Transcript Document

Perchlorate Issues at MMR and APG
Perchlorate Issues at the
Massachusetts Military Reservation
(MMR) and the Aberdeen Proving
Ground (APG)
9th Annual Joint Services Environmental Management Conference
August 2004
Malcolm Garg
Army Environmental Programs
Office of the Director of Environmental Programs
(703) 601-1513, [email protected]
Malcolm Garg / DAIM-EDT / (703) 601-15135 / [email protected]
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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 418 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’
Malcolm Garg / DAIM-EDT / (703) 601-15135 / [email protected]
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Massachusetts Military Reservation (MMR)
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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
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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.
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In 2002 Massachusetts Department of Environment (MADEP) recommends
a 1 ppb perchlorate in drinking water guideline for sensitive populations.
Malcolm Garg / DAIM-EDT / (703) 601-15135 / [email protected]
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Off-Post Detections
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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
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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
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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.
Malcolm Garg / DAIM-EDT / (703) 601-15135 / [email protected]
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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
Malcolm Garg / DAIM-EDT / (703) 601-15135 / [email protected]
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Aberdeen Proving Ground (APG)
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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.
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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.
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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
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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
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Subsequent sampling finds detections in 3 other wells (approx. 1 ppb)
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
Malcolm Garg / DAIM-EDT / (703) 601-15135 / [email protected]
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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
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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
Malcolm Garg / DAIM-EDT / (703) 601-15135 / [email protected]
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Similarities and Differences
• Similarities
– 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
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Policy Issues… and Lessons Learned?
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DoD policy
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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
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No policy to address remedial actions
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Both installations meet the first requirement
With MMR it is also a legal requirement
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
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Be prepared to address legal regulatory issues.
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Must be willing to take a stand and withstand political pressure
Identify future ‘emergent’ contaminants.
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Unregulated ‘emergent’ contaminant work group has been initiated by OSD
Identify potential candidates
Develop environmental and toxicological profiles in advance and fund efforts
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Collaborate with regulators armed with substantial knowledge early in the process
Malcolm Garg / DAIM-EDT / (703) 601-15135 / [email protected]
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