Environmental Protection: Status of Defense Initiatives for Cleanup,
Compliance, and Technology (Letter Report, 08/02/96, GAO/NSIAD-96-155).
Pursuant to a congressional request, GAO provided information on the
Department of Defense's (DOD) environmental cleanup efforts.
GAO found that DOD: (1) is reducing funding for environmental studies
and oversight and increasing funding for environmental cleanup
activities; (2) is prioritizing cleanup sites across geographic and
organizational boundaries; (3) is devolving management of its
environmental restoration account and setting up individual accounts for
various military departments; (4) lacks the data it needs to manage its
environmental compliance program; (5) will need at least $216 million to
fund its environmental technology initiatives for fiscal year 1996; and
(6) is implementing an on-line strategic investment plan that matches
various technology projects against specific service requirements.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: NSIAD-96-155
TITLE: Environmental Protection: Status of Defense Initiatives for
Cleanup, Compliance, and Technology
DATE: 08/02/96
SUBJECT: Prioritizing
Environmental monitoring
Environmental law
Waste disposal
Strategic information systems planning
Defense cost control
Environmental research
Hazardous substances
Pollution control
Data integrity
IDENTIFIER: National Oil and Hazardous Substances Pollution Contingency
Plan
DOD Environmental Compliance Program
DOD Environmental Security Technology Certification Program
DOD Environmental Restoration Account
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Cover
================================================================ COVER
Report to Congressional Requesters
August 1996
ENVIRONMENTAL PROTECTION - STATUS
OF DEFENSE INITIATIVES FOR
CLEANUP, COMPLIANCE, AND
TECHNOLOGY
GAO/NSIAD-96-155
Environmental Protection
(709181)
Abbreviations
=============================================================== ABBREV
BRAC - Base Realignment and Closure
CERCLA - Comprehensive Environmental Response, Compensation, and
Liability Act
DBOF - Defense Business Operations Fund
DERA - Defense Environmental Restoration Account
DLA - Defense Logistics Agency
DOD - Department of Defense
EPA - Environmental Protection Agency
MILCON - Military Construction
O&M - Operations & Maintenance
OSD - Office of the Secretary of Defense
RDT&E - Research, Development, Test, and Evaluation
Letter
=============================================================== LETTER
B-271818
August 2, 1996
The Honorable John McCain
Chairman
The Honorable John Glenn
Ranking Minority Member
Subcommittee on Readiness
Committee on Armed Services
United States Senate
This report responds to your letters of January 1996, which requested
specific data regarding Department of Defense (DOD) environmental
cleanup, compliance, and technology development activities. As
requested by your offices, this letter provides information and
analyses on related DOD initiatives, and appendix I presents
additional detail regarding these areas and overseas cleanup.
BACKGROUND
------------------------------------------------------------ Letter :1
DOD is responsible for managing and caring for thousands of military
installations and defense sites throughout the United States and
overseas. Its operations are subject to the same environmental,
safety, and health laws and regulations as private industry, as well
as additional requirements for federal facilities. The day-to-day
operations and activities of a typical military installation
generally mirror those of a small city. As a result, DOD
installations face most of the same environmental problems
confronting our nation's industrial and commercial sectors.
To achieve its environmental mission, DOD organized its $5 billion
environmental program into five elements: cleanup, compliance,
conservation, pollution prevention, and technology.\1 This report
addresses three of these elements:
-- cleanup (remediation), which includes identification,
investigation, and cleanup of contamination from hazardous
substances and waste on active and formerly used DOD land
(cleanup has been funded primarily through centralized accounts
for defense environmental restoration and for BRAC);
-- compliance with environmental laws and regulations of federal,
state, and local jurisdictions; and
-- technology, under which DOD invests in research, development,
demonstration, and validation of new technologies to support the
other elements of its program.
--------------------
\1 Also contained is funding for Base Realignment and Closure (BRAC)
efforts involving environmental restoration, compliance, and planning
at closing installations.
RESULTS IN BRIEF
------------------------------------------------------------ Letter :2
Recent DOD initiatives affecting environmental cleanup include
efforts to focus funding on actual cleanup versus study and
oversight, better target the funds through the use of risk
determination in priority setting, and devolve the budget process to
the military services. DOD has reported a reduction in the amount of
funds obligated for study and oversight of cleanup activities and an
increase in funds for actual cleanup activities. It has also begun
to use relative risk determinations--that is, whether a site is
categorized as high, medium, or low relative risk--in its cleanup
planning process. DOD plans to devolve management of cleanup funding
from a centralized environmental restoration account controlled by
the Office of the Secretary of Defense to four processes and proposed
accounts: three for the individual military departments and one for
DOD-wide functions. Funding for the single account for fiscal year
1996 is currently estimated at $1.4 billion.
Regarding compliance initiatives, your Committee expressed concern
that DOD's report to Congress on environmental compliance activities
does not provide data adequate to distinguish among categories and
track the basis for DOD's budget request. Also, we testified\2 that
DOD lacks the data it needs to manage its environmental compliance
program. Although DOD has required the services to use an
Environmental Protection Agency (EPA) system that classifies projects
by type of activity, it was unable to provide data on spending by EPA
classification. DOD approved plans, dated March 14, 1996, to improve
its information for fiscal year 1998. We expressed concerns about
the impact of definitions in those plans on priority setting, and DOD
officials stated that they will act on these concerns. Detailed
budget instructions for fiscal year 1998 are expected to be approved
in the summer of 1996. DOD's current estimate for fiscal year 1996
compliance funding is $2.2 billion.
With regard to environmental technology, your Committee expressed
concern about DOD's strategy to identify and meet environmental
technology needs and requested that DOD recommend ways to restructure
environmental technology activities. DOD did not submit a separate
recommendation. In commenting on our draft report, DOD officials
stated that a written response is not required and restructuring
efforts are reflected in the fiscal year 1997 budget submission.
Also, by late summer 1996, DOD plans to implement an on-line
strategic environmental technology plan that will show specific
service requirements and match ongoing and planned initiatives.
DOD's current estimate for fiscal year 1996 funding in environmental
technology is $216 million.
--------------------
\2 Environmental Protection: Issues Facing the Energy and Defense
Environmental Management Programs (GAO/T-RCED/NSIAD-96-127, Mar. 21,
1996).
RECENT CLEANUP INITIATIVES
------------------------------------------------------------ Letter :3
Your offices asked for an overview of DOD's effort to (1) increase
the proportion of funds devoted to actual cleanup activities versus
study and oversight and (2) incorporate assessments of relative risk
in planning and budgeting for environmental restoration activities.
DOD has also proposed to devolve management of the DOD-wide
environmental restoration account to four separate accounts for the
military departments and defense agencies.
Study and oversight obligations have significantly decreased since
1993, when they were $1 billion, or 62 percent of DOD's total
$1.6-billion costs. By fiscal year 1995, costs of studies and
oversight had fallen to $585 million, or about 39 percent of the
$1.5-billion total. For fiscal year 1997, DOD projects a further
decline to 26 percent for studies and oversight versus 74 percent for
cleanup activities. In commenting on this report, DOD officials
stated that some level of study will need to continue. Studies are
required by the National Contingency Plan\3 and are also needed to
characterize sites, determine whether remediation is needed, and
identify contaminants, if any.
We obtained data from the defense components in February and March
1996 that shows DOD has conducted relative risk assessments on about
70 percent of the 10,361 operational and formerly used defense sites
that may require future cleanup.\4 Over half of these sites have been
identified as high relative risk without any further ranking within
the category. Efforts to rank cleanup sites across geographic and
organizational boundaries are still in their infancy.
DOD plans to devolve budgeting for environmental cleanup from the
centralized departmental process used since 1984 into separate
service and defense agency budget processes. Congress had
established a centralized account in 1984 to facilitate oversight and
to ensure management attention to environmental restoration. DOD is
now proposing legislation to Congress that would remove the single
account for restoration funds, which is funded for fiscal year 1996
at $1.4 billion, and create in its place four accounts with otherwise
similar provisions. In its March 1996 report to Congress on
devolvement, DOD stated this is another step to make the program as
efficient as possible by putting responsibility, accountability, and
funding together. DOD policy guidance and reporting requirements for
the fiscal year 1997 Defense Budget, dated July 1995, provided the
military services with the specific funding categories to be used and
the types of activities to include in each category.
--------------------
\3 The National Oil and Hazardous Substances Pollution Contingency
Plan establishes EPA policy and key response steps for implementing
the Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA).
\4 In commenting on this report, officials of the Office of the
Secretary of Defense stated that they could not verify the service
data because they could not independently recreate it as of the dates
involved. DOD's report to Congress for fiscal year 1995 states that,
as of September 30, 1995, 56 percent of 12,570 sites at active and
former facilities had received relative risk ratings. In addition,
10,019 sites required no further cleanup.
ENVIRONMENTAL COMPLIANCE
INITIATIVES
------------------------------------------------------------ Letter :4
DOD environmental compliance initiatives aim to improve the adequacy
of data available to manage this program. Your Committee's report on
the National Defense Authorization Act for Fiscal Year 1996 in July
1995 stated that DOD's report to Congress on environmental compliance
activities does not distinguish among categories sufficiently to
track the basis for DOD's budget request. Our March 1996 testimony
also noted that DOD lacks the data it needs to manage its
environmental compliance program, particularly when compared to the
data used to manage cleanup activities. For example, Congress
receives annual reports with installation-level data on planned and
actual expenditures for cleanup, but DOD does not have comparable
expenditure data on compliance activities. (In commenting on this
report, DOD officials stated there is no requirement for including
actual expenditure data in the annual DOD environmental quality
report.) DOD has required the services to use an EPA system that
classifies whether projects address current or near-term
noncompliance with environmental laws and regulations or are only
indirectly related to compliance time lines. However, DOD was unable
to provide data on planned or actual expenditures by EPA
classification.
In 1994, the Office of the Secretary of Defense established a working
group that developed plans to ensure that detailed compliance data
can be obtained as needed. DOD approved the plans to improve data
and oversight for fiscal year 1998 by such actions as setting goals
and measuring progress. Detailed budget instructions are expected by
summer 1996. As we stated in testimony before joint subcommittees of
the House Committee on National Security, we agree with DOD's
approach to developing these plans. However, we are concerned that
the class definitions are a significant departure from DOD's past
definitions and do not conform to EPA definitions. As a result, the
number of projects within the high priority category may expand
without decisionmakers being able to distinguish among different
types. DOD officials stated that they will act to ensure that the
priorities are not diluted as they proceed and that, at a meeting
subsequent to our testimony, EPA officials stated that DOD's
definitions were acceptable.
An April 30, 1996, EPA memorandum to DOD stated that the Agency
accepted DOD's definitions for the DOD environmental quality report
to Congress. However, it also cited DOD's agreement to separately
provide EPA with computer disks of project-level data and to
supplement the project listings with the detailed project data needed
to support EPA's automated system. The additional detail agreed to
by DOD will allow EPA to recategorize DOD projects according to EPA
definitions for governmentwide comparability.
ENVIRONMENTAL TECHNOLOGY
INITIATIVES
------------------------------------------------------------ Letter :5
According to DOD, technological innovation is the key to more
efficiently and effectively meeting the environmental restoration
challenge it faces. To facilitate the development and deployment of
better, less costly, and more efficient environmental technologies,
DOD developed a strategy designed to foster technologies with such
benefits as the highest payback. DOD's strategy is based on
systematically identifying needs, and developing, demonstrating, and
validating prioritized technologies. Once needs and related projects
have been reviewed across the military services, high-priority
projects are funded through service, DOD-wide, or other multiagency
environmental programs.
Congressional direction resulted in DOD initiatives to develop a
research plan and a supporting requirements database. The 1992
Defense Authorization Act required the Director of Defense Research
and Engineering to develop a strategic investment plan for
environmental quality research and development. A DOD panel of
engineers published a Tri-Service Environmental Quality Research and
Development Strategic Plan in January 1993 and an updated version in
October 1994. The strategic plan matches various technology projects
against specific service requirements. The next version of the
Strategic Plan, expected in late summer 1996, will be automated. In
response to 1994 direction by the House Committee on Armed Services,
the Deputy Under Secretary for Environmental Security issued the
Environmental Technology Requirements Strategy in March 1995 that
will create a requirements database. This document identifies
prioritized service technology needs by category. For example, a
high-priority Navy requirement in the compliance category is
Hazardous Waste Management Ashore. According to DOD officials, this
requirements document will likely be issued biannually.
We identified work in two high-priority requirements areas where
several projects were underway or planned. Although projects were
funded from various sources and managed by different programs or
services, program and project officials were generally aware of other
projects in the two areas. Officials explained that differences in
the projects generally related to how the technology was applied.
For example, the Environmental Security Technology Certification
Program is funding a Navy project to demonstrate the feasibility of
using plasma arc technology to eliminate hazardous waste on a Navy
installation. The Navy is also funding a project to study the
feasibility of using plasma arc technology to eliminate hazardous
waste material aboard ships.
SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :6
The information presented in this report is drawn from our recent
testimony and from our review of DOD's environmental cleanup,
compliance, and technology issues.
We obtained cleanup and compliance budget data from and interviewed
officials in the Office of the Deputy Under Secretary of Defense for
Environmental Security. The data came from the fiscal years 1995,
1996, and 1997 budget submissions and other budgetary sources. The
fiscal year 1997 budget submission was in draft at the time the data
was provided, and some parts are being updated. Data for fiscal
years 1996 and 1997 is estimated. We compared the data provided with
other original summary sources for comparable periods when available.
We also discussed compliance definitions with EPA officials.
We discussed environmental technology programs and projects with
officials in the Office of the Deputy Under Secretary of Defense for
Environmental Security, the Director of Research and Engineering, and
the services. We selected two specific technology areas and analyzed
data on similar projects in those technology areas. We also visited
the National Defense Center for Environmental Excellence in
Johnstown, Pennsylvania, which was conducting work in the technology
areas we reviewed.
The information in appendix I is our analysis of data reported by
DOD. We compared data to other sources where possible, but did not
trace the data to individual transactions. We did not, for example,
perform detailed examinations at installations to identify the types
of expenditures that DOD reported as being spent for cleanup. As
requested, we provided detailed data on (1) defense environmental
restoration account expenditures for actual cleanup versus study and
oversight; (2) cleanup funding by category of priority, with
additional data for medium and low relative risk, and unranked sites;
(3) overseas cleanup; (4) environmental compliance expenditures by
selected categories; and (5) environmental technology development
programs.
We performed our work from February through April 1996 in accordance
with generally accepted government auditing standards.
AGENCY COMMENTS
------------------------------------------------------------ Letter :7
We received official oral comments from DOD officials, who generally
concurred with our data. Technical changes and updated data were
incorporated in this report where appropriate.
DOD did not fully concur with our observations regarding the impact
of DOD's definitions of compliance classes not conforming to EPA's
definitions and stated that at an April 19, 1996, meeting, EPA
officials accepted DOD's definitions. As we noted in the report, DOD
must also provide EPA with additional details that will allow EPA to
recategorize DOD projects according to EPA definitions for
governmentwide comparability. We will consider questions involving
the impact of DOD's revised definitions as part of ongoing work for
congressional requesters.
---------------------------------------------------------- Letter :7.1
Unless you publicly announce its contents earlier, we plan no further
distribution of this report until 30 days after its issue date. At
that time, we will send copies to appropriate congressional
committees; the Secretary of Defense; the Administrator, EPA; and the
Director of the Office of Management and Budget. We will provide
copies of this report to other interested parties upon request.
Please contact me on (202) 512-8412 if you or your staff have any
questions concerning this report. Major contributors to this report
are listed in appendix II.
David R. Warren
Director, Defense Management Issues
ADDITIONAL INFORMATION ON
ENVIRONMENTAL CLEANUP, COMPLIANCE,
AND TECHNOLOGY DEVELOPMENT
=========================================================== Appendix I
Figure I.1:
(See figure in printed
edition.)
Figure I.2:
(See figure in printed
edition.)
Figure I.3:
(See figure in printed
edition.)
\a Includes potentially responsible party funding from DOD.
Figure I.4:
(See figure in printed
edition.)
Note 1: Calculations of
cleanup include potentially
responsible party funding.
(See figure in printed
edition.)
Note 2: Totals may not add to
100 percent due to rounding.
(See figure in printed
edition.)
Figure I.5:
(See figure in printed
edition.)
Note: In commenting on a draft
of this report, officials of
the Office of the Secretary of
Defense (OSD) stated that the
number of sites, provided by
the services, cannot be
verified by OSD.
(See figure in printed
edition.)
Figure I.6:
(See figure in printed
edition.)
Note: In commenting on a draft
of this report, OSD officials
stated that the project
percentages, provided by the
services, cannot be verified by
OSD.
(See figure in printed
edition.)
Figure I.7:
(See figure in printed
edition.)
Figure I.8:
(See figure in printed
edition.)
Note 1: 10,361 total sites as
of March 1, 1996.
(See figure in printed
edition.)
Note 2: In commenting on a
draft of this report, OSD
officials stated that the
distribution of sites, provided
by the services, cannot be
verified by OSD.
(See figure in printed
edition.)
Figure I.9:
(See figure in printed
edition.)
Figure I.10:
(See figure in printed
edition.)
Figure I.11:
(See figure in printed
edition.)
Note: Totals may not add due
to rounding.
(See figure in printed
edition.)
Figure I.12:
(See figure in printed
edition.)
\a Defense Logistics Agency.
Figure I.13:
(See figure in printed
edition.)
Note: Due to multiple year
funding, some sites/projects
are listed in more than 1
fiscal year.
(See figure in printed
edition.)
Figure I.14:
(See figure in printed
edition.)
Figure I.15:
(See figure in printed
edition.)
Figure I.16:
(See figure in printed
edition.)
Legend
O&M - Operations & Maintenance
DBOF - Defense Business
Operations Fund
RDT&E - Research, Development,
Test, and Evaluation
MILCON - Military Construction
(See figure in printed
edition.)
Figure I.17:
(See figure in printed
edition.)
Figure I.18:
(See figure in printed
edition.)
Figure I.19:
(See figure in printed
edition.)
Figure I.20:
(See figure in printed
edition.)
Figure I.21:
(See figure in printed
edition.)
Figure I.22:
(See figure in printed
edition.)
MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix II
NATIONAL SECURITY AND
INTERNATIONAL AFFAIRS DIVISION,
WASHINGTON, D.C.
-------------------------------------------------------- Appendix II:1
Brad Hathaway
Uldis Adamsons
Bruce Brown
Raymond Cooksey
George Shelton
DENVER FIELD OFFICE
-------------------------------------------------------- Appendix II:2
Maria Durant
Mark McClarie
*** End of document. ***