CREW: Department of Defense: Department of The Air Force: Regarding Perchlorate: Scanned Perchlorate October 2008 JJ

Requestor/Requestor/Entered havirlCi open IEmeNd h.vlng jEntertd having lEnterect having enter8d having IHo......
8Jor lHoUsed &lor HOused&!or Housed&Jor Housed &Jor Housed.&lor lGrounctwater Soli sampled for
s FIx II Email bum/open detonation? ordnance and/or otdnan~e andlor propellint propelllnt _ng disposed 01 d3pos'" 01 dlspOOIdol dlspooadol disposed of dlspos'" 01 sampled lor perchlorate?
Number rocket motor rocket motor removal? andlor. rocket motors, tattlcal munitions· munitions· munitions· other materials? perchlorate?
ma_nance? lestlng? laboratory? CADs, & PAD.? missiles? Nomenclature? DoDIC? NSN?
Yes IYes Yes Yes

~-- No
No No No No No No No
No No No NO No No No
Surface water Sedlmont Plena lor IImpllng When IImp/lnD W••• n Requestors IIl1mpled. awale IIl1mpled, -'" Statoand II not sampled. why?
sampled lor sampJedfor if-not .'ready II"Ola_dy an.lysis information orS_and Fodalel Agone., Involved?
pen:hlorate1 perchlorate? Iequ_ Fedenl
Roqullements?
No No No No Until now, had not Iealized

the n~; the_Ie,
there is no current plan to
dol. we .... 40CFR264,
Appendix IX lor
groundwat~r sampling
peremeters and perchlorate
is not one of the listed
chemicals.
No No
No No No No NO NlA UNKNOWNREQ
Installation Name
Number f
lo.taboMjoate _ed IlnstalhlUO V_
5e<vIce
Agency
Installation StatUI City State ZlpCode Country
CONUS ISUbmltler ISUb_r -
Including
AI( & III or
Name
r ub
!Command ICommand IMoJOr IPrimary
Orgonlzatt Pbone inlI Olll...r 1111 Oll O<Or Command POC
on Numbo< PhORO Name
OCONUS Number
I
1571 1111412000IUSAF V ReRA Davis- AZ 85707 USA CONUS +
Manthan !'FB AK+HI
USA OldTown ME USA CONUS +

M&HI
USA Columbus OH USA CONUS +
All & HI
OIher Stockton CA USA CONUS +
AII&HI
OIher Tracy CA USA CONUS +
AII&HI
lother Memphll TN USA CONUS +
AII&HI
OIher Ogden UT USA CONUS +
AII&H!
OIher New PA USA CONUS +
Cumbo~and All & HI
0Iher CA USA CONUS +
AII&HI
0Iher Phillldelpl1ia PA USA CONUS +
AK&H1
0Iher Philadelphia PA USA CONUS +
\ AK&HI
USAF DE USA CONUS +
AK&HI
2181 1113012000 USAF NNV RCRA;ANGB Des Moines IA 50321 USA CONUS +
AK+H1
Primary
poc
Seconda, /_dlT
yPOCFax yPOC
Contraeto ICl)ntracto Icontraeto lCocdracto lContracto lcomrado IRequestorlRequeROrlRequestorl
r Address r !»tIone r Alternate r FIx r Emili r Area of • Name s Addre.. • Phone
Add,.ss Number email Number Phone Number Responslb Number
Number lilly
ReqUostorlReqUOstorjEnlOrod having open
• Fax.
Number
• Emall
1_ having lEntered having IEnte.... having e_
bum/open detonation? ordnance and/or ordnanctt andJor propellant
rocket motor rocket motor removal?
having IHoused &lor IHOusod &/or
propollanl_ng dls,.,- of .eIlsposed of
aRdIor. rocket moton, tIIetlcal
HolJsed&Jor
dlsposod of
HouMd&lor
eIlsposedof
munitions. munitions.
HouMd&lor
disposed of
mun1tJons
Housed &lor
eIlsposed of
IGroundwater sou sampled for
sampled for
othar materials? pere'hlorate?
perchlorata?
maintenance? tasllng? lab_tory? CADo. & PAllo? mlssl...? Nomenclature? DoOle? NSN?
Ves No No No No Yes
No No No No No
No No No No No
No No No No No
No No No No No
No No No No No
No No No No No
No No No No No
No No No No No
No No No No No
No No No No No
No No No No NO
No No No No No
Surface Wllter Sediment Pions for sampllnQ When. sampling Wa.an Requestors If sampled, aware • sampled, weAl State and • not sampled, why?
sampted for sampled for .nol.l....dy • not .Iready an.lysl. Informatlon otStat••nd Federal AgencJes InvolY8Cl?
pen:hlonrte? pen:hlorale? requested F.danll
Raqulrements?
No No Ve. Arizona Dept of Environmental

Qualily has establisned
"provisionar soil dean up levels
(non-regulatory) of 37 ppm for
residential sites and 850 ppm tor
non·residential siles. POC: Mr
Tony Bode, ADEQ Drinldng Weter
Program Development &
OUtreach Un~ (602) 2()7-4643.
ADEQ ia interested due to the
closure ofUle EOD renge (en
interim-statu. pennitled RCRA
treatment facWIIy).
No No
No No
No No
No No
~ No
No No
No No
No No
No No
No No
,
No No
No No No No No No identified nee<! or
requinment for such
sampling to date.
Installation Name I,Dotabo"
Numbor
3761
f
IDale Received Iinstallatio Ve_
Service
Agency
. 2171200f1USA V
Installation Status City
Tcoele
Statt
UT
Zip Code CoulllJY
84074 USA
-r. . .
Including Neme
AK&Hlor
OCONUS
CONUS +
'AK+HI
on
f~Number
COmmand Command \MaJor
Phone
Number
rrimary
Organlzatl Phone Ing OIIicer Ing OIIIcer Command POC
Name
USA Oetrol IMI USA ICONUS+
AK&H1
3431 5I2112001IUSAF v CERCLA Mar1elta IGA 300691uSA CONUS +
AK+HI
406 7f1212OO11uSN ,v BRAe Novato IeI'> 94947IUSA CONUS +
'AK+HI
175 1112012000IUSAF NNV NPL DoverAAFB IDE 19902IUSA CONUS +
AI< + HI
Primary
POC
PrImary /Prlmary ~secondar
POC Fax POC Emal YPOC
secondar jsecondar
y POC Fax y POC
Contracto IrCOniraeto IrCAddress
r POC
Oniracto jrcontPIloneracto \rCAlternate
c>ntraeto jcr OniFaxracto Icontracto ~ontrilctoJRequestorlRequestorlRequestor
r Em.n r Area of • Name a Address Phone &
Address Number . rt.me Number EmaU Name Company Number Phone Number Responsl Number
Name Number lilly
RequeltorlRequeltorlEntem hevlng open /E_ h.vlng IEntem hiving IEntetld
having
• Fax • Email bumlopen detonation? ordnance .ndlor ordRlnce andlor propellant
Number rocket motor rocket mo1or removal?
Encered having lHoused &lor0'
propelllnt teltlng dllposed
andlor a
dllposed
rocket moto.... attica.
0'
jHoused &lor Ho_&1or
dlspoled 01
Ho_&lor
dllposedo'
munltJo... ~ munttlona
HouMd&lor Ho_ &lor
disposed of dllposed of
munitions·
IG- ISotIllmpledfor
sampled lor perchlo.....?
other m.leri.ll? perch._?
""'Into nonce? teltlng? IIboratory? CADs. & PADI? mlll'les? Nomenclltu..? DoOIC? NSN?
Ves No Yes Yes ,No
No No No No No
No 'No No No No
No 'NO No No No No
No No No No No INo
Surface water Sediment Plans for IImpling Whenllmpllng Was an Requestors 'sampled. aware If sampled, were State and 1I not umpled, why?
aampledfor sampled tor if not already If not elrUdy analysis Information of State and Federal Agencies Involved?
perchlorate? per<:hlorate? requested Fedelll
Requl18ments?
No No No No Not required by the

regulator.
No No
No No No No No evidence nor
documentation or 8 release.
No No
,
No No No No No regulatory requirement.
:
Inl",Uotlon Name IDa"'. .... IDate Received Ilnllal_\verllled I'nSla''''tIon Stet...
Number
1321
n service
Agency
111312000IuSA INNV I
ICRy
IBroOklyn
1- r-[
fNY I 11252USA
r I-j-rrrl- r-
Including Name
& HI or
OCONUS
Organlzatl Phone
on Number
Ing om.. Ing OlIIcer Commond POC
Phone
Number
Name
USN VA USA
247 1111712000IuSAF NNV RCRA; ANGB IDuluth MN SS8111uSA
137 111312000IUSAF v 'Fonner TAe b.... IDuluth MN SS8011USA

Duluth AFB. Joint use
faCility, Dulutll in that
AP .nd MANG.;
ANGB
Primary Prim.ry
POe POC
Primary Primary J_der l&ec:oRcsar
POCF•• POC Emal y POC YPOC
S41condar seconda, I8ecOndar
jsecondar Contracro IContraclo Contraeto IConlracro jcontraeto Icontraeto Icontra.clo \ContraClO IRequestorlRequestorlRequestor
yPOC yPOC yPOeFax yPOC rPOC Ir rAddl'Kl!rphone rAiternate rFax rEmall rAtHof sName sAddress "Phone
Addle•• Phone Number Nam. Address PhOne Altemllte Number EA1&III Name Company Number Phone Number Responsib Number
Number ,Number Phone Name NumbN IU~
umber
Requ••,orIR.q....orIEburn/open
I Fax • Email
nte. . . ltIvlng open IEntet<lCl having IEnte..... ltIvlng IE- having
detolUltlon? ordnance and/or ordnance and/or propellant
ente..... haVing IHoUsed &lor IHoused &lor Housed
propellant teatlng eIIopooed of disposed of
&lor
dlspo'sed of
Houaed&lor Houaed&Jor Housed &lor
dlapooedOf disposed of dlspo.... of
IGroundwater
aamplOd for
Soil sampled for
perdllome?
Number rocket moto, IOGket motor removal? anellOf a _ motors, teetlcal munitions· munitions !munltkma other materials? perchlorate?
maintenance? tesllng? Iaboralory? CADs. & PADe7 mtHlles? Nomenclature? DoDIC? ,NSN?
No No No No Ni) Na
No No No No No NO No
No No No No INa No No
No No No No Y•• No
Surface water Sediment Plene for eampllnl Wilen eempllng Wa.an Req....o.. If sampled, aMre If aampled, ..,. seate and If nOleampled, why?
Nmpledfor eampledlor If not already Ifnot_dy analysis Infonnadon orS.... onCl . Federal Agenelea In.olved?
perchlorate? perchlorate? requested Federal
Requlremente?
No No
No No
No No No No
No No No Minnesota PoUutton Control

Agency (MPCA), Jane Mosel (651
29&-7813) and Ml<e Bares (651
297·6599,
mike.bares@pce.state.mn.us)
;
Inltallatlon Name DalobesejDaIo Received Iinatatiatio jVerIfIed Iinstallatlon Status
Number n Service
CIty Stalo IPrimary
IZlp Code ICountry '.CONUS ISUIl_r jSubmlttor \SUllmlttor ICommand lCommandlMaJor
Ilncludlng Name Organlzatl Phone lAg omcer Ing omcer Command POe
Agency AI( & HI or on Number PhOne Name
'OCONUS Number
280 111012001lUSAf NNV RCRA OyessN'B ITX 79607IUSA CONUS +
AK+H1
Primary
POC
Primary [Primary ~seconclar l8econclar
poe Fax POC Emal y POC Y POC
Secondar 18ec_r
.y POC Fax y POC
Cont..eto ICont
r POC r
neto Icontneto jcontraclo IContneto IContracto IrCEmail
r Add,.... r Ph'one r Attemater Fax
oRt...... IrCAntaOntn0"etoJRequestorlReq....torlReqUlstor
Name s Address • PIIone
Add.... Number Noms AcId.... NumIMr EmaU Name Comp.ny Number Phone Number Respon. Number
Noms Number IIUy
RequestorlReqUestor/EllteJed hllYlng open IEntend having IE....... having
Entered having EnteJed having IHou.... &/or IHoU &/or Housed &lor Housed &lor Housed &lor HoUHd &Jot IGroundWater SOU sampled for
I FIX • Email bumlopen deton_tion? ordnnce andlor ordnance .nd/ol propellant propelant _ng d1spoHd of dlspo of dlspoHdof disposed of dlspoMdof dlsposad of sampled for perchlorate?
Number rocket motor rocket motor removal? andlor a rocket mQtors, tactical munitions· muntllons. munitions. other material.? perchlorate?
maintenance? _ng? laboratory? CAD&,-& PADa? mlosllea? Nomenclatura? DoOle? NSN?
Yes 'No No No No No
Surface water sediment Pion. lor umplinG Wllenssmpllng W•••n Req....to.. If sampled, aware "ssmpled. welS Stoto .nd " not umpled, why?
umplldlor eampledlor "not._eIy " not.1lsady ....Iyol. IrdonnaUOn of Sto....d Fedsrsl Agent'" Involved?
porchlo....? porchlorate? requ..ted Fedenl
RequllSments?
No No No No OUR OBIOO Sile has

aIteady been investigated
and closed. The lab used
EPA method 8330 10 check
tor explosives. We have no
history 01 pon;hIoraIe
contamination at any other
de nor do we have a
regulalory requirement 10
check for pen;hJorates.
F_.. .
_ _.
DoD PERCHlORATE DATA. Y 2001
c_ _AI. . < . . .-. . . . -....._. . -.-. . . ..... ... ............. -. . . . . .

","enod .. _Olg ~ data (from llf>1IOInlI« pIImod plinglln 2001_ cal.1llt lie nollnclullodln """"" _ cal
- _-- ..-... . -. . . . . . ., an.. .,.••

'- _..
- -' -' -' -
..
-,
lfun'lP..tt•
InlUll"on
0
D",_
... D...
Recelv.d
1n...... Ml_
s..wc.Ag4Incr
V.rillllll In"aUation Silatul City ... Codo
ZJo
CONUS
" .. _w-.. -,,-... -.ungancUor

$011_100
.. .......... ...... .......
1l-..nple4, .""_ -...1K••

ors.... and
F_"
F_oJ
.w
OCOIIUa dlaon.&ri?
' "-' ...... ' r.quln_naal Invotwdl
,
CernpClI-SW"
TraingSile
15 '0l>12OOO USA V
CERCLA.NPt.;
NlNG
. . . . "'" ... .. USA
CONUS+N(
No v.. .. No .. No No No No No .
,
CampParh
Rlll!lllI'VeFOfl:8lI
Trehng .......
(RFTA) '" . USA V RCAA" CEAClA 0. CA . USA .CONUS.. "" . . No No It> No ,. r .. .. .. I,
_ - I-
DuI....
...
fct1Nll'TACbIM.
.. .., .. .. ..
I
ldemational
•
DWlIh MS. .JeW
CONUS'' ' .. .. ..
.. 1>1 tll:ll2OOO USAf IMfKlllly.DuUh
IAlhatAPand. ...
ANG.;N«38
"""'" ""'" 'H' No No No
.....
SlJbrrid8l~
nEAR NOn THAT THE: fOl.LOWlNG 37 DATA ElEIIENTS I COLlMIMI "'E HIlDEN CNI THIS SPREADSHEET SINCE NO..ORMATION WAS PflOVlDED til THER COLUMNS AHD THE CELLS WERE SKAD£O GIIAY ON tHE IIA;Y 300' DATA.$U8WlTTAL:
Submitlor PhoN HUmbef

_Commondow.e. Pt'IllM Nl:mber
<:ommandiO<I"""*
Culltr-*K POC H8rM
""'*- Compony-
~---
""'*-.......
CoIJInwdrQ ~AIernIQ~fU1\beI
ColiI8dDr f. I'Unb«
......... POe ..... eom..........
......... POe_
Prinwy POC~""" -.. . .
Carh::Sor AI88 Ool RMponIi:iily
PriIn8Jy POC~Pl'IOIW runber -.-

~IIPtmneNurllb8l
_.Emol. .I
PrilMryPOC FILIl fUnbeI'
......... POe ...... ~".f Jokmber
-,POe_
~pocMdr.. tb...s WdIoc ~ar mc:UIl'IlOich,. CADa.' p~..,
$MXI.nd8ryPOCPhone~ tbIIm ancUor dIIPOMd ollal:ticad ......,
$ea:niIlry POC _QIm8l:.~ nt.M'nIIIiII ~~~oIlDL111dorn1-Nomend"'e?
$IllDnli8ry POe fa Number I'bMd 8nIIor dMpoee:t 01 rNr4ion& - ODOIC?
",,-POeEmoll tbIIe 1ftdIor~of h'UilklRI. NSN1 "
tbMdaNllor~oIcdwlnlllerials?
I.
F1a.: Pwd>IIIa_alII1plII1lOn >11/ pnoI d" auilmillaIa

Page 1 0'2
ShNt; MlIy 2001 ....
Pro~j.,ed Information Page 1 of 1
Unknown 139
From: Kratz, Kurt, , OSD-ATL
Sent: Wednesday, November 19, 200308:19
To: Van Brocklin, Connie H Ms ACSIIVI
Cc: Newsome, Richard E Mr ASA-I&E; Cotter, Sandra, Ms, OSD-ATL
Subject: FW: Promised Information
Connie,
Enclosed is the list of installations that should have received the letters. We promised on Weds, last, to provide
an ETA to CA on the answers.
Thx,
Kurt
-----Original Message----- ,-/ J
From: Brausch, Rick [mailto
Sent: Monday, November 17~3 7:18 PM

To: 'Kratz, Kurt, , OSD-ATL'; 'Sandl-a.Cotter@osd.mil'
Cc: 'James Gia..!1U0poulos (E-mail)'; 'Lisa Babcock (E-mail)'; 'Unda Dorn (E-mail)'; 'Ton Vorster (E-mail)'; 'Rick
Moss (E-mail)';' - . ---:;:-'Schuparra, Kurt; Spagnole, Jim
Subject: PromISed-Information ,---J
Kurt and Sandy
Attached are two spreadsheets 'with information we promised at our video conference on Wednesday. The first is
the list of California installations/sites that received letters from a Regional Board requesting perchlorate
information. The second is the list of sites represented in the spreadsheet that was sent with the maps last week
(also attached for your convenience).
«000 Sites with RB Ltrs.xls» «Sites using USEPA Data.xls» «Perchlorate_ActiveBRAC sites.pdf»
In addition, we checked with the Department of Health Services regarding access to the data overlays for the
supply well information used to generate the maps. They indicated that they require a signed agreement with any
government entity ~ desires the information. I suggest you contact David Spath re.
--ir Steven B o o L ~r additional information.

Looking forward to hearing from you soon on when we can expect responses to the Regional Board letters.
"
Rick
9/14/2005
Active and BRAC FUD Sites*'" Perchlorate Sites with

Sites"'* Manufacturing Confirmed
Sites** Perchlorate
Releases ***
Total Sites 85 1,257 52 ' 28
Statewide ,
Number of sites 5 47 6 3
•
within 1-mile
radius of DHS "
public supply
wells having at
least one 4 PPB
perchlorate
detection *
Number of sites 16 227 24 15
within 5-mile
radius of DHS
public supply
wells having at
least one 4 PPB "
perchlorate
detection *
* 5-mile buffer zone includes those sites within the 1 mile buffer zones from the impacted DHS
wells. DHS well locations and perchlorate concentration data from DHS database (10/2002)
** Data source: USEPA, 6/2003
*** Data source: SWRCB, 2003

Perchlorate
000, FUDs and Manufacturers Within 1-mile and 5-miles of a Municipal Supply Well
DoD Sites ONE MILE FROM MUNICIPAL SUPPLY WELL

Branch Base Name
Air Force DOD Mather Air Force Base
Army DOD Fort Ord Military Reservation
Air Force DOD Edwards Air Force Base
Air Force DOD Norton Air Force Base ,
Navy DOD San Nicolas Island Naval Reservation
DoD Sites FIVE MILES FROM MUNICIPAL SUPPLY WELL

Air Force DOD McClellan Air Force Base
Air Force DOD McClellan Air Force Base
Air Force DOD Mather Air Force Base
Navy DOD Stockton Naval Communications Station
Army DOD Sharpe General Depot (Field Annex)
Navy DOD Moffett Field Naval Air Station
Army DOD Fort Ord Military Reservation
Navy DOD Lemoore Naval Air Station
Army Corps of Engineers DOD Success Lake
Air Force DOD Edwards Air Force Base
Air Force DOD Norton Air Force Base
Air Force DOD March Air Force Base
Army DOD Los Alamitos Armed Forces Reserve Center
Navy DOD Seal Beach Naval Weapons Station
Marine Corps DOD
Tustin Marine Corps Air Station
Navy DOD \
San Nicolas Island Naval Reservation
Manufacturers ONE MILE FROM MUNICIPAL SUPPLY WELL

Site City
Olin Safety Flare Morgan Hill
US Rocket .' Pomona
Dynamic Propellant Ontario
Jet Propulsion Laboratory (NASA) Pasadena
San Gabriel Valley Baldwin Park
Astro Pyrotechnics Rialto
The data prOVided in this table is from the USEPA. The USEPA collected data from various sources (USGS, USACE, California DHS). The SWRCB is not
responsible for its accuracy. Page 1
Perchlorate
DoD, FUDs and Manufacturers Within 1-mile and 5-miles of a Municipal Supply Well
Manufacturers FIVE MILES FROM MUNICIPAL SUPPLY WELL

Mather AFB Rancho Cordova
Olin Safety Flare Morgan Hill
Trojan Fireworks Palmdale
Kinetech Corp Rancho Cordova
Lawrence Natl Lab Tracy
Starflight Space Technologies Windsor
US Rocket Pomona
San Fernando Valley Glendale
U.S. Navy Firing Range
San Nicolas Island
Stringfellow
Glen Avon
Aerojet General Corp.
" Azusa.
Dynamic Propellant
Ontario
McKesson Chemical Co.
Riverside
Jet Propulsion Laboratory (NASA)
Pasadena
Aerojet General Corp. -Rancho Cordova
Rancho Cordova
San Gabriel Valley
Baldwin Park
Lockheed Propulsion Company (Former)
Redlands
Astro Pyrotechnics
Rialto
B.F. Goodrich Aerospace & Defense Products
Rialto
NATIONAL TECHNOLOGIES SYSTEM (NTS)
Hi-Shear Technology Corp.

Santa Clarita
Whittaker Bermite Division.

Saugus
WYLE LABS
Denova Environmental
FUOs FIVE MILES FROM MUNICIPAL SUPPLY WELL

ANAHEIM AIRPORT
STOCKTON ORDNANCE DEPOT
MARCH AFB RIFLE RANGE
MARCH FIELD
SAN NICHOLAS ISLAND NAVAL RES.
SANTA ANITA RECEPTION CENTER ARMY CAMP
STOCKTON MIL AF
POLLOCK STOCKTON SHIPBLDG
SUNNYVALE
HANFORD WAREHOUSE
The data provided in this table is from the USEPA. The USEPA collected data from various sources (USGS, USACE, California DHS). The SWRCB is not
Perchlorate
000, FUDs and Manufacturers Within 1·mile and 5·miles of a Municipal Supply Well
SPADRA GENERAL HOSPITAL

MCCLELLAN AFB OUTER MARKER
SAN NICHOLAS AIRFIELD
NORWALK AF POL RETAIL DIS #2
SAN ANTONIO DAM
MIRA LOMA ENGR SUB-DEPOT
LA RIVER IMPR SEC VII
ADVANCE Q.M. DEPOT
ARMY AIR CORPS SUPPLY DEPOT
ONTARIO ARMY AIRFIELD
ORDINANCE BACKUP STORAGE DEPOT
RYAN AIRCRAFT SCHOOL
OBSERVATION SQUADRON ONTARIO ARMY AIRPORT
QUARTERMASTER SUPPLY DEPOT
WEST COAST AIR TRAINING CENTER
NAVAL RESERVE ARMORY
VULTEE AIRCRAFT CO.
VEGA AIRCRAFT
ALHAMBRA AIRPORT
ARLINGTON STAGING AREA CAMP ANZA
WESTERN STOVE BOMB PLANT
HAYWARD BOMB PLANT
ARMY SUPPLY BASE GENERAL DEPOT
VEGA AIRCRAFT
VULTEE TRAINING FIELD \
PALMDALE AIRPORT
STATE GUARD AIR FIELD
NAVAL AIR STATION
IRVINE PARK- ARMY CAMP
AF PLANT #14 :.
CAMP KOHLER
LOS ANGELES ORDNANCE DEPOT
PRODUCTION FLiGH TEST AF PLT42
NIRF (UNDERSEA CENTER)
FORMER NIKE SITE LA-14 LAUNCHER AREA
NORTH AMERICAN AVIATION
SAN BER ENGR DEPOT
responsible for its accuracy. . Page 3
Perchlorate
000, FUOs and Manufacturers Within 1-mile and 5-miles of a Municipal Supply Well
MC SUPPLY FORWARDING ANNEX

NAAS SANTA ROSA
SANTA ROSAAAF
LONG BEA MUNICIPAL AIRPORT
PALM SPRINGS ARMY AIR FIELD
GRAND CENTRAL AIR TERMINAL
CPANZA
BREA FLOOD CONTROL BASIN
SANTA ANITA ORD TRAINING CTR
CLAREMONT RIFLE RANGE
MARCH TVOR ANX
WINDSOR POW LABOR CAMP
NIROP SACRAMENTO
NAS MOFFETT FIELD
NSC ROUGH & READY ISLAND
SHARPE GENERAL DEPOT
AF PLANT #71 (AIR RROD&CHE
CLASSIFICATION YARD
KINSBURY AUX FLD #1
TRACY AUX FLD #5
PORTERVILLE ARMY AF
AZUSA DUMP SITE OWL 4X PL
NIKE BATTERY 14 - SILOS
SAN BARNARDINO ARMY AIRFIELD
MOFFETT MIL AF
\
MARCH MILITARY AIRFIELD
SANTA ROSA FEDERAL CENTER
GEN ENGRG & DRYDOCK CO
AF PLANT #42 K9ANX
AIR FORCE PLANT #1~ (NASA)
MCCLELLAN COMM FAC ANX
NORWALK AF POL DIST STATION #1
MARQUARDT RAM JET DEV FACILITY
AIR FORCE PLANT 15 (NAA)
MARCH COMMUNICATION ANNEX #2
KINNER MOTORS
DOWNEY FAMILY HOUSING
I
• I
Perchlorate
CHEll AFS
AIR FORCE PLANT #76
VAN NUYSAAF
NORTON AFB ILS OUTER MARKER AN
MC CLELLAN SRC AUX
BAKERSFIELD MUNICIPAL AIRPORT
CAL-AERO AIRPORT
CARBON CANYON FLOOD CONT BASIN
FACTORY TRAINING SCH/DOUGLAS
DEL MAR-ENCINITAS FCS #1
GRIFFITH PARK PHOTO CENTER
GRIFFITH PARK EXPERIMENTAL LAB
HANSEN FLOOD CONTROL BASIN
FULLERTON DAM-E FULLERTON CREE
LA DEF AREA NIKE BTRY 96
KOBE INC
KAISER SHELL CASING PLANT
JET PROPULSION LAB
LONG BEACH CA BRIGADE SITE
LOCKHEED AIR TERMINAL /D/
LA DIST ENG CON PROJ OFF
LA DIST MAINT YARD
MIRA LOMA AIR FORCE STATION
MIRA LOMA QUARTERMASTER DEPOT
MARCH WATER SYSTEM ANNEX
LOS ANGELES MEDICAL DEPOT "
LOPEZ FLOOD CONTROL BASIN
ORANGE COUNTY ARMY AIRFIELD
ONTARIO A.N.G. TRAINING S~TE
NORTON AIR FORCE BASE
PRADO FLOOD CONTROL BASIN
POMONA QUARTERMASTER DEPOT
PASADENA AREA SUPPORT CENTER
POMONA ORDNANCE DEPOT
PALMDALE CANT AREA
PALMDALE ARMY AIR FIELD
SAN ANTONINCHINO CREEKCHANNEL
The data provided in this table is from the USEPA. The USEPA collected data from various sources (USGS. USACE, California DHS). The SWRCB is not
Perchlorate
000, FUOs and Manufacturers Within i-mile and 5-miles of a Municipal Supply Well
SALVAGE SEGREGATION CENTER

SAN BERNARDINO BASE GEN D RR#1
RIALTO AMMUNITION STORAGE POIT
LOS ALAMITOS RADAR BOMB SCORIN
RADAR BOMB SCORING
QUARTERMASTER STORAGE
SAN BERNARDINO ENG SUB-DEPOT
SAN BERNARDINO CWS PL
SAN BERNARDINO BASE GEN D RR2
SEPULVEDA FLOOD CONTROL BASIN
SANTA FE DAM
SAN ANA AIR NG RADAR RELAY
SANTA ANITA ORD TRNG CT RIF RG
SAN GABRIEL RIVER IMPROVEMENTS
SAN FERNANDO PLAYGROUND
U.S. ARMY RES CENTER PACOIMA
USARC BELL
USAR OUTDR TRAINNG AREA WH NAR
U.SAR. HUNTINGTON PARK
TUSTIN NATIL GUARD RIFLE RANGE
TORNEY GEN HOSPITAL
VAN NUYS MET AIRPORT
USARC SANTA ANA
WHiniER NARROWS FC BASIN
WEST LA AREA STATION HOSPITAL,
STO DIV CAN & CAL .
SHARPE ARMY DEPOT
BOMB MANUFACTURING/STORAGE PLT
CAMPONO POW
USNAS LOS ALAMITOS
NAVAL WEAPONS INDUST RES PLT
MCAS HOLFMILE FIELD
CALIF REHABILITATION CENTER
NAVAL ORDNANCE LAB
TAYLOR FORCE & PIPE CO
WESTERN GEAR WORKS OF CA
NAVAL INDUSTRIAL RESEARCH AP
Perchlorate
MCAS SANTA ANA

CORONA ANNEX
BRAZIL STREET DEPOT
LOCKHEED-CALIFORNIA
STEARNS-RODGERS
ONTARIO ARMY AIRFIELD
NINTH SERVICE COMMAND
AF PLANT #14 STORAGE ANNEX
NORTON COMMUNICATION FACILITY
SANTA ROSA FEDERAL RESERVE CENTER
NIKE BTRY #09-MT DISAPPOINTMENT
NIKE BTRY - LOS PINETOS
AIRSTRIP N SAN BERNARDINO
PASADENA ARMY HOSPITAL
NORCO USARC
PYRITE CANYON
.ARMY FIELD (OPERATIONS HOSPITAL)
ADEL PRECISION PRODUCTS CORP.
AEROJET ENGINEERING CORP.
ASSOCIATED MANUFACTURING CO.
AVIATION GASOLINE FACILITIES
AXELSON CORP.
BAASH-ROSS TOOL COMPANY
BAKERSFIELD GAUYULE PROCESSING MILL
BAKERSFIELD VEGETABLE DEHYDRATION
CAL-AERO FIELD \
CALIFORNIA INSTITUTE OF TECHNOLOGY
CAMP COMMANDER
CAMP RUBIDOUX - ARMY
CHINO PRISONER OFWAR CAMP - ARMY
CHRYSLER MOTORS
COMPAK FOODS
FIRESTONE TIRE & RUBBER CO.
GENERAL METALS CORP.
GLOBE ASBESTOS CO.
HIGHLAND AVE. AUXILIARY FIELD
HQ SOUTH DIST. 9TH SERVICE COMMAND
Perchlorate
JOSHUA HENDY IRON WORKS

KERN COUNlY DEHYDRATING PLANT
KINNEY ALUMINUM CO.
LA QUINTA
LINCOLN FOUNDRY CORP.
LOS ANGELES SIGNAL DEPOT
LOS ANGELES U.S.N. REPAIR DEPOT
MAGNOLIA HOUING PROJECT
MENASCO MANUFACTURING CO.
MERCOCO.
METROPOLITAN AIRPORT
NATIONAL CYLINDER GAS CO.
NAVAL HOSPITAL
NAVAL HOSPITAL UNIT6
NAVY TRAINING SCHOOL
NEWHALL AIRFIELD
NORTHERN TRANSPORTATION CO.
NORWALK AIRPORT - ARMY
PACIFIC PUMP WORKS
POMONA AIRPORT
RHEEM MANUFACTURING CO.
ROSS FIELD
SAN FERNANDO VALLEY AIRPORT
SAN NICOLAS ISLAND ARMY AIR BASE
SOUTHERN CAL. GAS CO. \
VARDS INC
WEBER SHOWCASE AND FIXTURE CO.
WILSHIRE OIL CO.
MCCLELLAN AFB TEMPORARY HOUSING
TEMECULA BOMB TARGET #107
OUTER LANDING FIELD COTATI
LAKE HODGES SCAR ROCKET RANGE
FUOs ONE MILE FROM MUNICIPAL SUPPLY WELL

STOCKTON MI L AF
MIRA LOMA ENGR SUB-DEPOT
ORDINANCE BACKUP STORAGE DEPOT
The data provided in this table is from the USEPA. The USEPA collected data from various sources (USGS. USACE, California DHS). The SWRCB is not
Perchlorate
WEST COAST AIR TRAINING CENTER

VULTEE AIRCRAFT CO.
VEGA AIRCRAFT
HAYWARD BOMB PLANT
VEGA AIRCRAFT
VULTEE TRAINING FIELD
STATE GUARD AIR FIELD
NIRF (UNDERSEA CENTER)
NORTH AMERICAN AVIATION
GRAND CENTRAL AIR TERMINAL
AZUSA DUMP SITE OWL 4X PL
SAN BARNARDINO ARMY AIRFIELD .
SANTA ROSA FEDERAL CENTER
AIR FORCE PLANT #16 (NASA)
MARCH COMMUNICATION ANNEX #2
CHEll AFS
JET PROPULSION LAB
LA DIST ENG CON PROJ OFF
ORANGE COUNTY ARMY AIRFIELD
NORTON AIR FORCE BASE
POMONA QUARTERMASTER DEPOT
POMONA ORDNANCE DEPOT
SAN ANTONINCHINO CREEKCHANNEL
RIALTO AMMUNITION STORAGE POIT
QUARTERMASTER STORAGE
SAN ANA AIR NG RADAR RELAY \
USARC BELL
USAR OUTDR TRAINNG AREA WH NAR
TORNEY GEN HOSPITAL
STO DIV CAN & CAL i "
SHARPE ARMY DEPOT
NAVAL WEAPONS INDUST RES PLT
NAVAL INDUSTRIAL RESEARCH AP
CALIFORNIA INSTITUTE OF TECHNOLOGY
CAMP RUBIDOUX - ARMY
CHINO PRISONER OF WAR CAMP - ARMY
HQ SOUTH DIST.
The data provided in this table is from the USEPA The USEPA collected data from various sources (USGS, USACE, California DHS). The SWRCB is not
Perchlorate
JOSHUA HENDY IRON WORKS

LINCOLN FOUNDRY CORP.
LOS ANGELES U.S.N. REPAIR DEPOT
NAVY TRAINING SCHOOL
NEWHALL AIRFIELD
PACIFIC PUMP WORKS
VARDS
,J
DRAFT Emergent ChemicallPerchlorate Letter Requests as ofSeptember 12,2003
- -
USSRAAF 1 712112003 9130/2003 Source Evaluation Report NONE
A1amedaNAS 2 6/1112003 9/1512003 Source Evaluation Report NONE
Alameda Naval Supply Center (NSC) Annex 2 611112003 9/1512003 Source Evaluation Report NONE
Concord Naval weapons Station 2 612712003 912712003 Source Evaluation Report 21191056
Concord PFC Bacciglieri Armed Forces Reserve Cente 2 7/112003 101112003 Source Evaluation Report 2119.1236
Golden Gate Nalional Recreational Area 2 612712003 912712003 Source Evaluation Report 2159'.5145
Hayward Army Airfield 2 7/112003 10/112003 Source Evaluation Report 2199.9441
San Jose AMSA 12sUB 2 7/112003 101112003 Source Evaluation Report 2119.1236
SANDIA NATIONAL LABS DOE 2 612712003 912712003 9/17/2003 Source Evaluation Report 2119.91
\
TravisAFB 2
Vallejo Young USARC 2 7/112003 101112003 Source Evaluation Report. 2129.2086
Camp Stoneman 2 71112003 10/112003 Source Evaluation Report 2199.1239
OAB Heroic War Dead USAR (B1086, 1060, 1064, 1070, 2 71312003 10/112003 Source~Evaluation Report 2199.944
Camp Roberts 3 81612003 10/612003 Source area evaluation report NONE
Fort Hunter Liggett 3 8/112003 101212003 Source area evaluation report NONE
LOMPOC, BRANCH U.S. DISCIPUNARY BARRACKS 3 81612003 10/612003 Source area evaluation report NONE
Monterey Peninsula Airport 3 91312003 10/28/2003 Source area evaluation r!'Port NONE
Presidio of Monterey 3 9/312003 1012812003 Source area evaluation report NONE
Vandenberg Air Foroe Base 3 419/2003 51912003 11/112003 5/2012003 Source area evaluation report YES NONE
San Nicolas Island (incl. With PI. Mugu NAWS) 4

Naval Information Research Foundation (J09CA105200 4 9/1112003 1113012003 source area evaluation NONE
Naval Marine CoMilitarys Reserve Center, Los Angel 4 512912003 9/3012003 source area evaluation NONE
Oxnard Air Base, Camarillo Sile (J09CA012600) 4 6/1712003 9/3012003 source area evaluation NONE
San Pedro, Fuel Tenninal DFSP 4 5/2912003 9/30/2003 source area ·evalualion NONE
Bakersfield Municipal Airport 5 ,
Source Area
Beale Air Foroe Base 5 6/1112003 9130/2003 Characterization Report NONE
Source Area
Beale Air Force Base - Tnan 1A 5 811112003 9130/2003 Characterization Report NONE
Source Area
Beale Air Force Base - Han 1B Suller Co 5 811112003 913012003 Characterization Report NONE
Source Area
Beale Air Force Base - Han lC. Bulle Co. 5 611112003 913012003 Characterization Report NONE
Source Area
Castle Air Force Base 5 611112003 913012003 Characterization Report NONE
Source Area
Defense DislributionSan Joaquin CA - Sharpe 5 611112003 913012003 Characterization Report NONE
Source Area
Defense Distribution San Joaquin CA - Tracy 5 611112003 913012003 Characterization Report NONE
S6urceArea
Deganawidah-Quetzalcoatl University 5 6/1112003 9/3012003 Characterization Report NONE
DoD Siles with RB Llfs

DRAFT Emergent ChemicallPerchlorate Letter Requests as of September 12,2003
------------------ - - -
- Source Area
Dixon Naval Reserve Training Facility 5 6/1112003 913012003 Characterization Report NONE
Source Area
Mather Air Forca Base 5 611112003 913012003 Characterization Report NONE
Source Area
McClellan N4 Force Base 5 6/1112003 913012003 Characterization Report NONE
Riverbank AAP 5 6111/2003 913012003 Souroe Area Evaluation Report NONE
Sacramento Army Depot

, Source Area
Characterization Report
5 611112003 913012003 NONE
SouroeArea
Stockton NCS 5 611112003 9/3012003 Characterization Report NONE
EdwardsAFB 6
Azusa Dump S~e 6
EI Toro MCAS 6 611212003 913012003 Source Area Evaluation Report NONE
Los Alamitos Armed Forees Reserve Cenler 6 611212003 913012003 Source Area Evaluation Report NONE
March Air ForoeBase 6 911112003 913012003 Source Area Evaluation Report NONE
March AJr Reserve Base 8 611212003 913012003 Source Area Eval.:.ation Report NONE
Norton AJr Force Base 8 611212003 913012003 Source Area Evaluation Report NONE
Riallo Ammo Storage 8
Seal Beach Naval weapons Station 8 611212003 913012003 Source Area Evaluation Report NONE
Borrego Springs 9
Coronado NAVPHIBASE \ 9 612012003 1013012003 Source Evaluation Report NONE
Imperial Beach Naval Auxiliary Landing Field 9 612012003 10l3OI2003 Source Evaluation Report NONE
MCAS Miramar 9 612012003 1013012003 Source Evaluation Report NONE
North Island Naval Air Station 9 612012003 1013012003 Source Evaluation Report NONE
Point Lorna Naval Complex SPAWAR • PLC 9 612012003 10l3OI2003 Source Evaluation Report NONE
San Diego FASWfC PAC 9 6/2012003 1013012003 Source Evaluation Report NONE
San Diego FISC (NSC) ; .1 9 612012003 1013012003 Source Evaluation Report NONE
San Diego MCRD 9 612012003 1013012003 Source Evaluation Report NONE
San Diego Naval Station 9 612012003 1013012003 Source Evaluation Report NONE
San Diego NAVSUBASE 9 612012003 1013012003 Source Evaluation Report NONE
San Diego NeTS 9 612012003 1013012003 Source Evaluation Report NONE
San Diego NISE-west (NOCCSC Old Town Campus)(formerly AF P1t#19) 9 612012003 1013012003 Source Evaluation R<lport NONE
San Diego NTC (BRACIII or DERA?) 9 612012003 1013012003 Source Evaluation Report NONE
Fallbrook Naval Weapons Station 9 612012003 1013012003 Source Evaluation Report NONE
warner Springs SERE Camp 9 612012003 1013012003 Source Evaluation Report NONE
CALIFORNIA AIR NATIONAL GUARD ?? 612712003 912712003 Source Evaluation Report. 2199.9154
DoD Siles witll RB Llrs 2

DRAFT Emergent Chemical/Perchlorate Letter Requests as ofSeptember 12,2003
unawater. Sne 12. No exposure patflw 'undWater no'

used as a drinking water source
Wei
\
Perchlorate max detect 492 uglL in gtN at site 16, OSfOO
mon~oringwell (000 Charter Mig)
DoD Sites with RB Ltrs 3

DRAFT Emergent ChemicalfPerchlorate Letter Requests as of September 12,2003
site, 50 we are perloming environmental deanup under the

CERCLA process with Stale and Federal regulator oVef"Site. We
have a groundwater plume under Mather as a result of
AerojetlBoeing past practice
GWand Soil: Rocket Research 300 ppb detected in GW plume.

Ion exchange perchlorate is currently being demonstrated. North
Base is contaminated by perchlorate and organic solvents.
Detectedi" soil (max detect 36,000 uglL in plume from jet
Groundwater 380 ppb
Drinking water >4 ppb to 811 ppb
; ,
DoD Sites with RB Ltrs 4
v
~
Unknown
/1/1
From: Cotter, Sandra, Ms, OSD-ATL
Sent: Wednesday, April 16, 2003 11 :27
To: 'Richard B. Belzer PhD'
SUbject: FW: Senators Urge 000 to Take 'Aggressive' Role In Perchlorate Clean Up
~
Draft LeUer to
Congress 8 Apr. ..
~
-'
1
.----_J \
.;
> -----Original Message----

> from: ferguson, Phyllis~ Ms, OSD-ATL
I
> Sent: friday, April 04, 2003 1:34 PM

> To: Grone, Philip, Mr, OSD-ATu; DuBois, Ray, Mr, OSD-ATL; -Kratz, Kurt,
> , OSD-ATL; Sullivan, Maureen, Ms, OSD-ATL

> Cc: Ungaro, Ronald, CDR, OSD-ATL; Armstrong, Brett, LTC(P), OSD-ATL;
> May, Lisa, Maj, OSD-ATL; Woodley Jr., John, Mr, OSD-ATL
> Subject: fW: Senators Urge DoD to Take 'Aggressive' Role In
> Perchlorate Clean Up
>
> FYI - Press Release from Glenn on Perchlorate below
>
> from: flood, Glenn, CIV, OASD-PA
> Sent: Friday, April 04, 2003 1:30 PM
> To: Woodley Jr., John, Mr, OSD-ATL
> Cc: Ferguson, Phyllis, Ms, OSD-ATL
> Subject: Senators Urge DoD to Take 'Aggressive' Role In Perchlorate
> Clean Up
>
> FYI----
> GF
>
>
>
> fOR IMMEDIATE RELEASE:
>
> Thursday, April 3, 2003
>
> Senators Feinstein, Reid, Boxer Urge Department of Defense to Take
> 'Aggressive' Role In Perchlorate Clean Up
>
> Washington, DC - U.S. Senators Dianne Feinstein (O-Calif.), Harry Reid
> (D-NV), and Barbara Boxer (D-Calif.) have urged the Department of
> Defense to take an 'aggressive and positive' role in the cleanup of
> perchlorate in groundwater supplies in California and across the
> nation.
>
> Widely used during the Cold War, perchlorate is a primary ingredient
> in rocket fuel. According to a recent report by the California
> Department of Health Services, perchlorate has been detected in water
> supplies in 22 states including the Colorado River. In California,
> perchlorate has been found in 292 groundwater wells operated by 80
> different agencies.
>
> Specifically, the Senators urged the Department of Defense to:
>
> * Provide information on the sites that pose the greatest threat to
> Americans' health; and
>
2
~
> * Describe the initial measures the Department would take to reduce
> perchlorate contamination at those sites.
>
> In a letter to Secretary of Defense Donald Rumsfeld, the Senators
> wrote: "We write you to request that the Department of Defense take a
> more aggressive and positive role in cleaning up defense-related
> perchlorate contaminated water supplies in as many as 22 states from
> California and Nevada to Massachusetts and Maryland.
>
> "We are seriously concerned that the Department's proposed exemption
> from environmental laws will limit its responsipility to clean up
> perchlorate. The state officials who are sworn to protect their
> citizens' drinking water from perchlorate and other threats have
> expressed alarm that their efforts will be preempted by your
> amendment .... This is a serious matter, because perchlorate can impair
> thyroid functioning and affect the physical and mental development of
> children.
>
> "To the best of our knowledge,/nearly all the perchlorate ~roduced in
> the United States over the last half century was used by the
> Department and our space program. This means that if the Defense
> Department ducks responsibility for its actions here, the burden will
> fallon hundreds of America's communities, whose residents will face
> not only contamination of their drinking water but the staggering
> costs of cleaning up a problem they did not create. This is completely
> unacceptable.
>
> "The plain truth is that the Department of Defense has long been not
> only the primary consumer of perchlorate, but also intimately involved
> in its manufacturing.

>
> "For example, between 1951 and 1962 the U.S. Navy owned and contracted
> for the operation of the largest perchlorate production facility in

> the country located in Henderson, Nevada. Even after relinquishing its
> ownership of the facility, the Department and its contractors

> continued to be the primary customers of its perchlorate.' Perchlorate
> from this facility is leaching into Lake Mead and the Colorado River,
> impacting water supplies in California, Arizona and Nevada. While
> aggressive cleanup efforts are underway at the site, we are very
> concerned that the Department has not actively engaged in contributing
> to that cleanup.

> .
> "The Department has also been involved in many other serious
> perchlorate contamination sites in our states. The California
> Department of Health Services has detected perchlorate in 292 public
> groundwater wells, the majority of which are located near facilities
> operated by the Department or its contractors.
>
> "The Defense Department has said that it is not willing to start
> clean-up of perchlorate until there is a national standard, but
> finalizing the standard is currently projected to take years. It is
> unacceptable for the Defense Department to adopt this delay strategy
> while private parties and drinking water utilities adopt costly
> measures to assure the purity of drinking water supplies. Companies
> have already spent millions on priority actions to reduce the threat
> to Americans - and we urge the Defense Department to do so as well.
>
> "One obvious priority effort is to try to stem· the flow of perchlorate
> into the Colorado River from the Henderson facility described above.
> Kerr-McGee, which operated the facility after the Defense Department,
3
~
> has built a state-of-the art ion-exchange facility and taken other
> measures in an attempt to address the problem. Yet the Defense
> Department has done nothing. The federal government cannot sit idly by
> where its actions are affecting the quality of our drinking water.
>
> "We request that the Department report back to us on the top priority
> sites around the country for it to reduce perchlorate contamination in
> drinking water, and what initial measures the Department would take in
> California, Nevada, Arizona, Texas and other states, given available
> funding. We expect a-serious and detailed response as warrants a
> potential threat to Americans' health.
>
> "We hope that you will join us in the spirit of cooperation to address
> this important issue. We look forward to hearing from you as soon as
> possible."
>
> A copy of the Senators' letter is available upon request.
>
> ###
>
> -----------------------------------------------
> You can find archived listserve messages on the CPEO website at
>
> http://www.cpeo.org/newsgrp.html
>
> If this email has been forwarded to you and you'd like to sUbscribe,
> please send a blank message with no subject to:
>
> cpeo-military-subscribe@igc.topica.com
>
> ==A===========================================================~====
> This email was sent to: roxanne_yonn@urscorp.com
>
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>
> Name: QFR-SAC

MILCON 18Mar03-#13-15-16-17 ver030403.doc
> QFR-SAC MILCON 18Mar03-#13-15-16-17 ver030403.doc Type: WINWORD_
File (application/msword)
> Encoding: base64
Daniel Kowalczyk
Booz Allen Hamilton
8283 Greensboro Dr
~cLean, VA 221Q2
L. ---1
4
a31\Oll\l3~
'S38Vd
Unknown 461
Sent: Friday, February 28,200312:01
To: Cohen, Ben, Mr, DoD OGC
Cc: Choudhury, Shah, Mr, OSD·ATL; Kratz, Kurt, , OSD-ATL
Subject: RE: Florida DEP Proposal for Perchlorate Cleanup Target Level
.11)
fY~ r: ;£
-"
I
I
•
>
I
I
[
I
-----Original Message----
Sent: Friday, February 28, 2003 11:20 AM
To: Cohen, Ben, Mr, DoD OGC
Subject: FW: Florida DEP Proposal for Perchlorate Cleanup Target Level
-----Original Message----- .- ~
From: Kowalczyk Daniel [mailto
Sent: Friday, February 28, 200j 10:57 AM- ~
To: Geoffrey Cullison; Lt Col Dan Rogers; Shah Choudhury; Lt Col Jeff
Cornell; Mike Garrison; Larry Glidewell; Angela Atkins; David Carrillo;
Bryan Harre; Norman Gelfand; Erica Becvar; Dave Mattie; Cornell Long;
Kurt Kratz; Maj David Rose; Jeff Breckenridge; Connie Van Brocklin;
Elaine Ross; Katharine Kurtz; Michael Major; Malcolm Garg; Lt Col
Barbara Larcom; Sardar Hassan; 'Maj Bill Myer; Ben Gregson; Maj Sandy
Sinay; Lt Col Jacqueline Little; Gail Bruss; Capt Lucy Murfitt; Lois
1
Bohne; Marriane Miclat; Larry Groner; Sandra Cotter; Shawn Holsinger;
Richard Mach
Subject: Florida DEP Proposal for Perchlorate Cleanup Target Level
FYI - NAVFAC provided the following file indicating recent decision by

Florida DEP to establish a 4.3 ppb cleanup target level for perchlorate.
vir
Dan
Daniel Kowalczyk
Bo02 Allen Hamilton
can,
8283 Greensboro Dr
VA 22~
---
2
Chapter 62-777, F.A.C.
Workshop IV Update
Dr. Steve Roberts
University of Florida
,!
Center for
En,,~.mental
:human
Toxicology
,
Changes in Exposure Assumptions

• Body weight
• Body weight assumptions are based on NHANES III data.
• When the exposure scenario involves a change in body weight over
time (e.g., aggregate resident), a more refined averaging process is
used.
• GCTLs and surface water targets are now based on updated adult
body weight (76.1 kg versus 70 kg previously)
• Surface area exposed
• Total body surface area is estimated based on body weight data
from NHANES III.
• Total surface area exposed is calculated based on specific body
:' areas assumed to be exposed in different scenarios (e.g., hands,
arms, lower legs, etc.)
2
Changes in Body Weight
Ch. Proposed
Receptor 62-777 Reference Reference
Value
i
I Derived from weighted i Derived from weighted
Aggregate I I average of child and average of child and
resident II 59
i adult body weights using 51.9
adult body weights
two age intervals.
~~~-~--i-_~~"!l annual intervals.
J
~"'-'--------"-_.'-'-"--~~'-'-'--'--"-""--"-'--
Exposure Factors,
Child II 15 I i USEPA 1991 (OSWER 16.8
I.l 1'1
I i No. 9285.6-03).
II I I Derived from NHANES
III data using annual
I I I I intervals.
RAGS (part A), USEPA
Adult! II
70 1989a (EPAl540/1- II 76.1
Worker II I 89/002).
3
Changes in Surface Area
! .
II I
62-
Receptor 777 Reference
I Proposed Reference
\
F.A.C. i
Value
--
Derived based on data

!---~----
Aggregate
resident
3674 from the Exposure
Factors Handbook,
I 4810
Total surface area
~._----_ ....• .,---~-'------
I
derived from NHANES

USEPA 1989b III body weight data
Child 1800 (EPAl600/8-89/043). I
I
2960
1- \
Derived based on data in

Dermal Exposure
I
I
I
using allometric scaling;

body part percentages
obtained from the
Exposure Factors
Aduttl Assessment: Principles I
Handbook, USEPA
Worker
2000
and Applications, USEPA I
3500
1989b (EPAl600/8
1992 (EPAl600/8- I
89/043).
L 91/011 B). !
_._. L
4
I
More Changes in Exposure Assumptions
• Soil-to-skin adherence factor

• Adherence factor assumptions are based on new data on soil
adherence on different parts of the body.
• An area-weighted average adherence factor is used depending
upon the body surface areas assumed to be exposed.
• Inhalation rates
• Gastrointestinal absorption rate
• The default gastrointe.stinal absorption rate is changed to 1000/0.
Chemical-specific GI absorption rates previously used remain
unchanged.
•:, Fish ingestion rate
• The fish ingestion rate used to calculate surface water criteria
based on human health has been increased from 6.5 to 17.5 g/day
(the new EPA default).
5
Changes in Adherence Factors
Receptor I , I
I!: 62-777 II ~ I Reference
IiI
I"I: II
Proposed
Value ,
Reference
1
I:; F.A.C.
!t;
i
ii 1--------
Agg~egate I,! 0.2 I !iI 0.1 '
resIdent I! i I Selected from range of ::I RAGS (part E),
I! i values in Dermal II ~ I USEPA 2000
1-------------- - -I LT-----~----I--- E~po~ure Assessment Su~plemental
I! I --..- ---,,-
.
Child
I, iii
,I 0.2 I
Prln~lpl~s and
Applications, USEPA
Ii
i;I
'I 0.2 G.U1dance for Dermal
Risk Assessment _
I
11-- - - - 11+-I:;!
;!
II 1992 (EPN600/8-
91/011 B).
111-----------
I I
Interim Guidance.
Adult! I' I
Iii
0.6 I
I
II
, i
0.2
Worker I'I i i i
Ii I j1 . _
6
Changes in Inhalation Rates
.I
62-777 Proposed
Receptor Reference Reference
F.A.C. Value
Derived based on
inhalation data by age
Derived from
and activity from the

Aggregate inhalation data by
15 ; Exposure Factors 12.2

resident age based on
Handbook, USEPA
. metabolic
1989b (EPAl600/8
l;~r'~~~'
_ i) requirements,
.....
\
...........
Exposure Factors
RAGS (part A), USEPA Handbook, USEPA
Child 10 1989a (EPAl540/1 8.1 1997.
. 89/002).
;
i!
.
Exposure Factors,
Adult!
20 USEPA 1991 (OSWER 20 Unchanged

Worker
No. 9285.6-03).
7
Toxicity Values Update
• Hierarchy of sources for obtaining toxicity values.
• Old: IRIS; HEAST; NCEA
• New: IRIS; NCEA; HEAST
• SCTLs reflect changes in toxicity values since the previous rule.
• Chloroform is now classified as a threshold carcinogen.
• The SCTL for chloroform is based in part on an oral reference
dose, which is thought to protect against both cancer and non
cancer effects.
'.
• More chemicals have been identified as C carcinogens.

• Sources other than IRIS have been consulted to identify C
i! carcinogens.
• This affects GCTL calculation where the GCTL for non-cancer
I
effects is divided by 10 for C carcinogens (e.g., naphthalene).
8
i
Criteria for Perchlorate in Drinking Water
USEPA USEPA USEPA USEPA OEHHA

(1992) (1995) (1998)* (2002)* (2002)*
Adult 4 4-18 32 1 6
2 L/day; 70 kg.
Child 1 1-5 10 0.3 2

1 L/day; 10 kg
i'
*Draft documents
All concentrations are in IJg/L.
9
Adult Lead SCTL
• EPA has updated the adult lead model.

• The recommended GSD and baseline blood lead
concentrations have changed.
• This affects commercial/industriallead SeTl only.
• Changes from 920 to 1400 mg/kg .
'.
i'
10
SCTL and GCTL Tables
• More 'extensive listings "of synonyms.

• Changes in some surface water criteria to be more
consistent with Chapter 62-302.
• Listings for individual carcinogenic PAHs have been
replaced with a single entry for total carcinogenic PAHs.
• Value for silver changed.
• All GCTL listings are now risk-based.
• -Some may be below quantitation limits.
,,
11
,
Technical Background Document

• Explains more completely h'ow to calculate
polychlorinated dibenzodioxin and polychlorinated
dibenzofuran toxic equivalents and how to compare
them with the SCTls.
• All dioxin and furan mixtures should be converted to total
2,3,7,8-reDO equivalents.
• Explains how to handle non-detects for individual congeners.
• Contains a section discussing the uncertainties
i' associated with SCTls. This section will be
expanded.
12
Leaching of Arsenic from Soils
• The current leachability SCTls for inorganics are based on a
partitioning equation developed by the U.S. EPA (Soil Screening
Guidance, 1996).
• leaching of inorganics from soil to water can be highly site
specific. For some inorganics, the partitioning coefficient (Kd)
can vary by orders of magnitude.
• For some inorganics, the range of potential Kds is so large, a
leaching SeTl wasn't developed (e.g., lead and copper).
• There is empirical evidence that the leachability SCTl for
arsenic (29 mg/kg) does not protect groundwater at some sites.
i! • Soils with 10 to 20 mg/kg have produced groundwater
concentrations> the 50 ppb primary standard for arsenic.
• The proposed solution is to remove the leachability SCTl for
arsenic and require a site-specific leaching test (SPLP).
13
I
Arsenic Bioavailability from Soils

• The current SCTL for arsenic includes a default assumption of
100% relative bioavailability.
• Toxicity [cancer] data for arsenic were developed from populations
exposed to arsenic in drinking water.
• A relative bioavailability assumption of 100°A> means that the
absorption of arsenic from soil is considered to be equal to the
absorption of arsenic from water.
• Data from experimental studies indicate that the absorption of
. arsenic from soils is less than from water.
• These data include results from a study of arsenic bioavailability in
. soils from five contaminated sites in Florida using a primate model.
~' The FDEP is considering an adjustment to the default
bioavailability assumption based on these data.
• Any adjustment would result in a nearly proportional increase in the
arsenic direct exposure SCTL.
14
I ~ jg
From: Kowalczyk Daniel ~. I]

Sent: Friday, August 15, :lUU3 16:57
To: Kurt Kratz; Sandra Cotter
Cc: Jean McCarty; Richard Belzer
Subject: ASTSWMO Presentation
Importance: High
~
draft Kratz
STSWMO Aug03.PI
Sir,
A small presentation for your ASTSWMO meeting. Good luck with all of
them!
vir
Dan
Daniel Kowalczyk
can, VA 22:i
Booz Allen Hamilton
8283 Greensboro Dr
1
AT&L I Installations & Environment _
Science, Policy and the Regulatory

Process:
A DoD Perspective of Perchlorate
and Other Unregulated Contaminants
Briefing
To the Association of State and Territorial
Solid Waste Management Officials
August 20, 2003
DoD's Persp_ec_t_iv_e _
• DoD has legitimate concerns about the' scientific

quality of EPA's draft risk assessments for
perchlorate
• Do~ has legitimate concerns with EPA policy and
regulatory procedures for perchlorate and TeE
- The premature use ofdraft risk assessment values, and the

inappropriate use of final values short-circuit established
\
regulatory processes
- Significant implications for other unregulated
contaminants
• These actions drive up cleanup costs, possibly

without achieving estimated public health benefits 2
Science Quality Issues
• 1998 EPA Draft Risk Characterization

- Proposed an RID equivalent to 32 ppb, but did not revise
its 4-18 ppb remediation guidance
- Peer review rejected key EPA definition ofcritical effect,
concluded 32 ppb likely too conservative
- Peer review recommended additional research to provide
sound scientific basis for increasing RID
o DoD and the Perchlorate Study Group (PSG) funded the research
and conducted some ofit
o iEPA agreed with, and sometimes dictated, study protocols and hired
the contractors
- DoD and PSG scientists be.lieve research confirms peer
review conclusion that 32 ppb is overly conservative
3
Science Quality Issues
• 2002 EPA Draft Risk Characterization

- Definition ofcritical effect"changed, RID equivalent to 1
ppb proposed ~ ".
- :qoD and other stakeholders baffled by EPA proposal
o RID expected to go up based on completion ofresearch

recommended by 1998 EPA peer review
- DoD scientists believe the animal studies relied upon by
EPA are flawed, and that there is strong human evidence
that the no effect level is r-.J200 ppb
d .200 ppb no effect level means no adverse effects are even feasible
below 200 ppb
- Wide gap in DoD and EPA perspectives support the need
for an independent National Academy of Science review
4
Policy and Procedural Issues
• Accepted Risk Regulation Process

- Follow proper administrative procedures to ensure due
, "
process and full public participation

- Perform screening level risk assessment - proceed only if
risks exceed level of concern
- Prepare draft comprehensive risk characterization
- Conduct peer review of draft risk characterization
o Ensure the objectivity and scientific soundness of product

o, ,Open, rigorous, independent and external
o Finalize based on peer review and public comment
- Use finalized risk characterization to establish verified
RIDs, RFCs, slope factors
o Science must be clearly distinguished from policy 5

• Accepted Risk Regulation Process - cont'd

- Use RIDs, RFCs, slope factors in the development of
regulations of general applicability (e.g., SDWA standards)
o Use verified (never draft) reference values, and only as starting
, point
o Combine with information on occurrence, treatment technology and
cost
o Derive cost-effective regulations based on all information
"
o Submit draft regulatory standards to OMB for review under EO
12866
, .
o Comprehensive costlbenefit analysis required for draft proposed and
final regulations having an annual effect of $100 million or more
6
• Accepted Risk Regulation Process - cont'd

- Use RIDs, RFCs, slope factors in the development of site
specific risk management decisions (e.g., CERCLA RODS)
o Use verified (never draft) reference values, and only as starting
, point
o Combine with information on likely and significant human exposure
pathways, treatment technology and cost
o Derive cost-effective site-specific remediation targets based on all
information .
; .
7
• Short-Circuiting of the Accepted Risk'Regulation

Process
- Perform screening level risk assessment
- I~sue provisional remediation guidance based on screening
level risk assessment without following administrative
procedures that ensure due process and full public
participation
- Use values from remediation guidance as "bright line"
requirements for cleanup irrespective of site-specific
factors, technology constraints, or cost
- Perform draft comprehensive risk characterization
- Conduct peer review with minimal compliance with
procedural requirements 8
• Short-Circuiting of the Accepted Risk'Regulation

Process - cont'd
- Direct EP'A Regions and "encourage" states to issue site
specific risk management requirements based on draft risk
characterization
o IfPRP raises procedural or substantive objections, use "imminent
and substantial endangerment" authority to force desired action
- Finalize c,omprehensive risk characterization
- Use finalized risk characterization to establish verified
RIDs, RFCs, slope factors
o Interweave science and policy so that distinctions are difficult or
impossible
9
• Short-Circuiting of the Accepted Risk:Regulation

Process - cont'd
- Develop regulations of general applicability (e.g., SDWA
standards)
o If standards are below provisional remediation guidance
• Set using screening level risk analysis
• Reopen remediation decision documents to require compliance
with new lower standards
\.
o If standards are above provisional remediation targets

; ,I
• Set using screening level risk analysis
• Do not permit PRPs to achieve new, higher standards in lieu of
provisional remediation targets
10
• Summary of DoD Policy and Procedural Issues

- Regulatory agencies "putting the cart before the horse" in
the risk regulation process \
- Draft risk assessments and remedial actions cost taxpayers
billions ofdollars
- EPA does not submit draft risk assessments or remedial
guidance documents to OMB or other interagency forum
for review
- EPA does not subject draft risk assessments or remedial
guidance documents to notice and comment provisions of
the Administrative Procedures Act
11
• Summary of DoD Policy and Procedural Issues

- Draft risk assessments say \'Do Not Quote or Cite" on
every page, but EPA Regions and states routinely quote or
cite them as the authority for remediation decisions
- We are concerned that these documents do not comply with
the pre-dissemination review requirements of information
quality guidance
-,
12
Consequences for 000 Cleanup Program
• Cleanup Costs Increase Without Limit

- In 1987, estimated DoD remediation costs at $9-14 billion
, \
- Now, DoD estimated remediation costs at about $50 billion

o Revised estimate does not reflect cleanup costs for emerging or
, unregulated contaminants for which no remediation targets have
been established
• Cleanup Costs
.
Rise Even Before EPA Has
Completed Risk Characterization
- Massachusetts - perchlorate
o DoD must provide bottled water to residents because perchlorate

has been detected at I ppb near a DoD remediation site
o Action level based on controversial EPA 2002 draft risk
characterization set to undergo NAS review

13
Consequences for DoD Cleanup Program
• Cleanup Costs Rise Even Before EPA Has

Completed Risk Characterization - cont'd
- Colorado - TCE
o EPA MeL is 5 ppb, but DoD told to achieve 1 ppb

o Decision based on EPA 2001 draft risk characterization that has
been disavowed by the authors ofthe studies upon which EPA relies
o Science sufficiently controversial that DoD has asked for an
independent 3rd party review
,'
14
"
Unregulated Contaminants
• Unregulated Contaminants
- Examples include perchlorate, TeE, 1,4-dioxane, RDX and
tetrachloroethylene ...
- RDX and tetrachloroethylene slated for assessment and
inclusion in EPA's Integrated Risk Assessment System
(IRIS)
• DoD Striving to Develop Plan for Addressing

Unregulated Contaminants
- Desire a more organized, systematic approach to dealing
with unregulated contaminants
- Use cooperation with EPA 'on perchlorate as model for
addressing unregulated contaminants

15
;
Lessons Learned From Perchlorate
• The Federal Government Needs a Neutral Source

for Scientific Information
- DoD may be perceived as conflicted because it is a
regulated party (biased towards understating risk)
- Ifso, then EPA should also be understood as conflicted
because it is a regulatory agency (biased towards
overstating risk)
- Possible solutions
o :White House office such as OMB or OSTP, or a new office
specifically chartered to address similar issues
o Authoritative, independent, and policy-neutral non-governmental
source
16
o31\011\1 3C1
38Vd
'I :.JJ
DoD Sites with Known Perchlorate Contamination

state State City Facility Statas Contamination Mo. Reference
"Advisories" Identified Cone.
w_-.. .
SolI- JIPII
AL Huntsville Redstone Arsenal Missile Plant NPL Groundwater 19,000 EPA June 2, 2003
Soil NL DoD NPL 0ct03
SDriDgslSeeJ)s 37 EPA Abril 2003
A2 14ppb Bellemont ICamP Navajo Groundwater NL DoDOct03
Tucson Davis Mootban Air Fon:e Base Soil 28 DoDSurvey2
Yuma Yuma Marine Corps Air Station NFL Groundwater 4.21 DoD NPL OCt03
Surface Water 4.S6 DoD NFL 0ct0J
CA 4ppb 'Marysville Beale Air Fon:e Base Groundwater 500 CA SWRCBlDTSC
Ridgccrest China Lab Naval Weapons Station Groundwater 560 CA SWRCBlDTSC
Edwards Edwards Air Force Base NFL Groundwater 160,000 EPA June 2, 2003
Soil 2,100 DoDSurvey2
EI Toro £1 TolO Marine Corps Air Station NPL Grouodwater 380 EPA June 2. 2003
Closed
Rancho Cordova Mather Air Foree Base· NPL Drinking Water ]20 EPA June 2, 2003
Closed Groundwater ],800 EPA l 111Cl 2, 2003
Sacramento McClellan Air Force Baso NPL GroWldwater 6 CA SWRCBIDTSC
Closed
Herlong Sierra Amry Depot Groundwater 8 CA SWRCBlDTSC
Soil 7.52 CA SWRCBIOTSC
Fairfield Travis Air Force Base NPL Groundwater NL DoDOctOJ
Vandenberg AFB Vandenberg Air FOICC Base Groundwater 517 CA SWRCBlDTSC
Soil NL DoD Letter to CalEPA
Sao Nicholas Island US Navy Firing Range Drinkin2 Water 20 CADHS2003
Soil 88 CA SWRCBlDTSC
CO Pueblo Pueblo Chemical Depot Groundwater ]80 EPA June 2, 2003
GA MoodyAFB Moody Air Forci: Base Soil 46.9 DoDSurvey2
IA Middletown Iowa Army Ammunition Plant NPL Groundwater 9 EPA June 2, 2003
30 Interview 02.25.04-EPA official
MA I ppb Bourne Massachusetts Mililaly Reservation NPL Drinking Water 1.75 DoDOct03
Groundwater 300 DoD NPL Oct03
MD I ppb Aberdeen Aberdeen Proving Ground NPL DriDking Water S DoD NPL Oct03
Groundwater 24 EPA June 2, 2003
Soil 0.015 DoD NPL 0ct03
Adelphi Adelphi La1xxatory Center* Groundwater Nt DoDSurvey2
Odenton Fort Meade NFL Groundwater Nt DoDOct03
DemocraUc Stall of the Committee on Energy and Commerce March " 2004
DoD Sites with Known Perchlorate Contamination
State State City FaclUty StatUI Contamination MaL RefereDce
Soiw_-.l-_. .
"AdviJorles" Identified Cone.
TIC 4 ppb, 7 ppb or McGregor McGregor Naval WeapollS Plant

Closed· Groundwater 91,000 EPA June 2, 2003
IOppb. Soil NL EPA June 2. 2003
Springs 22,000 DoD
Surface Water 5,600 DoD
Texarkana Red River Army Depot GroWldwatcr 80 EPA June 2. 2003
Soil NL DoDOct03
Storm Water 82 DoDSurveY2
Surface Water NL DoD0cIt03
UT Ogden Hill Air Force Base NPL Water NL DoD0ct03
Groundwater 70 DoD0ct03
Soil NL DoD0ct03
Orcal Salt Lake Desert Hill AFD, , Groundwater 84 DoD Survey2
Utah Test lU1d Training Range IQuench Water 4.668 DoD SUl'VCY2
Soil 0.25 DoDSurvcy2
Magna, Naval Industrial Reserve Ordnance " NA. NL DoDSurvcy2
Plant (NIROP) facility
at Alliant Techsystems
WA VancOllver Camp Bonnevillo Closed Groundwater 200 EPA June 2, 2003
Soil NL EPA June 2, 2003
WV Rocket Center Allegany Ballistics Lab NPL Groundwater 26,200 DoDSurvey2
Surface Water 400 DoD NPL Oct03
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Democratic Stal! of 1lI~ Commlltee on Enll "gy and Convnerce 3 March 1, 2004
DISCUSSION D R AFT
"(b) DEFINmON OF RELEAsE.
"(1) The term 'release' as used in the Comprehensive Environmental Response.

Compensation, and Uability Act of 1980, as amended (42 U.S.C. §9601 et seq.), does not
include the deposit or presence on an operational range of any military munitions, including
Wlexploded ordnance, and the constituents thereof, that are or have been deposited thereon
incident to their normal and expected use, and remain thereon.
(2) Paragraph (1) shall not apply to military munitions, including unexploded
ordnance, and constituents thereof, that
"(A) migrate off an operational range; or
U(B) are deposited offof an operational range; or
"(C) remain on the range once the range ceases to be an operational range.
"(3) Notwithstanding the provisions of paragraph (1), the authority of the President
under section 106(a) ,of the' Comprehensive Environmental Response, Compensation, and
Liability Act of 1980, as amended (42 U.S.C. §9606(a», to take action because there may be
an imminent and substantial endangerment to the public health or welfare or the environment
because of an actual or threatened release of a hazardous substance includes the authority to
take action because of the deposit or presence on an operational range of any military
munitions, including unexploded ordnance, or the constituents thereof that are or have been
deposited thereon incident to their normal and expected use and remain thereon.
"(c) DEFINmON OF CONSTITUENTS.-For purposes of this section, the term

'constituents' means any materials originating from military munitions, including unexploded
ordnance, explosive and non-explosive materials, and emission, degradation, or breakdown
products of such munitions.
"(d) CHANGE IN RANGE STATIJS.-Nothing in this section affects the legal requirements
applicable to military munitions, including unexploded ordnance, aJ}d the constituents thereof,
that have been deposited on an operational range, once the range ceases to be an operational
range.
"(e) Nothing in this section affects the authority of the Department to protect the
environment, safety, and health on operational ranges.•
June 10, 2003 version

DRAFT
DermitioDs of RaDge aDd RaDge Activities
Excerpt from Defense Authorization Act for FY04 - Public Law
"(e) Facilities and Operations.--The following definitions relating

to facilities and operations apply in this title:
"(1) Range.-The term 'range', when used in a geographic
sense, means a designated land or water area that is set aside,
managed~and used for range activities ofthe Department of
Defense. Such term includes the following:
"(A) Firing lines and positions, maneuver areas,
firing lanes, test pads, detonation pads, impact areas,
electronic scoring sites, buffer zones with restricted
access, and exclusionary areas.
"(B) Airspace areas designated for military use in
accordance with regulations and procedures prescribed by
the Administrator of the Federal Aviation
Administration.
"(2) Range activities.--The tenn 'range activities' means-
.,(A) research, development, testing, and evaluation
ofmilitary munitions, other ordnance, and weapons
systems; and -
"(B) the training of members ofthe armed forces in
the use and handling ofmilitary munitions, other
ordnance, and weapons systems.
"(3) Operational range.-The term 'operational range' means
a range that is under the jurisdiction, custody, or control of
the Secretary ofDefense and-
"(A) that is used for range activities, or
"(B) although not cUrrently being used for range
activities, that is still considered by the Secretary to
be a range and has not been put to a new use that is
incompatible with range activities.
SEC, _ ' RIGHT OF REMOVAL TO FEDERAL DISTRICT COURT IN CLEAN
AIR ACT AND SAFE DRINKING WATER ACT CASES FILED AGAINST THE
FEDERAL GOVERNMENT,
***
(b) CLARIFICATION OF RIGHT TO REMOvE.-8ection 1447 of the Safe
Drinking Water Act (42 U.S.C. 300j-6) is amended by adding at the end the following
new subsection:
"(f) REMOVAL.-Nothing in this part shall be construed to prevent any

department, agency, or instrumentality of the Fedetal Government, or any officer,
agent, or employee thereof in the performance of his official duties, from
removing to the appropriate Federal district court any proceeding in State court to
which the department, agency, or instrumentality or officer, agent, or employee
thereofis subject pursuant to subsection (a), and any suchproceeding may be
removed in accordance with section 1441 et seq. of title 28.".
/
The Honorable Michael O. Leavitt
February 26. 2004
Page 2
state partners or even water systenw from Interceding to protect a water source threatened with
contamination from or on a defense~related site.
DoD officials have stated that the only goal of the ~eflnitlons Is to avoid a situation ill which the
firing of weapons on.ranges is considered a "release" under RCRA or CERCLA. If this Is the case. then
we encourage the Administration to narrow the scope of Its initiative to reflect this concern. We be1leve
that our anned forces should be able to conduct weapons training. yet stlll clean up hazardous waste on
its ranges and protect sources of drinking water both on and ofT military installations.
We are avaUable for further discussion on this topic with your office.
Regards.
Diane VanDe Hei. Executive Director Jack Hoftbubr, Executive Director

Association of Metropolitan Water Agen.cies American Water Works Association
~
Steve Hall, Executive Director
Association of California Water Agencies
Peter Cook, Executive Director
National Association afWater Companies
cc: OMB Director

quality: It was also noted that AMWA, in conjunction with member water purveyors
such as ACWA provided a letter on 26 February 2004 to EPA Administrator Leavitt
expressing the belief that belief that RRPI proposal was too broadly written (see
Attachments1 and 2 for the letter and proposed RRPI legislation that was distributed.)
It was reported as a result of recent meetings between industry lobbyists and DoD,
ACWA can report:
• DoD has provided assurances that it is not trying to use RRPI to escape from
potential perchlorate liability;
• DoD has not shut the door on on-range monitoring; and
• DoD is still trying to push through the Office of Management and Budget
(OMB) RRPI provisions that are substantially similar to what was proposed
last year. Proposed RRPI legislative language was provided.
Mr. Reynolds reiterated AMWA's major concerns with RRPI as being the belief that
exemptions were written to broadly, that action to protect human health and the
environment would only be reqUired if range contaminants move beyond the boundary
of a range, and that DoD would construe the exemptions to extend to contractor
facilities vs. DoD ranges. He reported that the final push to get RRPI through OMB
could begin as early as 29 April 2004, which means AMWA has only a few weeks to
mobilize and get legal assistance from Peter Winer (sp?). To that end, AMWA members
were informed "the h51t was being passed" to help fund Mr. Winer help the association
work with Congress and DoD on the RRPI proposal. It was also reported that Rep.
Duncan Hunter (Chair, House Armed Services Committee) has asked AMWA for its
input on proposals for ranges.
It was also reported that Sec. Rumsfeld and EPA Administrator Leavitt have met to
discuss the RRPI proposal, and that EPA personnel have described the meeting as
"difficult." It was stated AMWA needs to work more closely with EPA to
counterbalance DoD influence on the issue. He noted that States Attorney Generals
have described the proposed legislation as "a blatant move to shirk responsibility", and
that AMWA should also consider how to mobilize mayoral support against RRPI. A 21
April 2004 meeting at the ljouse was referenced, along wi!!' the need to work on the
message they want to present at the meeting.
It was reported that the RRPI proposal and perchlorate issues have been briefed to the
Vice President, who questioned "why are we picking a fight with the water companies
during an election year?" It was suggested that this may mean that e!ection year
politics will result in RRPI legislation riot being addressed this year, but will be
resurrected again after the election. It was also suggested that this year's goal should be
to work with EPA, negotiate with DoD, and find ways to ensure financial relief for the
water companies.
List of DoD Perchlorate Sites
The meeting briefly discussed the list of DoD perchlorate sites compiled by the House's
Democratic staff members (Attachment 3)
Questions
It was suggested by several in the audience that DoD has legitimate national defense
and security concerns. Mr. Reynolds was asked if there is a solution that is acceptable
to both AMWA for liability and for DoD in terms of ensuring active ranges are not shut
down for environmental reasons? His response indicated that AMWA is not actively
seeking to shut down DoD ranges, but is simply seeking to ensure that responsible
parties, not AMWA members, bear environmental liability costs. He reiterated the
AMWA position again, noting that the current language is too broad and that the
association has its concerns that DoD contractor facilities will be granted exemptions
intended only for DoD ranges.
It was noted that DoD ranges typically cover vast tracts of land, and that AMWA has
legitimate concerns about off-range transport of range contaminants. Drinking water
contamination at Camp Lejeune, NC, raised, followed by the comment that DoD should
be more concerned about protecting the health of its own people from range
contamination. .
MTBE, Perchlorate af..\d DoD's Range Readiness Initiatives - 30 March 2004
Rep. Hilda Solis (Ranking Member Subcommittee on Environment and Hazardous

Materials, Committee on Energy and Commerce)
Rep. Solis began her discussion by noting that her California district is the home to
three Superfund sites, and that securing funding to continue cleanup of the sites
remains a high priority. She posed the general question of how (we) should address
perchlorate? Rep. Solis responded that there really appears to be no single remedy for
the question, but that something "positive" needs to happen. She commented that the
perchlorate pollution in her district is a direct result of contractor factories and facilities
put into place years ago fo~ the purpose of supporting DoI;>activities. She reported, but
did not identify or elaborate on, another potential chemical contaminant that had been
identified near several military vendor sites. With regard to cleanup costs, it was stated
that while the Federal government has a role to play, it has not played a big enough role
yet.
Role of Water Purveyors

It was asserted that EPA should be more aggressive and ahead of the state on
perchlorate actions vs. being behind the ball and following California's lead (citing
OEHHA's recent PHG action.) Rep. Solis commented that she knows the water
purveyors have a higher tolerance level for perchlorate than others, and sought input
from AMWA members on how tolerant they are. It was noted that while the water
purveyors have to do a better job on outreach activities to Congress and other
stakeholders to communicate their concerns and positions, they should recognize that
potential remedies may have significant costs associated with them. Rep. Solis
observed that water purveyors need to be up front with potential allies, noting she has
experienced less than up front actions from some purveyors on other drinking water
issues.
Perspective of DoD Perchlorate Response

Rep. Solis noted that she has asked the Committee Chair to hold hearings on the extent
of DoD knowledge of potential perchlorate contamination, noting that several letters
have been sent to DoD seeking such information, but she has not yet heard back from
the Department on the most recent request. Again, the issue of Camp Lejeune, NC, was
raised as an example of DoD contamination of drinking water sources. Rep. Solis
observed that there are real health issues associated with perchlorate such as thyroid
illnesses and cancer, and that these issues remain high on the mind of some Committee
members. It was noted that while some information on perchlorate at some 300 DoD
installations has been provided in the past, there are over 5,000 sites that are or have
been used by DoD. It was also noted that Sen. Boxer has received some information as
well, but characterized it as sketchy at best.
Rep. Solis took the opportunity to tug on the heartstrings of the audience by asserting
that in her district, perchlorate has been detected in school drinking water fountains.
She ended her perchlQrate discussion by acknowledging AMWA and ACWA concerns
with perchlorate as being linked to issues of environmental liability and cleanup costs.
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June 18, 2003

secretary of D.'ense
Thc Honorable Donald Rumsfcld
Secretary of Defense 111111~IUIIIIIIII~IIIIIIl~~

SADD27005
Department of Defense '-'--'. -"'
The Pentagon
Washington, DC 2030 1
Dear Secretary Rumsfeld:
We write to continue the dialogue on perchlorate contamination.ln response to our

April 2 request for information on perchlorate contamination at Defense facilities,
Assistant Deputy {rnde,.. ~ecretary John Paul Woodley sent our offices a cOflY of a
spreadsheet. We appreciate this response and the effort it involved. However, the
information we have received falls far short of what was requested and what is
needed; it is incomplete and outdated.
The spreadsheet fOrwarded to our offices reveals that perchlorate contamination is

potentially widespread and pervasive at military installations. Unfortunately, the
spreadsheet does not include comprehensive data and the data included is outdated,
making it difficult to draw conclusions on the extent of the contamination and
necessary next steps. Specifically, only 305 out of more than 5000 bases are
included and the most recent data is from August of 2001. Further. the original
survey questions are not included and neither the raw data that went into producing
the survey. nor analysis one would expect from the Department. was provided.
Purthennore, it includes almost no infomlation on the :itcps that the Department is
taking to remediate contamination.
We request that the Department provide us with the full information we have
requested by July 16, 2003. If the Department does not have this information, then
the Defense should undertake a comprehensive perchlorate contamination survey.
This information is critical to understanding the extent of the perchlorate threat to

our country's drinking water supply. This infonnation is also needed by EPA to
complete a national perchlorate contamination survey as a critical step in
implementing a national drinking water standard. This standard is essential to
protecting the health and safety of the public and to providing the bes~ possible
. guidance to our water agencies as to what level of protection is needed.
U1 e.e. "~I 03
~~
Perchlorate poses a significant problem to our communities. In California alone,

perchlorate has already been detected in 319 underground wells. Coupled with the
perchlorate detected in the Colorado River emanating from the site in Nevada, we
face a serious; challenge to our drinking water ~upplies.
With the many Defense and defense contractor sites in California and Nevada,
Calffomia and Nevada need the cooperation of the Depanmcnt in addressing the
perchlorate detected in our drinking water. These concerns are detailed in the
attached letter from the California Environmental Protection Agency.
Secretary Rumsfeld, our military has protected the American people for centuries.
For this, we are grateful. We strongly urge you to reaffirm that this conmlitmcnt
extends to protecting citizens within the U.s. from threats to their public health that
may arise from critical defense activities.
We look forward to you leadership on this matter, and your complete response.
Sincerely,
Senator Dianne Feinstein

<,
.~ At.,,"}; WlTUlton ·M. Hlcko>

State of ~lifomia C>T':y Davia
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GOVC'n\OT
CalifoT111a EnvlTonmental Protection Agency
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aled
June 6, 2003
Mr. John Paul Woodley, Jr.
Assistant Deputy Under Secretary
of Defense for Environment
Department of Defense
, Washington, D.C. 20301·3400

••
Dear Mr. Woodley:
We are writing to seek the cooperation of the Oeparbnent of Defense (000) in

addressing perchlorate contamination at DoD's active, closed, and historic military and
contractor"facilities in California on behalf of my office, the California Environmental
Protection Agency (Cal/i:PA) and Cal/EPA's Department of Toxic Substances Control
(DTSC) and State Water Resources Control Board (SWRCB). The potential sources of
perchlorate contamination include facilities that manufacture, conduct research on, and
use solid propellants for rockets, missiles, military ordnance, and pyrotechnics. Military
and defense contractor facilities are among the known and suspected sources of
contamination of ttl is type.
We cannot overstate the seriousness of this problem for the State of California. To
date, perchlorate has been detected in more than 300 wells, including public water
supply wells. The loss of drinking water supply wells to perchlorate contamination may
Ieave parts of California without sufficient water for the summer months. I n response to
this crisis, the California Legislature is expressing Its interest in finding the sources and
solutions to these impacts to the State's water by holding hearings on the matter.
Our efforts to address perchlorate contamination in California warrant a collaborative

approach to this environmental crisis. Together, we need to identify sources of
perchlorate contamination, coordinate research of treatment strategies and technologies,
and eventually clean up ,both impacted drinking water and water used for other beneficial
uses.
Cal/EPA and its constituent boards and departments need to extend this coordinated
approach to 000 to address perchlotate and other emerging chemicals of concern
emanating from military properties. To that end, the Regional Water Quality Control
Boards have coordinated with the SWRCB in preparing a letter to military installations in
California requesting assistance in identifying, investigating, and cleaning up sources of
The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy
consumption. For a list of simple ways you can reduce demand and cut your energy costs, see the Web site:
W)!IIW f1exyo"rpower ca go II '
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Mr. John Paul Woodley, Jr.
June 6, 2003
Page 2
perchlorate and other chemicals of concern on their properties. We have enclosed a

copy of this draft letter for your information.
We ask that you direct the installations and appropriate program managers in 000 to
assist and cooperate in this effort. In addition, we understand that 000 conducted a
national survey of perchlorate contarnination on military facilities, and we would request
the opportunity to review the results of this survey for installations in California.
Both DTSC and SWaCB representatives are available to meet with you or your staff
to further discuss this issue. Should you have any questions or need further assistance,
please contact Mr. Frederick S. Moss, Chief, Office of Military Facilities, DTSC, at
(916) 255-3750 or Ms. Lisa Babcock, Chief, Land Disposal Section, SWRCB, at
(916) 341-5687.
~~
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Sincerely,
JJ ~ Ii, d<cttx .a.~~ (
'
" ____ ~V /'
Winston H. Hickox Edwin F. Lowry Cel~ste CantU

Agency Secretary Director Executive Officer
Department of Toxic State Water.Resources
Substances Control Control Board
Enclosures
cc: See next page.

..
Perchlorate Technical Conferences and Presentations

Information Provided by the DOD Perchlorate Working Group
for more information, contact Erica Becvar (see below)
2003
Date Title Location Web Site
Jun Bioremediation of Perchlorate Session at the Orlando, FL www.battelle.org/biosy

2-5 Battelle In Situ and On-Site Bioremediation mp
Conference
Jun Perchlorate session at the AWMA Annual Conference San Diego, CA

www.awma.org/ACE20
22 - 26 Technical Program 031
Ju1 Perchlorate in Groundwater: Occurrence, Analysis and Sacramento, CA www.grac.org
31 Treatment Symposium
Aug Perchlorate presentations at the 8th Annual Joint San Antonio, TX www.p2
11 - 14 Services Pollution Prevention Conference & Exhibition hwmconference.coml
Aug 1112-hr plenary session on- perchlorate at the 2003 Portland, OR www.astswmo .org
20 - 22 ASTSWMO Federal Facilities Managers Symposium
Oct Perchlorate presentations at the US EPA 13th Annual Dallas, TX www.epa.govregion6/qa

20 - 24 Quality Assurance Conference
Oct Perchlorate session at the Annual Conference on Soils, Amherst, MA www.umasssoils.com/
20 - 23 Sediments and Water
Nov Perchlorate session at the SETAC Annual Meeting Austin, TX www.setac.org/austinm
9 - 13 ain.html#geninfo
Nov Perchlorate presentations in the Environmental San Francisco, CA www.aiche.orgl confer
16 21 Restoration of Energetic Materials Session of the enceslAnnuall
2003 American Institute of Chemical Engineers
(AIChE) Annual Conference
Dec Perchlorate session at the Partners in Environmental Washington, DC www.estcp.org/relate

2-4 Technology Technical Symposium & Workshop d_events/index.cfm#
12_02-04_2003
2004
Jan Perchlorate presentations at the Sustainable Range New Orleans, LA www.battelle.org/envir
5-8 Management Conference onment1er1conference
s/rangel
Mar Perchlorate session at the 2004 AFCEE Technology San Antonio, TX www.afcee.brooks.af .
1- 4 Transfer Workshop mi 1/er1 techworkshopl
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The Honorable Donald H. Rumsfeld
Secretary
Deparanent of Defense
The Pentagon
Washinb'ton. D.C. 20301
In the spnng of2001. the Departmrnt ofDefcmse (DOD) compiled a survey [0 identify
the potential for perchlorale contamination at all active and closed DOD faciliues. The survey
description stated mat "early identification is critical in order to help evaluate potential risks to
soils, groundwater, and drinking water," It further stated thac "all DOD facilities (active and
closed) dating back to 1950 which could have had perchlorate ex.posure must be identifi~d as
qUickly as possible."
The U.S. Air Foree Rtsearch LaboraTory, Aerospace Expeditionary Force TechnoloSles
Division. Tyndall AFB, Florida was tasked with conducting the perchlorate survey with the
assistance of contractor per&Qnnel at Appli~ Research Associates. Incorporated.
Some of the questions that each DOD facility was asked to respond [0 were:
1. Have you ever sampled for perchlorate in grol1Jldwater, soil, sediment, and/or
surface water?
2. Have you ever had activities such as open-burn or open-deTerioration propellant

removal, propclllUlt test and analysis laboratories; ordnance andlor rocket motOr
testing, or ore1nance and/or rocket mOTor maintenance at your facilitY?
3. What are yoUr reasons for noT sampling [or perchlorate?
#. If sampbng occurred, has the perchlorate plume been mapped?
5. Are you cwrently in\'olved in any remediation acTivities at your facility?
The DOD also mdicated that it was contracting separately to get the infonnaticn listed on an
interaCtive map.
U07475 J 03
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. OS·rE-C3 03:59pm Fr~-COUME~CE CMTE DEMOCRATIC STAFF zozmZ525 T-764 P 03104 F·09Z
The Honorable Donald H. Rwnsleld

Pagel
More than two years have passed and DOD has not provided this comprehensive
information on perchlorate contamination to the Envirorunental Protection Agency (EPA)
officials who requested it nor to the public at large. In fact, we understand that the EPA wi thheld
issuing information requestS to DOD under Section l04(c) of the Comprehensi'le En..ironmtntal
Response, Coznpensation and Liability Act in reliance on DOD assuranc.es that it 'Would
voluntarily provide comprehenslve information on perchlorate contaIl1.Ulation.
It appears that the DOD has adopted a pOlicy ofcovering up and hiding information abOllt
the nature and magnitude ofthe serious perchlorate contamination that ex.ists at its facilities. As
a result, the existence of groundwater contamination trom perchlorate at DOD facilities is often
first discovered after drinking water wells and supplies are already affected. As the drinking
water urility associations have recently infonned Congress, such a policy of acting only after the
damagl" h3S been done will incur WlDcCessary pUblic health risks. uniicceptabk lus~es CJf"'aler
sources, and high CQSIS to clean up water supplies andlor secure alternate sources.
Therefore, we requesltnal you provide us with copies of all of the responses that were
submitted by DOD facilities to the perchlorate survey that was initlated in the Spring of200l.
and a copy of the interactive map. We would appreciate receiving this material by Fnday. June
6,2003.
runher, with respectto the 131 DOD facilities that are listed 011 the Superfund National
Pnorities List, please indicate which of those facilities used equipment, mWlitions, or weaponry
believed to contain perchlorate, the type of equipment, munitions, or weaponry, whethc
sampling for perchlorate has occurred, and the results of an)' such sampling, including the level
detected. We would appreciate receiving this infonnation by Fnday, June 13, 2003.
Finally, we are concerned that the November 13, 2002, memorandum entitled
"Perchlorate Assessment Policy," issued by Aisislant Deputy Under Secretary ofDefense John
Woodley to the Services. is too restrictive to identify contamination of groundwater or surface
water that may be potential sources ofdrinking WaIer or that may be used for other beneficial
uses such as crop inigation. Before DOD Component! can ascertain and assess for perchlorate,
that policy appears to reqUire "a pathway on their installations where it could threaten public
health." Please state whc:Iher this policy would restrict testing and assessment for perchlorate
contamination of grollndwater that is not currently a source ofdrick.ing water but may be a
porential source in the futlLl'e or groundwater that could be used for orher beneficial uses sllch as
crop lmgation. w~ also re~uest any infonnation that has been generated or gathered by DOD
installations under the ··Perchlorate Assessment Policy." We would also appreciate receiving this
infonnation by Friday, June 13,2003.
From-COItlIfCE CllTE DEw)c~ATIC STAFF 2D22252525 T-764 P D4/D4 F-OS2
,• 05-1'6-03 04:00PQl
The Honorable Donald H. R1l1T1sfeld

Page 3
If you have any questions about these r~quests. please contact us or have your staff
contact Richard A. Frandsen, Conunince on Energy and Commerce Democratic staff. at 202
225-3641 or Heather Taylor of Representative Solis's office at 202-226-9883. Thank you (or
your attention to this request.
Sincerely,
~
HILDA 1. SOLIS
~GMEMBER
SUBCOMMITTEE ON ENVIRONMENT
AND HAZARDOUS MATERIALS
cc: The Honorable W. 1. "Billy' Tauzin, ChairmlU1

Committee on Energy and Commerce
The HQnor~ble Paul E. Gillmor. Chairman
Subcommittee on Environment and Hazardous Materials
The Honorable Christine Todd Whiunan. Administrator
Environmental Protection Agency
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PERCHLORATE STUDY GRDUP
A lOIIil'Glt '" MIIIlIDo ill'-

clMlllcol'odlllletliodolslriti
June 16. 2003
Colonel Daniel E. Rogers

Chief, Environmental Law and Litigation
1501 Wilson Blvd
Arlington. VA 22209-2403
.. ::~,\-,
RE: I' REQUEST FOR FUNPING. PERCHLORATE RAT NEUROBEHAVIORAL AND BRAIN
~ME1'R:fCSTUDY
Dear Colonel Rogers:
Per our recent conversation, I am writing to inform you of a study being developed and
overseen by the Perchlorate Study Group to assess the possible impact of ammonium
perchlorate on neurodevelopmental effects in rats (the Study), and to request financial
support for the Study from the Department of Defense. The objective of the Study win be to
determine a no-observable adverse effect level (NOAEL) for perchlorate on
neurodevelopmental endpoints in rats. These neurodevelopmental endpoints will be brain
morphometry and developmental behavior of offspring of mothers given perchlorate in
drinking water. The Study will be conducted using standard and accepted methods applied
by neurodevelopmental scientists, and will correct deficiencies in the previously conducted
Argus 1998 and Argus 2001 studies about which there has been great controversy regarding
the data quality and interpretation.
The estimated cost of the.Study including animal treatment, data collection and analysis, and
publishing of results, for eight dose groups is $7401(. The Study is scheduled to begin in
mid-July 2003. We are working to have results available before the National Academy of
Science review is complete. and we anticipate results of this work to be immediately
published in a peer-reviewed journal. Work will be conducted using the highest standards of
scientific research and good laboratory practices (GLP). We expect the data to be available
to any party interested in reviewing the work.
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BACKGROUND
The current EPA risk assessment:. Perchlorate Environmental Contamination: Toxicological

Review and Risk Characterization (U.s. EPA, 2002), has recommended a reference dose
(RID) of 0.0003 mglkg-day for perchlorate, which is equivalent to a DWEL of I pbb. U.S.
EPA has largely relied on results from two studies in rats, Argus 1998 and Argus 200 I, plus a
subsequent neurobehavioral study by Bekkedahl et al. 2000, and bases the RID primarily on
brain morphometry data from the Argus 2001 study. In this study, EPA reports that a dose of
om mglkg-day increased the thickness ofthe corpus callosum (a brain region) in offspring.
To this lowest observed adverse effect level (LOAEL), EPA applied an uncertainty factor of
300 1 to derive the RID.
FATAL FLAWS IN CURRENT STUDIES
Several groups of scientists with expertise in brain morphometry and developmental

behavior, including an expert on EPA's most recent Peer Review Panel, have detennined the
studies EPA on which bases its assessment are seriously flawed and the data unreliable or the
results misinterpreted (TERA. 2001; Aschner, 2002; Bruce and Pleus, 2002; Bruce et al.,
2002; Wahlsten. 2002a,b).
Examples of problems with the studies EPA relies upon include:

• Inaccurate and biased methodologies in brain sectioning yielded laboratory artifacts
that more clearly explain the morphometric "effects" EPA reports;
• "Effects" ci!ed by EPA are inconsistent with studies ofhypothyroidism-inducing
agents; and
• EPA reports behavioral "effects" when the authors of the original studies (Argus
1998 and Bekkedal et al. 2000) concluded no statistically significant neurobehavioral
effects occurred.
A number of the researchers also believe the data do not demonstrate a hint of an effect.
However, because of the manner in which the data are being used, repeating the study
measures that did not yield conclusive data using methods that correct previous deficiencies
is prudent.
THE PROPOSED STUDY (BRIEFLY)
The Study will address rat maternal exposure to perchlorate in drinking water. from two
weeks prior to conception through weaning. Rat pups will then be assessed for sensitive
neurodevelopmental endpoints. including behavioral and brain morphometric measures, at
two ages-weaning and post-weaning. Perchlorate in maternal milk and pup blood will also
be measured, to confirm exposure. Figure 1 shows the proposed Study design.
The Study will include the following parameters that correct flaws in the previous studies (all
I The composite uncertainty factor of 300 is comprised of a factor of 10 to extrapolate from a lowest-observed-advcrse.
effect-level (LOAEL) to a NOAEL. a factor of 3 for intraspecics variability, a factor of 3 for study duration. and a
factor of 3 for inadequate characterization of potential immunotoxic effects (U .S. EPA. 2002).
20f6
4
of which are standard scientific practice and consistent with EPA guidance):
• PQsitive control. The positive control group will be exposed to propylthiouracil

(PTU), a substance known by accepted research to cause the studied effects (e.g.,
maternal hypothyroidism), in order to demonstrate that the Study is capable of
detecting an adverse effect. The study on which EPA relies (Argus 2001) did not
include a positive control.
• Higher perchlorate dose. Reanalyses of Argus 200 I demonstrated that minor effects
might have occurred at the highest dose of perchlorate given (30 mg/kg-day), but in
general it did not appear that the doses administered were high enough to elicit a true
adverse effect. To ensure that an adverse effect can be detected, a higher dose (100
mg/kg/day) will be included. Additional perchlorate dose groups will be 0.01, 0.1,1,
10, and 30 mg/kg/day, plus a control (no perchlorate exposure) group.
• Testing at standard developmental time POints. In tests ofneurodevelopment,
assessing pre- and post-weaning ages is standard. The Study will include testing for
neurobehavioral and morphometric effects at weaning and at maturity to assess
whether any effects are transient or permanent Argus 2001 did not include a post
weaning age when assessing brain morphometric effects.
• Standard and accepted methods of brain analyses. The Study will use standard, state
of-science methods for assessing brain morphometry. For example, brain structure
areas or volumes will be measured rather than just thicknesses, as was done in the
Argus 1998 and Argus 2001 studies.
• Testing for the most sensitive endpoints. For agents that cause maternal
hypothyroidism, tests for acoustic startle are considered among the most sensitive
behavioral tests and will be included in the Study. Neither Argus 1998 nor
Bekkedahl et al., 2000 reported effects on acoustic startle, although EPA interpreted
the results as showing effects on other, less sensitive, motor activity endpoints.
Use of standard methods will ensure that the results can be published in the peer-reviewed
literature, and will also yield results that are comparable to the wider neurodevelopmental
database for other test compounds.
BENEFITS TO DOD
Repeating the perchlorate study offers a number of benefits to Governmental agencies

including DOD, EPA, FDA, USDA and others. These include:
• Adherence to the long held commitment to use of good science in making decisions;
• Demonstration that the agencies are working to protect public health using the best
possible science;
• A credible, high-quality toxicological database gathered using methods consistent
with those used by the greater scientific community, which should reduce uncertainty
factors applied in the development ofthe RID (e.g., database uncertainty).
• An expectation, based on the mechanism ofaction for perchlorate and what the
animal and human data demonstrate thus far, that the perchlorate NOAEL and
30f6
...
LOAEL for neurotoxicological endpoints is higher than currently interpreted by EPA.

This should:
• Alleviate concerns from communities around the US that they are in danger of
adverse effects from low concentrations ofperchlorate in drinking water, and
• Reduce the need for spending excessive money on remediation that yields
neglible, if any, public health benefit.
• As the California Proposition 65 Developmental and Reproductive Toxicity (DART)
committee relies on the data cited by EPA to assess reproductive and developmental
toxicity, this study should provide quality data that the DART committee can use to
appropriately assess perchlorate listing under Proposition 65.
FACILITIES, EQUIPMENT, AND RESOURCES
Currently, we are examining two options for conduct of the Study:

1. Conduct the Study at the University ofBritish Columbia. British Columbia Research
Institute. UBC will conduct the full Study, from animal management and treatment
through assessment of behavioral endpoints and collection of brain morphometry
measurements. The key researchers at UBC, Drs. Innis, Weinberg, and O'Kusky, are
extremely well-recognized in the fields ofneurobehavior and brain morphometry.
2. Conduct the Study through sacrifice by Charles River Laboratories (formerly Argus).
followed by completion ofbrain morphometry by Dr. Douglas Wahlsten. Charles
River Laboratories could conduct the full Study or we could have them conduct the
animal management and treatment portion ofthe Study. The fixed brains would then
be shipped to Dr. Wahlsten of the University ofAlberta, who would take the brain
morphometry measurements. Charles River Laboratories would do behavioral
testing. This is the same group that conducted the first set of studies per the protocol
set forth by EPA.
PROPOSED BUDGET
The total proposed cost of the Study is estimated as $740,000. This is comprised of an
estimated as $620,000 for UBC to conduct the study inclusive of all study costs (per
experimental protocol) including manuscript submission, plus an estimated $120,000 for
study oversight, data analysis, and report/manuscript preparation assistance by Intertox and
Dr. Wahlsten.
SCHEDULE AND TIMING
With approval of funding by June 15. 2003, the Study will begin with animal procurement
and acclimation in approximately mid-July, and will end with completion of brain
morphometry measures by early March 2004. Study results will be available by mid-March
2004 and a draft manuscript will be ready for submission to a peer-reviewed journal by late
March 2004.
I hope this letter provides you with the infonnation you need to assess issues regarding
40f6
•
funding the proposed Study. I would be happy to answer any additional questions.
Sincerely,
.--::7
Michael Girard
Chairperson
Perchlorate Study Group
Enclosures (l)
50f6
REFERENCES
Achner, M. 2002. Comments. In: Report on the Peer Review ofthe U.S. Environmental Protection
Agency's Draft External Review Document "Perchlorate Environmental Contamination: Toxicological
Review and Risk Characterization, Sacramento, CA, March 5·6.2002. Washington, DC. EPAl6351R
02/003. June.
Argus Research Laboratories, Inc. 1998. A Neurobehavioral Developmental Study OfAmmonium

Perchlorate Administered Ora//y In Drinking Water To Rats. Horsham, PA: Protocol No. 1613-002.
Argus Research l:-aboratories, Inc., 2001. Hormone, Thyroid and Neurohistological Effects ofOral
(Drinking Water) Exposure to Ammonium Perchlorate in Pregnant and Lactating Rats and in Fetuses and
Nursing Pups Exposed to Ammonium Perchlorate During Gestation or via Maternal Milk. March, 200 I.
Protocol no. ARGUS 1416-003.
Bekkedal M.Y.V., Carpenter T., Smith J., Ademujohn C., Maken D., Mattie D.R. 2000. A
Neurodevelopmental Study ofthe Effects ofOral Ammonium Perchlorate Exposure on the Motor Activity of
Pre-Weaning Rat Pups. Naval Health Research Center Detachment, Neurobehavioral Effects Laboratory,
report no. TOXDET-00-03. Wright-Patterson Air Force Base, OH.
Bruce G.M., and Pleus R.C. 2002. Summary ofthe Expert Review ofthe Argus. 2001 ("Effects Study ")
Evaluation ofPerchlorate Effects on Brain Morphometry in Neonatal Rats. Submitted to Eastern Research
Group, Inc. for the U.S. EPA lORD Peer Review Workshop-Perchlorate Environmental Contamination:
Toxicological Review and Risk Characterization. March 5-6, Sacramento, CA. February 19.
Bruce G.M., Johnson D., and Pleus R.C. 2002. Assessment ofthe Validity of u.s. EPA's Interpretation of
an Effect ofAltered Neurobehavior in Offspring Treated with Perchlorate in utero: A Critical Review of
the Argus (1998) and Bekkedal et 01. (2000) Studies. Submitted to Eastern Research Group, Inc. for the
U.S. EPA lORD Peer Review Workshop-Perchlorate Environmental Contamination: Toxicological Review
and Risk Characterization, March 5-6, Sacramento, CA. February 19.
Toxicology Excellence for Risk Assessment, 2001. Report on Five Expert Reviews ofthe Primedica 2001
Study Report. Prepared for the Perchlorate Study Group. May 18.
WahIsten, D. 2002a. Perchlorate Effect.~ On Rat Brain Morphometry: A Critical Evaluation. Submitted
to Eastern Research Group, Inc. for the U.S. EPA lORD Peer Review Workshop-Perchlorate
Environmental Contamination: Toxicological Review and Risk Characterization, March 5-6, Sacramento,
CA. February 19.
Wahlsten, D. 2002b. Perchlorate Effects On Rat Motor Activity: A Critical Evaluation. Submitted to
Eastern Research Group, Inc. for the U.S. EPA lORD Peer Review Workshop-Perchlorate Environmental
Contamination: Toxicological Review and Risk Characterization, March 5-6, Sacramento, CA. February
19.
6of6
.
House Rpt.l08-187 - DEPARTMENT OF DEFENSE APPROPRIATIONS BILL, 2004
PERCHLORATE GROUNDWATER CONTAMINATION STUDY

Perchlorate is a salt, commonly used in a host of commercial and military applications
ranging from rocket fuels and fireworks to automobile airbags. High levels of
perchlorate are known to interfere with thyroid gland and mental acuity functions and
with the human bodyts ability to produce growth and fetal development hormones.
Though much is known about perchlorate, the specific long term effects and the specific
dosage levels at which perchlorate becomes hazardous are still being debated in the
environmental, scientific and medical communities. In Southern California, growing
groundwater perchlorate contamination is widely attributed to Department of Defense
activities and the commercial fuels and explosives industry, though the specific causes
of contamination have yet to be rigorously established; the Department has refused to
acknowledge a causal relationship until an extensive study is completed. The
Committee is aware of the controversy surrounding the evaluation of perchlorate
contamination of groundwater in Southern California and other areas across the
country. The Committee directs the Department to conduct a joint study with the
Environmental Protection Agency of perchlorate groundwater contamination, to be
completed within 180 day~ of the enactment of this Bill. This report will examine in
detail perchlorate groundwater pollution in and around the Colorado River, San
Bernardino County, the Cochella Valley, Santa Clara River and the Imperial Valley that
threatens drinking and irrigation water supplies in Southern California, Arizona and
Nevada. This report y;ill assess the breadth and scope of contamination and make
preliminary recommendations that will, at a minimum, include:
1. Recommendations for the establishment of a national standard for
acceptable levels of perchlorate groundwater contamination;
2. Determination of the military/defense industry sources that have
contributed to perchlorate contamination; and
3. Outline appropriate steps to be taken to mitigate or clean up those areas
that are deemed to be the government's responsibility.
, Cucamonga County Water District
10440 Ashford Street
Rancho Cucamonga, CA 91729.0638
P:O. BOX 638· (909) 987·2591 • Fax (909) 476·8032
Robert A. DeLoach
General Manager
Chief Executive Officer
STATEMENT OF INTENT BETWEEN THE
DEPARTMENT OF DEFENSE AND INLAND EMPIRE
WATER ENTITIES
Objective:
To establish a collaborative process culminating in a Memorandum of
Understanding combining the technical, financial, environmental, and
legislative resources of the Department ofDefense and the affected agencies
and interests of the Inland Empire of Southern California whose
groundwater resourc~s have been impacted as a result of perchlorate
contamination.
The intent of this collaborative process is to ensure timely participation

toward matters -related to the characterization of the perchlorate impacted
areas, identification of clean-up measures needed and the implementation of
clean-up solutions. This would include assistance with the demonstration of
technologies and remedial programs and pursuing additional resources
leading to the cleaning up of the local groundwater.
Robert Neufeld Mike Whitenead

President President
c~on: Fontana Water Company
!~
! ~
Anthony Araiza
General Manager
West Valley Water District
ROBERT NEUFELD HENRY L. STOY JAMES V. CURATALO, JR. JEROME M. WILSON RONSAKALA
President Vice Preside"t Director Director Director
FW: Academies Review OfPCTc~lorate Analysis To Begin in Fall
SUbject: FW: Academies Review of Perchlorate Analysis To Begin in Fall
Date: Mon, 14 Ju12003 09:17:49 -0400
From: "Van Brocklin, Connie_H Ms ACSIM"{.
To: "'Kowalczyk Daniel''' . _ _
"Rogers, Daniel Col APtSNJACE" L
-----Original Message---
From: M~jor, Michael A Dr USACHPPM
mai t
Sent: Fn ay, July.Il, 2003 6:46 AM --

To: Van Brocklin, Connie H Ms ACSIM; Garg, Malcolm J ACSIMlCH2M HILL
Subject: FW: Academies Review of Perchlorate Analysis To Begin in Fall

> From: Druck, Dennis E Mr USACHPPM
> Sent: Wednesday, July 09,20032:24 PM
> To: Major, Michael A Dr USACHPPM; Druck, Dennis E Mr USACHPPM; White,
> Thomas M (Mike) Mr USACHPPM; Smith, Roxanne D Ms USACHPPM; Richards, Todd
> E Mr USACHPPM; Boles, James LTC (Jim) USACHPPM
> Subject: Academies Reyiew of Perchlorate Analysis To Begin in Fall
>
> FYI
>
> Academies Review of Perchlorate Analysis To Begin in Fall; Panel Now Being
> Formed
> The National Academies expects to begin its review in September of
> scientific assumptions the Environmental Protection Agency made in a draft
> assessment of the risks of perchlorate, an academies spokesman told BNA.
> The Committee on Toxicological Assessment of Perchlorate Ingestion is
> being formed by the academies at the request of EPA, the Department of
> Defense, the Department of Energy, and the National Aeronautics and Space
> Administration ( 55 DEN A-15, 03/21103).
> The academies has begun to select experts who could serve on the
> committee, spokesman William Kearney said July 3. A list of proposed
> members is likely to be posted for public comment in August, and the
> committee's first meeting could be scheduled in September, he said.
> EPA issued a draft reassessment ofperchlorate in January 2002 and hopes
> to finalize the assessment after the National Academies completes its
> review (16 DEN A-3, 01124/02).
> Ammonium perchlorate is a primary ingredient in the fuel used for rockets,
> missiles, and ftreworks. Perchlorate salts are used in air bag inflators,
> nuclear reactors, electronic tubes, and for a variety of other purposes,
> according to EPA's assessment.
> The draft assessment conCluded that perchlorate may pose more of a health
> risk at low levels of exposure than previously thought, a fmding that
> could have implications for cleanup of superfund sites and the setting of
lof2 71l 5/2003 8:30 AM

FW: Academies Review of perchlorate Analysis To Begin in Fall
> a standard for safe drinking water.
> The Defense Department, in particular, is concerned over possible
> liability related to perchlorate that may be leaking from defense-related
> facilities into water supplies.
> Committee to Tackle Key Questions.
> The four federal agencies have asked the Committee on Toxicological
> Assessment of Perchlorate Ingestion to offer advice on several issues,
> according to the statement of task provided to BNA.
> For example, the conunittee wi)) evaluate whether science supports the
> prediction that changes in thyroid hormone regulation, which result from
> disruption of iodide uptake by the thyroid gland, could harm
> neurodevelopment and cause cells to grow abnormally.
> EPA's assessment concludes the thyroid gland is a key target tissue and
> means by which perchlorate harms human health.
> To protect a developing fetus, the agency proposed to reduce an earlier
> draft reference dose (RID) for perchlorate from 0.0009 miUigrarns per
> kilogram per day, which the agency had put forward for consideration Dec.
> 31, 1998, to a proposed RID of 0.00003 mg/kg/day. A reference dose is an
> approximate daily exposure level that EPA estimates a person, including
> sensitive subpopulations, could receive over a lifetime without adverse
> health effects.
> The academies panel will advise ~e agencies as to the level of chronic
> iodide inhibition and the level of thyroid hormone changes that would lead
> to adverse health effects, especially in susceptible populations, the task
> statement said.
> The committee will evaluate animal studies of perchlorate and whether they
> are relevant to predict human health effects.

> In addition, the conunittee will determine whether daily ingestion of
> perchlorate may cause problems other than reduced iodide uptake.
> Based on such analyses, the conunittee will determine whether EPA's draft
> toxicological review of perchlorate is consistent with scientific evidence
> about the chemical and make suggestions if the document can be improved.
> The agencies have also asked the National Academies panel to provide a
> range of exposure levels that would protect the public at various life
> stages.
> By Pat Phibbs
>
20f2 7/15120038:30 AM
i ex.t from Senate Rpt.l 08·082
Subject: Text from Senate Rpt.l08-082
Date: Wed, 02 luI 2003 07:36:21 -0400
From: "Sand Steven"
Organization: Booz Allen Ha,;mlton-
To: Messier Ryan C
CC: Kowalczyk Daniel L

PERCHLORATE
The Committee is growing increasingly concerned about the potential
impact of perchlorate contamination at installations that have been
closed through the BRAC process as well as at active and inactive
defense sites. Perchlorate, a chemical used in solid rocket propellant,
has been identified by the Environmental Protection Agency [EPA) as an
unregulated toxin. Perchlorate contamination has been found in drinking
water supplies in 29 States/ including California, Texas, Colorado,
Maryland, and Massachusetts. More than 300 groundwater wells in
California are contaminated with perchlorate, as is the Colorado River,
which supplies drinking water to more than 15/000/000 people in the
Southwest.
According to the EPA, the Department of Defense and the National
Aeronautics and Space Administration are responsible for 90 percent of
the perchlorate produced in the United States. Although the EPA last
year concluded in a draft assessment that perchlorate could pose a risk
to human health at drinking water concentrations of just one part per
billion, the Federal Government has yet to set a drinking water standard
for perchlorate. Therefore, no remediation standard exists. The EPA
assessment has been referred to the National Academy of Sciences for
review, which could significantly delay the establishment of a national
drinking water standard for perchlorate.
The Committee recognizes that, absent a state or Federal standard for
perchlorate, the Department of Defense is under no legal obligation to
remediate perchlorate contamination at defense sites. However, the
Committee is disappointed that the Department has been unresponsive to
requests to test for perchlorate at BRAC properties or other defense
sites.
To ensure that the Department is prepared to respond quickly and

appropriately once a perchlorate standard is determined, the Committee
directs that the Department take the following actions:
(1) Submit to the congressional defense committees no later than
December 31, 2003, a report on the activities of the Interagency
Perchlorate Steering Committee of the Department of Defense that was
established in January 1998 and was originally chartered to facilitate
a~d coordinate accurate aGcounts of technological issues (occurrence,
health effects, treatability and waste stream handling, analytical
detection, and ecological impacts) related to perchlorate contamination
of drinking water supplies and irrigation water supplies and to create
information transfer links for interagency and intergovernmental
activities regarding such areas of concern. The report shall cover all
activities that were identified in the memorandum of the Deputy Under
Secretary of Defense (Environmental Security), dated January 24, 2.001,
to the Secretaries of the military departments and the Director of'the
Defense Logistics Agency.
(2) Identify sources of perchlorate on BRAC properties and develop a
plan to remediate perchlorate contamination on BRAC sites that can be
implemented rapidly onCe State or Federal perchlorate standards are set.
The Department shall report to the congressional defense committees on
its perchlorate findings and remediation action plan no later than March
lof2 7/15/200311:12AM
'I ext from Senat~ Rpt.l 08-082
30, 2004.
http://thomas.loc.gov/cgi-bin/cpquery/l?cplOB:./temp/-cplOB3jkz&sid=cpl083lkz&item=1
20f2 7/15/2003 II: 12 AM

OFFICE OF THE UNOER SECRETARY OF DEFENSE
3000 DEF"ENSE PENTAGON
WASHINGTON, DC 20301·3000
ACOUISlTlON,
'lkCHNOI.UU Y
AND LOGISTICS
JUL 3 2003
Ms. Celeste Cantu
Executive Officer. State Water Resources Control Board
California Environmental Protection Agency
1001 I Su-e:ct
Sacr~mento. CA 95814
Dear Ms. Cantu,
Thank: you for your lel1~r of June 6.2003. I look forward to workin2 with you
on developing an inf{)lJ11ed, balanced, risk management response to Perchlorate in
conjunction WJth the affected industries and communities.
The Department of Defense has already collected some infonnauon on the

presence of perchlorate at California sites. We have enclosed a copy of the moSl
current information we have and will direct the Military Services to provide you
with any information they already have.
While EPA works towards defwitiveJy addressing the health questions and
issuing an official MeL. the Department is investing in activities that will enable
us to step out qUickly once EPA establishes the MeL:
~ I is&ued a policy in November 2002, allowing the Military Services to

sample for perchlorate if there is a reasonable basis to suspect perchlorat.e is
present and an exposure pathway exists. 'Ine Department of Defense is in
the process of developing n more comprehensive sampling policy for
perchlorate which will be out later this summer.
)- The Department of Defense, over the Jast several years, has spent over $25
million on research directed at perchlorate issues. 'Ibis includes
approximately $4.5 million on technology for treatment and cleanup of
perchlorate. We are currently co-sponsoring a pilot on in-situ biological
treatment In California. We are preparing to publish a book that compares
the current perchlorate cleanup technologies for efficiency and
effectiveness. We arc: posturing ourselves to be able to respond
immediately when California., other states, and theEPA set cleanup and
drinking water lltandards.
~ Our Environmental Quality Data Working Group is working with EPA staff
to develop a reliable, consistent methodology for te.llting for the. pr~sence of'
perchloralc in variau!! media,
> The Anny is taking steps to replace perchlorate in two key munitions that
aCCOUfl[ for over 70% of usage in the Anny.
In addition, the Department of Defense is complying with EPA's Unregulated

Contaminant Monitoring Rule. Along with many other drinking water systems
across the United States, our systems that meet the EPA size requirements are
conducting sampling for perchlorate over a consecutive 12 month period from
2001 to 2003 and reporting those results to EPA's Safe Drinking Water Accession
and Review System (SDW ARSIUCMR). The information in SDWARS/UCMR is
already available to state officials.
Dealing with emerging chemicals of concern is a clutllenge to all of us. We

need to work cooperatively to ensure that addresses these challenges in a
thoughtful, deliberative manner. J look forward to working with you to develop an
approach based on sound science that is fully protective of human health and the
environment.
We are eValuating the specific requests in your letter of June 6. 2003. To

establish a collaborative approach to these issues, I recommend we immediately
fonn an interagency working group to advise us jointly on options for addressing
perchlorate and other emerging contaminants. I have provided a similar letter to
Mr. Hickox., and Mr. Lowry.
Sincerely,
.It.,:....
i .J
/"l.·......(
.. I - .")
",,"'."~ '''-'i' ~
i
John Paul Woodley. Jr.

Assistant Deputy Under Secretary of Defense
(Environment)
Enclosure
---,-_,,,,,,,0 ._....
Page 1 of 1
From: Cornell, Jeff, Lt. Col, SAFIIE

Sent: Friday, June 13, 2003 08:34
To: Cotter, Sandra, Ms, OSD-ATL
Subject: enclosure 2-4
10/18/2005
DEPARTMENT OF THE AIR FORCE SfUlIl) RECORDS erR

98832
WASHINGTON, DC
Office Of Ttle At8llstant S8cNtawy

241uly 1998
SAFIMIQ
1660 Air Force Pentagon
Washington.. DC 20330-1660
Mr. Mike Osinski

U.S. EPA, Office of Ground Water and Drinking Wet
Mailcode 4607
401 M Street NW
Washington, DC 20460
Dear Mr. Osinski

Attached per £PA'& xequest to DoD is a listing of all known Air Force sites to have used
and/or stored ammonium perchlorate (AP). The Arttiy and Navy are C'W:tent1y q,u.etyins their
installations and. esdJ!1B1e forwardiDg their iDstaUationlistings to me within 30 days. I cxpcc::t to
AFMe LOfIAV,
SinceI:ely
~.LTCOL,
Deputy far Environmental Readiness
USAF
Deputy Assistant Sec:retaty of the

AirFOICe
(Environment, Safety, and
Occupational Health)
OT0/8001J1
'. .
.4!''1 '..
Air Fore! IgltJl"tIpM BsyJplf U!ed gdlor Stpnd Am._. Penh)ontt
Installslon J2t!rD*4 Pat. TmeotYs

Eclwards AFB, CA 1910'. SoUd aockIt Motors
HlUAFB,UT 1970's R.odrat Motor ~Ifaetltte

• Same drums ofAP wa. fbund
end cktanmed in 1he elIt1y 1990's
Palrick APB, PI. 19S0's-prasem: Solid locket Motol'll

.. A1co lCCltet motors hive been
usembledhere sfDt;e the 19t5Q',
USAF Academy, CO 199' sman quamityuse4 for cJassroom

IabaraloIy
UtlhTest IDd T1'aizliq RlDp 1990'S Rodcet motOrdemil_ the Thermal

TrtatmemUJllt
Vandon'bori AFEl, CA 1942-1957 I)rmn disposal.
19S9"lft'W Soll.cl J.ockllr Motors
oro/looO'l astt Dee Lee XVd LS:Lt 68/10130

'2
Attac:bmcnt:
Air Force AP Sites
cc:
ADUSD(CL)
AFMC LO/JAV (Lt Col Rogers)
;
:
OTO/otOIJl! ISfT 919 Ltt XY~ SS:Lt 88/101:0

~r . 4.".
~-
Attachments:
A1:rny Site List
Navy Sitrl List
cc:
ADUSD(CL)
DASA(ESOH)
DASN(E&S)
AFMC LO/JAV (Lt Col Rogers)
otO/tOOIJ!
a n ACTIVI'.rms ~~ RAVJI S~01U!:D, H:JUImLED, OR. USED
PD.CBLORATBS
STATE
1. Naval Air Weapons Station, China Lake CA

2. Naval Explosive Ordnance Disposal Technology MD
Piyision
3. Naval Indu$trial Reserve Ordnan~e Plant, Allegany wv
Sallistics La~oratory
4. Naval Industrial Reserve Ordnance Plant, Magna UT
5. Naval Inventory Control Point, Mechanicsburg FA
6. Naval Surface Warfare Center, Cardetock Oivi5ion* MD
7. Naval Surface Warfare Center, Carderock Division, l?A
SS£S Philadelphia·
8. Naval Surface Warfare Center, Crane Division IN
9. Naval Surface Warfare Center, Indian Head Division MD
10. Naval Weapons_Industrial Reserve Plant, McGregor TX
11. Naval Weapons Station, 'toJ:ktcwn VA
12. Space Warfare Systems Center, San Oiego* CA
13. Weapons Support Facility, Seal Beach, Concord CA
Detachment'"
14. Weapons Support Facility, Seal Beach, Fallbrook CA
Detachment"
15. Weapons Support Fac111ty, Seal Beach, io~~ Hadlock WA
Detachment·
* Small scale laboratory operations
Enclosure (1)
OlO/JOO IJl 'Itl 8S9 Lt8 XY~ 8S;Ll 88/Z0/Z0

'
-.
....r - ',""
Ammonium Perchlorate inventory
MACOM: U.S. Army Materle' Command
MSC: U.S. Army Aviation ind Missil, Command
Installation: Redstone Arsenal, AL
Tlmeframe: 1941 to pl'8Sent

Pureose: Manufacture of rocket engines, rocket ~rs and propellant testing.
L , f · ! J"--t
M§l;i U,§. Army laok:automotln aDd Armaments Command
Installation: Picatlnny Arsenal
Tlmeframe: Currently used on an ongoing basis.
P...Jm)ose: Research and development --...,
Evaluation MSC; U. S. Army TtIt and Command
c:
Installation: White Sands MissDe Range
Tlmetrame: >20 years
Test large rockets and molors end' rockets.
InstallatIon: Aberdeen ProvIng Ground
Tlmeframe: >20 years
t!.ur:Pose: Test Pyrotechnlcs and $fTUl1I rocke~
k. .. . ....- --
Installation: Dugway Proving Ground
1lmeframe: >20 years
J!.urpose: Test pyrotechnics -.
InstaUatlon: Yuma Proving Ground
Timeframe: >20 years
e-0ose: Test Dyro~echnlCS and 'imal~ '!3~~
01:0/9001J1 iQ't ssa Lt8 XV! 8G:Lt 88/Z0/10

MSyj u. s.
Army Industrial Operation. Command
Installation: Longhorn Army Ammunition Plant
Purpose: Perchlorate has been used In many areas at Longhom both with the
~ning and base burner. :::
Installation: PIne Bluff Arsenal

Purpose: Pine Bluff has used ammonIum perchlorate In the production of
pyrotechnic smoke mixes. They have also used It In starter mixes for pyrotechnJc
( munitions.
.
.--.....,
---'
InStallation: Sierra Army Depot
Pura088: Traatmsnt of mcket.l'TtOfor$.
Installation: Radford Army Ammunition Plant

Purpose: Ammonium perchlorate Is a part of certaIn propellant fcnnulations at
..B!9forc1. -.,
~
Installation: Tooele Army Depot
Purpose: Tooele is storing 5 Inch projectile. In which ammonium perchlorate Is
contained In the amount of .005 pounds per projectile. It Itl In the tracer
compound.
Tlmeframe: Many of these projectiles were detonated In the 08100 area in
-
.. 1996 and 1997. "7
Installation: McAlester Army Ammunition Plant

Purpose: The Instellation stores rockets with fuel1hat contains perchlorate.
}b'Y use ammonium, perchto,~UnittonS loading.
OfO/8001J1 Sitt 9S8 Lte lVd LS:Lt 661l0JZO

-3
Installation: Hawthome Army Depot

Purpose: Hawthorne stored 4.S million pounds of ammonium perchlorate from
1988-1990. In 1995 Hawthome dem1l1taJiZed,220 ammonium perchlorate-filled
Hawk motors using high-pressure water to washout the material from the motors.
CurrenUy Hawthome receives. stores and ships ammunition Items that contain
~onlum perchlorate. -,
L.. -i
Installation: LetterXenny Army Depot
Tim.frame: Current
Pumose~ DemUitarlzlng Shrike m~es.
MACOM: U. S. Army '8 pace and Missile Defense Command
Installation: Kwajaleln Atoll
Timeframe: 1970s to present
Purpose.: Perchlorate is used In the fuels of rockets that have been fired on
~jalein Atoll. ~
-
f
OIOILOOlJ!
/5/8
PAGES
REMOVED
/61 ~
.
E~C~~~~~' ..
1""3
W \""
..• 1 -~~, ::1 <:,: 26
May 7, 2003
The Honorable Donald H. Rumsfeld Facsimile Transmission

SecretalY.of Defense (703) 697·9080
Office of the Secretary of Defense
1000 Defense Pentagon
Washington, D. C. 20301
Subject: FerchlJrate in the Colorado River
Western Grovvers Association urgently seeks your assistance in a matter that Is of

the highest Importance to the health and welfare of all Californians and Arizonans and has
recently placed the California and Arizona produce Industries and the economies
associated with them at risk of conceivable elimination. This issue is the occurrence of
perchlorate in California and Arizona waters and particulariy in the Colorado River a
principal source of_drinking and irrigation water in both states.
First and foremost we wish to emphasize that. this is a water quality issue of
national scope and importance. Perchlorate's occurrence in ground and surface waters In
at least 20 states has been the subject of intense scientific and political debate for over a
decade. During that time we have enhanced our ability to detect perchlorate and have
begun to evaluate the risk associated with it in an effort to arrive at 8 science based
standard for water quality. Today there is a draft reference dose that is under review by
the regulatory and scientific community that could become the basis for a drinking water
standard In the future.
In recent months, the Environmental Working Group (EWG) has linked perchlorate
in water to a theoretical health risk associated wiU1 the consumption of crops Irrigated with
those waters. This linkage precedes any established and reviewed science associated
with the risks of perchlorate that may occur In fresh or processed foods, health standards
or even the testing methodology for perchlorate In foods. In fact the EWG's reckless report
could put the pUblic, including sensitive populations, at higher risk by discouraging the
consumption of fresh fruits and vegetables advocated by every health expert in the
country.
Z/l 'd Z91.0 'ON

,
May 7,2003
Page 2
Western Growers seeks your urgent and Immediate help in addressing this issue
and would like to meet with you or your designate to discuss specific strategies that we
can collaborate on to protect the public and the industry. We are first and foremost
concemed with thE steps being taken to establish standards for water, stop the
introduction of perchlorate into the Colorado system and clean up the water prior to its
delivery to agricult,:rG. We are also concerned with legislative efforts that create
exemptions from lii"lJility for this contamination and in facilitating research into the level and
scope of any risk a::sociated With perchlorate in foods and means of addressing/mitigating
that risk.
Western Growe rs is concerned that without an immediate, and definitive response to

this issue that is cOJrdinated among several select federal and state government agencies
the consumer including sensitive populations such as children, pregnant women and
women of childbearing age will be scared away from the consumption of the diet rich in
fresh fruits and vegetables advocated by every health expert in this country. In tum. the
stigma for the reg i C rJ and products will have severe economic Impacts on the local areas.
states and nation ,o;·~ a whole as we sacrifice the production in the area based on a report
on a limited Samp1\1 ·i9 by the EWG.
We request you~ active intervention in and assIstance with this Issue as 600n as
possible and invite you to meet with us Immediately, to discuss further, the strategies and
tactics that may be employed by industry and your agency to address this situation. I offer
to facilitate such n iI,eeting at your earliest convenience. In the meantime, if you have any
questions comments or concerns please contact me directly at (949) 863-1000.
Sincerely,
~r
THOMAS A. NASSir
President
c: Bill Lyons, Secretary

California DE' partment of Food and Agriculture
Jack Petersen, Acting Director
Arizona Dep"rtment of Agriculture
WG Execuht; Committee
GIl 'd 19LO 'ON ,.,....... SaRIt\Oa~ Na:1JS:11t\ NVVEQ,l.

J.Q.OrJ.. .'AY.~ .
....................................................
Print Date: 51812003 SE_'C_F_IL_E_S_F_U_L_L_RE_C_O_RD

__D_E_T_A_I_L ~r;;;mL
OSD CONTROL U06938-03 DOC 517/2003 DOR 51812003 SIGNATURE CASE:
FROM WESTERN GROWERS TO SECDEF
SUBJECT PERCm...ORATE IN THE COLORADO RIVER
KEYWORDS NASSIF, T
COMMENTS
FN SEC U OCN RDD
STATUS CODE DEClSIO~, DECISION DATE PRIORITY ACTION REPORT:
AGENCY USA ACTION ASSIGNEl; RD SUSPENSE 5!.ZJ12003
SUSPENSE COMPLETE ACD COORDINATION
SUSPENSE STATUS
INTERIM REPLY HiT .REPLY TO REPLY IS REPLY TO

REPLYT02 CYS ReD 1 PAGES 2 ENCLOSURES
CMFROM CMIS CMDATE CMSC CMCOPIES CMPAGES

DESTRUCTION
CYNOSTART CYNOEND CYNOTOTAL CMSTART CMEND CMTOTAL
CMENCL ITEMCNT CMCNT LAST ENTRY 05/08103 09:28-DAVISR
DISTRIBUTION: OFFICE COPIES

ADe *R
USA E
UPR E
GC R
SA E
FB R
2
PAGES
REMOVED
[CPEO-MEF] EPA Decision on Perchlorate Criticized Page 1 of 1
Unknown
From: CPEO Moderator [cpeo@cpeo.org]

Sent: Thursday, July 17, 2003 14:00
To: cpeo-mi Iitary@igc. topica. com
Subject: [CPE:.O-~,~EF] EPA Decision on Perchlorate Criticized
The following was a feature on yesterday's (July 16,2003) Morning

Edition ofNPR. In order to listen to the piece, you must have
RealAudio Player, Windows Media Player, or QuickTime Player.
EPA Decision on Perchlorate Criticized

Listen to Mornil]g, Edition audio
July 16,2003
The Environmental Protect Agency announces it will not set a national

drinking water standard for so-called perchlorate pollution.
Environmental activists and public health scientists criticize the
decision, saying perch Iorate -- a key ingtedient in rocket fuel that has
been found in water supplies -- has been linked to developmental
problems in chiL!ren. I lear NPR's John Nielsen.
http://discover.nl'i'9rg/ Ceatures/feature.jhtml?wfld=1338307
(Take the "Listen to M aming Edition audio" link)
You can find ar('11 ivcd iistserve messages on the CPEO website at
http://www.cpeoorgil· . ·wsgrp.html
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10/13/2005
[CPEO-MEF] EPJ\ decision on perchlorate under fire Page lof2
Unknown
From: CPEO Moderator [cpeo@cpeo.org]

Sent: Thursday, July 17, 2003 13:55
To: cpeo-military@igc.topica.com
Subject: [C:'EO-f,;EF] EPA decision on perchlorate under fire
SAN ANGELO STA l\ DARD TIMES

EPA decision on perc !I Iorate under fire
By JOAN LOWY
July 15,2003
The Environmental Pr,'tection Agency has decided not to regulate

perchlorate, a h'y ingr"dient in rocket fuel that has been found in the
drinking water,'.' :2 0 1" 'Ilion Americans at potentially unsafe levels.
The decision mC~lls tl1;~t it could be a decade or more before the EPA
issues a safety,: :111 dZI r, ~ for perchlorate, a chemical that studies show
interferes with il,Tl11al \l1yroid function and may cause cancer. The
chemical persists indefinitely in the envir.onment.
The agency ha~ :1150 c!:'cided not to set a safety standard for certain
byproducts of,' !Grine 'md other chemicals used to disinfect drinking
water that haw 'cell I: "Iced in numerous studies to birth defects and
miscarriages.
Instead, EPA (l1':icial~ decided to leave it up to each state to set
safety standar,'< "or th,.' byproducts, which are found in the drinking
water of250 m::: ion !\inericans.
The decisions wen.' bl"'ied at the bottom of a nine-paragraph press
statement the Z'~IlCY r.'leased quietly late Friday afternoon and which
did not attract', .' :ltlc; : ion of environmentalists and public health
advocates until Tuesc\:,\'.
"This is nothil''' less ,,1',111 a sneak attack .on America's drinking water
safety," said r OlsC' 1 of the Natural Resources Defense Council, a
national envirr-· "'cnl:t! group. "These are major regulatory decisions that
they essentially were t :'y ing to hide from the American public."
This article C~" l'e vic" ed at:
http://www.!..!·1:111~).. ).com/sast/news national/article/0,1897,SAST 4957 211 1618,OO.html
You can fmd 111'~hivcd iistserve messages on the CPEO website at
bJ:tp://www.c:' \1'r~1 'wsgrp.html
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10/13/2005
[CPEO-ME''1 EP/\ decision on perchlorate under fire Page 2 of2
cpeo-military-,, '[;scl:ih,' :illigc.topica.com

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="'======
10/13/2005
PAGES
REMOVED
OFFICE OF THE UNDER SECRETARY OF DEFENSE

3000 DEFENSE PENTAGON
WASHINGTON, DC 20301·3000
ACQUIt::IT10I"J, 2 9 SEP 2~Gl

TECH'" (
AND L,OGISTICS
MEMORANDUM FOR ASSISTANT SECRETARY OF THE ARMY

(INSTALLATIONS AND ENVIRONMENT)
ASSISTANT SECRETARY OF THE NAVY
(INSTALLATIONS AND ENVIRONMENT)
ASSISTANT SECRETARY OF THE AIR FORCE
(INSTALLATIONS, ENVIRONMENT, AND LOGISTICS)
DEFENSE LOGISTICS AGENCY (DSS-E)
'-' L-l3JECT: Interim Policy on Perchlorate Sampling
There are a number of actions that the Department of Defense (DoD) has
l"'ckrtaken to address perchlorate in drinking water, including monitoring for perchlorate
t:1:, 'gh the Safe Drinking Water Act's (SDWA) Unregulated Contaminant Monitoring
. ",' (UCMR), monitoring surface water discharge under the Clean Water Act (CWA) at
" , s' requests, and collection of data on occurrence of perchlorate at Defense
, ' lronmental Restoration Program (DERP) sites. Given recent public concerns over
, ',ible risks associated with perchlorate, the Department believes it is appropriate to
" :,dditional measures to assess the extent of perchlorate occurrence at active and
C~(',eJ installations, ranges, and Fonnerly Used Defense Sites (FUnS). Towards that
end, DoD Components shall continue to consolidate existing perchlorate occurrence data,
:'re] ('~1aJl sample any previously unexamined sites where a perchlorate release is
'cted because of DoD activities and where a complete human exposure pathway is
, to exist. DoD Components shall establish and maintain databases containing the
:nation listed in the enclosed spreadsheets described in each section below. This
'Y supercedes the DoD November 13,2002, memorandum; Perchlorate Assessment
"'nWA
The UCMR (40 CFR Parts 9, 141, 142) mandates that all community and non
:ent non-community water systems serving more than 10,000 people, as well as
'cr systems selected by the U.S. Environmental Protection Agency (EPA), monitor
"~cific contaminants, including perchlorate. Some military installations are subject
:: UCMR and, therefore, should be testing for the presence of perchlorate and
cling the results to EPA and state regulators, as appropriate. UCMR'sarnpling and
')fling is a Class 1 compliance-funding requirement. This requirement is not
",::able to FUDS.
Each Component shall establish and maintain a database of UCMR sampling

~c:ivj~'s. The database shall include installation identification information, all data
l" 'n! collecled, and, at a minimum, the information listed in enclosure 1. DoD
(' . 'lcnts shall work with the DoD SDWA Services Steering Committee in compiling
d "':idated DoD report ofUCMR sampling results by January 31, 2004.
Several states require some military installations to monitor for perchlorate under
ll~, ,.,\'/ A National Pollutant Discharge Elimination System (NPDES) permit program.
:' m :lg and reporting in compliance with an NPDES permit is a Class 1 compliance
,,(1 i 'rcquirement. This requirement is not applicable to FUDS.
:~~lC!1 DoD Component shall establish and maintain a database of sampling data
,.h:lrge point) for those permitted discharges that have a perchlorate reporting
, nent in their NPDES permit, or other state requirement to monitor for perchlorate.
'J • I. G;) Components shall list every NPDES discharge point required to monitor for
r .':llC';:1te. The database will contain, at a minimum, the information listed in enclosure
\ ') Components shall work with the DoD CWA Services Steering Committee in
'::,g a consolidated DoD report of NPDES sampling results by January 31, 2004.
I' \,j "onmental Restoration
I)()D Components shall continue to consolidate existing perchlorate occurrence

. DoD active or closed installations, non-operational ranges, and FUDS. For these
;c ;~S, DoD Components shall also program resources and sample for the presence of
'~::·~:te at any previously unexamined site where there is a reasonable basis to suspect
:' : ~~~:\se has occurred as a result of DoD activities and where a complete human
,,;"2 p:l thway is likely to exist. DoD Components shall consult with their office of
:l 10 determine an appropriate course of action with regard to sampling at sites
::~:: potentially responsible parties other than DoD.
:" determining the likelihood of perchlorate occurrence, DoD Components should

.:' ::1 ' ; volume of perchlorate used, or disposed, and/or the intensity of perchlorate
: ::i '.ities at the site. Activities that could potentially contribute to perchlorate
.II" '::cc include, but are not limited to:
\, The manufacture/maintenance of missiles, rockets and/or munitions containing

l'~rchlorates;
b, The use of perchlorate-containing munitions for training or testing purposes;
.:, 'J 'he demilitarization of perchlorate-containing munitions using techniques,
such as "hog-out" of rockets and missiles containing solid propellant; and,
r', Cpen burning/open detonation operations.
:n :::'~'cssing potential pathways of exposure, DoD Components should consider
W' L 'lC:' the-!'G are:
a. Drinking water sources likely to be impacted by ground water or surface water

c:, or leaving the active or closed installation, non-operalional cange, or PUDS;
::r:J1or,
b. Drinking water systems on or near the active or closed installation, non
0;--crational range, or FUDS that are listed on EPA's UCMR database.
]::\~'':
DoD Component shall establish and maintain a database of existing data and
tI I,,: 1 (' , : : :cted pursuant to this policy at active and closed installations, non
( .:iJI1::: ranges, and FUDS. The database will include, at a minimum, the information
1. :cJ i:l C:>~']osure 3. DoD Components shall work with the DoD Cleanup Committee in
c .npiljJl~':' consolidated DoD report of sampling results by January 31, 2004.
r I. F\' for' "
Dc Components may only ust: t:nvirOJllllental restoration funding for sampling

j
:: :\'it;c:' ",r.t meet DERP eligibility requirements described in the current version of the
.? '." .::gement-Guidance. Under DoDI 4715.6, "Environmental Compliance,"
.. . '~ampling is an Environmental Quality Status Class I requirement.
l~ :!" "
~sing operational ranges for the potential for off-range migration of

:s consistent with the Munitions Action Plan and the Defense Planning
JPG) requirements. The DPG requires the Secretaries of the Military
.s to assess potential hazards from off-range migration of munitions
. This policy memorandum requires the Military Departtnents to include
:n future range assessments.
.',elated Efforts
r'~ntly EPA has only one approved method for testing for the presence of
.".('I~: : This method (Method 314.0) is only approved for testing drinking water.
'T: " test methods have proven to be more accurate and reliable for other media
, ,'diment, groundwater, etc.). Therefore, DoD Components are required to
. \' Jance for appropriate testing methodologies for perchlorate in other media. If
sampling protocols are used, the method must be documented in the enclosed
_.s.
l:~, Jition, DoD Components shall continue to work together to develop and
dcm0ns,: .' new technologies for treatment and cleanup of perchlorate. I appreciate your
SUPI"':l ~.' : bese important efforts.
Phil W. rone
Principal Assistant Deputy Under Secretary of Defense
(Installations and Environment)
r ., .':(' sur.
U, .1R Spreadsheet
r J;:'. ES Spreadsheet
J. ". Sampling Spre.adsheet
,.li
Enclosure 1
Unregulated Con!;minant Monitoring Rule Sampling Re5uI1s
-:
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• Sampling
P .. ~
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,
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~". r.. ,,~ R~o;~ 7'1 :\~J(')l

EPI. veMA 1151 nJU;~I~~~~ rVI:"~ i~;;;;t;~;~::-:_ pu'poses 10< lutu,tJ use.f fI'l~'r'tJec()mfl Hflyul;.tlP.r1
"
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>'~~":'.'I·~7f.~;-:.'~,,,;;f:':'>-~: -j . . .":r*~~~·:~:j-:~ ;r2"'<:'~ ,·;t<;~~i~·fi<;':f, .~::•. ~r:." :::,.!~~
',;21¥1%;'/ ~~~~,~.~:~:~; ·:,1 :':,,!:~~~~:::~i~-l:~~~;ij~~~.JtJ~~ ;"~":~>""" ~;;:-'r:~>i':'

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f·":':;:·'('i::'i.-hO:-:J:,;-; ~;,::,!----:;·;,··.';I I{.,i<. t··:·;-'~{F'i:"'1 >~;::j~ :"i.iI;,~"'~':··~~4,¢~!?f.,t~. .< ,.; ~~_<""::".~' ,;,.,'~0"JX;;'.;
-, .{,:~:' :l.- .• ':: ~;r;..:;~. .'::":":/ ';'::';'>~'~~!, ,1:.-: ' ~o':,~t~.~:~~~ ;;;:~~'''-;''i.'\
.~?'q··~·Pt"~·;-·::~·I.~'<i~': ·1 ;:\~.".::;O.",! :~~ I ~-;j~~\ ",;

'''''·;''·~¢;',·:."r.-->!-'',;;:::.:::'T.E;,~l,.~i,.;':{i4" :\ .;" ,~~~~";,-{,'·I,;'-.lt-;;,,;,,..:~1!:~j,l.r-'tt~:"; <'
>.;..,.:~ ,~ .. '.'i ,,'. ' ~ .

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-
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Enclosure 2
National Pollutant Discharge Elimination System
Sampling Results
I ·fl·_
."~; · · ·
, ' '.,' ...".' i ,
,.%,
C<""m<'nl. On SAmpling ReolJ;,",,'"n!
!:lPt;;,;;,~,:,
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"""::,;",,,:,' I "f:""'''''' i7;fV~,l,f;',~I;,:f·~Trt;?~'" ·-'~::ff~~f;)~~~,:,,?
-~;'~ :_if::0:;~~¢E~~~i:' ·:"t5~;~8~ J '; . :.,; '~';~; ';-:~~I:~i!e'<:~~:~~:~~~~i?+·~I:::I;;;~t;*,;f~l~<?,ti~:
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·. .:---"r!?F~.':: ""0:~;if'-,:,.t~ 1·:4?:{..'!::'.:::~:~~,
,y,; .~,"' _~;;,·'I .~;\j:~\:~-~f.1 '-. . ,'
... ' . " " .• ",.;-,,,,, ''''';fie,'
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".""",' ,','. ·;c.,,·'" I·',',""}> -', '.' ~ "' -:

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"'·~'{!it~F]IS.::Z;.~;.~:'::~ ~.~.. ~_~,:-'~:~~i~t'-~.~>::";·::
.:;-i'" " ,,~r ~;.! _.'1,'.) t·· ~ ;.. • :.1 ':~~,;.\.:!~r> i~;:;i~~3~,; ,<~:~.t-;\i:.'?~:R.?~~
. ': .:": , -,. :}:1:,:;J. . ~ -.:.";;i\'
~W!;"~s;;;J;~~;~:~~~Jt~~
'. . . .' ':,',: I ", ':,,,,,,, "",,-,,,.~,,,,,-.,, ". .'. ~?~:,.!~/.' ·'f;S:i,:(;i:::i·~<:.f~~~~tir:~:~.~,. .:t-::
~:..:. ;,~ ':': ~ I':.~;·"~_~f::~::-:· ·\;~;1;.;',:t::'1.i:J> .:
',< .:.! : .(:: ... :, "' .;~~ .: ; '''':?:r:~'i~i~-':
~i·
Enclosure 3
Site Sampling Results
FacUlty S"e Source of Perchlcwate Loatlon cleleeted tlumbef ot Pathway 01 Ex_oe FevulatOl'Y In_(Cleanup
(Operallons. Equipment, cIoIeeuonolaamples nquested.........tIlng
collededlan.alytlut method r!qulrementl, lampllng
I ______________________l Ac~lvllll.." 1
i r~qulr.emf>l""t~:~. ____
__-l=__: :==:: _: : : : :_ I r:: : : : : : : : : ==r--- -

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1
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REMOVED
5 E eRE TAR Y OF THE ARM Y

WAS H IN'G TON
DEC 6 2002
The Honorable Joe Baca

United States House of Representatives
Washington, D.C. 20515-0542
Dear Representative Baca:
Thank you for your October 23. 2002, letter to the Secretary of Defense
regarding the detection of perchlorate In production wells used by the Inland
Empire Utilities Agency to supply water to the residents of San Bernardino
County, California.
The former Rialto Ammunition Supply Point (Rialto ASP), a property under
the Formerly Used Defense Sites (FUDS) program, was identified as a possible
source of the perchlorate in production wells used by the Inland Empire Utilities
Agency. In 1945. the War Department, the predecessor to the Department of
Defense (DoD), declared Rialto ASP excess and the depot was transferred to the
Farm Credit Administration in 1946. Subsequent owners have included industrial
and commercial enterprises that made use of perchlorate in their operations.
The United States Army Corps of Engineers (USACE) reviewed archived

documents on Rialto,ASP. From this review, USACE determined that the depot
was used for storage and transshipment of fully manufactured items with no
testing, firing, or processing of ordnance components or fillers on the site.
USACE officials did not find any evidence of perchlorate release while the Army
owned the property during World War II.
USACE representatives will continue to cooperate and provide information

on DoD activities at the Rialto ASP to local officials, to include the Inland Empire
Perchlorate Task Force.
Respectfully,
-;/-~ttu~
Thomas E. White
Printed on *RltGyCllld Paper

5 EC RET A R Y OF THE ARM Y
WASHINGTON
DEC 10 2002
The Honorable Dianne Feinstein

United States Senator
750 B Street, Suite 1030
San Diego, California 92101
Dear Senator Feinstein:
Thank you for your November 27,2002, letter to the Secretary of Defense
regarding the detection of perchlorate in production wells used by the Inland
Empire Utilities Agency to supply water to the residents of San Bernardino
County, California.
The former Rialto Ammunition Supply Point (Rialto ASP), a property under
the Formerly Used Defense Sites (FUDS) program, was identified as a possible
source of the perchlorate in production wells used by the Inland Empire Utilities
Agency. In 1945, the War Department, the predecessor to the Department of
Defense (000), declared Rialto ASP excess and the depot was transferred to the
Farm Credit Administration in 1946. Subsequent owners have included industrial
and commercial enterprises that made use of perchlorate in their operations.
The United States Army Corps of Engineers (USACE) reviewed archived

documents on Rialto ASP. From this review, USACE determined that the depot
was used for storage and transshipment of fully manufactured items with no
testing, firing, or processing of ordnance components or fillers on the site.
USACE officials did not find any evidence of perchlorate release while the Army
owned the property during Wond War II. Therefore, DoD is not liable for the
clean up because it occurred subsequent to turning the site over to the Farm
Credit Administration.
USACE representatives will continue to cooperate and provide information

on DoD activities at the.Rialto ASP to local officials, to include the Inland Empire
Perchlorate Task Force.
Respectfully,
~44£:~ Thomas E. White
Prinl!ld on *Recycled Paper

)00/
PAGES
REMOVED
/ &0 I
OFFICE OF THE UNDER SECRETARY OF' OEFENSE

3000 DEFENSE PENTAGON
WASI-4INGTON. DC 20301·3000
ACQUISITION.
T~CHNoLoaY AUG 2 1 2003
ANO LOGISTICS
Mr. Winston H. Hickox
Agency Secretary
California Environmental
Protection Agency
J001 J Street
Sacramento, California 95814
CL~.V'i1t........
DearMr~
./-"
Thank you for your letters of June 6 and July 21, 2003. I too believe that we made
significant progress during our meeting in July, and concur with your general sense of the
meeting's outcome. The Department stands cOltunittcd to work with the State of
California in setting priorities for determining the source and magnitude of perchlorate
problems at military facilities, communicating and understanding California's
requirements related to perchlorate, and assisting in marshalling "assets and resources"
for researching effective treatment technologies. It is my understanding that the working
group will not, however, be involved in or attempt to influence the establishment of
California's perchlorate public health goal or Maximum Contaminant Level.
With respect co your request that installations respond to recent California

Regional Water Quality Control Board lettcrs requesting certain information, I am
reminding the Services to ensure that our installations work with the Boards to address
their concerns. Under the Defense Environmental Restoration Program (DERP), our
instal1ations may already have collected and provided to California state regulatory
personnel information regarding chemicals that have established federal toxicity criteria
and that were previously identified during our response actions as chemicals of concern.
If you have concerns relating to a specific installation, that installation will gladly review
the matter WIth appropriate state regulatory personnel.
With regard to the proposed Readiness and Range Preservation Initiative, wc

agree that the RCRA and CERCLA proposals are codifications of current practice and
not changes in our common understanding of the law. These two proposals arc not
intcndcd to affect any responsibility that DoD may have for perchlorate contamination
that has migrated or may migrate from an operational range.
"
In addition, we recognize that the Department of Defense is subject to and musl

comply with properly promulgated standards established by Federal and State authorities
under the authority of the Federal Safe Drinking Water Act. Federal and State standards
set under authority of the Safe Drinking Water Act address protection of wellhead areas,
public water systems, and underground injection. While Safe Drinking Water Act
standards do not automatically translate into cleanup standards, the program managers
take these standards into consideration under the Federal regulatory cleanup process.
I've enclosed a draft of what I hope can be a charter for our interagency working
group. I propose that we convene our first meeting during the week of August 25, 2003,
to finalize our agreement and determine membership for the group. Please call me at
your earliest convenience at (703) 6~7-~mW, to conhrm.
Sincerely,
/l "..._,) ~
,: ;;,../-;"'- Ii
~tft.-... \J co(... . - A
i
{
lohn Paul Woodley, Jr.
Assistant Deputy Under Secretary of Defense
Enviromnent
Enclosure
--------_._-- -_.- .
DRAFT
CHARTER
DoD· CALIFORNIA INTERAGENCY TECHNICAL WORKGROUP ON
PERCHLORATE
ARTICLE I-ESTABLISHMENT
The Department of Defense (000) and the State of California (California)
hereby establish an Intcragcncy Technical Workgroup on Perchlorate
("Interagency Technical Workgroup," or "ITW").
ARTICLE H--MISSION
000 and California shall work collaboratively, in a process that fully
recognizes and respects the interests and needs of all affected stakeholders, to
identify and resolve issues regarding the scope, scale and significance of
perchlorate releases caused by current and/or past activities at facilities controlled
by 000. All parties recognize and agree to focus on genuine risks to public health
and to obtain and use the best sciences available as identii1ed by authoritative,
disinterested and policy-neutral scientific experts.
ARTICLE III-OBJECTIVES
1. The objccJivcs of the Interagency Technical Workgroup are:
a. To prioritize the types of activities deemed necessary and
appropriate to address the issues related to perchlorate releases at
facililies comrolled by 000. Prioritization of activities will take
inlo account existing prioritization protocols and methods, identified
human health risks, reliability, uncertainty, indirect risks, and cost
effectiveness of technological alternatives as applied to site-specific
conditions.
b. To Identify and share science and technology information that may
be useful regarding perchlorate issues, and to identify the site
conditions and limitations under which the application is likely to be
appropriate.
ARTICLE IV--ORGANIZATION
Within DoD, the.establishrnent, administration, and operations of the ITW
shall be under the authority of the Assistant Deputy Undersecretary of Defense for
Environment (ADUSD~E)
Within California, the establishment, administration, and operations of the
ITW shall be under the authority of _
DIlAFT
1. Balanced Repl·e~entation.
a. ITW shaH be composed of an equal number of representatives from

DoD and California.
b. Notwithstanding any other provision of this Charter, the DoD
California balance shall remain unchanged if additional members are
added.
2. McmbershiQ.
- a. DoD shall be initially represented by appropriate representatives of
the following components:
i. U.S. Army.
Ii. U.S. Navy.
iii. U.S. Air Force.

iv. U.S. Marine Corps.
v..Defense Logistics Agency.
vi. U.S. Army Corps of Engineers

viLADUSD (E)
b. California shall be initially represented by appropriate technical
representatives of the following operating offices and/or agencies.
i.
ii.
til. _
iv. _
v.
VI. _
vii. _
c. ITW sh~ll be co-chaired by the ADUSD (E) member and one

member selected by California.
d. At the discretion of the ITW by 2/3rds vote additional members may
be added.
e. The ITW is advisory in nature and shall not include any matter of
agency or public policy. Members are authorized to develop,
provide, review, dis:se1l1.iuatc:; and analyze technical informaLion
related to the Mission and Objectivesas stated in Articles II and III
- -_._---~--~-~~~~~~~~-,
DRAFT
of this charter. No member is authorized to opine or make decisions

on any matter of agency policy.
3. Operating fTocedur~~.
a. Revision. This Charter may be revised by mutual agreement of the
Co-chairs. (Make sure this is consistent with Article V below).
b. Co-Chair Responsibilities.
i. Share Chair responsibilities on an alternating basis.
ii. Jointly oversee all activities, including the activities of any
committees established to address specific issues.
c. Establishment ofFacilitator
i. A Facilitator shall be selected to moderate and expedite
ITW affairs subject to two-thirds vote.
11. The Facilitator shall possess sufficient technical knowledge
to perfonn the functions expected; be a nonmember of ITW
and be organizationally- and policy-neutral.
iii. The Facilitator shall be funded by equal DoD und California
contributions.
4. Facilitator Responsibilities.
a. Coordinate with the Co-Chairs to establish the meeting date,
location, and agenda and provide these to the members in a timely
manner.
b. Ensure that meetings stay on schedule and on agenda, members arc
offered equal opportunities to participate, and manage procedural
and administrative matters related to lTW functions and activities.
c. Ensure that a complete and accurate record is maintained in
accordance with Paragraph 5(e) below.
d. Ensure that minutes of all meetings are promptly distributed to
members for review, comment and concurrence.
e. Prepare 'and distribute all correspondence.
f. Maintain a current roster of all members.
g. Mnintain all records of the ITW.
5. Meetings.
a. Frequency. The ITW shall set a goal to meet either in person, by
teleconference or video teleconference monthly for the first three
months then as necessary at a mutually agreeable time and place.
DRAFT
b. Quorum. A quorum shall exist if no less than two-thirds of all

members are present. No official meeting shall occur without the
existence of a quorum. The Co-chairs must be present.
C. Non-members. At the discretion of the ITW, by majority vote or the
agreement of the Co-chairs, non-members may address, provide
information to, or participate in technical discussions with ITW.
d. Agenda. The Facilitator, in coordination with both Co-Chairs, shall
establish the agenda prior to each scheduled meeting and distribute it
to all members for review and comment no less than three working
days in advance of the scheduled meeting. Any item not on an
advance Agenda may be added at. any time hy majority vote of all
members or the concurrence of both Co-Chairs.
e. Minutes.
1. The Facilitator shall prepare and forward an accurate and
complete set of minutes to the Co-Chairs for content review
within three working days after any scheduled meeting.
11. Each Co-Chair shall be responsible for securing timely
concurrence of the members within their respective
organizations. After coordination is complete, each Co
Chair and the Facilitator shall sign the minutes and retain
copies in their permanent files.
iii. The Facilitator shall distribute minutes to all members by
email distribution list within one working day of approval
by both Co-Chairs.
6. Records.
a. A complete set of records shall be maintained by the Facilitator.
Each Co-Chair will keep a complete set of records as provided by
the FaciHtator.
b. These records shall be made available upon request to any ITW
member via their representative Co-chair.
7. Voting.
a. Each participating operating component, operating office and/or
agency shall designate a principal member and an alternate member.
Each member shall have one vote.
b. No member shall be permitted to vote by proxy, but members shall
he allowed to vote hy voice if unahle to he physically present ar the
meeting..
DRAFT
c. A roll call record of all decisions shall be maintained by the

Facilitator.
d. All ITW recommendations shall be by a consensus of members
present or participating by telephone.
e. No recommendation shall be forwarded without at least two-thirds of
votes cast. ( don't understand d. and e. consensus to me means 50%
but e. says 67%. Recommend this be adjudicated).
8. Infonnation Qualily.
a. All Federal agencies have a nondiscretionary duty to comply with
applicable Information Quality Guidelines issued by the Office of
Management and Budget (OMB). Information dissemination by
000 is also subject to Infonnation Quality Guidelines issued by
DoD.Jnformation to be disseminated by ITW shall be covered
under these Guidelines.
b. All covered information shall be subject to appropriate pre
dissemination review and post-dissemination error correction
procedures as set forth by OMB and 000.
c. Scientific, technical and statistical information related to perchlorate
shall be considered to be "influential" as that term is defined in
OMB's Information Quality Guidelines.
9. Progress Reports.
a. The Co-Chairs, with the assistance of the Facilitator, shall provide
the governing authorities (ADUSD-E and California authority)
quarterly progress reports beginning 90 days after the first regular
meeting.
ARTICLE V-AMENDMENTS
1. ITW may seek amendments or this Charter, or the revocation of a
previously approved amendment, by the governing authorities. The
submission of a recommendation does not aller in any way governing
authorities' management prerogatives.
2. Recommendations for an amendment shall be forwarded by majority( 7e
above says 2/3rds vote) vote through the Co-Chairs to the governing
authorities. .
What is perchlorate? Perchlorate is both a man-made and naturally occurring compound. In solid fonn, it is a
type of salt. Perchlorate dissolves easily and moves quickly in groundwater and surface water. Once dissolved
in water it remains in wate~ for a very long time.
What are the uses of perchlorate? Perchlorate was once used to treat thyroid disorders in people suffering
from a thyroid condition called Graves' Disease. Perchlorate is still used today under
limited conditions to test for thyroid honnone production.
Perchlorate is used in the production of explosives and fireworks. Additional uses include
the production of matches, dyes, electroplating, rubber manufacturing, paint production,
and certain chemical fertilizers. It is an important part of safety devices that we use
everyday such as road flares and airbags.
Perchlorate has been used for decades- as part of the United States national
defense and space programs. It is a major component in solid fuel for rockets
and missiles. The highest potential for the release of perchlorate at DoD sites
is during the removal, recovery, and disposal of propellant from the solid
rocket motors. Currently, there-are strict procedures that must be followed to
prevent release of perchlorate into the environment during these procedures.
How can I be exposed to perchlorate? The primary way people can be

exposed to perchlorate is by drinking water that has perchlorate in it. Another possible fonn of exposure would
be by eating vegetables that have been irrigated with water that contains perchlorate.
People who live near areas where perchlorate has been used, tested, produced, or disposed of may be exposed to
low levels in their drinking water. The Department of Defense (DoD) may sample for perchlorate at DoD sites
if there is both a reasonable basis to suspect the presence of perchlorate and a way for people to come into
contact with water that contains potentially harmful levels of perchlorate. EPA, other federal agencies, states,
water suppliers and industry are actively addressing this issue by testing for perchlorate in drinking water and
surface water. If you believe that you may have perchlorate in your drinking water, please contact your
local/state health department or water utility for additional infonnation.
Can exposure to perchlorate affect my health? A large amount of infonnation is available on the health
effects of perchlorate. Health studies using data from patients who were given perchlorate to treat thyroid
conditions indicate that high doses, much higher than what has been found in drinkip.g water, can affect
metabolism, growth, and development of the body: In addition, long-tenn exposure to high levels of
perchlorate taken as medication has been linked to potentially serious blood disorders. The levels ofperchlorate
found in drinking water are much lower than what has been found to cause these conditions. The potential
health impacts of exposure to low levels in drinking water continue to be studied to detennine a definite safe
level.
How do you test for perchlorate? Before 1997, it
was not easy to identify the presence of perchlorate in
water supplies because laboratory-testing methods
could not measure very low levels in water. DoD was
instrumental in the development of a new, more
effective technique in 1997, which has helped identify
additional sources of perchlorate. At present,
drinking water can be tested for perchlorate through
EPA's Unregulated Contaminant Monitoring Program. The U.S. Geological Survey and others are monitoring
for perchlorate in surface water. U.S. EPA, DoD, and other agencies are continuing to work on improving
methods to test for perchlorate.
What are the laws regulating perchlorate? Currently, there are no federal drinking water standards for
perchlorate. DoD ancfother federal agencies are cooperating with U.S. EPA as it establishes a regulatory level
of perchlorate to protect health. Once established, DoD will comply with regulatory requirements. In the
meantime, DoD will take measures to ensure that people's health will be protected if their drinking water
contains harmjUllevels ofperchlorate that originatedfrom DoD sites.
On 22 January 2003, the U.S. EPA reaffInned its 1999 guidelines of an interim level for perchlorate in water.
The National Academy of Sciences will review available research results and studies which will help the U.S.
EPA establish a regulatory level. DoD welcomes this review.
U.S. EPA may establish a drinking water standard called a maximum contaminant level (MCL) after completion
of the National Academy of Sciences review. The MCL is a maximum amount of perchlorate the U.S. EPA
will allow in drinking water to ~l}sure the protection of human health.
California EPA recently proposed a Public Health Goal (PHG) for perchlorate in drinking water (December
2002) but has not finalized the goal. Other states, such as Texas and Massachusetts, have either proposed a
drinking water level or have begun the process. In the meantime, the California Department of Health Services
(DHS) adopted an advisory action level. The DHS detennined that perchlorate concentrations lower than the
action level are considered to be
protective of all people, including children and pregnant women.
Where can I go for more information?
The U. S. EPA draft risk assessment on perchlorate can be viewed at http://wew.epa.gov/ncea. You may also
visit the EPA perchlorate web site at Www.epa.gov/safewaterlccl/perch[orate/perchlorate.html
Please contact ... at 1-800-... DoD has infonnation at [insert link] for more infonnation.
.-: ,. 1>~ fJ
Army Impacts
Massachusetts Military Reservation
'
• Encroachment ',
• SDWA Administrative Order for RDX -7 Cessation of Live Fire; Later
Perchlorate Added
ACTIVITY Perchlorate in
G. Water
Firing Areas (Artillery and Mortar) 5ppb
Maneuver Areas " 3ppb
Munitions Disposal / EOD Activities 300ppb
SOMARC Missile Ops ??
1
April 29, 2003
... /!",
Army Impacts
Massachusetts Military Reservation
__________________________________ Installations & Environment _
.- {
• P2/Compliance
• Perchlorate less than 1ppb "
• Bourne pipeline built
• Restoration
• EPA orders study to determine cleanup
feasibility to 1.. 5ppb
2
April 29, 2003
. /..'
Army Impacts
Aberdeen Proving Ground
Installations & Environment_

i
• Perchlorate in Public Water Wells - 2-4ppb

• Extreme Political Pressure to Respond
• Encroachment "
• Smoke / Obscurant training in vicinity of Public Drinking Water Extraction Wells·
• Training Stopped (voluntarily) - Looking for Area to Relocate
• P2/Compliance
• State Issues Health Advisory to Drinking Water Supplier
• Perchlorate in Public Water System < 1 ppb
• Restoration - pressure to put in, physical barrier
3
April 29, 2003
1
PAGE
REMOVED
,.
2/(P
Bill/Report Number Bill Name Requirement Language Responsibility Due Date
H.R.2599 2004 Defense Military (H. Rpt. 108-342) "The conferees direct the Department to submit a report identifying the Secretary of Defense 30-Apr-04
Construction Appropriations sources of perchlorate on Base Realignment and Closure (BRAe) properties and the plans
Act(Conf Report 108-342, Items to remediate perchlorate contamination on these sites no later than April 30, 2004, instead of
of General Interest) March 30, 2004 as proposed by the Senate (S.Rpt 108-82)."
(S. Rpt 108-82) "The Committee is growing increasingly concerned about the potential impact
of perchlorate contamination at installations that have been closed through the BRAC process
as well as at active and inactive defense sites. Perchlorate, a chemical used in solid rocket
propellant, has been identified by the Environmental Protection Agency [EPA] as an
unregulated toxin. Perchlorate contamination has been found in drinking water supplies in 29
States, including California, Texas, Colorado, Maryland, and Massachusetts. More than 300
groundwater wells in California are contaminated with perchlorate, as is the Colorado River,
which supplies drinking water to more than 15,000,000 people in the Southwest.
According to the EPA, the Department of Defense and the National Aeronautics and Space
Administration are responsible for 90 percent of the perchlorate produced in the United States.
Although the EPA last year concluded in a draft assessment that perchlorate could pose a risk
to human health at drinking water concentrations of just one part per billion, the Federal
Government has yet to set a drinking water standard for perchlorate. Therefore, no remediation
standard exists. The EPA assessment has been referred to the National Academy of Sciences
for review, which could significantly delay the establishment of a national drinking water
standard for perchlorate.
The Committee recognizes that, absent a state or Federal standard for perchlorate, the
Department of Defense is under no legal obligation to remediate perchlorate contamination at
defense sites. However, the Committee is disappointed that the Department has been
unresponsive to requests to test for perchlorate at BRAC properties or other defense sites.
To ensure that the Department is prepared to respond quickly and appropriately once a
perchlorate standard is determined, the Committee directs that the Department take the
fnllnu/inn "3r-tinnc::'
(1) $ubmitto the congressional defense committees no later than December 31, 2003, a report 31-Dec-03
on the activities of the Interagency Perchlorate Steering Committee of the Department of
Defense that was established in January 1998 and was originally chartered to facilitate and
coordinate accurate accounts of technological issues (occurrence, health effects, treatability
and waste stream handling, analytical detection, and ecological impacts) related to perchlorate
contamination of drinking water supplies and irrigation water supplies and to create information
r! transfer links for interagency and intergovernmental activities regarding such areas of concern.
The report shall cover all activities that were identified in the memorandum of the Deputy Under
Secretary of Defense (Environmental Security), dated January 24, 2001, to the Secretaries of
the military departments and the Director of the Defense Logistics Agency.
(2) Identify sources of perchlorate on BRAC properties and develop a plan to remediate
perchlorate contamination on BRAC sites that can be implemented rapidly once State or
Federal perchlorate standards are set. The Department shall report to the congressional
defense committees on its perchlorate findings and remediation action plan no later than March
30, 2004."
HR 1588 FY 2004 Defense Authorization (Section 323) (a)EPIDEMIOLOGICAL STUDY OF EXPOSURE TO PERCHLORATE- The Secretary of Defense 1-Jun-05
Act Secretary of Defense shall provide for an independent epidemiological study of exposure to
perchlorate in drinking water. The entity conducting the study shall-
(1) assess the incidence of thyroid disease and measurable effects of thyroid function in
relation to exposure to perchlorate;
(2) ensure that the study is of sufficient scope and scale to permit the making of meaningful
conclusions of the measurable public health threat associated with exposure to perchlorate,
especially the threat to sensitive subpopulations; and
(3) examine thyroid function, including measurements of urinary iodine and thyroid hormone
levels, in a sufficient number of pregnant women, neonates, and infants exposed to perchlorate
in drinking water and match measurements of perchlorate levels in the drinking water of each
study participant in order to permit the development of meaningful conclusions on the public
health threat to individuals exposed to perchlorate~,
(b) REVIEW OF EFFECTS OF PERCHLORATE ON ENDOCRINE SYSTEM- The Secretary 1-Jun-05

shall provide for an independent review of the effects of perchlorate on the human endocrine
system. The entity conducting the review shall assess
(1) available data on human exposure to perchlorate, including clinical data and data on
exposure of sensitive subpopulations, and the levels at which health effects were observed;
and
(2) available data on other substances that have endocrine effects similar to perchlorate to
which the public is frequently exposed.
(c) PERFORMANCE OF STUDY AND REVIEW- (1) The Secretary shall provide for the
performance of the study under subsection (a) through the Centers for Disease Control and
Prevention, the National Institutes of Health, or another Federal entity with experience in
environmental toxicology selected by the Secretary.
(2) The Secretary shall provide for the performance of the review under subsection (b) through
the Centers for Disease Control and Prevention, the National Institutes of Health, or another
appropriate Federal research entity with experience in human endocrinology selected by the
Searetary. The Secretary shall ensure that the panel conducting the review is composed of
individuals with expertise in human endocrinology.
(d) REPORTING REQUIREMENTS- Not later than June 1, 2005, the Federal entities
conducting the study and review under this section shall submit to the Secretary reports
containing the results of the study and review."
H Rpt 108-187 FY2004 Defense Authorization The managers on the part of the House and the Senate at the conference on the disagreeing 180 days of
Act - Conference Report 108 votes of the two Houses on the amendment of the Senate to the bill (H.R. 2658), making enactment(became PL
283 Joint Explanatory Statement appropriations for the Department of Defense for the fiscal year ending September 30, 2004, 108-879/30/03; signed
(Page 59) - The conference and for other purposes, submit the following joint statement to the House and the Senate in 11124/03)
agreement on the Department of explanation of the effect of the action agreed upon by the managers and recommended in the
Defense Appropriations Act, accompanying conference report.
2004; incorporates some of the
provisions of both the House and
Senate versions of the bill.
The conference agreement on the Department of l?efense Appropriations Act, 2004,

incorporates some of the provisions of both the House and Senate versions of the bill. The
language and allocations set forth in House Report 108-187 and Senate Report 108- 87
should be complied with unless specifically addressed in the acco.mpanying bill and statement
of the managers to the contrary.
"Perchlorate Groundwater Contamination Study" Perchlorate is a salt, commonly used in a

host of commercial and military applications ranging from rocket fuels and fireworks to
automobile airbags. High levels of perchlorate are known to interfere with thyroid gland and
mental acuity functions and with the human body's ability to produce growth and fetal
development hormones. Though much is known about perchlorate, the specific long term
effects and the specific dosage levels at which perchlorate becomes hazardous are still being
debated in the environmental, scientific and medical communities. In Southern California,
growing groundwater perchlorate contamination is widely attributed to Department of Defense
activities and the commercial fuels and explosives industry, though the specific causes of
contamination have yet to be rigorously established; the Department has refused to
acknowledge a causal relationship until an extensive study is completed. responsibility:
The, Committee is aware of the controversy surrounding the evaluation of perchlorate

contamination of groundwater in Southern California and other areas across the country. The
Committee directs the Department to conduct a joint study with the Environmental Protection
Agency of perchlorate groundwater contamination, to be completed within 180 days of the
enactment of this Bill. This report will examine in detail perchlorate groundwater pollution in and
around the Colorado River, San Bernardino County, the Cochella Valley, Santa Clara River and
i' the Imperial Valley that threatens drinking and irrigation water supplies in Southern California,
Arizona and Nevada. This report will assess the breadth and scope of contamination and make
preliminary recommendations that will, at a minimum, include:
1. Recommendations for the establishment of a national standard for acceptable levels of

perchlorate groundwater contamination
2. Determination of the military/defense industry sources that have contributed to perchlorate

contamination; and
3. Outline appropriate steps to be taken to mitigate or clean up those areas that are deemed to
be the government's responsibility.
·
~3Z
Installations & Environment _
, !
Department of Defense
Perchlorate Initiatives
Briefing
Jor
Representative Baca
February 26, 2004
Background on,DoD Perchlorate Initiatives
• DoD complies with all applicable legal standards

established by Federal and State regulatory'agencies
• Reasons for a DoD Perchlorate Assessment Policy
- Absence of Federal regulation; perchlorate is currently an unregulated
contaminant under SDWA, CERCLA, RCRA, and CWA
Planning; policy provides:
o Knowledge of perchlorate occurrence
o A single framework for addressing potential perchlorate contamination at
DoD installations
o Instructions for reporting of data
o Basis for the collection of data needed to assess the extent of -perchlorate
contamination
February 26,2004 2
Background on DoD Perchl'orate Initiatives (cant.)
• DoD Perchlorate Assessment Policy (Nov. , i
2002)
- Proposed Sampling must satisfy specifie,d criteria
o A reasonable basis to suspect a potential release of perchlorate
associated with DoD activities, and
o A pathway exists for the potential contamination to threaten
public health
- Active ranges
o Military Munitions Rule (MMR) provisions of RCRA will continue

to apply where perchlorate is released and does not impact
drinking water supplies
February 26,2004 3
000 Leadership on Perchlorate
• Perchlorate contamination challenge I!
- Credible science leading to substantiated decisions
- Accurate risk characterization

\
- Appropriate risk management strategies
• Interagency Perchlorate Steering Committee

- Formed to address challenges of perchlorate contamination
- Representatives of Federal Government agencies, affected State,
Local, and Tribal governme{lts - 000 co-chair ,
- Integrated parallel approach to simultaneously address:
o HeaIth effects
I
o Treatment technology
o Analytical
o Ecological
February 26,2004 4
DoD Leadership on Perchlorate (cant.)
• Federal Interagency Working Group

- Membership includes 000, EPA, DOE, NASA, OMS, OSTP,
and CEQ
- Sponsoring a National Academy of Science (NAS) review of
perchlorate science issues
o NAS review expected to be concluded by Fall 2004
c.
o 000 contributing funding as part of cost-sharing agreement
• California Interagency Working Group
- Evolving from California Perchlorate Roundtable
- Ad Hoc Workgroup win prioritize sampling at installations in
California '
- Membersrip includes California EPA, Regional Water Quality
Boards, and DoD Components.
- 000 extended the invitation to municipalities and water
purveyors
February 26,2004 5
DoD Perchlorate R&D Initiatives
Perchlorate treatment technology and identification of

alternatives to perchlorate are DoD's number one
environmental R&D priority ,
- Investigation and demonstration of innovative treatment technologies

o Strategic Environmental Research and Development (SERDP)
o Environmental Security Technology Certification Program (ESTCP)/Air Force
Research Laboratory (AFRL)
o Edwards AFB
o Vandenberg AFB
o EI Toro
o Aerojet Rancho Cordova
o Other applications being considered
- Investigating the identification of alternative chemicals for perchlorate
in Defense uses
o SERDP
o Army
February 26,2004 6
000 Perchlorate R&D Initiatives (cant.)
• Treatment technology development initiatives

- SERDP; national projects investigating the in-situ bioremediation of
perchlorate
o Develop an understanding of the environmental factors that affect the
biological reduction of perchlorate
o Demonstrate the ability to remove perchlorate from contaminated
groundwater and soils
- ESTCP/AFRL
o Ammonium perchlorate degradation for industrial wastewater treatment

o Biological reduction of perchlorate-contaminated production and
demilitarization wastewaters
- Edwards AFB
o Ion exchange technology for treatment of contaminated groundwater

o Uses innovative exchange resin developed by Oak Ridge National
Laboratory expected to improve cost-effectiveness of process
February 26,2004 7
DoD Perchlorate R&D Initiatives (cont.)
• Alternative chemicals for perchlorate in Defens~ uses

SERDP
o Alternatives for ammonium perchlorate in DoD missi,le applications
o Elimination of chlorine-containing compounds in pyrotechnic flare
compositions
o "Clean" or "green" energetic material projects
• Eliminate chlorinated compounds
• Improve process efficiency
• Reduce production and demilitarization wastes
- Army
o Replacement of perchlorate in grenade and artillery simulators

o Accounts for approximately 70% of perchlorate expended annually in
Army training exercises
February 26,2004 8
DoD Analytical' Initiatives
• Enhanced analytical methods

- DoD scientists lead the inter-laboratory validation studies of industry
and state enhancements of perchlorate analytical methods
- Perchlorate detection limit lowered from 400 ppb tb 100 ppb to 4 ppb
- Leads to EPA-approved method for drinking water, Method 314.0
• DoD Environmental Data Quality Workgroup (EDQW)

- DoD partnering with EPA to evaluate current and emerging
perchlorate analytical capabilities
o Develop and validate neW methodologies to reliably test for perchlorate in

groundwater and other media "
o Improved ion chromatography (IC) (Proposed EPA Methods 314.1 and
314.2)
o Liquid chromatography/mass spectrometry (LC/MS)
o Others
February 26,2004 9
DoD Analytical Initiatives (cont.)
· 000 Environmental Data Quality Workgroup (cQ!nt.)

- Perchlorate testing roundtable scheduled for October 2003
- Jointly sponsored by 000 and EPA \
- Invited participants include chemists from 000, EPA, other Federal
agencies, States, academia, laboratories, instrument manufacturers
February 26,2004 10
"
California Public Health Goal

• There is substantial debate amongst scientists as to whether

perchlorate poses a health risk at low concentrations.
• Results of a National Academy of Science peer review available

by this fall is expected to resolve many of these scientific
questions and provide recommendations for setting health
standards.
• DoD is concerned that California regulatory agencies may feel

pressured to regulate perchlorate prior to resolution of these
underlying science issues. '
• Although theoretically nQn-binding, the California Public Health

Goal would trigger immediate public concern and force
regulators, water suppliers, industry, and DoD to treat the
Public Health Goal as a de facto drinking water standard.
• The state could secure an extension which would allow
consideration of National Academy of Science study
recommendations.
February 26, 2004 11

(
Summary
• 000 will comply with applicable perchlorate standards as
they are established by Federal and State regulatory!
agencies
• DoD's Perchlorate Assessment Policy authorizes
installations to investigate the extent of perchlorate
contamination in the absence of legal standards
• 000 continues its leadership role in addressing the
perchlorate issue at the Federal and State levels
• Perchlorate treatment te'chnology and alternatives
identification are DoD's top environmental R&D priority
.• Urge Congressman Baca support postponement of Public Health

Goal until after National Academy of Science review is completed.
February 26,2004 12
79tLJ
PAGES
REMOVED
rJ 90
Source:. Open-Burn/Open
Detonation (OB/OD) Pits
, .
• Demand for OB/OD
facili'ties with larg'e
rocket motor capacity
- STARTII
- Nunn-Luger
- Multi-National Force
Reduction Treaty
w. • Decreased availability
§
i·
of OB/OD facilities
- 1990 Clean Air Act
Amendment (CAAA)
- Base Realignment and
Closure (BRAC) Peace Keeper first stage (98,000 Ibs)
Medical Use of
Perchlorate
PAST
- Clinical use of perchlo'rate to treat Graves' Disease
(hyperthyroidism) in 1950s and 1960
- Anti-thyroid drugs act by:
• Either by blocking iodine uptake into thyroid
• Or by blocking T3 and T4 synthesis in thyroid

'1 - Recommended dose: 800 - 1000 mg/day
- "Single dose up to daily doses for weeks, years
- Use limited in mid-60s due to reports of
agranulocytosis and fatal aplastic anemia
Medical Use of
Perchlorate
CURRENT
- Amiodarone used to treat· patients with ischemic
heart disease or with ventricular tachycardia; 1000
, mg·/day potassium perchlorate used to treat
amiodarone-induced hyperthyroidism
- Used if sensitive to standard antithyroid drugs
- Perch~orate discharge test to diagnose thyroid
function - iodine discharged from thyroid if there
.,is problem with hormone production
,.
Perchlorate Effects
Main Symptoms/Effects of
Hypothyroidism- adults diagnosed
with hypothyroidism due to iodine
.deficiency
- Run down, slow, depressed
- Sluggish, cold, tired
.'1 Dryness and brittleness of hair
-"Dry and itchy skin, constipation
- Muscle cramps
- Increased menstrual flow
- Possibly goiter
Background
• Perchlorate (CI04-) chemistry

- Highly oxidized but generally unreactive
- If's a salt, in many ways similar to nitrate
(N0 3-)
• What does this mean?
- Mobile in subsurface but stable
- Same for surface water
- Treatability:
• Not technically difficult, but development &
optimization required
• Potentially very costly due to volume of water
requiring treatment
Source: US EPA website
www.clu-in.org/ .
C/)
c:::
(I)
••
Perchlorate releases in US
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,0
e:, ' 'i>''c::> • Perchlor.u:e Relea.<es as of April, 200.3
_&.~~ Major Rivers
{» ['·. _·_ i State with no reported perchlorate rclca..:;c

•••••_ J Sate with a reported ~rchlorate release
The Perchlorate Contamination
Challenge
Credible Science
Credible Decisions
• Accurate risk characterization
• Appropriate management strategies
:. Coordinate activities within the IPSC
Recent Events with
Perchlorate
• The .debate over heal.th effects

• Inter-Agency Work Group
, - OMB, EPA, NASA, DoD, OSTP et 01
• State of the Science Symposium
• NAS Contract and Review
• DoD'Interim Sampling Policy (29 Sep 03)
~. Specific Service Policy Directives
Summary of RIDs
EPA 1992 EPA 1995 EPA 1999 EPA 2002 TERA

\
2002
Critical Stanbury & Stanbury & Argus Argus 2001 Crump and
Wyngaarden Wyngaarden
Study (1952) (1952) 1998 Effects Greer 2000
Neurodev
Species Human Human Rat Rat Human
-
Critical Point of iodide Point of PND5 Decrease Decrease

Effect disruption iodide pups T4levels T4 humans
disruption in dams
and brain
NOAELI .14 mg/kg/day .14 0.1 .01 .02
LOAEL mg/kg/day mg/kg/day mg/kg/day mg/kg/day
,'
UF 1000 300 100 300 3-30
DWEL 4ppb 18ppb 32ppb Ippb 70ppb

University of Nebraska State of the
Science Conference Oct 2003
• Present new scientific work performed since 1999

• Provided an opportunity \for experts in each relevant
field to evaluate the new science that could alter the
state of scientific knowledge
• Provided an opportunity for scientists to directly engage
in query and discussion with invited experts and the
researchers who performed these new studies
• Develop among the invited experts a shared
understanding and exposition of the state-of-the
science of perchlorate as of 2003
~ Information presented to NAS in December 2003
Challenge to the NAS Panel
• Regulatory standards set/based on

the highest quality scientific
information
• Transparency essential to risk
(lssessment
• Risk assessments must be objective,

realistic and scientifically balanced
; ,
• $24M DoD/taxpayer investment

Why the NAS Review?
• Federal agencies a·nd nationally recognized
scientists disagree with EPA's assessment
• Science policy implications to realistic training

and overall readiness
• Achieve balance between environmental
protection (on the extreme edge) and our
obligations to national defense and our
military communities
" • We want the science to be "right"

• Credible science should be used for
appropriate decision and policy decision
making
Next Steps - S~ience
• IWG/DoDPWG
, ,
• Continue working with PSG and
industry stakeholder partners
• Stakeholder Outreach and Training
Programs for all DoD Installations
• Additional NAS Meetings:
i'
- 13/14 Dec 03, Irvine, California
- March and May 04 - Washington DC

DOD Policy
29 September 2003 DOD Interim Policy on

I
Perchlorate Sampling
• SDW~: Sample and test dr~nking water supply systems that are
subject to the Unregulated Contaminant Monitoring Rule (UCMR).
• CWA: Sample and test permitted discharges under the National

Pollutant Discharge Elimination System (NPDES), where permit
limits have been established for perchlorate
• Environmental Restoration: Sample and test [environmental

media] for the presence of perchlorate at any previously
unexar.nined site where 1) there is a reasonable basis to suspect ~
perchlorate release has occurred as a result of DoD activities and
2) a complete human exposure pathway is likely to exist.
• ' Munitions Action Plan and Defense Planning Guidance: Assess the
potential hazards from off-range migration of munitions
constituents, including perchlorate, in future range assessments.
(j)
-+
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Regulatory Status
• Standards:
- US,EPA's Final Maximum Contaminant Level (MCL) for
Drinking Water expected 2006 - 2008
• Risk Assessment Data:
- Toxicity levels: human and animal data available
• Human - studies in US and foreign countries
• Animal - most studies are rats, mice, but also wildlife
• Plant - studies on food crops, trees
- National Academy of Sciences will be final authority
:' • Evaluation began Sept 03; to be completed June 04
• Most panel members from universities; experts in field

• http://www.epa.gov/ncea/presentations/perchlorate/in
dex.html
Establishing a Reference
Dose (RID).
A high confidence RfD is based on data that

addresses ALL potentiolly critical life stages
--tU f
--t --t
--t
~
I \ I
Reproductive
i I I I I
Developmental General Toxicity
Risk Assessment / RfD
- Current propQsed EPA value of 1 ppb
. based on rat data (rat much more
sensitive to perchlorate than humans)
- Although based on human data, Calif.
Public Health Goal of 6 ppb is overly
conservative
- Human No Observable Effects Level
(NOEL) for iodine inhibition = 180
i'
220 ppb (avg. 200 ppb); RfD could

be 200 ppb
For More Information
www.serdp.org
- www.estcp.org
- www.afcee.brooks.af:mil/products/techtrans/
- www.denix.osd.mil/den·ix/Publicl
Library/Water/Perchlorate/perchlorate.html
- www.epa.gov/ogwdwOOOlccl/
perchlor/perchlo.html
- www.dhs.cahwnet.gov/ps/ddwem/
chemicals/perchl/perchlindex.htm
- www.adeq.state.az.us/environ/water/dw/fact.htmI
- tera.org/Perchlorate/welcome.htm
;' - www.gwrtac.org/html/techstatus.html#PERCHLOR
ATE
- www.epa.gov/safewater/ccl/perchlor/r9699fac.p4f
- http://www.epa.gov/ncea/presentations/perchlorate/inde
x.html
f t EA~
...~~
United States
Environmental Protection
" Agency
Disposition of Comments
.and Recommendations for
Revisions to
"Perchlorate Environmental
Contamination:
Toxicological Review and
Risk Characterization
External Review Draft
.:
(~anuary 16, 2002)"

Disclaimer
This document has been reviewed in accordance with U.S. Environmental Protection
Agency policy and approved for publication. Mention of trade names or commercial products
does not constitute endorsement or recommendation for use.
11
Table of Contents
List of Tables x
List of Figures xiii
Contributors and Reviewers xv
Preface xxiii
Acknowledgments xxvi
1. INTRODUCTION " 1-1
1.1 PURPOSE OF REVIEW BY THE NATIONAL ACADEMY OF
SCIENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1-3
1.2 ORGANIZATION OF RESPONSE AND RECOMMENDATIONS FOR
REVISION DOCUMENT 1-4
1.3 STATUS OF AGENCY REGULATORY EFFORTS 1-6
1.3.1 Production Uses and Sources of Perchlorate Contamination 1-7
1.3.2 Emerging Occurrence Surveys and Exposure Evaluation 1-8
1.3.3 Analytical Methods Development . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1-12
1.3.4 TreatmeniTechnologies 1-15
1.4 INTERIM GUIDANCE AND REGULATORY AGENDA 1-18
1.4.1 U.S. Environmental Protection Agency Regulatory Plans 1-18
1.4.2 StateRegulatory Plans . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1-21
1.5 SUMMAl{"'{ 1-22
2. HAZARD CHARACTERIZATION AND MODE-OF-ACTION 2-1
2.1 COMMENTS ON THE INTERACTION OF PERCHLORATE WITH THE
SODIUM (Na+)-IODIDE (1") SYMPORTER (NIS) 2-2
2.1.1 Perchlorate Translocation into Thyroid Cells 2-3
2.1.2 Metabolism 2-8
2.1.3 NIS in Other Tissues 2-8
2.1.4 NIS Inhibition and Upregulation 2-10
2.1.5 Toxicodynamics 2-10
2.1.6 Other Comments 2-12
2.2 COMMENTS ON CONCEPTUAL MODEL 2-13
2.3 COMMENTS ON THE CARCINOGENIC POTENTIAL OF
PERCHLORATE AND IMPLICATIONS FOR PROCEDURES OF
LOW-DOSE EXTRAPOLATION 2-14
2.3.1 Use of Nonlinear Low-Dose Extrapolation 2-14
2.3.1.1 New Section 5.1.3 (Summary and Cancer Hazard
Assessment) 2-16
2.3.2 Selection'of Area-Under-the-Curve in Blood (AUCB) as tlie

Dose Metric :. '. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-17
2.4 COMMENTS ON HARMONIZED APPROACH 2-17
iii
Table of Contents
(cont'd)
3. HUMAN HEALTH EFFECTS DATA , 3-1
3.1 STATUS OF EPA POLICY ON THE USE OF THIRD-PARTY HUMAN
DATA 3-1
3.2 COMMENTS ON THE EPA SUMMARY OF THE ECOLOGICAL

EPIDEMIOLOGICAL DATA 3-4
--3.2.1 Revised EPA Analysis of Crump et al. (2000) 3-9
3.2.1.1 New Section 4.1.1.3.1.1: Concerns Regarding Thyroid
Disease Status in the Study Population 3-10
3.2.1.2 New Section 4.1.1.3.1.2: Concerns Regarding Adequacy
of Exposure Characterization 3-14
3.2.1.3 New Section 4.1.1.3.1.3: Concerns Regarding the
Comparability ofPersonal Demographic and General
Health / Nutritional Characteristics ',' 3-17
3.2.1.4 New Section 4.1.1.3.1.4: Concerns Regarding the Sample
Size and Variability of Serum Hormone Analyses 3-19
3.2.1.5 New Section 4.1.1.3.1.5: EPA Conclusions Regarding
Reanalysis of Crump et al. (2000) 3-21
3.3 COMMENTS"ON THE EPA REVIEW OF THE HUMAN DOSING
ANDCLTNICALDATA 3-23
3.3.1 New Section 4.2.1.3: Revised EPA Analysis ofthe Greer et al.
(2000, 2002) Study 3-26
3.3.1.1 New Section 4.2.1.3.1: Greer et al. (2002) Study Design. 3-27
3.3.1.2 New Section 4.2.1.3.1.1: Greer et al. (2002) Statistical
Analyses and Results 3-29
3.3.1.3 New Section 4.2.1.3.2: Revised EPA Analysis ofRAIU
Data 3-32
3.3.1.4 New Secti<?n 4.2.1.3.3: EPA Analysis of Serum Hormone
Data 3-48
3.3.1.5 New Section 4.2.1.3.4: EPA Conclusions Regarding
Analysis of Greer et al. (2002) Study 3-50
3.4 DISCUSSION" OF EXPOSURE MEASURES AND BOUNDING ON

/",,
DOSE-RESPONSE ESTIMATES 3-52
3.5 CONSISTENCY OF ASSOCIATIONS WITH MODE OF ACTION
AND CONTROL FOR CONFOUNDING : 3-54
3.6 ADDITIONAL COMMENTS AND EPA RECOMMENDATIONS 3-54
APPENDIX 3A: Summary of Human Population Studies ::.:. 3A-l
iv
Table of Contents
(cont'd)
4. TOXICOLOGICAL EFFECTS IN LABORATORY ANIMAL STUDIES 4-1
4.1 COMMENTS ON DEVELOPMENTAL TOXICITY 4-2
4.1.1 Review of Developmental Studies Prior to the 1999 Peer Review 4-3
4.1.1.1 Recommended New Summary "Section 5.4.1.1
Conclusions Regarding Historical Data Available
on Developmental Toxicity" 4-3
4.1.2 Regarding the Study of Developmental Toxicity in New Zealand
White Rabbits (Argus Research Laboratories, Inc., 1998a) 4-4
4.1.3 Regarding the Segment II Developmental Study in Rats (Argus
Research Laboratories, Inc., 2000) 4-4
4.2 COMMENTS ON REPRODUCTIVE TOXICITY 4-5
4.2.1 On Reproductive Endpoints , 4-6
4.2.2 Concerns Regarding Tissue Fixation and Spenn Evaluation 4-7
4.3 COMMENTS ON ENDOCRINE AND NEUROENDOCRINE
TOXICITY .. : 4-9
4.3.1 On Concordance Among Honnonal Endpoints and Sources
of Inconsistency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-10
4.3.2 On tbe Shape of the Observed Dose-Response 4-12
4.3.3 "On Statistical Analyses of Thyroid Honnone Levels 4-13
4.4 COMMENTS ON THYROID HISTOPATHOLOGY INCLUDING
CANCER : 4-14
4.4.1 General Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-14
4.4.1.1 Diet Used in Argus (2001) Study 4-14
4.4.1.2 Are Colloid Depletion, Hypertrophy, and
Hyperplasia Adverse Effects? 4-15
4.4.1.3 Diagnoses ofThyroid Adenomas 4-18
4.4.1.4 Rodents as Models for Neoplastic Outcomes in
Humans 4-19
4.4.2 Specific Comments on Bayesian Statistics Used for Tumor
Analyses 4-20
4.4.2..1 Comments on the Software US<;.d to Implement
the Analysis 4-21
4.4.2.2 Rationale for Bayesian Analyses 4-21
4.4.2.3 On the Extrapolation of Cancer Incidence Across
Age 4-22
4.5 COMMENTS ON NEUROTOXICITY 4-22
4.5.1 Comments on Studies of Changes in Brain Morphometty 4-23
4.5.1.1 Methodological Concerns Regarding the "Effects
Study" (Argus Research Laboratories, Inc., 2001) 4-26
4.5.1.2 New Section 5.3.3.4 (Additional Study and Analyses
of Brain Morphometry) 4-31
4.5.1.3 Comments on Shape of the Dose-Response 4-39
v
Table of Contents
(cont'd)
4.5.1.4 Comments on Consistency Across Studies 4-43
4.5.1.5 General Comments and Conclusions 4-45
4.5.1.6 Are Changes in Brain Morphometry Adverse? 4-46
4.5.1.7 Additional General Comments and Conclusions 4-47
4.5.2 Comments on Motor Activity Studies 4-48
4.6 CONCLUSIONS REGARDING THE NEUROTOXICOLOGICAL
EFFECTS OF DEVELOPMENTAL EXPOSURES TO PERCHLORATE ... 4-49
4.6.1 New Section 5.3.4.1: Perchlorate Treatment Reduces Circulating
Levels of Thyroid Hormones 4-50
4.6.2 New Section 5.3.4.2: Hypothyroxinemia Alters Neural
Development 4-51
4.6.3 New Section 5.3.4.3: Laboratory Animal Models of Brain
Development and Neurotoxicity 4-52
4.6.4 New Section 5.3.4.4: Perchlorate Treatment Alters the Size
of Structures in the Developing Brain 4-55
4.6.5 New Section 5.3.4.5: Perchlorate Treatment Alters Behavior
of Offspring 4-56
4.6.6 New Section 5.3.4.6: Conclusions Regarding the Developmental
-Neurotoxicity of Perchlorate Based on Current Principles .4-58
4.7 COMMENTS ON IMMUNOTOXICITY 4-59
4.7.1 On Keil et al. (1999) : 4-59
4.7.2 On BRT-Burleson Research Technologies (2000a,b,c) and the
Local Lymph Node Assay 4-61
4.7.3 On EPA's Overall Interpretation ofImmunotoxicity 4-63
APPENDIX 4A: Summary Tables and Figures of Thyroid Histopathology

Across Laboratory Animal Studies (as Provided in
2002 ERD) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 4A-l
APPENDIX 4B: Summary Table of Effects on Serum Hormones

Across Laboratory Animal Studies (as Provided in
2002 ERD) ¥
; 4B-l
5. ECOLOGICAL RISK ASSESSMENT AND EVIDENCE FOR INDIRECT

EXPOSURE 5-1
. 5.1 REVIEW OF RELEVANT STUDIES 5-1
5.2 ADEQUACY OF ASSAYS TO DETERMINE ECOLOGICAL EFFECTS
OF CONCERN :: 5-3
5.3 GOALS AND OBJECTIVES OF ECOLOGICAL ASSESSMENT 5-5
5.4 COMMENTS ON ANALYSES, CONCLUSIONS, AND
CHARACTERIZATION OF UNCERTAINTY IN THE ECOLOGICAL
RISK ASSESSMENT 5-6
vi
Table of Contents
(cont'd)
5.5 REVIEW OF AVAILABLE DATA TO CHARACTERIZE
ENVIRONMENTAL TRANSPORT AND TRANSFORMATION 5-8
5.6 REVIEW OF AVAILABLE DATA TO CHARACTERIZE SOURCES
OF INDIRECT EXPOSURES 5-9
5.7 ADDITIONAL PUBLIC COMMENTS 5-10
5.8 MAJOR TEXT REVISIONS TO THE ECOLOGICAL ASSESSMENT
(CHAPTER 8) 5-12
5.8.1 Changes to Section 8.1.2 Scope, Complexity, and Focus 5-12
5.8.1.1 Changes to New Section 8.1.2.2 5-13
5.8.1.6 New Data in New Section 8.1.2 5-14
5.8.2 Changes to Section 8.2: Problem Formulation 5-15
5.8.2.1 New Section 8.2.1.4: Population Productivity of
Herbivorous or Detritivorous Aquatic Organisms
.;. or Wildlife 5-15
5.8.3 ""Changes to Section 8.3.1.2: Aquatic Bioaccumulation 5-16
5.8.4 Changes to Section 8.3.1.4 Uptake by Vegetation, 5-17
5.8.5 Revised Section 8.3.2 Characterization of Effects 5-18
5.8.5.1 Changes to Section 8.3.2: Characterization of
Effects 5-18
5.9 MAJOR TEXT REVISIONS TO THE EVALUATION OF EVIDENCE
FOR INDIRECT EXPOSURES (CHAPTER 9) 5-34
5.9.1 Changes to Section 9.2.3: Extrapolating to Food Plants 5-34
5.9.2 Changes to Section 9.3: Summary 5-39
6. USE OF PBPK MODELING 6-1
6.1 COMMENTS ON MODEL STRUCTURES 6-2
6.2 COMMENTS 9N REPRESENTATION OF IODI~f UPTAKE INTO
THYROID CELLS 6-3
6.3 COMMENTS ON REPRESENTATION OF PERCHLORATE UPTAKE
INTO THYROID CELLS ' 6-4
'6.4 COMMENTS ON MODEL PARAMETERIZATION 6-5
6.5 COMMENTS ON MODEL APPLICATIONS 6-6
6.5.1 Comments on EPA's Choice of Dose Metric for Interspecies

Extrapolation ~ ,..................... 6-6
6.5.2 Comments on EPA's Parallelogram Extrapolation of Life Stages .... 6-8
VII
Table of Contents
(cont'd)
7. HUMAN HEALTH DOSE-RESPONSE ASSESSMENT 7-1
7.1 CONCLUSIONS AND CONDITIONS REGARDING KEY EVENT,
WEIGHT OF THE EVIDENCE, AND CHOICE OF POINT OF
DEPARTURE ' 7-2
7.1.1 Consistency Between Observed Effects and Mode of Action 7-2
7.1.1.1 Lack of Phannacodynamic Modeling , 7-3
7.1.1.2 Dose-Associated with Iodide Uptake Inhibition 7-4
7.1.1.3 Inconsistencies of Findings on Thyroid Hormone
Levels 7-6
7.1.1.4 Recommended Revisions· to Section 7.1.1 (Key Events
and Weight ofthe Evidence) 7-7
7.1.2 Comments on the Data Used to Designate the Point of
Departure 7-15
7.1.2.1 Summary of the 2002 Peer Panel Comment on the

, Use of Different Data to Designate the Point of
Departure 7-17
7.1.2.2 EPA Recommended Revisions to Section 7.1.3
_ .:. (Point-of-Departure Analysis) 7-28
7.2 USE OF PBPK MODELS FOR INTERSPECIES EXTRAPOLATION
AND CHOICE OF DOSE METRIC 7-41
7.2.1 Revisions to Section 7.1.2 (Dosimetric Adjustment of Exposures
Associated with Effect Levels) 7-43
7.2.1.1 Revisions to Section 7.1.2.1 (Choice of dose metric) 7-43
7.2.1.2 Revisions to Section 7.1.2.2 (Choice of Representative
Life Stage) 7-46
7.3 CONSIDERATIONS FOR APPLICATIONS OF UNCERTAINTY
FACTORS 7-46
7.3.1 Comments on Intrahuman Variability 7-47
7.3.2 Comments on Interspecies Extrapolation 7-48
7.3.3 Comments on LOAEL to NOAEL Extrapolation 7-49
7.3.4 SUbcbronic
, to Chronic Duration ~
7-50
7.3.5 Comments on Database Insufficiency 7-52
7.3.6 General Comments on Uncertainty Factors 7-53
7.3.7 Recommendations for Revised UF and New Section 7.1.4
(Application of Uncertainty Factors) 7-54
7.4 FACTORS INFLUENCING SUSCEPTIBLITY 7-58
7.5 RECOMMENDATIONS FOR REVISION TO SECTION 7.1.5.:
(OPERATIONAL DERIVATION OF HARMONIZED RFD) 7-59
7.5.1 Revision to Section 7.1.5.1 (Comparison with Derivation
Considering Human Data) 7-61
viii
Table of Contents
(cont'd)
7.5.2 Revisions to Section 7.1.5.2 (Comparison with
Derivation Based on Tumor Data 7-63
7.5.2.1 Revisions to Section 7.1.5.2.1 (Choice of Dose-
Response Procedure) , 7-63
7.5.2.2 Revisions to Section 7.1.5.2.2 (Dose-response
Assessment for Thyroid Neoplasia) 7-65
7.6 ADDITIONAL RESPONSES AND RECOMMENDATIONS , 7-66
7.6.1 Revisions to Section 7.1.6 (Designation of Confidence Levels) 7-66
7.6.2 New Section 7.2 (Cancer Hazard Characterization) 7-66
7.6.3 Revisions to Section 7.2 (Inhalation Reference Concentration) 7-68
Appendix 7A: Summary Tables of Human Equivalent Exposure (HEE)

Estimates as Calculated with PBPK Models 7A-l
Appendix 7B: Tables Showing Minimum Database Requirements and
Uncertainty Factors Applied for Derivation of an Oral Reference
Dose (RID) 7B-l
8. MAJOR RISK CHARACTERIZATION CONCLUSIONS , 8-1
8.1 COMME'NTSONHUMANHEALTHRISKCHARACTERIZATION 8-1
8.1.1 Revisions to Section 10.1.2 (Dose Response) 8-2
8.1.2 Revisions to Section 10.1.4 (Major Uncertainties and Research
Needs) ", , .. ', 8-4
8,2 COMMENTS ON ECOLOGICAL RISK CHARACTERIZATION 8-6
8.2.1 Specific Comments on Ecological Risk Characterization 8-6
8.2.2 Revisions to Major Risk Characterization Conclusions in Section

10.2 (Ecotoxicology) ...................................•... 8-7
8.2.2.1 Revisions to Section 10.2.1 (Aquatic Life) 8-8
8.2.2.2 Revisions to Section 10.2.2 (Risks to Consumers of
Aquatic Life) , 8-9
8.2.2.3 Revisions to Section 10.2.3 (Terrestrial Life) ., 8-10
8.2.2:~ Revisions to Section 10.2.4 (Uncertainties) , 8-12
8.2.2.5 Revisions to Section 10.2.5 (~search Needs) 8- 15
8.3 REVISIONS TO SECTION 10.3 (CHARACTERIZATION PROGRESS
SUMMARY) , , 8-18
9, REFERENCES , 9-1
ix
List of Tables
Number Page
2-1 Comparison of Equations to Represent Various Types of Inhibition by Perchlorate at

the NIS 2-7
3-1 New Table 4-2. Coefficients of Variation' (%) For School Chi\dren Samples
in Each City from Crump et al. (2000) 3-13
3-2 New-Table 4-3. Coefficients of Variation (%) for TSH in Neonatal and School
Children Samples in Each City of Crump et al. (2000) 3-15
3-3 New Table 4-7. Descriptive Statistics Provided by Greer et al. (2002) for the
Inhibition of Radioactive Iodide Uptake (RAIU) at Various Sample Times and
Different Days ofExposure 3-30
3-4 New Table 4-8. Estimates ofBMD and BMDL at BMR = 0.05 Absolute Risk
for All Four Sample Sets on Thyroid Radioactive Iodide Uptake in Greer et al.
(2000,2002) and Merrill (2001a) 3-35
3-5 New Table 4-9. Estimates ofBMD and BMDL at BMR = 0.05 Extra Risk for
All Four SampJe Sets on Thyroid Iodide Uptake in Greer et al. (2000, 2002)
and Merrill (2001a) 3-35
3-6 New Table 4-10. Suspected Outliers in the Four Sample Sets on Thyroid Iodide
Uptake in Greer et al. (2000, 2002) and Merrill (2001a) 3-38
3-7 New Table 4-11. Goodness-of-Fit P values (Test 3) for the Hill Model with
Sample Sets 8B14 and 24B14 and a Test ofthe Equality of the Variances
Among the Four Dose Groups (Test 2) 3-38
3-8 New Table 4-12. Comparison ofAIC in Four Different Models for RAIU
Inhibition by Perchlorate 3-43
3-9 New Table 4-13. aMOS Estimates of Parameters k, Po,,,,Y; and n for All
Four Sample Sets on Thyroid Iodide Uptake in Greer et al. (2000, 2002) and
Merrill (2001a) 3-45
3-10 New Table 4-14. Nonlinear Regression Estimates of Parameters Po, PI' P2 in
the Exponential Model for All Four Sample Sets on Thyroid Iodide Uptake
in Greer et al. (2000,2002) and ~errill (2001a) --.:: 3-46
3A-l Table 4A-5 now Table 4-15. Summary of Human Population Studies
(Park,2001) 3A-2
x
List of Tables
(cont'd)
Number Page
4-1 New Table 5-7. Qualitative Consistency of Effects of Perchlorate on Thyroid

and Pituitary Serum Hormones 4-11
4-2 New Table 5-4. Coefficients of Variation' (%) for PND22 Male Rats in
Different Brain Regions 4-30
4-3 New Table 5-5. Results of Univariate Analyses of Variance on Data from
Cerebellum and Striatum (Consultants in Veterinary Pathology, Inc., 2003;
Geller, 2003) 4-39
4-4 New Table 5-6. Comparison of Results of EPA Analyses of Brain

Morphometry Data From Two Studies Submitted by Argus Research
Laboratories, Inc. (1998a, 2001) 4-44
4A-l Table 5-1. Benchmark Dose (BMD) and Benchmark Dose Lower
Confidence Limit (BMDL) Estimates Calculated From the Wolf (2000,
2001) Thyroid Histopathology Data (Geller, 2001a) 4A-2
.;,
4A-2 Table 5-3. Benchmark Dose (BMD)8 and Benchmark Dose Lower
Confidence Limit (BMDL)8 Estimates From Thyroid Histopathology in
the "Effects Study" (Argus Laboratories, Inc., 2001; Geller, 2001 b) 4A-4
4B-l Table 5-2. A Comparison ofNOAELs and LOAELs from the Original
1998 Analysis and the 2001 Re-Analyses for Hormone and Morphometry
on Thyroid Follicular Lumen Size (Crofton and Marcus, 2001; Marcus,
2001; Crofton, 2001a) 4B-2
4B-2 Table 5-4. NOAELs and LOAELs for Effects on Thyroid and Pituitary
Hormones from the Argus 2001 "Effects Study" (Crofton, 2001b) 4B-5
5-1 New Table 8-1. Re~ults of Perchlorate Toxicity Tests in~Aquatic and
Terrestrial Species 5-21
5-2 New Table 8-2. Procedure for Deriving Acute and Chronic Aquatic
Benchmark Values' for Perchlorate 5-24
5-3 New Table: 8-3. Ranking of Genus Mean Acute Values (GMAVS) fur
Perchlorate ~ 5-25
5-4 New Table 8-4. Calculation of Species Mean Acute Chronic Ratios for
Species with Acute and Chronic Values Species Are Ranked Based
on Their Chronic Values 5-25
xi
List of Tables
(cont'd)
Number Page
7-1 New Table 7-4. Studies Associated with Effect Levels in Figure 7-2 (New
Figure 7-5 in Revised Assessment) Used to Designate the Point of Departure ..... 7-31
7-2 Table 7-8 in Revised Document. Default Dose-response Procedures for

Thyroid Carcinogens (U.S. Environmental Protection Agency, 1998a) 7-63
7-3 Table 7-9 in Revised Document. Data Demonstrating Antithyroid Activity

U.S. Environmental Protection Agency (I 998a) 7-64
7A-I PBPK-Model Calculated Human Equivalent Exposures (HEE) to Various

Experimental Doses in the Male Rat for 15 and 70 kg Human-Based on
Perchlorate Area Under the Curve (AUC) in Serum or Thyroid as the Dose
Metric (Merrill, 200!e) 7A-2
7A-2 Ratio ofPBPK-Derived Perchlorate Area Under the Curve (AUC) Serum
Concentrations in Drinking Water for Various Experimental Life Stages
(Merrill,2001e) . :'
4··
" 7A-2
7A-3 PBPK-Model Calculated Human Equivalent Exposures (HEE) to Various

Experimental Life Stages in the Rat Using Serum Perchlorate Area Under
the Curve (AUC) as the Dose Metric . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 7A-3

Experimental Doses in the Adult Male Rat for 15 and 70 kg Human Based
on % Iodide Uptake Inhibition in the Thyroid " 7A-3
7A-5 PBPK-Model Predicted % Inhibition oflodide Uptake in the Thyroid. . . . . . . . .. 7A-4
7A-6 Ratios ofPBPK-Derived % Iodide Uptake Inhibition in Drinking Water for

Various Experiment,al Life Stages ~.' 7A-4

Experimental Life Stages in the Rate Using % Iodide Uptake Inhibition in
the Thyroid as the Dose Metric 7A-5
7B-l Minimum Database for Deriviation of an Oral Reference Dose :: 7B-2
7B-2 Factors for Uncertainties in Applied Extrapolations Used to Derive

Reference Doses 7B-2
xii

CREW: Department of Defense: Department of The Air Force: Regarding Perchlorate: Scanned Perchlorate October 2008 JJ

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Requestor/Requestor/Entered havirlCi open IEmeNd h.vlng jEntertd having lEnterect having enter8d having IHo......

Yes IYes Yes Yes

No No No No Until now, had not Iealized

USA OldTown ME USA CONUS +

No No Ve. Arizona Dept of Environmental

USA Oetrol IMI USA ICONUS+

3431 5I2112001IUSAF v CERCLA Mar1elta IGA 300691uSA CONUS +

406 7f1212OO11uSN ,v BRAe Novato IeI'> 94947IUSA CONUS +

175 1112012000IUSAF NNV NPL DoverAAFB IDE 19902IUSA CONUS +

Ves No Yes Yes ,No

No No No No Not required by the

247 1111712000IuSAF NNV RCRA; ANGB IDuluth MN SS8111uSA

137 111312000IUSAF v 'Fonner TAe b.... IDuluth MN SS8011USA

No No No Minnesota PoUutton Control

No No No No OUR OBIOO Sile has

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an ETA to CA on the answers.

-----Original Message----- ,-/ J

From: Brausch, Rick [mailto

Sent: Monday, November 17~3 7:18 PM ­

Moss (E-mail)';' - . ---:;:-'Schuparra, Kurt; Spagnole, Jim

Subject: PromISed-Information ,---J

Kurt and Sandy ­

(also attached for your convenience).

--ir Steven B o o L ~r additional information.

Active and BRAC FUD Sites*'" Perchlorate Sites with

** Data source: USEPA, 6/2003

*** Data source: SWRCB, 2003

DoD Sites ONE MILE FROM MUNICIPAL SUPPLY WELL

DoD Sites FIVE MILES FROM MUNICIPAL SUPPLY WELL

San Nicolas Island Naval Reservation

Manufacturers ONE MILE FROM MUNICIPAL SUPPLY WELL

Manufacturers FIVE MILES FROM MUNICIPAL SUPPLY WELL

Hi-Shear Technology Corp.

Whittaker Bermite Division.

FUOs FIVE MILES FROM MUNICIPAL SUPPLY WELL

SPADRA GENERAL HOSPITAL

MC SUPPLY FORWARDING ANNEX

SALVAGE SEGREGATION CENTER

MCAS SANTA ANA

JOSHUA HENDY IRON WORKS

FUOs ONE MILE FROM MUNICIPAL SUPPLY WELL

WEST COAST AIR TRAINING CENTER

JOSHUA HENDY IRON WORKS

Camp Roberts 3 81612003 10/612003 Source area evaluation report NONE

Presidio of Monterey 3 9/312003 1012812003 Source area evaluation report NONE

San Nicolas Island (incl. With PI. Mugu NAWS) 4

DoD Siles with RB Llfs

Riverbank AAP 5 6111/2003 913012003 Souroe Area Evaluation Report NONE

Sacramento Army Depot

EI Toro MCAS 6 611212003 913012003 Source Area Evaluation Report NONE

DoD Siles witll RB Llrs 2

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- _-- ..-... . -. . . . . . ., an.. .,.••

" .. _w-.. -,,-... -.ungancUor

Sent: Monday, November 17~3 7:18 PM

Kurt and Sandy

> -----Original Message----