Recommendation: The Assistant Administrator for Water of EPA's Office of Water should require states to report available information about lead pipes to EPA's Safe Drinking Water Information System (SDWIS)/Fed (or a future redesign such as SDWIS Prime) database, in its upcoming revision of the LCR. (Recommendation 1)

Agency: Environmental Protection Agency
Status: Open
Priority recommendation

Comments: As of July 2020 there has been no change in the status of this recommendation. In July 2019, EPA said that the 2016 America's Water Infrastructure Act (AWIA) requires EPA to conduct an assessment of the costs to replace lead service lines and that EPA would conduct this assessment (a survey) in 2020. In a previous update, EPA said that it would consider GAO's recommendation to require states to report available information about lead pipes along with those of other stakeholders as part of the development of the revisions to the Lead and Copper Rule. EPA officials estimated that the agency would publish a proposal for the revisions in 2019.

Recommendation: The Assistant Administrator for Water of EPA's Office of Water should require states to report all 90th percentile sample results for small water systems to EPA's SDWIS/Fed (or a future redesign such as SDWIS Prime) database, in its upcoming revision of the LCR. (Recommendation 2)

Agency: Environmental Protection Agency
Status: Open
Priority recommendation

Comments: As of July 2020 there has been no change in the status of this recommendation. In July 2019, EPA said that it would consider GAO's recommendation to require states to report all 90th percentile sample results for small systems along with those of other stakeholders as part of the development of the revisions to the Lead and Copper Rule. EPA officials estimated that a proposal for the revisions would be published in 2019.

Recommendation: The Assistant Administrator for Water of EPA's Office of Water and the Assistant Administrator of EPA's Office of Enforcement and Compliance Assurance should develop a statistical analysis that incorporates multiple factors--including those currently in SDWIS/Fed and others such as the presence of lead pipes and the use of corrosion control--to identify water systems that might pose a higher likelihood for violating the LCR once complete violations data are obtained, such as through SDWIS Prime. (Recommendation 3)

Agency: Environmental Protection Agency
Status: Open
Priority recommendation

Comments: As of July 2020 there has been no change in the status of this recommendation. In July 2019, EPA stated that the agency developed a Lead and Cooper Rule (LCR) violation reporting tool that is updated and distributed to the EPA regional offices on a quarterly basis. This tool, according to EPA, enhances national oversight by fostering closer engagement with the regional offices to continuously assess any new water systems violating the LCR. EPA has stated that the agency has also developed, and shared with its regional offices, an internal resource to make ad hoc assessments of water systems, nationwide, that would benefit most from assistance with lead service line replacements or (for water systems without lead service lines) corrosion control treatment installation/re-optimization. According to EPA, this internal resource takes a multi-factor approach that considers historical action level exceedance occurrences and information on additional factors (for which information is already available through regulatory development efforts for the LCR long-term revisions or internet search engine queries). These additional factors include the number of lead service lines known to be present in a given water system; the proportion of a system's service connections that are served by lead service lines; and potential technical, managerial, and financial capacity challenges experienced by that system. Although EPA has made progress in addressing the recommendation, GAO will leave this recommendation open until SDWIS Prime is implemented.

Recommendation: To ensure that DOE's long-term plans for storing waste in the existing SSTs and DSTs at Hanford consider the condition of the tanks and the WTP construction delay, the Secretary of Energy should assess the extent to which the factors that may have led to corrosion in AY-102 are present in any of the other 27 DSTs.

Agency: Department of Energy
Status: Open

Comments: As of March 2020, DOE has not yet done this study though they are currently planning to do so.

Recommendation: To improve DOD's corrosion-prevention and control program, and to enhance DOD in its oversight of the status and potential benefits of its equipment-related corrosion projects, the Under Secretary of Defense for Acquisition, Technology and Logistics should require the Director, Corrosion Policy and Oversight Office, to revise the DOD Corrosion Prevention and Mitigation Strategic Plan or other guidance to require that the military departments include in all follow-on reports the details of measures of achievement other than ROI, such as the features, results, and potential benefits of the project.

Agency: Department of Defense: Office of the Under Secretary of Defense for Acquisition, Technology and Logistics
Status: Open

Comments: DOD did not concur with this recommendation. As of March 2016, DOD had not implemented this recommendation and stated that the DoD Corrosion Prevention and Mitigation Strategic Plan currently provide sufficient guidance in this regard. As of March 2019, DOD has decided to take action to implement this recommendation. According to DOD Corrosion Office officials, they plan to list measures of achievement for the military departments to follow on the departments' corrosion project in a new DOD manual on corrosion. The Office's goal is to create this new manual by the end of calendar year 2020. We will monitor the extent to which DOD implements this recommendation.

Recommendation: Further, to provide greater assurance that the military departments will meet reporting milestones for future projects, the Under Secretary of Defense for Acquisition, Technology, and Logistics--in coordination with the Director of the Office of Corrosion Policy and Oversight-- should revise corrosion-related guidance to clearly define a role for the military departments' Corrosion Control and Prevention Executives to assist the Office of Corrosion Policy and Oversight in holding their departments' project management offices accountable for submitting infrastructure-related reports in accordance with the DOD Corrosion Prevention and Mitigation Strategic Plan.

Agency: Department of Defense: Office of the Secretary of Defense: Office of the Under Secretary of Defense for Acquisition, Technology, and Logistics
Status: Open

Comments: On July 24, 2013, DOD reported that it non-concurred with our recommendation. DOD reported that the Military Department Corrosion Control and Prevention Executives are given the freedom to manage their programs in the most efficient and effective manner for their respective departments. Additionally, DOD reported that the Corrosion Control and Prevention Executives know the reporting requirements and are working closely with the Corrosion Policy and Oversight Office and the project managers to ensure reports are submitted in accordance with the DoD Corrosion Prevention and Mitigation Strategic Plan. Therefore, DOD reported that further guidance is not necessary as the requirements are already clearly stated in the DoD Corrosion Prevention and Mitigation Strategic Plan. Our audit work showed that DOD's strategic plan and guidance do not define a role for the Corrosion Executives in assisting the Corrosion Office in the project reporting process. Our recommendation was intended to fortify the role of Corrosion Executives in ensuring that project management offices within the Corrosion Executives' respective military departments submit project reports as required in the strategic plan. We continue to believe that the Corrosion Executives could provide the additional management oversight necessary to strengthen corrosion project reporting. In May 2016, the Senate Armed Services Committee informed us that it have included language in its National Defense Authorization Act Bill for fiscal year 2017. Specifically, the language reads: SEC. 312. REVISION OF GUIDANCE RELATED TO CORROSION CONTROL AND PREVENTION EXECUTIVES. Not later than 90 days after the date of the enactment of this Act, the Under Secretary of Defense for Acquisition, Technology, and Logistics, in coordination with the Director of Corrosion Policy and Oversight, shall revise corrosion-related guidance to clearly define the role of the corrosion control and prevention executives of the military departments in assisting the Office of Corrosion Policy and Oversight in holding the appropriate project management office in each military department accountable for submitting the report required under section 903(b)(5) of the Duncan Hunter National Defense Authorization Act for Fiscal Year 2009 (Public Law 110-417; 10 U.S.C. 2228 note) with an expanded emphasis on infrastructure, as required in the long-term strategy of the Department of Defense under section 2228(d) of title 10, United States Code. As of October 2016, legislation was not passed. As of March 2019, DOD has since decided to take action to implement this recommendation. According to Corrosion Office officials, they will include a definition of the military departments' Corrosion Executives' role in: an update to DOD Instruction 5000.67 (Prevention and Mitigation of Corrosion on DOD Military Equipment and Infrastructure), a new DOD manual on corrosion, an update to the DOD Corrosion Prevention and Mitigation Strategic Plan, and an update to the Corrosion Prevention Control Integrated Product Team charter. The Corrosion Office's goal is to complete these updates and create the new manual by the end of calendar year 2020. We will monitor the extent to which DOD implements this recommendation.

Recommendation: To enhance the safety of unregulated onshore hazardous liquid and gas gathering pipelines, the Secretary of Transportation should direct the PHMSA Administrator to collect data from operators of federally unregulated onshore hazardous liquid and gas gathering pipelines, subsequent to an analysis of the benefits and industry burdens associated with such data collection. Data collected should be comparable to what PHMSA collects annually from operators of regulated gathering pipelines (e.g., fatalities, injuries, property damage, location, mileage, size, operating pressure, maintenance history, and the causes of incidents and consequences).

Agency: Department of Transportation
Status: Open

Comments: PHMSA plans to collect data on previously unregulated hazardous liquid and natural gas gathering lines via rulemakings. PHMSA issued a final rule that covers data collection for hazardous liquid gathering pipelines in October 2019. As of May 2020, PHMSA anticipates issuing the final rule for natural gas pipelines by Fall, 2020.

Recommendation: To ensure sufficient follow-up to DOD's corrosion study, the Secretary of Defense should direct the USD (AT&L) to document program-specific recommendations flowing from the corrosion study with regard to the other weapon systems identified--specifically, the Expeditionary Fighting Vehicle, CH-53K helicopter, Joint High Speed Vessel, Broad Area Maritime Surveillance Unmanned Aircraft System, and the Joint Light Tactical Vehicle--and establish a process for monitoring and assessing the effectiveness of the CPC programs for these systems.

Agency: Department of Defense
Status: Open

Comments: As of September 2015, DOD had not documented program-specific recommendations from the corrosion study for the other weapon systems identified in its report. However, DOD updated its Corrosion Prevention and Control Planning Guidebook in 2014 and, according to officials, is working to update DOD Instruction 5000.67, Prevention and Mitigation of Corrosion on DOD Military Equipment and Infrastructure. These actions may improve the corrosion prevention and control planning for the weapon systems identified in DOD's study. DOD partially concurred with this recommendation at the time of our report but as of March 2019, has since decided to take action to implement it. According to Corrosion Office officials, they interacted with two of five weapon-systems programs on corrosion-related matters. One of these weapon-system programs, per Corrosion Office officials, was eventually canceled. In addition to updating the Corrosion Prevention and Control Planning Guidebook for Military Systems and Equipment in 2014, officials stated that they are planning to further update DOD Instruction 5000.67 (Prevention and Mitigation of Corrosion on DOD Military Equipment and Infrastructure). Also, according to Corrosion Office officials, procedures for evaluating acquisition programs will be included in the new DOD manual on corrosion. The Corrosion Office's goal of completing this instruction update and creating the new manual is by the end of calendar year 2020. We will monitor the extent to which DOD implements this recommendation.

Recommendation: To ensure sufficient follow-up to DOD's corrosion study, the Secretary of Defense should direct the USD (AT&L) to document Air Force-and Navy-specific recommendations flowing from the corrosion study and establish a process for monitoring and assessing the effectiveness of these services' corrective actions.

Agency: Department of Defense
Status: Open

Comments: As of September 2015, DOD had not documented Air Force- and Navy-specific recommendations flowing from the corrosion study. However, DOD updated its Corrosion Prevention and Control Planning Guidebook in 2014 and, according to officials, is working to update DOD Instruction 5000.67, Prevention and Mitigation of Corrosion on DOD Military Equipment and Infrastructure. Further, the Air Force and the Navy have both taken actions to address the DOD-wide recommendations from the corrosion study. These actions may improve corrosion prevention and control planning for Air Force and Navy programs. As of March 2019, Corrosion Office officials stated that they are planning to further update DOD Instruction 5000.67 (Prevention and Mitigation of Corrosion on DOD Military Equipment and Infrastructure) or other appropriate guidance related to the process or procedures for monitoring and assessing the effectiveness of Corrosion Prevention Control planning for weapon systems, particularly related to how the military services will accomplish this within their increased weapon system oversight role. In addition, per Corrosion Office officials, this information will be addressed in the new DOD manual on corrosion. The Corrosion Office's goal to complete this instruction update and create the new manual by the end of calendar year 2020. We will monitor the extent to which DOD implements this recommendation.

Recommendation: To ensure that the Department of Defense is taking full advantage of the cost savings that can be achieved by implementing CPC projects, the Secretary of Defense should direct the Under Secretary of Defense (Acquisition, Technology and Logistics) to update applicable guidance, such as DOD Instruction 5000.67, Prevention and Mitigation of Corrosion on DOD Military Equipment and Infrastructure or the DOD Corrosion Prevention and Mitigation Strategic Plan to further define the responsibilities of the military departments' Corrosion Executives, to include more specific oversight and review of the project proposals before and during the project selection process.

Agency: Department of Defense
Status: Open

Comments: DOD has not updated DOD Instruction 5000.67 - Prevention and Mitigation of Corrosion on DOD Military Equipment and Infrastructure, the DOD Corrosion Prevention and Mitigation Strategic Plan, or other applicable guidance since the publication of our report. DOD did not concur with this recommendation at the time of our report but as of March 2019, has since decided to take action to implement it. Corrosion Office officials agree that Corrosion Executives' responsibilities in the Corrosion Prevention Project selection process have to be further defined. They plan to clearly document the selection procedures and participation of the Corrosion Executive in an update to DOD Instruction 5000.67 (Prevention and Mitigation of Corrosion on DOD Military Equipment and Infrastructure) and in the new DOD manual on corrosion. The Corrosion Office's goal is to complete this instruction update and create the new manual by the end of calendar year 2020. We will monitor the extent to which DOD implements this recommendation.

Recommendation: The Administrator, EPA, should take a number of steps to further protect the American public from elevated lead levels in drinking water. Specifically, to improve EPA's ability to oversee implementation of the lead rule and assess compliance and enforcement activities, EPA should ensure that data on water systems' test results, corrective action milestones, and violations are current, accurate, and complete.

Agency: Environmental Protection Agency
Status: Open

Comments: As of July 2020 there has been no change on the status of this recommendation. In June 2019, EPA reported to GAO that its tools for improving data about water systems compliance are not complete, though some states and laboratories have been exploring and testing incremental versions of them. EPA reported in a previous update that the agency had been working with states through face-to-face trainings and webinars on the reporting of milestone data. GAO will continue to monitor these efforts and reevaluate whether water systems' test results, corrective action milestones and violations are current, accurate and complete subsequent to the completion of the Compliance Monitoring Data Portal and the Safe Drinking Water Information System (SDWIS) Prime, described briefly below. However, until these new tools are complete, the status of this recommendation remains open. According to EPA, as of June 2018, SDWIS Prime has been available for exploring and testing, following incremental interim releases, since early 2018. In addition, EPA stated that SDWIS Prime will continue to be available for exploring and testing until the first production release anticipated for mid-2020.The agency has also focused on promoting electronic reporting of drinking water data through the development of the Compliance Monitoring Data Portal (CMDP). In June 2019, EPA stated that as of May 31, 2019, 10 states and more than 200 laboratories were using CMDP. According to EPA, as a result of using CMDP, these states reported a 30-70 percent reduction in staff time for data processing and a 90-99 percent reduction in errors for data.

Recommendation: To craft an effective strategy, the Secretary of Defense should direct that the department's strategic plan for corrosion prevention and mitigation include developing clearly defined goals, outcome-oriented objectives, and performance measures that show progress toward achieving objectives (these measures should include such elements as the expected return on investment and realized net savings of prevention projects).

Agency: Department of Defense
Status: Open

Comments: DOD concurred with all recommendations for Executive Action in the report. DOD stated it "is committed to meeting the requirements of Congress and, to the extent compatible with its core mission, the positive recommendations of the GAO report." In DOD's Corrosion Prevention and Mitigation Strategic Plan dated November 2004, DOD stated that the working integrated product team for Metrics, Impact and Sustainment established as one of its objectives initiating studies and surveys to determine the impact of corrosion, pinpoint critical areas for concentration of prevention and mitigation efforts and to develop metrics to measure the effect of corrosion and results of prevention and mitigation efforts. In its 2005 update to the DOD corrosion strategic plan, DOD included a revised list of metrics for cost, readiness and safety and the associated outcomes that would result from the implementation of these metrics. In addition, the strategic plan included details of corrosion projects funded in 2005 and 2006 and the expected results of completing the projects in terms of achieving cost savings, increasing readiness, and enhancing safety. As of March 2019, Corrosion Office officials stated that they plan to include goals, objectives, and performance measures in the update to the DOD Corrosion Prevention and Mitigation Strategic Plan. The Corrosion Office's goal is to complete this plan update by the end of calendar year 2020 . We will monitor the extent to which DOD implements this recommendation.