Defense cleanup: a quick and dirty review. (Hazardous Waste).

Over 9,000 formerly used defense sites, or FUDS, dot the landscape of the United States and its territories. These sites include storage depots, military bases, radar stations, and missile sites. Although the sites have been retired, the hazards contained on some of them have not--structurally unsound buildings, radioactive and toxic wastes, explosives, and chemical warfare agents all remain, and will cost an estimated $16 billion to clean up, according to U.S. Army Corps of Engineers spokeswoman Candice Walters. The corps is responsible for determining whether the Department of Defense (DOD) caused the contamination on such sites and for cleaning up military-related contamination. Sites that are determined to not have been contaminated by the DOD are classified as "no DOD action indicated," or NDAI. But according to the August 2002 General Accounting Office (GAO) report Environmental Contamination: The Corps Needs to Reassess Its Determinations That Many Formerly Used Defense Sites Do Not Need Cleanup, nearly 40% of the corps' decisions on DOD responsibility are "questionable."

The report was requested by John Dingell (D-Michigan) of the House Committee on Energy and Commerce, who has long expressed concern about pollution and the military. The GAO reviewed a random sample of 603 records of corps examinations and estimated, based on the evidence in the files, that the corps was not justified in determining that 1,468 of a total of 3,840 sites do not require DOD action. In one example cited in the report, maps of a former military airfield indicated the presence of a building for storing bombs, but there was no indication that the corps searched for this building and the possible hazards posed by leftover munitions. "[T]here is no evidence that the Corps reviewed or obtained information that would allow it to identify all the potential hazards at the [questionable] sites or that it took sufficient steps to assess the presence of potential hazards," the report concludes.

"Many of the FUDS properties are [now] owned by private individuals. These are now homes, schools, parks where people are going. You don't know what level of risk exists in those areas," says Sherry McDonald, a senior GAO analyst who worked on the report.

The corps maintains it has a limited mandate in dealing with environmental problems at FUDS. "`NDAI' does not mean that there may not be some contamination there," says Walters--only that the DOD is not responsible for cleaning it up. If the contamination is not the fault of the DOD, "it is up to the states [where the facility is] or the U.S. Environmental Protection Agency to determine who's responsible for cleaning it up," she says.

One reason for the inconsistent determinations may have been the vague guidelines under which the corps operated. For example, corps guidelines originally failed to indicate what site-related documents should be examined and how detailed such examination should be. In a letter attached to the report, deputy undersecretary of defense Raymond Dubois states that many of the files examined were from the early days of the cleanup program and that the examinations are now more detailed. However, Edward Zadjura, assistant director of the GAO's Natural Resource and Environment Team, stoutly defends the study's methods, saying that the files examined were randomly chosen and that there was no statistical bias. He emphasizes that the files on the problem sites are simply inadequate to back the NDAI rating.

The GAO report recommends that the corps review its conclusions regarding the NDAI status of certain sites. Walters says the corps is doing that, working with states to reassess between four and six sites per state annually. And in line with report recommendations, the corps is revising its assessment procedures, says Walters, and has developed a new checklist that must be completed before a cleanup determination is made. Among the questions to be answered are whether prior studies of the sites were examined and whether site maps, aerial or ground photographs, or real estate records were reviewed. Such documents would describe the transfer of sites--including information on other potential polluters--and provide leads on where inspectors might look to find pollution.