DOD Operational Ranges: More Reliable Cleanup Cost Estimates and a Proactive Approach to Identifying Contamination Are Needed
Published: 2004-05-28T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: For decades, the Department of Defense (DOD) has tested and fired munitions on more than 24 million acres of operational ranges. Munition constituents such as lead, trinitrotoluene (TNT), and perchlorate may cause various health effects, including cancer. Concerned about the potential cost to clean up munitions, Congress required DOD to estimate the cost to clean up its operational ranges. Congress asked GAO to determine (1) how DOD identified the location and last use of operational ranges and the basis for DOD's cost estimates for cleaning up those ranges; and (2) DOD's policy to address contaminants linked to the use of munitions on operational ranges and, where contaminants such as perchlorate have been detected, what corrective actions the military services have taken.
section_title: What GAO Found
paragraphs: DOD identified the location and status of its operational ranges based on inventory data developed by the individual military services. However, the reliability of DOD's inventory is questionable because the services did not use a common framework to collect and analyze data on the number of existing operational ranges. Because DOD's cost estimates to clean up its operational ranges were based on individual service calculations that combined inventory data with unvalidated DOD cost assumptions, various service assumptions, and computer-generated cost rates, these cost estimates are also questionable. Specifically, GAO found that each service compiled inventory data using various methodologies over different time periods and developed cost estimates using a mix of differing assumptions and estimates, along with actual data. As a result, the services' estimates to clean up an acre of highly contaminated land vary from about $800 for the Air Force to about $7,600 for the Army. DOD does not have a comprehensive policy requiring sampling or cleanup on operational ranges for the more than 200 chemicals associated with military munitions. However, when required by the Safe Drinking Water Act or other environmental laws, DOD has sampled and cleaned up munitions and munitions constituents. With regard to perchlorate, DOD has issued sampling policies but cannot assure funding is provided for such sampling. In some cases, DOD has sampled for perchlorate when required under the Safe Drinking Water Act's Unregulated Contaminant Monitoring Regulation and for other contaminants when directed by state environmental agencies. However, DOD generally has not independently taken actions specifically directed at cleaning up munitions contaminants, such as perchlorate, on operational ranges when they have been detected.

section_title: Letter
paragraphs: For decades, the Department of Defense (DOD) has tested and fired  munitions on millions of acres of operational ranges. These munitions  contain various constituents such as lead, trinitrotoluene (TNT), and  ammonium perchlorate salt (perchlorate) that are, in some instances,  known or suspected of causing health effects such as damage to the central  and peripheral nervous systems, cancer, and interfering with thyroid  function. Concerns about the potential cost to clean up munitions  prompted Congress to require that DOD develop an estimate for what it  would cost to clean up its operational ranges. The National Defense  Authorization Act for Fiscal Year 2002 required DOD to provide (1) a  comprehensive assessment of unexploded ordnance, discarded military  munitions, and munitions constituents at current and former DOD  facilities; and (2) an estimate of the aggregate projected cost of  remediation (cleanup) at operational ranges, stated as a range of costs,  including a low and high estimate. As of April 2003, DOD identified 10,444  operational ranges located in the United States and its territories, with  Army operational ranges accounting for 94 percent of the total. DOD  estimated it would cost between $16 billion and $165 billion to clean up  unexploded ordnance, discarded military munitions, and munitions  constituents on these operational ranges.
There is a growing concern about the potential health effects associated  with the environmental contamination caused by constituents used in the  munitions and specifically the possible contamination of drinking water  with perchlorate—the primary ingredient of solid rocket propellant that is  also used in varying quantities in many types of munitions, explosives, and  incendiary devices, such as mortars, grenades, and flares. The  Environmental Protection Agency (EPA) estimates that about 90 percent of  the perchlorate manufactured in the United States is for solid rocket fuel  used for military purposes and by the National Aeronautics and Space  Administration. According to EPA, studies have shown that perchlorate can  interfere with thyroid function and negatively affect fetal and infant brain  development and growth. Since 1990, the state of California has detected  perchlorate in wells and other drinking water sources near sites that once  supported munitions manufacturing, storage, and testing. EPA reports that  perchlorate has been detected in 34 states and attributes a significant  portion of the contamination to defense manufacturing and test sites.
In monitoring and cleaning up munitions and munitions constituents on  operational ranges, DOD must comply with applicable provisions of  various federal environmental laws, including the Safe Drinking Water Act,  as amended; the Resource Conservation and Recovery Act of 1976, as  amended (RCRA); and the Comprehensive Environmental Response,  Compensation, and Liability Act of 1980, as amended (CERCLA). EPA does  not have specific regulatory standards under the Safe Drinking Water Act  for the roughly 200 chemicals associated with military munitions use, but  requires sampling for some of these contaminants, including perchlorate.  According to DOD, at least 20 of these constituents, including perchlorate,  are of great concern due to their widespread use and potential  environmental impact. For example, EPA and some states are considering  whether to establish a specific drinking water standard for perchlorate  levels and have, in some cases, established advisory levels. Appendix I  contains a listing of munitions constituents of greatest concern and their  potential health effects.
You asked us to determine (1) how DOD identified the location and last  active use of all operational ranges and the basis for DOD’s cost estimates  for cleaning up those ranges; and (2) DOD’s policy to address contaminants  linked to the use of munitions on operational ranges and, where munitions- related contaminants have been detected, what corrective actions the  services have taken. Specifically, you asked us to focus on DOD’s actions  with regard to perchlorate.
To determine how DOD identified the location and last active use of all  operational ranges, we reviewed the services’ inventory data and  interviewed DOD and service officials to obtain information on how the  inventories were conducted and the reliability of the data collected. We  assessed the reliability of the services’ data (1) by reviewing existing  information about the data and processes that produced them and (2) by  interviewing DOD officials knowledgeable about the data. We determined  that data on the number of operational ranges and acreage were  sufficiently reliable to include in our report. Although we found the  reliability of data on operational range characteristics to be questionable,  we present the data in the report for informational purposes. To determine  the basis for DOD’s cost estimates for cleaning up the operational ranges,  we reviewed the services’ estimated costs, supporting analyses, and  calculations, and interviewed service and DOD officials on the scope and  methodology used to develop cost estimates. To identify DOD’s policy on  sampling for constituents linked to the use of munitions on operational  ranges, we reviewed DOD’s and the services’ policies related to sampling  and cleanup of potential contaminants and specifically their policies on  perchlorate. Finally, to report on what corrective actions the services have  taken with regard to munitions constituents, particularly perchlorate, we  visited seven DOD installations where perchlorate had been detected and  discussed what efforts have taken place or were planned to respond  generally to munitions-related contaminants and specifically to  perchlorate. Our observations about these installations are not  generalizable to all military installations. We conducted our work between  June 2003 and March 2004 in accordance with generally accepted  government auditing standards. More detail on the scope and methodology  of our review is presented in appendix II.
subsections: section_title: Background
paragraphs: DOD policy defined an operational range as an area used to conduct  research, develop and test military munitions, or train military personnel.  Operational ranges were considered active when regularly used for range  activities, and inactive when not currently used but still under military  control and available for use as a range. Once a range is closed, DOD is  required to identify, assess, and clean up or take other appropriate action in  response to contamination by military munitions. As such, DOD’s current  inventory of operational ranges represents a potential liability for future  cleanup. Figures 1, 2, and 3 show examples of the types of ordnance and  explosives that can be found on operational ranges.
Section 313(a)(1) of the National Defense Authorization Act for Fiscal Year  2002 required DOD to provide Congress with a comprehensive assessment  of unexploded ordnance, discarded military munitions, and munitions  constituents at current and former DOD facilities.  The law required the  assessment to include an estimate of the aggregate projected cost of  remediation (or cleanup) at operational ranges, to be presented as a range  of costs including a low and high estimate, and delivered to Congress in  2003 in DOD’s report on the Defense Environmental Restoration Program.  In April 2003, DOD reported its estimate for the total cost to address the  potential liability associated with unexploded ordnance, discarded military  munitions, and munitions constituents at operational ranges to be between  $16 billion and $165 billion.
subsections: section_title: Collecting Inventory Data and Estimating Cleanup Costs
paragraphs: To provide Congress with estimated costs to clean up operational ranges,  DOD used inventory data available at the time of its April 2003 report,  which counted 10,444 operational ranges located in the United States and  its territories. At the direction of Congress, only operational ranges in the  United States and its territories were to be considered for the purpose of  estimating cleanup costs. According to DOD, these cost estimates were  supported by individual service estimates, which in turn were supported by  summary information on the number of operational ranges and acreage  assumed to contain a high density of unexploded ordnance and munitions  constituents—such as target areas, detonation sites, and demolition  areas—and the percentage of acreage assumed to contain a low density of  contamination from unexploded ordnance and munitions constituents,  such as buffers, training areas, and maneuver areas.
The services continued to inventory operational ranges under section 366  of the National Defense Authorization Act for Fiscal Year 2003, which  required DOD to inventory operational ranges to address training range  sustainment and encroachment concerns and submit the inventory to  Congress as part of the President’s fiscal year 2005 budget request early in  calendar year 2004. The scope of this inventory effort addressed  operational range training and testing capacities and capabilities, and  specific constraints on the use of operational ranges, but did not  specifically include data on the cleanup of unexploded ordnance, discarded  military munitions, or munitions constituents.
We previously reported that the two key data needed to develop  operational range cleanup costs were (1) an accurate and complete  operational range inventory and (2) a consistent methodology for  estimating costs. Reliable cost estimates can be critical information for  DOD and Congress when considering the potential benefits of closing  operational ranges or entire installations versus the potentially very high  cost of cleaning up such sites. However, such estimates must be based on  accurate data that, in the case of operational ranges, begins with a  complete and accurate operational range inventory. The costs for cleaning  up ranges can be extensive. For example, DOD estimates it will cost $22.6  million to clean up Fort McClellan in Alabama, recommended for closure  under DOD’s base realignment and closure program in 1995, and $247  million to clean up Fort Ord in California, closed in 1994. DOD officials  explained that wide variations in cost can be attributed to a number of  factors, such as future land use, technical complexities, and the high level  of difficulty to locate, recover, and destroy ordnance located beneath the  ground surface.
section_title: Environmental Laws and Regulations Affecting DOD Installations and Operational Ranges
paragraphs: DOD’s operations at military installations and operational ranges in the  United States are subject to laws and regulations governing a variety of  environmental concerns, from water quality to the treatment and disposal  of hazardous wastes. These laws include the Safe Drinking Water Act, the  Clean Water Act, RCRA, the Federal Facility Compliance Act, and CERCLA.  DOD is also generally required to comply with state and local  environmental statutory and regulatory requirements on its installations  and operational ranges. DOD has proposed that Congress specifically  exempt it from requirements to clean up unexploded ordnance, munitions,  and munitions constituents on operational ranges under RCRA and  CERCLA.
The Safe Drinking Water Act authorizes EPA to issue national primary  drinking water regulations setting maximum contaminant level standards  for drinking water that must be met by public water systems. EPA may  authorize states to carry out primary enforcement authority for  implementing the Safe Drinking Water Act if, among other things, the state  adopts drinking water regulations that are no less stringent than the  national primary drinking water regulations. EPA has set standards for  approximately 90 contaminants in drinking water, including  microorganisms, organic chemicals, inorganic chemicals, disinfectants,  disinfection byproducts, and radioactive substances. None of the more  than 200 chemical contaminants associated with munitions use are  currently regulated under the Safe Drinking Water Act.
The 1996 amendments to the Safe Drinking Water Act required EPA to  establish criteria for a monitoring program for unregulated contaminants  (where a maximum contamination level has not been established) and to  publish a list of contaminants—chosen from those not currently monitored  by public water systems—to be monitored.  EPA’s regulation, referred to as  the Unregulated Contaminant Monitoring Regulation, was issued in 1999  and supplemented in 2000 and 2001. The purposes of the regulation are to  determine whether a contaminant occurs at a frequency and in  concentrations that warrant further analysis and research on its potential  effects and to possibly establish  future drinking water regulations. The  first step in the current program required public water systems serving  more than 10,000 customers (and a sample of 800 small public water  systems serving fewer than 10,000) to monitor drinking water for  perchlorate and 11 other unregulated contaminants over a consecutive 12- month period at any point between 2001 and 2003, and report the results to  the EPA. Under this regulation, some DOD installations were required to  monitor drinking water for perchlorate and other munitions-related  contaminants and to report the results.
The Clean Water Act authorizes EPA to regulate the discharge of pollutants  into waters in the United States. EPA may authorize states to carry out a  state program in lieu of the federal program if the state program is at least  equivalent to the federal program and provides for adequate enforcement.  Under the Clean Water Act’s National Pollution Discharge Elimination  System (NPDES) program, facilities discharging pollutants into waters of  the United States are required to obtain an NPDES permit from EPA or  authorized states. NPDES permits include specific limits on the quantity of  pollutants that may be discharged and require monitoring of those  discharges to ensure compliance. EPA’s list of the toxic pollutants subject  to regulation under the Clean Water Act includes nitrobenzene, a chemical  that is on DOD’s list of 20 constituents of greatest concern.
RCRA requires owners and operators of facilities that treat, store, and  dispose of hazardous waste, including federal agencies, to obtain a permit  specifying how their facilities will safely manage the waste. Under RCRA’s  corrective action provisions, facilities seeking or holding RCRA permits  can be required to clean up their hazardous waste contamination. The  corrective actions can be specified in the facility’s operating permit, in a  separate corrective action permit, or through an enforcement order. EPA  also has authority under RCRA to order a cleanup of hazardous waste when  there is an imminent and substantial endangerment to public health or the  environment. EPA may authorize states to administer their own programs  in lieu of the federal program, as long as these programs are equivalent to  and consistent with the federal program and provide for adequate  enforcement. EPA’s regulations define hazardous wastes to include those  that are specifically listed in the regulations as well as those that are  “characteristic wastes.” Characteristic hazardous wastes are defined as  wastes that are ignitable, corrosive, reactive, or toxic. A federal district  court in California recently ruled, in part, that perchlorate is a hazardous  waste under RCRA because it is ignitable.
Under section 107 of the Federal Facility Compliance Act of 1992, EPA  was required, in consultation with DOD and the states, to issue a rule  identifying when military munitions become hazardous waste under RCRA,  and to provide for protective storage and transportation of that waste.  Under the rule issued by EPA, military munitions are subject to RCRA  when, among other things, (1) unexploded munitions or their constituents  are buried or otherwise disposed of, or (2) when used or fired munitions  are taken off-range.
CERCLA governs the cleanup of releases or threatened releases of  hazardous substances, pollutants, or contaminants. CERCLA’s definition of  a hazardous substance includes substances regulated under various other  environmental laws, including RCRA, the Clean Air Act, the Clean Water  Act, and the Toxic Substances Control Act. Under section 120 of CERCLA,  the federal government is subject to and must comply with CERCLA's  requirements to the same extent as any nongovernmental entity. DOD’s  cleanup under CERCLA section 120 is interrelated with its environmental  restoration program under section 211 of the Superfund Amendments and  Reauthorization Act of 1986.
section_title: Contaminants Associated with Military Munitions
paragraphs: According to DOD, there are more than 200 chemicals associated with  military munitions, and of these, 20 are of great concern due to their  widespread use and potential environmental impact. TNT, Propanetriol  trinitrate (nitroglycerin), Royal Demolition Explosive, and perchlorate are  among the 20. Perchlorate is the primary oxidizer in propellants, present in  varying amounts in explosives, and is highly soluble. According to EPA, an  estimated 90 percent of the perchlorate produced in the United States is  manufactured for use by the military and the National Aeronautics and  Space Administration. Typical production quantities average several  million pounds per year. Nonmilitary uses for perchlorate include  fireworks, flares, fertilizer, and automobile airbags. As of 2004, EPA  reported that 34 states confirmed perchlorate contamination in ground and  surface water, and in states where EPA determined the source of the  contamination, it attributed a significant portion to defense manufacturing  and test sites.
EPA has not established a federal drinking water standard for perchlorate.  However, in 1999, EPA established a provisional reference dose for  perchlorate in drinking water of between 4 and 18 parts per billion. A  reference dose is an estimate of the daily exposure to a human that would  not pose a significant risk of harmful effects. In October 2003, the National  Academy of Sciences (Academy) began a study of the best scientific model  to use for determining a drinking water standard or reference dose for  perchlorate, if any. According to EPA, the Academy’s study will take about  one year to complete. Based on recommendations from the Academy, EPA  will decide whether to regulate the contaminant and will have up to 2 years  after making an affirmative determination to propose a national primary  drinking water regulation for perchlorate. An EPA official told us that  updating drinking water standards can take 2 to 3 years and predicted that  a perchlorate standard will likely not be available until 2006 or 2008.
In the meantime, some states that detected perchlorate in various media,  such as groundwater, have established state guidance or advisory levels for  the contaminant. As of February 2004, seven states have established  interim perchlorate advisory levels. Of those states, Maryland and  Massachusetts have the lowest perchlorate advisory level of 1 part per  billion. On March 12, 2004, California revised its advisory action level for  perchlorate from 4 parts per billion to 6 parts per billion.
section_title: DOD’s Inventory and Cost Estimates for Operational Range Cleanup May Not Provide Congress with a Reliable Picture of Potential Liabilities
paragraphs: DOD’s estimate that it would cost between $16 billion and $165 billion to  clean up unexploded ordnance, discarded military munitions, and  munitions constituents on operational ranges is questionable. To determine  the costs of operational range clean up, DOD had to first inventory its  operational ranges and obtain data such as the type of range and munitions  used. However, the military services used inventory data that were  collected for different purposes over different periods of time and verified  with varying degrees of analytical rigor. Next, the costs of operational  range cleanup were calculated using a mix of unvalidated assumptions  provided by DOD and assumptions provided by the individual services, as  well as actual service data, where available. Consequently, DOD’s overall  cost estimates were based on assumptions, estimates, and actual data that  differed across the services and that raise questions about the reliability of  DOD’s estimated costs to clean up operational ranges.
subsections: section_title: Operational Range Inventory Process Lacked a Common Framework and Analytical Rigor
paragraphs: Each service inventoried its operational ranges and collected data on range  acreage and munitions used, using various methodologies over different  periods of time. (See table 1 for the starting and ending dates of the  service’s inventories.)  Services also conducted inventories for different  reasons, such as to respond to pending legislation on ranges, public  concern about military use of ranges, or simply to gather data to calculate  cleanup cost estimates. The rigor of the analysis and the degree of the  validity of the inventory results varied by service. The inconsistencies in  how DOD collected and analyzed data on operational ranges raise  questions about the reliability of DOD’s inventory.
The Air Force inventory of operational ranges in the United States and its  territories was based on a survey sent to field command levels to estimate  costs to clean up operational ranges. Service officials said survey data was  validated during on-site field inspections or, in some cases, brief desk  reviews to assure surveys were complete and free of obvious errors. As of  December 2002, the Air Force counted 222 active ranges, 23 inactive  ranges, and 23 ranges that were not categorized as either active or inactive.  Together, Air Force operational ranges covered 6,423,161 acres.
The Army’s inventory of operational ranges was conducted concurrently  with an inventory of nonoperational ranges and was based on field surveys.  According to Army officials, the Army initiated an inventory of its ranges  primarily in response to anticipated legislation on the use of ranges,  which required a comprehensive inventory of DOD ranges as well as a  collection of descriptive data about each range, such as the acreage and  types of munitions used on the range. The Army’s inventory was also  conducted in response to DOD directives issued in August 1999 that  required the services to establish and maintain an inventory of operational  ranges and data on munitions and ordnance. To inventory ranges, the  Army used contract support staff who requested data from field commands  and installations, and then sought to validate the data through on-site visits.  Army officials said the Army’s inventory of operational ranges was  completed in December 2002, and encompassed 9,427 active ranges, 377  inactive ranges, and 4 ranges not designated active or inactive. In total,  Army operational ranges covered 14,991,072 acres in the United States and  its territories.
Similar to the Army, the Marine Corps conducted an inventory of its  operational ranges primarily in response to anticipated legislation on the  use of ranges and DOD directives that required the services to establish and  maintain an inventory of operational ranges and data on munitions and  ordnance. The Marine Corps developed its inventory from an archive data  search and surveys sent to installations. Headquarters’ officials reviewed  the surveys to assure that submitted data agreed with data in the archive  search. As of December 2002, the Marine Corps counted 216 operational  ranges totaling 1,980,119 acres in the United States and its territories.  According to headquarters’ officials, the Marine Corps did not distinguish  between active and inactive ranges but designated all ranges as  operational.
The Navy’s inventory of operational ranges in the United States and its  territories was conducted at the request of the Navy’s Environmental  Readiness Division. The Navy’s inventory was prepared in response to the  anticipated inventory requirements of DOD’s proposed range rule and  because of increased public and regulatory scrutiny of military ranges,  Navy officials said. The inventory was conducted through surveys sent to  the installations. As of December 2002, Navy operational ranges totaled 121  active ranges and 31 inactive ranges on 1,284,374 acres.
As of April 2003, when DOD reported its estimated cost to clean up  operational ranges, DOD’s inventory included 10,444 operational ranges  totaling 24.6 million acres in the United States and its territories. (See table  2 for a breakout of operational ranges by service and status and total  acres.)
DOD continued to inventory its operational ranges. The National Defense  Authorization Act for Fiscal Year 2003 required DOD to develop a plan to  address training range issues, such as range sustainment and  encroachment and, as part of this plan, to develop a range inventory system  that included all available operational training ranges. In January 2003,  DOD provided the services with an inventory framework and data  definitions to ensure reporting consistency and required the services to  complete detailed inventories of all of their operational ranges. DOD  revised its existing inventory of operational ranges to meet this new  requirement. Because the revised inventory was conducted for different  purposes, using a scope and set of assumptions that were different from  the inventory data used to estimate cleanup costs, it identified a different  number of operational ranges. For example, the inventory for developing  the cost estimates used actual operational range acreage, whereas the  revised inventory used actual and potential operational range acreage.  Further, the revised inventory is divided into range complexes and  individual ranges, and includes operational ranges outside the United  States and its territories not included in the inventory DOD used to  estimate cleanup costs.
In February 2004, DOD released the results of its training range plan and  revised inventory. The revised inventory listed 353 range complexes and  172 individual ranges on 26 million acres worldwide. These numbers differ  from the inventory data DOD used to estimate cleanup costs, which  counted 10,444 operational ranges on 24.6 million acres in the United States  and its territories primarily because of the aggregation of individual ranges  into complexes and the inclusion of ranges outside the United States and  its territories. For example, under the prior inventory, Fallon Naval Air  Station, in Nevada, reported it had 150,365 acres of rangeland, but under  the new inventory, Fallon reported it had just 103,300 acres of actual and  potential rangeland. Also under the prior inventory, the Marine Corps  reported that Camp Lejeune, in North Carolina, had 95,872 acres of  rangeland, while under the new inventory, Camp Lejeune reported it had  152,000 acres of actual and potential rangeland (even though the entire  installation encompasses just 153,000 acres). The Marine Corps also  reported that Camp Pendleton, in California, had 39,084 acres of rangeland  under the old inventory, but under the new inventory, Camp Pendleton  reported it had 114,000 acres of actual and potential rangeland, almost a  threefold increase.
While the 2003 and 2004 inventories are not readily comparable because of  the varying scope and definitions used to develop the revised inventory, the  difference between the two highlights the difficulty in understanding the  basis for, and the results of, DOD’s cost estimates. Finally, we believe the  differences in the two inventories may further complicate efforts of  Congress to identify the potential liabilities that may exist if operational  ranges or installations are closed and require cleanup.
section_title: Cost Estimates Were Calculated Using a Mix of Differing Assumptions, Estimates, and Actual Data
paragraphs: In 2002, DOD provided guidance to the services on how to estimate costs  for cleaning up operational ranges. This guidance specified the scope for  estimating costs but allowed for variation across the services. According to  DOD officials, because the requirement to estimate cleanup costs was a  one-time congressional requirement, DOD directed the services to limit  their data gathering efforts by using certain costing assumptions and a  computer-costing model in combination with already existing data.  Examples of the scope and some of the assumptions DOD used to estimate  costs include the following:  The scope of the inventory was limited to operational ranges within the  United States and its territories because DOD believed that was what  Congress intended.
The scope excluded certain operational ranges, such as water ranges,  because DOD did not have a model for estimating costs associated with  such ranges and did not have any significant historical experience on  which to base an estimate. DOD also did not develop cost estimates for  several types of airspace, such as warning areas and restricted areas.
DOD directed the services to use both a computer-costing model that  automatically assigned certain values for the cleanup costs of  unexploded ordnance and discarded military munitions and an  electronic worksheet to estimate costs to clean up munitions  constituents.
DOD provided cost assumptions to the services based on operational  range acreage and other variables. For example, the services were  directed to divide range acreage into areas assumed to have a high  density of contamination and a low density of contamination and, on  that basis, calculate individual cleanup costs.
DOD also provided specific assumptions to calculate costs for various  cleanup activities. For example, to estimate the cost to remove  unexploded ordnance from a highly contaminated range area, the  services were told to assume they would need to remove ordnance from  50 percent of that area to calculate the high cost estimate and 5 percent  of that area to calculate the low cost estimate.
DOD said its assumptions were based on discussions with the services and  developed through consensus. DOD could not provide any documentation  that the assumptions they asked the services to use were validated—a  confirmation of the reasonableness and justification for assumptions  used—and a senior DOD official told us that, in fact, the assumptions were  not validated.
Furthermore, DOD instructions to the services allowed them to use  additional assumptions or site-specific data so that cost estimates were  calculated based on a mix of actual data and assumptions. Based on our  review of DOD’s 2003 report to Congress, and discussions with service  officials on their methodologies to estimate costs, we found DOD did not  fully explain the mix of assumptions and data used and how this mix  affected the cost estimates, so that the usefulness of DOD’s overall cleanup  cost estimates to Congress is questionable.
The inconsistencies in how the services developed their cost estimates are  evident in areas such as how the services calculated high-density acreage  (that is, the area of a range containing a high density of ordnance) and the  costs for cleaning up these acres. For example, although DOD guidance  directed the services to estimate what proportion or percentage of  operational range acreage contained a high density of unexploded  ordnance and munitions constituents, and specified how various types of  ranges were to be treated for cost estimating purposes, each service  performed this calculation differently. If site-specific data was unavailable,  the Marine Corps used varying percentages based on the characteristics of  similar ranges to determine those that were highly contaminated. Our  analysis showed that for about two-thirds of its operational ranges, the  Marine Corps assumed 10 percent of its nonsmall arms or multipurpose  range acreage was highly contaminated. However, based on a review of the  Marine Corps’ total cleanup cost estimates for operational ranges, GAO  determined that the Marine Corps calculated its costs assuming that an  average 53 percent of range acreage has highly contaminated. In contrast,  the Air Force and the Army used estimated data to determine that 44  percent and 60 percent of their acreage was highly contaminated,  respectively. Further, the Air Force did not designate a percentage of each  operational range with a high density of contamination and a low density of  contamination, but rather defined each operational range as either 100  percent high density or 100 percent low density. The Navy used actual data  to determine that 11 percent of its operational range acreage was highly  contaminated. (Figure 4 shows the high and low density acreage by service  used to estimate cleanup costs.)
Based on the data provided by the services, the model calculated four  totals for each operational range: a low and high estimated cost to clean up  the portion of the range assumed to have a low level of contamination, and  a low and high estimated cost to clean up the portion of the range assumed  to be highly contaminated. Low estimates for low and high contamination  areas were combined to calculate a total low estimate, and high estimates  for low and high contamination areas were combined to calculate a total  high estimate. (See table 3 for low and high estimates by service.)
In general, using the model and standardized assumptions should have  produced estimates with some variation across the services because of  differing missions, operational practices, and types of munitions used.  However, as reflected in table 4, a tenfold difference in the average cost to  clean up an acre of highly contaminated rangeland calls into question the  mix of different assumptions and data used by the services to estimate  costs. For example, the Air Force’s average cost to clean up an acre with a  high density of contamination was $755, whereas the Army’s estimate was  $7,577. As a result, the services cost estimates are not comparable. (Table 4  shows the total and average cost per acre estimates by service.)
section_title: DOD Does Not Have a Comprehensive Policy on Contaminants Associated with Military Munitions and Has Not Specifically Cleaned Up Known Perchlorate Contamination
paragraphs: DOD does not have a comprehensive policy requiring sampling or cleanup  of the more than 200 chemical contaminants associated with military  munitions on operational ranges. However, DOD installations have  sampled for and cleaned up munitions-based constituents when directed by  state regulatory authorities. With regard to perchlorate, DOD has issued  sampling policies but does not provide specific funding for such sampling.  Nevertheless, we found some installations have sampled and monitored for  perchlorate to meet the requirements of environmental laws and  regulations, such as RCRA and the Unregulated Contaminant Monitoring  Regulation. During visits to six installations that reported high levels of  perchlorate, we found that none were cleaning up perchlorate  contamination. At six of the seven installations we visited, perchlorate  contamination was largely the result of researching, manufacturing,  testing, and disposing of munitions, and not the use of munitions during  training.
subsections: section_title: Previous DOD Policy Did Not Require Cleanup or Sampling for Contaminants Associated with Military Munitions
paragraphs: According to EPA, of the more than 200 chemicals associated with military  munitions, which include 20 that DOD considers to be of greatest concern  due to their widespread use and potential environmental impact, none are  specifically regulated under the Safe Drinking Water Act. Further, except in  some specific instances, EPA does not generally use its authority under  other environmental laws, such as RCRA and CERCLA, to require DOD to  conduct cleanups on operational ranges. An EPA official told us that  although EPA is concerned with constituents associated with military  munitions such as perchlorate and Royal Demolition Explosive, and the  migration of plumes (pollutants that drain or flow through soil and water)  from military ranges to groundwater, the agency generally does not  interfere with DOD’s operation of its operational ranges. Recently, DOD  proposed that Congress specifically exempt it from requirements to clean  up unexploded ordnance, munitions, and munitions constituents that  remain on operational ranges under RCRA and CERCLA.
DOD policy does not generally require the services to clean up or sample  for munitions contaminants because, according to DOD officials, these  contaminants are deposited on operational ranges in the course of the  normal and intended use of these munitions. Yet, DOD may be required by  EPA or states to sample and clean up its munitions contaminants under  various environmental laws and regulations on operational ranges. For  example, under the Clean Water Act, facilities that discharge pollutants into  surface water are required to obtain a NPDES permit from EPA or an  authorized state agency. Several states have required some DOD  installations to monitor for various contaminants associated with military  munitions as part of the NPDES permit process. For example, the Regional  Water Quality Control Board in San Diego and the Hampton Roads  Sanitation District in Hampton Roads, Virginia, required Navy facilities to  monitor their water discharges for various constituents that are on EPA’s  list of toxic pollutants under the Clean Water Act. Under the Unregulated  Contaminant Monitoring Regulation, EPA required some installations to  sample for and report on 12 unregulated contaminants in drinking water  during any 12-month period between 2001 and 2003. The list of  contaminants included four munitions-related contaminants—perchlorate,  2,4 and 2,6 dinitrotoluene, and nitrobenzene. In April 2004, DOD reported  that 36 installations had sampled for the presence of unregulated  contaminants in drinking water, including perchlorate, under this  regulation. Of these, 33 installations reported no perchlorate was detected  or detection results were below the reporting limit of 4 parts per billion.  Only three Air Force installations detected perchlorate above the reporting  limit, ranging from just over 4 parts per billion to 46 parts per billion.
section_title: Revised DOD Policy Directs Sampling for Perchlorate under Certain Conditions but Little Sampling Has Been Done
paragraphs: In November 2002, DOD issued its first policy on perchlorate assessment  that stated the services may sample and assess for perchlorate if there was  a reasonable basis to suspect both a potential presence of perchlorate and  a likely pathway that could lead to human exposure. The policy stated that  the services could fund assessments using the operations and maintenance  environmental compliance account, but specified that sampling should be  considered a lower priority (Class II) environmental project and, as we found in a prior effort, was unlikely to be funded.  Finally, the policy  directed those installations that sampled for and found perchlorate to  report to DOD on the location and amount of perchlorate found. On  September 29, 2003, DOD issued a revised policy on perchlorate sampling  that directed the services to (1) consolidate data on perchlorate detections,  including data developed in response to environmental laws such as the  Clean Water Act and Safe Drinking Water Act, and (2) sample any  previously unexamined sites, including ranges, where a perchlorate release  is suspected because of prior DOD activities and where human exposure is  likely. The policy stated that the services should fund sampling using the  same environmental compliance account specified in the previous policy,  but elevated sampling to a higher (Class I) funding priority and thus made it  more likely to be funded. However, when DOD issued its policy, funding  had already been allocated to Class I requirements for fiscal year 2004. In  future years, unless specific or additional funding is added, perchlorate  sampling will have to compete with other high priority environmental  requirements and may not be funded.
In implementing the revised policy, the services added a third criterion  requiring that installations coordinate with, or obtain written approval  from, headquarters and the chain of command before sampling for  perchlorate. However, if sampling is specifically required by an  environmental law or state agency, the service policies do not require  installations to request approval or notify headquarters before sampling.  During visits we made to selected installations with reported perchlorate  contamination between October 2003 and January 2004, we found  installations were not sampling under the revised policy to determine the  presence of perchlorate on operational ranges. More broadly, as of  February 2004, Marine Corps and Navy officials said that no installations  had requested permission to sample under this policy. According to the Air  Force, three installations asked for permission to sample for perchlorate  because EPA had asked that they sample. Air Force headquarters approved  two of the requests but denied the third because, according to Air Force  headquarters, there was not a reason to suspect the presence of  perchlorate. Four Army installations have asked for approval to sample for  perchlorate, and Army headquarters approved all four as of March 2004, an  Army headquarters official said. Overall, this suggests that little sampling is  being done under DOD’s revised perchlorate policy.
Although none of the installations had begun sampling under DOD’s revised  policy, during our visits we found a few installations had sampled and  monitored for perchlorate to meet the requirements of certain  environmental laws and regulations. Table 5 summarizes the perchlorate  sampling that has been conducted at installations we visited as reported by  DOD as of April 2004.
During our visits, we found the following installations had sampled for and  monitored perchlorate to meet the requirements of RCRA or the Safe  Drinking Water Act:  In 1999, as part of an application under RCRA to close an open burning  and detonation facility used to destroy excess and obsolete ammunition,  the state of New Mexico required White Sands Missile Range, in New  Mexico, to sample for contaminants, including perchlorate. The former  open burning and detonation facility is located on an operational range.  Groundwater sampling detected high levels of perchlorate—up to 25,000  parts per billion.  The Army installed 56 monitoring wells on the range  to map the plume. Each well is sampled quarterly. After four years of  quarterly sampling and monitoring, Army officials said the plume is  stable and contained, which means it is isolated underground and not  expected to move. Further, officials said there is no indication that  perchlorate has migrated outside the identified plume. Under its RCRA  closure permit with the state of New Mexico, the Army must continue  monitoring the groundwater for up to 20 years.
Three of the seven installations we visited tested for perchlorate under  the Safe Drinking Water Act’s Unregulated Contaminant Monitoring  Regulation program. Edwards Air Force Base, in California, sampled  twice in 2002 and reported that none of the 12 chemicals listed on the  EPA list of unregulated contaminants, including perchlorate, were  detected in any of the groundwater samples collected from drinking  water wells. (Under the regulation, EPA required surface water systems  to be sampled quarterly and groundwater systems to be sampled  semiannually for one consecutive 12-month period.)  Redstone Arsenal,  in Alabama, sampled quarterly for a 12-month period beginning June  2001. Two water intake sites were sampled (a drinking water source and  a drinking water and industrial water source), both along the Tennessee  River. Redstone Arsenal reported that perchlorate was not detected  above the EPA sampling level of 4 parts per billion. Nearby Huntsville,  Alabama, also sampled for perchlorate and detected no contamination,  a Redstone Arsenal official said. Finally, although the requirements of  the Unregulated Contaminant Monitoring Regulation did not apply to  the Naval Air Weapons Station, China Lake, in California, because its  water supply system was too small, installation officials volunteered to  sample for perchlorate and other unregulated contaminants.  Accordingly, in October 2003, officials at China Lake sampled 10  drinking water wells for perchlorate and other contaminants, but  perchlorate was not detected.
section_title: DOD Has Not Directed the Services to Clean Up Known Perchlorate Contamination
paragraphs: According to information provided by DOD and officials at the installations  we visited, the services were generally not cleaning up known perchlorate  contamination. DOD officials explained that perchlorate is not a regulated  contaminant and, therefore, there is no requirement to clean up perchlorate  contamination. (Current DOD policy is that DOD will clean up  perchlorate if there is imminent and substantial endangerment to the  public.)  The exceptions we found were two installations that had cleaned  up perchlorate under demonstration projects designed to demonstrate  perchlorate cleanup technologies. At the installations we visited,  perchlorate contamination was generally the result of research,  manufacturing, testing, and disposal of munitions (such as rocket motors)  that contained high levels of perchlorate. In one case, the perchlorate  resulted from training with smoke munitions containing perchlorate.
Although six of the seven sites we visited reported high levels of  perchlorate contamination, none of these installations were conducting  cleanup actions specifically directed at perchlorate. However, at two  installations we visited—Edwards Air Force Base and the Naval Surface  Warfare Center, Indian Head—officials said they conducted demonstration  projects to develop perchlorate treatment and cleanup technologies in  anticipation of future cleanup requirements. (See app. III for details on  these demonstration projects.)
At six of the seven installations we visited that had operational ranges and  detectable levels of perchlorate, we found the perchlorate contamination  was generally not due to training on operational ranges. Rather, we found  that prior and ongoing research, manufacturing, testing, and disposal of  rocket motors were primarily responsible for perchlorate contamination.  (See app. IV for details of perchlorate contamination caused by such  factors.)  Only Aberdeen Proving Ground, in Maryland, reported that some  perchlorate contamination was due to the use of perchlorate during  training exercises on operational ranges. Further, Aberdeen was the only  installation we visited where perchlorate had contaminated a neighboring  municipal water supply. At Aberdeen, perchlorate concentrations of up to 5  parts per billion have been detected in drinking water supply wells and 24  parts per billion have been detected in groundwater.
Between June and August 2002, Aberdeen Proving Ground sampled  drinking water wells owned by the city of Aberdeen located in and along  the northern border between the city and the installation, and detected  perchlorate contamination in four wells ranging from 1.2 to 5 parts per  billion. According to Aberdeen officials, the installation sampled for  perchlorate because it was required to do so by the state of Maryland.  Groundwater samples taken near the well field showed a large perchlorate  plume with contamination levels up to 24 parts per billion. Aberdeen  Proving Ground officials attributed the perchlorate contamination to  intensive testing and training with smoke grenades and other obscurants.  Until about mid-2002, during training exercises in the vicinity of the city of  Aberdeen drinking water wells, Aberdeen Proving Ground trained troops  using smoke grenades that contained perchlorate. After perchlorate was  found in city drinking water, Aberdeen Proving Ground stopped all training  with smoke grenades containing perchlorate. However, officials at  Aberdeen Proving Ground are not cleaning up the perchlorate detected in  city wells. Instead, both the city of Aberdeen and the installation sample  finished water and production wells on an alternating monthly schedule:   Finished water is sampled weekly, four production wells are sampled twice  a month, and the remaining eight production wells are sampled monthly.  Recent sampling has detected contamination below the EPA interim  assessment guidance of 4 parts per billion, but in some cases, well samples  have been above the Maryland Department of the Environment public  health advisory for perchlorate, which is 1 part per billion for drinking  water. In the event a sample is found to be above the Maryland state  advisory limit, the city of Aberdeen blends well water without perchlorate  with well water containing perchlorate to lower the concentration level to  below 1 part per billion. The Army stated that it would not clean up the  perchlorate contamination at Aberdeen until an EPA maximum  contaminant level for perchlorate in drinking water is established.
section_title: Conclusions
paragraphs: Because of DOD’s approach to how it inventoried its operational ranges for  munitions and how it estimated the costs to clean up those ranges, both the  inventory and the cost estimates are questionable. Further, DOD did not  fully disclose to Congress the basis and limitations of its estimates,  including identifying estimates based on direct observations and those  based on assumptions, and the affect of assumptions on DOD’s cost  estimates. Instead, DOD provided only general information to Congress on  the assumptions and cost model used without specific details on how costs  were developed or the effect of assumptions used on the resulting cost  estimates. Consequently, we believe it is difficult for Congress to evaluate  the cost estimates DOD provided and that it may be unwise to rely on them  for assessing the potential liability associated with contamination on  operational ranges. Reliable cost estimates can be a critical piece of  information for DOD and Congress when considering the potential costs  versus benefits of closing operational ranges or entire installations.  However, such estimates must be based on accurate data that, in terms of  ranges, begins with a complete and accurate operational range inventory.
DOD installations have conducted little or no sampling for perchlorate  under DOD’s perchlorate policy, and DOD has not provided specific  funding to the services to conduct the sampling that is required by its  policy. Available information indicates that testing for perchlorate on  installations has been limited and is specifically needed at facilities that are  or were involved in research, manufacturing, testing, and disposal of  munitions. DOD’s decision not to provide specific funding to the services  for sampling hampers the ability of DOD, as well as EPA and the states, to  collect better data on the extent and nature of possible perchlorate  contamination on military installations. Such information could be  important to regulators when determining if there is a potential public  health risk from perchlorate and deciding what, if any, actions might be  warranted. Further, the lack of such information impedes DOD and  congressional efforts for planning and budgeting  future cleanup that may  be required if federal or state standards regulating perchlorate are adopted.
section_title: Recommendations for Executive Action
paragraphs: In order to the assist Congress, EPA, and state regulators in assessing and  planning for the cleanup of contamination associated with military  munitions at operational ranges, we are making the following two  recommendations:   To improve congressional oversight of DOD and its operational ranges,  including providing Congress with more realistic estimates of the  potential liability associated with cleaning up contamination related to  the use of military munitions, we recommend that DOD, using a more  consistent estimating methodology, use its most complete operational  range inventory to revise its cost estimates for the cleanup of  operational ranges. The revised estimates should include an explanation  of the basis and scope on which the inventory was conducted, and how  the cost estimates were calculated. The estimates should be  accompanied by a detailed description of how costs were developed,  such as where estimates and assumptions were used, the basis of and  rationale for any assumptions used, and an explanation as to how such  assumptions affected cost figures.
To develop information needed by Congress, EPA, and the states, such  as the location and amount of perchlorate contamination, when  deciding what, if any, actions are warranted to address such  contamination, we recommend that DOD, acting under its revised  perchlorate sampling policy, provide specific funding for comprehensive  sampling at sites where no prior sampling has been conducted, yet  perchlorate contamination is likely and human exposure is possible  based on the sites’ prior or current use.  To help identify possible sites of  perchlorate contamination, we recommend DOD consolidate and  review sampling data previously collected by installations under  environmental laws governing the release or disposal of various  hazardous substances.
section_title: Agency Comments and Our Evaluation
paragraphs: In its May 6, 2004, letter, DOD disagreed with our findings and  recommendations. DOD also provided technical comments and  clarifications that we incorporated in the report, as appropriate.
DOD disagreed with our conclusion that it did not have a comprehensive  policy requiring sampling or cleanup of munitions constituents on  operational ranges, and that it generally has not taken actions to clean up  contaminants. In its letter, DOD cited specific policies in place requiring the  services to address the release of munitions constituents. However, the  guidance DOD cited pertains only to the migration of munitions  constituents off-range and the reporting of environmental liabilities, but  does not address the sampling or cleanup of munitions constituents found  on operational ranges that are the subject of this report. Further, DOD’s  letter states that it is responding to munitions constituents at 23  installations and ranges. We acknowledge that DOD is sampling for, and in  some cases, cleaning up munitions constituents when directed to do so by  EPA or a state environmental agency under various environmental laws. In  reviewing the data provided by DOD, however, we found that only 2 of the  installations they cited had operational ranges and both of those were  being cleaned up because of EPA direction or a court order. At the 12 other  installations with active ranges, half of them had sampled or were sampling  for munitions constituents as a result of EPA or state environmental agency  requests, RCRA requirements, or cleanup associated with Superfund  hazardous waste sites. None of these installations, however, were cleaning  up the munitions constituents found as a result of sampling.
DOD disagreed with our assessment that its inventory data and cost  estimates were questionable and said it was not necessary to revise its cost  estimates because inventory data used to develop the estimates were  “accurate within reason.” In its comments, DOD stated that it was not  required to use validated costing assumptions, or a consistent estimating  methodology, because the fiscal year 2002 National Defense Authorization  Act provided that the standard for the report of liabilities did not apply to  DOD’s cost estimates. Although the act allowed DOD to develop cost  estimates that did not meet the same standards as required for the report of  liabilities in DOD’s annual financial statement, we believe that DOD had a  responsibility to provide Congress with useful information by making a  reasonable attempt to prepare accurate and complete estimates, including  assuring that its assumptions were valid. However, as our report sets out,  the inconsistencies in how DOD collected and analyzed data on operational  ranges raise questions about the reliability of DOD’s inventory. Specifically,  DOD did not provide Congress with a detailed description of how the costs  were prepared and an explanation of where site-specific data were used in  place of assumptions, why specific and different assumptions were used by  the services, and how assumptions affected the overall cost estimates.  Without DOD’s supporting data and analysis, it is difficult for Congress to  evaluate the accuracy or validity of the cost estimates DOD provided and it  may be unwise to rely on them for assessing the potential liability  associated with contamination on operational ranges.
DOD disagreed with our recommendation that it needed to develop new  cost estimates for cleaning up operational ranges, stating that it is  developing a system for providing auditable data that meets the standards  for the report of liabilities and is actively assessing its ranges for potential  munitions constituent migration to off-range areas. However, the  requirement in the National Defense Authorization Act for fiscal year 2002  was to report estimated costs to clean up operational ranges, not the costs  to respond to or clean up constituent migration off-range. In its letter to  GAO, DOD also questioned whether decision makers would find useful an  estimated cost to clean up operational ranges and asserted that it is not  required to develop cleanup estimates for operational ranges until such  costs become probable and estimable by accounting standards. We  disagree with DOD’s view of the information and its usefulness to  Congress. Congress on two occasions asked DOD to provide just such  information. Specifically, the 2002 Defense Authorization Act required that  DOD report this information. In addition, the Senate Committee on Armed  Services, in its report accompanying the National Defense Authorization  Act for fiscal year 2000 (S. Rep. No. 106-50), directed DOD to provide to the  congressional defense committees a report with a complete estimate of  current and projected costs to clean up munitions constituents. In our  opinion, the authorization act’s requirement and the committee’s direction  provide ample evidence that congressional decision makers would find  such information useful.
DOD also disagreed with our recommendation that DOD provide specific  funding for sampling for perchlorate. As our report points out, DOD’s  current policy on perchlorate sampling designates funding for sampling as  a Class I high priority environmental project. This means that perchlorate  sampling is a priority for funding, along with all other high priority  environmental projects. As a result, perchlorate sampling must compete  with other high priority environmental priorities for funding and, due to  limited funds, may not be funded. The result is that while DOD policy has  designated a funding mechanism for perchlorate, DOD’s policy cannot  assure that perchlorate sampling will be funded. Simply stated, if DOD  wants to assure that installations conduct perchlorate sampling where  appropriate, then it will need to provide specific funding for this sampling.
As agreed with your office, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies of this report to the  appropriate congressional committees, the Secretary of Defense, and other  interested parties. We will also make copies available to others upon  request. In addition, the report will be available at no charge on the GAO  Web site at http://www.gao.gov.
If you or your staffs have any questions, please call me at (202) 512-3841, or  Edward Zadjura at (202) 512-3841. Key contributors to this report are listed  in appendix V.
section_title: Safety, Environmental, and Human Health Risks
paragraphs: Military munitions can pose risks to public safety, human health, and the  environment. Unexploded ordnance poses a risk of physical injury to those  who encounter it. Military munitions may also pose a health and  environmental risk especially on ranges located in ecologically sensitive  wetlands and floodplains because their use and disposal may release  constituents that may contaminate soil, groundwater, and surface water.  More than 200 chemical munitions constituents are associated with  ordnance and its use. When exposed to some of these constituents, humans  potentially face long-term health problems, such as cancer and damage to  the heart, liver, and kidneys.
subsections: section_title: Munitions Constituents of Greatest Concern
paragraphs: Of the more than 200 chemical munitions constituents associated with  ordnance and its use, DOD considers 20 to be of greatest concern because  of their widespread use and potential environmental impact. The 20  munitions constituents, taken from DOD’s Fiscal Year 2002 Defense  Environmental Restoration Program Annual Report to Congress, are  Trinitrotoluene (TNT),  Octahydro-1,3,5,7-tetranitro-1,3,5,7-tetrazocine (HMX),  4-Nitrotoluene,  Hexahydro-1,3,5-trinitro-1,3,5-triazine (RDX),  1,2,3-Propanetriol trinitrate (Nitroglycerine),  Pentaerythritoltetranitrate (PETN),  N,2,4,6-Tetranitro-N-methylaniline (Tetryl) (White Phosphorus).
While many of these compounds have been an environmental concern to  DOD for more than 20 years, the current understanding of the causes,  distribution, and potential effect of constituent releases into the  environment remains limited. The nature of the potential effect, and  whether it poses an unacceptable risk to human health and the  environment, depends upon the dose, duration, and pathway of exposure,  as well as the sensitivity of the exposed populations. The link between  constituents and their potential health effects is not always clear and  continues to be studied.  Table 6 describes some of the potential health  effects of five of the munitions constituents of greatest concern.
section_title: Scope and Methodology
paragraphs: You asked us to determine (1) how DOD identified the location and last  active use of all operational ranges and the basis for DOD’s cost estimates  for cleaning up those ranges; and (2) DOD’s policy on sampling for  contaminants linked to the use of ordnance on operational ranges and,  where munitions-related contaminants have been detected, what  corrective actions the services have taken. Specifically, you asked us to  focus on DOD’s actions with regard to perchlorate.
To determine how DOD identified the location and last active use of all  operational ranges, we reviewed the services’ inventory data and  interviewed service headquarters officials to determine how the  inventories were conducted and the reliability of the data collected. We  assessed the reliability of the services’ data (1) by reviewing existing  information about the data and the processes that produced them and (2)  by interviewing DOD officials knowledgeable about the data. We  determined that data on the number of operational ranges and acreage  were sufficiently reliable to include in our report; however, we determined  that data on range characteristics were unreliable. Although we found the  data on range characteristics to be unreliable, we present the data for  informational purposes. To determine the basis for DOD’s cost estimates  for cleaning up operational ranges, we reviewed the services’ estimated  costs, supporting analyses, and calculations, and interviewed service and  DOD officials on the scope and methodology used to develop cost  estimates.
To identify DOD’s policy on sampling for constituents linked to the use of  ordnance on operational ranges, we reviewed DOD’s and the service’s  policies related to the sampling and cleanup of potential contaminants and  specifically their policies on perchlorate. We also interviewed officials at  both headquarters and several installations on the implementation of DOD  and service policies. To report on what actions the services have taken with  regard to munitions constituents and perchlorate, we visited seven DOD  installations where perchlorate had been detected and discussed what  efforts have taken place, or were planned, to respond generally to  munitions-related contaminants and specifically for perchlorate. We  selected installations based on available data but were unable to determine  the total number of installations reporting perchlorate contamination. We  selected installations where generally high levels of perchlorate had been  detected or, in one case, where perchlorate had contaminated a local  municipal water supply. We also based our selection on the desire to  include at least two installations from each military department and  installations from different states or geographic locations in order to  provide a mix of services and state agencies. (See table 7 for a listing of the  installations we visited.)
During our visits, where possible, we observed the areas of contamination  as well as any cleanup demonstration projects under way. To identify what  levels of contamination had been detected at DOD installations, we first  obtained various summary schedules and lists of active and closed DOD  and non-DOD sites with suspected or detected perchlorate contamination  from both EPA and DOD. Because DOD has only recently begun to collect  data on perchlorate, none of the listings we obtained included all  installations. Further, most lists did not generally contain current data and  were incomplete. Additionally, much of the data was redundant, with the  same installations appearing on more than one list. Prior to selecting an  installation to visit, therefore, we contacted service officials to verify that  perchlorate contamination had, in fact, been detected. Our observations  about perchlorate contamination and response actions at these  installations are not generalizable to all military installations.
section_title: Installations That Were Cleaning Up Perchlorate as a Result of Demonstration Projects
paragraphs: Although we found no installations were cleaning up perchlorate, two  installations we visited were conducting or had conducted demonstration  projects of new technologies to clean up perchlorate, in anticipation of  future cleanup requirements.
subsections: section_title: Edwards Air Force Base
paragraphs: In May 2003, Edwards Air Force Base, in California, began a demonstration  project to remove perchlorate from groundwater. Edwards officials said  the installation funded the project because the Air Force is DOD’s lead  agency for perchlorate-related efforts and expected to help develop  perchlorate treatment technologies. Edwards first detected perchlorate on  the installation in 1997, while testing for other contaminants, and has  detected perchlorate at 10 sites on the installation. Perchlorate  contamination of 160,000 parts per billion was detected at one site where  the source of the contamination is attributed to the use of perchlorate by  various research facilities beginning about 1945. On this site the Air Force  constructed a well field and project treatment facility. The demonstration  project uses resin beads, which act like a magnet to pull perchlorate out of  the water. Four wells extract groundwater that is discharged into a storage  tank and then pumped through treatment equipment containing the resin.  Treated groundwater is returned to the aquifer through five injection wells.   Plans are to operate the project through July 2005. Currently, Edwards  officials report that perchlorate continues to be removed to nondetectable  levels, or less than 1 part per billion.
section_title: Naval Surface Warfare Center, Indian Head
paragraphs: In 2002, the Naval Surface Warfare Center, Indian Head, in Maryland,  funded a field demonstration project using naturally occurring  microorganisms, or bacteria, that break down or consume perchlorate.  Navy officials first became concerned about perchlorate in 1998 when they  learned of widespread perchlorate contamination at DOD sites in  California. At that time, the installation regularly drained perchlorate- contaminated water into ditches and two bordering rivers. In 2001, Navy  officials sampled and detected a shallow and well-defined plume of  perchlorate contamination located in an area where the Navy once cleaned  small rocket motors using a high-pressure wash. Perchlorate levels  detected in the area ranged from 8,000 to 430,000 parts per billion. On this  site in early 2002, the Navy installed two extraction wells, two injection  wells, and nine groundwater monitoring wells. Groundwater was removed  from the site, mixed with a lactate and a carbonate/bicarbonate liquid  mixture, and then reinjected into the aquifer. After 20 weeks, perchlorate  levels were reduced by more than 95 percent in eight of the nine monitoring  wells. According to Navy officials, the mixture acted as an oxidizer to  stimulate microorganisms that consumed the perchlorate. Officials said  they plan to reuse the equipment to field test the technology at another site  in an attempt to clean soil contaminated with perchlorate.
section_title: Installations That Identified Perchlorate as a Result of Munitions Research, Manufacturing, Testing, and Disposal Activities
paragraphs: We visited installations that had operational ranges and detectable levels of  perchlorate but found the perchlorate contamination was generally not due  to training, but rather due to prior and ongoing research, testing,  manufacturing, and disposal of rocket motors and propellant waste on  operational ranges and other parts of the installations.
subsections: section_title: Edwards Air Force Base
paragraphs: Perchlorate contamination was detected at 10 sites on Edwards Air Force  Base beginning in 1997. Officials attributed all detected perchlorate  contamination to rocket propellant manufacturing, research, development,  and testing, and not to the use of munitions during training. The maximum  perchlorate contamination level detected was 160,000 parts per billion in  groundwater at one site. Officials said no live bombs had been exploded on  Edwards Air Force Base ranges since 1952, and some ranges where bombs  were exploded have been closed. Perchlorate is not used as part of current  range activities, and Edwards Air Force Base does not test for  contaminants on operational ranges, installation officials said.
section_title: Holloman Air Force Base
paragraphs: In March 1999, after a rainstorm, the U.S. Geological Survey sampled for  perchlorate in a normally dry riverbed at Holloman Air Force Base, in New  Mexico, and detected contamination of 16,000 parts per billion. During  periods of rain, the river flows from the installation to the neighboring  White Sands National Monument. The contamination was found on the  installation near a former munitions operations site and rocket sled. Air  Force officials said it was unlikely that the contamination was due to  training. They attributed the perchlorate contamination to munitions  research and testing in the 1960s and 1970s. Officials at White Sands  National Monument attributed the perchlorate contamination to spent  rocket motors stacked near the river and a high-speed rocket sled used to  test the effects of acceleration. DOD and New Mexico’s state  environmental agency sampled the riverbed and surrounding area again in  1999 and 2000 but did not find the high concentration of perchlorate  previously detected. Air Force officials said they believed the 16,000 parts  per billion detected in 1999 was an anomaly.
section_title: Naval Surface Warfare Center, Indian Head
paragraphs: At the time of our visit, officials at the Naval Surface Warfare Center, Indian  Head, in Maryland, reported they detected perchlorate contamination at  five sites on the installation, of which three were landfills, one was a metal  parts disposal site, and one was a metal parts degreasing tank site. Indian  Head detected maximum perchlorate concentrations between 88 and  450,000 parts per billion in the soil at two of the three landfills. At the third  landfill, a perchlorate concentration of 2,000 parts per billion was detected  in the groundwater. However, none of the contamination detected was  attributed to the use of perchlorate during training exercises on operational  ranges.
section_title: Redstone Arsenal
paragraphs: As of March 2004, Redstone Arsenal, in Alabama, detected perchlorate  contamination in the groundwater at 2 sites and in surface water and soil at  11 other sites. Redstone Arsenal officials attributed contamination to  various past production, maintenance, and disposal activities at a number  of sites, including at open burning areas used to incinerate waste rocket  motor propellant, burning trenches used to incinerate solid material  contaminated with rocket propellant, a rocket engine plant, motor  degreasing and trimming areas, and a propellant waste storage area.  Perchlorate contamination of about 20 parts per billion was also detected  in ground and surface water outside the installation. The highest  concentration levels detected in groundwater on Redstone installations  have ranged from 106,000 to 160,000 parts per billion and the highest  concentration levels detected in surface water have ranged from 377 to  1,700 parts per billion. Although Redstone Arsenal has conducted training  on the installation, none of the contamination detected has been attributed  to the use of perchlorate during training exercises.
section_title: White Sands Missile Range
paragraphs: White Sands Missile Range, in New Mexico, detected perchlorate  contamination at two sites beginning in 1999. At one site, sampling  detected perchlorate concentrations up to 25,000 parts per billion. Officials  said they were unsure of the precise cause of the contamination but said  they initially believed it was due to an open burning and detonation facility  used in the 1950s to incinerate rocket motors. However, officials also said  that the contamination plume was uphill from where the open burning and  detonation site is believed to have been, so that the contamination may be  generally due to previous testing of hazardous materials in the area.  Perchlorate was also found at the former site of a high-energy laser system  test facility. Perchlorate contamination detected has been as high as 118  and 295 parts per billion in some wells. Officials said the contamination  might be due to open ground burning of expended test items, or residue  from actual tests, conducted prior to 1995. Officials said they planned to  conduct more sampling to precisely identify the source of the perchlorate  but did not attribute any of the perchlorate detected to training exercises  on operational ranges.
section_title: Naval Air Weapons Station, China Lake
paragraphs: At the time of our visit in October 2003, the Naval Air Weapons Station,  China Lake, in California, had detected perchlorate at five sites on the  installation. Perchlorate contamination was predominantly found in  drainage and waste disposal areas, most likely the result of research on  propellants and explosives, and residue from the manufacture of  propellants. Installation officials said that since the 1960s, thousands of  pounds of perchlorate-based propellant have been stored and tested on  China Lake. In July 2003, installation officials sampled and detected  perchlorate concentrations of 778 and 921 parts per billion at two wells and  at a drainage site. However, none of the contamination detected is  attributed to the use of munitions during training exercises on operational  ranges.
section_title: Comments from the Department of Defense
section_title: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contacts
section_title: Staff Acknowledgments
paragraphs: In addition to those named above, Christine Frye, Roderick Moore, David  Noguera, and Doreen Feldman made key contributions to this report. John  Delicath and Amy Webbink also contributed to this report.
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