Environmental Contamination: Cleanup Actions at Formerly Used	 
Defense Sites (31-JUL-01, GAO-01-557).				 
								 
The U.S. Army Corps of Engineers estimates that it will spend as 
much as $20 billion to clean up contamination at thousands of	 
properties that were once owned, leased, or  operated by the	 
Defense Department (DOD). These properties contain hazardous,	 
toxic, and radioactive wastes in the soil and water or in	 
containers, such as underground storage tanks. The Corps is	 
responsible for cleaning up the hazards, including removing	 
underground storage tanks. DOD's annual report on its		 
environmental restoration activities can provide a misleading	 
picture of the Corps' accomplishments. In its annual report, DOD 
accounts of completed projects include projects that were	 
ineligible or that did not involve any actual cleanup effort. As 
a result, the impression is that after 15 years and expenditures 
of $2.6 billion, more than half of the projects at formerly used 
defense sites have been completed.  In reality, only about 32	 
percent of those projects that required actual cleanup actions	 
have been completed, and those are the cheapest and least	 
technologically challenging. The Corps estimates that the	 
remaining projects will cost more than $13 billion and take	 
upwards of 70 years to complete. The Corps' reporting of	 
completed  projects reflects DOD's reporting policies for all of 
its environmental cleanup programs, including those at closing	 
bases and active installations. As such, progress on those	 
cleanup programs may not be accurately pictured either. In	 
addition, DOD's range survey did not include all formerly used	 
defense sites properties that may contain unexploded ordnance and
could be former training ranges. Consequently, DOD's inventory of
training ranges is likely incomplete, and its estimated cost to  
clean up these ranges is likely understated.			 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-01-557 					        
    ACCNO:   A01497						        
    TITLE:   Environmental Contamination: Cleanup Actions at Formerly 
             Used Defense Sites                                               
     DATE:   07/31/2001 
  SUBJECT:   Base closures					 
	     Environmental monitoring				 
	     Hazardous substances				 
	     Obsolete facilities				 
	     Radioactive waste disposal 			 
	     Reporting requirements				 
	     Army Corps of Engineers Formerly Used		 
	     Defense Sites Program				                                                               
	     DOD Environmental Restoration Account		 
	     DOD Environmental Restoration Program		 

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GAO-01-557
     
Report to Congressional Requesters

United States General Accounting Office

GAO

July 2001 ENVIRONMENTAL CONTAMINATION

Cleanup Actions at Formerly Used Defense Sites

GAO- 01- 557

Page i GAO- 01- 557 Cleanup at Formerly Used Defense Sites Letter 1

Results in Brief 2 Background 3 Most Potential FUDS Properties Are
Ineligible or Do Not Require

Cleanup 8 Geographic Distribution and Status of Potential FUDS Properties 12
Conclusions 17 Recommendations 17 Agency Comments and Our Evaluation 18
Scope and Methodology 18

Appendix I Properties Identified for Potential Inclusion in the FUDS Cleanup
Program 20

Appendix II Cleanup Projects on FUDS Properties 21

Tables

Table 1: Reasons That Potential FUDS Properties Were Ineligible 8 Table 2:
Eligibility and Status of 9,171 Potential FUDS Properties

by Geographic Location 14

Figures

Figure 1: Decision Tree Flow Chart for the Preliminary Assessment of
Eligibility Phase 5 Figure 2: Decision Tree Flow Chart for the Site
Inspection Through

Long- Term Monitoring Phases 7 Figure 3: Breakout of 9,171 Potentially
Eligible FUDS Properties 9 Figure 4: Status of 3,736 FUDS Cleanup Projects
11 Figure 5: Distribution of 9, 171 Potential FUDS Properties 13 Contents

Page ii GAO- 01- 557 Cleanup at Formerly Used Defense Sites Abbreviations

CERCLA Comprehensive Environmental Response, Compensation and Liability Act
of 1980 DERP Defense Environmental Restoration Program DOD Department of
Defense FUDS Formerly Used Defense Sites GAO General Accounting Office SARA
Superfund Amendments and Reauthorization Act of 1986

Page 1 GAO- 01- 557 Cleanup at Formerly Used Defense Sites

July 31, 2001 The Honorable John D. Dingell Ranking Minority Member
Committee on Energy and Commerce House of Representatives

The Honorable Tom Sawyer House of Representatives

The U. S. Army Corps of Engineers (Corps) estimates that it will spend at
least $15 billion to $20 billion to clean up contamination and other hazards
(hereafter hazards) at thousands of properties that were formerly owned,
leased, possessed, or operated by the Department of Defense (DOD) or its
components. These properties, located throughout the United States, are
known as formerly used defense sites (FUDS). The properties may contain
hazardous, toxic, and radioactive wastes in the soil and water or in
containers such as underground storage tanks. Such wastes can contribute to
mortality and serious illness, or pose a threat to the environment. Other
hazards, including unexploded ordnance and unsafe buildings, may also be
present on the properties. As of October 1, 2000, the Corps, states, and
other parties had identified 9,171 properties for potential inclusion in the
FUDS cleanup program. The Corps is responsible for cleaning up the hazards,
including removing underground storage tanks, and demolishing unsafe
structures.

Concerned about the ongoing presence of defense- related hazards on property
that is no longer controlled by DOD, you asked us to determine (1) how many
properties identified for potential inclusion in the FUDS cleanup program
are actually eligible for cleanup under the program and require or have
required cleanup and (2) the geographic distribution, by state, of the
potentially eligible FUDS properties and their locations, type( s) of
hazard, including unexploded ordnance, and cleanup status. For those
properties with unexploded ordnance, you also asked us to indicate if they
are former training ranges, which often have large amounts of ordnance
present after many years of use and may be costly to clean up. Our review of
these issues encompassed all potentially eligible properties included in the
Corps? FUDS inventory as of the end of fiscal year 2000.

United States General Accounting Office Washington, DC 20548

Page 2 GAO- 01- 557 Cleanup at Formerly Used Defense Sites

Most of the 9,171 properties identified as potential candidates for cleanup
as formerly used defense sites are either not eligible for such cleanup or,
if eligible, do not require it according to the Corps. Approximately 2,700
properties are eligible and may have one or more areas with hazards; the
Corps has identified almost 4,500 individual cleanup projects to address
these contaminated properties. According to the Corps? database, 2,382 of
these projects were considered complete as of the end of fiscal year 2000.
However, over 57 percent of the projects reported as complete were closed as
a result of a study or administrative action without performing any actual
cleanup action. In fact, nearly 800 of these projects were ones that the
Corps initially thought were eligible but later determined were ineligible,
usually because the contamination was caused by other parties after DOD
relinquished control of the properties. The Corps classified these projects
as complete as a way of closing them out. If DOD, in its annual report to
the Congress on the status of its cleanup efforts, segregated projects that
did not require cleanup from those projects where actual cleanup actions
were required, it would provide a more accurate depiction of cleanup
activity and progress. Specifically, our analysis indicates that the number
of projects requiring cleanup would decline by about a third, and the
relative portion of projects completed would drop from over half of all
projects to less than a third. We are therefore making a recommendation to
improve the clarity of DOD?s reporting on the results of the FUDS cleanup
program by excluding from the cleanup list those projects that were either
closed as the result of a study or determined to be ineligible and by
reporting such projects separately. In commenting on our report, DOD stated
that it did not agree with the need to remove such projects from the list of
completed projects but agreed to clarify in future annual reports that such
projects were not cleaned up but were completed by other means.

The 9,171 potential FUDS properties currently identified are distributed
across every state, the District of Columbia, and six U. S. territories and
possessions. However, certain states have greater concentrations of these
properties than others. For example, 10 states account for almost 52 percent
of all potential FUDS properties. Unexploded ordnance and other explosive
wastes may contaminate over 1,600 FUDS properties, of which about 750 are
associated with former military training ranges according to a recent DOD
survey. However, our review of the approximately 850 other FUDS properties
that were not designated by the Corps as training ranges showed that at
least 200 of these properties may be training ranges that should be included
in DOD?s range survey results. To improve the accuracy of DOD?s range
survey, we are making a recommendation that the Corps review these
additional FUDS properties to determine which of Results in Brief

Page 3 GAO- 01- 557 Cleanup at Formerly Used Defense Sites

them are former training ranges and should be included in the range survey
results. DOD agreed with this recommendation.

Information on individual potential FUDS properties, by state, and their
locations, type( s) of hazard, and cleanup status is contained in appendix
I. Detailed information on individual cleanup projects at these properties,
by state, is contained in appendix II. Appendixes I and II are available
only on the Internet at http:// www. gao. gov/ GAO- 01- 1012SP/.

Identification, investigation, and cleanup of hazardous substances under
DOD?s FUDS program are authorized by the Defense Environmental Restoration
Program (DERP). Such actions must be carried out consistent with the
Comprehensive Environmental Response, Compensation, and Liability Act of
1980 (CERCLA) as amended by the Superfund Amendments and Reauthorization Act
of 1986 (SARA), which established DERP. The goals of the program also
include the correction of environmental damage. To fund the program, SARA
set up the Defense Environmental Restoration Account.

DOD has established specific goals for the cleanup of properties, including
FUDS, that have hazardous, toxic, and radioactive wastes in the soil and
water. These goals include having an approved cleanup process in place or
cleanup complete at 100 percent of all such properties by the end of fiscal
year 2014. DOD has not yet set any goals for projects involving hazardous,
toxic, and radioactive waste in containers, unexploded ordnance, other
explosive wastes, or unsafe building demolition.

Total spending for the FUDS cleanup program since fiscal 1984 is $2.6
billion. During the most recent past five fiscal years (1997- 2001), annual
program funding for FUDS cleanup averaged about $238 million, with program
funding in fiscal year 2001 of $231 million. The Corps? estimate of the
additional cost to complete cleanup of the 4,467 currently identified
projects is about $13 billion, not including program management or support
costs or inflation beyond fiscal year 2007. Also omitted from the estimated
cost is a revised cost projection for the cleanup of unexploded ordnance,
which resulted from a recent survey of DOD training ranges. According to
Corps officials, the revised cost projection for ordnance cleanup would add
another $5 billion or more, depending on the level of cleanup selected, to
the estimated cost to complete all FUDS projects. By the time all projects
are completed, the Corps estimates that it will spend Background

Page 4 GAO- 01- 557 Cleanup at Formerly Used Defense Sites

at least $15 billion to $20 billion cleaning up FUDS properties. 1 At the
current funding level, the Corps does not expect to meet the established
goal of cleaning up FUDS properties with hazardous, toxic, and radioactive
waste by fiscal year 2014, even if work could be deferred on all other
projects, such as containerized wastes, unexploded ordnance, and building
demolition, for which no goals have been established.

In deciding which actions, if any, need to be taken at a potential FUDS
property, the Corps generally follows the process established for cleanup
actions under CERCLA. The process usually includes the following phases:

 Preliminary assessment of eligibility- The Corps determines if the
property is eligible for the FUDS cleanup program based on whether there are
records showing that DOD formerly owned, leased, possessed, or operated the
property or facility. 2 The Corps also identifies any potential hazard on
the property related to DOD activities. The results of this assessment are
detailed in an Inventory Project Report. If the property is eligible but
there is no evidence of hazards, the property is categorized as requiring
?no further action.? 3

 Site inspection- The Corps inspects the site to confirm the presence,
extent, and source( s) of hazards.

 Remedial investigation and feasibility study- The Corps evaluates the risk
associated with the hazard; determines whether cleanup is needed; and, if
so, selects alternative cleanup approaches.

 Remedial action- The Corps designs the remedy, performs the cleanup, and
conducts long- term monitoring if necessary.

1 This estimate includes inflation only through fiscal year 2007. 2 As
defined in Corps guidance, eligible properties are real property that was
formerly owned, leased, possessed by, or otherwise under the jurisdiction of
the Secretary of Defense within the 50 states and other areas over which the
United States has jurisdiction. Eligible projects are those where there is
contamination on the eligible property requiring cleanup, and where DOD has
or shares potential responsibility for the hazardous conditions or is
otherwise responsible for cleanup of the site under CERCLA.

3 Beginning with fiscal year 2001, the FUDS program has changed this
designation to ?no

DOD action indicated? (NDAI) and established subcategories that are relevant
to later phases of the process. However, these changes were not incorporated
into the database until March 2001.

Page 5 GAO- 01- 557 Cleanup at Formerly Used Defense Sites

When all of these steps have been completed for a given project, or if no
cleanup is needed, the Corps considers the project to be ?response

complete.? After all projects at a property are designated as response
complete, the property can then be closed out. Property closeout may require
concurrence by federal or state regulators depending on the type of hazard
involved.

A flow chart showing the decision process in the preliminary assessment of
eligibility phase is shown in figure 1.

Figure 1: Decision Tree Flow Chart for the Preliminary Assessment of
Eligibility Phase

Source: Prepared by GAO based on Army Corps of Engineers data.

Upon completion of the preliminary assessment of eligibility phase, a
property enters the site inspection phase. The site inspection phase
involves a more detailed examination of the property and related records

Is the property eligible?

Is the property eligible? Potential FUDS identified Potential FUDS
identified

Is there a potential hazard? Is there a

potential hazard?

Was hazard caused by

DOD? Was hazard

caused by DOD?

Is project recommended

for action? Is project

recommended for action?

No further action needed

No further action needed

No further action needed

No further action needed

No DOD action needed

No DOD action needed

No DOD action needed

No DOD action needed

Eligible property with approved projects. Property moves to site inspection
phase. Eligible property with approved projects.

Property moves to site inspection phase. No

No No No Yes Yes Yes

Yes Property

Eligibility Project

Eligibility

Page 6 GAO- 01- 557 Cleanup at Formerly Used Defense Sites

to confirm that a hazard exists and that a cleanup project is required to
remove or reduce the hazard to a safe level. After the site inspection
phase, the Corps conducts a remedial investigation to assess the risk posed
by the hazard and determine if a cleanup is necessary. A feasibility study
is then performed to select a cleanup approach. 4 The Corps develops more
detailed plans for constructing and carrying out the selected cleanup
approach during the remedial design phase. A project next moves into the
remedial action phase 5 . The remedial action phase can involve several
steps including constructing or installing the selected cleanup approach,
operating the approach, and long- term monitoring, if necessary.

A flow chart for the site inspection through long- term monitoring process
is shown as figure 2.

4 For some projects, an engineering evaluation and cost analysis are
substituted for the remedial investigation and feasibility study phase. This
phase is omitted for projects that involve waste in containers or building
demolition; instead such projects move directly to the remedial design
phase.

5 In some cases, an interim removal action may be taken if a prompt or time-
critical response is considered necessary.

Page 7 GAO- 01- 557 Cleanup at Formerly Used Defense Sites

Figure 2: Decision Tree Flow Chart for the Site Inspection Through Long-
Term Monitoring Phases

Source: Prepared by GAO based on Army Corps of Engineers data. Is action

complete? Is action

complete? Site Inspection Site Inspection

Is action complete?

Is action complete?

Is monitoring needed? Is monitoring

needed? Yes

No Yes Remedial investigation/

feasibility study or engineering evaluation/ cost analysis Remedial
investigation/

feasibility study or engineering evaluation/ cost analysis

Is operation needed? Is operation

needed? Criteria: Contamination not confirmed

and remedial/ removal response not required

Project considered response complete Criteria: Contamination not confirmed

and remedial/ removal response not required

Project considered response complete Criteria: Hazard below risk- based
standards and remedial/ removal response not required

Project considered response complete Criteria: Hazard below risk- based

standards and remedial/ removal response not required

Project considered response complete Criteria: All remedial/ removal actions
taken

Remedial action in place Project considered response complete Criteria: All
remedial/ removal actions

taken Remedial action in place Project considered response complete

Criteria: All remedial actions including remedial action operations and/ or
long term monitoring is completed

Project considered response complete Criteria: All remedial actions
including

remedial action operations and/ or long term monitoring is completed

Project considered response complete Remedial design/

Remedial action- construction Remedial design/

Remedial action- construction Remedial action- operation Remedial action-
operation

Yes No

Yes Completed Long- term monitoring Long- term monitoring

No No

Project Closeout Project Closeout

Page 8 GAO- 01- 557 Cleanup at Formerly Used Defense Sites

Corps review of potential FUDS properties found that many properties are
ineligible because they are still part of an active DOD installation or
there are no records available showing that DOD ever owned or controlled the
property. Many of the eligible properties did not require cleanup under the
FUDS program because the Corps determined that no DOD- related hazards
existed.

As of October 1, 2000, there were 9,171 properties that had been identified
by the Corps, the states, or other parties as potentially eligible for
cleanup under the FUDS program. 6 Of these properties, 9,055 had received a
preliminary assessment of eligibility, 42 were still being assessed, and 74
properties had not been assessed yet. Based on preliminary assessments, the
Corps determined that 6,746 properties were eligible and that 2,309 of the
properties- more than a quarter of those assessed- were ineligible. In most
cases, properties were ineligible either because the properties were still
under DOD control (915) or because there were no records found showing that
DOD had ever controlled the property (787). Table 1 shows the reasons that
properties were found to be ineligible.

Table 1: Reasons That Potential FUDS Properties Were Ineligible Reason
Properties

Active DOD installation 915 Contaminated by an act of war 4 Defense Plant
Corporation property 80 DOD component accepted cleanup responsibility or
initiated cleanup 5 Not formerly, used, owned, or controlled by DOD 236 No
records 787 Outside U. S. jurisdiction 12 Offshore ordnance property 5 Civil
works property 48 Other 79 Excluded properties: cemeteries, recruiting
stations, United Service Organization properties 138

Total 2309

Source: Army Corps of Engineers.

6 Another 677 properties were identified as potentially eligible but, after
further investigation, were found to be duplicates of properties already on
the list. The Corps maintains these properties on the inventory solely for
the purpose of having a record of what became of them and the amount of
money spent on them. Consequently, we have excluded these properties from
our analysis. Most Potential FUDS

Properties Are Ineligible or Do Not Require Cleanup

Many Potential FUDS Properties Are Ineligible Because DOD?s Presence Is
Either Ongoing or Not Proven

Page 9 GAO- 01- 557 Cleanup at Formerly Used Defense Sites

Although the Corps initially found that 6,746 properties were eligible for
cleanup, the Corps subsequently determined, on the basis of site
inspections, that most of these properties do not require cleanup after all.
Specifically, the Corps determined that 4,070 properties either do not have
any hazards requiring DOD cleanup or else have hazards that do not meet the
level requiring cleanup. 7 Hazards requiring cleanup were found on 2,676 of
the eligible properties. Figure 3 shows the breakout of properties by
eligibility and those where hazards were found.

Figure 3: Breakout of 9,171 Potentially Eligible FUDS Properties

Source: GAO?s analysis of data provided by the Army Corps of Engineers.

The Corps identified 4,467 distinct projects requiring cleanup at the 2,676
properties that were identified as having hazards needing cleanup. At 25 of

7 The Corps makes its determination that no contamination or other hazards
exist that require cleanup by the Corps without input from state or federal
regulatory agencies, which may not agree. Such determinations are called ?no
further action.? According to Corps officials, these determinations do not
mean that action may not be required by other, subsequent users or owners of
the properties to clean up contamination they caused. Corps officials
emphasize that they are willing to reconsider the ?no further action?
determinations if evidence of contamination caused by DOD is found. Most of
the Eligible

Properties Do Not Require Cleanup

Page 10 GAO- 01- 557 Cleanup at Formerly Used Defense Sites

these properties, no specific projects have been identified as yet. However,
after further investigation the Corps determined that projects identified at
405 properties were ineligible because other outside parties were
responsible for contaminating the properties after DOD relinquished control.
At another 33 properties, the identified projects were not recommended for
further action or were not approved. The reasons for not recommending a
project for further action or not approving a project varied. For example,
the current landowner might have refused access to the property or might
have already addressed the problem. The remaining 2,213 eligible properties
had 3,736 projects requiring investigation and cleanup.

Of these projects, 284 were not yet scheduled for action, 1,844 projects
were under way or planned, and 1,608 were completed. Figure 4 depicts the
status of FUDS projects with hazards that required cleanup actions.

Page 11 GAO- 01- 557 Cleanup at Formerly Used Defense Sites

Figure 4: Status of 3,736 FUDS Cleanup Projects

Source: GAO?s analysis of data provided by the Army Corps of Engineers.

DOD reports on the status of its various environmental cleanup programs in
an annual report to the Congress. However, as of the date of this report,
DOD had not yet released its report for fiscal year 2000- the most recently
completed fiscal year. According to the Corps? FUDS database, there were
2,382 completed FUDS projects as of the end of fiscal year 2000, or about 53
percent of the nearly 4,500 FUDS projects that required cleanup. 8 The
completed projects figure includes those removed from the active inventory
either as a result of a study or an administrative action or as the result
of an actual cleanup action such as removing toxic wastes or treating
contaminated groundwater. In fact, our analysis showed that over 57 percent
of the projects reported as complete did not require any actual cleanup and
were reported as complete on the basis of a study or an administrative
decision. For example, 183 of the 205 unexploded ordnance projects reported
as complete were closed based on a study, while only 22 required an actual
cleanup phase. Further, the completed figure includes 774 projects that were
ineligible for cleanup as part of the FUDS program. The Corps initially
thought that these projects were eligible but later

8 The Corps database is updated frequently as new information on properties
and projects becomes available. Accordingly, there can be some differences
in the numbers discussed in various documents depending on when the
information was obtained. Such differences are not material in the short
term. DOD Reporting on FUDS

Program Status Can Be Misleading

Page 12 GAO- 01- 557 Cleanup at Formerly Used Defense Sites

determined that they were ineligible because the contamination was caused by
other parties after DOD relinquished control of the properties. The Corps
made an administrative decision to classify these projects as

?response complete? to remove them from its tracking system. If only the
number of projects actually believed to require cleanup- 3,148- was used as
the basis for calculating cleanup progress, then only 1,020 projects or
about 32 percent of those requiring cleanup have actually been cleaned up.

Further, according to Corps officials, most of the projects cleaned up to
date were the least complex and least expensive ones, such as removing
underground storage tanks (668 completed projects) or demolishing buildings
(198 completed projects). On the other hand, many of the remaining cleanup
projects are high cost and technologically difficult. Consequently, cleanup
of the approximately 2,100 remaining projects will require at least $13
billion 9 (revised estimates may raise this to $18 billion or more) and take
more than 70 years to complete based on current planned funding of about
$200 million per year. According to Corps officials, reporting of completed
FUDS projects follows DOD?s reporting policies for all its environmental
cleanup areas such as base closures and active installations.

The more than 9, 000 properties identified as potential candidates for
cleanup as FUDS are distributed across every state, the District of
Columbia, and six U. S. territories and possessions. 10 However, there are
large concentrations of potential FUDS properties in certain states. For
example, 10 states account for almost 52 percent of all the properties,
while 27 states have more than 100 properties each and represent over 81
percent of all the properties. Figure 5 shows the geographic distribution of
potential FUDS properties.

9 This estimate includes inflation only through fiscal year 2007. 10 The
territories and possessions are American Samoa, Guam, the Northern Mariana
Islands, Palau, Puerto Rico, and the U. S. Virgin Islands. Geographic

Distribution and Status of Potential FUDS Properties

Page 13 GAO- 01- 557 Cleanup at Formerly Used Defense Sites

Figure 5: Distribution of 9, 171 Potential FUDS Properties

Source: GAO?s analysis of data provided by the Army Corps of Engineers.

Unexploded ordnance and other explosive wastes were believed to contaminate
over 1,600 FUDS properties, of which 753 were associated with former
training ranges according to a recent DOD survey. Our review of the over 800
properties not designated as training ranges in DOD?s survey results showed
that there may be 200 or more additional properties with training ranges
that should be included in DOD?s range survey results.

AK 599

HI 377

AL 171 AR

82 AZ 262

DC 55 CA 1088

CO 93

CT 54 DE 34

FL 647 GA

229 IA

34 ID

75 IL 156

IN 73

KS 123

KY 24

LA 87

MA 279 MD 102 NJ 175 ME

177 MI 171 MN

76 MO

88 MS 193 MT

107 NC 182 ND

66 NE 101

NH 28 VT 12

NM 240 NV

70 NY

484 OH

91 OK 111 OR

115 PA 164

RI 74 SC 206 SD

91 TN 66 WA

323 UT

55 VA 278

TX 404 WY

70 WV

26 WI

68 American Samoa 30 Guam 48 Northern Mariana Islands 33 Palau 14 Puerto
Rico 79 U. S. Virgin Islands 11

< 100 properties 100- 199 properties 200 + properties

Page 14 GAO- 01- 557 Cleanup at Formerly Used Defense Sites

As discussed previously, most of the 9,171 potential FUDS are either
ineligible for the cleanup program (2,309 properties) or do not require any
environmental cleanup (4,070 properties) according to assessments made by
the Corps; 116 properties were still being reviewed for eligibility and
potential hazards. The remaining 2,676 properties were found to have
sufficiently high levels of hazards to require cleanup. Of these, 463
properties were excluded because other parties were deemed responsible for
the hazard (405 properties), or because no specific project had been
identified as yet (25 properties), or because no projects had been
identified or approved for further action (33 properties). Table 2
summarizes the eligibility status of the potential FUDS by geographic
location.

Table 2: Eligibility and Status of 9,171 Potential FUDS Properties by
Geographic Location Eligibility status Eligible property hazards Property
status

State Potential FUDS Still under

review a Ineligible property Eligible

property No hazards found

Potential hazards

found Other b Properties

requiring cleanup

AK 599 33 49 517 391 126 17 109 AL 171 2 48 121 97 24 6 18 AR 82 0 5 77 64
13 1 12 AZ 262 0 72 190 105 85 26 59 CA 1088 19 300 769 397 372 65 307
CO9304746 16 30426 CT 54 0 9 45 23 22 5 17 DC 55 1 5 49 22 27 0 27 DE 34 0 3
31 20 11 2 9 FL 647 9 149 489 339 150 59 91 GA 229 0 85 144 100 44 18 26 HI
377 0 74 303 233 70 2 68 IA 34 0 9 25 12 13 1 12 ID7541556 44 1239 IL 156 1
40 115 53 62 8 54 IN7312151 34 17017 KS 123 0 10 113 44 69 1 68 KY 24 0 7 17
13 4 1 3 LA 87 0 16 71 55 16 2 14 MA 279 3 36 240 129 111 31 80 MD10212279
37 421131 ME 177 21 26 130 67 63 13 50 MI 171 1 68 102 38 64 8 56 MN 76 0 8
68 48 20 3 17 MO 88 0 9 79 53 26 0 26 MS 193 0 67 126 93 33 7 26

Eligibility and Status of Potential FUDS by Geographic Location

Page 15 GAO- 01- 557 Cleanup at Formerly Used Defense Sites

Eligibility status Eligible property hazards Property status State Potential

FUDS Still under review a Ineligible

property Eligible property No hazards

found Potential

hazards found Other b

Properties requiring

cleanup

MT 107 1 55 51 34 17 4 13 NC 182 0 86 96 60 36 4 32 ND 66 0 52 14 10 4 0 4
NE 101 0 31 70 15 55 6 49 NH 28 0 3 25 14 11 0 11 NJ 175 0 60 115 71 44 8 36
NM 240 0 17 223 85 138 3 135 NV 70 7 5 58 27 31 12 19 NY 484 0 215 269 172
97 11 86 OH9112169 43 26125 OK 111 0 4 107 54 53 8 45 OR 115 0 16 99 72 27 2
25 PA 164 1 32 131 62 69 27 42 RI 74 0 6 68 26 42 10 32 SC 206 2 126 78 47
31 7 24 SD9104051 18 33231 TN6602640 23 1789 TX 404 0 42 362 195 167 28 139
UT5511341 24 17017 VA 278 3 111 164 125 39 3 36 VT12048 2 615 WA 323 3 35
285 227 58 5 53 WI6801652 27 25124 WV 26 0 10 16 6 10 3 7 WY7003634 12 22220
AS c 30 0 1 29 21 8 0 8 CN c 33 1 6 26 4 22 0 22 GM c 48 0 8 40 22 18 2 16
PR c 7901960 37 231013 PT c 140122 2 000 VI c 11 0 1 10 6 4 1 3

Total 9,171 116 2,309 6,746 4,070 2,676 463 2,213

a Includes 74 properties where the preliminary assessments were not
completed and 42 properties where the preliminary assessments were completed
but eligibility was not yet determined. b Includes 405 properties where
other parties were deemed responsible for the hazard, 25 properties

where no projects were identified yet, and 33 properties where the
identified projects were not recommended or not approved to go forward. c
American Samoa (AS), the Northern Mariana Islands (CN), Guam (GM), Palau
(PT), Puerto Rico (PR), the U. S. Virgin Islands (VI). Source: Army Corps of
Engineers.

Page 16 GAO- 01- 557 Cleanup at Formerly Used Defense Sites

For the remaining 2,213 properties, a total of 3,736 projects were
identified and approved for further action. The status of these projects
varies from those that were only recently identified and have had no cleanup
action taken as yet to those that are completed.

Information on individual properties, by state, including the property name,
location, congressional district, eligibility, existence of hazards, number
of eligible projects, estimated costs incurred to date, and estimated cost
to complete cleanup is contained in appendix I. Information on individual
projects, by state, including the property name, location, congressional
district, project number, type( s) of hazard, risk level, status of cleanup,
cleanup remedy used, costs incurred to date, and estimated cost to complete
cleanup is contained in appendix II. These appendixes are available only on
the Internet at http:// www. gao. gov/ GAO01- 1012SP/.

In response to the Senate Armed Service?s Committee direction to develop
more complete information on the estimated cost to conduct environmental
cleanup at training ranges, DOD conducted a survey of training ranges at its
active, closing, and closed facilities to determine which ones might contain
unexploded ordnance. 11 Because DOD does not have a complete inventory of
its training ranges, the amount of funding necessary to clean up training
ranges has been unreliable and is believed to be significantly understated.
12 DOD?s survey results indicated that 753 FUDS properties that might
contain unexploded ordnance should be classified as training ranges. For a
variety of reasons, over 800 FUDS properties were not included in DOD?s
survey. Many of these properties were excluded because the Corps had
previously decided that, although there might be unexploded ordnance or
other explosive wastes present, no further action was needed to address the
hazards at these properties. We reviewed basic information about these
properties, such as the name of the property and the project description, to
see if there could be additional ranges not reported as part of DOD?s
survey. For example, if a project with ordnance or explosive wastes was
located at property that was named

?Bombing Range? or ?Bombing Target? or was described as an ordnance or
explosive wastes cleanup project at a bombing range or bombing target,

11 Senate Report on the National Defense Authorization Act for Fiscal Year
2000 (S. Rep. No. 106- 50, May 17, 1999). 12 Environmental Liabilities: DOD
Training Range Cleanup Cost Estimates Are Likely Understated (GAO- 01- 479,
Apr. 2001). DOD?s Range Survey May

Not Include All FUDS Ranges

Page 17 GAO- 01- 557 Cleanup at Formerly Used Defense Sites

we concluded that these properties were likely training ranges. We found
over 200 properties that could be ranges based on such criteria.

DOD?s annual report on the status of its environmental restoration
activities can provide a misleading picture of FUDS program accomplishments.
In its annual report, DOD accounts of completed projects include projects
that were determined to be ineligible or that did not involve any actual
cleanup effort, as well as projects that required actual cleanup actions to
complete. As a result, it appears that after 15 years and expenditures of
$2.6 billion, over 50 percent of the FUDS projects have been completed. In
reality, only about 32 percent of those projects that required actual
cleanup actions have been completed, and those are the cheapest and least
technologically challenging. The Corps estimates that the remaining projects
will cost over $13 billion and take more than 70 years to complete. The
Corps? reporting of completed FUDS projects reflects DOD?s reporting
policies for all of its environmental cleanup programs, including those at
closing bases and active installations. As such, progress on those cleanup
programs may not be accurately pictured either.

In addition, DOD?s range survey did not include all FUDS properties that may
contain unexploded ordnance and could be former training ranges.
Consequently, DOD?s inventory of FUDS training ranges is likely incomplete,
and its estimated cost to clean up these ranges is likely understated.

The Secretary of Defense should clarify DOD?s reporting of the cleanup
progress at FUDS and for other DOD cleanup activities by excluding projects
from its ?completed? list that were closed solely as a result of a study or
administrative action and did not require actual cleanup. Such projects
should instead be reported as eligible properties where a hazard either was
not found or did not require cleanup because it was below the threshold
level or because it resulted from another party?s actions. Similarly, DOD?s
annual report should exclude projects from its

?completed? list that were determined to be ineligible for cleanup under the
FUDS program.

To improve the accuracy of DOD?s FUDS training range survey results and its
estimate of the costs related to environmental cleanup at these ranges, the
Secretary of Defense should direct the Corps to review the FUDS properties
that were excluded in DOD?s initial survey to determine if any are training
ranges that should be included in the survey. Conclusions

Recommendations

Page 18 GAO- 01- 557 Cleanup at Formerly Used Defense Sites

DOD provided oral comments that generally agreed with the need to clarify
reporting on the status of the FUDS program and to review the unexploded
ordnance projects that were excluded from its initial training range survey.
DOD did not agree with the need to exclude from the list of completed
projects those projects closed either as the result of a study or because
they were determined to be ineligible. However, DOD did agree that it needs
to clarify in future annual reports to the Congress that the restoration
efforts on some projects were completed with a study phase and not a cleanup
action. DOD did not specifically address how it would report on the
ineligible projects that were being reported as completed.

DOD also provided a number of technical comments and clarifications related
to specific numbers and dollar figures in the report, which we addressed as
appropriate in the body of the report.

The scope of this review encompassed all potentially eligible properties
included in DOD?s FUDS inventory as of the end of fiscal year 2000.

To obtain information on the number of potential FUDS properties that are
eligible and require or have required cleanup and on the geographic
distribution, by state, of FUDS properties, we relied primarily on the Corps
database of FUDS properties.

To obtain information on those FUDS properties that contain or contained
ordnance and other explosive wastes, we also relied on the Corps database of
FUDS properties and on a database constructed by the Corps to respond to
DOD?s range survey. We then compared those databases to determine which
properties were included as part of the range survey and which were not. For
those that were not included, we reviewed the property name and project
description information to determine if there were additional properties
that could be ranges based on these descriptors.

The data in this report represent a static point in time- the end of fiscal
year 2000. The Corps database of FUDS properties is used by the Corps on a
daily basis to plan, schedule, and monitor the FUDS program, so there are
constant changes and updates. Consequently, the numbers presented in this
report may vary somewhat from other published sources; however, such
variations represent the changing status of individual properties and
projects, not material changes in the overall program status. On an overall
level and as a measure of the FUDS program?s scope and efforts, we believe
that these data represent a reasonable picture of the program at the end of
fiscal year 2000. Agency Comments

and Our Evaluation Scope and Methodology

Page 19 GAO- 01- 557 Cleanup at Formerly Used Defense Sites

The Corps database of FUDS properties incorporates data from a previous
Corps effort that did not contain all of the various categories of data in
the current database. Consequently, for some properties and projects,
particularly those that are no longer active, some information is dated and
may not reflect current property conditions. We reviewed the Corps? policies
and procedures to verify the reliability of these data and found them to be
reasonably accurate for our use. To the extent that we found material errors
in the data, we worked with the Corps to correct those errors. We did not,
however, attempt to independently assess the reliability of the data.

We also acquired and reviewed program documents and interviewed Corps
officials from headquarters, division, and district offices to obtain
information about the FUDS program. We did not ask state officials to verify
or confirm the Corps data for this review. We also contacted DOD and
Environmental Protection Agency officials about aspects of the FUDS program.

We conducted our review from November 2000 through May 2001 in accordance
with generally accepted government auditing standards.

As arranged with your offices, unless you publicly announce the contents of
this report earlier, we plan no further distribution of it until 30 days
from the date of this letter. We will then send copies to the Secretary of
Defense; the Director, Office of Management and Budget; the appropriate
congressional committees; and other interested parties. We will also provide
copies to others on request.

If you or your staff have any questions regarding this report, please call
me or Edward Zadjura on (202) 512- 3841. Key contributors to this assignment
were Patricia Foley- Hinnen; Susan Irwin; Arthur James, Jr.; Robert Kigerl;
and Cynthia Norris.

(Ms.) Gary L. Jones Director, Natural Resources and Environment

Appendix I: Properties Identified for Potential Inclusion in the FUDS
Cleanup Program

Page 20 GAO- 01- 557 Cleanup at Formerly Used Defense Sites

Appendix I contains summary data on all 9,171 properties identified for
potential inclusion in the FUDS cleanup program. The properties are listed
by state, the District of Columbia, and six U. S. territories and
possessions. For each property, the data include the property name, Corps?
property number, the county and congressional district where the property is
located, the eligibility status, and whether hazards are present. Also
included for eligible properties with hazards are the number of eligible
cleanup projects, the actual cleanup- related costs incurred to date, and
the estimated cost to complete the cleanup projects. All information is
reported as of the end of fiscal year 2000.

Appendix I is available only on the Internet at http:// www. gao. gov/ GAO-
01- 1012SP/. Appendix I: Properties Identified for

Potential Inclusion in the FUDS Cleanup Program

Appendix II: Cleanup Projects on FUDS Properties

Page 21 GAO- 01- 557 Cleanup at Formerly Used Defense Sites

Appendix II contains summary data on the 2,213 eligible properties with
hazards that have cleanup projects. The projects are listed by state, the
District of Columbia, and six U. S. territories and possessions. For each
project, the data include the property name, the Corps? property number,
county and congressional district where the property is located, the Corps?
project number, the type of hazard on the property, and the risk posed by
the hazard. In addition, information is provided on whether or not the
project has been scheduled to begin, is planned or under way, or has been
completed, with actual or estimated dates for commencement and completion.
The type of cleanup remedy selected for the project is also indicated.
Finally, the actual cleanup- related cost incurred to date and the estimated
cost to complete each project are provided. All information is reported as
of the end of fiscal year 2000.

Appendix II is available only on the Internet at http:// www. gao. gov/ GAO-
01- 1012SP/. Appendix II: Cleanup Projects on FUDS

Properties

(360010)

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