Environmental Contamination
Many Uncertainties Affect the Progress of the Spring Valley Cleanup Gao ID: GAO-02-556 June 6, 2002During World War I, the U.S. Army operated a large research facility to develop and test chemical weapons and explosives in the area that became the Spring Valley neighborhood in Washington, D.C. Buried ordnance, discovered there in 1993, led to the designation by the Department of Defense (DOD) of 61 acres as a formerly used defense site. Through fiscal year 2001, DOD had spent over $50 million to identify and remove hazards at the site. The government entities involved have identified and removed a large number of hazards, but the number remaining is unknown. The health risks influencing cleanup activities at Spring Valley are the possibility of injury or death from exploding or leaking ordnance and containers of chemical warfare agents and potential long-term health problems from exposure to arsenic-contaminated soil. As of April 2002, the U.S. Army estimated that the remaining cleanup activities would cost $7.1 million and take 5 years. But these estimates are unreliable. GAO summarized this report in congressional testimony (See GAO-02-836T).
GAO-02-556, Environmental Contamination: Many Uncertainties Affect the Progress of the Spring Valley Cleanup
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United States General Accounting Office:
GAO:
Report to the Subcommittee on the District of Columbia, Committee on
Government Reform, House of Representatives:
June 2002:
Environmental Contamination:
Many Uncertainties Affect the Progress of the Spring Valley Cleanup:
GAO-02-556:
Contents:
Letter:
Results in Brief:
Background:
Government Entities Have Formed a Partnership Approach for the Spring
Valley Cleanup:
Government Entities Have Identified and Removed a Large Number of
Hazards, but the Extent of Hazards Remaining Is Unknown:
Risks from Buried Hazards and from Arsenic-Contaminated Soil Drive
Cleanup Decisions:
The Corps‘ Estimated Cost and Cleanup Schedule May Change as More
Information about the Site Is Known:
Observations:
Agency Comments:
Scope and Methodology:
Appendix I: Properties in the District of Columbia Where Hazards
Resulting from Federal Activities Have Been Found:
Appendix II: Comments from the Department of Defense:
Appendix III: Comments from the Environmental Protection Agency:
Appendix IV: Comments from the District of Columbia‘s Department of
Health:
Appendix V: GAO Contacts and Staff Acknowledgments:
Tables:
Table 1: Estimated Cost to Complete the Cleanup at Spring Valley,
Fiscal Years 1997 through 2001 and as of April 2002:
Table 2: Estimated Total Cost to Complete Cleanup Activities at Spring
Valley, as of April 2002:
Table 3: Levels of Annual Funding Specified in the Corps‘ Schedule for
Completing Cleanup Work at Spring Valley, Fiscal Year 2000, Fiscal Year
2001, and as of April 2002:
Table 4: Properties in the District of Columbia Where Hazards Resulting
from Federal Activities Have Been Found:
Table 5: Hazards Found at Leaking Underground Storage Tanks on Federal
Properties in the District of Columbia Where Remediation Was in
Process, as of January 2002:
Figures:
Figure 1: World War I-era Photograph of Two Soldiers Preparing to Test
Chemical Munitions in a Trench Located in Spring Valley:
Figure 2: Location of the Spring Valley FUDS in the District of
Columbia:
Figure 3: Total Estimated Cost to Clean up Spring Valley, Fiscal Years
1997 through 2001 and as of April 2002:
[End of section]
United States General Accounting Office:
Washington, DC 20548:
June 6, 2002:
The Honorable Constance A. Morella:
Chairwoman:
The Honorable Eleanor Holmes Norton:
Ranking Minority Member:
Subcommittee on the District of Columbia:
Committee on Government Reform:
House of Representatives:
During World War I, at a portion of American University and in other
areas that became the Spring Valley neighborhood in Washington, D.C.,
the U.S. Army operated a large research facility to develop and test
chemical weapons and explosives. After World War I, the majority of the
site was returned to private ownership and was developed for
residential and other uses. The site now includes, in addition to
American University, about 1,200 private residences, Sibley Hospital,
27 embassy properties, and several commercial properties.
In 1993, buried ordnance was discovered in Spring Valley, leading to its
designation by the Department of Defense (Defense) as a formerly used
defense site (FUDS) currently comprising 661 acres. FUDS are properties
that were formerly owned, leased, possessed, or operated by Defense or
its components, and are now owned by private parties or other
governmental entities. These properties, located throughout the United
States and its territories, may contain hazardous, toxic, and
radioactive wastes in the soil and water or in containers such as
underground storage tanks. Other hazards, including unexploded ordnance
and unsafe buildings, may also be present on the properties. Such
hazards can contribute to deaths and serious illness or pose a threat
to the environment.
Through fiscal year 2001, Defense had spent over $50 million to identify
and remove hazards at the Spring Valley site. However, concerns persist
over the extent of hazards remaining, and the U.S. Army Corps of
Engineers (the Corps) is continuing to survey targeted properties for
buried ordnance and explosives, and sample all properties in Spring
Valley for arsenic-contaminated soil.
In response to your letter, and as agreed with your offices, this report
provides information on the (1) specific roles and responsibilities of
the government entities involved at the Spring Valley site, as
authorized by statute, regulation, or guidance, and as actually carried
out, (2) progress the government entities have made toward identifying
and removing hazards at the site, (3) health risks government entities
have determined are associated with the hazards at the site and the
impact of these risks on cleanup decisions, and (4) estimated cost and
schedule of the remaining cleanup. In addition, you asked us to provide
a list of sites in the District of Columbia where hazards resulting
from federal activities have been found. We have included this list in
appendix I. To address these objectives, we reviewed documents on
activities conducted at the site during World War I, the progress of
cleanup activities at the site, health risks, and estimated costs, and
interviewed federal and District of Columbia government officials and
other stakeholders. We also reviewed the statutes authorizing various
cleanup activities. In addition, we visited the site to observe the
activities first-hand and attended meetings of resident and other
stakeholder groups formed to advise the cleanup process. We obtained
and reviewed records from Defense, the Environmental Protection Agency,
and the District of Columbia‘s Department of Health to develop a list
of sites in the District of Columbia where hazards resulting from
federal activities have been found.
Results in Brief:
The principal government entities involved at the Spring Valley site are
carrying out their roles and responsibilities in cleaning up the site
primarily under the Defense Environmental Restoration Program
(environmental restoration program), which was established by the
Superfund Amendments and Reauthorization Act of 1986. Under the
environmental restoration program, Defense is authorized to identify,
investigate, and clean up environmental contamination at formerly used
defense sites. The U.S. Army, through the Corps, is responsible for
these activities at Spring Valley and is carrying out the physical
cleanup. Defense is required under the environmental restoration
program to consult with the Environmental Protection Agency (EPA),
which has its own authority to act at the site under the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980. Under
the program, Defense‘s activities must also be consistent with a
statutory provision that addresses, among other things, participation
by the affected states”in this case, the District of Columbia. Under
the Corps‘ program guidance for FUDS, the District of Columbia has a
role in defining the cleanup levels at the Spring Valley site.
According to the District of Columbia‘s Department of Health, the
department assesses the human health risks associated with any exposure
to remaining hazards at Spring Valley. In carrying out their roles,
these government entities have, over time, formed an active partnership
to make cleanup decisions. For example, the Corps leads the effort to
identify hazards, but in many cases it uses the recommendations
of the District of Columbia and EPA to look for hazards buried at
certain sites. The entities are currently reaching agreement as to a
cleanup level”that is, how much contamination can be left in the soil
without endangering human health and the environment. The partners
expect to finalize this decision by early June 2002. While the entities
have not agreed on all cleanup decisions, officials acknowledge that,
by having formed a partnership, a means exists to foster communication
and collaboration, and officials of all three entities stated that the
partnership is operating effectively. Continued progress at the site
will depend, in part, on the effectiveness of this partnership over the
duration of the cleanup period.
The government entities involved at Spring Valley have identified and
removed a large number of hazards, but the extent to which hazards
remain is unknown. The hazards identified include buried ordnance;
chemical warfare agents in glass containers; and arsenic-contaminated
soil. Beginning in 1986, the U.S. Army searched records and reviewed
photographs to identify locations where ordnance and chemicals might
have been buried and concluded that there was no evidence of large-scale
burials at the site. However, following the discovery of buried
ordnance by a utility contractor in 1993, the U.S. Army identified and
removed 141 pieces of ordnance, 43 of which were suspected chemical
munitions (but most were destroyed before being tested). After the
ensuing investigation of the site, the Corps concluded in 1996 that it
was unlikely to discover additional hazards at the site. Since then,
however, the Corps has found and removed 667 pieces of ordnance, 25 of
which were chemical munitions, and 101 bottles of chemicals. Moreover,
the Corps has discovered arsenic in the soil throughout the site that
exceeds naturally occurring levels. As of April 2002, the Corps had
identified and removed 5,623 cubic yards of arsenic-contaminated soil
from three properties. The Corps has extensive work remaining to search
for any additional hazards at the site, and, if found, remove them.
The primary health risks influencing cleanup activities currently at
Spring Valley are the possibility of injury or death from exploding or
leaking ordnance and containers of chemical warfare agents and potential
long-term health problems from exposure to arsenic-contaminated soil,
according to the government entities involved. Because of the immediacy
of the risks, the partnership agrees that ordnance and containers must
be removed as soon as possible after they are found. In contrast, the
partners have disagreed over the immediacy of the health risk posed by
arsenic-contaminated soil. The partners recognize that exposure to
arsenic has been generally linked to cancers and other health
conditions. A recent study by the District of Columbia concluded that
Spring Valley residents showed no increased incidence of certain
cancers. A study by the Agency for Toxic Substances and Disease
Registry (an agency of the Department of Health and Human Services)
found no evidence of actual exposure to arsenic in the individuals
tested. However, these studies, according to some residents, were not
sufficiently broad. Additional studies to assess whether residents have
actually been exposed to arsenic are ongoing. Over the past year, the
partners have been in the process of reaching agreement on a single
level of arsenic that may remain in the soil throughout the site and
that is protective of human health and the environment.
As of April 2002, the U.S. Army estimated that the remaining cleanup
activities at Spring Valley would cost $71.7 million and take 5 years to
complete, but the reliability of these estimates is uncertain. Many
factors”such as the discovery of additional hazards or changes in annual
funding levels”make it inherently challenging to estimate the costs and
schedule for cleaning up the site. Since fiscal year 1997, the Corps has
continually needed to increase the scope of the remaining cleanup as
more information about the hazards at the site became known. As a
result, the Corps increased the total estimated cost for the Spring
Valley cleanup six-fold over the same period, from about $21 million in
fiscal year 1997 to about $125 million as of April 2002. On the other
hand, the Corps has reduced its estimate of the time it will take to
complete the cleanup since fiscal year 2000 (the first year the Corps
made public this estimate) by increasing considerably the amount of
annual funding it plans to devote to the site. It is unclear at this
time how long the Corps will be able to accommodate the increasing
funding needs at Spring Valley because funding the cleanup activities
at the site is currently adversely affecting the pace and progress of
cleanups at the approximately 2,800 other formerly used defense sites
presently known to require remediation. Consequently, any significant
increases in the cost of completing the Spring Valley cleanup, or
decreases in the amount of available annual funding, would likely
require the Corps to extend the completion date further into the
future.
We provided a draft of this report to the Department of Defense,
Environmental Protection Agency, and the District of Columbia‘s
Department of Health for review and comment. These agencies generally
agreed with the information presented in the draft and provided a number
of technical comments, which we incorporated in the report as
appropriate. Defense stated that, while they agreed that there are some
uncertainties associated with the Spring Valley cleanup, it is
important to note that such unknowns are not unique to Spring Valley.
Defense also stated that the partnership formed has been a model for
regulatory relationships at other site cleanups. EPA stated that our
report develops an accurate and unbiased appraisal of the problems and
uncertainties present at the site. The District of Columbia‘s
Department of Health stated that it is committed to continuing to work
with the other governmental partners in order to protect human health.
Background:
In 1917, the Bureau of Mines initiated the Chemical Warfare Research
Program at American University, and in 1918, the research effort was
transferred to the Chemical Warfare Service in the War Department. The
Chemical Warfare Service used a portion of American University and other
areas that became part of the Spring Valley neighborhood to operate a
large research facility to develop and test chemical agents, equipment,
and munitions. The U.S. Army used the remaining part of the area as a
camp to house and train engineer troops. These two areas were known as
the American University Experiment Station and Camp Leach (which
includes Fort Gaines), respectively. Historical and archival
information indicates that onsite development and testing of ordnance
and chemical warfare materials occurred at the American University
Experiment Station between 1917 and 1919, as shown in figure 1. The
majority of the property was returned to private ownership by October
1920.
Figure 1: World War I-era Photograph of Two Soldiers Preparing to Test
Chemical Munitions in a Trench Located in Spring Valley.
[Refer to PDF for image]
Source: The Corps.
[End of figure]
During the 1950s and 1980s, American University and others raised
concerns about buried munitions in the Spring Valley neighborhood.
Following an accidental discovery of buried ordnance in Spring Valley in
1993, the Corps designated the site as a FUDS. The Spring Valley FUDS
includes, in addition to American University, about 1,200 private
residences, Sibley Hospital, 27 embassy properties, and several
commercial properties. According to the U.S. Army, Spring Valley is the
only known FUDS where chemical agents were tested in what became a well-
established residential neighborhood at the heart of a large
metropolitan area. Figure 2 shows the location of the Spring Valley
neighborhood in Washington, D.C.
Figure 2: Location of the Spring Valley FUDS in the District of
Columbia:
[Refer to PDF for image]
This figure contains a map of the District of Columbia and surrounding
areas, as well as a detailed map of the Spring Valley FUDS area.
Source: The Corps.
[End of figure]
To fund the environmental restoration program, the Superfund Amendments
and Reauthorization Act of 1986 (SARA) established the Defense
Environmental Restoration Account. Total spending for the FUDS cleanup
program since fiscal year 1984 is $2.6 billion.[Footnote 1] During the
5 most recent fiscal years (1997-2001), annual program funding for FUDS
cleanup has decreased from about $255.9 million to about $231 million,
with program funding estimated to decrease further to about $212.1
million by fiscal year 2003. By the end of fiscal year 2001, the Corps
had identified 4,649 potential cleanup projects on 2,825 properties
requiring environmental response actions. Through fiscal year 2001 (the
latest figure available), the Corps had spent about $53.4 million on
cleanup activities at Spring Valley. In addition, as of April 2002, EPA
had spent about $800,000 on activities related to the site.
Government Entities Have Formed a Partnership Approach for the Spring
Valley Cleanup:
The principal government entities involved at the Spring Valley site are
carrying out their roles and responsibilities in cleaning up the site
under the Defense Environmental Restoration Program (environmental
restoration program). The environmental restoration program was
established by SARA, which amended the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA). Under the
environmental restoration program, Defense is authorized to identify,
investigate, and clean up environmental contamination at FUDS. Defense
is required to consult with EPA in carrying out the environmental
restoration program; EPA, in turn, has established written guidance
under CERCLA for its activities at FUDS. Activities under the
environmental restoration program also must be consistent with another
statutory provision[Footnote 2] that addresses, among other things,
participation by the affected states”in this case, the District of
Columbia. Under the Corps‘ program guidance, the District of Columbia
has a role in defining the cleanup levels at the Spring Valley site.
According to a District of Columbia Department of Health official, the
department assesses the human health risks associated with any exposure
to remaining hazards at Spring Valley.[Footnote 3] In carrying out
their roles, these government entities have, over time, formed an
active partnership to make cleanup decisions. For example, the Corps
leads the effort to identify hazards, but in many cases it follows the
recommendations of the District of Columbia and EPA to look for hazards
buried at certain sites. The entities are currently finalizing
decisions as to a cleanup level for arsenic that will determine how
much contamination can be left in the soil throughout the site without
endangering human health and the environment. While the entities have
not agreed on all cleanup decisions, officials of all three entities
state that the partnership has been working effectively in the recent
past. Continued progress at the site will depend, in part, on the
effectiveness of this partnership over the duration of the cleanup
period.
Government Entities Are Authorized to Take Various Actions for Cleanup
at the Spring Valley Site:
Because Spring Valley was designated as a FUDS, Defense is authorized to
carry out cleanup activity at the site under the environmental
restoration program established by SARA. The environmental restoration
program also provides for participation by other entities.
Specifically, in carrying out the environmental restoration program,
Defense is required to consult with EPA, which has its own authority
under CERCLA to act at the site. Also, Defense must carry out the
program consistent with section 120 of CERCLA. Section 120 addresses
the cleanup of federal facilities and, among other things, provides for
participation in cleanup decisions by the state (in this case, the
District of Columbia) in which a federal facility is located. The
following sections provide more detail on the entities‘ authorities.
* Under the environmental restoration program, Defense is authorized to
identify, investigate, and clean up hazards at FUDS. In implementing the
environmental restoration program, Defense has established guidance for
the FUDS program. The FUDS program is intended to reduce the risk to
human health and safety, and to the environment, resulting from past
Defense activities at FUDS properties. Defense has delegated its
authority for administering the FUDS program to the U.S. Army; in turn,
the U.S. Army has delegated execution of the program to the Corps. The
Corps‘ responsibilities include determining the eligibility of
properties for inclusion in the FUDS program, identifying the
requirements for funding the FUDS program, conducting environmental
restoration activities at eligible properties, and reporting on the
cleanup progress. The Corps is responsible for the cleanup of
environmental contamination related to past Defense activities at
eligible sites.
* Defense‘s policies for administering FUDS are outlined in its
environmental restoration program management guidance, which cites
CERCLA as the statutory framework. Additionally, under the Corps‘
guidance, efforts should be made to accommodate standards,
requirements, or criteria requested by EPA, states, and local
authorities where they are consistent with CERCLA. Both of these
guidance manuals recognize the importance of involving EPA, the state
government, and the public, among others. Defense consults with EPA and
the states on cleanup decisions at specified points in the
environmental restoration process, such as developing a site-wide
sampling plan. Also, at Spring Valley, the Corps was urged to form an
advisory board to involve the community and others. According to the
Corps, these efforts have the overall goal of ensuring that decisions
regarding environmental restoration activities reflect a broad spectrum
of advice, expertise, and stakeholder concerns in making cleanup
decisions.
* As with any hazardous waste site, EPA has its own authority under
CERCLA to act, including investigating the site and carrying out a
removal action.[Footnote 4] EPA has established written policy for its
activities at FUDS.[Footnote 5] The policy states that EPA intends to
minimize duplication of effort, but may become more involved at a site
if conditions warrant EPA action. EPA has not listed Spring Valley on
its national priorities list of hazardous waste sites. According to EPA
officials, if a site is not listed and there is no ’imminent and
substantial endangerment“ or the releases are being adequately
addressed by others, EPA may limit its role. According to EPA
officials, EPA has the flexibility to increase its role should it later
determine that greater participation is warranted. At Spring Valley, EPA
has chosen not to investigate and remove hazards because Defense is
carrying out the cleanup, and because the Corps has expertise in
munitions and has responsibility for ordnance-related cleanups. EPA
receives no targeted resources for FUDS. At Spring Valley, EPA primarily
consults with and provides technical assistance to Defense and the
District of Columbia. For example, EPA has consulted with the Corps to
interpret aerial photography and test soil to locate potential buried
hazards and contaminated soil. The Corps notes that EPA has been fully
engaged in the decision making process at the site.
* According to EPA, CERCLA provides that federal cleanup standards be
used at sites covered by the statute, unless a promulgated state-wide
standard exists which is more stringent than the federal standard.
According to District of Columbia Department of Health officials, they
are establishing cleanup standards for hazardous wastes under the
Brownfield Revitalization Amendment Act of 2000, which contains some
provisions comparable to CERCLA. As of the end of April 2002, the
standards were in draft form. Although these standards were not yet
final, a District of Columbia Department of Health official told us
that the lack of formal standards would have no effect on the cleanup
decisions made at Spring Valley.
Government Entities Have Formed an Active Partnership:
Over time, the Corps, EPA, and the District of Columbia formed a
partnership in order to reach accord on important cleanup decisions.
Early on in the cleanup, EPA and the District of Columbia collaborated
with the Corps, but they did not always agree with the Corps‘
decisions. Further, there were concerns about the extent of
collaboration on decision-making. For example, according to a senior
District of Columbia Department of Health official, in the mid-1990s
the District of Columbia environmental officials were not consulted on
important cleanup decisions.[Footnote 6]
In the past several years, the partnering process for reaching cleanup
decisions has become increasingly more formalized and active. EPA has
provided assistance in identifying possible buried hazards by using
photographic interpretation of aerial maps and providing technical
expertise with regard to the presence of hazards in soil, water, and
air. The Corps now routinely coordinates with EPA and the District of
Columbia on technical and health-related issues. In terms of cleanup
levels, EPA has proposed how much contamination may remain in the soil
without endangering human health and the environment. Under the Corps‘
guidance, the District of Columbia has a role in defining the cleanup
levels at the Spring Valley site. According to the District of
Columbia‘s Department of Health, the department assesses the human
health risks associated with any exposure to remaining hazards at
Spring Valley. In addition, the District of Columbia, together with the
Agency for Toxic Substances and Disease Registry (ATSDR), is studying
whether residents have actually been exposed to arsenic in the soil.
[Footnote 7] The government entities currently collaborate on the
process of selecting a cleanup level, addressing health risks posed by
hazards, and communicating with the public.
Additionally, in the past year, advisory entities have been created to
further facilitate the partnering process and ensure buy-in from all
partners and community members. Important decisions, such as the
cleanup levels at Spring Valley and the plan to prioritize cleanup, are
now routinely discussed among these entities. The Restoration Advisory
Board (the Board) and the Scientific Advisory Panel (the Panel) are two
active advisory entities in which partners exchange information and
collaborate as to cleanup decisions and potential health risks. The
Board, created in May 2001, consists of residents of Spring Valley as
well as representatives from the Corps, EPA, the District of Columbia,
and American University, among others. The District of Columbia created
the Panel in March 2001 to advise the District of Columbia and other
partners on health risks associated with the hazards at Spring Valley.
The Panel is currently evaluating data and is expected to make a
recommendation as to the proposed cleanup level of arsenic in soil at
the Spring Valley site. This recommendation was announced at the
Panel‘s May 29, 2002, meeting. The partners expect to finalize this
decision by early June 2002.
Officials acknowledge that, by having formed a partnership, a means
exists to foster communication and collaboration, and stated that the
partnership has been effective in the recent past. Continued progress
at the site”which includes, among other things, finalizing a cleanup
level for arsenic in soil”will depend on the effectiveness of this
partnership over the duration of the cleanup period.
Government Entities Have Identified and Removed a Large Number of
Hazards, but the Extent of Hazards Remaining Is Unknown:
The Corps, in partnership with EPA and the District of Columbia, has
identified and removed a large number of hazards from areas within the
Spring Valley site. However, the extent to which hazards remain
throughout the site is unknown. Since 1986, the U.S. Army has twice
concluded that no large burials of ordnance remained on the site, but
subsequent investigations discovered additional ordnance in large burial
pits and widespread arsenic-contaminated soil. The Corps is continuing
to search for hazards.
U.S. Army Twice Concluded That No Large-Scale Hazards Remained at the
Site:
The U.S. Army concluded in 1986 and again in 1996 that it had not found
any evidence of large-scale burials of hazards remaining at Spring
Valley.[Footnote 8] In March 1986, American University was preparing to
begin the largest construction project in its history, but it was
concerned that chemical munitions might have been buried on campus.
After the results of the university‘s search of its own and available
government records proved inconclusive, the university contacted the
U.S. Army for assistance. The U.S. Army‘s Toxic and Hazardous Materials
Agency reviewed the work done by the university and interviewed the
university officials who had done the work, reviewed documentation from
additional sources, such as military and university libraries and
historical centers and the National Archives, and contracted with EPA‘s
Environmental Photographic Interpretation Center to review available
aerial photographs of the site taken during the World War I era.
However, the photographs were not received or reviewed by EPA
headquarters or Region III prior to 1993, according to EPA officials.
Based on the results of its review, in October 1986, the U.S. Army
concluded that if any materials were buried in the vicinity of the
university, the amounts were probably limited to small quantities and
no further action was needed. In August 1986, the U.S. Army agreed to a
plan to ensure safety in the event that ordnance was actually
discovered during the construction project. This plan included an onsite
support presence before, during, and after any excavation activities.
According to the university, no buried ordnance was found before or
during the construction project.
In January 1993, a utility contractor accidentally uncovered buried
ordnance at another location in the Spring Valley site. The U.S. Army‘s
Chemical and Biological Defense Command immediately responded and, by
February 1993, had removed 141 pieces of ordnance, 43 of which were
suspected chemical munitions (but most were destroyed before being
tested). Immediately following this removal, the Corps began to
investigate the site. To focus its investigation, the Corps revisited
the documents reviewed by the Toxic and Hazardous Materials Agency in
1986, including the results of the photographic analysis performed by
EPA‘s Environmental Photographic Interpretation Center, and reviewed
additional information. The Corps identified 53 locations with the
greatest potential for hazards. The Corps decided that if it found
contamination in any of these locations, it would expand its
investigation around each contaminated location.
During the investigation, the Corps used two techniques to look for
potential hazards: (1) a subsurface (geophysical) soil survey with metal
detectors to identify buried ordnance and (2) an analysis of soil
samples to identify chemical contamination. The Corps surveyed soil for
ordnance at about 490 properties, including 37 of the 53 potentially
hazardous locations that the Corps considered to be potential ordnance
burial sites. These surveys identified over 2,000 buried metallic
objects that could be pieces of ordnance, which, upon further review by
the Corps, were narrowed down to about 840 warranting further
excavation. These excavations led the Corps to identify and remove one
piece of ordnance containing suspected chemical agent, ten expended
pieces of ordnance, an empty bomb nose cone, and several fragments of
ordnance scrap. Concurrently with the Corps‘ investigation, a builder
found another piece of ordnance during construction activities, and two
pieces of ordnance were anonymously left for the Corps to find. As for
soil sampling, the Corps, in conjunction with EPA, sampled for a
variety of chemicals at 15 of the 53 potentially hazardous locations
where historical documents indicated field-testing, development, or
accidental releases of chemical agents were known or believed to have
occurred.[Footnote 9] No chemical warfare agents, explosives, or
Defense-related chemicals whose only source could be chemical warfare
agents or explosives were found in any soil samples collected at these
locations, according to the Corps. Some metals were detected at levels
exceeding both EPA‘s screening levels (levels that EPA estimates are
associated with a one in a million increased risk of causing cancer)
and naturally occurring levels; but risk assessments, which consider
many factors such as the levels of the chemicals, the likelihood of
exposure to the chemicals, and the toxicity of the chemicals, indicated
that no remedial action was needed, according to the Corps.
Following this investigation, in June 1995, the U.S. Army determined
that no further action was required at the Spring Valley site, except
for a portion of the site referred to as the Spaulding/Captain Rankin
Area, which was then still under investigation. This area contained
concrete shell pits or bunkers that were used during World War I to
test explosives and chemical warfare agents. Subsequent sampling
detected arsenic in the layer of soil on the bunkers‘ concrete floors
and debris at levels exceeding both EPA‘s screening and naturally
occurring levels, but risk assessments indicated that no remedial
action was necessary, according to the Corps. Therefore, in June 1996,
the Corps recommended that no further action be taken at the
Spaulding/Captain Rankin Area. With both investigations, the U.S. Army
maintained that it would remain responsible for taking any actions
necessary if DOD-related hazards were discovered at the site.
Follow-on Investigations Found Additional Large-Scale Hazards"
In 1997, the District of Columbia completed a report of the actions
taken at the Spring Valley site that raised a number of concerns about
how the Corps had completed its investigation. In response, the Corps
reviewed its work at the site and concluded that it had incorrectly
located 1 of the 53 potentially hazardous locations it had previously
investigated, which should have been situated on a property owned by
the Republic of Korea (South Korea) on Glenbrook Road.[Footnote 10]
According to the Corps, in February 1998, it surveyed the soil on the
South Korean property and identified two potential burial pits.
Excavation initiated in March 1999 and completed in March 2000 yielded
288 pieces of ordnance, 14 of which were chemical munitions; 175 glass
bottles, 77 of which contained various chemicals, including mustard and
lewisite; and 39 cylinders and 9 metal drums. Soil sampling conducted
by EPA in mid-1999 resulted in the discovery of elevated levels of
arsenic at the South Korean property and two adjacent properties on
Glenbrook Road. Subsequent analyses concluded that arsenic was present
in the soil at these properties at levels exceeding both EPA‘s
screening level for residential areas and the naturally occurring
levels for Spring Valley. The Corps decided that contaminated soil
needed to be removed from this site. By May 2001, the Corps had removed
arsenic-contaminated soil from the South Korean property and the
adjacent property. It has not yet conducted soil removal at the third
property, which is the American University President‘s residence. As of
April 2002, the Corps had completed most restoration (i.e.,
landscaping) activities at the South Korean property, but is still
working at excavating a pit that extends from the South Korean property
into the adjacent property on Glenbrook Road. In total, the Corps had
removed about 4,560 cubic yards of contaminated soil from these
properties.
After the discovery of hazards on the Glenbrook Road properties, and
consistent with the rationale it employed during the investigation, in
January 2000, at the request of the District of Columbia, the Corps
expanded its arsenic investigation to include about 60 nearby residences
and the southern portion of the American University campus. Sampling at
these locations found elevated levels of arsenic at the American
University Child Development Center and other locations on the American
University campus, and on 11 residential properties. As of April 2002,
the Corps had removed about 1,063 cubic yards of contaminated soil from
American University. The Corps is finalizing plans to address arsenic
contamination in soil at other locations on American University.
Agencies Have Initiated Extensive Additional Investigations for
Hazards:
At a public meeting in February 2001, community members urged testing
the entire Spring Valley neighborhood for arsenic, a request first made
by the District of Columbia in its 1997 report. The Corps, in
consultation with EPA and the District of Columbia, agreed to sample
soil for arsenic on all 1,483 properties within the Spring Valley site,
with more intensive sampling at selected properties located where
historical documents indicated that chemical weapons testing may have
occurred. This expanded sampling effort, begun in May 2001, was
completed at 1,316 properties, as of April 2002. About 160 of these
sampled properties will require some degree of cleanup. Currently,
seven of these properties are identified for priority removals of
arsenic-contaminated soil because they present relatively higher risks
of exposure, according to the Corps. The priority removals are
scheduled to begin by late June 2002. In addition, the Corps has
sampled for additional chemicals in selected locations depending on
information it has about what type of research activities might have
occurred at the locations in the past. The results of the sampling are
currently under review, but preliminary results have not identified any
additional chemicals of concern.
In May 2001, at the urging of the District of Columbia and EPA, the
Corps began to investigate an additional burial pit on the property
line between the South Korean property and the adjoining residence on
Glenbrook Road. The Corps discovered this pit by conducting a number of
exploratory excavations at the adjoining property to determine whether
any additional buried ordnance might be present. The Corps is continuing
to investigate the burial pit, and as of January 2002, had found 379
pieces of ordnance, 11 of which contained the chemical warfare agents
mustard and lewisite; fragments of another 8 pieces of ordnance; 60
glass bottles and 3 cylinders, 24 of which contained mustard, lewisite,
and acids; and 5 metal drums that showed signs of leakage.[Footnote 11]
Concurrently with the efforts to expand the arsenic investigation, the
Corps is planning to expand its efforts to survey properties for buried
ordnance. EPA‘s Environmental Photographic Interpretation Center has
reviewed archives and several additional aerial photographs of the area.
This review and subsequent surveying activities performed by the Corps
identified two properties on Sedgwick Street where buried metallic
objects that could possibly be pieces of ordnance need to be excavated.
The Corps plans to begin excavating these properties by September 2002.
In addition, the Corps, in conjunction with EPA and the District of
Columbia, is developing a list of properties to be geophysically
surveyed for potential buried ordnance. Along with the results of the
review performed by EPA‘s Environmental Photographic Interpretation
Center, other site-specific information, such as the results of
previous arsenic sampling and the extent of prior landscaping work,
will be factored into determining priorities for surveying these
additional sites. As of April 2002, the Corps had estimated that a
total of 200 properties would be surveyed for ordnance. The government
entities recognize that the extent that hazards remain may never be
known with certainty due to the technical limitations associated with
sampling and geophysically surveying soil.
Risks from Buried Hazards and from Arsenic-Contaminated Soil Drive
Cleanup Decisions:
At Spring Valley, as at other FUDS, cleanup decisions depend on the
immediacy of the safety and human health risks presented. If disturbed,
unexploded or leaking ordnance or containers filled with chemical
warfare agent may present an immediate risk, and the partners have
agreed to remove these hazards as soon as possible after their
discovery. In contrast, exposure to arsenic-contaminated soil poses a
long-term health risk and the partners have, in the past, disagreed
about the level and extent of the risk at Spring Valley. Over the past
year, the partners have been in the process of reaching agreement on
the level of arsenic that may remain in the soil and that is protective
of human health and the environment. The partners have agreed on a
proposed cleanup level and are awaiting input from the Panel before
finalizing the decision.
Ordnance Removal Generally Takes Priority Because of the Immediacy of
Risk:
Throughout the cleanup of the Spring Valley site, identification and
removal of buried ordnance have been and continue to be the government
entities‘ top priorities in terms of human health concerns and cleanup
decisions. Because of the immediacy of the potential risk posed by human
contact with ordnance, for example by the detonation of unexploded
ordnance or skin exposure to a leaking container of a chemical warfare
agent such as lewisite, the government entities agree that ordnance and
containers must be removed as soon as possible after they are found to
avoid the risk of immediate injury or death. Accordingly, since early
on in the cleanup effort at Spring Valley, removal of buried ordnance
has taken priority over other tasks. For example, shortly after the
accidental discovery of buried ordnance in January 1993, the U.S. Army
initiated an emergency response action to identify and remove ordnance
buried at the site. Four weeks after that initial discovery, the U.S.
Army had removed 141 pieces of ordnance, and the Corps, in conjunction
with EPA and the District of Columbia, began its comprehensive
investigation of the entire site, including soil sampling.
Arsenic-contaminated Soil Cleanup Depends on Ultimate Risk
Determination:
The partners also attempt to set priorities for cleaning up properties
containing elevated levels of chemicals or metals in soil on the basis
of the risk the hazards pose. As noted previously, after the Corps
completed the emergency removal of ordnance in 1993, it began to sample
soil for contamination. The Corps collected 260 soil samples from 15
locations, and with EPA, tested and analyzed the samples. No chemical
warfare agents, explosives, or chemicals whose only source could be
chemical warfare agents or explosives were found in any of the samples;
however, several metals were identified at levels that exceeded EPA‘s
standards. The Corps used EPA‘s criteria to assess the health risks
associated with these hazards to determine whether further sampling or
soil removal was necessary. This assessment found no elevated health
risk requiring remedial action. Arsenic was not identified as a
contaminant of potential concern for the risk assessment, since,
according to the Corps, the sampling results of the level of arsenic in
the soil were not significantly different from naturally occurring
levels. In commenting on a draft of this report, EPA noted that it was
involved in the oversight of the cleanup and did not object to the
decision made at the time.
Since early 1999, with the additional discovery of buried ordnance and
elevated levels of arsenic-contaminated soil at the South Korean
property, the levels of arsenic in soil have become the primary focus
of soil cleanup efforts by the partners. Although many chemical agents
were tested at Spring Valley during World War I, of those contaminants
now present at elevated levels, arsenic is deemed to pose the greatest
risk to human health and therefore is the contaminant of most concern
to the partners. The partners recognize that arsenic exposure at
certain doses in drinking water has been generally linked to cancers
and other adverse health conditions.[Footnote 12] Based on scientific
studies, the District of Columbia has identified lung cancer, bladder
cancer, and skin cancer as effects associated with the long-term
ingestion of arsenic. However, the extent to which arsenic is present
and residents are exposed through ingestion, inhalation, or external
contact at Spring Valley is unknown. The District of Columbia has
requested technical assistance from ATSDR, which has conducted an
exposure investigation of residents who have high arsenic levels on
their property. Through soil sampling, the partners have attempted to
detect levels of arsenic in the soil to ascertain health risks and to
set priorities for cleanup. The partners agree that soil containing
elevated levels of arsenic poses a greater health risk than does soil
with lesser levels of arsenic. As such, properties with greater levels
of arsenic in soil generally have cleanup priority over properties with
lesser levels of arsenic.
After the Corps tested and confirmed elevated arsenic soil levels at
American University‘s Child Development Center, at the request of the
District of Columbia, ATSDR conducted an exposure study to determine
the extent of arsenic exposure in children and employees at the site.
After testing hair samples, ATSDR concluded that the children and
employees had had no significant exposure to arsenic. Spring Valley
residents then requested comprehensive soil sampling, extending to
every residence in the Spring Valley site. The Corps, in consultation
with EPA and the District of Columbia, responded with a plan to sample
for arsenic on every property in Spring Valley, with more intensive
sampling in selected locations. Efforts are still underway to determine
the extent of arsenic present at Spring Valley and the extent to which
residents are likely to have been exposed to that risk. At the request
of the District of Columbia, ATSDR is conducting another exposure study
(biomonitoring), in which it is studying the level of arsenic present
in biological samples from residents on Spring Valley properties with
the highest levels of arsenic in the soil. The individual results from
the biological samples collected during the exposure investigation were
mailed to the residents May 16, 2002, and were reviewed and discussed
by the Panel on May 29, 2002.
The District of Columbia has also conducted descriptive epidemiological
studies in an attempt to assess the arsenic-related health effects in
Spring Valley compared with two control groups. The studies examined the
incidence of bladder, skin, lung, liver, and kidney cases. However, the
number of cases of liver and kidney cancers at Spring Valley was too
small to conduct a meaningful statistical analysis. Of bladder, skin,
and lung cancers, however, the District of Columbia observed no
excesses of cancer incidence and mortality in Spring Valley as compared
to U.S. national rates, and one of these control groups.
Residents have raised concerns about the extent of the population
studied and completeness of data used for these exposure and
epidemiological studies. For example, some residents have voiced
concerns that the full suite of hazards present at Spring Valley, even
at trace levels, has not been factored into exposure and
epidemiological studies and that arsenic is the sole hazard considered
for exposure studies. The District of Columbia and the Corps have
indicated that mustard agent was found in containers in the pit
discovered at Glenbrook Road in May 2001. The District of Columbia‘s
Department of Health does not plan to study exposure to mustard agent,
however, because it did not identify a pathway of exposure to mustard
agent that could produce a dose resulting in adverse human health
effects. The District of Columbia‘s Department of Health has told
Spring Valley residents that, if necessary, it will expand the
investigation to hazards other than arsenic, if the hazard is found at
levels of concern in Spring Valley.
As of April 2002, because of the safety risks associated with the
ordnance burial pit on Glenbrook Road, the Corps had temporarily
redirected other investigation and cleanup efforts, such as soil
surveying and removal, to the removal of known buried ordnance. To
identify other locations of potential remaining buried hazards, the
Corps, after consulting with the partners, has proposed a
classification scheme that attempts to prioritize the properties most
likely at risk for the presence of hazards. The plan takes into account
the results of preliminary arsenic sampling, aerial photography
interpretation, and other characteristics. In conjunction with EPA and
the District of Columbia, the Corps is developing a priority list of
properties for additional geophysical surveys. Once comprehensive
sampling is complete and soil removal commences, where necessary,
arsenic in soil will be reduced to a cleanup level that is now being
finalized by the partnership.
The partners gather feedback on health risks from residents in several
ways and consider this information when making cleanup decisions. In the
past year, a communication process has been put in place to address
residents‘ concerns about the health risks associated with Spring
Valley. The District of Columbia publishes a periodic newsletter that
has included information from ATSDR and updates residents on the latest
information regarding the District of Columbia‘s efforts to address the
issues in Spring Valley, including the Scientific Advisory Panel
meeting agenda. A hotline gives residents an opportunity to voice their
concerns or share anecdotal information about exposure to hazards.
Moreover, in November 2001, the District of Columbia and ATSDR
conducted a focus group comprised of Spring Valley residents to, among
other things, discuss community health concerns. The partners have also
sponsored public meetings and distributed questionnaires. The District
of Columbia has used anecdotal information from the residents about
health effects they have experienced and compared that information to
scientific literature concerning symptoms of certain cancers related to
arsenic exposure.
The Corps‘ Estimated Cost and Cleanup Schedule May Change as More
Information about the Site Is Known:
As of April 2002, the Corps estimated that the Spring Valley cleanup
would cost another $71.7 million, including fiscal year 2002, and take
5 years beyond fiscal year 2002 to complete, but these estimates are
uncertain. Factors, such as the potential discovery of additional
hazards, make it inherently challenging for the Corps to estimate the
cost for completing cleanup activities at the site, as evidenced by
periodic estimated cost increases. Further, the Corps‘ estimated
schedule for completing the cleanup necessarily depends on projections
of available annual funding, which may be different from actual
funding. Consequently, any significant increases in the estimated cost
of completing the cleanup or decreases in the amount of available
funding would likely require that the Corps extend the completion date
for Spring Valley.
Estimated Cost to Clean up Spring Valley Has Increased by about Six
Fold Since 1997:
Under the environmental restoration program, the Secretary of Defense is
required to report annually to the Congress on the progress the
department has made in carrying out environmental restoration activities
at military installations and FUDS. From fiscal years 1997 through 2001
(the most recent report available), the total estimated cost to clean up
Spring Valley increased by about six fold, from about $21 million to
about $124.1 million. In response to our request, the U.S. Army
provided us with an update of the Corps‘ estimate, as of April 2002.
The Corps had revised its estimate slightly to about $125.1 million, as
shown in figure 3.[Footnote 13]
Figure 3: Total Estimated Cost to Clean up Spring Valley, Fiscal Years
1997 through 2001 and as of April 2002 (dollars in millions):
[Refer to PDF for image]
This figure is a stacked vertical bar graph depicting the following
estimated data:
Fiscal year: 1997;
Cost to complete: $20 million;
Spent to date: $20 million.
Fiscal year: 1998;
Cost to complete: $22 million;
Spent to date: $20 million.
Fiscal year: 1999;
Cost to complete: $30 million;
Spent to date: $25 million.
Fiscal year: 2000;
Cost to complete: $80 million;
Spent to date: $40 million.
Fiscal year: 2001;
Cost to complete: $124 million;
Spent to date: $50 million.
Fiscal year: April 2002;
Cost to complete: $125 million;
Spent to date: $53 million.
Note: For April 2002, ’spent to date“ reflects the Corps‘ revised total
of the dollars spent through the end of fiscal year 2001 (September
2001), whereas ’cost to complete“ reflects the Corps‘ revised estimate
for fiscal years 2002 through 2007, as of April 2002.
Source: GAO‘s analysis of data from Defense‘s Defense Environmental
Restoration Program annual reports to the Congress, fiscal years 1997
through 2001, and data from the Corps.
[End of figure]
Costs have increased principally because the Corps needed to increase
the scope of the remaining cleanup, as more information about the site
became known (see table 1).
Table 1: Estimated Cost to Complete the Cleanup at Spring Valley,
Fiscal Years 1997 through 2001 and as of April 2002 (Dollars in
millions):
Year of estimate: Fiscal year 1997;
Estimated cost to complete the clean up: $0.5 million;
Changes to scope of the cleanup: The Corps discovered it had
incorrectly identified one of the potentially hazardous locations it had
previously investigated.
Year of estimate: Fiscal year 1998;
Estimated cost to complete the clean up: $0.6 million;
Changes to scope of the cleanup: The Corps surveyed two potential
burial pits on the South Korean property.
Year of estimate: Fiscal year 1999;
Estimated cost to complete the clean up: $4.5 million;
Changes to scope of the cleanup: The Corps increased the scope to
include removing buried ordnance and bottles of chemicals found on
the South Korean property.
Year of estimate: Fiscal year 2000;
Estimated cost to complete the clean up: $35.8 million;
Changes to scope of the cleanup: The Corps increased the scope to
include removing arsenic-contaminated soil from the South Korean
property and two adjacent properties and subsequently expanding soil
sampling efforts to about 60 nearby residences and the southern
portion of the American University campus.
Year of estimate: Fiscal year 2001;
Estimated cost to complete the clean up: $72.9 million;
Changes to scope of the cleanup: The Corps increased the scope to
include expanding sampling efforts to cover the entire Spring Valley
site, surveying selected properties for buried ordnance, and completing
additional work needed to remove buried hazards at one location.
Year of estimate: April 2002;
Estimated cost to complete the clean up: $71.7 million;
Changes to scope of the cleanup: The Corps lowered its fiscal year 2001
estimate as the preliminary results of the sitewide soil sampling
yielded additional information about the extent of arsenic
contamination.
Source: GAO‘s analysis of Defense‘s data.
[End of table]
As shown in table 2, the April 2002 estimate depends on assumptions the
Corps has made about how many properties will require the removal of
arsenic-contaminated soil and how many properties will need to be
surveyed and excavated to remove possible buried hazards.
Table 2: Estimated Total Cost to Complete Cleanup Activities at Spring
Valley, as of April 2002 (Dollars in millions):
Activities: Ordnance removal and soil removal and restoration
activities at the South Korean property and two adjacent properties;
Estimated cost: $13.1 million.
Activities: Soil removal, landscape restoration, and other related
activities at 11 properties subsequently found to have arsenic-
contaminated soil;
Estimated cost: $4.6 million.
Activities: Soil removal, landscape restoration, and other related
activities at an additional 150 properties estimated to have arsenic-
contaminated soil;
Estimated cost: $24.4 million.
Activities: Soil excavation and restoration activities at 2 properties
where buried metallic objects that could be pieces of ordnance were
identified; subsurface soil survey, excavation, and restoration
activities at another 200 properties estimated to contain such
features; and other related activities;
Estimated cost: $29.7 million.
Activities: Total;
Estimated cost: $71.7 million.
Note: Figures do not add to $71.7 million due to rounding.
Source: GAO‘s analysis of Defense‘s data.
[End of table]
Cost and Funding Uncertainties Suggest That Cleanup Schedule Could
Change:
Prior to fiscal year 2000, Defense‘s annual reports to the Congress did
not provide any estimate of when the Corps planned to complete cleanup
activities at Spring Valley. In Defense‘s fiscal year 2000 annual
report to the Congress, the Corps estimated, for the first time, that
it would complete such activities by the end of fiscal year 2012.
However, as of April 2002, the Corps had moved up its estimate of the
completion date by 5 years, to fiscal year 2007, even though it had
doubled the estimated cost of the remaining cleanup.
As shown in table 3, the Corps plans to meet the shortened time frame by
applying considerably more funding to the site in the near term.
Table 3: Levels of Annual Funding Specified in the Corps‘ Schedule for
Completing Cleanup Work at Spring Valley, Fiscal Year 2000, Fiscal Year
2001, and as of April 2002 (Dollars in millions):
Year of estimate: Fiscal year 2000;
Annual funding, Fiscal year 2001: $3.3 million;
Annual funding, Fiscal year 2002: $2.5 million;
Annual funding, Fiscal year 2003: $2.8 million;
Annual funding, Fiscal year 2004: $2.5 million;
Annual funding, Fiscal year 2005: $4.7 million;
Annual funding, Fiscal year 2006: $7.4 million;
Annual funding, Fiscal year 2007: $8.4 million;
Annual funding, Fiscal years 2008 to 2012: $4.2 million;
Total cost to complete the cleanup: $35.8[A] million.
Year of estimate: Fiscal year 2001;
Annual funding, Fiscal year 2001: $10.7[B] million;
Annual funding, Fiscal year 2002: $12.1 million;
Annual funding, Fiscal year 2003: 0[C];
Annual funding, Fiscal year 2004: $1.2 million;
Annual funding, Fiscal year 2005: $2.4 million;
Annual funding, Fiscal year 2006: $2.4 million;
Annual funding, Fiscal year 2007: $1.8 million;
Annual funding, Fiscal years 2008 to 2012: $53.1 million;
Total cost to complete the cleanup: $72.9[D] million.
Year of estimate: April 2002;
Annual funding, Fiscal year 2001: $12.9[E] million;
Annual funding, Fiscal year 2002: $18.0[F] million;
Annual funding, Fiscal year 2003: $11.0 million;
Annual funding, Fiscal year 2004: $11.0 million;
Annual funding, Fiscal year 2005: $11.0 million;
Annual funding, Fiscal year 2006: $11.0 million;
Annual funding, Fiscal year 2007: $9.8 million;
Annual funding, Fiscal years 2008 to 2012: 0;
Total cost to complete the cleanup: $71.7[G] million.
[A] For the fiscal year 2000 estimate, the estimated total cost to
complete the cleanup covers fiscal years 2001 through 2012.
[B] Figure denotes actual costs incurred during fiscal year 2001.
[C] According to the fiscal year 2001 Defense Environmental Restoration
Program report, the U.S. Army planned to reprogram $11 million in
funding not allocated to specific projects toward fiscal year 2003
costs and additional dollars in the outyears.
[D] For the fiscal year 2001 estimate, the estimated total cost to
complete the cleanup covers fiscal years 2002 through 2012. Annual
totals do not add to $72.9 million due to rounding.
[E] Figure denotes actual costs incurred during fiscal year 2001 as
revised by the U.S. Army in April 2002.
[F] Includes a $5.2 million increase approved by the U.S. Army on April
9, 2002. According to the Corps, these funds were reprogrammed from
possible use at other sites.
[G] For the April 2002 estimate, the estimated total cost to complete
the cleanup covers fiscal years 2002 through 2007. Annual totals do not
add to $71.7 million due to rounding.
Source: GAO‘s analysis of Defense‘s data.
[End of table]
However, the Corps may find it difficult to achieve its planned
completion even if there are no further changes to the scope of work.
As part of its April 2002 revised estimate, the Corps acknowledged that
meeting the schedule would depend on the FUDS budget and the U.S.
Army‘s ability to apply the specified funding to the Spring Valley
site. In order to continue to meet these needs, the U.S. Army may have
to reprogram funds from possible use at other sites nationwide in each
of the remaining years of the cleanup. Furthermore, in fiscal year
2002, the Corps planned to allocate to Spring Valley about 8 percent of
the national budget for FUDS”which has declined in recent years”and
about 86 percent of the FUDS budget for the Baltimore District, which
includes funding for FUDS in the District of Columbia and the states of
Delaware, Maryland, New York, Pennsylvania, Virginia, and West
Virginia. According to the U.S. Army, the provision of funds for the
Spring Valley cleanup is currently adversely affecting the availability
of funding and progress at other sites.
As more information becomes available about the hazards at the site, the
Corps will develop a clearer sense of how reliable its assumptions are
on the extent of the hazards present and the cost of removing them. The
Corps‘ experience with excavating buried hazards at two Glenbrook Road
properties illustrates the difficulty of estimating the cost of removing
buried hazards. In fiscal year 2002, the Corps determined that
completing the removal would cost about $6 million more than
anticipated at the end of fiscal year 2001. Furthermore, the Corps
assumed that arsenic would remain the focus of its efforts to reduce
the risks of exposure to contaminated soil, and based its cost estimate
on the work needed to meet a proposed cleanup level for arsenic; as of
April 2002, the partners had not finalized this level. As part of its
expanded soil sampling efforts, the Corps could identify the presence
of yet other chemicals and expand the scope of soil removal. Until more
complete information is known about the actual types and extent of the
hazards present throughout the site and the actual cost of removing
them, the reliability of the Corps‘ estimate of the cost and schedule
to complete the cleanup remains uncertain.
Observations:
Uncertainties will continue to affect the progress of the Spring Valley
cleanup. The unknowns are many: the potential that as-yet undiscovered
hazards will come to light and expand the scope of necessary cleanup
activities; the extent of soil removal or cleanup that will be needed,
which depends, in part, on reaching final agreement on a cleanup level
for arsenic in the soil; and the actual availability of funding for the
site cleanup that the Corps has projected for future years. Further,
these uncertainties are interdependent; for example, estimating the
amounts of funding needed in future years requires some certainty about
the scope of the cleanup”certainty that has proven to be elusive as
additional hazards have been discovered in the past.
The Corps, EPA, and the District of Columbia have made progress by
adopting a partnership approach to Spring Valley cleanup decisions.
Importantly, they have established a systematic means of communicating
information to, and receiving input from, the residents of Spring
Valley and other interested members of the public. Progress depends on
the continued effectiveness with which the government entities involved
will sustain their partnership approach throughout the cleanup period.
However, until some of the existing uncertainties are resolved, the
government entities will not be able to provide the community with
definitive answers on any remaining health risks or the cost and
duration of the cleanup.
Agency Comments:
We provided the Department of Defense, Environmental Protection Agency,
and the District of Columbia‘s Department of Health with a draft of
this report for review and comment. These agencies generally agreed
with the information presented in the draft. They provided a number of
technical comments, which we incorporated in the report as appropriate.
Defense stated that, while they agreed that there are some uncertainties
associated with the Spring Valley cleanup, it is important to note that
such unknowns are not unique to Spring Valley, and that every
environmental cleanup involves a number of unknowns, regardless of the
locale, type of contaminant, or specific entity executing the cleanup.
In addition, Defense stated that the partnership formed has been a
model for regulatory relationships at other site cleanups. EPA stated
that our report develops an accurate and unbiased appraisal of the
problems and uncertainties present at the Spring Valley site, and that
our report presents the substantive historical facts of this very
complex and challenging site cleanup. The District of Columbia‘s
Department of Health stated that it is committed to continuing to work
with the other governmental partners to establish and fully implement
any action and/or remediation plan it determines is required to protect
human health. The letters from these agencies are included in
appendixes II through IV.
Scope and Methodology:
We performed our review at the Corps‘ project office at the site, U.S.
Army‘s and EPA‘s headquarters in Washington, D.C., and the District of
Columbia‘s Department of Health in Washington, D.C. We reviewed
statutes, regulations, and appropriate guidance, as well as interviewed
government entity program officials to determine the relevant statutory
framework. We interviewed officials at Defense and U.S. Army
headquarters responsible for overseeing the FUDS program and budget.
We interviewed officials at EPA headquarters, including those from the
Office of Solid Waste and Emergency Response responsible for developing
EPA‘s guidance for FUDS, and the Office of Enforcement and Compliance
Assurance responsible for investigating matters relating to Spring
Valley. Further, we interviewed regional and project officials of both
federal agencies, as well as officials from the District of Columbia‘s
Department of Health, to understand their roles as actually carried out
at the site. We reviewed historical information and agency data, as
well as interviewed appropriate officials to identify hazards found at
the site and the progress made toward cleaning up the site. We reviewed
descriptive epidemiological studies conducted by the District of
Columbia and interviewed Department of Health officials to understand
risks associated with hazards at the site. We also attended Restoration
Advisory Board and Scientific Advisory Panel meetings to gain an
understanding of the perspectives of the various stakeholders. We
reviewed cost, budget, and schedule data from the U.S. Army and the
Corps and interviewed appropriate officials to determine how much the
Corps had spent to date at the site and understand the Corps‘ estimate
of how much it would cost and how long it would take to complete the
cleanup.
We conducted our work from October 2001 through May 2002 in accordance
with generally accepted government auditing standards.
As we agreed with your office, unless you publicly announce the contents
of this report earlier, we plan no further distribution of it until 30
days from the date of this letter. We will then send copies to other
interested parties and make copies available to others who request
them. In addition, the report will be available at no charge at GAO‘s
Web site at [hyperlink, http://www.gao.gov].
If you or your staff has any questions about this report, please call
Peg Reese or me at (202) 512-3841. Key contributors to this report are
listed in appendix VI.
Signed by:
David G. Wood:
Director, Natural Resources and Environment:
[End of section]
Appendix I: Properties in the District of Columbia Where Hazards
Resulting from Federal Activities Have Been Found:
Table 4 contains summary data on 44 properties in the District of
Columbia where hazards resulting from federal activities have been
found, using Defense data as of March 2002 and EPA data as of April
2002. For each property, the data include the name of the property, the
agency or agencies responsible for leaving the hazards, the past or
current use of the property, and the hazards found. Most sites are
active Department of Defense (Defense) installations or formerly used
defense sites (FUDS). For an active Defense installation, the host
military branch of the installation is responsible for the cleanup
while the U.S. Army Corps of Engineers (the Corps) is responsible for
the cleanup of all FUDS. In addition, there are six properties
involving other federal agencies that are being addressed through the
Environmental Protection Agency‘s environmental cleanup programs.
Table 4: Properties in the District of Columbia Where Hazards Resulting
from Federal Activities Have Been Found:
Defense, active installations (8):
Name of property: Bolling Air Force Base[A];
Agency or agencies responsible for leaving the hazards: U.S. Air Force;
Past or current use of the property: Active installation;
Hazards found: Polychlorinated biphenyls (PCB); petro hydrocarbons;
benzene, toluene, ethylbenzene, and xylenes (BTEX); semi-volatile
organic compounds (SVOC); lindane; dichlorodiphenyltrichloroethane
(DDT); and heavy metals.
Name of property: Fort McNair[A];
Agency or agencies responsible for leaving the hazards: U.S. Army;
Past or current use of the property: Active installation;
Hazards found: Lead, BTEX, and total petroleum hydrocarbons (TPH);
Name of property: Naval Station–Anacostia;
Agency or agencies responsible for leaving the hazards: U.S. Navy;
Past or current use of the property: Active installation;
Hazards found: Acid, heavy metals, and other chemicals.
Name of property: Naval Observatory;
Agency or agencies responsible for leaving the hazards: U.S. Navy;
Past or current use of the property: Active installation;
Hazards found: Petroleum, oil, and lubricants.
Name of property: Naval Research Laboratory;
Agency or agencies responsible for leaving the hazards: U.S. Navy;
Past or current use of the property: Active installation;
Hazards found: Hazardous, toxic, and radioactive waste.
Name of property: Naval Security Station[A];
Agency or agencies responsible for leaving the hazards: U.S. Navy;
Past or current use of the property: Active installation;
Hazards found: Hazardous, toxic, and radioactive waste.
Name of property: Walter Reed Army Medical Center[A];
Agency or agencies responsible for leaving the hazards: U.S. Army;
Past or current use of the property: Active installation;
Hazards found: Fuel oil.
Name of property: Washington Navy Yard[A];
Agency or agencies responsible for leaving the hazards: U.S. Navy;
Past or current use of the property: Active installation;
Hazards found: Heavy metals, chlorinated solvents, and PCB.
Defense, FUDS (30):
Name of property: Anti-Aircraft Artillery Site–Fort Reno;
Agency or agencies responsible for leaving the hazards: U.S. Army;
Past or current use of the property: Civil War fortification and anti-
aircraft site;
Hazards found: Civil War-era ordnance and explosive waste.
Name of property: Barney Circle;
Agency or agencies responsible for leaving the hazards: U.S. Army Corps
of Engineers and National Park Service;
Past or current use of the property: Landfill;
Hazards found: Lead.
Name of property: Camp Simms Military Reservation;
Agency or agencies responsible for leaving the hazards: Department of
Defense;
Past or current use of the property: Military installation–small arms
range;
Hazards found: Ordnance and explosive waste, and hazardous, toxic, and
radioactive waste.
Name of property: Catholic University–Offense Research Station;
Agency or agencies responsible for leaving the hazards: U.S. Army;
Past or current use of the property: World War I munitions research
laboratory;
Hazards found: Ordnance and explosive waste.
Name of property: Chain Bridge Batteries Complex;
Agency or agencies responsible for leaving the hazards: U.S. Army;
Past or current use of the property: Civil War fortification;
Hazards found: Civil War-era ordnance and explosive waste.
Name of property: Diamond Ordnance Fuze Laboratories[A];
Agency or agencies responsible for leaving the hazards: U.S. Army and
Department of Commerce;
Past or current use of the property: Former location of the National
Bureau of Standards‘ ordnance research and development activities;
Hazards found: Ordnance and explosive waste.
Name of property: Fort Baker;
Agency or agencies responsible for leaving the hazards: U.S. Army;
Past or current use of the property: Civil War fortification;
Hazards found: Civil War-era ordnance and explosive waste.
Name of property: Fort Bayard;
Agency or agencies responsible for leaving the hazards: U.S. Army;
Past or current use of the property: Civil War fortification;
Hazards found: Civil War-era ordnance and explosive waste.
Name of property: Fort Bunker Hill;
Agency or agencies responsible for leaving the hazards: U.S. Army;
Past or current use of the property: Civil War fortification;
Hazards found: Civil War-era ordnance and explosive waste.
Name of property: Fort Chaplin;
Agency or agencies responsible for leaving the hazards: U.S. Army;
Past or current use of the property: Civil War fortification;
Hazards found: Civil War-era ordnance and explosive waste.
Name of property: Fort Davis;
Agency or agencies responsible for leaving the hazards: U.S. Army;
Past or current use of the property: Civil War fortification;
Hazards found: Civil War-era ordnance and explosive waste.
Name of property: Fort DeRussy;
Agency or agencies responsible for leaving the hazards: U.S. Army;
Past or current use of the property: Civil War fortification;
Hazards found: Civil War-era ordnance and explosive waste.
Name of property: Fort Dupont Park Site;
Agency or agencies responsible for leaving the hazards: U.S. Army;
Past or current use of the property: Civil War fortification;
Hazards found: Civil War-era ordnance and explosive waste.
Name of property: Fort Greble;
Agency or agencies responsible for leaving the hazards: U.S. Army;
Past or current use of the property: Civil War fortification;
Hazards found: Civil War-era ordnance and explosive waste.
Name of property: Fort Kearny;
Agency or agencies responsible for leaving the hazards: U.S. Army;
Past or current use of the property: Civil War fortification;
Hazards found: Civil War-era ordnance and explosive waste.
Name of property: Fort Lincoln[A];
Agency or agencies responsible for leaving the hazards: U.S. Army;
Past or current use of the property: Civil War fortification;
Hazards found: Civil War-era ordnance and explosive waste.
Name of property: Fort Mahan;
Agency or agencies responsible for leaving the hazards: U.S. Army;
Past or current use of the property: Civil War fortification;
Hazards found: Civil War-era ordnance and explosive waste.
Name of property: Fort Ricketts;
Agency or agencies responsible for leaving the hazards: U.S. Army;
Past or current use of the property: Civil War fortification;
Hazards found: Civil War-era ordnance and explosive waste.
Name of property: Fort Slemmer;
Agency or agencies responsible for leaving the hazards: U.S. Army;
Past or current use of the property: Civil War fortification;
Hazards found: Civil War-era ordnance and explosive waste.
Name of property: Fort Slocum;
Agency or agencies responsible for leaving the hazards: U.S. Army;
Past or current use of the property: Civil War fortification;
Hazards found: Civil War-era ordnance and explosive waste.
Name of property: Fort Snyder;
Agency or agencies responsible for leaving the hazards: U.S. Army;
Past or current use of the property: Civil War fortification;
Hazards found: Civil War-era ordnance and explosive waste.
Name of property: Fort Stanton;
Agency or agencies responsible for leaving the hazards: U.S. Army;
Past or current use of the property: Civil War fortification;
Hazards found: Civil War-era ordnance and explosive waste.
Name of property: Fort Stevens;
Agency or agencies responsible for leaving the hazards: U.S. Army;
Past or current use of the property: Civil War fortification;
Hazards found: Civil War-era ordnance and explosive waste.
Name of property: Fort Totten;
Agency or agencies responsible for leaving the hazards: U.S. Army;
Past or current use of the property: Civil War fortification;
Hazards found: Civil War-era ordnance and explosive waste.
Name of property: Fort Wagner;
Agency or agencies responsible for leaving the hazards: U.S. Army;
Past or current use of the property: Civil War fortification;
Hazards found: Civil War-era ordnance and explosive waste.
Name of property: Naval Station–Anacostia Annex;
Agency or agencies responsible for leaving the hazards: U.S. Navy;
Past or current use of the property: Ordnance research, barracks,
school;
Hazards found: Ordnance and explosive waste.
Name of property: Rock Creek Park Troop Housing;
Agency or agencies responsible for leaving the hazards: [B];
Past or current use of the property: [B];
Hazards found: [B].
Name of property: Shepherd Parkway;
Agency or agencies responsible for leaving the hazards: [B];
Past or current use of the property: [B];
Hazards found: [B].
Name of property: Spring Valley;
Agency or agencies responsible for leaving the hazards: U.S. Army;
Past or current use of the property: World War I munitions testing
area;
Hazards found: Ordnance and explosive waste and arsenic in soil.
Name of property: Washington Navy Yard[A];
Agency or agencies responsible for leaving the hazards: U.S. Navy;
Past or current use of the property: Naval shipbuilding and ordnance
production;
Hazards found: Hazardous, toxic, and radioactive waste.
Other federal agencies (6):
Name of property: Kenilworth Park Landfill Site[A];
Agency or agencies responsible for leaving the hazards: National Park
Service;
Past or current use of the property: Former municipal dump;
Hazards found: PCB and polynuclear hydrocarbons.
Name of property: National Park Service–Anacostia Park Sections E &
F[A];
Agency or agencies responsible for leaving the hazards: Not available;
Past or current use of the property: Not available;
Hazards found: Not available.
Name of property: Southeast Federal Center[A];
Agency or agencies responsible for leaving the hazards: U.S. Navy;
Past or current use of the property: Administrative offices and storage
facilities, ordnance research and manufacturing, and shipbuilding;
Hazards found: Solvents, PCB, polyaromatic hydrocarbons, and heavy
metals (including lead, arsenic, and chromium).
Name of property: St. Elizabeth‘s Hospital[A];
Agency or agencies responsible for leaving the hazards: Not available;
Past or current use of the property: Former federally owned and
operated mental institution sold to the District of Columbia;
Hazards found: Polynuclear hydrocarbons, perchloroethylene (PCE),
toluene, chromium, cadmium, mercury, cobalt, and DDT.
Name of property: U.S. Department of Agriculture–National Arboretum[A];
Agency or agencies responsible for leaving the hazards: U.S. Department
of Agriculture;
Past or current use of the property: Agricultural research facility;
Hazards found: Organochlorine, insecticide, herbicide, fungicides, wood
preservatives, and solvents.
Name of property: Washington Gas Light Site[A];
Agency or agencies responsible for leaving the hazards: Federal
property affected by contamination from a private property;
Past or current use of the property: Equipment storage area for the
District of Columbia‘s Department of Public Works, river debris removal
staging area, and recreational use;
Hazards found: Coke breeze, benzene, xylenes, toluene,naphthalene, fat
chemco, carboseal, petroleum by-products, and polynuclear hydrocarbons.
[A] Also listed as a Comprehensive Environmental Response,
Compensation, and Liability Act site.
[B] Defense was unable to provide information on the agency or agencies
responsible for leaving any hazards, the past or current use of the
property, or whether or not hazards had been found at the site.
Note: Table includes Defense active installations and FUDS listed as of
March 2002 and properties involving other federal agencies as of April
2002.
Source: GAO‘s analysis of Defense‘s and EPA‘s data.
[End of table]
Table 5 contains data on 30 federal properties in the District of
Columbia, on which remediation of leaking underground storage tanks was
in process, as of January 2002, as well as the hazards found.
Table 5: Hazards Found at Leaking Underground Storage Tanks on Federal
Properties in the District of Columbia Where Remediation Was in
Process, as of January 2002:
Federal property: Anacostia Naval Station–Building #353;
Hazards found: Diesel fuel, gasoline, halogenated hydrocarbons,
trichloropropane (TCP), and waste oil.
Federal property: Architect of the Capitol–Capitol Power Plant;
Hazards found: Diesel fuel and heating oil.
Federal property: Architect of the Capitol–O‘Neill House Office
Building;
Hazards found: Diesel fuel and gasoline.
Federal property: Architect of the Capitol–Rayburn House Office
Building;
Hazards found: Diesel fuel and gasoline.
Federal property: Architect of the Capitol–Senate Underground Garage;
Hazards found: Diesel fuel and gasoline.
Federal property: Bolling Air Force Base;
Hazards found: Diesel fuel and gasoline.
Federal property: Bolling Air Force Base–Army and Air Force Exchange
Service‘s Service Station;
Hazards found: Gasoline.
Federal property: Bolling Air Force Base–Car Care Center;
Hazards found: Gasoline.
Federal property: Dalecarlia Water Treatment Plant;
Hazards found: Heating oil.
Federal property: Edgewater Stable–U.S. Secret Service;
Hazards found: Gasoline.
Federal property: Federal Triangle;
Hazards found: Diesel fuel and gasoline.
Federal property: Former Architect of the Capitol Poplar Point Nursery;
Hazards found: Gasoline.
Federal property: Fort McNair–Fitness Center;
Hazards found: Heating oil and kerosene.
Federal property: Fort McNair–Gas Station;
Hazards found: Gasoline, kerosene, and waste oil.
Federal property: Fort McNair–Parking Lot;
Hazards found: Gasoline.
Federal property: Fort McNair–Quarters #20;
Hazards found: Heating oil.
Federal property: The John F. Kennedy Center;
Hazards found: Diesel fuel.
Federal property: National Park Service–1900 Anacostia Drive;
Hazards found: Gasoline, heating oil, and waste oil.
Federal property: Naval Observatory–Building #52;
Hazards found: Heating oil.
Federal property: Naval Observatory–Building #64;
Hazards found: Gasoline.
Federal property: Park Police Anacostia Operation;
Hazards found: Gasoline.
Federal property: Southeast Federal Center–Block H;
Hazards found: Diesel fuel.
Federal property: Southeast Federal Center–Building #216, 2nd & M Sts.,
SE;
Hazards found: Waste oil.
Federal property: U.S. Department of Agriculture National
Arboretum– Building #014;
Hazards found: Gasoline.
Federal property: U.S. Government Printing Office;
Hazards found: Heating oil.
Federal property: U.S. Postal Service–Brightwood;
Hazards found: Diesel fuel and gasoline.
Federal property: U.S. Postal Service–Vehicle Maintenance Facility;
Hazards found: Diesel fuel, gasoline, and waste oil.
Federal property: Veterans Affairs Medical Center;
Hazards found: Heating oil.
Federal property: Washington Navy Yard–Building #071;
Hazards found: Diesel fuel, gasoline, and waste oil.
Federal property: Washington Navy Yard–Building #111;
Hazards found: Heating oil.
Note: Table excludes leaking underground storage tank cases where
remediation was complete as of January 2002.
Source: GAO‘s analysis of the District of Columbia‘s data.
[End of table]
[End of section]
Appendix II: Comments from the Department of Defense:
Office Of The Under Secretary Of Defense:
Acquisition and Technology:
3000 Defense Pentagon:
Washington DC 20301-3000:
May 20, 2002:
Mr. David G. Wood:
Director:
Natural Resources and Environment:
U.S. General Accounting Office:
Washington, D.C. 20548:
Dear Mr. Wood:
The Department of Defense (DoD) appreciates the opportunity to provide
comments regarding the GAO draft report, GAO-02-556, 'Environmental
Contamination: Many Uncertainties Affect the Progress of the Spring
Valley Cleanup', dated May 7, 2002 (GAO Code 360145).
The objectives and findings of the report focus on uncertainties at the
Spring Valley site involving: 1) the extent of contamination remaining
at Spring Valley; 2) the regulatory partnerships; 3) health risks from
contaminated soils; and 4) funding, and the uncertainties impacts on
the progress of cleanup. While we agree that there are some
uncertainties associated with the Spring Valley cleanup, it is
important to note that such unknowns are not unique to Spring Valley.
Every environmental cleanup involves a number of unknowns, regardless
of the locale, type of contaminant, or specific entity executing the
cleanup. The purpose of the site characterization process is to reduce
the uncertainties associated with the nature and extent of
contamination, risk to human health, and implementation of the
appropriate response action. The site characterization process at
Spring Valley has, in many respects, reduced many of these
uncertainties, and the Army, with its regulatory partners, plans to
continue to address each discovery in the same deliberative and
responsive manner.
In addition, the cooperative relationship formed between the U.S.
Environmental Protection Agency (EPA), the District of Columbia
Department of Health (D.C. Health) and the Corps of Engineers has been,
in our opinion, a model for regulatory relationships at other site
cleanups. Each agency's dedicated commitment to the partnership, and
participation in critical decisions throughout the cleanup process, is
evidenced by the substantial progress made in addressing contamination
arising from war preparation activities of almost a century ago. This
collaboration, in contrast to enforcement, has resulted in a more
timely and cost effective cleanup, and the Department has every reason
to expect that this relationship will continue to be effective into the
future.
In regard to funding, DoD has continually demonstrated a financial
commitment to completing the cleanup at the Spring Valley site. Over
the last ten years, and at the expense of other cleanups, the Army has
allocated over $50 million to the cleanup of Spring Valley and, at the
behest of stakeholders, will reprioritize another $70 million to
complete the cleanup at this site.
The protection of human health and the environment is critical, and DoD
will continue to work in partnership with EPA and the D.C. Health to
ensure that the health and safety of the residents are protected, and
that sufficient resources are made available. Our attached comments
reflect this position.
My point of contact on this matter, Mr. Kurt Kratz (703) 697-5372, is
available to discuss our responses to findings and additional comments
provided on this document.
Sincerely,
Signed by:
Raymond F. DuBois, Jr.
Deputy Under Secretary of Defense (Installations and Environment):
Enclosure:
[End of section]
Appendix III: Comments from the Environmental Protection Agency:
United States Environmental Protection Agency:
Office Of Solid Waste And Emergency Response:
Washington, D.C. 20460:
[hyperlink, http://www.epa.gov]:
May 20, 2002:
David G. Wood:
Director:
Natural Resources and Environment:
United States General Accounting Office (GAO):
Washington, DC 20548:
Dear Mr. Wood:
Thank you for the opportunity to review and comment on the May 7, 2002,
draft report entitled "Environmental Contamination - Many Uncertainties
Affect the Progress of the Spring Valley Cleanup" (GAO-02-556). This
letter transmits our comments on the draft report.
EPA believes the report has done an excellent job presenting the
substantive historical facts of this very complex and challenging site
cleanup. EPA appreciates the substantial effort made by the GAO in
developing an accurate and unbiased appraisal of the problems and
uncertainties present at the Spring Valley Site. However, there are
several issues raised during our conference call on Monday, April 29
that were not addressed in the draft report. These concerns are the
references to and the description of the relationship between the
Comprehensive Environmental Response, Compensation, and Liability Act
of 1980 (CERCLA), the Superfund Amendments and Reauthorization Act of
1986 (SARA) and the Defense Environmental Restoration Program (DERP).
There are also some statements attributed to EPA that are inconsistent
with our policy on privately-owned Formerly Used Defense Sites (FUDS).
We hope these comments will be considered during your revision of the
draft report.
All comments included in the enclosure are intended to improve the
accuracy of the draft report. If you have any questions about these
comments, please contact Renee Wynn, of my staff, at (202) 260-8366 or
Hank Sokolowski, Region 3, at (215) 814-3348.
Sincerely,
Signed by:
Michael Shapior, for:
Marianne Lamont Horinko:
Assistant Administrator:
Enclosure:
[End of section]
Appendix IV: Comments from the District of Columbia‘s Department of
Health:
Government of the District of Columbia:
Department of Health:
Office of the Senior Deputy Director for Public Health Assurance:
825 North Capitol Street, NE, 4th Floor:
Washington, DC 20002:
Tel: 202-442-8982:
Fax: 202-442-4886:
May 17, 2002:
Mr. David G. Wood, Director:
Natural Resources and Environment:
United States General Accounting Office:
Washington, DC 20548:
Dear Mr. Wood:
The DC Department of Health (DOH) has received a draft copy from the
United States Government Accounting Office (GAO) of the proposed report
entitled "Environmental Contamination: Many Uncertainties Affect the
Progress of the Spring Valley Cleanup" (GAO-02-556). The DOH's written
comments were transmitted to you during our meeting with the GAO on
April 26, 2002 and many have been included in your draft report.
The DOH has received additional information since our meeting on April
260th, regarding the collaborative investigation with the Agency For
Toxic Substances and Disease Registry (ATSDR) that has been conducted
with the participation of Spring Valley residents. The results of the
Phase I exposure investigation suggest that arsenic contamination on
properties in Spring Valley has not resulted in significant exposure by
the residents. The interpretation is based on biological samples
(urine, hair) collected from Spring Valley residents with the highest
soil levels of arsenic on their properties. The results from the Phase
I exposure investigation will be helpful as part of the ongoing
assessment of Spring Valley residents by the DOH.
The District is committed to continuing to work with the other
governmental partners to establish and fully implement any action
and/or remediation plan it determines is required to protect human
health. Using its available scientific resources and information, its
monitoring and enforcement capabilities and authority, the District is
confident that the objective of ensuring a timely response to protect
human health will be achieved.
We appreciate the inclusion of our remarks in your report and the
opportunity to comment on the initial draft.
Sincerely,
Signed by:
Theodore J. Gordon:
Senior Deputy Director for Public Health Assurance:
cc: James Buford, Interim Director, DOH:
[End of section]
Appendix V: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
David G. Wood (202) 512-3841:
Peg Reese (202) 512-9695:
Acknowledgments:
In addition to those named above, Ridge Bowman, Stephen Cleary,
Margaret McDavid, and Carol Herrnstadt Shulman made key contributions
to this report.
[End of section]
Footnotes:
[1] The Department of Defense Appropriation Act, 1984 (P.L. 98-212)
provided 1 year of funding for the cleanup of hazardous substances
released from Defense properties and the removal of unsafe or unsightly
Defense buildings and debris. Annual appropriations for these
activities have continued, but since 1986, have been funded under the
Defense Environmental Restoration Account established by the Congress
as part of the Defense Environmental Restoration Program.
[2] Specifically, Defense‘s activities addressing hazardous substances,
pollutants, or contaminants are required to be carried out consistent
with section 120 of CERCLA.
[3] The Department of Health defines exposure as any completed pathway
through the air, water, or soil of the contaminant that results in an
inhaled, ingested, or dermal-absorbed dose associated with adverse
human health effects.
[4] Removal actions are generally short-term responses to address
immediate and significant dangers at any hazardous waste site but are
not necessarily final solutions.
[5] EPA Policy Toward Privately-Owned Formerly Used Defense Sites,
which notes that, while the policy focuses on authorities available to
EPA under CERCLA, ’nothing in this policy should be construed as
limiting EPA‘s or a State‘s authorities“ under other applicable
environmental statutes, such as the Resource Conservation and Recovery
Act or the Clean Water Act.
[6] In commenting on our report, the Corps stated that the reason the
environmental officials were not included was that the Mayor of the
District of Columbia had expressly designated a different agency as the
point of contact for Spring Valley.
[7] ATSDR is an agency of the Department of Health and Human Services.
It was created by CERCLA, and its mission is to take responsive public
health action and provide public health information to prevent harmful
exposures and diseases related to toxic substances.
[8] We are currently reviewing the Corps‘ process for assessing the
need to clean up FUDS nationwide and will issue a report this summer.
[9] In addition, the Corps sampled soil for a variety of chemicals at a
number of locations at American University and at the location where a
piece of ordnance containing suspected chemical agent was found. Total
potentially hazardous locations surveyed and sampled do not add to 53
because some locations were both surveyed and sampled, some were either
surveyed or sampled but not both, while others were neither surveyed
nor sampled because they were either buildings or under a large
concrete reservoir.
[10] According to a District of Columbia official, the Corps had
discovered this error in 1994 and had found a possible buried ordnance
pit, but did not undertake a cleanup action at the time. However, the
Corps disagrees and stated that it did not find any indication of a
possible ordnance burial pit at the site in 1994.
[11] In January 2001, the Corps also removed oil filters, glass, and
lab equipment, along with soil contaminated with elevated levels of
lead and arsenic from a small surface disposal area discovered on
American University property adjacent to the South Korean property.
However, according to the Corps, it was not possible to determine
whether these hazards resulted from past Defense research activities,
or from another source.
[12] For example, EPA recently established a more stringent standard
for arsenic in drinking water. See U.S. General Accounting Office,
Environmental Protection Agency: Use of Precautionary Assumptions in
Health Risk Assessments and Benefits Estimates, [hyperlink,
http://www.gao.gov/products/GAO-01-55] (Washington, D.C.: Oct. 16,
2000).
[13] For this report, we focused on the revised cost figures that the
Army provided to us in April 2002, as opposed to the figures reported
in the fiscal year 2001 Defense Environmental Restoration Program
report. According to the Corps, the revised figures more accurately
reflect the costs incurred by the Corps through fiscal year 2001 and the
Corps‘ estimate of the cost to complete cleanup activities at Spring
Valley.
[End of section]
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