Perchlorate%20Issues%20at%20the%20Massachusetts%20Military%20Reservation%20(MMR)%20and%20the%20Aberdeen%20Proving%20Ground%20(APG) - PowerPoint PPT Presentation

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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)

Perchlorate Issues at the Massachusetts Military
Reservation (MMR) and the Aberdeen Proving Ground
  • 9th Annual Joint Services Environmental
    Management Conference
  • August 2004
  • Malcolm Garg
  • Army Environmental Programs
  • Office of the Director of Environmental Programs
  • (703) 601-1513,

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
  • DoD facilities have struggled with how to
    react when to sample and what then

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
  • In 1997 USEPA begins issuing a series of
    Administrative Orders (AOs) under the Safe
    Drinking Water Act (SDWA) to protect sole source
  • 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
  • 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

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
  • MADEP is currently supplying bottled water to the

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
  • Remediation occurring in conjunction with other
  • 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

Aberdeen Proving Ground (APG)
  • APG is located next to the Chesapeake Bay in
  • 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
  • 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

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
  • 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

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

Similarities and Differences
  • Similarities
  • Very informed and active community groups
  • Strong political, regulatory and media pressure
  • Both facilities are dealing with low action
  • 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

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
  • 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