Hazardous Waste:

Improvements Needed in DOD's Contracting System for Disposal of Waste

NSIAD-91-131: Published: Aug 6, 1991. Publicly Released: Sep 11, 1991.

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Pursuant to a congressional request, GAO determined whether the Department of Defense (DOD) adequately ensured: (1) the capability of transportation and disposal contractors; and (2) that hazardous waste generated by DOD installations reached the proper disposal site.

GAO found that: (1) DOD installations arrange for the disposal of certain types of waste, and the Defense Reutilization and Marketing Service (DRMS) competitively procures contracts on behalf of installations for the disposal of remaining waste; (2) while DRMS has not experienced significant problems with most contracts, some of the small business contractors encountered performance or financial difficulties that resulted in contract defaults; (3) to avoid such defaults, DRMS planned to make experience a technical factor in solicitations, reduce the scope of work awarded to small businesses, and form a review team to assess and resolve issues before determining bidder responsibility; (4) environmental legislation and courts have held DOD liable for contractors' mishandling of hazardous waste; (5) neither DRMS nor the DOD installations verified contractors' documentation regarding the arrival of waste at disposal facilities; (6) some contractors stored waste at interim facilities until they had a sufficient quantity for transportation and disposal, and some installations did not know where their hazardous waste was or what was being done with it; (7) neither DRMS nor the installations routinely performed on-site audits to ensure proper waste handling and disposal, and DRMS typically audited contractors only when it identified discrepancies; and (8) the Environmental Protection Agency and states varied in their monitoring of hazardous waste transportation and disposal contractors.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: DOD concurred with the recommendation, but said that it is essentially moot, since DRMS has placed increased emphasis on compliance auditing. DOD said that quotas will be established for routine inspection of service contractors, with appropriate frequency of inspections for all contractors used, based on associated risks.

    Recommendation: The Secretary of Defense, through the Director, Defense Logistics Agency, should direct DRMS to give high priority to audits of hazardous waste disposals.

    Agency Affected: Department of Defense

  2. Status: Closed - Not Implemented

    Comments: DOD said that the use of interim storage is necessary to preclude impacting storage facilities at the generation site. DOD said that due to the multiple waste streams generated by DOD activities, as well as the remote locations of the generators, direct shipment to the treatment or disposal facility is unrealistic and cost prhibitive. GAO will consider this issue for followup work.

    Recommendation: The Secretary of Defense, through the Director, Defense Logistics Agency, should direct DRMS to consider tracking hazardous waste to final disposal by not allowing transporters to use interim storage.

    Agency Affected: Department of Defense

  3. Status: Closed - Not Implemented

    Comments: DOD does not agree that further study of costs and benefits of using separate contracts for transportation and disposal of hazardous waste is warranted. DOD believes that its varied needs do not warrant specialized contracts but rather more flexible contracts. DOD said that separating transportation from disposal contracts will multiply the number of contracts to be administered.

    Recommendation: The Secretary of Defense should study the costs and the benefits of issuing separate contracts for transportation and disposal of hazardous waste.

    Agency Affected: Department of Defense

  4. Status: Closed - Not Implemented

    Comments: DOD believes its controls will achieve the same purpose as suggested by GAO. DOD imposed requirements on contractors to obtain copies of manifests from downstream handlers to the point of disposal. DOD said that verification of receipt of the manifest by the generator would be difficult. GAO will consider this issue for follow-up work.

    Recommendation: The Secretary of Defense, through the Director, Defense Logistics Agency, should direct DRMS to issue disposal contracts that require transporters of hazardous waste to have disposal facilities send tracking manifests directly to the DOD generator.

    Agency Affected: Department of Defense

  5. Status: Closed - Implemented

    Comments: DOD concurred with the recommendation. It will continue to improve hazardous waste disposal procedures and practices and disseminate this information throughout DOD. DOD will include guidance on compliance auditing in the comprehensive environmental instructions. This instruction for updating DOD environmental policy is being developed.

    Recommendation: The Secretary of Defense should require that the changes to hazardous waste disposal practices be required of all DOD installations.

    Agency Affected: Department of Defense

 

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