United States General Accounting Office

GAO Report to the Chairman, Subcommittee

on National Security, International

Affairs, and Criminal Justice, Committee

on Government Reform and Oversight,

House of Representatives

September 1996 MILITARY BASE

CLOSURES

Reducing High Costs of

Environmental

Cleanup Requires

Difficult Choices

G O A

years

1921 - 1996

GAO/NSIAD-96-172

GAO United States

General Accounting Office

Washington, D.C. 20548

National Security and

International Affairs Division

B-272218 

September 5, 1996

The Honorable William H. Zeliff, Jr.

Chairman, Subcommittee on National Security,

 International Affairs, and Criminal Justice

Committee on Government Reform

 and Oversight

House of Representatives

Dear Mr. Chairman:

As requested, we reviewed the cost of the Department of Defense’s (DOD)

environmental cleanup efforts at bases being closed under the base

realignment and closure (BRAC) process.1

 Specifically, this report

addresses the (1) cost of cleanup efforts, (2) reasons that cleanups are so

costly, and (3) potential opportunities for reducing costs and their impact

on programmatic goals.

Background After the Cold War, DOD’s base structure was larger than required to meet

changing national security needs. Consequently, the Congress enacted two

separate laws that instituted base closure rounds in 1988, 1991, 1993, and

1995.2

 Through these four BRAC rounds, DOD has closed or scheduled to

close 311 bases, installations, and activities and realigned or planned to

realign an additional 112 bases. Table 1 shows the number of closures and

realignments for each BRAC round.

Table 1: Closures and Realignments

by BRAC Round BRAC round Closures Realignments

1988 89 10

1991 35 39

1993 119 38

1995 68 25

Total 311 112

Source: Defense Base Closure and Realignment Commission.

1

Environmental cleanup in this report refers broadly to both compliance and restoration efforts.

Typically, compliance refers to work required to ensure current operations comply with environmental

laws and regulations, and restoration refers to work involving the cleanup of contamination caused by

past disposal practices.

2

Defense Authorization Amendments and Base Closure and Realignment Act of 1988 (P.L. 100-526) and

Defense Base Closure and Realignment Act of 1990 (P.L. 101-510, title XXIX, part A).

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As a result of military base downsizing, DOD has had to phase down base

operations, expedite the sale or transfer of unneeded base property for

future reuse, properly account for cost and savings attributable to base

closures, and perform environmental cleanup of contaminated property no

longer needed. Because of congressional interest in the impact of base

closures on DOD and affected states and communities, we have issued

several reports on these issues. In August 1996, we reported on the status

of bases closed during the BRAC 1988, 1991, and 1993 rounds.3

 In

February 1995, we reported on the environmental impact at DOD closing

bases.4

 In November 1994 and August 1995, we reported on property reuse

issues arising from the BRAC 1988 and 1991 rounds.5

 In March 1993 and

April 1996, we reported on BRAC cost and savings issues.6

The severity of contamination at a large number of BRAC bases has turned

environmental cleanup into a major challenge for DOD. Before BRAC, DOD

had begun addressing environmental contamination at its active military

bases through ongoing compliance and restoration programs. Types of

hazardous waste found at military installations include solvents and

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

and chromium; and unique military substances, such as nerve agents and

unexploded ordnance.7

 Contamination has usually resulted from storage

and disposal practices that were accepted at the time but which have

proved damaging to the environment.

Cleanup issues faced at closing bases are similar to those at active bases.

Base closures have underscored the importance and urgency of

environmental cleanup. Because cleanup is, in most instances, a

prerequisite for the title transfer of BRAC property to nonfederal parties,

DOD must begin to address environmental issues early in the closure

process to expedite property transfer. In doing so, DOD must comply with

existing federal and state laws and regulations. Two federal environmental

3

Military Bases: Update on Status of Bases Closed in 1988, 1991, and 1993 (GAO/NSIAD-96-149, Aug. 6,

1996).

4

Military Bases: Environmental Impact at Closing Installations (GAO/NSIAD-95-70, Feb. 23, 1995).

5

Military Bases: Reuse Plans for Selected Bases Closed in 1988 and 1991 (GAO/NSIAD-95-3, Nov. 1,

1994) and Military Bases: Case Studies on Selected Bases Closed in 1988 and 1991 (GAO/NSIAD-95-139,

Aug. 15, 1995).

6

Military Bases: Revised Cost and Saving Estimates for 1988 and 1991 Closures and Realignments

(GAO/NSIAD-93-161, Mar. 31, 1993) and Military Bases: Closure and Realignment Savings Are

Significant, but Not Easily Quantified (GAO/NSIAD-96-67, Apr. 8, 1996).

7

Ordnance that remains unexploded either through malfunction or design is capable of causing injury

to personnel or damage to material. Types of unexploded ordnance include bombs, missiles, rockets,

artillery rounds, ammunition, or mines.

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statutes—the Comprehensive Environmental Response, Compensation,

and Liability Act (CERCLA) and the Resource Conservation and Recovery

Act (RCRA)—and state laws and regulations govern most of the

environmental compliance and restoration activities at closing bases. In

general, CERCLA governs the cleanup of inactive waste sites, and RCRA

regulates the management of facilities that treat, store, and dispose of

hazardous wastes. Appendix I summarizes selected federal and state laws

and regulations pertinent to BRAC environmental cleanup.

The Congress established separate BRAC funding accounts to help ensure

that DOD could devote high-priority attention to base closure and property

transfer. Although the Congress appropriates overall funding for BRAC

based on DOD budget requests and not directly for environmental cleanup

purposes, it may specify either maximum (ceiling) or minimum (floor)

dollar amounts to be used for environmental efforts in any given budget

year.8 DOD uses overall BRAC appropriations to allocate funds to the

services based on requirements in each of several BRAC subaccounts,

including the environmental subaccount. This subaccount includes

multiyear funding for each of the BRAC rounds, thereby allowing the

services greater flexibility in executing the environmental cleanup

program. Further, with a floor, unneeded funds from other BRAC

subaccounts may be transferred into the environmental subaccount

throughout the year. With a ceiling, environmental funding can be shifted

into other subaccounts. We review BRAC budget account issues on an

annual basis; we issued our latest report in July 1996 on the validity of

DOD’s fiscal year 1997 BRAC budget submission.9

Results in Brief As of March 1996, DOD had allocated about $3.4 billion for the BRAC

environmental cleanup program. However, as more bases are closed and

more cleanup actions are underway, program costs are likely to increase

significantly. Although DOD has not computed a total cost estimate for the

program, available DOD financial data indicate that program costs are likely

to exceed $11 billion.

8

Before fiscal year 1996, legislation established a floor for the environmental subaccount that required

DOD to spend at least the amount requested in the BRAC budget submission for environmental costs.

Consequently, the specified minimum amount could not be shifted to other subaccounts. In fiscal year

1996, however, legislation established a ceiling for the environmental subaccount that prohibited DOD

from spending more than the amount requested in the BRAC budget justification for environmental

costs. The Secretary of Defense must notify the appropriations committees if more spending on

environmental activities is found to be necessary.

9

Military Bases: Potential Reductions to the Fiscal Year 1997 Base Closure Budget (GAO/NSIAD-96-158,

July 15, 1996).

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The key reasons for the high cost of closing base cleanups include (1) the

large number of contaminated sites and difficulties associated with types

of contamination, (2) requirements of federal and state laws and

regulations, (3) lack of cost-effective cleanup technology for certain

contaminants, and (4) intended property reuse. DOD has identified over

5,300 potentially contaminated sites at its BRAC bases. Also, the laws and

regulations DOD must abide by in expediting property transfer for reuse

have proven to be time-consuming, complex, and costly. Further,

technology limitations in cleaning property of certain contaminants (such

as unexploded ordnance) have proved costly.

Options for reducing cleanup costs at closing bases include (1) deferring

or extending certain cleanup actions, (2) modifying existing laws and

regulations, (3) adopting more cost-effective cleanup technologies, and

(4) sharing costs with the ultimate user of the property. However, all of

these options may adversely impact programmatic goals, thereby

presenting decisionmakers with difficult choices in developing a

cost-effective environmental cleanup program. Deferring or extending

cleanup actions may delay property transfer and reuse, hurt the economic

revitalization of communities affected by the closure process, and harm

the environment and health as well. Modifying laws and regulations may

increase environmental risk, thereby increasing public resistance and

dissatisfaction. Adopting more cost-effective technologies may delay the

program because new technologies currently under development may not

be available for years and the new technologies may not be more

cost-effective than existing technologies. Sharing costs with the ultimate

user could present problems because of unknown future liabilities and

difficulty establishing the value of the property.

Environmental

Cleanup Is Costly

The cleanup of contaminated base property has been costly, and with the

majority of base cleanup work still to be done, costs will continue to grow.

Although $3.4 billion had been allocated for BRAC environmental cleanup

through March 1996, it is likely that costs will exceed $11 billion before

cleanups are completed well into the next century. In the earlier years of

the BRAC program, the Congress had expressed concern about DOD’s slow

progress in obligating funds for environmental cleanup. Our analysis

shows that in recent years DOD has greatly increased the rate at which it

has obligated funds. As of September 1995, for example, DOD had obligated

96 percent of available funds, which was substantially higher than the

50-percent rate 2 years earlier.

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Through March 1996, DOD had allocated $3.4 billion, obligated $2.8 billion,

and expended $1.6 billion on BRAC environmental cleanup. Tables 2 and 3

show these amounts by BRAC round and military component, respectively.

Table 2: Environmental Cleanup

Allocations, Obligations, and

Expenditures by BRAC Round (as of

Mar. 31, 1996) Amounts

Dollars in thousands

BRAC

round Allocated Obligated Expended

Percent of

allocations

obligated

Percent of

obligations

expended

1988 $980,119 $966,926 $600,672 98.7 62.1

1991 1,391,779 1,100,520 676,134 79.1 61.4

1993 812,677 660,775 302,997 81.3 45.9

1995 177,601 43,868 1,817 24.7 4.14

Total $3,362,176 $2,772,089 $1,581,620 82.5 57.1

Source: Our analysis of DOD data.

Table 3: Environmental Cleanup

Allocations, Obligations, and

Expenditures by Military Component

(as of Mar. 31, 1996) Amounts

Dollars in thousands

Military

component Allocated Obligated Expended

Percent of

allocations

obligated

Percent of

obligations

expended

Air Force $1,314,620 $1,033,337 $599,644 78.6 58.0

Army 956,622 781,158 451,073 81.7 57.7

Navy 1,077,520 949,167 528,214 88.1 55.7

Defense

agencies 13,414 8,427 2,689 62.8 31.2

Total $3,362,176 $2,772,089 $1,581,620 82.5 57.1

Source: Our analysis of DOD data.

Appendix II provides additional detail on allocations, obligations, and

expenditures by military component for each BRAC round.

Estimated BRAC

Environmental Program

Costs Will Be Substantial

The estimated cost for the BRAC environmental cleanup program is

uncertain but will be much higher than amounts allocated thus far. The

$3.4 billion allocation through March 1996 included only initial funding for

BRAC 1995 bases and was insufficient to complete cleanup at prior round

BRAC bases. Even though the Congress has established a 6-year period for

closing a base, there are no statutory deadlines for the cleanup process.

All indicators point to cleanups extending well into the next century. At

the time of our review, DOD did not have a total BRAC environmental

Page 5 GAO/NSIAD-96-172 Military Base Closures
B-272218 

cleanup cost but was in the process of collecting the data to make such a

projection. Our analysis showed that many base cleanups are expected to

be very costly. Available DOD data indicate, for example, that cleanup costs

for 27 closing bases will likely exceed $100 million each. Further, with the

use of available DOD financial data, we estimate that the total cost is likely

to exceed $11 billion, as shown in table 4.

Table 4: Estimated DOD BRAC

Environmental Cleanup Program Costs Dollars in millions

BRAC round

Funds allocated

through fiscal year

1995

Estimated cost to

complete cleanupsa Total

1988 $980.1 $2,139.1 $3,119.2

1991 1,066.8 1,656.5 2,723.3

1993 573.1 1,342.3 1,915.4

1995 0 3,577.4 3,577.4

Total $2,620.0 $8,715.3 $11,335.3

aThe cost includes closing base estimates for fiscal year 1996 through completion, as shown in

the Defense Environmental Restoration Program Annual Report to Congress for Fiscal Year 1995,

and estimated program management costs. Certain Navy and Air Force environmental

compliance costs are not included in the estimate.

Our total cost estimate was based on the best available data at the time of

our review, but we believe the estimate is likely to be conservative for

several reasons. First, environmental cleanup cost estimates for many of

the 1995 BRAC bases are based on projected costs developed while they

were active installations. DOD officials told us that cost estimates for these

bases would likely increase as additional environmental studies are

performed, more work is identified, and cleanup timelines are accelerated.

Second, according to DOD officials, certain Navy and Air Force

environmental compliance costs that are funded under the BRAC program

are not included in the above estimate. Finally, previous DOD estimates

were generally understated. For example, in September 1994, DOD reported

that it would cost about an additional $3.1 billion to complete base-level

environmental cleanups of its 1988, 1991, and 1993 BRAC bases. However,

in September 1995, that estimate had increased to $4.7 billion.

Obligations Have

Increased Recently, but

Significant Funding

Remains Unexpended

In recent years, DOD has significantly increased the rate at which it has

obligated environmental funds for the BRAC program. As shown in figure 1,

DOD obligated $2.5 billion, or 96 percent, of the $2.6 billion available for the

BRAC environmental program as of September 1995. In comparison, DOD

Page 6 GAO/NSIAD-96-172 Military Base Closures
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had obligated 50 percent of the funding available in September 1993. Low

obligation rates in the early years of the BRAC program raised concerns on

the part of the Congress.

Figure 1: Comparison of BRAC Environmental Cleanup Allocations, Obligations, and Expenditures (Sept. 1993 Through

Sept. 1995)

1993 1994 1995

0.0

0.5

1.0

1.5

2.0

2.5

3.0

Fiscal year

Dollars in billions

Allocated

Obligated

Expended

DOD officials offered a variety of reasons for the low obligation rate in the

early BRAC years and the high obligation rate in recent years. First, during

the early BRAC years, DOD officials acknowledged they (1) were probably

overly optimistic in the level of funds requested, (2) did not have all the

Page 7 GAO/NSIAD-96-172 Military Base Closures
B-272218 

necessary expertise to better estimate requirements and timing, and

(3) were slow in actually obligating funds through existing contract

mechanisms. Second, because BRAC funds are available for use on a

multiyear basis, there was no overriding pressure to quickly obligate

funds. Due in large part to heightened congressional interest in the issue,

however, DOD made a concerted effort to increase obligations. Further,

with the expiration of BRAC 1988 funds on September 30, 1995, DOD focused

its attention on obligating as much of the available money as possible for

remaining BRAC 1988 cleanup requirements.

Although the obligation rate has increased and the relative amount of

unobligated funds has decreased, a large unexpended balance of funds

remains. As of September 1995, BRAC environmental expenditures were

about 48 percent of obligations—a modest increase from the 34-percent

rate existing in September 1993. DOD officials told us that the large amount

of unexpended funds was typical of other environmental programs and

were relatively low because of (1) widespread service use of large

cost-reimbursable contracts for environmental work where major projects

are in the early stages and (2) the lag involved in contractor payments and

subsequent reporting in the financial system. DOD officials also told us that

the services had been able to obligate funds quicker through the use of

large cost-reimbursable contracts than through previous contracting

vehicles. However, because the contracts are often for time-consuming

studies or site cleanups, expenditures have a tendency to lag well behind

the obligated amounts.

Further, the gap between expenditures and obligations has widened, since

many projects are deferred or planned for execution in later years. As this

practice continues, there is greater uncertainty as to when and how much

of the funds will actually be spent. Charleston Naval Shipyard officials, for

example, told us they were expending funds at a slower rate than expected

because of uncertain cleanup requirements and state regulatory reviews

that were delaying many contracted site contamination surveys. In

addition, at Pease Air Force Base, BRAC officials, citing that available BRAC

1988 funds were due to expire, obligated about $8 million in

September 1995 for future environmental monitoring and operating

requirements extending into fiscal year 1998. The amount of this money

that will actually be spent will not be known for several years.

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Key Factors Drive the

High Cost of Cleanup

Our review of selected base closure sites and other analysis showed that

BRAC environmental costs are driven by several key factors. Among these

factors are (1) the large number of contaminated sites and associated

extent of contamination, (2) the requirements of federal and state

environmental laws and regulations, (3) the lack of cost-effective cleanup

technology, and (4) property reuse plans.

Identifying Full Extent of

Contamination at BRAC

Sites Is Difficult and Costly

The sheer magnitude of the BRAC program, coupled with the severe soil

and water contamination that has developed over decades of base

operations, is a key cause for the high cost of cleanup. The closing bases

have a large number of contaminated sites, and it often becomes very

difficult and costly to determine the full extent and severity of site

contamination. Further, the number of BRAC contaminated sites has grown

as more bases have been selected for closure and additional contaminated

sites have been identified. In addition, further study often reveals a

number of areas of environmental concern on the bases, thereby

increasing fund expenditures to resolve the concerns. DOD officials told us

that typically after a base is slated for closure, the likelihood increases that

additional contaminated sites will be identified as more investigative work

is performed. For example, before the closure of Pease Air Force Base, Air

Force officials had identified 18 contaminated sites; as the closure process

progressed and more investigative work was performed, the number of

sites grew to 55. Table 5 shows the number of BRAC contaminated sites and

their disposition.

Table 5: Contaminated Sites at BRAC

Closing Bases (as of Sept. 30, 1995) BRAC round Sites completeda Sites in progressb Total

1988 503 735 1,238

1991 287 1,044 1,331

1993 110 796 906

1995 552 1,310 1,862

Total 1,452 3,885 5,337

aThese sites have either been cleaned or do not need any further action.

bThese sites are either awaiting cleanup funding or have some ongoing work.

Source: DOD.

DOD officials told us that the extent of site contamination is often difficult,

time-consuming, and costly to detect and may not be fully determined

until environmental cleanup is actually underway. At Pease Air Force Base

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landfill sites, for example, it was not known whether contaminants existed

below the water table level until excavation was underway. Also,

according to Army officials, the Army spent over $45 million—$20 million

more than originally estimated—for radioactive contamination cleanup at

the Army Material Technology Laboratory in Massachusetts. The cost

underestimation was due largely to difficulties in accurately determining

the extent of the contamination caused by the reactor.

Unexploded ordnance is another concern for many closing bases. At Mare

Island Naval Shipyard, for example, potential unexploded ordnance sites,

which include dredge ponds and the waterfront, are the result of decades

of ordnance manufacturing, storage, and disposal. Navy engineers

estimate that cleaning up these sites could cost about $60 million.

Environmental Laws and

Regulations Contribute to

High Costs

The requirements of federal and state environmental laws and regulations

have a significant impact on the cost of environmental cleanup. Under the

existing environmental legal framework, DOD must comply with cleanup

standards and processes associated with existing laws, regulations, and

executive orders in conducting assessments and cleanups of its base

closure property. Although CERCLA and RCRA are two of the primary drivers

for the BRAC environmental program and the ones that impact most closing

bases, other laws or executive orders, such as the Endangered Species Act

or Executive Order 11990 (Protection of Wetlands), are directed to more

unique areas of concern that may exist at a BRAC base. At Pease Air Force

Base, for example, BRAC officials had to consider threatened and

endangered species, sensitive habitats, wetlands, and historic sites in their

cleanup plans. In response to the requirements to protect wetlands, these

officials were creating a 2.5-acre wetlands parcel at a cost of about

$100,000 to replace wetlands destroyed during cleanup at another site.

Further, environmental laws and regulations vary by state and often have

more stringent requirements that tend to increase cost. For example,

California’s standard for clean drinking water is 10 times more stringent

than the federal standard, thereby increasing cleanup costs when this

standard is applied.

BRAC officials told us that the current assessment and cleanup process, as

dictated by legal requirements, was complex, costly, and time-consuming.

This description is consistent with our findings in our review of

high-priority site cleanup efforts at active bases.10 For example, under

10Environmental Cleanup: Too Many High Priority Sites Impede DOD’s Program (GAO/NSIAD-94-133,

Apr. 21, 1994).

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CERCLA, DOD follows a detailed four-phase process—preliminary

assessment, site inspection, remedial investigation/feasibility study, and

remedial design/remedial action—in cleaning up property for transfer.

Embodied in the process are extensive requirements for documentation,

studies, and the need to interact frequently with Environmental Protection

Agency (EPA) and state officials and the public. BRAC officials told us that

cleanups could require sustained action over many years—10 years in

many cases—to achieve targeted goals. Site studies can take 4 or more

years to complete, remedial designs may require 3 years, and cleanup may

take another 3 years. Delays are frequent as federal and state regulators

review and approve documents.

An inherent part of the process that has undergone criticism is the amount

of time and money devoted to base contamination studies. Our prior work

on environmental issues, for example, showed that DOD has spent large

amounts of money on studies but that actual cleanup progress has been

slow.11 We recognize that the cleanup process is driven largely by

regulation and involves time-intensive steps. Therefore, many of the BRAC

sites have not reached the actual cleanup stage while several sites have

been closed out as a result of study. The Congress has expressed concern

and directed DOD to establish a goal to limit, by the end of fiscal year 1997,

spending for administration, support, studies, and investigations to 

20 percent of the funding for its active base program.12 No such restriction

has been enacted for the BRAC program. Although DOD does not have

readily available data that show overall funding devoted to studies at BRAC

bases, officials have stated that the amount has been substantial. However,

DOD now states that more funding is being devoted to actual cleanups,

particularly for earlier round BRAC bases. Our review of the six bases we

visited indicated considerable amounts of money are being expended on

studies. Pease Air Force Base officials estimated, for example, that about

one-half of the $140 million they expected to spend would be for studies.

Available Cleanup

Technology Is Not Always

Cost-Effective

The technology used to clean contaminated property can be a key cost

factor. In many cases, a cost-effective cleanup technology may not be

available. Cleaning up unexploded ordnance, for example, may be not be

practical or affordable, especially when there are large parcels of property.

Removal work can involve burning and clearing thousands of acres to

11Environmental Cleanup: Too Many High Priority Sites Impede DOD’s Program (GAO/NSIAD-94-133,

Apr. 21, 1994).

12This goal was set forth in the National Defense Authorization Act for Fiscal Year 1996 (P.L. 104-106,

Sec. 323).

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apply existing cleanup techniques, which are labor-intensive, dangerous,

time-consuming, and costly. For example, preliminary estimates by the

Army Corps of Engineers indicate that cleaning up unexploded ordnance

at Fort Ord may cost over $200 million. Most of the cost would be

attributable to an 8,000-acre impact range.

“Pump and treat” systems, which are shown in figure 2 and commonly

used to treat groundwater contamination, can also cost millions and,

depending on site conditions, be only marginally effective in some cases.

Further, such systems may need to operate for decades after the base has

closed and the property has been transferred. As this occurs, DOD

continues to incur costs for operating and maintaining the system as well

as monitoring water quality results. At Norton Air Force Base, for

example, the Air Force spent over $10 million between 1980 and 1992 to

investigate contamination of a groundwater plume that extends beyond

the base boundary and threatens water supplies in a nearby community. A

small-scale pump and treat system was initially installed in 1989; beginning

in 1991, a larger-scale pilot system was constructed and subsequently

upgraded in 1995. Further, in March 1993, the Air Force contracted for a

$5.5-million pump and treat system to be located near the base boundary,

and in August 1994, it increased the funding by $1.6 million. Even though

the project was costly, its effectiveness was not certain, and Air Force

officials agreed to modify the system to treat the off-base water or

reimburse the community if the remediation action was not effective.

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Figure 2: Pump and Treat System at

Pease Air Force Base

Property Reuse Plans

Impact Costs

Intended property reuse can also increase the costs associated with

cleaning up contaminated property. In particular, reuse plans are a major

determinant most often in the cleanup standard levels (e.g., residential or

industrial) used as criteria in cleanup plans. Cleanup of a site that will be

transferred to the Department of Interior for nonpublic use, for example,

will typically not be as thorough or costly as a site that will be used for

residential purposes.

We noted several cases in which reuse or public concern associated with

reuse has, or could, impact costs. For example, the Air Force has been

conducting site investigations since 1982 in search of radioactive wastes in

soils and groundwater on or near Norton Air Force Base. In fiscal year

1995, it obligated $2.7 million, and in May 1996 was planning to obligate an

additional $185,000. The Air Force cited high community interest, scrutiny,

and review as significant in its search for the waste. At Lowry Air Force

Base, a change the community has proposed for the 77-acre landfill site

could cost the Air Force an additional $1 million to $5 million for cleanup.

The Air Force had originally planned for limited use (e.g., nature trails) at

the site; however, in March 1996, the redevelopment authority identified

alternative uses for the property, such as a golf course and facility to be

used along with the adjacent existing golf course or polo and soccer fields.

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Air Force officials told us they were studying these alternatives because

they would require more extensive and costlier remediation actions.

Opportunities for

Reducing Cleanup

Costs and Their

Impact on

Programmatic Goals

Potential options exist for reducing the cost of cleanup. We are not taking

a position on these options because of policy and legislative implications

associated with them. Rather, we are presenting them in the context of

tradeoffs they represent so that congressional and defense decisionmakers

have the information for their consideration as they explore ways to

reduce program costs while achieving environmental cleanup goals. The

options we analyzed are (1) deferring or extending certain cleanup

actions, (2) modifying existing laws and regulations, (3) adopting more

cost-effective cleanup technologies, and (4) sharing costs with transferees.

Deferring or Extending

Cleanup Actions

Deferring or extending certain cleanup actions for those sites where there

is no immediate danger to human health or the environment has the

potential for reducing environmental costs at closing bases. Under current

policy, DOD is advocating an expedited approach to BRAC cleanups in the

interest of making property quickly available to communities and others

for reuse. Because of the higher priority given to cleanups, DOD officials

told us that preclosure cleanup schedules are typically accelerated after a

base is slated for closure. However, although accelerating cleanup may

offer faster transfer possibilities, it may also cause program cost increases,

according to DOD officials. For example, McClellan Air Force Base officials

estimate that their cleanup efforts, originally targeted to cost between

$705 million and $925 million through fiscal year 2034, could cost

$1.2 billion to $1.8 billion under an accelerated program ending in fiscal

year 2018. The officials said longer time frames allow for more

cost-effective sequencing of the cleanup work and the use of new

technologies that become available.

Deferring or extending cleanup within acceptable bounds of risk may

decrease costs but not without programmatic tradeoffs and cost risks. It

would delay transfer of property to users and be contrary to the spirit of

the President’s base closure community reinvestment program, announced

in July 1993, for the economic recovery of those communities affected by

the closure process. Delaying cleanup could promote significant

community dissatisfaction and delay reuse—even for clean parcels that

may be adjacent to contaminated property.

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It must be recognized that, on a case-by-case basis, deferring or extending

cleanups may increase costs. Because DOD may be required to retain

unneeded property for a longer period of time, it may incur added

caretaker costs. However, according to DOD officials, the caretaker costs

would be relatively minor in comparison to the cleanup cost. Further,

environmental costs may increase if contamination spreads or is not

otherwise contained while cleanup is deferred.

Deferring or delaying cleanup at certain sites requires that a priority

system be in place to provide decisionmakers with a means to determine

the sequence in which projects are funded. The order in which sites are

cleaned can impact the overall cost of environmental cleanup. DOD has

stated that its highest priorities for BRAC environmental cleanup are for

those sites that pose an immediate danger to human health or the

environment or are needed for prompt reuse. With regard to protecting

health and the environment, in September 1994, DOD issued guidance for a

prioritization framework, referred to as Relative Risk Site Evaluation, that

categorizes contaminated sites into high-, medium-, and low-relative risk

groups. Relative risk is based on an evaluation of contaminants, hazards,

pathways, and receptors in groundwater, surface water, sediment, and

surface soils. Even though relative risk categorizations are important,

service officials said that relative risk is one of many factors they consider

in prioritizing funding at BRAC bases. Other considerations include reuse

plans; cultural, social, and economic factors; and statutory requirements

and legal agreements. These officials said that, with the exception of

immediate health and safety threats, reuse plans are often the most

important factor for funding and that some sites with lower environmental

risk are funded in the interest of reuse.

Although most interested parties we spoke to endorsed the need for

setting priorities, many had concerns about DOD’s current efforts. For

example, EPA officials were concerned about the (1) lack of objectivity in

DOD’s relative risk model, (2) large number of sites not included in the

evaluation, and (3) lack of regulatory involvement in the development of

the criteria. State environmental representatives were also concerned that

a large number of sites, some of which may be high priority, had not been

evaluated. One state official indicated many states had already established

cleanup priorities that may differ from DOD’s because of differences in risk

evaluations. DOD officials told us that the use of Restoration Advisory

Boards, as advisors in the prioritization process, have had strong input in

community-based decisions, taking into account risk and other factors. We

did not evaluate the effectiveness of these efforts.

Page 15 GAO/NSIAD-96-172 Military Base Closures
B-272218 

Modifying Existing Laws

and Regulations

Modifying laws and regulations that must be considered when performing

environmental cleanup at closing bases could ease the severity of

requirements and help reduce costs. However, the benefits of modifying

certain aspects of existing laws and regulations may not be achieved

without tradeoffs. For example, easing cleanup standards and associated

requirements may increase environmental risk and create unacceptable

danger to human health and the environment, thereby increasing public

resistance and dissatisfaction.

DOD has supported a number of proposed legislative and administrative

changes that would reduce the cost of environmental cleanup and

expedite the closure process. Many of these have been debated by the

Congress in the past and are still under consideration. In this regard, DOD

supports efforts to improve the remedy selection process by using realistic

site-based risk assumptions and foreseeable future land uses in the

decision-making process. According to Navy environmental officials,

emphasizing site-based risk assumptions over specific cleanup standards

has the potential for reducing costs. Further, DOD supports wider use of

generic or presumptive remedies in certain cases to reduce lengthy study

time and cost. DOD also supports legislative revision as to what constitutes

an uncontaminated parcel and further clarification that such parcels be

excluded from placement on the National Priorities List.13 This revision

would reduce cost and allow more expedited transfer of uncontaminated

property. EPA has indicated its support for many of DOD’s proposals, but

state officials and private representatives we talked to were more

skeptical.

Changing regulatory requirements can have a significant impact on costs,

as illustrated by recent changes being recommended in California’s

approach to remediating contamination resulting from leaking

underground fuel storage tanks. In late 1995, a report by the Department of

Energy’s Lawrence Livermore National Laboratory, California, concluded

that, where soil conditions were favorable, natural processes, rather than

other cleanup actions, could be relied on to clean up petroleum

contaminants left by leaking underground fuel storage tanks. The report

estimated that traditional cleanup costs had been averaging $150,000,

thereby prompting state water control board officials to recommend the

use of natural processes for cleanup of those sites where contamination

was deemed to be of low risk.

13The National Priorities List is EPA’s list of highest priorities for further study and cleanup.

Page 16 GAO/NSIAD-96-172 Military Base Closures
B-272218 

If these same procedures were used at DOD facilities where favorable soil

conditions existed, costs could be reduced. At Norton Air Force Base, the

Air Force has spent about $5 million to remediate about 20,000 cubic yards

of contaminated soil at former underground storage tank sites. Air Force

officials estimate that about 20 percent of the cleanup may not have been

needed and could have been left to natural processes. At Pease Air Force

Base, officials estimated that about $2.5 million was spent to clean up fuel

contaminated soils around 10 pumphouses. Figures 3 and 4 show

underground tank removal operations at Pease Air Force Base. At Mare

Island Naval Shipyard, Navy officials estimate that about 50 underground

storage tanks and about 42,000 feet of abandoned underground fuel lines

require cleanup at an estimated cost of $26.9 million. Under the new policy

for underground storage tank cleanups, this estimate may be reduced to

$13.5 million. However, Air Force and Navy officials noted that the new

policy is not statewide at this point and is being adopted only in certain

regions of the state.

Figure 3: Underground Fuel Storage

Tanks at Pease Air Force Base

Page 17 GAO/NSIAD-96-172 Military Base Closures
B-272218 

Figure 4: Underground Fuel Storage

Tank Removal at Pease Air Force Base

In another example, bases were once required, before the issuance of EPA

guidance in September 1993, to develop cleanup plans for certain

groundwater problems, even though the proper technology was not

available. However, EPA guidance now recognizes that some groundwater

cleanups are technically not possible. According to Air Force BRAC

officials, the Air Force was thus permitted to cease further consideration

of several remedial actions proposed for one site contaminated by a waste

solvent that could not be removed with known technology. The officials

said this change saved between $2.3 million and $7 million, depending on

which remedial action alternative would have been selected.

Developing and Using

More Cost-Effective

Technology

New and more cost-effective technology may offer cost reduction

potential for cleaning up groundwater, unexploded ordnance, and other

contaminants. The Congressional Budget Office has reported that (1) DOD

could reduce costs by delaying expensive remediation projects when

contamination posed no imminent threat and cost-effective technology

was lacking and (2) in the long run, new cleanup technologies represented

the best hope of addressing environmental problems with available DOD

Page 18 GAO/NSIAD-96-172 Military Base Closures
B-272218 

funds.14 The replacement of many of the current remediation technologies

with more cost-effective methods of environmental cleanup could have a

significant effect on reducing the cost of cleanup.

However, although new technologies may offer significant cost reduction

potential, there are programmatic tradeoffs or risks involved with awaiting

for the emergence of more cost-effective technology. First, because many

BRAC bases are being cleaned up under accelerated schedules, many new

technologies now under development may not be available for widespread

use for years after the technology is needed. Awaiting for new technology

would thus delay program progress. Second, newer technology may not be

more cost-effective than existing technology. Third, the outlook for DOD

research and development funding of new technology may not be as

optimistic as in previous years, as DOD’s budget has been drastically

reduced for this activity in the last 2 fiscal years. Last, contractors and

regulators who have become comfortable with certain cleanup methods

may be reluctant to adopt new technologies and unwilling to risk using an

unfamiliar cleanup technology.

Our discussions with interested parties showed a wide range of views on

environmental technology issues. The likelihood that entirely new

technologies will quickly and inexpensively solve major contamination site

problems is slim, according to Air Force and Navy environmental program

managers. They said more gains could be made by improving and refining

cleanup standards and existing technologies. Army officials told us that,

with the exception of unexploded ordnance, they had the technology

needed for addressing most contamination at their BRAC bases. EPA officials

told us that new technology could reduce the costs of cleanup and that

deferring cleanup until new technology becomes available might be an

option in certain situations. One state regulator said that new technology

was needed for many contaminants because no cost-effective treatment

was available and some prevalent problems were not being addressed.

Another state official said that, except for unexploded ordnance and

groundwater contamination, the services had the necessary technology

and should not delay cleanups.

Sharing Costs With

Transferees

Allowing the receiving party, or transferee, to pay fully or in part for

environmental cleanup would reduce DOD’s costs, but there are several

14Statement for the Joint Hearing on the Defense Environmental Program before the House National

Security Committee (Mar. 24, 1995) and Statement on Environmental Cleanup Programs in the

Departments of Defense and Energy before the Subcommittees on Military Procurement and Military

Readiness, House Committee on National Security (Mar. 21, 1996).

Page 19 GAO/NSIAD-96-172 Military Base Closures
B-272218 

barriers to achieving cost reduction in this manner. Existing legislation to

encourage sharing costs has not been effective, in part, because of

unknown future liabilities and difficulty establishing the value of the

property. According to DOD officials, communities have not expressed an

interest in assuming the cost of cleanup to receive property more quickly

because there is apparently little incentive to do so.

Current legislation allows DOD to transfer property without cleaning it up,

provided that the recipient agrees to do so. Specifically, section 2908 of

the National Defense Authorization Act for Fiscal Year 1994 

(P.L. 103-160) authorizes DOD to enter into an agreement to transfer by

deed real property or facilities with any person who agrees to perform all

environmental restoration, waste management, and all environmental

compliance activities that are required under federal and state laws,

administrative decisions, agreements, and concurrences. However, this

transfer may be made only if DOD certifies to the Congress that cleanup

costs are equal to or greater than the fair market value of the property or

facilities. If, however, the cleanup costs are lower, the recipient must pay

the difference between the fair market value and such costs. Although less

revenue would be received from the property transfer, DOD would not

incur the cost of cleanup.

Officials we talked to were unaware of any instances in which property

had been transferred under the above provision. They cited a number of

reasons for this situation, including (1) difficulty in determining the fair

market value of property to be transferred, (2) little incentive for investors

to assume the risks of unknown liabilities, and (3) stipulations that the

transferee gives up the right for future indemnification if further

contamination is found.

Agency Comments

and Our Evaluation

We requested written comments on a draft of this report from DOD, but

none were received. However, officials from the Office of the Deputy

Under Secretary of Defense (Environmental Security), Under Secretary of

Defense (Comptroller), and the Navy provided us with oral comments.

DOD concurred with the findings and the general tone of the report. The

officials, however, offered a number of technical clarifications to improve

the accuracy of the report. We considered their comments and have made

changes as necessary in the appropriate sections of this report. For

example, DOD commented that our use of specific environmental

Page 20 GAO/NSIAD-96-172 Military Base Closures
B-272218 

terminology was inconsistent throughout the report. We agree and have

clarified our use of the terms.

Scope and

Methodology

To determine the amount of money devoted to the BRAC environmental

program, we interviewed DOD and military service comptroller officials and

reviewed documentation that tracked BRAC financial information. We

analyzed data to determine the relative growth over time in the amounts of

money allocated, obligated, and expended for cleanup efforts. We inquired

as to the rationale underlying financial growth trends. To determine the

estimated total cost for the BRAC environmental program, we aggregated

(1) actual DOD fund allocations through fiscal year 1995 for all BRAC rounds,

(2) estimated base program completion costs reported in the Defense

Environmental Restoration Program Annual Report to Congress for Fiscal

Year 1995, and (3) estimated program management costs through

completion.

To find out how funds are being used and gain insight as to why cleanup

efforts are so costly, we visited six closing bases, interviewed DOD

headquarters and base-level BRAC officials, discussed cleanup actions with

selected state and community representatives, reviewed base cleanup

documentation, and observed site cleanup actions underway. Our

base-level visits were intended to get a mix of military services’ 1988, 1991,

and 1993 BRAC round bases that had obligated significant funds for

environmental cleanup. We did not visit 1995 BRAC round bases because, at

the time our review, DOD was in the early stages of the closure process at

these bases and had not obligated significant BRAC funds for environmental

efforts. We visited the following BRAC bases: Norton Air Force Base,

California; Pease Air Force Base, New Hampshire; Army Material

Technology Laboratory, Massachusetts; Fort Ord, California; Charleston

Naval Shipyard, South Carolina; and Mare Island Naval Shipyard,

California.

We also visited the following military service agencies involved in the

award and management of contracts associated with environmental study

and cleanup actions: Air Force Center for Environmental Excellence,

Texas; Army Environmental Center, Maryland; Army Corps of Engineers,

Sacramento District, California; and Naval Facilities Engineering

Command, Engineering Field Activity (West), California.

To identify potential opportunities and tradeoffs for reducing

environmental costs, we analyzed a number of cost reduction proposals

Page 21 GAO/NSIAD-96-172 Military Base Closures
B-272218 

that have surfaced in recent years. We reviewed documentation to include

past work by us, DOD, the Congressional Budget Office, and the

Congressional Research Service, along with congressional efforts to revise

existing environmental legislation. We discussed cost and programmatic

tradeoffs with affected parties, including BRAC officials; EPA officials;

community environmental representatives; and state environmental

officials overseeing BRAC issues in California, New York, South Carolina,

and Texas.

We performed our work between April 1995 and May 1996 in accordance

with generally accepted government auditing standards.

Unless you publicly announce its contents earlier, we plan no further

distribution of this report until 10 days after its issue date. At that time, we

will send copies to other congressional committees; the Secretaries of

Defense, the Air Force, the Army, and the Navy; the Director, Office of

Management and Budget; the Administrator, EPA; 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 III.

Sincerely yours,

David R. Warren, Director

Defense Management Issues

Page 22 GAO/NSIAD-96-172 Military Base Closures
Page 23 GAO/NSIAD-96-172 Military Base Closures
Contents

Letter 1

Appendix I 

Selected

Environmental Laws

and Regulations

Pertinent to Cleanup

at Closing Bases

26

Appendix II 

Environmental

Cleanup Allocations,

Obligations, and

Expenditures by

BRAC Round and

Military Component

28

Appendix III 

Major Contributors to

This Report

29

Tables Table 1: Closures and Realignments by BRAC Round 1

Table 2: Environmental Cleanup Allocations, Obligations, and

Expenditures by BRAC Round

5

Table 3: Environmental Cleanup Allocations, Obligations, and

Expenditures by Military Component

5

Table 4: Estimated DOD BRAC Environmental Cleanup Program

Costs

6

Table 5: Contaminated Sites at BRAC Closing Bases 9

Figures Figure 1: Comparison of BRAC Environmental Cleanup

Allocations, Obligations, and Expenditures

7

Figure 2: Pump and Treat System at Pease Air Force Base 13

Figure 3: Underground Fuel Storage Tanks at Pease Air Force

Base

17

Page 24 GAO/NSIAD-96-172 Military Base Closures
Contents

Figure 4: Underground Fuel Storage Tank Removal at Pease Air

Force Base

18

Abbreviations

BRAC base realignment and closure

CERCLA Comprehensive Environmental Response, Compensation,

and Liability Act

DOD Department of Defense

EPA Environmental Protection Agency

RCRA Resource Conservation and Recovery Act

Page 25 GAO/NSIAD-96-172 Military Base Closures
Appendix I 

Selected Environmental Laws and

Regulations Pertinent to Cleanup at Closing

Bases

Title Summary

Primary sources of authority

Base Closure and Realignment Act of 1988 (P.L. 100-526,

102 Stat. 2623) and the Defense Base Closure and

Realignment Act of 1990 (P.L. 101-510, 104 Stat. 1808), 

10 U.S.C. 2687

Requires the Department of Defense (DOD) to comply with a variety of

laws—including the Comprehensive Environmental Response,

Compensation, and Liability Act (CERCLA) and National Environmental

Policy Act—to effect federal real property disposal at most base

realignment and closure (BRAC) installations.

CERCLA, section 120, 42 U.S.C. 9620 Defines the roles for the Environmental Protection Agency (EPA), state

agencies, and DOD components. CERCLA section 120 compliance is

required for all federal facilities, including BRAC bases. Requires for

property transfer that all remedial action necessary to protect human

health and the environment has been taken. Also requires the federal

government to assume financial responsibility for any additional cleanup

of DOD-caused pollution discovered in the future.

National Oil and Hazardous Substances Pollution

Contingency Plan, 42 U.S.C. 9605

Sets criteria for an installation’s inclusion on the National Priorities List

(NPL).

Executive Order 12580 Authorizes DOD components to conduct site investigations and cleanups.

Superfund Amendments and Reauthorization Act, 

section 211, 10 U.S.C. 2701

Used as the basis for the Defense Environmental Restoration Program.

Authorizes removal of unexploded ordnance and unsafe buildings and

debris on BRAC bases.

National Environmental Policy Act, 42 U.S.C 4331 Defines the process for examining potential impacts to the environment

that may result from disposition of BRAC installation property. Requires

that reuse alternatives are identified and characterized and that the

environmental impacts associated with each are disclosed.

State laws and other statutes CERCLA section 120(a)(4) states that “State laws concerning removal and

remedial actions, including State laws regarding enforcement, shall apply

to removal and remedial action at facilities owned or operated by a

department, agency, or instrumentality of the United States when such

facilities are not included in the National Priorities List.”

Other relevant federal environmental laws

Resource Conservation and Recovery Act (RCRA), 

42 U.S.C. 6901, et seq.

Establishes the framework for managing solid wastes, including

hazardous substances. Applies to both NPL and non-NPL installations.

Toxic Substances Control Act, 

15 U.S.C. 2601, et seq.

Regulates specific chemical substances, including polychlorinated

biphenyls and asbestos.

Federal Water Pollution Control Act (“Clean Water Act”), 

33 U.S.C. 1251, et seq.

Regulates discharges of pollutants into waters. Requires the

establishment of criteria and standards to protect water quality. Requires

federal permits for dredge and fill operations.

Safe Drinking Water Act, 42 U.S.C. 300f, et seq. Establishes regulations to protect human health from contaminants in

drinking water.

Clean Air Act, 42 U.S.C. 7418 Regulates releases of pollutants into the air.

Federal Insecticide, Fungicide, and Rodenticide Act, 

7 U.S.C. 135, et seq.

Establishes a registration program for pesticides. Governs disposal of

pesticides.

Other selected federal laws impacting land use

American Indian Religious Freedom Act, 

42 U.S.C. 1996

Protects and preserves access to religious sites of Native Americans.

Archaeological and Historic Preservation Act, 

16 U.S.C. 469

Protects historic or archaeological resources threatened by federal dams

or construction projects.

(continued)

Page 26 GAO/NSIAD-96-172 Military Base Closures
Appendix I 

Selected Environmental Laws and

Regulations Pertinent to Cleanup at Closing

Bases

Title Summary

Bald and Golden Eagle Protection Act, 

16 U.S.C. 668

Governs activities and facilities that may threaten protected birds.

Coastal Zone Management Act, 16 U.S.C. 1451-1464 Requires federal agencies to observe state Coastal Zone Management

Plans for activities near shorelines.

Endangered Species Act, 16 U.S.C. 1531-1544 Protects the habitat of threatened or endangered species by controlling

land use and regulating construction.

Fish and Wildlife Coordination Act, 16 U.S.C. 663 Requires federal agencies to consider the effect of their land and water

use activities on fish and wildlife.

National Historic Preservation Act, 16 U.S.C. 470 Establishes a program for the preservation of designated historic

properties throughout the nation.

Water Resources Development Acts, 

33 U.S.C. 2283 and 2317

Establishes a national goal of no net loss of wetlands. Provides for

mitigation of negative effects of water resource projects on fish and

wildlife.

Wild and Scenic Rivers Act, 16 U.S.C. 1271 Preserves and protects the free-flowing condition of designated rivers.

Page 27 GAO/NSIAD-96-172 Military Base Closures
Appendix II 

Environmental Cleanup Allocations,

Obligations, and Expenditures by BRAC

Round and Military Component

BRAC

Dollars in thousands

1988 1991 1993 1995 Total

Air Force

Allocated $397,850 $583,928 $276,444 $56,398 $1,314,620

Obligated 394,974 458,497 172,082 7,784 1,033,337

Expended 273,604 264,189 61,785 66 599,644

Army

Allocated 527,462 341,247 39,331 48,582 956,622

Obligated 522,954 227,380 26,328 4,496 781,158

Expended 302,474 135,421 13,033 145 451,073

Navy

Allocated 54,807 466,604 488,154 70,955 1,077,520

Obligated 48,998 414,643 453,938 31,588 949,167

Expended 24,594 276,524 225,490 1,606 528,214

Defense agencies

Allocated 0 0 11,748 1,666 13,414

Obligated 0 0 8,427 0 8,427

Expended 0 0 2,689 0 2,689

Total

Allocated $980,119 $1,391,779 $812,677 $177,601 $3,362,176

Obligated $966,926 $1,100,520 $660,775 $43,868 $2,772,089

Expended $600,672 $676,134 $302,997 $1,817 $1,581,620

Note: Data are as of March 31, 1996.

Source: Our analysis of DOD data.

Page 28 GAO/NSIAD-96-172 Military Base Closures
Appendix III 

Major Contributors to This Report

National Security and

International Affairs

Division, Washington,

D.C.

James F. Wiggins

John J. Klotz

James R. Reifsnyder

David F. Keefer

Los Angeles Regional

Office

Lionel C. Cooper, Jr.

(709139) Page 29 GAO/NSIAD-96-172 Military Base Closures
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