NSIAD-91-146 Environmental Protection: Solving NASA's Current

GAO

__“-~ ---._-_--_-_-- I- .“_.__._.._l___l-. ““l._l.l”--l” --..- _I-__ April I!$!11 ENVIRONMENTAL PROTECTION Solving NASA’s Current Problems Requires Agencywide Emphasis

GAO/NSIAI)-91-146 NationalSecurkyand InternationalMairsDivislon

B-242740

April 6,lQOl The Honorable John Glenn Chairman, Committee on Governmental Affairs United States Senate Dear Mr. Chairman:

We reviewed the National Aeronautics and SpaceAdministration ’s (NASA) environmental protection program. Specifically, we determined the extent of NASA’S known hazardous waste contamination and the effectiveness of the program’s management. Unless you publicly announce its contents earlier, we plan no further distribution of this report until 30 days after its issue date. At this time we will send copies to the NASA Administrator and appropriate congressionalcommittees. We will also make copies available to others. Pleasecontact me on (202) 276-6140 if you or your staff have any questions concerning the report. The major contributors to this report are listed in appendix II.

Sincerely yours,

Mark E. Gebicke Director, NASA Issues NASA has not adequately implementedits policy to prevent, control, and abate environmental pollution. NASA has delegatedresponsibility for implementingits environmental pollution policy to its centerswithout establishing an agencywidestrategy and an effective monitoring and managementsystem. W ithout an implementationstrategy, the quality and successof the centers’ programs vary considerablyin terms of the level of emphasisplaced on environmental issuesand the staffing and financial resourcescommitted to the programs.Similarly, without effective headquarters management,NASA is unaware of seriousnoncompli- anceproble ms,does not ensure that problemsidentified at one center are investigated at other centerswith similar facilities, and doesnot ensure that centersperfor m periodic environmental complianceaudits. Thus, program office and Facilities Engineeringstaff need to work together more closely to effectively monitor centers’ activities.

Principal Findings

NASA FacesMany At the five centers GAO visited, the extent of contamination and regula- Environmental Problems, tory noncompliancevaried, as did the types of corrective actions being taken or planned. While someactions, such as upgrading of hazardous but Cleanup Cost Is material storage areas,are relatively minor, others represent significant Unknown contamination cleanups.The worst problemsare candidatesfor the EPA'S Superfund list of sites consideredto present the most seriousthreats to public health and the environment.

NASA has prioritized its projects to correct the most seriousproble ms first. Where corrective action has been slow, however, state regulatory agencieshave taken enforcementactions. For example,the Marshall SpaceFlight Center stored electroplating wastes in an industrial waste treatment basin and two lagoons.Because the Center failed to periodically sampleand analyzethe groundwater surrounding the site, Ala- bama environmental authorities issueda July 1990 order requiring Marshall to submit a groundwater assessmentplan.

NASA plans to spend about $32 million to $60 million a year for the next 6 years to addressenvironmental projects and activities. However, this cost covers only the projects funded from one appropriation. Environ- mental projects are also funded from other appropriations, at the center directors’ discretion, which do not specifically identify those project

Page 3 GAO/NSIAD91-146 Jhvhmmental Protection had been contaminatedwhen mercury in the tunnel’s pressure gauges spilled. Although the program office responsiblefor the researchcenters informed them about Lewis’ problem, it did not require those centersto determine if they were similarly contaminated.The Ames Research Center, for instance,did not begin testing for mercury contamination until January 1991,because of other priorities and limited resources.

Environmental Audits: NASA requires environmental complianceaudits at centers every 6 years. Current Problems and a EPA believesthat environmental auditing, if properly conducted,can Potential Solution improve a facility’s compliancewith environmental requirements.How- ever, the Director, EPA Office of Federal Facility Enforcement,ques- tioned the effectivenessof auditing only every 6 years and suggested intervals of no more than 3 years. Also, center environmental coordinators were concernedabout the quality and attention to detail of contractors’ audits, preferring contractor-supported audit teams that include NASA headquarters and center environmental experts.

Recommendations GAO recommendsthat the NASA Administrator take the following actions:

l Develop an agencywidestrategy, including center-based,measurable goals,on implementing the environmental pollution prevention, abatement, and control policy. . Establish standards on center environmental staff levels and qualifications, organizational authority, and provide for mechanismsto identify funding requirements.

l Develop criteria and guidelines for center reporting of imminent or actual noncompliancewith environmental regulations, new state and local regulatory requirementsbeing proposedor issued,and other items as appropriate. . Require that problems identified at one center be addressedat other centers with similar facilities or functions. . Establish an environmental audit program to evaluate, at least every 3 years, the centers’ regulatory complianceand managementsystems for ensuring compliance.

As requested,GAO did not ask NASA to commentofficially on a draft of Agency Comments this report. However, the views of responsibleofficials were sought during the course of GAO'S work and are included in the report where appropriate.

Page 6 GAO/NSIAD-91-149 Environmental Protection Abbreviations

CERCLA ComprehensiveEnvironmental Response,Compensation, and Liability Act DOD Department of Defense EPA Environmental Protection Agency GAO GeneralAccounting Office NASA National Aeronautics and SpaceAdministration PCB polychlorinated biphenyl RCRA ResourceConservation and RecoveryAct

Page 7 GAO/NSIAD@l-146 Enviromental Protection Chapter 1 introduction

of their responsibilitiesunder RCRA. In particular, while NASA headquarters had emphasizedRCRA to its field activities, three NASA facilities had violations becauselocal officials had not understood RCRA'S applicability to their operations, or becausethey lacked knowledgeof RCRA requirements.

NASA ManagementInstruction 8800.13 states that NASA’S policy is to pre- Organizational vent, control, and abate environmental pollution in accordancewith Structure and applicable laws and consistentwith NASA statutory authority. To imple- Responsibilities ment this policy, NASA assignedresponsibilities to the headquarters Facilities EngineeringOffice, three headquarters program offices, and the nine centers.While the headquarters offices primarily provide oversight and coordination, the centers are responsiblefor the day-to-day compliancewith NASA’S environmental policy. In 1986,the Facilities EngineeringOffice becamethe focal point for agencywidematters on environmental complianceand protection. In an August 1987 letter to headquarters program offices and the centers,the Facilities EngineeringOffice stated that its responsibilitiesincluded (1) coordinating funding for environmental studies,(2) preparing the environmental restoration fund budget submission,and (3) managing agencywideefforts to comply with significant environmental regulations. As environmental compliancerequire mentsbecame stricter and regulatory agenciesincreased oversight, NASA created the Environmental ManagementBranch within Facilities Engineering.In June 1990,the Branch was establishedin an attempt to centralizethe managementof environmental activities and to increasethe environmental program’s visibility. Branch personnelprovide expertise to the centers and program offices. Also at headquarters, the program offices are responsiblefor the overall planning and direction of operations and resourcesat the centers.These offices exercisetheir oversight primarily through the budget process. Following are the program offices and the centers for which they are responsible:

l Office of Aeronautics and Exploration Technology

l AmesResearch Center

l Langley ResearchCenter . Lewis ResearchCenter

Page 9 GAO/NSIAD-91-146 Environmental Protection Chaptm 1 Introduction

reported in the Pollution Abatement Plans are funded from both headquarters and center funds. It should be noted that the plans are planning documents,not funding requests.

We reviewed NASA'S environmental protection program at the request of Objectives,Scope, and the Chairman, SenateCommittee on GovernmentalAffairs. Our objec- Methodology tives were to (1) determinethe extent of environmental problemscon- fronting NASA and the corrective actions being taken or planned and (2) assessNASA'S managementof its environmental protection program.

We performed our work at NASA headquarters in Washington,D.C., and at the following five centers:

. Ames ResearchCenter, Moffett Field, California; . Goddard SpaceFlight Center’sWallops Flight Facility, WallopsIsland, Virginia; Johnson SpaceCenter, Houston, Texas; Marshall SpaceFlight Center, Huntsville, Alabama; and Lewis ResearchCenter, Cleveland,Ohio.

Thesecenters were judgmentally selectedfro m NASA’S nine centersto include at least one from each program office and to provide for geo- graphic dispersion in our work. We limited the number of centers visited becauseat the time of our review, NASA’s Inspector Generalwas conducting environmental managementaudits at four centers.

To determine the extent of environmental problems,we interviewed officials from the Facilities EngineeringOffice, program offices, and selectedcenters and obtained documents,where possible,describing efforts to identify problems.W ith these individuals, we also discussed the centers’ environmental compliancestatus, the cost of complianceand restoration projects, and existing headquarters and center organizational support for monitoring the actions of field environmental activities.

To gain an overall view of NASA’S environmental protection program, we obtained the following from headquarters:

. managementinstructions, policies, and other guidance;

Page 11 GAO/NSIAD-91-146 Environmental Proteetlon / Chapter 2 1 NASA Is Facing Various Ehviroqmentd ’ Problemsand Unknown CleanupCos ts

Over the years, NASA has encounteredvarious environmental problems, such as groundwater and soil contamination, and noncompliancewith EPA, state, and local regulations. Theseproblems, identified through internal and external assessments,have resulted in costly compliance and correction projects whose costs are shared by NASA headquarters and centers.NASA headquarters, for example,estimates it needs$32 million to $60 million a year over the next 6 years to addressenvironmental projects and activities. However, this cost covers only the projects funded from the Construction of Facilities appropriation; it doesnot include projects funded from the centers’ other appropriations. Further- more, for many cleanup projects not yet approved, it is unclear what clean up will be done, and how much the clean up will cost until required studies are completed.

NASA and its contractors have traced current environmental problems to Origin of maintenance,industrial, and researchprocesses and to practices of pre- Environmental vious military owners of someNASA centers. Problems From 1986 to 1990, NASA contractors conductednumerous reviews required by CERCLA at NASA centers and satellite installations. Thesecon- tractors found that NASA had contaminated its facilities, surrounding soil, and groundwater through spills, inadequate or improper storage and disposal of waste. EPA and state inspections,conducted during this period, found similar problems. In someinstances, contamination was causedby actions that were con- sidered standard practices at the time. For example,EPA has ordered NASA’S White SandsTest Facility to investigate the magnitude of freon and trichloroethylene contamination of the groundwater. According to an EPA project manager,White Sandsstored wastewaters containing these substancesin an unlined surface impoundment,l a practice consid- ered normal at that time. Today, surface impoundmentsmust be lined to prevent seepage.

NASA’S assessmentsalso found that somecontamination had been caused by prior owners, especially military owners of NASA facilities. For example, the Santa SusanaField Laboratory (a Marshall SpaceFlight Center satellite installation located in Ventura County, California), the

'A natural topographicdepression, man-made excavation, or dikedarea formed primarily of earthen materials,which is designedto holdan accumulation of liquid wastes. Examples include holding pita, ponds,and lagoons.

Page 13 GAO/NSW91-149 Environmental Protection chaptar 2 NASA b Facing Varlour Fmironmental Problema md Unknown Cleanup Coats

In somecases, the contaminatedsite may pose a sufficient hazard to human health and the environment to be a candidate for EPA’S National Priority List of Superfund sites. CERCLA created the Superfund program, which is managedby EPA, to clean up the most dangerousabandoned hazardouswaste sites and authorized EPA to compelresponsible parties to clean up those sites. According to NASA officials, the following sites may be included in the Superfund list.

l Water supply wells in the vicinity of the Jet Propulsion Laboratory are contaminatedwith trichloroethylene and other solvents.

l A fire-training pit at the WallopsFlight Facility where waste fuel was dischargedonto the ground, ignited, and then extinguished during training exercises.

l The Ames ResearchCenter ’sDryden Flight ResearchFacility, which is being evaluated becauseit is a tenant of Edwards Air Force Base,itself a Superfund site. Appendix I provides further examplesof environmental problems, potential corrective actions, and, where available, NASA'S estimated costs.

Problems Requiring If a facility doesnot promptly and properly correct environmental problemsidentified in warning letters and violation notices,EPA or state Regulatory Enforcement regulators may take enforcementaction. Whether by an agreementor an Action order, the enforcementdocument requires the facility to take certain actions by specific dates to attain compliance.Of the centerswe visited, the Wallops Flight Facility and the Marshall SpaceFlight Center were recently ordered to comply with environmental requirements. Until 1989, the Marshall SpaceFlight Center stored electroplating wastes in an industrial waste treatment basin and two lagoons.Wastes from an industrial sewer and laboratory were also stored in the basin. The Center proposed closingthe basin and lagoonsin 1984 and, as part of the closure process,was required to samplethe groundwater surrounding the site. The Alabama Department of Environmental Manage- ment requestedthat the Center periodically assessgroundwater quality becauseof the concentration of hazardouswaste and its componentsin the groundwater. Becausethe Center failed to obtain additional groundwater samples,in July 1990,the state ordered that the testing be conducted.

Page 15 GAO/NSIAD-91-146 Environmental Protection clmpter 2 NASA b Fadug Varloue Environmental Problema and Unknown Cleanup Costs

. NASA cannot rely on when other responsibleparties will provide their share of cleanup costs; . the time and methodsneeded to completesome complex projects, and the resulting cost, are difficult to estimate,and remedial investigation/ feasibility studies and similar studies must be completedbefore costs can be accurately assessed;and . environmental regulations can changeat any time, which would require new or revised projects.

Environmental Program The centers fund projects from various appropriations, including Con- Costs Not Identified as struction of Facilities, Researchand Development,and Researchand Program Management.In somecases, such programs as the space QUULll..nh shuttle also fund environmental projects. NASA’S budget submissionsto the Congressidentify amountsto be spent from the Construction of Facilities appropriation for environmental projects-first approved as a separate line-item in its fiscal year 1988 budget request. NASA budgeted $23.9 million for environmental projects for fiscal year 1988 and $32 million for fiscal year 1991, although these amountsdo not include all the money spent agencywideto prevent, control, and abate environmental pollution. For fiscal years 1988-90,for example,NASA budgeted about $80 million from the Construction of Facilities appropriation account,while the total amount that NASA reported that it planned to spend in its Pollution Abatement Plan was $108 million. Projects funded from appropriations other than the Construction of Facilities account made up the difference. Although the Pollution Abatement Plan provides a more completepic- ture of environmental project costs,it doesnot include all costsof the environmental program. According to NASA officials, someexpenses not included are salariesof environmental staff, hazardouswaste disposal cost, contract servicesfor hazardouswaste handling and laboratory analysis, and small projects that are completedquickly.

Sharing the Cost With NASA expectsto receive someDOD funds for its share of contamination at ResponsibleParties someinstallations. However, NASA officials said they cannot rely on DOD contributions in the budget developmentprocess. DOD contributions to site cleanup costsare long-term negotiated items, with funds not immediately available for NASA’S cleanup work. BecauseDOD must also go * through a budget prioritization process,any DOD apportionment of costs will not necessarilybe available for use when NASA must accomplishthe work.

Page 17 GAO/NSIAD91-146 Environmental Protection chaptar 2 NASA Ia Fadng Varlotu Environmental Problema and Unknown Cleanup Cowa

Figure 2.1: Conwuction of Frcllltlor Budget for Envlronmental Projects by 20 Wlam (In mll2on8) Clam

24 22 20 18 16 14 12 10 2 0 4 2 0

1922 1989 Plqmed 1222 Floal Year

I I Claasl I I Class II

m Class Ill

Source: NASA

Page 19 GAO/NSIAD-91-146 Environmental Protection chapter 3 Ovemlgbt and Bhmgement of Environmental Frogram IWould Be Strengthened

SpaceFlight Center when it was seekingsomeone to evaluate its environmental program. At the Lewis ResearchCenter, where a lack of managementattention has causedcostly environmental damage,recent improvementshave been made.However, before 1989, senior managementassigned a low priority to the environmental program. Staff were not trained to manage the environmental function and did not notify senior managementof environmental concerns,including hazardoussubstance spills that were not immediately cleanedup. Additionally, the Center lacked adequate safeguardsto prevent illegal dumping of hazardouswastes. After the Center receivednegative media attention in 1989, senior man- agerstook decisivesteps to improve the environmental program. Man- agersreorganized the environmental function to provide greater authority and visibility, employedhighly qualified individuals, and included environmental protection responsibilitiesin senior managers’ performance plans. The Center also beganperiodic, unannouncedvisits to evaluate compliancewith environmental regulations.

Insufficient Resourcesand Someenvironmental offices, as discussedbelow, were not given suffi- Training at SomeCenters cient managementattention or resourcesto ensure effective performance of environmental responsibilities.As a result, environmental problemsthat could have been prevented or corrected may have occurred or continued.

Ames ResearchCenter The environmental coordinator at the AmesResearch Center was the only full-time civil servant assignedenvironmental responsibilities.The coordinator served multiple roles: regulatory specialist,hazardous waste program manager,and chemicalspill responsecoordinator. The coordinator told us that as a result of these many responsibilities,she had insufficient time to make complianceinspections of the Center’son-site hazardouswaste generating activities and commercialoff-site treatment, storage, and disposal facilities. At the time of our visit, Ameswas in violation of several county requirements relating to such matters as container management,labeling of hazardouswastes, training, and fire and spill control equipment. The environmental coordinator had issuedletters to responsiblemanagers to correct these deficienciesbut, becauseof time constraints, had been unable to verify that the facilities had complied.

Page 21 GAO/NSIAD-91-146 Environmental Protection chapter 8 Over&&t and Management of J3nvironmental Frogmna Should Be Strengthened

Marshall SpaceFlight In 1988 and 1989, Marshall’s Internal Control Office and a committeeon Center environmental activities cited a need for more Center involvement in environmental management.The groups also identified the need for Center guidanceand instructions on implementingaspects of the environmental program. In May 1990,the Marshall director approved the establishmentof an environmental office. At the time of our visit in July 1990,the Center employedtwo environmental engineersand by December1990, hired two more. However, as of February 1991,the Center had not issued managementinstructions on an environmental managementprogra m, a waste minimization policy, and spill prevention procedures. Furthermore, the Center’senvironmental coordinator told us that insufficient resourceshad hamperedthe office’s ability to identify environmental problems.However, even when environmental problemswere identified, the Center was slow to take action. For example,a 1989 EPA- sponsoredassessment of previously unregulated releasesto air, soil, and groundwater identified over 50 areasfor which further action, such as testing for environmental damages,were suggested.According to the environmental coordinator, no action has beentaken, except at one site, becausethe EPA assessmentwas in draft format. Only one of these potentially contaminatedsites is included in the Center’s5-year pollution abatementplan, used to project future needs.

Becauseof inadequate monitoring, NASA headquarters is not sufficiently Comprehensive informed to ensure that the centers comply with environmental laws Headquarters and regulations. NASA Instruction 8800.13 requires headquarters pro- Oversight Needed gram offices to ensure the overview and managementof centers’ imple- mentation of NASA environmental requirementsfunded from non- Construction of Facilities sources.The instruction also requires that the Facilities EngineeringOffice ensure the overview and managementof Construction of Facilities-fundedenvironmental activities, with program offices’ review. The instruction also requires Facilities Engineeringto support and guide program offices and centersin interpreting NASA’S environmental policy.

To improve monitoring, NASA needsa better and more comprehensive strategy for implementingits environmental policy than delegatingenvi- ronmental responsibility to centers without establishingspecific and

Page 22 GAO/NSIAD91-149 Environmental Protection cilapmr 8 OvermIght and Management of Environmental i%ogmnu Should Be Strengthened

Headquartersofficials believe that program office and Facilities Engi- neering staff need to work together more closelyto effectively monitor centers’ activities. This is consideredessential because progra m office staff, who can require centersto conduct specific activities, lack environmental expertise, while Facilities Engineeringstaff, who possessthe expertise, lack the authority to ensure centers’ compliancewith policies and regulations.

Compliance Not Enforced Headquartersprogra m managersoften did not exercisetheir authority by Headquarters Program to enforce the centers’ compliancewith environmental regulations and headquarters directives. Although they shared information about envi- Managers ronmental problemsexperienced among their centers,they did not ensure that the centersused this information to identify potential contamination or to better managetheir environmental programs. For example,in April 1989,the Lewis ResearchCenter ’sEnvironmental Pollution Control Board was told that a wind tunnel had been contaminated when mercury in the tunnel’s pressure gaugesspilled. Although the program office responsiblefor the researchcenters that use such tunnels informed its centers about Lewis’ problem, it did not require those centersto conduct a comprehensivecenter-wide mercury evaluation to determine if they were similarly contaminated.The Ames ResearchCenter, for instance,did not begin testing for mercury contamination until January 1991, becauseof other priorities and limited resources.

In another case,the Facilities EngineeringOffice tried to minimizeNASA'S potential liability for cleaningup off-site commercialtreat ment, storage, and disposal facilities. The Office proposedin October 1988, and issued in September1989, a policy requiring centersto annually audit all off- site facilities they use. However, one center visited did not conduct such audits and two centersonly audited somefacilities they use, even though their environmental coordinators believed that the audits were necessary.For example,in a January 1990 memo,a Goddard Space Flight Center official stated that the Center would not audit its off-site facilities becauseheadquarters did not provide the necessaryresources and becauseusing available resourceswould dilute higher priority efforts. The responsibleprogra m offices took no actions to enforce compliance.

Page 25 GAO/NSLADgl-146 Environmental Protection chapter 3 Overnight and Management of Environmental Programa Should Be Strengthened

A lack of emphasison environmental issuesby somecenter directors Conclusions and a lack of comprehensiveoversight by headquartershas hampered implementationof NASA'S policy on preventing, abating, and controlling environmental pollution, As a result, NASA may be permitting environmental problemsto occur or continue at somecenters, with the potential for additional cleanup costs. Although somecenters have improved their environmental programs in recent years, the quality and successof the programsvary considerably amongcenters. Several centers still lack adequateresources or trained personnelto carry out NASA'S environmental policy. Further, headquarters is not adequately overseeingand managingenvi- ronmental activities to ensure that the centers . comply with all relevant environmental laws and regulations; . effectively use information about the problemsencountered at other centerswith similar facilities or functions; and . conduct required inspectionsof off-site facilities used to treat, store, and disposeof hazardouswastes. In addition, more frequent and more detailed environmental audits could assistthe centers in identifying potential problemsbefore they require cleanup or enforcementaction.

Recommendations We recommendthat the NASA Administrator take the following actions: . Developan agencywidestrategy, including center-based,measurable goals,on implementingthe environmental pollution prevention, abatement, and control policy. . Establish standards on center environmental staff levels, qualifications, and organizational authority, and provide for mechanismsto identify funding requirements. . Developcriteria and guidelinesfor center reporting of imminent or actual noncompliancewith environmental regulations, new state and local regulatory requirementsbeing proposedor issued,and other items as appropriate.

l Require that problemsidentified at one center be addressedat other centers with similar facilities or functions.

l Establish an environmental audit program to evaluate, at least every 3 years, the centers’ regulatory complianceand managementsystems

Page 27 GAO/NSIAB91-146 Environmental Protection Page 29 GAO/NSIAD91-149 EnvIronmental Protection APPS* 1 Examplea of Envhnmental Problems

Goddard SpaceF light Center

Asbestosre moval: Flaking asbestosmust be removedfro m various Goddard’s Greenbelt, l Maryland Facility . buildings at an estimatedcost of $660,000. Underground storagetanks: Underground storagetanks will be replaced with above-groundtanks, if possible,or with a ResourceConservation and RecoveryAct (RCRA)underground storagetank system.The estimated cost is $1.3 million.

Goddard_._.~-. ’s- Wa_---ll01- ps Flight l Aviation storage tanks: Underground storagetanks built by the Navy in Facility, Wallops Island, 1943 as a fueling station and storage area and later used by Wallops have petroleum-relatedgroundwater contamination.The Center plans to Virginia take measuresto protect nearby drinking water well fields at an estimated cost of $4 million. . Scrapyard: In the 197Os,polychlorinated biphenyl (PCB)transfor mers, along with excessmetal wastes and batteries, were dumped in a scrapyard. When testing the site, Wallopsdiscovered that PcB-contaminated oil from the transformers had contaminatedthe soil. This project cost has not been determined.

l Sewagetreat ment plant contamination:During a December1989 RCRA inspection,Virginia inspectorsconcluded that Wallopswas operating a hazardouswaste treatment, storage,and disposal facility without a permit. The facility dischargedwaste from the electroplating and etching operation to the sanitary sewer system.Thus, the state contends that this dischargecontaminated the sewagetreat ment plant and wastewater treatment holding sites. The cleanup cost has not been determined.

Cleanup of groundwater contamination:Previous samplingand testing Jet Propulsion ’ of groundwater from City of Pasadenawater supply wells in the vicinity Laboratory, Pasadena, of the Laboratory have confirmed the presenceof trichloroethylene and other solvents in excessof federal and state standards. This project pro- California vides for the design and initiation of construction of a treatment facility to remove the volatile organic compoundsfro m municipal water sup- plies. The estimatedcost of this project is $4 million. 1 . Hazardoussubstance underground storagetanks: This project will provide funds for storage tank testing, soil testing, replacementof leaking

Page 81 GAO/N&ID-91-146 Environmental Protection Appendtx I Example of Jhvhnmental Problema

capping the landfill and installing a stormwater drainage system and monitoring systemat an estimatedcost of $7.6 million.

Langley Research 9 Remediationof Tabbs Creek:The creek has polychlorinated terphenyl residues.This project will clean up these residuesand possiblePCBs as Center, Hampton, determined by a site study and risk analysis.The estimatedcleanup cost Virginia is $4 million. . Underground storagetank spill and leak prevention: Existing tanks do not conform to the leak detection specificationsrequired by 1993. This project will provide corrosion protection, spillage,overfill prevention, and leak detection deviceson underground storagetanks at an estimated cost of $2.6 million. . Construction debris landfill: This project will provide clean up and remediation of an abandonedconstruction debris landfill, recently identified by a site inspection.Results were submitted to EPA and the State of Virginia, but EPA has not decidedon the level of cleanup.The estimated cost is $1 million.

Lewis Research ’ Remediationof South 40 area: The Center is investigating if landfilling and storage of drums, batteries, and PCB transformers in this area have Center, Cleveland, contaminatedthe soil and groundwater. Mercury contamination has Ohio already been confirmed and cleanup is estimatedat $3.2 million. . Underground storagetanks: This project will remove,replace, or protect, as necessary,42 underground storagetanks at Lewis and the Plum- brook Station to meet federal, state, and local regulatory requirements. The estimated cleanup cost is $4.8 million.

. Driller’s mud disposal site: Significant quantities of sodium dichromate Marshall SpaceF light solution and barium sulfate-baseddriller ’s mud were dischargedat this Center, Huntsville, site. One assessmentconcluded that a high potential exists for releaseof Alabama contaminantsto soils and groundwater. The Center plans to excavate 1,600 cubic yards of contaminatedmaterials and then fill and cap the excavated area at an estimatedcost of $1 million. . Industrial waste treatment basin: The Center stored electroplating wastes in an industrial waste treatment basin and two lagoons.NASA proposed closingthe basin and lagoonsin September1984, with a closure completiondate set for August 1986. However, the Alabama Department of Environmental Managementnoted significant differences amonggroundwater samplesfro m different wells. In September1988, the state cited the Center for failure to obtain additional groundwater

Page 33 GAO/NSIAJ&91-146 Environmental Protection Appendix II Major Contributorsto This Report

National Security and Charles F. Rey, Assistant Director International Affairs Division, Washington, D.C.

Dallas Regional Office Sandra H. Vice Site Senior Gerald W. Hopbmann,Evaluator

(397018) Page 36 GAO/NSIAD-91-146 Environmental Protection

,.. I”, .” ,... ..““. .__“,“l__l _“____-_ -~ ..ll_.l .^I ..-. lll.. “.” l..” ...I”.. .^_ .._ ^ “. ._,... ..” “. ., ExecutivtiveSumma ry

The National Aeronautics and SpaceAdministration (NASA) produces Purpose tons of hazardous wastes annually through its scientific research and development and routine operations and maintenance activities. Improper managementof these wastes may have caused and may continue to cause environmental pollution problems that must be corrected to prevent shutdown of some facilities by the Environmental Protection Agency (EPA) or state environmental authorities. Since 1988, NASAhas planned to spend more than $100 million on projects and studies to comply with environmental requirements. Concernedabout the potential impact on the environment and the government’s cleanup costs, the Chairman, SenateCommittee on Govern- mental Affairs, asked GAOto

l determine the extent of environmental problems confronting NASAand the corrective actions being taken or planned and

. assessNASA ’S managementof its environmental protection program.

Several laws, as well as EPA,state, and local regulations, govern federal Background agencies’management and disposal of hazardous wastes and the cleanup of contamination. In accordancewith these requirements, NASA'S policy is to prevent, control, and abate environmental pollution,

To carry out its policy, NASAuses a decentralized managementapproach. Its nine center directors are responsible for day-to-day compliance with environmental laws. At the headquarters level, program offices are responsible for overseeing and ensuring the managementof environmental protection actions at the centers they monitor, and the Facilities Engineering Office is the focal point for environmental compliance and protection matters.

Through its internal assessmentsand inspections by environmental reg- Results in Brief ulators, NASAidentified various environmental problems at its centers, including leaking underground storage tanks, exposed asbestos,and mercury spills. These problems have been traced to maintenance, industrial, and research processesand to the practices of previous military owners of someNASA centers. To correct the problems and to comply with environmental regulations, NASAhas undertaken or planned many costly projects. However, the total costs of these projects are unknown, partially becauseenvironmental costs are not always specifically identified in the budget. Also, for many contaminated sites, it is unclear what cleanup will be done until required studies are completed.

Page 2 GAO/NSIAD-91-149 Environmental Protection ExeentIve Summary

costs.In addition, NASAis uncertain whether the amountsit has budgeted for environmental projects will be sufficient becausethe scopeof somecomplex projects is difficult to determine and becauseenvironmental requirementsare becomingmore stringent. However, NASAhead- quarters officials believe the budget requestsrepresent the best assessmentof funds neededto meet the most urgent requirements known or anticipated at the time the budget is prepared.

Centers’ Emphasis on Of the five centersvisited, two gave environmental issueshigh priority Environmental Issues and provided their environmental offices with sufficient resourcesto carry out NASA'S policy. The other three centers’ environmental offices Varies lacked sufficient, adequately trained staff and resourcesto monitor operations and effectively carry out their responsibilities.

For example,the environmental coordinator at the AmesResearch Center was the only full-time civil servant assignedenvironmental responsibilities.The coordinator served as a regulatory specialist,hazardous waste program manager,and chemicalspill responsecoordinator. Thus, she did not have the time to inspect commercialoff-site treatment, storage, and disposalfacilities used by the Center. NASA requires these inspectionsto limit the agency’spotential liability. Somecenters were aware of deficienciesin their environmental programs and had recently made improvements.For example,the Wallops Flight Facility, associatedwith the Goddard SpaceFlight Center, created an environmental office in 1990 and hired additional staff.

Headquarters Oversight Although headquarters is to ensure that the centerscarry out their envi- and ManagementNeed to ronmental responsibilities,it was at times unaware of problemsexperi- encedby the centers and did not exerciseits authority to require the Be Strengthened centersto conduct neededenvironmental activities. Programoffice staff, who can require centersto conduct specific activities, lack environmental expertise, while Facilities Engineeringstaff, who possessthe expertise, lack the authority to ensure centers’ compliancewith policies and regulations.

Headquarters program managersshared someinfor mation about environmental problemsexperienced among their centers,but they did not ensure that the centersused this information to identify potential contamination. For example,in April 1989,the Lewis ResearchCenter ’s Environmental Pollution Contra1Board was told that its wind tunnel

Page 4 GAO/NSIAD-91-149 Environmental Protection Executive Summary 2 Chapter 1 8 Introduction Federal Agency Environmental Requirements 8 Prior GAO Reports on NASA’s ComplianceWith 8 Environmental Regulations Organizational Structure and Responsibilities 9 Funding for Environmental Projects 10 Objectives,Scope, and Methodology 11

Chapter 2 13 NASA Is Facing Origin of Environmental Problems 13 Types and Extent of Environmental Problems 14 Various Cost of Complianceand Restoration Activities 16 Environmental Problems and Unknown Cleanup costs

Chapter 3 20 Oversight and Centers’ Emphasison Environmental ProgramsIs 20 SometimesInadequate Management of ComprehensiveHeadquarters Oversight Needed 23 Environmental Environmental Audits: Current Problemsand a Potential 26 Solution Programs Should Be Conclusions 27 Strengthened Recommendations 27

Appendixes Appendix I: Examples of Environmental Problems 30 Appendix II: Major Contributors to This Report 36

Figure Figure 2.1: Construction of Facilities Budget for Environmental Projects by Class

Page 0 GAO/NSIAD4l-1443 Environmental Protection Chapter 1 Introduction

In carrying out its scientific researchand developmentmission, the National Aeronautics and SpaceAdministration (NASA)generates, stores, and disposesof tons of hazardouswastes, such as solvents, acids, and heavy metals (e.g.,mercury). Exposure to someof these wastes in large dosescan pose immediate health threats, long-term illness, or even death. When no longer needed,these wastes are treated, stored, or disposedof-often at commercialoff-site facilities. NASAmust ensurethat ita facilities comply with environmental requirementsor face possible shutdown by Environmental Protection Agency (EPA) or state environmental authorities.

While NASA headquarters is responsiblefor overseeingfacilities, its nine centers manageand control their own activities, including environmental protection, within broad NASA directives and budgetary guidelines and constraints. Thesecenters have different missions,such as developing space-basedshuttle payloads and spaceshuttle launches and providing aeronautical and aerospacetesting capabilities.

To regulate the managementand- disposal of hazardouswastes and the Federal Agency cleanup of contamination, the Congresshas passedSeveral major envi- Environmental ronmental statutes, such as the’ResourceConservation and Recovery Requirements Act (RCRA) and the ComprehensiveEnvironmental Response,Compensa- tion, and Liability Act (CERCLA).Federal facilities are subject not only to federal but also to state and local environmental standards. In addition, Executive Order 12088,dated October 13,1978, requires the headsof executive agenciesto ensurethat all necessaryactions are taken to prevent, control, and abate environmental pollution at facilities under their control.

In previous reports,l we assessedcivilian agencies’,including NASA'S, Prior GAO Reports on compliancewith RCRAand CERCLArequirements. In 1984,we reported NASA’s Compliance that NASAwas unaware of a CERCLArequirement to notify EPAof facilities With Environmental where hazardoussubstances had been stored, treated, or disposedof. In 1987,we reported that NASAhad physically inspectedits facilities to Regulations locate hazardouswaste sites and, as of September1986, regarded its site discovery efforts as complete.Another report in 1986 found that federal agencieshad been slow in developing an awarenessand understanding

‘Statusof CivilianFederal Agencies Efforts’ to AddressHazardous Waste Problems on Their Lsnds (-@pt. 28 1084 S perfun&Civilisn Federal Agencies Slow to CleanUp Hsz- ardousWssk (GAO/RCED-&-153,%~ 24 1987 d HszsrdousWaste: Federal Civil Agencies slowto ComplyWith Regulatory Requiremeks (&r/R-, May6,1986).

Page 8 GAO/NSIAD-91-146 Ehvironmental Protection chapter1 lntroduct4on

l Office of SpaceScience and Applications

l Goddard SpaceFlight Center

l Jet Propulsion Laboratory

l Office of SpaceFlight . JohnsonSpace Center . Kennedy SpaceCenter

l Marshall SpaceFlight Center . StennisSpace Center

Center directors are responsiblefor implementing NASA’s environmental policy. They therefore must plan, design,construct, manage,operate, and maintain facilities accordingto applicable environmental regulations and provide timely responsesand appropriate remedial actions to addressenvironmental compliancerequirements. The directors execute the agency’stechnical and administrative programs within budgetary guidelines and generally allocate budgetedresources among various center functions as they deemappropriate.

NASA environmental projects are funded from various appropriations Funding for that do not specifically identify the funds allocated to those projects. Environmental However, NASA’s budget submissionsto the Congressset forth amounts Projects to be allocated from the Construction of Facilities appropriation for environmental complianceand restoration project funding. Headquar- ters allocatesfunds from the Construction of Facilities appropriation account to the centers for specific environmental projects. At the center directors’ discretion, funds from other appropriations may also be used for environmental projects. The centers’ appropriations therefore do not pinpoint the costsof environmental projects. Another source for ;(lentifying the potential cost of environmental projects is through F;JAsAPollution’s Abatement Plans.Federal agencies prepare these plans for the Office of Managementand Budget to ensure their continuing compliancewith new regulatory requirementsor to correct problems or violations identified by EPA or the states.At NASA, each center reports to the Facilities EngineeringOffice the environmental projects that it plans to undertake for the next 6 years. The Office then submits the agency’soverall plan and estimated coststo the Office of Managementand Budget through EPA. If approved, NASA projects

Page10 GAO/NSIADBl-148EnvironmentalProtection Chapter 1 introduction

. NASA’s&year Pollution Abatement Plans for its centersand satellite installations and budget submissionsfor the Construction of Facilities appropriation; and l environmental audits, preliminary assessments,and site inspections. Additionally, at the program offices, we reviewed correspondencefiles to determineproble msexperienced by the centers and satellite installations that we did not visit. We also determinedhow the program offices prioritize environmental projects and how they monitor and manage operations at the centersthey oversee.

To determine the status of environmental activities at the centers,we reviewed studies,budget data, inspection files, and managementinstructions and guidance.We also toured the facilities to observehazardous waste-generatingactivities and storage areas,as well as contaminated sites. However, our work at the Lewis ResearchCenter, whose Office of Inspector Generalwas in the processof reviewing its environmental managementprogra m, consistedof a briefing by center managementon environmental problemsand the corrective actions taken, and a tour of the facility.

We also interviewed EPAofficials to discussfederal facility requirements and the relative status of NASA’S environmental activities comparedwith those of other federal agencies. We conductedour work from July 1990 to February 1991 in accordance with generally acceptedgovernment auditing standards. We discussed our findings with NASAofficials and incorporated their commentswhere appropriate. As requested,however, we did not obtain official comments on this report.

Page 12 GAO/NSIAD-91-146 Environmental Protection NASA Is Facing Variona ICnvIronmental Problem and Unknown Cleanup Costa

Jet Propulsion Laboratory, and the WallopsFlight Facility, all formerly owned by the Department of Defense(DOD), are experiencingground- water contaminationthat appearsto have resulted from activities conducted under DOD ownership. Given that DOD is one of the federal government’smost seriouspolluters2 and that 6 NASAcenters and 10 satellite installations have beenpreviously owned by DODor have had tenant relationships with DOD, further pollution attributable to DODmay still be found on NASAproperty.

While the extent of contamination and regulatory noncompliancevaried Types and Extent of amongthe centersvisited, all had problems and had taken or planned Environmental corrective actions. Someof these actions are neededto meet regulatory Problems deadlines,and others are neededto clean up contamination that poses significant risk to human health and the environment. NASAhas set priorities accordingto such risks and is correcting its most serious problems first. Where corrective action has been slow, however, state regulatory agencieshave taken enforcementactions.

Environmental Project Environmental projects are scheduledfor implementationaccording to a Priorities three-tiered classification defined by EPA.The highest priority, ClassI, includes projects for facilities that are out of regulatory compliance. ClassII projects are neededat facilities that are not yet out of compliance but need to meet an upcomingcompliance deadline. Class III projects include those which are neededand are important to environmental quality, but are not directly related to a complianceissue. Fol- lowing are examplesof environmental projects, by class,submitted by someof the centers: . ClassI: Storm drains flowing into San FranciscoBay have contaminated the bay with toxins, and wildlife has died in the marshlands.The Ames ResearchCenter plans to install an oil/water separation systemto remove toxins from the storm drains.

l ClassII: The Marshall SpaceFlight Center has planned a multiyear program to replace 44 underground tanks used to store petroleum products and hazardoussubstances. Regulations require all such tanks to meet new standards.

l ClassIII: The Johnson SpaceCenter repaired its underground sewer systemto prevent leaks.

2FederalLiabilities Under Hazardous Waste Laws, Congressional Budget Office, May 1090.

Page 14 GAO/NSIAD-91-146 Environmental Protection chapter 2 NASA lo Fadng Varhw Environmental Problemr and Unknown Cleanup Cada

Similarly, in August 1989,the Virginia Department of WasteManage- ment ordered the WallopsFlight Facility to (1) comply with state regulations when shipping hazardouswastes and (2) develop a contingency plan, a waste analysis plan, and a written inspection schedule.However, a December1989 state inspection,which cited 41 violations,3found that Wallopswas still not complying with various hazardouswaste management regulations and had not developeda detailed contingencyplan. Furthermore, the state cited Wallopsfor disposingof hazardouselectro- plating and etching wastes improperly and without a permit at an on- site location. Wallopsenvironmental staff told us they had not acquired the necessaryper mit becausethey were unaware that the wastewater from the operation was consideredhazardous. State environmental authorities consideredthese violations of such a seriousnature that they referred the matter to the state Environmental EnforcementSection. According to a headquarters program office manager, the sewagetreat ment plant that receiveselectroplating and etching wastewaterswas subject to closure as an illegal operation. According to the Chief of the EnforcementSection, as of February 1991, state and Wallopsofficials were still negotiating actions Wallopsmust take to correct these violations.

Potential NASA Becauseagencies retain liability for their wastes regardlessof where Responsibility for they are disposed,NASA may be liable for cleanup costsat commercial waste disposal facilities it has used. EPAhad inquired about all five cen- Problems at Off-Site Waste ters’ transactions with contaminatedcommercial sites. In one case,EPA Facilities linked NASAto a low-level radioactive disposalsite, Maxey Flats in Morehead,Kentucky. Of 662 potentially responsibleparties, NASAwas ranked as the 18th largest waste contributor, accountingfor 1.3 percent of the wastes.

The total cost of NASA'Scompliance and restoration activities is unknown Cost of Compliance partially becausefunds for environmental projects, activities, and and Restoration staffing are not fully identified in the budget or in NASA'SPollution Activities Abatement Plans.Also, NASAdoes not know whether the amountsit has budgetedto clean up identified problemswill be sufficient because

3Thestate issued violations to Wallop’mains base and island complex separately, because it consid- eredthem separate facilities requiring different hazardous waste generator identification numbers. Thus,several of theviolations were repeated.

Page 16 GAO/NSIAD-91-146 Environmental Protection Chapt8r 2 NASA Ie Fadng Varions Environmental Problerrm and Unknown Cleanup Cogtn

To date, DODhas not transferred funds to NASAfor its share of cleanup costsat any NASAfacility. However, accordingto a NASAheadquarters official, the Army’s Corps of Engineersinstalled somewells at the Jet Propulsion Laboratory to monitor groundwater and provide background data in support of an on-goinginvestigation.

Estimating Future Costs NASAdoes not know how much future cleanupswill cost for those environmental problemsit has already identified. For someprojects, such as upgrading hazardousmaterial storage areas,the costscan be accurately estimatedbecause the scopecan be easily defined and the work can be completedwithin a short period. For complexprojects, however, the scopeand corrective actions depend on results of remedial investiga- tions and feasibility studies, making it difficult to predict how long cleanup will take and what it will cost.

In its Pollution Abatement Plan, NASAhas reported about $34 million and $60 million, respectively for fiscal years 1991 and 1992 environmental projects. Also, NASAheadquarters estimatesit needs$32 to $60 million annually in its Construction of Facilities budget request over the next 6 years to addressenvironmental projects and activities, but it is uncertain whether this is sufficient. NASAheadquarters officials believe the budget requestsrepresent the best assessmentof funds neededto meet the most urgent requirementsknown or anticipated at the time the budget is prepared. However, headquarters and center officials believe that the cost of planned and future complianceand restoration projects will increasebecause of stricter environmental requirements,such as those restricting the land disposalof hazardous waste.4Also, someplanned projects that have not yet receivedEPA or state approval may have to be revised as new regulations are issued. With the passageof stricter regulatory requirements,the approach of regulatory deadlines,and the approval of cleanup plans, the number of classI projects is expectedto increase.Since fiscal year 1988, the Con- struction of Facilities account for classI projects has steadily increased from $8.6 million to a proposed $27 million in fiscal year 1992. In con- trast, funding for classII and III projects decreasedfro m fiscal year 1988 to 1991, with no funding proposedfor classIII projects in fiscal years 1991 and 1992.(See fig. 2.1.)

4TheHazardous and Solid Waste Amendments of 1984 prohibit the continued land disposal of hazardouswastes beyond specified dates unless such wastes are granted variances or aretreated to meet EPAstandards. Land disposal includes any placement of hazardouswastes in, for example,surface impoundments,landfills, waste piles, and injection wells.

Page 18 GAO/NSIADBl-146 Environmental Protection Chapter 3 Oversight and Managemenoft Environmental ProgramsShou ldBe Strengthened

A lack of emphasison environmental issuesby somecenter directors and a lack of comprehensiveguidance and oversight by NASAheadquar- ters may have contributed to someof the centers’ environmental problems discussedin chapter 2. Centersgenerally focusedon cleaning up identified environmental damagerather than preventing and controlling future pollution and the resulting cleanup costs.Although somecenters have recently improved their environmental managementprograms, more needsto be done to ensurethat centers carry out NASA'spolicy to prevent, abate, and control environmental pollution.

Centers’ Emphasis on NASAInstruction 8800.13 requires center directors to Environmental . prevent, control, and abate environmental pollution at their centers; report progressto headquarters in meeting the objectivesof centers’ Programs Is Pollution Abatement Plans; SometimesInadequate : establish an environmental oversight coordinator with responsibility for prevention, control, and abatementof environmental pollution; and . establish and maintain internal environmental compliancecontrols. However, due to inadequatemanagement emphasis, the environmental organizationsat somecenters lacked adequateresources, including trained specialists,to monitor operations and effectively carry out their programs. The environmental programs at other centers were more suc- cessful, due to either managementcommitment or recent improvements made as a result of negative publicity.

ManagementAttention The Johnson SpaceCenter has made a strong commitment to environmental protection. The Center director establishedan environmental Noted at SomeCenters office in 1986 and has staffed it with four environmental experts with regulatory experience,each with a different area of responsibility, such as hazardouswaste. Environmental compliancehas received top managementattention, including developmentof instructions on waste disposal, spill prevention and response,and waste minimization. At the time of our visit, the JohnsonSpace Center had no outstanding violations and only one contaminatedsite, which it was cleaningup. It was also pursuing an aggressivewaste minimization program, as certified by an independentcontractor.

NASA’sFacilities EngineeringOffice considersJohnson ’senvironmental program to be one of the agency’sbest managed.For example,the Office recommendedJohnson ’senvironmental coordinator to the Goddard

Page 20 GAO/NSIADBl-1443 Environmental Protection chapter 8 Ovemight and Mamgenwnt of Environmental Pmgmna Should Be Strengthened

The environmental coordinator also said she was unable to ensure that sound environmental procedureswere practiced at the off-site facilities the Center usesdue to limited resources.NASA requires off-site facility inspectionsto limit the agency’spotential liability for cleanup of such facilities. Ames’current environmental support contractor disposesof the vast majority of the center’s wastes at its own treatment, storage, and disposal facilities. Therefore, it may not be reasonableto rely on the support contractor to inspect its own facilities.

Goddard SpaceFlight Goddard’senvironmental office, responsiblefor both Goddard’sGreen- Center belt, Maryland, and WallopsIsland facilities, was headedby an experiencedenvironmental coordinator. The two additional employees, however, had receivedlittle training in environmental requirements. Oneemployee, stationed at Wallops,was trained as a safety engineer, and the other, stationed at Greenbelt,was trained as a fire protection specialist. At the time of our visit, the WallopsFlight Facility was not complying with various environmental regulations and was facing potentially significant cleanups.As previously discussed,the Virginia Department of WasteManagement ordered Wallopsto comply with hazardouswaste and other regulations. The order also required Wallopsto identify staff positions involved in hazardouswaste management,develop a written job description for each position, develop a training program for these positions, and submit documentationthat training had occurred.

Additional managementand complianceproble mswere found when the JohnsonSpace Center ’senvironmental coordinator evaluated the Wal- lops environmental program in March 1990. This evaluation, made at the request of the Goddard SpaceFlight Center, concludedthat Wallops’ environmental program was not effectively organized,lacked management directives, and was not in compliancewith somebasic waste storage and disposalenvironmental requirements.Of the nine recom- mendationsmade by Johnson’senvironmental coordinator, Wallops agreedwith eight and by February 1991 had taken action on seven. Recentimprovements have beenmade at Goddard. Recognizingthat its environmental program neededrestructuring and was understaffed, in 1990 the Goddard Center director establishedan environmental office. That sameyear, the Center hired an experiencedenvironmental engineer for the Greenbeltfacility. Also, at the time of our visit, Wallopswas in the processof hiring another environmental engineer.

Page 22 GAO/NSIAIb@l-1ILB Environmental Protection Chfwter 8 Ovemlght and Management of Environmental Progmma Should Be Strengthened

measurableenvironmental goals and methodsto review the accomplish- ment of such goals.For example,such a strategy could include specific objectivesand goals for each center to

. reduce the amountsof hazardouswaste generatedthrough waste minimization, resourcerecovery, and recycling programs, and

l conduct training activities to ensurethat appropriate personnel are pro- ficient in their responsibilities.

Ineffective Headquarters Although headquarters is to ensure that the centerscarry out their envi- Monitoring ronmental responsibilities,it has an ineffective systemfor monitoring the centers’ environmental programs. Moreover,monitoring and sup- porting centers’ environmental programs is only one task that headquarters program offices and Facilities Engineeringmust do. Thus, headquarters was unable to devote much time to monitoring centers’ compliancewith environmental policies and regulations.

According to the Chief of the Facilities EngineeringOffice, Environ- mental ManagementBranch, headquarters relies on the centersto properly report their environmental problemsand doesnot have a mechanismto ensure that the centers do so. For example,the Assistant AssociateAdministrator for Facilities Engineeringwas surprised to learn on August 3 1,1989, that the AmesResearch Center was expected to sign an EPAorder by September11, 1989, for its contribution to contamination at a Superfund site. Becausehis office was unaware that negotiations betweenEPA and other parties had reachedthis advanced stage and had not been notified of the resulting funding requirements, no funds for this project had been budgetedfor fiscal years 1990 or 1991. To avoid further problems,in June 1990 the Facilities Engineering Office requestedthat centers inform the Office whenever an environmental regulatory agencyissues a violation or beginsan enforcement action. EPArecently began sendingto the Office a list of NASAfacilities that had been issuedan EPAor state violation or enforcementaction. However, the Chief of the Environmental ManagementBranch said that this additional information doesnot guarantee complete,pro mpt disclo- sure of the centers’ problemsbecause proble mscould surface after an EPAor state inspection and becausethe EPAlist excludeslocal inspection results.

Page 24 GAO/NSIAD-91-146 Environmental Protection Chapter 3 Oversight sndManagement of EnvIronmental Progmma Should Be Strengthened

NASA requires environmental complianceaudits at centersevery 6 years, Environmental Audits: and it is currently planning its secondround of audits. EPAbelieves that Current Problems and environmental auditing, if properly conducted,can improve a facility’s a Potential Solution compliancewith environmental requirements.However, questionshave been raised about the infrequency and quality of the NASA contractor audits.

The Director, EPAOffice of Federal Facility Enforcement,said that although EPAdid not formally require environmental audits or suggest the frequency of such audits, conducting audits every 6 years was too infrequent to serve as an effective managementtool. The Director sug- gestedthat NASA audit its large centersevery 2 years and its smaller centersevery 2 or 3 years. As another option, the U.S. Navy has estab- lished a flexible auditing policy that requires more frequent audits where managersbelieve greater environmental risks exist. Navy policy requires audits no later than 6 months after an activity has been cited for significant environmental violations. In addition, three of four environmental coordinators we interviewed questionedthe quality and attention to detail of contractors’ environmental audits. Commoncriticis ms were that contractors reported only what center officials told them and that contractors failed to identify significant complianceproble ms,such as the need for permits required by federal, state, and local regulatory agencies.Most coordinators agreedthat a more successfulapproach would be to establish contractor-supported audit teamsof NASAheadquarters and center environmental experts who are more familiar with NASAoperations. A successfulprecedent to this approach was demonstratedin March 1990, when the JohnsonSpace Center environmental coordinator evaluated the WallopsFlight Facility’s program at the request of Goddard Space Flight Center management. A commonconcern of headquarters and center officials was that environmental complianceproble msdiscovered through environmental audits might lead to the demandsthat problemsbe immediately corrected without due regard to other concerns,costs, or budget priorities. For its part, EPAhas taken steps to encourageenvironmental auditing in light of these concerns.It has pledgedits assistancein finding cost- effective solutions to agencyenvironmental problemsand has stated that it will refrain from routinely requesting internal audit reports.

Page 26 GAO/NSIADBl-146Environmental Protection chapter 3 Overnight and Management of Environmental Programa Should Be Strengthened

for ensuring compliance.Audits should be conductedby headquarters and field officials and supported by contractors.

Page 28 GAO/NSIAD91-146 Environmental Protection Appendix I Examplesof ErwironmentalPrgb lems

This appendix presentsexamples of environmental problems identified and potential corrective actions for the National Aeronautics and Space Administration’s (NASA)nine centers and someof the centers’satellite installations. NASA’Sestimated costs for the projects are included where available.

l Super-fundsite: The Environmental Protection Agency (EPA) identified Ames Research the Center as contributing to a contaminatedgroundwater plume Center, Moffett Field, flowing north to the San FranciscoBay under the Center. EPAdirected California the Center to negotiate a joint responsibility agreementwith the compa- nies primarily responsiblefor the Superfund site, becausepetroleum from the Center’sleaking underground storagetanks will eventually join the plume. The Center’sestimated cleanup cost is $1 million. . Underground air storage facility: The Center has an abandonedunder- ground air storage facility, made up of 60 storagetanks, which previously stored highly pressurizedair used in wind tunnel testing. These tanks extend approximately 1,200feet into the ground and penetrate four aquifers. While the deeper aquifer is a sourceof drinking water for the Bay area, the shallow aquifers are contaminatedwith petroleum products and solvents. Oneof these high pressuretanks has ruptured and causedgroundwater to spurt from the deeperaquifer to the surface. The Center fears that ruptured tanks may eventually provide conduits betweenthe aquifers and contaminatethe drinking water supply. The Center plans to keep the aquifers separatedby permanently sealingthe air tanks. The estimated cost is $1.3 million, but becausethe Center is unsure whether the proposedmethod will work, it has reserved an additional $660,000for an alternate method.

l Aircraft ramp: The soil and groundwater north of the aircraft ramp are contaminatedwith solvents and fuel components.The Center plans to excavate contaminatedsoil or treat it, at an estimated cost of $1.2 million.

l Storm drain compliance:Storm drains flowing into the San Francisco Bay have contaminatedthe bay with toxins and wildlife has died in the marshlands.To comply with state and local laws, the Center plans to spend about $1.7 million to enhancewastewater treatment by installing an oil/water separation system,connecting drains and overflow lines to the sanitary sewer system, and relocating the existing main storm drain channel.

Page 80 GAO/NSIAD-91-146 Jhvironmental Protection Appendix I Exnmplw of Emlronmental Problemm

tanks, installation of monitoring systems,tank removal, and excavation and disposal of contaminatedsoil. The estimatedcost is $2.6 million.

Thermochemicaltest area: The Center’smonitoring wells have detected Johnson SpaceCenter, l freon contamination in the subsurfaceof this area, requiring cleanup. Houston, Texas Additionally, a 1990 state inspection identified concernswith the Center’ssystem for collecting stormwater/processwater from the test area. As a result, the Center plans to assessthe contamination,re me- diate the area, and install an above-groundtank systemto collect potentially contaminatedrunoff. The total estimatedcost for these projects is $2.9 million.

Johnson’s NASA Industrial0 Chemicalstorage building: Hazardouschemicals that support shuttle Plant, Downey, California production are stored throughout the facility in storage areasthat do not meet OccupationalSafety and Health Administration or 1988 fire codesor military temperature and humidity control specifications.The planned project will construct a centrally controlled storage building to comply with these specificationsat an estimatedcost of $606,000.

Johnson’s White Sands l Fuel scrubber and oxidizer fume exhaust systems:This project is Test Facility, Las Cruces, required to comply with RCRA,the CleanAir Act, and Occupational Safety and Health Administration regulations. The estimatedcost to New Mexico replace overloaded and wornout equipment is $1.1 million. 9 Groundwater and soil contamination:EPA ordered White Sandsto assess the extent of contamination and associatedpublic health risks resulting from improper releasesof freon and trichloroethylene. The estimated cost is $33.1 million, including $18.1 million for the assessmentand $16 million for corrective actions,if necessary.

. Flight crew rescuetraining area: A survey identified contaminated Kennedy Space groundwater consistingof several volatile organic compounds,including Center, Florida trichloroethylene. A study will further define the level and extent of contamination, as required by ComprehensiveEnvironmental Response, Compensation,and Liability Act (CERCLA),at an estimatedcost of $660,000. . Schwartz Road landfill: As of November 1989,the landfill was projected to have another 2 years of capacity. If the landfill is not expanded,it will have to be closedto comply with federal regulations. This involves

Page 32 GAO/NSIAJJ-91-146 Environmental Protection APP~- 1 Jhamplm of Environmental Problema

samplesfro m downgradient wells, where a significant difference occurred. In July 1990,the state ordered the Center to submit a comprehensive groundwater quality assessmentplan. The estimatedcost for this plan has not yet been determined.

Marshall’s Santa Susana l Groundwater contamination:NASA used this facility to test rocket Field Laboratory, Ventura engines,and waste fuel residuals from the enginescontaminated the groundwater with trichloroethylene. This project will define and design County, California treatment strategies and treat groundwater to meet a federal and state complianceschedule. The estimatedcost of the project is $30 million. . Container storage area: The current facility is undersized,uncovered, and cannot properly segregatewastes by characteristics.This project to expand and upgrade the storage facilities will ensure RCRA compliance and reduce the generation of hazardouswaste. EPAhas issueda noncom- pliance warning letter. The estimatedproject cost is $360,000.

. Hazardousmaterial handling facility: Presentfacilities are inadequate Stennis SpaceCenter, for future growth. A new facility will be designedfor handling the Mississippi increasedquantities of hazardousmaterials. The estimatedcost is $310,000.

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