DOD's Implementation of the Relative Risk Site Evaluation Process
NSIAD-99-25, Oct 7, 1998
Pursuant to a legislative requirement, GAO reviewed the Department of Defense's (DOD) relative risk site evaluation process, focusing on: (1) the extent to which DOD has issued uniform relative risk site evaluation guidance and the application of the guidance by the defense components; and (2) whether the relative risk site evaluation process provided data that enabled the defense components to categorize sites and prioritize required work.
GAO noted that: (1) DOD's Environmental Security office provided guidance in August 1997 on its relative risk site evaluation process to defense components by updating its 1994 Relative Risk Site Evaluation Primer and publishing a Quality Assurance Plan; (2) the principal change in the updated primer was to establish new, DOD-wide criteria for defining low-risk sites; (3) defense components are to provide site evaluation results to DOD semi-annually; (4) the Environmental Security office issued the Quality Assurance Plan to help ensure the integrity of data that is reported to DOD managers and Congress; (5) the plan requires defense components to ensure that data are credible, auditable, accountable, and consistent and to follow specific data verification and reporting procedures; (6) for example, the plan requires defense components to review the process used to derive relative risk site evaluations for accuracy and consistency, and report the results to appropriate organizational elements; (7) DOD used the relative risk site evaluation process as one of several key factors for making site funding priority decisions; (8) GAO's analysis of site evaluation data being reported by the defense components showed that over 99 percent of the reported categorizations were consistent with DOD's criteria; (9) however, while consistent with the criteria, GAO did note two categories that DOD identifies as high relative risk and evaluation not required, account for two-thirds of the sites and three-fourths of the estimated $15 billion completion costs at the about 6,000 sites GAO analyzed; (10) the high relative risk category contains 1,622 sites with an estimated $9 billion cost to complete, and the evaluation not required category contains 2,584 sites, with an estimated $2.2 billion cost to complete; (11) also, sites in the evaluation not required category may have high to low or no known levels of contamination, and costly long-term remedial actions or no anticipated costs; (12) with so many sites in these categories, the designations are not as helpful as they could be to managers as one of the key pieces of information they use in making cleanup priority decisions among competing projects; (13) they are also not as helpful as they could be in assessing the status of sites not required to be evaluated; and (14) GAO found that officials at the installations GAO visited were differentiating further within the categories to aid in their decision-making processes.
- Closed - implemented
- Closed - not implemented
Recommendation for Executive Action
Recommendation: To assist managers in making priority decisions in the relative risk site evaluation process, the Secretary of Defense should direct the Deputy Under Secretary of Defense for Environmental Security or service components to provide more specific categories that aid in priority setting and in the accurate reporting of the status of sites.
Agency Affected: Department of Defense
Status: Closed - Implemented
Comments: DOD believes implementing the recommendation would have a disruptive effect on its program. However, an April 1999 Army Audit Agency (AAA) report found that the Corps of Engineers, responsible for managing formerly used defense site (FUDS) projects, could improve the priority system by further prioritizing hazardous, toxic and radiological waste projects ranked equally within the same priority codes. AAA also found that funding constraints left high-priority ordnance and explosive waste projects underfunded. Neither the Office of the Assistant Secretary of the Army (Installations and Environment) nor the Corps fully agreed with AAA's recommendation to refine the Corps' priority system, but they indicated they would take alternative corrective action that met AAA's intent (see Audit Report: AA99-186, 19 April 1999). This recommendation is being closed because a July 2000 congressional request addresses issues of relative risk and priority for formerly used defense sites.