1. Perchlorate Issues at the Massachusetts Military Reservation (MMR) and the Aberdeen Proving Ground (APG)
9th Annual Joint Services Environmental Management Conference
August 2004
Malcolm Garg
Army Environmental Programs
Office of the Director of Environmental Programs
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2. Short Perchlorate Regulatory History
Perchlorate is an unregulated Contaminant and has no drinking water maximum contaminant limit (MCL)
In 1997 the USEPA provided interim MCL guidance of 4-18 ppb
In January 2002 EPA drafted a perchlorate health-based risk assessment that equated to a Draft MCL of 1 ppb
Currently the National Academy of Sciences is reviewing the science and will recommend actions to the EPA.
The USEPA interim guidance is still 4-18 ppb
Many states and some EPA regions have imposed their own standards using various legal authorities.
DoD facilities have struggled with ‘how to react’; when to sample and ‘what then’

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

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

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

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

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

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

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

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