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

[petestrauss1@attbi.com]

Lenny:

I think that you are giving the military way too much time to implement a
sampling program at any site suspected of having perchlorate contamination
(medium and high priority, in your terminology).  I know things move slowly
in DoD, but perchlorate is up on everyone's radar screen, and its time that
DoD actively look for it in the subsurface.  This is especially true at IR
sites.  Perhaps you should bifurcate the proposal: one for a general
inventory of active bases and one for IR sites.  At IR sites, sampling for
perchlorate should be added to the suite of contaminants sampled.

Also, aside from sole source aquifers as a potential focus area, plumes near
agricultural or residential areas that use irrigation water need to be
identified, as well as plumes near habitat of any endangered or sensitive
species.  This is because of perchlorate's proclivity to hyper-accumulate in
plants.

I would also suggest that the work at Texas Tech. (or something equivalent)
be accelerated and funded (by DoD) appropriately.

Peter Strauss

----- Original Message -----
From: "Lenny Siegel" <lsiegel@cpeo.org>
To: "Military Environmental Forum" <cpeo-military@igc.topica.com>
Sent: Friday, June 06, 2003 10:53 AM
Subject: Re: [CPEO-MEF] Interim Guidance on Perchlorate Activities


> I've been informally circulating this proposal for a few weeks. I
> originally phrased it in legislative terms, but the strategy could also
> be adopted administratively.  The Defense Department's draft Interim
> Guidance already addresses some of the concepts I've put forward below.
> - LS
>
>
>
> Comprehensive Perchlorate Sampling Program
> a proposal by Lenny Siegel
> Center for Public Environmental Oversight (CPEO)
> May, 2003
>
> Long ago, before the Defense Department was subjected to regulatory
> oversight on cleanup, Congress directed it to do cleanup anyhow - at
> places like McClellan Air Force Base (Sacramento) and Tinker Air Force
> Base (in Oklahoma). There is no reason to focus only on the regulatory
> side of the equation.
>
> The Department of Defense (DOD) has been doing some things on the inside
> even as it rejects outside requirements. Navy documents mention a
> perchlorate use study, but no one outside DOD has seen it. We've also
> heard about a potential internal sampling requirement.
>
> If the country is forced to wait for a promulgated maximum contaminant
> level (MCL) to do much about perchlorate, it will be too late.
>
> Therefore, CPEO is proposing the following national strategy for
> addressing perchlorate. We are looking for feedback. The framework, at
> this point, is more important than the details.
>
> Congress should require, in the Defense Authorization Act or Defense
> Appropriation Act of 2004, that DOD conduct a Comprehensive Perchlorate
> Sampling Program, subject to regulatory oversight. Here are the basic
> elements of such a program:
>
> 1) DOD shall update and release the results of its perchlorate use
> survey within 3 months of enactment. The final survey shall include
> current facilities, including operational ranges, former facilities
> (including ranges, production plants, and Nike missile sites), and other
> facilities where DOD is liable for cleanup costs.
>
> 2) DOD, in consultation with EPA and state regulators, tribes, and
> potentially affected communities, shall develop a draft high-medium-low
> ranking system of sites from that survey to characterize for
> perchlorate, within 6 months. After a 30-day public comment period, it
> shall finalize the ranking system within 9 months of enactment. Factors
> in the priority system should include the type and quantity of use,
> known and likely releases, potential pathways (such as adjacency to
> sole-source aquifers), and community concern. Note that "priority" is
> not the same as "risk."
>
> 3) DOD shall rank all facilities identified in the perchlorate use
> survey, as high, medium, or low priority, within 18 months of enactment.
>
> 4) DOD shall develop, with regulator approval, sampling workplans on the
> following schedule. Sampling plans should be based on the possibility
> that the science-based cleanup standard may end up as low as 1 part per
billion.
> High priority - within two years of enactment
> Medium priority - within three years of enactment
> Low Priority - within five years of enactment
> Nothing in this schedule shall delay workplans or sampling already
> underway or otherwise required by environmental regulatory agencies.
>
> 5) Nothing in this provision shall delay remediation already underway or
> otherwise required by environmental regulatory agencies.
>
> 6) DOD shall ensure, through the sponsorship of appropriate research and
> development by its Strategic Environmental Research and Development
> Project or the Environmental Security Technology Certification Project,
> that the technology exists to reliably measure perchlorate contamination
> in water at levels as low as 1 part per billion.
>
> 7) Congress should authorize and appropriate sufficient funds to
> implement the Comprehensive Perchlorate Sampling Program in the first
> year. DOD shall request sufficient funds in subsequent years to
> implement the program. Funds for this additional requirement shall be
> added to the cleanup accounts (Environmental Restoration, Formerly Used
> Defense Sites, Base Realignment and Closure, Military Munitions
> Response) so they don't subtract from already identified and planned
> cleanup projects.
>
> --
>
>
> 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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