Re: [CPEO-MEF] Interim Guidance on Perchlorate Activities

[CPEO Moderator <cpeo@cpeo.org>]

Shortly after posting the memo below we have heard that it is an early
draft that is undergoing review and comment.  We'll post more
information as it becomes available.

Aimee

At 02:00 PM 6/5/2003 , you wrote:
>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.
>
>~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
>You can find archived listserve messages on the CPEO website at
>
>http://www.cpeo.org/newsgrp.html
>
>If this email has been forwarded to you and you'd like to
subscribe,
>please send a blank message with no subject to:
>
>cpeo-military-subscribe@igc.topica.com

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~