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Report to Congressional Requesters: 

May 2004: 

DOD OPERATIONAL RANGES: 

More Reliable Cleanup Cost Estimates and a Proactive Approach to 
Identifying Contamination Are Needed: 

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-04-601]: 

GAO Highlights: 

Highlights of GAO-04-601, a report to congressional requesters

Why GAO Did This Study: 

For decades, the Department of Defense (DOD) has tested and fired 
munitions on more than 24 million acres of operational ranges. 
Munition constituents such as lead, trinitrotoluene (TNT), and 
perchlorate may cause various health effects, including cancer. 
Concerned about the potential cost to clean up munitions, Congress 
required DOD to estimate the cost to clean up its operational ranges. 

You asked GAO to determine (1) how DOD identified the location and 
last use of operational ranges and the basis for DOD’s cost estimates 
for cleaning up those ranges; and (2) DOD’s policy to address 
contaminants linked to the use of munitions on operational ranges and, 
where contaminants such as perchlorate have been detected, what 
corrective actions the military services have taken. 


What GAO Found: 

DOD identified the location and status of its operational ranges based 
on inventory data developed by the individual military services. 
However, the reliability of DOD’s inventory is questionable because the 
services did not use a common framework to collect and analyze data on 
the number of existing operational ranges. Because DOD’s cost estimates 
to clean up its operational ranges were based on individual service 
calculations that combined inventory data with unvalidated DOD cost 
assumptions, various service assumptions, and computer-generated cost 
rates, these cost estimates are also questionable. Specifically, GAO 
found that each service compiled inventory data using various 
methodologies over different time periods and developed cost estimates 
using a mix of differing assumptions and estimates, along with actual 
data. As a result, the services’ estimates to clean up an acre of 
highly contaminated land vary from about $800 for the Air Force to 
about $7,600 for the Army. The figure below shows high and low cost 
estimates and range acreage used to estimate costs, by service.

High and Low Cleanup Cost Estimates and Total Range Acreage by Service: 

[See PDF for image]

[End of figure]

DOD does not have a comprehensive policy requiring sampling or cleanup 
on operational ranges for the more than 200 chemicals associated with 
military munitions. However, when required by the Safe Drinking Water 
Act or other environmental laws, DOD has sampled and cleaned up 
munitions and munitions constituents. With regard to perchlorate, DOD 
has issued sampling policies but cannot assure funding is provided for 
such sampling. In some cases, DOD has sampled for perchlorate when 
required under the Safe Drinking Water Act’s Unregulated Contaminant 
Monitoring Regulation and for other contaminants when directed by state 
environmental agencies. However, DOD generally has not independently 
taken actions specifically directed at cleaning up munitions 
contaminants, such as perchlorate, on operational ranges when they have 
been detected.

What GAO Recommends: 

GAO recommends that DOD (1) revise its cost estimates for the cleanup 
of operational ranges using its most complete range inventory and a 
consistent estimating methodology, and (2) provide specific funding for 
sampling at sites where perchlorate contamination is likely, in 
accordance with DOD’s policy requiring sampling. 

In commenting on this report, DOD disagreed with GAO’s findings and 
recommendations. GAO believes its findings are sound and its 
recommendations are appropriate.

www.gao.gov/cgi-bin/getrpt?GAO-04-601.

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

[End of section]

Contents: 

Letter: 

Results in Brief: 

Background: 

DOD's Inventory and Cost Estimates for Operational Range Cleanup May 
Not Provide Congress with a Reliable Picture of Potential Liabilities: 

DOD Does Not Have a Comprehensive Policy on Contaminants Associated 
with Military Munitions and Has Not Specifically Cleaned Up Known 
Perchlorate Contamination: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendixes: 

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

Appendix II: Scope and Methodology: 

Appendix III: Installations That Were Cleaning Up Perchlorate as a 
Result of Demonstration Projects: 

Edwards Air Force Base: 

Naval Surface Warfare Center, Indian Head: 

Appendix IV: Installations That Identified Perchlorate as a Result of 
Munitions Research, Manufacturing, Testing, and Disposal Activities: 

Edwards Air Force Base: 

Holloman Air Force Base: 

Naval Surface Warfare Center, Indian Head: 

Redstone Arsenal: 

White Sands Missile Range: 

Naval Air Weapons Station, China Lake: 

Appendix V: Comments from the Department of Defense: 

Appendix VI: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

Staff Acknowledgments: 

Tables: 

Table 1: Dates Service Inventories Were Conducted: 

Table 2: Active and Inactive Operational Ranges and Acreage as Reported 
by DOD in April 2003: 

Table 3: Low and High Cost Estimates to Clean Up Unexploded Ordnance, 
Discarded Military Munitions, and Munitions Constituents: 

Table 4: High Cost Estimates to Clean Up an Acre with a High Density of 
Contamination, by Service: 

Table 5: Summary of Perchlorate Sampling Conducted at Installations 
Visited by GAO: 

Table 6: Potential Effects of the Munitions Constituents Closely 
Associated with Military Munitions: 

Table 7: Installations Visited during Our Review: 

Figures: 

Figure 1: Discarded Munitions on an Operational Range That Were Later 
Uncovered by Erosion: 

Figure 2: Discarded Military Munitions Discovered on a Closed Range: 

Figure 3: Munitions Debris, Including Ordnance, Collected during Range 
Clearance: 

Figure 4: High and Low Density Operational Range Acreage Used to 
Estimate Cleanup Costs, by Service: 

Abbreviations: 

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

DOD: Department of Defense: 

EPA: Environmental Protection Agency: 

NPDES: National Pollution Discharge Elimination System: 

RCRA: Resource Conservation and Recovery Act: 

TNT: Trinitrotoluene: 

Letter May 28, 2004: 

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

The Honorable Hilda L. Solis: 
Ranking Minority Member:
Subcommittee on Environment and Hazardous Materials: 
Committee on Energy and Commerce: 
House of Representatives: 

For decades, the Department of Defense (DOD) has tested and fired 
munitions on millions of acres of operational ranges. These munitions 
contain various constituents such as lead, trinitrotoluene (TNT), and 
ammonium perchlorate salt (perchlorate) that are, in some instances, 
known or suspected of causing health effects such as damage to the 
central and peripheral nervous systems, cancer, and interfering with 
thyroid function. Concerns about the potential cost to clean up 
munitions prompted Congress to require that DOD develop an estimate for 
what it would cost to clean up its operational ranges. The National 
Defense Authorization Act for Fiscal Year 2002 required DOD to provide 
(1) a comprehensive assessment of unexploded ordnance, discarded 
military munitions, and munitions constituents at current and former 
DOD facilities; and (2) an estimate of the aggregate projected cost of 
remediation (cleanup) at operational ranges,[Footnote 1] stated as a 
range of costs, including a low and high estimate. As of April 2003, 
DOD identified 10,444 operational ranges located in the United States 
and its territories, with Army operational ranges accounting for 94 
percent of the total. DOD estimated it would cost between $16 billion 
and $165 billion to clean up unexploded ordnance, discarded military 
munitions, and munitions constituents on these operational ranges.

There is a growing concern about the potential health effects 
associated with the environmental contamination caused by constituents 
used in the munitions and specifically the possible contamination of 
drinking water with perchlorate--the primary ingredient of solid rocket 
propellant that is also used in varying quantities in many types of 
munitions, explosives, and incendiary devices, such as mortars, 
grenades, and flares. The Environmental Protection Agency (EPA) 
estimates that about 90 percent of the perchlorate manufactured in the 
United States is for solid rocket fuel used for military purposes and 
by the National Aeronautics and Space Administration. According to EPA, 
studies have shown that perchlorate can interfere with thyroid function 
and negatively affect fetal and infant brain development and growth. 
Since 1990, the state of California has detected perchlorate in wells 
and other drinking water sources near sites that once supported 
munitions manufacturing, storage, and testing. EPA reports that 
perchlorate has been detected in 34 states and attributes a significant 
portion of the contamination to defense manufacturing and test sites.

In monitoring and cleaning up munitions and munitions constituents on 
operational ranges, DOD must comply with applicable provisions of 
various federal environmental laws, including the Safe Drinking Water 
Act, as amended; the Resource Conservation and Recovery Act of 1976, as 
amended (RCRA); and the Comprehensive Environmental Response, 
Compensation, and Liability Act of 1980, as amended (CERCLA). EPA does 
not have specific regulatory standards under the Safe Drinking Water 
Act for the roughly 200 chemicals associated with military munitions 
use,[Footnote 2] but requires sampling for some of these contaminants, 
including perchlorate. According to DOD, at least 20 of these 
constituents, including perchlorate, are of great concern due to their 
widespread use and potential environmental impact. For example, EPA and 
some states are considering whether to establish a specific drinking 
water standard for perchlorate levels and have, in some cases, 
established advisory levels. Appendix I contains a listing of munitions 
constituents of greatest concern and their potential health effects.

You asked us to determine (1) how DOD identified the location and last 
active use of all operational ranges and the basis for DOD's cost 
estimates for cleaning up those ranges; and (2) DOD's policy to address 
contaminants linked to the use of munitions on operational ranges and, 
where munitions-related contaminants have been detected, what 
corrective actions the services have taken. Specifically, you asked us 
to focus on DOD's actions with regard to perchlorate.

To determine how DOD identified the location and last active use of all 
operational ranges, we reviewed the services' inventory data and 
interviewed DOD and service officials to obtain information on how the 
inventories were conducted and the reliability of the data collected. 
We assessed the reliability of the services' data (1) by reviewing 
existing information about the data and processes that produced them 
and (2) by interviewing DOD officials knowledgeable about the data. We 
determined that data on the number of operational ranges and acreage 
were sufficiently reliable to include in our report. Although we found 
the reliability of data on operational range characteristics to be 
questionable, we present the data in the report for informational 
purposes. To determine the basis for DOD's cost estimates for cleaning 
up the operational ranges, we reviewed the services' estimated costs, 
supporting analyses, and calculations, and interviewed service and DOD 
officials on the scope and methodology used to develop cost estimates. 
To identify DOD's policy on sampling for constituents linked to the use 
of munitions on operational ranges, we reviewed DOD's and the services' 
policies related to sampling and cleanup of potential contaminants and 
specifically their policies on perchlorate. Finally, to report on what 
corrective actions the services have taken with regard to munitions 
constituents, particularly perchlorate, we visited seven DOD 
installations where perchlorate had been detected and discussed what 
efforts have taken place or were planned to respond generally to 
munitions-related contaminants and specifically to 
perchlorate.[Footnote 3] Our observations about these installations are 
not generalizable to all military installations. We conducted our work 
between June 2003 and March 2004 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 identified the location and status of its operational ranges based 
on inventory data developed by the individual services. However, 
inconsistencies in how DOD collected and analyzed data on operational 
ranges raise questions about the reliability of DOD's inventory. For 
example, the services used different methods to gather data, conducted 
inventories at different periods of time and for different reasons, and 
did not always validate their results. DOD's cost estimates to clean up 
operational ranges also are questionable because the estimates were 
based on this inventory data, as well as on a mix of cost assumptions 
that were not validated--where DOD did not establish a reasonable and 
defensible basis for the assumptions used--and computer-generated cost 
rates that varied across the services. For example, we found that in 
addition to DOD-provided assumptions, the services were allowed to use 
their own assumptions to estimate cleanup costs. Their differing 
approaches to estimating the percentage of acreage likely to be 
contaminated produced varying, and likely questionable, estimates of 
the costs to clean up operational ranges. In 2004, DOD completed 
another inventory of its operational ranges that was based on a more 
consistent data collection framework. However, because the 2004 
inventory was conducted for a different purpose and scope, the 2003 and 
2004 inventories are not comparable and there are differences between 
them. The differences between the two inventories make it difficult to 
determine if the range data used to estimate the cost of cleaning up 
operational ranges were accurate.

DOD does not have a comprehensive policy requiring sampling or cleanup 
of the more than 200 chemical contaminants associated with military 
munitions on operational ranges. None of these munitions constituents 
are currently regulated with a drinking water standard under the Safe 
Drinking Water Act, although some of them, including perchlorate, are 
covered under the act's Unregulated Contaminant Monitoring 
Regulation.[Footnote 4] Certain chemicals associated with military 
munitions may, however, be subject to other environmental laws, 
including RCRA and CERCLA. With a few exceptions, EPA generally has not 
used its authority under these laws to require DOD to conduct a cleanup 
of its operational ranges, although some states have required 
installations to monitor and sample for contaminants, including 
perchlorate. For example, EPA and several states have asked DOD to test 
for perchlorate in areas such as old dump sites because of concern 
about potential contamination of groundwater. In this context, DOD 
issued a policy in November 2002 allowing the services to test for 
perchlorate if there was a reasonable basis to suspect both the 
presence of perchlorate and the possibility for human exposure. In 
September 2003, DOD revised its policy to direct sampling for 
perchlorate contamination at previously unexamined sites, including 
operational ranges, where a perchlorate release is suspected and a 
pathway to human exposure is likely, but the policy did not identify 
specific funding for this sampling. None of the seven installations 
with reported perchlorate contamination that we visited were currently 
sampling operational ranges for perchlorate under DOD's guidance, 
although they had conducted some sampling when required by states. 
While six of the installations we visited had reported high levels of 
perchlorate, none of these were cleaning up perchlorate contamination 
because, installation officials said, DOD policy did not require that 
they do so. Further, at six of the locations we visited, we determined 
that research, manufacturing, testing, and disposal of perchlorate were 
the primary activities that had caused contamination, and not the use 
of ordnance during training exercises.

In order to assist Congress, EPA, and state regulators in assessing and 
planning for the cleanup of contamination from the use of munitions at 
operational ranges, we are recommending that DOD (1) use its most 
complete operational range inventory to revise its cost estimates for 
the cleanup of operational ranges and use a more consistent methodology 
for estimating costs, and (2) provide specific funding for sampling at 
sites where perchlorate contamination is likely, in accordance with 
DOD's policy requiring sampling.

In commenting on a draft of this report, DOD disagreed with our 
findings and recommendations. DOD disagreed with our conclusion that it 
did not have a comprehensive policy requiring sampling or cleanup of 
munitions constituents on operational ranges and cited specific 
policies requiring the services to respond to the release of munitions 
constituents. However, the policies cited by DOD pertain only to the 
migration of munitions constituents off-range, and environmental 
reporting, and do not address the sampling or cleanup of munitions 
constituents found on operational ranges that are the subject of this 
report. DOD disagreed with our recommendation that it needed to develop 
new cost estimates for cleaning up operational ranges, stating that it 
is developing a system for providing data and assessing its ranges for 
potential munitions constituent migration to off-range areas. However, 
the requirement in the National Defense Authorization Act for fiscal 
year 2002 was to report estimated costs to clean up operational ranges, 
not the costs to respond to or clean up constituent migration off-
range. DOD also questioned whether decision makers would find useful an 
estimated cost to clean up operational ranges. We disagree with DOD's 
view of the usefulness of the information to Congress, because on two 
occasions, including in DOD's authorization act, Congress has directed 
DOD to provide such information. DOD also disagreed with our 
recommendation to provide specific funding for perchlorate sampling. 
According to DOD, its current policy designates funding for perchlorate 
sampling as a high priority environmental project. However, we believe 
that due to limited funds and because perchlorate sampling must compete 
with other high priority environmental priorities, it may not be 
funded. Consequently, while DOD policy designates a funding mechanism 
for perchlorate, it cannot assure that perchlorate sampling will be 
funded. DOD also provided technical comments and clarifications that we 
incorporated into the report, as appropriate. DOD's comments appear in 
appendix V.

Background: 

DOD policy defined an operational range as an area used to conduct 
research, develop and test military munitions, or train military 
personnel. Operational ranges were considered active when regularly 
used for range activities, and inactive when not currently used but 
still under military control and available for use as a range.[Footnote 
5] Once a range is closed, DOD is required to identify, assess, and 
clean up or take other appropriate action in response to contamination 
by military munitions.[Footnote 6] As such, DOD's current inventory of 
operational ranges represents a potential liability for future cleanup. 
Figures 1, 2, and 3 show examples of the types of ordnance and 
explosives that can be found on operational ranges.

Figure 1: Discarded Munitions on an Operational Range That Were Later 
Uncovered by Erosion: 

[See PDF for image] 

[End of figure] 

Figure 2: Discarded Military Munitions Discovered on a Closed Range: 

[See PDF for image] 

[End of figure] 

Figure 3: Munitions Debris, Including Ordnance, Collected during Range 
Clearance: 

[See PDF for image] 

[End of figure] 

Section 313(a)(1) of the National Defense Authorization Act for Fiscal 
Year 2002[Footnote 7] required DOD to provide Congress with a 
comprehensive assessment of unexploded ordnance, discarded military 
munitions, and munitions constituents at current and former DOD 
facilities.[Footnote 8] The law required the assessment to include an 
estimate of the aggregate projected cost of remediation (or cleanup) at 
operational ranges, to be presented as a range of costs including a low 
and high estimate, and delivered to Congress in 2003 in DOD's report on 
the Defense Environmental Restoration Program. In April 2003, DOD 
reported its estimate for the total cost to address the potential 
liability associated with unexploded ordnance, discarded military 
munitions, and munitions constituents at operational ranges to be 
between $16 billion and $165 billion.

Collecting Inventory Data and Estimating Cleanup Costs: 

To provide Congress with estimated costs to clean up operational 
ranges, DOD used inventory data available at the time of its April 2003 
report, which counted 10,444 operational ranges located in the United 
States and its territories. At the direction of Congress, only 
operational ranges in the United States and its territories were to be 
considered for the purpose of estimating cleanup costs. According to 
DOD, these cost estimates were supported by individual service 
estimates, which in turn were supported by summary information on the 
number of operational ranges and acreage assumed to contain a high 
density of unexploded ordnance and munitions constituents--such as 
target areas, detonation sites, and demolition areas--and the 
percentage of acreage assumed to contain a low density of contamination 
from unexploded ordnance and munitions constituents, such as buffers, 
training areas, and maneuver areas.

The services continued to inventory operational ranges under section 
366 of the National Defense Authorization Act for Fiscal Year 
2003,[Footnote 9] which required DOD to inventory operational ranges to 
address training range sustainment and encroachment concerns and submit 
the inventory to Congress as part of the President's fiscal year 2005 
budget request early in calendar year 2004. The scope of this inventory 
effort addressed operational range training and testing capacities and 
capabilities, and specific constraints on the use of operational 
ranges, but did not specifically include data on the cleanup of 
unexploded ordnance, discarded military munitions, or munitions 
constituents.

We previously reported that the two key data needed to develop 
operational range cleanup costs were (1) an accurate and complete 
operational range inventory and (2) a consistent methodology for 
estimating costs.[Footnote 10] Reliable cost estimates can be critical 
information for DOD and Congress when considering the potential 
benefits of closing operational ranges or entire installations versus 
the potentially very high cost of cleaning up such sites. However, such 
estimates must be based on accurate data that, in the case of 
operational ranges, begins with a complete and accurate operational 
range inventory. The costs for cleaning up ranges can be extensive. For 
example, DOD estimates it will cost $22.6 million to clean up Fort 
McClellan in Alabama, recommended for closure under DOD's base 
realignment and closure program in 1995, and $247 million to clean up 
Fort Ord in California, closed in 1994. DOD officials explained that 
wide variations in cost can be attributed to a number of factors, such 
as future land use, technical complexities, and the high level of 
difficulty to locate, recover, and destroy ordnance located beneath the 
ground surface.

Environmental Laws and Regulations Affecting DOD Installations and 
Operational Ranges: 

DOD's operations at military installations and operational ranges in 
the United States are subject to laws and regulations governing a 
variety of environmental concerns, from water quality to the treatment 
and disposal of hazardous wastes. These laws include the Safe Drinking 
Water Act, the Clean Water Act, RCRA, the Federal Facility Compliance 
Act, and CERCLA. DOD is also generally required to comply with state 
and local environmental statutory and regulatory requirements on its 
installations and operational ranges. DOD has proposed that Congress 
specifically exempt it from requirements to clean up unexploded 
ordnance, munitions, and munitions constituents on operational ranges 
under RCRA and CERCLA.

The Safe Drinking Water Act authorizes EPA to issue national primary 
drinking water regulations setting maximum contaminant level standards 
for drinking water that must be met by public water systems.[Footnote 
11] EPA may authorize states to carry out primary enforcement authority 
for implementing the Safe Drinking Water Act if, among other things, 
the state adopts drinking water regulations that are no less stringent 
than the national primary drinking water regulations. EPA has set 
standards for approximately 90 contaminants in drinking water, 
including microorganisms, organic chemicals, inorganic chemicals, 
disinfectants, disinfection byproducts, and radioactive 
substances.[Footnote 12] None of the more than 200 chemical 
contaminants associated with munitions use are currently regulated 
under the Safe Drinking Water Act.

The 1996 amendments to the Safe Drinking Water Act required EPA to 
establish criteria for a monitoring program for unregulated 
contaminants (where a maximum contamination level has not been 
established) and to publish a list of contaminants--chosen from those 
not currently monitored by public water systems--to be monitored. 
EPA's regulation, referred to as the Unregulated Contaminant Monitoring 
Regulation, was issued in 1999 and supplemented in 2000 and 
2001.[Footnote 13] The purposes of the regulation are to determine 
whether a contaminant occurs at a frequency and in concentrations that 
warrant further analysis and research on its potential effects and to 
possibly establish future drinking water regulations. The first step in 
the current program required public water systems serving more than 
10,000 customers (and a sample of 800 small public water systems 
serving fewer than 10,000) to monitor drinking water for perchlorate 
and 11 other unregulated contaminants over a consecutive 12-month 
period at any point between 2001 and 2003, and report the results to 
the EPA. Under this regulation, some DOD installations were required to 
monitor drinking water for perchlorate and other munitions-related 
contaminants and to report the results.

The Clean Water Act authorizes EPA to regulate the discharge of 
pollutants into waters in the United States. EPA may authorize states 
to carry out a state program in lieu of the federal program if the 
state program is at least equivalent to the federal program and 
provides for adequate enforcement. Under the Clean Water Act's National 
Pollution Discharge Elimination System (NPDES) program, facilities 
discharging pollutants into waters of the United States are required to 
obtain an NPDES permit from EPA or authorized states. NPDES permits 
include specific limits on the quantity of pollutants that may be 
discharged and require monitoring of those discharges to ensure 
compliance. EPA's list of the toxic pollutants subject to regulation 
under the Clean Water Act includes nitrobenzene, a chemical that is on 
DOD's list of 20 constituents of greatest concern.[Footnote 14]

RCRA requires owners and operators of facilities that treat, store, and 
dispose of hazardous waste, including federal agencies, to obtain a 
permit specifying how their facilities will safely manage the waste. 
Under RCRA's corrective action provisions, facilities seeking or 
holding RCRA permits can be required to clean up their hazardous waste 
contamination. The corrective actions can be specified in the 
facility's operating permit, in a separate corrective action permit, or 
through an enforcement order. EPA also has authority under RCRA to 
order a cleanup of hazardous waste when there is an imminent and 
substantial endangerment to public health or the environment. EPA may 
authorize states to administer their own programs in lieu of the 
federal program, as long as these programs are equivalent to and 
consistent with the federal program and provide for adequate 
enforcement. EPA's regulations define hazardous wastes to include those 
that are specifically listed in the regulations as well as those that 
are "characteristic wastes." Characteristic hazardous wastes are 
defined as wastes that are ignitable, corrosive, reactive, or toxic. A 
federal district court in California recently ruled, in part, that 
perchlorate is a hazardous waste under RCRA because it is 
ignitable.[Footnote 15]

Under section 107 of the Federal Facility Compliance Act of 
1992,[Footnote 16] EPA was required, in consultation with DOD and the 
states, to issue a rule identifying when military munitions become 
hazardous waste under RCRA, and to provide for protective storage and 
transportation of that waste. Under the rule issued by EPA, military 
munitions are subject to RCRA when, among other things, (1) unexploded 
munitions or their constituents are buried or otherwise disposed of, or 
(2) when used or fired munitions are taken off-range.[Footnote 17]

CERCLA governs the cleanup of releases or threatened releases of 
hazardous substances, pollutants, or contaminants. CERCLA's definition 
of a hazardous substance includes substances regulated under various 
other environmental laws, including RCRA, the Clean Air Act, the Clean 
Water Act, and the Toxic Substances Control Act. Under section 120 of 
CERCLA, the federal government is subject to and must comply with 
CERCLA's requirements to the same extent as any nongovernmental entity. 
DOD's cleanup under CERCLA section 120 is interrelated with its 
environmental restoration program under section 211 of the Superfund 
Amendments and Reauthorization Act of 1986.[Footnote 18]

Contaminants Associated with Military Munitions: 

According to DOD, there are more than 200 chemicals associated with 
military munitions, and of these, 20 are of great concern due to their 
widespread use and potential environmental impact. TNT, Propanetriol 
trinitrate (nitroglycerin), Royal Demolition Explosive, and 
perchlorate are among the 20. Perchlorate is the primary oxidizer in 
propellants, present in varying amounts in explosives, and is highly 
soluble. According to EPA, an estimated 90 percent of the perchlorate 
produced in the United States is manufactured for use by the military 
and the National Aeronautics and Space Administration. Typical 
production quantities average several million pounds per year. 
Nonmilitary uses for perchlorate include fireworks, flares, fertilizer, 
and automobile airbags. As of 2004, EPA reported that 34 states 
confirmed perchlorate contamination in ground and surface water, and in 
states where EPA determined the source of the contamination, it 
attributed a significant portion to defense manufacturing and test 
sites.

EPA has not established a federal drinking water standard for 
perchlorate. However, in 1999, EPA established a provisional reference 
dose for perchlorate in drinking water of between 4 and 18 parts per 
billion. A reference dose is an estimate of the daily exposure to a 
human that would not pose a significant risk of harmful effects. In 
October 2003, the National Academy of Sciences (Academy) began a study 
of the best scientific model to use for determining a drinking water 
standard or reference dose for perchlorate, if any. According to EPA, 
the Academy's study will take about one year to complete. Based on 
recommendations from the Academy, EPA will decide whether to regulate 
the contaminant and will have up to 2 years after making an affirmative 
determination to propose a national primary drinking water regulation 
for perchlorate.[Footnote 19] An EPA official told us that updating 
drinking water standards can take 2 to 3 years and predicted that a 
perchlorate standard will likely not be available until 2006 or 2008.

In the meantime, some states that detected perchlorate in various 
media, such as groundwater, have established state guidance or advisory 
levels for the contaminant. As of February 2004, seven states have 
established interim perchlorate advisory levels. Of those states, 
Maryland and Massachusetts have the lowest perchlorate advisory level 
of 1 part per billion. On March 12, 2004, California revised its 
advisory action level for perchlorate from 4 parts per billion to 6 
parts per billion.

DOD's Inventory and Cost Estimates for Operational Range Cleanup May 
Not Provide Congress with a Reliable Picture of Potential Liabilities: 

DOD's estimate that it would cost between $16 billion and $165 billion 
to clean up unexploded ordnance, discarded military munitions, and 
munitions constituents on operational ranges is questionable. To 
determine the costs of operational range clean up, DOD had to first 
inventory its operational ranges and obtain data such as the type of 
range and munitions used. However, the military services used inventory 
data that were collected for different purposes over different periods 
of time and verified with varying degrees of analytical rigor. Next, 
the costs of operational range cleanup were calculated using a mix of 
unvalidated assumptions provided by DOD and assumptions provided by the 
individual services, as well as actual service data, where available. 
Consequently, DOD's overall cost estimates were based on assumptions, 
estimates, and actual data that differed across the services and that 
raise questions about the reliability of DOD's estimated costs to clean 
up operational ranges.

Operational Range Inventory Process Lacked a Common Framework and 
Analytical Rigor: 

Each service inventoried its operational ranges and collected data on 
range acreage and munitions used, using various methodologies over 
different periods of time. (See table 1 for the starting and ending 
dates of the service's inventories.) Services also conducted 
inventories for different reasons, such as to respond to pending 
legislation on ranges, public concern about military use of ranges, or 
simply to gather data to calculate cleanup cost estimates. The rigor of 
the analysis and the degree of the validity of the inventory results 
varied by service. The inconsistencies in how DOD collected and 
analyzed data on operational ranges raise questions about the 
reliability of DOD's inventory.

Table 1: Dates Service Inventories Were Conducted: 

Military Service: Air Force; 
Inventory started: August 2001; 
Inventory ended: December 2002.

Military Service: Army; 
Inventory started: July 2000; 
Inventory ended: December 2002.

Military Service: Marine Corps; 
Inventory started: October 2001; 
Inventory ended: November 2002.

Military Service: Navy; 
Inventory started: December 1999; 
Inventory ended: January 2000.

Source: GAO analysis of military service data.

[End of table]

The Air Force inventory of operational ranges in the United States and 
its territories was based on a survey sent to field command levels to 
estimate costs to clean up operational ranges. Service officials said 
survey data was validated during on-site field inspections or, in some 
cases, brief desk reviews to assure surveys were complete and free of 
obvious errors. As of December 2002, the Air Force counted 222 active 
ranges, 23 inactive ranges, and 23 ranges that were not categorized as 
either active or inactive. Together, Air Force operational ranges 
covered 6,423,161 acres.

The Army's inventory of operational ranges was conducted concurrently 
with an inventory of nonoperational ranges and was based on field 
surveys. According to Army officials, the Army initiated an inventory 
of its ranges primarily in response to anticipated legislation on the 
use of ranges,[Footnote 20] which required a comprehensive inventory of 
DOD ranges as well as a collection of descriptive data about each 
range, such as the acreage and types of munitions used on the range. 
The Army's inventory was also conducted in response to DOD directives 
issued in August 1999 that required the services to establish and 
maintain an inventory of operational ranges and data on munitions and 
ordnance.[Footnote 21] To inventory ranges, the Army used contract 
support staff who requested data from field commands and installations, 
and then sought to validate the data through on-site visits. Army 
officials said the Army's inventory of operational ranges was completed 
in December 2002, and encompassed 9,427 active ranges, 377 inactive 
ranges, and 4 ranges not designated active or inactive. In total, Army 
operational ranges covered 14,991,072 acres in the United States and 
its territories.

Similar to the Army, the Marine Corps conducted an inventory of its 
operational ranges primarily in response to anticipated legislation on 
the use of ranges and DOD directives that required the services to 
establish and maintain an inventory of operational ranges and data on 
munitions and ordnance. The Marine Corps developed its inventory from 
an archive data search and surveys sent to installations. Headquarters' 
officials reviewed the surveys to assure that submitted data agreed 
with data in the archive search. As of December 2002, the Marine Corps 
counted 216 operational ranges totaling 1,980,119 acres in the United 
States and its territories. According to headquarters' officials, the 
Marine Corps did not distinguish between active and inactive ranges but 
designated all ranges as operational.

The Navy's inventory of operational ranges in the United States and its 
territories was conducted at the request of the Navy's Environmental 
Readiness Division. The Navy's inventory was prepared in response to 
the anticipated inventory requirements of DOD's proposed range rule and 
because of increased public and regulatory scrutiny of military ranges, 
Navy officials said. The inventory was conducted through surveys sent 
to the installations. As of December 2002, Navy operational ranges 
totaled 121 active ranges and 31 inactive ranges on 1,284,374 acres.

As of April 2003, when DOD reported its estimated cost to clean up 
operational ranges, DOD's inventory included 10,444 operational ranges 
totaling 24.6 million acres in the United States and its territories. 
(See table 2 for a breakout of operational ranges by service and status 
and total acres.)

Table 2: Active and Inactive Operational Ranges and Acreage as Reported 
by DOD in April 2003: 

Air Force; 
Operational Ranges: Active: 222; 
Operational Ranges: Inactive: 23; 
Operational Ranges: Not categorized: 23; 
Operational Ranges: Total: 268; 
Total acreage (in millions): 6.4.

Army[A]; 
Operational Ranges: Active: 9,427; 
Operational Ranges: Inactive: 377; 
Operational Ranges: Not categorized: 4; 
Operational Ranges: Total: 9,808; 
Total acreage (in millions): 15.0.

Marine Corps; 
Operational Ranges: Active: 0; 
Operational Ranges: Inactive: 0; 
Operational Ranges: Not categorized: 216; 
Operational Ranges: Total: 216; 
Total acreage (in millions): 1.9.

Navy; 
Operational Ranges: Active: 121; 
Operational Ranges: Inactive: 31; 
Operational Ranges: Not categorized: 0; 
Operational Ranges: Total: 152; 
Total acreage (in millions): 1.3.

DOD total; 
Operational Ranges: Active: 9,770; 
Operational Ranges: Inactive: 431; 
Operational Ranges: Not categorized: 243; 
Operational Ranges: Total: 10,444; 
Total acreage (in millions): 24.6. 

Source: GAO analysis of military service data.

[A] According to Army officials, the Army's inventory of operational 
ranges was finalized in the summer of 2003 and revised to 9,427 active 
and 377 inactive ranges totaling about 15 million acres in the United 
States and its territories.

[End of table]

DOD continued to inventory its operational ranges. The National Defense 
Authorization Act for Fiscal Year 2003 required DOD to develop a plan 
to address training range issues, such as range sustainment and 
encroachment and, as part of this plan, to develop a range inventory 
system that included all available operational training ranges. In 
January 2003, DOD provided the services with an inventory framework and 
data definitions to ensure reporting consistency and required the 
services to complete detailed inventories of all of their operational 
ranges. DOD revised its existing inventory of operational ranges to 
meet this new requirement. Because the revised inventory was conducted 
for different purposes, using a scope and set of assumptions that were 
different from the inventory data used to estimate cleanup costs, it 
identified a different number of operational ranges. For example, the 
inventory for developing the cost estimates used actual operational 
range acreage, whereas the revised inventory used actual and potential 
operational range acreage. Further, the revised inventory is divided 
into range complexes and individual ranges, and includes operational 
ranges outside the United States and its territories not included in 
the inventory DOD used to estimate cleanup costs.

In February 2004, DOD released the results of its training range plan 
and revised inventory. The revised inventory listed 353 range complexes 
and 172 individual ranges on 26 million acres worldwide. These numbers 
differ from the inventory data DOD used to estimate cleanup costs, 
which counted 10,444 operational ranges on 24.6 million acres in the 
United States and its territories primarily because of the aggregation 
of individual ranges into complexes and the inclusion of ranges outside 
the United States and its territories. For example, under the prior 
inventory, Fallon Naval Air Station, in Nevada, reported it had 150,365 
acres of rangeland, but under the new inventory, Fallon reported it had 
just 103,300 acres of actual and potential rangeland. Also under the 
prior inventory, the Marine Corps reported that Camp Lejeune, in North 
Carolina, had 95,872 acres of rangeland, while under the new inventory, 
Camp Lejeune reported it had 152,000 acres of actual and potential 
rangeland (even though the entire installation encompasses just 153,000 
acres). The Marine Corps also reported that Camp Pendleton, in 
California, had 39,084 acres of rangeland under the old inventory, but 
under the new inventory, Camp Pendleton reported it had 114,000 acres 
of actual and potential rangeland, almost a threefold increase.

While the 2003 and 2004 inventories are not readily comparable because 
of the varying scope and definitions used to develop the revised 
inventory, the difference between the two highlights the difficulty in 
understanding the basis for, and the results of, DOD's cost estimates. 
Finally, we believe the differences in the two inventories may further 
complicate efforts of Congress to identify the potential liabilities 
that may exist if operational ranges or installations are closed and 
require cleanup.

Cost Estimates Were Calculated Using a Mix of Differing Assumptions, 
Estimates, and Actual Data: 

In 2002, DOD provided guidance to the services on how to estimate costs 
for cleaning up operational ranges. This guidance specified the scope 
for estimating costs but allowed for variation across the services. 
According to DOD officials, because the requirement to estimate cleanup 
costs was a one-time congressional requirement, DOD directed the 
services to limit their data gathering efforts by using certain costing 
assumptions and a computer-costing model in combination with already 
existing data. Examples of the scope and some of the assumptions DOD 
used to estimate costs include the following: 

* The scope of the inventory was limited to operational ranges within 
the United States and its territories because DOD believed that was 
what Congress intended.

* The scope excluded certain operational ranges, such as water ranges, 
because DOD did not have a model for estimating costs associated with 
such ranges and did not have any significant historical experience on 
which to base an estimate. DOD also did not develop cost estimates for 
several types of airspace, such as warning areas and restricted areas.

* DOD directed the services to use both a computer-costing model that 
automatically assigned certain values for the cleanup costs of 
unexploded ordnance and discarded military munitions and an electronic 
worksheet to estimate costs to clean up munitions constituents.

* DOD provided cost assumptions to the services based on operational 
range acreage and other variables. For example, the services were 
directed to divide range acreage into areas assumed to have a high 
density of contamination and a low density of contamination and, on 
that basis, calculate individual cleanup costs.

* DOD also provided specific assumptions to calculate costs for various 
cleanup activities. For example, to estimate the cost to remove 
unexploded ordnance from a highly contaminated range area, the services 
were told to assume they would need to remove ordnance from 50 percent 
of that area to calculate the high cost estimate and 5 percent of that 
area to calculate the low cost estimate.

DOD said its assumptions were based on discussions with the services 
and developed through consensus. DOD could not provide any 
documentation that the assumptions they asked the services to use were 
validated--a confirmation of the reasonableness and justification for 
assumptions used--and a senior DOD official told us that, in fact, the 
assumptions were not validated.

Furthermore, DOD instructions to the services allowed them to use 
additional assumptions or site-specific data so that cost estimates 
were calculated based on a mix of actual data and assumptions. Based on 
our review of DOD's 2003 report to Congress, and discussions with 
service officials on their methodologies to estimate costs, we found 
DOD did not fully explain the mix of assumptions and data used and how 
this mix affected the cost estimates, so that the usefulness of DOD's 
overall cleanup cost estimates to Congress is questionable.

The inconsistencies in how the services developed their cost estimates 
are evident in areas such as how the services calculated high-density 
acreage (that is, the area of a range containing a high density of 
ordnance) and the costs for cleaning up these acres. For example, 
although DOD guidance directed the services to estimate what proportion 
or percentage of operational range acreage contained a high density of 
unexploded ordnance and munitions constituents, and specified how 
various types of ranges were to be treated for cost estimating 
purposes, each service performed this calculation differently. If site-
specific data was unavailable, the Marine Corps used varying 
percentages based on the characteristics of similar ranges to determine 
those that were highly contaminated. Our analysis showed that for about 
two-thirds of its operational ranges, the Marine Corps assumed 10 
percent of its nonsmall arms or multipurpose range acreage was highly 
contaminated. However, based on a review of the Marine Corps' total 
cleanup cost estimates for operational ranges, GAO determined that the 
Marine Corps calculated its costs assuming that an average 53 percent 
of range acreage has highly contaminated. In contrast, the Air Force 
and the Army used estimated data to determine that 44 percent and 60 
percent of their acreage was highly contaminated, 
respectively.[Footnote 22] Further, the Air Force did not designate a 
percentage of each operational range with a high density of 
contamination and a low density of contamination, but rather defined 
each operational range as either 100 percent high density or 100 
percent low density. The Navy used actual data to determine that 11 
percent of its operational range acreage was highly contaminated. 
(Figure 4 shows the high and low density acreage by service used to 
estimate cleanup costs.)

Figure 4: High and Low Density Operational Range Acreage Used to 
Estimate Cleanup Costs, by Service: 

[See PDF for image] 

[End of figure] 

Based on the data provided by the services, the model calculated four 
totals for each operational range: a low and high estimated cost to 
clean up the portion of the range assumed to have a low level of 
contamination, and a low and high estimated cost to clean up the 
portion of the range assumed to be highly contaminated. Low estimates 
for low and high contamination areas were combined to calculate a total 
low estimate, and high estimates for low and high contamination areas 
were combined to calculate a total high estimate. (See table 3 for low 
and high estimates by service.)

Table 3: Low and High Cost Estimates to Clean Up Unexploded Ordnance, 
Discarded Military Munitions, and Munitions Constituents: 

Billions of dollars; 

Air Force; 
Low estimate: $1.2; 
High estimate: $14.0.

Army; 
Low estimate: $14.5; 
High estimate: $141.5.

Navy; 
Low estimate: $0.2; 
High estimate: $2.5.

Marine Corps; 
Low estimate: $0.5; 
High estimate: $6.7.

DOD[A]; 
Low estimate: $16.0; 
High estimate: $165.0.

Sources: The Fiscal Year 2002 Defense Environmental Restoration 
Program report and military service data.

[A] Estimates do not add due to rounding.

[End of table]
 
In general, using the model and standardized assumptions should have 
produced estimates with some variation across the services because of 
differing missions, operational practices, and types of munitions used. 
However, as reflected in table 4, a tenfold difference in the average 
cost to clean up an acre of highly contaminated rangeland calls into 
question the mix of different assumptions and data used by the services 
to estimate costs. For example, the Air Force's average cost to clean 
up an acre with a high density of contamination was $755, whereas the 
Army's estimate was $7,577. As a result, the services cost estimates 
are not comparable. (Table 4 shows the total and average cost per acre 
estimates by service.)

Table 4: High Cost Estimates to Clean Up an Acre with a High Density of 
Contamination, by Service: 

Service: Air Force; 
Acreage: 2,835,579; 
High cost estimate (dollars): $$2,140,072,819; 
Average high cost per acre (dollars): $755.

Service: Army; 
Acreage: 8,691,311; 
High cost estimate (dollars): $65,855,410,348; 
Average high cost per acre (dollars): $7,577.

Service: Marine Corps; 
Acreage: 1,023,623; 
High cost estimate (dollars): $3,719,488,388; 
Average high cost per acre (dollars): $3,634.

Service: Navy; 
Acreage: 134,459; 
High cost estimate (dollars): $920,669,000; 
Average high cost per acre (dollars): $6,847. 

Source: GAO analysis of military service data.

[End of table]

DOD Does Not Have a Comprehensive Policy on Contaminants Associated 
with Military Munitions and Has Not Specifically Cleaned Up Known 
Perchlorate Contamination: 

DOD does not have a comprehensive policy requiring sampling or cleanup 
of the more than 200 chemical contaminants associated with military 
munitions on operational ranges. However, DOD installations have 
sampled for and cleaned up munitions-based constituents when directed 
by state regulatory authorities. With regard to perchlorate, DOD has 
issued sampling policies but does not provide specific funding for such 
sampling. Nevertheless, we found some installations have sampled and 
monitored for perchlorate to meet the requirements of environmental 
laws and regulations, such as RCRA and the Unregulated Contaminant 
Monitoring Regulation. During visits to six installations that reported 
high levels of perchlorate, we found that none were cleaning up 
perchlorate contamination. At six of the seven installations we 
visited, perchlorate contamination was largely the result of 
researching, manufacturing, testing, and disposing of munitions, and 
not the use of munitions during training.

Previous DOD Policy Did Not Require Cleanup or Sampling for 
Contaminants Associated with Military Munitions: 

According to EPA, of the more than 200 chemicals associated with 
military munitions, which include 20 that DOD considers to be of 
greatest concern due to their widespread use and potential 
environmental impact, none are specifically regulated under the Safe 
Drinking Water Act. Further, except in some specific instances, EPA 
does not generally use its authority under other environmental laws, 
such as RCRA and CERCLA, to require DOD to conduct cleanups on 
operational ranges.[Footnote 23] An EPA official told us that although 
EPA is concerned with constituents associated with military munitions 
such as perchlorate and Royal Demolition Explosive, and the migration 
of plumes (pollutants that drain or flow through soil and water) from 
military ranges to groundwater, the agency generally does not interfere 
with DOD's operation of its operational ranges. Recently, DOD proposed 
that Congress specifically exempt it from requirements to clean up 
unexploded ordnance, munitions, and munitions constituents that remain 
on operational ranges under RCRA and CERCLA.

DOD policy does not generally require the services to clean up or 
sample for munitions contaminants because, according to DOD officials, 
these contaminants are deposited on operational ranges in the course of 
the normal and intended use of these munitions. Yet, DOD may be 
required by EPA or states to sample and clean up its munitions 
contaminants under various environmental laws and regulations on 
operational ranges. For example, under the Clean Water Act, facilities 
that discharge pollutants into surface water are required to obtain a 
NPDES permit from EPA or an authorized state agency. Several states 
have required some DOD installations to monitor for various 
contaminants associated with military munitions as part of the NPDES 
permit process. For example, the Regional Water Quality Control Board 
in San Diego and the Hampton Roads Sanitation District in Hampton 
Roads, Virginia, required Navy facilities to monitor their water 
discharges for various constituents that are on EPA's list of toxic 
pollutants under the Clean Water Act.[Footnote 24] Under the 
Unregulated Contaminant Monitoring Regulation, EPA required some 
installations to sample for and report on 12 unregulated contaminants 
in drinking water during any 12-month period between 2001 and 2003. The 
list of contaminants included four munitions-related contaminants--
perchlorate, 2,4 and 2,6 dinitrotoluene, and nitrobenzene. In April 
2004, DOD reported that 36 installations had sampled for the presence 
of unregulated contaminants in drinking water, including perchlorate, 
under this regulation. Of these, 33 installations reported no 
perchlorate was detected or detection results were below the reporting 
limit of 4 parts per billion. Only three Air Force installations 
detected perchlorate above the reporting limit, ranging from just over 
4 parts per billion to 46 parts per billion.

Revised DOD Policy Directs Sampling for Perchlorate under Certain 
Conditions but Little Sampling Has Been Done: 

In November 2002, DOD issued its first policy on perchlorate assessment 
that stated the services may sample and assess for perchlorate if there 
was a reasonable basis to suspect both a potential presence of 
perchlorate and a likely pathway that could lead to human exposure. The 
policy stated that the services could fund assessments using the 
operations and maintenance environmental compliance account, but 
specified that sampling should be considered a lower priority (Class 
II) environmental project and, as we: 

found in a prior effort, was unlikely to be funded.[Footnote 25] 
Finally, the policy directed those installations that sampled for and 
found perchlorate to report to DOD on the location and amount of 
perchlorate found. On September 29, 2003, DOD issued a revised policy 
on perchlorate sampling that directed the services to (1) consolidate 
data on perchlorate detections, including data developed in response to 
environmental laws such as the Clean Water Act and Safe Drinking Water 
Act, and (2) sample any previously unexamined sites, including ranges, 
where a perchlorate release is suspected because of prior DOD 
activities and where human exposure is likely. The policy stated that 
the services should fund sampling using the same environmental 
compliance account specified in the previous policy, but elevated 
sampling to a higher (Class I) funding priority and thus made it more 
likely to be funded. However, when DOD issued its policy, funding had 
already been allocated to Class I requirements for fiscal year 2004. In 
future years, unless specific or additional funding is added, 
perchlorate sampling will have to compete with other high priority 
environmental requirements and may not be funded.

In implementing the revised policy, the services added a third 
criterion requiring that installations coordinate with, or obtain 
written approval from, headquarters and the chain of command before 
sampling for perchlorate. However, if sampling is specifically required 
by an environmental law or state agency, the service policies do not 
require installations to request approval or notify headquarters before 
sampling. During visits we made to selected installations with reported 
perchlorate contamination between October 2003 and January 2004, we 
found installations were not sampling under the revised policy to 
determine the presence of perchlorate on operational ranges. More 
broadly, as of February 2004, Marine Corps and Navy officials said that 
no installations had requested permission to sample under this policy. 
According to the Air Force, three installations asked for permission to 
sample for perchlorate because EPA had asked that they sample. Air 
Force headquarters approved two of the requests but denied the third 
because, according to Air Force headquarters, there was not a reason to 
suspect the presence of perchlorate. Four Army installations have asked 
for approval to sample for perchlorate, and Army headquarters approved 
all four as of March 2004, an Army headquarters official said. Overall, 
this suggests that little sampling is being done under DOD's revised 
perchlorate policy.

Although none of the installations had begun sampling under DOD's 
revised policy, during our visits we found a few installations had 
sampled and monitored for perchlorate to meet the requirements of 
certain environmental laws and regulations. Table 5 summarizes the 
perchlorate sampling that has been conducted at installations we 
visited as reported by DOD as of April 2004.

Table 5: Summary of Perchlorate Sampling Conducted at Installations 
Visited by GAO: 

Installation: Edwards Air Force Base; 
Number of samples collected: 413; 
Number of positive detections: 309; 
Range of concentrations detected (in parts per billion): Up to 
2,100,000 in soil and up to 30,700 in groundwater; 
Source of perchlorate contamination: Propulsion research and rocket 
test stand; maintenance; landfill.

Installation: Holloman Air Force Base; 
Number of samples collected: 2; 
Number of positive detections: 1; 
Range of concentrations detected (in parts per billion): 7,600; 
Source of perchlorate contamination: Research, development, testing 
and evaluation.

Installation: Aberdeen Proving Ground; 
Number of samples collected: 1,193; 
Number of positive detections: 540; 
Range of concentrations detected (in parts per billion): Less than 1 
and up to 12,000; 
Source of perchlorate contamination: Training with pyrotechnics and 
smoke; use of propellants, ordnance, smoke and chemical agents.

Installation: Redstone Arsenal; 
Number of samples collected: Not reported; 
Number of positive detections: Not reported; 
Range of concentrations detected (in parts per billion): Up to 37,000; 
Source of perchlorate contamination: Rocket testing.

Installation: White Sands Missile Range[A]; 
Number of samples collected: Not reported; 
Number of positive detections: Not reported; 
Range of concentrations detected (in parts per billion): Not reported; 
Source of perchlorate contamination: Not reported.

Installation: Naval Air Weapons Station, China Lake; 
Number of samples collected: 12; 
Number of positive detections: 12; 
Range of concentrations detected (in parts per billion): Up to 720; 
Source of perchlorate contamination: Research, development and testing; disposal; possible natural occurrence.

Installation: Naval Surface Warfare Center, Indian Head; 
Number of samples collected: 708; 
Number of positive detections: 278; 
Range of concentrations detected (in parts per billion): Up to 480,000; 
Source of perchlorate contamination: Disposal, open burning, unknown 
source. 

Source: DOD perchlorate sampling data as of April 2004.

[A] Although it was not reported by DOD as of April 2004, we found 
during our visit to White Sands Missile Range that officials sampled 
for perchlorate as part of an RCRA application.

[End of table]

During our visits, we found the following installations had sampled for 
and monitored perchlorate to meet the requirements of RCRA or the Safe 
Drinking Water Act: 

* In 1999, as part of an application under RCRA to close an open 
burning and detonation facility used to destroy excess and obsolete 
ammunition, the state of New Mexico required White Sands Missile Range, 
in New Mexico, to sample for contaminants, including perchlorate. The 
former open burning and detonation facility is located on an 
operational range. Groundwater sampling detected high levels of 
perchlorate--up to 25,000 parts per billion.[Footnote 26] The Army 
installed 56 monitoring wells on the range to map the plume. Each well 
is sampled quarterly. After four years of quarterly sampling and 
monitoring, Army officials said the plume is stable and contained, 
which means it is isolated underground and not expected to move. 
Further, officials said there is no indication that perchlorate has 
migrated outside the identified plume. Under its RCRA closure permit 
with the state of New Mexico, the Army must continue monitoring the 
groundwater for up to 20 years.

* Three of the seven installations we visited tested for perchlorate 
under the Safe Drinking Water Act's Unregulated Contaminant Monitoring 
Regulation program. Edwards Air Force Base, in California, sampled 
twice in 2002 and reported that none of the 12 chemicals listed on the 
EPA list of unregulated contaminants, including perchlorate, were 
detected in any of the groundwater samples collected from drinking 
water wells. (Under the regulation, EPA required surface water systems 
to be sampled quarterly and groundwater systems to be sampled 
semiannually for one consecutive 12-month period.) Redstone Arsenal, in 
Alabama, sampled quarterly for a 12-month period beginning June 2001. 
Two water intake sites were sampled (a drinking water source and a 
drinking water and industrial water source), both along the Tennessee 
River. Redstone Arsenal reported that perchlorate was not detected 
above the EPA sampling level of 4 parts per billion. Nearby Huntsville, 
Alabama, also sampled for perchlorate and detected no contamination, a 
Redstone Arsenal official said. Finally, although the requirements of 
the Unregulated Contaminant Monitoring Regulation did not apply to the 
Naval Air Weapons Station, China Lake, in California, because its water 
supply system was too small, installation officials volunteered to 
sample for perchlorate and other unregulated contaminants. Accordingly, 
in October 2003, officials at China Lake sampled 10 drinking water 
wells for perchlorate and other contaminants, but perchlorate was not 
detected.

DOD Has Not Directed the Services to Clean Up Known Perchlorate 
Contamination: 

According to information provided by DOD and officials at the 
installations we visited, the services were generally not cleaning up 
known perchlorate contamination. DOD officials explained that 
perchlorate is not a regulated contaminant and, therefore, there is no 
requirement to clean up perchlorate contamination.[Footnote 27] 
(Current DOD policy is that DOD will clean up perchlorate if there is 
imminent and substantial endangerment to the public.) The exceptions we 
found were two installations that had cleaned up perchlorate under 
demonstration projects designed to demonstrate perchlorate cleanup 
technologies. At the installations we visited, perchlorate 
contamination was generally the result of research, manufacturing, 
testing, and disposal of munitions (such as rocket motors) that 
contained high levels of perchlorate. In one case, the perchlorate 
resulted from training with smoke munitions containing perchlorate.

Although six of the seven sites we visited reported high levels of 
perchlorate contamination, none of these installations were conducting 
cleanup actions specifically directed at perchlorate. However, at two 
installations we visited--Edwards Air Force Base and the Naval Surface 
Warfare Center, Indian Head--officials said they conducted 
demonstration projects to develop perchlorate treatment and cleanup 
technologies in anticipation of future cleanup requirements. (See app. 
III for details on these demonstration projects.)

At six of the seven installations we visited that had operational 
ranges and detectable levels of perchlorate, we found the perchlorate 
contamination was generally not due to training on operational ranges. 
Rather, we found that prior and ongoing research, manufacturing, 
testing, and disposal of rocket motors were primarily responsible for 
perchlorate contamination. (See app. IV for details of perchlorate 
contamination caused by such factors.) Only Aberdeen Proving Ground, in 
Maryland, reported that some perchlorate contamination was due to the 
use of perchlorate during training exercises on operational ranges. 
Further, Aberdeen was the only installation we visited where 
perchlorate had contaminated a neighboring municipal water supply. At 
Aberdeen, perchlorate concentrations of up to 5 parts per billion have 
been detected in drinking water supply wells and 24 parts per billion 
have been detected in groundwater.

Between June and August 2002, Aberdeen Proving Ground sampled drinking 
water wells owned by the city of Aberdeen located in and along the 
northern border between the city and the installation, and detected 
perchlorate contamination in four wells ranging from 1.2 to 5 parts per 
billion. According to Aberdeen officials, the installation sampled for 
perchlorate because it was required to do so by the state of Maryland. 
Groundwater samples taken near the well field showed a large 
perchlorate plume with contamination levels up to 24 parts per billion. 
Aberdeen Proving Ground officials attributed the perchlorate 
contamination to intensive testing and training with smoke grenades and 
other obscurants. Until about mid-2002, during training exercises in 
the vicinity of the city of Aberdeen drinking water wells, Aberdeen 
Proving Ground trained troops using smoke grenades that contained 
perchlorate. After perchlorate was found in city drinking water, 
Aberdeen Proving Ground stopped all training with smoke grenades 
containing perchlorate. However, officials at Aberdeen Proving Ground 
are not cleaning up the perchlorate detected in city wells. Instead, 
both the city of Aberdeen and the installation sample finished water 
and production wells on an alternating monthly schedule: Finished water 
is sampled weekly, four production wells are sampled twice a month, and 
the remaining eight production wells are sampled monthly. Recent 
sampling has detected contamination below the EPA interim assessment 
guidance of 4 parts per billion, but in some cases, well samples have 
been above the Maryland Department of the Environment public health 
advisory for perchlorate, which is 1 part per billion for drinking 
water. In the event a sample is found to be above the Maryland state 
advisory limit, the city of Aberdeen blends well water without 
perchlorate with well water containing perchlorate to lower the 
concentration level to below 1 part per billion. The Army stated that 
it would not clean up the perchlorate contamination at Aberdeen until 
an EPA maximum contaminant level for perchlorate in drinking water is 
established.

Conclusions: 

Because of DOD's approach to how it inventoried its operational ranges 
for munitions and how it estimated the costs to clean up those ranges, 
both the inventory and the cost estimates are questionable. Further, 
DOD did not fully disclose to Congress the basis and limitations of its 
estimates, including identifying estimates based on direct observations 
and those based on assumptions, and the affect of assumptions on DOD's 
cost estimates. Instead, DOD provided only general information to 
Congress on the assumptions and cost model used without specific 
details on how costs were developed or the effect of assumptions used 
on the resulting cost estimates. Consequently, we believe it is 
difficult for Congress to evaluate the cost estimates DOD provided and 
that it may be unwise to rely on them for assessing the potential 
liability associated with contamination on operational ranges. Reliable 
cost estimates can be a critical piece of information for DOD and 
Congress when considering the potential costs versus benefits of 
closing operational ranges or entire installations. However, such 
estimates must be based on accurate data that, in terms of ranges, 
begins with a complete and accurate operational range inventory.

DOD installations have conducted little or no sampling for perchlorate 
under DOD's perchlorate policy, and DOD has not provided specific 
funding to the services to conduct the sampling that is required by its 
policy. Available information indicates that testing for perchlorate on 
installations has been limited and is specifically needed at facilities 
that are or were involved in research, manufacturing, testing, and 
disposal of munitions. DOD's decision not to provide specific funding 
to the services for sampling hampers the ability of DOD, as well as EPA 
and the states, to collect better data on the extent and nature of 
possible perchlorate contamination on military installations. Such 
information could be important to regulators when determining if there 
is a potential public health risk from perchlorate and deciding what, 
if any, actions might be warranted. Further, the lack of such 
information impedes DOD and congressional efforts for planning and 
budgeting future cleanup that may be required if federal or state 
standards regulating perchlorate are adopted.

Recommendations for Executive Action: 

In order to the assist Congress, EPA, and state regulators in assessing 
and planning for the cleanup of contamination associated with military 
munitions at operational ranges, we are making the following two 
recommendations: 

* To improve congressional oversight of DOD and its operational ranges, 
including providing Congress with more realistic estimates of the 
potential liability associated with cleaning up contamination related 
to the use of military munitions, we recommend that DOD, using a more 
consistent estimating methodology, use its most complete operational 
range inventory to revise its cost estimates for the cleanup of 
operational ranges. The revised estimates should include an explanation 
of the basis and scope on which the inventory was conducted, and how 
the cost estimates were calculated. The estimates should be accompanied 
by a detailed description of how costs were developed, such as where 
estimates and assumptions were used, the basis of and rationale for any 
assumptions used, and an explanation as to how such assumptions 
affected cost figures.

* To develop information needed by Congress, EPA, and the states, such 
as the location and amount of perchlorate contamination, when deciding 
what, if any, actions are warranted to address such contamination, we 
recommend that DOD, acting under its revised perchlorate sampling 
policy, provide specific funding for comprehensive sampling at sites 
where no prior sampling has been conducted, yet perchlorate 
contamination is likely and human exposure is possible based on the 
sites' prior or current use. To help identify possible sites of 
perchlorate contamination, we recommend DOD consolidate and review 
sampling data previously collected by installations under environmental 
laws governing the release or disposal of various hazardous substances.

Agency Comments and Our Evaluation: 

In its May 6, 2004, letter, DOD disagreed with our findings and 
recommendations. DOD also provided technical comments and 
clarifications that we incorporated in the report, as appropriate.

DOD disagreed with our conclusion that it did not have a comprehensive 
policy requiring sampling or cleanup of munitions constituents on 
operational ranges, and that it generally has not taken actions to 
clean up contaminants. In its letter, DOD cited specific policies in 
place requiring the services to address the release of munitions 
constituents. However, the guidance DOD cited pertains only to the 
migration of munitions constituents off-range and the reporting of 
environmental liabilities, but does not address the sampling or cleanup 
of munitions constituents found on operational ranges that are the 
subject of this report. Further, DOD's letter states that it is 
responding to munitions constituents at 23 installations and ranges. We 
acknowledge that DOD is sampling for, and in some cases, cleaning up 
munitions constituents when directed to do so by EPA or a state 
environmental agency under various environmental laws. In reviewing the 
data provided by DOD, however, we found that only 2 of the 
installations they cited had operational ranges and both of those were 
being cleaned up because of EPA direction or a court order. At the 12 
other installations with active ranges, half of them had sampled or 
were sampling for munitions constituents as a result of EPA or state 
environmental agency requests, RCRA requirements, or cleanup associated 
with Superfund hazardous waste sites. None of these installations, 
however, were cleaning up the munitions constituents found as a result 
of sampling.

DOD disagreed with our assessment that its inventory data and cost 
estimates were questionable and said it was not necessary to revise its 
cost estimates because inventory data used to develop the estimates 
were "accurate within reason." In its comments, DOD stated that it was 
not required to use validated costing assumptions, or a consistent 
estimating methodology, because the fiscal year 2002 National Defense 
Authorization Act provided that the standard for the report of 
liabilities did not apply to DOD's cost estimates. Although the act 
allowed DOD to develop cost estimates that did not meet the same 
standards as required for the report of liabilities in DOD's annual 
financial statement, we believe that DOD had a responsibility to 
provide Congress with useful information by making a reasonable attempt 
to prepare accurate and complete estimates, including assuring that its 
assumptions were valid. However, as our report sets out, the 
inconsistencies in how DOD collected and analyzed data on operational 
ranges raise questions about the reliability of DOD's inventory. 
Specifically, DOD did not provide Congress with a detailed description 
of how the costs were prepared and an explanation of where site-
specific data were used in place of assumptions, why specific and 
different assumptions were used by the services, and how assumptions 
affected the overall cost estimates. Without DOD's supporting data and 
analysis, it is difficult for Congress to evaluate the accuracy or 
validity of the cost estimates DOD provided and it may be unwise to 
rely on them for assessing the potential liability associated with 
contamination on operational ranges.

DOD disagreed with our recommendation that it needed to develop new 
cost estimates for cleaning up operational ranges, stating that it is 
developing a system for providing auditable data that meets the 
standards for the report of liabilities and is actively assessing its 
ranges for potential munitions constituent migration to off-range 
areas. However, the requirement in the National Defense Authorization 
Act for fiscal year 2002 was to report estimated costs to clean up 
operational ranges, not the costs to respond to or clean up constituent 
migration off-range. In its letter to GAO, DOD also questioned whether 
decision makers would find useful an estimated cost to clean up 
operational ranges and asserted that it is not required to develop 
cleanup estimates for operational ranges until such costs become 
probable and estimable by accounting standards. We disagree with DOD's 
view of the information and its usefulness to Congress. Congress on two 
occasions asked DOD to provide just such information. Specifically, the 
2002 Defense Authorization Act required that DOD report this 
information. In addition, the Senate Committee on Armed Services, in 
its report accompanying the National Defense Authorization Act for 
fiscal year 2000 (S. Rep. No. 106-50), directed DOD to provide to the 
congressional defense committees a report with a complete estimate of 
current and projected costs to clean up munitions constituents. In our 
opinion, the authorization act's requirement and the committee's 
direction provide ample evidence that congressional decision makers 
would find such information useful.

DOD also disagreed with our recommendation that DOD provide specific 
funding for sampling for perchlorate. As our report points out, DOD's 
current policy on perchlorate sampling designates funding for sampling 
as a Class I high priority environmental project. This means that 
perchlorate sampling is a priority for funding, along with all other 
high priority environmental projects. As a result, perchlorate sampling 
must compete with other high priority environmental priorities for 
funding and, due to limited funds, may not be funded. The result is 
that while DOD policy has designated a funding mechanism for 
perchlorate, DOD's policy cannot assure that perchlorate sampling will 
be funded. Simply stated, if DOD wants to assure that installations 
conduct perchlorate sampling where appropriate, then it will need to 
provide specific funding for this sampling.

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, 
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].

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

Signed by: 

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

[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. Unexploded ordnance poses a risk of physical injury to 
those who encounter it. Military munitions may also pose a health and 
environmental risk especially on ranges located in ecologically 
sensitive wetlands and floodplains because their use and disposal may 
release constituents that may contaminate soil, groundwater, and 
surface water. More than 200 chemical munitions constituents are 
associated with ordnance and its use. When exposed to some of these 
constituents, humans potentially face long-term health problems, such 
as cancer and damage to the heart, liver, and kidneys.

Munitions Constituents of Greatest Concern: 

Of the more than 200 chemical munitions constituents associated with 
ordnance and its use, DOD considers 20 to be of greatest concern 
because of their widespread use and potential environmental impact. The 
20 munitions constituents, taken from DOD's Fiscal Year 2002 Defense 
Environmental Restoration Program Annual Report to Congress, are: 

* 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, and: 

* N,2,4,6-Tetranitro-N-methylaniline (Tetryl) (White Phosphorus).

While many of these compounds have been an environmental concern to DOD 
for more than 20 years, the current understanding of the causes, 
distribution, and potential effect of constituent releases into the 
environment remains limited. The nature of the potential effect, and 
whether it poses an unacceptable risk to human health and the 
environment, depends upon the dose, duration, and pathway of exposure, 
as well as the sensitivity of the exposed populations. The link between 
constituents and their potential health effects is not always clear and 
continues to be studied. Table 6 describes some of the potential health 
effects of five of the munitions constituents of greatest concern.

Table 6: Potential Effects of the Munitions Constituents Closely 
Associated with Military Munitions: 

Contaminant: Trinitrotoluene (TNT); 
Potential toxicity/effects: Possible human carcinogen. Targets liver, 
skin, irritations, cataracts.

Contaminant: Royal Demolition Explosive (RDX); 
Potential toxicity/ effects: Possible human carcinogen, prostate 
problems, nervous system problems, nausea, and vomiting. Laboratory 
exposure to animals indicates potential organ damage.

Contaminant: High Melting Explosive (HMX); 
Potential toxicity/effects: Animal studies suggest potential liver and 
central nervous system damage.

Contaminant: 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.

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

Source: Environmental Protection Agency.

[End of table]

[End of section]

Appendix II: Scope and Methodology: 

You asked us to determine (1) how DOD identified the location and last 
active use of all operational ranges and the basis for DOD's cost 
estimates for cleaning up those ranges; and (2) DOD's policy on 
sampling for contaminants linked to the use of ordnance on operational 
ranges and, where munitions-related contaminants have been detected, 
what corrective actions the services have taken. Specifically, you 
asked us to focus on DOD's actions with regard to perchlorate.

To determine how DOD identified the location and last active use of all 
operational ranges, we reviewed the services' inventory data and 
interviewed service headquarters officials to determine how the 
inventories were conducted and the reliability of the data collected. 
We assessed the reliability of the services' data (1) by reviewing 
existing information about the data and the processes that produced 
them and (2) by interviewing DOD officials knowledgeable about the 
data. We determined that data on the number of operational ranges and 
acreage were sufficiently reliable to include in our report; however, 
we determined that data on range characteristics were unreliable. 
Although we found the data on range characteristics to be unreliable, 
we present the data for informational purposes. To determine the basis 
for DOD's cost estimates for cleaning up operational ranges, we 
reviewed the services' estimated costs, supporting analyses, and 
calculations, and interviewed service and DOD officials on the scope 
and methodology used to develop cost estimates.

To identify DOD's policy on sampling for constituents linked to the use 
of ordnance on operational ranges, we reviewed DOD's and the service's 
policies related to the sampling and cleanup of potential contaminants 
and specifically their policies on perchlorate. We also interviewed 
officials at both headquarters and several installations on the 
implementation of DOD and service policies. To report on what actions 
the services have taken with regard to munitions constituents and 
perchlorate, we visited seven DOD installations where perchlorate had 
been detected and discussed what efforts have taken place, or were 
planned, to respond generally to munitions-related contaminants and 
specifically for perchlorate. We selected installations based on 
available data but were unable to determine the total number of 
installations reporting perchlorate contamination. We selected 
installations where generally high levels of perchlorate had been 
detected or, in one case, where perchlorate had contaminated a local 
municipal water supply. We also based our selection on the desire to 
include at least two installations from each military department and 
installations from different states or geographic locations in order to 
provide a mix of services and state agencies. (See table 7 for a 
listing of the installations we visited.)

During our visits, where possible, we observed the areas of 
contamination as well as any cleanup demonstration projects under way. 
To identify what levels of contamination had been detected at DOD 
installations, we first obtained various summary schedules and lists of 
active and closed DOD and non-DOD sites with suspected or detected 
perchlorate contamination from both EPA and DOD. Because DOD has only 
recently begun to collect data on perchlorate, none of the listings we 
obtained included all installations. Further, most lists did not 
generally contain current data and were incomplete. Additionally, much 
of the data was redundant, with the same installations appearing on 
more than one list. Prior to selecting an installation to visit, 
therefore, we contacted service officials to verify that perchlorate 
contamination had, in fact, been detected. Our observations about 
perchlorate contamination and response actions at these installations 
are not generalizable to all military installations.

Table 7: Installations Visited during Our Review: 

Installation: Edwards Air Force Base; 
Military department: Air Force; 
State: California; 
Perchlorate contamination levels initially detected or reported: Up to 
160,000 parts per billion in groundwater (detected in 1997).

Installation: Holloman Air Force Base; 
Military department: Air Force; 
State: New Mexico; 
Perchlorate contamination levels initially detected or reported: About 
16,000 parts per billion in surface water (detected in 1999).

Installation: Aberdeen Proving Ground; 
Military department: Army; 
State: Maryland; 
Perchlorate contamination levels initially detected or reported: 5 
parts per billion in drinking water and 24 parts per billion in 
groundwater (reported in 1998).

Installation: Redstone Arsenal; 
Military department: Army; 
State: Alabama; 
Perchlorate contamination levels initially detected or reported: About 
19,000 parts per billion in groundwater (as of 2000).

Installation: White Sands Missile Range; 
Military department: Army; 
State: New Mexico; 
Perchlorate contamination levels initially detected or reported: 21,000 
parts per billion in groundwater (reported in 1998).

Installation: Naval Air Weapons Station, China Lake; 
Military department: Navy; 
State: California; 
Perchlorate contamination levels initially detected or reported: 560 
parts per billion in groundwater (detected in 2001).

Installation: Naval Surface Warfare Center, Indian Head; 
Military department: Navy; 
State: Maryland; 
Perchlorate contamination levels initially detected or reported: More 
than 1,000 parts per billion in surface water (reported in 1998). 

Source: GAO.

[End of table]

[End of section]

Appendix III: Installations That Were Cleaning Up Perchlorate as a 
Result of Demonstration Projects: 

Although we found no installations were cleaning up perchlorate, two 
installations we visited were conducting or had conducted demonstration 
projects of new technologies to clean up perchlorate, in anticipation 
of future cleanup requirements.

Edwards Air Force Base: 

In May 2003, Edwards Air Force Base, in California, began a 
demonstration project to remove perchlorate from groundwater. Edwards 
officials said the installation funded the project because the Air 
Force is DOD's lead agency for perchlorate-related efforts and expected 
to help develop perchlorate treatment technologies. Edwards first 
detected perchlorate on the installation in 1997, while testing for 
other contaminants, and has detected perchlorate at 10 sites on the 
installation. Perchlorate contamination of 160,000 parts per billion 
was detected at one site where the source of the contamination is 
attributed to the use of perchlorate by various research facilities 
beginning about 1945. On this site the Air Force constructed a well 
field and project treatment facility. The demonstration project uses 
resin beads, which act like a magnet to pull perchlorate out of the 
water. Four wells extract groundwater that is discharged into a storage 
tank and then pumped through treatment equipment containing the resin. 
Treated groundwater is returned to the aquifer through five injection 
wells. Plans are to operate the project through July 2005. Currently, 
Edwards officials report that perchlorate continues to be removed to 
nondetectable levels, or less than 1 part per billion.

Naval Surface Warfare Center, Indian Head: 

In 2002, the Naval Surface Warfare Center, Indian Head, in Maryland, 
funded a field demonstration project using naturally occurring 
microorganisms, or bacteria, that break down or consume perchlorate. 
Navy officials first became concerned about perchlorate in 1998 when 
they learned of widespread perchlorate contamination at DOD sites in 
California. At that time, the installation regularly drained 
perchlorate-contaminated water into ditches and two bordering rivers. 
In 2001, Navy officials sampled and detected a shallow and well-defined 
plume of perchlorate contamination located in an area where the Navy 
once cleaned small rocket motors using a high-pressure wash. 
Perchlorate levels detected in the area ranged from 8,000 to 430,000 
parts per billion. On this site in early 2002, the Navy installed two 
extraction wells, two injection wells, and nine groundwater monitoring 
wells. Groundwater was removed from the site, mixed with a lactate and 
a carbonate/bicarbonate liquid mixture, and then reinjected into the 
aquifer. After 20 weeks, perchlorate levels were reduced by more than 
95 percent in eight of the nine monitoring wells. According to Navy 
officials, the mixture acted as an oxidizer to stimulate microorganisms 
that consumed the perchlorate. Officials said they plan to reuse the 
equipment to field test the technology at another site in an attempt to 
clean soil contaminated with perchlorate.

[End of section]

Appendix IV: Installations That Identified Perchlorate as a Result of 
Munitions Research, Manufacturing, Testing, and Disposal Activities: 

We visited installations that had operational ranges and detectable 
levels of perchlorate but found the perchlorate contamination was 
generally not due to training, but rather due to prior and ongoing 
research, testing, manufacturing, and disposal of rocket motors and 
propellant waste on operational ranges and other parts of the 
installations.

Edwards Air Force Base: 

Perchlorate contamination was detected at 10 sites on Edwards Air Force 
Base beginning in 1997. Officials attributed all detected perchlorate 
contamination to rocket propellant manufacturing, research, 
development, and testing, and not to the use of munitions during 
training. The maximum perchlorate contamination level detected was 
160,000 parts per billion in groundwater at one site. Officials said no 
live bombs had been exploded on Edwards Air Force Base ranges since 
1952, and some ranges where bombs were exploded have been closed. 
Perchlorate is not used as part of current range activities, and 
Edwards Air Force Base does not test for contaminants on operational 
ranges, installation officials said.

Holloman Air Force Base: 

In March 1999, after a rainstorm, the U.S. Geological Survey sampled 
for perchlorate in a normally dry riverbed at Holloman Air Force Base, 
in New Mexico, and detected contamination of 16,000 parts per billion. 
During periods of rain, the river flows from the installation to the 
neighboring White Sands National Monument. The contamination was found 
on the installation near a former munitions operations site and rocket 
sled. Air Force officials said it was unlikely that the contamination 
was due to training. They attributed the perchlorate contamination to 
munitions research and testing in the 1960s and 1970s. Officials at 
White Sands National Monument attributed the perchlorate contamination 
to spent rocket motors stacked near the river and a high-speed rocket 
sled used to test the effects of acceleration. DOD and New Mexico's 
state environmental agency sampled the riverbed and surrounding area 
again in 1999 and 2000 but did not find the high concentration of 
perchlorate previously detected. Air Force officials said they believed 
the 16,000 parts per billion detected in 1999 was an anomaly.

Naval Surface Warfare Center, Indian Head: 

At the time of our visit, officials at the Naval Surface Warfare 
Center, Indian Head, in Maryland, reported they detected perchlorate 
contamination at five sites on the installation, of which three were 
landfills, one was a metal parts disposal site, and one was a metal 
parts degreasing tank site. Indian Head detected maximum perchlorate 
concentrations between 88 and 450,000 parts per billion in the soil at 
two of the three landfills. At the third landfill, a perchlorate 
concentration of 2,000 parts per billion was detected in the 
groundwater. However, none of the contamination detected was attributed 
to the use of perchlorate during training exercises on operational 
ranges.

Redstone Arsenal: 

As of March 2004, Redstone Arsenal, in Alabama, detected perchlorate 
contamination in the groundwater at 2 sites and in surface water and 
soil at 11 other sites. Redstone Arsenal officials attributed 
contamination to various past production, maintenance, and disposal 
activities at a number of sites, including at open burning areas used 
to incinerate waste rocket motor propellant, burning trenches used to 
incinerate solid material contaminated with rocket propellant, a rocket 
engine plant, motor degreasing and trimming areas, and a propellant 
waste storage area. Perchlorate contamination of about 20 parts per 
billion was also detected in ground and surface water outside the 
installation. The highest concentration levels detected in groundwater 
on Redstone installations have ranged from 106,000 to 160,000 parts per 
billion and the highest concentration levels detected in surface water 
have ranged from 377 to 1,700 parts per billion. Although Redstone 
Arsenal has conducted training on the installation, none of the 
contamination detected has been attributed to the use of perchlorate 
during training exercises.

White Sands Missile Range: 

White Sands Missile Range, in New Mexico, detected perchlorate 
contamination at two sites beginning in 1999. At one site, sampling 
detected perchlorate concentrations up to 25,000 parts per billion. 
Officials said they were unsure of the precise cause of the 
contamination but said they initially believed it was due to an open 
burning and detonation facility used in the 1950s to incinerate rocket 
motors. However, officials also said that the contamination plume was 
uphill from where the open burning and detonation site is believed to 
have been, so that the contamination may be generally due to previous 
testing of hazardous materials in the area. Perchlorate was also found 
at the former site of a high-energy laser system test facility. 
Perchlorate contamination detected has been as high as 118 and 295 
parts per billion in some wells. Officials said the contamination might 
be due to open ground burning of expended test items, or residue from 
actual tests, conducted prior to 1995. Officials said they planned to 
conduct more sampling to precisely identify the source of the 
perchlorate but did not attribute any of the perchlorate detected to 
training exercises on operational ranges.

Naval Air Weapons Station, China Lake: 

At the time of our visit in October 2003, the Naval Air Weapons 
Station, China Lake, in California, had detected perchlorate at five 
sites on the installation. Perchlorate contamination was predominantly 
found in drainage and waste disposal areas, most likely the result of 
research on propellants and explosives, and residue from the 
manufacture of propellants. Installation officials said that since the 
1960s, thousands of pounds of perchlorate-based propellant have been 
stored and tested on China Lake. In July 2003, installation officials 
sampled and detected perchlorate concentrations of 778 and 921 parts 
per billion at two wells and at a drainage site. However, none of the 
contamination detected is attributed to the use of munitions during 
training exercises on operational ranges.

[End of section]

Appendix V: Comments from the Department of Defense: 

OFFICE OF THE UNDER SECRETARY OF DEFENSE:
3000 DEFENSE PENTAGON 
WASHINGTON, DC 20301-3000:

ACQUISITION, TECHNOLOGY AND LOGISTICS:

MAY - 6 2004:

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 
report, "DOD OPERATIONAL RANGES: More Reliable Cost Estimates and a 
Proactive Approach to Identifying Contamination Are Needed," May 2004 
(GAO-04-601).

The Department nonconcurs with GAO recommendations that the Department 
(1) revise its cost estimates for the cleanup of operational ranges and 
(2) provide specific funding for sampling at sites where perchlorate 
contamination is likely. Enclosed are specific comments on each of 
these recommendations.

The Department also nonconcurs with the GAO findings that (1) the 
reliability of DoD's inventory is questionable, (2) DoD's cost 
estimates are questionable, (3) DoD does not have a comprehensive 
policy requiring sampling, (4) neither DoD nor the Services provide 
specific funding to installations to sample for or cleanup contaminants 
linked to munitions use, and (5) no corrective actions have been taken 
by DoD specifically directed at cleaning up contaminants, such as 
perchlorate. Enclosed are specific comments on each of these findings.

Although some of GAO's points merit discussion, the Report presents an 
invalid characterization of the Department's environmental efforts at 
operational ranges. The Department believes that government decision 
makers deserve a more accurate and objective analysis of the 
Department's Sustainable Range policies and actions.

The Report incorrectly asserts that DoD does not have a comprehensive 
policy requiring sampling or cleanup of munitions constituents. A 
careful examination of the Department's policies and actions 
demonstrate that it has comprehensive policies in place to address 
munitions constituents associated with operational ranges. The Report 
mentions none of the key policies. For example:

* Since 1999, DoDI 4715.11 has required the Services to conduct an 
appropriate response using existing statutory authorities (e.g., DERP, 
CERCLA) to any release of munitions constituents that are migrating 
from an operational range to off-range 
areas. An update to be published soon will further require assessments 
of the hydrology and hydrogeology of operational ranges and how the 
ranges are being or have been used.

* The Defense Planning Guidance (DPG) for Fiscal Years 2004-2009 
established a requirement for the Services to "... assess potential 
hazards from off-range migration of munitions constituents and begin 
remediation by FY2008." The Services have begun implementing programs 
to conduct operational range assessments, and are expecting to begin 
any necessary responses by the FY08 date.

DoD Directive 3200.15 "Sustainment of Ranges and Operating Areas 
(OPAREAs)" requires reporting of environmental liabilities for 
operational ranges where the Department of Defense is obligated to 
conduct environmental remediation, in accordance with DoD 7000.14-R 
(the DoD Financial Management Regulations).

The Report states that, "DoD policy does not require the Services to 
clean up or sample for munitions contaminants." In fact, the Department 
has had policy in place on response actions for some time. In addition 
to the failure to discuss current policies, GAO does not address new 
or expanding policies that the Department presently has under 
development.

The Report also asserts that, "To date, no corrective actions have been 
taken specifically directed at cleaning up contaminants when they have 
been detected." Again, this observation is not factual. DoD is 
responding to munitions constituents at twenty-three installations and 
ranges, as is illustrated in the enclosures. The Report fails to 
recognize DoD's efforts at these sites.

Finally, the Report asserts that DoD's operational range inventory and 
its estimates of cleanup costs are "questionable." However, the Report 
provides no supporting analysis for this conclusion and is misleading 
in that it does not factually address:

* The adequacy of inventory data to support cost estimating.

* The specific Congressional direction to DoD about development of the 
aggregate high-low cost estimates.

* The reasonableness of the assumptions in the detailed estimating 
guidance the Department developed.

* Differences in the way the Services use and manage operational ranges 
and the impact of these differences in cost estimates among the 
Services.

In addition, the Report incorrectly assumes that decision makers would 
find a cost to clean up an operational range useful. The decision to 
close an operational range will not be determined by cleanup cost. It 
will be determined by whether the range is needed for operational 
requirements. An estimate of the cost to clean up a range will be 
developed after the range is no longer operational. There is no 
requirement for DoD to produce cleanup estimates for operational 
ranges.

The report also misrepresents the current state of affairs because it 
fails to report the facts surrounding EPA's treatment of perchlorate 
regulation. The report insinuates that DoD has some affirmative 
responsibility to sample for perchlorate under the Safe Drinking Water 
Act beyond Unregulated Contaminate Monitoring Rule requirements, which 
is not the case.

This response and the enclosed materials are provided to help GAO 
better understand and recognize DoD's policies and actions. Enclosure 1 
provides the Department's specific responses to GAO's Report Findings 
and Recommendations. Enclosure 2 offers the Department's detailed, 
line-by-line analysis of the elements of GAO's report. Enclosures 3 and 
4 provide examples of 
the Services' operational range assessment programs that assess 
potential hazards from off-range migration of munitions constituents. 
Enclosures 5, 6, and 7, which the U.S. Environmental Protection Agency 
provided to Congressman Dingell in response to an inquiry, provide some 
details on munitions constituents. Specifically:

* Enclosure 5 provides information on DoD installations where sampling 
for perchlorate and other munitions constituents is ongoing:

* Enclosure 6 provides information on occurrences of perchlorate or 
other constituents of military munitions in public or private drinking 
water wells where a DoD facility is a possible or likely source of the 
occurrence.

* Enclosure 7 provides information on DoD installations where EPA has 
reason to believe that a constituent of military munitions, including 
perchlorate, TNT, RDX, HMX, or White Phosphorus has been detected or 
discovered, and the status of the response action.

Taken together, the analytical and logical deficiencies in this Report 
render the findings and recommendations invalid. The Department 
recommends that the Report be withdrawn and a new analysis be 
undertaken.

Sincerely,

Signed by: 

Alex A. Beehler: 
Assistant Deputy Under Secretary of Defense 
(Environment, Safety, and Occupational Health):

Enclosures: As stated. 

[End of section]

Appendix VI: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

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

Staff Acknowledgments: 

In addition to those named above, Christine Frye, Roderick Moore, David 
Noguera, and Doreen Feldman made key contributions to this report. John 
Delicath and Amy Webbink also contributed to this report.

(360349): 

FOOTNOTES

[1] DOD was also required to provide a separate estimate for all other 
defense sites. 

[2] DOD's Fiscal Year 2002 Defense Environmental Restoration Program 
Annual Report to Congress. 

[3] The installations we visited were Holloman Air Force Base, in New 
Mexico; Edwards Air Force Base, in California; Army Redstone Arsenal, 
in Alabama; Army Aberdeen Proving Ground, in Maryland; Army White Sands 
Missile Range, in New Mexico; Naval Surface Warfare Center, Indian 
Head, in Maryland; and Naval Air Weapons Station, China Lake, in 
California. We selected installations based on available data, but were 
unable to determine the total number of installations reporting 
perchlorate contamination. DOD and EPA had only recently begun to 
collect data on perchlorate and data lists were not always current or 
complete, and were often redundant in that the same installations 
appeared on more than one list of installations reporting 
contamination. 

[4] DOD has other policies requiring the services to assess potential 
hazards from munitions constituents migrating from operational ranges 
to off-range areas. 

[5] DOD no longer distinguishes between active and inactive ranges. The 
current statutory definition of an operational range is "a range that 
is under the jurisdiction, custody, or control of the Secretary of 
Defense and (A) that is used for range activities, or (B) although not 
currently being used for range activities, that is still considered by 
the Secretary to be a range and has not been put to a new use that is 
incompatible with range activities." Pub. L. No. 108-136, § 1042(e)(3) 
(Nov. 24, 2003). 

[6] DOD distinguishes range cleanup from range clearance. Range 
clearance is routine, conducted for the continued use of active ranges, 
and performed primarily for safety reasons, whereas range cleanup 
involves interim removal, remedial activities, and a final remedy, but 
only for closed ranges. 

[7] Pub. L. No. 107-107 (Dec. 28, 2001).

[8] This report deals with operational ranges on active installations. 
In December 2003, we issued a report on closed installations or those 
in the process of closing. As of September 2002, DOD had closed 542 
ranges on open installations and 74 ranges on installations closed 
under the Base Realignment and Closure process, and is required to 
clean up munitions contamination on these ranges, if present. See U.S. 
General Accounting Office, Military Munitions: DOD Needs to Develop a 
Comprehensive Approach for Cleaning Up Contaminated Sites, GAO-04-147 
(Washington, D.C.: Dec. 19, 2003).

[9] Pub. L. No. 107-314 (Dec. 2, 2002).

[10] U.S. General Accounting Office, Environmental Liabilities: DOD 
Training Range Cleanup Cost Estimates Are Likely Understated, GAO-01-
479 (Washington, D.C.: Apr. 11, 2001). 

[11] A public water system is subject to the Safe Drinking Water Act if 
the system has at least 15 service connections or regularly serves at 
least 25 individuals.

[12] None of the approximately 90 contaminants regulated by EPA under 
the Safe Drinking Water Act are associated with the use of military 
munitions. Some regulated contaminants, such as arsenic, may result 
from the use of military munitions, but EPA does not regulate arsenic 
resulting from such use. It does, however, regulate arsenic found in 
drinking water resulting from the erosion of natural deposits, runoff 
from agriculture sites, and certain production wastes.

[13] 40 C.F.R. § 141.40.

[14] 40 C.F.R. § 401.15.

[15] Castaic Lake Water Agency v. Whittaker Corp, 272 F. Supp. 2d 1053 
(C.D. Cal. 2003). The conclusion that perchlorate is a hazardous waste 
was the first step in the court's analysis of whether perchlorate is a 
hazardous substance under CERCLA. (The definition of hazardous 
substances under CERCLA includes hazardous waste under RCRA.)

[16] Section 107 of the Federal Facility Compliance Act amended RCRA by 
adding a new section 3004(y), codified at 42 U.S.C. § 6924(y). 

[17] 40 C.F.R § 266.202.

[18] Under the Defense Environmental Restoration Program established 
under section 211, 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. 

[19] 42 U.S.C. § 300g-1(b)(1)(E).

[20] On September 26, 1997, DOD published a proposed range rule on 
closed, transferred, and transferring ranges containing military 
munitions. The proposed rule identified a process for evaluating 
response action on closed, transferred, and transferring ranges and 
required a comprehensive inventory of DOD ranges, including a 
collection of descriptive data for each range. However, the proposed 
rule applied to nonoperational ranges only. On November 13, 2000, DOD 
withdrew the proposed range rule from the rule-making process because 
DOD, EPA, and federal land managers could not reach consensus on 
several key issues, including how explosive safety would be handled 
under the rule, concurrence on remedial actions, and who would decide 
the remedy. 

[21] DOD Directives 4715.11 and 4715.12. 

[22] Army officials told us the Army assumed 60 percent of operational 
range acreage was highly contaminated, but our analysis of Army data 
(see table 4) shows the Army actually assumed that 58 percent of 
acreage was highly contaminated. 

[23] In some instances, EPA has used its authority under these acts to 
require cleanup of munitions constituents on operational ranges. For 
example, at Fort Richardson, Alaska, EPA required the Army to clean up 
contamination caused by munitions containing white phosphorus. 

[24] See 40 C.F.R. § 401.15. The three constituents--2,4 and 2,6 
dinitrotoluene (used to produce explosives and ammunition and known to 
cause cancer) and nitrobenzene (may be used in defense manufacturing 
and linked to blood disorders)--are on DOD's list of munitions 
constituents of greatest concern. 

[25] To assure compliance with the requirements of environmental laws, 
DOD has an environmental quality program that is largely funded by 
DOD's appropriation for operation and maintenance activities. This 
account also funds a wide range of installation activities such as 
military training, base operations, and property management. As such, 
DOD's environmental quality program must compete with these other 
activities for funding. As GAO reported in June 2003, DOD's 
environmental quality program has a ranking system for funding 
environmental activities where activities ranked Class 0 or I must be 
funded in the current program year because of a law or regulation, 
whereas funding for activities ranked Class II or III may be deferred 
because there is no legislative requirement in the current budget year. 
We found DOD did not always have sufficient funds to pay for 
environmental priorities and sometimes did not follow the program's 
ranking system and instead funded lower priority activities while not 
funding some higher priorities. See U.S. General Accounting Office, 
Environmental Compliance: Better DOD Guidance Needed to Ensure That the 
Most Important Activities Are Funded, GAO-03-639 (Washington, D.C.: 
June 17, 2003).

[26] Initially, Army officials said they believed the perchlorate 
contamination resulted from the burning of rocket motors in pits at the 
open burning and detonation facility. More recently, however, Army 
officials speculated that the plume in the hazardous test area is from 
another unknown source because it is uphill from the open burning and 
detonation facility.

[27] Although there is not a standard for perchlorate under the Safe 
Drinking Water Act, in at least one instance EPA required the Army to 
clean up munitions constituents in groundwater, such as perchlorate. 
EPA required the Massachusetts Military Reservation to clean up 
munitions constituents under its Safe Drinking Water Act authority, 
which allows it to take action when there is an imminent and 
substantial endangerment to the health of persons. 42 U.S.C. § 300i(a). 


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