    Military Munitions: DOD Needs to Develop a Comprehensive Approach
    for Cleaning Up Contaminated Sites (19-DEC-03, GAO-04-147).

    Over 15 million acres in the United States are suspected of
    being, or known to be, contaminated with military munitions.
    These sites include ranges on closing military installations,
    closed ranges on active installations, and formerly used defense
    sites. Under the Defense Environmental Restoration Program,
    established in 1986, the Department of Defense (DOD) must
    identify, assess, and clean up military munitions contamination
    at these sites. DOD estimates these activities will cost from $8
    billion to $35 billion. Because of the magnitude of DOD's cleanup
    effort, both in terms of cost and affected acreage, as well as
    the significant public safety, health, and environmental risks
    that military munitions may pose, The Ranking Minority Member of
    the House Committee on Energy and Commerce asked us to evaluate
    (1) DOD's progress in implementing its program to identify,
    assess, and clean up military munitions sites and (2) DOD's plans
    to clean up remaining sites in the future.
    -------------------------Indexing Terms-------------------------
    REPORTNUM:   GAO-04-147
        ACCNO:   A09026
      TITLE:     Military Munitions: DOD Needs to Develop a Comprehensive
    Approach for Cleaning Up Contaminated Sites
         DATE:   12/19/2003
      SUBJECT:   Cost analysis
    	     Data collection
    	     Hazardous substances
    	     Land management
    	     Military facilities
    	     Munitions
    	     Obsolete facilities
    	     Performance measures
    	     Strategic planning
    	     DOD Defense Environmental Restoration
    	     Program

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    GAO-04-147

    United States General Accounting Office

    GAO	Report to the Honorable John D. Dingell Ranking Minority Member,
    Committee on

                     Energy and Commerce, House of Representatives

    December 2003

    MILITARY MUNITIONS

    DOD Needs to Develop a Comprehensive Approach for Cleaning Up Contaminated Sites

                                           a

    GAO-04-147

    Highlights of GAO-04-147, a report to the Honorable John D. Dingell,
    Ranking Minority Member, Committee on Energy and Commerce, House of
    Representatives

    Over 15 million acres in the United States are suspected of being, or
    known to be, contaminated with military munitions. These sites include
    ranges on closing military installations, closed ranges on active
    installations, and formerly used defense sites. Under the Defense
    Environmental Restoration Program, established in 1986, the Department of
    Defense (DOD) must identify, assess, and clean up military munitions
    contamination at these sites. DOD estimates these activities will cost
    from $8 billion to $35 billion. Because of the magnitude of DOD's cleanup
    effort, both in terms of cost and affected acreage, as well as the
    significant public safety, health, and environmental risks that military
    munitions may pose, you asked us to evaluate (1) DOD's progress in
    implementing its program to identify, assess, and clean up military
    munitions sites and (2) DOD's plans to clean up remaining sites in the
    future.

    We are recommending that DOD develop a comprehensive approach by revising
    its plan to (1) establish deadlines for completing its site inventory and
    initial evaluations, (2) reassess the timetable proposed for completing
    its risk assessment reevaluations, and (3) establish service-specific
    targets. We are also recommending that after DOD revises its plan, it
    should work with the Congress to develop budget proposals that will allow
    timely completion of cleanup activities.

    www.gao.gov/cgi-bin/getrpt?GAO-04-147.

    To view the full product, including the scope and methodology, click on
    the link above. For more information, contact Anu K. Mittal at (202)
    512-3841 or mittala@gao.gov.

    December 2003

    MILITARY MUNITIONS

    DOD Needs to Develop a Comprehensive Approach for Cleaning Up Contaminated Sites

    DOD has made limited progress in its program to identify, assess, and
    clean up sites that may be contaminated with military munitions. While DOD
    had identified 2,307 potentially contaminated sites as of September 2002,
    DOD officials said that they continue to identify additional sites and are
    not likely to have a firm inventory for several years. Of the identified
    sites, DOD had initially determined that 362 sites required no further
    study or cleanup action because it found little or no evidence of military
    munitions. For 1,387 sites, DOD either has not begun or not completed its
    initial evaluation or determined that further study is needed. DOD has
    completed its assessment of 558 sites, finding that 475 of these required
    no cleanup action. The remaining 83 sites required some cleanup action, of
    which DOD has completed 23.

    DOD does not yet have a complete and viable plan for cleaning up military
    munitions at remaining potentially contaminated sites. DOD's plan is
    lacking in several respects, including the following:

    o  	Essential data for DOD's plan may take years to develop. Not all the
    potential sites have been identified, and DOD has set no deadline for
    doing so. Also, DOD intends to use a new procedure to assign a relative
    priority for the remaining 1,387 sites, but it will not complete the
    reassessments until 2012. Until these are done, DOD cannot be assured that
    it is using its limited resources to clean up the riskiest sites first.

    o  	DOD's plan relies on preliminary cost estimates that can change
    greatly and the reallocation of funds that may not be available. For
    example, the Air Force used estimated, not actual, acreage to create its
    cost estimates, limiting the estimate's reliability and DOD's ability to
    plan and budget cleanup for these sites. Also, DOD expects additional
    funds will become available for munitions cleanup as other DOD hazardous
    waste cleanup efforts are completed. However, some of these efforts are
    behind schedule; therefore, funds may not become available as anticipated.

    o  	DOD's plan does not contain goals or measures for site assessment and
    cleanup. DOD recently established a working group tasked with developing
    agencywide program goals and performance measures, but not
    service-specific targets, limiting DOD's ability to ensure that the
    services are making progress in cleaning the potentially contaminated
    sites and achieving the overall goals of the program as planned.

    Unexploded Military Munition

    Contents

      Letter

    Results in Brief
    Background
    DOD Has Made Limited Progress in Its Program to Identify, Assess,

    and Clean Up Potentially Contaminated Sites DOD Does Not Have a Complete
    and Viable Plan for Assessing and

    Cleaning Up Potentially Contaminated Sites Conclusions Recommendations
    Agency Comments

    1 4 6

    8

    14 18 19 19

    Appendixes

    Safety, Environmental, and Human Health Risks
    Additional Details on Our Scope and Methodology
    Comments from the Department of Defense
    GAO Contacts and Staff Acknowledgments

    GAO Contacts Acknowledgments 22

    25

    27

    30 30 30

                  Appendix I: Appendix II: Appendix III: Appendix IV:
                       Table 1:
                Distribution of
    Tables          Military
                      Munitions
               Response Program
                          Sites
                 by Service      8
                  Table 2:
                  Munitions     23
               Constituents of
              Greatest Concern
                       Table 3:
              Potential Effects
               of the Munitions
                   Constituents
                        Closely
                                    Table 4:                   Figure 1:
               Associated with      Districts            Distribution of 2,307
                  Military      24   Visited  25 Figures  Suspected Military
                  Munitions          during               Munitions Response
                                     Review                  Program Sites
                                                           Identified by DOD   10
                      Figure 2:
                       Military
                      Munitions
               Response Program
                 Site Inventory
                (2,307 Sites)   11
                      Figure 3:
                       Military
                      Munitions
               Response Program
                Sites Requiring
               Further Action   12
                  Figure 4:
                 Examples of
               Cleanup Actions
                 at Military
                  Munitions
              Response Program  13
                    Sites

    Contents

    Abbreviations

    DOD Department of Defense
    Corps U.S. Army Corps of Engineers
    CERCLA Comprehensive Environmental Response, Compensation,

    and Liability Act of 1980

    This is a work of the U.S. government and is not subject to copyright
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    its entirety without further permission from GAO. However, because this
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    separately.

    A

    United States General Accounting Office Washington, D.C. 20548

    December 19, 2003

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

    Dear Mr. Dingell:

    Over 15 million acres in the United States are known to be or are
    suspected of being contaminated with military munitions, which include
    unexploded ordnance, discarded military munitions, and munitions
    constituents such as propellants or other chemicals.1 These sites, which
    are no longer in use, include closed ranges on active installations,
    ranges on military installations that are being closed (closing sites),
    and formerly used defense sites.2 Much of the land on which these sites
    are located has been or will be converted to nonmilitary uses such as
    farming, residential or commercial development, and recreation. The
    Department of Defense (DOD) estimates that identifying, assessing, and
    cleaning up contamination from military munitions at such sites will cost
    from $8 billion to $35 billion and could take more than 75 years. Within
    DOD, cleanup of sites on active or closing installations is the
    responsibility of the military service-Air Force, Army, Navy, or Marine
    Corps-that currently owns the land. The U.S. Army Corps of Engineers
    (Corps) is responsible for executing the cleanup of formerly used defense
    sites.

    Military munitions can pose risks to public safety, human health, and the
    environment. Unexploded ordnance poses a potential explosive hazard and
    risk of personal injury to those who encounter it. The Environmental
    Protection Agency, in September 2001, using a DOD database and other
    sources, identified at least 126 incidents involving civilians who were

    1Unexploded ordnance, discarded military munitions, and munitions
    constituents are hereafter referred to as "military munitions" for the
    purpose of this report. Unexploded ordnance includes ordnance primed and
    fired but remain unexploded. For a more complete definition, see the
    National Defense Authorization Act for Fiscal Year 2004, Pub. L. No.
    108136, section 1042 (a)(2).

    2A formerly used defense site is a property that Department of Defense
    (DOD) formerly owned, leased, possessed, operated, or otherwise
    controlled, and was transferred from DOD prior to October 17, 1986.

    exposed to unexploded ordnance over the past 83 years, which resulted in
    65 fatalities and 131 injuries.3 The risk of such exposures is expected to
    grow with an increase in development and recreational activities on land
    once used by the military for munitions related activities (e.g., live
    fire testing and training). In addition, human exposure to munitions
    constituents such as trinitrotoluene (TNT) and perchlorate may cause
    longterm health problems, such as cancer and damage to the heart, liver,
    and kidneys. However, the link between such constituents and any potential
    health effects is not always clear and continues to be studied. (See app.
    I for a list of common munitions constituents and potential health
    effects.) Military munitions may also pose an environmental risk because
    their use and disposal may release constituents that could contaminate
    soil, groundwater, and surface water. Former ranges on which
    munitionsrelated activities were conducted and which are known or
    suspected to contain military munitions are in a variety of locations,
    including near ecologically sensitive wetlands, surface waters, and
    floodplains. While many constituents have been an environmental concern to
    DOD for more than 20 years, the current understanding of the causes,
    distribution, and potential impact of constituent releases into the
    environment remains limited. The nature of these impacts, and whether they
    pose an unacceptable risk to human health and the environment, depend upon
    the dose, duration, and pathway of exposure, as well as the sensitivity of
    the exposed populations. Until recently, DOD has focused primarily on
    mitigating the public safety risk associated with unexploded ordnance, but
    it is now giving additional attention to environmental and health concerns
    posed by munitions constituents.

    Under the Defense Environmental Restoration Program, established in 1986,
    DOD is required to identify, investigate, and clean up environmental
    contamination and other hazards at active and closing installations, as
    well as at formerly used defense sites.4 The program is organized into
    three categories that focus on DOD's primary goals: (1) identification and
    cleanup of contamination from hazardous substances, pollutants, and
    contaminants; (2) demolition and removal of unsafe buildings and

    3U.S. Environmental Protection Agency, Office of Solid Waste, Permits and
    State Programs Division, UXO Incident Report (Revision 1), (Washington,
    D.C., 2001).

    4The Defense Environmental Restoration Program was established by section
    211 of the Superfund Amendments and Reauthorization Act of 1986, which
    amended the Comprehensive Environmental Response, Compensation, and
    Liability Act of 1980 (CERCLA).

    structures; and (3) correction of other environmental damage, such as
    detection and disposal of military munitions. Most of DOD's past focus had
    been on identifying and cleaning up contamination from hazardous
    substances. To better focus DOD's efforts on identifying, assessing, and
    cleaning up sites containing military munitions, DOD established the
    Military Munitions Response program in September 2001. Subsequently, in
    December 2001, the Congress passed the National Defense Authorization Act
    for Fiscal Year 2002, which among other things, required DOD to develop an
    initial inventory of sites that are known or suspected to contain military
    munitions and a comprehensive plan for cleaning up these sites. Of the
    $1.9 billion budgeted by DOD for environmental cleanup in fiscal year
    2002, approximately $113 million was designated for sites with military
    munitions. In fiscal years 2003 and 2004, DOD designated approximately
    $115 million and $89 million, respectively, for sites with military
    munitions.

    In deciding what actions, if any, are needed to clean up a site identified
    as potentially contaminated with military munitions, DOD generally follows
    the process established for cleanup actions under the Comprehensive
    Environmental Response, Compensation, and Liability Act of 1980 (CERCLA).
    CERCLA, as amended, governs the cleanup of hazardous waste sites,
    including contamination on military installations. After identifying a
    potential military munitions site, the appropriate DOD military service or
    the Corps performs a preliminary assessment, during which DOD determines
    if military munitions may be present and if further study or cleanup
    action is needed. If necessary, DOD may conduct a site investigation to
    better identify the types and extent of potential hazards present. For
    specific areas suspected to contain military munitions, DOD surveys the
    land and evaluates and selects alternatives, in consultation with
    stakeholders, for addressing the potential hazards. These cleanup
    alternatives could include removing the military munitions, limiting
    public contact with the site through signs and fences, or determining that
    no further action with regard to the site is warranted. After implementing
    the chosen cleanup alternative, DOD periodically monitors the site and
    reviews the alternative chosen to ensure its continued effectiveness.

    Because of the magnitude of DOD's cleanup effort, both in terms of cost
    and affected acreage, as well as the significant public safety, human
    health, and environmental risks posed by military munitions, you asked us
    to evaluate (1) DOD's progress in implementing its program to identify,
    assess, and clean up sites containing military munitions and (2) DOD's
    plans to clean up remaining sites in the future.

    To evaluate DOD's progress in identifying, assessing, and cleaning up
    military munitions, we reviewed and analyzed DOD's database for sites
    identified under the Military Munitions Response program as of September
    30, 2002, the end of their most recent reporting cycle. We assessed the
    reliability of relevant fields in this database by electronically testing
    for obvious errors in accuracy and completeness, reviewing information
    about the data and the system that produced them, and interviewing agency
    officials knowledgeable about the data. When we found inconsistencies, we
    worked with DOD and military service officials to correct the
    discrepancies before conducting our analyses. We determined that the data
    needed for our analyses were sufficiently reliable for the purposes of our
    report. We also reviewed project files from 38 of the 75 sites where,
    according to DOD's database, cleanup action is either complete or under
    way.5 These files represented 52 percent of the 23 sites with a completed
    cleanup action and 50 percent of the 52 sites with a cleanup action under
    way. We used our file reviews to develop case examples of changes in
    estimated costs to complete cleanup over time and cleanup actions taken.
    These case examples are for illustration only. We conducted our work
    between November 2002 and October 2003 in accordance with generally
    accepted government auditing standards. More detail on the scope and
    methodology of our review is presented in appendix II.

    Results in Brief	DOD has made limited progress in its program to identify,
    assess, and clean up sites that may be contaminated with military
    munitions. While DOD had identified 2,307 potentially contaminated sites
    as of September 2002, DOD officials said that the department is continuing
    to identify additional sites and is not likely to have a firm inventory
    for several years. For example, the Army had only surveyed and identified
    closed ranges on 14 percent of its active installations. Of the total
    2,307 identified sites, DOD had initially determined that 362 sites
    required no further study or cleanup action because there was little or no
    evidence of military munitions. However, because these sites are formerly
    used defense sites, and the initial evaluations conducted were less
    comprehensive than for other sites in the program, the Corps has recently
    decided that some of these sites need to be reassessed to determine if
    cleanup is needed. For 1,387 sites, DOD either has not begun or not
    completed its initial evaluation or has determined that further study is
    needed. DOD has completed its assessment of 558 sites,

    5There are an additional eight sites for which cleanup action is planned,
    but not yet begun. These sites were not included in our file review
    process.

    finding that 475 sites required no cleanup action. The remaining 83 sites
    required some cleanup action, of which DOD has completed 23.

    DOD does not yet have a complete and viable plan for guiding its remaining
    clean up activity at potentially contaminated sites. DOD's plan is lacking
    in several respects, including the following:

    o 	Essential data for DOD's plan may take years to develop. For example,
    not all the potential sites have been identified, and DOD has set no
    deadline for doing so. Because the inventory serves as the basis for other
    elements of the plan, such as budget development, the sites must first be
    identified before DOD can have a reasonable picture of the magnitude of
    the challenge ahead and plan accordingly. Furthermore, DOD intends to use
    new procedures to reassess the relative risk for the 1,387 sites needing
    further study, but DOD is not scheduled to complete these reassessments
    until 2012. The resulting relative risk assessments will be a key
    component in determining cleanup priorities. Until the assessments are
    complete, DOD cannot be assured that it is using its limited resources to
    clean up those sites that pose the greatest risk to public safety, human
    health, and the environment.

    o 	DOD's plan relies on preliminary cost estimates that may change
    significantly and reallocated funds from other programs that may not be
    available as anticipated. For example, at Camp Maxey, Texas, the estimated
    cost for cleanup in 2000 was $45 million. However, in DOD's Fiscal Year
    2002 Defense Environmental Restoration Program Annual Report to Congress,
    the estimated cleanup cost had grown to $130 million. A June 2003 cost
    estimate showed a decrease in total costs to $73 million. Furthermore, DOD
    expects that as other DOD hazardous substance cleanup efforts are
    completed, increased funds will become available for munitions cleanup.
    However, not all of these other DOD cleanup efforts are on schedule. For
    example, between fiscal years 2001 and 2002, the schedule to complete
    hazardous, toxic, and radioactive waste cleanup at formerly used defense
    sites had slipped by more than 6 years. As a result, anticipated funds
    from completing cleanups at these sites may not become available until
    2021 or later.

    o 	DOD's plan does not yet contain goals or measures for site assessment
    and cleanup. In September 2003, 2 years after the establishment of the
    Military Munitions Response program, DOD established a working group
    tasked with developing agencywide program goals and performance measures.
    However, the working group is not expected to

    establish service-specific targets, therefore DOD will have limited
    assurance that the services and the Corps are (1) making progress in
    cleaning their Military Munitions Response program sites and (2) are
    contributing to achieving the overall goals of the program as planned.

    We are recommending that DOD revise its plan to (1) establish deadlines
    for completing its site inventory and initial evaluations; (2) reassess
    the timetable proposed for completing its reevaluation of sites, using the
    new risk assessment procedures; and (3) establish interim goals based on
    criteria, such as relative risk levels or cleanup phases, for the services
    and the Corps to target. We are also recommending that after DOD revises
    its comprehensive plan, it should work with the Congress to develop
    realistic budget proposals that will allow DOD to complete cleanup
    activities in a timely manner.

    In commenting on a draft of this report, DOD concurred with our
    recommendation to work with the Congress to develop realistic budget
    proposals that will allow DOD to complete cleanup activities on
    potentially contaminated sites in a timely manner. In addition, DOD
    partially concurred with our recommendations to (1) establish deadlines to
    complete the identification process and initial evaluations; (2) reassess
    the timetable proposed for completing the reevaluation of sites, using the
    new risk assessment procedure; and (3) establish interim goals for cleanup
    phases for the services and the Corps to target. DOD also suggested some
    technical changes throughout the report that we have incorporated as
    appropriate. DOD's comments appear in appendix III.

    Background	To better focus its munitions cleanup activities under the
    Defense Environmental Restoration Program, DOD established the Military
    Munitions Response program in September 2001. The objectives of the
    program include compiling a comprehensive inventory of military munitions
    sites, developing a prioritization protocol for sequencing work at these
    sites, and establishing program goals and performance measures to evaluate
    progress. In December 2001, shortly after DOD established the program, the
    Congress passed the National Defense Authorization Act for Fiscal Year
    2002, which among other things, required DOD to develop an initial
    inventory of sites that are known or suspected to contain military
    munitions by May 31, 2003, and to provide annual updates thereafter. DOD

    provides these updates as part of its Defense Environmental Restoration
    Program Annual Report to Congress.6

    To clean up potentially contaminated sites, DOD generally follows the
    process established for cleanup actions under CERCLA, which includes the
    following phases and activities:

    o 	Preliminary Assessment-Determine whether a potential military munitions
    hazard is present and whether further action is needed.

    o 	Site Investigation-Inspect the site and search historical records to
    confirm the presence, extent, and source(s) of hazards.

    o 	Remedial Investigation/Feasibility Study or Engineering Evaluation/Cost
    Analysis-Determine the nature and extent of contamination; determine
    whether cleanup action is needed and, if so, select alternative cleanup
    approaches. These could include removing the military munitions, limiting
    public contact with the site through signs and fences, or determining that
    no further action is warranted.

    o 	Remedial Design/Remedial Action-Design the remedy and perform the
    cleanup or other response.

    o 	Long-Term Monitoring-Periodically review the remedy in place to ensure
    its continued effectiveness, including checking for unexploded ordnance
    and public education.

    For sites thought to be formerly used defense sites, the Corps also
    performs an initial evaluation prior to the process above. In this initial
    evaluation, called a preliminary assessment of eligibility, the Corps
    determines if the property is a formerly used defense site. The Corps
    makes this determination based on whether there are records showing that
    DOD formerly owned, leased, possessed, operated, or otherwise controlled
    the property and whether hazards from DOD's use are potentially present.
    If eligible, the site then follows the CERCLA assessment and cleanup
    process discussed earlier. When all of these steps have been completed for
    a given site and long-term monitoring is under way, or it has been
    determined that

    6In the report issued on April 21, 2003, DOD provided aggregate high and
    low program cost estimates for clean up of military munitions at Military
    Munitions Response program sites, as well as operational ranges, to
    satisfy a one-time congressional reporting requirement.

    no cleanup action is needed, the services and the Corps consider the site
    to be "response complete."

    DOD Has Made Limited Progress in Its Program to Identify, Assess, and
    Clean Up Potentially Contaminated Sites

    While DOD has identified 2,307 potentially contaminated sites as of
    September 2002, the department continues to identify additional sites, and
    it is not likely to have a firm inventory for several years (see table 1
    for the distribution of these sites by service). Of the identified sites,
    DOD determined that 362 sites require no further study or cleanup action
    because it found little or no evidence of military munitions. For 1,387
    sites, DOD either has not begun or not completed its initial evaluation,
    or has determined that further study is needed. DOD has completed an
    assessment of 558 sites, finding that 475 of these required no cleanup
    action. The remaining 83 sites require some cleanup action, of which DOD
    has completed 23.

    Table 1: Distribution of Military Munitions Response Program Sites by
    Service

                                  Responsible service

                                            Closed ranges on active installations

                                     Closing ranges

    on base

    realignment

    and closure

                                     installationsa

    Formerly used defense sites Total

                             Army    105         58              N/A          163
                             Navy    196         16              N/A          212
                        Air Force    241         0               N/A          241
                    Army Corps of    N/A        N/A            1,691        1,691
                        Engineers
                            Total    542         74            1,691        2,307

    Source: DOD.

    aThe base realignment and closure program is a DOD program governing the
    scheduled closing of DOD sites and includes a focus on compliance and
    cleanup efforts at military installations undergoing closure or
    realignment.

    DOD had identified 2,307 sites potentially contaminated with military
    munitions, as of September 30, 2002, and it continues to identify
    additional sites. (Fig. 1 shows the distribution of these sites by state.)
    DOD officials acknowledge that they will not have a firm inventory for
    several years. For example, as of September 30, 2002, the Army had not
    completed a detailed inventory of closed ranges at 86 percent of active
    installations; the 105 sites identified by the Army represented sites on
    only 14 percent of the Army's

    installations. The Army is working to identify sites on the remaining
    installations and plans to have 40 percent of its installations accounted
    for by the next Defense Environmental Restoration Program Annual Report to
    Congress in spring 2004. Similarly, the Corps recently identified 75
    additional sites to be included in the inventory as a result of its effort
    to reevaluate sites previously determined not to need further action after
    the initial evaluation. Because not all of the sites have been identified,
    DOD has only a preliminary idea of the extent of cleanup that will be
    needed. To help complete the identification process, DOD has developed a
    Web site that stakeholders, such as states, tribes, and federal
    regulators, can use to suggest additions and revisions to the inventory.
    DOD plans to update the inventory in its future Defense Environmental
    Response Program Annual Report to Congress using, in part, the information
    collected from this Web site.

    Of the 2,307 sites identified, DOD has determined, based on an initial
    evaluation, that 362 do not require any further DOD action (see fig. 2).
    However, these 362 sites are formerly used defense sites, and the Corps'
    evaluation of these sites was less comprehensive than other evaluations
    conducted by DOD under the CERCLA process. 7 In making its determinations,
    the Corps conducted a preliminary assessment of eligibility and determined
    that the potential for military munitions hazard was not present. As a
    result of this determination, the sites were not evaluated further. The
    Corps is in the process of reviewing these determinations with local
    stakeholders to ensure that there was a sound basis for the original
    determination. It has recently decided that some of these sites need to be
    reassessed to determine if cleanup is needed.

    Figure 2: Military Munitions Response Program Site Inventory (2,307 Sites)

    No action required, based on initial evaluations (362)

    Further action required (1,945)

    Source: GAO.

    7In previous GAO work, we estimated that the Corps lacked a sound basis
    for about 38 percent of its determinations, based on its preliminary
    assessment of eligibility, that sites did not require any further DOD
    action; and we recommended that the Corps review these files to determine
    if these properties should be reassessed. The 38 percent includes all
    potential formerly used defense sites, including those suspected of
    containing military munitions. As noted above, the Corps is in the process
    of reassessing the determinations. See U.S. General Accounting Office,
    Environmental Contamination: Corps Needs to Reassess Its Determinations
    That Many Former Defense Sites Do Not Need Cleanup, GAO02-658 (Washington,
    D.C.: Aug. 23, 2002).

    Of the 1,945 sites that required further action, DOD has either not begun
    or has not completed its study, or has determined that further study is
    needed, for 1,387 sites (see fig. 3). For example, 241 Air Force and 105
    Army sites at closed ranges on active installations have not been
    evaluated. For other sites, primarily formerly used defense sites, DOD has
    completed its initial evaluation and determined that further investigation
    is needed.

    Figure 3: Military Munitions Response Program Sites Requiring Further
    Action

    No cleanup action needed (475)

    Cleanup action planned or under way (60) Cleanup action complete (23)

    Source: GAO.

    DOD has completed its assessment of 558 sites, nearly all of which are
    ranges on formerly used defense sites or closing installations, and
    determined that no cleanup action was needed for 475; the remaining 83
    sites required some level of cleanup action. Of the 83 sites that required
    cleanup action, 60 have cleanup action planned or under way and 23 are
    complete. Actions taken at these 23 sites have been varied and include
    surface and subsurface removal of munitions, and institutional controls,
    such as the posting of warning signs or educational programs. See figure 4
    for examples of cleanup actions at Military Munitions Response program
    sites.

    DOD Does Not Have a Complete and Viable Plan for Assessing and Cleaning Up
    Potentially Contaminated Sites

    In DOD's Fiscal Year 2002 Defense Environmental Restoration Program Annual
    Report to Congress, DOD identified several elements integral to the
    success of the Military Munitions Response program: compiling a
    comprehensive inventory of sites; developing a new procedure to assess
    risk and prioritize sites; ensuring proper funding for accurate planning
    and program execution; and establishing program goals and performance
    measures. While DOD has established the basic framework to address these
    elements, DOD's plan is lacking in three key respects. First, essential
    data for DOD's plan may take years to develop. Second, DOD's plan is
    contingent upon preliminary cost estimates that may change significantly
    and a reallocation of funds that may not be available. Finally, DOD's plan
    lacks specific goals and performance measures to track progress.

    Essential Data for DOD's Plan May Take Years to Develop

    DOD's inventory of potentially contaminated sites serves as the basis for
    other elements of its plan, yet this inventory is incomplete. DOD's
    inventory of 2,307 sites includes only those identified through September
    30, 2002. As previously discussed, according to DOD officials, this
    inventory is not final; and DOD has not set a deadline to complete it.
    According to DOD, most of the ranges on formerly used defense sites and on
    military installations that are being closed have been identified and are
    being assessed or cleanup action is under way. The ranges yet to be
    identified are primarily located on active installations. For example, the
    Army, as of September 30, 2002, had completed a detailed inventory of
    potentially contaminated sites on only 14 percent of its active
    installations. Because the inventory serves as the basis for other
    elements of the plan, such as budget development and establishing program
    goals, most sites must first be identified in order for DOD to have a
    reasonable picture of the magnitude of the challenge ahead and to plan
    accordingly.

    Furthermore, DOD intends to use a new procedure to reassess the relative
    risk and priority for 1,387 sites needing further study and any new sites
    identified as part of the continuing inventory effort, but DOD is not
    scheduled to complete these reassessments until 2012. DOD recently
    developed this procedure for assigning each site in the inventory a
    priority level for cleanup action, based on the potential risk of exposure
    resulting from past munitions-related activities.8 Under this procedure,
    DOD plans to reevaluate the 1,387 sites for three potential hazard types:
    (1) explosive hazards posed by unexploded ordnance and discarded military
    munitions, (2) hazards associated with the effects of chemical warfare
    material, and (3) chronic health and environmental hazards posed by
    munitions constituents. Once assessed, each site's relative risk-based
    priority will be the primary factor determining future cleanup order.9 DOD
    plans to require assessment of each site on the inventory for at least one
    of these hazard types by May 31, 2007, and for all three hazard types by
    May 31, 2012. Until all three hazard types are fully assessed, DOD cannot
    be assured that it is using its limited resources to clean up those sites
    that pose the greatest risk to safety, human health, and the environment.

    DOD's Plan Relies on Preliminary Cost Estimates That Can Change
    Significantly and a Reallocation of Funds That May Not Be Available

    DOD's plan to identify and address military munitions sites relies on
    preliminary cost estimates that were developed using incomplete
    information. The majority of the site estimates were developed using a
    cost-estimating tool that incorporates variables, such as the affected
    acreage; types, quantity, and location of munitions; and future land use.
    These variables can have a significant impact on cost, according to DOD.
    However, detailed site-specific information was not available for all
    sites. For example, as mentioned earlier, 105 Army and 241 Air Force sites
    at closed ranges on active installations have not had an initial
    evaluation. As a result, the Air Force used estimated, not actual, acreage
    figures, including assumptions regarding the amount of acreage known or
    suspected of containing military munitions when preparing its cost
    estimates. Because changes in acreage can greatly impact the final cost of
    site assessment and cleanup action, the estimates produced for these sites
    are likely to change when estimates based on more complete data or the
    actual cost figures are

    8DOD proposed a rule establishing this protocol on August 22, 2003,
    allowing 90 days for a public comment period. 68 Fed. Reg. 50,900.

    9DOD recognized that other factors, such as economic, programmatic, and
    stakeholder concerns, may affect the sequence in which sites are cleaned
    up.

    known. The following examples illustrate how cost estimates can change
    during the life of the cleanup as better information becomes available:

    o 	Camp Maxey was a 41,128-acre Army post in Texas used from 1942 to 1945
    for training infantry in live fire of weapons including pistols, rifles,
    machine guns, mortars, bazookas, and antitank guns. The Corps confirmed
    the presence of unexploded ordnance, and in 2000, estimated the cleanup
    cost for the land at $45 million. In DOD's Fiscal Year 2002 Defense
    Environmental Restoration Program Annual Report to Congress, the estimated
    total cost of cleanup had grown to $130 million. A June 2003 cost estimate
    showed a decrease in total cost to about $73 million, but still 62 percent
    more than the original cost estimate in 2000. The main factors behind
    these shifting cost estimates, according to the project manager, were
    changes in the acreage requiring underground removal of ordnance and
    changes in the amount of ordnance found.

    o 	Fort McClellan, Alabama, was among the installations recommended for
    closure under DOD's base realignment and closure effort in 1995. This site
    had been used since the Spanish American War (1898), including as a World
    War I and II training range upon which grenades, mortars, and antiaircraft
    guns, were used. An April 2002 cost estimate prepared for one site on Fort
    McClellan requiring cleanup showed the anticipated cost of clearing the
    land of munitions as $11,390,250. A subsequent cost estimate prepared in
    May 2003, showed the cost of clearing this site at $22,562,200. According
    to the Army, the increase in estimated costs reflects a change in the
    final acreage recommended for clearance and the extent to which buried
    munitions would be searched for and removed.

    Moreover, until DOD and stakeholders agree upon a cleanup action, it is
    often difficult for them to predict the extent of the cleanup action
    required and cost estimates can change because of the cleanup action
    implemented at the site. For example, at the former Indian Rocks Range in
    Pinellas County, Florida, the Corps identified 178 acres that were used as
    an air-toground and antiaircraft gunnery range impact area from 1943 to
    1947. Munitions used on this shoreline site included bullets, aircraft
    rockets, and small practice bombs. Much of the land had been developed,
    limiting the Corps ability to pursue the alternative of searching for and
    removing buried munitions. In 1995, the Corps analyzed a number of
    alternatives to address munitions contamination at the site and developed
    cost estimates for these alternatives. However, because the development
    was largely composed of hotels, condominiums, and single-family
    residences, the Corps chose the

    alternative of conducting a community education program. The total cost of
    this alternative was $21,219. If the Corps had decided to search for and
    remove the remaining munitions at this site, the cost could have
    approached $3 million, according to the prepared cost analysis.

    Furthermore, at an annual funding level of approximately $106 million (the
    average amount budgeted or spent annually from fiscal year 2002 to fiscal
    year 2004), cleanup at the remaining munitions sites in DOD's current
    inventory could take from 75 to 330 years to complete.10 To reduce this
    timeline, DOD expects to use funds currently designated for hazardous,
    toxic, and radioactive waste cleanup after these cleanups are complete.
    However, these other cleanup efforts are not on schedule in all of the
    services and the Corps. For example, between fiscal years 2001 and 2002,
    the schedule to complete hazardous substance cleanups at formerly used
    defense sites slipped by more than 6 years. As a result, anticipated funds
    from completing hazardous substance cleanups at these sites may not become
    available to clean up munitions sites until 2021 or later. This delay is
    significant because, as of September 30, 2002, formerly used defense sites
    account for over 85 percent of DOD's total anticipated costs to complete
    munitions cleanup, yet the Corps receives about 66 percent of the total
    munitions cleanup funds. Delays in the availability of anticipated funding
    from hazardous, toxic, and radioactive waste sites could greatly impair
    DOD's ability to accurately plan for and make progress in cleaning up
    Military Munitions Response sites.

    DOD's Plan Does Not Contain Goals or Measures for Site Assessment and
    Cleanup

    DOD has yet to establish specific program goals and performance measures
    in its plan. Specifically, DOD has yet to identify interim milestones and
    service-specific targets that will help it achieve overall program
    objectives. In September 2003, 2 years after the Military Munitions
    Response program was initiated, DOD established a workgroup tasked with
    recommending overall goals and measures for the program, near-term goals
    and measures to support its budgeting cycle for fiscal years 2006 to 2011,
    and a program completion date goal. DOD has asked the workgroup to
    accomplish these objectives by the end of calendar year 2003. According to
    DOD, these goals and measures, when developed, should help DOD track the
    progress of sites through the cleanup phases, and ensure that DOD responds
    to the sites with the greatest risk first. While it is important

    10This estimate is a conservative estimate because it was calculated based
    on annual funding totals that include funding that is needed for program
    management and administration.

    for DOD to establish goals and measures that will track overall program
    progress and ensure that the riskiest sites are assessed and cleaned up
    first, DOD will not have the information it needs to do this until 2012.
    As we discussed earlier, because DOD plans to reassess potentially
    contaminated sites using a new risk-based prioritization procedure, until
    these reassessments are complete, DOD will not have complete information
    on which of the sites pose the greatest risk. Consequently, goals and
    measures established in 2003 will be of limited use and may not reflect
    DOD's true priorities.

    Moreover, according to DOD, the program goals and measures to be
    established by the workgroup will be agencywide, and not service-specific,
    although it may establish interim goals for the services and Corps.
    However, DOD has not yet decided what these goals will be based on, such
    as relative risk levels or cleanup phases. In the absence of
    service-specific goals, each service has implemented the program with a
    different level of effort. For example, the Air Force has not budgeted any
    funds to assess and clean up munitions sites, nor do they plan to do so
    through fiscal year 2004. As mentioned before, the Air Force also has not
    conducted initial evaluations on any of its 241 sites and has little
    site-specific information from which to create a reliable cost estimate.
    In contrast, the Army has undertaken a comprehensive inventory of ranges
    that will result in detailed site information, such as acreage and the
    types, quantity, and location of munitions, that can be used to, among
    other things, create more robust cost estimates. The Army has completed
    this comprehensive inventory on 14 percent of its installations as of
    September 2002, and has set a goal to complete this effort by December
    2003. This uneven effort in implementing the Military Munitions Response
    program could continue through various program phases, such as preliminary
    assessments and site investigations, making it difficult for DOD to assure
    that each of the services and the Corps are making progress in cleaning up
    their potentially contaminated sites and achieving the overall goals of
    the program.

    Conclusions	DOD has made limited progress in identifying, assessing, and
    cleaning up sites known or suspected to contain military munitions.
    Accomplishing this long and arduous task in a timely manner that best
    protects public safety, human health, and the environment will require a
    comprehensive approach that includes effective planning and budgeting.
    However, DOD lacks the data needed-such as a complete inventory,
    up-to-date prioritization, and reliable cost estimates-to establish a
    comprehensive approach. Without such an approach for identifying,
    assessing, and cleaning up potentially

    contaminated sites, DOD will be hampered in its efforts to achieve the
    program's objectives.

    Recommendations	To ensure that DOD has a comprehensive approach for
    identifying, assessing, and cleaning up military munitions at potentially
    contaminated sites, we recommend that the Secretary of Defense revise
    DOD's plan to

    o 	establish deadlines to complete the identification process and initial
    evaluations so that it knows the universe of sites that needs to be
    assessed, prioritized, and cleaned up;

    o 	reassess the timetable proposed for completing its reevaluation of
    sites using the new risk assessment procedures so that it can more timely
    establish the order in which sites should be assessed and cleaned up,
    thereby focusing on the riskiest sites first; and

    o 	establish interim goals for cleanup phases for the services and Corps
    to target.

    In addition, after DOD has revised its comprehensive plan, we recommend
    that it work with the Congress to develop realistic budget proposals that
    will allow DOD to complete cleanup activities on potentially contaminated
    sites in a timely manner.

    Agency Comments	We provided DOD with a draft of this report for review and
    comment. In its comments, DOD concurred with our recommendation to work
    with the Congress to develop realistic budget proposals that will allow it
    to complete cleanup activities on potentially contaminated sites in a
    timely manner. DOD partially concurred with our recommendation to
    establish deadlines to complete the identification process and initial
    evaluations so that it knows the universe of sites. DOD stated that the
    military services and the Corps have been working, and will continue to
    work, with stakeholders to identify additional sites and add these sites
    to the inventory as appropriate. DOD also stated that it believes most of
    the remaining sites to be identified are located on active installations
    still under DOD control. While we have clarified this point in the report,
    we note that the number of formerly used defense sites identified has
    increased by about 75 sites since the current inventory was completed and
    an unknown but possibly significant number of sites may be added as the
    Army completes

    identification of sites on 86 percent of its installations. These sites
    and many others still need to undergo initial evaluations. Consequently,
    we continue to believe that it is important for DOD to establish deadlines
    to complete the identification and initial evaluations for all of the
    sites in its inventory in order to establish a reasonable approximation of
    the future workload it faces.

    DOD also partially concurred with our recommendation to reassess the
    timetable proposed for completing the reevaluation of sites using the new
    risk assessment procedure. DOD stated that the military services and the
    Corps would need sufficient time and resources to complete each risk
    assessment. However, DOD stated that it had recently established 2010 as
    the goal for completing the prioritization of sites, instead of 2012 which
    was the original goal set forth in the proposed regulation. While we agree
    that this is a step in the right direction, DOD should continue to look
    for other opportunities to accelerate these inspections and the
    prioritization of sites to help ensure that resources are being targeted
    toward the riskiest sites first.

    Finally, DOD partially concurred with our recommendation to establish
    interim goals for cleanup phases for the services and the Corps. DOD
    stated that it has established interim goals of completing all preliminary
    assessments by 2007 and all site inspections by 2010, and that these goals
    apply to all military components, thereby eliminating the need for
    separate service-specific goals. However, DOD noted that it is working
    with each military service to establish additional goals and measures to
    gauge progress. While we are encouraged by DOD's efforts in this area, we
    believe that service-specific goals and measures, as they apply to the
    cleanup phases, will be essential for DOD to ensure that each of the
    services and the Corps are making progress in cleaning up potentially
    contaminated sites and achieving the overall goals of the program.

    In addition to its written comments on our draft report, DOD also provided
    a number of technical comments and clarifications, which we have
    incorporated in this report as appropriate. DOD's written comments appear
    in appendix III.

    As agreed with your office, unless you publicly announce the contents of
    this report earlier, we plan no further distribution until 30 days from
    the report date. At that time, we will send copies of this report to the
    appropriate congressional committees; the Secretary of Defense; Director,

    Office of Management and Budget; and other interested parties. We will
    also make copies available to others upon request. In addition, the report
    will be available at no charge on the GAO Web site at http://www.gao.gov.

    If you or your staffs have any questions, please call me or Edward Zadjura
    at (202) 512-3841. Key contributors to this report are listed in appendix
    IV.

    Sincerely yours,

    Anu K. Mittal Director, Natural Resources and Environment

    Appendix I

    Safety, Environmental, and Human Health Risks

    Military munitions can pose risks to public safety, human health, and the
    environment. In terms of the explosive hazard, unexploded ordnance poses
    an immediate safety risk of physical injury to those who encounter it.
    Military munitions may also pose a health and environmental risk because
    their use and disposal may release constituents that may contaminate soil,
    groundwater, and surface water. Ranges contaminated with military
    munitions, especially those located in ecologically sensitive wetlands and
    floodplains, may have soil, groundwater, and surface water contamination
    from any of the over 200 chemical munitions constituents that are
    associated with the ordnance and their usage. When exposed to some of
    these constituents, humans potentially face long-term health problems,
    such as cancer and damage to heart, liver, and kidneys. Of these
    constituents, there are 20 that are of greatest concern due to their
    widespread use and potential environmental impact. Table 2 contains a
    listing of these munitions constituents, and table 3 describes some of the
    potential health effects of five of them.

    Appendix I
    Safety, Environmental, and Human Health
    Risks

         Table 2: Munitions Constituents of Greatest Concern Type of munitions
                                      constituents

    Trinitrotoluene (TNT)
    1,3-Dintrobenzene
    Nitrobenzene
    2,4-Dinitrotoluene
    2-Amino-4,6-Dinitrotoluene
    2-Nitrotoluene
    2,6-Dinitrotoluene
    4-Amino-2,6-Dinitrotoluene
    3-Nitrotoluene
    Octahydro-1,3,5,7-tetranitro-1,3,5,7-tetrazocine (HMX)
    2,4-Diamino-6-nitrotoluene
    4-Nitrotoluene
    Hexahydro-1,3,5-trinitro-1,3,5-triazine (RDX)
    2,6-Diamino-4-nitrotoluene
    Methylnitrite
    Perchlorate
    1,2,3-Propanetriol trinitrate (Nitroglycerine)
    Pentaerythritoltetranitrate (PETN)
    1,3,5-Trinitrobenzene
    N,2,4,6-Tetranitro-N-methylaniline (Tetryl) (White Phosphorus)

    Source: DOD, Fiscal Year 2002 Defense Environmental Restoration Program
    Annual Report to Congress.

    While many of these constituents have been an environmental concern to the
    Department of Defense (DOD) for more than 20 years, the current
    understanding of the causes, distribution, and potential impact of
    constituent releases into the environment remains limited. The nature of
    these impacts, and whether they pose an unacceptable risk to human health
    and the environment, depend upon the dose, duration, and pathway of
    exposure, as well as the sensitivity of the exposed populations. However,
    the link between such constituents and any potential health effects is not
    always clear and continues to be studied.

    Appendix I
    Safety, Environmental, and Human Health
    Risks

    Table 3: Potential Effects of the Munitions Constituents Closely
    Associated with Military Munitions

                         Constituent Potential toxicity/effects

    TNT	Possible human carcinogen, targets liver, skin irritations, and
    cataracts.

    RDX	Possible human carcinogen, prostate problems, nervous system problems,
    nausea and vomiting. Laboratory exposure to animals indicates potential
    organ damage.

    HMX	Animal studies suggest potential liver and central nervous system
    damage.

    Perchlorate	Exposure causes itching, tearing, and pain; ingestion may
    cause gastroenteritis with abdominal pain, nausea, vomiting, and diarrhea;
    systemic effects may follow and may include ringing of ears, dizziness,
    elevated blood pressure, blurred vision, and tremors. Chronic effects may
    include metabolic disorders of the thyroid.

    White Phosphorus	Reproductive effects. Liver, heart, or kidney damage;
    death; skin burns, irritation of throat and lungs, vomiting, stomach
    cramps, drowsiness.

    Source: Environmental Protection Agency, Handbook on the Management of
    Ordnance and Explosives at Closed, Transferring, and Transferred Ranges
    and Other Sites.

    Appendix II

    Additional Details on Our Scope and Methodology

    The objectives of our review were to evaluate (1) DOD's progress in
    implementing its program to identify, assess, and clean up sites
    containing military munitions and (2) DOD's plans to clean up remaining
    sites in the future. To evaluate DOD's progress in identifying, assessing,
    and cleaning up military munitions sites, we analyzed data provided to us
    by DOD's Office of the Deputy Undersecretary of Defense (Installations and
    Environment) Cleanup Office from its database for sites identified under
    the Military Munitions Response program. This information includes the
    status of studies or cleanup actions, as well as cost estimates. The data
    are complete as of September 30, 2002, DOD's most recent reporting cycle,
    and were used to develop DOD's Fiscal Year 2002 Defense Environmental
    Restoration Program Annual Report to Congress. We also analyzed additional
    data on the status of studies or cleanup actions provided to us by the
    Army Corps of Engineers (the Corps) from its database of formerly used
    defense sites. We assessed the reliability of relevant fields in these
    databases by electronically testing for obvious errors in accuracy and
    completeness, reviewing information about the data and the system that
    produced them, and interviewing agency officials knowledgeable about the
    data. When we found inconsistencies, we worked with DOD and military
    service officials to correct the inconsistencies before conducting our
    analyses. We determined that the data needed for our review were
    sufficiently reliable for the purposes of our report.

    We also reviewed 38 of 75 project files at seven Corps districts where,
    according to DOD's database, site cleanup action is either complete or
    under way. (See table 4 for a listing of these districts).

                        Table 4: Districts Visited during Review

    Total number Sites with cleanup Sites with cleanup Corps district of sites
    completed under way

                       Baltimore          2                                   1 1
                      Fort Worth          3                                   0 3
                        Honolulu          2                                   0 2
                      Huntsville         12                                   4 8
                    Jacksonville          8                                   2 6
                     Kansas City          4                                   3 1
                     Los Angeles          7                                   2 5
                           Total         38                                 12 26
                    Source: GAO.
                         Page 25                    GAO-04-147 Military Munitions

    Appendix II
    Additional Details on Our Scope and
    Methodology

    We selected these districts based on the number of sites where cleanup was
    completed or under way and the estimated cost to complete cleanup, with
    some consideration given for geographic distribution. These files
    represented 52 percent of the 23 sites with a completed cleanup action and
    50 percent of the 52 sites with a cleanup action under way. We used our
    file reviews to develop case example of changes in estimated costs to
    complete cleanup over time and cleanup actions taken. These case examples
    are for illustration only.

    To evaluate DOD's plans for addressing the remaining sites, we analyzed
    the plans, as well as the assumptions upon which those plans are based,
    including cost and projected completion dates. In addition, we reviewed
    policies and program guidance, analyzed financial data, and interviewed
    program managers in DOD and the military services and the Corps. We
    conducted our work between November 2002 and October 2003 in accordance
    with generally accepted government auditing standards.

                                      Appendix III

                        Comments from the Department of Defense

    Appendix III
    Comments from the Department of Defense

    Appendix III
    Comments from the Department of Defense

    Appendix IV

                         GAO Contacts and Staff Acknowledgments

    GAO Contacts	Ms. Anu K. Mittal, (202) 512-3841 Edward Zadjura, (202)
    512-9914

    Acknowledgments 	In addition to those named above, Jack Burriesci,
    Elizabeth Erdmann, Sherry McDonald, and Matthew Reinhart made key
    contributions to this report. Also contributing to this report were
    Cynthia Norris, Rebecca Shea, and Ray Wessmiller.

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