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Evaluation of Army Recovered Chemical Warfare Materiel Response Actions DODIG-2018-042

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Background:

The DoD designated the Secretary of the Army as the DoD Executive Agent for the RCWM Program in the United States. The Secretary of the Army further delegated Executive Agent responsibilities to the Assistant Secretary of the Army for Installations, Energy and Environment (ASA[IE&E]). The U.S. Army Corps of Engineers (USACE) is a key executing organization for RCWM planned responses and is responsible for environmental restoration, operational range clearance, and other RCWM-related field activities. The Recovered Chemical Materiel Directorate (RCMD) is the other key executing organization and provides centralized management and direction for the assessment and disposal of RCWM.

USACE is the lead Army agency for remediation activities and intrusive investigations and RCMD is the lead Army agency for destruction activities. However, in this report, the term “Army” refers to any subordinate Army entity involved in the RCWM Program, such as USACE and RCMD.

 

Finding:

The Army’s remediation activities in progress at the SVFUDS complied with the Army Interim Guidance and the U SACE E P 75-1-3. In addition, the Army performed a preoperational survey at RSA for an intrusive investigation that complied with the Army Interim Guidance and the USACE EP 75-1-3. Finally, the Army performed a preoperational survey for a destruction activity at JBMDL that complied with applicable portions of the Army Interim Guidance.

Although we determined that the Army complied with the Army Interim Guidance and the USACE EP 75-1-3 at the SVFUDS, RSA, and JBMDL, we also found that the guidance documents did not comply with Army Regulation (AR) 25-30, “Army Publishing Program,” June 3, 2015. AR 25-30 sets the currency standard for Department of the Army publications at 5 years. In addition, temporary directives are in effect for 2 years or less. The Army Interim Guidance was published 8 years ago, and the USACE EP 75-1-3 was published 13 years ago. Updated policy is necessary to ensure that procedures, terminology, and designations are current and accurate for organizations that are responsible for executing requirements.

 

Recommendation:

We recommend that the ASA(IE&E), as the Executive Agent for the RCWM Program, issue policy to replace the Army Interim Guidance and direct the Commander, USACE, to update the USACE EP 75-1-3, to comply with AR 25-30.

 

Management Comments and Our Response:

The Deputy Assistant Secretary of the Army for Environment, Safety and Occupational Health, responding for the Assistant Secretary of the Army for Installations, Energy and Environment, agreed with our finding and recommendation.

The Deputy Assistant Secretary stated that the Army has drafted Department of Defense Manual (DoDM) 5101.17, Volumes 1 through 3, “DoD Recovered Chemical Warfare Materiel Program Guidance.” The Deputy Assistant Secretary further stated that the draft DoDM, which will replace the Army Interim Guidance, should be submitted for formal coordination by February 28, 2018. Once DoDM 5101.17 is submitted for formal coordination, the Deputy Assistant Secretary’s office will work with USACE to update USACE EP 75-1-3.

Comments from the Deputy Assistant Secretary of the Army for Environment, Safety and Occupational Health addressed all the specifics of the recommendation. Therefore, the recommendation is resolved but remains open. We will close the recommendation once we verify that DoDM 5101.17, Volumes 1 through 3, and the updated USACE EP 75-1-3 have been published.