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Environmental Contamination: Corps Needs to Reassess Its Determinations That Many Former Defense Sites Do Not Need Cleanup

GAO-02-658 Published: Aug 23, 2002. Publicly Released: Sep 23, 2002.
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Highlights

The Department of Defense (DOD) estimates that cleaning up contamination and hazards at thousands of properties that it formerly owned or controlled will take more than 70 years and cost as much as $20 billion. These formerly used defense sites (FUDS), which can range in size from less than an acre to many thousands of acres, are now used for parks, farms, schools, and homes. Hazards at these properties include unsafe buildings, toxic and radioactive wastes, containerized hazardous wastes, and ordnance and explosive wastes. The U.S. Army Corps of Engineers is responsible for identifying, investigating, and cleaning up hazards resulting from military use. GAO found that the Corps lacks a sound basis for its conclusion that 38 percent of 3,840 FUDS need no further study or cleanup action. The Corps' determinations are questionable because there is no evidence that it reviewed or obtained information that would allow it to identify all the potential hazards at the properties, or that it took sufficient steps to assess the presence of potential hazards. GAO also found that the Corps often did not notify owners of its determinations that the properties did not need further action, as called for in its guidance, or tell the owners to contact the Corps if evidence of DOD-caused hazards was found later.

Recommendations

Recommendations for Executive Action

Agency Affected Recommendation Status
Department of Defense To help ensure that all potential hazards are adequately identified and assessed, the Secretary of Defense should direct the Corps to develop and consistently implement more specific guidelines and procedures for assessing FUDS properties. These guidelines and procedures should specify the historical documents such as site maps, aerial and ground photos, and comprehensive site histories that the Corps should try to obtain for each property to identify all of the potential hazards that might have been caused by DOD's use.
Closed – Implemented
The Army Corps of Engineers has developed more specific guidance to identify and assess potential hazards as recommended.
Department of Defense To help ensure that all potential hazards are adequately identified and assessed, the Secretary of Defense should direct the Corps to develop and consistently implement more specific guidelines and procedures for assessing FUDS properties. These guidelines and procedures should include a listing of typical hazards that might be present at certain types of properties, such as communication facilities or motor pools, and incorporate the guides already developed for ordance hazards and Nike missile sites into Corps procedures.
Closed – Implemented
DOD has implemented this recommendation.
Department of Defense To help ensure that all potential hazards are adequately identified and assessed, the Secretary of Defense should direct the Corps to develop and consistently implement more specific guidelines and procedures for assessing FUDS properties. These guidelines and procedures should require that the Corps contact other interested parties--including federal, state, and local agencies--as well as owners during the preliminary assessment of eligibility to discuss potential hazards at the properties.
Closed – Implemented
The Corps updated its procedures to require that owners and regulators are notified in a timely manner, and that regulators are notified of hazards that were not the result of DOD actions.
Department of Defense To help ensure that all potential hazards are adequately identified and assessed, the Secretary of Defense should direct the Corps to develop and consistently implement more specific guidelines and procedures for assessing FUDS properties. These guidelines and procedures should provide instructions for conducting site visits to ensure that each site receives an adequate site visit and that all potential hazards are properly assessed.
Closed – Implemented
The Corps has updated its procedures to require prompt notification of owners and regulators as recommended.
Department of Defense To further ensure that all hazards caused by DOD at FUDS properties are identified, the Secretary of Defense, as an initial step, should direct the Corps to use the newly developed guidance and procedures to review the files of FUDS properties that it has determined do not need further study or cleanup action to determine if the files contain adequate evidence to support the no DOD action indicated (NDAI) determinations. If there is an insufficient basis for the determination, those properties should be reassessed.
Closed – Implemented
The Corps has updated its procedures to assure prompt notification of owners and regulators as recommended.
Department of Defense To ensure that all parties are notified of the Corps' NDAI determinations, the Secretary of Defense should direct the Corps to develop and consistently implement procedures to ensure that owners and appropriate federal, state, and local environmental agencies are notified of the results of the Corps' preliminary assessments of eligibility in a timely manner. The Corps should also ensure that owners are aware that the Corps will reconsider an NDAI determination if new evidence of DOD hazards is found. In addition, when preliminary assessments of eligibility identify potential hazards that did not result from DOD activities, the procedures should direct the Corps to notify the appropriate regulatory agencies in a timely manner.
Closed – Implemented
The Corps has completed action requiring that owners are aware that the Corps will reconsider its determination if new evidence of DOD hazards is found.

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Topics

Eligibility determinationsEnvironmental monitoringContaminationHazardous substancesObsolete facilitiesPotential hazardsRegulatory agenciesMunitionsU.S. ArmyRadioactive wastes