2002 CPEO Military List Archive

From: Lenny Siegel <lsiegel@cpeo.org>
Date: 2 Oct 2002 19:00:51 -0000
Reply: cpeo-military
Subject: [CPEO-MEF] Review of GAO FUDS Report
The recent General Accounting Office (GAO) report on Formerly Used
Defense Sites (FUDS), "Environmental Contamination: Corps Needs to
Reassess Its Determinations That Many Former Defense Sites Do Not Need
Cleanup" (GAO-02-658, August 23, 2002), makes several recommendations to
the Defense Department (DOD) and Army Corps of Engineers to improve the
way they determine whether those properties require government-conducted
cleanup. A careful reading of the report suggests, however, that
improved procedures will accomplish little unless the FUDS program
budget is significantly increased.

In its study, GAO reviewed records on a statistical sample of over 600
individual FUDS. Appendix II contains a table with GAO's site-by-site
findings. GAO found "that the Corps does not have a sound basis for
determining that about 38 percent, or 1,468, of 3,840 formerly used
defense sites do not need further study or cleanup action."

The agency cautions, however, "Our questioning of an NDAI {No Defense
Action Indicated] determination does not mean that the property is
contaminated; rather, it indicates that the Corps' file did not contain
evidence that the Corps took steps to identify and assess potential
hazards at the property that would support the NDAI determination."
Still, many such sites are likely to be contaminated. GAO supplies
several examples where action is probably necessary despite former Corps
findings otherwise. These include Camp O'Reilly (Puerto Rico), Ft. Casey
(Washington), Ft. Pickens (Florida), Othello Air Force Station
(Washington), Kasiana Island (Alaska), and Wilkins Air Force Base (Ohio).

GAO also found that in most cases the Corps did not notify current
owners that they had made NDAI determinations. More important, in many
cases this left owners or the public at large subject to hazards that
the Corps believed to be the responsibility of other parties: GAO
estimates that at "about 246 NDAI properties the Corps did not notify
EPA or state regulatory agencies of non-DOD hazards." It explains:

"The Corps also did not notify EPA or state environmental agencies of
its determinations or of potential hazards it identified that were not
the result of DOD use, even though these agencies may have regulatory
responsibilities to ensure that cleanup occurs. Although there is no
specific requirement for the Corps to notify regulatory agencies of
non-DOD contamination, its failure to do so results in missed
opportunities to assist the agencies' efforts to carry out their
statutory responsibilities to protect human health and the environment."

GAO supplies a disturbing example: "when conducting a site visit in
Louisiana in 1986, Corps staff identified an underground diesel oil
storage tank of unknown size that held approximately 12 inches of diesel
oil. The Corps concluded that this hazard was not the result of DOD
activities, but was left by the Coast Guard. However, the file contains
no evidence that the Corps notified EPA or state regulators of the
suspected hazard."

On the positive side, the Corps is now more closely cooperating with
regulatory agencies. In fact, it has promised state regulators to
re-evaluate a limited number of properties each year. This should bring
into the system most FUDS where contamination is relatively obvious.

Still, even if the Corps partners better with regulators and  implements
all of GAO's recommendations, it won't accomplish much more. The Defense
Department estimates that it will take more than 70 years and $15 to $20
billion to remediate known FUDS contamination. GAO says, "In its '2001
Funding Strategies' Report, the Corps proposed that the Army and DOD
increase the annual FUDS program funding by $155 million to
approximately $375 million per year." But neither the Defense Department
Comptroller's office nor Congress has approved anything in that ballpark.

There is little opportunity, within current funding levels, to develop
new guidance or to re-visit additional NDAI sites. More important, if
the review or characterization of NDAI sites thrusts them into the
remediation queue, the resources aren't there to respond quickly without
taking money away from other, high-priority sites. Addressing newly
recognized contamination competes with the removal of ordnance from
someone's backyard, arsenic from someone's front yard, or protecting
schoolchildren from underground solvents.

GAO's suggestions for improving the FUDS program are welcome, but they
won't mean much until the program is funded at a level that promises
program completion within 20 to 30 years, not the 70 years currently estimated.

As we reported earlier, the 80-page, 7.2-megabyte document may be
downloaded directly from http://www.gao.gov/cgi-bin/getrpt?GAO-02-658 or
ordered from 202-512-6000.


Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 278-A Hope St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/961-8918

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