Unregulated and Emerging Contaminants JSEM August 2004

1 Unregulated and Emerging Contaminants JSEM August 2004

2 What are they? Unregulated Contaminants Monitoring Rule Unregulated Contaminants Monitoring Rule –Perchlorate –DNT –RDX

3 What are they? New standards being set New standards being set –TCE and Naphthalene inhalation

4 What are they? Emerging issues Emerging issues –Nanomaterials

5 Other U&EC w/ Relevancy to DoD Polybrominated Diphenyl Ethers (PBDEd) Polybrominated Diphenyl Ethers (PBDEd) Hexavalent Chromium (Cr VI) Hexavalent Chromium (Cr VI) N-Nitrosodimethylamine (NDMA) N-Nitrosodimethylamine (NDMA) Methyl tertiary-butyl ether (MTBE) Methyl tertiary-butyl ether (MTBE) 1,4 Dioxane 1,4 Dioxane 1,2,3 – Trichloropropane 1,2,3 – Trichloropropane Tungsten alloys Tungsten alloys CL 20 CL 20

6 DoD’s U&EC Challenges U&EC issues generate uncertainties and strains resources and impacts DoD mission accomplishment by affecting: Acquisition Acquisition Research, and development investments Research, and development investments Operations Operations Readiness and range management Readiness and range management Occupational health and safety Occupational health and safety Environmental management (compliance & clean- up) Environmental management (compliance & clean- up)

7 High Recognition of the U&EC Issues USD memo on range sustainability provides overarching guidance (6/03) USD memo on range sustainability provides overarching guidance (6/03) Sampling policy (9/03) Sampling policy (9/03) Hired executive and Sr. Scientist to address issues fulltime (3/04) Hired executive and Sr. Scientist to address issues fulltime (3/04) SROC (5/04) SROC (5/04) Congressional Interest remains high Congressional Interest remains high –Letters –Legislation: Appropriations and Authorization

8 Perchlorate: the U&EC Poster Child Fundamental information is lacking; Interpretation is a challenge Fundamental information is lacking; Interpretation is a challenge Science processes need improvement Science processes need improvement Community concern drives issues Community concern drives issues Engagement early at appropriate levels Engagement early at appropriate levels Funding Funding Authority questions raised Authority questions raised Policy practices need to be put in place Policy practices need to be put in place Cross cutting nature lack of ownership management challenges Cross cutting nature lack of ownership management challenges

9 Perchlorate issues Vital to mission accomplishment Vital to mission accomplishment –Stable oxidant used in training and field –Not unique to DoD, but DoD large consumer Water supply q/q link & droughts Water supply q/q link & droughts DoD as deep pockets DoD as deep pockets

10 Perchlorate Science Issues Detection Methodology Detection Methodology –False positives –Used for other than drinking water Controversy over Health Risk Controversy over Health Risk Determining sources and responsibility Determining sources and responsibility Costly technical remediation solutions Costly technical remediation solutions

11 Perchlorate & other recent adventures with U&EC demonstrate larger issues Science Process-Policy Interface Science Process-Policy Interface –When/how are stakeholders appropriately involved in science-based decisions that have policy ramifications –Role and timing of peer review –EPA’s RfDs and guidelines used by states to promulgate regulation in advance of risk assessment process Data Quality Act Data Quality Act –Accurate and defensible reporting Cost not a persuasive argument Cost not a persuasive argument

12 Types of Issues Posed by U&EC LegacyCurrentFuture Mission CriticalValuable Clean up CostsMonitoringMonitoring, Management Early ID of potential contaminants Trade offsManagement or containment Clean upFull knowledge of risk of use. True Life cycle costs build in. Life cycle “Taxes” Clean upSubstitutionAvoidance or substitution, where possible.

13 Not Every U&EC will be an issue to DoD; not all issues will be the same size Is it vital to DoD mission accomplishment? Is it vital to DoD mission accomplishment? Will its regulation change the way we do business? To what effect? Will its regulation change the way we do business? To what effect? Is it unique to DoD? Is it unique to DoD? Is it, was it, might it be widely used by DoD? Is it, was it, might it be widely used by DoD? Equally effective substitutes readily available? Equally effective substitutes readily available? Where are they? Widespread? Conditions at site? Where are they? Widespread? Conditions at site? Potential exposure risk to health and environment? Potential exposure risk to health and environment?

14 Coordinating U&EC Issues Will Identify upcoming issues and their relevance and impact to military readiness and program execution. Identify upcoming issues and their relevance and impact to military readiness and program execution. Minimize disruption of ongoing operations. Minimize disruption of ongoing operations. Develop robust, consistent information and data management approaches. Develop robust, consistent information and data management approaches. Integrate, support and promote targeted science and technology. Integrate, support and promote targeted science and technology.

15 Outcomes of Focused Energy Outcomes of Focused Energy Resource Planning & Integration Resource Planning & Integration Improve mission performance and reduce costs Improve mission performance and reduce costs

16 How Are We Going to Do That? Risk Identification Risk Identification –Early warning; –Advanced characterization Sources, activities, and places at risk –Improve science of risk assessment

17 How Are We Going to Do That? Risk Management Risk Management –Reduce risks –Provide solutions –Increase confidence, flexibility, cooperation

18 How Are We Going to Do That? Bridge gaps Integrat e Coordinat e Find solutions Look Forward & act Synergize Team Work Listen Communicate Leverage Think

19 Near Term Products Identify Identify –contaminants or chemicals that merit evaluation or review. Characterize the nature of identified issues Characterize the nature of identified issues –better understand impacts on military mission (including costs), health, and environmental quality due to new or pending regulatory changes, new scientific information. Prioritize Prioritize –based on the characterization, contaminants or issues requiring action by key decision makers. Share and Coordinate Share and Coordinate –Establish mechanisms to share this knowledge with the appropriate decision makers for further consideration and action.

20 Policies & Practices for Implementation OSD September 2003 Sampling policy OSD September 2003 Sampling policy –Release –Human exposure California Sampling Prioritization Protocol California Sampling Prioritization Protocol ITRC – expanding and expediting approvals of new technologies ITRC – expanding and expediting approvals of new technologies Catalyzing partnerships to test & demo technologies Catalyzing partnerships to test & demo technologies

21 Guiding Philosophies Sustainability Sustainability –Ensure sustainable ranges; Mission accomplishment; Human health; Relationships Transparency Transparency –Prompt notification, explanation, –Accomplishments Accountability Accountability –Ensure robust science, quality data, solid interpretation –Cost effective actions Responsibility Responsibility –Informed decisionmaking and action –Maintain and enhance our credibility

22 What we’re not going to do…