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

[Lenny Siegel <lsiegel@cpeo.org>]

The draft Defense Department "Interim Guidance on Perchlorate
Activities," which we posted on June 5, 2003, appears to be a step in
the right direction. I assume that it is undergoing intense
"coordination" - that is, internal argument - within the Pentagon, but
it shows that at least some people in the Defense Department are
listening to their critics.

It's clear that the Defense Department does not want to commit to
perchlorate remediation until there are legally promulgated standards,
and nationally that process is likely to take some time. But that
shouldn't prevent the military from sampling, since it will be
impossible to know whether a site requires a response, once the
standards are in place, without such data.

Therefore, the proposed directive "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)" is welcome.

In addition, the draft guidance would create the beginning of a
prioritized system for perchlorate sampling. Since a "complete' sampling
program might entail hundreds of thousands of locations at thousands of
facilities, it's clear that the Department needs to focus on those
locations where pathways might exist - such as the "installation public
water systems" mentioned in the memo - or near likely sources, such as
"down-gradient from active and/or closed open burn/open detonation
(OBOD) sites."

It shouldn't be surprising, however, that I think the Pentagon should go
even further. In a separate message I will introduce my proposal for a
Comprehensive Perchlorate Sampling Program.

Lenny

-- 


Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 278-A Hope St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/961-8918
<lsiegel@cpeo.org>
http://www.cpeo.org

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