Environmental Protection: Information Used for Defense Environmental
Management (Letter Report, 06/11/97, GAO/NSIAD-97-135).

Pursuant to a congressional request, GAO provided information on certain
aspects of the Department of Defense's (DOD) environmental compliance
and cleanup activities, focusing on the: (1) extent to which DOD
components are meeting requirements to provide data on the cost and
status of compliance projects; and (2) relative risk characteristics DOD
uses to determine priorities for site cleanup.

GAO noted that: (1) not all the information that DOD, the Environmental
Protection Agency (EPA), and Congress have identified as required for
compliance oversight is being provided; (2) DOD components do not
provide detailed expenditure data on compliance activities; (3) DOD's
reports to EPA do not provide such information as whether compliance
projects address existing or expected noncompliance; (4) in addition,
some data in DOD's latest report to Congress were not complete or
correct; (5) DOD used a relative risk site evaluation methodology in
designating 4,472 of 8,534 sites as high-risk; (6) GAO's analysis of
reported data on 407 high-cost sites, including 266 considered high
risk, indicates that DOD includes a range of site characteristics within
its high-risk category; (7) at 54 percent of the sites that were
designated as high-risk, all three elements used by DOD to make priority
determinations were reported present; (8) at the remaining 46 percent of
the sites one or two of the elements, but not all three, were reported
present; and (9) in addition, the reported levels of contamination at 58
of the 407 sites GAO analyzed were less than the standard DOD used to
determine whether a site is contaminated.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  NSIAD-97-135
     TITLE:  Environmental Protection: Information Used for Defense 
             Environmental Management
      DATE:  06/11/97
   SUBJECT:  Defense budgets
             Environmental policies
             Health hazards
             Hazardous substances
             Environment evaluation
             Reporting requirements
             Military facilities
             Environmental law
             Waste disposal
             Pollution control
IDENTIFIER:  DOD Environmental Compliance Program
             
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Cover
================================================================ COVER


Report to the Chairman, Committee on National Security, House of
Representatives

June 1997

ENVIRONMENTAL PROTECTION -
INFORMATION USED FOR DEFENSE
ENVIRONMENTAL MANAGEMENT

GAO/NSIAD-97-135

Environmental Protection

(709222)


Abbreviations
=============================================================== ABBREV

  CERCLA - Comprehensive Environmental Response, Compensation, and
  Liability Act
  DOD - Department of Defense
  EPA - Environmental Protection Agency
  OSD - Office of the Secretary of Defense
  RCRA - Resource Conservation and Recovery Act

Letter
=============================================================== LETTER


B-276616

June 11, 1997

The Honorable Floyd Spence
Chairman, Committee on National Security
House of Representatives

Dear Mr.  Chairman: 

As you requested, we are providing information on certain aspects of
the Department of Defense's (DOD) environmental compliance and
cleanup activities.  This report discusses (1) the extent to which
DOD components are meeting requirements to provide data on the cost
and status of compliance projects and (2) the relative risk
characteristics DOD uses to determine priorities for site cleanup. 


   BACKGROUND
------------------------------------------------------------ Letter :1

Like private industry, DOD is subject to environmental, safety, and
health laws and regulations.  To meet the requirements of these laws
and regulations at its installations, DOD has organized its
environmental program into five areas:  compliance, cleanup,
conservation, pollution prevention, and technology.  This report
covers the two largest of these areas--compliance and cleanup,\1

which at $2 billion each, account for more than 88 percent of DOD's
fiscal year 1997 environmental budget of $4.6 billion.  (See a list
of GAO related products at the end of the report.)

Compliance focuses on operating and maintaining military
installations in accordance with environmental laws and regulations
of federal, state, and local jurisdictions.  A number of federal laws
protect the environment.  According to DOD, those laws that most
affect DOD's funding for compliance are (1) the Clean Air Act; (2)
the Federal Water Pollution Control Act (Clean Water Act); and (3)
the Solid Waste Disposal Act, as amended by the Resource Conservation
and Recovery Act (RCRA) of 1976.  The Environmental Protection Agency
(EPA) is the primary agency responsible for implementing
environmental laws, but it may authorize states to administer some
programs, including RCRA. 

Cleanup includes identification, investigation, and actual cleanup of
existing contamination from hazardous substances and waste on active
and closing installations and formerly used defense sites.  According
to DOD's fiscal year 1996 annual report to Congress, DOD plans to
spend about $27 billion for site cleanup at DOD installations
beginning in fiscal
year 1997, through the time period represented in the Future Years
Defense Plan, and well into the next century.  In restoring
contaminated sites, DOD must comply with two major federal
environmental laws--RCRA and the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), as
amended--as well as applicable state laws and regulations. 

In this report, we use the term "standard" to define levels of
contamination and the term "element" to refer to the three factors
used by DOD and EPA to determine risk levels.  Risk considers the
following elements:  (1) site contamination--the pollutants that are
present and their concentrations; (2) an identified receptor--the
people or ecosystems that could be harmed; and (3) an evident
pathway--the medium through which the contaminant could reach the
receptor.  We use the term "characteristics" to describe the various
combinations of risk elements and levels of contamination that we
analyzed.\2


--------------------
\1 Funding for cleanup includes $724 million appropriated in the Base
Realignment and Closure account, as discussed in Military Bases: 
Potential Reductions to the Fiscal Year 1997 Base Closure Budget
(GAO/NSIAD-96-158, July 7, 1996). 

\2 DOD describes the elements of the relative risk site evaluation as
follows:  "(1)contamination hazard factor (CHF)--contaminant
concentrations compared to comparison values (comparison values
differ from cleanup standards and are typically two orders of
magnitude higher than cleanup standards); (2) migration pathway
factor (MPF)--is contamination moving or likely to move; and (3)
receptor factor--are humans or sensitive environments currently or
likely to be affected." Additional information on how DOD applies its
relative risk methodology is included in appendix IV. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :2

Not all the information that DOD, EPA, and Congress have identified
as required for compliance oversight is being provided.  DOD
components do not provide detailed expenditure data on compliance
activities.  DOD's reports to EPA do not provide such information as
whether compliance projects address existing or expected
noncompliance.  In addition, some data in DOD's latest report to
Congress were not complete or correct. 

DOD used a relative risk site evaluation methodology in designating
4,472 of 8,534 sites as high risk.\3 Our analysis of reported data on
407 high-cost sites--including 266 considered high risk--indicates
that DOD includes a range of site characteristics within its
high-risk category.  At 54 percent of the sites that were designated
as high risk, all three elements used by DOD to make priority
determinations were reported present.  At the remaining 46 percent of
the sites one or two of the elements, but not all three, were
reported present.  In addition, the reported levels of contamination
at 58 of the 407 sites we analyzed were less than the standard DOD
used to determine whether a site is contaminated. 


--------------------
\3 Based on data as of September 30, 1995.  DOD summary data as of
September 30, 1996, designates 4,100 of 8,084 sites as high risk, but
did not yet have supporting detail available for our analysis. 


   REQUIRED DATA FOR COMPLIANCE
   MANAGEMENT ARE NOT ALWAYS
   AVAILABLE
------------------------------------------------------------ Letter :3

DOD, EPA, and Congress have established requirements for the defense
components to provide certain environmental data.  The Office of the
Secretary of Defense (OSD) has developed information requirements
that are designed to help DOD manage its wide-ranging environmental
compliance activities and cost.  DOD must provide its environmental
program plans to EPA, and certain data on its environmental
compliance activities to Congress.  However, not all of the required
data are being provided.  In addition, our May 1997 report addresses,
among other related issues, DOD's need for and efforts toward uniform
tracking and management for programs involving DOD's compliance with
laws and regulations.\4


--------------------
\4 Environmental Protection:  Status of Defense Initiatives for
Cleanup, Technology, and Compliance (GAO/NSIAD-97-126, May 29, 1997). 


      DOD REPORTING
---------------------------------------------------------- Letter :3.1

We and OSD have noted that DOD's budget execution and financial
reporting do not provide DOD or Congress with the information needed
to provide for oversight of compliance.  In 1995, the Deputy Under
Secretary of Defense for Environmental Security began an
environmental quality data initiative to promote consistency in
compliance definitions, categories, and requirements.  Under the
initiative, DOD made changes to the classes it uses to prioritize
nonrecurring (one time) compliance projects and added a new class "0"
for recurring costs not related to one-time projects.  DOD's changes
also permitted recurring and nonrecurring costs for compliance,
conservation, and pollution prevention to be reported separately. 
After these changes, funds used for activities such as personnel,
training, permits, fees, and hazardous waste disposal were to be
reported as recurring costs, and funds used for activities such as
underground storage tank replacement and stormwater system upgrades
were to be reported as nonrecurring costs. 


      EPA REPORTING
---------------------------------------------------------- Letter :3.2

EPA has developed guidance for environmental data reporting under a
system now called FEDPLAN, which replaced the reporting that had
previously been required under the Office of Management and Budget
Circular A-106.\5 According to EPA headquarters officials, DOD
stopped reporting A-106 information to EPA in 1994.  OSD officials
told us they had recommended canceling the circular's reporting
requirements because EPA was not using submissions and reporting did
not help improve DOD's environmental compliance program.  According
to EPA officials, DOD's environmental data are important.  In
September 1996, DOD began submitting data files used to produce its
annual environmental quality report to Congress.  DOD officials told
us they believe that the data files are more informative than
previous data because they are linked to current budgets. 

For FEDPLAN system reporting, EPA requests that agencies, including
DOD, provide information on 47 data elements related to environmental
compliance activities.  EPA ranks the importance of all required data
elements on a three-point scale.  Of the 47 data elements, EPA
officials determined that 21 elements are critical to making the
FEDPLAN system function effectively because a project cannot be
entered into the system without them.  EPA's critical elements
include federal facilities identification numbers, compliance status,
compliance codes, and statutory authority.  (Some elements, such as
cleanup site data, may not apply to compliance activities.)


--------------------
\5 The Office of Management and Budget Circular A-106 was issued in
December 1974 and rescinded in April 1996.  Executive Order 12088 (42
U.S.C.  4321 note), promulgated in 1978, requires federal agencies to
provide a pollution control plan.  According to EPA officials,
FEDPLAN fulfills that requirement. 


      CONGRESSIONAL REPORTING
---------------------------------------------------------- Letter :3.3

Congress requires DOD to provide data on its environmental compliance
activities.  The Office of the Deputy Under Secretary of Defense for
Environmental Security provides the data to Congress each year in a
report entitled Defense Environmental Quality Annual Report to
Congress.  For the upcoming fiscal year 1996 report, OSD asked the
defense components to provide data on planned recurring spending for
fiscal
years 1998 through 2002.  Required report information was requested
for the following categories: 

  -- appropriation,

  -- major command,

  -- installation,

  -- federal facilities identification number,

  -- state,

  -- country, and

  -- budget year. 

For fiscal year 1998 only, OSD also asked the defense components to
provide information on nonrecurring projects costing over $300,000. 
In addition to the previous categories, DOD asked for the following
information: 

  -- project description,

  -- legal requirement, and

  -- compliance class. 

Appendix I contains a more complete list and explanation of the
reporting requirements. 


      EXTENT TO WHICH DATA
      REQUIREMENTS ARE BEING MET
---------------------------------------------------------- Letter :3.4

Most of DOD's data involving future-year budget estimates for
compliance activities are reported by the components, but details on
actual expenditures are not.  Also, the project data in DOD's most
recent report to Congress were not complete or accurate.  Subsequent
to our draft report, DOD provided additional fiscal year 1998 budget
data to Congress.\6

DOD also did not provide complete data to EPA in its submission of
fiscal year 1997 data for environmental quality projects.  The
defense components' submissions accounted for $422 million (18
percent) of DOD's reported $2.33 billion total.  The Army reported 36
percent of its total environmental quality budget, the Air Force
reported 27 percent, and the Navy reported 6 percent.  Marine Corps
officials stated that, although they submitted data through the Navy
to OSD for incorporation into DOD's environmental quality report, for
unknown reasons the same data did not reach EPA.  That data showed
projects estimated to cost $300,000 or more were valued at $39.5
million (25 percent) of the Marines Corps' total fiscal year 1997
environmental quality budget of $157.6 million. 

Also, for those activities that DOD components reported to EPA, not
all the details requested by EPA were provided.  Some, but not all,
DOD components provided information on 15 of 47 data elements.  For
the 21 elements identified by EPA as critical, the components
provided at least partial data on 12.  An EPA official stated and EPA
guidance indicated that, without those data elements, EPA could not
assess DOD's overall compliance status or address the relative
importance of the projects DOD is undertaking.  In addition to DOD
not providing data adequate for EPA's analysis, an EPA official told
us that it was received too late in the budget cycle for EPA to
request additional data from DOD.  (See app.  II for a detailed
breakdown of the data EPA requires and the information DOD provided.)

DOD officials stated that they do not believe EPA has provided useful
feedback on the environmental compliance data DOD has provided. 
Also, DOD officials stated that they are required to report only
those projects estimated to cost $300,000 or more and that this
requirement partially accounts for the difference between DOD's total
compliance budget and the amounts reported to EPA. 

In its fiscal year 1995 report, provided to Congress in December
1996, DOD accounted for only $2.33 billion of the $2.58 billion
fiscal year 1997 environmental quality program reported in the
President's budget for 1998.\7 Also, the report's breakout of
projects costing $300,000 or more omitted some projects.  DOD
officials told us they were aware of the difference between the
report and the budget and would correct this amount in future
reports. 


--------------------
\6 The additional data provided by DOD in its budget submission
contain information on the obligation of prior-year funds by
component, appropriation, pillar (compliance, pollution prevention,
and conservation), and functional area (e.g., permits and fees, waste
disposal, Clean Air Act, and Clean Water Act).  DOD officials stated
that there is currently no requirement that DOD's annual quality
report to Congress contain project-level obligation data. 

\7 DOD officials stated that the environmental quality program is
divided into six major functions:  planning, compliance, pollution
prevention, conservation, education and training, and environmental
technology. 


   RELATIVE RISK CHARACTERISTICS
   AT DOD'S CLEANUP SITES
------------------------------------------------------------ Letter :4

To direct resources to cleanup sites that pose the greatest risk to
human health and the environment, DOD has developed a methodology for
evaluating the relative risk at its sites.  DOD stated that the
methodology provides a quantifiable basis for justifying requirements
and allocating funds.  On the basis of the degree of contamination
and the potential exposure, DOD assigns each site a relative risk
rating of high, medium, or low.  According to DOD criteria, a site
can be characterized as high if it has significant contamination or
if it has lesser contamination that could potentially affect human
health or the environment. 

DOD's fiscal year 1995 report showed that relative risk assessments
had been completed for 8,534 of 15,240 sites.  Of the completed
assessments,

  -- 4,472 (52.4 percent) were reported as high,

  -- 1,913 (22.4 percent) as medium, and

  -- 2,149 (25.2 percent) as low. 

We analyzed data on 91 installations that had a total of 407 sites
that met our criteria for being a high-cost site.\8 DOD components
reported that these sites had estimated combined cleanup costs of
$5.1 billion for fiscal year 1996 to completion.  We identified those
sites having similar characteristics.  For example, we grouped the
high-risk sites by the degree of identified contamination: 
significant, moderate, or minimal.\9

We also grouped those sites having an identified means of contact
between contaminants and people, animals, or plants and an evident
pathway through which the contaminants could travel. 

Our review of DOD's risk data worksheets for the 266 high-risk sites
of the 407 total sites indicated that 20 percent reported significant
contamination with a confirmed pathway and identified receptors.  In
addition, 54 percent reported all three elements of risk: 
contamination above standard, an identified receptor, and an evident
pathway.\10 (We did not visit the sites or determine the basis for
cleanup in any of these cases.) Figure 1 shows the results of our
analysis.  The estimated cost to complete cleanup of the 266
high-risk sites is $4.3 billion. 

   Figure 1:  Our Analysis of DOD
   Sites with High Relative Risk

   (See figure in printed
   edition.)

In our sample of 407 sites, we also identified those sites in all
three relative risk categories (high, medium, and low) that had
contamination, as reported by DOD, within the standards that DOD
used.  Of the 407 sites, 58 reported contamination levels that were
less than the standard that DOD used.  These 58 sites have estimated
cleanup costs of about $443 million.  (See app.  III.)

In discussing relative risk data, DOD and service officials stated
that the ranking system is an initial screening method and only one
of the factors considered by decisionmakers in determining whether to
fund cleanup at specific sites.  The officials stated that the final
decisions are supported by detailed site assessments made in
accordance with regulations.\11 Also, they noted that the existence
of an estimated cost of completion does not mean that a site has in
fact been funded for fiscal year 1998. 


--------------------
\8 The site data were requested from installations for which DOD's
annual report showed more than $20 million in planned funding during
fiscal years 1996-98 or more than $100 million in projected costs
from fiscal year 1996 to completion. 

\9 With a contaminant ratio (called a "comparison value") of 1
signifying the standard, DOD designated sites whose contaminant
ratios totaled over 100 as having significant contamination.  DOD
designated sites whose contaminant ratios totaled from 2 to 100 as
having moderate contamination.  DOD designated sites whose
contaminant ratios totaled less than 2 as having minimal
contamination. 

\10 DOD uses the same basic elements of risk as EPA but applies these
elements in a simplified manner.  For example, rather than a
quantified score for the degree to which a pathway may exist for
contaminants to reach receptors, such as people, DOD categorizes the
pathway by whether it is "evident," "potential," or "confined."

\11 According to DOD, reuse is a major factor in prioritizing and
funding decisions for sites at BRAC [Base Realignment and Closure]
installations.  For example, DOD stated that ANAD-48, an Army site on
the first line of the appendix III table, is only in the fiscal year
1998 budget for $1,107,000, compared to the $118,457,000 cost to
complete estimate shown in the table. 


   AGENCY COMMENTS
------------------------------------------------------------ Letter :5

DOD had no comments on the overall report message but they did
suggest some technical and editorial changes.  We made those
suggested changes where we felt it was appropriate.  We reprinted
DOD's comments in their entirety in appendix IV, as well as our
comments on specific points. 


   SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :6

To address compliance data needs, we interviewed and reviewed data
from officials at EPA headquarters; DOD's Office of the Deputy Under
Secretary of Defense for Environmental Security; and Army, Navy, Air
Force, and Marine Corps headquarters.  To address the risk-related
characteristics of cleanup sites funded by DOD, we requested and
analyzed 407 relative risk worksheets for selected high-cost sites at
91 high-cost installations identified from DOD's 1995 annual report
to Congress.\12 The site data were requested from installations for
which DOD's annual report showed more than $20 million of planned
funding during fiscal
years 1996-98 or more than $100 million of projected costs from 1996
to completion.  From each installation, we requested relative risk
data worksheets for up to five sites:  the three highest cost
high-risk sites and the highest cost medium-risk and low-risk sites. 
We did not visit these sites, assess the relative risk standards DOD
used, or determine the basis for cleanup in these cases. 

We conducted our review from November 1996 to March 1997 in
accordance with generally accepted government auditing standards. 


--------------------
\12 Defense Environmental Restoration Program Annual Report to
Congress for Fiscal Year 1995. 


---------------------------------------------------------- Letter :6.1

Unless you publicly announce its contents earlier, we plan no further
distribution of this report until 30 days from its issue date.  At
that time, we will send copies to other appropriate congressional
committees; the Secretaries of Defense, the Army, the Navy, and the
Air Force; the Commandant, Marine Corps; and the Directors, Office of
Management and Budget and Defense Logistics Agency.  We will also
make copies available to others on request. 


If you or your staff have any questions concerning the report, please
contact me on (202) 512-8412.  Major contributors to this report are
listed in appendix V. 

Sincerely yours,

David R.  Warren, Director
Defense Management Issues


COMPLIANCE DATA REQUIREMENTS FOR
THE DEPARTMENT OF DEFENSE 1996
ANNUAL ENVIRONMENTAL QUALITY
REPORT TO CONGRESS
=========================================================== Appendix I

Requirement                         Description
----------------------------------  ----------------------------------
Recurring cost data category
----------------------------------------------------------------------
Appropriation                       Operation and maintenance;
                                    military construction;
                                    procurement; the Department of
                                    Defense (DOD) working capital
                                    fund; or research, development,
                                    test, and evaluation.

Major command                       "Self-explanatory."

Installation                        "Self-explanatory."

Federal facilities identification   Unique number used to identify the
number                              installation.

State                               "Self-explanatory."

Country                             "Self-explanatory."

Budget years 1997 through 2001      Dollar value, in thousands, of
                                    each of the
                                    5 budget years for an
                                    installation.


Nonrecurring cost data category \a
----------------------------------------------------------------------
Project name                        Descriptive name of the unique
                                    project

Legal requirement                   A five-digit code corresponding to
                                    the appropriate statutory
                                    requirement. For example, the
                                    Clean Air Act (CAA) would be
                                    represented by CAA, and the
                                    Resource Conservation and Recovery
                                    Act (RCRA) (subtitle C) would be
                                    represented by RCRAC.

Compliance class                    The priority code associated with
                                    the project.

Project budget                      FY97 projected dollar value of the
                                    project, in thousands.
----------------------------------------------------------------------
\a This category includes appropriation, major command, installation,
and federal facilities identification number. 


EPA FEDPLAN DATA REQUIREMENTS AND
DOD SERVICE SUBMISSIONS
========================================================== Appendix II

                                               Service submission
                                          ----------------------------
                                 Element
                                importan                      Air
Data element description              ce  Army      Navy      Force
------------------------------  --------  --------  --------  --------
Federal facilities                     1  YES                 YES
identification number

Department/agency name                 1  YES       YES       YES

Bureau/major command name              1  YES       YES       YES

Name of facility                       1  YES       YES       YES

Street mailing address                 1

City name                              1

Country                                1            YES

EPA region                             1

Agency project number                  1            YES

Project name                           1  YES       YES       YES

Project city name                      1

Multiple installations                 1

Progress code                          1

Total cost estimate                    1  YES       YES       YES

Federal agency funding account         1  YES       YES       YES
code

Estimated project cost                 1  YES       YES       YES

Statutory authority (law/              1  YES       YES\a     YES
regulation)

Environmental category code            1

Compliance status                      1

Compliance class                       1  YES       YES       YES

Priority score                         1

Zip code (facility location)           2

National Priority List site            2

Ownership type                         2

Project name contact                   2

Project contact telephone              2
number

Project street address                 2

Zip code (project location)            2

Year funding required                  2            YES

Funded/unfunded                        2            YES\a

Major program area                     2  YES       YES\a

Pollution prevention                   2

Description                            2

Operable unit/activity data          2,3
sheet

Installation latitude/                 3
longitude

Building number                        3

Room number                            3

Project site latitude/                 3
longitude

Project milestones                     3

Reasons for discontinuance             3

Federal agency program element         3
code

Office of Management and               3
Budget appropriation account
identification code

Type of cost                           3

Local priority                         3

Bureau/major command priority          3

Geographic initiative                  3

Reason for initiation                  3
----------------------------------------------------------------------
Legend for EPA element importance category

1 = Project cannot be entered into the system without this data. 
Input must be completed or corrected immediately.
2 = Project will be entered into the system.  However, missing or
inaccurate data should be completed or corrected within 45 days.
3 = Project will be entered into the system.  Missing or inaccurate
data should be corrected during the next update. 

Note:  EPA--Environmental Protection Agency. 

\a Data provided were incomplete. 

Source:  Federal Agency Environmental Management Program Planning
Guidance, EPA, October 1994, and DOD and service submissions to EPA. 


HIGH-COST SITES WITH REPORTED
CONTAMINATION LEVELS THAT DO NOT
EXCEED STANDARD
========================================================= Appendix III

From DOD's fiscal year 1995 cleanup report to Congress, we identified
installations that reported more than $20 million in planned total
spending during fiscal years 1996 through 1998, or more than $100
million in estimated cost from fiscal year 1996 to completion.  We
requested data for each installation's three highest cost sites with
a high-relative risk ranking and the highest cost sites with medium-
and low-relative risk rankings.  We received data for 91
installations as of March 27, 1997.  In table III.1, "risk rating" is
the overall relative risk assigned on each site's worksheet,
"contamination" is the DOD-prescribed contaminant hazard factor
calculated for the site, and "cleanup cost" is the estimated cost to
complete from fiscal year 1996 to completion. 



                              Table III.1
                
                             Sites Reported

                         (Dollars in thousands)

Service                    Risk rating    Contamination   Cleanup cost
-------------------------  -------------  -------------  -------------
Army                       High                    0.02       $118,457
Army                       High                    0.04            639
Army                       High                    0.15         18,626
Army                       High                    0.24            471
Navy                       High                    0.03         36,293
Air Force                  High                    0.44         23,257
Air Force                  High                    0.94          1,001
Army                       Medium                  0.09          3,362
Army                       Medium                  0.09          3,379
Army                       Medium                  0.13            402
Army                       Medium                  0.23         55,948
Army                       Medium                  0.03         49,331
Navy                       Medium                     0            643
Navy                       Medium                  0.28          2,300
Air Force                  Medium                     0         14,434
Air Force                  Medium                  0.29          2,518
Air Force                  Medium                  0.32            296
DLA                        Low                     0.02             41
DLA                        Low                     0.47            317
Army                       Low                        0          6,341
Army                       Low                        0          9,868
Army                       Low                        0            430
Army                       Low                     0.07          1,321
Army                       Low                     0.19          4,179
Army                       Low                     0.32          4,847
Army                       Low                     0.34          2,254
Army                       Low                     0.79          1,409
Army                       Low                     0.83          1,930
Navy                       Low                        0          4,546
Navy                       Low                        0          8,341
Navy                       Low                     0.01            557
Navy                       Low                     0.01            632
Navy                       Low                     0.10            573
Navy                       Low                     0.10          2,164
Navy                       Low                     0.10            392
Navy                       Low                     0.11          2,734
Navy                       Low                     0.16             80
Navy                       Low                     0.20          1,520
Navy                       Low                     0.29          2,431
Navy                       Low                     0.04            920
Navy                       Low                     0.50             57
Navy                       Low                     0.60          1,004
Navy                       Low                     0.17            906
Air Force                  Low                        0          1,240
Air Force                  Low                        0            572
Air Force                  Low                        0         14,129
Air Force                  Low                        0            816
Air Force                  Low                     0.02            721
Air Force                  Low                     0.04            383
Air Force                  Low                     0.11          4,155
Air Force                  Low                     0.14          1,826
Air Force                  Low                     0.33          1,390
Air Force                  Low                     0.43            510
Air Force                  Low                     0.49         15,614
Air Force                  Low                     0.53          3,707
Air Force                  Low                     0.63          4,855
Air Force                  Low                     0.63            100
Air Force                  Low                     0.78          1,601
======================================================================
Total                                                         $442,770
----------------------------------------------------------------------
Note:  DLA--Defense Logistics Agency. 




(See figure in printed edition.)APPENDIX IV
COMMENTS FROM THE DEPARTMENT OF
DEFENSE
========================================================= Appendix III



(See figure in printed edition.)

See comment 4. 



(See figure in printed edition.)

See comment 5. 

See comment 1. 

See comment 3. 



(See figure in printed edition.)

See comment 6. 

See comment 3. 

See comment 3. 

See comment 3. 

See comment 8. 

See comment 9. 

See comment 10. 



(See figure in printed edition.)

See comment 10. 


The following are GAO's comments on the DOD's letter dated May 16,
1997. 

GAO COMMENTS

1.  Our draft report cited a 1994 working group that the Deputy
Comptroller in the Office of the Secretary of Defense established to
develop budgeting procedures for compliance activities.  We deleted
reference to that working group because DOD officials stated that
they intended the authorization for an environmental security working
group to be limited to cleanup activities. 

2.  The results in brief and relative risk sections address the
relative risk site characteristics that DOD reported in its fiscal
year 1995 annual report to Congress.  Our report recognizes in the
section on relative risk characteristics that the ranking system is
an initial screening method that is only one of the factors
considered by decisionmakers in determining whether to fund cleanup
at specific sites.  Our report recognizes other factors and therefore
does not imply that relative risk evaluation is a substitute for a
risk assessment. 

3.  We have modified our report in response to DOD's comment. 

4.  We included these additional DOD data and conclusions in a
footnote on page 2. 

5.  Our statement refers to distinctions such as the difference
between "identified" receptors and "potential" or "limited"
receptors. 

6.  The cited paragraph is intended only to introduce the subject. 

7.  DOD acknowledged that the total costs shown in its annual report,
$2.33 billion, did not reflect all of the defense agencies' projects. 
However, DOD indicated that it understated the figure by only $40
million, not the $250 million we reported.  Even though DOD's annual
report lists technology as one of its six major environmental quality
program functions, DOD officials told us they did not consider
technology as part of the environmental quality program and thus
excluded such amounts from reported totals.  Our calculations,
showing a difference of $250 million between the President's budget
and the annual report, included totals for the defense agencies and
technology programs that DOD omitted.  The 1998 President's budget
for fiscal year 1997 totaled $2.58 billion, including technology. 
The $2.37 billion cited by DOD included defense agencies but excluded
technology.  Since the President's budget included technology
programs and the annual report did not indicate that technology
programs were being excluded from reported totals, we have not
changed our calculations. 

8.  We added the modifier "identified" to the first three notes.  We
did not add "potential" to the note for the 46 percent segment
because we noted that other combinations, including confined pathways
and limited receptors, were present. 

9.  We did not delete the term "standard" because our draft specified
the term as defining levels of contamination and each of DOD's
relative risk worksheets used the term "standard" in this context. 

10.  We did not replace "determining whether to fund" with
"prioritizing" but did add the additional information supplied by
DOD. 


MAJOR CONTRIBUTORS TO THIS REPORT
=========================================================== Appendix V

NATIONAL SECURITY AND
INTERNATIONAL AFFAIRS DIVISION,
WASHINGTON, D.C. 

Charles I.  Patton, Jr.
Uldis Adamsons
Richard Meeks
Joanne Jurmu

KANSAS CITY FIELD OFFICE

Virgil Schroeder
Steve Pruitt
Ben Douglas

OFFICE OF THE GENERAL COUNSEL

Lynn Gibson


RELATED GAO PRODUCTS
============================================================ Chapter 0

Environmental Protection:  Status of Defense Initiatives for Cleanup,
Technology, and Compliance (GAO/NSIAD-97-126, May 29, 1997). 

Federal Facilities:  EPA's Penalties for Hazardous Waste Violations
(GAO/RCED-97-42, Feb.  28, 1997). 

DOD Problem Disbursements (GAO/AIMD-97-36R, Feb.  20, 1997). 

Environmental Cleanup:  Inadequate Army Oversight of Rocky Mountain
Arsenal Shared Costs (GAO/NSIAD/AIMD-97-33, Jan.  23, 1997). 

Military Base Closures:  Reducing High Costs of Environmental Cleanup
Requires Difficult Choices (GAO/NSIAD-96-172, Sept.  5, 1996). 

Environmental Protection:  Status of Defense Initiatives for Cleanup,
Compliance, and Technology (GAO/NSIAD-96-155, Aug.  2, 1996). 

Military Bases:  Potential Reductions to the Fiscal Year 1997 Base
Closure Budget (GAO/NSIAD-96-158, July 7, 1996). 

Environmental Compliance:  Continued Need for Guidance in Programming
Defense Construction Projects (GAO/NSIAD-96-134, June 21, 1996). 

Federal Facilities:  Consistent Relative Risk Evaluations Needed for
Prioritizing Cleanups (GAO/RCED-96-150, June 7, 1996). 

Military Bases:  Closure and Realignment Savings Are Significant, but
Not Easily Quantified (GAO/NSIAD-96-67, Apr.  8, 1996). 

Environmental Protection:  Issues Facing the Energy and Defense
Environmental Management Programs (GAO/T-RCED/NSIAD-96-127, Mar.  21,
1996). 

Environmental Protection:  Challenges in Defense Environmental
Program Management (GAO/T-NSIAD-95-121, Mar.  24, 1995). 

Military Bases:  Environmental Impact at Closing Installations
(GAO/NSIAD-95-70, Feb.  23, 1995). 

Environmental Cleanup:  Case Studies of Six High Priority DOD
Installations (GAO/NSIAD-95-8, Nov.  18, 1994). 

Pollution Prevention:  Status of DOD's Efforts (GAO/NSIAD-95-13, Nov. 
9, 1994). 

Environment:  DOD's New Environmental Security Strategy Faces
Barriers (GAO/NSIAD-94-142, Sept.  30, 1994). 

Environmental Compliance:  DOD Needs to Better Identify and Monitor
Equipment Containing Polychlorinated Biphenyls (GAO/NSIAD-94-243,
Aug.  24, 1994). 

Environmental Cleanup:  Better Data Needed for Radioactively
Contaminated Defense Sites (GAO/NSIAD-94-168, Aug.  24, 1994). 

Natural Resources:  Defense and Interior Can Better Manage Land
Withdrawn for Military Use (GAO/NSIAD-94-87, Apr.  26, 1994). 

Environmental Cleanup:  Too Many High Priority Sites Impede DOD's
Program (GAO/NSIAD-94-133, Apr.  21, 1994). 

Environmental Compliance:  Guidance Needed in Programming Defense
Construction Projects (GAO/NSIAD-94-22, Nov.  26, 1993). 

*** End of document. ***