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

[Lenny Siegel <lsiegel@cpeo.org>]

I received this anonymous response to my proposal for a Comprehensive
Perchlorate Sampling Program. - LS


Good proposal!  I am glad you have put this forward.  I would like to
suggest some changes for your consideration.

1) I suggest that your proposal explicitly require DOD to update its
perchlorate use study to include all sites where any perchlorate has
been detected.  This would require DOD to include sites where
perchlorate has been detected even though the samples were not collected
by DOD.  It would also require DOD to include sites where perchlorate
was detected in the soil.

2) I suggest that your proposal explicitly require DOD to include all
sites that managed products/waste that either intentionally or
unintentionally contained perchlorate (e.g., munitions/explosives and
sodium nitrate products).  DOD has perchlorate-contaminated sites that
have no history of disposal of rocket fuel or perchlorate containing
munitions.  At these sites, the perchlorate contamination is related to
usage of conventional munitions/explosives or sodium nitrate products. 
I suspect that some conventional munitions/explosives inadvertently
contain perchlorate.  In our state, we have detected perchlorate in the
sediment of TNT leach beds that received washout from munitions that did
not contain perchlorate as an intentional ingredient.

3) I suggest that the proposal include a simplified and less
time-consuming prioritization exercise.  At this early stage, I do not
believe it is necessary to engage in a time-consuming  prioritization
exercise to determine which sites to sample first. I think that a simple
prioritization exercise would be sufficient.  I believe that DOD could
quickly come up with a total universe and identify one third of the
sites as high priority sites in consultation with the States, EPA,
tribes, and other stake holders.  I do not think it would be "value
added" to prioritize the remaining two thirds of the sites.  I think
time is the critical factor in detecting perchlorate plumes.  I believe
the sooner we sample, the sooner we will know the scope of the problem. 
Therefore, I believe that DOD could manage to sample the high priority
sites (one third) within one year, the other third within two years, and
the last third within three years. I do not like the idea of having
medium and low priority sites and then waiting five years to sample the
low priority sites.  Frankly, I don't think we really have sufficient
information to divide the sites between medium and low priority.   I am
afraid that some states would end up with mostly low priority sites
because of their low population and their relative lack of sole source
aquifers. I think it would be better if the time and money were spent on
perchlorate sampling itself.  I think that after DOD has sampled the
entire universe and has some real data, they could conduct a meaningful
prioritization exercise.

Last of all, I have a question for you.  How should DOD address sites
that have no nearby downgradient monitor wells?  I would wager that at
least 50% of the potentially contaminated sites do not have  monitor
wells in appropriate locations. It would be great if the proposal
required DOD to install downgradient monitor wells in close proximity to
the potentially contaminated sites so that meaningful ground water
samples could be collected.  Of course additional time would be needed
for this additional work.

 

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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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