Health and Safety: Environmental Oversight of Classified Federal Research
(Testimony, 03/12/96, GAO/T-RCED-96-99).
GAO discussed its review of the Environmental Protection Agency's (EPA)
capability to conduct environmental oversight of classified federal
research. GAO noted that: (1) EPA conducts limited oversight of
classified federal research, primarily relying on agencies' internal
environmental monitoring programs; (2) although agencies are required to
submit environmental impact statements (EIS) to EPA for review, EPA does
not ensure that agencies submit all EIS or know the liaisons for some
agencies' environmental issues; (3) environmental compliance officials
within agencies may not be reviewing all classified research activities;
(4) EPA conducts environmental enforcement activities at known
classified federal facilities when the agencies cooperate, but it does
not have a complete inventory of all facilities and is sometimes
hindered by secrecy and need-to-know considerations; (6) while it is
possible that federal agencies have secretly sought exemptions from
environmental requirements, it appears that they have rarely sought such
exemptions; and (7) agencies have occasionally sought special emergency
arrangements concerning environmental standards because of national
security concerns.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: T-RCED-96-99
TITLE: Health and Safety: Environmental Oversight of Classified
Federal Research
DATE: 03/12/96
SUBJECT: Research and development facilities
Environmental monitoring
Research program management
Official secrets
Environmental impact statements
Reporting requirements
Safety regulation
National defense operations
Waivers
IDENTIFIER: Project Sapphire
EPA National Priorities List
Groom Lake (NV)
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Cover
================================================================ COVER
Before the Committee on Governmental Affairs,
U.S. Senate
For Release on Delivery
Expected at
9:00 a.m., EST
Tuesday
March 12, 1996
HEALTH AND SAFETY - ENVIRONMENTAL
OVERSIGHT OF CLASSIFIED FEDERAL
RESEARCH
Statement of Bernice Steinhardt, Associate Director, Energy,
Resources, and Science Issues,
Resources, Community, and Economic
Development Division
GAO/T-RCED-96-99
GAO/RCED-96-99T
(302190)
Abbreviations
=============================================================== ABBREV
CEQ -
CERCLA -
CIA -
DOD -
DOE -
EIS -
EPA -
GAO -
NSA -
NEPA -
OMB -
RCRA -
NSC -
NOAA -
AEC -
============================================================ Chapter 0
Mr. Chairman, Mr. Ranking Minority Member, and Members of the
Committee:
In October 1995, the presidential Advisory Committee on Human
Radiation Experiments reported a troubling legacy of secret Cold War
government radiation research on human subjects and experimental
radiation releases into the environment whose scope and extent was
previously unknown. Among many findings, the Committee criticized
the government's historical research ethics and raised the
possibility that events analogous to past secret environmental
releases--such as the controversial Green Run atmospheric release at
Hanford Works, Washington, in 1949\1 --could still happen today. The
report also mentioned alleged past environmental violations at a
classified Air Force facility near Groom Lake, Nevada, as an
indication that secret releases or analogous events could still
occur, despite the environmental oversight system now in place. To
guard against this, the Committee recommended the creation of an
independent group to oversee the environmental consequences of
classified research and a broader role for the Environmental
Protection Agency (EPA) in overseeing classified research as well.
In line with this history, the Ranking Minority Member asked us to
examine EPA's capability to conduct environmental oversight of
classified federal research and the extent to which federal
facilities and activities have been exempted from compliance with
environmental laws. We conducted our work principally at the
headquarters of EPA, the Department of Energy (DOE) and the
Department of Defense (DOD), and at the Executive Office of the
President. We relied primarily on unclassified discussions with
responsible agency officials in obtaining information.
In summary:
EPA's broad responsibilities include environmental oversight of
federal facilities--including classified federal research
planning and operations--but EPA's capability to conduct such
oversight is limited. EPA is, however, taking steps to improve
its environmental enforcement at classified federal facilities.
While the President can exempt federal agencies from environmental
requirements in cases involving the paramount interest of the
U.S. or in the interest of national security, agencies have
rarely sought such exemptions. We found only two instances of
federal agencies obtaining Presidential exemptions from
environmental laws. Although it is possible that exemptions
were sought and obtained in secret, those with whom we spoke,
including an official of the National Security Council,
generally indicated they did not know of any such exemptions.
--------------------
\1 This classified atomic intelligence experiment released
significant radioactive iodine and xenon emissions into the air over
large portions of Washington and Oregon and was not disclosed for
almost four decades. See Nuclear Health and Safety: Examples of
Post World War II Radiation Releases at U.S. Nuclear Sites
(GAO/RCED-94-51FS, Nov. 24, 1993).
BACKGROUND
---------------------------------------------------------- Chapter 0:1
In recent years, federal agencies, the Advisory Committee on Human
Radiation Experiments, GAO, and others have documented hundreds of
secret, intentional government releases of radiation and other
pollutants into the environment in connection with the Cold War. The
releases occurred in the years after World War II at locations around
the country, including Tennessee, New Mexico, Washington, Alaska, and
Utah. (See app. I.) Such releases typically occurred at remote
federal installations, in an era when there was little federal or
state environmental regulation of such activities.
Today, an extensive environmental oversight framework is in place.
In accordance with NEPA, the Council on Environmental Quality's (CEQ)
implementing regulations, and the Clean Air Act, EPA shares with CEQ
the responsibility for overseeing federal agencies' environmental
planning, including their classified planning. For example, under
NEPA, federal agencies must assess the environmental impact of major
federal actions significantly affecting the environment before they
proceed and must submit environmental impact statements (EIS) for
review by the public and other federal agencies; EPA is supposed to
review these EISs, including those portions containing classified
information. CEQ, within the Executive Office of the President,
conducts administrative oversight of agencies' NEPA programs.
NEPA also places public disclosure requirements on agencies.
However, NEPA and its implementing regulations allow agencies to
avoid public disclosure of classified proposals in the interest of
national security. NEPA still requires agencies to prepare EISs and
other NEPA assessments for classified actions, but CEQ regulations
allow agencies to segregate information from public oversight in
fully classified EIS documents or appendixes.
Federal agencies are also subject to the requirements of federal
pollution control laws, such as the Clean Water Act, the Clean Air
Act, and the Resource Conservation and Recovery Act (RCRA). EPA has
a mandate to oversee the enforcement of the environmental laws at
federal facilities, including those that conduct highly classified
research operations. EPA's Office of Federal Facilities Enforcement
is the agency's focal point for enforcement, including developing
strategies and participating in enforcement oversight and litigation.
EPA has some resources for inspecting highly classified facilities
and storing classified documents, including headquarters and field
personnel with the appropriate security clearances.
Under some laws, such as the Clean Water Act and RCRA, EPA can
authorize states to carry out their own program for these laws if
they meet certain requirements. Whether EPA or a state acts as the
regulatory authority, federal agencies with facilities that are
releasing pollutants into the environment must obtain required
permits and are subject to inspections and enforcement actions.
Radioactive materials regulated under the Atomic Energy Act are
exempt from RCRA and the Clean Water Act. DOE regulates these
materials under its Atomic Energy Act authority. Over the years, we
have issued numerous reports addressing how well various EPA, DOE,
and DOD programs implement this framework. (See app. II.) We found
that although EPA was given many additional pollution prevention,
control, abatement, and enforcement initiatives, its budget for
carrying out these activities did not keep pace with the increased
responsibilities.
The Advisory Committee's report therefore recommended that (1) an
independent panel review planned secret environmental releases and
(2) EPA permanently keep key documents related to its environmental
oversight of classified programs and report periodically to the
Congress on its oversight of such programs. A February 1996 draft
response by the Human Radiation Interagency Working Group\2 questions
the need for the recommended independent review panel but agrees that
EPA should keep permanent files of key environmental documents.
--------------------
\2 The Advisory Committee reported to the Presidentially established
Human Radiation Interagency Working Group. The interagency working
group is composed of the heads of pertinent agencies and was
established to oversee federal efforts to locate historical records
describing radiation experiments on humans and radiation releases to
the environment.
EPA'S OVERSIGHT OF FEDERAL
AGENCIES' CLASSIFIED RESEARCH
ACTIVITIES IS LIMITED
---------------------------------------------------------- Chapter 0:2
EPA has responsibilities for overseeing federal facilities'
activities, including classified federal research planning and
operations. However, the agency's capability to conduct such
oversight is limited. In large measure, under NEPA and other laws,
EPA relies on the agencies themselves to have their own internal
environmental monitoring programs. In part because of secrecy
requirements, EPA is especially dependent on the cooperation of
agencies in identifying their facilities and activities and reporting
on the environmental impacts of their classified research planning
and operations.
ENVIRONMENTAL OVERSIGHT OF
AGENCIES' CLASSIFIED
PLANNING
-------------------------------------------------------- Chapter 0:2.1
EPA's Office of Federal Activities reviews hundreds of EISs each
year, but according to activities office staff, only a tiny fraction
of these--perhaps two or three a year--are either partially or fully
classified. According to EPA, classified EISs are submitted almost
exclusively by DOE and DOD. The activities office has two people
with high-level clearances who review these classified EISs. EPA
does not keep records of classified EISs that have been sent to it
for review and does not store them, although it does have some
classified storage capability. Classified EISs are stored at the
agencies themselves. Officials in EPA's activities office said there
is little incentive to establish such recordkeeping or more such
storage at EPA because classified EIS submittals are rare.
Neither EPA nor CEQ has the responsibility or the resources to
closely monitor and direct the EIS submittal process. Agencies are
required to submit unclassified and classified EISs for EPA's review,
but according to activities office officials, EPA is not charged with
conducting outreach to ensure that all such EISs are submitted.
Also, EPA is not responsible for reviewing the thousands of other
lower level environmental planning documents--such as environmental
assessments--which agencies generate each year; its review is limited
to EISs, which are required for "major" actions only. As a result,
EPA activities office staff said their overview of agencies' internal
NEPA planning is very limited.
According to EPA records and activities office officials,
historically some agencies have not been sending EISs to EPA for
review, either classified or unclassified, as required. Such
agencies include the Central Intelligence Agency (CIA), the National
Security Agency (NSA), and the Defense Intelligence Agency.
According to EPA officials who have been assigned the responsibility
to review EIS's for the CIA and NSA over the past several years, they
have not had contact with these agencies concerning EISs and do not
know who these agencies' liaisons are for NEPA matters.
Furthermore, environmental compliance officials within the agencies
may not be reviewing all classified research activities. According
to a responsible Air Force NEPA compliance official, although his
office is charged with reviewing classified EISs internally,
historically the office has rarely received such documents for
review. He said his office may not have a need-to-know for all such
documents. He also could not recall his office receiving for review
any unclassified or classified NEPA documents prepared for proposed
projects at the classified Air Force operating location near Groom
Lake, Nevada.
Agencies may conduct environmental planning secretly, and a proposed
action may proceed without prior public comment. For example, in
1994, the government conducted Project Sapphire, a classified nuclear
nonproliferation action that transferred highly enriched uranium from
Kazakhstan in the former Soviet Union to storage at Oak Ridge,
Tennessee. DOE conducted internal NEPA planning for Project Sapphire
in the form of a detailed classified environmental assessment, but
because it was an environmental assessment and not an EIS, EPA was
not required to review the assessment and prior public comment was
not possible for national security reasons. The public was fully
apprised of the Project Sapphire environmental assessment after the
uranium transfer was completed.
ENVIRONMENTAL OVERSIGHT OF
AGENCIES' CLASSIFIED
OPERATIONS
-------------------------------------------------------- Chapter 0:2.2
According to EPA headquarters and regional enforcement officials, EPA
and the states have been conducting enforcement activities at known
classified federal research facilities, but management oversight of
such enforcement has not been systematic. According to EPA, known
facilities are inspected and required through EPA and/or state
oversight to comply with environmental laws. However, neither EPA
headquarters nor its regions have complete inventories of all
classified federal facilities subject to environmental requirements,
either nationally or at a regional level.
Instead, EPA headquarters and field enforcement officials said they
depend on agencies to report the existence of their classified
facilities, to report environmental monitoring data, and to cooperate
with EPA and authorized states in assuring that such facilities are
in compliance. They said they receive a degree of cooperation at
known DOE and DOD classified facilities but are constrained by
secrecy and need-to-know considerations. When they receive
cooperation, they conduct appropriate field enforcement activities.
In this regard, an ongoing lawsuit by former employees at an Air
Force facility near Groom Lake, Nevada, alleged violations of RCRA,
including EPA's failure to conduct a RCRA inspection there. EPA has
affirmed that EPA field inspectors conducted an inspection of the
location pursuant to RCRA from December 1994 to March 1995. In
August 1995, the U.S. District Court for the District of Nevada
ruled that the plaintiffs' objectives in bringing the suit had been
accomplished, in that EPA had performed its duties under RCRA to
inspect and inventory the site.\3
In May 1995, EPA and the Air Force affirmed by a memorandum of
agreement that EPA will continue to have access at the Groom Lake
facility for purposes of administering the environmental laws and
that the Air Force is committed to complying with RCRA at the
location. The details of the issues resulting in the agreement are
classified. According to the director of EPA's Office of Federal
Facilities Enforcement, EPA is fulfilling its oversight
responsibility at the facility. However, he said he was uncertain of
the extent to which other such highly classified federal
facilities--or areas within facilities--may exist and whether their
research operations are in environmental compliance.
According to the director of federal facilities enforcement, the
degree of EPA's involvement in classified activities may broaden in
the future. The agency is currently working with the Air Force on a
broader memorandum of agreement applicable to all classified Air
Force facilities. Also, the director said that EPA held a meeting in
1995 with other agencies, including intelligence agencies, concerning
further possible memorandums of agreement similar to the one signed
with the Air Force for Groom Lake. Also, EPA, in conjunction with
agencies that have highly classified programs, is working on
procedures for improved environmental regulation at classified
installations.
Nevertheless, it is not clear that EPA will have the resources to
oversee additional environmental compliance by any federal
facilities. EPA's Office of Federal Facilities Enforcement is
currently responsible for overseeing the cleanup of the 154 federal
sites included in the National Priorities List under the
Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA). EPA has stated that it has the resources to oversee
federal facilities' overall environmental management and compliance,
but few additional resources for greater oversight of classified
facilities.
--------------------
\3 DOE v. Browner, 902 F. Supp.1240 (D. Nev. 1995).
KNOWN EXEMPTIONS OF FEDERAL
FACILITIES FROM ENVIRONMENTAL
LAWS HAVE BEEN RARE
---------------------------------------------------------- Chapter 0:3
Although federal environmental laws allow the President to provide
exemptions from environmental requirements in cases involving the
paramount interest of the U.S. or in the interest of national
security, federal agencies appear to have rarely sought these
exemptions. We found only two cases in over 15 years of federal
agencies obtaining presidential exemptions from environmental laws.
While it is possible that exemptions were sought and obtained in
secret, those with whom we spoke, including an official of the
National Security Council, generally indicated they did not know of
any such exemptions. Under NEPA, numerous less formal special
arrangements have been obtained through emergency agreements with
CEQ.
PRESIDENTIAL EXEMPTIONS
-------------------------------------------------------- Chapter 0:3.1
Presidential exemption provisions are contained in some environmental
laws, including the Clean Water Act, the Clean Air Act, RCRA, the
Safe Drinking Water Act, CERCLA, and the Noise Control Act. These
provisions differ in detail but generally provide that the President
can declare a facility or activity exempt from applicable
environmental standards. Depending on the law, he may do so in the
paramount interest of the nation or in the interest of national
security. A presidential exemption can suspend the applicable
pollution standards in the laws for whole facilities or specific
sources of pollution. Generally, exemptions are for 1 to 2 years,
may be renewed indefinitely, and must be reported to the Congress.
Executive Order 12088 gives agencies guidance on complying with the
laws and contains implementation procedures. Generally, the head of
an executive agency may recommend to the President, through the
Director of the Office of Management and Budget (OMB), that an
activity or facility be exempt from an applicable pollution control
standard. According to an EPA official, the exemption mechanism is a
"last resort" for agencies that may not be able to comply with
environmental laws.
We found only two cases in which federal facilities have been
exempted by the President from compliance with environmental laws.
Responsible officials at several agencies and in the Executive Office
of the President were aware of only these two exemptions:
In October 1980, President Carter exempted Fort Allen in Puerto
Rico from applicable sections of four environmental
statutes--the Clean Water Act, the Clean Air Act, the Noise
Control Act, and RCRA. The exemption was determined to be in
the paramount interest of the U.S., allowing time for the
relocation of thousands of Cuban and Haitian refugees to the
fort from Florida. The exemption was renewed once, in October
1981, by President Reagan.
In September 1995, President Clinton exempted the Air Force's
classified facility near Groom Lake, Nevada from the public
disclosure provisions of RCRA, determining that the exemption
was in the paramount interest of the United States.
According to OMB and the National Security Council (NSC), the most
recent exemption was routed through NSC for Presidential attention,
not through OMB as provided in Executive Order 12088.
EMERGENCY AGREEMENTS UNDER
NEPA
-------------------------------------------------------- Chapter 0:3.2
NEPA does not contain explicit exemption provisions related to
paramount national interest or national security. The CEQ
regulations implementing NEPA permit special arrangements when NEPA's
procedures might impede urgent agency actions. According to CEQ's
records, there have been at least 22 instances of emergency NEPA
agreements between an agency and CEQ, usually for reasons of time
criticality. Three of these recorded emergency arrangements
concerned national policy or national security issues:
In 1991, the Air Force and CEQ agreed to alternative measures
instead of a written EIS--including noise abatement steps--so
that aircraft launches from Westover Air Force Base,
Massachusetts, toward the Persian Gulf could proceed in a timely
manner.
In 1991, the Air Force and CEQ agreed that an EIS was not required
before conducting a Desert-Storm-related test of aerial
deactivation of land mines at the Tonapah Range in Nevada.
In 1993, DOE and CEQ agreed on alternative NEPA arrangements for
U.S. acceptance of spent nuclear fuel from a reactor in
Belgium. Subsequently, Belgium declined the U.S. offer of
acceptance.
-------------------------------------------------------- Chapter 0:3.3
This concludes our testimony. We would be pleased to respond to any
questions you or other Members of the Committee may have.
DOCUMENTED FEDERAL ENVIRONMENTAL
TESTS/RELEASES 1944-77
=========================================================== Appendix I
1944-62:254 open air implosion physics tests, Atomic Energy
Commission (AEC), Los Alamos National Laboratory, New Mexico
1948:3 radiological warfare experiments, AEC, Oak Ridge National
Laboratory, Tennessee
1949-52:21 radiological warfare tests, U.S. Army, Dugway, Utah
1949:Green Run atmospheric radiation test, Air Force/AEC, Hanford,
Washington
1950:4 atmospheric tracking tests, Air Force, Los Alamos National
Laboratory, New Mexico
1954- ?:Radionuclide laboratory and field studies, AEC/Health Physics
Division/Massachusetts Institute of Technology, Oak Ridge, Tennessee,
Walker Branch Watershed, Tennessee, and Bickford Watershed,
Massachusetts
1955-61:At least 26 aircraft nuclear propulsion tests, Air Force,
National Reactor Testing Station, Idaho
1955:2 atmospheric uranium hexafluoride releases, AEC, Paducah
Gaseous Diffusion Plant, Kentucky
1957:Fuel element burn tests, Air Force, National Reactor Testing
Station, Idaho
1958:At least 9 fission product field release tests, Air Force,
National Reactor Testing Station, Idaho, and Dugway Proving Grounds,
Utah
1959-66:Kiwi space program reactor tests, Air Force/AEC/Los Alamos,
Nevada Test Site
1960:Organic moderated solvent burning experiment, AEC, Idaho
National Engineering Laboratory, Idaho
1962:Project Chariot related erosion and weathering tests, U.S.
Geological Survey, Cape Thompson, Alaska
1962-63:2 iodine-131 air and soil dispersion tests, AEC, Hanford,
Washington
1962-64:3 series of special power excursion reactor tests, AEC, Idaho
National Engineering Laboratory, Idaho
1963-68:24 controlled environmental radioiodine tests, AEC, Idaho
National Engineering Laboratory, Idaho
1964-66:2 series of nuclear auxiliary power tests, Idaho National
Engineering Laboratory, Idaho
1964-66:Tracer experiments on lichens, AEC/Hanford, Anaktuvuk Pass,
Alaska
1965:Kiwi space program reactor transient nuclear test, Air Force/Los
Alamos/U.S. Public Health Service, Nevada Test Site
1967-69:4 pollutant relative diffusion tests, National Oceanic and
Atmospheric Administration (NOAA)/AEC, Idaho National Engineering
Laboratory, Idaho
1968-70:Experimental cloud exposure study, AEC, Idaho National
Engineering Laboratory, Idaho
1968-77:Controlled environmental release test series, AEC, Idaho
National Engineering Laboratory, Idaho
1971-72:Long distance diffusion tests, NOAA/AEC, Idaho National
Engineering Laboratory, Idaho
1974:2 atmospheric uranium hexafluoride releases, AEC, Paducah
Gaseous Diffusion Plant, Kentucky
1976:57 uranium hexafluoride outleakage tests, K-25 Gaseous Diffusion
Plant, Oak Ridge, Tennessee
Undated:8 loss-of-fluid tests, Organization for Economic Cooperation
and Development, Idaho National Engineering Laboratory, Idaho
Sources: Nuclear Health and Safety: Radiation Events at DOE's Idaho
National Engineering Laboratory (GAO/RCED-92-64FS, Jan. 13, 1992)
Nuclear Health and Safety: Examples of Post World War II Radiation
Releases at U.S. Nuclear Sites (GAO/RCED-94-51FS, Nov. 24, 1993);
Nuclear Health and Safety: Sites Used for Disposal of Radioactive
Waste in Alaska (GAO/RCED-94-130FS, July 6, 1994) Advisory Committee
on Human Radiation Experiments Final Report (Oct. 1995); Human
Radiation Experiments: The Department of Energy Roadmap to the Story
and the Records (DOE/EH-0445, Feb. 1995); "Summary of Radiological
Warfare Testing at Dugway Proving Grounds, 1949-52," undated DOD
abstract.
SELECTED RECENT GAO REPORTS
ADDRESSING EPA'S ENVIRONMENTAL
OVERSIGHT AND DOD'S AND DOE'S
ENVIRONMENTAL COMPLIANCE
========================================================== Appendix II
Nuclear Waste: Management and Technical Problems Continue to Delay
Characterizing Hanford's Tank Waste (GAO/RCED-96-56, Jan. 26, 1996).
Department of Energy: Savings From Deactivating Facilities Can Be
Better Estimated (GAO/RCED-95-183, July 7, 1995).
Department of Energy: National Priorities Needed for Meeting
Environmental Agreement (GAO/RCED-95-1, Mar. 3, 1995).
Nuclear Cleanup: Difficulties in Coordinating Activities Under Two
Environmental Laws (GAO/RCED-95-66, Dec. 22, 1994).
Environment: DOD's New Environmental Security Strategy Faces
Barriers (GAO/NSIAD-94-142, Sept. 30, 1994).
Nuclear Health and Safety: Consensus on Acceptable Radiation Risk to
the Public is Lacking (GAO/RCED-94-190, Sept. 19, 1994).
Environmental Cleanup: Better Data Needed for Radioactivity
Contaminated Defense Sites (GAO/NSIAD-94-168, Aug. 24, 1994).
Environmental Cleanup: Too Many High Priority Sites Impede DOD's
Program (GAO/NSIAD-94-133, Apr. 21, 1994).
Federal Facilities: Agencies Slow to Define the Scope and Cost of
Hazardous Waste Site Cleanups (GAO/RCED-94-73, Apr. 15, 1994).
Pollution Prevention: EPA Should Reexamine the Objectives and
Sustainability of State Programs (GAO/PEMD-94-8, Jan. 25, 1994).
Air Pollution: Progress and Problems In Implementing Selected
Aspects of the Clean Air Act Amendments of 1990 (GAO/T-RCED-94-68,
Oct. 29, 1993).
Environmental Enforcement: EPA Cannot Ensure the Accuracy of
Self-Reported Compliance Monitoring Data (GAO/RCED-93-21, Mar. 31,
1993).
Environmental Enforcement: Alternative Enforcement Organizations for
EPA (GAO/RCED-92-107, Apr. 14, 1992).
Environmental Enforcement: EPA Needs a Better Strategy to Manage Its
Cross-Media Information (GAO/IMTEC-92-14, Apr. 2, 1992).
*** End of document. ***