Military Munitions: DOD Needs to Develop a Comprehensive Approach for Cleaning Up Contaminated Sites
Published: 2003-12-19T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Over 15 million acres in the United States are suspected of being, or known to be, contaminated with military munitions. These sites include ranges on closing military installations, closed ranges on active installations, and formerly used defense sites. Under the Defense Environmental Restoration Program, established in 1986, the Department of Defense (DOD) must identify, assess, and clean up military munitions contamination at these sites. DOD estimates these activities will cost from $8 billion to $35 billion. Because of the magnitude of DOD's cleanup effort, both in terms of cost and affected acreage, as well as the significant public safety, health, and environmental risks that military munitions may pose, The Ranking Minority Member of the House Committee on Energy and Commerce asked us to evaluate (1) DOD's progress in implementing its program to identify, assess, and clean up military munitions sites and (2) DOD's plans to clean up remaining sites in the future.
section_title: What GAO Found
paragraphs: DOD has made limited progress in its program to identify, assess, and clean up sites that may be contaminated with military munitions. While DOD had identified 2,307 potentially contaminated sites as of September 2002, DOD officials said that they continue to identify additional sites and are not likely to have a firm inventory for several years. Of the identified sites, DOD had initially determined that 362 sites required no further study or cleanup action because it found little or no evidence of military munitions. For 1,387 sites, DOD either has not begun or not completed its initial evaluation or determined that further study is needed. DOD has completed its assessment of 558 sites, finding that 475 of these required no cleanup action. The remaining 83 sites required some cleanup action, of which DOD has completed 23. DOD does not yet have a complete and viable plan for cleaning up military munitions at remaining potentially contaminated sites. DOD's plan is lacking in several respects. Essential data for DOD's plan may take years to develop. Not all the potential sites have been identified, and DOD has set no deadline for doing so. Also, DOD intends to use a new procedure to assign a relative priority for the remaining 1,387 sites, but it will not complete the reassessments until 2012. Until these are done, DOD cannot be assured that it is using its limited resources to clean up the riskiest sites first. DOD's plan relies on preliminary cost estimates that can change greatly and the reallocation of funds that may not be available. For example, the Air Force used estimated, not actual, acreage to create its cost estimates, limiting the estimate's reliability and DOD's ability to plan and budget cleanup for these sites. Also, DOD expects additional funds will become available for munitions cleanup as other DOD hazardous waste cleanup efforts are completed. However, some of these efforts are behind schedule; therefore, funds may not become available as anticipated. DOD's plan does not contain goals or measures for site assessment and cleanup. DOD recently established a working group tasked with developing agencywide program goals and performance measures, but not service-specific targets, limiting DOD's ability to ensure that the services are making progress in cleaning the potentially contaminated sites and achieving the overall goals of the program as planned.

section_title: Letter
paragraphs: Over 15 million acres in the United States are known to be or are suspected  of being contaminated with military munitions, which include unexploded  ordnance, discarded military munitions, and munitions constituents such  as propellants or other chemicals. These sites, which are no longer in use,  include closed ranges on active installations, ranges on military  installations that are being closed (closing sites), and formerly used  defense sites. Much of the land on which these sites are located has been  or will be converted to nonmilitary uses such as farming, residential or  commercial development, and recreation. The Department of Defense  (DOD) estimates that identifying, assessing, and cleaning up contamination  from military munitions at such sites will cost from $8 billion to $35 billion  and could take more than 75 years. Within DOD, cleanup of sites on active  or closing installations is the responsibility of the military service—Air  Force, Army, Navy, or Marine Corps—that currently owns the land. The  U.S. Army Corps of Engineers (Corps) is responsible for executing the  cleanup of formerly used defense sites.
Military munitions can pose risks to public safety, human health, and the  environment. Unexploded ordnance poses a potential explosive hazard and  risk of personal injury to those who encounter it. The Environmental  Protection Agency, in September 2001, using a DOD database and other  sources, identified at least 126 incidents involving civilians who were exposed to unexploded ordnance over the past 83 years, which resulted in  65 fatalities and 131 injuries. The risk of such exposures is expected to  grow with an increase in development and recreational activities on land  once used by the military for munitions related activities (e.g., live fire  testing and training). In addition, human exposure to munitions  constituents such as trinitrotoluene (TNT) and perchlorate may cause long- term health problems, such as cancer and damage to the heart, liver, and  kidneys. However, the link between such constituents and any potential  health effects is not always clear and continues to be studied. (See app. I  for a list of common munitions constituents and potential health effects.)   Military munitions may also pose an environmental risk because their use  and disposal may release constituents that could contaminate soil,  groundwater, and surface water. Former ranges on which munitions- related activities were conducted and which are known or suspected to  contain military munitions are in a variety of locations, including near  ecologically sensitive wetlands, surface waters, and floodplains. While  many constituents have been an environmental concern to DOD for more  than 20 years, the current understanding of the causes, distribution, and  potential impact of constituent releases into the environment remains  limited. The nature of these impacts, and whether they pose an  unacceptable risk to human health and the environment, depend upon the  dose, duration, and pathway of exposure, as well as the sensitivity of the  exposed populations. Until recently, DOD has focused primarily on  mitigating the public safety risk associated with unexploded ordnance, but  it is now giving additional attention to environmental and health concerns  posed by munitions constituents.
Under the Defense Environmental Restoration Program, established in  1986, DOD is required to identify, investigate, and clean up environmental  contamination and other hazards at active and closing installations, as well  as at formerly used defense sites. The program is organized into three  categories that focus on DOD’s primary goals:  (1) identification and  cleanup of contamination from hazardous substances, pollutants, and  contaminants; (2) demolition and removal of unsafe buildings and  structures; and (3) correction of other environmental damage, such as  detection and disposal of military munitions. Most of DOD’s past focus had  been on identifying and cleaning up contamination from hazardous  substances. To better focus DOD’s efforts on identifying, assessing, and  cleaning up sites containing military munitions, DOD established the  Military Munitions Response program in September 2001. Subsequently, in  December 2001, the Congress passed the National Defense Authorization  Act for Fiscal Year 2002, which among other things, required DOD to  develop an initial inventory of sites that are known or suspected to contain  military munitions and a comprehensive plan for cleaning up these sites. Of  the $1.9 billion budgeted by DOD for environmental cleanup in fiscal year  2002, approximately $113 million was designated for sites with military  munitions. In fiscal years 2003 and 2004, DOD designated approximately  $115 million and $89 million, respectively, for sites with military munitions.
In deciding what actions, if any, are needed to clean up a site identified as  potentially contaminated with military munitions, DOD generally follows  the process established for cleanup actions under the Comprehensive  Environmental Response, Compensation, and Liability Act of 1980  (CERCLA). CERCLA, as amended, governs the cleanup of hazardous waste  sites, including contamination on military installations. After identifying a  potential military munitions site, the appropriate DOD military service or  the Corps performs a preliminary assessment, during which DOD  determines if military munitions may be present and if further study or  cleanup action is needed. If necessary, DOD may conduct a site  investigation to better identify the types and extent of potential hazards  present. For specific areas suspected to contain military munitions, DOD  surveys the land and evaluates and selects alternatives, in consultation  with stakeholders, for addressing the potential hazards. These cleanup  alternatives could include removing the military munitions, limiting public  contact with the site through signs and fences, or determining that no  further action with regard to the site is warranted.  After implementing the  chosen cleanup alternative, DOD periodically monitors the site and reviews  the alternative chosen to ensure its continued effectiveness.
Because of the magnitude of DOD’s cleanup effort, both in terms of cost  and affected acreage, as well as the significant public safety, human health,  and environmental risks posed by military munitions, you asked us to  evaluate (1) DOD’s progress in implementing its program to identify,  assess, and clean up sites containing military munitions and (2) DOD’s  plans to clean up remaining sites in the future.
To evaluate DOD’s progress in identifying, assessing, and cleaning up  military munitions, we reviewed and analyzed DOD’s database for sites  identified under the Military Munitions Response program as of September  30, 2002, the end of their most recent reporting cycle. We assessed the  reliability of relevant fields in this database by electronically testing for  obvious errors in accuracy and completeness, reviewing information about  the data and the system that produced them, and interviewing agency  officials knowledgeable about the data. When we found inconsistencies, we  worked with DOD and military service officials to correct the discrepancies  before conducting our analyses. We determined that the data needed for  our analyses were sufficiently reliable for the purposes of our report. We  also reviewed project files from 38 of the 75 sites where, according to  DOD’s database, cleanup action is either complete or under way. These  files represented 52 percent of the 23 sites with a completed cleanup action  and 50 percent of the 52 sites with a cleanup action under way. We used our  file reviews to develop case examples of changes in estimated costs to  complete cleanup over time and cleanup actions taken. These case  examples are for illustration only. We conducted our work between  November 2002 and October 2003 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: To better focus its munitions cleanup activities under the Defense  Environmental Restoration Program, DOD established the Military  Munitions Response program in September 2001. The objectives of the  program include compiling a comprehensive inventory of military  munitions sites, developing a prioritization protocol for sequencing work at  these sites, and establishing program goals and performance measures to  evaluate progress. In December 2001, shortly after DOD established the  program, the Congress passed the National Defense Authorization Act for  Fiscal Year 2002, which among other things, required DOD to develop an  initial inventory of sites that are known or suspected to contain military  munitions by May 31, 2003, and to provide annual updates thereafter. DOD provides these updates as part of its Defense Environmental Restoration  Program Annual Report to Congress.
To clean up potentially contaminated sites, DOD generally follows the  process established for cleanup actions under CERCLA, which includes the  following phases and activities:    Preliminary Assessment—Determine whether a potential military  munitions hazard is present and whether further action is needed.
Site Investigation—Inspect the site and search historical records to  confirm the presence, extent, and source(s) of hazards.
Remedial Investigation/Feasibility Study or Engineering  Evaluation/Cost Analysis—Determine the nature and extent of  contamination; determine whether cleanup action is needed and, if so,  select alternative cleanup approaches. These could include removing  the military munitions, limiting public contact with the site through  signs and fences, or determining that no further action is warranted.
Remedial Design/Remedial Action—Design the remedy and perform  the cleanup or other response.
Long-Term Monitoring—Periodically review the remedy in place to  ensure its continued effectiveness, including checking for unexploded  ordnance and public education.
For sites thought to be formerly used defense sites, the Corps also  performs an initial evaluation prior to the process above. In this initial  evaluation, called a preliminary assessment of eligibility, the Corps  determines if the property is a formerly used defense site. The Corps makes  this determination based on whether there are records showing that DOD  formerly owned, leased, possessed, operated, or otherwise controlled the  property and whether hazards from DOD’s use are potentially present. If  eligible, the site then follows the CERCLA assessment and cleanup process  discussed earlier. When all of these steps have been completed for a given  site and long-term monitoring is under way, or it has been determined that  no cleanup action is needed, the services and the Corps consider the site to  be “response complete.”
section_title: DOD Has Made Limited Progress in Its Program to Identify, Assess, and Clean Up Potentially Contaminated Sites
paragraphs: While DOD has identified 2,307 potentially contaminated sites as of  September 2002, the department continues to identify additional sites, and  it is not likely to have a firm inventory for several years (see table 1 for the  distribution of these sites by service). Of the identified sites, DOD  determined that 362 sites require no further study or cleanup action  because it found little or no evidence of military munitions. For 1,387 sites,  DOD either has not begun or not completed its initial evaluation, or has  determined that further study is needed. DOD has completed an  assessment of 558 sites, finding that 475 of these required no cleanup  action. The remaining 83 sites require some cleanup action, of which DOD  has completed 23.
DOD had identified 2,307 sites potentially contaminated with military  munitions, as of September 30, 2002, and it continues to identify additional  sites. (Fig. 1 shows the distribution of these sites by state.)  DOD officials  acknowledge that they will not have a firm inventory for several years. For  example, as of September 30, 2002, the Army had not completed a detailed  inventory of closed ranges at 86 percent of active installations; the 105 sites  identified by the Army represented sites on only 14 percent of the Army’s  installations. The Army is working to identify sites on the remaining  installations and plans to have 40 percent of its installations accounted for  by the next Defense Environmental Restoration Program Annual Report to  Congress in spring 2004. Similarly, the Corps recently identified 75  additional sites to be included in the inventory as a result of its effort to  reevaluate sites previously determined not to need further action after the  initial evaluation. Because not all of the sites have been identified, DOD has  only a preliminary idea of the extent of cleanup that will be needed. To help  complete the identification process, DOD has developed a Web site that  stakeholders, such as states, tribes, and federal regulators, can use to  suggest additions and revisions to the inventory. DOD plans to update the  inventory in its future Defense Environmental Response Program Annual  Report to Congress using, in part, the information collected from this Web  site.
Of the 2,307 sites identified, DOD has determined, based on an initial  evaluation, that 362 do not require any further DOD action (see fig. 2).  However, these 362 sites are formerly used defense sites, and the Corps’  evaluation of these sites was less comprehensive than other evaluations  conducted by DOD under the CERCLA process. In making its  determinations, the Corps conducted a preliminary assessment of  eligibility and determined that the potential for military munitions hazard  was not present. As a result of this determination, the sites were not  evaluated further. The Corps is in the process of reviewing these  determinations with local stakeholders to ensure that there was a sound  basis for the original determination. It has recently decided that some of  these sites need to be reassessed to determine if cleanup is needed.
Of the 1,945 sites that required further action, DOD has either not begun or  has not completed its study, or has determined that further study is needed,  for 1,387 sites (see fig. 3). For example, 241 Air Force and 105 Army sites at  closed ranges on active installations have not been evaluated. For other  sites, primarily formerly used defense sites, DOD has completed its initial  evaluation and determined that further investigation is needed.
DOD has completed its assessment of 558 sites, nearly all of which are  ranges on formerly used defense sites or closing installations, and  determined that no cleanup action was needed for 475; the remaining 83  sites required some level of cleanup action. Of the 83 sites that required  cleanup action, 60 have cleanup action planned or under way and 23 are  complete.  Actions taken at these 23 sites have been varied and include  surface and subsurface removal of munitions, and institutional controls,  such as the posting of warning signs or educational programs. See figure 4  for examples of cleanup actions at Military Munitions Response program  sites.
section_title: DOD Does Not Have a Complete and Viable Plan for Assessing and Cleaning Up Potentially Contaminated Sites
paragraphs: In DOD’s Fiscal Year 2002 Defense Environmental Restoration Program  Annual Report to Congress, DOD identified several elements integral to the  success of the Military Munitions Response program:  compiling a  comprehensive inventory of sites; developing a new procedure to assess  risk and prioritize sites; ensuring proper funding for accurate planning and  program execution; and establishing program goals and performance  measures. While DOD has established the basic framework to address  these elements, DOD’s plan is lacking in three key respects. First, essential  data for DOD’s plan may take years to develop. Second, DOD’s plan is  contingent upon preliminary cost estimates that may change significantly  and a reallocation of funds that may not be available. Finally, DOD’s plan  lacks specific goals and performance measures to track progress.
subsections: section_title: Essential Data for DOD’s Plan May Take Years to Develop
paragraphs: DOD’s inventory of potentially contaminated sites serves as the basis for  other elements of its plan, yet this inventory is incomplete. DOD’s inventory  of 2,307 sites includes only those identified through September 30, 2002. As  previously discussed, according to DOD officials, this inventory is not final;  and DOD has not set a deadline to complete it. According to DOD, most of  the ranges on formerly used defense sites and on military installations that  are being closed have been identified and are being assessed or cleanup  action is under way. The ranges yet to be identified are primarily located on  active installations. For example, the Army, as of September 30, 2002, had  completed a detailed inventory of potentially contaminated sites on only 14  percent of its active installations. Because the inventory serves as the basis  for other elements of the plan, such as budget development and  establishing program goals, most sites must first be identified in order for  DOD to have a reasonable picture of the magnitude of the challenge ahead  and to plan accordingly.
Furthermore, DOD intends to use a new procedure to reassess the relative  risk and priority for 1,387 sites needing further study and any new sites  identified as part of the continuing inventory effort, but DOD is not  scheduled to complete these reassessments until 2012. DOD recently  developed this procedure for assigning each site in the inventory a priority  level for cleanup action, based on the potential risk of exposure resulting  from past munitions-related activities. Under this procedure, DOD plans to  reevaluate the 1,387 sites for three potential hazard types:  (1) explosive  hazards posed by unexploded ordnance and discarded military munitions,  (2) hazards associated with the effects of chemical warfare material, and  (3) chronic health and environmental hazards posed by munitions  constituents. Once assessed, each site’s relative risk-based priority will be  the primary factor determining future cleanup order. DOD plans to require  assessment of each site on the inventory for at least one of these hazard  types by May 31, 2007, and for all three hazard types by May 31, 2012. Until  all three hazard types are fully assessed, DOD cannot be assured that it is  using its limited resources to clean up those sites that pose the greatest risk  to safety, human health, and the environment.
section_title: DOD’s Plan Relies on Preliminary Cost Estimates That Can Change Significantly and a Reallocation of Funds That May Not Be Available
paragraphs: DOD’s plan to identify and address military munitions sites relies on  preliminary cost estimates that were developed using incomplete  information. The majority of the site estimates were developed using a  cost-estimating tool that incorporates variables, such as the affected  acreage; types, quantity, and location of munitions; and future land use.  These variables can have a significant impact on cost, according to DOD.  However, detailed site-specific information was not available for all sites.  For example, as mentioned earlier, 105 Army and 241 Air Force sites at  closed ranges on active installations have not had an initial evaluation. As a  result, the Air Force used estimated, not actual, acreage figures, including  assumptions regarding the amount of acreage known or suspected of  containing military munitions when preparing its cost estimates. Because  changes in acreage can greatly impact the final cost of site assessment and  cleanup action, the estimates produced for these sites are likely to change  when estimates based on more complete data or the actual cost figures are  known. The following examples illustrate how cost estimates can change  during the life of the cleanup as better information becomes available:  Camp Maxey was a 41,128-acre Army post in Texas used from 1942 to  1945 for training infantry in live fire of weapons including pistols, rifles,  machine guns, mortars, bazookas, and antitank guns. The Corps  confirmed the presence of unexploded ordnance, and in 2000, estimated  the cleanup cost for the land at $45 million. In DOD’s Fiscal Year 2002  Defense Environmental Restoration Program Annual Report to  Congress, the estimated total cost of cleanup had grown to $130 million.  A June 2003 cost estimate showed a decrease in total cost to about $73  million, but still 62 percent more than the original cost estimate in 2000.  The main factors behind these shifting cost estimates, according to the  project manager, were changes in the acreage requiring underground  removal of ordnance and changes in the amount of ordnance found.
Fort McClellan, Alabama, was among the installations recommended for  closure under DOD’s base realignment and closure effort in 1995. This  site had been used since the Spanish American War (1898), including as  a World War I and II training range upon which grenades, mortars, and  antiaircraft guns, were used. An April 2002 cost estimate prepared for  one site on Fort McClellan requiring cleanup showed the anticipated  cost of clearing the land of munitions as $11,390,250. A subsequent cost  estimate prepared in May 2003, showed the cost of clearing this site at  $22,562,200. According to the Army, the increase in estimated costs  reflects a change in the final acreage recommended for clearance and  the extent to which buried munitions would be searched for and  removed.
Moreover, until DOD and stakeholders agree upon a cleanup action, it is  often difficult for them to predict the extent of the cleanup action required  and cost estimates can change because of the cleanup action implemented  at the site. For example, at the former Indian Rocks Range in Pinellas  County, Florida, the Corps identified 178 acres that were used as an air-to- ground and antiaircraft gunnery range impact area from 1943 to 1947.  Munitions used on this shoreline site included bullets, aircraft rockets, and  small practice bombs. Much of the land had been developed, limiting the  Corps ability to pursue the alternative of searching for and removing buried  munitions. In 1995, the Corps analyzed a number of alternatives to address  munitions contamination at the site and developed cost estimates for these  alternatives. However, because the development was largely composed of  hotels, condominiums, and single-family residences, the Corps chose the  alternative of conducting a community education program. The total cost  of this alternative was $21,219. If the Corps had decided to search for and  remove the remaining munitions at this site, the cost could have  approached $3 million, according to the prepared cost analysis.
Furthermore, at an annual funding level of approximately $106 million (the  average amount budgeted or spent annually from fiscal year 2002 to fiscal  year 2004), cleanup at the remaining munitions sites in DOD’s current  inventory could take from 75 to 330 years to complete. To reduce this  timeline, DOD expects to use funds currently designated for hazardous,  toxic, and radioactive waste cleanup after these cleanups are complete.  However, these other cleanup efforts are not on schedule in all of the  services and the Corps. For example, between fiscal years 2001 and 2002,  the schedule to complete hazardous substance cleanups at formerly used  defense sites slipped by more than 6 years. As a result, anticipated funds  from completing hazardous substance cleanups at these sites may not  become available to clean up munitions sites until 2021 or later. This delay  is significant because, as of September 30, 2002, formerly used defense  sites account for over 85 percent of DOD’s total anticipated costs to  complete munitions cleanup, yet the Corps receives about 66 percent of the  total munitions cleanup funds. Delays in the availability of anticipated  funding from hazardous, toxic, and radioactive waste sites could greatly  impair DOD’s ability to accurately plan for and make progress in cleaning  up Military Munitions Response sites.
section_title: DOD’s Plan Does Not Contain Goals or Measures for Site Assessment and Cleanup
paragraphs: DOD has yet to establish specific program goals and performance  measures in its plan. Specifically, DOD has yet to identify interim  milestones and service-specific targets that will help it achieve overall  program objectives. In September 2003, 2 years after the Military Munitions  Response program was initiated, DOD established a workgroup tasked  with recommending overall goals and measures for the program, near-term  goals and measures to support its budgeting cycle for fiscal years 2006 to  2011, and a program completion date goal. DOD has asked the workgroup  to accomplish these objectives by the end of calendar year 2003. According  to DOD, these goals and measures, when developed, should help DOD  track the progress of sites through the cleanup phases, and ensure that  DOD responds to the sites with the greatest risk first. While it is important  for DOD to establish goals and measures that will track overall program  progress and ensure that the riskiest sites are assessed and cleaned up first,  DOD will not have the information it needs to do this until 2012. As we  discussed earlier, because DOD plans to reassess potentially contaminated  sites using a new risk-based prioritization procedure, until these  reassessments are complete, DOD will not have complete information on  which of the sites pose the greatest risk. Consequently, goals and measures  established in 2003 will be of limited use and may not reflect DOD’s true  priorities.
Moreover, according to DOD, the program goals and measures to be  established by the workgroup will be agencywide, and not service-specific,  although it may establish interim goals for the services and Corps.  However, DOD has not yet decided what these goals will be based on, such  as relative risk levels or cleanup phases. In the absence of service-specific  goals, each service has implemented the program with a different level of  effort. For example, the Air Force has not budgeted any funds to assess and  clean up munitions sites, nor do they plan to do so through fiscal year 2004.  As mentioned before, the Air Force also has not conducted initial  evaluations on any of its 241 sites and has little site-specific information  from which to create a reliable cost estimate. In contrast, the Army has  undertaken a comprehensive inventory of ranges that will result in detailed  site information, such as acreage and the types, quantity, and location of  munitions, that can be used to, among other things, create more robust cost  estimates. The Army has completed this comprehensive inventory on 14  percent of its installations as of September 2002, and has set a goal to  complete this effort by December 2003. This uneven effort in implementing  the Military Munitions Response program could continue through various  program phases, such as preliminary assessments and site investigations,  making it difficult for DOD to assure that each of the services and the  Corps are making progress in cleaning up their potentially contaminated  sites and achieving the overall goals of the program.
section_title: Conclusions
paragraphs: DOD has made limited progress in identifying, assessing, and cleaning up  sites known or suspected to contain military munitions. Accomplishing this  long and arduous task in a timely manner that best protects public safety,  human health, and the environment will require a comprehensive approach  that includes effective planning and budgeting. However, DOD lacks the  data needed—such as a complete inventory, up-to-date prioritization, and  reliable cost estimates—to establish a comprehensive approach. Without  such an approach for identifying, assessing, and cleaning up potentially  contaminated sites, DOD will be hampered in its efforts to achieve the  program’s objectives.
section_title: Recommendations
paragraphs: To ensure that DOD has a comprehensive approach for identifying,  assessing, and cleaning up military munitions at potentially contaminated  sites, we recommend that the Secretary of Defense revise DOD’s plan to    establish deadlines to complete the identification process and initial  evaluations so that it knows the universe of sites that needs to be  assessed, prioritized, and cleaned up;  reassess the timetable proposed for completing its reevaluation of sites  using the new risk assessment procedures so that it can more timely  establish the order in which sites should be assessed and cleaned up,  thereby focusing on the riskiest sites first; and  establish interim goals for cleanup phases for the services and Corps to  target.
In addition, after DOD has revised its comprehensive plan, we recommend  that it work with the Congress to develop realistic budget proposals that  will allow DOD to complete cleanup activities on potentially contaminated  sites in a timely manner.
section_title: Agency Comments
paragraphs: We provided DOD with a draft of this report for review and comment. In its  comments, DOD concurred with our recommendation to work with the  Congress to develop realistic budget proposals that will allow it to  complete cleanup activities on potentially contaminated sites in a timely  manner. DOD partially concurred with our recommendation to establish  deadlines to complete the identification process and initial evaluations so  that it knows the universe of sites. DOD stated that the military services  and the Corps have been working, and will continue to work, with  stakeholders to identify additional sites and add these sites to the inventory  as appropriate. DOD also stated that it believes most of the remaining sites  to be identified are located on active installations still under DOD control.  While we have clarified this point in the report, we note that the number of  formerly used defense sites identified has increased by about 75 sites since  the current inventory was completed and an unknown but possibly  significant number of sites may be added as the Army completes  identification of sites on 86 percent of its installations. These sites and  many others still need to undergo initial evaluations. Consequently, we  continue to believe that it is important for DOD to establish deadlines to  complete the identification and initial evaluations for all of the sites in its  inventory in order to establish a reasonable approximation of the future  workload it faces.
DOD also partially concurred with our recommendation to reassess the  timetable proposed for completing the reevaluation of sites using the new  risk assessment procedure. DOD stated that the military services and the  Corps would need sufficient time and resources to complete each risk  assessment. However, DOD stated that it had recently established 2010 as  the goal for completing the prioritization of sites, instead of 2012 which  was the original goal set forth in the proposed regulation. While we agree  that this is a step in the right direction, DOD should continue to look for  other opportunities to accelerate these inspections and the prioritization of  sites to help ensure that resources are being targeted toward the riskiest  sites first.
Finally, DOD partially concurred with our recommendation to establish  interim goals for cleanup phases for the services and the Corps. DOD  stated that it has established interim goals of completing all preliminary  assessments by 2007 and all site inspections by 2010, and that these goals  apply to all military components, thereby eliminating the need for separate  service-specific goals. However, DOD noted that it is working with each  military service to establish additional goals and measures to gauge  progress. While we are encouraged by DOD’s efforts in this area, we believe  that service-specific goals and measures, as they apply to the cleanup  phases, will be essential for DOD to ensure that each of the services and  the Corps are making progress in cleaning up potentially contaminated  sites and achieving the overall goals of the program.
In addition to its written comments on our draft report, DOD also provided  a number of technical comments and clarifications, which we have  incorporated in this report as appropriate. DOD’s written comments appear  in appendix III.
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; Director,  Office of Management and Budget; 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 or Edward Zadjura  at (202) 512-3841. Key contributors to this report are listed in appendix IV.
section_title: Safety, Environmental, and Human Health Risks
paragraphs: Military munitions can pose risks to public safety, human health, and the  environment. In terms of the explosive hazard, unexploded ordnance poses  an immediate safety risk of physical injury to those who encounter it.  Military munitions may also pose a health and environmental risk because  their use and disposal may release constituents that may contaminate soil,  groundwater, and surface water. Ranges contaminated with military  munitions, especially those located in ecologically sensitive wetlands and  floodplains, may have soil, groundwater, and surface water contamination  from any of the over 200 chemical munitions constituents that are  associated with the ordnance and their usage. When exposed to some of  these constituents, humans potentially face long-term health problems,  such as cancer and damage to heart, liver, and kidneys. Of these  constituents, there are 20 that are of greatest concern due to their  widespread use and potential environmental impact. Table 2 contains a  listing of these munitions constituents, and table 3 describes some of the  potential health effects of five of them.
Trinitrotoluene (TNT)  1,3-Dintrobenzene  Nitrobenzene  2,4-Dinitrotoluene  2-Amino-4,6-Dinitrotoluene  2-Nitrotoluene  2,6-Dinitrotoluene  4-Amino-2,6-Dinitrotoluene  3-Nitrotoluene  Octahydro-1,3,5,7-tetranitro-1,3,5,7-tetrazocine (HMX)  2,4-Diamino-6-nitrotoluene  4-Nitrotoluene  Hexahydro-1,3,5-trinitro-1,3,5-triazine (RDX)  2,6-Diamino-4-nitrotoluene  Methylnitrite  Perchlorate  1,2,3-Propanetriol trinitrate (Nitroglycerine)  Pentaerythritoltetranitrate (PETN)  1,3,5-Trinitrobenzene  N,2,4,6-Tetranitro-N-methylaniline (Tetryl) (White Phosphorus)
While many of these constituents have been an environmental concern to  the Department of Defense (DOD) for more than 20 years, the current  understanding of the causes, distribution, and potential impact of  constituent releases into the environment remains limited. The nature of  these impacts, and whether they pose an unacceptable risk to human  health and the environment, depend upon the dose, duration, and pathway  of exposure, as well as the sensitivity of the exposed populations. However,  the link between such constituents and any potential health effects is not  always clear and continues to be studied.
section_title: Additional Details on Our Scope and Methodology
paragraphs: The objectives of our review were to evaluate (1) DOD’s progress in  implementing its program to identify, assess, and clean up sites containing  military munitions and (2) DOD’s plans to clean up remaining sites in the  future. To evaluate DOD’s progress in identifying, assessing, and cleaning  up military munitions sites, we analyzed data provided to us by DOD’s  Office of the Deputy Undersecretary of Defense (Installations and  Environment) Cleanup Office from its database for sites identified under  the Military Munitions Response program. This information includes the  status of studies or cleanup actions, as well as cost estimates. The data are  complete as of September 30, 2002, DOD’s most recent reporting cycle, and  were used to develop DOD’s Fiscal Year 2002 Defense Environmental  Restoration Program Annual Report to Congress. We also analyzed  additional data on the status of studies or cleanup actions provided to us by  the Army Corps of Engineers (the Corps) from its database of formerly  used defense sites. We assessed the reliability of relevant fields in these  databases by electronically testing for obvious errors in accuracy and  completeness, reviewing information about the data and the system that  produced them, and interviewing agency officials knowledgeable about the  data. When we found inconsistencies, we worked with DOD and military  service officials to correct the inconsistencies before conducting our  analyses. We determined that the data needed for our review were  sufficiently reliable for the purposes of our report.
We also reviewed 38 of 75 project files at seven Corps districts where,  according to DOD’s database, site cleanup action is either complete or  under way. (See table 4 for a listing of these districts).
We selected these districts based on the number of sites where cleanup was  completed or under way and the estimated cost to complete cleanup, with  some consideration given for geographic distribution. These files  represented 52 percent of the 23 sites with a completed cleanup action and  50 percent of the 52 sites with a cleanup action under way. We used our file  reviews to develop case example of changes in estimated costs to complete  cleanup over time and cleanup actions taken. These case examples are for  illustration only.
To evaluate DOD’s plans for addressing the remaining sites, we analyzed  the plans, as well as the assumptions upon which those plans are based,  including cost and projected completion dates. In addition, we reviewed  policies and program guidance, analyzed financial data, and interviewed  program managers in DOD and the military services and the Corps.  We  conducted our work between November 2002 and October 2003 in  accordance with generally accepted government auditing standards.
section_title: Comments from the Department of Defense
section_title: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contacts
section_title: Acknowledgments
paragraphs: In addition to those named above, Jack Burriesci, Elizabeth Erdmann,  Sherry McDonald, and Matthew Reinhart made key contributions to this  report.  Also contributing to this report were Cynthia Norris, Rebecca Shea,  and Ray Wessmiller.
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section_title: To Report Fraud, Waste, and Abuse in Federal Programs
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