Perchlorate Issues at the Massachusetts Military Reservation (MMR) and the Aberdeen Proving Ground (APG) 9th Annual Joint Services Environmental Management Conference August 2004 Malcolm Garg Army Environmental Programs Office of the Director of Environmental Programs (703) 601-1513, malcom.garg@hqda.army.mil

Short Perchlorate Regulatory History Perchlorate is an unregulated Contaminant and has no drinking water maximum contaminant limit (MCL) In 1997 the USEPA provided interim MCL guidance of 4-18 ppb In January 2002 EPA drafted a perchlorate health-based risk assessment that equated to a Draft MCL of 1 ppb Currently the National Academy of Sciences is reviewing the science and will recommend actions to the EPA. The USEPA interim guidance is still 4-18 ppb Many states and some EPA regions have imposed their own standards using various legal authorities. DoD facilities have struggled with ‘how to react’; when to sample and ‘what then’

Massachusetts Military Reservation (MMR) MMR located in Cape Cod Massachsetts Training and impact areas used since 1911 Training activities included a variety of munitions, pyrotechnics and the use of open burn/open detonation (OB/OD). MMR sits on a sole source aquifer used for Cape drinking water. In 1982 program to address site contamination was initiated In 1997 USEPA begins issuing a series of Administrative Orders (AOs) under the Safe Drinking Water Act (SDWA) to protect sole source aquifer Artillery and mortar training are banned under the AO In 2001 perchlorate is detected in several on-post monitoring wells EPA Region 1 asks MMR to use 1.5 parts-per-billion (ppb) as a groundwater cleanup level MMR responds that it will continue to use the EPA interim guidance of 4-18 ppb An uneasy agreement is made to screen to 1.5 ppb and cleanup to 4 ppb. In 2002 Massachusetts Department of Environment (MADEP) recommends a 1 ppb perchlorate in drinking water guideline for sensitive populations.

Off-Post Detections In early 2002 perchlorate is detected in 3 of 4 production wells for the Town of Bourne. Frequent testing shows levels between non-detect to 0.5 ppb MMR installs new monitoring wells to determine the extent of contamination. It is decided to construct a pipeline connecting the Bourne Water District to a newly completed regional water system. Construction is completed in summer 2002 – Cost approx. $2M January 2003 perchlorate detected at > 5ppb in an unused production well. Source is unknown. Local fireworks are suspected Additional monitoring wells are installed to characterize contamination In May 2003 perchlorate was detected at 1.75 ppb in a private off-post well. MADEP stated this requires Immediate Response Actions according to the Massachusetts Contingency Plan (MCP) Army legal authorities disagreed with the MCP authority MADEP is currently supplying bottled water to the residence.

Perchlorate issues at MMR Perchlorate has been found on-post in many areas at significant levels. Training activity has been halted Cleanup levels are uncertain. Army does not authorize cleanup for unregulated contaminants Remediation occurring in conjunction with other contaminants. Under the AOs, EPA Region 1 is the lead agency. Army does not have decision making authority. Off-Post detections are low and usually below EPA interim guidance. When to act? Source is not always clear, especially at low levels – fireworks? Screening levels are testing the limits of analytical methodology. Significant costs have been incurred MMR has struggled with receiving clear direction from HQDA Well informed and active community groups

Aberdeen Proving Ground (APG) APG is located next to the Chesapeake Bay in Maryland Is the oldest active proving ground and has been used for munitions testing, evaluation, research, development and training since 1918 In Jun 2002 perchlorate is detected in groundwater at a training field that is adjacent to a well field that supplies the City of Aberdeen. Maximum detection is 24 ppb. 4 of the 11 city wells are located on the training field, the other 7 wells are just outside the boundry Production well sampling finds perchlorate at 5 ppb in one well. The well is shut down. Subsequent sampling finds detections in 3 other wells (approx. 1 ppb) APG ceases training activity with perchlorate containing items in this area In Aug 2002 the Maryland Department of Environment (MDE) issues a drinking water advisory for the City at 1 ppb Mandates sampling of finished water If levels exceed 1 ppb then advise the community Levels to be kept < 1ppb by ‘mixing’ water. In Nov 2002 MDE provides a Draft Administrative Order to APG Provide a treatment system for the City water system Curtail activity that may release perchlorate Feasibility study to determine best method to keep perchlorate from city wells Army did not agree to the order and the Draft was never finalized

Perchlorate at APG Perchlorate has twice been detected at 1 ppb in the City’s finished water. Maryland Senators request the Army to release funds and provide treatment EPA Region 9 requests APG provide methods to halt migration to City wells. APG with concurrence from HQDA agree to limited study MDE requests APG to remediate perchlorate contaminated soil APG seeks HQDA approval Approval not granted APG is attempting to perform action as a research & development (R&D) project

Perchlorate issues at APG Primary issue is at the training field adjacent to the City well field Low levels but impacting drinking water Army will not approve remedial actions Regulators are pressuring for substantial remedial efforts Very active and informed community group Strong political and regulatory pressure Costs could become appreciable

Similarities and Differences Very informed and active community groups Strong political, regulatory and media pressure Both facilities are dealing with low action levels Screening levels are testing the limits of analytical methodology Final MCL may be higher than action level Differences MMR is acting under AOs; APG has resisted After MMR results HQDA is ‘holding ground’ Different political and regulatory atmosphere also responsible MMR is conducting base-wide characterizations and cleanup actions. Is addressing off-post issues at multiple sites. APG’s main issue is in a limited area, however, perchlorate is impacting the entire community’s water supply

Policy Issues… and Lessons Learned? DoD policy Sample for perchlorate if there is a release and if there is completed pathway that could endanger human health. Sample if it is a legal requirement Both installations meet the first requirement With MMR it is also a legal requirement No policy to address remedial actions Remediate to what level? Final promulgated action levels may well be > 1 ppb, perhaps appreciably higher. How is it funded? Not a compliance issue. Not usually eligible for Restoration funds Require policy to deal with future unregulated contaminants? To include funding Lessons Learned Be prepared to address legal regulatory issues. Must be willing to take a stand and withstand political pressure Identify future ‘emergent’ contaminants. Unregulated ‘emergent’ contaminant work group has been initiated by OSD Identify potential candidates Develop environmental and toxicological profiles in advance and fund efforts Collaborate with regulators armed with substantial knowledge early in the process