Environmental Compliance:

DOD Needs to Better Identify and Monitor Equipment Containing Polychlorinated Biphenyls

NSIAD-94-243: Published: Aug 24, 1994. Publicly Released: Sep 30, 1994.

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Pursuant to a congressional request, GAO reviewed Department of Defense (DOD) efforts to identify, replace, monitor, store, and dispose of equipment containing polychlorinated biphenyls (PCB).

GAO found that: (1) because DOD has not provided specific Environmental Protection Agency (EPA) guidance on the identification of PCB items, many installations do not know how many PCB items are in use at their specific bases; (2) because there is no legal, regulatory, or DOD guidance, service efforts to replace PCB items vary considerably; (3) some installations do not meet EPA requirements for monitoring PCB items or for storing and disposing of PCB items removed from service; (4) EPA periodically inspects some DOD installations to see if they are complying with EPA regulations, but it generally relies on the assurances of the installations that any deficiencies identified are corrected; (5) DOD officials have stated that budget constraints sometimes cause difficulty in modifying facilities, especially ones that would not be modified once PCB items were eliminated; (6) DOD installations have not properly documented the shipment and disposal of PCB items; and (7) some PCB items with unacceptable levels of contaminants have been salvaged and sold to disposal companies.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: OSD and DOD components have established a defense-wide policy and program for full and sustained compliance with all legal environmental requirements, including PCB regulations under TSCA. To improve the DOD-Wide Corporate Information Management, DOD is developing and fielding computer-based systems to better track and manage all environmental requirements. At the installation level, a toxic substance module will contain PCB inventory data and be integrated with a compliance deficiency management module containing PCB deficiency and corrective action data from all sources. Both modules will be fielded during fiscal years 1996-1998. DOD IG plans to monitor progress on the modules. Regarding the implementation of a follow-up program for EPA-noted deficiencies, DOD has established comprehensive service and agency environmental compliance assessment and management programs.

    Recommendation: In view of the frequent lapses in identification, labeling, monitoring, storage, and disposal of PCB, and the instances where identified problems had not been corrected even years after the fact, the Secretary of Defense should direct the military services to fully comply with the Toxic Substances Control Act and EPA regulations by: (1) requiring all installations to identify and maintain inventories of major PCB items; and (2) implementing a follow-up program to ensure that deficiencies identified by EPA and other monitoring organizations are corrected.

    Agency Affected: Department of Defense

  2. Status: Closed - Not Implemented

    Comments: DOD feels that existing DOD policy and direction requires all DOD components to monitor and evaluate all activities on a routine basis and take such measures as necessary to insure compliance with applicable environmental requirements, including EPA regulations under TSCA. However, the Congress has taken action that would achieve similar purpose by requiring DOD to input fines and penalties levied by regulatory agencies.

    Recommendation: The Administrator, EPA, should require installations to report on actions being taken to remedy instances of noncompliance.

    Agency Affected: Environmental Protection Agency

  3. Status: Closed - Not Implemented

    Comments: DOD feels that existing DOD policy and direction requires all DOD components to monitor and evaluate all activities on a routine basis and take such measures as necessary to insure compliance with applicable environmental requirements, including EPA regulations under TSCA. However, the Congress has taken action that would achieve similar purpose by requiring DOD to input fines and penalties levied by regulatory agencies.

    Recommendation: The Administrator, EPA, should improve on the timeliness of its follow-up inspections.

    Agency Affected: Environmental Protection Agency

 

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