Chemical Weapons Stockpile: Emergency Preparedness in Alabama Is Hampered
by Management Weaknesses (Letter Report, 07/23/96, GAO/NSIAD-96-150).
Pursuant to a congressional request, GAO reviewed the Army's Chemical
Stockpile Emergency Preparedness Program (CSEPP) for Alabama and Calhoun
County, Alabama, focusing on: (1) the status and funding of CSEPP in
these areas; (2) the impact of federal, state, and local management on
Alabama's program; and (3) Calhoun County's opposition to an Army
chemical stockpile disposal facility.
GAO found that: (1) Alabama counties near Anniston Army Depot are not
fully prepared to respond to a chemical stockpile emergency; (2) as of
March 1995, Alabama had spent one-third of its CSEPP funds, and Calhoun
County had spent one-fifth of its CSEPP funds; (3) Alabama and Calhoun
County have been unable to spend more of their CSEPP funds because the
Federal Emergency Management Agency (FEMA), state, and local officials
cannot agree on specific requirements for major capital projects, and
FEMA has not given Alabama or Calhoun County permission to spend
additional CSEPP funds; (4) more than 83 percent of Alabama's unexpended
funds are associated with four projects, including the 800-MegaHertz
(MHz) Communications Project, collective protection of special
facilities, tone alert radios, and personal protective equipment; (5)
Calhoun County will oppose a state environmental permit for the
construction of the Anniston disposal facility until it receives a
written commitment from the Army supporting the county's emergency
preparedness requirements, or an acceptable alternative; (6) the lack of
progress in Alabama's CSEPP is the result of management weaknesses at
the federal level and inadequate action by state and local agencies; (7)
these weaknesses have resulted in time-consuming negotiations and delays
in implementing projects critical to emergency preparedness; and (8) the
Army's financial management of CSEPP has been ineffective.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: NSIAD-96-150
TITLE: Chemical Weapons Stockpile: Emergency Preparedness in
Alabama Is Hampered by Management Weaknesses
DATE: 07/23/96
SUBJECT: Army facilities
Emergency preparedness
Chemical warfare
Intergovernmental relations
Waste disposal
Hazardous substances
Communications equipment
Funds management
Defense contingency planning
IDENTIFIER: Army Chemical Stockpile Emergency Preparedness Program
Alabama
Calhoun County (AL)
Alabama 800-Mega Hertz Communications Project
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Cover
================================================================ COVER
Report to the Honorable
Glen Browder, House of Representatives
July 1996
CHEMICAL WEAPONS STOCKPILE -
EMERGENCY PREPAREDNESS IN ALABAMA
IS HAMPERED BY MANAGEMENT
WEAKNESSES
GAO/NSIAD-96-150
Chemical Weapons
(709180)
Abbreviations
=============================================================== ABBREV
CSEPP - Chemical Stockpile Emergency Preparedness Program
DOD - Department of Defense
DEM - Department of Environmental Management
EMA - Emergency Management Agency
FEMA - Federal Emergency Management Agency
MHz - megahertz
Letter
=============================================================== LETTER
B-271766
July 23, 1996
The Honorable Glen Browder
House of Representatives
Dear Mr. Browder:
As requested, we reviewed the Army's Chemical Stockpile Emergency
Preparedness Program (CSEPP) for Alabama and Calhoun County. You
were concerned that Alabama communities may not be prepared to
respond to a chemical stockpile emergency, even though the Army
allocated the state $46 million to enhance emergency preparedness.
Our objectives were to assess (1) the funding and status of CSEPP in
Alabama and Calhoun County; (2) the impact of federal, state, and
local management on Alabama's program; and (3) Calhoun County's
opposition to the chemical stockpile disposal facility that the Army
plans to build at the Anniston Army Depot.
RESULTS IN BRIEF
------------------------------------------------------------ Letter :1
Eight years after CSEPP's inception, Alabama communities near
Anniston Army Depot are not fully prepared to respond to a chemical
stockpile emergency because they lack critical items. Alabama and
six counties have not spent $30.5 million, 66.4 percent of the $46
million allocated to enhance emergency preparedness. The unexpended
funds are associated primarily with the following four projects for
which federal, state, and local officials have not agreed on specific
requirements: (1) a CSEPP
800-megahertz (MHz) emergency communications system, (2) equipment
and supplies to protect people in public buildings (including schools
and hospitals), (3) indoor alert and notification devices for public
buildings and homes, and (4) personal protective equipment for
emergency workers.\1 Citing these four projects and eight other areas
as major emergency preparedness deficiencies, Calhoun County
Emergency Management Agency (EMA) opposes the granting of a state
environmental permit for the construction of Anniston's disposal
facility until it receives a written commitment from the Army to
support the county's emergency preparedness requirements or provide
acceptable alternatives.
The lack of progress in Alabama's CSEPP is the result of management
weaknesses at the federal level and inadequate action by state and
local agencies. Management weaknesses at the federal level are
fragmented and unclear roles and responsibilities, incomplete and
imprecise planning guidance, extensive involvement in the
implementation of certain local projects, lack of team work in the
budget process, and ineffective financial controls. These weaknesses
have resulted in time-consuming negotiations and delays in
implementing projects critical to emergency preparedness. At the
state level, Alabama EMA spent more than 2 years trying to contract
for a demographics survey, which will serve as the basis for
determining the requirements for the tone alert radios and developing
critical planning documents. The survey still has not started as of
May 28, 1996. In addition, Calhoun County EMA has been reluctant to
initiate CSEPP projects until federal officials agree to the county's
requirements.
The situation in Alabama may not be unique; since 1994, we have
reported that CSEPP is not working the way it was intended. Our work
has shown that although some progress has been made, local
communities near the eight chemical weapons storage sites in the
United States are not fully prepared to respond to a chemical
emergency, financial management is weak, and costs are growing. For
example, almost $157.3 million
(44.9 percent) of the $350.5 million in CSEPP expenditures have been
for federal management, contracts and Army installations, and the
Army's current program cost estimate of $1.03 billion has increased
by
800 percent over the original estimate of $114 million.
We are not making any recommendations at this time. The information
on Alabama's CSEPP is being used in an ongoing assessment of the
status and management of CSEPP in the other nine states participating
in the program. We plan to issue a report later this year. However,
at this time, clearly the problems experienced in Alabama's CSEPP are
likely to continue until an effective approach is developed for
reaching timely agreements among federal, state, and local officials
on specific requirements for projects. Developing this approach
should rest with the Army to whom the program funds are appropriated
and is ultimately responsible for the program's success.
--------------------
\1 On April 23, 1996, federal, state, and local officials negotiated
an agreement on the 800-MHz communications project.
BACKGROUND
------------------------------------------------------------ Letter :2
In November 1985, the Congress directed the Department of Defense
(DOD) to destroy the U.S. stockpile of obsolete chemical agents and
munitions and also directed that the disposal program provide for the
maximum protection of the environment, the public, and the personnel
involved in disposing of the munitions.\2 Although the Army considers
the likelihood of a chemical release at one of its eight storage
sites to be extremely small, the health effects of an accident can be
severe. Some munitions contain nerve agents, which can disrupt the
nervous system and lead to loss of muscular control and death.
Others contain a series of blister agents commonly, but incorrectly,
referred to as mustard agents, which blister the skin and can be
lethal in large amounts.
State and local officials, in accordance with state laws, have
primary responsibility for developing and implementing emergency
response programs for communities in the event of an emergency. In
1988, the Army established CSEPP to assist communities near the
chemical stockpile storage sites to enhance existing emergency
preparedness and response capabilities in the unlikely event of a
chemical accident. Most communities near the sites had little
capability to respond to a chemical emergency when CSEPP began.
Threats to the stockpile include external events such as earthquakes,
airplane crashes, and tornadoes and internal events such as
spontaneous leakage of chemical agent, accidents during handling and
maintenance activities, and self-ignition of propellant. The effect
of a chemical stockpile accident would depend on such things as the
amount and type of agent released, meteorological conditions, and the
community's proximity to the storage site and emergency response
capabilities.
The Department of the Army is responsible for managing and funding
CSEPP. Section 1521(c)(3) of 50 U.S.C. states that the Secretary of
Defense may make grants to state and local governments, either
directly or through the Federal Emergency Management Agency (FEMA),
to assist those governments in carrying out functions related to
emergency preparedness. Under a memorandum of understanding, the
Army delegated partial management of the program to FEMA. As the
primary source of technical expertise in chemical weapons, the Army
determines overall program direction and provides funding. As the
primary source of expertise in emergency preparedness, FEMA
distributes Army funds to states through cooperative agreements and
provides technical assistance.\3 "Cooperative agreements" are legal
instruments that provide federal funds when there will be substantial
involvement by federal agencies in the management of state and local
programs. In contrast to cooperative agreements, "federal grants"
are legal instruments that provide funds when there will be no
substantial federal involvement. Program funds flow from the Army to
FEMA headquarters, through FEMA regional offices, and to the states.
States provide funds to counties as their subgrantees. According to
CSEPP guidance, FEMA is responsible for working with state and local
governments in developing emergency preparedness plans, upgrading
community response capabilities, and conducting training.\4 A
combined Army and FEMA office, called the CSEPP Core Team,
coordinates and implements public affairs, exercises, training,
communications, and other activities for the program. (See app. I
for funds allocated to CSEPP entities for fiscal years 1988 through
1995.)
At the state level, the Alabama EMA is responsible for CSEPP and
other emergency programs. Six Alabama counties participate in the
program: Calhoun, Clay, Cleburne, Etowah, St. Clair, and Talladega.
Of the six counties, Calhoun County has the largest population at
risk and has received most of the funds. Calhoun EMA manages CSEPP
and other emergency programs for the county. Anniston Army Depot in
Alabama stores 661,000 chemical weapons containing more than 2,200
tons of nerve and mustard agents. Included in Anniston's stockpile
are approximately 78,000 nerve agent-filled M55 rockets, the
stockpile's most unstable weapon. Before constructing its chemical
stockpile disposal facility at Anniston and other stockpile sites,
the Army is required to obtain certain permits and approvals from
federal, state, and local regulatory agencies. Under the Resource
Conservation and Recovery Act of 1976, as amended (42 U.S.C. 6901 et
seq), the Environmental Protection Agency has delegated the
administration of the environmental permitting process to the Alabama
Department of Environmental Management (DEM).
--------------------
\2 Public Law 99-145.
\3 The funds provided to the states are covered by the Uniform
Administrative Requirements for Grants and Cooperative Agreements to
State and Local Governments (44 C.F.R., parts 13 and 14).
\4 Planning Guidance for the Chemical Stockpile Emergency
Preparedness Program, the Army and FEMA, July 6, 1994.
ALABAMA AND SIX COUNTIES HAVE
NOT SPENT MOST CSEPP FUNDS
------------------------------------------------------------ Letter :3
Since 1989, the Army and FEMA have awarded Alabama $46 million, more
than any other state, for CSEPP. Table 1 shows that as of March 1995
Alabama had spent only one-third of the $46 million and that Calhoun
County, whose share of the $46 million is $30.2 million, had spent
only one-fifth of its money.
Table 1
Comparison of Expended and Unexpended
CSEPP Funds for Alabama and Calhoun
County (fiscal years 1989-95)
(Dollars in thousands)
Calhou
n Total\
Category County a
------------------------------------------------------ ------ ------
Allocated funds $30,18 $45,98
7.8 0.8
Expended funds 6,145. 15,449
9 .4
Unexpended funds 24,041 30,531
.9 .4
800-MHz communications system 14,678 16,234
.7 .4
Collective protection project 4,200. 4,200.
0 0
Tone alert radios 3,772. 4,169.
0 8
Personal protective equipment 780.0 850.0
Other CSEPP projects 611.2 5,077.
2
----------------------------------------------------------------------
\a Figures are as of March 1995. Total for all state agencies and
Calhoun, Clay, Cleburne, Etowah, St. Clair, and Talladega counties.
Alabama and its counties have not been able to spend most of the
CSEPP funds allocated to them because (1) FEMA, state, and local
officials cannot agree on specific requirements for major capital
projects and (2) FEMA has not provided Alabama or Calhoun County
officials permission to spend some of the funds. According to FEMA,
the unexpended funds are mostly the result of Calhoun County's
refusal to initiate the CSEPP projects until the Army and FEMA agree
to all of the county's demands related to specific requirements.
According to Calhoun County EMA, the agency does not initiate actions
that do not conform to CSEPP guidance and could be detrimental to
providing maximum protection to the public. When disputes related to
specific requirements occur, there is no established approach for
negotiating an agreement among federal, state, and local officials.
More than 83 percent of Alabama's unexpended funds are associated
with four projects: 800-MHz communications system, collective
protection of special facilities, tone alert radios, and personal
protective equipment.
DISAGREEMENTS ON ASPECTS OF
THE 800-MHZ COMMUNICATIONS
SYSTEM DELAYED THE PROJECT
---------------------------------------------------------- Letter :3.1
On the basis of CSEPP-funded studies, Calhoun County EMA concluded in
1990 that the county's conventional communications system did not
meet CSEPP requirements. In 1992, the Army and FEMA determined that
every CSEPP jurisdiction should have a functioning communications
system connecting the Army installation, state EMA, and immediate
response zone counties. The immediate response zone is the area
generally extending approximately 6 to 9 miles around the storage
site and the area considered at the greatest risk from a chemical
release. The Army and FEMA approved a CSEPP 800-MHz communications
system for Alabama in 1993 and authorized $8.8 million and $4.4
million in fiscal years 1994 and 1995, respectively. FEMA
subsequently authorized an additional $3 million, bringing total
funding for the system to $16.2 million.
The communications system is an integrated, simulcast network with
20 channels that operate at a frequency of
800-MHz. The system will enable Alabama emergency workers to
communicate inter- and intra-agency without having to wait for a
channel to clear if someone is using it. The system is also the
platform to simultaneously activate sirens and tone alert radios. In
the authorization, FEMA also said the precise number of radios, their
distribution, and follow-on radios would be decided by negotiations
among FEMA, state, and county officials.
Despite several years of studying, meeting, and negotiating, Alabama
does not have an integrated 800 MHz communications system for CSEPP.
Federal, state, and local officials did not agree on the number and
distribution of the 800-MHz radios until April 23, 1996. In
addition, FEMA officials decided to place a $1-million repeater tower
and some radios in Talladega County's precautionary zone. The
"precautionary zone" is the area beyond 21 to
30 miles from the storage site and, under most conditions, beyond
where CSEPP activities are required and where a repeater tower would
be located. However, Calhoun and St. Clair county officials believe
placing the tower and radios in the precautionary zone does not
comply with program guidance. Some equipment will be nearly 50 miles
from the Anniston Army Depot. As a result, Calhoun EMA, which is
managing the contract for the 800-MHz system, was reluctant to award
the contract.
According to FEMA, the 800-MHz communications system is not in place
because Calhoun County EMA refused to initiate work on the contract
until the county's demand for additional radios was met. According
to the Calhoun EMA Director, his agency only supports projects that
provide goods, services, and equipment in compliance with CSEPP
guidance. On April 23, 1996, federal, state, and county officials
met to resolve the issues that were delaying the implementation of
the CSEPP 800-MHz project in Alabama. At the meeting, federal
officials agreed to provide additional
800-MHz radios to Alabama and Calhoun and Talladega counties.
Calhoun County EMA awarded the 800-MHz contract on May 30, 1996.
According to Calhoun EMA, the contractor has 16 months from the
contract award date to manufacture and install the communications
system.
CALHOUN COUNTY EMA DISAGREES
WITH FEMA'S SELECTION OF
FACILITIES FOR COLLECTIVE
PROTECTION
---------------------------------------------------------- Letter :3.2
In 1989, the Oak Ridge National Laboratory concluded that, in the
event of an accidental release of chemical agent, a chemical plume
could cover sections of Calhoun County's immediate response zone in 1
hour.\5 (See app. II for a description of the potential distribution
of the hazard from a chemical release.) Oak Ridge also concluded in
the 1989 report that evacuation was not recommended for the general
population in Anniston's immediate response zone and recommended
expedient sheltering. According to another Oak Ridge National
Laboratory draft report in 1991, Calhoun County residents would take
5 hours and 45 minutes to evacuate the greater Anniston area. The
Oak Ridge's estimate is the clearance time required for 100 percent
of the vehicles to evacuate the area during bad weather at nighttime.
On the basis of the Oak Ridge studies, Calhoun County EMA officials
believe that it would be impossible to safely evacuate everyone.
However, according to a senior official from the Oak Ridge National
Laboratory, Calhoun County officials should not rely on the results
of the 1991 draft report for planning purposes because the (1) report
was never finalized and (2) changes in road conditions and
demographics since 1991 may have affected the results of the draft
report.\6
To shelter the people they cannot evacuate, Calhoun County EMA
officials believe collective protection is the best option.
According to Calhoun EMA officials, "collective protection" is a
combination of (1) a filtered overpressurized air system and (2)
adequate food, water, and medical supplies to house a selected number
of people up to 3 days in a closed facility. However, Army officials
believe Calhoun EMA's shelter time estimate of 3 days is excessive
and that a chemical plume would pass over the area in 3 to 12 hours.
The facilities to be provided with collective protection include
schools, hospitals, jails, community centers, and public buildings
that are within walking distance of homes and businesses. The Army
Edgewood Research, Development and Engineering Center has completed a
study to validate procedures for sheltering residents in a variety of
housing types and identify a less burdensome and costly way to
protect citizens in place. The draft report is dated December 8,
1995, and comments are being incorporated for publication of the
final report.
Although FEMA allocated Alabama $4.2 million for positive
pressurization, county officials are reluctant to accept the
allocation because they disagree with FEMA's selection of facilities
and funding amount.\7 In September 1995, Calhoun County EMA provided
federal officials a suggested list of 55 facilities for collective
protection. FEMA officials selected 21 facilities from the list on
the basis of the location and type of facility but did not discuss
their selection with Calhoun EMA officials. According to county
officials, five of the facilities FEMA selected were not their
highest priority. In addition, FEMA only provided enough funding for
8 to 10 hours of support rather than the 3 days requested by the
county. As a result, as of April 19, 1996, county officials had not
accepted the allocation. According to FEMA, the agency has not
received a formal rebuttal or request from Calhoun County to change
this authorization.
--------------------
\5 Emergency Response Concept Plan for Anniston Army Depot and
Vicinity, Oak Ridge National Laboratory, Oct. 1989.
\6 FEMA never asked Oak Ridge National Laboratory to finalize the
draft report.
\7 "Positive pressurization" is just one portion (the filtered
overpressurized air system) of Calhoun County's concept of collective
protection.
FEMA HAS NOT RELEASED FUNDS
FOR TONE ALERT RADIOS
BECAUSE REQUIREMENTS ARE NOT
IDENTIFIED
---------------------------------------------------------- Letter :3.3
In 1992, the Army and FEMA agreed that every CSEPP location should
have a functioning alert and notification system for communities in
the immediate response and protective action zones.\8 Tone alert
radios are indoor alert and notification devices that will be placed
in homes, schools, hospitals, jails, nursing homes, and businesses in
the zones. The radios are capable of providing alerting signals and
instructional messages about appropriate protective actions.
In fiscal year 1993, FEMA allocated Alabama $900,000 to conduct a
demographics survey to determine the requirements for tone alert
radios and $4.3 million for the radios, with the stipulation that the
funds not be released until the survey was completed. FEMA required
the demographics survey to determine the number of residences and
institutions requiring tone alert radios before they were purchased
and installed. Because the Alabama EMA has not completed the
demographics survey, FEMA has not released the funds. (See app. III
for a discussion of Alabama EMA's management of the demographics
survey.) According to Alabama EMA officials, they are close to
awarding a contract for the survey with the Argonne National
Laboratory and plan to submit their contract proposal to the
governor's office in June 1996. After the contract is awarded, the
demographics survey should take 6 to 9 months to complete.
--------------------
\8 The "protective action zone" is the area generally extending 10 to
30 miles from the chemical stockpile storage site where public
protective actions may be necessary but where most people have time
to evacuate in case of a chemical emergency.
FEMA DELAYED FUNDING FOR
PERSONAL PROTECTIVE
EQUIPMENT
---------------------------------------------------------- Letter :3.4
Personal protective equipment has been considered a critical response
requirement for several years. In July 1994, the Argonne National
Laboratory concluded there was a potential for the aerosol deposition
of agents off post from a chemical stockpile accident at Anniston.\9
The deposition creates the requirement for personal protective
equipment. "Personal protective equipment" consists of portable
respirators, protective suits, gloves, boots, and hoods. Because of
their traffic, decontamination, health, and other critical response
duties at the periphery of the chemical plume, local CSEPP emergency
workers may find themselves in danger of contamination from an
unexpected shift in the chemical plume.
In fiscal year 1994, Calhoun County EMA requested funding for
personal protective equipment. FEMA deferred the request until CSEPP
funds became available in fiscal year 1995. At this time, FEMA
transferred $850,000 to Alabama EMA for personal protective equipment
with the condition the agency was not authorized to purchase
equipment until the Occupational Safety and Health Administration
completed an evaluation of available civilian protective equipment.
The Occupational Safety and Health Administration completed its
evaluation in late 1995. However, Calhoun EMA officials believe they
need additional funding for Army-provided equipment, protective
components for decontamination teams, and medical examinations for
local emergency workers. A draft document produced by the Centers
for Disease Control and Prevention suggests that emergency workers
who wear personal protective equipment complete annual medical
examinations.\10 In late 1995, the Army initiated a needs assessment
study to calculate new equipment requirements for Alabama and
Kentucky. Alabama EMA officials assume that any additional personal
protective equipment funding will be withheld pending the outcome of
the assessment.
According to FEMA, there is nothing preventing Calhoun County EMA
from purchasing the approved equipment, but the county has refused to
initiate work on the project until its demand for additional funding
is approved. According to Calhoun County EMA, the agency is ready to
issue a contract for the civilian respirators and protective suits
after the requirements for medical examinations are defined and
related funds are provided by FEMA.
--------------------
\9 Potential for Surface Contamination by Deposition of Chemical
Agent Following Accidental Release at an Army Storage Depot, Argonne
National Laboratory, July 1994.
\10 The draft is not dated, but officials from the centers believe
that it was produced in early 1996.
MANAGEMENT WEAKNESSES AT THE
FEDERAL LEVEL HAVE HAMPERED
PROGRESS
------------------------------------------------------------ Letter :4
The Army is slow to achieve the desired results in Alabama because
CSEPP's (1) management roles and responsibilities are fragmented and
unclear, (2) planning guidance is imprecise and incomplete, (3)
officials at the federal level are too involved in the management of
certain local projects, (4) budget process lacks teamwork, and (5)
financial controls are ineffective. These weaknesses have resulted
in time-consuming negotiations and delays in implementing projects
critical to emergency preparedness.
THE ARMY'S AND FEMA'S ROLES
AND RESPONSIBILITIES ARE NOT
WELL-DEFINED
---------------------------------------------------------- Letter :4.1
The Army and FEMA formed the CSEPP Core Team to facilitate
communication with state and county officials. However, the Core
Team does not function as intended. The Army's and FEMA's management
responsibilities are not well-defined; there is no clearly defined
protocol for communicating with any of the management groups. As a
result, state and county EMA officials are uncertain about federal
roles and responsibilities, and often find themselves trying to
interact with two or more officials from the CSEPP Core Team, FEMA
headquarters, and the FEMA regional office. For example, a Calhoun
EMA official recently contacted a FEMA Core Team member to discuss
the unresolved issue about the distribution of 800 MHz radios. The
Core Team member told the county official to use the state's chain of
command and direct his inquiries through Alabama EMA and the FEMA
regional office. In some cases, county EMA officials have vented
their frustrations to the Army Program Manager for Chemical
Demilitarization and to Members of Congress.
In commenting on a draft of this report, FEMA said that CSEPP has a
well-defined and long-established protocol for intergovernmental
communications. Specifically, according to FEMA, information flows
back and forth along the following protocol:
Figure 1: FEMA's
Communications Protocol for
CSEPP
(See figure in printed
edition.)
Source: FEMA.
(See figure in printed
edition.)
However, FEMA's protocol does not recognize the role and
responsibilities of the CSEPP Core Team. According to the Core
Team's charter, dated January 6, 1995, the Core Team is the focal
point for accountability of the program and coordinates and
integrates on- and off-post activities. The Core Team was
established, in part, to streamline procedures, improve
responsiveness to state and local agencies, and enhance the overall
budget process. We believe that FEMA's illustration supports our
observation that the role and responsibilities of the CSEPP Core Team
are not clearly understood by state and county officials.
PLANNING GUIDANCE IS
IMPRECISE AND INCOMPLETE
---------------------------------------------------------- Letter :4.2
The Army and FEMA's planning guidance, by design, allows states and
counties flexibility to enhance their local emergency preparedness
programs to address the different risks at the stockpile sites. In
commenting on a draft of this report, FEMA said that too much
precision in the guidance would limit CSEPP's ability to change with
improvements in technology and emergency management techniques.
However, as a result of its imprecise nature, the guidance is often
interpreted differently by federal, state, and county officials. In
other cases such as emergency medical services, reentry, and
restoration, the guidance has not been completed.
CSEPP's guidance on communication systems states that radios should
go to public safety agencies. At one time, FEMA officials
interpreted this to mean only agencies responding immediately to the
chemical emergency. On the other hand, Calhoun EMA officials
interpret the guidance to include law, fire, rescue, and other public
safety agencies responding to a chemical emergency, as well as
governmental, medical, educational, and other special agencies.
County officials point out that CSEPP guidance goes far beyond public
safety agencies. In February 1996, after extensive negotiations,
FEMA tentatively agreed to fund radios for agencies defined as
quasi-public safety agencies. These agencies include Calhoun County
Road Department, Anniston Public Works, and Anniston Water Works.
Federal, state, and local officials did not agree on the final number
and distribution of the 800-MHz radios until April 23, 1996.
In another example, Calhoun County EMA officials provided five pages
of references to CSEPP guidance to justify their request for 24-hour
staffing of their emergency operations center. However, the guidance
does not provide a firm position on the requirement for 24-hour
staffing. County officials' justification is based primarily on the
8-minute window to respond to a chemical emergency. The officials
believe the county needs to have 24-hour staffing for its operations
center to meet the 8-minute alert and notification requirement. If
an incident occurred when the center was closed, it would take a
minimum of 30 minutes for an employee to travel to the center and
initiate the alert and notification process. The Army policy is to
implement 24-hour staffing of the depot's emergency operations center
when disposal operations begin and not to fund 24-hour staffing of
local centers. In commenting on a draft of this report, the Army
said that Calhoun EMA should consider less costly options, such as
using the county's 911 emergency center, to initiate its alert and
notification process. According to Calhoun County EMA, there are
safety concerns about the location of the county's existing 911
center in the immediate response zone. In addition, Calhoun EMA
attempted to relocate and consolidate the county's 911 emergency
center with the EMA emergency operations center in the early 1990s,
but did not receive any support from the Army or FEMA. The need for
24-hour staffing is still an ongoing issue with federal, state, and
Calhoun County officials.
Local officials are also dissatisfied with FEMA's inconsistent
interpretation of CSEPP guidance. For example, the St. Clair County
EMA Director commented to us about FEMA's inconsistent budget
decisions. FEMA denied her request for alert devices for the
county's volunteer fire department because the department was not in
the protective action zone and does not comply with CSEPP guidance.
In contrast, she points out that Talladega County is receiving a
repeater tower and radios for its precautionary zone, outside of
CSEPP guidance. According to FEMA officials, they are obtaining a
waiver to CSEPP guidance for Talladega's tower.
In other cases, CSEPP guidance is not complete. Program officials
originally planned to complete all program guidance and standards by
September 1989. However, they have not yet completed their guidance
on emergency medical services or reentry and restoration
procedures.\11 As a result, local communities lack formal guidance to
help them prepare their plans and determine their requirements for
medical services, reentry, and restoration. According to FEMA
officials, the guidance has been distributed in draft form pending
resolution of outstanding issues. They believe that the outstanding
issues should not preclude the states and counties from using the
drafts for daily planning. However, Calhoun County EMA and other
CSEPP participants do not consider FEMA's drafts as final planning
guidance.
--------------------
\11 On June 27, 1995, the Centers for Disease Control and Prevention
published in the Federal Register their recommendations for medical
preparedness guidelines for communities near the chemical stockpile
storage sites. FEMA is still in the process of issuing the final
medical preparedness guidelines.
FEMA OFFICIALS ARE TOO
INVOLVED IN CERTAIN LOCAL
PROJECTS
---------------------------------------------------------- Letter :4.3
FEMA has said that the states are in the best position to determine
CSEPP priorities on a statewide basis and balance local requirements
against the needs of all affected counties. However, our work shows
that in certain cases, FEMA officials become involved in the
management of local projects to the point of making specific
decisions on requirements. This level of involvement has contributed
to disagreements and time-consuming negotiation on projects.
For example, according to Calhoun EMA officials, FEMA never consulted
with the county on their selection of the 21 facilities to be
collectively protected and selected 5 facilities that county
officials would prefer to be protected at a later date. In another
example, FEMA officials had Talladega County EMA officials take them
by helicopter to view the proposed sites for additional sirens. In
Calhoun County, the same FEMA officials videotaped the locations
where county officials said they needed sirens. With respect to the
800-MHz communications project, FEMA officials specified where the
radios will be located by each agency in Calhoun County. In
commenting on a draft of this report, FEMA said that the past and
present scrutiny by the Congress and us has resulted in the agency's
instituting stricter controls to ensure that it does not authorize
unnecessarily elaborate or unreasonable funding requests. We believe
that once the Army and FEMA approve and allocate funds for a CSEPP
project, state and local agencies are in the best position to
implement and manage the project. Similarly, FEMA also concludes in
its comments that the states are in the best position to determine
program priorities on a statewide basis and balance local
requirements against the needs of all CSEPP counties.
According to Calhoun County EMA, FEMA sometimes places unacceptable
conditions on the county's use of CSEPP funds. For example, in
September 1995, FEMA allocated Calhoun County $11,400 to complete the
purchase of three mobil emergency road signs, with the following
conditions: no vehicles would be provided to move the signs, no
additional funding would be provided for maintenance, and Calhoun
County would be accountable for the signs. Calhoun EMA rejected the
funding because of the conditions. The agency reported that FEMA's
conditions were unprecedented, undesirable, and unproductive.
According to Calhoun EMA officials, the county does not have
available vehicles to move the signs.
BUDGET PROCESS LACKS
TEAMWORK
---------------------------------------------------------- Letter :4.4
According to state and county officials, the budget process lacks
teamwork. County officials told us they have little or no influence
on the budgetary process other than to make the initial request and
that FEMA's rationale for budget decisions is not fully explained to
them.
Alabama EMA officials said that federal officials do not understand
the state's concept of operations. For example, FEMA allocated
Alabama EMA funds in fiscal year 1996 to purchase laptop computers
for local public information officers to use every day and take to
the joint information center during a chemical emergency. However,
the intent of this allocation differs from Alabama EMA's concept of
operations, which provides for local public information officers to
remain in their counties' operations centers. The state's concept of
operations provides for county liaisons in the joint information
center to handle county affairs. As a result, Alabama EMA officials
plan to request that FEMA reallocate these funds to the county EMAs.
Similarly, Calhoun EMA officials said that the funding process lacks
teamwork and that federal officials do not understand the county's
concept of operations. FEMA deferred funding for several local
projects that county officials believe should have been funded
sooner. For example, the county did not receive funding for personal
protective equipment until 1995--more than 6 years after the
program's inception. In another instance, Alabama and Calhoun EMA
officials concluded in 1992 that Calhoun County lacked the
infrastructure to treat and care for all evacuees but FEMA did not
provide funding for host counties until fiscal year 1996. In
addition, according to Calhoun EMA officials, FEMA may not have the
personnel with the technical expertise to adequately assess local
budget requests. For example, the FEMA regional official, who
reviews Alabama budgets, said that he did not have the technical
background to assess requirements for automation information systems
and did not fully understand Calhoun County's collective protection
concept.
OUR PREVIOUS REPORTS
DESCRIBE LONG-STANDING
WEAKNESSES IN CSEPP'S
FINANCIAL MANAGEMENT AND
CONTROLS
---------------------------------------------------------- Letter :4.5
The Army's financial management of CSEPP has not been effective in
controlling the growth in costs. The Army's current cost estimate
for the program has increased by 800 percent over the initial cost
estimate of $114 million in 1988. In commenting on a draft of this
report, the Army said that the initial estimate was made prior to
defining the program's scope, requirements, and time frames. The
Army and FEMA have already spent $350.5 million and estimate the
program will cost $1.03 billion. In addition, almost $157.3 million
(44.9 percent) of the expenditures have been for federal management,
contracts, and Army installations. According to the Army, some of
these expenditures were for computer hardware and software provided
to state and local emergency management agencies and for emergency
preparedness projects at Army installations at the local level.
In our previous work, we concluded that Army's and FEMA's management
of CSEPP needed improvements to ensure that (1) local communities
could effectively respond to a chemical emergency, (2) officials have
accurate financial information to identify how funds are spent, and
(3) program goals are achieved. In 1994, we reported that
communities near the stockpile sites lacked critical items to respond
to a chemical emergency, including operational communications
systems, alert and notification devices, decontamination equipment,
complete automated information systems, and personal protective
equipment.\12 For example, Pine Bluff, Arkansas, and Pueblo,
Colorado, did not have sirens installed and most other stockpile
sites did not have tone alert radios. According to the Army, Pine
Bluff now has an operational siren system. In 1995, we reported that
program officials lacked accurate financial information to identify
how funds were spent and ensure that program goals were achieved.\13
For example, Arkansas had reprogrammed $413,000 in unobligated funds
to construct office space without FEMA's approval, and Kentucky and
Washington had unexpended CSEPP balances of $4.4 million and $2.4
million, respectively.
Army and FEMA officials subsequently stated that they are working to
improve CSEPP's financial management. For example, the Army
restructured the overall management of CSEPP and established the
centralized CSEPP Core Team. In addition, the Army and participating
states developed life-cycle cost estimates for CSEPP in 1995 to
facilitate DOD's oversight of the program's escalating costs.
Notwithstanding these actions, the federal financial management of
CSEPP is still weak. Specifically, records on expenditure data are
limited; allocation data differ among FEMA, Alabama EMA, and county
EMAs; and FEMA maintains large unexpended balances of funds for
Alabama and Calhoun County. In response to our 1995 report on CSEPP,
DOD reported that (1) it was not cost-effective for federal program
managers to account for actual CSEPP expenditures after the initial
allocations were made, (2) discrepancies in allocation data among
management levels were not indications of weak financial management,
and (3) existence of unexpended balances that are 2 years old was not
poor management.
--------------------
\12 Chemical Weapon Stockpile: Army's Emergency Preparedness Program
Has Been Slow to Achieve Results (GAO/NSIAD-94-91, Feb. 22, 1994).
\13 Chemical Weapons: Army's Emergency Preparedness Program Has
Financial Management Weaknesses (GAO/NSIAD-95-94, Mar. 15, 1995).
STATE AND LOCAL ACTIONS HAVE
DELAYED PROJECTS
------------------------------------------------------------ Letter :5
Although the progress of CSEPP in Alabama has been hampered by
management weaknesses at the federal level, some state and local
actions have contributed to the delay in implementing projects
critical to emergency preparedness. For example, Alabama EMA spent
more than
2 years trying to contract for a demographics survey, which will
serve as the basis for determining the requirements for the tone
alert radios and developing critical planning documents. In
addition, Calhoun County EMA has been reluctant to initiate CSEPP
projects until federal officials agree to the county's requirements.
ALABAMA EMA IS SLOW TO
CONTRACT FOR THE
DEMOGRAPHICS SURVEY
---------------------------------------------------------- Letter :5.1
In September 1993, FEMA allocated Alabama $900,000 to conduct a
demographics survey of counties in the immediate response zone. The
survey was intended to serve as the basis for determining the
requirements for the tone alert radios, selecting host counties in
Alabama, and developing critical planning documents.
Alabama EMA spent more than 2 years trying to contract for a
demographics survey and the survey has still not begun. Because
Alabama EMA lacked contracting and legal personnel, the agency wanted
a former consultant to manage the contract for the demographics
survey and other planning studies. Initially, Alabama EMA spent 2
years trying to hire and pursue a sole-source contract with the
former consultant, but the Alabama Personnel Board denied the
agency's request for a merit position and, due to liability insurance
issues, the contract was never awarded.
In October 1995, Alabama EMA requested FEMA's assistance with
managing the contract. In response, FEMA contacted the Argonne
National Laboratory. In December 1995, Argonne submitted a draft
contract proposal to the state EMA. The agency sent Argonne's
proposal to its six CSEPP counties for their review. Initially,
Calhoun EMA was reluctant to participate because the contract did not
provide for specific tasks, products, time frames, and a reasonable
means of relief if the specifications were not met. In March 1996,
Alabama EMA officials told us they had concurrence from all counties
and planned to move forward with the contract. Agency officials
submitted their contract proposal for approval to the Alabama
Legislative Review Committee on May 28, 1996, and plan to submit the
proposal to the governor's office in June 1996. The purpose of the
initial contract is for Argonne to develop statements of work for the
first three planning projects: (1) the demographics survey, (2)
evacuation time estimates, and (3) a traffic management plan. After
the contract is awarded, the demographics survey should take 6 to 9
months to complete.
On May 9, 1996, the Director of Calhoun County EMA reported that his
agency had not concurred with the state's moving ahead with the total
proposed contract with the Argonne National Laboratory because the
proposal still lacks specific requirements. The Director hopes that
the lack of specificity his agency is concerned about will be laid
out in subsequent contractual efforts with Argonne.
SOME OF CALHOUN COUNTY'S
ACTIONS ARE CONSIDERED
CONTROVERSIAL
---------------------------------------------------------- Letter :5.2
Federal, state, and other county officials believe that Calhoun EMA
is often uncooperative and that its actions have a negative effect on
the progress of CSEPP in Alabama. Alabama EMA's correspondence with
Calhoun EMA often note that the county's lack of teamwork consumes
time and delays the progress of the program in Alabama. However, in
commenting on a draft of this report, Calhoun County EMA Director
disagreed with the federal, state, and other county officials'
assessment that some of his agency's actions have slowed the progress
of the program. The Director reported that Calhoun EMA has an
obligation to the citizens of the county to ensure maximum protection
and that he fully supports his agency's prior decisions and actions
regarding CSEPP issues.
In fiscal year 1992, FEMA allocated Alabama $1.2 million for a siren
system in and around Anniston and, subsequently, asked Calhoun County
EMA to manage the contract for the system. As part of the contract,
Calhoun EMA officials purchased four sirens and one activation
control panel, which are still county property, for Anniston Army
Depot. During the project, Calhoun EMA officials installed four of
the county's sirens on the depot but kept the control panel. County
EMA officials concluded there was no need for the depot to have a
control panel to activate the off-base siren system and justified
keeping the panel on the basis of a local statute prohibiting the
transfer of county property to the federal government.\14 As a
result, Anniston Army Depot could not activate the four sirens it
received or the off-base sirens. According to Army officials, the
depot plans to return the four sirens to the county and install its
own sirens. The Army estimates that the upgrade and addition of
sirens for the depot will cost $88,000.
Calhoun County EMA also manages the contract for the CSEPP 800-MHz
communications system in Alabama. In a memorandum dated October 18,
1995, after a meeting where Calhoun EMA officials declined to
negotiate on the distribution of radios, an Alabama EMA official said
it was a mistake to allow Calhoun County EMA to manage the contract.
The official concluded that Calhoun EMA officials were unable or
unwilling to look after the interests of other stakeholders in the
program. However, in commenting on a draft of this report, the
Calhoun County EMA Director disagreed with the state official's
assessment that Calhoun EMA was unable or unwilling to consider the
interests of others in the program. The Director said that all
Alabama CSEPP entities, as well as federal agencies, will directly
benefit or have already benefitted from the county's actions.
--------------------
\14 In commenting on a draft of this report, Calhoun County EMA said
that Anniston Army Depot decided that it was not activating the
off-post siren system, thus negating the requirement for a siren
controller on the depot.
CALHOUN COUNTY EMA OPPOSES
THE ENVIRONMENTAL PERMIT FOR
ANNISTON'S DISPOSAL FACILITY
---------------------------------------------------------- Letter :5.3
Because of 12 major deficiencies it has identified in the program,
Calhoun County EMA opposes the Army's environmental permit
application to construct Anniston's disposal facility until it
receives a written commitment from the Army to support the county's
emergency preparedness requirements or provide acceptable
alternatives. According to Calhoun EMA, correcting these
long-standing deficiencies is critical for the county to adequately
respond to a chemical stockpile emergency. (The 12 major
deficiencies are described in app. III.) In addition, Calhoun EMA
officials question the Army's ability to maintain its current level
of emergency support because of the decision during the base
realignment and closure process to close Fort McClellan in Alabama.
Previously, Fort McClellan was to provide medical, fire,
decontamination, and transportation support to Anniston Army Depot.
According to Alabama DEM officials, the department does not plan to
oppose the environmental permit on the basis of Calhoun EMA's
concerns. They believe that the Army has made adequate arrangements
to replace Fort McClellan's emergency response capabilities. If a
conflict between DEM and Calhoun County should exist at the time a
decision on the environmental permit is due, state laws allow the
governor of Alabama to override local communities' opposition in an
emergency situation. According to DEM officials, the chemical
stockpile weapons are considered to be a risk and, therefore, an
emergency situation.
AGENCY COMMENTS AND OUR
EVALUATION
------------------------------------------------------------ Letter :6
We received written comments on a draft of this report from DOD,
FEMA, and Calhoun County EMA. All of the agencies agreed that there
has been a lack of progress in implementing CSEPP in Alabama;
however, each expressed different views on the extent to which their
actions contributed to the delay. The major concerns raised by each
agency and our evaluations are presented here. The comments of DOD
and FEMA are presented in their entirety in appendixes IV and V,
respectively, along with our evaluation of specific points. They
also provided technical clarifications and, where appropriate, we
incorporated them in our report. The Director of Calhoun County EMA
also provided technical clarifications, which we incorporated in our
report. We did not reproduce the Director's comments because they
were technical in nature and their length and format made them
difficult to reprint.
DOD PARTIALLY CONCURRED
---------------------------------------------------------- Letter :6.1
DOD agreed with our assessment that the lack of progress in
implementing CSEPP in Alabama relates to management weaknesses.
However, DOD did not agree that federal agencies were primarily
responsible. DOD suggested that a more balanced assessment would
include the roles of federal, state, and local governments.
In our draft report, we concluded that the lack of progress of
Alabama's CSEPP was primarily the result of management weaknesses at
the federal level and that state and local actions also slowed the
program. It was not our intent to leave the impression that the
delay in Alabama's CSEPP was solely the result of management
weaknesses at the federal level. We have revised the final report to
eliminate the reference to primarily and to more clearly attribute
the lack of progress to federal management weaknesses and actions by
state and local agencies. However, it is important to note that the
problems experienced in Alabama's CSEPP are likely to continue until
an effective approach is developed for reaching timely agreements
among federal, state, and local officials on specific requirements
for projects. Even though other agencies are involved, CSEPP is an
Army program and, as such, its progress and stewardship of CSEPP
resources is ultimately the Army's responsibility.
FEMA RAISED A NUMBER OF
CONCERNS
---------------------------------------------------------- Letter :6.2
FEMA reported that it had serious concerns about our conclusions and
the tone of the report. Specifically, the agency stated that the
draft report did not (1) incorporate information supporting FEMA
actions and (2) adequately assign blame to Calhoun County EMA for
many of the delays in the program. FEMA was concerned that all of
the problems were attributed to federal mismanagement; in FEMA's view
Alabama EMA and Calhoun County EMA clearly shared responsibility for
many of the delays.
In response to FEMA's comments, we incorporated additional
information describing the agency's actions in the report. Our draft
report recognized that state and local actions, including Calhoun
County, contributed to the lack of progress in Alabama's CSEPP.
However, it was not our intent to attribute the lack of progress
solely to federal management weaknesses, and we revised the final
report to eliminate the reference to federal weaknesses as the
primary cause.
CALHOUN COUNTY EMA PARTIALLY
CONCURRED
---------------------------------------------------------- Letter :6.3
The Director of Calhoun County EMA agreed with our assessment that
Calhoun County is not fully prepared to respond to a chemical
stockpile emergency and also reported that the county is not
adequately prepared to recover from the effects of chemical
contamination. In addition, the Director concurred with our
assessment that the lack of progress in Alabama CSEPP is primarily
the result of management weaknesses at the federal level, but said
that our draft report should have focused less on management
weaknesses at the state and local levels. The Director disagreed
with our assessment that some of the county's actions have slowed the
progress of the program in Alabama. He reported that Calhoun County
EMA has an obligation to the citizens of the county to ensure maximum
protection and that he fully supports his agency's prior decisions
and actions regarding CSEPP issues. However, as discussed in the
report, we believe that some of Calhoun EMA's actions have
contributed to the lack of progress in Alabama's CSEPP.
SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :7
We obtained information from the Army and FEMA on CSEPP policies,
guidance, procedures, and projects. We also interviewed officials
and analyzed data given to us by officials from the Army Program
Manager for Chemical Demilitarization; Anniston Army Depot; FEMA
headquarters and region IV; Alabama EMA and DEM; and Calhoun, Clay,
Cleburne, Etowah, St. Clair, and Talladega counties.
To assess the funding and progress of Alabama's and Calhoun County's
emergency preparedness programs, we examined a variety of federal,
state, and county planning and funding documents and reconciled data
among the Army, FEMA, state, and counties. To assess the status of
Alabama's and Calhoun County's programs, we compared selected
projects with program guidance and requirements and determined
whether the projects complied with program goals, benchmarks, and
time frames. To assess the effectiveness of the federal, state, and
county management, we reviewed the Army's and FEMA's management
structure and guidance and compared them with state and local
requirements and concerns. For those critical projects not yet
completed, we identified and analyzed the reasons for their delay.
We also documented and analyzed the impact of (1) state and county
EMAs' involvement in the funding process, (2) the Army's and FEMA's
feedback on the budget process and partial funding of projects, and
(3) slow disbursements of funds. To assess Calhoun County EMA's
opposition to the Army's environmental permit application, we
reviewed the permitting requirements and application process and
determined the status of the county's 12 major deficiencies.
Our review was conducted from November 1995 to April 1996 in
accordance with generally accepted government auditing standards.
---------------------------------------------------------- Letter :7.1
We are sending copies of this report to the Chairmen of the Senate
Committees on Armed Services and Appropriations and the House
Committees on National Security and Appropriations, the Secretaries
of Defense and the Army, the Directors of FEMA and the Office of
Management and Budget, and other interested parties. We will make
copies available to others upon request.
Please contact me at (202) 512-8412 if you or your staff have any
questions. Major contributors to this report are listed in appendix
VI.
Sincerely yours,
David R. Warren
Director, Defense Management Issues
FUNDS ALLOCATED TO CHEMICAL
STOCKPILE EMERGENCY PREPAREDNESS
PROGRAM ENTITIES IN FISCAL YEARS
1988 THROUGH 1995
=========================================================== Appendix I
(Dollars in thousands)
Percen
Entity Amount t
------------------------------------------------------ ------ ------
Army headquarters and commands $24,45 6.98
2.7
Army installations 27,067 7.72
.6
Army major contracts (over $100,000) 68,536 19.55
.3
Other Army contracts 122.8 0.04
Federal Emergency Management Agency headquarters and 11,917 3.40
regions .7
Federal Emergency Management Agency contracts\a 25,165 7.18
.2
Alabama and counties 46,661 13.31
.1
Arkansas and counties 20,060 5.72
.7
Colorado and county 13,039 3.72
.6
Illinois and counties 3,226. 0.92
9
Indiana and counties 12,672 3.62
.2
Kentucky and counties 17,796 5.08
.6
Maryland and counties 17,437 4.97
.4
Oregon and counties 22,568 6.44
.2
Utah and counties 21,134 6.03
.4
Washington and county 15,777 4.50
.4
Other entities 1,093. 0.31
1
Not allocated 1,778. 0.51
6
======================================================================
Total $350,5 100.00
08.5
----------------------------------------------------------------------
\a According to the Federal Emergency Management Agency (FEMA), the
agency's contracts support the entire Chemical Stockpile Emergency
Preparedness Program (CSEPP) community and include the development of
program guidance, training courses, and computer software.
Source: Department of the Army and FEMA.
HAZARD DISTRIBUTION FROM A
HYPOTHETICAL CHEMICAL RELEASE
========================================================== Appendix II
A variety of accidents associated with the chemical stockpile weapons
can occur at the storage site or disposal facility or in transit.
The distribution of the hazard from these accidents is based on a
number of factors, including how much agent is released, how it is
released, the duration of the release, the meteorological conditions,
and the topography. In general, the risks from any release decreases
as the distance away from the release point increases. As a result,
the level of planning decreases and type of planning changes as the
distance from the release site increases. CSEPP planning zones are
partitioned into three territories: the innermost zone is the
immediate response zone, the middle zone is the protective action
zone, and the outermost zone is the precautionary zone. (See fig.
II.1.)
Figure II.1: Three-Zone
Planning Concept for CSEPP
(See figure in printed
edition.)
Source: Emergency Response
Concept Plan for Anniston Army
Depot and Vicinity , Oak Ridge
National Laboratory, Oct.
1989.
(See figure in printed
edition.)
CALHOUN COUNTY HAS IDENTIFIED 12
MAJOR DEFICIENCIES IN ITS PROGRAM
========================================================= Appendix III
NO DEMOGRAPHICS SURVEY
------------------------------------------------------- Appendix III:1
The demographics survey is 1 of 12 planning studies that the Army and
FEMA provided the Alabama Emergency Management Agency (EMA) $1.5
million in fiscal years 1992, 1993, and 1994 to implement. A
demographics survey would identify the size, density, and
characteristics of the population in the state's immediate response
zone. Demographics data are critical to other CSEPP projects because
their requirements will be based on these data. However, the survey
had not started as of May 28, 1996. According to FEMA, Alabama EMA
received adequate funding for the demographics survey in fiscal year
1992 and any delays encountered in contracting for the survey
resulted from the difficulties Alabama EMA experienced rather than
from any involvement on the part of the federal government.
Because Alabama EMA did not have the expertise to manage the
contracts for the 12 studies, including the demographics survey, the
agency pursued a person for 2 years in attempts to hire and contract
with him to serve as the contract manager for the 12 studies. The
Alabama Personnel Board denied the agency's request for a merit
position. The agency then pursued the person through a sole-source
contract. Alabama EMA officials told us that a sole-source contract
was justified because the individual previously worked as a
consultant for the agency and had extensive knowledge of the program.
State officials gave up the pursuit for a short time when the
individual could not meet the liability insurance requirements
imposed by Alabama Finance Department's Risk Management Division.
This person then went to work for Ketron Corporation, and Alabama EMA
officials tried to hire him again believing he could get the
necessary liability insurance through the corporation. However, by
September 1995, negotiations with Ketron fell through.
In October 1995, Alabama EMA requested FEMA's assistance with
contracting for the demographics survey. FEMA contacted Argonne
National Laboratory and requested its services. In December 1995,
Argonne submitted a draft contract proposal to the state EMA. The
Alabama EMA sent the proposal to its six CSEPP counties for review.
Initially, Calhoun County EMA informed the agency that it was
reluctant to participate in the contract because the proposal did not
provide for specific tasks, products, time frames, and a reasonable
means of relief if provisions are not met. In March 1996, Alabama
EMA officials said that all county EMAs concurred with the proposed
contract and they plan to move forward with negotiations. Agency
officials submitted their contract proposal for approval to the
Alabama Legislative Review Committee on May 28, 1996, and plan to
submit the proposal to the governor's office in June 1996. The
purpose of the initial contract is for Argonne to develop statements
of work for the first three planning projects: (1) the demographics
survey, (2) evacuation time estimates, and (3) a traffic management
plan. After the contract is awarded, the demographics survey should
take 6 to 9 months to complete.
In commenting on a draft of this report, the Director of Calhoun
County EMA said that his agency had not concurred with the state's
moving ahead with the total proposed contract with the Argonne
National Laboratory because the proposal still lacks specific
requirements. The Director hopes that the lack of specificity his
agency is concerned about will be laid out in subsequent contractual
efforts with Argonne.
NO EVACUATION TIME ESTIMATE
STUDY
------------------------------------------------------- Appendix III:2
This deficiency will be alleviated when the Argonne National
Laboratory completes the 12 planning studies. The evacuation time
estimate study is
1 of the 12.
NO INDOOR TONE ALERT RADIO
SYSTEM
------------------------------------------------------- Appendix III:3
Although funds were allocated in fiscal year 1993, Alabama
communities still do not have tone alert radios. Tone alert radios
are indoor alert and notification devices, that will be placed in
homes, schools, hospitals, jails, nursing homes, and businesses in
the immediate response and protective action zones. These warning
devices are to be activated by the
800-megahertz (MHz) communications system to warn people of a
chemical emergency and provide voice instructions on what to do.
Until the radios are in place, according to Calhoun EMA officials,
local citizens cannot be adequately warned of a chemical stockpile
emergency.
In fiscal year 1993, FEMA allocated Alabama EMA $4.3 million for tone
alert radios with the stipulation that funds would not be released
until the agency had completed a demographics survey to determine the
number of residences and institutions needing the radios before they
are purchased and installed. Calhoun EMA cannot purchase tone alert
radios because the demographics survey is not completed. According
to FEMA, even if the tone alert radios had been purchased when
initially funded, they would have remained unusable because Calhoun
County EMA delayed implementation of the 800-MHz communications
system needed to activate the radios. In addition, on April 12,
1996, an Alabama EMA official told us that FEMA was in the process of
revising the standards for the tone alert radios.
Table III.1 shows the breakdown of funding for the radios in fiscal
year 1993.
Table III.1
CSEPP Funding for Tone Alert Radios by
County in Fiscal Year 1993
Percen
County Amount t
------------------------------------------------------ ------ ------
Calhoun $3,772 90.5
,000\a
Talladega 390,00 9.4
0
Cleburne 3,900 0.1
Clay 3,900 0.1
======================================================================
Total $4,169 100\b
,800
----------------------------------------------------------------------
Note: Alabama EMA and Etowah and St. Clair counties have not
received funding for tone alert radios.
\a Reduced from the initial allocation of $3.9 million because
$128,000 was reallocated to the sirens project in fiscal year 1995.
\b Does not total to 100 percent due to rounding.
Calhoun EMA officials said FEMA has not allocated enough funding to
meet the county's requirement for tone alert radios. The initial
funding estimate was based on obtaining 30,000 radios. However,
county EMA officials now estimate the county will need approximately
50,000 radios.
NO PERSONAL PROTECTIVE
EQUIPMENT
------------------------------------------------------- Appendix III:4
Personal protective equipment is needed to provide protection for
emergency workers responding to a chemical emergency. According to
CSEPP guidance, personal protective equipment is required in any
situation where there is a possibility that emergency personnel will
encounter a chemical agent during the performance of their duties.
Personal protective equipment consists of portable respirator,
protective suit, gloves, boots, and hood. According to Calhoun
County EMA officials, emergency workers cannot adequately respond to
a chemical emergency until they are provided basic protection.
Because of their assigned traffic, decontamination, health, and other
critical response duties at the periphery of the chemical plume,
local emergency workers may find themselves in danger of
contamination from an unexpected shift in the plume. In July 1994,
the Argonne National Laboratory concluded there was a potential for
aerosol deposition of a chemical agent off-post. The deposition
creates the requirement for personal protective equipment. According
to Calhoun EMA, local emergency workers who might normally help
during a chemical emergency would have to evacuate if they did not
have personal protective equipment. According to the Army, the
typical public safety official should not be located in the predicted
hazard area. However, the Army and FEMA allocated Alabama $850,000
for personal protective equipment in 1995.
FEMA allocated Alabama $850,000 with the condition the agency would
not purchase the equipment until the Occupational Safety and Health
Administration completed its ongoing evaluation. Although the
Occupational Safety and Health Administration had completed its
evaluation at the end of 1995, personal protective equipment
requirements in Alabama are still uncertain. According to Calhoun
EMA officials, $780,000 is sufficient to purchase the required 1,148
sets of equipment. However, county EMA officials believe they need
additional funding for Army-provided equipment, protective components
for decontamination teams, and medical examinations for local
emergency workers. A draft document produced by the Centers for
Disease Control and Prevention suggested that emergency workers who
wear personal protective equipment complete annual medical
examinations.\1 Just recently, the Army initiated a needs assessment
study to determine requirements for Alabama and Kentucky. Alabama
EMA officials assume any additional personal protective equipment
funding will be withheld pending the outcome of the new needs
assessment.
Table III.2 breaks down FEMA's funding for personal protective
equipment in fiscal year 1995.
Table III.2
CSEPP Funding for Personal Protective
Equipment by Agency in Fiscal Year 1995
Percen
Agency Amount t
------------------------------------------------------ ------ ------
Alabama EMA $40,00 4.7
0
Calhoun County EMA 780,00 91.8
0
Talladega County EMA 30,000 3.5
======================================================================
Total $850,0 100.0
00
----------------------------------------------------------------------
According to Army and FEMA officials, Alabama and Calhoun County EMAs
have been authorized since December 1995 to purchase the baseline
equipment with the funds already authorized. They do not understand
why the agencies have not acted more aggressively in obtaining the
equipment. In commenting on a draft of this report, FEMA said that
there is nothing preventing Calhoun County EMA from purchasing the
approved equipment but the county has refused to initiate work on the
project until its demand for additional funding is approved.
According to Calhoun County EMA, the agency is ready to issue a
contract for the civilian respirators and protective suits when
requirements for medical examinations and related funding are
established and provided by FEMA.
--------------------
\1 The draft is not dated, but officials from the centers believe
that it was produced in early 1996.
LACK OF RECEPTION AND MASS CARE
LOCATIONS
------------------------------------------------------- Appendix III:5
According to Calhoun County EMA officials, local citizens do not know
where to evacuate in case of a chemical emergency. Parents are
especially concerned about their children and demand to know where
their children will be in the event county schools are evacuated.
Regardless, Alabama EMA officials believe FEMA's recent selection and
funding of Lee, Jefferson, and Madison counties as reception and host
counties essentially settled Calhoun EMA's concern.
Host counties in Alabama are required to receive, decontaminate,
medically screen, treat, and shelter an estimated 110,000 evacuees in
case of a chemical emergency. The state EMA initially suggested some
Calhoun County residents evacuate to Georgia. FEMA rejected this
request and suggested the state study the option of sending evacuees
to safe locations in the protective action zone. According to FEMA,
the decision not to expand the program into Georgia was based on
sound fiscal management. However, the counties in the protective
action zones are rural, and do not have adequate infrastructure to
process evacuees. Therefore, Alabama and Calhoun County EMA
officials recommended that Lee, Jefferson, and Madison counties,
which have the necessary infrastructure to provide mass care, serve
as reception and host counties. In March 1996, FEMA approved the
state's selection of host counties. The annual costs, mostly for
planning and preparation activities, are estimated to range from
$50,000 to $60,000 for each county.
In commenting on a draft of this report, FEMA said that reception and
mass care facilities have been identified and CSEPP officials are in
the process of working with the host counties. Because of FEMA's
recent approval of funds for host counties, according to Calhoun
County EMA, Alabama participants can start working toward meeting the
CSEPP requirement for reception and mass care facilities.
NO COLLECTIVE PROTECTION SYSTEM
------------------------------------------------------- Appendix III:6
Calhoun County EMA officials said that they first proposed the
concept of collective protection about 4 years ago, but no one from
the Army or FEMA ever discussed the idea with them. Collective
protection provides pressurized shelter with an air-filtering system
and enough food, water, and supplies to house a selected number of
people up to 3 days. On March 25, 1996, Alabama EMA transferred $4.2
million to Calhoun County for collective protection projects.
In 1989, Oak Ridge National Laboratory concluded that, in the event
of an accidental release of chemical agent, the chemical plume could
cover segments of Calhoun County's immediate response zone in 1 hour.
Oak Ridge also concluded in the 1989 report that evacuation was not
recommended for the general population in Anniston's immediate
response zone and recommended expedient sheltering. According to
another Oak Ridge National Laboratory 1991 draft report, it would
take
5 hours and 45 minutes to evacuate the residents in the greater
Anniston area. The estimate is the clearance time required for 100
percent of the vehicles to evacuate the area during bad weather at
nighttime. On the basis of the Oak Ridge studies, Calhoun County EMA
officials believe it would be impossible to safely evacuate everyone
from the chemical plume. To shelter the people they cannot evacuate,
county officials believe collective protection is the best option.
However, according to a senior official from the Oak Ridge National
Laboratory, Calhoun County officials should not rely on the 1991
draft report for planning purposes because the (1) report was never
finalized and (2) changes in road conditions and demographics since
1991 may have affected the results reported in the draft.\2
According to the Army, Calhoun EMA must be planning to evacuate the
entire immediate response zone and believe that a more prudent action
would be to evacuate only those portions of the county that would be
at risk.
Calhoun County EMA's collective protection concept involves both
building protection systems and community shelters. County EMA
officials believe building protection systems will be needed in
hospitals, schools, nursing homes, jails, and other facilities that
cannot be quickly evacuated. This system consists of a small
enclosed room that folds out within a larger room and contains an air
filtration system and adequate food, water, sanitary, and medical
supplies. Community shelters would include large facilities
containing an air filtration system and provisions. The shelters
would be located so that residents could walk to them during a
chemical emergency.
Alabama EMA officials told us more research and data are needed to
make any rational decision on Calhoun County's proposal for
collective protection. The Army Edgewood Research, Development and
Engineering Center has completed a study to validate procedures for
sheltering residents in a variety of housing types and identify a
less burdensome and costly way to protect citizens in place. The
draft report is dated December 8, 1995, and comments are being
incorporated for publication in the final report.
On September 12, 1995, FEMA allocated Alabama $4.2 million for
positive pressurization projects in Calhoun County. On March 25,
1996, Alabama EMA transferred the $4.2 million authorization to
Calhoun County. However, positive pressurization is just one portion
of Calhoun County's concept of collective protection. The county's
concept combines filtered over pressurized air and the support of
food, water, and medical supplies to house specific numbers of people
up to 3 days. As a result, Calhoun EMA officials believe the $4.2
million allocation is too little. They estimate that the county will
require about $67.6 million for collective protection--$16 million
for building protection sites and $51.6 million for the community
shelters. The Army believes that a chemical plume would pass over
the area in 3 to 12 hours and that Calhoun EMA's shelter time
estimate of 3 days is excessive.
On the basis of the type of facilities, distance from the storage
site, potential to support nearby communities and available funding,
FEMA selected 21 facilities in Calhoun County for positive
pressurization. However, according to Calhoun EMA officials, FEMA
officials never coordinated their selection of the 21 facilities with
them. Although county officials provided FEMA a suggested list of 55
facilities for collective protection, they disagree with 5 of the 21
facilities selected. They believe other facilities in the county
have a greater need for collective protection. As a result, county
officials would prefer protecting 5 facilities selected at a later
date and replace them with 5 facilities considered higher priorities.
According to FEMA, the agency has not received a formal rebuttal or
request from Calhoun County to change this authorization. According
to Army and FEMA officials, funds will be allocated in the future to
pressurize additional facilities in the county.
--------------------
\2 FEMA never asked Oak Ridge to finalize the draft report.
NO INTEGRATED COMMUNICATIONS
SYSTEM
------------------------------------------------------- Appendix III:7
After several years of studying and meeting, Alabama still does not
have an integrated communications system. On the basis of
CSEPP-funded research completed in 1990 and 1991, Calhoun EMA
officials decided that the existing conventional communications
system did not meet CSEPP integrated requirements. In 1992, Army and
FEMA officials agreed that every CSEPP jurisdiction should have a
functioning communications system connecting the Army installation,
state EMA, and counties in the immediate response zone. In May 1993,
FEMA approved the 800-MHz communications system for CSEPP in Alabama.
The 800-MHz communications system is an integrated, simulcast network
with 20 channels that operate at a frequency of 800-MHz. The CSEPP
system will provide Alabama and Calhoun and Talladega counties with a
critical capability of communicating inter- and intra-agency without
having to wait for a channel to clear if someone is using it. The
system can also be used as the platform to simultaneously activate
sirens and tone alert radios.
Initially, federal officials anticipated local EMAs would jointly
acquire and maintain the 800-MHz system. According to Alabama EMA
officials, they wanted to handle the contract but FEMA officials
allowed Calhoun County to manage the contract. However, according to
Calhoun EMA officials, Alabama EMA could not put together the
contract so FEMA officials asked the county to manage the contract.
Following are instances that show the history of the growth in costs
for the CSEPP 800-MHz communications system in Alabama:
-- FEMA provided Alabama $8.8 million for the baseline system and
$4.4 million to expand the system and purchase additional radios
in fiscal years 1994 and 1995, respectively. According to the
authorization letter, the funds were considered "not to exceed"
limits for the project. The letter also declared that the
precise number of radios, their distribution, and follow-on
radios would be determined by negotiations between FEMA, state,
and county officials.
-- In June 1995, FEMA authorized an additional $1,034,426 for the
placement of a second communications tower in Talladega County.
The letter also said that any negotiated reductions in the
system's cost would be applied to additional field equipment at
the discretion of FEMA, state, Calhoun, and Talladega officials.
-- In August 1995, FEMA provided an additional $2 million for more
equipment and radios bringing the total amount available for the
800-MHz system to $16.2 million.
Calhoun EMA officials announced during a meeting in October 1995 that
with the additional $2 million they could obtain the required
communication equipment plus 1,187 extra radios and Calhoun EMA
intended to keep all the extra radios. According to other program
officials, they attempted to negotiate with Calhoun EMA officials
regarding the additional radios, but Calhoun officials would not
negotiate. According to Calhoun EMA officials, they tried to discuss
the distribution of the additional radios, but Talladega County
officials left the meeting. In a memorandum describing the meeting,
an Alabama EMA official said it was a mistake for Calhoun County to
manage the contract. The official concluded Calhoun EMA officials
were unable or unwilling to look after the interests of other
stakeholders in Alabama. In commenting on a draft of this report,
the Calhoun County EMA Director disagreed with the state EMA
official's assessment that his agency was unable or unwilling to
consider the interests of others in the program. He said that all
Alabama CSEPP entities either have or will directly benefit from the
county's actions related to CSEPP.
According to Alabama and Calhoun County officials, the number and
distribution of radios were tentatively negotiated in December 1995.
However, FEMA, state, and county officials continued to disagree
about the number of radios needed by first responders until April 23,
1996. In addition, FEMA officials decided to place a $1-million
communications tower and some radios for Talladega County in its
precautionary zone. Some equipment would be nearly 50 miles from
Anniston Army Depot. Calhoun and St. Clair county officials believe
placing the equipment in the precautionary zone does not comply with
program guidance. As a result, Calhoun EMA officials were reluctant
to award the contract. On March 15, 1996, the Calhoun County
Commission Chairman sent a letter to the Program Manager for Chemical
Demilitarization expressing his concerns about the 800-MHz system and
recommended that the Army reevaluate FEMA's distribution of radios.
On April 23, 1996, federal, state, and county officials met to
resolve the issues that were delaying the implementation of the
800-MHz project in Alabama. At the meeting, federal officials agreed
to provide additional 800-MHz radios to Alabama and Calhoun and
Talladega counties. In return, Calhoun County EMA awarded the
800-MHz contract on May 30, 1996. According to the Calhoun EMA, the
contractor has 16 months from the contact award date to manufacture
and install the communications system.
According to the Army, Calhoun EMA's claim that the county does not
have a sufficient communications system to adequately respond to a
chemical stockpile emergency implies that the county is not prepared
to respond to other hazards--earthquakes, tornadoes, hazardous
material incidents, etc. The Army concluded that, until CSEPP
provided funding for the county's communications system, Calhoun EMA
was unable to provide basic emergency protection to its citizens.
According to the Army, Calhoun County has not provided any funding to
upgrade its local communications system. According to FEMA, the
CSEPP 800-MHz communications system is not in place because Calhoun
EMA refused to initiate work on the contract until the county's
demand for additional radios was met. According to the Calhoun
County EMA Director, his agency only supports projects that provide
goods, services, and equipment complying with CSEPP guidance.
LACK OF 24-HOUR STAFFING OF
EMERGENCY OPERATIONS CENTER
------------------------------------------------------- Appendix III:8
Federal, state, and Calhoun County officials differ on the need for
24-hour staffing of the county emergency operations center. The
center serves as the location where responsible officials gather
during a chemical emergency to direct and coordinate operations,
communicate with officials from other jurisdictions in the field, and
formulate protective action decisions. The Army policy is to
implement 24-hour staffing of the depot's emergency operations center
when disposal operations begin and not to fund 24-hour staffing of
local centers. Alabama EMA officials believe the Army should staff
the depot's emergency operations center during both storage and
disposal operations. State officials told us the current lack of
24-hour staffing at the depot's center results in less than adequate
immediate response capability during nonworking hours and places
local citizens at unnecessary risk. CSEPP guidance requires Anniston
Army Depot 5 minutes from the initial detection of an actual or
likely chemical agent release to notify local points of contact of
the release, its emergency notification level, and recommended
protective actions.
Calhoun EMA officials believe they should staff their center 24 hours
a day. Currently, Calhoun County emergency operations center is
staffed only during normal working hours, 24 percent of the time.
County EMA officials believe this would present a problem if there
were a chemical emergency during the other 76 percent of the time
when the center is empty. Calhoun EMA officials believe this is
unacceptable when it takes a minimum of
30 minutes for agency employees to reach the center and begin
activating the alert and notification process. According to CSEPP
guidance, the time that elapses from the chemical accident to the
decision to warn the public of the danger is of paramount importance
to the success of the public alert and notification system. The
guidance also requires the outdoor alert and notification system be
capable of providing an alerting signal and instructional message
within 8 minutes from the time a decision is made that the public is
in danger. County EMA officials plan for a response time of 8
minutes--5 minutes to make a protective action decision and
3 minutes to alert and notify the public. According to county
officials, if an emergency occurs while the center is empty, the lack
of any capability to quickly activate the alert and notification
system places local citizens at risk.
Calhoun EMA officials have proposed three ways to resolve the 24-hour
staffing issue with CSEPP funds:
-- Provide Calhoun EMA additional people to staff its emergency
operations center 24 hours a day. According to the Director of
Calhoun County EMA, the current staff's job descriptions do not
provide for shift rotations to allow them to operate the center
full time.
-- Consolidate the county's 911 emergency center and CSEPP
operations center. Currently, the 911 center is located in
another facility in the immediate response zone, an area that
would be evacuated during a chemical emergency.
-- Require the Army to administer the immediate response operations
and initiate the alert and notification system.
Army and FEMA officials state that there is no need for Calhoun
County to have a 24-hour emergency operations center on the basis of
Anniston's risk assessment. The risk assessment concludes that the
greatest risk of a chemical accident is during normal handling and
maintenance activities. The Army plans to staff Anniston's emergency
operations center 24 hours a day when disposal operations begin.
Until then, Anniston has a duty officer in charge 24 hours a day. In
the unlikely event a chemical emergency was to occur, Army officials
would contact Calhoun County's 24-hour 911 emergency center, which
would notify the local emergency response agencies.
In commenting on a draft of this report, the Army said that Calhoun
County EMA should consider less costly and equally effective
alternatives to 24-hour staffing of the county's CSEPP operations
center, such as using the county's 911 emergency center to initiate
the alert and notification process. In addition, FEMA believes that
the cost of 24-hour staffing of the CSEPP emergency operations center
out weighs the benefits in light of available alternatives, ranging
from using the county's current 911 emergency system to using the
off-post warning system. FEMA officials also recommend that the 911
center stay in the immediate response zone and that its building be
overpressurized to allow the center to operate during a chemical
emergency and be responsible for the initial alert and notification
actions. According to FEMA, Calhoun County refuses to consider
reasonable alternatives adopted by other counties participating in
CSEPP. However, Calhoun County EMA questions the feasibility of the
Army's and FEMA's concept, without additional analysis, of using the
county's 911 emergency center to initiate a CSEPP response.
LACK OF FUNDING FOR LOCAL
PUBLIC INFORMATION AWARENESS
------------------------------------------------------- Appendix III:9
Alabama and Calhoun County EMA officials believe FEMA does not
provide adequate support and money for local public awareness
programs. Calhoun officials cite the county's $9,000 allocation in
fiscal year 1995 for public awareness activities as one of the
reasons for their concern. In addition, they note that the county
has over 60 public schools, a university, 3 hospitals, 5 nursing
homes, and approximately 120,000 people. Alabama EMA officials said
that they agreed with the county on this issue.
Army and FEMA officials said that Calhoun EMA officials did not
consider funds allocated to pay for salary of the county's public
information officer in their $9,000 figure. Federal officials also
recognize that 1995 was a lean year for CSEPP. In contrast to the
funding for fiscal year 1995, Calhoun County received over $150,000
for its public awareness program, but less than requested, in fiscal
years 1994 and 1996. (See table III.3.)
Table III.3
CSEPP Funding for Calhoun County's
Public Awareness Program in Fiscal Years
1994 Through 1996
Public
Reques Calend awaren
Fiscal year ted ar ess Salary Total
------------------ ------ ------ ------ ------ ==================
1994 $310,0 $93,75 $40,79 $18,29 $152,850
00 5\a 6 9
1995 63,000 102,00 9,000 19,495 130,495
0\a
1996 483,91 102,00 45,000 23,523 170,523
0 0
======================================================================
Total $856,9 $297,7 $94,79 $61,31 $453,868
10 55 6 7
----------------------------------------------------------------------
\a Alabama EMA funds allocated for CSEPP calendars that were never
produced by the state EMA. The funds were requested by and
transferred to Calhoun County EMA.
In commenting on a draft of this report, FEMA said that Calhoun
County's requests for funds do not professionally support the public
affairs mission of informing the public of how to respond in the case
of a chemical stockpile emergency. For example, FEMA reported that
some of the county's requests were intended to fund frisbees, key
chains, baseball caps, T-shirts, and pencils. According to Calhoun
County EMA, these public awareness items comply with CSEPP guidance,
which provides that each CSEPP jurisdiction consider (1) using a
variety of methods to communicate with the public and (2) developing
promotional items for distribution at community fairs, shopping
malls, and public meetings.
LACK OF A COMPLETE SIREN SYSTEM
------------------------------------------------------ Appendix III:10
According to Calhoun EMA officials, additional sirens are needed to
adequately warn the public in case of a chemical emergency at
Anniston Army Depot. Currently, the county has 43 sirens. According
to Alabama EMA officials, they have supported the county's position
on this issue for several years, pending the on-site assessment of
the current siren system.
Calhoun EMA officials believe they need at least 19 additional sirens
to adequately warn the public of a chemical emergency. The immediate
response zone has dead spots, where the population cannot hear the
sirens, and the protective action zone has special population areas
that are not covered by the current system. County officials said
they saved $102,947 from their negotiations for the initial siren
contract to pay for some of the additional sirens. However, FEMA is
withholding the funds pending a site survey and a new site assessment
and sound propagation study. Calhoun County EMA supports the
requirement for the site assessment and sound propagation study, but
questions why the assessment and study are required only for Calhoun
EMA and not for other CSEPP entities.
FEMA reallocated Calhoun County $128,000 for a new sound propagation
study and additional sirens in fiscal year 1995.\3 In addition, FEMA
reported that it would authorize the expenditure of existing funds to
purchase additional sirens if the study validates the requirement.
According to Alabama EMA, FEMA has been slow in taking action to
resolve Calhoun County's concern that the current siren system is
inadequate to warn the public of a chemical stockpile emergency.
--------------------
\3 Funds were reallocated from the tone alert radios project.
LACK OF A COMPLETE, AUTOMATED
INFORMATION SYSTEM
------------------------------------------------------ Appendix III:11
According to Calhoun EMA officials, the agency's ability to respond
and recover from a chemical emergency depends on its automated
information system. County officials identified several items they
believe are required to sustain or enhance their automated
capabilities. They include remote automated workstations for county
officials, additional projectors, a back-up server, and optical
jukebox. In fiscal years 1995 and 1996, Calhoun EMA requested more
than $1 million for automated data processing equipment. The Army
and FEMA approved $79,700 for automation equipment in fiscal year
1995 and $201,000 in fiscal year 1996. According to Calhoun EMA
officials, inadequate automation capabilities are still an unresolved
issue for the county.
According to FEMA, the necessary equipment for the Federal Emergency
Management Information System has been authorized for purchase for
Alabama. FEMA said that Calhoun County EMA was insisting on
equipment that exceeds the automation requirements for the county.
REQUIREMENT FOR LOCAL
WORKSTATIONS
---------------------------------------------------- Appendix III:11.1
Calhoun EMA officials said they need 19 remote automated workstations
for local officials from the County Commission, the County Health
Department, the American Red Cross, mayors' offices, hospitals, and
several other groups. The workstations are estimated to cost about
$8,000 each. According to county EMA officials, these workstations
would allow local officials to train and participate in daily CSEPP
operations and operate from their offices during a chemical emergency
if they could not travel to the county's emergency operations center.
According to state EMA officials, they believe procurement and
maintenance costs are too high for the county's workstation concept,
especially when too many other higher priority projects are not fully
funded.
In fiscal year 1995, Army and FEMA officials rejected the workstation
concept stating it provides for unnecessary automation countywide.
In fiscal year 1996, Calhoun EMA reported that remote stations are
required to ensure that daily operations are carried out and to
increase the county's preparedness, response, and recovery
capabilities. Army and FEMA officials again rejected the funding,
stating that the other local agencies could provide data to Calhoun
EMA's data entry clerk for input to the county's information system.
According to Calhoun EMA officials, this would be difficult because
the agency's one data entry clerk is already overworked.
REQUIREMENT FOR ADDITIONAL
PROJECTORS
---------------------------------------------------- Appendix III:11.2
FEMA funded six screens for Calhoun County's operations center, but
only three projectors. According to Calhoun EMA officials, three
projectors are not enough during a chemical emergency. In addition,
county officials said the current projectors need to be replaced
because of the inadequate funding allocated for repair and
maintenance. The projectors are operated daily and have more than
4,000 hours of use, compared with the recommended maximum of 1,700
hours.
In fiscal year 1995, FEMA and Alabama EMA officials said Calhoun
County's request for three additional projectors was not adequately
justified. FEMA officials concluded that the county already has the
required number of projectors. In fiscal year 1996, state officials
changed their position and agreed with the county's request for three
new projectors if the county traded in the used ones. However, FEMA
still rejected Calhoun's request for funds. FEMA officials
recommended that the existing projectors be used in moderation (not
daily) and adequately maintained. In addition, FEMA officials said
funding the county's six screens was an oversight on their part and
only three screens were necessary. In response, Calhoun EMA
officials said their county has the greatest response requirement of
any other county and therefore, requires a greater number of spatial
displays.
REQUIREMENTS FOR BACKUP
SERVER AND OPTICAL JUKEBOX
---------------------------------------------------- Appendix III:11.3
According to Calhoun County EMA officials, a backup server is
required in case the primary server crashes. Calhoun EMA documents
indicate that the primary server has crashed or locked up several
times and that on one occasion, the server was down for about a
month. In fiscal years 1995 and 1996, the state EMA concurred with
the county's requests for a backup server on the basis of program
guidance. FEMA officials rejected the requests stating that Alabama
EMA, Anniston Army Depot, or Talladega County would have servers
attached to their areawide network, which could serve as backups.
However, according to Calhoun EMA officials, if the county server
goes down, they cannot hook up to other servers at the state EMA,
Anniston, or Talladega County. In addition, Calhoun County officials
said the other servers cannot perform as Calhoun's backup because the
other automated systems do not have the county's requirements or
databases.
Calhoun EMA officials told us that other required automated data
processing items are also unfunded or partially funded. For example,
the county EMA requested $63,000 for an optical jukebox to provide
on-line mass data backup and storage. However, FEMA and state EMA
officials rejected the quoted price stating that the county could use
less expensive storage equipment. As a result, FEMA allocated
Calhoun County $24,000 for the optical jukebox on December 13, 1995.
However, according to county officials, their initial request was
based on a vendor's quoted price for the item and federal officials
did not seem to understand that the county could not purchase the
item with less money.
LACK OF COMPLETE PLANNING
GUIDANCE
------------------------------------------------------ Appendix III:12
Although Army and FEMA officials originally planned to complete all
CSEPP planning guidance and standards by September 1989, planning
guidance for emergency medical services, reentry, and restoration
procedures remains uncompleted. As a result, local communities lack
formal guidance to help them prepare their plans and determine their
requirements for these emergency response issues. According to FEMA
officials, the guidance is scheduled to be issued mid-1996.
On June 27, 1995, the Centers for Disease Control and Prevention
published in the Federal Register its recommendations for medical
preparedness guidelines for communities near the chemical stockpile
storage sites. The Army reported that the recommendations were
available to all locations for use. According to FEMA, the guidance
has been distributed in draft form pending resolution of outstanding
issues. The agency concluded that the outstanding issues should not
preclude the states and counties from using the drafts for daily
planning. However, Calhoun County EMA and other CSEPP participants
do not consider FEMA's drafts as final planning guidance.
(See figure in printed edition.)Appendix IV
COMMENTS FROM THE DEPARTMENT OF
DEFENSE
========================================================= Appendix III
(See figure in printed edition.)
The following are GAO's comments on the letter from the Office of the
Assistant to the Secretary of Defense for Atomic Energy. The letter
was received on May 28, 1996.
GAO COMMENTS
------------------------------------------------------ Appendix III:13
1. It was not our intent in our draft report to leave the impression
that the delay in Alabama's CSEPP was solely the result of management
weaknesses at the federal level. We have revised the final report to
eliminate the reference to primarily and to more clearly attribute
the lack of progress to federal management weaknesses and actions by
state and local agencies. It is important to note that the problems
experienced in Alabama's CSEPP are likely to continue until an
effective approach is developed for reaching timely agreements among
federal, state, and local officials on specific requirements for
projects.
2. In the draft of this report, we stated that the Army had taken
some encouraging steps to improve the management and oversight of the
Chemical Stockpile Disposal Program. For example, the Army
restructured the overall management of CSEPP and established a
centralized office to streamline procedures, improve responsiveness
to the states and counties, and improved the budget process.
However, we found little evidence that these steps had any
significant effect on the federal management of CSEPP in Alabama.
For example, during this review, we found that records on expenditure
data are limited; allocation data differ among FEMA, Alabama EMA, and
county EMAs; and FEMA maintains large unexpended balances of funds
for Alabama and Calhoun County.
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COMMENTS FROM THE FEDERAL
EMERGENCY MANAGEMENT AGENCY
========================================================= Appendix III
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The following are GAO's comments on the letter from the Associate
Director for Preparedness, Training and Exercises, FEMA. The letter
is dated May 29, 1996.
GAO COMMENTS
------------------------------------------------------ Appendix III:14
1. It was not our intent to leave the impression that the delay in
Alabama's CSEPP was solely the result of management weaknesses at the
federal level. We have revised the final report to delete references
to primarily and more clearly state that federal management
weaknesses and state and local actions have contributed to the delay.
However, until the Army and FEMA take steps to delineate their roles
and responsibilities, complete and clarify CSEPP's planning guidance,
reduce their involvement in state and local management of projects,
and implement effective financial controls, federal, state, and local
officials will continue to disagree on specific CSEPP requirements
and time-consuming negotiations on projects in Alabama are likely to
continue.
2. See comment 1.
3. We revised the report to show that some of FEMA's expenditures
support the entire CSEPP community, including the development of
program guidance, training courses, and computer software. However,
almost
45 percent of all CSEPP funds have been for federal management,
contracts, and military installations such as the Anniston Army
Depot. Specifically, $190.4 million (54.3 percent) was allocated to
the state and counties, $157.3 million (44.9 percent) was allocated
to the Army and FEMA, $1.1 million (0.3 percent) was allocated to
other entities, and $1.8 million (0.5 percent) is unallocated.
In our 1995 report on CSEPP's financial management weaknesses, we
said that allocated funds at four of the eight storage sites were
generally used for priority items and other critical CSEPP projects.
However, because of weaknesses in FEMA's financial management and
reporting, we were unable to provide a complete picture of how
program funds were spent at the other four storage sites and that the
program was susceptible to fraud, waste, and abuse. In addition, we
did not report that CSEPP funds were effectively allocated. On the
contrary, we reported that critical items needed by local communities
to adequately respond to a chemical stockpile emergency were not
operational or had not been purchased.
4. We revised the final report to more clearly state that some of
Alabama EMA's and Calhoun County EMA's actions have contributed to
the lack of progress in Alabama's CSEPP. However, we do not agree
with FEMA's position that the unexpended funds are mostly the result
of Calhoun County EMA's refusal to initiate CSEPP projects until the
Army and FEMA agree to all of the county's demands. The delays
experienced in Alabama's CSEPP are likely to continue until an
effective approach is developed for reaching timely agreements among
federal, state, and local officials on specific requirements for
projects.
5. We revised our report to reflect FEMA's position that the 800-MHz
communications system is not in place because Calhoun County EMA
refused to initiate work on the contract until the county's demand
for additional radios was met. However, we disagree with FEMA's
statement that the overall scope of the 800-MHz communications
project was resolved in 1993. Since 1993, the Army and FEMA
allocated $1 million and $2 million for additional equipment and
radios in June 1995 and August 1995, respectively. As recently as
April 23, 1996, FEMA authorized additional radios for Alabama and
Talladega and Calhoun counties. It appears that all the
disagreements about the project may have been resolved on April 23,
1996, when Army and FEMA officials agreed to provide additional
800-MHz radios to Alabama and Talladega and Calhoun counties.
Calhoun County EMA officials awarded the 800-MHz contract on May 30,
1996. According to Calhoun EMA officials, the contractor has 16
months from the contact award date to manufacture and install the
communications system.
The 800-MHz project is an example in which Calhoun County EMA delayed
implementation of the project until it received enough radios, in its
opinion, to help ensure maximum protection for the citizens of the
county. In addition, Alabama and Talladega County benefited from
Calhoun EMA's efforts in that they also received additional radios.
In summary, we question FEMA's conclusion that Calhoun County EMA
wrongfully delayed the 800-MHz project because the county insisted on
a system that exceeded CSEPP requirements; after 3 years of
negotiations, FEMA itself agreed to fund the county's request.
Similar problems experienced with the 800-MHz project are likely to
continue in Alabama until an effective approach is developed for
reaching timely agreements among federal, state, and local officials
on specific requirements for projects.
6. We revised the final report to include that, according to FEMA,
the agency has not received a formal rebuttal or request from Calhoun
County to change the authorization for the collective protection
project. We also added to the report that Army officials believe
Calhoun EMA's shelter time estimate of 3 days is excessive and that a
chemical plume would pass over the area in 3 to 12 hours. However,
our concern with this project was that FEMA officials did not discuss
their selection of facilities to be protected with local officials
and selected five that they would prefer to be protected at a later
date. In addition, according to Calhoun EMA, FEMA did not (1)
provide enough funding for the supplies requested by the county and
(2) discuss FEMA methodology to estimate the average cost of $200,000
to protect each facility. Finally, as a result of CSEPP's fragmented
management structure, there was a 6-month lapse between FEMA
headquarters' authorization and Calhoun County's receipt of it.
7. We revised our report to include FEMA's position that there is
nothing preventing Calhoun County EMA from purchasing the approved
personal protective equipment but that the county has refused to
initiate work on the project until its demand for additional funding
is approved. As discussed previously, Calhoun County EMA is ready to
issue a contract for the civilian respirators and protective suits
when the requirements for medical examinations are defined and
related funds are provided by FEMA. Although FEMA allocated funds
for personal protective equipment in fiscal year 1995, federal and
local officials are still negotiating specific requirements. The
problems experienced in Alabama's CSEPP are likely to continue until
an effective approach is developed for reaching timely agreements on
specific requirements among federal, state, and local officials.
8. We revised our report to include the protocol for
intergovernmental communications as described by FEMA. However, FEMA
does not recognize the role and responsibilities of the CSEPP Core
Team in its protocol. According to the Core Team's charter, dated
January 6, 1995, the team is the focal point for accountability of
the program and coordinates and integrates on- and off-post
activities. The Core Team was established, in part, to streamline
procedures, improve responsiveness to state and local agencies, and
enhance the overall budget process. Because of differences similar
to these, we continue to believe that the role and responsibilities
of the CSEPP Core Team are not clearly understood by state and county
officials.
In addition, we disagree with FEMA's statement that CSEPP has had a
long-established protocol for communications. Army and FEMA
officials routinely communicate with local officials without
complying with the protocol described by FEMA. During this review,
FEMA officials conducted on-site inspections of the CSEPP siren
system in Alabama and routinely contacted county officials outside of
FEMA's stated protocol.
9. According to FEMA, to the extent that CSEPP guidance is unclear,
such flexibility is necessary to meet the diverse functional,
technical, and geographical needs of CSEPP and the ill-defined
maximum protection mandate of the Chemical Stockpile Disposal
Program. We believe that without clear and complete program
guidance, disagreements and time-consuming negotiations on projects
in Alabama are likely to continue. In May 1996, we reported similar
concerns about FEMA's ambiguous criteria for its disaster assistance
program.\1
We revised the report to show that CSEPP guidance has been
distributed in draft to state and county agencies pending resolution
of outstanding issues. FEMA officials believe that the outstanding
issues should not preclude the states and counties from using the
drafts for daily planning. However, Calhoun County EMA officials do
not consider FEMA drafts as final planning guidance. In addition,
Alabama EMA officials said the program still needs to resolve
numerous problems with reentry and restoration issues and that the
continuous changes and redirection of the program have diverted
resources away from protecting the public and the environment. Clay
County EMA officials in Alabama told us that there is a general lack
of clear guidance for CSEPP. In addition, Etowah County EMA
officials said that CSEPP standards and guidance were changed
whenever Army and FEMA officials wanted to change them, without
regard to the needs of local governments.
CSEPP has had a working definition of maximum protection since 1991.
CSEPP Policy Paper Number 1, entitled Definition of Maximum
Protection, states that the most important objective of the emergency
preparedness and implementation process is the avoidance of
fatalities to the maximum extent possible should an accidental
release of chemical agent occur. The policy paper states that this
objective can be achieved through (1) the establishment of
comprehensive emergency planning and preparedness programs and (2)
preventive measures designed to render the chemical stockpile less
susceptible to both internally and externally generated accidents.
The Assistant Associate Director in FEMA's Office of Technological
Hazards signed the policy paper on May 6, 1991.
10. We believe that the inability to reach agreement on specific
projects is due, in part, to federal officials' being too involved in
the management of local projects. Once the Army and FEMA approve and
allocate funds for a CSEPP project, state and local agencies are in
the best position to implement and manage the project and federal
involvement in the project should be minimal.
According to Alabama EMA officials, they have discussed the problem
related to Army's and FEMA's micromanagement of CSEPP with FEMA
officials. These officials said that the current CSEPP process does
not allow state directors flexibility in managing their emergency
preparedness programs. The issue of FEMA's involvement in the
management of local projects was also raised by the Director of
Calhoun County EMA on July 13, 1995, before the Procurement
Subcommittee, House Committee on National Security. The Director
testified that CSEPP projects were hampered by micromanagement at the
federal level.
11. We believe that the inability to reach timely agreements on
project and funding requirements indicates that the CSEPP budget
process is not working effectively. As discussed in the report,
state and county officials told us that the CSEPP process lacks
teamwork. For example, Etowah County EMA officials in Alabama told
us that the agency did not have an influence on the CSEPP budget
process and that the agency very seldom receives a response from the
Army or FEMA on substantive issues. Similarly, according to St.
Clair County EMA officials, the county has no influence in the CSEPP
budget process.
12. We revised the final report to recognize that some progress in
CSEPP has occurred in Alabama. However, communities near Anniston
Army Depot are not fully prepared to respond to a chemical stockpile
emergency, and Alabama and six counties have not been able to spend
$30.5 million,
66.4 percent of the $46 million allocated to enhance their emergency
preparedness. Alabama and its counties have not been able to spend
most of the CSEPP funds allocated to them because (1) FEMA, state,
and local officials cannot agree on specific requirements for major
capital projects and (2) FEMA has not provided Alabama or Calhoun
County officials permission to spend some of the funds.
13. As discussed above, we have revised the report to more clearly
state that Calhoun County EMA's actions have contributed to the delay
of Alabama's CSEPP. However, we do not agree with FEMA's position
that the unexpended funds are mostly the result of Calhoun County
EMA's refusal to initiate CSEPP projects until the Army and FEMA
agree to all of the county's demands. Disagreements and
time-consuming negotiations on CSEPP projects in Alabama are likely
to continue until an effective approach is developed for reaching
timely agreements on specific requirements.
--------------------
\1 Disaster Assistance: Improvements Needed in Determining
Eligibility for Public Assistance (GAO/RCED-96-113, May 23, 1996).
MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix VI
NATIONAL SECURITY AND
INTERNATIONAL AFFAIRS DIVISION,
WASHINGTON, D.C.
Thomas J. Howard, Assistant Director
Mark A. Little, Evaluator-in-Charge
Bonita J. Page, Evaluator
ATLANTA FIELD OFFICE
Lee A. Edwards, Assistant Director
Terry D. Wyatt, Evaluator
Fredrick W. Felder, Evaluator
*** End of document. ***