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Report to the Honorable John D. Dingell: 
Ranking Minority Member, 
Committee on Energy and Commerce, 
House of Representatives:

December 2003:

MILITARY MUNITIONS:

DOD Needs to Develop a Comprehensive Approach for Cleaning Up 
Contaminated Sites:

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-04-147] GAO-04-147:

GAO Highlights:

Highlights of GAO-04-147, a report to the Honorable John D. Dingell, 
Ranking Minority Member, Committee on Energy and Commerce, House of 
Representatives

Why GAO Did This Study:

Over 15 million acres in the United States are suspected of being, or 
known to be, contaminated with military munitions. These sites include 
ranges on closing military installations, closed ranges on active 
installations, and formerly used defense sites. Under the Defense 
Environmental Restoration Program, established in 1986, the Department 
of Defense (DOD) must identify, assess, and clean up military 
munitions contamination at these sites. DOD estimates these activities 
will cost from $8 billion to $35 billion. Because of the magnitude of 
DODís cleanup effort, both in terms of cost and affected acreage, as 
well as the significant public safety, health, and environmental risks 
that military munitions may pose, you asked us to evaluate (1) DODís 
progress in implementing its program to identify, assess, and clean up 
military munitions sites and (2) DODís plans to clean up remaining 
sites in the future.

What GAO Found:

DOD has made limited progress in its program to identify, assess, and 
clean up sites that may be contaminated with military munitions. While 
DOD had identified 2,307 potentially contaminated sites as of 
September 2002, DOD officials said that they continue to identify 
additional sites and are not likely to have a firm inventory for 
several years. Of the identified sites, DOD had initially determined 
that 362 sites required no further study or cleanup action because it 
found little or no evidence of military munitions. For 1,387 sites, 
DOD either has not begun or not completed its initial evaluation or 
determined that further study is needed. DOD has completed its 
assessment of 558 sites, finding that 475 of these required no cleanup 
action. The remaining 83 sites required some cleanup action, of which 
DOD has completed 23.

DOD does not yet have a complete and viable plan for cleaning up 
military munitions at remaining potentially contaminated sites. DODís 
plan is lacking in several respects, including the following:
* Essential data for DODís plan may take years to develop. Not all the 
potential sites have been identified, and DOD has set no deadline for 
doing so. Also, DOD intends to use a new procedure to assign a 
relative priority for the remaining 1,387 sites, but it will not 
complete the reassessments until 2012. Until these are done, DOD 
cannot be assured that it is using its limited resources to clean up 
the riskiest sites first. 
* DODís plan relies on preliminary cost estimates that can change 
greatly and the reallocation of funds that may not be available. For 
example, the Air Force used estimated, not actual, acreage to create 
its cost estimates, limiting the estimateís reliability and DODís 
ability to plan and budget cleanup for these sites. Also, DOD expects 
additional funds will become available for munitions cleanup as other 
DOD hazardous waste cleanup efforts are completed. However, some of 
these efforts are behind schedule; therefore, funds may not become 
available as anticipated. 
* DODís plan does not contain goals or measures for site assessment 
and cleanup. DOD recently established a working group tasked with 
developing agencywide program goals and performance measures, but not 
service-specific targets, limiting DODís ability to ensure that the 
services are making progress in cleaning the potentially contaminated 
sites and achieving the overall goals of the program as planned.

What GAO Recommends:

We are recommending that DOD develop a comprehensive approach by 
revising its plan to (1) establish deadlines for completing its site 
inventory and initial evaluations, (2) reassess the timetable proposed 
for completing its risk assessment reevaluations, and (3) establish 
service-specific targets. We are also recommending that after DOD 
revises its plan, it should work with the Congress to develop budget 
proposals that will allow timely completion of cleanup activities.

www.gao.gov/cgi-bin/getrpt?GAO-04-147.

To view the full product, including the scope and methodology, click 
on the link above. For more information, contact Anu K. Mittal at 
(202) 512-3841 or mittala@gao.gov.

[End of section]

Contents:

Letter: 

Results in Brief: 

Background: 

DOD Has Made Limited Progress in Its Program to Identify, Assess, and 
Clean Up Potentially Contaminated Sites: 

DOD Does Not Have a Complete and Viable Plan for Assessing and Cleaning 
Up Potentially Contaminated Sites: 

Conclusions: 

Recommendations: 

Agency Comments: 

Appendixes:

Appendix I: Safety, Environmental, and Human Health Risks : 

Appendix II: Additional Details on Our Scope and Methodology: 

Appendix III: Comments from the Department of Defense: 

Appendix IV: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

Acknowledgments: 

Tables: 

Table 1: Distribution of Military Munitions Response Program Sites by 
Service: 

Table 2: Munitions Constituents of Greatest Concern: 

Table 3: Potential Effects of the Munitions Constituents Closely 
Associated with Military Munitions: 

Table 4: Districts Visited during Review: 

Figures: 

Figure 1: Distribution of 2,307 Suspected Military Munitions Response 
Program Sites Identified by DOD: 

Figure 2: Military Munitions Response Program Site Inventory (2,307 
Sites): 

Figure 3: Military Munitions Response Program Sites Requiring Further 
Action: 

Figure 4: Examples of Cleanup Actions at Military Munitions Response 
Program Sites: 

Abbreviations: 

DOD: Department of Defense:

Corps: U.S. Army Corps of Engineers:

CERCLA: Comprehensive Environmental Response, Compensation, and 
Liability Act of 1980:

Letter December 19, 2003:

The Honorable John D. Dingell: 
Ranking Minority Member: 
Committee on Energy and Commerce: 
House of Representatives:

Dear Mr. Dingell:

Over 15 million acres in the United States are known to be or are 
suspected of being contaminated with military munitions, which include 
unexploded ordnance, discarded military munitions, and munitions 
constituents such as propellants or other chemicals.[Footnote 1] These 
sites, which are no longer in use, include closed ranges on active 
installations, ranges on military installations that are being closed 
(closing sites), and formerly used defense sites.[Footnote 2] Much of 
the land on which these sites are located has been or will be converted 
to nonmilitary uses such as farming, residential or commercial 
development, and recreation. The Department of Defense (DOD) estimates 
that identifying, assessing, and cleaning up contamination from 
military munitions at such sites will cost from $8 billion to $35 
billion and could take more than 75 years. Within DOD, cleanup of sites 
on active or closing installations is the responsibility of the 
military service--Air Force, Army, Navy, or Marine Corps--that 
currently owns the land. The U.S. Army Corps of Engineers (Corps) is 
responsible for executing the cleanup of formerly used defense sites.

Military munitions can pose risks to public safety, human health, and 
the environment. Unexploded ordnance poses a potential explosive hazard 
and risk of personal injury to those who encounter it. The 
Environmental Protection Agency, in September 2001, using a DOD 
database and other sources, identified at least 126 incidents involving 
civilians who were 
exposed to unexploded ordnance over the past 83 years, which resulted 
in 65 fatalities and 131 injuries.[Footnote 3] The risk of such 
exposures is expected to grow with an increase in development and 
recreational activities on land once used by the military for munitions 
related activities (e.g., live fire testing and training). In addition, 
human exposure to munitions constituents such as trinitrotoluene (TNT) 
and perchlorate may cause long-term health problems, such as cancer and 
damage to the heart, liver, and kidneys. However, the link between such 
constituents and any potential health effects is not always clear and 
continues to be studied. (See app. I for a list of common munitions 
constituents and potential health effects.) Military munitions may also 
pose an environmental risk because their use and disposal may release 
constituents that could contaminate soil, groundwater, and surface 
water. Former ranges on which munitions-related activities were 
conducted and which are known or suspected to contain military 
munitions are in a variety of locations, including near ecologically 
sensitive wetlands, surface waters, and floodplains. While many 
constituents have been an environmental concern to DOD for more than 20 
years, the current understanding of the causes, distribution, and 
potential impact of constituent releases into the environment remains 
limited. The nature of these impacts, and whether they pose an 
unacceptable risk to human health and the environment, depend upon the 
dose, duration, and pathway of exposure, as well as the sensitivity of 
the exposed populations. Until recently, DOD has focused primarily on 
mitigating the public safety risk associated with unexploded ordnance, 
but it is now giving additional attention to environmental and health 
concerns posed by munitions constituents.

Under the Defense Environmental Restoration Program, established in 
1986, DOD is required to identify, investigate, and clean up 
environmental contamination and other hazards at active and closing 
installations, as well as at formerly used defense sites.[Footnote 4] 
The program is organized into three categories that focus on DOD's 
primary goals: (1) identification and cleanup of contamination from 
hazardous substances, pollutants, and contaminants; (2) demolition and 
removal of unsafe buildings and structures; and (3) correction of other 
environmental damage, such as detection and disposal of military 
munitions. Most of DOD's past focus had been on identifying and 
cleaning up contamination from hazardous substances. To better focus 
DOD's efforts on identifying, assessing, and cleaning up sites 
containing military munitions, DOD established the Military Munitions 
Response program in September 2001. Subsequently, in December 2001, the 
Congress passed the National Defense Authorization Act for Fiscal Year 
2002, which among other things, required DOD to develop an initial 
inventory of sites that are known or suspected to contain military 
munitions and a comprehensive plan for cleaning up these sites. Of the 
$1.9 billion budgeted by DOD for environmental cleanup in fiscal year 
2002, approximately $113 million was designated for sites with military 
munitions. In fiscal years 2003 and 2004, DOD designated approximately 
$115 million and $89 million, respectively, for sites with military 
munitions.

In deciding what actions, if any, are needed to clean up a site 
identified as potentially contaminated with military munitions, DOD 
generally follows the process established for cleanup actions under the 
Comprehensive Environmental Response, Compensation, and Liability Act 
of 1980 (CERCLA). CERCLA, as amended, governs the cleanup of hazardous 
waste sites, including contamination on military installations. After 
identifying a potential military munitions site, the appropriate DOD 
military service or the Corps performs a preliminary assessment, during 
which DOD determines if military munitions may be present and if 
further study or cleanup action is needed. If necessary, DOD may 
conduct a site investigation to better identify the types and extent of 
potential hazards present. For specific areas suspected to contain 
military munitions, DOD surveys the land and evaluates and selects 
alternatives, in consultation with stakeholders, for addressing the 
potential hazards. These cleanup alternatives could include removing 
the military munitions, limiting public contact with the site through 
signs and fences, or determining that no further action with regard to 
the site is warranted. After implementing the chosen cleanup 
alternative, DOD periodically monitors the site and reviews the 
alternative chosen to ensure its continued effectiveness.

Because of the magnitude of DOD's cleanup effort, both in terms of cost 
and affected acreage, as well as the significant public safety, human 
health, and environmental risks posed by military munitions, you asked 
us to evaluate (1) DOD's progress in implementing its program to 
identify, assess, and clean up sites containing military munitions and 
(2) DOD's plans to clean up remaining sites in the future.

To evaluate DOD's progress in identifying, assessing, and cleaning up 
military munitions, we reviewed and analyzed DOD's database for sites 
identified under the Military Munitions Response program as of 
September 30, 2002, the end of their most recent reporting cycle. We 
assessed the reliability of relevant fields in this database by 
electronically testing for obvious errors in accuracy and completeness, 
reviewing information about the data and the system that produced them, 
and interviewing agency officials knowledgeable about the data. When we 
found inconsistencies, we worked with DOD and military service 
officials to correct the discrepancies before conducting our analyses. 
We determined that the data needed for our analyses were sufficiently 
reliable for the purposes of our report. We also reviewed project files 
from 38 of the 75 sites where, according to DOD's database, cleanup 
action is either complete or under way.[Footnote 5] These files 
represented 52 percent of the 23 sites with a completed cleanup action 
and 50 percent of the 52 sites with a cleanup action under way. We used 
our file reviews to develop case examples of changes in estimated costs 
to complete cleanup over time and cleanup actions taken. These case 
examples are for illustration only. We conducted our work between 
November 2002 and October 2003 in accordance with generally accepted 
government auditing standards. More detail on the scope and methodology 
of our review is presented in appendix II.

Results in Brief:

DOD has made limited progress in its program to identify, assess, and 
clean up sites that may be contaminated with military munitions. While 
DOD had identified 2,307 potentially contaminated sites as of September 
2002, DOD officials said that the department is continuing to identify 
additional sites and is not likely to have a firm inventory for several 
years. For example, the Army had only surveyed and identified closed 
ranges on 14 percent of its active installations. Of the total 2,307 
identified sites, DOD had initially determined that 362 sites required 
no further study or cleanup action because there was little or no 
evidence of military munitions. However, because these sites are 
formerly used defense sites, and the initial evaluations conducted were 
less comprehensive than for other sites in the program, the Corps has 
recently decided that some of these sites need to be reassessed to 
determine if cleanup is needed. For 1,387 sites, DOD either has not 
begun or not completed its initial evaluation or has determined that 
further study is needed. DOD has completed its assessment of 558 sites, 
finding that 475 sites required no cleanup action. The remaining 83 
sites required some cleanup action, of which DOD has completed 23.

DOD does not yet have a complete and viable plan for guiding its 
remaining clean up activity at potentially contaminated sites. DOD's 
plan is lacking in several respects, including the following:

* Essential data for DOD's plan may take years to develop. For example, 
not all the potential sites have been identified, and DOD has set no 
deadline for doing so. Because the inventory serves as the basis for 
other elements of the plan, such as budget development, the sites must 
first be identified before DOD can have a reasonable picture of the 
magnitude of the challenge ahead and plan accordingly. Furthermore, DOD 
intends to use new procedures to reassess the relative risk for the 
1,387 sites needing further study, but DOD is not scheduled to complete 
these reassessments until 2012. The resulting relative risk assessments 
will be a key component in determining cleanup priorities. Until the 
assessments are complete, DOD cannot be assured that it is using its 
limited resources to clean up those sites that pose the greatest risk 
to public safety, human health, and the environment.

* DOD's plan relies on preliminary cost estimates that may change 
significantly and reallocated funds from other programs that may not be 
available as anticipated. For example, at Camp Maxey, Texas, the 
estimated cost for cleanup in 2000 was $45 million. However, in DOD's 
Fiscal Year 2002 Defense Environmental Restoration Program Annual 
Report to Congress, the estimated cleanup cost had grown to $130 
million. A June 2003 cost estimate showed a decrease in total costs to 
$73 million. Furthermore, DOD expects that as other DOD hazardous 
substance cleanup efforts are completed, increased funds will become 
available for munitions cleanup. However, not all of these other DOD 
cleanup efforts are on schedule. For example, between fiscal years 2001 
and 2002, the schedule to complete hazardous, toxic, and radioactive 
waste cleanup at formerly used defense sites had slipped by more than 6 
years. As a result, anticipated funds from completing cleanups at these 
sites may not become available until 2021 or later.

* DOD's plan does not yet contain goals or measures for site assessment 
and cleanup. In September 2003, 2 years after the establishment of the 
Military Munitions Response program, DOD established a working group 
tasked with developing agencywide program goals and performance 
measures. However, the working group is not expected to establish 
service-specific targets, therefore DOD will have limited assurance 
that the services and the Corps are (1) making progress in cleaning 
their Military Munitions Response program sites and (2) are 
contributing to achieving the overall goals of the program as planned.

We are recommending that DOD revise its plan to (1) establish deadlines 
for completing its site inventory and initial evaluations; (2) reassess 
the timetable proposed for completing its reevaluation of sites, using 
the new risk assessment procedures; and (3) establish interim goals 
based on criteria, such as relative risk levels or cleanup phases, for 
the services and the Corps to target. We are also recommending that 
after DOD revises its comprehensive plan, it should work with the 
Congress to develop realistic budget proposals that will allow DOD to 
complete cleanup activities in a timely manner.

In commenting on a draft of this report, DOD concurred with our 
recommendation to work with the Congress to develop realistic budget 
proposals that will allow DOD to complete cleanup activities on 
potentially contaminated sites in a timely manner. In addition, DOD 
partially concurred with our recommendations to (1) establish deadlines 
to complete the identification process and initial evaluations; (2) 
reassess the timetable proposed for completing the reevaluation of 
sites, using the new risk assessment procedure; and (3) establish 
interim goals for cleanup phases for the services and the Corps to 
target. DOD also suggested some technical changes throughout the report 
that we have incorporated as appropriate. DOD's comments appear in 
appendix III.

Background:

To better focus its munitions cleanup activities under the Defense 
Environmental Restoration Program, DOD established the Military 
Munitions Response program in September 2001. The objectives of the 
program include compiling a comprehensive inventory of military 
munitions sites, developing a prioritization protocol for sequencing 
work at these sites, and establishing program goals and performance 
measures to evaluate progress. In December 2001, shortly after DOD 
established the program, the Congress passed the National Defense 
Authorization Act for Fiscal Year 2002, which among other things, 
required DOD to develop an initial inventory of sites that are known or 
suspected to contain military munitions by May 31, 2003, and to provide 
annual updates thereafter. DOD 
provides these updates as part of its Defense Environmental Restoration 
Program Annual Report to Congress.[Footnote 6]

To clean up potentially contaminated sites, DOD generally follows the 
process established for cleanup actions under CERCLA, which includes 
the following phases and activities:

* Preliminary Assessment--Determine whether a potential military 
munitions hazard is present and whether further action is needed.

* Site Investigation--Inspect the site and search historical records to 
confirm the presence, extent, and source(s) of hazards.

* Remedial Investigation/Feasibility Study or Engineering Evaluation/
Cost Analysis--Determine the nature and extent of contamination; 
determine whether cleanup action is needed and, if so, select 
alternative cleanup approaches. These could include removing the 
military munitions, limiting public contact with the site through signs 
and fences, or determining that no further action is warranted.

* Remedial Design/Remedial Action--Design the remedy and perform the 
cleanup or other response.

* Long-Term Monitoring--Periodically review the remedy in place to 
ensure its continued effectiveness, including checking for unexploded 
ordnance and public education.

For sites thought to be formerly used defense sites, the Corps also 
performs an initial evaluation prior to the process above. In this 
initial evaluation, called a preliminary assessment of eligibility, the 
Corps determines if the property is a formerly used defense site. The 
Corps makes this determination based on whether there are records 
showing that DOD formerly owned, leased, possessed, operated, or 
otherwise controlled the property and whether hazards from DOD's use 
are potentially present. If eligible, the site then follows the CERCLA 
assessment and cleanup process discussed earlier. When all of these 
steps have been completed for a given site and long-term monitoring is 
under way, or it has been determined that no cleanup action is needed, 
the services and the Corps consider the site to be "response 
complete.":

DOD Has Made Limited Progress in Its Program to Identify, Assess, and 
Clean Up Potentially Contaminated Sites:

While DOD has identified 2,307 potentially contaminated sites as of 
September 2002, the department continues to identify additional sites, 
and it is not likely to have a firm inventory for several years (see 
table 1 for the distribution of these sites by service). Of the 
identified sites, DOD determined that 362 sites require no further 
study or cleanup action because it found little or no evidence of 
military munitions. For 1,387 sites, DOD either has not begun or not 
completed its initial evaluation, or has determined that further study 
is needed. DOD has completed an assessment of 558 sites, finding that 
475 of these required no cleanup action. The remaining 83 sites require 
some cleanup action, of which DOD has completed 23.

Table 1: Distribution of Military Munitions Response Program Sites by 
Service:

Responsible service: Army; 
Closed ranges: on active installations: 105; 
Closing ranges on base: realignment: and closure installations[A]: 58; 
Formerly used defense sites: N/A; 
Total: 163.

Responsible service: Navy; 
Closed ranges: on active installations: 196; 
Closing ranges on base: realignment: and closure installations[A]: 16; 
Formerly used defense sites: N/A; 
Total: 212.

Responsible service: Air Force; 
Closed ranges: on active installations: 241; 
Closing ranges on base: realignment: and closure installations[A]: 0; 
Formerly used defense sites: N/A; 
Total: 241.

Responsible service: Army Corps of Engineers; 
Closed ranges: on active installations: N/A; 
Closing ranges on base: realignment: and closure installations[A]: N/A; 
Formerly used defense sites: 1,691; 
Total: 1,691.

Responsible service: Total; 
Closed ranges: on active installations: 542; 
Closing ranges on base: realignment: and closure installations[A]: 74; 
Formerly used defense sites: 1,691; 
Total: 2,307. 

Source: DOD.

[A] The base realignment and closure program is a DOD program governing 
the scheduled closing of DOD sites and includes a focus on compliance 
and cleanup efforts at military installations undergoing closure or 
realignment.

[End of table]

DOD had identified 2,307 sites potentially contaminated with military 
munitions, as of September 30, 2002, and it continues to identify 
additional sites. (Fig. 1 shows the distribution of these sites by 
state.) DOD officials acknowledge that they will not have a firm 
inventory for several years. For example, as of September 30, 2002, the 
Army had not completed a detailed inventory of closed ranges at 86 
percent of active installations; the 105 sites identified by the Army 
represented sites on only 14 percent of the Army's installations. The 
Army is working to identify sites on the remaining installations and 
plans to have 40 percent of its installations accounted for by the next 
Defense Environmental Restoration Program Annual Report to Congress in 
spring 2004. Similarly, the Corps recently identified 75 additional 
sites to be included in the inventory as a result of its effort to 
reevaluate sites previously determined not to need further action after 
the initial evaluation. Because not all of the sites have been 
identified, DOD has only a preliminary idea of the extent of cleanup 
that will be needed. To help complete the identification process, DOD 
has developed a Web site that stakeholders, such as states, tribes, and 
federal regulators, can use to suggest additions and revisions to the 
inventory. DOD plans to update the inventory in its future Defense 
Environmental Response Program Annual Report to Congress using, in 
part, the information collected from this Web site.

Figure 1: Distribution of 2,307 Suspected Military Munitions Response 
Program Sites Identified by DOD:

[See PDF for image]

[End of figure]

Of the 2,307 sites identified, DOD has determined, based on an initial 
evaluation, that 362 do not require any further DOD action (see fig. 
2). However, these 362 sites are formerly used defense sites, and the 
Corps' evaluation of these sites was less comprehensive than other 
evaluations conducted by DOD under the CERCLA process.[Footnote 7] In 
making its determinations, the Corps conducted a preliminary assessment 
of eligibility and determined that the potential for military munitions 
hazard was not present. As a result of this determination, the sites 
were not evaluated further. The Corps is in the process of reviewing 
these determinations with local stakeholders to ensure that there was a 
sound basis for the original determination. It has recently decided 
that some of these sites need to be reassessed to determine if cleanup 
is needed.

Figure 2: Military Munitions Response Program Site Inventory (2,307 
Sites):

[See PDF for image]

[End of figure]

Of the 1,945 sites that required further action, DOD has either not 
begun or has not completed its study, or has determined that further 
study is needed, for 1,387 sites (see fig. 3). For example, 241 Air 
Force and 105 Army sites at closed ranges on active installations have 
not been evaluated. For other sites, primarily formerly used defense 
sites, DOD has completed its initial evaluation and determined that 
further investigation is needed.

Figure 3: Military Munitions Response Program Sites Requiring Further 
Action:

[See PDF for image]

[End of figure]

DOD has completed its assessment of 558 sites, nearly all of which are 
ranges on formerly used defense sites or closing installations, and 
determined that no cleanup action was needed for 475; the remaining 83 
sites required some level of cleanup action. Of the 83 sites that 
required cleanup action, 60 have cleanup action planned or under way 
and 23 are complete. Actions taken at these 23 sites have been varied 
and include surface and subsurface removal of munitions, and 
institutional controls, such as the posting of warning signs or 
educational programs. See figure 4 for examples of cleanup actions at 
Military Munitions Response program sites.

Figure 4: Examples of Cleanup Actions at Military Munitions Response 
Program Sites:

[See PDF for image]

[End of figure]

DOD Does Not Have a Complete and Viable Plan for Assessing and Cleaning 
Up Potentially Contaminated Sites:

In DOD's Fiscal Year 2002 Defense Environmental Restoration Program 
Annual Report to Congress, DOD identified several elements integral to 
the success of the Military Munitions Response program: compiling a 
comprehensive inventory of sites; developing a new procedure to assess 
risk and prioritize sites; ensuring proper funding for accurate 
planning and program execution; and establishing program goals and 
performance measures. While DOD has established the basic framework to 
address these elements, DOD's plan is lacking in three key respects. 
First, essential data for DOD's plan may take years to develop. Second, 
DOD's plan is contingent upon preliminary cost estimates that may 
change significantly and a reallocation of funds that may not be 
available. Finally, DOD's plan lacks specific goals and performance 
measures to track progress.

Essential Data for DOD's Plan May Take Years to Develop:

DOD's inventory of potentially contaminated sites serves as the basis 
for other elements of its plan, yet this inventory is incomplete. DOD's 
inventory of 2,307 sites includes only those identified through 
September 30, 2002. As previously discussed, according to DOD 
officials, this inventory is not final; and DOD has not set a deadline 
to complete it. According to DOD, most of the ranges on formerly used 
defense sites and on military installations that are being closed have 
been identified and are being assessed or cleanup action is under way. 
The ranges yet to be identified are primarily located on active 
installations. For example, the Army, as of September 30, 2002, had 
completed a detailed inventory of potentially contaminated sites on 
only 14 percent of its active installations. Because the inventory 
serves as the basis for other elements of the plan, such as budget 
development and establishing program goals, most sites must first be 
identified in order for DOD to have a reasonable picture of the 
magnitude of the challenge ahead and to plan accordingly.

Furthermore, DOD intends to use a new procedure to reassess the 
relative risk and priority for 1,387 sites needing further study and 
any new sites identified as part of the continuing inventory effort, 
but DOD is not scheduled to complete these reassessments until 2012. 
DOD recently developed this procedure for assigning each site in the 
inventory a priority level for cleanup action, based on the potential 
risk of exposure resulting from past munitions-related 
activities.[Footnote 8] Under this procedure, DOD plans to reevaluate 
the 1,387 sites for three potential hazard types: (1) explosive hazards 
posed by unexploded ordnance and discarded military munitions, (2) 
hazards associated with the effects of chemical warfare material, and 
(3) chronic health and environmental hazards posed by munitions 
constituents. Once assessed, each site's relative risk-based priority 
will be the primary factor determining future cleanup order.[Footnote 
9] DOD plans to require assessment of each site on the inventory for at 
least one of these hazard types by May 31, 2007, and for all three 
hazard types by May 31, 2012. Until all three hazard types are fully 
assessed, DOD cannot be assured that it is using its limited resources 
to clean up those sites that pose the greatest risk to safety, human 
health, and the environment.

DOD's Plan Relies on Preliminary Cost Estimates That Can Change 
Significantly and a Reallocation of Funds That May Not Be Available:

DOD's plan to identify and address military munitions sites relies on 
preliminary cost estimates that were developed using incomplete 
information. The majority of the site estimates were developed using a 
cost-estimating tool that incorporates variables, such as the affected 
acreage; types, quantity, and location of munitions; and future land 
use. These variables can have a significant impact on cost, according 
to DOD. However, detailed site-specific information was not available 
for all sites. For example, as mentioned earlier, 105 Army and 241 Air 
Force sites at closed ranges on active installations have not had an 
initial evaluation. As a result, the Air Force used estimated, not 
actual, acreage figures, including assumptions regarding the amount of 
acreage known or suspected of containing military munitions when 
preparing its cost estimates. Because changes in acreage can greatly 
impact the final cost of site assessment and cleanup action, the 
estimates produced for these sites are likely to change when estimates 
based on more complete data or the actual cost figures are known. The 
following examples illustrate how cost estimates can change during the 
life of the cleanup as better information becomes available:

* Camp Maxey was a 41,128-acre Army post in Texas used from 1942 to 
1945 for training infantry in live fire of weapons including pistols, 
rifles, machine guns, mortars, bazookas, and antitank guns. The Corps 
confirmed the presence of unexploded ordnance, and in 2000, estimated 
the cleanup cost for the land at $45 million. In DOD's Fiscal Year 2002 
Defense Environmental Restoration Program Annual Report to Congress, 
the estimated total cost of cleanup had grown to $130 million. A June 
2003 cost estimate showed a decrease in total cost to about $73 
million, but still 62 percent more than the original cost estimate in 
2000. The main factors behind these shifting cost estimates, according 
to the project manager, were changes in the acreage requiring 
underground removal of ordnance and changes in the amount of ordnance 
found.

* Fort McClellan, Alabama, was among the installations recommended for 
closure under DOD's base realignment and closure effort in 1995. This 
site had been used since the Spanish American War (1898), including as 
a World War I and II training range upon which grenades, mortars, and 
antiaircraft guns, were used. An April 2002 cost estimate prepared for 
one site on Fort McClellan requiring cleanup showed the anticipated 
cost of clearing the land of munitions as $11,390,250. A subsequent 
cost estimate prepared in May 2003, showed the cost of clearing this 
site at $22,562,200. According to the Army, the increase in estimated 
costs reflects a change in the final acreage recommended for clearance 
and the extent to which buried munitions would be searched for and 
removed.

Moreover, until DOD and stakeholders agree upon a cleanup action, it is 
often difficult for them to predict the extent of the cleanup action 
required and cost estimates can change because of the cleanup action 
implemented at the site. For example, at the former Indian Rocks Range 
in Pinellas County, Florida, the Corps identified 178 acres that were 
used as an air-to-ground and antiaircraft gunnery range impact area 
from 1943 to 1947. Munitions used on this shoreline site included 
bullets, aircraft rockets, and small practice bombs. Much of the land 
had been developed, limiting the Corps ability to pursue the 
alternative of searching for and removing buried munitions. In 1995, 
the Corps analyzed a number of alternatives to address munitions 
contamination at the site and developed cost estimates for these 
alternatives. However, because the development was largely composed of 
hotels, condominiums, and single-family residences, the Corps chose the 
alternative of conducting a community education program. The total cost 
of this alternative was $21,219. If the Corps had decided to search for 
and remove the remaining munitions at this site, the cost could have 
approached $3 million, according to the prepared cost analysis.

Furthermore, at an annual funding level of approximately $106 million 
(the average amount budgeted or spent annually from fiscal year 2002 to 
fiscal year 2004), cleanup at the remaining munitions sites in DOD's 
current inventory could take from 75 to 330 years to complete.[Footnote 
10] To reduce this timeline, DOD expects to use funds currently 
designated for hazardous, toxic, and radioactive waste cleanup after 
these cleanups are complete. However, these other cleanup efforts are 
not on schedule in all of the services and the Corps. For example, 
between fiscal years 2001 and 2002, the schedule to complete hazardous 
substance cleanups at formerly used defense sites slipped by more than 
6 years. As a result, anticipated funds from completing hazardous 
substance cleanups at these sites may not become available to clean up 
munitions sites until 2021 or later. This delay is significant because, 
as of September 30, 2002, formerly used defense sites account for over 
85 percent of DOD's total anticipated costs to complete munitions 
cleanup, yet the Corps receives about 66 percent of the total munitions 
cleanup funds. Delays in the availability of anticipated funding from 
hazardous, toxic, and radioactive waste sites could greatly impair 
DOD's ability to accurately plan for and make progress in cleaning up 
Military Munitions Response sites.

DOD's Plan Does Not Contain Goals or Measures for Site Assessment and 
Cleanup:

DOD has yet to establish specific program goals and performance 
measures in its plan. Specifically, DOD has yet to identify interim 
milestones and service-specific targets that will help it achieve 
overall program objectives. In September 2003, 2 years after the 
Military Munitions Response program was initiated, DOD established a 
workgroup tasked with recommending overall goals and measures for the 
program, near-term goals and measures to support its budgeting cycle 
for fiscal years 2006 to 2011, and a program completion date goal. DOD 
has asked the workgroup to accomplish these objectives by the end of 
calendar year 2003. According to DOD, these goals and measures, when 
developed, should help DOD track the progress of sites through the 
cleanup phases, and ensure that DOD responds to the sites with the 
greatest risk first. While it is important for DOD to establish goals 
and measures that will track overall program progress and ensure that 
the riskiest sites are assessed and cleaned up first, DOD will not have 
the information it needs to do this until 2012. As we discussed 
earlier, because DOD plans to reassess potentially contaminated sites 
using a new risk-based prioritization procedure, until these 
reassessments are complete, DOD will not have complete information on 
which of the sites pose the greatest risk. Consequently, goals and 
measures established in 2003 will be of limited use and may not reflect 
DOD's true priorities.

Moreover, according to DOD, the program goals and measures to be 
established by the workgroup will be agencywide, and not service-
specific, although it may establish interim goals for the services and 
Corps. However, DOD has not yet decided what these goals will be based 
on, such as relative risk levels or cleanup phases. In the absence of 
service-specific goals, each service has implemented the program with a 
different level of effort. For example, the Air Force has not budgeted 
any funds to assess and clean up munitions sites, nor do they plan to 
do so through fiscal year 2004. As mentioned before, the Air Force also 
has not conducted initial evaluations on any of its 241 sites and has 
little site-specific information from which to create a reliable cost 
estimate. In contrast, the Army has undertaken a comprehensive 
inventory of ranges that will result in detailed site information, such 
as acreage and the types, quantity, and location of munitions, that can 
be used to, among other things, create more robust cost estimates. The 
Army has completed this comprehensive inventory on 14 percent of its 
installations as of September 2002, and has set a goal to complete this 
effort by December 2003. This uneven effort in implementing the 
Military Munitions Response program could continue through various 
program phases, such as preliminary assessments and site 
investigations, making it difficult for DOD to assure that each of the 
services and the Corps are making progress in cleaning up their 
potentially contaminated sites and achieving the overall goals of the 
program.

Conclusions:

DOD has made limited progress in identifying, assessing, and cleaning 
up sites known or suspected to contain military munitions. 
Accomplishing this long and arduous task in a timely manner that best 
protects public safety, human health, and the environment will require 
a comprehensive approach that includes effective planning and 
budgeting. However, DOD lacks the data needed--such as a complete 
inventory, up-to-date prioritization, and reliable cost estimates--to 
establish a comprehensive approach. Without such an approach for 
identifying, assessing, and cleaning up potentially contaminated sites, 
DOD will be hampered in its efforts to achieve the program's 
objectives.

Recommendations:

To ensure that DOD has a comprehensive approach for identifying, 
assessing, and cleaning up military munitions at potentially 
contaminated sites, we recommend that the Secretary of Defense revise 
DOD's plan to:

* establish deadlines to complete the identification process and 
initial evaluations so that it knows the universe of sites that needs 
to be assessed, prioritized, and cleaned up;

* reassess the timetable proposed for completing its reevaluation of 
sites using the new risk assessment procedures so that it can more 
timely establish the order in which sites should be assessed and 
cleaned up, thereby focusing on the riskiest sites first; and:

* establish interim goals for cleanup phases for the services and Corps 
to target.

In addition, after DOD has revised its comprehensive plan, we recommend 
that it work with the Congress to develop realistic budget proposals 
that will allow DOD to complete cleanup activities on potentially 
contaminated sites in a timely manner.

Agency Comments:

We provided DOD with a draft of this report for review and comment. In 
its comments, DOD concurred with our recommendation to work with the 
Congress to develop realistic budget proposals that will allow it to 
complete cleanup activities on potentially contaminated sites in a 
timely manner. DOD partially concurred with our recommendation to 
establish deadlines to complete the identification process and initial 
evaluations so that it knows the universe of sites. DOD stated that the 
military services and the Corps have been working, and will continue to 
work, with stakeholders to identify additional sites and add these 
sites to the inventory as appropriate. DOD also stated that it believes 
most of the remaining sites to be identified are located on active 
installations still under DOD control. While we have clarified this 
point in the report, we note that the number of formerly used defense 
sites identified has increased by about 75 sites since the current 
inventory was completed and an unknown but possibly significant number 
of sites may be added as the Army completes identification of sites on 
86 percent of its installations. These sites and many others still need 
to undergo initial evaluations. Consequently, we continue to believe 
that it is important for DOD to establish deadlines to complete the 
identification and initial evaluations for all of the sites in its 
inventory in order to establish a reasonable approximation of the 
future workload it faces.

DOD also partially concurred with our recommendation to reassess the 
timetable proposed for completing the reevaluation of sites using the 
new risk assessment procedure. DOD stated that the military services 
and the Corps would need sufficient time and resources to complete each 
risk assessment. However, DOD stated that it had recently established 
2010 as the goal for completing the prioritization of sites, instead of 
2012 which was the original goal set forth in the proposed regulation. 
While we agree that this is a step in the right direction, DOD should 
continue to look for other opportunities to accelerate these 
inspections and the prioritization of sites to help ensure that 
resources are being targeted toward the riskiest sites first.

Finally, DOD partially concurred with our recommendation to establish 
interim goals for cleanup phases for the services and the Corps. DOD 
stated that it has established interim goals of completing all 
preliminary assessments by 2007 and all site inspections by 2010, and 
that these goals apply to all military components, thereby eliminating 
the need for separate service-specific goals. However, DOD noted that 
it is working with each military service to establish additional goals 
and measures to gauge progress. While we are encouraged by DOD's 
efforts in this area, we believe that service-specific goals and 
measures, as they apply to the cleanup phases, will be essential for 
DOD to ensure that each of the services and the Corps are making 
progress in cleaning up potentially contaminated sites and achieving 
the overall goals of the program.

In addition to its written comments on our draft report, DOD also 
provided a number of technical comments and clarifications, which we 
have incorporated in this report as appropriate. DOD's written comments 
appear in appendix III.

As agreed with your office, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies of this report 
to the appropriate congressional committees; the Secretary of Defense; 
Director, Office of Management and Budget; and other interested 
parties. We will also make copies available to others upon request. In 
addition, the report will be available at no charge on the GAO Web site 
at [Hyperlink, http://www.gao.gov] http://www.gao.gov.

If you or your staffs have any questions, please call me or Edward 
Zadjura at (202) 512-3841. Key contributors to this report are listed 
in appendix IV.

Sincerely yours,

Anu K. Mittal: 
Director, Natural Resources and Environment:

Signed by Anu K. Mittal: 

[End of section]

Appendixes: 

Appendix I: Safety, Environmental, and Human Health Risks:

Military munitions can pose risks to public safety, human health, and 
the environment. In terms of the explosive hazard, unexploded ordnance 
poses an immediate safety risk of physical injury to those who 
encounter it. Military munitions may also pose a health and 
environmental risk because their use and disposal may release 
constituents that may contaminate soil, groundwater, and surface water. 
Ranges contaminated with military munitions, especially those located 
in ecologically sensitive wetlands and floodplains, may have soil, 
groundwater, and surface water contamination from any of the over 200 
chemical munitions constituents that are associated with the ordnance 
and their usage. When exposed to some of these constituents, humans 
potentially face long-term health problems, such as cancer and damage 
to heart, liver, and kidneys. Of these constituents, there are 20 that 
are of greatest concern due to their widespread use and potential 
environmental impact. Table 2 contains a listing of these munitions 
constituents, and table 3 describes some of the potential health 
effects of five of them.

Table 2: Munitions Constituents of Greatest Concern:

Type of munitions constituents: 

Trinitrotoluene (TNT) 
1,3- Dintrobenzene 
Nitrobenzene 
2,4-Dinitrotoluene 
2-Amino-4,6- Dinitrotoluene 
2-Nitrotoluene 
2,6-Dinitrotoluene 4-Amino-2,6- Dinitrotoluene 
3-Nitrotoluene 
Octahydro-1,3,5,7-tetranitro-1,3,5,7- tetrazocine (HMX) 
2,4-Diamino-6-nitrotoluene 
4-Nitrotoluene 
Hexahydro- 1,3,5-trinitro-1,3,5-triazine (RDX) 
2,6-Diamino-4-nitrotoluene 
Methylnitrite 
Perchlorate 
1,2,3-Propanetriol trinitrate (Nitroglycerine) 
Pentaerythritoltetranitrate (PETN) 
1,3,5- Trinitrobenzene 
N,2,4,6-Tetranitro-N-methylaniline (Tetryl) (White Phosphorus). 

Source: DOD, Fiscal Year 2002 Defense Environmental Restoration Program 
Annual Report to Congress.

[End of table]

While many of these constituents have been an environmental concern to 
the Department of Defense (DOD) for more than 20 years, the current 
understanding of the causes, distribution, and potential impact of 
constituent releases into the environment remains limited. The nature 
of these impacts, and whether they pose an unacceptable risk to human 
health and the environment, depend upon the dose, duration, and pathway 
of exposure, as well as the sensitivity of the exposed populations. 
However, the link between such constituents and any potential health 
effects is not always clear and continues to be studied.

Table 3: Potential Effects of the Munitions Constituents Closely 
Associated with Military Munitions:

Constituent: TNT; Potential toxicity/effects: Possible human 
carcinogen, targets liver, skin irritations, and cataracts.

Constituent: RDX; Potential toxicity/effects: Possible human 
carcinogen, prostate problems, nervous system problems, nausea and 
vomiting. Laboratory exposure to animals indicates potential organ 
damage.

Constituent: HMX; Potential toxicity/effects: Animal studies suggest 
potential liver and central nervous system damage.

Constituent: Perchlorate; Potential toxicity/effects: Exposure causes 
itching, tearing, and pain; ingestion may cause gastroenteritis with 
abdominal pain, nausea, vomiting, and diarrhea; systemic effects may 
follow and may include ringing of ears, dizziness, elevated blood 
pressure, blurred vision, and tremors. Chronic effects may include 
metabolic disorders of the thyroid.

Constituent: White Phosphorus; Potential toxicity/effects: 
Reproductive effects. Liver, heart, or kidney damage; death; skin 
burns, irritation of throat and lungs, vomiting, stomach cramps, 
drowsiness.

Source: Environmental Protection Agency, Handbook on the Management of 
Ordnance and Explosives at Closed, Transferring, and Transferred Ranges 
and Other Sites.

[End of table]

[End of section]

Appendix II: Additional Details on Our Scope and Methodology:

The objectives of our review were to evaluate (1) DOD's progress in 
implementing its program to identify, assess, and clean up sites 
containing military munitions and (2) DOD's plans to clean up remaining 
sites in the future. To evaluate DOD's progress in identifying, 
assessing, and cleaning up military munitions sites, we analyzed data 
provided to us by DOD's Office of the Deputy Undersecretary of Defense 
(Installations and Environment) Cleanup Office from its database for 
sites identified under the Military Munitions Response program. This 
information includes the status of studies or cleanup actions, as well 
as cost estimates. The data are complete as of September 30, 2002, 
DOD's most recent reporting cycle, and were used to develop DOD's 
Fiscal Year 2002 Defense Environmental Restoration Program Annual 
Report to Congress. We also analyzed additional data on the status of 
studies or cleanup actions provided to us by the Army Corps of 
Engineers (the Corps) from its database of formerly used defense sites. 
We assessed the reliability of relevant fields in these databases by 
electronically testing for obvious errors in accuracy and completeness, 
reviewing information about the data and the system that produced them, 
and interviewing agency officials knowledgeable about the data. When we 
found inconsistencies, we worked with DOD and military service 
officials to correct the inconsistencies before conducting our 
analyses. We determined that the data needed for our review were 
sufficiently reliable for the purposes of our report.

We also reviewed 38 of 75 project files at seven Corps districts where, 
according to DOD's database, site cleanup action is either complete or 
under way. (See table 4 for a listing of these districts).

Table 4: Districts Visited during Review:

Corps district: Baltimore; Total number of sites: 2; Sites with 
cleanup completed: 1; Sites with cleanup under way: 1.

Corps district: Fort Worth; Total number of sites: 3; Sites with 
cleanup completed: 0; Sites with cleanup under way: 3.

Corps district: Honolulu; Total number of sites: 2; Sites with cleanup 
completed: 0; Sites with cleanup under way: 2.

Corps district: Huntsville; Total number of sites: 12; Sites with 
cleanup completed: 4; Sites with cleanup under way: 8.

Corps district: Jacksonville; Total number of sites: 8; Sites with 
cleanup completed: 2; Sites with cleanup under way: 6.

Corps district: Kansas City; Total number of sites: 4; Sites with 
cleanup completed: 3; Sites with cleanup under way: 1.

Corps district: Los Angeles; Total number of sites: 7; Sites with 
cleanup completed: 2; Sites with cleanup under way: 5.

Corps district: Total; Total number of sites: 38; Sites with cleanup 
completed: 12; Sites with cleanup under way: 26.

Source: GAO.

[End of table]

We selected these districts based on the number of sites where cleanup 
was completed or under way and the estimated cost to complete cleanup, 
with some consideration given for geographic distribution. These files 
represented 52 percent of the 23 sites with a completed cleanup action 
and 50 percent of the 52 sites with a cleanup action under way. We used 
our file reviews to develop case example of changes in estimated costs 
to complete cleanup over time and cleanup actions taken. These case 
examples are for illustration only.

To evaluate DOD's plans for addressing the remaining sites, we analyzed 
the plans, as well as the assumptions upon which those plans are based, 
including cost and projected completion dates. In addition, we reviewed 
policies and program guidance, analyzed financial data, and interviewed 
program managers in DOD and the military services and the Corps. We 
conducted our work between November 2002 and October 2003 in accordance 
with generally accepted government auditing standards.

[End of section]

Appendix III: Comments from the Department of Defense:

ACQUISITION, TECHNOLOGY AND LOGISTICS:

OFFICE OF THE UNDER SECRETARY OF DEFENSE:

3000 DEFENSE 
PENTAGON 
WASHINGTON, DC 20301-3000:

DEC 1 2003:

Ms. Anu Mittal:

Director 
Natural Resources and Environment 
U.S. General Accounting Office:

441 G Street N.W. 
Washington, DC 20548:

Dear Ms. Mittal:

This letter is the Department of Defense (DoD) response to the GAO 
draft report, "MILITARY MUNITIONS: DoD Needs to Develop a Comprehensive 
Approach for Cleaning Up Contaminated Sites," November 13, 2003 (GAO 
Code 360286/GAO-04-147).

The Department concurs with the GAO recommendation in the draft report 
to work with the Congress to develop realistic budget proposals that 
will allow DoD to complete cleanup activities on potentially 
contaminated sites in a timely manner. The Department partially:

concurs with GAO recommendations to (1) establish deadlines to complete 
the identification process and initial evaluations, (2) establish 
interim goals for cleanup phases for the Services and Corps to target, 
and (3) reassess the timetable proposed for completing the reevaluation 
of sites using the new risk assessment procedure. Enclosed are specific 
comments on each of these recommendations.

Additionally, after reviewing the final report, DoD has technical 
comments, which are also enclosed for your consideration.

Sincerely,

Philip W. Grone:

Principal Assistant Deputy Under Secretary of Defense (Installations 
& Environment):

Signed by Philip W. Grone: 

Enclosures: as stated:

GAO DRAFT REPORT - DATED NOVEMBER 13, 2003 GAO CODE 360286/GAO-04-147:

"MILITARY MUNITIONS: DoD Needs to Develop a Comprehensive Approach for 
Cleaning Up Contaminated Sites":

DEPARTMENT OF DEFENSE COMMENTS TO THE RECOMMENDATIONS:

RECOMMENDATION 1: The GAO recommended that the Secretary of Defense 
revise DoD's plan to establish deadlines to complete the identification 
process and initial evaluations so that it knows what the universe of 
sites is that needs to be assessed, prioritized, and cleaned up. (p. 
19/GAO Draft Report):

DOD RESPONSE: Partially concur. Over the last two years, DoD has been 
working with the Military Components to identify potential munitions 
response sites. Through the publicly available site of the Defense 
Environmental Network and Information Exchange (DENIX), DoD has shared 
the most recent inventory results and continues to solicit information 
from both the environmental regulatory community and public 
stakeholders to assist in site identification. This is an ongoing 
process that will likely continue throughout the early years of the 
program and is not dissimilar to DOD's traditional hazardous waste 
cleanup program where limited site discovery takes place to the 
present. DoD and the Military Components will continue to work with 
stakeholders to identify additional sites and add sites to the 
munitions response site inventory, as appropriate. Goals recently 
established for preliminary assessments and site inspections are 
sufficient to drive the program at this stage.

Additionally, the GAO report fails to differentiate between the action 
that DoD has taken and those that it has not. For munitions response 
sites that are also Formerly Used Defense Sites (FUDS) or that are 
located on installations under a Base Realignment and Closure (BRAG) 
action, the inventory accuracy is at the 95% level or better. FUDS, 
which have already transferred to the public, and BRAC which are, for 
the most part, in the process of transferring, are correctly being 
given greater priority than most munitions response sites still under 
DoD control. For example, Army munitions response sites that are 
lacking in terms of inventory and initial evaluation are, for the most 
part, located on active installations still under DoD control.

RECOMMENDATION 2: The GAO recommends that the Secretary of Defense 
revise DoD's plan to reassess the timetable proposed for completing its 
reevaluation of sites using the new risk assessment procedures so that 
it can, in a more timely manner, establish the order in which sites 
should be assessed and cleaned up, thereby focusing on the riskiest 
sites first. (p. 19/GAO Draft Report):

DOD RESPONSE: Partially concur. DoD plans to finalize the munitions 
response site prioritization protocol in 2004 and will immediately 
begin applying the protocol to sites with sufficient information to 
evaluate at least one risk module. For sites where little or no 
information is available, the Military Components will need sufficient 
time and resources to conduct site assessments and gather information 
for completion of each risk module. Application of the prioritization 
process is an iterative process. As new information becomes 
available, sites will be reevaluated to ensure that the sites with the 
highest relative risk are given priority for the sequencing of 
munitions responses.

Working closely with the Military Components, DoD recently established 
2010 as the goal for all site inspections to be complete at all 
munitions response sites. This date was determined to be both 
appropriate and achievable after careful evaluation of site information 
currently available; time and resource requirements to gather needed 
information; and impact on the traditional hazardous waste cleanup 
program. This will effectively change the goal of applying the three 
modules of the prioritization protocol to all munitions response sites 
from 2012 to 2010.

Lastly, the US Army Corps of Engineers has for a number of years used 
its relative risk assessment code (RAC) which assigns a relative risk 
to each munitions response site. Currently, work for the vast majority 
of munitions response sites is sequenced using this "risk-based" 
system.

RECOMMENDATION 3: The GAO recommended that the Secretary of Defense 
revise DoD's plan to establish interim goals for cleanup phases for the 
Services and Corps to target. (p. 19/GAO Draft Report):

DOD RESPONSE: Partially concur. As part of the current budgeting and 
programming guidance, DoD established interim goals requiring 
completion of all preliminary assessments by 2007 and all site 
inspections by 2010. These goals apply to all the Military Components, 
eliminating the need to have separate Service-specific goals. DoD is 
working with each of the Military Components to establish additional 
goals (including the establishment of a program completion date) and 
metrics to gauge progress toward goal accomplishment.

RECOMMENDATION 4: The GAO recommended that after DoD has revised its 
comprehensive plan that DoD work with the Congress to develop realistic 
budget proposals that will allow DoD to complete cleanup activities on 
potentially contaminated sites in a timely manner. (p. 19/GAO Draft 
Report):

DOD RESPONSE: Concur. DoD and the Military Components will be working 
together to determine realistic program completion cost estimates and 
budgets that support achievement of program goals in a timely and 
affordable manner. Consultation with Congress is vital.

[End of section]

Appendix IV: GAO Contacts and Staff Acknowledgments:

GAO Contacts:

Ms. Anu K. Mittal, (202) 512-3841 Edward Zadjura, (202) 512-9914:

Acknowledgments:

In addition to those named above, Jack Burriesci, Elizabeth Erdmann, 
Sherry McDonald, and Matthew Reinhart made key contributions to this 
report. Also contributing to this report were Cynthia Norris, Rebecca 
Shea, and Ray Wessmiller.

(360286):


FOOTNOTES

[1] Unexploded ordnance, discarded military munitions, and munitions 
constituents are hereafter referred to as "military munitions" for the 
purpose of this report. Unexploded ordnance includes ordnance primed 
and fired but remain unexploded. For a more complete definition, see 
the National Defense Authorization Act for Fiscal Year 2004, Pub. L. 
No. 108-136, section 1042 (a)(2).

[2] A formerly used defense site is a property that Department of 
Defense (DOD) formerly owned, leased, possessed, operated, or otherwise 
controlled, and was transferred from DOD prior to October 17, 1986.

[3] U.S. Environmental Protection Agency, Office of Solid Waste, 
Permits and State Programs Division, UXO Incident Report (Revision 1), 
(Washington, D.C., 2001).

[4] The Defense Environmental Restoration Program was established by 
section 211 of the Superfund Amendments and Reauthorization Act of 
1986, which amended the Comprehensive Environmental Response, 
Compensation, and Liability Act of 1980 (CERCLA).

[5] There are an additional eight sites for which cleanup action is 
planned, but not yet begun. These sites were not included in our file 
review process.

[6] In the report issued on April 21, 2003, DOD provided aggregate high 
and low program cost estimates for clean up of military munitions at 
Military Munitions Response program sites, as well as operational 
ranges, to satisfy a one-time congressional reporting requirement.

[7] In previous GAO work, we estimated that the Corps lacked a sound 
basis for about 38 percent of its determinations, based on its 
preliminary assessment of eligibility, that sites did not require any 
further DOD action; and we recommended that the Corps review these 
files to determine if these properties should be reassessed. The 38 
percent includes all potential formerly used defense sites, including 
those suspected of containing military munitions. As noted above, the 
Corps is in the process of reassessing the determinations. See U.S. 
General Accounting Office, Environmental Contamination: Corps Needs to 
Reassess Its Determinations That Many Former Defense Sites Do Not Need 
Cleanup, GAO-02-658 (Washington, D.C.: Aug. 23, 2002).

[8] DOD proposed a rule establishing this protocol on August 22, 2003, 
allowing 90 days for a public comment period. 68 Fed. Reg. 50,900.

[9] DOD recognized that other factors, such as economic, programmatic, 
and stakeholder concerns, may affect the sequence in which sites are 
cleaned up.

[10] This estimate is a conservative estimate because it was calculated 
based on annual funding totals that include funding that is needed for 
program management and administration. 

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