Environmental Contamination: Many Uncertainties Affect the Progress of the Spring Valley Cleanup (06/06/2002, GAO-02-556}

-------------------------Indexing Terms-------------------------
REPORTNUM:   GAO-02-556
    TITLE:   Environmental Contamination: Many Uncertainties Affect the Progress of the Spring Valley Cleanup
     DATE:   06/06/2002



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United States General Accounting Office: 
GAO: 

Report to the Subcommittee on the District of Columbia, Committee on
Government Reform, House of Representatives: 

June 2002: 

Environmental Contamination: 

Many Uncertainties Affect the Progress of the Spring Valley Cleanup: 

GAO-02-556: 

Contents: 

Letter: 

Results in Brief: 
Background: 
Government Entities Have Formed a Partnership Approach for the Spring 
Valley Cleanup: 

Government Entities Have Identified and Removed a Large Number of 
Hazards, but the Extent of Hazards Remaining Is Unknown: 

Risks from Buried Hazards and from Arsenic-Contaminated Soil Drive 
Cleanup Decisions: 

The Corpsï¿½ Estimated Cost and Cleanup Schedule May Change as More 
Information about the Site Is Known: 

Observations: 

Agency Comments: 

Scope and Methodology: 

Appendix I: Properties in the District of Columbia Where Hazards 
Resulting from Federal Activities Have Been Found: 

Appendix II: Comments from the Department of Defense: 

Appendix III: Comments from the Environmental Protection Agency: 

Appendix IV: Comments from the District of Columbiaï¿½s Department of 
Health: 

Appendix V: GAO Contacts and Staff Acknowledgments: 

Tables: 

Table 1: Estimated Cost to Complete the Cleanup at Spring Valley, 
Fiscal Years 1997 through 2001 and as of April 2002: 

Table 2: Estimated Total Cost to Complete Cleanup Activities at Spring 
Valley, as of April 2002: 

Table 3: Levels of Annual Funding Specified in the Corpsï¿½ Schedule for 
Completing Cleanup Work at Spring Valley, Fiscal Year 2000, Fiscal Year 
2001, and as of April 2002: 

Table 4: Properties in the District of Columbia Where Hazards Resulting 
from Federal Activities Have Been Found: 

Table 5: Hazards Found at Leaking Underground Storage Tanks on Federal 
Properties in the District of Columbia Where Remediation Was in 
Process, as of January 2002: 

Figures: 

Figure 1: World War I-era Photograph of Two Soldiers Preparing to Test 
Chemical Munitions in a Trench Located in Spring Valley: 

Figure 2: Location of the Spring Valley FUDS in the District of 
Columbia: 

Figure 3: Total Estimated Cost to Clean up Spring Valley, Fiscal Years 
1997 through 2001 and as of April 2002: 

[End of section] 

United States General Accounting Office: 
Washington, DC 20548: 

June 6, 2002: 

The Honorable Constance A. Morella: 
Chairwoman: 
The Honorable Eleanor Holmes Norton: 
Ranking Minority Member: 
Subcommittee on the District of Columbia: 
Committee on Government Reform: 
House of Representatives: 

During World War I, at a portion of American University and in other 
areas that became the Spring Valley neighborhood in Washington, D.C., 
the U.S. Army operated a large research facility to develop and test 
chemical weapons and explosives. After World War I, the majority of the 
site was returned to private ownership and was developed for 
residential and other uses. The site now includes, in addition to 
American University, about 1,200 private residences, Sibley Hospital, 
27 embassy properties, and several commercial properties. 

In 1993, buried ordnance was discovered in Spring Valley, leading to its
designation by the Department of Defense (Defense) as a formerly used
defense site (FUDS) currently comprising 661 acres. FUDS are properties
that were formerly owned, leased, possessed, or operated by Defense or
its components, and are now owned by private parties or other 
governmental entities. These properties, located throughout the United
States and its territories, may contain hazardous, toxic, and 
radioactive wastes in the soil and water or in containers such as 
underground storage tanks. Other hazards, including unexploded ordnance 
and unsafe buildings, may also be present on the properties. Such 
hazards can contribute to deaths and serious illness or pose a threat 
to the environment. 

Through fiscal year 2001, Defense had spent over $50 million to identify
and remove hazards at the Spring Valley site. However, concerns persist
over the extent of hazards remaining, and the U.S. Army Corps of
Engineers (the Corps) is continuing to survey targeted properties for
buried ordnance and explosives, and sample all properties in Spring 
Valley for arsenic-contaminated soil. 

In response to your letter, and as agreed with your offices, this report
provides information on the (1) specific roles and responsibilities of 
the government entities involved at the Spring Valley site, as 
authorized by statute, regulation, or guidance, and as actually carried 
out, (2) progress the government entities have made toward identifying 
and removing hazards at the site, (3) health risks government entities 
have determined are associated with the hazards at the site and the 
impact of these risks on cleanup decisions, and (4) estimated cost and 
schedule of the remaining cleanup. In addition, you asked us to provide 
a list of sites in the District of Columbia where hazards resulting 
from federal activities have been found. We have included this list in 
appendix I. To address these objectives, we reviewed documents on 
activities conducted at the site during World War I, the progress of 
cleanup activities at the site, health risks, and estimated costs, and 
interviewed federal and District of Columbia government officials and 
other stakeholders. We also reviewed the statutes authorizing various 
cleanup activities. In addition, we visited the site to observe the 
activities first-hand and attended meetings of resident and other 
stakeholder groups formed to advise the cleanup process. We obtained
and reviewed records from Defense, the Environmental Protection Agency, 
and the District of Columbiaï¿½s Department of Health to develop a list 
of sites in the District of Columbia where hazards resulting from 
federal activities have been found. 

Results in Brief: 

The principal government entities involved at the Spring Valley site are
carrying out their roles and responsibilities in cleaning up the site
primarily under the Defense Environmental Restoration Program 
(environmental restoration program), which was established by the 
Superfund Amendments and Reauthorization Act of 1986. Under the 
environmental restoration program, Defense is authorized to identify,
investigate, and clean up environmental contamination at formerly used
defense sites. The U.S. Army, through the Corps, is responsible for 
these activities at Spring Valley and is carrying out the physical 
cleanup. Defense is required under the environmental restoration 
program to consult with the Environmental Protection Agency (EPA), 
which has its own authority to act at the site under the Comprehensive 
Environmental Response, Compensation, and Liability Act of 1980. Under 
the program, Defenseï¿½s activities must also be consistent with a 
statutory provision that addresses, among other things, participation 
by the affected statesï¿½in this case, the District of Columbia. Under 
the Corpsï¿½ program guidance for FUDS, the District of Columbia has a 
role in defining the cleanup levels at the Spring Valley site. 
According to the District of Columbiaï¿½s Department of Health, the 
department assesses the human health risks associated with any exposure 
to remaining hazards at Spring Valley. In carrying out their roles, 
these government entities have, over time, formed an active partnership 
to make cleanup decisions. For example, the Corps leads the effort to 
identify hazards, but in many cases it uses the recommendations
of the District of Columbia and EPA to look for hazards buried at 
certain sites. The entities are currently reaching agreement as to a 
cleanup levelï¿½that is, how much contamination can be left in the soil 
without endangering human health and the environment. The partners 
expect to finalize this decision by early June 2002. While the entities 
have not agreed on all cleanup decisions, officials acknowledge that, 
by having formed a partnership, a means exists to foster communication 
and collaboration, and officials of all three entities stated that the 
partnership is operating effectively. Continued progress at the site 
will depend, in part, on the effectiveness of this partnership over the 
duration of the cleanup period. 

The government entities involved at Spring Valley have identified and
removed a large number of hazards, but the extent to which hazards 
remain is unknown. The hazards identified include buried ordnance; 
chemical warfare agents in glass containers; and arsenic-contaminated
soil. Beginning in 1986, the U.S. Army searched records and reviewed
photographs to identify locations where ordnance and chemicals might
have been buried and concluded that there was no evidence of large-scale
burials at the site. However, following the discovery of buried 
ordnance by a utility contractor in 1993, the U.S. Army identified and 
removed 141 pieces of ordnance, 43 of which were suspected chemical 
munitions (but most were destroyed before being tested). After the 
ensuing investigation of the site, the Corps concluded in 1996 that it 
was unlikely to discover additional hazards at the site. Since then, 
however, the Corps has found and removed 667 pieces of ordnance, 25 of 
which were chemical munitions, and 101 bottles of chemicals. Moreover, 
the Corps has discovered arsenic in the soil throughout the site that 
exceeds naturally occurring levels. As of April 2002, the Corps had 
identified and removed 5,623 cubic yards of arsenic-contaminated soil 
from three properties. The Corps has extensive work remaining to search 
for any additional hazards at the site, and, if found, remove them. 

The primary health risks influencing cleanup activities currently at 
Spring Valley are the possibility of injury or death from exploding or 
leaking ordnance and containers of chemical warfare agents and potential
long-term health problems from exposure to arsenic-contaminated soil,
according to the government entities involved. Because of the immediacy
of the risks, the partnership agrees that ordnance and containers must 
be removed as soon as possible after they are found. In contrast, the 
partners have disagreed over the immediacy of the health risk posed by 
arsenic-contaminated soil. The partners recognize that exposure to 
arsenic has been generally linked to cancers and other health 
conditions. A recent study by the District of Columbia concluded that 
Spring Valley residents showed no increased incidence of certain 
cancers. A study by the Agency for Toxic Substances and Disease 
Registry (an agency of the Department of Health and Human Services) 
found no evidence of actual exposure to arsenic in the individuals 
tested. However, these studies, according to some residents, were not 
sufficiently broad. Additional studies to assess whether residents have 
actually been exposed to arsenic are ongoing. Over the past year, the 
partners have been in the process of reaching agreement on a single 
level of arsenic that may remain in the soil throughout the site and 
that is protective of human health and the environment. 

As of April 2002, the U.S. Army estimated that the remaining cleanup
activities at Spring Valley would cost $71.7 million and take 5 years to
complete, but the reliability of these estimates is uncertain. Many 
factorsï¿½such as the discovery of additional hazards or changes in annual
funding levelsï¿½make it inherently challenging to estimate the costs and
schedule for cleaning up the site. Since fiscal year 1997, the Corps has
continually needed to increase the scope of the remaining cleanup as 
more information about the hazards at the site became known. As a 
result, the Corps increased the total estimated cost for the Spring 
Valley cleanup six-fold over the same period, from about $21 million in 
fiscal year 1997 to about $125 million as of April 2002. On the other 
hand, the Corps has reduced its estimate of the time it will take to 
complete the cleanup since fiscal year 2000 (the first year the Corps 
made public this estimate) by increasing considerably the amount of 
annual funding it plans to devote to the site. It is unclear at this 
time how long the Corps will be able to accommodate the increasing 
funding needs at Spring Valley because funding the cleanup activities 
at the site is currently adversely affecting the pace and progress of 
cleanups at the approximately 2,800 other formerly used defense sites 
presently known to require remediation. Consequently, any significant 
increases in the cost of completing the Spring Valley cleanup, or 
decreases in the amount of available annual funding, would likely 
require the Corps to extend the completion date further into the 
future. 

We provided a draft of this report to the Department of Defense, 
Environmental Protection Agency, and the District of Columbiaï¿½s 
Department of Health for review and comment. These agencies generally
agreed with the information presented in the draft and provided a number
of technical comments, which we incorporated in the report as 
appropriate. Defense stated that, while they agreed that there are some
uncertainties associated with the Spring Valley cleanup, it is 
important to note that such unknowns are not unique to Spring Valley. 
Defense also stated that the partnership formed has been a model for 
regulatory relationships at other site cleanups. EPA stated that our 
report develops an accurate and unbiased appraisal of the problems and 
uncertainties present at the site. The District of Columbiaï¿½s 
Department of Health stated that it is committed to continuing to work 
with the other governmental partners in order to protect human health. 

Background: 

In 1917, the Bureau of Mines initiated the Chemical Warfare Research
Program at American University, and in 1918, the research effort was
transferred to the Chemical Warfare Service in the War Department. The
Chemical Warfare Service used a portion of American University and other
areas that became part of the Spring Valley neighborhood to operate a
large research facility to develop and test chemical agents, equipment, 
and munitions. The U.S. Army used the remaining part of the area as a 
camp to house and train engineer troops. These two areas were known as 
the American University Experiment Station and Camp Leach (which 
includes Fort Gaines), respectively. Historical and archival 
information indicates that onsite development and testing of ordnance 
and chemical warfare materials occurred at the American University 
Experiment Station between 1917 and 1919, as shown in figure 1. The 
majority of the property was returned to private ownership by October 
1920. 

Figure 1: World War I-era Photograph of Two Soldiers Preparing to Test 
Chemical Munitions in a Trench Located in Spring Valley. 

[Refer to PDF for image] 

Source: The Corps. 

[End of figure] 

During the 1950s and 1980s, American University and others raised 
concerns about buried munitions in the Spring Valley neighborhood. 
Following an accidental discovery of buried ordnance in Spring Valley in
1993, the Corps designated the site as a FUDS. The Spring Valley FUDS
includes, in addition to American University, about 1,200 private 
residences, Sibley Hospital, 27 embassy properties, and several 
commercial properties. According to the U.S. Army, Spring Valley is the
only known FUDS where chemical agents were tested in what became a well-
established residential neighborhood at the heart of a large 
metropolitan area. Figure 2 shows the location of the Spring Valley
neighborhood in Washington, D.C. 

Figure 2: Location of the Spring Valley FUDS in the District of 
Columbia: 

[Refer to PDF for image] 

This figure contains a map of the District of Columbia and surrounding 
areas, as well as a detailed map of the Spring Valley FUDS area. 

Source: The Corps. 

[End of figure] 

To fund the environmental restoration program, the Superfund Amendments 
and Reauthorization Act of 1986 (SARA) established the Defense 
Environmental Restoration Account. Total spending for the FUDS cleanup 
program since fiscal year 1984 is $2.6 billion.[Footnote 1] During the 
5 most recent fiscal years (1997-2001), annual program funding for FUDS 
cleanup has decreased from about $255.9 million to about $231 million, 
with program funding estimated to decrease further to about $212.1 
million by fiscal year 2003. By the end of fiscal year 2001, the Corps 
had identified 4,649 potential cleanup projects on 2,825 properties 
requiring environmental response actions. Through fiscal year 2001 (the 
latest figure available), the Corps had spent about $53.4 million on 
cleanup activities at Spring Valley. In addition, as of April 2002, EPA 
had spent about $800,000 on activities related to the site. 

Government Entities Have Formed a Partnership Approach for the Spring 
Valley Cleanup: 

The principal government entities involved at the Spring Valley site are
carrying out their roles and responsibilities in cleaning up the site 
under the Defense Environmental Restoration Program (environmental 
restoration program). The environmental restoration program was 
established by SARA, which amended the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA). Under the
environmental restoration program, Defense is authorized to identify,
investigate, and clean up environmental contamination at FUDS. Defense
is required to consult with EPA in carrying out the environmental
restoration program; EPA, in turn, has established written guidance 
under CERCLA for its activities at FUDS. Activities under the 
environmental restoration program also must be consistent with another 
statutory provision[Footnote 2] that addresses, among other things, 
participation by the affected statesï¿½in this case, the District of 
Columbia. Under the Corpsï¿½ program guidance, the District of Columbia 
has a role in defining the cleanup levels at the Spring Valley site. 
According to a District of Columbia Department of Health official, the 
department assesses the human health risks associated with any exposure 
to remaining hazards at Spring Valley.[Footnote 3] In carrying out 
their roles, these government entities have, over time, formed an 
active partnership to make cleanup decisions. For example, the Corps 
leads the effort to identify hazards, but in many cases it follows the
recommendations of the District of Columbia and EPA to look for hazards
buried at certain sites. The entities are currently finalizing 
decisions as to a cleanup level for arsenic that will determine how 
much contamination can be left in the soil throughout the site without 
endangering human health and the environment. While the entities have 
not agreed on all cleanup decisions, officials of all three entities 
state that the partnership has been working effectively in the recent 
past. Continued progress at the site will depend, in part, on the 
effectiveness of this partnership over the duration of the cleanup 
period. 

Government Entities Are Authorized to Take Various Actions for Cleanup 
at the Spring Valley Site: 

Because Spring Valley was designated as a FUDS, Defense is authorized to
carry out cleanup activity at the site under the environmental 
restoration program established by SARA. The environmental restoration 
program also provides for participation by other entities. 
Specifically, in carrying out the environmental restoration program, 
Defense is required to consult with EPA, which has its own authority 
under CERCLA to act at the site. Also, Defense must carry out the 
program consistent with section 120 of CERCLA. Section 120 addresses 
the cleanup of federal facilities and, among other things, provides for 
participation in cleanup decisions by the state (in this case, the 
District of Columbia) in which a federal facility is located. The 
following sections provide more detail on the entitiesï¿½ authorities. 

* Under the environmental restoration program, Defense is authorized to
identify, investigate, and clean up hazards at FUDS. In implementing the
environmental restoration program, Defense has established guidance for
the FUDS program. The FUDS program is intended to reduce the risk to
human health and safety, and to the environment, resulting from past
Defense activities at FUDS properties. Defense has delegated its 
authority for administering the FUDS program to the U.S. Army; in turn, 
the U.S. Army has delegated execution of the program to the Corps. The 
Corpsï¿½ responsibilities include determining the eligibility of 
properties for inclusion in the FUDS program, identifying the 
requirements for funding the FUDS program, conducting environmental 
restoration activities at eligible properties, and reporting on the 
cleanup progress. The Corps is responsible for the cleanup of 
environmental contamination related to past Defense activities at 
eligible sites. 

* Defenseï¿½s policies for administering FUDS are outlined in its
environmental restoration program management guidance, which cites
CERCLA as the statutory framework. Additionally, under the Corpsï¿½
guidance, efforts should be made to accommodate standards,
requirements, or criteria requested by EPA, states, and local 
authorities where they are consistent with CERCLA. Both of these 
guidance manuals recognize the importance of involving EPA, the state 
government, and the public, among others. Defense consults with EPA and 
the states on cleanup decisions at specified points in the 
environmental restoration process, such as developing a site-wide 
sampling plan. Also, at Spring Valley, the Corps was urged to form an 
advisory board to involve the community and others. According to the 
Corps, these efforts have the overall goal of ensuring that decisions 
regarding environmental restoration activities reflect a broad spectrum 
of advice, expertise, and stakeholder concerns in making cleanup 
decisions. 

* As with any hazardous waste site, EPA has its own authority under
CERCLA to act, including investigating the site and carrying out a 
removal action.[Footnote 4] EPA has established written policy for its 
activities at FUDS.[Footnote 5] The policy states that EPA intends to 
minimize duplication of effort, but may become more involved at a site 
if conditions warrant EPA action. EPA has not listed Spring Valley on 
its national priorities list of hazardous waste sites. According to EPA 
officials, if a site is not listed and there is no ï¿½imminent and 
substantial endangermentï¿½ or the releases are being adequately 
addressed by others, EPA may limit its role. According to EPA 
officials, EPA has the flexibility to increase its role should it later
determine that greater participation is warranted. At Spring Valley, EPA
has chosen not to investigate and remove hazards because Defense is
carrying out the cleanup, and because the Corps has expertise in
munitions and has responsibility for ordnance-related cleanups. EPA 
receives no targeted resources for FUDS. At Spring Valley, EPA primarily
consults with and provides technical assistance to Defense and the 
District of Columbia. For example, EPA has consulted with the Corps to 
interpret aerial photography and test soil to locate potential buried 
hazards and contaminated soil. The Corps notes that EPA has been fully 
engaged in the decision making process at the site. 

* According to EPA, CERCLA provides that federal cleanup standards be
used at sites covered by the statute, unless a promulgated state-wide
standard exists which is more stringent than the federal standard.
According to District of Columbia Department of Health officials, they 
are establishing cleanup standards for hazardous wastes under the 
Brownfield Revitalization Amendment Act of 2000, which contains some 
provisions comparable to CERCLA. As of the end of April 2002, the 
standards were in draft form. Although these standards were not yet 
final, a District of Columbia Department of Health official told us 
that the lack of formal standards would have no effect on the cleanup 
decisions made at Spring Valley. 

Government Entities Have Formed an Active Partnership: 

Over time, the Corps, EPA, and the District of Columbia formed a
partnership in order to reach accord on important cleanup decisions. 
Early on in the cleanup, EPA and the District of Columbia collaborated 
with the Corps, but they did not always agree with the Corpsï¿½ 
decisions. Further, there were concerns about the extent of 
collaboration on decision-making. For example, according to a senior 
District of Columbia Department of Health official, in the mid-1990s 
the District of Columbia environmental officials were not consulted on 
important cleanup decisions.[Footnote 6] 

In the past several years, the partnering process for reaching cleanup
decisions has become increasingly more formalized and active. EPA has
provided assistance in identifying possible buried hazards by using
photographic interpretation of aerial maps and providing technical
expertise with regard to the presence of hazards in soil, water, and 
air. The Corps now routinely coordinates with EPA and the District of 
Columbia on technical and health-related issues. In terms of cleanup 
levels, EPA has proposed how much contamination may remain in the soil 
without endangering human health and the environment. Under the Corpsï¿½ 
guidance, the District of Columbia has a role in defining the cleanup 
levels at the Spring Valley site. According to the District of 
Columbiaï¿½s Department of Health, the department assesses the human 
health risks associated with any exposure to remaining hazards at 
Spring Valley. In addition, the District of Columbia, together with the 
Agency for Toxic Substances and Disease Registry (ATSDR), is studying 
whether residents have actually been exposed to arsenic in the soil. 
[Footnote 7] The government entities currently collaborate on the 
process of selecting a cleanup level, addressing health risks posed by 
hazards, and communicating with the public. 

Additionally, in the past year, advisory entities have been created to
further facilitate the partnering process and ensure buy-in from all
partners and community members. Important decisions, such as the
cleanup levels at Spring Valley and the plan to prioritize cleanup, are 
now routinely discussed among these entities. The Restoration Advisory 
Board (the Board) and the Scientific Advisory Panel (the Panel) are two 
active advisory entities in which partners exchange information and 
collaborate as to cleanup decisions and potential health risks. The 
Board, created in May 2001, consists of residents of Spring Valley as 
well as representatives from the Corps, EPA, the District of Columbia, 
and American University, among others. The District of Columbia created 
the Panel in March 2001 to advise the District of Columbia and other 
partners on health risks associated with the hazards at Spring Valley. 
The Panel is currently evaluating data and is expected to make a 
recommendation as to the proposed cleanup level of arsenic in soil at 
the Spring Valley site. This recommendation was announced at the 
Panelï¿½s May 29, 2002, meeting. The partners expect to finalize this 
decision by early June 2002. 

Officials acknowledge that, by having formed a partnership, a means 
exists to foster communication and collaboration, and stated that the 
partnership has been effective in the recent past. Continued progress 
at the siteï¿½which includes, among other things, finalizing a cleanup 
level for arsenic in soilï¿½will depend on the effectiveness of this 
partnership over the duration of the cleanup period. 

Government Entities Have Identified and Removed a Large Number of 
Hazards, but the Extent of Hazards Remaining Is Unknown: 

The Corps, in partnership with EPA and the District of Columbia, has
identified and removed a large number of hazards from areas within the
Spring Valley site. However, the extent to which hazards remain 
throughout the site is unknown. Since 1986, the U.S. Army has twice 
concluded that no large burials of ordnance remained on the site, but
subsequent investigations discovered additional ordnance in large burial
pits and widespread arsenic-contaminated soil. The Corps is continuing 
to search for hazards. 

U.S. Army Twice Concluded That No Large-Scale Hazards Remained at the 
Site: 

The U.S. Army concluded in 1986 and again in 1996 that it had not found
any evidence of large-scale burials of hazards remaining at Spring 
Valley.[Footnote 8] In March 1986, American University was preparing to 
begin the largest construction project in its history, but it was 
concerned that chemical munitions might have been buried on campus. 
After the results of the universityï¿½s search of its own and available 
government records proved inconclusive, the university contacted the 
U.S. Army for assistance. The U.S. Armyï¿½s Toxic and Hazardous Materials 
Agency reviewed the work done by the university and interviewed the 
university officials who had done the work, reviewed documentation from 
additional sources, such as military and university libraries and 
historical centers and the National Archives, and contracted with EPAï¿½s 
Environmental Photographic Interpretation Center to review available 
aerial photographs of the site taken during the World War I era. 
However, the photographs were not received or reviewed by EPA 
headquarters or Region III prior to 1993, according to EPA officials. 
Based on the results of its review, in October 1986, the U.S. Army 
concluded that if any materials were buried in the vicinity of the 
university, the amounts were probably limited to small quantities and 
no further action was needed. In August 1986, the U.S. Army agreed to a 
plan to ensure safety in the event that ordnance was actually 
discovered during the construction project. This plan included an onsite
support presence before, during, and after any excavation activities.
According to the university, no buried ordnance was found before or
during the construction project. 

In January 1993, a utility contractor accidentally uncovered buried 
ordnance at another location in the Spring Valley site. The U.S. Armyï¿½s
Chemical and Biological Defense Command immediately responded and, by 
February 1993, had removed 141 pieces of ordnance, 43 of which were 
suspected chemical munitions (but most were destroyed before being 
tested). Immediately following this removal, the Corps began to 
investigate the site. To focus its investigation, the Corps revisited 
the documents reviewed by the Toxic and Hazardous Materials Agency in
1986, including the results of the photographic analysis performed by
EPAï¿½s Environmental Photographic Interpretation Center, and reviewed
additional information. The Corps identified 53 locations with the 
greatest potential for hazards. The Corps decided that if it found 
contamination in any of these locations, it would expand its 
investigation around each contaminated location. 

During the investigation, the Corps used two techniques to look for
potential hazards: (1) a subsurface (geophysical) soil survey with metal
detectors to identify buried ordnance and (2) an analysis of soil 
samples to identify chemical contamination. The Corps surveyed soil for 
ordnance at about 490 properties, including 37 of the 53 potentially 
hazardous locations that the Corps considered to be potential ordnance 
burial sites. These surveys identified over 2,000 buried metallic 
objects that could be pieces of ordnance, which, upon further review by 
the Corps, were narrowed down to about 840 warranting further 
excavation. These excavations led the Corps to identify and remove one 
piece of ordnance containing suspected chemical agent, ten expended 
pieces of ordnance, an empty bomb nose cone, and several fragments of 
ordnance scrap. Concurrently with the Corpsï¿½ investigation, a builder 
found another piece of ordnance during construction activities, and two 
pieces of ordnance were anonymously left for the Corps to find. As for 
soil sampling, the Corps, in conjunction with EPA, sampled for a 
variety of chemicals at 15 of the 53 potentially hazardous locations 
where historical documents indicated field-testing, development, or 
accidental releases of chemical agents were known or believed to have 
occurred.[Footnote 9] No chemical warfare agents, explosives, or 
Defense-related chemicals whose only source could be chemical warfare 
agents or explosives were found in any soil samples collected at these 
locations, according to the Corps. Some metals were detected at levels 
exceeding both EPAï¿½s screening levels (levels that EPA estimates are 
associated with a one in a million increased risk of causing cancer) 
and naturally occurring levels; but risk assessments, which consider 
many factors such as the levels of the chemicals, the likelihood of 
exposure to the chemicals, and the toxicity of the chemicals, indicated
that no remedial action was needed, according to the Corps. 

Following this investigation, in June 1995, the U.S. Army determined 
that no further action was required at the Spring Valley site, except 
for a portion of the site referred to as the Spaulding/Captain Rankin 
Area, which was then still under investigation. This area contained 
concrete shell pits or bunkers that were used during World War I to 
test explosives and chemical warfare agents. Subsequent sampling 
detected arsenic in the layer of soil on the bunkersï¿½ concrete floors 
and debris at levels exceeding both EPAï¿½s screening and naturally 
occurring levels, but risk assessments indicated that no remedial 
action was necessary, according to the Corps. Therefore, in June 1996, 
the Corps recommended that no further action be taken at the 
Spaulding/Captain Rankin Area. With both investigations, the U.S. Army 
maintained that it would remain responsible for taking any actions 
necessary if DOD-related hazards were discovered at the site. 

Follow-on Investigations Found Additional Large-Scale Hazards" 

In 1997, the District of Columbia completed a report of the actions 
taken at the Spring Valley site that raised a number of concerns about 
how the Corps had completed its investigation. In response, the Corps 
reviewed its work at the site and concluded that it had incorrectly 
located 1 of the 53 potentially hazardous locations it had previously 
investigated, which should have been situated on a property owned by 
the Republic of Korea (South Korea) on Glenbrook Road.[Footnote 10] 

According to the Corps, in February 1998, it surveyed the soil on the 
South Korean property and identified two potential burial pits. 
Excavation initiated in March 1999 and completed in March 2000 yielded 
288 pieces of ordnance, 14 of which were chemical munitions; 175 glass 
bottles, 77 of which contained various chemicals, including mustard and 
lewisite; and 39 cylinders and 9 metal drums. Soil sampling conducted 
by EPA in mid-1999 resulted in the discovery of elevated levels of 
arsenic at the South Korean property and two adjacent properties on 
Glenbrook Road. Subsequent analyses concluded that arsenic was present 
in the soil at these properties at levels exceeding both EPAï¿½s 
screening level for residential areas and the naturally occurring 
levels for Spring Valley. The Corps decided that contaminated soil 
needed to be removed from this site. By May 2001, the Corps had removed 
arsenic-contaminated soil from the South Korean property and the 
adjacent property. It has not yet conducted soil removal at the third 
property, which is the American University Presidentï¿½s residence. As of 
April 2002, the Corps had completed most restoration (i.e., 
landscaping) activities at the South Korean property, but is still 
working at excavating a pit that extends from the South Korean property
into the adjacent property on Glenbrook Road. In total, the Corps had
removed about 4,560 cubic yards of contaminated soil from these 
properties. 

After the discovery of hazards on the Glenbrook Road properties, and
consistent with the rationale it employed during the investigation, in
January 2000, at the request of the District of Columbia, the Corps
expanded its arsenic investigation to include about 60 nearby residences
and the southern portion of the American University campus. Sampling at
these locations found elevated levels of arsenic at the American 
University Child Development Center and other locations on the American 
University campus, and on 11 residential properties. As of April 2002, 
the Corps had removed about 1,063 cubic yards of contaminated soil from 
American University. The Corps is finalizing plans to address arsenic 
contamination in soil at other locations on American University. 

Agencies Have Initiated Extensive Additional Investigations for 
Hazards: 

At a public meeting in February 2001, community members urged testing
the entire Spring Valley neighborhood for arsenic, a request first made 
by the District of Columbia in its 1997 report. The Corps, in 
consultation with EPA and the District of Columbia, agreed to sample 
soil for arsenic on all 1,483 properties within the Spring Valley site, 
with more intensive sampling at selected properties located where 
historical documents indicated that chemical weapons testing may have 
occurred. This expanded sampling effort, begun in May 2001, was 
completed at 1,316 properties, as of April 2002. About 160 of these 
sampled properties will require some degree of cleanup. Currently, 
seven of these properties are identified for priority removals of 
arsenic-contaminated soil because they present relatively higher risks 
of exposure, according to the Corps. The priority removals are 
scheduled to begin by late June 2002. In addition, the Corps has 
sampled for additional chemicals in selected locations depending on 
information it has about what type of research activities might have 
occurred at the locations in the past. The results of the sampling are 
currently under review, but preliminary results have not identified any 
additional chemicals of concern. 

In May 2001, at the urging of the District of Columbia and EPA, the 
Corps began to investigate an additional burial pit on the property 
line between the South Korean property and the adjoining residence on 
Glenbrook Road. The Corps discovered this pit by conducting a number of
exploratory excavations at the adjoining property to determine whether
any additional buried ordnance might be present. The Corps is continuing
to investigate the burial pit, and as of January 2002, had found 379 
pieces of ordnance, 11 of which contained the chemical warfare agents 
mustard and lewisite; fragments of another 8 pieces of ordnance; 60 
glass bottles and 3 cylinders, 24 of which contained mustard, lewisite, 
and acids; and 5 metal drums that showed signs of leakage.[Footnote 11] 

Concurrently with the efforts to expand the arsenic investigation, the
Corps is planning to expand its efforts to survey properties for buried
ordnance. EPAï¿½s Environmental Photographic Interpretation Center has
reviewed archives and several additional aerial photographs of the area.
This review and subsequent surveying activities performed by the Corps
identified two properties on Sedgwick Street where buried metallic 
objects that could possibly be pieces of ordnance need to be excavated.
The Corps plans to begin excavating these properties by September 2002.
In addition, the Corps, in conjunction with EPA and the District of
Columbia, is developing a list of properties to be geophysically 
surveyed for potential buried ordnance. Along with the results of the 
review performed by EPAï¿½s Environmental Photographic Interpretation 
Center, other site-specific information, such as the results of 
previous arsenic sampling and the extent of prior landscaping work, 
will be factored into determining priorities for surveying these 
additional sites. As of April 2002, the Corps had estimated that a 
total of 200 properties would be surveyed for ordnance. The government 
entities recognize that the extent that hazards remain may never be 
known with certainty due to the technical limitations associated with 
sampling and geophysically surveying soil. 

Risks from Buried Hazards and from Arsenic-Contaminated Soil Drive 
Cleanup Decisions: 

At Spring Valley, as at other FUDS, cleanup decisions depend on the
immediacy of the safety and human health risks presented. If disturbed,
unexploded or leaking ordnance or containers filled with chemical 
warfare agent may present an immediate risk, and the partners have 
agreed to remove these hazards as soon as possible after their 
discovery. In contrast, exposure to arsenic-contaminated soil poses a 
long-term health risk and the partners have, in the past, disagreed 
about the level and extent of the risk at Spring Valley. Over the past 
year, the partners have been in the process of reaching agreement on 
the level of arsenic that may remain in the soil and that is protective 
of human health and the environment. The partners have agreed on a 
proposed cleanup level and are awaiting input from the Panel before 
finalizing the decision. 

Ordnance Removal Generally Takes Priority Because of the Immediacy of 
Risk: 

Throughout the cleanup of the Spring Valley site, identification and
removal of buried ordnance have been and continue to be the government
entitiesï¿½ top priorities in terms of human health concerns and cleanup
decisions. Because of the immediacy of the potential risk posed by human
contact with ordnance, for example by the detonation of unexploded
ordnance or skin exposure to a leaking container of a chemical warfare
agent such as lewisite, the government entities agree that ordnance and
containers must be removed as soon as possible after they are found to
avoid the risk of immediate injury or death. Accordingly, since early 
on in the cleanup effort at Spring Valley, removal of buried ordnance 
has taken priority over other tasks. For example, shortly after the 
accidental discovery of buried ordnance in January 1993, the U.S. Army 
initiated an emergency response action to identify and remove ordnance 
buried at the site. Four weeks after that initial discovery, the U.S. 
Army had removed 141 pieces of ordnance, and the Corps, in conjunction 
with EPA and the District of Columbia, began its comprehensive 
investigation of the entire site, including soil sampling. 

Arsenic-contaminated Soil Cleanup Depends on Ultimate Risk 
Determination: 

The partners also attempt to set priorities for cleaning up properties
containing elevated levels of chemicals or metals in soil on the basis 
of the risk the hazards pose. As noted previously, after the Corps 
completed the emergency removal of ordnance in 1993, it began to sample 
soil for contamination. The Corps collected 260 soil samples from 15 
locations, and with EPA, tested and analyzed the samples. No chemical 
warfare agents, explosives, or chemicals whose only source could be 
chemical warfare agents or explosives were found in any of the samples; 
however, several metals were identified at levels that exceeded EPAï¿½s 
standards. The Corps used EPAï¿½s criteria to assess the health risks 
associated with these hazards to determine whether further sampling or 
soil removal was necessary. This assessment found no elevated health 
risk requiring remedial action. Arsenic was not identified as a 
contaminant of potential concern for the risk assessment, since, 
according to the Corps, the sampling results of the level of arsenic in 
the soil were not significantly different from naturally occurring 
levels. In commenting on a draft of this report, EPA noted that it was 
involved in the oversight of the cleanup and did not object to the 
decision made at the time. 

Since early 1999, with the additional discovery of buried ordnance and
elevated levels of arsenic-contaminated soil at the South Korean 
property, the levels of arsenic in soil have become the primary focus 
of soil cleanup efforts by the partners. Although many chemical agents 
were tested at Spring Valley during World War I, of those contaminants 
now present at elevated levels, arsenic is deemed to pose the greatest 
risk to human health and therefore is the contaminant of most concern 
to the partners. The partners recognize that arsenic exposure at 
certain doses in drinking water has been generally linked to cancers 
and other adverse health conditions.[Footnote 12] Based on scientific 
studies, the District of Columbia has identified lung cancer, bladder 
cancer, and skin cancer as effects associated with the long-term 
ingestion of arsenic. However, the extent to which arsenic is present 
and residents are exposed through ingestion, inhalation, or external 
contact at Spring Valley is unknown. The District of Columbia has 
requested technical assistance from ATSDR, which has conducted an 
exposure investigation of residents who have high arsenic levels on 
their property. Through soil sampling, the partners have attempted to 
detect levels of arsenic in the soil to ascertain health risks and to 
set priorities for cleanup. The partners agree that soil containing 
elevated levels of arsenic poses a greater health risk than does soil 
with lesser levels of arsenic. As such, properties with greater levels 
of arsenic in soil generally have cleanup priority over properties with 
lesser levels of arsenic. 

After the Corps tested and confirmed elevated arsenic soil levels at 
American Universityï¿½s Child Development Center, at the request of the
District of Columbia, ATSDR conducted an exposure study to determine
the extent of arsenic exposure in children and employees at the site. 
After testing hair samples, ATSDR concluded that the children and 
employees had had no significant exposure to arsenic. Spring Valley 
residents then requested comprehensive soil sampling, extending to 
every residence in the Spring Valley site. The Corps, in consultation 
with EPA and the District of Columbia, responded with a plan to sample 
for arsenic on every property in Spring Valley, with more intensive 
sampling in selected locations. Efforts are still underway to determine 
the extent of arsenic present at Spring Valley and the extent to which 
residents are likely to have been exposed to that risk. At the request 
of the District of Columbia, ATSDR is conducting another exposure study 
(biomonitoring), in which it is studying the level of arsenic present 
in biological samples from residents on Spring Valley properties with 
the highest levels of arsenic in the soil. The individual results from 
the biological samples collected during the exposure investigation were 
mailed to the residents May 16, 2002, and were reviewed and discussed 
by the Panel on May 29, 2002. 

The District of Columbia has also conducted descriptive epidemiological
studies in an attempt to assess the arsenic-related health effects in 
Spring Valley compared with two control groups. The studies examined the
incidence of bladder, skin, lung, liver, and kidney cases. However, the
number of cases of liver and kidney cancers at Spring Valley was too 
small to conduct a meaningful statistical analysis. Of bladder, skin, 
and lung cancers, however, the District of Columbia observed no 
excesses of cancer incidence and mortality in Spring Valley as compared 
to U.S. national rates, and one of these control groups. 

Residents have raised concerns about the extent of the population 
studied and completeness of data used for these exposure and 
epidemiological studies. For example, some residents have voiced 
concerns that the full suite of hazards present at Spring Valley, even 
at trace levels, has not been factored into exposure and 
epidemiological studies and that arsenic is the sole hazard considered 
for exposure studies. The District of Columbia and the Corps have 
indicated that mustard agent was found in containers in the pit 
discovered at Glenbrook Road in May 2001. The District of Columbiaï¿½s 
Department of Health does not plan to study exposure to mustard agent, 
however, because it did not identify a pathway of exposure to mustard 
agent that could produce a dose resulting in adverse human health 
effects. The District of Columbiaï¿½s Department of Health has told 
Spring Valley residents that, if necessary, it will expand the 
investigation to hazards other than arsenic, if the hazard is found at 
levels of concern in Spring Valley. 

As of April 2002, because of the safety risks associated with the 
ordnance burial pit on Glenbrook Road, the Corps had temporarily 
redirected other investigation and cleanup efforts, such as soil 
surveying and removal, to the removal of known buried ordnance. To 
identify other locations of potential remaining buried hazards, the 
Corps, after consulting with the partners, has proposed a 
classification scheme that attempts to prioritize the properties most 
likely at risk for the presence of hazards. The plan takes into account 
the results of preliminary arsenic sampling, aerial photography 
interpretation, and other characteristics. In conjunction with EPA and 
the District of Columbia, the Corps is developing a priority list of
properties for additional geophysical surveys. Once comprehensive 
sampling is complete and soil removal commences, where necessary,
arsenic in soil will be reduced to a cleanup level that is now being 
finalized by the partnership. 

The partners gather feedback on health risks from residents in several
ways and consider this information when making cleanup decisions. In the
past year, a communication process has been put in place to address
residentsï¿½ concerns about the health risks associated with Spring 
Valley. The District of Columbia publishes a periodic newsletter that 
has included information from ATSDR and updates residents on the latest 
information regarding the District of Columbiaï¿½s efforts to address the 
issues in Spring Valley, including the Scientific Advisory Panel 
meeting agenda. A hotline gives residents an opportunity to voice their 
concerns or share anecdotal information about exposure to hazards. 
Moreover, in November 2001, the District of Columbia and ATSDR 
conducted a focus group comprised of Spring Valley residents to, among 
other things, discuss community health concerns. The partners have also 
sponsored public meetings and distributed questionnaires. The District 
of Columbia has used anecdotal information from the residents about 
health effects they have experienced and compared that information to 
scientific literature concerning symptoms of certain cancers related to 
arsenic exposure. 

The Corpsï¿½ Estimated Cost and Cleanup Schedule May Change as More 
Information about the Site Is Known: 

As of April 2002, the Corps estimated that the Spring Valley cleanup 
would cost another $71.7 million, including fiscal year 2002, and take 
5 years beyond fiscal year 2002 to complete, but these estimates are 
uncertain. Factors, such as the potential discovery of additional 
hazards, make it inherently challenging for the Corps to estimate the 
cost for completing cleanup activities at the site, as evidenced by 
periodic estimated cost increases. Further, the Corpsï¿½ estimated 
schedule for completing the cleanup necessarily depends on projections 
of available annual funding, which may be different from actual 
funding. Consequently, any significant increases in the estimated cost 
of completing the cleanup or decreases in the amount of available 
funding would likely require that the Corps extend the completion date 
for Spring Valley. 

Estimated Cost to Clean up Spring Valley Has Increased by about Six 
Fold Since 1997: 

Under the environmental restoration program, the Secretary of Defense is
required to report annually to the Congress on the progress the 
department has made in carrying out environmental restoration activities
at military installations and FUDS. From fiscal years 1997 through 2001
(the most recent report available), the total estimated cost to clean up
Spring Valley increased by about six fold, from about $21 million to 
about $124.1 million. In response to our request, the U.S. Army 
provided us with an update of the Corpsï¿½ estimate, as of April 2002. 
The Corps had revised its estimate slightly to about $125.1 million, as
shown in figure 3.[Footnote 13] 

Figure 3: Total Estimated Cost to Clean up Spring Valley, Fiscal Years 
1997 through 2001 and as of April 2002 (dollars in millions): 

[Refer to PDF for image] 

This figure is a stacked vertical bar graph depicting the following 
estimated data: 

Fiscal year: 1997; 
Cost to complete: $20 million; 
Spent to date: $20 million. 

Fiscal year: 1998; 
Cost to complete: $22 million; 
Spent to date: $20 million. 

Fiscal year: 1999; 
Cost to complete: $30 million; 
Spent to date: $25 million. 

Fiscal year: 2000; 
Cost to complete: $80 million; 
Spent to date: $40 million. 

Fiscal year: 2001; 
Cost to complete: $124 million; 
Spent to date: $50 million. 

Fiscal year: April 2002; 
Cost to complete: $125 million; 
Spent to date: $53 million. 

Note: For April 2002, ï¿½spent to dateï¿½ reflects the Corpsï¿½ revised total 
of the dollars spent through the end of fiscal year 2001 (September 
2001), whereas ï¿½cost to completeï¿½ reflects the Corpsï¿½ revised estimate 
for fiscal years 2002 through 2007, as of April 2002. 

Source: GAOï¿½s analysis of data from Defenseï¿½s Defense Environmental 
Restoration Program annual reports to the Congress, fiscal years 1997 
through 2001, and data from the Corps. 

[End of figure] 

Costs have increased principally because the Corps needed to increase 
the scope of the remaining cleanup, as more information about the site
became known (see table 1). 

Table 1: Estimated Cost to Complete the Cleanup at Spring Valley, 
Fiscal Years 1997 through 2001 and as of April 2002 (Dollars in 
millions): 

Year of estimate: Fiscal year 1997; 
Estimated cost to complete the clean up: $0.5 million; 
Changes to scope of the cleanup: The Corps discovered it had 
incorrectly identified one of the potentially hazardous locations it had
previously investigated. 

Year of estimate: Fiscal year 1998; 
Estimated cost to complete the clean up: $0.6 million; 
Changes to scope of the cleanup: The Corps surveyed two potential 
burial pits on the South Korean property. 

Year of estimate: Fiscal year 1999; 
Estimated cost to complete the clean up: $4.5 million; 
Changes to scope of the cleanup: The Corps increased the scope to 
include removing buried ordnance and bottles of chemicals found on
the South Korean property. 

Year of estimate: Fiscal year 2000; 
Estimated cost to complete the clean up: $35.8 million; 
Changes to scope of the cleanup: The Corps increased the scope to 
include removing arsenic-contaminated soil from the South Korean
property and two adjacent properties and subsequently expanding soil 
sampling efforts to about 60 nearby residences and the southern
portion of the American University campus. 

Year of estimate: Fiscal year 2001; 
Estimated cost to complete the clean up: $72.9 million; 
Changes to scope of the cleanup: The Corps increased the scope to 
include expanding sampling efforts to cover the entire Spring Valley 
site, surveying selected properties for buried ordnance, and completing 
additional work needed to remove buried hazards at one location. 

Year of estimate: April 2002; 
Estimated cost to complete the clean up: $71.7 million; 
Changes to scope of the cleanup: The Corps lowered its fiscal year 2001 
estimate as the preliminary results of the sitewide soil sampling
yielded additional information about the extent of arsenic 
contamination. 

Source: GAOï¿½s analysis of Defenseï¿½s data. 

[End of table] 

As shown in table 2, the April 2002 estimate depends on assumptions the
Corps has made about how many properties will require the removal of
arsenic-contaminated soil and how many properties will need to be 
surveyed and excavated to remove possible buried hazards. 

Table 2: Estimated Total Cost to Complete Cleanup Activities at Spring 
Valley, as of April 2002 (Dollars in millions): 

Activities: Ordnance removal and soil removal and restoration 
activities at the South Korean property and two adjacent properties; 
Estimated cost: $13.1 million. 

Activities: Soil removal, landscape restoration, and other related 
activities at 11 properties subsequently found to have arsenic-
contaminated soil; 
Estimated cost: $4.6 million. 

Activities: Soil removal, landscape restoration, and other related 
activities at an additional 150 properties estimated to have arsenic-
contaminated soil; 
Estimated cost: $24.4 million. 

Activities: Soil excavation and restoration activities at 2 properties 
where buried metallic objects that could be pieces of ordnance were 
identified; subsurface soil survey, excavation, and restoration 
activities at another 200 properties estimated to contain such 
features; and other related activities; 
Estimated cost: $29.7 million. 

Activities: Total; 
Estimated cost: $71.7 million. 

Note: Figures do not add to $71.7 million due to rounding. 

Source: GAOï¿½s analysis of Defenseï¿½s data. 

[End of table] 

Cost and Funding Uncertainties Suggest That Cleanup Schedule Could
Change: 

Prior to fiscal year 2000, Defenseï¿½s annual reports to the Congress did 
not provide any estimate of when the Corps planned to complete cleanup
activities at Spring Valley. In Defenseï¿½s fiscal year 2000 annual 
report to the Congress, the Corps estimated, for the first time, that 
it would complete such activities by the end of fiscal year 2012. 
However, as of April 2002, the Corps had moved up its estimate of the 
completion date by 5 years, to fiscal year 2007, even though it had 
doubled the estimated cost of the remaining cleanup. 

As shown in table 3, the Corps plans to meet the shortened time frame by
applying considerably more funding to the site in the near term. 

Table 3: Levels of Annual Funding Specified in the Corpsï¿½ Schedule for 
Completing Cleanup Work at Spring Valley, Fiscal Year 2000, Fiscal Year 
2001, and as of April 2002 (Dollars in millions): 

Year of estimate: Fiscal year 2000;
Annual funding, Fiscal year 2001: $3.3 million; 
Annual funding, Fiscal year 2002: $2.5 million; 
Annual funding, Fiscal year 2003: $2.8 million; 
Annual funding, Fiscal year 2004: $2.5 million; 
Annual funding, Fiscal year 2005: $4.7 million; 
Annual funding, Fiscal year 2006: $7.4 million; 
Annual funding, Fiscal year 2007: $8.4 million; 
Annual funding, Fiscal years 2008 to 2012: $4.2 million; 
Total cost to complete the cleanup: $35.8[A] million. 

Year of estimate: Fiscal year 2001; 
Annual funding, Fiscal year 2001: $10.7[B] million; 
Annual funding, Fiscal year 2002: $12.1 million; 
Annual funding, Fiscal year 2003: 0[C]; 
Annual funding, Fiscal year 2004: $1.2 million; 
Annual funding, Fiscal year 2005: $2.4 million; 
Annual funding, Fiscal year 2006: $2.4 million; 
Annual funding, Fiscal year 2007: $1.8 million; 
Annual funding, Fiscal years 2008 to 2012: $53.1 million; 
Total cost to complete the cleanup: $72.9[D] million. 

Year of estimate: April 2002; 
Annual funding, Fiscal year 2001: $12.9[E] million; 
Annual funding, Fiscal year 2002: $18.0[F] million; 
Annual funding, Fiscal year 2003: $11.0 million; 
Annual funding, Fiscal year 2004: $11.0 million; 
Annual funding, Fiscal year 2005: $11.0 million; 
Annual funding, Fiscal year 2006: $11.0 million; 
Annual funding, Fiscal year 2007: $9.8 million; 
Annual funding, Fiscal years 2008 to 2012: 0; 
Total cost to complete the cleanup: $71.7[G] million. 

[A] For the fiscal year 2000 estimate, the estimated total cost to 
complete the cleanup covers fiscal years 2001 through 2012. 

[B] Figure denotes actual costs incurred during fiscal year 2001. 

[C] According to the fiscal year 2001 Defense Environmental Restoration 
Program report, the U.S. Army planned to reprogram $11 million in 
funding not allocated to specific projects toward fiscal year 2003 
costs and additional dollars in the outyears. 

[D] For the fiscal year 2001 estimate, the estimated total cost to 
complete the cleanup covers fiscal years 2002 through 2012. Annual 
totals do not add to $72.9 million due to rounding. 

[E] Figure denotes actual costs incurred during fiscal year 2001 as 
revised by the U.S. Army in April 2002. 

[F] Includes a $5.2 million increase approved by the U.S. Army on April 
9, 2002. According to the Corps, these funds were reprogrammed from 
possible use at other sites. 

[G] For the April 2002 estimate, the estimated total cost to complete 
the cleanup covers fiscal years 2002 through 2007. Annual totals do not 
add to $71.7 million due to rounding. 

Source: GAOï¿½s analysis of Defenseï¿½s data. 

[End of table] 

However, the Corps may find it difficult to achieve its planned 
completion even if there are no further changes to the scope of work. 
As part of its April 2002 revised estimate, the Corps acknowledged that 
meeting the schedule would depend on the FUDS budget and the U.S. 
Armyï¿½s ability to apply the specified funding to the Spring Valley 
site. In order to continue to meet these needs, the U.S. Army may have 
to reprogram funds from possible use at other sites nationwide in each 
of the remaining years of the cleanup. Furthermore, in fiscal year 
2002, the Corps planned to allocate to Spring Valley about 8 percent of 
the national budget for FUDSï¿½which has declined in recent yearsï¿½and 
about 86 percent of the FUDS budget for the Baltimore District, which 
includes funding for FUDS in the District of Columbia and the states of 
Delaware, Maryland, New York, Pennsylvania, Virginia, and West 
Virginia. According to the U.S. Army, the provision of funds for the 
Spring Valley cleanup is currently adversely affecting the availability 
of funding and progress at other sites. 

As more information becomes available about the hazards at the site, the
Corps will develop a clearer sense of how reliable its assumptions are 
on the extent of the hazards present and the cost of removing them. The
Corpsï¿½ experience with excavating buried hazards at two Glenbrook Road
properties illustrates the difficulty of estimating the cost of removing
buried hazards. In fiscal year 2002, the Corps determined that 
completing the removal would cost about $6 million more than 
anticipated at the end of fiscal year 2001. Furthermore, the Corps 
assumed that arsenic would remain the focus of its efforts to reduce 
the risks of exposure to contaminated soil, and based its cost estimate 
on the work needed to meet a proposed cleanup level for arsenic; as of 
April 2002, the partners had not finalized this level. As part of its 
expanded soil sampling efforts, the Corps could identify the presence 
of yet other chemicals and expand the scope of soil removal. Until more 
complete information is known about the actual types and extent of the 
hazards present throughout the site and the actual cost of removing 
them, the reliability of the Corpsï¿½ estimate of the cost and schedule 
to complete the cleanup remains uncertain. 

Observations: 

Uncertainties will continue to affect the progress of the Spring Valley
cleanup. The unknowns are many: the potential that as-yet undiscovered
hazards will come to light and expand the scope of necessary cleanup
activities; the extent of soil removal or cleanup that will be needed, 
which depends, in part, on reaching final agreement on a cleanup level 
for arsenic in the soil; and the actual availability of funding for the 
site cleanup that the Corps has projected for future years. Further, 
these uncertainties are interdependent; for example, estimating the 
amounts of funding needed in future years requires some certainty about 
the scope of the cleanupï¿½certainty that has proven to be elusive as 
additional hazards have been discovered in the past. 

The Corps, EPA, and the District of Columbia have made progress by
adopting a partnership approach to Spring Valley cleanup decisions.
Importantly, they have established a systematic means of communicating
information to, and receiving input from, the residents of Spring 
Valley and other interested members of the public. Progress depends on 
the continued effectiveness with which the government entities involved 
will sustain their partnership approach throughout the cleanup period.
However, until some of the existing uncertainties are resolved, the
government entities will not be able to provide the community with 
definitive answers on any remaining health risks or the cost and 
duration of the cleanup. 

Agency Comments: 

We provided the Department of Defense, Environmental Protection Agency, 
and the District of Columbiaï¿½s Department of Health with a draft of 
this report for review and comment. These agencies generally agreed 
with the information presented in the draft. They provided a number of
technical comments, which we incorporated in the report as appropriate.
Defense stated that, while they agreed that there are some uncertainties
associated with the Spring Valley cleanup, it is important to note that 
such unknowns are not unique to Spring Valley, and that every 
environmental cleanup involves a number of unknowns, regardless of the 
locale, type of contaminant, or specific entity executing the cleanup. 
In addition, Defense stated that the partnership formed has been a 
model for regulatory relationships at other site cleanups. EPA stated 
that our report develops an accurate and unbiased appraisal of the 
problems and uncertainties present at the Spring Valley site, and that 
our report presents the substantive historical facts of this very 
complex and challenging site cleanup. The District of Columbiaï¿½s 
Department of Health stated that it is committed to continuing to work 
with the other governmental partners to establish and fully implement 
any action and/or remediation plan it determines is required to protect 
human health. The letters from these agencies are included in 
appendixes II through IV. 

Scope and Methodology: 

We performed our review at the Corpsï¿½ project office at the site, U.S.
Armyï¿½s and EPAï¿½s headquarters in Washington, D.C., and the District of
Columbiaï¿½s Department of Health in Washington, D.C. We reviewed 
statutes, regulations, and appropriate guidance, as well as interviewed
government entity program officials to determine the relevant statutory
framework. We interviewed officials at Defense and U.S. Army 
headquarters responsible for overseeing the FUDS program and budget.
We interviewed officials at EPA headquarters, including those from the
Office of Solid Waste and Emergency Response responsible for developing
EPAï¿½s guidance for FUDS, and the Office of Enforcement and Compliance
Assurance responsible for investigating matters relating to Spring 
Valley. Further, we interviewed regional and project officials of both 
federal agencies, as well as officials from the District of Columbiaï¿½s 
Department of Health, to understand their roles as actually carried out 
at the site. We reviewed historical information and agency data, as 
well as interviewed appropriate officials to identify hazards found at 
the site and the progress made toward cleaning up the site. We reviewed 
descriptive epidemiological studies conducted by the District of 
Columbia and interviewed Department of Health officials to understand 
risks associated with hazards at the site. We also attended Restoration 
Advisory Board and Scientific Advisory Panel meetings to gain an 
understanding of the perspectives of the various stakeholders. We 
reviewed cost, budget, and schedule data from the U.S. Army and the 
Corps and interviewed appropriate officials to determine how much the 
Corps had spent to date at the site and understand the Corpsï¿½ estimate 
of how much it would cost and how long it would take to complete the 
cleanup. 

We conducted our work from October 2001 through May 2002 in accordance 
with generally accepted government auditing standards. 

As we agreed with your office, 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 other 
interested parties and make copies available to others who request 
them. In addition, the report will be available at no charge at GAOï¿½s 
Web site at [hyperlink, http://www.gao.gov]. 

If you or your staff has any questions about this report, please call 
Peg Reese or me at (202) 512-3841. Key contributors to this report are 
listed in appendix VI. 

Signed by: 

David G. Wood: 
Director, Natural Resources and Environment: 

[End of section] 

Appendix I: Properties in the District of Columbia Where Hazards 
Resulting from Federal Activities Have Been Found: 

Table 4 contains summary data on 44 properties in the District of 
Columbia where hazards resulting from federal activities have been 
found, using Defense data as of March 2002 and EPA data as of April 
2002. For each property, the data include the name of the property, the 
agency or agencies responsible for leaving the hazards, the past or 
current use of the property, and the hazards found. Most sites are 
active Department of Defense (Defense) installations or formerly used 
defense sites (FUDS). For an active Defense installation, the host 
military branch of the installation is responsible for the cleanup 
while the U.S. Army Corps of Engineers (the Corps) is responsible for 
the cleanup of all FUDS. In addition, there are six properties 
involving other federal agencies that are being addressed through the 
Environmental Protection Agencyï¿½s environmental cleanup programs. 

Table 4: Properties in the District of Columbia Where Hazards Resulting 
from Federal Activities Have Been Found: 

Defense, active installations (8): 

Name of property: Bolling Air Force Base[A]; 
Agency or agencies responsible for leaving the hazards: U.S. Air Force; 
Past or current use of the property: Active installation; 
Hazards found: Polychlorinated biphenyls (PCB); petro hydrocarbons; 
benzene, toluene, ethylbenzene, and xylenes (BTEX); semi-volatile 
organic compounds (SVOC); lindane; dichlorodiphenyltrichloroethane 
(DDT); and heavy metals. 

Name of property: Fort McNair[A]; 
Agency or agencies responsible for leaving the hazards: U.S. Army; 

Past or current use of the property: Active installation; 
Hazards found: Lead, BTEX, and total petroleum hydrocarbons (TPH); 

Name of property: Naval Stationï¿½Anacostia; 
Agency or agencies responsible for leaving the hazards: U.S. Navy; 
Past or current use of the property: Active installation; 
Hazards found: Acid, heavy metals, and other chemicals. 

Name of property: Naval Observatory; 
Agency or agencies responsible for leaving the hazards: U.S. Navy; 
Past or current use of the property: Active installation; 
Hazards found: Petroleum, oil, and lubricants. 

Name of property: Naval Research Laboratory; 
Agency or agencies responsible for leaving the hazards: U.S. Navy; 
Past or current use of the property: Active installation; 
Hazards found: Hazardous, toxic, and radioactive waste. 

Name of property: Naval Security Station[A]; 
Agency or agencies responsible for leaving the hazards: U.S. Navy; 
Past or current use of the property: Active installation; 
Hazards found: Hazardous, toxic, and radioactive waste. 

Name of property: Walter Reed Army Medical Center[A]; 
Agency or agencies responsible for leaving the hazards: U.S. Army; 

Past or current use of the property: Active installation; 
Hazards found: Fuel oil. 

Name of property: Washington Navy Yard[A]; 
Agency or agencies responsible for leaving the hazards: U.S. Navy; 

Past or current use of the property: Active installation; 
Hazards found: Heavy metals, chlorinated solvents, and PCB. 

Defense, FUDS (30): 

Name of property: Anti-Aircraft Artillery Siteï¿½Fort Reno; 
Agency or agencies responsible for leaving the hazards: U.S. Army; 

Past or current use of the property: Civil War fortification and anti-
aircraft site; 
Hazards found: Civil War-era ordnance and explosive waste. 

Name of property: Barney Circle; 
Agency or agencies responsible for leaving the hazards: U.S. Army Corps 
of Engineers and National Park Service; 
Past or current use of the property: Landfill; 
Hazards found: Lead. 

Name of property: Camp Simms Military Reservation; 
Agency or agencies responsible for leaving the hazards: Department of 
Defense; 
Past or current use of the property: Military installationï¿½small arms 
range; 
Hazards found: Ordnance and explosive waste, and hazardous, toxic, and 
radioactive waste. 

Name of property: Catholic Universityï¿½Offense Research Station; 
Agency or agencies responsible for leaving the hazards: U.S. Army; 
Past or current use of the property: World War I munitions research 
laboratory; 
Hazards found: Ordnance and explosive waste. 

Name of property: Chain Bridge Batteries Complex; 
Agency or agencies responsible for leaving the hazards: U.S. Army; 
Past or current use of the property: Civil War fortification; 
Hazards found: Civil War-era ordnance and explosive waste. 

Name of property: Diamond Ordnance Fuze Laboratories[A]; 
Agency or agencies responsible for leaving the hazards: U.S. Army and 
Department of Commerce; 
Past or current use of the property: Former location of the National 
Bureau of Standardsï¿½ ordnance research and development activities; 
Hazards found: Ordnance and explosive waste. 

Name of property: Fort Baker; 
Agency or agencies responsible for leaving the hazards: U.S. Army; 
Past or current use of the property: Civil War fortification; 
Hazards found: Civil War-era ordnance and explosive waste. 

Name of property: Fort Bayard; 
Agency or agencies responsible for leaving the hazards: U.S. Army; 
Past or current use of the property: Civil War fortification; 
Hazards found: Civil War-era ordnance and explosive waste. 

Name of property: Fort Bunker Hill; 
Agency or agencies responsible for leaving the hazards: U.S. Army; 
Past or current use of the property: Civil War fortification; 
Hazards found: Civil War-era ordnance and explosive waste. 

Name of property: Fort Chaplin; 
Agency or agencies responsible for leaving the hazards: U.S. Army; 
Past or current use of the property: Civil War fortification; 
Hazards found: Civil War-era ordnance and explosive waste. 

Name of property: Fort Davis; 
Agency or agencies responsible for leaving the hazards: U.S. Army; 
Past or current use of the property: Civil War fortification; 
Hazards found: Civil War-era ordnance and explosive waste. 

Name of property: Fort DeRussy; 
Agency or agencies responsible for leaving the hazards: U.S. Army; 
Past or current use of the property: Civil War fortification; 
Hazards found: Civil War-era ordnance and explosive waste. 

Name of property: Fort Dupont Park Site; 
Agency or agencies responsible for leaving the hazards: U.S. Army; 
Past or current use of the property: Civil War fortification; 
Hazards found: Civil War-era ordnance and explosive waste. 

Name of property: Fort Greble; 
Agency or agencies responsible for leaving the hazards: U.S. Army; 
Past or current use of the property: Civil War fortification; 
Hazards found: Civil War-era ordnance and explosive waste. 

Name of property: Fort Kearny; 
Agency or agencies responsible for leaving the hazards: U.S. Army; 
Past or current use of the property: Civil War fortification; 
Hazards found: Civil War-era ordnance and explosive waste. 

Name of property: Fort Lincoln[A]; 

Agency or agencies responsible for leaving the hazards: U.S. Army; 
Past or current use of the property: Civil War fortification; 
Hazards found: Civil War-era ordnance and explosive waste. 

Name of property: Fort Mahan; 
Agency or agencies responsible for leaving the hazards: U.S. Army; 
Past or current use of the property: Civil War fortification; 
Hazards found: Civil War-era ordnance and explosive waste. 

Name of property: Fort Ricketts; 
Agency or agencies responsible for leaving the hazards: U.S. Army; 
Past or current use of the property: Civil War fortification; 
Hazards found: Civil War-era ordnance and explosive waste. 

Name of property: Fort Slemmer; 
Agency or agencies responsible for leaving the hazards: U.S. Army; 
Past or current use of the property: Civil War fortification; 
Hazards found: Civil War-era ordnance and explosive waste. 

Name of property: Fort Slocum; 
Agency or agencies responsible for leaving the hazards: U.S. Army; 
Past or current use of the property: Civil War fortification; 
Hazards found: Civil War-era ordnance and explosive waste. 

Name of property: Fort Snyder; 
Agency or agencies responsible for leaving the hazards: U.S. Army; 
Past or current use of the property: Civil War fortification; 
Hazards found: Civil War-era ordnance and explosive waste. 

Name of property: Fort Stanton; 
Agency or agencies responsible for leaving the hazards: U.S. Army; 
Past or current use of the property: Civil War fortification; 
Hazards found: Civil War-era ordnance and explosive waste. 

Name of property: Fort Stevens; 
Agency or agencies responsible for leaving the hazards: U.S. Army; 
Past or current use of the property: Civil War fortification; 
Hazards found: Civil War-era ordnance and explosive waste. 

Name of property: Fort Totten; 
Agency or agencies responsible for leaving the hazards: U.S. Army; 
Past or current use of the property: Civil War fortification; 
Hazards found: Civil War-era ordnance and explosive waste. 

Name of property: Fort Wagner; 
Agency or agencies responsible for leaving the hazards: U.S. Army; 
Past or current use of the property: Civil War fortification; 
Hazards found: Civil War-era ordnance and explosive waste. 

Name of property: Naval Stationï¿½Anacostia Annex; 
Agency or agencies responsible for leaving the hazards: U.S. Navy; 
Past or current use of the property: Ordnance research, barracks, 
school; 
Hazards found: Ordnance and explosive waste. 

Name of property: Rock Creek Park Troop Housing; 
Agency or agencies responsible for leaving the hazards: [B]; 
Past or current use of the property: [B]; 
Hazards found: [B]. 

Name of property: Shepherd Parkway; 
Agency or agencies responsible for leaving the hazards: [B]; 
Past or current use of the property: [B]; 
Hazards found: [B]. 

Name of property: Spring Valley; 
Agency or agencies responsible for leaving the hazards: U.S. Army; 
Past or current use of the property: World War I munitions testing 
area; 
Hazards found: Ordnance and explosive waste and arsenic in soil. 

Name of property: Washington Navy Yard[A]; 
Agency or agencies responsible for leaving the hazards: U.S. Navy; 
Past or current use of the property: Naval shipbuilding and ordnance 
production; 
Hazards found: Hazardous, toxic, and radioactive waste. 

Other federal agencies (6): 

Name of property: Kenilworth Park Landfill Site[A]; 
Agency or agencies responsible for leaving the hazards: National Park 
Service; 
Past or current use of the property: Former municipal dump; 
Hazards found: PCB and polynuclear hydrocarbons. 

Name of property: National Park Serviceï¿½Anacostia Park Sections E & 
F[A]; 
Agency or agencies responsible for leaving the hazards: Not available; 
Past or current use of the property: Not available; 
Hazards found: Not available. 

Name of property: Southeast Federal Center[A]; 
Agency or agencies responsible for leaving the hazards: U.S. Navy; 
Past or current use of the property: Administrative offices and storage 
facilities, ordnance research and manufacturing, and shipbuilding; 
Hazards found: Solvents, PCB, polyaromatic hydrocarbons, and heavy 
metals (including lead, arsenic, and chromium). 

Name of property: St. Elizabethï¿½s Hospital[A]; 
Agency or agencies responsible for leaving the hazards: Not available; 
Past or current use of the property: Former federally owned and 
operated mental institution sold to the District of Columbia; 
Hazards found: Polynuclear hydrocarbons, perchloroethylene (PCE), 
toluene, chromium, cadmium, mercury, cobalt, and DDT. 

Name of property: U.S. Department of Agricultureï¿½National Arboretum[A]; 
Agency or agencies responsible for leaving the hazards: U.S. Department 
of Agriculture; 
Past or current use of the property: Agricultural research facility; 
Hazards found: Organochlorine, insecticide, herbicide, fungicides, wood 
preservatives, and solvents. 

Name of property: Washington Gas Light Site[A]; 
Agency or agencies responsible for leaving the hazards: Federal 
property affected by contamination from a private property; 
Past or current use of the property: Equipment storage area for the 
District of Columbiaï¿½s Department of Public Works, river debris removal 
staging area, and recreational use; 
Hazards found: Coke breeze, benzene, xylenes, toluene,naphthalene, fat 
chemco, carboseal, petroleum by-products, and polynuclear hydrocarbons. 

[A] Also listed as a Comprehensive Environmental Response, 
Compensation, and Liability Act site. 

[B] Defense was unable to provide information on the agency or agencies 
responsible for leaving any hazards, the past or current use of the 
property, or whether or not hazards had been found at the site. 

Note: Table includes Defense active installations and FUDS listed as of 
March 2002 and properties involving other federal agencies as of April 
2002. 

Source: GAOï¿½s analysis of Defenseï¿½s and EPAï¿½s data. 

[End of table] 

Table 5 contains data on 30 federal properties in the District of 
Columbia, on which remediation of leaking underground storage tanks was 
in process, as of January 2002, as well as the hazards found. 

Table 5: Hazards Found at Leaking Underground Storage Tanks on Federal 
Properties in the District of Columbia Where Remediation Was in 
Process, as of January 2002: 

Federal property: Anacostia Naval Stationï¿½Building #353; 
Hazards found: Diesel fuel, gasoline, halogenated hydrocarbons, 
trichloropropane (TCP), and waste oil. 

Federal property: Architect of the Capitolï¿½Capitol Power Plant; 
Hazards found: Diesel fuel and heating oil. 

Federal property: Architect of the Capitolï¿½Oï¿½Neill House Office 
Building; 
Hazards found: Diesel fuel and gasoline. 

Federal property: Architect of the Capitolï¿½Rayburn House Office 
Building; 
Hazards found: Diesel fuel and gasoline. 

Federal property: Architect of the Capitolï¿½Senate Underground Garage; 
Hazards found: Diesel fuel and gasoline. 

Federal property: Bolling Air Force Base; 
Hazards found: Diesel fuel and gasoline. 

Federal property: Bolling Air Force Baseï¿½Army and Air Force Exchange 
Serviceï¿½s Service Station; 
Hazards found: Gasoline. 

Federal property: Bolling Air Force Baseï¿½Car Care Center; 
Hazards found: Gasoline. 

Federal property: Dalecarlia Water Treatment Plant; 
Hazards found: Heating oil. 

Federal property: Edgewater Stableï¿½U.S. Secret Service; 
Hazards found: Gasoline. 

Federal property: Federal Triangle; 
Hazards found: Diesel fuel and gasoline. 

Federal property: Former Architect of the Capitol Poplar Point Nursery; 
Hazards found: Gasoline. 

Federal property: Fort McNairï¿½Fitness Center; 
Hazards found: Heating oil and kerosene. 

Federal property: Fort McNairï¿½Gas Station; 
Hazards found: Gasoline, kerosene, and waste oil. 

Federal property: Fort McNairï¿½Parking Lot; 
Hazards found: Gasoline. 

Federal property: Fort McNairï¿½Quarters #20; 
Hazards found: Heating oil. 

Federal property: The John F. Kennedy Center; 
Hazards found: Diesel fuel. 

Federal property: National Park Serviceï¿½1900 Anacostia Drive; 
Hazards found: Gasoline, heating oil, and waste oil. 

Federal property: Naval Observatoryï¿½Building #52; 
Hazards found: Heating oil. 

Federal property: Naval Observatoryï¿½Building #64; 
Hazards found: Gasoline. 

Federal property: Park Police Anacostia Operation; 
Hazards found: Gasoline. 

Federal property: Southeast Federal Centerï¿½Block H; 
Hazards found: Diesel fuel. 

Federal property: Southeast Federal Centerï¿½Building #216, 2nd & M Sts., 
SE; 
Hazards found: Waste oil. 

Federal property: U.S. Department of Agriculture National 
Arboretumï¿½ Building #014; 
Hazards found: Gasoline. 

Federal property: U.S. Government Printing Office; 
Hazards found: Heating oil. 

Federal property: U.S. Postal Serviceï¿½Brightwood; 
Hazards found: Diesel fuel and gasoline. 

Federal property: U.S. Postal Serviceï¿½Vehicle Maintenance Facility; 
Hazards found: Diesel fuel, gasoline, and waste oil. 

Federal property: Veterans Affairs Medical Center; 
Hazards found: Heating oil. 

Federal property: Washington Navy Yardï¿½Building #071; 
Hazards found: Diesel fuel, gasoline, and waste oil. 

Federal property: Washington Navy Yardï¿½Building #111; 
Hazards found: Heating oil. 

Note: Table excludes leaking underground storage tank cases where 
remediation was complete as of January 2002. 

Source: GAOï¿½s analysis of the District of Columbiaï¿½s data. 

[End of table] 

[End of section] 

Appendix II: Comments from the Department of Defense: 

Office Of The Under Secretary Of Defense: 
Acquisition and Technology: 
3000 Defense Pentagon: 
Washington DC 20301-3000: 

May 20, 2002: 

Mr. David G. Wood: 
Director: 
Natural Resources and Environment: 
U.S. General Accounting Office: 
Washington, D.C. 20548: 

Dear Mr. Wood: 

The Department of Defense (DoD) appreciates the opportunity to provide 
comments regarding the GAO draft report, GAO-02-556, 'Environmental 
Contamination: Many Uncertainties Affect the Progress of the Spring 
Valley Cleanup', dated May 7, 2002 (GAO Code 360145). 

The objectives and findings of the report focus on uncertainties at the 
Spring Valley site involving: 1) the extent of contamination remaining 
at Spring Valley; 2) the regulatory partnerships; 3) health risks from 
contaminated soils; and 4) funding, and the uncertainties impacts on 
the progress of cleanup. While we agree that there are some 
uncertainties associated with the Spring Valley cleanup, it is 
important to note that such unknowns are not unique to Spring Valley. 

Every environmental cleanup involves a number of unknowns, regardless 
of the locale, type of contaminant, or specific entity executing the 
cleanup. The purpose of the site characterization process is to reduce 
the uncertainties associated with the nature and extent of 
contamination, risk to human health, and implementation of the 
appropriate response action. The site characterization process at 
Spring Valley has, in many respects, reduced many of these 
uncertainties, and the Army, with its regulatory partners, plans to 
continue to address each discovery in the same deliberative and 
responsive manner. 

In addition, the cooperative relationship formed between the U.S. 
Environmental Protection Agency (EPA), the District of Columbia 
Department of Health (D.C. Health) and the Corps of Engineers has been, 
in our opinion, a model for regulatory relationships at other site 
cleanups. Each agency's dedicated commitment to the partnership, and 
participation in critical decisions throughout the cleanup process, is 
evidenced by the substantial progress made in addressing contamination 
arising from war preparation activities of almost a century ago. This 
collaboration, in contrast to enforcement, has resulted in a more 
timely and cost effective cleanup, and the Department has every reason 
to expect that this relationship will continue to be effective into the 
future. 

In regard to funding, DoD has continually demonstrated a financial 
commitment to completing the cleanup at the Spring Valley site. Over 
the last ten years, and at the expense of other cleanups, the Army has 
allocated over $50 million to the cleanup of Spring Valley and, at the 
behest of stakeholders, will reprioritize another $70 million to 
complete the cleanup at this site. 

The protection of human health and the environment is critical, and DoD 
will continue to work in partnership with EPA and the D.C. Health to 
ensure that the health and safety of the residents are protected, and 
that sufficient resources are made available. Our attached comments 
reflect this position. 

My point of contact on this matter, Mr. Kurt Kratz (703) 697-5372, is 
available to discuss our responses to findings and additional comments 
provided on this document. 

Sincerely, 

Signed by: 
Raymond F. DuBois, Jr. 
Deputy Under Secretary of Defense (Installations and Environment): 

Enclosure: 

[End of section] 

Appendix III: Comments from the Environmental Protection Agency: 

United States Environmental Protection Agency: 
Office Of Solid Waste And Emergency Response: 
Washington, D.C. 20460: 
[hyperlink, http://www.epa.gov]: 

May 20, 2002: 

David G. Wood: 
Director: 
Natural Resources and Environment: 
United States General Accounting Office (GAO): 
Washington, DC 20548: 

Dear Mr. Wood: 

Thank you for the opportunity to review and comment on the May 7, 2002, 
draft report entitled "Environmental Contamination - Many Uncertainties 
Affect the Progress of the Spring Valley Cleanup" (GAO-02-556). This 
letter transmits our comments on the draft report. 

EPA believes the report has done an excellent job presenting the 
substantive historical facts of this very complex and challenging site 
cleanup. EPA appreciates the substantial effort made by the GAO in 
developing an accurate and unbiased appraisal of the problems and 
uncertainties present at the Spring Valley Site. However, there are 
several issues raised during our conference call on Monday, April 29 
that were not addressed in the draft report. These concerns are the 
references to and the description of the relationship between the 
Comprehensive Environmental Response, Compensation, and Liability Act 
of 1980 (CERCLA), the Superfund Amendments and Reauthorization Act of 
1986 (SARA) and the Defense Environmental Restoration Program (DERP). 
There are also some statements attributed to EPA that are inconsistent 
with our policy on privately-owned Formerly Used Defense Sites (FUDS). 
We hope these comments will be considered during your revision of the 
draft report. 

All comments included in the enclosure are intended to improve the 
accuracy of the draft report. If you have any questions about these 
comments, please contact Renee Wynn, of my staff, at (202) 260-8366 or 
Hank Sokolowski, Region 3, at (215) 814-3348. 

Sincerely, 

Signed by: 

Michael Shapior, for: 

Marianne Lamont Horinko: 
Assistant Administrator: 

Enclosure: 

[End of section] 

Appendix IV: Comments from the District of Columbiaï¿½s Department of 
Health: 

Government of the District of Columbia: 
Department of Health: 
Office of the Senior Deputy Director for Public Health Assurance: 
825 North Capitol Street, NE, 4th Floor: 
Washington, DC 20002: 
Tel: 202-442-8982: 
Fax: 202-442-4886: 

May 17, 2002: 

Mr. David G. Wood, Director: 
Natural Resources and Environment: 
United States General Accounting Office: 
Washington, DC 20548: 

Dear Mr. Wood: 

The DC Department of Health (DOH) has received a draft copy from the 
United States Government Accounting Office (GAO) of the proposed report 
entitled "Environmental Contamination: Many Uncertainties Affect the 
Progress of the Spring Valley Cleanup" (GAO-02-556). The DOH's written 
comments were transmitted to you during our meeting with the GAO on 
April 26, 2002 and many have been included in your draft report. 

The DOH has received additional information since our meeting on April 
260th, regarding the collaborative investigation with the Agency For 
Toxic Substances and Disease Registry (ATSDR) that has been conducted 
with the participation of Spring Valley residents. The results of the 
Phase I exposure investigation suggest that arsenic contamination on 
properties in Spring Valley has not resulted in significant exposure by 
the residents. The interpretation is based on biological samples 
(urine, hair) collected from Spring Valley residents with the highest 
soil levels of arsenic on their properties. The results from the Phase 
I exposure investigation will be helpful as part of the ongoing 
assessment of Spring Valley residents by the DOH. 

The District is committed to continuing to work with the other 
governmental partners to establish and fully implement any action 
and/or remediation plan it determines is required to protect human 
health. Using its available scientific resources and information, its 
monitoring and enforcement capabilities and authority, the District is 
confident that the objective of ensuring a timely response to protect 
human health will be achieved. 

We appreciate the inclusion of our remarks in your report and the 
opportunity to comment on the initial draft. 

Sincerely, 

Signed by: 

Theodore J. Gordon: 
Senior Deputy Director for Public Health Assurance: 

cc: James Buford, Interim Director, DOH: 

[End of section] 

Appendix V: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

David G. Wood (202) 512-3841: 
Peg Reese (202) 512-9695: 

Acknowledgments: 

In addition to those named above, Ridge Bowman, Stephen Cleary, 
Margaret McDavid, and Carol Herrnstadt Shulman made key contributions
to this report. 

[End of section] 

Footnotes: 

[1] The Department of Defense Appropriation Act, 1984 (P.L. 98-212) 
provided 1 year of funding for the cleanup of hazardous substances 
released from Defense properties and the removal of unsafe or unsightly 
Defense buildings and debris. Annual appropriations for these 
activities have continued, but since 1986, have been funded under the 
Defense Environmental Restoration Account established by the Congress 
as part of the Defense Environmental Restoration Program. 

[2] Specifically, Defenseï¿½s activities addressing hazardous substances, 
pollutants, or contaminants are required to be carried out consistent 
with section 120 of CERCLA. 

[3] The Department of Health defines exposure as any completed pathway 
through the air, water, or soil of the contaminant that results in an 
inhaled, ingested, or dermal-absorbed dose associated with adverse 
human health effects. 

[4] Removal actions are generally short-term responses to address 
immediate and significant dangers at any hazardous waste site but are 
not necessarily final solutions. 

[5] EPA Policy Toward Privately-Owned Formerly Used Defense Sites, 
which notes that, while the policy focuses on authorities available to 
EPA under CERCLA, ï¿½nothing in this policy should be construed as 
limiting EPAï¿½s or a Stateï¿½s authoritiesï¿½ under other applicable 
environmental statutes, such as the Resource Conservation and Recovery 
Act or the Clean Water Act. 

[6] In commenting on our report, the Corps stated that the reason the 
environmental officials were not included was that the Mayor of the 
District of Columbia had expressly designated a different agency as the 
point of contact for Spring Valley. 

[7] ATSDR is an agency of the Department of Health and Human Services. 
It was created by CERCLA, and its mission is to take responsive public 
health action and provide public health information to prevent harmful 
exposures and diseases related to toxic substances. 

[8] We are currently reviewing the Corpsï¿½ process for assessing the 
need to clean up FUDS nationwide and will issue a report this summer. 

[9] In addition, the Corps sampled soil for a variety of chemicals at a 
number of locations at American University and at the location where a 
piece of ordnance containing suspected chemical agent was found. Total 
potentially hazardous locations surveyed and sampled do not add to 53 
because some locations were both surveyed and sampled, some were either
surveyed or sampled but not both, while others were neither surveyed 
nor sampled because they were either buildings or under a large 
concrete reservoir. 

[10] According to a District of Columbia official, the Corps had 
discovered this error in 1994 and had found a possible buried ordnance 
pit, but did not undertake a cleanup action at the time. However, the 
Corps disagrees and stated that it did not find any indication of a
possible ordnance burial pit at the site in 1994. 

[11] In January 2001, the Corps also removed oil filters, glass, and 
lab equipment, along with soil contaminated with elevated levels of 
lead and arsenic from a small surface disposal area discovered on 
American University property adjacent to the South Korean property.
However, according to the Corps, it was not possible to determine 
whether these hazards resulted from past Defense research activities, 
or from another source. 

[12] For example, EPA recently established a more stringent standard 
for arsenic in drinking water. See U.S. General Accounting Office, 
Environmental Protection Agency: Use of Precautionary Assumptions in 
Health Risk Assessments and Benefits Estimates, [hyperlink, 
http://www.gao.gov/products/GAO-01-55] (Washington, D.C.: Oct. 16, 
2000). 

[13] For this report, we focused on the revised cost figures that the 
Army provided to us in April 2002, as opposed to the figures reported 
in the fiscal year 2001 Defense Environmental Restoration Program 
report. According to the Corps, the revised figures more accurately 
reflect the costs incurred by the Corps through fiscal year 2001 and the
Corpsï¿½ estimate of the cost to complete cleanup activities at Spring 
Valley. 

[End of section] 

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