[CPEO-MEF] Interim Guidance on Perchlorate Activities

[CPEO Moderator <cpeo@cpeo.org>]

The following document outlines DOD's Interim Guidance on Perchlorate.
As far as we can determine the letter appears genuine, however, we are
trying to confirm whether it is a final document or a draft.  If any of
the information below has changed or is incorrect we would appreciate
knowing right away.

Aimee
_________________________________________________
MEMORANDUM FOR ASSISTANT SECRETARY OF THE ARMY
(INSTALLATIONS AND ENVIRONMENT)
ASSISTANT SECRETARY OF THE NAVY
(INSTALLATIONS AND ENVIRONMENT)
ASSISTANT SECRETARY OF THE AIR FORCE
(INSTALLATIONS, ENVIRONMENT, AND LOGISTICS)
STAFF DIRECTOR, ENVIRONMENT AND SAFETY,
DEFENSE LOGISTICS AGENCY SUPPORT SERVICES
(DSS-E)

SUBJECT: Interim Guidance on Perchlorate Activities

 Currently the National Academy of Sciences is conducting a study to
determine the best science and model to use for determining standards
for perchlorate.  The result will be used by EPA to finalize a risk
assessment that will likely lead to the development of an oral reference
dose (RfD) for perchlorate.  Once established, the RfD can be used for
conducting risk assessments for environmental restoration purposes and
for setting a Federal drinking water standard (i.e., maximum contaminant
level under the Safe Drinking Water Act).  A few states are also taking
actions on provisional non-enforceable perchlorate risk or action
levels.  In preparation, and to allow us to plan and then respond when
standards are set, I am directing the Services to conduct a record
search for past and current perchlorate use and sample to ascertain
perchlorate occurrence at our installations, both active and closed, as
well as at Formerly Used Defense Sites (FUDS) as we investigate each of
those sites.  At a minimum, all installations will be required to sample
for perchlorate at the installation public water systems, and
down-gradient from active and/or closed open burn/open detonation (OBOD)
sites.  Additionally to the extent that monitoring wells are located
down gradient of active or closed ranges, sampling should also be
conducted at those locations.  I am issuing this interim guidance under
authority of DoDD 4715.1, Environmental Security.  I believe this will
position the Department to react faster and more efficiently when
standards are set.

 When perchlorate is detected at a level above 1 part per billion, the
installation is to immediately inform its’ chain of command, through
channels, the local community and consult with leadership on what
actions to take.  The installation will evaluate each incident based on
the unique circumstances to determine the next step and report up the
chain both the occurrence and the action to be taken.  The Components
will plan and program for future cleanup.

 This interim policy is part of a larger effort within the Department of
Defense.  We are currently working to improve test and analytical
methods for determining concentrations of perchlorate.  We are
developing and testing new techniques for cleanup, and we are
researching substitutes for perchlorate in solid rocket systems.

 This approach in planning and budgeting for perchlorate sampling and
analysis will put DoD in a better position to comply with regulatory
standards when they are established.  My points of contact are Mr. Shah
A. Choudhury at (703) 697-7475 for environmental restoration, and Mr. Ed
Miller at (703) 604-1765 for compliance.


John Paul Woodley, Jr.
Assistant Deputy Under Secretary of Defense
(Environment)

Enclosures
Sampling and Analysis
_________________

Funding Sampling and Analysis.  Components are to plan, program, budget,
and use appropriate environmental restoration or compliance funding for
future perchlorate sampling and analysis requirements.  Environmental
restoration funding can only be used for sites that meet Defense
Environmental Restoration Program (DERP) eligibility requirements in the
current version of the DERP Management Guidance.  Under DODI 4715.6,
“Environmental Compliance,” perchlorate sampling and analysis would be
considered Environmental Quality Status Class III.

Analysis Method.  At present, EPA Method 314.0 is the only approved test
method for the analysis of Perchlorate in water.  This method was
promulgated under the Unregulated Contaminants Monitoring Rule of the
Safe Drinking Water Rule.  The method requires that each laboratory
establish and verify with every analysis batch a minimum reporting level
(MRL) for perchlorate (Section 9.2.7 of Method 314.0).  If a regulatory
agency desires a lower MRL for monitoring under the Safe Drinking Water
Act or other regulatory program, then that agency needs to identify an
alternate method that meets or exceeds the performance criteria of
Method 314.0.

Analytical Quality Assurance.  A laboratory chosen to perform
perchlorate analysis shall demonstrate proficiency to perform the test
method through an accreditation process established by the Component.
In addition, the laboratory shall posses the requisite state
certification(s).  All analyses for perchlorate must be performed in
accordance with the current DoD Quality Systems Manual for Environmental
Laboratories (DoD QSM).  The current version of the DoD QSM is available
on the Defense Environmental Network and Information eXchange (DENIX).

Conducting Sampling.  Any perchlorate sampling plan will be based on
specific site conditions using the quality assurance and analytical
method described above.  The sampling plan will include the reasonable
basis for suspecting the presence of perchlorate, sampling approach, and
decision criteria for potential further action to be taken based on the
analytical results.

Sampling Request from Regulatory Agencies.  A regulatory agency may
request the installation to conduct perchlorate sampling or allow the
regulatory agency access to an installation to conduct sampling at the
agency’s own expense.  In either case, installations will not consider
any regulatory agency request for perchlorate sampling unless the
agency’s written request clearly states the reason for the sampling
request (such as evidence stating that perchlorate was released into the
environment at the installation), risk posed (such as the pathway for
perchlorate that either exists on the installation or risk of exposure),
the regulatory structure for the sampling and the evaluation of
analytical results, and decision criteria for and expectation for
potential further actions.  This request will then be the basis of the
written agreement between the regulatory agency and the installation
prior to sampling.  This written agreement will clearly describe an
acceptable sampling plan as described above.  Split sampling with
regulatory agencies is strongly recommended.

Actions Beyond Sampling and Analysis.  Follow-on action can only be
taken when proper environmental restoration or compliance funding
resources are identified and available.

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