[CPEO-MEF] Analysis of California perchlorate agreement

[lsiegel@np.craigslist.org]

I've just reviewed the "Prioritization Protocol for Perchlorate Impacts to
Drinking Water from Department of Defense Facilities in California," the
August-September, 2004 agreement between the Defense Department (DOD) and
California environmental agencies. It's essentially an agreement for the
Defense components to voluntarily sample for perchlorate at high priority
sites in California. It doesn't override existing characterization or
remediation projects, and California's regulatory agencies still retain
their regulatory authorities to require responses. If actual cleanup is
required, projects are supposed to be integrated into existing programs
for environmental restoration and munitions response.

The Prioritization Protocol relies on two questions: Is a drinking water
supply impacted? And is there a perchlorate release in the area? If the
answers are yes, the site merits a high priority. If the answers are
"unknown," the priority is moderate. If the distance between the drinking
water supply and the perchlorate release area is less than one mile, it
gets a higher mark than if the distance is between a mile and five miles.
More than five miles isn't considered.

Furthermore, Operational Ranges are excluded from the Prioritization
Protocol. Instead, DOD addresses those sites under its September 29, 2003
Sampling Policy. DOD components will "sample any previously unexamined
sites where a perchlorate release is suspected because of DoD activities
and where a complete human exposure pathway is likely to exist?"

As a floor, the protocol is a step forward. Other than at Operational
Ranges, it captures those sites that deserve a high priority response. But
if it's treated as a ceiling, it could reinforce inaction that may be
allowing perchlorate water contamination to spread. This is the essential
weakness of the agreement.

First and foremost, the trigger concentration for identifying drinking
water impacts is 6 parts per billion (ppb), the new California Public
Health Goal. Setting aside for a moment the argument over what that Public
Health Goal should be, there still should be a lower priority trigger for
any perchlorate contamination above background. That is, even if 2 ppb is
considered safe to drink, that sampling result might be from the lead edge
of a perchlorate plume. Sampling should be conducted to determine whether
more contamination is on the way. That's the strategy normally used to
study threats to drinking water.

Beyond that, there may be sites with massive perchlorate pollution source
areas that today are far from drinking water source areas. This Protocol
offers no help in identifying such source areas. If they are not
addressed, they are likely to spread, increasing the cost of eventual
remediation and making it more difficult to change the property use in the
future.

Overall, the proposal is a step forward. The Defense Department and
California are preparing for the upcoming promulgation of the California
perchlorate standard. But Defense is still dragging its feet. Setting
priorities has limited value unless one is willing to identify the entire
problem.


Lenny Siegel
<lsiegel@cpeo.org>



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