Perchlorate%20Issues%20at%20the%20Massachusetts%20Military%20Reservation%20(MMR)%20and%20the%20Aberdeen%20Proving%20Ground%20(APG) - PowerPoint PPT Presentation
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Perchlorate%20Issues%20at%20the%20Massachusetts%20Military%20Reservation%20(MMR)%20and%20the%20Aberdeen%20Proving%20Ground%20(APG)
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Frequent testing shows levels between non-detect to 0.5 ppb ... Local fireworks are suspected ... Source is not always clear, especially at low levels fireworks? ... – PowerPoint PPT presentation
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Title: Perchlorate%20Issues%20at%20the%20Massachusetts%20Military%20Reservation%20(MMR)%20and%20the%20Aberdeen%20Proving%20Ground%20(APG)
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
- (703) 601-1513, malcom.garg_at_hqda.army.mil
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 gt 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 lt 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 Citys 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 (RD) 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
- 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. - APGs main issue is in a limited area, however,
perchlorate is impacting the entire communitys
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 gt 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
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