[CPEO-MEF] OEHHA scientist comments on perchlorate in BMDS PEIS

[Lenny Siegel <lsiegel@cpeo.org>]

[In November, 2004 Robert Howd, toxicologist at California's Office of
Environmental Health Hazard Assessment submitted the following personal
comments on the Army's draft Programmatic Environmental Impact Statement
for the Ballistic Missile Defense System. -LS]

In the draft Programmatic Environmental Impact Statement for the Missile
Defense System (1 September 2004), I would like to point out incomplete
and misleading statements about perchlorate toxicity and standards in
the bottom paragraph on Vol. 1, p. 4-56. This discussion provides the
viewpoint of the DoD and the Perchlorate Study Group, an Industry
Workgroup, on perchlorate toxicity, but ignores all risk assessments
conducted by actual risk assessment agencies. The U.S. EPA has been
evaluating perchlorate toxicity for years, in association with several
defense agencies (as stated), and has released a draft risk assessment
which proposes a drinking water equivalent level of 1 ppb. The State of
California Office of Environmental Health Hazard Assessment has
published our risk assessment which estimates a health-protective  level
of perchlorate in drinking water of 6 ppb. The State of Massachusetts
has recently released their evaluation with a recommended drinking water
level of 1 ppb to protect pregnant women and fetuses (or other sensitive
sub-populations), and 18 ppb for healthy adults. The U.S. EPA guidance
applicable to water contaminant plumes emanating from industrial and DoD
sites has used a standard of 4-18 ppb for several years.

To not consider and apply these relevant and applicable standards to the
evaluation of potential environmental impact of the deployed missile
systems seems to me to be putting both the DoD and the public at risk,
both from legal liability and potential chemical hazards. I recommend
that this section of the report, and any financial and toxicological
calculations based on it, be revised to include the viewpoints expressed
by the regulatory agencies whose job it is to regulate the public and
environmental exposure to perchlorate. Acknowledging these opinions need
not wait for the finalization of the U.S. EPA's current draft risk
assessment for perchlorate, currently under review by the National
Academy of Sciences, nor the promulgation of the California Maximum
Contaminant Level for perchlorate in drinking water, scheduled for 2005.

Thank you for consideration of these comments.

Robert A. Howd, Ph.D.
Chief, Water Toxicology Unit
Office of Environmental Health Hazard Assessment
Oakland, CA 94612

The above comments represent my personal opinions, and have not been
reviewed or approved by OEHHA prior to submission.

-- 


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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