July 7, 2016 —
Our objective was to inspect military-occupied facilities at King Abdullah II Special Operations Training Center (KASOTC) to verify compliance with DoD health and safety policies and standards regarding the electrical and fire protection systems and to conduct a radiological assessment to determine whether background radiation levels from foreign building materials pose an unacceptable health risk.
We found significant deficiencies in electrical and fire protection systems during the physical inspections of the U.S. military-occupied facilities at KASOTC. We identified a total of 286 deficiencies that could affect the health, safety, and well-being of warfighters: 154 related to fire protection and 132 related to electrical systems. Based on our evaluation, the majority of deficiencies resulted from insufficient inspection and inadequate maintenance of the facilities attributable to the lack of a maintenance and inspection plan.
Of the total deficiencies, 77 were critical, requiring immediate action; therefore, we issued a notice of concern (NOC) to the Commanders of U.S. Central Command (USCENTCOM) and U.S. Army Central (USARCENT). We received a response to the NOC on October 9, 2015, which provided a mitigation plan. In the mitigation plan, the Director, CENTCOM Forward-Jordan, in a memorandum through the Commander, USARCENT, requested that three of the deficiencies identified be re-evaluated as he believed the deficiencies were not violations of applicable regulatory guidance. After reevaluating the codes and standards and consulting with subject matter experts, we stand by our original recommendations.
For the radiological assessment, the health physicist team measured external radiation of indoor facilities and adjacent outdoor areas as well as the contact radiation surface of building materials at KASOTC to evaluate background radiation levels from cosmic and terrestrial sources (natural background) and from building materials. The annual individual dose at KASOTC was determined to be comparable to the average annual background external radiation dose individuals receive in the United States (less than 1.0 mSv). At these levels, there are no demonstrable radiation-induced health effects.
We recommend that the Commander, USARCENT, for both Finding A (Electrical System Deficiencies) and Finding B (Fire Protection System Deficiencies):
- Conduct a root-cause analysis and implement a corrective action plan for all 286 deficiencies identified in this report.
- Create and execute a plan for ongoing inspections and maintenance of all U.S. military-occupied facilities at KASOTC and other locations under the Commander, Combined Joint Operations Center-Jordan (CJOC-J). Ensure that inspection and maintenance of these locations complies with applicable electrical and fire protection safety codes and standards.
Management Comments and Our Response
The Commander, USARCENT, agreed with our findings and recommendations. He concurs and supports the work being performed to correct the deficiencies as addressed in the March 2, 2016, memorandum from the Commander, CJOC-J. The Commander, CJOC-J reported that of the 286 electrical and fire protection systems deficiencies found in our inspection, CJOC-J has corrected a total of 109 deficiencies (82 electrical and 27 fire), and will correct an additional 45 electrical and 61 fire deficiencies via a contract modification to the KASOTC Base Life Support (BLS) contract, effective March 30, 2016. For the remaining 71 deficiencies (5 electrical and 66 fire), however, the Commander, CJOC-J stated that Armed Forces-Jordan will submit waiver requests, along with safety mitigation measures, for deficiencies where appropriate corrective measures would be cost prohibitive or impede the operational mission of the occupying unit. Comments from the USARCENT Commander only partially addressed the specifics of the recommendations.
Our report recommends a root-cause analysis and corrective action plan for all 286 electrical and fire protection deficiencies, whereas the Armed Forces-Jordan plans to submit waivers for 71 deficiencies. The Commander, USCENTCOM, is granted authority by DFARS 246.270-3 to waive compliance with UFC 1-200-01 when it is “impracticable to comply with such standards under prevailing operational conditions.” However, we believe that all of deficiencies found are safety related issues and create hazardous environment for the health and life of the occupants. Rectifying these deficiencies will eliminate the hazard, but with mitigation the hazards remain. Consequently, the occupants are still potentially exposed to the unsafe environments. Also, we believe that rectifying these deficiencies would not be expensive nor interrupt the operational mission. Neither USARCENT nor USCENTCOM responses provided adequate evidence to support a justification of the DFARS waivers for the 71 deficiencies. Therefore, we request USCENTCOM, in coordination with the Commander, USARCENT, to provide the cost estimate for the corrective actions, and the statements on how implementing of these corrective actions will interrupt the mission operation.
Although not required to comment, the Chief of Staff, USCENTCOM, agreed that our findings are violations of UFC 1-200-01, “General Building Requirements,” which is the criteria we used to inspect KASOTC. However, the Chief of Staff, USCENTCOM, non-concurs with the criteria we used for the inspection, stating that UFC 1-201-02, “Assessment of Existing Facilities for Use in Military Operations,” is the appropriate criteria for inspecting facilities at KASOTC. We disagree with USCENTCOM’s assertion. UFC 1-201-02, which provides assessment guidelines for evaluating existing facilities for the potential use in military operations, was published in June 2014 as a guide for warfighters to assess the life safety and habitability of existing facilities for potential occupancy by DoD personnel in support of military operations. At the time of our inspection, the facilities at KASOTC were not existing facilities to be evaluated for potential occupancy. They were constructed as permanent facilities, built for the KASOTC mission and had been occupied by U.S. Forces since 2009. Thus, we concluded that inspection of the U.S. military-occupied facilities at KASOTC for compliance with general criteria for fire protection and electrical system safety found in UFC 1-200-01 was valid.
Furthermore, our companion audit report, Report No. DODIG-2016-065, found that the 2010 Defense Federal Acquisition Regulation Supplement (DFARS) clause, which implements Public Law 111-84 (Section 807), October 28, 2009 was mistakenly omitted from the BLS contract for the operation and maintenance of the KASOTC facilities and recommended that it be included. Inclusion of this clause in the BLS contract would have required compliance with UFC 1-200-01. The Executive Director, U.S. Army Contracting Command-Rock Island (ACC-RI), in his response to the audit, agreed, and stated the clause will be added to the contract no later than March 30, 2016. ACC-RI amended the BLS contract to include the contract clause on March 24, 2016. The change made as stated contractually mandates compliance with UFC 1-200-01.
This report is a result of Project No. D2015-D000PT-0227.000.