DOD Operational Ranges:

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

GAO-04-601: Published: May 28, 2004. Publicly Released: Jun 29, 2004.

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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. Congress 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.

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. 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.

Recommendations for Executive Action

  1. Status: Closed - Not Implemented

    Comments: Since DOD does not agree with this recommendation, DOD will not take action on this recommendation. According to contact with DOD in August 2008, DOD management still nonconcurs with the recommendation. The Assistant Deputy Under Secretary of Defense stated that the report contained analytical and logical deficiencies and asserts that DOD does have comprehensive policies in place.

    Recommendation: 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, DOD should, 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.

    Agency Affected: Department of Defense

  2. Status: Closed - Not Implemented

    Comments: Since DOD does not agree with this recommendation, DOD has not taken action on this recommendation. In August 2008, DOD reasserted its position that DOD nonconcurs with the recommendation and that no action will be taken.

    Recommendation: 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, DOD should, 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, DOD should consolidate and review sampling data previously collected by installations under environmental laws governing the release or disposal of various hazardous substances.

    Agency Affected: Department of Defense


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