Re: [CPEO-MEF] new Army perchlorate guidance

[Lenny Siegel <lsiegel@cpeo.org>]

Like the draft Defense Department "Interim Guidance on Perchlorate" that
we circulated in early June, the Army's June 27, 2003 "Guidance for
Addressing Potential Perchlorate Contamination" is a major step in the
right direction. Unlike the Defense Department draft, the Army document
has been signed off, by Major General Larry J. Lust, Army Assistant
Chief of Staff for Installation Management.

The guidance provides Army field personnel with practical assistance in
determining if, when, and how to sample for perchlorate at active Army
installations, including operational ranges, recently closed Army bases,
and Formerly Used Defense Sites. As I read it, it permits sampling at
the initiation of Army officials or in response to requests from
regulators, water purveyors, or others. 

Though the focus is on characterization, the guidance authorizes
remediation or other response, as "required by federal, state, or local
laws and regulations." This of course, depends on the interpretation of
Army legal counsel. The Army may also respond - this appears to include
remediation as well as sampling - if its suspects a perchlorate release,
there is a pathway that threatens public health, AND the chain of
command approves. (That is, all three conditions must be met.)

The most challenging element of the guidance is "Determining the
potential for perchlorate contamination." In addition to common known
sources of perchlorate contamination, such as manufacturing, wash-out,
and open burning of solid-fuel rockets, the guidance mentions "using
perchlorate-containing munitions for training or testing purposes." As I
have mentioned before, perchlorate has been detected in groundwater at
Army and National Guard ranges where routine training takes place. Some
Army officials suggest that simulator explosives are the most likely
source, but rockets, flares, spotting charges, and "smokes" may also
contribute to the contamination. Since such activities have taken place
at literally hundreds of locations, it's my hope that the Army or
Defense Department will generate more technical information to help
guide decisions to sample, and if so, where on such ranges samples
should be taken.

In addition, I know of at least one former Nike missile site, in
California, where perchlorate has been detected. Since there are
hundreds of such sites around the country, most no longer owned by the
Department of Defense, it is important to generate similar technical
information to guide decisions to sample at those sites.

Constructively, in describing how to determine the presence of pathways,
the guidance recognizes the possibility that those pathways may exist
ON, not just at the boundary of, military installations. Furthermore, it
suggests that those responsible for managing Defense sites "work with
regulators and the public, as appropriate, to identify potential
exposure scenarios and pathways." This is not only important as an
investigation tool. The Army is likely to find much more buy-in from the
public and regulatory agencies if it works in close concert with them.

The guidance, in its entirety, is permissive. Ideally, however, the
Defense Department will take the next step and establish a funded,
comprehensive, and pro-active perchlorate sampling program. Because
perchlorate has been used and/or disposed of at hundreds of locations, a
large share of which are likely to contain pathways threatening public
health. I believe that the military should establish a prioritization
scheme, in which it systematically, but not simultaneously addresses ALL
of the sites meeting the criteria in the November 2002 policy. Action
should begin at sites where concern is greatest, measured by the likely
intensity of the sources, likely pathways, and the presence of receptors.

In summary, the Army's guidance is a good thing. I hope the other armed
services follow suit.


Lenny Siegel
-- 


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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