United States General Accounting Office

GAO Report to Congressional Requesters

February 1995 MILITARY BASES

Environmental Impact

at Closing Installations

GAO/NSIAD-95-70

GAO United States

General Accounting Office

Washington, D.C. 20548

National Security and

International Affairs Division

B-256333 

February 23, 1995

The Honorable Bill Zeliff

Chairman

The Honorable Karen Thurman

Ranking Minority Member

Subcommittee on National Security,

 International Affairs, and

 Criminal Justice

Committee on Government Reform

 and Oversight

House of Representatives

The Honorable George Miller

House of Representatives

This report addresses concerns that environmental cleanup at closing military bases is costly

and has significantly affected the Department of Defense’s ability to transfer property to

nonfederal users. It summarizes the results of our review of the (1) cleanup costs,

transferability, and reuse of property and (2) progress, difficulties, and plans to address the

problems.

We are sending copies of this report to the Secretaries of Defense, the Air Force, the Army, and

the Navy; the Director of the Office of Management and Budget; and other interested parties.

We will also make copies available to others on request.

If you have any questions, please call me on (202) 512-8412. Major contributors to this report

are listed in appendix V.

Donna M. Heivilin

Director, Defense Management

 and NASA Issues
Executive Summary

Purpose Since 1988, the Department of Defense (DOD) has been closing and

realigning military installations. A major problem confronting DOD is the

billions of dollars it will cost to clean up the hazardous waste

contaminating these installations. Congress has been concerned that this

environmental cleanup has significantly affected DOD’s ability to transfer

property to nonfederal users. Therefore, the former Chairman,

Subcommittee on Environment, Energy and Natural Resources, House

Committee on Government Operations, and Representative George Miller

asked GAO to review the (1) cleanup costs, transferability, and reuse of

property by nonfederal users and (2) progress, difficulties, and plans to

address the problems.

Background DOD began the first round of base closures and realignments in 1988, and

additional rounds followed in 1991 and 1993. As a result of these efforts,

123 installations and activities1

 have been identified to close and realign.

DOD will recommend additional installations for realignment or closure in

the 1995 round.

Closed or realigned installations have large amounts of unneeded

property, but this property is not automatically sold. Federal property

disposal laws require DOD to first screen excess property for possible use

by defense agencies and then by other federal agencies. If no federal

agency needs the property, it is declared surplus and is made available to

nonfederal parties, including state and local agencies and the public. Base

closure laws require DOD to comply with environmental laws for disposing

of real property. These laws require that all relevant parties agree to the

extent of cleanup required before property can be transferred within the

federal government and that property be cleaned up before it can be

transferred to nonfederal users.

In the 1990 base closure law and DOD’s authorization act for fiscal years

1992 and 1993, Congress provided separate accounts to fund cleanup of

closing and realigning installations and appropriated $1.8 billion through

fiscal year 1994 for this purpose. In July 1993, the administration

expressed concern that closing military installations had been

cumbersome and slow, with environmental cleanup and other processes

taking many years to complete. At that time, DOD introduced a Fast Track

Cleanup program to accelerate cleanup.

1

The 123 includes installations and activities in DOD’s base realignment and closure budget

justification documents for fiscal year 1995. This number differs from other summary figures for base

closures because of the way DOD aggregated these numbers for budget purposes.

Page 2 GAO/NSIAD-95-70 Military Bases
Executive Summary

Results in Brief Congress, DOD, and the Environmental Protection Agency (EPA) have taken

a number of actions over the past several years to resolve environmental

cleanup issues at bases that are being closed and realigned. However,

problems still remain with determining accurate cleanup costs, timing

appropriations with cleanup needs, prioritizing available cleanup funds,

and protecting the government’s interests when leasing or transferring

property.

Most sites at closing and realigning installations are still being investigated

and studied. Thus, the full extent of cleanup actions required may not be

known for years. Also, installations may not be cleaned up by the time

they close, and major groundwater, landfill, and unexploded ordnance

sites will remain contaminated unless new technology is developed.

Dissatisfied with the slow pace of cleanup that had occurred, DOD designed

the Fast Track Cleanup program in 1993. Although the program has made

some progress, improvements could be made in such ways as adding

performance measures to gauge progress.

Specifically, GAO’s work shows the following:

• DOD’s cost estimate for cleaning up 123 closing and realigning bases

increased to $4.0 billion in its fiscal year 1995 budget request. However,

later, more comprehensive estimates developed by 84 installations for

their April 1994 cleanup plans totaled about $5.4 billion. GAO found that

even these estimates are understated.

• DOD has made all closing and realigning installations eligible for high

priority funding. However, most of the property will remain as federal

lands and may not have to be cleaned up before reuse. In 1994, DOD

received authority to use long-term leases so property could be reused

before cleanup is completed, but only a few leases have been signed.

• DOD’s cleanup progress has been limited. Most sites at closing and

realigning installations are in the earliest stages of investigation and study,

and major sites may be 10 years or more away from cleanup. Cleanup

technology is often inefficient and not cost-effective. Also, cleanup

technology is not available for certain contaminants. Consequently,

installations may not be cleaned up by the time they close, and major

groundwater, landfill, and unexploded ordnance sites will remain

contaminated unless new technology is developed.

• DOD has implemented the Fast Track Cleanup program to address

problems and accelerate the cleanup process. Although certain elements

in the program have achieved desired results, others have not and

opportunities for improvement remain. For example, one initiative

Page 3 GAO/NSIAD-95-70 Military Bases
Executive Summary

focused on quickly identifying and transferring uncontaminated property.

However, although the services identified about 121,200 of about 250,100

acres at 1988 and 1991 closing installations as uncontaminated, the

regulators only concurred on 34,499 acres.

Principal Findings

Cleanup Estimates Have

Increased and Will Be

Higher

DOD’s estimate for cleaning up bases identified in the 1988 and 1991 rounds

increased by $400 million from 1993 to 1995, for a total of about

$2.2 billion. When the cost for the 1993 round installations was added in,

the estimate in DOD’s 1995 budget request for 123 installations and

activities in three rounds was almost $4 billion. However, this estimate is

probably understated for three reasons. First, the budget estimates DOD

originally submitted were based on preliminary information. Since it

originally developed the estimate, DOD has discovered additional sites, the

cleanup standards have increased, and new technologies have not

materialized as expected. More recent information provided by 84 affected

bases in April 1994 shows estimates to be about $5.4 billion, or $1.6 billion

more than the total estimate for these same installations in the fiscal year

1995 budget request. Second, DOD required more comprehensive estimates

of environmental cleanup and compliance costs in the recent information.

Third, the 1995 budget estimates are for the 6 years bases have to close, as

opposed to the actual cleanup time, which usually takes much longer. For

example, the average cleanup for the more serious sites can require 10

years, and with long-term monitoring can extend to 30 years and longer.

Of the nearly $4 billion identified in the 1995 budget, as of September 1994,

$1.8 billion had been appropriated; of that amount, about $334 million was

unobligated, down from $813 million unobligated as of June 1994. DOD said

that high levels of unobligated funds have occurred because it lacked the

expertise needed to develop better estimates and installations were slow

to obligate funds.

Efforts to Facilitate

Property Transfer Are

Affected by Cleanup Issues

The Comprehensive Environmental Response, Compensation, and

Liability Act of 1980 requires that all property be cleaned up before it is

transferred to nonfederal owners for reuse. Consequently, DOD gives a high

priority for cleanup to installations scheduled to close and realign in order

to allow for quick, nonfederal reuse. DOD also gives high cleanup priority to

Page 4 GAO/NSIAD-95-70 Military Bases
Executive Summary

sites on the Environmental Protection Agency’s National Priorities List, a

register of the nation’s worst contaminated sites. But most closing and

realigning bases are not on this list. For example, of 84 bases that

submitted cleanup plans, only 21 are on the National Priorities List. As a

result, the need for cleanup funding has been accelerated for many

installations that would not have been eligible otherwise. GAO reported in

April 1994 that DOD had too many high priority sites, which distracts from

cleaning up the worst sites first.

Much of the property at closing bases will be retained by federal agencies

and can be made available to federal users before it is cleaned up. For

example, DOD is retaining or transferring to federal agencies about 156,700

acres, or 63 percent of the 250,100 acres on installations from the 1988 and

1991 rounds. Some of the property is heavily contaminated with

unexploded ordnance. For example, most of the Army’s Jefferson Proving

Ground, Indiana, is being added to a national wildlife refuge owned by the

Department of the Interior’s Fish and Wildlife Service.

The Comprehensive Environmental Response, Compensation, and

Liability Act prohibits transferring property to nonfederal ownership until

the necessary cleanup actions have been taken, but the Community

Environmental Response Facilitation Act amended it in 1992 to expedite

transfer. This amendment considers cleanup actions “have been taken” if

they are in place and operating properly and successfully. Although the

amendment allows the property to be transferred to nonfederal users

before cleanup is finished, much of the property is in the early stages of

the cleanup process and little of it has actually been transferred.

To further facilitate the reuse of property prior to cleanup and ownership

transfer, Congress in the National Defense Authorization Act for Fiscal

Year 1994 allowed long-term leases of property to nonfederal users. As of

January 1995, the Air Force had signed six leases covering 11,169 acres

and ranging from 25 to 70 years, and the other services had leasing actions

in process. With leases, the government is still potentially liable for any

hazardous waste the tenant generates. Other issues affecting leasing are

(1) the time and effort required to complete the documents and processes

required to satisfy federal and state laws and DOD policies and (2) the

obligation of the services to monitor and manage the environmental

aspects of the property.

Page 5 GAO/NSIAD-95-70 Military Bases
Executive Summary

Cleanup Progress Has

Been Limited, and

Improvements Are Needed

DOD has made limited cleanup progress for several reasons. First, the study

and evaluation process is lengthy, and cleanups are complex and, with

existing technology, take time. In cleanup plans submitted for 84

installations in April 1994, 51 identified polluted groundwater, 67 identified

contaminated landfills, and 25 identified unexploded ordnance

contamination among sites to be cleaned up. Second, some of the

contaminated sites are just too large or prohibitively expensive to clean

up, and some of the cleanup methods are unsure. Decontaminating

groundwater is costly, difficult, and sometimes impossible. At Norton Air

Force Base, California, for example, groundwater contamination extends

from the central base area, southwest in the direction of groundwater flow

beneath the base, and continues beyond the base boundary, possibly

affecting several community water supply wells. One method, called

pump-and-treat, is expensive, can take decades, and still leaves the water

contaminated. At landfills, national cleanup standards do not exist, and

local standards must be negotiated for each site. Cost-effective technology

is not available to clean up unexploded ordnance, and some areas are so

large that it is not even feasible to consider cleaning it up. For example,

unexploded ordnance covers potentially about 51,000 acres of Jefferson

Proving Ground, Indiana, and 7,200 acres of Fort Ord, California. The

cleanup plan for Jefferson Proving Ground estimated that cleanup of

unexploded ordnance could cost from $216 million to $8 billion, depending

on reuse. Third, new technology is frequently not a ready option because it

may involve unacceptable risks or contractors may prefer other

technology based on their past experiences.

Impediments Remain to

Quick Cleanups

To try to overcome these obstacles, DOD established the Fast Track

Cleanup program in 1993. Although the program has addressed

impediments to quick cleanup and transfer of property, certain actions

have not achieved the desired or initially planned results. Thus, some

significant impediments remain. Progress in the program’s five key

elements has been as follows:

• Environmental impact statements depend on communities submitting

reuse plans, and most of these plans have not been developed.

• Restrictive indemnification language has been clarified.

• Uncontaminated parcels from the 1988 and 1991 closing installations have

been identified for transfer, but not as much uncontaminated property has

been identified as hoped.

Page 6 GAO/NSIAD-95-70 Military Bases
Executive Summary

• Teams have been established at closing bases to make decisions and

develop cleanup plans, but decisions are still made above the base level,

and base cleanup plans can be improved.

• Community cleanup advisory boards that involve the public in the cleanup

program have been established, but can be improved.

DOD has not been able to evaluate the effectiveness of the Fast Track

Cleanup program because it lacks a baseline and performance measures.

Although DOD is developing performance measures, it has not set any

milestones for completion. Right now, it is considering two measures.

First, identify the percentage of closing bases with a completed

environmental impact analysis. However, this is not a problem that needs

to be addressed now. Second, cite the percentage of property at closing

bases that could be made available for reuse. This does not measure the

success of cleanup actions if property is leased. Neither of these measures

address other elements of the program.

Recommendations GAO recommends that the Secretary of Defense (1) develop an

environmental program cost estimate that reflects the total financial

impact of realignment and closure actions, (2) approve sites for high

priority environmental funding only when cleanup or compliance is

required or cost-effective for nonfederal reuse to occur, and (3) establish

Fast Track Cleanup program standards that will allow DOD to assess the

program’s progress.

Agency Comments As requested, GAO did not obtain formal comments on this report.

However, GAO discussed its findings with DOD and EPA officials and

included their comments where appropriate.

Page 7 GAO/NSIAD-95-70 Military Bases
Contents

Executive Summary 2

Chapter 1 

Introduction

10

Background 10

Military Installation Closures in 1988, 1991, and 1993 10

Environmental Cleanup Requirements 12

DOD Environmental Cleanup Efforts 14

Objectives, Scope, and Methodology 14

Chapter 2 

Significant Cost,

Funding Priority, and

Reuse Issues Need to

Be Addressed

16

Cleanup Cost Estimates Are Likely to Continue Increasing 16

Substantial Unobligated Amounts in BRAC Environmental

Accounts

19

High Priority Cleanup Funding Appears Unwarranted for Many

Installations

20

Conclusions 24

Recommendations 24

Chapter 3 

Cleanup Progress Is

Limited, and

Technology and

Management

Improvements Are

Needed

26

Cleanup Is in the Early Stages of the Process, and New and Better

Technology Is Needed

26

Fast Track Cleanup Program Is Being Implemented but Needs

Additional Development

35

Conclusions 40

Recommendation 41

Appendixes Appendix I: Comprehensive Environmental Response,

Compensation, and Liability Act Process

42

Appendix II: Locations and Organizations Visited 43

Appendix III: NPL Status and Summary of Contaminants as

Reported in 79 BRAC Cleanup Plans

44

Appendix IV: BRAC Cleanup Plan Cost Estimates Beyond the

6-Year Closure Period for 14 BRAC 1988 Installations

47

Appendix V: Major Contributors to This Report 48

Tables Table 2.1: Comparison of Total Estimated Cleanup Costs in BRAC

Budget and Cleanup Plans

17

Page 8 GAO/NSIAD-95-70 Military Bases
Contents

Table 2.2: Appropriated and Unobligated BRAC Environmental

Funds

19

Table 2.3: BRAC Cleanup Plan Estimates for NPL and Non-NPL

Installations

21

Table 2.4: Long-Term Leases at BRAC Air Force Bases 23

Table 3.1: Summary of Uncontaminated Property on 1988 and

1991 Closing Installations

37

Figures Figure 1.1: Summary of Air Force, Army, and Navy Installations

and Activities in 1988, 1991, and 1993 Rounds

12

Figure 3.1: Groundwater Pump-and-Treat Pilot Project, Pease Air

Force Base, New Hampshire

28

Figure 3.2: Landfill Excavation and Soil Removal Project, Pease

Air Force Base, New Hampshire.

29

Figure 3.3: Portion of the Army’s Jefferson Proving Ground

Ordnance Range

32

Figure 3.4: Item of Unexploded Ordnance Found Buried on the

Army’s Jefferson Proving Ground Range

33

Abbreviations

BCP BRAC cleanup plan

BRAC Base realignment and closure

CERCLA Comprehensive Environmental Response, Compensation,

and Liability Act

CERFA Community Environmental Response Facilitation Act

DERA Defense Environmental Restoration Account

DOD Department of Defense

EPA Environmental Protection Agency

NPL National Priorities List

RCRA Resource Conservation and Recovery Act

Page 9 GAO/NSIAD-95-70 Military Bases
Chapter 1 

Introduction

The Department of Defense (DOD) is in the process of realigning and

closing military installations. An initial major round of installation

realignments and closures occurred in 1988, subsequent rounds followed

in 1991 and 1993, and another round is scheduled for 1995. Congress has

expressed concern that environmental cleanup issues related to past

activities at these installations are significantly affecting DOD’s ability to

transfer these properties to local communities. This report focuses on that

issue; however, other factors—disagreements between federal agencies,

local community interests, and others over reuse plans, as well as revised

laws and regulations designed to improve the property disposition

process—have also affected property transfers. We have reported

separately on these issues for bases closed in the 1988 and 1991 rounds1

and are reviewing 1993 closing bases now.

Background For decades, DOD activities and industrial facilities generated, stored,

recycled, and disposed of hazardous waste, which often contaminated

nearby soil and groundwater. In many instances, these problems predate

existing environmental laws and regulations. Hazardous waste

contamination can significantly contribute to serious illness or death or

pose a hazard to the environment and is extremely expensive to clean up.

Types of hazardous waste found at most DOD installations include solvents

and corrosives; paint strippers and thinners; metals, such as lead,

cadmium, and chromium; and unexploded ordnance. Contamination

usually results from disposal, leaks, or spills.

Cleanup goals and strategies are usually site specific and depend upon the

cleanup standards, exposure potential, affected population, and nature

and extent of contamination. All of these determine the threat to human

health and the environment. Cleanup efforts at closing installations are

carried out primarily by contractors. DOD gives the highest priority for

cleanup to installations on the Environmental Protection Agency’s (EPA)

National Priorities List (NPL), a register of the nation’s worst known

hazardous waste sites, and to those scheduled to realign and close.

Military Installation

Closures in 1988,

1991, and 1993

The Defense Authorization Amendments and Base Closure and

Realignment Act (P.L. 100-526), enacted on October 24, 1988, established a

bipartisan commission to make recommendations to Congress and the

Secretary of Defense on base closures and realignments and specified the

1

Military Bases: Reuse Plans for Selected Bases Closed in 1988 and 1991 (GAO/NSIAD-95-3,

Nov. 1, 1994).

Page 10 GAO/NSIAD-95-70 Military Bases
Chapter 1 

Introduction

conditions and authorities to implement these actions. The Defense Base

Closure and Realignment Act of 1990 (Part A of title XXIX of P.L.

101-510) also created an independent commission that would meet during

calendar years 1991, 1993, and 1995 to review additional installations DOD

recommended for realignment and closure.

DOD is carrying out the approved installation closures and realignments

and is reviewing installations to recommend for realignment and closure

for the 1995 round. Figure 1.1 summarizes DOD information on installations

and activities designated for closure and realignment in 1988, 1991, and

1993. We have reported separately on the recommendations and processes

for each of these rounds.2

2

Military Bases: An Analysis of the Commission’s Realignment and Closure Recommendations

(GAO/NSIAD-90-42, Nov. 29, 1989); Military Bases: Observations on the Analysis Supporting Proposed

Closures and Realignments (GAO/NSIAD-91-224, May 15, 1991); and Military Bases: Analysis of DOD’s

Recommendations and Selection Process for Closures and Realignments (GAO/NSIAD-93-173, Apr. 15,

1993).

Page 11 GAO/NSIAD-95-70 Military Bases
Chapter 1 

Introduction

Figure 1.1: Summary of Air Force,

Army, and Navy Installations and

Activities in 1988, 1991, and 1993

Rounds

Number of installations

0

5

10

15

20

25

30

35

40

45

50

55

60

65

Air

Force

Army Navy

27 33 63

1993

1991

1988

Environmental

Cleanup

Requirements

Federal property that is no longer needed is not automatically sold. The

Federal Property and Administrative Services Act of 1949 requires a

screening process to determine if property can be transferred to another

government or nonprofit agency. DOD first screens excess property for

possible use by other DOD agencies and then by other federal agencies. If

no federal agency needs the property, it is declared surplus to the federal

government and is made available to nonfederal parties, including state

agencies, local agencies, agencies caring for homeless people, public

benefit agencies, or the general public.

Also, federal agencies, including DOD, must comply with environmental

laws and regulations when disposing of real property. Pertinent

environmental laws include the following:

• The Comprehensive Environmental Response, Compensation, and

Liability Act of 1980 (CERCLA) (42 U.S.C. 9601), also known as Superfund,

Page 12 GAO/NSIAD-95-70 Military Bases
Chapter 1 

Introduction

authorizes the federal government to respond to spills and other releases

or threatened releases of hazardous substances, as well as to leaking

hazardous waste dumps. CERCLA provides the framework for responding to

contamination problems. It requires that the government warrant that all

remedial action necessary to protect human health and the environment

has been taken before property is transferred by the United States to any

other person or entity, such as communities or private parties.

• The Resource Conservation and Recovery Act of 1976 (RCRA) (42 U.S.C.

6901) was enacted to ensure that solid wastes are managed in an

environmentally sound manner.

• The Federal Facilities Compliance Act (42 U.S.C. 6901 note) amended RCRA

and provides that federal facilities may be subject to federal, state, and

local penalties for environmental violations. It also establishes specific

requirements for waste generated by the Department of Energy and DOD.

• The National Environmental Policy Act of 1969 (42 U.S.C. 4321) governs

the environmental assessments and impact statement preparation for the

disposal and reuse of base closure and realignment installations.

CERCLA and RCRA govern much of the environmental and closure-related

activities at base realignment and closure, or BRAC, installations. In

compliance with CERCLA, EPA reviews DOD information to determine if the

installation should be included on the NPL. The CERCLA process consists of

several stages and may apply to any waste source and site containing

hazardous substances at BRAC installations. (See app. I.) EPA does not have

authority to delegate CERCLA enforcement to the states. However, CERCLA

does call for substantial involvement by each state in initiating,

developing, and selecting remedial actions to be taken.

RCRA is designed to ensure that solid waste is managed in an

environmentally sound manner and establishes a framework for managing

hazardous waste. All BRAC installations are subject to RCRA because of

practices that generated, stored, treated, or disposed of hazardous waste.

RCRA, as amended in 1992 by the Federal Facilities Compliance Act,

directed EPA to conduct annual inspections of federal facilities. RCRA allows

EPA to authorize states to conduct equivalent state programs; in these

cases, they have the primary responsibility for implementing corrective

actions at a base that is designated as a treatment, storage, or disposal

facility. States with an authorized hazardous waste program may inspect a

federal facility to enforce compliance with state hazardous waste

programs.

Page 13 GAO/NSIAD-95-70 Military Bases
Chapter 1 

Introduction

DOD Environmental

Cleanup Efforts

DOD established the Installation Restoration Program in 1975 to study and

clean up contaminated sites. In 1984, this program was made part of the

Defense Environmental Restoration Program, and Congress provided

funding through the Defense Environmental Restoration Account (DERA).

In the 1990 base closure law (P.L 101-510), Congress began providing

separate cleanup funding for closing and realigning installations under the

BRAC account.

In May 1993, DOD created the Under Secretary of Defense (Environmental

Security) position to oversee cleanup and other environmental efforts. In

July 1993, the administration expressed concern that closing military

installations had been cumbersome and slow, with environmental cleanup

and other processes taking many years to complete. At that time, it

announced a five-part program to help accelerate cleanup and community

reuse of closing installations.

Objectives, Scope,

and Methodology

The former Chairman, Subcommittee on Environment, Energy and Natural

Resources, House Committee on Government Operations, and

Representative George Miller, California, requested us to review DOD’s

environmental cleanup efforts at installations being closed under the BRAC

process. Specifically, they asked us to review issues related to the

(1) cleanup cost, transferability, and reuse of property by nonfederal users

and (2) progress, difficulties, and plans to address the problems.

We performed work at the Office of Secretary of Defense, military services

headquarters, and EPA. To determine costs being estimated for the

program, we reviewed DOD’s BRAC budget data, including justification

documents submitted to Congress in February 1994. In addition, we

observed BRAC cleanup plan (BCP) training sessions held in San Francisco,

California, in November 1993. Later, we analyzed cost information in

79 plans prepared by installations with property to be transferred to

nonfederal users. (See app. III.) We also visited closing installations and

environmental cleanup design and construction management commands

to determine how cost data is developed by each of the services.

(See app. II.)

To determine transferability and reuse, we reviewed BRAC and

environmental laws, DOD and EPA headquarters policies and guidance to the

military services, and environmental cleanup and reuse programs at BRAC

installations. We also reviewed data developed by the services to identify

uncontaminated property that would be available for quick transfer.

Page 14 GAO/NSIAD-95-70 Military Bases
Chapter 1 

Introduction

We identified progress and plans to address problems during discussions

with DOD and EPA headquarters, DOD design and construction management,

and closing base officials, as well with EPA regional officials. In addition,

we observed training sessions on DOD’s Fast Track Cleanup program,

reviewed data in installations’ BCPs, and visited a number of these

installations. Furthermore, we attended meetings of the Defense

Environmental Restoration Task Force in Austin, Texas; Philadelphia,

Pennsylvania; and Charleston, South Carolina. We also attended several

public hearings during visits to installations, including the California

Military Base Reuse Task Force, installations’ cleanup advisory board

meetings, and a hearing on cleanup remedy selection. We visited the

California Environmental Protection Agency, Sacramento, California, and

discussed specific issues with environmental officials of other states.

As requested, we did not obtain written agency comments. However, we

discussed the report’s contents with DOD and EPA officials and

incorporated their comments where appropriate. We performed the review

between February 1994 and January 1995 in accordance with generally

accepted government auditing standards.

Page 15 GAO/NSIAD-95-70 Military Bases
Chapter 2 

Significant Cost, Funding Priority, and

Reuse Issues Need to Be Addressed

Congress, DOD, and EPA have taken actions over the past several years to

address a number of important matters relevant to resolving

environmental cleanup issues at bases that are being closed and realigned.

However, problems still remain with determining accurate cleanup costs,

timing appropriations with cleanup needs, prioritizing available cleanup

funds, and protecting the government’s interests when leasing or

transferring property.

Cleanup Cost

Estimates Are Likely

to Continue

Increasing

As reported in its fiscal year 1995 BRAC budget justification document,

DOD’s total estimate for cleaning up environmental problems at 123 closing

and realigning installations and activities was about $4 billion. However,

more recent data developed by DOD in April 1994 shows that estimates for

just 84 installations totaled about $5.4 billion, and costs are likely to go

beyond that amount as more complete data becomes available.

BRAC Budget Estimates

for Cleanup Will Continue

to Increase

The BRAC accounts were established to be the exclusive source of funds for

environmental restoration projects related to base closures. The intent

was to preclude the cleanup actions from competing with other sources of

funding for environmental cleanup such as the DERA. DOD’s BRAC budget

estimates for cleanup cover 6-year periods; thus, the estimate for the 1988

round spans fiscal years 1990 through 1995; the estimate for the 1991

round spans fiscal years 1992 through 1997; and the 1993 round spans

fiscal years 1994 through 1999. BRAC budget justification documents are to

address the total financial impact of realignment and closure actions.

DOD’s estimate in the fiscal year 1995 budget for the 1988 and 1991 rounds

increased from the fiscal year 1993 estimate by about $400 million, to

about $2.2 billion. In addition, the 1995 budget estimate included about

$1.8 billion for the 1993 round, raising the total estimate for the first three

rounds to almost $4.0 billion for 123 installations and supporting activities.

This estimate represents the total BRAC budget through fiscal year 1999.

According to DOD, these estimates increased because they were based on

preliminary information, and costs depend on the type of contaminants

detected, conditions found, and the cleanup technologies selected.

More Recent Information

Increases Estimates

More recent information developed by DOD in cleanup plans on 84 of the

123 installations shows an estimate of about $5.4 billion. This estimate is

likely to increase as more bases are added and all costs are captured.

Page 16 GAO/NSIAD-95-70 Military Bases
Chapter 2 

Significant Cost, Funding Priority, and

Reuse Issues Need to Be Addressed

In September 1993, as part of its Fast Track Cleanup program to accelerate

cleanup and reuse of BRAC installations, DOD required installations with

property that could be transferred for nonfederal use to develop

comprehensive BRAC cleanup plans and to submit these plans by

April 1994. The military services forwarded 79 such plans, covering 84

installations, and the estimated cleanup costs in these plans totaled nearly

$5.4 billion. (See app. III.) This is about $1.6 billion more than the fiscal

year 1995 BRAC budget estimates for these same 84 installations, as

summarized in table 2.1.

Table 2.1: Comparison of Total

Estimated Cleanup Costs in BRAC

Budget and Cleanup Plans

Dollars in millions

Number of

cleanup plans

Fiscal year

1995 BRAC

budget

estimates

Cleanup plan

estimates Difference

Air Force 26 $1,674 $1,207 ($467)

Army 19 693 1,268 575

Navy 34 1,356 2,882 1,526

Total 79 $3,723 $5,357 $1,634

Source: DOD BRAC Fiscal Year 1995 Budget Estimates, Justification Data Submitted to Congress

(Feb. 1994); BRAC Cleanup Plans (Apr. 1994)

DOD officials told us that the cleanup plans required more comprehensive

cost estimates than the BRAC budget estimates. They said that total

environmental programs at closing and realigning bases go beyond those

costs identified in the BRAC budgets. For example, some cleanup plans for

Army installations needed DERA funds in addition to BRAC funds. Also, both

the Army and Navy plans identified funding needed for environmental

compliance and for the preservation of natural and cultural resources.

Also, BRAC budget estimates cover only the 6-year period that bases are

allowed to close. However, the average cleanup can take much longer. The

cleanup plans include 14 installations from the 1988 round of closures that

estimated they will need $536 million after the 6-year period. (See app. IV.)

For example, the BRAC budget estimate for the Army’s Jefferson Proving

Ground, Indiana, was about $11 million. The cleanup plan estimated it

would cost $233 million, including $789,000 prior to 1989, $16.1 million in

BRAC and other funding between 1990 and 1995, and $216.1 million in DERA

funding after the 6-year period. The cleanup plan shows that this

$216.1-million figure assumed no change in how the base was being used,

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and if another reuse option was selected, the total estimated cost for this

one base could be $2 billion per year for fiscal years 1996 to 1999.

Although the cleanup plans provide a more complete view of

environmental costs at closing bases, they did not generally capture

complete costs. In some cases, long-term monitoring costs may go on for

many years beyond the base cleanup plan estimates. For example, Pease

Air Force Base, New Hampshire, reported no costs beyond fiscal year

1999, but officials estimated it will cost $300,000 a year to monitor the

groundwater for an indefinite period beyond 1999. Similarly, Norton Air

Force Base, California, officials estimated long-term remedial operations

will cost $38.9 million through 2010, but the Air Force’s estimate only

included monitoring costs through fiscal year 1999.

Furthermore, the cleanup plan estimates did not include some sites that

have yet to be investigated at the 84 installations. At its Charleston, South

Carolina, complex, consisting of a station, shipyard, and fleet industrial

supply center, the Navy is presently investigating 39 waste management

sites and has identified 330 potential areas of concern that require further

study. Assessments are currently being performed of 118 of the potential

areas. The remaining sites were recently identified during a site inspection,

and the appropriate investigation approaches are being formulated. The

Army Materials Technology Laboratory, Massachusetts, was recently

added to the NPL, requiring the Army to address surface water

contamination cleanup previously not planned or budgeted. EPA is

currently assessing the Army’s Jefferson Proving Ground for possible

addition to the NPL, and other installations could be considered for NPL

status in the future.

The Congressional Budget Office reported in January 1995 on

unanticipated cost growth that has occurred for installations scheduled to

close. It observed that cost estimates increased for 34 of 49 installations

being closed because (1) DOD discovered additional sites and contaminants

on its installations and (2) new technologies that could reduce costs have

been slow in coming and gaining acceptance. They also said that stricter

cleanup standards than planned could significantly add to the costs.3

 As

part of our review on DOD’s Future Years Defense Program, we reported in

July 1994 that DOD’s environmental costs may be significantly understated.4

3

Cleaning Up Defense Installations: Issues and Options, Congressional Budget Office (Jan. 1995).

4

Future Years Defense Program: Optimistic Estimates Lead to Billions in Overprogramming

(GAO/NSIAD-94-210, July 29, 1994).

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Significant Cost, Funding Priority, and

Reuse Issues Need to Be Addressed

Substantial

Unobligated Amounts

in BRAC

Environmental

Accounts

Of the nearly $4 billion identified for environmental cleanup through fiscal

year 1999 in the 1995 BRAC budget estimate, $1.8 billion had been

appropriated through fiscal year 1994. By June 1994, only about 55 percent

of $1.8 billion had been obligated, and about $813 million was unobligated.

However, by September 30, 1994, about $334 million remained

unobligated, as shown in table 2.2.

Table 2.2: Appropriated and

Unobligated BRAC Environmental

Funds (as of September 30, 1994) 

Dollars in millions

Fiscal year 1991 1992 1993 1994 Total

Total appropriated $302.8 $542.0 $453.4 $515.1 $1,813.3

Amount unobligated

BRAC 1988 $27.7 $33.1 $62.2 0 $123.0

BRAC 1991 0 30.7 80.1 $66.7 $177.5

BRAC 1993 0 0 0 33.9 $ 33.9

Total $27.7 $63.8 $142.3 $100.6 $334.4

Percent unobligated 9 12 31 20 18

Source: DOD, Office of the Comptroller

BRAC funds are available to be obligated during the 6-year period bases

have to close. According to DOD officials, however, the services’ perception

is that funds should be obligated in the year appropriated, and high

unobligated balances are seen by the services as a failure to execute their

programs. For example, in October 1992, the Army increased the BRAC 1991

account for Fort Ord, California, by $11.8 million for environmental

restoration, stating that the Army had to obligate its current funds to

receive additional 1991 funds DOD had withheld. Between February and

September 1993, $10.8 million was obligated for an existing contract with

provisions that the work would be fully defined and priced later.

In explaining the high levels of unobligated balances, DOD said that it

(1) was probably overly optimistic in the funds requested, (2) did not have

all the necessary expertise to better estimate requirements and timing, and

(3) experienced slow obligation rates by the installations. DOD officials told

us that the unobligated balances improved between June and

September 1994 because the services entered into cost-reimbursable

contracts for the total design and actual cleanup of installations, instead of

contracting separately for design and cleanup. As indefinite

delivery/indefinite quantity cost-reimbursable contracts, they are higher

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risk to the government and will require closer oversight of the contractor’s

operations.

High Priority Cleanup

Funding Appears

Unwarranted for

Many Installations

DOD gives the highest priority to cleaning up installations on EPA’s NPL and

installations scheduled to close and realign. For BRAC installations in the 79

BRAC cleanup plans, the cost of cleanup for non-NPL installations is about

$3.4 billion, compared to $2.0 billion for NPL installations. BRAC installations

are given a high priority to facilitate the transfer of property to nonfederal

use as soon as possible. However, most BRAC property will stay under

federal ownership. Also, until 1992, CERCLA required cleanup before

property could be transferred to nonfederal owners, but a 1992

amendment allows for the transfer of property before cleanup is finished

under certain stipulations. Furthermore, a 1994 law allows for long-term

leases to nonfederal users before cleanup is complete. We reported that

DOD will not be able to efficiently institute cleanup efforts until it and EPA

evaluate the large number of sites currently on the NPL and at BRAC

installations and determine which should be designated as high priority.5

High Priority Cleanup

Accelerates DOD’s

Funding Needs

In 1990, Congress designated the BRAC appropriations account to be the

exclusive source of funding for environmental restoration at BRAC

installations. Congress established this separate cleanup funding because

it was concerned that the higher priority being given to closing and

realigning installations would exhaust all DERA funding. In the same act,

Congress directed that DOD restore any property excess to its needs as a

result of closure or realignment as soon as possible. High priority funding

was necessary for these installations because CERCLA requires

environmental cleanup to be completed before nonfederal ownership

transfer and reuse can occur.

Giving all closing and realigning installations the same status as NPL

installations has significantly increased the number of priority installations

and accelerated the funding DOD needs for high priority cleanup. Of the 84

installations identified in the cleanup plans, 21 are for NPL installations and

receive priority cleanup funding consideration regardless of whether they

close or realign. (See app. III.) Cleanup estimates in these 21 installations’

plans totaled $2.0 billion. However, the other 63 installations would not

have been given high priority status if they were not closing or realigning.

Estimated cleanup costs in plans for these installations amounted to

5

Environmental Cleanup: Too Many High Priority Sites Impede DOD’s Program (GAO/NSIAD-94-133,

Apr. 21, 1994).

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$3.4 billion, or 63 percent of the nearly $5.4-billion total estimate. (See

table 2.3.) For example, the Long Beach Naval Station and Hospital,

California, are not on the NPL. However, these installations add an

estimated $221 million to DOD’s priority requirements.

Were these non-NPL bases not closing or realigning, they would likely

receive funds only for essential cleanup and compliance activities. For

example, non-NPL installations would likely receive funds to remove

underground storage tanks to meet deadlines in the law, but asbestos and

lead-based paint surveys not subject to a deadline might be deferred to

later years. Army headquarters officials told us there had never been much

DERA funding available to clean up non-NPL installations, but funds became

available once an installation was identified for closure. Environmental

officials at Fort Ord, California, said that before their installation was on

the NPL, they had trouble competing for DERA cleanup funding.

Table 2.3: BRAC Cleanup Plan

Estimates for NPL and Non-NPL

Installations

Dollars in millions

NPL Non-NPL Total

BRAC 1988 $257 $841 $1,098

BRAC 1991 1,147 874 $2,021

BRAC 1993 601 1,636 $2,237

Total $2,005 $3,351 $5,356

Source: BRAC cleanup plans

DOD officials told us that cleanup priority funding was needed for non-NPL

installations because (1) BRAC funding is tied to the 6-year period allowed

for bases to close, (2) legal mandates established by state law or the courts

exist at some bases, and (3) communities are expecting their installations

to be cleaned up as soon as possible.

Property Can Be

Transferred to Other

Federal Agencies Before

Cleanup Is Complete

CERCLA allows DOD to transfer property to another service or federal agency

before completing cleanup. However, the proper arrangements for cleanup

must be made, and DOD’s potential liability is significant.

As we reported in November 1994, DOD is retaining most of the property or

transferring it to other federal agencies.6

 It is retaining about

156,700 acres, or 63 percent of the 250,100 acres on installations from the

6

Military Bases: Reuse Plans for Selected Bases Closed in 1988 and 1991 (GAO/NSIAD-95-3,

Nov. 1, 1994).

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1988 and 1991 rounds. Some of this property is being retained because of

extensive unexploded ordnance contamination. For example, at the

Army’s Jefferson Proving Ground, Indiana, due to long-term hazardous

waste contamination and the potential that unexploded ordnance could be

found all over the installation, it is impossible to dispose of all the

property. The Army was considering retaining all or part of it under a

caretaker program. However, the U.S. Department of Interior’s Fish and

Wildlife Service requested that most of the installation’s property be added

to a national wildlife refuge.

Even though these installations will not have to be cleaned up before the

property is transferred, DOD and the receiving agency must agree on what

remedial action will be taken. Consequently, DOD is still held responsible

for the cleanup, which ultimately could involve substantial costs.

According to DOD officials, DOD is responsible for cleaning up past

contamination, regardless of when it is identified, and meeting the

requirements of any new federal or state cleanup standards and laws. For

example, at the Hamilton Army Airfield, California, ownership of a landfill

on property once auctioned to a private developer has reverted to the

Army. Due to the presence of contamination, the Army will now pay to

contain landfill contaminants and treat the groundwater.

Property Can Be

Transferred to Nonfederal

Users Before Cleanup Is

Finished

About 93,400 (37 percent) of the 250,100 acres at closing 1988 and 1991

installations will potentially be available for transfer to nonfederal users.

CERCLA had prohibited DOD property transfers to nonfederal ownership

until the necessary cleanup action had been taken, but the Community

Environmental Response Facilitation Act (CERFA) amended CERCLA in 1992

to expedite transfer. Under the act, remedial action is considered to have

been taken if (1) the construction and installation of an approved remedial

design has been completed and (2) the remedy has been demonstrated to

EPA to be operating properly and successfully. Thereafter, any long-term

pumping and treating or operation and monitoring after the demonstration

does not preclude transferring the property.

Although the CERFA amendment could eventually facilitate the transfer and

reuse of property under CERCLA, most sites at BRAC installations are in the

early investigation and study stages and have not reached the point where

remedies are in place. An EPA headquarters official, after checking with EPA

regions, told us that data is not being collected, but it is unlikely that much

property has been transferred so far where remedies are in place and

operating successfully.

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Long-Term Leases Allow

Reuse Before Cleanup

In general, DOD may only lease property that is under its control, not

currently needed for public use, and not excess property. A limited

exception was available for property found to be excess as a result of

closure or realignment, where a military service determined that leasing

would facilitate economic reuse. However, leases were subject to

limitations, including a term not to exceed 5 years and DOD’s right to

revoke the lease at will.

As part of the National Defense Authorization Act for Fiscal Year 1994

(P.L. 103-160), Congress authorized the military services to lease property

to facilitate state or local economic reuse without limiting the length of a

lease. As of January 1995, the Air Force has used the provision to enter

into six leases, ranging from 25 to 70 years, for airports and other uses, as

shown in table 2.4. The other services had leasing actions in process.

Table 2.4: Long-Term Leases at BRAC

Air Force Bases Air Force base State Acres Years

Bergstrom TX 2,516 50

Chanute IL

1,801

Airport - 25

Other - 50

George CA 2,300 25

Norton CA 1,289 55

Pease NH 1,720 55

Rickenbacker OH 1,543 70

Total 11,169

Source: Air Force Base Conversion Agency

Although leasing property allows its reuse before cleanup has been

completed, DOD is still liable for environmental cleanup costs. Thus,

leasing still leaves the question of how the government should be

protected from liability for hazardous waste that results from the current

tenant’s operations. Even though DOD conducts extensive environmental

surveys and includes numerous provisions in its leases to limit its liability,

DOD nonetheless remains a responsible party under CERCLA. For example,

between 1976 and 1986, the Navy leased most of its Hunters Point

Annex—a deactivated Navy shipyard listed for closure on the 1991

round—to a commercial business, which subleased many of the buildings

to other businesses. The activities conducted were primarily commercial

ship repair, and the lessee was later sued by the city of San Francisco for

the alleged illegal disposal of large amounts of hazardous waste. The Navy

remained the owner of the property and, according to the Navy

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environmental coordinator, has included these sites in its BRAC cleanup

program.

Other issues affecting leases are (1) the time and effort required to

complete the environmental documents and processes necessary to satisfy

federal and state laws and DOD policies and (2) the obligation of the

services to monitor and manage the property and environmental

requirements.

Conclusions Although various actions have been taken in recent years, Congress, DOD,

and local communities still face a number of difficult issues related to

(1) obtaining accurate cost estimates for completing cleanup efforts at

closing and realigning bases, (2) determining the proper timing of

appropriations to meet cleanup needs, (3) determining whether, in view of

limited resources and changes in law, all closing and realigning bases

should be given priority funding, and (4) facilitating the transfer of

property to federal and nonfederal users while ensuring the government’s

and DOD’s interests are protected.

In particular, we believe high priority funding for environmental cleanup at

closing and realigning installations needs to be reevaluated because most

property will stay under federal ownership, and property that will be

available for nonfederal ownership transfer can now be leased or reused

before it is entirely clean. It appears that DOD could be more selective and

designate priority funding for NPL installations and other sites where

cleanup is required for nonfederal reuse. This might reduce DOD’s

requirements for accelerated funding for nonpriority sites and spread

these costs into more appropriate future budget years.

Also, although property remaining as federal lands does not have to be

cleaned up before transfer, DOD appears to be retaining much of the

responsibility for cleanup. Accordingly, DOD needs to include these

potential unfunded liabilities in its total environmental program cost

estimate.

Recommendations We recommend that the Secretary of Defense develop a total

environmental program cost estimate of the financial impact of

realignment and closure actions that reflects

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• a more complete description of the costs as identified in the installations’

BRAC cleanup plans, including estimates for compliance, preservation of

natural and cultural resources, and long-term costs associated with

cleanup and monitoring; and

• unfunded liabilities where property is being retained by the federal

government and cleanup will be deferred.

We also recommend that the Secretary of Defense approve sites for high

priority environmental funding only when cleanup or compliance is

required or cost-effective for nonfederal reuse to occur.

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Technology and Management Improvements

Are Needed

Most sites at closing and realigning installations are still being investigated

and studied. Thus, the full extent of cleanup actions required may not be

known for years. Also, installations may not be cleaned up by the time

they close, and major groundwater, landfill, and unexploded ordnance

sites will remain contaminated unless new technology is developed.

Dissatisfied with the slow pace of cleanup that had occurred, DOD designed

the Fast Track Cleanup program in 1993. Although the program has made

some progress, it could be improved in such ways as adding performance

measures to gauge progress.

Cleanup Is in the

Early Stages of the

Process, and New and

Better Technology Is

Needed

DOD’s guidance for preparing cleanup plans called for installations to

account for all sites requiring restoration and to summarize their

environmental compliance programs. For example, installations identified

cleanup requirements, such as fuels, solvents, unexploded ordnance, and

other contaminants in training and maintenance areas, landfills, burn pits,

fuel stations, wastewater treatment areas, and at other sites. They

reported on programs to remove asbestos, radon, and lead-based paint

from buildings and other structures as well as inventories of underground

storage tanks that held fuel, waste petroleum, and other products.

The 84 installations included in the cleanup plans reported that most

environmental cleanup work was still in the early stages. For example, 49

of the installations combined many contaminated sites into “operable

units”7

 for more effective cleanup management. They reported that work

on 165 of 239 units, or 69 percent, was in the earliest phases—remedial

investigation and feasibility study. The plans estimated that 129 of the 165

units would not complete this phase until fiscal years 1995 to 1998. Most of

the work at the remaining installations was still in the remedial

investigation and feasibility study phases as well. According to DOD

officials, technology exists for the cleanup of many sites, but it needs to be

made more efficient and cost-effective. We reported that the CERCLA

progress is sluggish because the study and evaluation process is lengthy,

cleanups are complex, existing technology takes a long time, and the

average cleanup can require about 10 years.8

7

Operable units can be defined in a variety of ways. Examples of typical operable units include areas

(1) with similar contamination or waste materials, (2) in a similar geographic location, (3) that can be

cleaned up using similar techniques or timeframes, and (4) that can be managed under a single

remedial investigation or feasibility study.

8

Superfund: Progress, Problems, and Reauthorization Issues (GAO/RCED-93-27, Apr. 21, 1993).

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Technology and Management Improvements

Are Needed

Contaminated groundwater, landfills, and unexploded ordnance were

identified in many installations’ cleanup plans. (See app. III.) Some large

contaminated sites cannot be cleaned up because either knowledge and

expertise does not exist or has technology or cost limitations. At these

sites, interim cleanup actions are being used, and the sites will remain

contaminated unless new removal technology is developed. Remedies to

contain contamination require significant long-term operation,

maintenance, and monitoring efforts as well as further cleanup actions if

contamination recurs. A 1990 EPA study showed that containment

remedies may initially be less expensive to construct, but the required

operation and maintenance and the potential for failure increase their cost

in the long run. Containment at BRAC installations for major groundwater,

landfill, and unexploded ordnance sites will likely require cleanup efforts

over many years.

Cleanup of Groundwater Is

a Problem at Most BRAC

Installations

Decontaminating polluted groundwater, an issue identified in 51 of the 79

cleanup plans, is costly, difficult, and sometimes impossible. Once

contamination is detected, the uneven flow of groundwater and the

redistribution of the contaminants make cleanup difficult. According to

EPA, the technical challenges of eliminating groundwater contamination

are complex and efforts to speed up the process have been expensive and

achieved limited success.

For example, one of the most commonly used groundwater cleanup

technologies is “pump and treat,” where contaminated water is pumped to

the surface for treatment. However, this technology can cost millions of

dollars, take decades, and still leave groundwater contaminated.

Pump-and-treat systems were in place or planned for at least 24 of the

installations identified in appendix III. Figure 3.1 shows an example of a

pump-and-treat remediation project.

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Technology and Management Improvements

Are Needed

Figure 3.1: Groundwater

Pump-and-Treat Pilot Project, Pease

Air Force Base, New Hampshire

Pump-and-treat systems may need to be tested over several years to

determine their effectiveness. For example, at two installations we visited,

Norton and George Air Force Bases in California, pilot systems were in

place, but officials said they were operating at about one-half of the

capacity because the groundwater did not flow as expected. They said the

number of wells for these systems will need to be increased for sufficient

water to flow, and even if successful the systems may need to operate for

30 years or more. At Norton Air Force Base, groundwater contamination

extends from the central base area, toward the southwest in the direction

of groundwater flow beneath the base, and continues beyond the base

boundary. There are several community water wells near the base within

the anticipated path of the contaminants.

Furthermore, the pump-and-treat technology does not work on some

contaminants, according to EPA. These contaminants include certain

organic compounds, such as chlorinated solvents, polychlorinated

biphenyls (PCBs), creosote, and some pesticides. They are difficult to locate

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Are Needed

and remove and may continue to contaminate groundwater for hundreds

of years, despite best efforts to clean them up.

Landfills Must Be Cleaned

up at Most BRAC

Installations

Contaminated landfills were identified in 67 of 79 cleanup plans for closing

and realigning installations and may pose some major environmental

threats, particularly for groundwater. (See app. III.) Although small

landfills can be removed and eliminated, it is not practical to remove all

waste and contamination from larger ones.

National standards do not exist for cleaning up most contaminants in soil,

so DOD, EPA, and state regulators negotiate standards for each site. Large

landfills are often treated by placing a protective cap over the site to

contain the waste and prevent further contamination of the soil,

groundwater, and atmosphere. The groundwater conditions around the

landfill must also be assessed to determine whether contamination exists,

and, if necessary, identify the cleanup measures. Figure 3.2 shows a

landfill excavation and a soil removal project.

Figure 3.2: Landfill Excavation (below)

and Soil Removal Project (page 30),

Pease Air Force Base, New Hampshire.

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Are Needed

Landfills that close where waste has not been removed are also subject to

EPA requirements for maintenance and groundwater monitoring 30 years

after the landfill is closed. These requirements were established because

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Technology and Management Improvements

Are Needed

of the potential for environmental problems after closure. EPA or the state

must determine that closed facilities have complied with all regulatory

requirements. If not, the facilities must be brought into compliance.

More Cost-Effective

Technology Needed to

Clean up Unexploded

Ordnance

Unexploded ordnance is ordnance that has failed to function as designed,

has been abandoned or discarded, and is still capable of exploding and

causing injury. It results from operations conducted at weapons test and

training ranges and contains explosive, petroleum, metal, and other

compounds that may contribute to soil and water contamination. If

unexploded ordnance is buried below 3 feet, current technology may not

be able to detect it, and it can migrate to the surface over time.

Consequently, surface cleanup may need to be repeated.

Unexploded ordnance and related waste were identified at 25 closing

installations, including some installations where the contaminated areas

are so large that cleanup technology is not affordable. For example,

unexploded ordnance is potentially present on about 51,000 acres of the

Army’s Jefferson Proving Ground, Indiana; 7,200 acres of the Army’s Fort

Ord, California; and an unspecified amount of property at the Navy’s Mare

Island Shipyard, California. Current removal technology is labor intensive,

costly, and unreliable. Figure 3.3 shows a portion of a munitions firing

range that contains unexploded ordnance.

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Technology and Management Improvements

Are Needed

Figure 3.3: Portion of the Army’s Jefferson Proving Ground Ordnance Range

Note: The smoke in the upper center of the photograph is from the impact of live munitions.

According to Army ordnance and other officials, new and more

cost-effective technology needs to be developed for cleaning up the

unexploded ordnance. A study at the Army’s Jefferson Proving Ground,

which has extensive quantities, types, and dispersion of unexploded

ordnance, found that the cleanup effort would be labor intensive. For

example, the work would require using metal detectors for the majority of

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Technology and Management Improvements

Are Needed

land, mapping the unexploded ordnance, handling or removing it, and

disposing of it. Because the installation potentially has 51,000

contaminated acres and is heavily forested, current cleanup technology is

not practical or affordable. Although the cleanup plan included

$216 million in estimated costs, the plan noted that costs could run to

$2 billion a year for several years, and officials said other estimates for

cleanup have ranged from $5 billion to $8 billion in total, depending on

how the property is to be reused. Figure 3.4 shows an example of buried

unexploded ordnance.

Figure 3.4: Item of Unexploded Ordnance Found Buried on the Army’s Jefferson Proving Ground Range

Page 33 GAO/NSIAD-95-70 Military Bases
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Technology and Management Improvements

Are Needed

The closure of military installations and extent of unexploded ordnance

have intensified the need for DOD and EPA headquarters and states to

address many unresolved issues related to unexploded ordnance. These

issues concern costs and cleanup requirements, when unexploded

ordnance becomes a hazardous material, when DOD turns over control to

EPA and states, and which laws apply to cleanup. The 1992 Federal

Facilities Compliance Act amending RCRA required EPA to propose, after

consulting with the Secretary of Defense and appropriate state officials,

regulations identifying when military munitions become hazardous waste

and providing for its safe transportation and storage. The deadline for the

proposed regulations was October 1994. EPA officials told us in

January 1995 they missed that deadline and now plan to propose the

guidelines in July 1995.

Developing New

Technology Will Take Time

Containing and cleaning up contamination depends on developing new,

affordable technologies, but these technologies will take time to develop.

We recently reported that the process of choosing a new technology

involves many decisionmakers, technical expertise, and competing

interests.9

 The pressure to meet cleanup milestones also influences the

technology evaluation process and the solutions accepted. The reasons

why new technologies are not adopted faster include the following:

• Conflicting priorities prevent the approval of innovative approaches for

cleanup.

• Field officials may associate the newer technologies with unacceptable

levels of risk.

• On-site contractors may favor particular technologies on the basis of their

own experiences and investments.

In May 1993 testimony, DOD recognized that its environmental program

could be improved by directing cleanup efforts to meet potential users’

needs. DOD said it intended to (1) target environmental technology to high

payback areas, (2) apply research and demonstration funds to real

environmental needs, and (3) get support from regulators, states, and the

public for testing and fielding innovative technologies.10 Subsequently, in

1994, DOD began looking at technologies with high potential and ranking

9

Department of Energy: Management Changes Needed to Expand Use of Innovative Cleanup

Technologies (GAO/RCED-94-205, Aug. 10, 1994).

10Statement of the Deputy Under Secretary of Defense (Environmental Security), before the

Subcommittee on Installations and Facilities, Committee on Armed Services, House of Representatives

(May 13, 1993).

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Cleanup Progress Is Limited, and

Technology and Management Improvements

Are Needed

them according to potential benefits and feasibility. DOD officials said they

plan to begin demonstrating technologies and offer them to EPA and state

regulators for validation in 1995.

Fast Track Cleanup

Program Is Being

Implemented but

Needs Additional

Development

DOD established the Fast Track Cleanup program in July 1993 to accelerate

the environmental cleanup at closing installations. The program was

initiated under the five-part program the administration designed to

expedite the environmental cleanup and economic recovery of

communities affected by installation closures.

Progress in the Fast Track Cleanup program’s five key elements has been

as follows:

• Environmental impact statements depend on communities submitting

reuse plans, and most of these plans have not been developed.

• Restrictive indemnification language has been clarified.

• Uncontaminated parcels from the 1988 and 1991 closing installations have

been identified for transfer, but not as much uncontaminated property has

been identified as hoped.

• Teams have been established at closing bases to make decisions and

develop the cleanup plans, but decisions are still made above the base

level, and bases’ cleanup plans can be improved.

• Community cleanup advisory boards that involve the public in the cleanup

program have been established, but can be improved.

The program is not fully implemented, and it is too early to

comprehensively judge its effectiveness. However, DOD has made some

progress in implementing certain elements of the program, but further

development is necessary.

Completing Environmental

Impact Statements

The Fast Track Cleanup strategy paper stated that the process for

preparing an environmental impact statement typically takes

28 to 48 months. The Fast Track Cleanup program requires the military

services to complete the environmental impact statement within

12 months of a community submitting its final reuse plan. However,

community reuse plans are not completed for many of the installations

submitting cleanup plans. According to service officials, they anticipate

being able to complete the statements within the 12 months allowed once

reuse plans are received.

Page 35 GAO/NSIAD-95-70 Military Bases
Chapter 3 

Cleanup Progress Is Limited, and

Technology and Management Improvements

Are Needed

Law Covering

Indemnification Clarified

The Fast Track Cleanup program concluded that indemnification language

in DOD’s 1993 appropriations act unintentionally caused DOD to slow down

granting interim leases. DOD’s authorization and appropriations acts for

1993 contained different provisions regarding the government’s liability for

the transfer of contaminated property. DOD viewed the provisions of the

appropriations act as exposing the government to costly claims because of

sweeping DOD indemnification language in the law. In response, DOD

stopped entering into any leases or transferring property for fear of future

claims. Congress subsequently repealed the appropriations language and

let the authorization language stand, which limited DOD’s liability to past

problems. DOD has proceeded with efforts to lease and transfer property.

Limited Uncontaminated

and Desirable Property

Identified for Nonfederal

Transfer

An issue that arose early in the BRAC process was whether property could

be transferred to parties outside the federal government without the entire

installation being cleaned up. Subsequently, Congress enacted CERFA in

1992, which allowed an installation to be divided into parcels that could be

considered separately for transfer. CERFA directs federal agencies to

identify uncontaminated parcels based on the specific requirements set

forth in CERFA. For parcels that are on a NPL installation, EPA must concur

with the results. For parcels on non-NPL installations, appropriate state

officials must concur. The deadline for identifying all parcels on BRAC 1988

and 1991 installations, including EPA or state concurrence, was April 19,

1994.

DOD officials told us that CERFA did not work as expected. Although

considerable resources have been spent, the anticipated numbers of

uncontaminated parcels available for quick transfer and reuse have not

been identified. Furthermore, they said that data was not readily available,

but they believed little of the uncontaminated property that was identified

had been transferred. They also said the developed land on the

installations is often the most desirable for immediate reuse, but this

property tends to be contaminated. However, DOD officials commented

that one benefit of the CERFA process has been that DOD identified the

condition of the property at these installations, and this information will

be extremely useful in leasing and later transferring contaminated

property.

DOD records showed that of about 250,100 acres at 1988 and 1991 closing

installations, the services identified about 121,200 acres as

uncontaminated; however, the regulators only concurred that 34,499 acres

Page 36 GAO/NSIAD-95-70 Military Bases
Chapter 3 

Cleanup Progress Is Limited, and

Technology and Management Improvements

Are Needed

were uncontaminated. Table 3.1 shows uncontaminated acreage at closing

1988 and 1991 installations that did receive regulatory concurrence.

Table 3.1: Summary of

Uncontaminated Property on 1988 and

1991 Closing Installations

Service Year Installation State Acreage

Air Force 1988 George Air Force Base CA 2,330

1991 England Air Force Base LA 1,191

1991 Loring Air Force Base ME 4,700

1991 Myrtle Beach Air Force Base SC 2,126

1991 Williams Air Force Base AZ 3,001

1991 Wurtsmith Air Force Base MI 2,257

Total - Air Force 15,605

Army 1988 Cameron Station VA 58

1988 Coosa River Annex AL 2,586

1988 Defense Mapping Agency -

Herndon

VA 3

1988 Fort Des Moines IA 15

1988 Fort Sheridan IL 22

1988 Hamilton Army Airfield CA 500

1988 Presidio of San Francisco CA 530

1988 Pontiac Storage Facility MI 25

1991 Fort Devens MA 1,878

1991 Fort Ord CA 13,186

1991 Sacramento Army Depot CA 51

Total - Army 18,854

Navy 1988 Naval Station New York NY 26

1991 Construction Battalion Center

Davisville

RI 7

1988 Naval Air Station Moffett Field CA 7

Total - Navy 40

Total all

installations

34,499

The regulators did not agree that many parcels were uncontaminated

because activities related to compliance—asbestos removal, lead-based

paint surveys, and resolution of issues related to petroleum—were not

completed. Also, state regulators were not willing to concur because of

concerns about the state’s potential liability. At Fort Wingate, New

Mexico, the Army identified 17,353 of 21,812 total acres as

uncontaminated, but the state regulator did not concur on any acreage.

Likewise, the Air Force identified 1,323 of 3,216 acres at Bergstrom Air

Page 37 GAO/NSIAD-95-70 Military Bases
Chapter 3 

Cleanup Progress Is Limited, and

Technology and Management Improvements

Are Needed

Force Base, Texas, as uncontaminated, but the state regulator did not

concur.

Of the 34,499 uncontaminated acres, about one-half is on property the

federal government is retaining and one-half is on property available for

transfer to nonfederal users. However, according to DOD, the

uncontaminated property is usually undeveloped, remotely located, or

linked to contaminated parcels and cannot be used separately. For

example, about 7,000 of the uncontaminated acres at Fort Ord are

considered unusable because, according to DOD officials, the acreage is in

an undeveloped part of the installation that has no access to a usable

water supply. Also, at George Air Force Base, environmental officials said

much of the property identified as uncontaminated surrounds the runways

and cannot be separated from the flightline.

Installation Cleanup Teams

in Place but Not

Empowered

The Fast Track Cleanup program concluded environmental decisions were

taking too long to make and required each installation to establish a team

consisting of EPA, DOD, and state representatives that would be empowered

to make decisions quickly. Officials at some closing installations we

visited told us they already had teams but were not empowered to make

decisions at the local level.

EPA issued draft guidance on empowerment to its installation-level team

members in March 1994, but did not mandate that it be followed.

According to EPA officials in January 1995, EPA has delegated to the regions

the necessary authority to make decisions, and the regions have

established procedures to ensure that management approval is redelegated

or provided to the installations’ cleanup teams in a timely manner. The Air

Force also issued guidance on empowerment to its installation-level team

members in April 1994. This guidance delegated some key decision-making

authority to mid-level managers, but not to the installation team members

as originally envisioned.

Various DOD and EPA officials told us that their agencies try to avoid legal

problems by reviewing and approving decisions made at the local level,

and states do the same thing. According to Navy officials, in one case, the

state representative for environmental cleanup at the Marine Corps Air

Station Tustin, California, decided in a local meeting on a particular action

because the state environmental agency had approved a similar remedy at

the Presidio of San Francisco, California. However, the state overruled the

installation representative.

Page 38 GAO/NSIAD-95-70 Military Bases
Chapter 3 

Cleanup Progress Is Limited, and

Technology and Management Improvements

Are Needed

Cleanup Plans Not Fully

Developed

DOD provided guidance and training on the development of BRAC cleanup

plans. The plans were to provide a comprehensive and consolidated

strategy for expedited environmental cleanup at all BRAC installations. DOD

stated that the cleanup plans should support the BRAC budget submission.

The cleanup plans developed to date are not of the quality described in the

guidance document. DOD officials told us, for example, that sections in

some plans were incomplete and had not been thoroughly reviewed, and

data was viewed as somewhat unreliable.

A contractor’s review of 77 BRAC cleanup plans in June 1994 identified a

lack of uniformity in the plans due to (1) different levels of progress

among installations based on the year the installation was designated for

closure, (2) short time frames for completing the plans, and (3) various

installation interpretations of guidance for the plans. At installations we

visited while cleanup plans were being compiled—Norton Air Force Base,

the Jefferson Proving Ground, and the Army Materials Technology

Laboratory—officials said that they did not have time to develop complete

plans for expediting cleanup and meet reporting deadlines, so they

reported (1) existing information in the cleanup plan format directed by

DOD or (2) the information had to be developed and would be provided

later.

DOD officials recognized that the time available for the services to develop

cleanup plans was not sufficient and now view the April 1994 plans as a

first effort. They are considering possible improvements in developing the

BRAC cleanup plans, but have not established milestones for the services to

submit more complete plans.

Community Cleanup

Advisory Boards Still Being

Formed

DOD guidance for the Fast Track Cleanup program directed the military

services to improve public involvement in the environmental cleanup

process. For each installation with property to be transferred or with

sufficient community interest, DOD requires the formation of cleanup

advisory boards comprised of members of the local community and jointly

chaired by a military service representative and a member of the

community. DOD’s guidance said these advisory boards are key to

installations being responsive to community concerns.

DOD’s goal of having fully functioning cleanup advisory boards in place

may take time. These advisory boards at closing installations are in the

early stages of development. According to the contractor’s review of 77

cleanup plans, about one-third of the installations had not yet formed

Page 39 GAO/NSIAD-95-70 Military Bases
Chapter 3 

Cleanup Progress Is Limited, and

Technology and Management Improvements

Are Needed

cleanup advisory boards. Also, at installations with boards, only about half

of the boards participated in developing the BRAC cleanup plans.

Furthermore, we reported that EPA, in a similar effort to establish advisory

boards, had not been able to earn the public’s trust due to differing

interests, even with the best intentions and community relations

outreach.11 On the basis of our observations at some of the BRAC

community advisory board meetings we attended and in discussions with

DOD officials, it appears that DOD may face similar difficulties.

Performance Measures Not

Developed for Fast Track

Cleanup

DOD officials recognized that the Fast Track Cleanup program lacked a

baseline and performance measures. As a result, they have begun

developing measures for the program, but have not set a target date for

completing this effort. As of December 1994, just two measures of

effectiveness were being considered: (1) the percentage of closing bases

with a completed environmental impact analysis and (2) the percentage of

property at closing bases that could be made available for reuse.

These measures do not seem to adequately address performance. The first

measure addresses an element that is not considered a problem. The

second measure does not precisely measure environmental cleanup

actions if leases are used. Also, these two measures do not address

program elements concerned with timely decisions being made on

installations’ cleanup, the number of installations with fully developed and

effectively implemented cleanup plans, and the extent and effectiveness of

public involvement in the cleanup process.

Conclusions Most sites at closing and realigning installations are in the early stages of

the cleanup process. Cleanup is costly, difficult, and sometimes

impossible, and technology does not exist or has serious limitations when

it comes to cleaning up massive amounts of contaminated groundwater,

large landfills, or extensive areas with unexploded ordnance. Furthermore,

new technology will take time to develop.

The Fast Track Cleanup program is being implemented and has helped the

cleanup process, but some elements of the program need further

development. For example, CERFA has not produced the expected results.

Expectations that installation cleanup teams could be empowered to make

11Superfund: EPA’s Community Relations Efforts Could Be More Effective (GAO/RCED-94-156,

Apr. 8, 1994).

Page 40 GAO/NSIAD-95-70 Military Bases
Chapter 3 

Cleanup Progress Is Limited, and

Technology and Management Improvements

Are Needed

decisions were probably unrealistic, as was the deadline for installations

to develop base cleanup plans. There is a need to establish standards that

will allow DOD to assess the various measures taken to speed up the

cleanup process.

Recommendation We recommend that the Secretary of Defense establish Fast Track

Cleanup program standards that will allow DOD to assess the steps taken to

accelerate the cleanup process at BRAC installations.

Page 41 GAO/NSIAD-95-70 Military Bases
Appendix I 

Comprehensive Environmental Response,

Compensation, and Liability Act Process

Preliminary

Assessment

The initial stage of the cleanup program is an installationwide study to

determine if sites are present that pose hazards to public health or the

environment. Available information is collected on the source, nature,

extent, and magnitude of actual and potential hazardous substance

releases at sites on the installation.

Site Inspection The next step consists of sampling and analysis to determine the existence

of actual site contamination. Information gathered is used to evaluate the

site and determine the response action needed. Uncontaminated sites do

not proceed to later stages of the process.

Remedial

Investigation

Remedial investigation may include a variety of site investigative,

sampling, and analytical activities to determine the nature, extent, and

significance of the contamination. The focus of the evaluation is

determining the risk to the general population posed by the contamination.

Feasibility Study Concurrent with the remedial investigations, feasibility studies are

conducted to evaluate remedial action alternatives for the site to

determine which would provide the protection required.

Remedial Design Detailed design plans for the remedial action alternative chosen are

prepared.

Remedial Action The chosen remedial alternative is implemented.

Interim Remedial

Action

Remedial actions can be taken at any time during the cleanup process to

protect public health or to control contaminant releases to the

environment.

Remedy in Place and

Functioning as

Intended

The remedial action is functioning properly and performing as designed.

These include such actions as the operation of pump-and-treat systems

that will take decades to complete cleanup.

Page 42 GAO/NSIAD-95-70 Military Bases
Appendix II 

Locations and Organizations Visited

Air Force Air Force Center For Environmental Excellence,

 Brooks Air Force Base, Texas

George Air Force Base, California

Loring Air Force Base, Maine

Mather Air Force Base, California

Norton Air Force Base, California

Pease Air Force Base, New Hampshire

Army Army Corps Of Engineers, Sacramento District, California

Army Materials Technology Laboratory, Massachusetts

Fort Ord, California

Jefferson Proving Ground, Indiana

Navy Marine Corps Air Station, El Toro, California

Marine Corps Air Station, Tustin, California

Naval Facilities Engineering Command, San Diego, California

Naval Air Station, Chase Field, Texas

Naval Complex, Philadelphia, Pennsylvania

Environmental

Protection Agency

Region IX, San Francisco California

Page 43 GAO/NSIAD-95-70 Military Bases
Appendix III 

NPL Status and Summary of Contaminants

as Reported in 79 BRAC Cleanup Plans

Types of problems

BRAC cleanup plans State NPL Groundwater Landfills UXOa

Air Force bases

Chanute IL 1

George CA 1 1 1 1

Mather CA 1 1 1

Norton CA 1 1 1

Pease NH 1 1 1

Bergstrom TX 1

Carswell TX 1 1

Castle CA 1 1 1 1

Eaker AR 1 1 1

England LA 1 1

Grissom IN 1 1 1

Loring ME 1 1 1

Lowry CO 1 1

Myrtle Beach SC 1 1 1

Richards-Gebaur MO 1

Rickenbacker Air National

Guard Base

OH 1

Williams AZ 1 1 1 1

Wurtsmith MI 1 1

Gentile Air Force Station OH 1 1 1

Griffiss NY 1 1 1

Homestead FL 1 1 1

K.I. Sawyer MI 1 1

McDill FL 1 1 1

March CA 1 1 1 1

Newark OH 1 1

Plattsburgh NY 1 1 1 1

Subtotal 26 11 20 26 12

Army installations

Cameron Station VA 1 1

Fort Meade MD 1 1 1

Fort Sheridan IL 1 1

Fort Wingate Depot Activity NM 1 1

Hamilton Army Airfield CA 1 1

Jefferson Proving Ground IN 1 1

Lexington Blue Grass Depot KY 1 1

(continued)

Page 44 GAO/NSIAD-95-70 Military Bases
Appendix III 

NPL Status and Summary of Contaminants

as Reported in 79 BRAC Cleanup Plans

Types of problems

BRAC cleanup plans State NPL Groundwater Landfills UXOa

Presidio of San Francisco CA 1

Pueblo Depot Activity CO 1 1 1

Umatilla Depot Activity OR 1 1 1 1

Army Materials Technology

Laboratory

MA 1 1

Fort Benjamin Harrison IN 1 1

Fort Devens MA 1 1 1

Fort Ord CA 1 1 1 1

Sacramento Army Depot CA 1 1

Woodbridge Research Facility VA 1 1

Charles Wood and Evans

Area, Fort Monmouth

NJ 1

Tooele Depot UT 1 1

Vint Hill Farms Station VA 1

Subtotal 19 6 12 16 8

Navy installations

Salton Sea Test Base CA 1 1

Naval Station New York and

Brooklyn Naval Station

NY

Naval Air Station Treasure

Island (Hunters Point Annex)

CA 1 1 1

Naval Construction Battalion

Center, Davisville

RI 1 1 1

Marine Corps Air Station, Tustin CA 1 1

Naval Air Station Moffett Field CA 1 1 1

Naval Auxiliary Landing Field,

Crows Landing

CA 1 1

Naval Air Warfare Center,

Aircraft Division, Warminster

PA 1 1

Naval Station Puget Sound,

Seattle

WA 1

Philadelphia Naval Complex PA 1 1

Naval Station, Naval Hospital

and Associated Housing, Long

Beach

CA 1 1

Naval Station Treasure Island CA 1 1

Libertyville Training Site,

Vernon Hills

IL 1 1

Marine Corps Air Station, El

Toro

CA 1 1 1

Naval Air Station, Agana Guam 1 1

(continued)

Page 45 GAO/NSIAD-95-70 Military Bases
Appendix III 

NPL Status and Summary of Contaminants

as Reported in 79 BRAC Cleanup Plans

Types of problems

BRAC cleanup plans State NPL Groundwater Landfills UXOa

Naval Air Station, Alameda CA 1

Naval Air Station, Barbers Point HI 1 1 1

Naval Air Station, Cecil Field FL 1 1

Naval Air Station, Dallas TX 1

Naval Air Station, Glenview IL 1 1

Naval Air Station, Memphis TN 1 1

Naval Air Facility, Midway

Island

1 1

Naval Air Warfare Center,

Aircraft Division, Trenton

NJ

Naval Civil Engineering

Laboratory, Port Hueneme

CA

Naval Complex, Charleston SC 1

Naval Medical Center, Oakland CA

Naval Reserve Center, Pacific

Grove

CA

Naval Reserve Center,

Staunton

VA

Naval Shipyard, Mare Island CA 1 1 1

Naval Station, Mobile AL

Naval Training Center, San

Diego

CA 1 1

Naval Radio Transmitting

Facility, Driver

VA 1 1

Department of Defense

Housing Facility, Novato

CA

Naval Training Center, Orlando FL 1

Subtotal 34 4 19 25 5

Total 79 21 51 67 25

aUnexploded ordnance.

Page 46 GAO/NSIAD-95-70 Military Bases
Appendix IV 

BRAC Cleanup Plan Cost Estimates Beyond

the 6-Year Closure Period for 14 BRAC 1988

Installations

Dollars in millions

Service Installation State

Cost estimate

for 1996 to 1999

Air Force Chanute Air Force Base IL $23,800

George Air Force Base CA 7,600

Mather Air Force Base CA 10,000

Norton Air Force Base CA 27,400

Pease Air Force Base NH 13,000

Total - Air Force $81,800

Army Cameron Station VA 200

Fort Meade MD 830

Fort Wingate NM 8,900

Jefferson Proving Ground IN 216,100

Presidio CA 40,000

Pueblo Depot CO 78,140

Umatilla Depot OR 9,710

Total - Army $353,880

Navy Salton Sea Test Base CA 96,540

Naval Station New York NY 3,378

Total - Navy $99,918

Total - all services $535,598

Source: BRAC cleanup plans

Page 47 GAO/NSIAD-95-70 Military Bases
Appendix V 

Major Contributors to This Report

National Security and

International Affairs

Division, Washington,

D.C.

David R. Warren, Associate Director

John J. Klotz, Assistant Director

Los Angeles Regional

Office

Lionel C. Cooper, Evaluator-in-Charge

Thaddeus S. Rytel, Jr., Senior Evaluator

Gary W. Kunkle, Senior Evaluator

Nancy A. Merlino, Evaluator

Dallas Regional Office Charnel F. Harlow, Regional Assignment Manager

John D. Strong, Evaluator

Office of General

Counsel

Mark C. Speight, Attorney-Adviser

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