a

GAO

United States General Accounting Office

Report to the Honorable John D. Dingell 

Ranking Minority Member, Committee on 

Energy and Commerce, House of 

Representatives

December 2003 MILITARY 

MUNITIONS

DOD Needs to 

Develop a 

Comprehensive 

Approach for Cleaning 

Up Contaminated 

Sites

GAO-04-147
www.gao.gov/cgi-bin/getrpt?GAO-04-147.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Anu K. Mittal at 

(202) 512-3841 or mittala@gao.gov. 

Highlights of GAO-04-147, a report to the 

Honorable John D. Dingell, Ranking 

Minority Member, Committee on Energy 

and Commerce, House of Representatives 

December 2003

MILITARY MUNITIONS

DOD Needs to Develop a Comprehensive 

Approach for Cleaning Up Contaminated 

Sites 

DOD has made limited progress in its program to identify, assess, and clean 

up sites that may be contaminated with military munitions. While DOD had 

identified 2,307 potentially contaminated sites as of September 2002, DOD 

officials said that they continue to identify additional sites and are not likely 

to have a firm inventory for several years. Of the identified sites, DOD had 

initially determined that 362 sites required no further study or cleanup action 

because it found little or no evidence of military munitions. For 1,387 sites, 

DOD either has not begun or not completed its initial evaluation or 

determined that further study is needed. DOD has completed its assessment 

of 558 sites, finding that 475 of these required no cleanup action. The 

remaining 83 sites required some cleanup action, of which DOD has 

completed 23. 

DOD does not yet have a complete and viable plan for cleaning up military 

munitions at remaining potentially contaminated sites. DOD’s plan is lacking 

in several respects, including the following:

• Essential data for DOD’s plan may take years to develop. Not all the 

potential sites have been identified, and DOD has set no deadline for 

doing so. Also, DOD intends to use a new procedure to assign a relative 

priority for the remaining 1,387 sites, but it will not complete the 

reassessments until 2012. Until these are done, DOD cannot be assured 

that it is using its limited resources to clean up the riskiest sites first. 

• DOD’s plan relies on preliminary cost estimates that can change greatly 

and the reallocation of funds that may not be available. For example, the 

Air Force used estimated, not actual, acreage to create its cost estimates, 

limiting the estimate’s reliability and DOD’s ability to plan and budget 

cleanup for these sites. Also, DOD expects additional funds will become 

available for munitions cleanup as other DOD hazardous waste cleanup 

efforts are completed. However, some of these efforts are behind 

schedule; therefore, funds may not become available as anticipated. 

• DOD’s plan does not contain goals or measures for site assessment and 

cleanup. DOD recently established a working group tasked with 

developing agencywide program goals and performance measures, but 

not service-specific targets, limiting DOD’s ability to ensure that the 

services are making progress in cleaning the potentially contaminated 

sites and achieving the overall goals of the program as planned. 

Unexploded Military Munition 

Over 15 million acres in the United 

States are suspected of being, or 

known to be, contaminated with 

military munitions. These sites 

include ranges on closing military 

installations, closed ranges on 

active installations, and formerly 

used defense sites. Under the 

Defense Environmental 

Restoration Program, established 

in 1986, the Department of Defense 

(DOD) must identify, assess, and 

clean up military munitions 

contamination at these sites. DOD 

estimates these activities will cost 

from $8 billion to $35 billion. 

Because of the magnitude of DOD’s 

cleanup effort, both in terms of 

cost and affected acreage, as well 

as the significant public safety, 

health, and environmental risks 

that military munitions may pose, 

you asked us to evaluate (1) DOD’s 

progress in implementing its 

program to identify, assess, and 

clean up military munitions sites 

and (2) DOD’s plans to clean up 

remaining sites in the future. 

We are recommending that DOD 

develop a comprehensive approach 

by revising its plan to (1) establish 

deadlines for completing its site 

inventory and initial evaluations, 

(2) reassess the timetable proposed 

for completing its risk assessment 

reevaluations, and (3) establish 

service-specific targets. We are 

also recommending that after DOD 

revises its plan, it should work with 

the Congress to develop budget 

proposals that will allow timely 

completion of cleanup activities. 
Page i GAO-04-147 Military Munitions

Contents

Letter 1

Results in Brief 4

Background 6

DOD Has Made Limited Progress in Its Program to Identify, Assess, 

and Clean Up Potentially Contaminated Sites 8

DOD Does Not Have a Complete and Viable Plan for Assessing and 

Cleaning Up Potentially Contaminated Sites 14

Conclusions 18

Recommendations 19

Agency Comments 19

Appendixes

Appendix I: Safety, Environmental, and Human Health Risks 22

Appendix II: Additional Details on Our Scope and Methodology 25

Appendix III: Comments from the Department of Defense 27

Appendix IV: GAO Contacts and Staff Acknowledgments 30

GAO Contacts 30

Acknowledgments 30

Tables Table 1: Distribution of Military Munitions Response Program Sites 

by Service 8

Table 2: Munitions Constituents of Greatest Concern 23

Table 3: Potential Effects of the Munitions Constituents Closely 

Associated with Military Munitions 24

Table 4: Districts Visited during Review 25

Figures Figure 1: Distribution of 2,307 Suspected Military Munitions 

Response Program Sites Identified by DOD 10

Figure 2: Military Munitions Response Program Site Inventory 

(2,307 Sites) 11

Figure 3: Military Munitions Response Program Sites Requiring 

Further Action 12

Figure 4: Examples of Cleanup Actions at Military Munitions 

Response Program Sites 13
Contents

Page ii GAO-04-147 Military Munitions

Abbreviations

DOD Department of Defense

Corps U.S. Army Corps of Engineers

CERCLA Comprehensive Environmental Response, Compensation,

and Liability Act of 1980

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Page 1 GAO-04-147 Military Munitions

United States General Accounting Office

Washington, D.C. 20548

A

December 19, 2003 Letr

The Honorable John D. Dingell

Ranking Minority Member

Committee on Energy and Commerce

House of Representatives

Dear Mr. Dingell:

Over 15 million acres in the United States are known to be or are suspected 

of being contaminated with military munitions, which include unexploded 

ordnance, discarded military munitions, and munitions constituents such 

as propellants or other chemicals.1 These sites, which are no longer in use, 

include closed ranges on active installations, ranges on military 

installations that are being closed (closing sites), and formerly used 

defense sites.2

 Much of the land on which these sites are located has been 

or will be converted to nonmilitary uses such as farming, residential or 

commercial development, and recreation. The Department of Defense 

(DOD) estimates that identifying, assessing, and cleaning up contamination 

from military munitions at such sites will cost from $8 billion to $35 billion 

and could take more than 75 years. Within DOD, cleanup of sites on active 

or closing installations is the responsibility of the military service—Air 

Force, Army, Navy, or Marine Corps—that currently owns the land. The 

U.S. Army Corps of Engineers (Corps) is responsible for executing the 

cleanup of formerly used defense sites. 

Military munitions can pose risks to public safety, human health, and the 

environment. Unexploded ordnance poses a potential explosive hazard and 

risk of personal injury to those who encounter it. The Environmental 

Protection Agency, in September 2001, using a DOD database and other 

sources, identified at least 126 incidents involving civilians who were

1

Unexploded ordnance, discarded military munitions, and munitions constituents are 

hereafter referred to as “military munitions” for the purpose of this report. Unexploded 

ordnance includes ordnance primed and fired but remain unexploded. For a more complete 

definition, see the National Defense Authorization Act for Fiscal Year 2004, Pub. L. No. 108-

136, section 1042 (a)(2).

2

A formerly used defense site is a property that Department of Defense (DOD) formerly 

owned, leased, possessed, operated, or otherwise controlled, and was transferred from 

DOD prior to October 17, 1986.
Page 2 GAO-04-147 Military Munitions

exposed to unexploded ordnance over the past 83 years, which resulted in 

65 fatalities and 131 injuries.3

 The risk of such exposures is expected to 

grow with an increase in development and recreational activities on land 

once used by the military for munitions related activities (e.g., live fire 

testing and training). In addition, human exposure to munitions 

constituents such as trinitrotoluene (TNT) and perchlorate may cause longterm health problems, such as cancer and damage to the heart, liver, and 

kidneys. However, the link between such constituents and any potential 

health effects is not always clear and continues to be studied. (See app. I 

for a list of common munitions constituents and potential health effects.) 

Military munitions may also pose an environmental risk because their use 

and disposal may release constituents that could contaminate soil, 

groundwater, and surface water. Former ranges on which munitionsrelated activities were conducted and which are known or suspected to 

contain military munitions are in a variety of locations, including near 

ecologically sensitive wetlands, surface waters, and floodplains. While 

many constituents have been an environmental concern to DOD for more 

than 20 years, the current understanding of the causes, distribution, and 

potential impact of constituent releases into the environment remains 

limited. The nature of these impacts, and whether they pose an 

unacceptable risk to human health and the environment, depend upon the 

dose, duration, and pathway of exposure, as well as the sensitivity of the 

exposed populations. Until recently, DOD has focused primarily on 

mitigating the public safety risk associated with unexploded ordnance, but 

it is now giving additional attention to environmental and health concerns 

posed by munitions constituents.

Under the Defense Environmental Restoration Program, established in 

1986, DOD is required to identify, investigate, and clean up environmental 

contamination and other hazards at active and closing installations, as well 

as at formerly used defense sites.4

 The program is organized into three 

categories that focus on DOD’s primary goals: (1) identification and 

cleanup of contamination from hazardous substances, pollutants, and 

contaminants; (2) demolition and removal of unsafe buildings and 

3

U.S. Environmental Protection Agency, Office of Solid Waste, Permits and State Programs 

Division, UXO Incident Report (Revision 1), (Washington, D.C., 2001).

4

The Defense Environmental Restoration Program was established by section 211 of the 

Superfund Amendments and Reauthorization Act of 1986, which amended the 

Comprehensive Environmental Response, Compensation, and Liability Act of 1980 

(CERCLA).
Page 3 GAO-04-147 Military Munitions

structures; and (3) correction of other environmental damage, such as 

detection and disposal of military munitions. Most of DOD’s past focus had 

been on identifying and cleaning up contamination from hazardous 

substances. To better focus DOD’s efforts on identifying, assessing, and 

cleaning up sites containing military munitions, DOD established the 

Military Munitions Response program in September 2001. Subsequently, in 

December 2001, the Congress passed the National Defense Authorization 

Act for Fiscal Year 2002, which among other things, required DOD to 

develop an initial inventory of sites that are known or suspected to contain 

military munitions and a comprehensive plan for cleaning up these sites. Of 

the $1.9 billion budgeted by DOD for environmental cleanup in fiscal year 

2002, approximately $113 million was designated for sites with military 

munitions. In fiscal years 2003 and 2004, DOD designated approximately 

$115 million and $89 million, respectively, for sites with military munitions. 

In deciding what actions, if any, are needed to clean up a site identified as 

potentially contaminated with military munitions, DOD generally follows 

the process established for cleanup actions under the Comprehensive 

Environmental Response, Compensation, and Liability Act of 1980 

(CERCLA). CERCLA, as amended, governs the cleanup of hazardous waste 

sites, including contamination on military installations. After identifying a 

potential military munitions site, the appropriate DOD military service or 

the Corps performs a preliminary assessment, during which DOD 

determines if military munitions may be present and if further study or 

cleanup action is needed. If necessary, DOD may conduct a site 

investigation to better identify the types and extent of potential hazards 

present. For specific areas suspected to contain military munitions, DOD 

surveys the land and evaluates and selects alternatives, in consultation 

with stakeholders, for addressing the potential hazards. These cleanup 

alternatives could include removing the military munitions, limiting public 

contact with the site through signs and fences, or determining that no 

further action with regard to the site is warranted. After implementing the 

chosen cleanup alternative, DOD periodically monitors the site and reviews 

the alternative chosen to ensure its continued effectiveness.

Because of the magnitude of DOD’s cleanup effort, both in terms of cost 

and affected acreage, as well as the significant public safety, human health, 

and environmental risks posed by military munitions, you asked us to 

evaluate (1) DOD’s progress in implementing its program to identify, 

assess, and clean up sites containing military munitions and (2) DOD’s 

plans to clean up remaining sites in the future.
Page 4 GAO-04-147 Military Munitions

To evaluate DOD’s progress in identifying, assessing, and cleaning up 

military munitions, we reviewed and analyzed DOD’s database for sites 

identified under the Military Munitions Response program as of September 

30, 2002, the end of their most recent reporting cycle. We assessed the 

reliability of relevant fields in this database by electronically testing for 

obvious errors in accuracy and completeness, reviewing information about 

the data and the system that produced them, and interviewing agency 

officials knowledgeable about the data. When we found inconsistencies, we 

worked with DOD and military service officials to correct the discrepancies 

before conducting our analyses. We determined that the data needed for 

our analyses were sufficiently reliable for the purposes of our report. We 

also reviewed project files from 38 of the 75 sites where, according to 

DOD’s database, cleanup action is either complete or under way.5

 These 

files represented 52 percent of the 23 sites with a completed cleanup action 

and 50 percent of the 52 sites with a cleanup action under way. We used our 

file reviews to develop case examples of changes in estimated costs to 

complete cleanup over time and cleanup actions taken. These case 

examples are for illustration only. We conducted our work between 

November 2002 and October 2003 in accordance with generally accepted 

government auditing standards. More detail on the scope and methodology 

of our review is presented in appendix II. 

Results in Brief DOD has made limited progress in its program to identify, assess, and clean 

up sites that may be contaminated with military munitions. While DOD had 

identified 2,307 potentially contaminated sites as of September 2002, DOD 

officials said that the department is continuing to identify additional sites 

and is not likely to have a firm inventory for several years. For example, the 

Army had only surveyed and identified closed ranges on 14 percent of its 

active installations. Of the total 2,307 identified sites, DOD had initially 

determined that 362 sites required no further study or cleanup action 

because there was little or no evidence of military munitions. However, 

because these sites are formerly used defense sites, and the initial 

evaluations conducted were less comprehensive than for other sites in the 

program, the Corps has recently decided that some of these sites need to be 

reassessed to determine if cleanup is needed. For 1,387 sites, DOD either 

has not begun or not completed its initial evaluation or has determined that 

further study is needed. DOD has completed its assessment of 558 sites, 

5

There are an additional eight sites for which cleanup action is planned, but not yet begun. 

These sites were not included in our file review process.
Page 5 GAO-04-147 Military Munitions

finding that 475 sites required no cleanup action. The remaining 83 sites 

required some cleanup action, of which DOD has completed 23.

DOD does not yet have a complete and viable plan for guiding its remaining 

clean up activity at potentially contaminated sites. DOD’s plan is lacking in 

several respects, including the following:

• Essential data for DOD’s plan may take years to develop. For example, 

not all the potential sites have been identified, and DOD has set no 

deadline for doing so. Because the inventory serves as the basis for 

other elements of the plan, such as budget development, the sites must 

first be identified before DOD can have a reasonable picture of the 

magnitude of the challenge ahead and plan accordingly. Furthermore, 

DOD intends to use new procedures to reassess the relative risk for the 

1,387 sites needing further study, but DOD is not scheduled to complete 

these reassessments until 2012. The resulting relative risk assessments 

will be a key component in determining cleanup priorities. Until the 

assessments are complete, DOD cannot be assured that it is using its 

limited resources to clean up those sites that pose the greatest risk to 

public safety, human health, and the environment.

• DOD’s plan relies on preliminary cost estimates that may change 

significantly and reallocated funds from other programs that may not be 

available as anticipated. For example, at Camp Maxey, Texas, the 

estimated cost for cleanup in 2000 was $45 million. However, in DOD’s 

Fiscal Year 2002 Defense Environmental Restoration Program Annual 

Report to Congress, the estimated cleanup cost had grown to $130 

million. A June 2003 cost estimate showed a decrease in total costs to 

$73 million. Furthermore, DOD expects that as other DOD hazardous 

substance cleanup efforts are completed, increased funds will become 

available for munitions cleanup. However, not all of these other DOD 

cleanup efforts are on schedule. For example, between fiscal years 2001 

and 2002, the schedule to complete hazardous, toxic, and radioactive 

waste cleanup at formerly used defense sites had slipped by more than 6 

years. As a result, anticipated funds from completing cleanups at these 

sites may not become available until 2021 or later. 

• DOD’s plan does not yet contain goals or measures for site assessment 

and cleanup. In September 2003, 2 years after the establishment of the 

Military Munitions Response program, DOD established a working 

group tasked with developing agencywide program goals and 

performance measures. However, the working group is not expected to 
Page 6 GAO-04-147 Military Munitions

establish service-specific targets, therefore DOD will have limited 

assurance that the services and the Corps are (1) making progress in 

cleaning their Military Munitions Response program sites and (2) are 

contributing to achieving the overall goals of the program as planned. 

We are recommending that DOD revise its plan to (1) establish deadlines 

for completing its site inventory and initial evaluations; (2) reassess the 

timetable proposed for completing its reevaluation of sites, using the new 

risk assessment procedures; and (3) establish interim goals based on 

criteria, such as relative risk levels or cleanup phases, for the services and 

the Corps to target. We are also recommending that after DOD revises its 

comprehensive plan, it should work with the Congress to develop realistic 

budget proposals that will allow DOD to complete cleanup activities in a 

timely manner. 

In commenting on a draft of this report, DOD concurred with our 

recommendation to work with the Congress to develop realistic budget 

proposals that will allow DOD to complete cleanup activities on potentially 

contaminated sites in a timely manner. In addition, DOD partially 

concurred with our recommendations to (1) establish deadlines to 

complete the identification process and initial evaluations; (2) reassess the 

timetable proposed for completing the reevaluation of sites, using the new 

risk assessment procedure; and (3) establish interim goals for cleanup 

phases for the services and the Corps to target. DOD also suggested some 

technical changes throughout the report that we have incorporated as 

appropriate. DOD’s comments appear in appendix III.

Background To better focus its munitions cleanup activities under the Defense 

Environmental Restoration Program, DOD established the Military 

Munitions Response program in September 2001. The objectives of the 

program include compiling a comprehensive inventory of military 

munitions sites, developing a prioritization protocol for sequencing work at 

these sites, and establishing program goals and performance measures to 

evaluate progress. In December 2001, shortly after DOD established the 

program, the Congress passed the National Defense Authorization Act for 

Fiscal Year 2002, which among other things, required DOD to develop an 

initial inventory of sites that are known or suspected to contain military 

munitions by May 31, 2003, and to provide annual updates thereafter. DOD
Page 7 GAO-04-147 Military Munitions

provides these updates as part of its Defense Environmental Restoration 

Program Annual Report to Congress.6

 

To clean up potentially contaminated sites, DOD generally follows the 

process established for cleanup actions under CERCLA, which includes the 

following phases and activities: 

• Preliminary Assessment—Determine whether a potential military 

munitions hazard is present and whether further action is needed.

• Site Investigation—Inspect the site and search historical records to 

confirm the presence, extent, and source(s) of hazards. 

• Remedial Investigation/Feasibility Study or Engineering 

Evaluation/Cost Analysis—Determine the nature and extent of 

contamination; determine whether cleanup action is needed and, if so, 

select alternative cleanup approaches. These could include removing 

the military munitions, limiting public contact with the site through 

signs and fences, or determining that no further action is warranted.

• Remedial Design/Remedial Action—Design the remedy and perform 

the cleanup or other response. 

• Long-Term Monitoring—Periodically review the remedy in place to 

ensure its continued effectiveness, including checking for unexploded 

ordnance and public education.

For sites thought to be formerly used defense sites, the Corps also 

performs an initial evaluation prior to the process above. In this initial 

evaluation, called a preliminary assessment of eligibility, the Corps 

determines if the property is a formerly used defense site. The Corps makes 

this determination based on whether there are records showing that DOD 

formerly owned, leased, possessed, operated, or otherwise controlled the 

property and whether hazards from DOD’s use are potentially present. If 

eligible, the site then follows the CERCLA assessment and cleanup process 

discussed earlier. When all of these steps have been completed for a given 

site and long-term monitoring is under way, or it has been determined that 

6

In the report issued on April 21, 2003, DOD provided aggregate high and low program cost 

estimates for clean up of military munitions at Military Munitions Response program sites, 

as well as operational ranges, to satisfy a one-time congressional reporting requirement.
Page 8 GAO-04-147 Military Munitions

no cleanup action is needed, the services and the Corps consider the site to 

be “response complete.” 

DOD Has Made Limited 

Progress in Its Program 

to Identify, Assess, and 

Clean Up Potentially 

Contaminated Sites

While DOD has identified 2,307 potentially contaminated sites as of 

September 2002, the department continues to identify additional sites, and 

it is not likely to have a firm inventory for several years (see table 1 for the 

distribution of these sites by service). Of the identified sites, DOD 

determined that 362 sites require no further study or cleanup action 

because it found little or no evidence of military munitions. For 1,387 sites, 

DOD either has not begun or not completed its initial evaluation, or has 

determined that further study is needed. DOD has completed an 

assessment of 558 sites, finding that 475 of these required no cleanup 

action. The remaining 83 sites require some cleanup action, of which DOD 

has completed 23. 

Table 1: Distribution of Military Munitions Response Program Sites by Service

Source: DOD.

a

The base realignment and closure program is a DOD program governing the scheduled closing of 

DOD sites and includes a focus on compliance and cleanup efforts at military installations undergoing 

closure or realignment.

DOD had identified 2,307 sites potentially contaminated with military 

munitions, as of September 30, 2002, and it continues to identify additional 

sites. (Fig. 1 shows the distribution of these sites by state.) DOD officials 

acknowledge that they will not have a firm inventory for several years. For 

example, as of September 30, 2002, the Army had not completed a detailed 

inventory of closed ranges at 86 percent of active installations; the 105 sites 

identified by the Army represented sites on only 14 percent of the Army’s 

Responsible service

Closed ranges

on active 

installations

Closing ranges 

on base 

realignment

and closure 

installationsa

Formerly used 

defense sites Total

Army 105 58 N/A 163

Navy 196 16 N/A 212

Air Force 241 0 N/A 241

Army Corps of 

Engineers

N/A N/A 1,691 1,691

Total 542 74 1,691 2,307
Page 9 GAO-04-147 Military Munitions

installations. The Army is working to identify sites on the remaining 

installations and plans to have 40 percent of its installations accounted for 

by the next Defense Environmental Restoration Program Annual Report to 

Congress in spring 2004. Similarly, the Corps recently identified 75 

additional sites to be included in the inventory as a result of its effort to 

reevaluate sites previously determined not to need further action after the 

initial evaluation. Because not all of the sites have been identified, DOD has 

only a preliminary idea of the extent of cleanup that will be needed. To help 

complete the identification process, DOD has developed a Web site that 

stakeholders, such as states, tribes, and federal regulators, can use to 

suggest additions and revisions to the inventory. DOD plans to update the 

inventory in its future Defense Environmental Response Program Annual 

Report to Congress using, in part, the information collected from this Web 

site. 
Page 10 GAO-04-147 Military Munitions

Figure 1: Distribution of 2,307 Suspected Military Munitions Response Program Sites Identified by DOD 

Source: GAO.

CT 10

DE 9

MD 61

DC 31

MA 72

NH 10

NJ 33

RI 24

VT 2

AK

50

HI 70

AL

22

American Samoa 3

Guam 12

Northern Mariana Islands 8

Puerto Rico 19

U.S. Virgin Islands 3

AZ

138 AR

15

CA

376

CO

34

GA

31

ID

20

IL

35

IN

22

IA

9

KS

62

LA

29

ME

36

MI

35

MN

5

MO

25

MT

16

NE

28

NV

40

NM

160

NY

29

ND

5

OK

38

OR

17

PA

30

SC

44

SD

21

TN 25

TX

139

UT

19

VA

66

WA

48

WV

3

WI

4

WY

12

FL

148

MS

23

NC

68

KY 3

OH

10
Page 11 GAO-04-147 Military Munitions

Of the 2,307 sites identified, DOD has determined, based on an initial 

evaluation, that 362 do not require any further DOD action (see fig. 2). 

However, these 362 sites are formerly used defense sites, and the Corps’ 

evaluation of these sites was less comprehensive than other evaluations 

conducted by DOD under the CERCLA process. 7 In making its 

determinations, the Corps conducted a preliminary assessment of 

eligibility and determined that the potential for military munitions hazard 

was not present. As a result of this determination, the sites were not 

evaluated further. The Corps is in the process of reviewing these 

determinations with local stakeholders to ensure that there was a sound 

basis for the original determination. It has recently decided that some of 

these sites need to be reassessed to determine if cleanup is needed. 

Figure 2: Military Munitions Response Program Site Inventory (2,307 Sites)

7

In previous GAO work, we estimated that the Corps lacked a sound basis for about 38 

percent of its determinations, based on its preliminary assessment of eligibility, that sites 

did not require any further DOD action; and we recommended that the Corps review these 

files to determine if these properties should be reassessed. The 38 percent includes all 

potential formerly used defense sites, including those suspected of containing military 

munitions. As noted above, the Corps is in the process of reassessing the determinations. 

See U.S. General Accounting Office, Environmental Contamination: Corps Needs to 

Reassess Its Determinations That Many Former Defense Sites Do Not Need Cleanup, GAO02-658 (Washington, D.C.: Aug. 23, 2002).

84% •

•

Source: GAO.

16%

No action required, based on 

initial evaluations (362)

Further action required (1,945)
Page 12 GAO-04-147 Military Munitions

Of the 1,945 sites that required further action, DOD has either not begun or 

has not completed its study, or has determined that further study is needed, 

for 1,387 sites (see fig. 3). For example, 241 Air Force and 105 Army sites at 

closed ranges on active installations have not been evaluated. For other 

sites, primarily formerly used defense sites, DOD has completed its initial 

evaluation and determined that further investigation is needed. 

Figure 3: Military Munitions Response Program Sites Requiring Further Action

DOD has completed its assessment of 558 sites, nearly all of which are 

ranges on formerly used defense sites or closing installations, and 

determined that no cleanup action was needed for 475; the remaining 83 

sites required some level of cleanup action. Of the 83 sites that required 

cleanup action, 60 have cleanup action planned or under way and 23 are 

complete. Actions taken at these 23 sites have been varied and include 

surface and subsurface removal of munitions, and institutional controls, 

such as the posting of warning signs or educational programs. See figure 4 

for examples of cleanup actions at Military Munitions Response program 

sites.

29% •

•

Source: GAO.

71%

Study not begun, study under way, or further study needed (1,387)

Study completed (558)

No cleanup action needed (475)

Cleanup action planned or under way (60)

Cleanup action complete (23)
Page 13 GAO-04-147 Military Munitions

Figure 4: Examples of Cleanup Actions at Military Munitions Response Program 

Sites

Source: GAO.

The former Baywood Park Training Area is an 8,810-acre site, located 

along Morro Bay near San Luis Obispo, California. Currently, the land is 

used for residential, recreational, agricultural uses as well as for a 

wildlife refuge. The Corps initially conducted a removal action on 166 

acres. It cleared 96 beachfront acres to a depth of 3 feet; 17 acres less 

susceptible to shifting and eroding sand were cleared to a depth of 2 

feet; and 53 acres were cleared at the surface for munitions. Following 

that work, the Corps also plans to implement institutional controls, such 

as putting up warning signs on primary trails and public education 

programs, for additional portions of the site. 

Jefferson Barracks is located along the Mississippi River in Saint 

Louis County, Missouri. Throughout much of the 19th century, the 

disposal of munitions from this site into the river was a common and 

acceptable practice. Over time, this practice resulted in potentially 

hazardous munitions being readily accessible to the public walking 

along the riverbank. The Missouri Air National Guard currently has 

responsibility for this land, but because it was a formerly used 

defense site the Corps has responsibility for cleanup. The Corps 

evaluated several alternatives and chose an innovative solution -- 

burying the potential hazard, located along approximately 650 linear 

feet of shoreline, under thousands of tons of rock.

At Seneca Army Depot in Romulus, New York, the primary 

mission was the receipt, storage, maintenance, and supply of 

military items, including munitions. Congress approved the 

closure of this 10,587-acre site under the base realignment 

and closure process. The Army assessed the site and 

evaluated the alternatives to reduce the risk posed by military 

munitions. The alternatives selected included institutional 

controls (such as fencing, land use restrictions, and public 

education), subsurface removal of munitions, and the 

excavation and sifting of soil to remove munitions.

The Waikoloa Maneuver Area in Hawaii, a military training area 

and live fire range, actually consists of three sites -- Waikoloa 

Maneuver Area, Nansay, and Lalamilo Firing Range and Camp. In 

total, the three sites encompass more than 100,000 acres and are 

estimated to be the most expensive to clean up. The Corps has 

already instituted a number of institutional controls, including 

notification of 14,000 land owners, the development of an 

educational package, and the production of a public safety and 

health video. As the Corps continues to monitor and assess this 

land, additional cleanup actions, including subsurface removal of at 

least 680 acres, are planned.
Page 14 GAO-04-147 Military Munitions

DOD Does Not Have a 

Complete and Viable 

Plan for Assessing and 

Cleaning Up 

Potentially 

Contaminated Sites 

In DOD’s Fiscal Year 2002 Defense Environmental Restoration Program 

Annual Report to Congress, DOD identified several elements integral to the 

success of the Military Munitions Response program: compiling a 

comprehensive inventory of sites; developing a new procedure to assess 

risk and prioritize sites; ensuring proper funding for accurate planning and 

program execution; and establishing program goals and performance 

measures. While DOD has established the basic framework to address 

these elements, DOD’s plan is lacking in three key respects. First, essential 

data for DOD’s plan may take years to develop. Second, DOD’s plan is 

contingent upon preliminary cost estimates that may change significantly 

and a reallocation of funds that may not be available. Finally, DOD’s plan 

lacks specific goals and performance measures to track progress. 

Essential Data for DOD’s 

Plan May Take Years to 

Develop

DOD’s inventory of potentially contaminated sites serves as the basis for 

other elements of its plan, yet this inventory is incomplete. DOD’s inventory 

of 2,307 sites includes only those identified through September 30, 2002. As 

previously discussed, according to DOD officials, this inventory is not final; 

and DOD has not set a deadline to complete it. According to DOD, most of 

the ranges on formerly used defense sites and on military installations that 

are being closed have been identified and are being assessed or cleanup 

action is under way. The ranges yet to be identified are primarily located on 

active installations. For example, the Army, as of September 30, 2002, had 

completed a detailed inventory of potentially contaminated sites on only 14 

percent of its active installations. Because the inventory serves as the basis 

for other elements of the plan, such as budget development and 

establishing program goals, most sites must first be identified in order for 

DOD to have a reasonable picture of the magnitude of the challenge ahead 

and to plan accordingly. 
Page 15 GAO-04-147 Military Munitions

Furthermore, DOD intends to use a new procedure to reassess the relative 

risk and priority for 1,387 sites needing further study and any new sites 

identified as part of the continuing inventory effort, but DOD is not 

scheduled to complete these reassessments until 2012. DOD recently 

developed this procedure for assigning each site in the inventory a priority 

level for cleanup action, based on the potential risk of exposure resulting 

from past munitions-related activities.8

 Under this procedure, DOD plans to 

reevaluate the 1,387 sites for three potential hazard types: (1) explosive 

hazards posed by unexploded ordnance and discarded military munitions, 

(2) hazards associated with the effects of chemical warfare material, and 

(3) chronic health and environmental hazards posed by munitions 

constituents. Once assessed, each site’s relative risk-based priority will be 

the primary factor determining future cleanup order.9

 DOD plans to require 

assessment of each site on the inventory for at least one of these hazard 

types by May 31, 2007, and for all three hazard types by May 31, 2012. Until 

all three hazard types are fully assessed, DOD cannot be assured that it is 

using its limited resources to clean up those sites that pose the greatest risk 

to safety, human health, and the environment. 

DOD’s Plan Relies on 

Preliminary Cost Estimates 

That Can Change 

Significantly and a 

Reallocation of Funds That 

May Not Be Available 

DOD’s plan to identify and address military munitions sites relies on 

preliminary cost estimates that were developed using incomplete 

information. The majority of the site estimates were developed using a 

cost-estimating tool that incorporates variables, such as the affected 

acreage; types, quantity, and location of munitions; and future land use. 

These variables can have a significant impact on cost, according to DOD. 

However, detailed site-specific information was not available for all sites. 

For example, as mentioned earlier, 105 Army and 241 Air Force sites at 

closed ranges on active installations have not had an initial evaluation. As a 

result, the Air Force used estimated, not actual, acreage figures, including 

assumptions regarding the amount of acreage known or suspected of 

containing military munitions when preparing its cost estimates. Because 

changes in acreage can greatly impact the final cost of site assessment and 

cleanup action, the estimates produced for these sites are likely to change 

when estimates based on more complete data or the actual cost figures are 

8

DOD proposed a rule establishing this protocol on August 22, 2003, allowing 90 days for a 

public comment period. 68 Fed. Reg. 50,900.

9

DOD recognized that other factors, such as economic, programmatic, and stakeholder 

concerns, may affect the sequence in which sites are cleaned up.
Page 16 GAO-04-147 Military Munitions

known. The following examples illustrate how cost estimates can change 

during the life of the cleanup as better information becomes available:

• Camp Maxey was a 41,128-acre Army post in Texas used from 1942 to 

1945 for training infantry in live fire of weapons including pistols, rifles, 

machine guns, mortars, bazookas, and antitank guns. The Corps 

confirmed the presence of unexploded ordnance, and in 2000, estimated 

the cleanup cost for the land at $45 million. In DOD’s Fiscal Year 2002 

Defense Environmental Restoration Program Annual Report to 

Congress, the estimated total cost of cleanup had grown to $130 million. 

A June 2003 cost estimate showed a decrease in total cost to about $73 

million, but still 62 percent more than the original cost estimate in 2000. 

The main factors behind these shifting cost estimates, according to the 

project manager, were changes in the acreage requiring underground 

removal of ordnance and changes in the amount of ordnance found. 

• Fort McClellan, Alabama, was among the installations recommended for 

closure under DOD’s base realignment and closure effort in 1995. This 

site had been used since the Spanish American War (1898), including as 

a World War I and II training range upon which grenades, mortars, and 

antiaircraft guns, were used. An April 2002 cost estimate prepared for 

one site on Fort McClellan requiring cleanup showed the anticipated 

cost of clearing the land of munitions as $11,390,250. A subsequent cost 

estimate prepared in May 2003, showed the cost of clearing this site at 

$22,562,200. According to the Army, the increase in estimated costs 

reflects a change in the final acreage recommended for clearance and 

the extent to which buried munitions would be searched for and 

removed. 

Moreover, until DOD and stakeholders agree upon a cleanup action, it is 

often difficult for them to predict the extent of the cleanup action required 

and cost estimates can change because of the cleanup action implemented 

at the site. For example, at the former Indian Rocks Range in Pinellas 

County, Florida, the Corps identified 178 acres that were used as an air-toground and antiaircraft gunnery range impact area from 1943 to 1947. 

Munitions used on this shoreline site included bullets, aircraft rockets, and 

small practice bombs. Much of the land had been developed, limiting the 

Corps ability to pursue the alternative of searching for and removing buried 

munitions. In 1995, the Corps analyzed a number of alternatives to address 

munitions contamination at the site and developed cost estimates for these 

alternatives. However, because the development was largely composed of 

hotels, condominiums, and single-family residences, the Corps chose the 
Page 17 GAO-04-147 Military Munitions

alternative of conducting a community education program. The total cost 

of this alternative was $21,219. If the Corps had decided to search for and 

remove the remaining munitions at this site, the cost could have 

approached $3 million, according to the prepared cost analysis.

Furthermore, at an annual funding level of approximately $106 million (the 

average amount budgeted or spent annually from fiscal year 2002 to fiscal 

year 2004), cleanup at the remaining munitions sites in DOD’s current 

inventory could take from 75 to 330 years to complete.10 To reduce this 

timeline, DOD expects to use funds currently designated for hazardous, 

toxic, and radioactive waste cleanup after these cleanups are complete. 

However, these other cleanup efforts are not on schedule in all of the 

services and the Corps. For example, between fiscal years 2001 and 2002, 

the schedule to complete hazardous substance cleanups at formerly used 

defense sites slipped by more than 6 years. As a result, anticipated funds 

from completing hazardous substance cleanups at these sites may not 

become available to clean up munitions sites until 2021 or later. This delay 

is significant because, as of September 30, 2002, formerly used defense 

sites account for over 85 percent of DOD’s total anticipated costs to 

complete munitions cleanup, yet the Corps receives about 66 percent of the 

total munitions cleanup funds. Delays in the availability of anticipated 

funding from hazardous, toxic, and radioactive waste sites could greatly 

impair DOD’s ability to accurately plan for and make progress in cleaning 

up Military Munitions Response sites. 

DOD’s Plan Does Not 

Contain Goals or Measures 

for Site Assessment and 

Cleanup

DOD has yet to establish specific program goals and performance 

measures in its plan. Specifically, DOD has yet to identify interim 

milestones and service-specific targets that will help it achieve overall 

program objectives. In September 2003, 2 years after the Military Munitions 

Response program was initiated, DOD established a workgroup tasked 

with recommending overall goals and measures for the program, near-term 

goals and measures to support its budgeting cycle for fiscal years 2006 to 

2011, and a program completion date goal. DOD has asked the workgroup 

to accomplish these objectives by the end of calendar year 2003. According 

to DOD, these goals and measures, when developed, should help DOD 

track the progress of sites through the cleanup phases, and ensure that 

DOD responds to the sites with the greatest risk first. While it is important 

10This estimate is a conservative estimate because it was calculated based on annual funding 

totals that include funding that is needed for program management and administration. 
Page 18 GAO-04-147 Military Munitions

for DOD to establish goals and measures that will track overall program 

progress and ensure that the riskiest sites are assessed and cleaned up first, 

DOD will not have the information it needs to do this until 2012. As we 

discussed earlier, because DOD plans to reassess potentially contaminated 

sites using a new risk-based prioritization procedure, until these 

reassessments are complete, DOD will not have complete information on 

which of the sites pose the greatest risk. Consequently, goals and measures 

established in 2003 will be of limited use and may not reflect DOD’s true 

priorities. 

Moreover, according to DOD, the program goals and measures to be 

established by the workgroup will be agencywide, and not service-specific, 

although it may establish interim goals for the services and Corps. 

However, DOD has not yet decided what these goals will be based on, such 

as relative risk levels or cleanup phases. In the absence of service-specific 

goals, each service has implemented the program with a different level of 

effort. For example, the Air Force has not budgeted any funds to assess and 

clean up munitions sites, nor do they plan to do so through fiscal year 2004. 

As mentioned before, the Air Force also has not conducted initial 

evaluations on any of its 241 sites and has little site-specific information 

from which to create a reliable cost estimate. In contrast, the Army has 

undertaken a comprehensive inventory of ranges that will result in detailed 

site information, such as acreage and the types, quantity, and location of 

munitions, that can be used to, among other things, create more robust cost 

estimates. The Army has completed this comprehensive inventory on 14 

percent of its installations as of September 2002, and has set a goal to 

complete this effort by December 2003. This uneven effort in implementing 

the Military Munitions Response program could continue through various 

program phases, such as preliminary assessments and site investigations, 

making it difficult for DOD to assure that each of the services and the 

Corps are making progress in cleaning up their potentially contaminated 

sites and achieving the overall goals of the program. 

Conclusions DOD has made limited progress in identifying, assessing, and cleaning up 

sites known or suspected to contain military munitions. Accomplishing this 

long and arduous task in a timely manner that best protects public safety, 

human health, and the environment will require a comprehensive approach 

that includes effective planning and budgeting. However, DOD lacks the 

data needed—such as a complete inventory, up-to-date prioritization, and 

reliable cost estimates—to establish a comprehensive approach. Without 

such an approach for identifying, assessing, and cleaning up potentially 
Page 19 GAO-04-147 Military Munitions

contaminated sites, DOD will be hampered in its efforts to achieve the 

program’s objectives. 

Recommendations To ensure that DOD has a comprehensive approach for identifying, 

assessing, and cleaning up military munitions at potentially contaminated 

sites, we recommend that the Secretary of Defense revise DOD’s plan to 

• establish deadlines to complete the identification process and initial 

evaluations so that it knows the universe of sites that needs to be 

assessed, prioritized, and cleaned up;

• reassess the timetable proposed for completing its reevaluation of sites 

using the new risk assessment procedures so that it can more timely 

establish the order in which sites should be assessed and cleaned up, 

thereby focusing on the riskiest sites first; and

• establish interim goals for cleanup phases for the services and Corps to 

target.

 In addition, after DOD has revised its comprehensive plan, we recommend 

that it work with the Congress to develop realistic budget proposals that 

will allow DOD to complete cleanup activities on potentially contaminated 

sites in a timely manner. 

Agency Comments We provided DOD with a draft of this report for review and comment. In its 

comments, DOD concurred with our recommendation to work with the 

Congress to develop realistic budget proposals that will allow it to 

complete cleanup activities on potentially contaminated sites in a timely 

manner. DOD partially concurred with our recommendation to establish 

deadlines to complete the identification process and initial evaluations so 

that it knows the universe of sites. DOD stated that the military services 

and the Corps have been working, and will continue to work, with 

stakeholders to identify additional sites and add these sites to the inventory 

as appropriate. DOD also stated that it believes most of the remaining sites 

to be identified are located on active installations still under DOD control. 

While we have clarified this point in the report, we note that the number of 

formerly used defense sites identified has increased by about 75 sites since 

the current inventory was completed and an unknown but possibly 

significant number of sites may be added as the Army completes 
Page 20 GAO-04-147 Military Munitions

identification of sites on 86 percent of its installations. These sites and 

many others still need to undergo initial evaluations. Consequently, we 

continue to believe that it is important for DOD to establish deadlines to 

complete the identification and initial evaluations for all of the sites in its 

inventory in order to establish a reasonable approximation of the future 

workload it faces.

DOD also partially concurred with our recommendation to reassess the 

timetable proposed for completing the reevaluation of sites using the new 

risk assessment procedure. DOD stated that the military services and the 

Corps would need sufficient time and resources to complete each risk 

assessment. However, DOD stated that it had recently established 2010 as 

the goal for completing the prioritization of sites, instead of 2012 which 

was the original goal set forth in the proposed regulation. While we agree 

that this is a step in the right direction, DOD should continue to look for 

other opportunities to accelerate these inspections and the prioritization of 

sites to help ensure that resources are being targeted toward the riskiest 

sites first. 

Finally, DOD partially concurred with our recommendation to establish 

interim goals for cleanup phases for the services and the Corps. DOD 

stated that it has established interim goals of completing all preliminary 

assessments by 2007 and all site inspections by 2010, and that these goals 

apply to all military components, thereby eliminating the need for separate 

service-specific goals. However, DOD noted that it is working with each 

military service to establish additional goals and measures to gauge 

progress. While we are encouraged by DOD’s efforts in this area, we believe 

that service-specific goals and measures, as they apply to the cleanup 

phases, will be essential for DOD to ensure that each of the services and 

the Corps are making progress in cleaning up potentially contaminated 

sites and achieving the overall goals of the program. 

In addition to its written comments on our draft report, DOD also provided 

a number of technical comments and clarifications, which we have 

incorporated in this report as appropriate. DOD’s written comments appear 

in appendix III.

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to the 

appropriate congressional committees; the Secretary of Defense; Director, 
Page 21 GAO-04-147 Military Munitions

Office of Management and Budget; and other interested parties. We will 

also make copies available to others upon request. In addition, the report 

will be available at no charge on the GAO Web site at http://www.gao.gov. 

If you or your staffs have any questions, please call me or Edward Zadjura 

at (202) 512-3841. Key contributors to this report are listed in appendix IV.

Sincerely yours,

Anu K. Mittal

Director, Natural Resources 

and Environment
Page 22 GAO-04-147 Military Munitions

Appendix I

Safety, Environmental, and Human Health Apendxies

Risks ApendxiI

Military munitions can pose risks to public safety, human health, and the 

environment. In terms of the explosive hazard, unexploded ordnance poses 

an immediate safety risk of physical injury to those who encounter it. 

Military munitions may also pose a health and environmental risk because 

their use and disposal may release constituents that may contaminate soil, 

groundwater, and surface water. Ranges contaminated with military 

munitions, especially those located in ecologically sensitive wetlands and 

floodplains, may have soil, groundwater, and surface water contamination 

from any of the over 200 chemical munitions constituents that are 

associated with the ordnance and their usage. When exposed to some of 

these constituents, humans potentially face long-term health problems, 

such as cancer and damage to heart, liver, and kidneys. Of these 

constituents, there are 20 that are of greatest concern due to their 

widespread use and potential environmental impact. Table 2 contains a 

listing of these munitions constituents, and table 3 describes some of the 

potential health effects of five of them. 
Appendix I

Safety, Environmental, and Human Health 

Risks 

Page 23 GAO-04-147 Military Munitions

Table 2: Munitions Constituents of Greatest Concern

Source: DOD, Fiscal Year 2002 Defense Environmental Restoration Program Annual Report to Congress.

While many of these constituents have been an environmental concern to 

the Department of Defense (DOD) for more than 20 years, the current 

understanding of the causes, distribution, and potential impact of 

constituent releases into the environment remains limited. The nature of 

these impacts, and whether they pose an unacceptable risk to human 

health and the environment, depend upon the dose, duration, and pathway 

of exposure, as well as the sensitivity of the exposed populations. However, 

the link between such constituents and any potential health effects is not 

always clear and continues to be studied. 

Type of munitions constituents

Trinitrotoluene (TNT)

1,3-Dintrobenzene

Nitrobenzene

2,4-Dinitrotoluene

2-Amino-4,6-Dinitrotoluene

2-Nitrotoluene

2,6-Dinitrotoluene

4-Amino-2,6-Dinitrotoluene

3-Nitrotoluene

Octahydro-1,3,5,7-tetranitro-1,3,5,7-tetrazocine (HMX)

2,4-Diamino-6-nitrotoluene

4-Nitrotoluene

Hexahydro-1,3,5-trinitro-1,3,5-triazine (RDX)

2,6-Diamino-4-nitrotoluene

Methylnitrite

Perchlorate

1,2,3-Propanetriol trinitrate (Nitroglycerine)

Pentaerythritoltetranitrate (PETN)

1,3,5-Trinitrobenzene

N,2,4,6-Tetranitro-N-methylaniline (Tetryl) (White Phosphorus)
Appendix I

Safety, Environmental, and Human Health 

Risks 

Page 24 GAO-04-147 Military Munitions

Table 3: Potential Effects of the Munitions Constituents Closely Associated with 

Military Munitions

Source: Environmental Protection Agency, Handbook on the Management of Ordnance and Explosives at Closed, Transferring, and 

Transferred Ranges and Other Sites.

Constituent Potential toxicity/effects

TNT Possible human carcinogen, targets liver, skin irritations, 

and cataracts.

RDX Possible human carcinogen, prostate problems, nervous 

system problems, nausea and vomiting. Laboratory 

exposure to animals indicates potential organ damage.

HMX Animal studies suggest potential liver and central nervous 

system damage.

Perchlorate Exposure causes itching, tearing, and pain; ingestion may 

cause gastroenteritis with abdominal pain, nausea, 

vomiting, and diarrhea; systemic effects may follow and 

may include ringing of ears, dizziness, elevated blood 

pressure, blurred vision, and tremors. Chronic effects may 

include metabolic disorders of the thyroid.

White Phosphorus Reproductive effects. Liver, heart, or kidney damage; 

death; skin burns, irritation of throat and lungs, vomiting, 

stomach cramps, drowsiness.
Page 25 GAO-04-147 Military Munitions

Appendix II

Additional Details on Our Scope and 

Methodology ApendxiI

The objectives of our review were to evaluate (1) DOD’s progress in 

implementing its program to identify, assess, and clean up sites containing 

military munitions and (2) DOD’s plans to clean up remaining sites in the 

future. To evaluate DOD’s progress in identifying, assessing, and cleaning 

up military munitions sites, we analyzed data provided to us by DOD’s 

Office of the Deputy Undersecretary of Defense (Installations and 

Environment) Cleanup Office from its database for sites identified under 

the Military Munitions Response program. This information includes the 

status of studies or cleanup actions, as well as cost estimates. The data are 

complete as of September 30, 2002, DOD’s most recent reporting cycle, and 

were used to develop DOD’s Fiscal Year 2002 Defense Environmental 

Restoration Program Annual Report to Congress. We also analyzed 

additional data on the status of studies or cleanup actions provided to us by 

the Army Corps of Engineers (the Corps) from its database of formerly 

used defense sites. We assessed the reliability of relevant fields in these 

databases by electronically testing for obvious errors in accuracy and 

completeness, reviewing information about the data and the system that 

produced them, and interviewing agency officials knowledgeable about the 

data. When we found inconsistencies, we worked with DOD and military 

service officials to correct the inconsistencies before conducting our 

analyses. We determined that the data needed for our review were 

sufficiently reliable for the purposes of our report. 

We also reviewed 38 of 75 project files at seven Corps districts where, 

according to DOD’s database, site cleanup action is either complete or 

under way. (See table 4 for a listing of these districts). 

Table 4: Districts Visited during Review

Source: GAO.

Corps district

Total number 

of sites

Sites with cleanup 

completed

Sites with cleanup 

under way

Baltimore 2 1 1

Fort Worth 3 0 3

Honolulu 2 0 2

Huntsville 12 4 8

Jacksonville 8 2 6

Kansas City 4 3 1

Los Angeles 7 2 5

Total 38 12 26
Appendix II

Additional Details on Our Scope and 

Methodology

Page 26 GAO-04-147 Military Munitions

We selected these districts based on the number of sites where cleanup was 

completed or under way and the estimated cost to complete cleanup, with 

some consideration given for geographic distribution. These files 

represented 52 percent of the 23 sites with a completed cleanup action and 

50 percent of the 52 sites with a cleanup action under way. We used our file 

reviews to develop case example of changes in estimated costs to complete 

cleanup over time and cleanup actions taken. These case examples are for 

illustration only. 

To evaluate DOD’s plans for addressing the remaining sites, we analyzed 

the plans, as well as the assumptions upon which those plans are based, 

including cost and projected completion dates. In addition, we reviewed 

policies and program guidance, analyzed financial data, and interviewed 

program managers in DOD and the military services and the Corps. We 

conducted our work between November 2002 and October 2003 in 

accordance with generally accepted government auditing standards.
Page 27 GAO-04-147 Military Munitions

Appendix III

Comments from the Department of Defense ApendxiI
Appendix III

Comments from the Department of Defense

Page 28 GAO-04-147 Military Munitions
Appendix III

Comments from the Department of Defense

Page 29 GAO-04-147 Military Munitions
Page 30 GAO-04-147 Military Munitions

Appendix IV

GAO Contacts and Staff Acknowledgments ApendxiIV

GAO Contacts Ms. Anu K. Mittal, (202) 512-3841

Edward Zadjura, (202) 512-9914

Acknowledgments In addition to those named above, Jack Burriesci, Elizabeth Erdmann, 

Sherry McDonald, and Matthew Reinhart made key contributions to this 

report. Also contributing to this report were Cynthia Norris, Rebecca Shea, 

and Ray Wessmiller.

(360286)
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