recent survey of DOD training ranges.

According to Corps officials, the revised cost projection for ordnance

cleanup would add another $5 billion or more, depending on the level of

cleanup selected, to the estimated cost to complete all FUDS projects. By

the time all projects are completed, the Corps estimates that it will spend

Background
Page 4 GAO-01-557 Cleanup at Formerly Used Defense Sites

at least $15 billion to $20 billion cleaning up FUDS properties.1 At the

current funding level, the Corps does not expect to meet the established

goal of cleaning up FUDS properties with hazardous, toxic, and

radioactive waste by fiscal year 2014, even if work could be deferred on all

other projects, such as containerized wastes, unexploded ordnance, and

building demolition, for which no goals have been established.

In deciding which actions, if any, need to be taken at a potential FUDS

property, the Corps generally follows the process established for cleanup

actions under CERCLA. The process usually includes the following phases:

• Preliminary assessment of eligibility—The Corps determines if the

property is eligible for the FUDS cleanup program based on whether

there are records showing that DOD formerly owned, leased,

possessed, or operated the property or facility.2

 The Corps also

identifies any potential hazard on the property related to DOD

activities. The results of this assessment are detailed in an Inventory

Project Report. If the property is eligible but there is no evidence of

hazards, the property is categorized as requiring “no further action.”

3

• Site inspection—The Corps inspects the site to confirm the presence,

extent, and source(s) of hazards.

• Remedial investigation and feasibility study—The Corps evaluates

the risk associated with the hazard; determines whether cleanup is

needed; and, if so, selects alternative cleanup approaches.

• Remedial action—The Corps designs the remedy, performs the

cleanup, and conducts long-term monitoring if necessary.

 1

This estimate includes inflation only through fiscal year 2007.

2

As defined in Corps guidance, eligible properties are real property that was formerly

owned, leased, possessed by, or otherwise under the jurisdiction of the Secretary of

Defense within the 50 states and other areas over which the United States has jurisdiction.

Eligible projects are those where there is contamination on the eligible property requiring

cleanup, and where DOD has or shares potential responsibility for the hazardous

conditions or is otherwise responsible for cleanup of the site under CERCLA.

3

Beginning with fiscal year 2001, the FUDS program has changed this designation to “no

DOD action indicated” (NDAI) and established subcategories that are relevant to later

phases of the process. However, these changes were not incorporated into the database

until March 2001.
Page 5 GAO-01-557 Cleanup at Formerly Used Defense Sites

When all of these steps have been completed for a given project, or if no

cleanup is needed, the Corps considers the project to be “response

complete.” After all projects at a property are designated as response

complete, the property can then be closed out. Property closeout may

require concurrence by federal or state regulators depending on the type

of hazard involved.

A flow chart showing the decision process in the preliminary assessment

of eligibility phase is shown in figure 1.

Figure 1: Decision Tree Flow Chart for the Preliminary Assessment of Eligibility

Phase

Source: Prepared by GAO based on Army Corps of Engineers data.

Upon completion of the preliminary assessment of eligibility phase, a

property enters the site inspection phase. The site inspection phase

involves a more detailed examination of the property and related records

Is the

property

eligible?

Is the

property

eligible?

Potential FUDS identified Potential FUDS identified

Is there a

potential

hazard?

Is there a

potential

hazard?

Was hazard

caused by

DOD?

Is project

recommended

for action?

Is project

recommended

for action?

No further

 action needed

No further

 action needed

No further 

action needed

No further 

action needed

No DOD 

action needed

No DOD 

action needed

No DOD 

action needed

No DOD 

action needed

Eligible property with approved projects.

Property moves to site inspection phase.

Eligible property with approved projects.

Property moves to site inspection phase.

No

No

No

No

Yes

Yes

Yes

Yes

PropertyEligibility

ProjectEligibility
Page 6 GAO-01-557 Cleanup at Formerly Used Defense Sites

to confirm that a hazard exists and that a cleanup project is required to

remove or reduce the hazard to a safe level. After the site inspection

phase, the Corps conducts a remedial investigation to assess the risk

posed by the hazard and determine if a cleanup is necessary. A feasibility

study is then performed to select a cleanup approach.4

 The Corps develops

more detailed plans for constructing and carrying out the selected cleanup

approach during the remedial design phase. A project next moves into the

remedial action phase5

. The remedial action phase can involve several

steps including constructing or installing the selected cleanup approach,

operating the approach, and long-term monitoring, if necessary.

A flow chart for the site inspection through long-term monitoring process

is shown as figure 2.

 4

For some projects, an engineering evaluation and cost analysis are substituted for the

remedial investigation and feasibility study phase. This phase is omitted for projects that

involve waste in containers or building demolition; instead such projects move directly to

the remedial design phase.

5

In some cases, an interim removal action may be taken if a prompt or time-critical

response is considered necessary.
Page 7 GAO-01-557 Cleanup at Formerly Used Defense Sites

Figure 2: Decision Tree Flow Chart for the Site Inspection Through Long-Term

Monitoring Phases

Source: Prepared by GAO based on Army Corps of Engineers data.

Is action

complete?

Is action

complete?

Site Inspection Site Inspection

Is action

complete?

Is action

complete?

Is monitoring

needed?

Is monitoring

needed?

Yes

No

Yes

Remedial investigation/

feasibility study or engineering

evaluation/cost analysis

Remedial investigation/

feasibility study or engineering

evaluation/cost analysis

Is operation

needed?

Is operation

needed?

Criteria: Contamination not confirmed

and remedial/removal response 

not required

Project considered response complete

Criteria: Contamination not confirmed

and remedial/removal response 

not required

Project considered response complete

Criteria: Hazard below risk-based

standards and remedial/removal response

not required

Project considered response complete

Criteria: Hazard below risk-based

standards and remedial/removal response

not required

Project considered response complete

Criteria: All remedial/removal actions 

taken

Remedial action in place

Project considered response complete

Criteria: All remedial/removal actions 

taken

Remedial action in place

Project considered response complete

Criteria: All remedial actions including

remedial action operations and/or

long term monitoring is completed

Project considered response complete

Criteria: All remedial actions including

remedial action operations and/or

long term monitoring is completed

Project considered response complete

Remedial design/

Remedial action-construction

Remedial design/

Remedial action-construction

Remedial action-operation Remedial action-operation

Yes

No

Yes

Completed

Long-term monitoring Long-term monitoring

No

No

Project Closeout Project Closeout
Page 8 GAO-01-557 Cleanup at Formerly Used Defense Sites

Corps review of potential FUDS properties found that many properties are

ineligible because they are still part of an active DOD installation or there

are no records available showing that DOD ever owned or controlled the

property. Many of the eligible properties did not require cleanup under the

FUDS program because the Corps determined that no DOD-related

hazards existed.

As of October 1, 2000, there were 9,171 properties that had been identified

by the Corps, the states, or other parties as potentially eligible for cleanup

under the FUDS program.6

 Of these properties, 9,055 had received a

preliminary assessment of eligibility, 42 were still being assessed, and 74

properties had not been assessed yet. Based on preliminary assessments,

the Corps determined that 6,746 properties were eligible and that 2,309 of

the properties—more than a quarter of those assessed—were ineligible. In

most cases, properties were ineligible either because the properties were

still under DOD control (915) or because there were no records found

showing that DOD had ever controlled the property (787). Table 1 shows

the reasons that properties were found to be ineligible.

Table 1: Reasons That Potential FUDS Properties Were Ineligible

Reason Properties

Active DOD installation 915

Contaminated by an act of war 4

Defense Plant Corporation property 80

DOD component accepted cleanup responsibility or initiated cleanup 5

Not formerly, used, owned, or controlled by DOD 236

No records 787

Outside U.S. jurisdiction 12

Offshore ordnance property 5

Civil works property 48

Other 79

Excluded properties: cemeteries, recruiting stations, United Service

Organization properties

138

Total 2309

Source: Army Corps of Engineers.

 6

Another 677 properties were identified as potentially eligible but, after further

investigation, were found to be duplicates of properties already on the list. The Corps

maintains these properties on the inventory solely for the purpose of having a record of

what became of them and the amount of money spent on them. Consequently, we have

excluded these properties from our analysis.

Most Potential FUDS

Properties Are

Ineligible or Do Not

Require Cleanup

Many Potential FUDS

Properties Are Ineligible

Because DOD’s Presence

Is Either Ongoing or Not

Proven
Page 9 GAO-01-557 Cleanup at Formerly Used Defense Sites

Although the Corps initially found that 6,746 properties were eligible for

cleanup, the Corps subsequently determined, on the basis of site

inspections, that most of these properties do not require cleanup after all.

Specifically, the Corps determined that 4,070 properties either do not have

any hazards requiring DOD cleanup or else have hazards that do not meet

the level requiring cleanup.7

 Hazards requiring cleanup were found on

2,676 of the eligible properties. Figure 3 shows the breakout of properties

by eligibility and those where hazards were found.

Figure 3: Breakout of 9,171 Potentially Eligible FUDS Properties

Source: GAO’s analysis of data provided by the Army Corps of Engineers.

The Corps identified 4,467 distinct projects requiring cleanup at the 2,676

properties that were identified as having hazards needing cleanup. At 25 of

 7

The Corps makes its determination that no contamination or other hazards exist that

require cleanup by the Corps without input from state or federal regulatory agencies, which

may not agree. Such determinations are called “no further action.” According to Corps

officials, these determinations do not mean that action may not be required by other,

subsequent users or owners of the properties to clean up contamination they caused. Corps

officials emphasize that they are willing to reconsider the “no further action”

determinations if evidence of contamination caused by DOD is found.

Most of the Eligible

Properties Do Not Require

Cleanup
Page 10 GAO-01-557 Cleanup at Formerly Used Defense Sites

these properties, no specific projects have been identified as yet. However,

after further investigation the Corps determined that projects identified at

405 properties were ineligible because other outside parties were

responsible for contaminating the properties after DOD relinquished

control. At another 33 properties, the identified projects were not

recommended for further action or were not approved. The reasons for

not recommending a project for further action or not approving a project

varied. For example, the current landowner might have refused access to

the property or might have already addressed the problem. The remaining

2,213 eligible properties had 3,736 projects requiring investigation and

cleanup.

Of these projects, 284 were not yet scheduled for action, 1,844 projects

were under way or planned, and 1,608 were completed. Figure 4 depicts

the status of FUDS projects with hazards that required cleanup actions.
Page 11 GAO-01-557 Cleanup at Formerly Used Defense Sites

Figure 4: Status of 3,736 FUDS Cleanup Projects

Source: GAO’s analysis of data provided by the Army Corps of Engineers.

DOD reports on the status of its various environmental cleanup programs

in an annual report to the Congress. However, as of the date of this report,

DOD had not yet released its report for fiscal year 2000—the most recently

completed fiscal year. According to the Corps’ FUDS database, there were

2,382 completed FUDS projects as of the end of fiscal year 2000, or about

53 percent of the nearly 4,500 FUDS projects that required cleanup.8

 The

completed projects figure includes those removed from the active

inventory either as a result of a study or an administrative action or as the

result of an actual cleanup action such as removing toxic wastes or

treating contaminated groundwater. In fact, our analysis showed that over

57 percent of the projects reported as complete did not require any actual

cleanup and were reported as complete on the basis of a study or an

administrative decision. For example, 183 of the 205 unexploded ordnance

projects reported as complete were closed based on a study, while only 22

required an actual cleanup phase. Further, the completed figure includes

774 projects that were ineligible for cleanup as part of the FUDS program.

The Corps initially thought that these projects were eligible but later

 8

The Corps database is updated frequently as new information on properties and projects

becomes available. Accordingly, there can be some differences in the numbers discussed in

various documents depending on when the information was obtained. Such differences are

not material in the short term.

DOD Reporting on FUDS

Program Status Can Be

Misleading
Page 12 GAO-01-557 Cleanup at Formerly Used Defense Sites

determined that they were ineligible because the contamination was

caused by other parties after DOD relinquished control of the properties.

The Corps made an administrative decision to classify these projects as

“response complete” to remove them from its tracking system. If only the

number of projects actually believed to require cleanup—3,148—was used

as the basis for calculating cleanup progress, then only 1,020 projects or

about 32 percent of those requiring cleanup have actually been cleaned up.

Further, according to Corps officials, most of the projects cleaned up to

date were the least complex and least expensive ones, such as removing

underground storage tanks (668 completed projects) or demolishing

buildings (198 completed projects). On the other hand, many of the

remaining cleanup projects are high cost and technologically difficult.

Consequently, cleanup of the approximately 2,100 remaining projects will

require at least $13 billion9

 (revised estimates may raise this to $18 billion

or more) and take more than 70 years to complete based on current

planned funding of about $200 million per year. According to Corps

officials, reporting of completed FUDS projects follows DOD’s reporting

policies for all its environmental cleanup areas such as base closures and

active installations.

The more than 9,000 properties identified as potential candidates for

cleanup as FUDS are distributed across every state, the District of

Columbia, and six U.S. territories and possessions.10 However, there are

large concentrations of potential FUDS properties in certain states. For

example, 10 states account for almost 52 percent of all the properties,

while 27 states have more than 100 properties each and represent over 81

percent of all the properties. Figure 5 shows the geographic distribution of

potential FUDS properties.

 9

This estimate includes inflation only through fiscal year 2007.

10The territories and possessions are American Samoa, Guam, the Northern Mariana

Islands, Palau, Puerto Rico, and the U.S. Virgin Islands.

Geographic

Distribution and

Status of Potential

FUDS Properties
Page 13 GAO-01-557 Cleanup at Formerly Used Defense Sites

Figure 5: Distribution of 9,171 Potential FUDS Properties

Source: GAO’s analysis of data provided by the Army Corps of Engineers.

Unexploded ordnance and other explosive wastes were believed to

contaminate over 1,600 FUDS properties, of which 753 were associated

with former training ranges according to a recent DOD survey. Our review

of the over 800 properties not designated as training ranges in DOD’s

survey results showed that there may be 200 or more additional properties

with training ranges that should be included in DOD’s range survey results.

AK

599

HI

377

AL

171

AR

82

AZ

262

CA DC 55

1088

CO

93

CT 54

DE 34

FL

647

GA

229

IA

34

ID

75

IL

156

IN

73

KS

123

KY

24

LA

87

MA 279

MD 102

NJ 175

ME

177

MI

171

MN

76

MO

88

MS

193

MT

107

NC

182

ND

66

NE

101

NH 28

VT 12

NM

240

NV

70

NY

484

OH

91

OK

111

OR

115

PA

164

RI 74

SC

206

SD

91

TN 66

WA

323

UT

55 VA

278

TX

404

WY

70

WV

26

WI

68

American Samoa 30

Guam 48

Northern Mariana Islands 33

Palau 14

Puerto Rico 79

U.S. Virgin Islands 11

< 100 properties

100-199 properties

200 + properties
Page 14 GAO-01-557 Cleanup at Formerly Used Defense Sites

As discussed previously, most of the 9,171 potential FUDS are either

ineligible for the cleanup program (2,309 properties) or do not require any

environmental cleanup (4,070 properties) according to assessments made

by the Corps; 116 properties were still being reviewed for eligibility and

potential hazards. The remaining 2,676 properties were found to have

sufficiently high levels of hazards to require cleanup. Of these, 463

properties were excluded because other parties were deemed responsible

for the hazard (405 properties), or because no specific project had been

identified as yet (25 properties), or because no projects had been

identified or approved for further action (33 properties). Table 2

summarizes the eligibility status of the potential FUDS by geographic

location.

Table 2: Eligibility and Status of 9,171 Potential FUDS Properties by Geographic Location

Eligibility status Eligible property hazards Property status

State

Potential

FUDS

Still under

reviewa

Ineligible

property

Eligible

property

No hazards

found

Potential

hazards

found Otherb

Properties

requiring

cleanup

AK 599 33 49 517 391 126 17 109

AL 171 2 48 121 97 24 6 18

AR 82 0 5 77 64 13 1 12

AZ 262 0 72 190 105 85 26 59

CA 1088 19 300 769 397 372 65 307

CO 93 0 47 46 16 30 4 26

CT 54 0 9 45 23 22 5 17

DC 55 1 5 49 22 27 0 27

DE 34 0 3 31 20 11 2 9

FL 647 9 149 489 339 150 59 91

GA 229 0 85 144 100 44 18 26

HI 377 0 74 303 233 70 2 68

IA 34 0 9 25 12 13 1 12

ID 75 4 15 56 44 12 3 9

IL 156 1 40 115 53 62 8 54

IN 73 1 21 51 34 17 0 17

KS 123 0 10 113 44 69 1 68

KY 24 0 7 17 13 4 1 3

LA 87 0 16 71 55 16 2 14

MA 279 3 36 240 129 111 31 80

MD 102 1 22 79 37 42 11 31

ME 177 21 26 130 67 63 13 50

MI 171 1 68 102 38 64 8 56

MN 76 0 8 68 48 20 3 17

MO 88 0 9 79 53 26 0 26

MS 193 0 67 126 93 33 7 26

Eligibility and Status of

Potential FUDS by

Geographic Location
Page 15 GAO-01-557 Cleanup at Formerly Used Defense Sites

Eligibility status Eligible property hazards Property status

State

Potential

FUDS

Still under

reviewa

Ineligible

property

Eligible

property

No hazards

found

Potential

hazards

found Otherb

Properties

requiring

cleanup

MT 107 1 55 51 34 17 4 13

NC 182 0 86 96 60 36 4 32

ND 66 0 52 14 10 4 0 4

NE 101 0 31 70 15 55 6 49

NH 28 0 3 25 14 11 0 11

NJ 175 0 60 115 71 44 8 36

NM 240 0 17 223 85 138 3 135

NV 70 7 5 58 27 31 12 19

NY 484 0 215 269 172 97 11 86

OH 91 1 21 69 43 26 1 25

OK 111 0 4 107 54 53 8 45

OR 115 0 16 99 72 27 2 25

PA 164 1 32 131 62 69 27 42

RI 74 0 6 68 26 42 10 32

SC 206 2 126 78 47 31 7 24

SD 91 0 40 51 18 33 2 31

TN 66 0 26 40 23 17 8 9

TX 404 0 42 362 195 167 28 139

UT 55 1 13 41 24 17 0 17

VA 278 3 111 164 125 39 3 36

VT 12 0 4 8 2 6 1 5

WA 323 3 35 285 227 58 5 53

WI 68 0 16 52 27 25 1 24

WV 26 0 10 16 6 10 3 7

WY 70 0 36 34 12 22 2 20

ASc30 0 1 29 21 8 0 8

CNc 33 1 6 26 4 22 0 22

GMc48 0 8 40 22 18 2 16

PRc79 0 19 60 37 23 10 13

PTc14 0 12 2 2 0 0 0

VIc11 0 1 10 6 4 1 3

Total 9,171 116 2,309 6,746 4,070 2,676 463 2,213

a

Includes 74 properties where the preliminary assessments were not completed and 42 properties

where the preliminary assessments were completed but eligibility was not yet determined.

b

Includes 405 properties where other parties were deemed responsible for the hazard, 25 properties

where no projects were identified yet, and 33 properties where the identified projects were not

recommended or not approved to go forward.

c

American Samoa (AS), the Northern Mariana Islands (CN), Guam (GM), Palau (PT), Puerto Rico

(PR), the U.S. Virgin Islands (VI).

Source: Army Corps of Engineers.
Page 16 GAO-01-557 Cleanup at Formerly Used Defense Sites

For the remaining 2,213 properties, a total of 3,736 projects were identified

and approved for further action. The status of these projects varies from

those that were only recently identified and have had no cleanup action

taken as yet to those that are completed.

Information on individual properties, by state, including the property

name, location, congressional district, eligibility, existence of hazards,

number of eligible projects, estimated costs incurred to date, and

estimated cost to complete cleanup is contained in appendix I.

Information on individual projects, by state, including the property name,

location, congressional district, project number, type(s) of hazard, risk

level, status of cleanup, cleanup remedy used, costs incurred to date, and

estimated cost to complete cleanup is contained in appendix II. These

appendixes are available only on the Internet at http://www.gao.gov/GAO01-1012SP/.

In response to the Senate Armed Service’s Committee direction to develop

more complete information on the estimated cost to conduct

environmental cleanup at training ranges, DOD conducted a survey of

training ranges at its active, closing, and closed facilities to determine

which ones might contain unexploded ordnance.11 Because DOD does not

have a complete inventory of its training ranges, the amount of funding

necessary to clean up training ranges has been unreliable and is believed

to be significantly understated.12 DOD’s survey results indicated that 753

FUDS properties that might contain unexploded ordnance should be

classified as training ranges. For a variety of reasons, over 800 FUDS

properties were not included in DOD’s survey. Many of these properties

were excluded because the Corps had previously decided that, although

there might be unexploded ordnance or other explosive wastes present, no

further action was needed to address the hazards at these properties. We

reviewed basic information about these properties, such as the name of

the property and the project description, to see if there could be additional

ranges not reported as part of DOD’s survey. For example, if a project with

ordnance or explosive wastes was located at property that was named

“Bombing Range” or “Bombing Target” or was described as an ordnance or

explosive wastes cleanup project at a bombing range or bombing target,

 11Senate Report on the National Defense Authorization Act for Fiscal Year 2000 (S. Rep.

No. 106-50, May 17, 1999).

12Environmental Liabilities: DOD Training Range Cleanup Cost Estimates Are Likely

Understated (GAO-01-479, Apr. 2001).

DOD’s Range Survey May

Not Include All FUDS

Ranges
Page 17 GAO-01-557 Cleanup at Formerly Used Defense Sites

we concluded that these properties were likely training ranges. We found

over 200 properties that could be ranges based on such criteria.

DOD’s annual report on the status of its environmental restoration

activities can provide a misleading picture of FUDS program

accomplishments. In its annual report, DOD accounts of completed

projects include projects that were determined to be ineligible or that did

not involve any actual cleanup effort, as well as projects that required

actual cleanup actions to complete. As a result, it appears that after 15

years and expenditures of $2.6 billion, over 50 percent of the FUDS

projects have been completed. In reality, only about 32 percent of those

projects that required actual cleanup actions have been completed, and

those are the cheapest and least technologically challenging. The Corps

estimates that the remaining projects will cost over $13 billion and take

more than 70 years to complete. The Corps’ reporting of completed FUDS

projects reflects DOD’s reporting policies for all of its environmental

cleanup programs, including those at closing bases and active

installations. As such, progress on those cleanup programs may not be

accurately pictured either.

In addition, DOD’s range survey did not include all FUDS properties that

may contain unexploded ordnance and could be former training ranges.

Consequently, DOD’s inventory of FUDS training ranges is likely

incomplete, and its estimated cost to clean up these ranges is likely

understated.

The Secretary of Defense should clarify DOD’s reporting of the cleanup

progress at FUDS and for other DOD cleanup activities by excluding

projects from its “completed” list that were closed solely as a result of a

study or administrative action and did not require actual cleanup. Such

projects should instead be reported as eligible properties where a hazard

either was not found or did not require cleanup because it was below the

threshold level or because it resulted from another party’s actions.

Similarly, DOD’s annual report should exclude projects from its

“completed” list that were determined to be ineligible for cleanup under

the FUDS program.

To improve the accuracy of DOD’s FUDS training range survey results and

its estimate of the costs related to environmental cleanup at these ranges,

the Secretary of Defense should direct the Corps to review the FUDS

properties that were excluded in DOD’s initial survey to determine if any

are training ranges that should be included in the survey.

Conclusions

Recommendations
Page 18 GAO-01-557 Cleanup at Formerly Used Defense Sites

DOD provided oral comments that generally agreed with the need to

clarify reporting on the status of the FUDS program and to review the

unexploded ordnance projects that were excluded from its initial training

range survey. DOD did not agree with the need to exclude from the list of

completed projects those projects closed either as the result of a study or

because they were determined to be ineligible. However, DOD did agree

that it needs to clarify in future annual reports to the Congress that the

restoration efforts on some projects were completed with a study phase

and not a cleanup action. DOD did not specifically address how it would

report on the ineligible projects that were being reported as completed.

DOD also provided a number of technical comments and clarifications

related to specific numbers and dollar figures in the report, which we

addressed as appropriate in the body of the report.

The scope of this review encompassed all potentially eligible properties

included in DOD’s FUDS inventory as of the end of fiscal year 2000.

To obtain information on the number of potential FUDS properties that

are eligible and require or have required cleanup and on the geographic

distribution, by state, of FUDS properties, we relied primarily on the Corps

database of FUDS properties.

To obtain information on those FUDS properties that contain or contained

ordnance and other explosive wastes, we also relied on the Corps

database of FUDS properties and on a database constructed by the Corps

to respond to DOD’s range survey. We then compared those databases to

determine which properties were included as part of the range survey and

which were not. For those that were not included, we reviewed the

property name and project description information to determine if there

were additional properties that could be ranges based on these

descriptors.

The data in this report represent a static point in time—the end of fiscal

year 2000. The Corps database of FUDS properties is used by the Corps on

a daily basis to plan, schedule, and monitor the FUDS program, so there

are constant changes and updates. Consequently, the numbers presented

in this report may vary somewhat from other published sources; however,

such variations represent the changing status of individual properties and

projects, not material changes in the overall program status. On an overall

level and as a measure of the FUDS program’s scope and efforts, we

believe that these data represent a reasonable picture of the program at

the end of fiscal year 2000.

Agency Comments

and Our Evaluation

Scope and

Methodology
Page 19 GAO-01-557 Cleanup at Formerly Used Defense Sites

The Corps database of FUDS properties incorporates data from a previous

Corps effort that did not contain all of the various categories of data in the

current database. Consequently, for some properties and projects,

particularly those that are no longer active, some information is dated and

may not reflect current property conditions. We reviewed the Corps’

policies and procedures to verify the reliability of these data and found

them to be reasonably accurate for our use. To the extent that we found

material errors in the data, we worked with the Corps to correct those

errors. We did not, however, attempt to independently assess the

reliability of the data.

We also acquired and reviewed program documents and interviewed

Corps officials from headquarters, division, and district offices to obtain

information about the FUDS program. We did not ask state officials to

verify or confirm the Corps data for this review. We also contacted DOD

and Environmental Protection Agency officials about aspects of the FUDS

program.

We conducted our review from November 2000 through May 2001 in

accordance with generally accepted government auditing standards.

As arranged with your offices, unless you publicly announce the contents

of this report earlier, we plan no further distribution of it until 30 days

from the date of this letter. We will then send copies to the Secretary of

Defense; the Director, Office of Management and Budget; the appropriate

congressional committees; and other interested parties. We will also

provide copies to others on request.

If you or your staff have any questions regarding this report, please call me

or Edward Zadjura on (202) 512-3841. Key contributors to this assignment

were Patricia Foley-Hinnen; Susan Irwin; Arthur James, Jr.; Robert Kigerl;

and Cynthia Norris.

(Ms.) Gary L. Jones

Director, Natural Resources and Environment
Appendix I: Properties Identified for

Potential Inclusion in the FUDS Cleanup

Program

Page 20 GAO-01-557 Cleanup at Formerly Used Defense Sites

Appendix I contains summary data on all 9,171 properties identified for

potential inclusion in the FUDS cleanup program. The properties are listed

by state, the District of Columbia, and six U.S. territories and possessions.

For each property, the data include the property name, Corps’ property

number, the county and congressional district where the property is

located, the eligibility status, and whether hazards are present. Also

included for eligible properties with hazards are the number of eligible

cleanup projects, the actual cleanup-related costs incurred to date, and the

estimated cost to complete the cleanup projects. All information is

reported as of the end of fiscal year 2000.

Appendix I is available only on the Internet at http://www.gao.gov/

GAO-01-1012SP/.

Appendix I: Properties Identified for

Potential Inclusion in the FUDS Cleanup

Program
Appendix II: Cleanup Projects on FUDS

Properties

Page 21 GAO-01-557 Cleanup at Formerly Used Defense Sites

Appendix II contains summary data on the 2,213 eligible properties with

hazards that have cleanup projects. The projects are listed by state, the

District of Columbia, and six U.S. territories and possessions. For each

project, the data include the property name, the Corps’ property number,

county and congressional district where the property is located, the Corps’

project number, the type of hazard on the property, and the risk posed by

the hazard. In addition, information is provided on whether or not the

project has been scheduled to begin, is planned or under way, or has been

completed, with actual or estimated dates for commencement and

completion. The type of cleanup remedy selected for the project is also

indicated. Finally, the actual cleanup-related cost incurred to date and the

estimated cost to complete each project are provided. All information is

reported as of the end of fiscal year 2000.

Appendix II is available only on the Internet at http://www.gao.gov/

GAO-01-1012SP/.

Appendix II: Cleanup Projects on FUDS

Properties

(360010)

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