a

GAO

United States General Accounting Office

Report to Congressional Requesters

May 2004 DOD OPERATIONAL 

RANGES

More Reliable Cleanup 

Cost Estimates and a 

Proactive Approach to 

Identifying 

Contamination Are 

Needed

GAO-04-601
www.gao.gov/cgi-bin/getrpt?GAO-04-601.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Anu MIttal at 

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

Highlights of GAO-04-601, a report to

congressional requesters 

May 2004

DOD OPERATIONAL RANGES 

More Reliable Cleanup Cost Estimates 

and a Proactive Approach to Identifying 

Contamination Are Needed 

DOD identified the location and status of its operational ranges based on 

inventory data developed by the individual military services. However, the 

reliability of DOD’s inventory is questionable because the services did not 

use a common framework to collect and analyze data on the number of 

existing operational ranges. Because DOD’s cost estimates to clean up its 

operational ranges were based on individual service calculations that 

combined inventory data with unvalidated DOD cost assumptions, various 

service assumptions, and computer-generated cost rates, these cost 

estimates are also questionable. Specifically, GAO found that each service 

compiled inventory data using various methodologies over different time 

periods and developed cost estimates using a mix of differing assumptions 

and estimates, along with actual data. As a result, the services’ estimates to 

clean up an acre of highly contaminated land vary from about $800 for the 

Air Force to about $7,600 for the Army. The figure below shows high and 

low cost estimates and range acreage used to estimate costs, by service. 

High and Low Cleanup Cost Estimates and Total Range Acreage by Service 

DOD does not have a comprehensive policy requiring sampling or cleanup 

on operational ranges for the more than 200 chemicals associated with 

military munitions. However, when required by the Safe Drinking Water Act 

or other environmental laws, DOD has sampled and cleaned up munitions 

and munitions constituents. With regard to perchlorate, DOD has issued 

sampling policies but cannot assure funding is provided for such sampling. 

In some cases, DOD has sampled for perchlorate when required under the 

Safe Drinking Water Act’s Unregulated Contaminant Monitoring Regulation 

and for other contaminants when directed by state environmental agencies. 

However, DOD generally has not independently taken actions specifically 

directed at cleaning up munitions contaminants, such as perchlorate, on 

operational ranges when they have been detected. 

For decades, the Department of 

Defense (DOD) has tested and fired 

munitions on more than 24 million 

acres of operational ranges. 

Munition constituents such as lead, 

trinitrotoluene (TNT), and 

perchlorate may cause various 

health effects, including cancer. 

Concerned about the potential cost 

to clean up munitions, Congress 

required DOD to estimate the cost 

to clean up its operational ranges. 

You asked GAO to determine (1) 

how DOD identified the location 

and last use of operational ranges 

and the basis for DOD’s cost 

estimates for cleaning up those 

ranges; and (2) DOD’s policy to 

address contaminants linked to the 

use of munitions on operational 

ranges and, where contaminants 

such as perchlorate have been 

detected, what corrective actions 

the military services have taken. 

GAO recommends that DOD (1) 

revise its cost estimates for the 

cleanup of operational ranges using 

its most complete range inventory 

and a consistent estimating 

methodology, and (2) provide 

specific funding for sampling at 

sites where perchlorate 

contamination is likely, in 

accordance with DOD’s policy 

requiring sampling. 

In commenting on this report, DOD 

disagreed with GAO’s findings and 

recommendations. GAO believes 

its findings are sound and its 

recommendations are appropriate. 
Page i GAO-04-601 DOD Operational Ranges

Contents

Letter 1

Results in Brief 3

Background 6

DOD’s Inventory and Cost Estimates for Operational Range Cleanup 

May Not Provide Congress with a Reliable Picture of Potential 

Liabilities 15

DOD Does Not Have a Comprehensive Policy on Contaminants 

Associated with Military Munitions and Has Not Specifically 

Cleaned Up Known Perchlorate Contamination 24

Conclusions 31

Recommendations for Executive Action 31

Agency Comments and Our Evaluation 32

Appendixes

Appendix I: Safety, Environmental, and Human Health Risks 36

Appendix II: Scope and Methodology 38

Appendix III: Installations That Were Cleaning Up Perchlorate as a Result 

of Demonstration Projects 40

Edwards Air Force Base 40

Naval Surface Warfare Center, Indian Head 40

Appendix IV: Installations That Identified Perchlorate as a Result of 

Munitions Research, Manufacturing, Testing, and Disposal 

Activities 42

Edwards Air Force Base 42

Holloman Air Force Base 42

Naval Surface Warfare Center, Indian Head 42

Redstone Arsenal 43

White Sands Missile Range 43

Naval Air Weapons Station, China Lake 44

Appendix V: Comments from the Department of Defense 45

Appendix VI: GAO Contacts and Staff Acknowledgments 48

GAO Contacts 48

Staff Acknowledgments 48

Tables Table 1: Dates Service Inventories Were Conducted 16

Table 2: Active and Inactive Operational Ranges and Acreage as 

Reported by DOD in April 2003 18
Contents

Page ii GAO-04-601 DOD Operational Ranges

Table 3: Low and High Cost Estimates to Clean Up Unexploded 

Ordnance, Discarded Military Munitions, and Munitions 

Constituents 23

Table 4: High Cost Estimates to Clean Up an Acre with a High 

Density of Contamination, by Service 23

Table 5: Summary of Perchlorate Sampling Conducted at 

Installations Visited by GAO 27

Table 6: Potential Effects of the Munitions Constituents Closely 

Associated with Military Munitions 37

Table 7: Installations Visited during Our Review 39

Figures Figure 1: Discarded Munitions on an Operational Range That Were 

Later Uncovered by Erosion 7

Figure 2: Discarded Military Munitions Discovered on a Closed 

Range 8

Figure 3: Munitions Debris, Including Ordnance, Collected during 

Range Clearance 9

Figure 4: High and Low Density Operational Range Acreage Used 

to Estimate Cleanup Costs, by Service 22

Abbreviations

CERCLA Comprehensive Environmental Response, Compensation, and 

Liability Act 

DOD Department of Defense

EPA Environmental Protection Agency

NPDES National Pollution Discharge Elimination System 

RCRA Resource Conservation and Recovery Act

TNT Trinitrotoluene

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately.
Page 1 GAO-04-601 DOD Operational Ranges

United States General Accounting Office

Washington, D.C. 20548

A

May 28, 2004 Letr

The Honorable John D. Dingell

Ranking Minority Member

Committee on Energy and Commerce

House of Representatives

The Honorable Hilda L. Solis

Ranking Minority Member

Subcommittee on Environment and Hazardous Materials

Committee on Energy and Commerce

House of Representatives

For decades, the Department of Defense (DOD) has tested and fired 

munitions on millions of acres of operational ranges. These munitions 

contain various constituents such as lead, trinitrotoluene (TNT), and 

ammonium perchlorate salt (perchlorate) that are, in some instances, 

known or suspected of causing health effects such as damage to the central 

and peripheral nervous systems, cancer, and interfering with thyroid 

function. Concerns about the potential cost to clean up munitions 

prompted Congress to require that DOD develop an estimate for what it 

would cost to clean up its operational ranges. The National Defense 

Authorization Act for Fiscal Year 2002 required DOD to provide (1) a 

comprehensive assessment of unexploded ordnance, discarded military 

munitions, and munitions constituents at current and former DOD 

facilities; and (2) an estimate of the aggregate projected cost of 

remediation (cleanup) at operational ranges,1

 stated as a range of costs, 

including a low and high estimate. As of April 2003, DOD identified 10,444 

operational ranges located in the United States and its territories, with 

Army operational ranges accounting for 94 percent of the total. DOD 

estimated it would cost between $16 billion and $165 billion to clean up 

unexploded ordnance, discarded military munitions, and munitions 

constituents on these operational ranges.

There is a growing concern about the potential health effects associated 

with the environmental contamination caused by constituents used in the 

munitions and specifically the possible contamination of drinking water 

with perchlorate—the primary ingredient of solid rocket propellant that is 

also used in varying quantities in many types of munitions, explosives, and 

1

DOD was also required to provide a separate estimate for all other defense sites. 
Page 2 GAO-04-601 DOD Operational Ranges

incendiary devices, such as mortars, grenades, and flares. The 

Environmental Protection Agency (EPA) estimates that about 90 percent of 

the perchlorate manufactured in the United States is for solid rocket fuel 

used for military purposes and by the National Aeronautics and Space 

Administration. According to EPA, studies have shown that perchlorate can 

interfere with thyroid function and negatively affect fetal and infant brain 

development and growth. Since 1990, the state of California has detected 

perchlorate in wells and other drinking water sources near sites that once 

supported munitions manufacturing, storage, and testing. EPA reports that 

perchlorate has been detected in 34 states and attributes a significant 

portion of the contamination to defense manufacturing and test sites. 

In monitoring and cleaning up munitions and munitions constituents on 

operational ranges, DOD must comply with applicable provisions of 

various federal environmental laws, including the Safe Drinking Water Act, 

as amended; the Resource Conservation and Recovery Act of 1976, as 

amended (RCRA); and the Comprehensive Environmental Response, 

Compensation, and Liability Act of 1980, as amended (CERCLA). EPA does 

not have specific regulatory standards under the Safe Drinking Water Act 

for the roughly 200 chemicals associated with military munitions use,2

 but 

requires sampling for some of these contaminants, including perchlorate. 

According to DOD, at least 20 of these constituents, including perchlorate, 

are of great concern due to their widespread use and potential 

environmental impact. For example, EPA and some states are considering 

whether to establish a specific drinking water standard for perchlorate 

levels and have, in some cases, established advisory levels. Appendix I 

contains a listing of munitions constituents of greatest concern and their 

potential health effects. 

You asked us to determine (1) how DOD identified the location and last 

active use of all operational ranges and the basis for DOD’s cost estimates 

for cleaning up those ranges; and (2) DOD’s policy to address contaminants 

linked to the use of munitions on operational ranges and, where munitionsrelated contaminants have been detected, what corrective actions the 

services have taken. Specifically, you asked us to focus on DOD’s actions 

with regard to perchlorate. 

2

DOD’s Fiscal Year 2002 Defense Environmental Restoration Program Annual Report to 

Congress.
Page 3 GAO-04-601 DOD Operational Ranges

To determine how DOD identified the location and last active use of all 

operational ranges, we reviewed the services’ inventory data and 

interviewed DOD and service officials to obtain information on how the 

inventories were conducted and the reliability of the data collected. We 

assessed the reliability of the services’ data (1) by reviewing existing 

information about the data and processes that produced them and (2) by 

interviewing DOD officials knowledgeable about the data. We determined 

that data on the number of operational ranges and acreage were 

sufficiently reliable to include in our report. Although we found the 

reliability of data on operational range characteristics to be questionable, 

we present the data in the report for informational purposes. To determine 

the basis for DOD’s cost estimates for cleaning up the operational ranges, 

we reviewed the services’ estimated costs, supporting analyses, and 

calculations, and interviewed service and DOD officials on the scope and 

methodology used to develop cost estimates. To identify DOD’s policy on 

sampling for constituents linked to the use of munitions on operational 

ranges, we reviewed DOD’s and the services’ policies related to sampling 

and cleanup of potential contaminants and specifically their policies on 

perchlorate. Finally, to report on what corrective actions the services have 

taken with regard to munitions constituents, particularly perchlorate, we 

visited seven DOD installations where perchlorate had been detected and 

discussed what efforts have taken place or were planned to respond 

generally to munitions-related contaminants and specifically to 

perchlorate.3

 Our observations about these installations are not 

generalizable to all military installations. We conducted our work between 

June 2003 and March 2004 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 identified the location and status of its operational ranges based on 

inventory data developed by the individual services. However, 

3

The installations we visited were Holloman Air Force Base, in New Mexico; Edwards Air 

Force Base, in California; Army Redstone Arsenal, in Alabama; Army Aberdeen Proving 

Ground, in Maryland; Army White Sands Missile Range, in New Mexico; Naval Surface 

Warfare Center, Indian Head, in Maryland; and Naval Air Weapons Station, China Lake, in 

California. We selected installations based on available data, but were unable to determine 

the total number of installations reporting perchlorate contamination. DOD and EPA had 

only recently begun to collect data on perchlorate and data lists were not always current or 

complete, and were often redundant in that the same installations appeared on more than 

one list of installations reporting contamination. 
Page 4 GAO-04-601 DOD Operational Ranges

inconsistencies in how DOD collected and analyzed data on operational 

ranges raise questions about the reliability of DOD’s inventory. For 

example, the services used different methods to gather data, conducted 

inventories at different periods of time and for different reasons, and did 

not always validate their results. DOD’s cost estimates to clean up 

operational ranges also are questionable because the estimates were based 

on this inventory data, as well as on a mix of cost assumptions that were 

not validated—where DOD did not establish a reasonable and defensible 

basis for the assumptions used—and computer-generated cost rates that 

varied across the services. For example, we found that in addition to DODprovided assumptions, the services were allowed to use their own 

assumptions to estimate cleanup costs. Their differing approaches to 

estimating the percentage of acreage likely to be contaminated produced 

varying, and likely questionable, estimates of the costs to clean up 

operational ranges. In 2004, DOD completed another inventory of its 

operational ranges that was based on a more consistent data collection 

framework. However, because the 2004 inventory was conducted for a 

different purpose and scope, the 2003 and 2004 inventories are not 

comparable and there are differences between them. The differences 

between the two inventories make it difficult to determine if the range data 

used to estimate the cost of cleaning up operational ranges were accurate. 

DOD does not have a comprehensive policy requiring sampling or cleanup 

of the more than 200 chemical contaminants associated with military 

munitions on operational ranges. None of these munitions constituents are 

currently regulated with a drinking water standard under the Safe Drinking 

Water Act, although some of them, including perchlorate, are covered 

under the act’s Unregulated Contaminant Monitoring Regulation.4

 Certain 

chemicals associated with military munitions may, however, be subject to 

other environmental laws, including RCRA and CERCLA. With a few 

exceptions, EPA generally has not used its authority under these laws to 

require DOD to conduct a cleanup of its operational ranges, although some 

states have required installations to monitor and sample for contaminants, 

including perchlorate. For example, EPA and several states have asked 

DOD to test for perchlorate in areas such as old dump sites because of 

concern about potential contamination of groundwater. In this context, 

DOD issued a policy in November 2002 allowing the services to test for 

perchlorate if there was a reasonable basis to suspect both the presence of 

4

DOD has other policies requiring the services to assess potential hazards from munitions 

constituents migrating from operational ranges to off-range areas. 
Page 5 GAO-04-601 DOD Operational Ranges

perchlorate and the possibility for human exposure. In September 2003, 

DOD revised its policy to direct sampling for perchlorate contamination at 

previously unexamined sites, including operational ranges, where a 

perchlorate release is suspected and a pathway to human exposure is 

likely, but the policy did not identify specific funding for this sampling. 

None of the seven installations with reported perchlorate contamination 

that we visited were currently sampling operational ranges for perchlorate 

under DOD’s guidance, although they had conducted some sampling when 

required by states. While six of the installations we visited had reported 

high levels of perchlorate, none of these were cleaning up perchlorate 

contamination because, installation officials said, DOD policy did not 

require that they do so. Further, at six of the locations we visited, we 

determined that research, manufacturing, testing, and disposal of 

perchlorate were the primary activities that had caused contamination, and 

not the use of ordnance during training exercises. 

In order to assist Congress, EPA, and state regulators in assessing and 

planning for the cleanup of contamination from the use of munitions at 

operational ranges, we are recommending that DOD (1) use its most 

complete operational range inventory to revise its cost estimates for the 

cleanup of operational ranges and use a more consistent methodology for 

estimating costs, and (2) provide specific funding for sampling at sites 

where perchlorate contamination is likely, in accordance with DOD’s policy 

requiring sampling. 

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

and recommendations. DOD disagreed with our conclusion that it did not 

have a comprehensive policy requiring sampling or cleanup of munitions 

constituents on operational ranges and cited specific policies requiring the 

services to respond to the release of munitions constituents. However, the 

policies cited by DOD pertain only to the migration of munitions 

constituents off-range, and environmental reporting, and do not address 

the sampling or cleanup of munitions constituents found on operational 

ranges that are the subject of this report. DOD disagreed with our 

recommendation that it needed to develop new cost estimates for cleaning 

up operational ranges, stating that it is developing a system for providing 

data and assessing its ranges for potential munitions constituent migration 

to off-range areas. However, the requirement in the National Defense 

Authorization Act for fiscal year 2002 was to report estimated costs to 

clean up operational ranges, not the costs to respond to or clean up 

constituent migration off-range. DOD also questioned whether decision 

makers would find useful an estimated cost to clean up operational ranges. 
Page 6 GAO-04-601 DOD Operational Ranges

We disagree with DOD’s view of the usefulness of the information to 

Congress, because on two occasions, including in DOD’s authorization act, 

Congress has directed DOD to provide such information. DOD also 

disagreed with our recommendation to provide specific funding for 

perchlorate sampling. According to DOD, its current policy designates 

funding for perchlorate sampling as a high priority environmental project. 

However, we believe that due to limited funds and because perchlorate 

sampling must compete with other high priority environmental priorities, it 

may not be funded. Consequently, while DOD policy designates a funding 

mechanism for perchlorate, it cannot assure that perchlorate sampling will 

be funded. DOD also provided technical comments and clarifications that 

we incorporated into the report, as appropriate. DOD’s comments appear in 

appendix V. 

Background DOD policy defined an operational range as an area used to conduct 

research, develop and test military munitions, or train military personnel. 

Operational ranges were considered active when regularly used for range 

activities, and inactive when not currently used but still under military 

control and available for use as a range.5

 Once a range is closed, DOD is 

required to identify, assess, and clean up or take other appropriate action in 

response to contamination by military munitions.6 As such, DOD’s current 

inventory of operational ranges represents a potential liability for future 

cleanup. Figures 1, 2, and 3 show examples of the types of ordnance and 

explosives that can be found on operational ranges.

5

DOD no longer distinguishes between active and inactive ranges. The current statutory 

definition of an operational range is “a range that is under the jurisdiction, custody, or 

control of the Secretary of Defense and (A) that is used for range activities, or (B) although 

not currently being used for range activities, that is still considered by the Secretary to be a 

range and has not been put to a new use that is incompatible with range activities.” Pub. L. 

No. 108-136, § 1042(e)(3) (Nov. 24, 2003). 

6

DOD distinguishes range cleanup from range clearance. Range clearance is routine, 

conducted for the continued use of active ranges, and performed primarily for safety 

reasons, whereas range cleanup involves interim removal, remedial activities, and a final 

remedy, but only for closed ranges. 
Page 7 GAO-04-601 DOD Operational Ranges

Figure 1: Discarded Munitions on an Operational Range That Were Later Uncovered by Erosion
Page 8 GAO-04-601 DOD Operational Ranges

Figure 2: Discarded Military Munitions Discovered on a Closed Range
Page 9 GAO-04-601 DOD Operational Ranges

Figure 3: Munitions Debris, Including Ordnance, Collected during Range Clearance

Section 313(a)(1) of the National Defense Authorization Act for Fiscal Year 

20027

 required DOD to provide Congress with a comprehensive assessment 

of unexploded ordnance, discarded military munitions, and munitions 

constituents at current and former DOD facilities.8

 The law required the 

assessment to include an estimate of the aggregate projected cost of 

7

Pub. L. No. 107-107 (Dec. 28, 2001).

8

This report deals with operational ranges on active installations. In December 2003, we 

issued a report on closed installations or those in the process of closing. As of September 

2002, DOD had closed 542 ranges on open installations and 74 ranges on installations closed 

under the Base Realignment and Closure process, and is required to clean up munitions 

contamination on these ranges, if present. See U.S. General Accounting Office, Military 

Munitions: DOD Needs to Develop a Comprehensive Approach for Cleaning Up 

Contaminated Sites, GAO-04-147 (Washington, D.C.: Dec. 19, 2003).
Page 10 GAO-04-601 DOD Operational Ranges

remediation (or cleanup) at operational ranges, to be presented as a range 

of costs including a low and high estimate, and delivered to Congress in 

2003 in DOD’s report on the Defense Environmental Restoration Program. 

In April 2003, DOD reported its estimate for the total cost to address the 

potential liability associated with unexploded ordnance, discarded military 

munitions, and munitions constituents at operational ranges to be between 

$16 billion and $165 billion. 

Collecting Inventory Data 

and Estimating Cleanup 

Costs

To provide Congress with estimated costs to clean up operational ranges, 

DOD used inventory data available at the time of its April 2003 report, 

which counted 10,444 operational ranges located in the United States and 

its territories. At the direction of Congress, only operational ranges in the 

United States and its territories were to be considered for the purpose of 

estimating cleanup costs. According to DOD, these cost estimates were 

supported by individual service estimates, which in turn were supported by 

summary information on the number of operational ranges and acreage 

assumed to contain a high density of unexploded ordnance and munitions 

constituents—such as target areas, detonation sites, and demolition 

areas—and the percentage of acreage assumed to contain a low density of 

contamination from unexploded ordnance and munitions constituents, 

such as buffers, training areas, and maneuver areas.

The services continued to inventory operational ranges under section 366 

of the National Defense Authorization Act for Fiscal Year 2003,9

 which 

required DOD to inventory operational ranges to address training range 

sustainment and encroachment concerns and submit the inventory to 

Congress as part of the President’s fiscal year 2005 budget request early in 

calendar year 2004. The scope of this inventory effort addressed 

operational range training and testing capacities and capabilities, and 

specific constraints on the use of operational ranges, but did not 

specifically include data on the cleanup of unexploded ordnance, discarded 

military munitions, or munitions constituents. 

9

Pub. L. No. 107-314 (Dec. 2, 2002).
Page 11 GAO-04-601 DOD Operational Ranges

We previously reported that the two key data needed to develop 

operational range cleanup costs were (1) an accurate and complete 

operational range inventory and (2) a consistent methodology for 

estimating costs.10 Reliable cost estimates can be critical information for 

DOD and Congress when considering the potential benefits of closing 

operational ranges or entire installations versus the potentially very high 

cost of cleaning up such sites. However, such estimates must be based on 

accurate data that, in the case of operational ranges, begins with a 

complete and accurate operational range inventory. The costs for cleaning 

up ranges can be extensive. For example, DOD estimates it will cost $22.6 

million to clean up Fort McClellan in Alabama, recommended for closure 

under DOD’s base realignment and closure program in 1995, and $247 

million to clean up Fort Ord in California, closed in 1994. DOD officials 

explained that wide variations in cost can be attributed to a number of 

factors, such as future land use, technical complexities, and the high level 

of difficulty to locate, recover, and destroy ordnance located beneath the 

ground surface. 

Environmental Laws and 

Regulations Affecting DOD 

Installations and 

Operational Ranges

DOD’s operations at military installations and operational ranges in the 

United States are subject to laws and regulations governing a variety of 

environmental concerns, from water quality to the treatment and disposal 

of hazardous wastes. These laws include the Safe Drinking Water Act, the 

Clean Water Act, RCRA, the Federal Facility Compliance Act, and CERCLA. 

DOD is also generally required to comply with state and local 

environmental statutory and regulatory requirements on its installations 

and operational ranges. DOD has proposed that Congress specifically 

exempt it from requirements to clean up unexploded ordnance, munitions, 

and munitions constituents on operational ranges under RCRA and 

CERCLA. 

The Safe Drinking Water Act authorizes EPA to issue national primary 

drinking water regulations setting maximum contaminant level standards 

for drinking water that must be met by public water systems.11 EPA may 

authorize states to carry out primary enforcement authority for 

10U.S. General Accounting Office, Environmental Liabilities: DOD Training Range 

Cleanup Cost Estimates Are Likely Understated, GAO-01-479 (Washington, D.C.: Apr. 11, 

2001). 

11A public water system is subject to the Safe Drinking Water Act if the system has at least 15 

service connections or regularly serves at least 25 individuals.
Page 12 GAO-04-601 DOD Operational Ranges

implementing the Safe Drinking Water Act if, among other things, the state 

adopts drinking water regulations that are no less stringent than the 

national primary drinking water regulations. EPA has set standards for 

approximately 90 contaminants in drinking water, including 

microorganisms, organic chemicals, inorganic chemicals, disinfectants, 

disinfection byproducts, and radioactive substances.12 None of the more 

than 200 chemical contaminants associated with munitions use are 

currently regulated under the Safe Drinking Water Act. 

The 1996 amendments to the Safe Drinking Water Act required EPA to 

establish criteria for a monitoring program for unregulated contaminants 

(where a maximum contamination level has not been established) and to 

publish a list of contaminants—chosen from those not currently monitored 

by public water systems—to be monitored. EPA’s regulation, referred to as 

the Unregulated Contaminant Monitoring Regulation, was issued in 1999 

and supplemented in 2000 and 2001.13 The purposes of the regulation are to 

determine whether a contaminant occurs at a frequency and in 

concentrations that warrant further analysis and research on its potential 

effects and to possibly establish future drinking water regulations. The 

first step in the current program required public water systems serving 

more than 10,000 customers (and a sample of 800 small public water 

systems serving fewer than 10,000) to monitor drinking water for 

perchlorate and 11 other unregulated contaminants over a consecutive 12-

month period at any point between 2001 and 2003, and report the results to 

the EPA. Under this regulation, some DOD installations were required to 

monitor drinking water for perchlorate and other munitions-related 

contaminants and to report the results. 

12None of the approximately 90 contaminants regulated by EPA under the Safe Drinking 

Water Act are associated with the use of military munitions. Some regulated contaminants, 

such as arsenic, may result from the use of military munitions, but EPA does not regulate 

arsenic resulting from such use. It does, however, regulate arsenic found in drinking water 

resulting from the erosion of natural deposits, runoff from agriculture sites, and certain 

production wastes.

1340 C.F.R. § 141.40.
Page 13 GAO-04-601 DOD Operational Ranges

The Clean Water Act authorizes EPA to regulate the discharge of pollutants 

into waters in the United States. EPA may authorize states to carry out a 

state program in lieu of the federal program if the state program is at least 

equivalent to the federal program and provides for adequate enforcement. 

Under the Clean Water Act’s National Pollution Discharge Elimination 

System (NPDES) program, facilities discharging pollutants into waters of 

the United States are required to obtain an NPDES permit from EPA or 

authorized states. NPDES permits include specific limits on the quantity of 

pollutants that may be discharged and require monitoring of those 

discharges to ensure compliance. EPA’s list of the toxic pollutants subject 

to regulation under the Clean Water Act includes nitrobenzene, a chemical 

that is on DOD’s list of 20 constituents of greatest concern.14 

RCRA requires owners and operators of facilities that treat, store, and 

dispose of hazardous waste, including federal agencies, to obtain a permit 

specifying how their facilities will safely manage the waste. Under RCRA’s 

corrective action provisions, facilities seeking or holding RCRA permits 

can be required to clean up their hazardous waste contamination. The 

corrective actions can be specified in the facility’s operating permit, in a 

separate corrective action permit, or through an enforcement order. EPA 

also has authority under RCRA to order a cleanup of hazardous waste when 

there is an imminent and substantial endangerment to public health or the 

environment. EPA may authorize states to administer their own programs 

in lieu of the federal program, as long as these programs are equivalent to 

and consistent with the federal program and provide for adequate 

enforcement. EPA’s regulations define hazardous wastes to include those 

that are specifically listed in the regulations as well as those that are 

“characteristic wastes.” Characteristic hazardous wastes are defined as 

wastes that are ignitable, corrosive, reactive, or toxic. A federal district 

court in California recently ruled, in part, that perchlorate is a hazardous 

waste under RCRA because it is ignitable.15

1440 C.F.R. § 401.15.

15Castaic Lake Water Agency v. Whittaker Corp, 272 F. Supp. 2d 1053 (C.D. Cal. 2003). The 

conclusion that perchlorate is a hazardous waste was the first step in the court’s analysis of 

whether perchlorate is a hazardous substance under CERCLA. (The definition of hazardous 

substances under CERCLA includes hazardous waste under RCRA.)
Page 14 GAO-04-601 DOD Operational Ranges

Under section 107 of the Federal Facility Compliance Act of 1992,16 EPA 

was required, in consultation with DOD and the states, to issue a rule 

identifying when military munitions become hazardous waste under RCRA, 

and to provide for protective storage and transportation of that waste. 

Under the rule issued by EPA, military munitions are subject to RCRA 

when, among other things, (1) unexploded munitions or their constituents 

are buried or otherwise disposed of, or (2) when used or fired munitions 

are taken off-range.17

CERCLA governs the cleanup of releases or threatened releases of 

hazardous substances, pollutants, or contaminants. CERCLA’s definition of 

a hazardous substance includes substances regulated under various other 

environmental laws, including RCRA, the Clean Air Act, the Clean Water 

Act, and the Toxic Substances Control Act. Under section 120 of CERCLA, 

the federal government is subject to and must comply with CERCLA's 

requirements to the same extent as any nongovernmental entity. DOD’s 

cleanup under CERCLA section 120 is interrelated with its environmental 

restoration program under section 211 of the Superfund Amendments and 

Reauthorization Act of 1986.18 

Contaminants Associated 

with Military Munitions

According to DOD, there are more than 200 chemicals associated with 

military munitions, and of these, 20 are of great concern due to their 

widespread use and potential environmental impact. TNT, Propanetriol 

trinitrate (nitroglycerin), Royal Demolition Explosive, and perchlorate are 

among the 20. Perchlorate is the primary oxidizer in propellants, present in 

varying amounts in explosives, and is highly soluble. According to EPA, an 

estimated 90 percent of the perchlorate produced in the United States is 

manufactured for use by the military and the National Aeronautics and 

Space Administration. Typical production quantities average several 

million pounds per year. Nonmilitary uses for perchlorate include 

fireworks, flares, fertilizer, and automobile airbags. As of 2004, EPA 

reported that 34 states confirmed perchlorate contamination in ground and 

16Section 107 of the Federal Facility Compliance Act amended RCRA by adding a new 

section 3004(y), codified at 42 U.S.C. § 6924(y). 

1740 C.F.R § 266.202.

18Under the Defense Environmental Restoration Program established under section 211, 

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. 
Page 15 GAO-04-601 DOD Operational Ranges

surface water, and in states where EPA determined the source of the 

contamination, it attributed a significant portion to defense manufacturing 

and test sites.

EPA has not established a federal drinking water standard for perchlorate. 

However, in 1999, EPA established a provisional reference dose for 

perchlorate in drinking water of between 4 and 18 parts per billion. A 

reference dose is an estimate of the daily exposure to a human that would 

not pose a significant risk of harmful effects. In October 2003, the National 

Academy of Sciences (Academy) began a study of the best scientific model 

to use for determining a drinking water standard or reference dose for 

perchlorate, if any. According to EPA, the Academy’s study will take about 

one year to complete. Based on recommendations from the Academy, EPA 

will decide whether to regulate the contaminant and will have up to 2 years 

after making an affirmative determination to propose a national primary 

drinking water regulation for perchlorate.19 An EPA official told us that 

updating drinking water standards can take 2 to 3 years and predicted that 

a perchlorate standard will likely not be available until 2006 or 2008. 

In the meantime, some states that detected perchlorate in various media, 

such as groundwater, have established state guidance or advisory levels for 

the contaminant. As of February 2004, seven states have established 

interim perchlorate advisory levels. Of those states, Maryland and 

Massachusetts have the lowest perchlorate advisory level of 1 part per 

billion. On March 12, 2004, California revised its advisory action level for 

perchlorate from 4 parts per billion to 6 parts per billion. 

DOD’s Inventory and 

Cost Estimates for 

Operational Range 

Cleanup May Not 

Provide Congress with 

a Reliable Picture of 

Potential Liabilities 

DOD’s estimate that it would cost between $16 billion and $165 billion to 

clean up unexploded ordnance, discarded military munitions, and 

munitions constituents on operational ranges is questionable. To determine 

the costs of operational range clean up, DOD had to first inventory its 

operational ranges and obtain data such as the type of range and munitions 

used. However, the military services used inventory data that were 

collected for different purposes over different periods of time and verified 

with varying degrees of analytical rigor. Next, the costs of operational 

range cleanup were calculated using a mix of unvalidated assumptions 

provided by DOD and assumptions provided by the individual services, as 

1942 U.S.C. § 300g-1(b)(1)(E).
Page 16 GAO-04-601 DOD Operational Ranges

well as actual service data, where available. Consequently, DOD’s overall 

cost estimates were based on assumptions, estimates, and actual data that 

differed across the services and that raise questions about the reliability of 

DOD’s estimated costs to clean up operational ranges. 

Operational Range 

Inventory Process Lacked a 

Common Framework and 

Analytical Rigor

Each service inventoried its operational ranges and collected data on range 

acreage and munitions used, using various methodologies over different 

periods of time. (See table 1 for the starting and ending dates of the 

service’s inventories.) Services also conducted inventories for different 

reasons, such as to respond to pending legislation on ranges, public 

concern about military use of ranges, or simply to gather data to calculate 

cleanup cost estimates. The rigor of the analysis and the degree of the 

validity of the inventory results varied by service. The inconsistencies in 

how DOD collected and analyzed data on operational ranges raise 

questions about the reliability of DOD’s inventory. 

Table 1: Dates Service Inventories Were Conducted

Source: GAO analysis of military service data. 

The Air Force inventory of operational ranges in the United States and its 

territories was based on a survey sent to field command levels to estimate 

costs to clean up operational ranges. Service officials said survey data was 

validated during on-site field inspections or, in some cases, brief desk 

reviews to assure surveys were complete and free of obvious errors. As of 

December 2002, the Air Force counted 222 active ranges, 23 inactive 

ranges, and 23 ranges that were not categorized as either active or inactive. 

Together, Air Force operational ranges covered 6,423,161 acres.

Military Service Inventory started Inventory ended

Air Force August 2001 December 2002

Army July 2000 December 2002

Marine Corps October 2001 November 2002

Navy December 1999 January 2000
Page 17 GAO-04-601 DOD Operational Ranges

The Army’s inventory of operational ranges was conducted concurrently 

with an inventory of nonoperational ranges and was based on field surveys. 

According to Army officials, the Army initiated an inventory of its ranges 

primarily in response to anticipated legislation on the use of ranges,20

which required a comprehensive inventory of DOD ranges as well as a 

collection of descriptive data about each range, such as the acreage and 

types of munitions used on the range. The Army’s inventory was also 

conducted in response to DOD directives issued in August 1999 that 

required the services to establish and maintain an inventory of operational 

ranges and data on munitions and ordnance.21 To inventory ranges, the 

Army used contract support staff who requested data from field commands 

and installations, and then sought to validate the data through on-site visits. 

Army officials said the Army’s inventory of operational ranges was 

completed in December 2002, and encompassed 9,427 active ranges, 377 

inactive ranges, and 4 ranges not designated active or inactive. In total, 

Army operational ranges covered 14,991,072 acres in the United States and 

its territories. 

Similar to the Army, the Marine Corps conducted an inventory of its 

operational ranges primarily in response to anticipated legislation on the 

use of ranges and DOD directives that required the services to establish and 

maintain an inventory of operational ranges and data on munitions and 

ordnance. The Marine Corps developed its inventory from an archive data 

search and surveys sent to installations. Headquarters’ officials reviewed 

the surveys to assure that submitted data agreed with data in the archive 

search. As of December 2002, the Marine Corps counted 216 operational 

ranges totaling 1,980,119 acres in the United States and its territories. 

According to headquarters’ officials, the Marine Corps did not distinguish 

between active and inactive ranges but designated all ranges as 

operational. 

20On September 26, 1997, DOD published a proposed range rule on closed, transferred, and 

transferring ranges containing military munitions. The proposed rule identified a process for 

evaluating response action on closed, transferred, and transferring ranges and required a 

comprehensive inventory of DOD ranges, including a collection of descriptive data for each 

range. However, the proposed rule applied to nonoperational ranges only. On November 13, 

2000, DOD withdrew the proposed range rule from the rule-making process because DOD, 

EPA, and federal land managers could not reach consensus on several key issues, including 

how explosive safety would be handled under the rule, concurrence on remedial actions, 

and who would decide the remedy. 

21DOD Directives 4715.11 and 4715.12. 
Page 18 GAO-04-601 DOD Operational Ranges

The Navy’s inventory of operational ranges in the United States and its 

territories was conducted at the request of the Navy’s Environmental 

Readiness Division. The Navy’s inventory was prepared in response to the 

anticipated inventory requirements of DOD’s proposed range rule and 

because of increased public and regulatory scrutiny of military ranges, 

Navy officials said. The inventory was conducted through surveys sent to 

the installations. As of December 2002, Navy operational ranges totaled 121 

active ranges and 31 inactive ranges on 1,284,374 acres. 

As of April 2003, when DOD reported its estimated cost to clean up 

operational ranges, DOD’s inventory included 10,444 operational ranges 

totaling 24.6 million acres in the United States and its territories. (See table 

2 for a breakout of operational ranges by service and status and total 

acres.) 

Table 2: Active and Inactive Operational Ranges and Acreage as Reported by DOD 

in April 2003 

Source: GAO analysis of military service data. 

a

According to Army officials, the Army’s inventory of operational ranges was finalized in the summer of 

2003 and revised to 9,427 active and 377 inactive ranges totaling about 15 million acres in the United 

States and its territories. 

DOD continued to inventory its operational ranges. The National Defense 

Authorization Act for Fiscal Year 2003 required DOD to develop a plan to 

address training range issues, such as range sustainment and 

encroachment and, as part of this plan, to develop a range inventory system 

that included all available operational training ranges. In January 2003, 

DOD provided the services with an inventory framework and data 

definitions to ensure reporting consistency and required the services to 

complete detailed inventories of all of their operational ranges. DOD 

Operational Ranges

Active Inactive

Not 

categorized Total 

Total 

acreage

(in millions)

Air Force 222 23 23 268 6.4

Armya 9,427 377 4 9,808 15.0

Marine 

Corps 0 0 216 216 1.9

Navy 121 31 0 152 1.3

DOD total 9,770 431 243 10,444 24.6
Page 19 GAO-04-601 DOD Operational Ranges

revised its existing inventory of operational ranges to meet this new 

requirement. Because the revised inventory was conducted for different 

purposes, using a scope and set of assumptions that were different from 

the inventory data used to estimate cleanup costs, it identified a different 

number of operational ranges. For example, the inventory for developing 

the cost estimates used actual operational range acreage, whereas the 

revised inventory used actual and potential operational range acreage. 

Further, the revised inventory is divided into range complexes and 

individual ranges, and includes operational ranges outside the United 

States and its territories not included in the inventory DOD used to 

estimate cleanup costs. 

In February 2004, DOD released the results of its training range plan and 

revised inventory. The revised inventory listed 353 range complexes and 

172 individual ranges on 26 million acres worldwide. These numbers differ 

from the inventory data DOD used to estimate cleanup costs, which 

counted 10,444 operational ranges on 24.6 million acres in the United States 

and its territories primarily because of the aggregation of individual ranges 

into complexes and the inclusion of ranges outside the United States and 

its territories. For example, under the prior inventory, Fallon Naval Air 

Station, in Nevada, reported it had 150,365 acres of rangeland, but under 

the new inventory, Fallon reported it had just 103,300 acres of actual and 

potential rangeland. Also under the prior inventory, the Marine Corps 

reported that Camp Lejeune, in North Carolina, had 95,872 acres of 

rangeland, while under the new inventory, Camp Lejeune reported it had 

152,000 acres of actual and potential rangeland (even though the entire 

installation encompasses just 153,000 acres). The Marine Corps also 

reported that Camp Pendleton, in California, had 39,084 acres of rangeland 

under the old inventory, but under the new inventory, Camp Pendleton 

reported it had 114,000 acres of actual and potential rangeland, almost a 

threefold increase. 

While the 2003 and 2004 inventories are not readily comparable because of 

the varying scope and definitions used to develop the revised inventory, the 

difference between the two highlights the difficulty in understanding the 

basis for, and the results of, DOD’s cost estimates. Finally, we believe the 

differences in the two inventories may further complicate efforts of 

Congress to identify the potential liabilities that may exist if operational 

ranges or installations are closed and require cleanup. 
Page 20 GAO-04-601 DOD Operational Ranges

Cost Estimates Were 

Calculated Using a Mix of 

Differing Assumptions, 

Estimates, and Actual Data

In 2002, DOD provided guidance to the services on how to estimate costs 

for cleaning up operational ranges. This guidance specified the scope for 

estimating costs but allowed for variation across the services. According to 

DOD officials, because the requirement to estimate cleanup costs was a 

one-time congressional requirement, DOD directed the services to limit 

their data gathering efforts by using certain costing assumptions and a 

computer-costing model in combination with already existing data. 

Examples of the scope and some of the assumptions DOD used to estimate 

costs include the following:

• The scope of the inventory was limited to operational ranges within the 

United States and its territories because DOD believed that was what 

Congress intended.

• The scope excluded certain operational ranges, such as water ranges, 

because DOD did not have a model for estimating costs associated with 

such ranges and did not have any significant historical experience on 

which to base an estimate. DOD also did not develop cost estimates for 

several types of airspace, such as warning areas and restricted areas.

• DOD directed the services to use both a computer-costing model that 

automatically assigned certain values for the cleanup costs of 

unexploded ordnance and discarded military munitions and an 

electronic worksheet to estimate costs to clean up munitions 

constituents.

• DOD provided cost assumptions to the services based on operational 

range acreage and other variables. For example, the services were 

directed to divide range acreage into areas assumed to have a high 

density of contamination and a low density of contamination and, on 

that basis, calculate individual cleanup costs.

• DOD also provided specific assumptions to calculate costs for various 

cleanup activities. For example, to estimate the cost to remove 

unexploded ordnance from a highly contaminated range area, the 

services were told to assume they would need to remove ordnance from 

50 percent of that area to calculate the high cost estimate and 5 percent 

of that area to calculate the low cost estimate. 

DOD said its assumptions were based on discussions with the services and 

developed through consensus. DOD could not provide any documentation 

that the assumptions they asked the services to use were validated—a 
Page 21 GAO-04-601 DOD Operational Ranges

confirmation of the reasonableness and justification for assumptions 

used—and a senior DOD official told us that, in fact, the assumptions were 

not validated. 

Furthermore, DOD instructions to the services allowed them to use 

additional assumptions or site-specific data so that cost estimates were 

calculated based on a mix of actual data and assumptions. Based on our 

review of DOD’s 2003 report to Congress, and discussions with service 

officials on their methodologies to estimate costs, we found DOD did not 

fully explain the mix of assumptions and data used and how this mix 

affected the cost estimates, so that the usefulness of DOD’s overall cleanup 

cost estimates to Congress is questionable.

The inconsistencies in how the services developed their cost estimates are 

evident in areas such as how the services calculated high-density acreage 

(that is, the area of a range containing a high density of ordnance) and the 

costs for cleaning up these acres. For example, although DOD guidance 

directed the services to estimate what proportion or percentage of 

operational range acreage contained a high density of unexploded 

ordnance and munitions constituents, and specified how various types of 

ranges were to be treated for cost estimating purposes, each service 

performed this calculation differently. If site-specific data was unavailable, 

the Marine Corps used varying percentages based on the characteristics of 

similar ranges to determine those that were highly contaminated. Our 

analysis showed that for about two-thirds of its operational ranges, the 

Marine Corps assumed 10 percent of its nonsmall arms or multipurpose 

range acreage was highly contaminated. However, based on a review of the 

Marine Corps’ total cleanup cost estimates for operational ranges, GAO 

determined that the Marine Corps calculated its costs assuming that an 

average 53 percent of range acreage has highly contaminated. In contrast, 

the Air Force and the Army used estimated data to determine that 44 

percent and 60 percent of their acreage was highly contaminated, 

respectively.22 Further, the Air Force did not designate a percentage of each 

operational range with a high density of contamination and a low density of 

contamination, but rather defined each operational range as either 100 

percent high density or 100 percent low density. The Navy used actual data 

to determine that 11 percent of its operational range acreage was highly 

22Army officials told us the Army assumed 60 percent of operational range acreage was 

highly contaminated, but our analysis of Army data (see table 4) shows the Army actually 

assumed that 58 percent of acreage was highly contaminated. 
Page 22 GAO-04-601 DOD Operational Ranges

contaminated. (Figure 4 shows the high and low density acreage by service 

used to estimate cleanup costs.)

Figure 4: High and Low Density Operational Range Acreage Used to Estimate 

Cleanup Costs, by Service

Based on the data provided by the services, the model calculated four 

totals for each operational range: a low and high estimated cost to clean up 

the portion of the range assumed to have a low level of contamination, and 

a low and high estimated cost to clean up the portion of the range assumed 

to be highly contaminated. Low estimates for low and high contamination 

areas were combined to calculate a total low estimate, and high estimates 

for low and high contamination areas were combined to calculate a total 

high estimate. (See table 3 for low and high estimates by service.)
Page 23 GAO-04-601 DOD Operational Ranges

Table 3: Low and High Cost Estimates to Clean Up Unexploded Ordnance, 

Discarded Military Munitions, and Munitions Constituents 

Sources: The Fiscal Year 2002 Defense Environmental Restoration Program report and military service data.

a

Estimates do not add due to rounding.

In general, using the model and standardized assumptions should have 

produced estimates with some variation across the services because of 

differing missions, operational practices, and types of munitions used. 

However, as reflected in table 4, a tenfold difference in the average cost to 

clean up an acre of highly contaminated rangeland calls into question the 

mix of different assumptions and data used by the services to estimate 

costs. For example, the Air Force’s average cost to clean up an acre with a 

high density of contamination was $755, whereas the Army’s estimate was 

$7,577. As a result, the services cost estimates are not comparable. (Table 4 

shows the total and average cost per acre estimates by service.) 

Table 4: High Cost Estimates to Clean Up an Acre with a High Density of 

Contamination, by Service

Source: GAO analysis of military service data. 

Billions of dollars

Low estimate High estimate

Air Force 1.2 14.0

Army 14.5 141.5

Navy 0.2 2.5

Marine Corps 0.5 6.7

DODa 16.0 165.0

Service Acreage 

High cost estimate 

(dollars)

Average high cost 

per acre (dollars)

Air Force 2,835,579 2,140,072,819 755

Army 8,691,311 65,855,410,348 7,577

Marine Corps 1,023,623 3,719,488,388 3,634

Navy 134,459 920,669,000 6,847
Page 24 GAO-04-601 DOD Operational Ranges

DOD Does Not Have a 

Comprehensive Policy 

on Contaminants 

Associated with 

Military Munitions and 

Has Not Specifically 

Cleaned Up Known 

Perchlorate 

Contamination

DOD does not have a comprehensive policy requiring sampling or cleanup 

of the more than 200 chemical contaminants associated with military 

munitions on operational ranges. However, DOD installations have 

sampled for and cleaned up munitions-based constituents when directed by 

state regulatory authorities. With regard to perchlorate, DOD has issued 

sampling policies but does not provide specific funding for such sampling. 

Nevertheless, we found some installations have sampled and monitored for 

perchlorate to meet the requirements of environmental laws and 

regulations, such as RCRA and the Unregulated Contaminant Monitoring 

Regulation. During visits to six installations that reported high levels of 

perchlorate, we found that none were cleaning up perchlorate 

contamination. At six of the seven installations we visited, perchlorate 

contamination was largely the result of researching, manufacturing, 

testing, and disposing of munitions, and not the use of munitions during 

training. 

Previous DOD Policy Did 

Not Require Cleanup or 

Sampling for Contaminants 

Associated with Military 

Munitions

According to EPA, of the more than 200 chemicals associated with military 

munitions, which include 20 that DOD considers to be of greatest concern 

due to their widespread use and potential environmental impact, none are 

specifically regulated under the Safe Drinking Water Act. Further, except in 

some specific instances, EPA does not generally use its authority under 

other environmental laws, such as RCRA and CERCLA, to require DOD to 

conduct cleanups on operational ranges.23 An EPA official told us that 

although EPA is concerned with constituents associated with military 

munitions such as perchlorate and Royal Demolition Explosive, and the 

migration of plumes (pollutants that drain or flow through soil and water) 

from military ranges to groundwater, the agency generally does not 

interfere with DOD’s operation of its operational ranges. Recently, DOD 

proposed that Congress specifically exempt it from requirements to clean 

up unexploded ordnance, munitions, and munitions constituents that 

remain on operational ranges under RCRA and CERCLA. 

23In some instances, EPA has used its authority under these acts to require cleanup of 

munitions constituents on operational ranges. For example, at Fort Richardson, Alaska, 

EPA required the Army to clean up contamination caused by munitions containing white 

phosphorus. 
Page 25 GAO-04-601 DOD Operational Ranges

DOD policy does not generally require the services to clean up or sample 

for munitions contaminants because, according to DOD officials, these 

contaminants are deposited on operational ranges in the course of the 

normal and intended use of these munitions. Yet, DOD may be required by 

EPA or states to sample and clean up its munitions contaminants under 

various environmental laws and regulations on operational ranges. For 

example, under the Clean Water Act, facilities that discharge pollutants into 

surface water are required to obtain a NPDES permit from EPA or an 

authorized state agency. Several states have required some DOD 

installations to monitor for various contaminants associated with military 

munitions as part of the NPDES permit process. For example, the Regional 

Water Quality Control Board in San Diego and the Hampton Roads 

Sanitation District in Hampton Roads, Virginia, required Navy facilities to 

monitor their water discharges for various constituents that are on EPA’s 

list of toxic pollutants under the Clean Water Act.24 Under the Unregulated 

Contaminant Monitoring Regulation, EPA required some installations to 

sample for and report on 12 unregulated contaminants in drinking water 

during any 12-month period between 2001 and 2003. The list of 

contaminants included four munitions-related contaminants—perchlorate, 

2,4 and 2,6 dinitrotoluene, and nitrobenzene. In April 2004, DOD reported 

that 36 installations had sampled for the presence of unregulated 

contaminants in drinking water, including perchlorate, under this 

regulation. Of these, 33 installations reported no perchlorate was detected 

or detection results were below the reporting limit of 4 parts per billion. 

Only three Air Force installations detected perchlorate above the reporting 

limit, ranging from just over 4 parts per billion to 46 parts per billion. 

Revised DOD Policy Directs 

Sampling for Perchlorate 

under Certain Conditions 

but Little Sampling Has 

Been Done

In November 2002, DOD issued its first policy on perchlorate assessment 

that stated the services may sample and assess for perchlorate if there was 

a reasonable basis to suspect both a potential presence of perchlorate and 

a likely pathway that could lead to human exposure. The policy stated that 

the services could fund assessments using the operations and maintenance 

environmental compliance account, but specified that sampling should be 

considered a lower priority (Class II) environmental project and, as we

24See 40 C.F.R. § 401.15. The three constituents—2,4 and 2,6 dinitrotoluene (used to produce 

explosives and ammunition and known to cause cancer) and nitrobenzene (may be used in 

defense manufacturing and linked to blood disorders)—are on DOD’s list of munitions 

constituents of greatest concern. 
Page 26 GAO-04-601 DOD Operational Ranges

found in a prior effort, was unlikely to be funded.25 Finally, the policy 

directed those installations that sampled for and found perchlorate to 

report to DOD on the location and amount of perchlorate found. On 

September 29, 2003, DOD issued a revised policy on perchlorate sampling 

that directed the services to (1) consolidate data on perchlorate detections, 

including data developed in response to environmental laws such as the 

Clean Water Act and Safe Drinking Water Act, and (2) sample any 

previously unexamined sites, including ranges, where a perchlorate release 

is suspected because of prior DOD activities and where human exposure is 

likely. The policy stated that the services should fund sampling using the 

same environmental compliance account specified in the previous policy, 

but elevated sampling to a higher (Class I) funding priority and thus made it 

more likely to be funded. However, when DOD issued its policy, funding 

had already been allocated to Class I requirements for fiscal year 2004. In 

future years, unless specific or additional funding is added, perchlorate 

sampling will have to compete with other high priority environmental 

requirements and may not be funded.

In implementing the revised policy, the services added a third criterion 

requiring that installations coordinate with, or obtain written approval 

from, headquarters and the chain of command before sampling for 

perchlorate. However, if sampling is specifically required by an 

environmental law or state agency, the service policies do not require 

installations to request approval or notify headquarters before sampling. 

During visits we made to selected installations with reported perchlorate 

contamination between October 2003 and January 2004, we found 

installations were not sampling under the revised policy to determine the 

presence of perchlorate on operational ranges. More broadly, as of 

25To assure compliance with the requirements of environmental laws, DOD has an 

environmental quality program that is largely funded by DOD’s appropriation for operation 

and maintenance activities. This account also funds a wide range of installation activities 

such as military training, base operations, and property management. As such, DOD’s 

environmental quality program must compete with these other activities for funding. As 

GAO reported in June 2003, DOD’s environmental quality program has a ranking system for 

funding environmental activities where activities ranked Class 0 or I must be funded in the 

current program year because of a law or regulation, whereas funding for activities ranked 

Class II or III may be deferred because there is no legislative requirement in the current 

budget year. We found DOD did not always have sufficient funds to pay for environmental 

priorities and sometimes did not follow the program’s ranking system and instead funded 

lower priority activities while not funding some higher priorities. See U.S. General 

Accounting Office, Environmental Compliance: Better DOD Guidance Needed to Ensure 

That the Most Important Activities Are Funded, GAO-03-639 (Washington, D.C.: June 17, 

2003).
Page 27 GAO-04-601 DOD Operational Ranges

February 2004, Marine Corps and Navy officials said that no installations 

had requested permission to sample under this policy. According to the Air 

Force, three installations asked for permission to sample for perchlorate 

because EPA had asked that they sample. Air Force headquarters approved 

two of the requests but denied the third because, according to Air Force 

headquarters, there was not a reason to suspect the presence of 

perchlorate. Four Army installations have asked for approval to sample for 

perchlorate, and Army headquarters approved all four as of March 2004, an 

Army headquarters official said. Overall, this suggests that little sampling is 

being done under DOD’s revised perchlorate policy.

Although none of the installations had begun sampling under DOD’s revised 

policy, during our visits we found a few installations had sampled and 

monitored for perchlorate to meet the requirements of certain 

environmental laws and regulations. Table 5 summarizes the perchlorate 

sampling that has been conducted at installations we visited as reported by 

DOD as of April 2004. 

Table 5: Summary of Perchlorate Sampling Conducted at Installations Visited by GAO

Source: DOD perchlorate sampling data as of April 2004.

a

Although it was not reported by DOD as of April 2004, we found during our visit to White Sands 

Missile Range that officials sampled for perchlorate as part of an RCRA application.

Installation

Number of 

samples 

collected

Number of 

positive 

detections

Range of 

concentrations 

detected (in parts per 

billion) Source of perchlorate contamination

Edwards Air Force 

Base

413 309 Up to 2,100,000 in soil 

and up to 30,700 in 

groundwater

Propulsion research and rocket test stand; 

maintenance; landfill 

Holloman Air Force 

Base

2 1 7,600 Research, development, testing and evaluation 

Aberdeen Proving 

Ground

1,193 540 Less than 1 and 

up to 

12,000 

Training with pyrotechnics and smoke; use of 

propellants, ordnance, smoke and chemical agents

Redstone Arsenal Not reported Not reported Up to 37,000 Rocket testing

White Sands Missile 

Rangea

Not reported Not reported Not reported Not reported

Naval Air Weapons 

Station, China Lake

12 12 Up to 720 Research, development and testing; disposal; 

possible natural occurrence

Naval Surface 

Warfare Center, 

Indian Head

708 278 Up to 480,000 Disposal, open burning, unknown source
Page 28 GAO-04-601 DOD Operational Ranges

During our visits, we found the following installations had sampled for and 

monitored perchlorate to meet the requirements of RCRA or the Safe 

Drinking Water Act:

• In 1999, as part of an application under RCRA to close an open burning 

and detonation facility used to destroy excess and obsolete ammunition, 

the state of New Mexico required White Sands Missile Range, in New 

Mexico, to sample for contaminants, including perchlorate. The former 

open burning and detonation facility is located on an operational range. 

Groundwater sampling detected high levels of perchlorate—up to 25,000 

parts per billion.26 The Army installed 56 monitoring wells on the range 

to map the plume. Each well is sampled quarterly. After four years of 

quarterly sampling and monitoring, Army officials said the plume is 

stable and contained, which means it is isolated underground and not 

expected to move. Further, officials said there is no indication that 

perchlorate has migrated outside the identified plume. Under its RCRA 

closure permit with the state of New Mexico, the Army must continue 

monitoring the groundwater for up to 20 years.

• Three of the seven installations we visited tested for perchlorate under 

the Safe Drinking Water Act’s Unregulated Contaminant Monitoring 

Regulation program. Edwards Air Force Base, in California, sampled 

twice in 2002 and reported that none of the 12 chemicals listed on the 

EPA list of unregulated contaminants, including perchlorate, were 

detected in any of the groundwater samples collected from drinking 

water wells. (Under the regulation, EPA required surface water systems 

to be sampled quarterly and groundwater systems to be sampled 

semiannually for one consecutive 12-month period.) Redstone Arsenal, 

in Alabama, sampled quarterly for a 12-month period beginning June 

2001. Two water intake sites were sampled (a drinking water source and 

a drinking water and industrial water source), both along the Tennessee 

River. Redstone Arsenal reported that perchlorate was not detected 

above the EPA sampling level of 4 parts per billion. Nearby Huntsville, 

Alabama, also sampled for perchlorate and detected no contamination, 

a Redstone Arsenal official said. Finally, although the requirements of 

the Unregulated Contaminant Monitoring Regulation did not apply to 

26Initially, Army officials said they believed the perchlorate contamination resulted from the 

burning of rocket motors in pits at the open burning and detonation facility. More recently, 

however, Army officials speculated that the plume in the hazardous test area is from another 

unknown source because it is uphill from the open burning and detonation facility.
Page 29 GAO-04-601 DOD Operational Ranges

the Naval Air Weapons Station, China Lake, in California, because its 

water supply system was too small, installation officials volunteered to 

sample for perchlorate and other unregulated contaminants. 

Accordingly, in October 2003, officials at China Lake sampled 10 

drinking water wells for perchlorate and other contaminants, but 

perchlorate was not detected. 

DOD Has Not Directed the 

Services to Clean Up Known 

Perchlorate Contamination 

According to information provided by DOD and officials at the installations 

we visited, the services were generally not cleaning up known perchlorate 

contamination. DOD officials explained that perchlorate is not a regulated 

contaminant and, therefore, there is no requirement to clean up perchlorate 

contamination.27 (Current DOD policy is that DOD will clean up 

perchlorate if there is imminent and substantial endangerment to the 

public.) The exceptions we found were two installations that had cleaned 

up perchlorate under demonstration projects designed to demonstrate 

perchlorate cleanup technologies. At the installations we visited, 

perchlorate contamination was generally the result of research, 

manufacturing, testing, and disposal of munitions (such as rocket motors) 

that contained high levels of perchlorate. In one case, the perchlorate 

resulted from training with smoke munitions containing perchlorate.

Although six of the seven sites we visited reported high levels of 

perchlorate contamination, none of these installations were conducting 

cleanup actions specifically directed at perchlorate. However, at two 

installations we visited—Edwards Air Force Base and the Naval Surface 

Warfare Center, Indian Head—officials said they conducted demonstration 

projects to develop perchlorate treatment and cleanup technologies in 

anticipation of future cleanup requirements. (See app. III for details on 

these demonstration projects.) 

At six of the seven installations we visited that had operational ranges and 

detectable levels of perchlorate, we found the perchlorate contamination 

was generally not due to training on operational ranges. Rather, we found 

that prior and ongoing research, manufacturing, testing, and disposal of 

27Although there is not a standard for perchlorate under the Safe Drinking Water Act, in at 

least one instance EPA required the Army to clean up munitions constituents in 

groundwater, such as perchlorate. EPA required the Massachusetts Military Reservation to 

clean up munitions constituents under its Safe Drinking Water Act authority, which allows it 

to take action when there is an imminent and substantial endangerment to the health of 

persons. 42 U.S.C. § 300i(a). 
Page 30 GAO-04-601 DOD Operational Ranges

rocket motors were primarily responsible for perchlorate contamination. 

(See app. IV for details of perchlorate contamination caused by such 

factors.) Only Aberdeen Proving Ground, in Maryland, reported that some 

perchlorate contamination was due to the use of perchlorate during 

training exercises on operational ranges. Further, Aberdeen was the only 

installation we visited where perchlorate had contaminated a neighboring 

municipal water supply. At Aberdeen, perchlorate concentrations of up to 5 

parts per billion have been detected in drinking water supply wells and 24 

parts per billion have been detected in groundwater. 

Between June and August 2002, Aberdeen Proving Ground sampled 

drinking water wells owned by the city of Aberdeen located in and along 

the northern border between the city and the installation, and detected 

perchlorate contamination in four wells ranging from 1.2 to 5 parts per 

billion. According to Aberdeen officials, the installation sampled for 

perchlorate because it was required to do so by the state of Maryland. 

Groundwater samples taken near the well field showed a large perchlorate 

plume with contamination levels up to 24 parts per billion. Aberdeen 

Proving Ground officials attributed the perchlorate contamination to 

intensive testing and training with smoke grenades and other obscurants. 

Until about mid-2002, during training exercises in the vicinity of the city of 

Aberdeen drinking water wells, Aberdeen Proving Ground trained troops 

using smoke grenades that contained perchlorate. After perchlorate was 

found in city drinking water, Aberdeen Proving Ground stopped all training 

with smoke grenades containing perchlorate. However, officials at 

Aberdeen Proving Ground are not cleaning up the perchlorate detected in 

city wells. Instead, both the city of Aberdeen and the installation sample 

finished water and production wells on an alternating monthly schedule: 

Finished water is sampled weekly, four production wells are sampled twice 

a month, and the remaining eight production wells are sampled monthly. 

Recent sampling has detected contamination below the EPA interim 

assessment guidance of 4 parts per billion, but in some cases, well samples 

have been above the Maryland Department of the Environment public 

health advisory for perchlorate, which is 1 part per billion for drinking 

water. In the event a sample is found to be above the Maryland state 

advisory limit, the city of Aberdeen blends well water without perchlorate 

with well water containing perchlorate to lower the concentration level to 

below 1 part per billion. The Army stated that it would not clean up the 

perchlorate contamination at Aberdeen until an EPA maximum 

contaminant level for perchlorate in drinking water is established.
Page 31 GAO-04-601 DOD Operational Ranges

Conclusions Because of DOD’s approach to how it inventoried its operational ranges for 

munitions and how it estimated the costs to clean up those ranges, both the 

inventory and the cost estimates are questionable. Further, DOD did not 

fully disclose to Congress the basis and limitations of its estimates, 

including identifying estimates based on direct observations and those 

based on assumptions, and the affect of assumptions on DOD’s cost 

estimates. Instead, DOD provided only general information to Congress on 

the assumptions and cost model used without specific details on how costs 

were developed or the effect of assumptions used on the resulting cost 

estimates. Consequently, we believe it is difficult for Congress to evaluate 

the cost estimates DOD provided and that it may be unwise to rely on them 

for assessing the potential liability associated with contamination on 

operational ranges. Reliable cost estimates can be a critical piece of 

information for DOD and Congress when considering the potential costs 

versus benefits of closing operational ranges or entire installations. 

However, such estimates must be based on accurate data that, in terms of 

ranges, begins with a complete and accurate operational range inventory.

DOD installations have conducted little or no sampling for perchlorate 

under DOD’s perchlorate policy, and DOD has not provided specific 

funding to the services to conduct the sampling that is required by its 

policy. Available information indicates that testing for perchlorate on 

installations has been limited and is specifically needed at facilities that are 

or were involved in research, manufacturing, testing, and disposal of 

munitions. DOD’s decision not to provide specific funding to the services 

for sampling hampers the ability of DOD, as well as EPA and the states, to 

collect better data on the extent and nature of possible perchlorate 

contamination on military installations. Such information could be 

important to regulators when determining if there is a potential public 

health risk from perchlorate and deciding what, if any, actions might be 

warranted. Further, the lack of such information impedes DOD and 

congressional efforts for planning and budgeting future cleanup that may 

be required if federal or state standards regulating perchlorate are adopted. 

Recommendations for 

Executive Action

In order to the assist Congress, EPA, and state regulators in assessing and 

planning for the cleanup of contamination associated with military 

munitions at operational ranges, we are making the following two 

recommendations: 
Page 32 GAO-04-601 DOD Operational Ranges

• To improve congressional oversight of DOD and its operational ranges, 

including providing Congress with more realistic estimates of the 

potential liability associated with cleaning up contamination related to 

the use of military munitions, we recommend that DOD, using a more 

consistent estimating methodology, use its most complete operational 

range inventory to revise its cost estimates for the cleanup of 

operational ranges. The revised estimates should include an explanation 

of the basis and scope on which the inventory was conducted, and how 

the cost estimates were calculated. The estimates should be 

accompanied by a detailed description of how costs were developed, 

such as where estimates and assumptions were used, the basis of and 

rationale for any assumptions used, and an explanation as to how such 

assumptions affected cost figures.

• To develop information needed by Congress, EPA, and the states, such 

as the location and amount of perchlorate contamination, when 

deciding what, if any, actions are warranted to address such 

contamination, we recommend that DOD, acting under its revised 

perchlorate sampling policy, provide specific funding for comprehensive 

sampling at sites where no prior sampling has been conducted, yet 

perchlorate contamination is likely and human exposure is possible 

based on the sites’ prior or current use. To help identify possible sites of 

perchlorate contamination, we recommend DOD consolidate and 

review sampling data previously collected by installations under 

environmental laws governing the release or disposal of various 

hazardous substances. 

Agency Comments and 

Our Evaluation

In its May 6, 2004, letter, DOD disagreed with our findings and 

recommendations. DOD also provided technical comments and 

clarifications that we incorporated in the report, as appropriate. 
Page 33 GAO-04-601 DOD Operational Ranges

DOD disagreed with our conclusion that it did not have a comprehensive 

policy requiring sampling or cleanup of munitions constituents on 

operational ranges, and that it generally has not taken actions to clean up 

contaminants. In its letter, DOD cited specific policies in place requiring the 

services to address the release of munitions constituents. However, the 

guidance DOD cited pertains only to the migration of munitions 

constituents off-range and the reporting of environmental liabilities, but 

does not address the sampling or cleanup of munitions constituents found 

on operational ranges that are the subject of this report. Further, DOD’s 

letter states that it is responding to munitions constituents at 23 

installations and ranges. We acknowledge that DOD is sampling for, and in 

some cases, cleaning up munitions constituents when directed to do so by 

EPA or a state environmental agency under various environmental laws. In 

reviewing the data provided by DOD, however, we found that only 2 of the 

installations they cited had operational ranges and both of those were 

being cleaned up because of EPA direction or a court order. At the 12 other 

installations with active ranges, half of them had sampled or were sampling 

for munitions constituents as a result of EPA or state environmental agency 

requests, RCRA requirements, or cleanup associated with Superfund 

hazardous waste sites. None of these installations, however, were cleaning 

up the munitions constituents found as a result of sampling.

DOD disagreed with our assessment that its inventory data and cost 

estimates were questionable and said it was not necessary to revise its cost 

estimates because inventory data used to develop the estimates were 

“accurate within reason.” In its comments, DOD stated that it was not 

required to use validated costing assumptions, or a consistent estimating 

methodology, because the fiscal year 2002 National Defense Authorization 

Act provided that the standard for the report of liabilities did not apply to 

DOD’s cost estimates. Although the act allowed DOD to develop cost 

estimates that did not meet the same standards as required for the report of 

liabilities in DOD’s annual financial statement, we believe that DOD had a 

responsibility to provide Congress with useful information by making a 

reasonable attempt to prepare accurate and complete estimates, including 

assuring that its assumptions were valid. However, as our report sets out, 

the inconsistencies in how DOD collected and analyzed data on operational 

ranges raise questions about the reliability of DOD’s inventory. Specifically, 

DOD did not provide Congress with a detailed description of how the costs 

were prepared and an explanation of where site-specific data were used in 

place of assumptions, why specific and different assumptions were used by 

the services, and how assumptions affected the overall cost estimates. 

Without DOD’s supporting data and analysis, it is difficult for Congress to 
Page 34 GAO-04-601 DOD Operational Ranges

evaluate the accuracy or validity of the cost estimates DOD provided and it 

may be unwise to rely on them for assessing the potential liability 

associated with contamination on operational ranges. 

DOD disagreed with our recommendation that it needed to develop new 

cost estimates for cleaning up operational ranges, stating that it is 

developing a system for providing auditable data that meets the standards 

for the report of liabilities and is actively assessing its ranges for potential 

munitions constituent migration to off-range areas. However, the 

requirement in the National Defense Authorization Act for fiscal year 2002 

was to report estimated costs to clean up operational ranges, not the costs 

to respond to or clean up constituent migration off-range. In its letter to 

GAO, DOD also questioned whether decision makers would find useful an 

estimated cost to clean up operational ranges and asserted that it is not 

required to develop cleanup estimates for operational ranges until such 

costs become probable and estimable by accounting standards. We 

disagree with DOD’s view of the information and its usefulness to 

Congress. Congress on two occasions asked DOD to provide just such 

information. Specifically, the 2002 Defense Authorization Act required that 

DOD report this information. In addition, the Senate Committee on Armed 

Services, in its report accompanying the National Defense Authorization 

Act for fiscal year 2000 (S. Rep. No. 106-50), directed DOD to provide to the 

congressional defense committees a report with a complete estimate of 

current and projected costs to clean up munitions constituents. In our 

opinion, the authorization act’s requirement and the committee’s direction 

provide ample evidence that congressional decision makers would find 

such information useful.

DOD also disagreed with our recommendation that DOD provide specific 

funding for sampling for perchlorate. As our report points out, DOD’s 

current policy on perchlorate sampling designates funding for sampling as 

a Class I high priority environmental project. This means that perchlorate 

sampling is a priority for funding, along with all other high priority 

environmental projects. As a result, perchlorate sampling must compete 

with other high priority environmental priorities for funding and, due to 

limited funds, may not be funded. The result is that while DOD policy has 

designated a funding mechanism for perchlorate, DOD’s policy cannot 

assure that perchlorate sampling will be funded. Simply stated, if DOD 

wants to assure that installations conduct perchlorate sampling where 

appropriate, then it will need to provide specific funding for this sampling.
Page 35 GAO-04-601 DOD Operational Ranges

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, 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 at (202) 512-3841, or 

Edward Zadjura at (202) 512-3841. Key contributors to this report are listed 

in appendix V. 

Anu K. Mittal

Director, Natural Resources

and Environment
Page 36 GAO-04-601 DOD Operational Ranges

Appendix I

Safety, Environmental, and Human Health Apendxies

Risks ApendxiI

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

environment. Unexploded ordnance poses a risk of physical injury to those 

who encounter it. Military munitions may also pose a health and 

environmental risk especially on ranges located in ecologically sensitive 

wetlands and floodplains because their use and disposal may release 

constituents that may contaminate soil, groundwater, and surface water. 

More than 200 chemical munitions constituents are associated with 

ordnance and its use. When exposed to some of these constituents, humans 

potentially face long-term health problems, such as cancer and damage to 

the heart, liver, and kidneys. 

Munitions Constituents of 

Greatest Concern

Of the more than 200 chemical munitions constituents associated with 

ordnance and its use, DOD considers 20 to be of greatest concern because 

of their widespread use and potential environmental impact. The 20 

munitions constituents, taken from DOD’s Fiscal Year 2002 Defense 

Environmental Restoration Program Annual Report to Congress, are

• 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,
Appendix I

Safety, Environmental, and Human Health 

Risks 

Page 37 GAO-04-601 DOD Operational Ranges

• 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, and 

• N,2,4,6-Tetranitro-N-methylaniline (Tetryl) (White Phosphorus). 

While many of these compounds have been an environmental concern to 

DOD for more than 20 years, the current understanding of the causes, 

distribution, and potential effect of constituent releases into the 

environment remains limited. The nature of the potential effect, and 

whether it poses an unacceptable risk to human health and the 

environment, depends upon the dose, duration, and pathway of exposure, 

as well as the sensitivity of the exposed populations. The link between 

constituents and their potential health effects is not always clear and 

continues to be studied. Table 6 describes some of the potential health 

effects of five of the munitions constituents of greatest concern. 

Table 6: Potential Effects of the Munitions Constituents Closely Associated with Military Munitions

Source: Environmental Protection Agency. 

Contaminant Potential toxicity/effects

Trinitrotoluene (TNT) Possible human carcinogen. Targets liver, skin, irritations, cataracts.

Royal Demolition Explosive (RDX) Possible human carcinogen, prostate problems, nervous system problems, nausea, and 

vomiting. Laboratory exposure to animals indicates potential organ damage.

High Melting Explosive (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. Skin burns, irritation of throat and lungs, vomiting, stomach 

cramps, drowsiness. Liver, heart, or kidney damage. Death.
Page 38 GAO-04-601 DOD Operational Ranges

Appendix II

Scope and Methodology ApendxiI

You asked us to determine (1) how DOD identified the location and last 

active use of all operational ranges and the basis for DOD’s cost estimates 

for cleaning up those ranges; and (2) DOD’s policy on sampling for 

contaminants linked to the use of ordnance on operational ranges and, 

where munitions-related contaminants have been detected, what 

corrective actions the services have taken. Specifically, you asked us to 

focus on DOD’s actions with regard to perchlorate. 

To determine how DOD identified the location and last active use of all 

operational ranges, we reviewed the services’ inventory data and 

interviewed service headquarters officials to determine how the 

inventories were conducted and the reliability of the data collected. We 

assessed the reliability of the services’ data (1) by reviewing existing 

information about the data and the processes that produced them and (2) 

by interviewing DOD officials knowledgeable about the data. We 

determined that data on the number of operational ranges and acreage 

were sufficiently reliable to include in our report; however, we determined 

that data on range characteristics were unreliable. Although we found the 

data on range characteristics to be unreliable, we present the data for 

informational purposes. To determine the basis for DOD’s cost estimates 

for cleaning up operational ranges, we reviewed the services’ estimated 

costs, supporting analyses, and calculations, and interviewed service and 

DOD officials on the scope and methodology used to develop cost 

estimates. 

To identify DOD’s policy on sampling for constituents linked to the use of 

ordnance on operational ranges, we reviewed DOD’s and the service’s 

policies related to the sampling and cleanup of potential contaminants and 

specifically their policies on perchlorate. We also interviewed officials at 

both headquarters and several installations on the implementation of DOD 

and service policies. To report on what actions the services have taken with 

regard to munitions constituents and perchlorate, we visited seven DOD 

installations where perchlorate had been detected and discussed what 

efforts have taken place, or were planned, to respond generally to 

munitions-related contaminants and specifically for perchlorate. We 

selected installations based on available data but were unable to determine 

the total number of installations reporting perchlorate contamination. We 

selected installations where generally high levels of perchlorate had been 

detected or, in one case, where perchlorate had contaminated a local 

municipal water supply. We also based our selection on the desire to 

include at least two installations from each military department and 

installations from different states or geographic locations in order to 
Appendix II

Scope and Methodology

Page 39 GAO-04-601 DOD Operational Ranges

provide a mix of services and state agencies. (See table 7 for a listing of the 

installations we visited.) 

During our visits, where possible, we observed the areas of contamination 

as well as any cleanup demonstration projects under way. To identify what 

levels of contamination had been detected at DOD installations, we first 

obtained various summary schedules and lists of active and closed DOD 

and non-DOD sites with suspected or detected perchlorate contamination 

from both EPA and DOD. Because DOD has only recently begun to collect 

data on perchlorate, none of the listings we obtained included all 

installations. Further, most lists did not generally contain current data and 

were incomplete. Additionally, much of the data was redundant, with the 

same installations appearing on more than one list. Prior to selecting an 

installation to visit, therefore, we contacted service officials to verify that 

perchlorate contamination had, in fact, been detected. Our observations 

about perchlorate contamination and response actions at these 

installations are not generalizable to all military installations. 

Table 7: Installations Visited during Our Review

Source: GAO.

Installation 

Military 

department State Perchlorate contamination levels initially detected or reported

Edwards Air Force Base Air Force California Up to 160,000 parts per billion in groundwater (detected in 1997)

Holloman Air Force 

Base

Air Force New Mexico About 16,000 parts per billion in surface water (detected in 1999)

Aberdeen Proving 

Ground

Army Maryland 5 parts per billion in drinking water and 24 parts per billion in 

groundwater (reported in 1998) 

Redstone Arsenal Army Alabama About 19,000 parts per billion in groundwater (as of 2000)

White Sands Missile 

Range

Army New Mexico 21,000 parts per billion in groundwater (reported in 1998)

Naval Air Weapons 

Station, China Lake

Navy California 560 parts per billion in groundwater (detected in 2001)

Naval Surface Warfare 

Center, Indian Head

Navy Maryland More than 1,000 parts per billion in surface water (reported in 1998)
Page 40 GAO-04-601 DOD Operational Ranges

Appendix III

Installations That Were Cleaning Up 

Perchlorate as a Result of Demonstration 

Projects ApendxiI

Although we found no installations were cleaning up perchlorate, two 

installations we visited were conducting or had conducted demonstration 

projects of new technologies to clean up perchlorate, in anticipation of 

future cleanup requirements. 

Edwards Air Force 

Base

In May 2003, Edwards Air Force Base, in California, began a demonstration 

project to remove perchlorate from groundwater. Edwards officials said 

the installation funded the project because the Air Force is DOD’s lead 

agency for perchlorate-related efforts and expected to help develop 

perchlorate treatment technologies. Edwards first detected perchlorate on 

the installation in 1997, while testing for other contaminants, and has 

detected perchlorate at 10 sites on the installation. Perchlorate 

contamination of 160,000 parts per billion was detected at one site where 

the source of the contamination is attributed to the use of perchlorate by 

various research facilities beginning about 1945. On this site the Air Force 

constructed a well field and project treatment facility. The demonstration 

project uses resin beads, which act like a magnet to pull perchlorate out of 

the water. Four wells extract groundwater that is discharged into a storage 

tank and then pumped through treatment equipment containing the resin. 

Treated groundwater is returned to the aquifer through five injection wells. 

Plans are to operate the project through July 2005. Currently, Edwards 

officials report that perchlorate continues to be removed to nondetectable 

levels, or less than 1 part per billion. 

Naval Surface Warfare 

Center, Indian Head 

In 2002, the Naval Surface Warfare Center, Indian Head, in Maryland, 

funded a field demonstration project using naturally occurring 

microorganisms, or bacteria, that break down or consume perchlorate. 

Navy officials first became concerned about perchlorate in 1998 when they 

learned of widespread perchlorate contamination at DOD sites in 

California. At that time, the installation regularly drained perchloratecontaminated water into ditches and two bordering rivers. In 2001, Navy 

officials sampled and detected a shallow and well-defined plume of 

perchlorate contamination located in an area where the Navy once cleaned 

small rocket motors using a high-pressure wash. Perchlorate levels 

detected in the area ranged from 8,000 to 430,000 parts per billion. On this 

site in early 2002, the Navy installed two extraction wells, two injection 

wells, and nine groundwater monitoring wells. Groundwater was removed 

from the site, mixed with a lactate and a carbonate/bicarbonate liquid 

mixture, and then reinjected into the aquifer. After 20 weeks, perchlorate 
Appendix III

Installations That Were Cleaning Up 

Perchlorate as a Result of Demonstration 

Projects

Page 41 GAO-04-601 DOD Operational Ranges

levels were reduced by more than 95 percent in eight of the nine monitoring 

wells. According to Navy officials, the mixture acted as an oxidizer to 

stimulate microorganisms that consumed the perchlorate. Officials said 

they plan to reuse the equipment to field test the technology at another site 

in an attempt to clean soil contaminated with perchlorate. 
Page 42 GAO-04-601 DOD Operational Ranges

Appendix IV

Installations That Identified Perchlorate as a 

Result of Munitions Research, Manufacturing, 

Testing, and Disposal Activities ApendxiIV

We visited installations that had operational ranges and detectable levels of 

perchlorate but found the perchlorate contamination was generally not due 

to training, but rather due to prior and ongoing research, testing, 

manufacturing, and disposal of rocket motors and propellant waste on 

operational ranges and other parts of the installations. 

Edwards Air Force 

Base

Perchlorate contamination was detected at 10 sites on Edwards Air Force 

Base beginning in 1997. Officials attributed all detected perchlorate 

contamination to rocket propellant manufacturing, research, development, 

and testing, and not to the use of munitions during training. The maximum 

perchlorate contamination level detected was 160,000 parts per billion in 

groundwater at one site. Officials said no live bombs had been exploded on 

Edwards Air Force Base ranges since 1952, and some ranges where bombs 

were exploded have been closed. Perchlorate is not used as part of current 

range activities, and Edwards Air Force Base does not test for 

contaminants on operational ranges, installation officials said. 

Holloman Air Force 

Base 

In March 1999, after a rainstorm, the U.S. Geological Survey sampled for 

perchlorate in a normally dry riverbed at Holloman Air Force Base, in New 

Mexico, and detected contamination of 16,000 parts per billion. During 

periods of rain, the river flows from the installation to the neighboring 

White Sands National Monument. The contamination was found on the 

installation near a former munitions operations site and rocket sled. Air 

Force officials said it was unlikely that the contamination was due to 

training. They attributed the perchlorate contamination to munitions 

research and testing in the 1960s and 1970s. Officials at White Sands 

National Monument attributed the perchlorate contamination to spent 

rocket motors stacked near the river and a high-speed rocket sled used to 

test the effects of acceleration. DOD and New Mexico’s state 

environmental agency sampled the riverbed and surrounding area again in 

1999 and 2000 but did not find the high concentration of perchlorate 

previously detected. Air Force officials said they believed the 16,000 parts 

per billion detected in 1999 was an anomaly. 

Naval Surface Warfare 

Center, Indian Head 

At the time of our visit, officials at the Naval Surface Warfare Center, Indian 

Head, in Maryland, reported they detected perchlorate contamination at 

five sites on the installation, of which three were landfills, one was a metal 

parts disposal site, and one was a metal parts degreasing tank site. Indian 
Appendix IV

Installations That Identified Perchlorate as a 

Result of Munitions Research, 

Manufacturing, Testing, and Disposal 

Activities

Page 43 GAO-04-601 DOD Operational Ranges

Head detected maximum perchlorate concentrations between 88 and 

450,000 parts per billion in the soil at two of the three landfills. At the third 

landfill, a perchlorate concentration of 2,000 parts per billion was detected 

in the groundwater. However, none of the contamination detected was 

attributed to the use of perchlorate during training exercises on operational 

ranges.

Redstone Arsenal As of March 2004, Redstone Arsenal, in Alabama, detected perchlorate 

contamination in the groundwater at 2 sites and in surface water and soil at 

11 other sites. Redstone Arsenal officials attributed contamination to 

various past production, maintenance, and disposal activities at a number 

of sites, including at open burning areas used to incinerate waste rocket 

motor propellant, burning trenches used to incinerate solid material 

contaminated with rocket propellant, a rocket engine plant, motor 

degreasing and trimming areas, and a propellant waste storage area. 

Perchlorate contamination of about 20 parts per billion was also detected 

in ground and surface water outside the installation. The highest 

concentration levels detected in groundwater on Redstone installations 

have ranged from 106,000 to 160,000 parts per billion and the highest 

concentration levels detected in surface water have ranged from 377 to 

1,700 parts per billion. Although Redstone Arsenal has conducted training 

on the installation, none of the contamination detected has been attributed 

to the use of perchlorate during training exercises.

White Sands Missile 

Range 

White Sands Missile Range, in New Mexico, detected perchlorate 

contamination at two sites beginning in 1999. At one site, sampling 

detected perchlorate concentrations up to 25,000 parts per billion. Officials 

said they were unsure of the precise cause of the contamination but said 

they initially believed it was due to an open burning and detonation facility 

used in the 1950s to incinerate rocket motors. However, officials also said 

that the contamination plume was uphill from where the open burning and 

detonation site is believed to have been, so that the contamination may be 

generally due to previous testing of hazardous materials in the area. 

Perchlorate was also found at the former site of a high-energy laser system 

test facility. Perchlorate contamination detected has been as high as 118 

and 295 parts per billion in some wells. Officials said the contamination 

might be due to open ground burning of expended test items, or residue 

from actual tests, conducted prior to 1995. Officials said they planned to 

conduct more sampling to precisely identify the source of the perchlorate 
Appendix IV

Installations That Identified Perchlorate as a 

Result of Munitions Research, 

Manufacturing, Testing, and Disposal 

Activities

Page 44 GAO-04-601 DOD Operational Ranges

but did not attribute any of the perchlorate detected to training exercises 

on operational ranges. 

Naval Air Weapons 

Station, China Lake

At the time of our visit in October 2003, the Naval Air Weapons Station, 

China Lake, in California, had detected perchlorate at five sites on the 

installation. Perchlorate contamination was predominantly found in 

drainage and waste disposal areas, most likely the result of research on 

propellants and explosives, and residue from the manufacture of 

propellants. Installation officials said that since the 1960s, thousands of 

pounds of perchlorate-based propellant have been stored and tested on 

China Lake. In July 2003, installation officials sampled and detected 

perchlorate concentrations of 778 and 921 parts per billion at two wells and 

at a drainage site. However, none of the contamination detected is 

attributed to the use of munitions during training exercises on operational 

ranges.
Page 45 GAO-04-601 DOD Operational Ranges

Appendix V

Comments from the Department of Defense ApendxiV
Appendix V

Comments from the Department of Defense

Page 46 GAO-04-601 DOD Operational Ranges
Appendix V

Comments from the Department of Defense

Page 47 GAO-04-601 DOD Operational Ranges
Page 48 GAO-04-601 DOD Operational Ranges

Appendix VI

GAO Contacts and Staff Acknowledgments ApendxiVI

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

Edward Zadjura, (202) 512-9914

Staff 

Acknowledgments

In addition to those named above, Christine Frye, Roderick Moore, David 

Noguera, and Doreen Feldman made key contributions to this report. John 

Delicath and Amy Webbink also contributed to this report. 

(360349)
GAO’s Mission The General Accounting Office, the audit, evaluation and investigative arm of 

Congress, exists to support Congress in meeting its constitutional responsibilities 

and to help improve the performance and accountability of the federal government 

for the American people. GAO examines the use of public funds; evaluates federal 

programs and policies; and provides analyses, recommendations, and other 

assistance to help Congress make informed oversight, policy, and funding 

decisions. GAO’s commitment to good government is reflected in its core values of 

accountability, integrity, and reliability.

Obtaining Copies of 

GAO Reports and 

Testimony

The fastest and easiest way to obtain copies of GAO documents at no cost is 

through the Internet. GAO’s Web site (www.gao.gov) contains abstracts and fulltext files of current reports and testimony and an expanding archive of older 

products. The Web site features a search engine to help you locate documents 

using key words and phrases. You can print these documents in their entirety, 

including charts and other graphics.

Each day, GAO issues a list of newly released reports, testimony, and 

correspondence. GAO posts this list, known as “Today’s Reports,” on its Web site 

daily. The list contains links to the full-text document files. To have GAO e-mail this 

list to you every afternoon, go to www.gao.gov and select “Subscribe to 

e-mail alerts” under the “Order GAO Products” heading.

Order by Mail or Phone The first copy of each printed report is free. Additional copies are $2 each. A check 

or money order should be made out to the Superintendent of Documents. GAO 

also accepts VISA and Mastercard. Orders for 100 or more copies mailed to a single 

address are discounted 25 percent. Orders should be sent to:

U.S. General Accounting Office

441 G Street NW, Room LM

Washington, D.C. 20548

To order by Phone: Voice: (202) 512-6000 

TDD: (202) 512-2537 

Fax: (202) 512-6061

To Report Fraud, 

Waste, and Abuse in 

Federal Programs

Contact:

Web site: www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470

Public Affairs Jeff Nelligan, Managing Director, NelliganJ@gao.gov (202) 512-4800

U.S. General Accounting Office, 441 G Street NW, Room 7149 

Washington, D.C. 20548
United States

General Accounting Office

Washington, D.C. 20548-0001

Official Business

Penalty for Private Use $300

Address Service Requested

Presorted Standard

Postage & Fees Paid

GAO

Permit No. GI00