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Environmental Cleanup: Better Data Needed for Radioactively Contaminated
Defense Sites (Letter Report, 08/24/94, GAO/NSIAD-94-168).

The Defense Department's (DOD) identification of radiologically
contaminated sites and their cleanup relies on data that often are
outdated, inaccurate, and incomplete. The list of 420 low-level
radioactive sites that DOD gave Congress in 1992 and 1993 was inaccurate
because the services had double-counted some sites and not identified
others. In addition, Defense Logistics Agency sites and former defense
sites, managed by the Army Corps of Engineers, were omitted. DOD
monitoring of status at known sites was impeded because neither it nor
the services recorded such basic data as the amount of radioactivity,
and the data they did record were often inaccurate and outdated. DOD's
database included only general categories of contaminants at sites, such
as low-level radiation, but could not identify specific contaminants or
quantities. For example, significant data on plutonium contamination at
Johnston Island were omitted in both DOD and Air Force data. More
specific information would better help identify the types of
contamination that exist, the types of required cleanup, and potential
risks associated with continued contamination and with cleanup efforts.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  NSIAD-94-168
     TITLE:  Environmental Cleanup: Better Data Needed for Radioactively 
             Contaminated Defense Sites
      DATE:  08/24/94
   SUBJECT:  Radioactive waste disposal
             Radioactive wastes
             Environmental monitoring
             Radiation monitoring
             Military facilities
             Data collection operations
             Data integrity
             Working conditions
             Radiation exposure hazards
             Hazardous substances
IDENTIFIER:  DOD Environmental Restoration Program
             Johnston Atoll
             Aberdeen (MD)
             
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Cover
================================================================ COVER

Report to the Chairman, Committee on Governmental Affairs, U.S. 
Senate

August 1994

ENVIRONMENTAL CLEANUP - BETTER
DATA NEEDED FOR RADIOACTIVELY
CONTAMINATED DEFENSE SITES

GAO/NSIAD-94-168

Environmental Cleanup

Abbreviations
=============================================================== ABBREV

  DLA - Defense Logistics Agency
  DNA - Defense Nuclear Agency
  DOD - Department of Defense
  GAO - General Accounting Office
  OSD - Office of the Secretary of Defense

Letter
=============================================================== LETTER

B-257487

August 24, 1994

The Honorable John Glenn
Chairman, Committee on
 Governmental Affairs
United States Senate

Dear Mr.  Chairman: 

Your December 22, 1992, letter expressed concern about whether the
Department of Defense (DOD) has systematically addressed issues
involving radiologically contaminated sites.  In this report, we
evaluate the accuracy and adequacy of data that DOD provided in July
1992 and April 1993 on identification and cleanup of military sites
contaminated with low-level radioactive waste.  As requested, we also
provide information on (1) data sharing among DOD and other agencies
(see app.  I) and (2) our recent reports addressing radiation risks
to DOD personnel (see app.  II). 

   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

DOD's identification of radiologically contaminated sites and their
cleanup relies on data that often are outdated, inaccurate, and
incomplete.  In data provided to your Committee in July 1992 and
April 1993, DOD identified 420 low-level radioactive waste sites. 
The estimates were incorrect because the services had double-counted
some sites and not identified others.  In addition, Defense Logistics
Agency (DLA) sites and former defense sites, managed by the Army
Corps of Engineers, were not included in the data provided to the
Committee. 

The Office of the Secretary of Defense's (OSD) monitoring of status
at known sites was impeded because neither it nor the services
recorded such basic data as the amount of radioactivity, and the data
they did record were often inaccurate and outdated.  DOD's database
included only general categories of contaminants at sites, such as
low-level radiation, but could not identify specific contaminants or
quantities.  For example, significant data on plutonium contamination
at Johnston Island were omitted in both Air Force and DOD data.  More
specific information would better help identify the types of
contamination that exist, the types of required cleanup, and
potential risks associated with continued contamination and with
cleanup efforts. 

   BACKGROUND
------------------------------------------------------------ Letter :2

DOD low-level radioactive waste includes a wide range of radioactive
materials from medical facilities, industrial facilities, research
and analytical laboratories, weapons testing, and nuclear propulsion
reactors.  Some common DOD radioactive materials are dials,
navigation instruments, markers, monitors, thickness gauges, radium
paint, and depleted uranium.  According to the Navy, no radioactive
waste from servicing of nuclear-powered warships was ever buried at a
DOD installation.  In addition, nuclear weapons accidents over the
years have also resulted in low-level radiation contaminated sites. 

In March 1990, we recommended that the Secretary of Defense develop
an inventory of the amounts and types of low-level radioactive waste
that are stored or buried at all DOD installations.  (See app.  II.)

About 97 percent of low-level radioactive waste decays to safe levels
within 100 years, while some of the rest may remain harmful for many
thousands of years.  DOD estimates that it generates about 1 percent
of the low-level waste in the United States. 

The Deputy Under Secretary of Defense (Environmental Security)
provides direction and oversight for the Defense Environmental
Restoration Program.  The program was established in 1984 to manage
the evaluation and cleanup of contamination at DOD installations. 
The military services and defense agencies implement the program at
their installations. 

The Defense Appropriations Act annually provides the primary funding
for the restoration program through the Defense Environmental
Restoration Account.  In addition, restoration work at bases
scheduled for closure is funded under the Defense Authorization
Amendments and Base Closure and Realignment Act (1988) and the
Defense Base Closure and Realignment Act of 1990. 

   RADIOACTIVELY CONTAMINATED
   SITES NOT ADEQUATELY IDENTIFIED
   AND MONITORED
------------------------------------------------------------ Letter :3

Execution of DOD's restoration program requires a DOD-wide management
information system containing site-specific data that are complete
and accurate.  The data are to be updated at least quarterly. 
However, DOD's identification and monitoring of sites contaminated
with low-level radiation is based on inconsistent and outdated data. 
According to DOD officials, this is partly due to varying
interpretations of what constitutes a low-level radioactive site.  As
a result, DOD does not know the precise number of contaminated sites. 
For example, in an April 1992 hearing before your Committee, DOD
identified 271 sites; in July 1992 and April 1993, DOD listed 420
such sites.  In addition, we believe that additional data that are
not required by DOD would be useful for oversight and management
purposes. 

Both of the above-mentioned estimates were based on lists from the
individual services, and not DOD records, as DOD did not believe its
own database could provide accurate information.  In July 1993, DOD's
database contained only 156 sites, in part because there were no data
from the Air Force.  In addition, the services' data often were
flawed.  In some cases, the military services overstated the number
of sites; for example, by listing individual contaminants as separate
sites.  In other cases, the services understated the number by
inadvertently omitting sites. 

When DOD did correctly identify sites, data flaws impeded monitoring
of cleanup efforts.  Neither the DOD database nor the services are
required to record such basic data as the amount of radioactivity,
and the data they did record were inaccurate and outdated.  DOD's
database included only general categories of contaminants at sites,
such as low-level radiation, but could not identify specific
contaminants or quantities. 

More specific data would be useful for such management information
purposes as identifying type and severity of contamination.  The
information could aid in current DOD initiatives to identify
candidates for common cleanup methodologies and to provide some
indication of the types of hazards presented by given sites. 
Testimony before the Congress on its budget request for fiscal year
1995 indicated that the use of generic remedies for cleanup was a key
element in its efforts to achieve faster cleanups and reduce
environmental risk.  DOD's program guidance states that its
restoration management information system is an important tool for
use in program management and oversight. 

Specific information for each military service, DLA, and former
defense sites is discussed below. 

      ARMY
---------------------------------------------------------- Letter :3.1

The Army's list of low-level radiation waste sites comprised 260 of
the 420 locations DOD reported in April 1993.  The list was drawn
from several sources.  Site identification was based on information
in the Army's database as of 1992, as well as an Army installation
radiation monitoring report last prepared in 1987.  Data on site
monitoring came from a contractor effort completed in 1991.  Army
officials stated that the Army is continuing to clarify and identify
site counts consistent with DOD guidance and definitions of low-level
radioactive waste. 

According to OSD Environmental Security officials, about 80 Army
sites were duplicates.  At Aberdeen Proving Grounds, Maryland, for
example, the list identified 30 sites.  According to an Aberdeen
official, there are actually only 12 sites.  The other 18 sites were
repeats of the 12.  In addition, the Army list omitted a site that
should have been included at Fort Wainwright, Alaska. 

Although there is no requirement that the information system
distinguish between burial sites and contamination from ongoing
activities, we believe it may be useful to reflect such data in DOD
and service reports.  For example, the Army list did not show that 11
of the 12 sites at Aberdeen Proving Ground involved contamination at
sites with ongoing, licensed activities, such as test firing ranges
and medical buildings.  Also, at Fort Sam Houston, Texas, the list
identified two contaminated sites.  One of the sites did serve as a
temporary storage area, but the other was the medical center
hospital. 

      AIR FORCE
---------------------------------------------------------- Letter :3.2

The Air Force list of contaminated and potentially contaminated sites
comprised 147 of the 420 total reported in April 1993.  Our visits to
four Air Force bases confirmed the 10 sites reported at the bases. 
However, data monitoring the status of cleanup efforts were often
inaccurate, and the Air Force was not routinely providing information
to DOD about location, number, and types of sites. 

The data provided during our site visits to George Air Force Base,
Lackland Air Force Base, and Norton Air Force Base confirmed the
number of the Air Force's listed sites.  However, we found that a
Randolph Air Force Base site on the list had been cleaned up and was
no longer considered contaminated. 

Data on the Johnston Island site reflected inaccurate cleanup status. 
According to Defense Nuclear Agency (DNA) officials, DNA is
responsible for cleaning up plutonium contamination that occurred at
Johnston Island when a rocket exploded on a test pad in the
mid-1960s.  The Air Force list indicated only the following about two
contaminated sites:  (1) residual contamination with plutonium in a
lagoon area with a completed site investigation and (2) a
contaminated launcher facility.  However, DNA data indicate that
ongoing cleanup efforts have been underway since 1990, with a
possible total cost of up to $15 million.  The Air Force data made no
reference to DNA's efforts to develop cleanup techniques, begun in
the middle 1980s, and the ongoing cleanup of the large, 24-acre site. 
According to a DNA official, the soil enclosing the contamination is
about 100,000 cubic meters in volume, although more than 200,000
cubic meters are restricted from use because some of it may be
plutonium-contaminated.  Operations at the site had processed about
17,000 tons of soil as of May 1993. 

The Air Force has provided incomplete site information to the DOD
environmental office.  In particular, the data provided do not
include site or contaminant type.  According to an Air Force
official, such specific information can be obtained from the service
directly.  However, without that information, DOD's databases cannot
provide information on even the number of low-level sites for the Air
Force. 

Additionally, the Air Force's information system itself poses
problems in communicating data to DOD.  The Air Force's system is
incompatible with those maintained by the Army, Navy, and OSD.  Hard
copy information, which is provided annually to OSD, must be manually
entered into its system, slowing efforts to update OSD's data. 

      NAVY
---------------------------------------------------------- Letter :3.3

The Navy reported 13 of the 420 sites, and we confirmed data
regarding 4 of the 13 during our visits to Barstow Marine Corps
Logistics Base, El Toro Marine Corps Air Station, and Miramar Naval
Air Station.  However, the list omitted many other sites.  In
December 1993, the Navy provided a list of at least 49 potentially
contaminated sites and another
17 sites that had been remediated or where contamination was
investigated but not found. 

Navy officials stated that radioactive waste from servicing of
nuclear powered warships was not buried at DOD installations. 

      DLA AND ARMY CORPS OF
      ENGINEERS
---------------------------------------------------------- Letter :3.4

We also found that both DLA and the Army Corps of Engineers have
identified some additional sites not reported to the Committee. 
According to DLA officials, DLA is responsible for low-level cleanup
at several waste sites, and cleanup efforts are underway.  The Corps
of Engineers is still identifying formerly used defense sites and has
not yet begun cleaning up those that have been identified as having
low-level radioactive contamination. 

   RECOMMENDATIONS
------------------------------------------------------------ Letter :4

We recommend that the Secretary of Defense take action to improve
DOD's databases to ensure that they have sufficient low-level
radioactive waste data for managing the contaminated sites'
restoration.  Specifically, the Secretary should require that DLA and
the military services correct current data errors and ensure that
data are reported to OSD at least four times a year. 

Because data on specific contaminants are readily available and
potentially useful for management decisions, we also recommend that
the Secretary of Defense modify DOD's reporting requirements to
include such information, as well as data available on estimated
quantities of contaminants. 

---------------------------------------------------------- Letter :4.1

Our work was conducted between November 1992 and July 1994 in
accordance with generally accepted government auditing standards.  As
requested, we did not obtain written agency comments on this report. 
However, we discussed our findings with agency officials and have
included their comments where appropriate.  The scope and methodology
for our review are discussed in appendix III. 

Unless you publicly announce its contents earlier, we plan no further
distribution of the report until 30 days after its issue date.  At
that time, we will send copies to appropriate congressional
committees, the Secretary of Defense, and the Director of the Office
of Management and Budget.  We will also make copies available to
others upon request. 

If you or your staff have any questions concerning this report,
please contact me on (202) 512-8412.  Major contributors to this
report are listed in appendix IV. 

Sincerely yours,

Donna M.  Heivilin
Director, Defense Management and NASA Issues

EFFORTS TO SHARE RADIOLOGICAL DATA
AMONG DOD AND OTHER AGENCIES
=========================================================== Appendix I

DOD officials said they recognize the need to share data as part of
efforts to identify and cleanup radiological contamination.  Two
programs appear especially likely to potentially improve sharing
technology and systems for use in environmental science:  the
congressionally mandated Strategic Environmental Research and
Development Program and the Central Intelligence Agency's
Environmental Task Force. 

The Strategic Environmental Research and Development Program is
conducted with participation from DOD, the Department of Energy, and
the Environmental Protection Agency.  It was established in 1991 to
address environmental matters through support for basic and applied
research and development of technologies.  The program is intended to
interact with other environmental programs to identify and solve
defense-specific needs, extend applications of defense information to
other agencies, and build on existing science and technology to
derive more usable and cost-effective approaches for reducing
environmental risks. 

The Central Intelligence Agency's task force comprises a team of
scientists who work to determine ways of applying classified systems
and data to environmental science.  The task force is in response to
congressional requests, and expects to recommend classified
information of value for release to the environmental community. 

We also obtained information from other agencies specified in your
request, but they did not indicate immediate potential for
coordination.  Other agencies' efforts to share data include the
following: 

  Defense Intelligence Agency officials stated that they do not get
     involved in identifying and cleaning up low-level waste sites
     because they are only involved with foreign-owned,
     foreign-operated bases overseas. 

  A Defense Nuclear Agency official said technology is generally
     known to the low-level radiation research community and
     attributed this knowledge to the specialized nature of the
     community.  According to this official, no formal mechanism has
     existed in DOD to ensure the coordination of low-level waste
     technology. 

  The Advanced Research Projects Agency is the central research and
     development organization of DOD with the responsibility to
     maintain U.S.  technological superiority over potential
     adversaries.  According to an agency official, it is not doing
     the type of work that would benefit DOD's low-level waste
     program.  He stated that he was not aware of any coordination
     with DOD regarding low-level wastes. 

OUR RECENT REPORTS ADDRESSING
RADIATION RISKS TO DOD PERSONNEL
========================================================== Appendix II

In Nuclear Regulation:  The Military Would Benefit From a
Comprehensive Waste Disposal Program (GAO/RCED-90-96, Mar.  23,
1990), we reported that no comprehensive DOD radioactive waste
disposal program exists.  We were asked to compare DOD and military
service waste disposal practices because of an accidental release of
low-level radioactive waste at Wright-Patterson Air Force Base, Ohio,
in 1986.  Several individuals had inhaled small quantities of a
radioactive substance. 

We reported that none of the three services had complete information
on the amounts or types of low-level radioactive waste generated or
disposed.  In 1988, the Navy had conducted two surveys to develop
this information, but the results were not complete.  The Army
expected to survey its installations in fiscal year 1990.  The Air
Force had surveyed 23 bases in 1987, but at that time did not plan to
conduct additional surveys. 

Among other recommendations to ensure that all DOD facilities
appropriately dispose of low-level radioactive waste, we recommended
that the Secretary of Defense develop an inventory of the amounts and
types of low-level radioactive waste that are stored or buried at all
DOD installations. 

In Nuclear Health and Safety:  Mortality Study of Atmospheric Nuclear
Test Participants Is Flawed (GAO/RCED-92-182, Aug.  10, 1992), we
reported inaccuracies in participant databases and the exposure data
reported by the National Academy of Sciences in 1985 dealing with
five selected atmospheric nuclear test series.  These inaccuracies
were the result of, among other things, the inexperience of the
service team members who gathered data, the lack of complete and
accurate records, and the inaccurate transcribing of data.  We
recommended that the Secretary of Defense require the Director,
Defense Nuclear Agency, to notify veteran groups, researchers, and
the general public that the conclusions reached in the 1985 National
Academy of Sciences' mortality study might not be valid because (1)
inaccuracies were found in the participant data used in performing
the study and (2) the study is being redone.  DOD agreed that the
Defense Nuclear Agency would notify the appropriate institutions and
veterans' organizations of the limitations of the 1985 mortality
study and its plans to update the study. 

In Operation Desert Storm:  Army Not Adequately Prepared to Deal With
Depleted Uranium Contamination (GAO/NSIAD-93-90, Jan.  29, 1993), we
reported that at least several dozen U.S.  soldiers, some
unknowingly, were exposed to depleted uranium during the Persian Gulf
War.  The exposure was through inhalation, ingestion, or shrapnel. 
Although Army and Nuclear Regulatory Commission officials believe
exposures did not exceed allowable limits, Army regulations require
that exposure to radiation be minimized.  We reported that the Army
has not effectively educated its personnel in the hazards of depleted
uranium contamination and in proper safety measures.  We noted that
although our work was limited to the Army, these issues may be
applicable to the other services. 

SCOPE AND METHODOLOGY
========================================================= Appendix III

To accomplish our objectives, we interviewed headquarters officials
from DOD, the Defense Logistics Agency, the Department of Energy, the
Defense Nuclear Agency, the Defense Intelligence Agency, and the
Environmental Protection Agency.  We also interviewed officials from
the U.S.  Army Corps of Engineers and the U.S.  Army Environmental
Center, Aberdeen Proving Ground, the Advanced Research Projects
Agency, and a representative of the National Governors Association. 

To evaluate the status and progress of contaminated sites and cleanup
efforts, we analyzed DOD's database, service reports, and supporting
documentation about selected sites. 

We visited the following locations:  Lackland Air Force Base,
Randolph Air Force Base, Camp Bullis, and Fort Sam Houston, Texas;
Aberdeen Proving Ground, Maryland; Fort Greely and Fort Wainwright,
Alaska; Miramar Naval Air Station, California; Marine Corps Air
Station, El Toro, California; Marine Corps Logistics Base, Barstow,
California; Norton Air Force Base, California; and George Air Force
Base, California. 

MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix IV

NATIONAL SECURITY AND
INTERNATIONAL AFFAIRS DIVISION,
WASHINGTON, D.C. 

David Warren
Uldis Adamsons

DALLAS REGIONAL OFFICE

Charnel Harlow
James Viola

LOS ANGELES REGIONAL OFFICE

Samuel VanWagner
Gary Kunkle
Nancy Merlino
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