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 [email protected].

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

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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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