Military

Environmental Liabilities: DOD Training Range Cleanup Cost Estimates Are Likely Understated (11-APR-01, GAO-01-479)

Because of concerns about the long-term budgetary implications	 
associated with the environmental cleanup of the Department of	 
Defense (DOD) training ranges, GAO examined (1) the potential	 
magnitude of the cost to clean up these ranges in compliance with
applicable laws and regulations, (2) the scope and reliability of
DOD's training range inventory, and (3) the methodologies used to
develop cost estimates. GAO found that DOD does not have complete
and accurate data needed to estimate training range cleanup	 
costs. DOD has not performed a complete inventory of its ranges, 
fully identifying the types and extent of unexploded ordnance	 
present and the associated contamination. Recently, DOD began the
initial compilation of training range data, but these initial	 
data collection efforts have been delayed because DOD did not	 
issue formal guidance to the services for collecting the range	 
information until October 2000. Since DOD has not completed an	 
inventory of its ranges, the services have used varying methods  
to estimate the size and condition of the ranges necessary to	 
estimate the cost of cleanup for financial statement purposes. As
a result, environmental liability costs are not consistently	 
calculated and reported across the services.			 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-01-479 					        
    ACCNO:   A00806						        
    TITLE:   Environmental Liabilities: DOD Training Range Cleanup    
             Cost Estimates Are Likely Understated                            
     DATE:   04/11/2001 
  SUBJECT:   Cost analysis					 
	     Waste disposal					 
	     Data collection					 
	     Environmental monitoring				 
	     Government liability (legal)			 
	     Hazardous substances				 
	     Military bases					 
	     Military training					 
	     Munitions						 
	     Reporting requirements				 
	     DOD Defense Environmental Restoration		 
	     Program						 
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GAO-01-479
Report to Congressional Requesters
United States General Accounting Office
GAO
April 2001 ARMY TRAINING Improvements Are Needed in 5- Ton Truck Driver
Training and Supervision
GAO- 01- 436
Page i GAO- 01- 436 Army Training Letter 1
Appendix I Objectives, Scope, and Methodology 21
Appendix II GAO Contact and Staff Acknowledgments 23
Tables
Table 1: Percentage of Students in Formal, Informal, and Reserve Programs
Satisfied With Training 10
Figures
Figure 1: Three M939 series Trucks 3 Figure 2: Number of Authorized,
Assigned, and On- hand
Instructors at Fort Leonard Wood, January- September 2000 6
Figure 3: On- hand Instructors as a Percentage of Assigned Instructors at
Three Schools, January- September 2000 8
Figure 4: Comparison of Two Formal Army Schools, Fiscal Year 2000 9
Figure 5: Percentage of Interviewees Aware of M939 Speed Limit Restriction
13
Figure 6: Some Recurring Conditions Cited in M939 Accident Reports, 1988- 99
17 Contents
Page 1 GAO- 01- 436 Army Training
April 11, 2001 The Honorable Christopher J. Dodd The Honorable Joseph I.
Lieberman United States Senate
The Honorable Rosa L. Delauro House of Representatives
In April 1997, a 5- ton M939 Army truck was involved in a fatal accident in
which two reservists died. The Army has over 30,000 of these trucks, which
are used extensively to carry personnel and pull equipment. You asked us to
report on the M939's accident history and to assess the training and
supervision received by its drivers. We broke your request into two issues.
The first dealing with the accident history and any inherent mechanical/
design defects in the truck itself. The second dealing with issues involving
the safe handling of the truck– the training and supervision of the
truck's drivers. In April 1999, we reported on the M939's accident history
and mechanical soundness. 1 For this second report, we (1) evaluated the
capacity of the Army's 5- ton truck driver training programs to fully train
drivers, (2) determined whether oversight procedures and processes for these
drivers are being followed, and (3) determined whether and how the Army uses
accident data to improve training, supervision, and safety.
The 5- ton truck driver training programs we reviewed do not graduate
drivers that are fully trained in all aspects of the instruction program and
for some tasks they may be required to perform. The main reasons for these
shortcomings are instructor shortages, limited environmental conditions
(lack of snow, ice, steep or rocky terrain, etc.) at the training sites, and
certain mission- related driving skills not being taught. There is also an
imbalance between the two formal truck driver training schools: the larger
one is understaffed to teach the number of students there, while
1 Military Safety: Army M939 5- Ton Truck Accident History and Planned
Modifications
(GAO/ NSIAD- 99- 82, Apr. 9, 1999).
United States General Accounting Office Washington, DC 20548
Results in Brief
Page 2 GAO- 01- 436 Army Training
the other one has smaller classes, conducts fewer classes per year, and
maintains a lower student- teacher ratio. In addition, some communication
problems hinder the flow of information to instructors, students,
supervisors, and licensed drivers.
Some supervisory procedures and processes designed to ensure that 5- ton
trucks are operated safely are not being performed or documented as
required. In particular, required annual “check rides” and
“sustainment
training” are either not properly performed or recorded. We reviewed
over 450 driver records and found that more than three- quarters of them did
not contain a required entry indicating that the driver had received an
annual check ride and/ or sustainment training as stipulated in Army
regulations.
The Army Safety Center maintains an accident database that has already
proven useful in developing some policies aimed at improving the safe
operation of M939 trucks. We analyzed M939 accident data from 1988 through
1999 and found trends that we believe could be used to improve driving
safety and to better focus training on problem areas. But the database is
not being periodically analyzed for these purposes, and opportunities are
thus being missed. Also, some accident reports have missing information,
thus limiting the usefulness of the database for some analytical processes
using these fields.
We are making recommendations aimed at improving the quality of truck driver
training, increasing compliance with Army regulations, and increasing the
safety of M939 truck driver operations. The Department of Defense concurred
with all our recommendations.
Page 3 GAO- 01- 436 Army Training
The Army has around 97,000 “medium tactical wheeled vehicles”
(about 57,000 5- ton trucks and 41,000 2- 1/ 2- ton trucks) in its fleet.
The M939 accounts for more than half its 5- ton trucks. The truck is used to
carry personnel or pull equipment under all weather and road conditions,
including rain, snow, ice, unpaved roads, sand, and mud (see fig. 1).
Figure 1: Three M939 Series Trucks
Source: Shane G. Deemer.
Background
Page 4 GAO- 01- 436 Army Training
The active Army uses formal and informal programs to train 5- ton truck
drivers. 2 The formal program is aimed at military personnel whose official
primary occupation will be “88M Motor Transport Operator”- or
truck driver. The program lasts 6 weeks and is taught in schools at Fort
Leonard Wood, Missouri, and Fort Bliss, Texas. Fort Leonard Wood trains
about 90 percent of all 88M students. Fort Bliss for the most part trains
the
“overflow” of students that Fort Leonard Wood cannot
accommodate. The formal instruction program calls for about 1 week in the
classroom and 5 weeks of hands- on training. Students who complete the
program do not immediately receive a license to drive a 5- ton truck; they
are licensed at their next duty station after undergoing additional training
and testing there. The Army Transportation Center and School at Fort Eustis,
Virginia, is responsible for the content of the instruction program used by
the formal training schools. It aligns under the Army Training and Doctrine
Command at Ft. Monroe, Virginia.
According to Army officials, informal programs are taught at installations
or units that need occasional 3 truck drivers but are not authorized any or
enough 88M drivers to handle their needs. Occasional drivers do not drive
trucks as their primary occupation; they do so on a part- time or as- needed
basis. Informal programs are usually 40 to 120 hours long and combine
classroom and driving time. Graduates are not automatically licensed and
must usually meet additional driving and testing requirements by their
units. Occasional drivers receive the same license as 88M drivers and,
accordingly, may be required to perform the same driving maneuvers.
The Army Reserve trains both Reserve and National Guard 88M drivers using a
two- part program that contains the same instructional material as the
formal program. The first part (81 hours) is conducted at the soldier's home
station during weekend drills. The second part (120 hours) is usually
conducted at a Reserve training center during a 2- week active duty session.
Like active Army truck drivers, program graduates must undergo additional
training and testing by their units before being licensed.
2 We define formal programs as resident training programs taught in a
school- house setting; and informal programs as those conducted by
individual Army units at many different installations.
3 We define an occasional driver as a driver licensed to operate a 5- ton
truck but not possessing the military occupation specialty designator or 88M
– Motor Transport Operator.
Page 5 GAO- 01- 436 Army Training
Graduates of the Army's truck driver training programs are not skilled
enough to safely handle 5- ton trucks in some situations for which they
should have received training. This is because of instructor shortages and
limited training conditions. Graduates are either partially trained or
untrained in some skills found in the instruction program. In addition, the
schools do not teach driving skills that are essential to performing the 5-
ton truck's primary mission.
One of the Army's two formal truck driver training schools, the school at
Fort Leonard Wood, Missouri, operates with sizable instructor shortages.
Because of this Fort Leonard Wood operates at a higher student- instructor
ratio than called for in the instruction program. In fiscal year 2000, the
Fort Leonard Wood facility trained nearly 90 percent of the Army's 88M
drivers in spite of these shortages. Instructors at the informal and Reserve
programs also said that their programs suffer from instructor shortages.
During the first 9 months of 2000, Fort Leonard Wood operated with an
average of 53 percent of its authorized instructors on- hand to teach the
program. The main reasons were 1) fewer personnel were assigned to teach
than were authorized and 2) even fewer were available (on- hand) than were
assigned due to other commitments (such as bus driving, funeral and parade
duty, leave, etc.). Authorized refers to the number of instructors the Army
determines are needed to teach a program; assigned refers to the number of
instructors the Army allocates to teach a program; and on- hand refers to
the number of instructors that are present and teaching a program. Figure 2
shows the number of instructors authorized, assigned, and on- hand at Fort
Leonard Wood in the first 9 months of 2000, when on average about 45 of 84
authorized instructors were available. Some Essential
Driving Skills Are Not Taught
Instructor Shortages
Page 6 GAO- 01- 436 Army Training
Figure 2: Number of Authorized, Assigned, and On- hand Instructors at Fort
Leonard Wood, January- September 2000.
Source: Our analysis of Army data.
Assuming that (1) the Army continues assigning instructors at about 85
percent of authorized levels and that (2) the number of instructors on- hand
remains constant at about 53 percent of those assigned, the Army would have
to increase its present authorized level of instructors from 84 to158, an
increase of 88 percent, in order to have a full complement on- hand.
The formal instruction program calls for a 6- to- 1 student- instructor
ratio- and Fort Leonard Wood is structured to operate at this ratio when
staffed at 100 percent of its authorized level. In the first 9 months of
2000, our review showed that Fort Leonard Wood operated overall at a higher
ratio of about 9 to 1. Nonetheless, training officials stated that the
school has been conducting the behind- the- wheel (hands- on) training
portion of the program at the 6- to- 1 ratio the instruction program calls
for. This means one instructor overseeing 3 trucks with two students per
truck. However, Army regulations stipulate a 1- to- 1 truck- instructor
ratio when a student driver is behind the wheel. In December 1998, Fort
Leonard Wood requested a waiver to allow the 6- to- 1 ratio when students
were driving
Page 7 GAO- 01- 436 Army Training
trucks. While the request has yet to be officially approved, school
officials claim that if required to maintain the 1- to- 1 ratio, each
student might drive as little as 30 miles during the entire course, instead
of the present target of about 100 miles per student on average.
Effects of Instructor Shortages
Instructor shortages affect the quantity and quality of training. Students
do not get sufficient hands- on driving experience and are not trained in
all the skills required by the instruction program.
Program officials at Fort Leonard Wood said that at times, instructors could
fully teach only about three- quarters of the instruction program's required
tasks. For example, in the second half of fiscal year 1999 two training
modules- driving off- road and basic vehicle control- were often carried out
only in part or demonstrated but not practiced. These two modules account
for almost 93 percent of the 85.5 hours students are supposed to spend
driving trucks. Because of instructor shortages during these two quarters,
the average number of miles driven by each student at Fort Leonard Wood
dropped from nearly 100 to less than 50. In addition, hands- on training is
presently limited to mostly driving in controlled settings only. Students
drive in convoys on unpaved but graded and regularly maintained training
routes at no more than 25 mph – receiving almost no training in how to
drive on public highways or in suburban settings. One group of trainers
stated that with more instructors, they could take students on some
realistic training rather than the “follow- theleader” driving
students now receive.
Students are also not being taught all the tasks that 5- ton- truck drivers
are expected to perform. Training officials at the two formal programs
stated they thought drivers should be trained in hauling loads or pulling
equipment- the primary mission of 5- ton trucks. While the instruction
program calls for 20 percent of all vehicles to operate with a load in the
cargo area, this is not being done, according to training officials, because
of logistical problems that make it difficult to train this skill. Pulling
equipment is not taught because it is not specified in the instruction
program. Therefore, students must learn these essential skills after
graduation and rotation to their next duty stations.
Neither the Marine Corps, which co- trains its 5- ton truck drivers with the
Army at Fort Leonard Wood, nor the smaller Fort Bliss school, which mostly
trains the overflow from Fort Leonard Wood, experience as severe Comparison
of On- hand
Instructors
Page 8 GAO- 01- 436 Army Training
instructor shortages as Fort Leonard Wood. Thus, neither encounters problems
teaching the instruction program in its entirety. According to Marine Corps
training officials, its detachment is authorized 76 instructors, and in the
first 9 months of 2000, averaged having 70 instructors assigned and 65 on-
hand (93 percent). During that same period of time, Fort Bliss training
officials stated its school was authorized 17 instructors but actually had
18 assigned and on- hand (106 percent).
During the first 9 months of 2000, the Marine Corps program averaged a
higher percentage of its assigned instructors on- hand than the Fort Leonard
Wood Army program – 93 percent versus 63 percent (see fig. 3). This,
according to Marine Corps training officials, was mostly because their
instructors did not have other commitments or assignments as did Army
instructors. Also, the average class size for the Marine Corps was much
smaller than that for the Army (44 versus 70 students), and they had more
instructors available to teach (65 on average versus the Army's 45). Because
of the smaller class size and larger number of on- hand instructors, the
Marine Corps can staff each truck at the 1- to- 1 instructorto- truck ratio
regulations call for. This, according to them, allows students to gain
driving skills in uncontrolled settings such as driving off- post, on public
highways, and in various urban settings.
On the other hand, the Fort Bliss school actually had a surplus of
instructors: it had 106 percent of its assigned instructors on- hand (see
fig. 3). According to program officials, their instructors also did not have
other commitments and assignments as did Fort Leonard Wood Army instructors.
Figure 3: On- hand Instructors as a Percentage of Assigned Instructors at
Three Schools, January- September 2000
Source: our analysis of Army data.
Page 9 GAO- 01- 436 Army Training
During fiscal year 2000, Fort Bliss also graduated fewer students, utilized
less of its overall available classroom capacity, averaged smaller class
sizes, and conducted about one- third the classes that Fort Leonard Wood
conducted (see fig. 4).
Figure 4: Comparison of Two Formal Army Schools, Fiscal Year 2000
Source: Our analysis of Army data.
Student Opinions Show Varied Satisfaction With Training Received
We surveyed 139 students at the two formal school programs, 72 students at
10 informal programs, and 98 students at 1 Army Reserve training program. We
asked them to rate their satisfaction with the type of training there were
receiving in various driving techniques and conditions. As table 1 shows,
students at Fort Bliss felt better about the training they received in many
driving skills than their counterparts at Fort Leonard Wood. Students in the
Reserve program were the most satisfied overall with the training they
received, while students in the informal programs were generally the least
satisfied. Imbalances Between the
Two Formal Army Schools
Page 10 GAO- 01- 436 Army Training
Table 1: Percentage of Students in Formal, Informal, and Reserve Programs
Satisfied With Training
Fort Bliss Fort Leonard Wood Informal Reserve
Backing empty truck 92 55 69 87 Overall wheel time 100 64 55 80 Small
inclines/ slopes– empty truck 38 66 15 50 Wheel time in different
weather/ surfaces– empty truck 08 07 09 57 Load in cargo area/ pulling
equipment a N/ A N/ A 02 04 Driving at night 00 23 09 32 a N/ A (not
applicable). The formal schools do not teach driving with a load, and the
instruction program does not call for training while pulling equipment.
Source: Our analysis of survey responses.
According to the instruction program, the majority of driving training time
(about 65 hours) should be dedicated to driving on and off roads through
woods, streams, brush, sand, mud, snow, ice, rocky terrain, ditches,
gullies, and ravines. However, we found that neither of the two formal
schools provides all these conditions in its training routes.
Students at Fort Bliss are well trained to drive in sand because the
school's training routes have sand. But the school seldom sees snow or ice
because these conditions seldom occur there. And the school's training
routes we observed were for the most part flat and unchallenging. One route
we drove offered few or no opportunities to drive through woods and brush,
over rocky terrain, or through gullies and ravines. The problem, according
to school officials, is that the land the training routes are on is too flat
and lacking in undergrowth. Training officials also told us that money
constraints and the fact that Fort Bliss' mission is to handle the overflow
of students from Fort Leonard Wood impede the development of more
challenging driving routes.
Training routes at Fort Leonard Wood also offered limited obstacles or
challenges. We drove what school officials said was the most difficult
training route and found that it did go through some woods and rocky terrain
and over some hills and inclines. However, it contained no sand and
engineering units maintained the surface the trucks drove on by routinely
smoothing out bumps, ruts, and other obstacles. Environmental Limitations
at Formal Training Schools
Page 11 GAO- 01- 436 Army Training Simulators Can Be Useful Training Tools
When adverse weather, dangerous road conditions, or other problems arise,
the formal schools hesitate to allow students to drive because of safety
concerns. However, the Army has determined that simulators can be used to
teach some driving skills that cannot be taught in high risk driving
conditions because of the dangers involved.
Because of safety concerns, the Fort Leonard Wood command has issued an oral
directive prohibiting students from driving off the installation. As a
result, students do not learn to drive trucks in traffic at highway speeds
or in urban settings. Furthermore, the training command frequently cancels
hands- on driver training in the presence of ice, snow, or fog because it
believes the risk of student drivers having a serious accident outweighs the
benefits of the driving experience.
Not training under adverse weather and road conditions limits the ability of
drivers to handle a truck safely in these situations when they rotate to
their new duty stations and begin to drive. In May 2000 the Analysis Center
at the Army Training and Doctrine Command completed a study that concluded,
among other things, that students graduating from the formal schools were
only about 15- percent proficient 4 in skills needed to drive in fog, ice,
or snow and 27- percent proficient in skills needed to drive on sand.
The study concluded that simulators could overcome these and other
shortcomings in driver training. It reviewed 31 critical driving tasks
taught at the formal schools and concluded that simulators could help
students obtain higher proficiency levels in as many as 22 of them. The
study also concluded that simulators might help reduce the potential for
accidents both during training and- most importantly- during the first year
after training by increasing driving proficiency in fog, snow, or ice.
4 The study defined proficiency as how well a school graduate performed a
specific driving task when compared to a driver with 1 year of post-
training experience, as assessed by qualified instructors.
Page 12 GAO- 01- 436 Army Training
Formal training program personnel agreed, stating that they cannot teach
students to drive under some of the more common hazardous conditions 5
because it is too dangerous. Other Army officials also said that simulators,
especially more advanced ones, can recreate such situations and give
students a sense of driving under these conditions without putting lives at
risk. Training personnel at both formal schools, Army Transportation School
officials, as well as the simulator study itself strongly cautioned,
however, that simulators should not replace actual behind- the- wheel
driving time.
The private sector uses simulators in its truck driving schools and
considers them very useful. Officials at two commercial driving schools
stated that their simulators help students learn to drive under various
high- risk driving and weather conditions, including braking with a load on
steep inclines or on wet and icy surfaces.
Some safety rules relating to M939 trucks are not being communicated
effectively. Moreover, many informal training programs seem to be unaware of
available assistance from the Army Transportation School. Better
communication is key to improving the flow of this type of information.
The M939 series trucks are not supposed to be driven over 40 mph, even under
ideal conditions. However, we found that some licensed drivers, students,
instructors, and supervisors alike were either unaware of the speed limit,
had forgotten about it, or did not know this restriction is still in effect
for M939s without anti- lock brake systems 6 . Two- thirds of licensed
drivers we interviewed, as well as about one- third of student drivers in
formal training programs and over two- thirds of student drivers in informal
training programs, did not know or could not recall the 40- mph limit. And
none in a group we interviewed from a recently graduated formal program
class were able to tell us the correct maximum speed
5 In 1995 the Army Deputy Director of Safety concluded that M939 trucks were
involved in a disproportionately high number of accidents in which a panic
stop on a wet surface with a partially loaded truck going over 40 mph were
among the factors that contributed to the accident.
6 For all M939s having been outfitted with anti- lock brake kits, the speed
limit restriction of 40 mph is no longer in effect. However, we did not
observe an M939 equipped with such during our on- site visits. Some
Information Not
Reaching Its Target
Page 13 GAO- 01- 436 Army Training
limit. Although nearly all the 65 formal and Reserve program instructors we
interviewed could state the correct speed limit, only about two- thirds of
informal program instructors and driver supervisors could do so. By
contrast, all of the nearly 100 students we interviewed at the Army Reserve
training program knew of the speed limit, and for a simple reason: all the
M939 trucks used for training had a dashboard sticker to remind the driver
of the speed limit. (See fig. 5.)
Figure 5: Percentage of Interviewees Aware of M939 Speed Limit Restriction
Source: Our analysis of interview responses.
There also appears to be a communication problem between informal program
instructors and the Army Transportation School. Although the instructors
believe their training programs are good ones, they also stated they do not
have enough time to focus on improving and upgrading these programs and
would like more input from “knowledgeable personnel,” such as
those at the Fort Eustis Transportation School who developed the formal
training program. Some said they could have avoided difficulties they
encountered in developing a high- quality informal program if such expertise
had been available. Many suggested that standardized, Armywide training
packages tailored for each type of vehicle would be an efficient and
economical way of training informal drivers.
However, none of the instructors we interviewed knew that the Transportation
School has a program available designed specifically for informal training
of M939 drivers. In November 1999, the Transportation School distributed a
CD- ROM driver training program 7 , which includes
7 Army Model Drivers Training Program M939, 5- ton Tactical Cargo Truck.
Page 14 GAO- 01- 436 Army Training
lessons on driving and performing operator maintenance on the M939 to Army
standards. Transportation School officials stated that the program was sent
to around 1,800 different Army locations (according to the number and
location of M939 trucks) and is also available through the Army's web site.
While facing similar instructor shortages and limited driving conditions,
the informal and Reserve training programs we reviewed must also try to
train drivers in a shorter time than the formal programs. The reserves also
have problems with their equipment.
The 10 informal programs we reviewed ranged between 40 and 120 hours
(compared to 6 weeks for the formal program). As a result, instructors focus
mostly on teaching the basics (driving on surfaced roads, backing up on flat
surfaces, and performing some required maintenance and service). Instructors
teach more difficult skills only if time and circumstances allow. Several
instructors questioned how their 40 to 80 hour programs could possibly teach
as much as was taught in the 6- week formal course.
The reserves have problems not only with instructor shortages, but also with
training equipment. Reserve officials said their 5- ton truck driver
training programs are generally understaffed because of a lack of available
senior noncommissioned officers to teach. Also, because programs are usually
not authorized a fleet of trucks exclusively for training, units must borrow
trucks from the installation where training is taking place or from other
nearby Army installations. The training unit is responsible for picking up
and returning the trucks or for paying to have the trucks delivered and
returned. They also pay an established usage fee to the units that lend the
trucks. This is costly, especially if a borrowed vehicle needs repair work
before it can pass the required safety inspection so that it can be used for
training. Reserve training officials told us that this happens frequently
and adversely impacts training. Additional Challenges
Facing Informal and Reserve Training Programs
Page 15 GAO- 01- 436 Army Training
Army regulations 8 require that truck drivers undergo a so- called
“check
ride” and “sustainment training 9 ” once a year (once
every 2 years for the Army Reserve and National Guard). Performing these
procedures- which are aimed at identifying and correcting poor driving
habits, maintaining high driving proficiency levels, and ensuring safe
driving- is the responsibility of the driver's assigned unit. Both
procedures must also be documented in personnel driving records. However, we
found that they are either not being performed or are not being recorded as
required.
We reviewed over 450 driving records and found that over 80 percent did not
contain an entry indicating a check ride had been performed every year and
for each type of vehicle in which the driver was licensed to drive. Eighty-
five percent of records also did not have an entry documenting that
sustainment training had been given annually as required. Seventy percent of
the drivers we interviewed (both 88M drivers and occasional drivers) stated
they either did not know what a check ride was or had not been given one
annually. Three- quarters of the drivers we interviewed also said they had
not attended an annual sustainment training course.
Supervisors 10 are responsible for administering check rides to assess a
driver's capabilities and overall driving habits. According to Army
officials, unit commanders and supervisors must also develop and implement
annual sustainment training programs, in part, on the basis of the results
of check rides. A number of supervisors told us that they do not always
conduct formal check rides because of personnel shortages and high operating
tempo; rather, they try to assess drivers' skills and give correctional
guidance- a sort of “informal” check ride- whenever they ride
with a driver. None of them knew about the Transportation School's informal
driver training program, which includes guidelines for sustainment training.
8 ArmyRegulation 600- 55, Army Driver and Operator Standardization Program
(Selection, Training, Testing, and Licensing). 9 Instruction and practice to
ensure that mastery of specific skills are maintained.
10 Supervisors are those in the driver's immediate chain- of- command who
oversee and direct the driver's day- to- day activities. Some Supervisory
Procedures Are Not Being Performed or Documented
Page 16 GAO- 01- 436 Army Training
The Army Safety Center maintains a ground accident database 11 that has been
used in the past to identify accident anomalies that in turn led to safety
improvements involving the operation of M939 series 5- ton trucks. The
database, however, is not complete because not all data fields in accident
investigation reports are always filled in. The database is also not being
analyzed on a regular basis to identify trends or recurring problems.
One of the purposes of the ground database is to provide demographic
information that can be used for statistical comparisons. The Army Safety
Center did so in 1998 when it compared accident rates of different Army
trucks 12 and found that the M939 series trucks had a much higher serious
accident rate than other similar trucks. In other, earlier studies, the
Center reviewed M939 accident data and found a series of recurring accident
conditions. On the basis of these studies, the Army Tank- automotive and
Armaments Command in December 1992 issued the first of several Army- wide
messages 13 warning of these problems and imposing the 40- mph speed limit
on the M939. Also on the basis of these studies, the Command conducted
additional studies on the M939, which in turn led to an estimated $122.4
million in recommended design modifications. 14
We analyzed nearly 400 M939 accident reports dating from 1988 through 1999
contained in the Safety Center's database and found that four of the 36 data
fields of information we requested for our analysis were often not filled
in. Safety Center personnel acknowledged that the missing data could weaken
any conclusions reached using these fields. Two fields –
Was the Driver Licensed at the Time of the Accident and What was the
Driver's Total Accumulated Army Motor Vehicle Mileage – contained no
information 45 and 50 percent of the time respectively, and because of this,
could not be included in the analyses we performed. Two other Fields
–What Was the Mistake Made and Why Was the Mistake Made- were also
often left blank.
11 Army regulations require that an accident investigation report be filled
out for all class A through C occupational injury accidents and all class A
through D property damage accidents. The classes denote the severity of the
accident, with “A” as the most serious or costly.
12 The M34/ 35 trucks, the M939 trucks, and the Family of Medium Tactical
Vehicle trucks. 13 The Army uses Ground Precautionary Messages and Safety of
Use Messages to disseminate service- wide safety information. 14 See
Military Safety: Army M939 5- Ton Truck Accident History and Planned
Modifications (GAO/ NSIAD- 99- 82, Apr. 9, 1999). Accident Database
Not Used Effectively
Page 17 GAO- 01- 436 Army Training
Our analysis also revealed patterns that, if studied further, might be
useful in improving training programs. For example, many of the reported
accidents occurred on wet or slippery surfaces or when the truck was hauling
cargo or pulling equipment. Furthermore, three- quarters of accidents
involved occasional drivers (those trained at informal schools). Some
patterns we identified are illustrated in figure 6.
Figure 6: Some Recurring Conditions Cited in M939 Accident Reports, 1988- 99
Source: Our analysis of Army Safety Center ground accident database.
Instructor shortages are affecting the quality and quantity of truck driver
training, especially at Fort Leonard Wood. The end result is that student
drivers are not fully trained in all aspects of the instruction program when
they graduate. This places an additional burden on the drivers' assigned
units, which must further train these drivers, and on supervisors, who must
be more vigilant in identifying drivers' shortcomings. If formal schools had
enough instructors on- hand, they would presumably be able to teach the
entire instruction program.
The student imbalance between the schools at Fort Leonard Wood, which is
understaffed, and Fort Bliss, which has smaller class sizes and a lower
student- instructor ratio, creates an ineffective use of resources. This
imbalance places an unnecessarily heavy burden on Fort Leonard Wood. If the
annual student load were more equally distributed between the two schools,
student graduates from Fort Leonard Wood might receive more complete
training. Conclusions
Page 18 GAO- 01- 436 Army Training
The formal schools are not adhering to the instruction program, which calls
for some training with trucks carrying cargo. Further, no training is
provided in how to pull equipment. With a high percentage of M939 accidents
taking place under these two conditions, the formal schools should provide
some training in these areas.
Similarly, students are not being trained to drive under different weather
and surface conditions. While it is understandable why formal schools
hesitate to take the risk of having students drive under hazardous or
highrisk conditions, it is also necessary that students receive such
training. An army study concluded that simulators can provide an effective
means of safely training drivers in high- risk weather and different road-
surface situations.
Because annual check rides and sustainment training are not always being
performed, unsafe driving habits may go undetected. Further, if corrective
oversight or training is not recorded, unit commanders and supervisors
cannot know which drivers need attention. Although performing and recording
check rides and sustainment training may be time- consuming, these
procedures can save lives.
Some important safety information, such as M939 speed limit restrictions, is
not always being passed on to or remembered by drivers, supervisors, and
trainers. Using inexpensive devices, such as dashboard stickers, is a simple
way to remind these personnel of the speed restrictions.
The Safety Center's accident database could be used to identify trends that
may show the need for greater training emphasis in certain driving
maneuvers. A periodic analysis of the database could assist school
officials, instructors, and supervisors in adjusting instruction programs or
mentoring drivers. However, such analysis would prove more useful if all
fields of information contained in the database were complete.
We recommend that the Secretary of the Army direct the Commander of the
Training and Doctrine Command to
? review and modify, as needed, instructor levels for the formal training
programs to ensure that the programs are adequately staffed to teach the
anticipated class size;
? balance the student load between the two schools by bringing the Fort
Bliss school up to fuller capacity and/ or increasing the number of classes
Recommendations
Page 19 GAO- 01- 436 Army Training
annually taught there, thereby reducing the student load and associated
problems created by such at Fort Leonard Wood;
? enforce the instruction program used by the two formal schools to ensure
that students receive hands- on training in driving trucks loaded with cargo
and also modify the program to include driving when pulling equipment- two
essential skills in performing the primary mission of the 5- ton tactical
fleet; and
? consider using simulators at the two formal schools to safely teach known
training shortfalls such as driving under hazardous conditions, with the
understanding that simulators not be used to replace hands- on driving
conducted under less risky conditions.
We also recommend that the Secretary of the Army issue instructions to all
applicable major army commands to
? require adherence to Army regulations on check rides and sustainment
training of licensed truck drivers and
? require that warning stickers indicating speed restrictions be prominently
displayed in the cabs of all M939 trucks not equipped with anti- skid brake
systems.
We further recommend that the Secretary of the Army direct the Commander of
the Army Safety Center to
? ensure that all information fields in accident reports are properly filled
in and
? periodically review accident data for the presence of trends or anomalies
for the purposes of informing trainers and supervisors of any information
that may help them perform their duties or help improve safety.
In oral comments on a draft of this report, Department of Defense officials
concurred with all our recommendations.
We are providing copies of this report to the Honorable Donald H. Rumsfeld,
Secretary of Defense; the Honorable Joseph W. Westphal, Ph. D., Acting
Secretary of the Army; and interested congressional committees. Copies will
also be made available to other interested parties upon request. Agency
Comments
and Our Review
Page 20 GAO- 01- 436 Army Training
If you or your staff have questions concerning the report, please call me at
(202) 512- 5559. Our scope and methodology is explained in appendix I. GAO
contacts and staff acknowledgments to this report are listed in appendix II.
Derek B. Stewart Director Defense Capabilities and Management
Appendix I: Objectives, Scope, and Methodology
Page 21 GAO- 01- 436 Army Training
Our objectives were to (1) evaluate the capacity of the Army's 5- ton truck
driver training programs to fully train drivers, (2) determine whether
oversight procedures and processes for these drivers are being followed, and
(3) determine whether and how the Army uses accident data to improve
training, supervision, and safety.
To evaluate the capacity of the Army's 5- ton truck driver training programs
to fully train drivers, we reviewed applicable training programs in terms of
compliance and completeness at both of the Army's formal schools (Fort
Leonard Wood and Fort Bliss) and 10 different informal training facilities
located at 4 installations. We also reviewed the training provided at one of
eight Army Reserve training centers. Reserve training centers all use the
same Program of Instruction. We reviewed these programs for compliance with
existing regulations and standard operating procedures established by the
various training components. To assess the completeness of training, we made
observations and collected documentation relating to the actual training
being conducted and compared that documentation to the training specified in
each training schools/ program's instruction program and also in relation to
the primary mission of the 5- ton truck fleet. We also discussed these
issues with officials responsible for designing the training programs,
training command personnel, driving instructors, and student drivers to gain
their perspectives. Lastly we compared the formal Marine Corps 5- ton
training program and two commercial sector training programs to the Army's
formal program to identify any training techniques and/ or devices that
might benefit 5- ton training curriculums.
To determine whether oversight procedures and processes for these drivers
are being followed, we documented the duties of supervisors of medium
tactical vehicles as found in Department of Defense and Army guidance,
instructions, procedures, and regulations. Through observations and
discussions with nearly 80 driver supervisors and nearly 200 truck drivers
stationed at 12 different Army and National Guard units, we then assessed
the degree to which they accomplished these responsibilities or followed
required documentary procedures. In addition, at the units visited we
collected over 450 historical driving records for truck operators and
reviewed them for required annual supervisory annotations relating to check
ride and sustainment training specified in Army regulations.
To ensure we collected information representative of the universe of
existing 5- ton truck informal training programs and the administering of
driver supervision responsibilities, we selected- for review and observation
purposes- four installations aligned under the U. S. Army Appendix I:
Objectives, Scope, and
Methodology
Appendix I: Objectives, Scope, and Methodology
Page 22 GAO- 01- 436 Army Training
Forces Command. This major command, according to the Army Materiel Command's
Logistic Support Activity, controls 94 percent of the active army's M939
series 5- ton trucks in the continental United States. Because Army
automated record- keeping systems cannot provide 5- ton truck densities or
locations below the major command level, we engaged the services of Army
Internal Review personnel to assist us. Within the four installations, we
requested that Internal Review personnel set up meetings with subordinate
commands conducting the majority of 5- ton truck driver training and with
commands maintaining the largest concentrations of 5ton trucks and/ or
drivers.
In discussing accident data with Army Safety Center personnel, we learned of
Army notifications currently in effect and relevant to the safe handling of
5- ton trucks that resulted from past analyses performed on the Center's
ground accident database. We reviewed these notifications, including
existing Army regulations and procedures pertaining to how this information
is to be disseminated Army- wide. We then queried 5- ton truck driver-
trainers, student drivers, supervisors, and licensed drivers to gain an
understanding of how knowledgeable they were of restrictions imposed by
these notifications.
To determine whether and how the Army uses accident data to improve
training, supervision, and safety, we interviewed safety center personnel
and obtained and reviewed past studies and analyses conducted by the Center.
In addition to identifying data that could be useful in improving training
or supervision, we analyzed 12 years of demographic accident information
pertaining to M939 series 5- ton tactical cargo trucks. Our analysis of this
information, compiled for us by Army Safety Center personnel, included Class
A, B, and C accidents occurring from January 1988 through December 1999 and
for which some degree of fault was attributable to an M939 driver. This
truck series accounts for about onehalf of the Army's 5- ton fleet and is
the series specifically mentioned in the request letter. We focused on
identifying the presence of any demographic anomalies or commonality factors
that, when compiled statistically, might prove beneficial to trainers,
supervisors, or the safer operation of M939 series trucks. We also discussed
the results of our accident analysis with Army Safety Center officials,
trainers, and supervisors to obtain their input and/ or concurrence.
We performed our work from May 1999 through July 2000 in accordance with
generally accepted government auditing standards.
Appendix II: GAO Contact and Staff Acknowledgments
Page 23 GAO- 01- 436 Army Training
Reginald L. Furr, Jr. (202) 512- 5426 In addition to those named above,
Aisha A. Mahmood, Stefano Petrucci, William R. Simerl, Lorelei St. James,
and Gerald L. Winterlin made key contributions to this report. Appendix II:
GAO Contact and Staff
Acknowledgments GAO Contact Acknowledgments
(702001)
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A
Report to the Chairman, Committee on the Budget, House of Representatives
April 2001 ENVIRONMENTAL LIABILITIES
DOD Training Range Cleanup Cost Estimates Are Likely Understated
GAO- 01- 479
GAO United States General Accounting Office
Page 1 GAO- 01- 479 Training Range Cleanup Letter 3
Appendix I Objectives, Scope, and Methodology 26
Appendix II Comments From the Department of Defense 28
Appendix III GAO Contact and Staff Acknowledgments 34
Figures
Figure 1: Signs Warning of the Dangers and Presence of Unexploded Ordnance
at Fort McClellan 11 Figure 2: Examples of Unexploded Ordnance Found on
Training
Ranges 12
Abbreviations
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
DOD Department of Defense DOE Department of Energy DUSD( ES) Deputy Under
Secretary of Defense for Environmental
Security EPA Environmental Protection Agency SARA Superfund Amendments and
Reauthorization Act SFFAS Statement of Federal Financial Accounting
Standards Contents
Page 2 GAO- 01- 479 Training Range Cleanup
Page 3 GAO- 01- 479 Training Range Cleanup
April 11, 2001 The Honorable Jim Nussle Chairman Committee on the Budget
House of Representatives
Dear Mr. Chairman: The previous chairman of your Committee expressed concern
about the long- term budgetary implications associated with the
environmental cleanup of the Department of Defense's (DOD) training ranges.
The chairman requested that we review (1) the potential magnitude of the
cost to clean up these ranges in compliance with applicable laws and
regulations, (2) the scope and reliability of DOD's training range
inventory, and (3) the methodologies used to develop cost estimates. This
report conveys the results of that review. He also requested a similar
review of certain other DOD property that has associated environmental
cleanup and disposal costs on which we will issue a separate report at a
later date. This report focuses on DOD's efforts to collect, analyze, and
report information on its training ranges and the potential cleanup costs 1
of
1 Federal accounting standards define environmental cleanup costs as the
cost of removing, containing, and/ or disposing of (1) hazardous waste from
property or (2) material and/ or property that consists of hazardous waste
at permanent or temporary closure or shutdown of associated property, plant,
and equipment. Hazardous waste is a solid, liquid, or gaseous waste, or
combination of these wastes, which because of its quantity, concentration,
or physical, chemical, or infectious characteristics may cause or
significantly contribute to an increase in mortality or an increase in
serious irreversible, or incapacitating reversible, illness or pose a
substantial present or potential hazard to human health or the environment
when improperly treated, stored, transported, disposed of, or otherwise
managed. Cleanup may include, but is not limited to, decontamination,
decommissioning, site restoration, site monitoring, closure, and postclosure
costs.
United States General Accounting Office Washington, DC 20548
Page 4 GAO- 01- 479 Training Range Cleanup
unexploded ordnance 2 or other constituent contamination 3 on these training
ranges. 4
DOD has estimated that millions of acres of training ranges in the United
States and its territories are contaminated with unexploded ordnance that
could potentially harm the public and the environment if not properly
managed or cleaned up. With the increase in DOD downsizing and resulting
base closures in recent years, large numbers of military properties are
being turned over to non- DOD ownership and control. Although DOD has
procedures to mitigate the risk to human health and the environment, the
transfer of ownership results in the public being put at greater risk of
sickness, injury, or even death from unexploded ordnance or its constituent
contamination. DOD is subject to various laws that govern remediation of
contamination on military installations and standards establishing
requirements for DOD to recognize and report the costs of managing and
cleaning up these properties.
We conducted our work in accordance with generally accepted government
auditing standards from May 2000 through March 2001. Further details on our
scope and methodology are in appendix I.
DOD does not have complete and accurate data needed to estimate training
range cleanup costs. The two primary elements needed to develop these costs
are (1) an accurate and complete training range inventory and (2) a
consistent cost methodology. Because DOD does not have a complete inventory
and has not used a consistent cost methodology, the amounts reported for
training range cleanup cannot be relied upon and are
2 Unexploded ordnance are munitions that have been primed, fused, armed, or
otherwise prepared for action, and have been fired, dropped, launched,
projected, or placed in such a manner as to constitute a hazard to
operations, installation, personnel, or material and remain unexploded
either by malfunction, design or any other cause.
3 Military munitions may contain many constituents that can pollute the soil
and water supplies. These constituents can be released by the detonation of
ordnance or from damaged or deteriorated unexploded ordnance. Constituents
that may be released include propellants, explosives, pyrotechnics, chemical
agents, metal parts, and other inert components.
4 The cleanup of unexploded ordnance and other constituent contamination on
training ranges will be referred to in this report as training range
cleanup. This does not include the cleanup of nontraining range sites
containing unexploded ordnance or sites such as manufacturing facilities,
munitions burial pits, or open burn and open detonation sites. Results in
Brief
Page 5 GAO- 01- 479 Training Range Cleanup
likely significantly understated. For example, in its fiscal year 2000
financial statements, DOD reported its liability for the cleanup of training
ranges at approximately $14 billion. 5 However, other DOD estimates show
that its liability for training range cleanup could exceed $100 billion.
Without complete and accurate data, it is impossible to determine whether
these amounts represent a reasonable estimate of the long- term budget
implications of cleaning up DOD's training ranges.
The military services have not performed complete inventories of their
ranges, fully identifying the types and extent of the unexploded ordnance
present and the associated contamination. Recently, DOD began the initial
compilation of training range data in response to the Senate Report
accompanying the National Defense Authorization Act for Fiscal Year 2000
(Report 106- 50, May 17, 1999), which called for a complete estimate of the
current and projected costs for unexploded ordnance remediation 6 at active
facilities, installations subject to base realignment and closure, and
formerly used defense sites, including all training ranges. However, DOD's
initial data collection efforts in response to the Senate Report were
delayed in part because DOD did not issue formal guidance to the services
for collecting the range information until October 2000- 17 months after the
date of the Senate Report, which directed DOD to prepare a report to the
congressional defense committees by March 1, 2001. However, as of March 30,
2001, this report had not been issued. In addition to the delay, the
guidance when issued was not comprehensive enough to develop a complete and
accurate inventory. In an attempt to meet the March 1, 2001, deadline in the
Senate Report, DOD officials limited the scope of the information gathered
and analyzed. For example, DOD did not direct the services to collect
information or report on the unexploded ordnance constituent contamination
of soil, ground water, and surface water, or water ranges. As a result, the
March 2001 report will not be complete or accurate.
Federal financial accounting standards have required that DOD report a
liability for the estimated cost of cleaning up its training ranges in its
annual financial statements since fiscal year 1997, although DOD did not
begin to do so until fiscal year 1999. Since DOD had not completed an
inventory of its ranges, the services have used varying methods to estimate
5 DOD Fiscal Year 2000 Agency- wide Financial Statements, February 15, 2001.
6 Unexploded ordnance remediation also includes the cleanup of other
constituent contamination associated with unexploded ordnance.
Page 6 GAO- 01- 479 Training Range Cleanup
the size and condition of the ranges necessary to estimate the cost of
cleanup for financial statement reporting purposes. For example, in fiscal
year 2000, the Navy estimated training range acreage based upon limited
surveys completed in 1995 through 1997 and applied a cleanup cost factor of
$10,000 an acre to the total. The Army, lacking detailed knowledge of its
ranges, estimated the number of closed ranges and applied historical costs
from other cleanup efforts. These ad hoc measures do not substitute for the
comprehensive inventory of training ranges needed to develop reasonable
environmental liability estimates for the financial statements.
In addition, environmental liability costs reported in the financial
statements for training range cleanup are not consistently calculated and
reported across the services. To date, the services have not been provided
adequate guidance to develop consistent cost estimates. As a result, the
services have independently developed cost estimates and used different
methodologies for estimating the cost of cleaning up training ranges for
financial statement reporting. DOD officials told us that they planned to
use a standard methodology for estimating the cleanup costs in the March
2001 report; however, this methodology was available but not used by the
services for the fiscal year 2000 financial statements. Also, the
assumptions and cost factors DOD planned to use in the model for estimating
the training range cleanup costs for the March 2001 report have not been
independently validated as required by DOD policy to ensure reliable
estimates. DOD is planning to validate this cost estimating model later in
2001.
Service officials have told us they are unsure whether the standard
methodology used to estimate training range cleanup costs for the March 2001
report will be used in the future for estimating the cleanup liability
reported in the financial statements. However, without a consistent
methodology, cleanup costs reported in the financial statements and other
reports will not be comparable and have limited value to management when
evaluating cleanup costs of each the services' training ranges and budgeting
for the future.
The problems we have identified with DOD's accumulation of its inventory and
cost data on training range cleanup demonstrate that DOD does not have the
top management focus and leadership necessary to reliably report estimates
of training range cleanup costs. The need for similar programmatic
leadership has been previously recognized and
Page 7 GAO- 01- 479 Training Range Cleanup
recommended by the Defense Science Board 7 in 1998. The Defense Science
Board found that DOD had no specific unexploded ordnance remediation policy,
goals, or program. In addition, several members of Congress have recently
written letters to the Secretary of Defense to express similar concerns
about the need for high- level attention and resources to address training
range cleanup issues.
We are making recommendations to address (1) the need for DOD leadership in
managing the reporting of training range liabilities and (2) developing and
implementing guidance to ensure that DOD has a complete inventory of all
training ranges and that a consistent cost methodology is used in reporting
training range cleanup liabilities.
In commenting on a draft of this report, DOD concurred with our
recommendations. The additional information that DOD provided in response to
one of our recommendations is discussed in the “Agency
Comments and Our Evaluation” section. DOD is subject to various laws
dating back to the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) as amended by the Superfund Amendments and
Reauthorization Act (SARA) of 1986 that govern remediation (cleanup) of
contamination on military installations. DOD must also follow federal
accounting standards that establish requirements for DOD to recognize and
report the estimated costs for the cleanup of training ranges in the United
States and its territories. Increasing public concern about potential health
threats has affected not only the present operations of these training
ranges but also the management, cleanup, and control of this training range
land that has been, or is in the process of being, transferred to other
agencies and public hands.
DOD defines a range as any land mass or water body that is used or was used
for conducting training, research, development, testing, or evaluation of
military munitions or explosives. DOD classifies its ranges into the
following five types.
7 The Defense Science Board is a federal advisory committee established to
provide independent advice to the Secretary of Defense. Background
Training Range Classification
Page 8 GAO- 01- 479 Training Range Cleanup
? Active ranges are currently in operation, construction, maintenance,
renovation, or reconfiguration to meet current DOD component training
requirements and are being regularly used for range activities. Examples of
these ranges would include ranges used for bombing, missiles, mortars, hand
grenades, and artillery testing and practice.
? Inactive ranges are ranges that are not currently being used as active
ranges. However, they are under DOD control and are considered by the
military to be a potential active range area in the future, and have not
been put to a new use incompatible with range activities.
? Closed ranges have been taken out of service and are still under DOD
control but DOD has decided that they will not be used for training range
activities again.
? Transferred ranges have been transferred to non- DOD entities such as
other federal agencies, state and local governments, and private parties,
and are those usually associated with the formerly used defense sites 8
program.
? Transferring ranges are in the process of being transferred or leased to
other non- DOD entities and are usually associated with the base realignment
and closure program.
Congress addressed environmental contamination at federal facilities under
SARA in 1986. This legislation established, among other provisions, the
Defense Environmental Restoration Program and the Defense Environmental
Restoration Account as DOD's funding source under the Act. The goals of the
Defense Environmental Restoration Program include (1) identification,
investigation, research and development, and cleanup of contamination from
hazardous substances, pollutants, and contaminants and (2) correction of
other environmental damage such as detection and disposal of unexploded
ordnance which creates an imminent and substantial danger to the public
health or welfare or to the environment. The Office of the Deputy Under
Secretary of Defense for Environmental Security (DUSD( ES)) was created in
1993. That office has overall responsibility for environmental cleanup
within DOD and includes the Office of Environmental Cleanup that manages the
Defense Environmental Restoration Program.
8 Formerly used defense sites are properties that were formerly owned,
leased, possessed, or operated by DOD. Requirements to Address
and Report Training Range Cleanup Liabilities
Page 9 GAO- 01- 479 Training Range Cleanup
Carrying out any remediation or removal actions under applicable
environmental laws, including SARA, would likely require the immediate or
future expenditure of funds. Federal accounting standards determine how
those expenditures are accounted for and reported. The Chief Financial
Officers' Act of 1990, as expanded by the Government Management and Reform
Act of 1994, requires that major federal agencies, including DOD, prepare
and submit annual audited financial statements to account for its
liabilities, among other things. Two federal accounting standards, Statement
of Federal Financial Accounting Standards (SFFAS) Nos. 5 and 6, establish
the criteria for recognizing and reporting liabilities in the annual
financial statements, including environmental liabilities.
SFFAS No. 5, Accounting for Liabilities of the Federal Government, defines
liability as a probable future outflow of resources due to a past government
transaction or event. SFFAS No. 5 further states that recognition of a
liability in the financial statements is required if it is both probable and
measurable. Effective in 1997, SFFAS No. 5 defines probable as that which is
more likely than not to occur (for example, greater than a 50 percent
chance) based on current facts and circumstances. It also states that a
future outflow is measurable if it can be reasonably estimated. The
statement recognizes that this estimate may not be precise and, in such
cases, it provides for recognizing the lowest estimate of a range of
estimates if no amount within the range is better than any other amount.
SFFAS No. 6, Accounting for Property, Plant, and Equipment, further defines
cleanup costs as costs for removal and disposal of hazardous wastes or
materials that because of quantity, concentration, or physical or chemical
makeup may pose a serious present or potential hazard to human health or the
environment.
The Office of the Under Secretary of Defense (Comptroller) issues the DOD
Financial Management Regulation containing DOD's policies and procedures in
the area of financial management, which require the reporting of
environmental liabilities associated with the cleanup of closed,
transferred, and transferring ranges in the financial statements. 9 DOD has
taken the position that the cleanup of these ranges is probable and
measurable and as such should be reported as a liability in its financial
statements. Under the presumption that active and inactive ranges will
9 DOD Financial Management Regulation, Volume 4, Chapter 13, Accrued
Environmental and Nonenvironmental Disposal Cost Liabilities and Chapter 14
, Accrued Environmental Restoration (Cleanup) Liabilities, October 1999; and
Volume 6B, Chapter 10 , Notes to the Financial Statements, December 2000.
Page 10 GAO- 01- 479 Training Range Cleanup
operate or be available to operate indefinitely, the DOD Financial
Management Regulation does not specify when or if liabilities should be
recognized in the financial statements for these ranges.
The Senate Report accompanying the National Defense Authorization Act for
Fiscal Year 2000 directed DOD to provide a report to the congressional
defense committees, no later than March 1, 2001, that gives a complete
estimate of the current and projected costs for all unexploded ordnance
remediation. As of March 30, 2001, DOD had not issued its report. For the
purposes of the March 2001 report, DOD officials had stated that they would
estimate cleanup costs for active and inactive training ranges just as they
would for closed, transferred, and transferring ranges. Thus, the cleanup
costs shown in this report would have been significantly higher than the
training range liabilities reported in the financial statements, which only
include estimates for closed, transferred, and transferring ranges. However,
in commenting on a draft of our report, DOD officials informed us that they
would not be reporting the cleanup costs of active and inactive training
ranges in their March report.
As DOD downsizing and base closures have increased in recent years, large
numbers of military properties have been, and are continuing to be, turned
over to non- DOD ownership and control, resulting in the public being put at
greater risk. DOD uses a risk- based approach when transferring ranges from
its control to reduce threats to human health and the environment. DOD
attempts to mitigate risk to human health on transferred and transferring
ranges. In instances where DOD has not removed, contained, and/ or disposed
of unexploded ordnance and constituent contamination from training ranges
prior to transfer, it implements institutional controls to restrict access
to transferring ranges and to transferred ranges where risks are found.
Institutional controls include implementing community education and
awareness programs, erecting fences or barriers to control access, and
posting signs warning of the dangers associated with the range. Figure 1
shows signs posted at Fort McClellan, Alabama, warning of unexploded
ordnance. Fort McClellan has been designated for closure under the base
realignment and closure program and, as such, is in the process of
transferring base properties out of DOD control. Senate Reporting Directive
Training Ranges Pose Significant Risk
Page 11 GAO- 01- 479 Training Range Cleanup
Figure 1: Signs Warning of the Dangers and Presence of Unexploded Ordnance
at Fort McClellan
Source: General Accounting Office.
DOD officials have estimated that approximately 16 million acres of
potentially contaminated training ranges have been transferred to the public
or other agencies. The risk to the public was further discussed by an
Environmental Protection Agency (EPA) official in a letter dated April 22,
1999, to DUSD( ES). The EPA official cautioned that many training ranges
known or suspected to contain unexploded ordnance and other hazardous
constituents have already been transferred from DOD control, and many more
are in the process of being transferred, and the risks from many of these
have not been adequately assessed. The letter went on to state that risks
correspondingly increase as ranges that were once remote are encroached by
development or as the public increases its use of these properties. An
example of the development of sites adjacent to training ranges is the
planned construction of two schools and a stadium by the Cherry Creek School
District adjacent to the Lowry Bombing Range, a transferred range, near
Denver. Construction is expected to begin in May 2001.
Most training range contamination is a result of weapons systems testing and
troop training activities conducted by the military services. Unexploded
ordnance consists of many types of munitions, including hand grenades,
rockets, guided missiles, projectiles, mortars, rifle grenades, and
Page 12 GAO- 01- 479 Training Range Cleanup
bombs. Figure 2 shows examples of some of the typical unexploded ordnance
that has been removed from training ranges.
Figure 2: Examples of Unexploded Ordnance Found on Training Ranges
Source: U. S. Army Corps of Engineers.
Risks from this unexploded ordnance can encompass a wide range of possible
outcomes or results, including bodily injury or death, health risks
associated with exposure to chemical agents, and environmental degradation
caused by the actual explosion and dispersal of chemicals or other hazardous
materials to the air, soil, surface water, and groundwater. For example,
according to an EPA report, 10 EPA surveyed 61 current or former DOD
facilities containing 203 inactive, closed, transferred, and transferring
ranges and identified unexploded ordnance “incidents” at 24
facilities. These incidents included five accidental explosions, which
resulted in two injuries and three fatalities. According to an EPA official,
the three fatalities identified in their limited survey were two civilian
DOD contractors and one military service member.
10 Used or Fired Munitions and Unexploded Ordnance at Closed, Transferred,
and Transferring Military Ranges (September 2000, EPA 505- R- 00- 01).
Page 13 GAO- 01- 479 Training Range Cleanup
Although DOD reported its unexploded ordnance cleanup liability on training
ranges at about $14 billion in its fiscal year 2000 agencywide financial
statements, it is likely that the financial statements are substantially
understated. Further, significant cleanup costs will not be included in the
planned March 2001 report. DOD officials and Members of Congress have
expressed concern over the potential liability the government may be faced
with but are still uncertain how large the liability may be. Various
estimates have shown that cleanup of closed, transferred, and transferring
training ranges could exceed $100 billion. For example:
? In preparation for DOD's planned issuance of the Range Rule, 11 DOD began
an analysis of the potential costs that may be incurred if the Rule was
implemented. The Rule was intended to provide guidance to perform
inventories and provide cleanup procedures at closed, transferred, and
transferring ranges. The Rule was withdrawn in November 2000 and the cost
analysis was never formally completed. However, a senior DOD official said
that initial estimates in the cost analysis that was developed in 2000 put
the cleanup costs of training ranges at about $40 billion to $140 billion
for closed, transferred, and transferring training ranges.
? DOD estimated that its potential liability for cleanup of unexploded
ordnance might exceed $100 billion as noted in a conference report to the
National Defense Authorization Act for Fiscal Year 2001 (Report 106- 945,
October 6, 2000).
DOD will not respond fully to the Senate Report request for reporting the
costs of cleaning up unexploded ordnance on its training ranges. DOD
officials informed us that due to time constraints, the training range
liability to be reported in the March 2001 report would not be complete or
comprehensive because the required information could not be collected in
time for analysis and reporting. A DUSD( ES) official said that the March
2001 report will include a discussion of the limitations and omissions. DOD
officials stated that they have deferred the collection and analysis of
11 DOD's Range Rule was a proposed regulation that defined a process to
identify closed, transferred, and transferring ranges and address risk to
human health and the environment posed by unexploded ordnance on these
ranges. The Office of Management and Budget, EPA, and federal land managers
were extensively involved in the rulemaking process. On November 13, 2000,
DOD withdrew the Range Rule from the rulemaking process because DOD, EPA,
and federal land managers could not reach consensus on several key issues
including how explosives safety would be handled under the Rule, concurrence
on remedial actions, and who decides the remedy. DOD's Reported
Cleanup Costs Are Likely Substantially Understated
Significant Cleanup Costs Will Not Be Reported in the March 2001 Report
Page 14 GAO- 01- 479 Training Range Cleanup
key data elements. Some of the items that were excluded are the costs to
clean up the soil and groundwater resulting from unexploded ordnance and
constituent contamination. These omitted costs could be significant.
Further, the March 2001 report will not include information on water ranges.
DOD's 1996 Regulatory Impact Analysis 12 reported that DOD had approximately
161 million acres of water training ranges, almost 10 times the size of the
estimated closed, transferred, and transferring land ranges. In commenting
on a draft of this report, DOD stated that the 161 million acres of water
ranges are active training ranges, the majority of which are open- ocean,
deep water, restricted access areas and most are outside the territorial
waters of the United States. DOD also stated that the majority of water
ranges are not likely to cause an imminent and substantial danger to public
health and safety or the environment. However, until a complete and accurate
inventory is performed, DOD will be unable to determine whether some water
ranges meet the reporting requirement of SFFAS No. 5 and, thus, must be
reported in the financial statements.
The DOD Comptroller has revised the DOD Financial Management Regulation to
clarify DOD's fiscal year 2000 financial statement reporting requirements
for training range cleanup costs. The revision includes guidance that
requires the reporting of the cleanup costs of closed, transferred, and
transferring ranges as liabilities in the financial statements. DOD has
indicated that the costs to clean up these training ranges is probable and
measurable and as such should be reported as a liability in the financial
statements. We concur with DOD that these costs should be reported in the
financial statements as liabilities because they are probable and
measurable.
Specifically, they are probable because DOD is legally responsible for
cleaning up closed, transferred, and transferring ranges which were
contaminated as a result of past DOD action. For example, under SARA, DOD is
responsible for the cleanup of sites that create an imminent and substantial
danger to public health and safety or the environment. In addition, these
training range cleanup efforts are measurable. DOD has prior experience in
training range cleanup under the formerly used
12 DOD's 1996 Regulatory Impact Analysis was an analysis of the estimated
costs to implement the Range Rule when it was first proposed in 1997. As
stated earlier, a recent analysis was never formally completed due to DOD's
withdrawal of the Range Rule. Financial Statement
Liability Also Understated
Page 15 GAO- 01- 479 Training Range Cleanup
defense sites program and has used this experience to develop a methodology
to estimate future cleanup costs. However, as explained later in this
report, DOD has not based its reported financial statement liability for
cleanup of these ranges on a complete inventory or consistent cost
methodology, resulting in estimates that range from $14 billion to over $100
billion.
In addition, we believe that certain active and inactive sites may have
contamination that should also be recorded as a liability in the financial
statements because these sites meet criteria in federal accounting standards
for recording a liability. The DOD Financial Management Regulation does not
include instructions for recognizing a liability for training range cleanup
costs on active and inactive ranges in the financial statements. Although
cleanup of active and inactive ranges would not generally be recognized as a
liability in the financial statements, there are circumstances when an
environmental liability should be recognized and reported for these ranges.
A liability should be recognized on active and inactive ranges if the
contamination is government related, the government is legally liable, and
the cost associated with the cleanup efforts is measurable. For example,
contaminants from an active training range at the Massachusetts Military
Reservation threaten the aquifer that produces drinking water for nearby
communities. The problem was so severe that in January 2000, EPA issued an
administrative order under the Safe Drinking Water Act requiring DOD to
cleanup several areas of the training range. According to a DOD official,
the cleanup effort could cost almost $300 million. As a result, the cleanup
of this contamination is probable (since it is legally required) and
measurable. Thus, this liability should be recognized in the financial
statements under SFFAS No. 5.
Although DOD and the services have collected information on other
environmental contamination under the Defense Environmental Restoration
Program for years, they have not performed complete inventories of training
ranges to identify the types and extent of contamination present. To
accurately compute the training range liabilities, the military services
must first perform in- depth inventories of all of their training ranges.
Past data collection efforts were delayed because the services were waiting
for the promulgation of the Range Rule which has been withdrawn. DOD
recently began collecting training range data to meet the reporting
requirements for the Senate Report. However, as stated previously, DOD has
limited its data collection efforts and will not be reporting on the cleanup
of water ranges or the unexploded ordnance constituent contamination of the
soil and water. Training Range
Inventories Are Not Complete
Page 16 GAO- 01- 479 Training Range Cleanup
The Army, under direction from DUSD( ES), proposed guidance for the
identification of closed, transferred, and transferring ranges with the
preparation and attempted promulgation of the Range Rule. In anticipation of
the Range Rule, DOD prepared a Regulatory Impact Analysis report in 1996,
recognizing that the cleanup of its closed, transferred and transferring
training ranges was needed and that the cleanup costs could run into the
tens of billions of dollars.
To address inventories of its active and inactive ranges, DOD issued
Directive 4715.11 for ranges within the United States and Directive 4715.12
for ranges outside the United States in August 1999. These directives
required that the services establish and maintain inventories of their
ranges and establish and implement procedures to assess the environmental
impact of munitions use on DOD ranges. However, the directives did not
establish the guidance necessary to inventory the ranges nor establish any
completion dates. Although the directives assigned responsibility for
developing guidance to perform the inventories, DOD has not developed the
necessary guidance specifying how to gather the inventory information or how
to maintain inventories of the active and inactive training ranges.
Since fiscal year 1997, federal accounting standards have required the
recognition and reporting of cleanup costs, as mentioned earlier. However,
DOD did not report costs for cleaning up closed, transferred, and
transferring training ranges until the services estimated and reported the
training range cleanup costs in DOD's agencywide financial statements for
fiscal year 1999. Agencywide financial statements are prepared in accordance
with the DOD Financial Management Regulation, which is issued by the DOD
Comptroller and incorporates Office of Management and Budget guidance on
form and content of financial statements.
In an attempt to comply with the mandates in the Senate Report, DOD embarked
on a special effort to collect training range data necessary to estimate
potential cleanup costs. The Senate Report directed DOD to report all known
projected unexploded ordnance remediation costs, including training ranges,
by March 1, 2001, and to report subsequent updates in the Defense
Environmental Restoration Program annual report to Congress. While the
Senate Report did not expressly direct DOD to identify an inventory of
training ranges at active facilities, installations subject to base
realignment and closure, and formerly used defense sites, the data necessary
to fully estimate costs of unexploded ordnance- normally located on training
ranges- could only be attained in Previous Inventory
Initiatives Senate Report Expedited DOD Inventory Data Collection
Page 17 GAO- 01- 479 Training Range Cleanup
conjunction with the performance of a complete and accurate inventory that
includes training ranges.
Although the Senate Report's directives were dated May 1999, DOD did not
provide formal guidance to the services for collecting training range data
until October 2000- 17 months later. As a first step in February 2000, the
Under Secretary of Defense for Acquisition, Technology, and Logistics
assigned the responsibility to the Office of the Director of Defense
Research and Engineering, in coordination with DUSD( ES), for obtaining the
range data and preparing the report. On October 23, 2000, DUSD( ES) issued
specific guidance to the military services instructing them to gather range
information and detailing some of the specific information needed. Although
DOD instituted an Unexploded Ordnance Inventory Working Group in March 2000
to work with the services to develop specific guidance, service officials
told us that DOD had not clearly told them what was required or when it was
required until shortly before the official tasking was issued on October 23,
2000. Once officially tasked to gather range information, the services were
given until January 5, 2001, to gather and provide it to DOD for analysis by
a DOD contractor.
Lacking specific guidance from DOD to inventory their ranges, but
recognizing that they would eventually be tasked to gather range information
in anticipation of the Range Rule or for the Senate Report, each of the
services developed its own survey questionnaires to begin gathering range
information before the formal guidance was issued. The Navy took a proactive
approach and began developing a questionnaire in late 1999. The
questionnaire was issued to the Navy commands in December 1999. The Army and
the Air Force also developed their own questionnaires and issued them in
September 2000. Because the formal guidance was issued after the services
had begun their initial data collection, the services had to collect
additional data from their respective units or other sources. According to
DOD officials, the training range inventory information gathered from these
questionnaires for the March 2001 report will also be used in the future as
a basis for financial statement reporting.
Although the scope of ranges in the United States and its territories is not
fully known- because DOD does not have a complete inventory of training
ranges- DOD estimates that over 16 million acres of land on closed,
transferred, and transferring ranges are potentially contaminated with
unexploded ordnance. DOD also estimates that it has about 1,500 contaminated
sites. Many former military range sites were transferred to Range
Identification Is
Difficult and Costly
Page 18 GAO- 01- 479 Training Range Cleanup
other federal agencies and private parties. Training ranges must be
identified and investigated to determine type and extent of contamination
present, risk assessments performed, cleanup plans developed, and permits
obtained before the actual cleanup is begun. These precleanup costs can be
very expensive. For example, the Navy estimates that these investigative
costs alone are as much as $3.96 million per site.
Identifying the complete universe of current and former training ranges is a
difficult task. Ranges on existing military bases are more easily
identifiable and accessible. More problematic, however, are those ranges
that were in existence decades ago, that have been transferred to other
agencies or the public, and records of the ranges' existence or the ordnance
used cannot always be found. Special investigative efforts may be necessary
to identify those locations and ordnance used. In preparing for World War I
and World War II, many areas of the country were used as training ranges. In
some instances, documentation on the location of and/ or the types of
ordnance used on these ranges is incomplete or cannot be found. For example,
unexploded ordnance was unexpectedly found by a hiker in 1999 at Camp Hale
in Colorado, a site used for mountain training during World War II and since
transferred to the U. S. Forest Service. Because additional live rifle
grenades were found in 2000, the Forest Service has closed thousands of
acres of this forest to public use pending further action. This site also
serves as an example of the difficulty in identifying and cleaning up
unexploded ordnance in rough mountain terrain and dense ground cover.
In addition to not having an accurate and complete inventory of its training
ranges, DOD has just recently focused on development of a consistent
methodology for estimating its training range cleanup cost estimates.
However, DOD is using different methodologies for estimating cleanup costs
for the annual financial statements and the March 2001 report. While DOD is
using a standard methodology for estimating and reporting its cleanup costs
for the March 2001 report, that methodology was not used to estimate the
training range cleanup costs for the fiscal year 2000 financial statements.
In addition, each of the services is using different methodologies for
calculating cleanup cost estimates for reporting its liabilities in the
financial statements. Without a consistent methodology, cleanup costs
reported in the financial statements and other reports will not be
comparable and have limited value to management when evaluating cleanup
costs of each the services' training ranges and budgeting for the future.
Cost Methodologies
Are Inconsistent
Page 19 GAO- 01- 479 Training Range Cleanup
Because the military services do not apply a consistent cost methodology to
compute the liabilities for their financial statements, any comparison among
the training range liabilities across the services will not be meaningful.
DOD is reporting a liability of about $14 billion for fiscal year 2000 for
cleaning up closed, transferred, and transferring training ranges. Of the
$14 billion, the Navy is reporting a liability of $53.6 million. The Navy,
based on limited surveys completed in 1995 through 1997, estimated the
number and size of its training ranges and applied a $10,000 an acre cleanup
cost factor to compute its liability. The Navy based its estimates on the
assumption of cleaning up its closed, transferred, and transferring ranges
to a “low” cleanup/ remediation level. The low cleanup/
remediation level means that the training ranges would be classified as
“limited public access” and be used for things such as livestock
grazing or wildlife preservation, but not for human habitation.
The Army recognized the largest training range cleanup liability for fiscal
year 2000. It reported a $13.1 billion liability for cleaning up closed,
transferred, and transferring ranges. The $13.1 billion was comprised of $8
billion to clean up transferred ranges, $4.9 billion for the cleanup of
closed ranges, and $231 million for the cleanup of transferring ranges. 13
The Army used an unvalidated cost model to compute the $8 billion costs of
cleaning up transferred ranges and used a different cost methodology for
estimating the $4.9 billion for closed ranges. The Air Force reported a
liability of $829 million for both fiscal years 1999 and 2000 based on a
1997 estimate of 42 closed ranges, using a historical cost basis for
estimating its liability.
According to DOD officials, DOD has standardized its methodology for
estimating and reporting the unexploded ordnance cleanup costs that will be
reported in the March 2001 report. DOD's cost model used to compute the
unexploded ordnance cleanup costs from its training ranges has not been
validated. The original cost model was initially developed by the Air Force
in 1991 and has been used by government agencies and the private sector to
estimate other environmental cleanup costs not associated with training
range cleanup. A new module was recently added to the cost model to estimate
costs for removing unexploded ordnance and its
13 The amount reported for transferred and transferring ranges included the
cleanup of nontraining range sites containing unexploded ordnance, such as
ordnance disposal sites and ordnance manufacturing facilities. Fiscal Year
2000 Financial
Statement Liabilities DOD Used a Standard Cost Methodology for March 2001
Report
Page 20 GAO- 01- 479 Training Range Cleanup
constituents from former training ranges. The new module uses cost data
developed by the U. S. Army Corps of Engineers from past experiences in
cleaning up training ranges on formerly used defense sites.
DOD officials told us that they believe that this model is the best one
available to compute the cleanup costs. However, the assumptions and cost
factors used in the model were not independently validated to ensure
accurate and reliable estimates. DOD Instruction 5000.61 requires that cost
models such as this must be validated to ensure that the results produced
can be relied upon. We did not evaluate this model, but we were informed
that DOD is in the process of developing and issuing a contract to have this
model validated. A DOD official also informed us that DOD is currently
considering requiring that the cost model be used as a standard for the
military services' valuation of their cleanup cost estimates used to report
liabilities in the financial statements.
Until DOD standardizes and validates its costing methodology used for
estimating and reporting all cleanup cost estimates for training range
cleanup and requires its use DOD- wide, it has no assurance that the
military services will compute their cleanup costs using the same
methodology. As a result, the services will in all probability continue to
produce unreliable and differing estimates for their various reporting
requirements.
DOD lacks leadership in reporting on the cleanup costs of training ranges.
DUSD( ES) was created in 1993 as the office responsible for environmental
cleanup within DOD. However, this office has focused its principal efforts
on the cleanup of other types of environmental contamination, not unexploded
ordnance. Although requirements for reporting a training range environmental
liability have existed for years, DOD has not established adequate or
consistent policies to reliably develop the cost of the cleanup of training
ranges and to oversee these costing efforts.
Similar to the problems noted previously in this report concerning the
inventory delays and lack of guidance, the Defense Science Board, in 1998,
reported that DOD had not met its management responsibility for unexploded
ordnance cleanup. It reported that there were no specific DOD- wide
unexploded ordnance cleanup goals, objectives, or management plans. The
report went on to say that unexploded ordnance cleanup decisions are made
within the individual services, where remediation requirements are forced to
compete against traditional Lack of Leadership
and Focus Hinders DOD Progress in Reporting Training Range Cleanup Costs
Defense Science Board Findings and Recommendations
Page 21 GAO- 01- 479 Training Range Cleanup
warfighting and toxic waste cleanup requirements. This competition has
resulted in unexploded ordnance cleanup efforts being relegated to
“house- keeping duties” at the activity or installation level,
according to the Board's report.
To address DOD's unmet management responsibilities for unexploded ordnance
cleanup, the Defense Science Board recommended the establishment of an
Office of Secretary of Defense focal point for oversight of unexploded
ordnance cleanup activities within DOD. This recommendation was made even
though DUSD( ES) had overall responsibility for environmental cleanup under
the Defense Environmental Restoration Program. According to the Director of
DOD's Environmental Cleanup Program, a single focal point for managing the
cleanup of unexploded ordnance has still not been formally designated. A
focal point with the appropriate authority could be a single point of
contact who could manage and oversee the development of a complete and
accurate training range inventory, the development of a consistent cost
methodology across all services, and the reporting of the training range
liability for the financial statements and other required reports.
The Department of Energy (DOE) has been successful in its identification and
reporting of thousands of environmentally contaminated sites, with cleanup
liabilities reported at $234 billion in fiscal year 2000. Initially, in the
early 1990s, DOE was unable to report the estimated cleanup costs. However,
through substantial effort and support of DOE leadership, DOE was able to
receive a clean, or unqualified, audit opinion, 14 for its fiscal year 1999
and 2000 financial statements. DOE's efforts provide a useful example to DOD
in its efforts to identify and report cost estimates on its contaminated
sites.
After 50 years of U. S. production of nuclear weapons, DOE was tasked with
managing the largest environmental cleanup program in the world. DOE has
identified approximately 10,500 release sites from which contaminants could
migrate into the environment. DOE has made substantial progress in defining
the technical scope, schedules, and costs of meeting this challenge, and in
creating a plan to undertake it. DOE
14 An unqualified, or clean, audit opinion means that the auditor believes
that information presented in the financial statements as a whole is
presented fairly, in all material respects, in accordance with generally
accepted accounting principles. Department of Energy
Process to Identify and Estimate the Cost to Clean Up Hazardous Waste Sites
Provides a Useful Example
Page 22 GAO- 01- 479 Training Range Cleanup
officials told us that in order to build a reliable database and management
program for contaminated sites, the process requires a significant
investment in time and manpower.
DOE officials stated that they began their data collection and management
program process in the early 1990s and are continuing to build and update
their database. However, they emphasized that their efforts, similar to
DOD's current efforts, started with an initial data call to collect
preliminary information to identify the sites. They said the next step
involved sending teams to each of the sites to actually visit and observe
the site, sometimes taking initial samples, to further identify and confirm
the contaminants, and to help assess the risk associated with the site
contamination. The information gathered was entered into a central database
in 1997 to be used for management and reporting purposes. In 1999, DOE
completed entering baseline data for all known cleanup sites.
In addition to the above steps, once a site was selected for cleanup, a much
more involved process was done to further test for and remove the
contaminants. However, until a site is fully cleaned up, each site is
reviewed and cost estimates are reviewed annually and any changes in
conditions are recorded in the central database.
DOE officials told us that in addition to providing the necessary leadership
and guidance to inventory and manage their sites, another key to this
success was establishing a very close working relationship between the
program office and the financial reporting office to ensure consistent and
accurate reporting of their cleanup liabilities.
As military land, including training ranges, is transferred to the public
domain, the public must have confidence that DOD has the necessary
leadership and information to address human health and environmental risks
associated with training range cleanup. Also, the Congress needs related
cost information to make decisions on funding needed. DOD's recent efforts
to develop the information needed to report training range cleanup costs for
the required March 2001 report represent an important first step in
gathering the needed data. However, accurate and complete reporting can only
be achieved if DOD compiles detailed inventory information on all of its
training ranges and uses a consistent and valid cost methodology. Because of
the complexity of the data gathering process and the many issues involved in
the cleanup of training ranges, top management leadership and focus is
essential. A senior- level official with appropriate management authority
and resources is key to effectively Conclusions
Page 23 GAO- 01- 479 Training Range Cleanup
leading these efforts to produce meaningful and accurate reports on training
range cleanup costs.
We recommend that the Secretary of Defense designate a focal point with the
appropriate authority to oversee and manage the reporting of training range
liabilities.
We also recommend that the Secretary of Defense require the designated focal
point to work with the appropriate DOD organizations to develop and
implement guidance for inventorying all types of training ranges, including
active, inactive, closed, transferred, and transferring training ranges. We
recommend that this guidance, at a minimum, include the following
requirements:
? key site characterization information for training ranges be collected for
unexploded ordnance removal;
? identification of other constituent contamination in the soil and/ or
water;
? performance time frames, including the requirements to perform the
necessary site visits to confirm the type and extent of contamination; and
? the necessary policies and procedures for the management and maintenance
of the inventory information.
We further recommend that the Secretary of Defense require the designated
focal point to work with the appropriate DOD organizations to develop and
implement a consistent and standardized methodology for estimating training
range cleanup costs to be used in reporting its training range cleanup
liabilities in DOD's agency- wide annual financial statements and other
reports as required. In addition, we recommend that the Secretary of Defense
require that the designated focal point validate the cost model in
accordance with DOD Instruction 5000.61.
Further, we recommend that the Secretary of Defense require the DOD
Comptroller to revise the DOD Financial Management Regulation to include
guidance for recognizing and reporting a liability in the financial
statements for the cleanup costs on active and inactive ranges when such
costs meet the criteria for a liability found in the federal accounting
standards. Recommendations
Page 24 GAO- 01- 479 Training Range Cleanup
In commenting on a draft of this report, DOD stated that it has made
significant progress in estimating and reporting environmental liabilities
on its financial statements; however, much work remains to be done. DOD's
response also indicated that as the department increases its knowledge
related to this area, the appropriate financial and functional policies will
be updated to incorporate more specific guidance for recognizing and
reporting environmental liabilities.
DOD concurred with our recommendations, but provided several comments in
response to our recommendation that the Secretary of Defense require the DOD
Comptroller to revise the DOD Financial Management Regulation to include
guidance for recognizing and reporting a liability in the financial
statements for the cleanup costs on active and inactive ranges when such
costs meet the criteria for a liability.
DOD stated that it revised Volume 6B, Chapter 10, of the DOD Financial
Management Regulation to clarify instances when a liability should be
recognized for an active or inactive range on an active installation.
However, this revision of the DOD Financial Management Regulation does not
address the recognition of an environmental liability at active and inactive
ranges in accordance with the criteria of SFFAS No. 5. For example, as
stated in our report, the total $300 million cleanup cost estimate on the
active range at the Massachusetts Military Reservation should be recognized
as a liability in accordance with the criteria in SFFAS No. 5.
DOD further stated that since it intends to continue to use its active and
inactive ranges in the foreseeable future, the removal of ordnance to
maintain safety and usability is considered an ongoing maintenance expense.
DOD stated that this expense is not accrued as a liability except in those
few specific instances in which an environmental response action- beyond
what is necessary to keep the range in operation- is probable and the costs
of such a response is measurable. Although this position is consistent with
SFFAS No. 5, it is not specifically indicated in the DOD Financial
Management Regulation.
Finally, DOD stated that as the Department gains additional experience in
this area, it will review appropriate chapters in the DOD Financial
Management Regulation to determine what, if any, additional specific
guidance may need to be included regarding recognizing and reporting
liabilities. While we agree that such a review is appropriate, we continue
to recommend that the DOD Financial Management Regulation be revised Agency
Comments
and Our Evaluation
Page 25 GAO- 01- 479 Training Range Cleanup
to include guidance in those instances when active and inactive ranges meet
the criteria in SFFAS No. 5.
DOD also provided several technical comments, which we have incorporated in
the report as appropriate.
We are sending copies of this report to the Honorable John Spratt, Ranking
Minority Member, House Committee on the Budget, and to other interested
congressional committees. We are also sending copies to the Honorable Donald
H. Rumsfeld, Secretary of Defense; the Honorable David R. Oliver, Acting
Under Secretary of Defense for Acquisition, Technology, and Logistics; and
the Honorable Mitchell E. Daniels, Jr., Director of the Office of Management
and Budget. Copies will be made available to others upon request.
Please contact me at (202) 512- 9095 if you or your staff have any questions
about this report. Other GAO contacts and key contributors to this report
are listed in appendix III.
Sincerely yours, Gregory D. Kutz Director Financial Management and Assurance
Appendix I: Objectives, Scope, and Methodology
Page 26 GAO- 01- 479 Training Range Cleanup
Our objectives were to review DOD's ongoing efforts to (1) gather and
collect information on its training ranges and issues affecting the
successful completion of the inventory and (2) recognize environmental
liabilities associated with the cleanup of unexploded ordnance from its
training ranges, including DOD's efforts to develop and implement a
methodology to develop cost estimates. The focus of our review was on DOD
efforts to gather and collect information on its training ranges and the
environmental costs associated with the cleanup of the training ranges. As a
result, other sites containing unexploded ordnance were not included in the
scope of our review. These sites include munitions manufacturing facilities,
munitions burial pits, and open burn and open detonation sites used to
destroy excess, obsolete, or unserviceable munitions. To accomplish these
objectives, we:
? reviewed relevant standards and guidance applicable to environmental
liabilities including Statement of Federal Financial Accounting Standards
(SFFAS) No. 5, Accounting for Liabilities of the Federal Government; SFFAS
No. 6, Accounting for Property, Plant, and Equipment; and DOD Financial
Management Regulation, Volume 6B, Chapter 10, and Volume 4, Chapters 13 and
14;
? reviewed DOD guidance to the military services for performing the training
range inventory survey;
? reviewed the military services' survey documents used to collect
information on training ranges;
? interviewed officials from the Deputy Under Secretary of Defense for
Environmental Security (DUSD( ES)); Director Defense Research and
Engineering; U. S. Army Corps of Engineers; and the Army, Navy, and Air
Force involved in planning and conducting the data collection efforts and
analyzing the data;
? interviewed an official from the Office of the Under Secretary of Defense
(Comptroller);
? interviewed officials from the U. S. Environmental Protection Agency;
? interviewed environmental officials from the states of Colorado and
Alabama;
? interviewed officials from the Department of Energy;
? interviewed the contractor selected by DOD, which assisted in planning and
analyzing the data and preparing the cost analysis for the March 2001
report; and
? visited two locations- Lowry Bombing Range, Denver, and Ft. McClellan,
Anniston, Alabama- to gain insight into the complexities involved in
estimating liabilities for training range cleanup. Appendix I: Objectives,
Scope, and
Methodology
Appendix I: Objectives, Scope, and Methodology
Page 27 GAO- 01- 479 Training Range Cleanup
We did not audit DOD's financial statements and therefore we do not express
an opinion on any of DOD's environmental liability estimates for fiscal year
1999 or 2000. We conducted our work in accordance with generally accepted
government auditing standards from May 2000 through March 2001. On March 29,
2001, DOD provided us with written comments on our recommendations, which
are discussed in the “Agency Comments and Our Evaluation”
section and are reprinted in appendix II. DOD also provided comments on
several other matters, which we have incorporated in the report as
appropriate but have not reprinted.
Appendix II: Comments From the Department of Defense
Page 28 GAO- 01- 479 Training Range Cleanup
Appendix II: Comments From the Department of Defense
Appendix II: Comments From the Department of Defense
Page 29 GAO- 01- 479 Training Range Cleanup
Appendix II: Comments From the Department of Defense
Page 30 GAO- 01- 479 Training Range Cleanup
Appendix II: Comments From the Department of Defense
Page 31 GAO- 01- 479 Training Range Cleanup
Appendix II: Comments From the Department of Defense
Page 32 GAO- 01- 479 Training Range Cleanup
Appendix II: Comments From the Department of Defense
Page 33 GAO- 01- 479 Training Range Cleanup
Appendix III: GAO Contact and Staff Acknowledgments
Page 34 GAO- 01- 479 Training Range Cleanup
Dianne Guensberg, (202) 512- 5285 Staff making key contributions to this
report were Paul Begnaud, Roger Corrado, Francine DelVecchio, and Stephen
Donahue. Appendix III: GAO Contact and Staff
Acknowledgments GAO Contact Acknowledgments
(918991)
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