Perchlorate: A System to Track Sampling and Cleanup Results Is
Needed (20-MAY-05, GAO-05-462).
Perchlorate, a primary ingredient in propellant, has been used
for decades in the manufacture and firing of rockets and
missiles. Other uses include fireworks, flares, and explosives.
Perchlorate has been found in drinking water, groundwater,
surface water, and soil in the United States. The National
Academy of Sciences (NAS) reviewed studies of perchlorate's
health effects and reported in January 2005 that certain levels
of exposure may not adversely affect healthy adults but
recommended more studies be conducted on the effects of
perchlorate exposure in children and pregnant women. GAO
determined (1) the estimated extent of perchlorate in the United
States, (2) what actions have been taken to address perchlorate,
and (3) what studies of perchlorate's health risks have reported.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-05-462
ACCNO: A24517
TITLE: Perchlorate: A System to Track Sampling and Cleanup
Results Is Needed
DATE: 05/20/2005
SUBJECT: Environmental law
Environmental monitoring
Environmental policies
Environmental research
Federal regulations
Federal/state relations
Hazardous substances
Health hazards
Potable water
Standards and standardization
Water pollution
Water pollution control
Standards (water quality)
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GAO-05-462
United States Government Accountability Office
GAO Report to the Chairman, Subcommittee on Environment and Hazardous Materials,
Committee on Energy and Commerce, House of Representatives
May 2005
PERCHLORATE
A System to Track Sampling and Cleanup Results Is Needed
a
GAO-05-462
May 2005
PERCHLORATE
A System to Track Sampling and Cleanup Results Is Needed
[IMG]
What GAO Found
Perchlorate contamination has been found in water and soil at almost 400
sites in the United States where concentration levels ranged from a
minimum reporting level of 4 parts per billion to millions of parts per
billion. More than one-half of all sites were in California and Texas, and
sites in Arkansas, California, Texas, Nevada, and Utah had some of the
highest concentration levels. Yet, most sites had lower levels of
contamination; roughly two-thirds of sites had concentration levels at or
below the Environmental Protection Agency's (EPA) provisional cleanup
standard of 18 parts per billion. Federal and state agencies are not
required to routinely report perchlorate findings to EPA, and EPA does not
centrally track or monitor perchlorate detections or the status of
cleanup. As a result, a greater number of contaminated sites than we
reported may already exist.
Although there is no specific federal requirement to clean up perchlorate,
EPA and state agencies have used broad authorities under various
environmental laws and regulations, as well as state laws and action
levels, to sample and clean up and/or require the sampling and cleanup of
perchlorate by responsible parties. Further, under certain federal and
state environmental laws, private industry may be required to sample for
contaminants, such as perchlorate. According to EPA and state officials,
private industry and public water suppliers have generally complied with
regulations requiring sampling and agency requests to sample. The
Department of Defense (DOD) has sampled and cleaned up perchlorate in some
locations when required by laws and regulations, but the department has
been reluctant to sample on or near active installations under other
circumstances. Except where there is a specific legal requirement, DOD's
perchlorate sampling policy requires the services to sample only under
certain conditions. Cleanup is planned or under way at 51 of the almost
400 perchlorate-contaminated sites identified to date.
Since 1998, EPA and DOD have sponsored a number of perchlorate health risk
studies using varying study methodologies. We reviewed 90 of these studies
that generally examined whether and how perchlorate affected the thyroid.
About one-quarter concluded that perchlorate had an adverse effect. In
January 2005, NAS reported on the potential health effects of perchlorate
and concluded that a total exposure level from all sources, higher than
that initially recommended by EPA (a dose equivalent to 1 part per billion
in drinking water, assuming that all exposure came from drinking water)
may not adversely affect a healthy adult. On the basis of NAS' report, EPA
revised its reference dose to a level that is equivalent to 24.5 parts per
billion in drinking water (if it is assumed that all exposure comes only
from drinking water). The reference dose is not a drinking water standard;
it is a scientific estimate of the total daily exposure level from all
sources that is not expected to cause adverse effects in humans, including
the most sensitive populations.
United States Government Accountability Office
Contents
Letter
Results in Brief
Background
Perchlorate Has Been Found at Almost 400 Sites across the United
States
EPA and State Environmental Agencies Use Federal and State
Environmental Laws and Regulations to Respond to
Perchlorate
DOD and EPA Sponsored Numerous Studies of Perchlorate
Exposure, but Findings about Perchlorate's Health Effects Are
Inconsistent
Conclusions
Recommendation for Executive Action
Agency Comments and Our Evaluation
1 2 6
10
15
21 23 23 24
Appendixes
Appendix I: Objectives, Scope, and Methodology 27
Facilities and Sites Where Perchlorate Was
Appendix II: Found and
Concentration Levels, as of January 2005 29
Appendix III: Perchlorate Health Risk Studies Published 45
Since 1998
Summary of Certain Environmental Laws and 66
Appendix IV: Regulations
The Resource Conservation and Recovery Act 66
Comprehensive Environmental Response,
Compensation, and
Liability Act 66
The Clean Water Act 67
The Federal Facility Compliance Act 68
The Safe Drinking Water Act 68
Appendix V: Comments from the Environmental Protection 70
Agency
Appendix VI: Comments from the Department of Defense 72
Appendix VII: GAO Contacts and Staff Acknowledgments 74
Figures Figure 1: Maximum Perchlorate Concentrations Reported in any
Media and Number of Sites, January 2005 12
Figure 2: Activities Linked to Perchlorate, by Site 13
Contents
Abbreviations
CERCLA Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 DOD Department of Defense EPA Environmental
Protection Agency NAS National Academy of Sciences NASA National
Aeronautics and Space Administration NPDES National Pollution Discharge
Elimination System RCRA Resource Conservation and Recovery Act
This is a work of the U.S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed in
its entirety without further permission from GAO. However, because this
work may contain copyrighted images or other material, permission from the
copyright holder may be necessary if you wish to reproduce this material
separately.
A
United States Government Accountability Office Washington, D.C. 20548
May 20, 2005
The Honorable Paul E. Gillmor
Chairman, Subcommittee on Environment and Hazardous Materials Committee on
Energy and Commerce House of Representatives
Dear Mr. Chairman:
Ammonium perchlorate (perchlorate) is a primary ingredient in solid rocket
propellant and has been used for decades by the Department of Defense
(DOD), the National Aeronautics and Space Administration (NASA), and the
defense industry in the manufacturing, testing, and firing of rockets and
missiles. Private industry has also used perchlorate to manufacture
products such as automobile airbags, fireworks, flares, and commercial
explosives. Perchlorate is a naturally occurring and manufactured salt
that is easily dissolved and transported in water and has been found in
groundwater, surface water, and soil across the country. Perchlorate has
also been found in drinking water and food products, such as milk and
lettuce. Recent health studies have shown that perchlorate can affect the
thyroid gland and may cause developmental delays.
Due to questions and ongoing debate about the risks of exposing children
and pregnant women to low levels of perchlorate, four federal agencies
asked the National Academy of Sciences (NAS) to review and comment on
recent studies of perchlorate and its health effects. In January 2005, NAS
concluded that existing studies did not support a clear link between
perchlorate exposure and adverse health effects. NAS recommended a
perchlorate reference dose-an estimated daily exposure level from all
sources that is not expected to cause adverse effects in humans, including
the most sensitive populations-of 0.0007 milligrams per kilogram of body
weight per day. The dose is equivalent to 2 liters of drinking water per
day containing 24.5 parts per billion of perchlorate when consumed by an
adult weighing 70 kilograms (or 154 pounds), assuming that all perchlorate
exposure comes from drinking water. In February 2005, the Environmental
Protection Agency (EPA) adopted NAS' recommended reference dose for
perchlorate, but it has not established a national federal standard for
perchlorate in drinking water or other regulatory requirements to clean up
perchlorate in groundwater, surface water, or soil.
In this context, we identified (1) the estimated extent of perchlorate
found in the United States; (2) what actions the federal government, state
governments, and responsible parties have taken to clean up or eliminate
the source of perchlorate; and (3) what studies of the potential health
risks from perchlorate have been conducted and, where presented, the
author's conclusions or findings on the health effects of perchlorate.
To provide an estimate of the extent of perchlorate found in the United
States, we compiled and analyzed data on perchlorate detections from EPA,
DOD, the U.S. Geological Survey, and state agencies. To identify the
actions governments and responsible parties have taken to clean up and
eliminate the source of the perchlorate, we (1) reviewed federal and state
laws, regulations, and policies on water quality and environmental cleanup
and (2) interviewed EPA officials and selected state agency officials to
identify the authorities they have used to monitor and respond to
instances of perchlorate. We also interviewed EPA and state agency
officials on whether responsible parties have taken action to clean up
perchlorate and reviewed and analyzed data from federal and state agencies
to determine the status and extent of cleanup efforts. For the purposes of
this report, "cleanup" refers to ongoing efforts to remove perchlorate
from water and/or soil. However, our use of this term excludes pollution
prevention efforts, such as the removal of perchlorate from wastewater. To
identify studies of the potential health risks from perchlorate, who
conducted them, and what methodologies were used, we conducted a
literature search for studies of perchlorate health risks published since
1998, interviewed DOD and EPA officials on what studies they considered
important in assessing perchlorate health risks, and examined the
references of each study for other studies we had not obtained. We
identified 125 studies on perchlorate and the thyroid, of which we
reviewed 90 that were relevant to our review. A more detailed description
of our scope and methodology is presented in appendix I. We conducted our
work from June 2004 to March 2005 in accordance with generally accepted
government auditing standards, including an assessment of data reliability
and internal controls.
Results in Brief Perchlorate has been found by federal and state agencies
at almost 400 sites in groundwater, surface water, soil, or public
drinking water in the United States. However, because there is not a
standardized approach for reporting perchlorate data nationwide, a greater
number of sites than we identified may already exist in the United States.
Perchlorate has been found in 35 states, the District of Columbia, and 2
commonwealths of the United States, where the highest concentrations
ranged from 4 parts per
billion to more than 3.7 million parts per billion. (At some sites,
federal and state agencies detected perchlorate concentrations as low as 1
part per billion or less, yet 4 parts per billion is the minimum reporting
level of the analysis method most often used.) More than one-half of all
sites were found in California and Texas, and sites in Arkansas,
California, Texas, Nevada, and Utah had some of the highest concentration
levels. However, most sites did not have high levels of perchlorate.
Roughly two-thirds of sites had concentration levels at or below 18 parts
per billion, the upper limit of EPA's provisional cleanup guidance, and
almost 70 percent of sites had perchlorate concentrations less than 24.5
parts per billion, the drinking water concentration calculated on the
basis of EPA's recently established reference dose. At more than
one-quarter of the sites, propellant manufacturing, rocket motor testing,
and explosives disposal were the most likely sources of perchlorate.
Public drinking water systems accounted for more than one-third of the
sites where perchlorate was found. EPA sampled more than 3,700 public
drinking water systems and found perchlorate in 153 systems across 26
states and 2 commonwealths of the United States. Perchlorate concentration
levels found at public drinking water systems ranged from 4 to 420 parts
per billion. However, only 14 of the 153 public drinking water systems had
concentration levels above 24.5 parts per billion. EPA and state officials
told us they had not cleaned up these public drinking water systems,
principally because there was no federal drinking water standard or
specific federal requirement to clean up perchlorate. Further, EPA
currently does not centrally track or monitor perchlorate detections or
the status of cleanup activities. In fact, several EPA regional officials
told us they did not always know whether states had found perchlorate, at
what levels, or what actions were taken. As a result, it is difficult to
determine the extent of perchlorate in the United States or the status of
cleanup actions, if any.
Although there is no specific federal requirement to clean up perchlorate
or a specific perchlorate cleanup standard, EPA and state environmental
agencies have investigated, sampled, and cleaned up unregulated
contaminants, such as perchlorate, under various federal environmental
laws and regulations. EPA and state agency officials have used their
authorities under these laws and regulations, as well as under state laws
and action levels, to sample and clean up and/or require the sampling and
cleanup of perchlorate by responsible parties. For example, according to
EPA and state officials, at least 9 states have established nonregulatory
action levels or advisories, ranging from under 1 part per billion to 18
parts per billion, under which responsible parties have been required to
sample and clean up perchlorate. Further, certain environmental laws and
programs require private companies to sample for contaminants, which can
include unregulated substances such as perchlorate, and report to
environmental agencies. According to EPA and state officials, private
industry and public water suppliers have generally complied with
regulations requiring sampling for contaminants and agency requests to
sample or clean up perchlorate. DOD has sampled and cleaned up when
required by specific environmental laws and regulations but has been
reluctant to sample on or near active installations, EPA and state
officials said. Where there is no specific legal requirement to sample at
a particular installation, DOD's policy on perchlorate requires sampling
only where a perchlorate release due to DOD activities is suspected and a
complete human exposure pathway is likely to exist. Finally, EPA, state
agencies, and/or responsible parties are cleaning up or planning cleanup
at 51 of the almost 400 sites where perchlorate was found. The remaining
sites are not being cleaned up for a variety of reasons. The reason most
often cited by EPA and state officials was that they were waiting for a
federal requirement to do so.
We identified and summarized 90 studies of perchlorate health risks
published since 1998. EPA and DOD sponsored the majority of these studies,
which used experimental, field study, and data analysis methodologies. For
26 of the 90 studies, the findings indicated that perchlorate had an
adverse effect. Eighteen of these studies found adverse effects on
development resulting from maternal exposure to perchlorate. Although the
studies we reviewed examined whether and how perchlorate affected the
thyroid, most of the studies of adult populations were unable to determine
whether the thyroid was adversely affected. Adverse effects of perchlorate
on the adult thyroid are difficult to evaluate because they may happen
over longer time periods than can be observed in a research study.
However, adverse effects of perchlorate on development can be studied and
measured within study time frames. We found some studies considered the
same perchlorate dose amount but found different effects. The precise
cause of the differences remains unresolved but may be attributed to an
individual study's design type or physical condition of the subjects, such
as their age. Such unresolved questions are one of the bases for the
differing conclusions among EPA, DOD, and academic studies on perchlorate
dose amounts and effects.
In January 2005, NAS issued its report on the potential health effects of
perchlorate. The NAS report evaluated many of the same health risk studies
included in our review. NAS reported that certain levels of exposure may
not adversely affect healthy adults but recommended that
more studies be conducted on the effects of perchlorate exposure in
children and pregnant women. NAS also recommended a perchlorate reference
dose, which is an estimated daily exposure level from all sources that is
expected not to cause adverse effects in humans, including the most
sensitive populations. The reference dose of 0.0007 milligrams per
kilogram of body weight is equivalent to a drinking water concentration of
24.5 parts per billion, if all exposure comes from drinking water.
To ensure that EPA has more reliable information on the extent of
perchlorate found, the status of cleanup efforts, and the results of
investigations of perchlorate and the effectiveness of cleanup methods, we
are recommending that EPA work with the states and other federal agencies
to establish a formal structure to track and monitor perchlorate
detections and the status of cleanup efforts in the United States and its
territories.
In commenting on a draft of this report, EPA agreed with our findings and
conclusions on the extent of perchlorate in the United States and also
agreed that defense-related activities have been found to be associated
with perchlorate detections. However, EPA did not agree with our
recommendation that it establish a formal structure to centrally track and
monitor perchlorate detections and the status of cleanup efforts across
the federal government and state agencies. In contrast to EPA's view of
our report's accuracy, DOD, in commenting on a draft of this report,
stated that our report did not provide an accurate assessment of
perchlorate issues and activities. DOD asserted that our report
mischaracterized DOD's response to perchlorate and cited examples of where
DOD has sampled and invested in cleanup technologies, even though
perchlorate is currently unregulated. We disagree with DOD's position. Our
report credits DOD with actions it has taken but also points out where DOD
has not acted. Finally, DOD disagreed with our recommendation that EPA
establish a more formal structure to centrally track and monitor
perchlorate because it believes that it is not clear that such a system
will provide added value. DOD stated that it will continue to share its
information on perchlorate. However, in its comments on this report, DOD
provided information on four locations where perchlorate has been found,
in one case as long as 5 years ago, but these locations do not appear on
EPA's list of perchlorate detection sites. Whether this omission occurred
as a result of a DOD or an EPA oversight is unknown, but it underscores
the need for a more structured and formalized system.
Background Perchlorate is a primary ingredient in solid rocket propellant
and has been used for decades by DOD, NASA, and the defense industry in
the manufacturing, testing, and firing of rockets and missiles. On the
basis of 1998 manufacturer data, EPA estimated that 90 percent of the
perchlorate produced in the United States is manufactured for use by the
military and NASA. Total typical production quantities average several
million pounds per year. Private industry has used perchlorate to
manufacture products such as fireworks, flares, automobile airbags, and
commercial explosives. Perchlorate is a salt, both manufactured and
naturally occurring, and is easily dissolved and transported in water. It
has been found in drinking water, groundwater, surface water, and soil
across the country. There is no national primary drinking water regulation
for perchlorate. In 1992 and again in 1995, EPA established a provisional
reference dose range for perchlorate of 0.0001 to 0.0005 milligrams per
kilogram of body weight per day. This converts to a drinking water
concentration of between 4 and 18 parts per billion. On the basis of the
drinking water conversion, EPA identified a corresponding provisional
cleanup level for perchlorate of between 4 and 18 parts per billion.1
History of Perchlorate Investigation and Study
Perchlorate was initially identified as a contaminant of concern by EPA in
1985, when it was found in wells at hazardous waste sites in California.
Perchlorate became a chemical of regulatory concern in 1997 after
California found perchlorate in the groundwater near Aerojet, a rocket
manufacturer in Rancho Cordova. At the time, perchlorate could not
reliably be detected below 400 parts per billion in water. In April 1997,
a new analytical method capable of detecting perchlorate in drinking water
at concentrations of 4 parts per billion became available. This
development prompted several states to test drinking water, as well as
groundwater and surface water, for perchlorate. Within 2 years,
perchlorate had been detected in drinking water in 3 western states and
groundwater and surface water in 11 states across the United States.
Perchlorate in drinking water is considered a more immediate concern.
In light of emerging concerns about perchlorate, EPA published in 1998 its
first draft risk assessment on the environmental risks of perchlorate
1Although EPA recently adopted a perchlorate reference dose of 24.5 parts
per billion, EPA's provisional cleanup level for perchlorate remains
between 4 and 18 parts per billion and has not been revised.
exposure. In February 1999, an external panel of independent scientists
reviewed EPA's draft risk assessment and recommended additional studies
and analyses to provide more data on perchlorate and its health effects.
DOD and industry researchers conducted laboratory and field studies of the
health effects of perchlorate and submitted them to EPA. On the basis of
an analysis of these studies, EPA revised its draft perchlorate risk
assessment and released it for peer review and public comment in January
2002. The revised draft risk assessment included a proposed reference dose
equivalent to a concentration of 1 part per billion in drinking water,2 if
it is assumed all exposure comes only from drinking water. After a second
panel peer review, and some disagreement about the proposed reference
dose, EPA, DOD, NASA, and the Department of Energy asked NAS, in 2003, to
review EPA's perchlorate risk assessment and key studies of the health
effects of perchlorate. These and other recent health studies have shown
that the consumption of perchlorate affects the human thyroid by
decreasing the amount of iodine absorbed. Iodine deficiency can result in
developmental delays if it occurs during pregnancy and early infancy and
can result in hypothyroidism3 if it occurs during adulthood. The purpose
of the NAS study was, in part, to assess the extent to which studies have
shown negative health effects from perchlorate.
In January 2005, NAS reported that existing studies did not support a
clear link between perchlorate exposure and developmental effects, and NAS
recommended additional research on perchlorate exposure and its effect on
children and pregnant women. NAS also recommended a safe exposure level,
or reference dose, for perchlorate of 0.0007 milligrams per kilogram of
body weight per day. (For comparison, EPA's draft reference dose for
perchlorate in its 2002 draft risk assessment, which equated to a drinking
water concentration of 1 part per billion, was based on a daily dose of
0.00003 milligrams per kilogram of body weight per day.) According to NAS,
the reference dose is conservative and includes safeguards to protect the
most sensitive population, the fetus of the nearly iodine-deficient
pregnant woman. In February 2005, EPA established a new reference dose for
perchlorate on the basis of the NAS recommendation. The new reference dose
is equivalent to 24.5 parts per billion in drinking water,
2Previously, in 1995, on the basis of a 1952 human pharmaceutical study,
EPA established a provisional reference dose for perchlorate in drinking
water that equated to a drinking water concentration of between 4 and 18
parts per billion.
3Hypothyroidism is a condition in which the thyroid gland fails to produce
enough thyroid hormone, causing a variety of symptoms-such as mental and
physical sluggishness.
assuming that an adult weighing 70 kilograms (or 154 pounds) consumes 2
liters of drinking water per day, and that all perchlorate ingested comes
from drinking water. If EPA establishes a drinking water standard for
perchlorate, however, it may be less than 24.5 parts per billion because
humans may consume perchlorate from other sources, such as produce and
milk.
In addition to studies of perchlorate and health effects, other federal
agencies, research groups, and universities have conducted or are
conducting studies of perchlorate found in food and the environment. For
example, the U.S. Geological Survey collected soil samples from California
and New Mexico to test for the presence of perchlorate in natural minerals
and materials. In 2003, an environmental research group reported that it
sampled lettuce purchased in northern California and found perchlorate
above 30 parts per billion in 4 of 22 samples. In September 2003,
researchers from Texas Tech University sampled 8 bottles of milk and 1 can
of evaporated milk and found perchlorate concentrations up to 6 parts per
billion in seven of the milk samples and more than 1 part per billion in
the evaporated milk sample. In 2004, the Food and Drug Administration
sampled the following items for perchlorate: lettuce, bottled water, milk,
tomatoes, carrots, cantaloupe, and spinach. Produce samples were taken
from areas where officials said they believed irrigation water contained
perchlorate. These data are currently being evaluated, but preliminary
results show perchlorate was found in some samples.
Method 314.0 is the EPA-approved method for analyzing perchlorate in
drinking water under the Safe Drinking Water Act. Method 314.0 can detect
perchlorate concentrations of 1 part per billion in finished (treated)
drinking water but has a minimum reporting limit of 4 parts per billion.
Both EPA and DOD officials have expressed concerns about using Method
314.0 to test for perchlorate in media other than drinking water, such as
groundwater, surface water, and soil (where researchers mix soil with a
liquid to extract the sample). According to EPA, sediment and dissolved
ions commonly found in groundwater and surface water can yield false
positive results if the method is not used properly. Analysis methods
other than Method 314.0 are available, and EPA has approved their use to
analyze specific sites for perchlorate. Further, two new methods have been
developed for the analysis of perchlorate in drinking water, and another
is expected to be available in the spring of 2005. These three methods
have minimum reporting limits ranging from 0.02 to 0.1 parts per billion.
However, Method 314.0 has been the principal method used to test and
report on the presence of perchlorate in all media, including soil,
sediment, groundwater, and surface water.
Various treatment technologies to remove perchlorate from groundwater and
surface water are in use or under review. Biological treatment and ion
exchange systems are among the technologies currently in use. Biological
treatment uses microbes to destroy perchlorate by converting the
perchlorate ion to nontoxic ions, oxygen, and chloride. Ion exchange
systems replace the perchlorate ion with chloride, which is an ion found
in table salt.
Environmental Laws, Regulations, and Federal Policy Covering Hazardous
Substances
Several federal environmental laws provide EPA, and states authorized by
EPA, with broad authorities to respond to actual or threatened releases of
substances that may endanger public health or the environment. For
example, the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), as amended, authorizes EPA to investigate
the release of any hazardous substance, pollutant, or contaminant. The
Resource Conservation and Recovery Act of 1976 (RCRA) gives EPA authority
to order a cleanup of hazardous waste when there is an imminent and
substantial endangerment to public health or the environment, and one
federal court has ruled that perchlorate is a hazardous waste under RCRA.
The Clean Water Act's National Pollutant Discharge Elimination System
(NPDES) provisions authorize EPA, which may, in turn, authorize states, to
regulate the discharge of pollutants into waters of the United States.
These pollutants may include contaminants such as perchlorate. The Safe
Drinking Water Act authorizes EPA to respond to actual or threatened
releases of contaminants into public water systems or underground sources
of drinking water, regardless of whether the contaminant is regulated or
unregulated, where there is an imminent and substantial endangerment to
health and the appropriate state and local governments have not taken
appropriate actions. Under certain environmental laws such as RCRA, EPA
can authorize states to implement the requirements as long as the state
programs are at least equivalent to the federal program and provide for
adequate enforcement. A detailed summary of these and other laws and
regulations is presented in appendix IV.
In addition, some states have their own environmental and water quality
laws that provide state and local agencies with the authority to monitor,
sample, and require cleanup of various hazardous substances, both
regulated and unregulated, that pose an imminent and substantial danger to
public health. For example, the California Water Code authorizes Regional
Water Control Boards to require sampling of waste discharges and to direct
cleanup and abatement, if necessary, of any threat to water, which may
include the release of a contaminant such as perchlorate.
DOD's September 2003 interim policy on perchlorate sampling states that
the military services shall sample for perchlorate where service officials
suspect the presence of perchlorate on the basis of prior or current DOD
activities, and where a complete human exposure pathway is likely to
exist. The policy also states that the services shall sample for
perchlorate (1) as required by the Safe Drinking Water Act's Unregulated
Contaminant Monitoring Regulation4 and the Clean Water Act's NPDES program
and (2) as part of cleanup conducted under DOD's Environmental Restoration
Program. While DOD's policy requires it to sample where the two conditions
of release and exposure are met, it does not specify whether the services
may sample for perchlorate when requested by state agencies or EPA, apart
from requirements under environmental laws and regulations. Further,
except for at a few sites,5 DOD has not independently directed the
services to clean up perchlorate. We previously reported that DOD has
cleaned up perchlorate when directed to do so by EPA or a state
environmental agency under various environmental laws, or when perchlorate
is found on closed ranges.6
Perchlorate Has Been Found at Almost 400 Sites across the United States
Various federal and state agencies have reported finding perchlorate at
almost 400 sites in 35 states, the District of Columbia, and 2
commonwealths of the United States in drinking water, surface water,
groundwater, and soil. Perchlorate was found at a variety of sites
including public water systems, private wells, military installations,
commercial manufacturers, and residential areas. The concentration levels
reported ranged from 4 parts per billion to more than 3.7 million parts
per billion in groundwater at 1 site, yet roughly two-thirds of sites had
concentration
4Sampling for perchlorate was required under this regulation between 2001
and 2003 (see app. IV).
5Edwards Air Force Base, California, is cleaning up perchlorate. According
to DOD, the cleanup is independent from, and not in response to, a
requirement from a regulatory agency or environmental law.
6GAO, DOD Operational Ranges: More Reliable Cleanup Cost Estimates and a
Proactive Approach to Identifying Contamination Are Needed, GAO-04-601
(Washington, D.C.: May 28, 2004).
levels at or below 18 parts per billion, the upper limit of EPA's
provisional cleanup guidance for perchlorate. Federal and state agencies
are not required to routinely report perchlorate findings to EPA, and EPA
does not currently have a formal process to centrally track or monitor
perchlorate detections or the status of a cleanup. As a result, a greater
number of sites may exist in the United States than is presented in this
report.
The Majority of Perchlorate Was Found in California and Texas
Through discussions with federal and state environmental agency officials
and a review of perchlorate sampling reports, we identified 395 sites in
the United States and its commonwealths where perchlorate was found in
drinking water, groundwater, surface water, sediment, or soil. A table of
reported perchlorate detections in the United States and its commonwealths
as of January 2005 is presented in appendix II.
Most of the sites and the highest levels of perchlorate were found in a
small number of states. More than one-half of all sites, or 224, was found
in Texas and California, where both states have conducted broad
investigations to determine the extent of perchlorate. The highest
perchlorate concentrations were found in 5 states-Arkansas, California,
Nevada, Texas, and Utah-where 11 sites had concentrations exceeding
500,000 parts per billion. However, the majority of the 395 sites had
lower levels of perchlorate. We found 249 sites where the highest
concentration was equal to or less than 18 parts per billion, the upper
limit of EPA's provisional cleanup level, and 271 sites where the highest
concentration was less than 24.5 parts per billion, the drinking water
concentration equivalent calculated on the basis of EPA's newly
established reference dose (see fig. 1).
According to EPA and state agency officials, perchlorate found at 110 of
the sites was due to activities related to defense and aerospace, such as
propellant manufacturing, rocket motor research and test firing, or
explosives disposal. At 58 sites, officials said the source of the
perchlorate found was manufacturing and handling, agriculture, and a
variety of commercial activities such as fireworks and flare manufacturing
(see fig. 2).
Figure 2: Activities Linked to Perchlorate, by Site
4%
Agriculture (6 sites)
Other (includes fireworks and flare manufacturing and disposal, general
manufacturing, and hazardous waste) (16 sites)
Perchlorate manufacturing and handling (36 sites)
DOD, NASA, and defense-related industries (includes propellant
manufacturing, rocket motor testing, and explosives testing and disposal)
(110 sites)
Sources: Environmental Protection Agency, Department of Defense, U.S.
Geological Survey, and state environmental agencies.
At the remaining 227 sites, EPA and state agency officials said the source
of the perchlorate found was either undetermined or naturally occurring.
Further, all 105 sites with naturally occurring perchlorate are located in
the Texas high plains region where perchlorate concentrations range from 4
to 59 parts per billion.
Perchlorate Was Found in 4 As of January 2005, and as required for a
12-month period between 2001 Percent of Sampled Public and 2003 under the
Safe Drinking Water Act's Unregulated Contaminant Drinking Water Systems
Monitoring Regulation, 3,722 public drinking water systems had sampled
drinking water and reported the results to EPA. Of these public drinking
water systems, 153, or about 4 percent, reported finding perchlorate.
Located across 26 states and 2 commonwealths, these 153 sites accounted
for more than one-third of the sites we identified, where perchlorate
concentrations reported ranged from 4 parts per billion to 420 parts per
billion and averaged less than 10 parts per billion. Only 14 of the 153
public drinking water systems had concentration levels above 24.5 parts
per billion, the drinking water equivalent calculated on the basis of
EPA's revised perchlorate reference dose. California had the most public
water systems with perchlorate, where 58 systems reported finding
perchlorate in drinking water. The highest drinking water perchlorate
concentration of 420 parts per billion was found in Puerto Rico in 2002.
Subsequent sampling in Puerto Rico did not find any perchlorate, and
officials said the source of the initial finding was undetermined.
Because of the proximity of these 153 public water systems to populated
areas, an EPA official estimated that about 10 million people may have
been exposed to perchlorate through their drinking water. EPA officials
told us that they do not know the source of most of the perchlorate found
in public water systems, but that perchlorate found in 32 water systems in
Arizona, California, and Nevada was likely due to previous perchlorate
manufacturing in Nevada. Regional EPA and state officials told us they did
not plan to clean up perchlorate found at public drinking water sites
pending a decision to establish a drinking water standard for perchlorate.
In some cases, officials did not plan to clean up because subsequent
sampling was unable to confirm that perchlorate was present.
Extent of Perchlorate and Cleanup Efforts Is Difficult to Determine Because
Federal and State Agencies Are Not Generally Required to Share with EPA
Information on Perchlorate Sampling or Cleanup
EPA officials said the agency does not centrally track or monitor
perchlorate detections, or the status of cleanup activities, other than
under the Safe Drinking Water Act where EPA collected data from public
water systems for 1 year. As a result, it is difficult to determine the
extent of perchlorate in the United States. EPA maintains a listing of
sites known to EPA where cleanup or other response actions are under way,
but the list does not include all sites because some sites have not been
reported to EPA. As a result, EPA officials said they did not always know
whether other federal and state agencies found perchlorate because, as is
generally the case with unregulated contaminants, there is no requirement
for states or other federal agencies to routinely report perchlorate
findings to EPA. For example, except as required under specific
environmental programs, DOD is not required to report to EPA when
perchlorate is found on active installations and facilities. Consequently,
EPA region officials in California said they did not know that the
Department of the Navy found perchlorate
at the Naval Air Weapons Station at China Lake. Further, even where EPA
has authorized states to implement the RCRA program, states are not
required to routinely notify EPA about perchlorate found under the
program. For example, EPA region officials in California said the Nevada
state agency did not tell them perchlorate was found at Rocketdyne, an
aerospace facility in Reno, or that it was being cleaned up. EPA only
learned about the perchlorate finding when the facility's RCRA permit was
renewed.
We also found that communication and data sharing between EPA and state
agency officials varied. Because states are not required to routinely
notify EPA about perchlorate, some EPA region officials told us they
contacted state agencies to ask whether new sites had been found. Some EPA
region and state officials told us they participated in monthly or
quarterly meetings to discuss perchlorate, and most EPA and state
officials told us they had good working relationships and shared
information about perchlorate. Yet a few EPA region officials told us they
did not always know whether states found perchlorate, at what levels, or
what actions were taken. For example, an EPA region official told us he
did not know what actions were taken at three RCRA sites in Utah where
perchlorate was found.
EPA and State Environmental Agencies Use Federal and State Environmental Laws
and Regulations to Respond to Perchlorate
Although there is no federal standard for perchlorate in drinking water or
a federal cleanup standard, EPA and state environmental agencies
authorized by EPA have investigated suspected sites; collected samples and
analyzed for perchlorate; and, when perchlorate is found, cleaned up or
limited perchlorate releases under broad authorities found in various
federal environmental laws and regulations. Further, both EPA and
authorized states have required responsible parties to sample and clean up
perchlorate under other state laws. Most responsible parties sampled and
cleaned up when required by regulation or directed by EPA or states. DOD
sampled and cleaned up on the basis of its interpretation of federal and
state legal requirements and its own policy. Of the 395 sites where
perchlorate has been found, EPA or state environmental officials told us
cleanup is under way or planned at 51 of them.
Various Environmental Laws, Regulations, and Provisional Standards Are Used
by Federal and Some State Agencies to Sample and Clean Up Perchlorate
We found EPA and state environmental agencies have investigated, sampled,
and cleaned up perchlorate, or have required sampling and cleanup,
pursuant to general authorities contained in various federal and state
environmental laws and regulations. According to EPA and state agency
officials, state agencies have also established levels for sampling and
cleanup, and some state environmental laws provide that other authorities
are to respond to contaminant releases, including perchlorate.
Both EPA and state environmental agencies have used federal environmental
laws, such as CERCLA, RCRA, and the NPDES provisions of the Clean Water
Act, as authority to respond to releases of substances that may endanger
public health or the environment, including perchlorate. EPA and the
states have used such authority to sample and clean up as well as require
the sampling and cleanup of perchlorate. For example:
o As part of a CERCLA review, EPA sampled groundwater near former
government-owned grain storage facilities in Iowa and found perchlorate in
residential and commercial drinking water wells at three sites. During
subsequent sampling, EPA did not find perchlorate at two of the sites but
confirmed perchlorate at the third site. EPA is providing bottled drinking
water to certain persons until an uncontaminated drinking water supply
becomes available.
o During sampling required as part of a RCRA permit, ATK Thiokol, a Utah
explosives and rocket fuel manufacturer, found perchlorate. Under
authority provided by RCRA, Utah required the manufacturer to install a
monitoring well to determine the extent of perchlorate and take steps to
prevent additional perchlorate releases.
o Under the NPDES program, Texas required the Navy to reduce perchlorate
levels in wastewater discharges at the McGregor Naval Weapons Industrial
Reserve Plant to 4 parts per billion, the lowest level at which
perchlorate could be detected.
According to EPA and state officials, EPA and state environmental agencies
have investigated and sampled groundwater and surface water areas for
perchlorate, or requested that responsible parties or others do so,
pursuant to agency oversight responsibilities to protect water quality and
human health. For example:
o EPA plans to sample five waste disposal sites in Niagara Falls, New
York, to determine whether the groundwater contains perchlorate from
manufacturing that took place in the area between 1908 and 1975.
o EPA asked Patrick Air Force Base and the Cape Canaveral Air Force
Station, Florida, to sample groundwater for perchlorate near rocket launch
sites. Previously, both installations inventoried areas where perchlorate
was suspected and conducted limited sampling. DOD officials did not find
perchlorate at Patrick Air Force Base, and, according to an EPA official,
the Department of the Air Force said it would not conduct additional
sampling at either installation until there is a federal standard for
perchlorate.
o Between 1998 and 2002, Utah sampled public drinking water systems
considered at risk for the presence of perchlorate because of nearby
perchlorate use and found perchlorate concentrations at more than 42 parts
per billion in three wells at two sites.
o Texas contracted with Texas Tech University to sample drinking water
wells for perchlorate in 54 counties after perchlorate was found in five
public water systems in the high plains region of the state. The
university study found perchlorate in some drinking water wells and
concluded that the most likely source was natural occurrence.
When perchlorate was found, according to state and EPA officials, state
agencies have taken steps to minimize human exposure or perform cleanup,
or required responsible parties to do so, pursuant to the same general
authorities contained in federal environmental laws and regulations. For
example:
o Nevada is requiring Pepcon, a former perchlorate manufacturing site, to
install a cleanup system to remove perchlorate from groundwater.
o Massachusetts closed a public well and provided bottled drinking water
to students at a nearby school when perchlorate was found in a city public
water system.
o At the request of California, United Technologies, a large rocket
testing facility in Santa Clara County, stopped releasing perchlorate and
cleaned up perchlorate found in the groundwater.
Without a federal standard for perchlorate, according to EPA and state
officials, at least nine states have established nonregulatory action
levels or advisories for perchlorate ranging from under 1 part per billion
to 18 parts per billion. States that have sampled, or required responsible
parties to sample, report, and clean up, have used these advisories as the
levels at which action must be taken. For example:
o Oregon initiates in-depth site studies to determine the cause and
extent of perchlorate when concentrations of 18 parts per billion or
greater are found.
o Nevada required the Kerr-McGee Chemical site in Henderson to treat
groundwater and reduce perchlorate concentration releases to 18 parts per
billion, which is Nevada's action level for perchlorate.
o According to Utah officials, Utah does not have a written action level
for perchlorate, but, if perchlorate concentrations exceed 18 parts per
billion, the state may require the responsible party to clean up.
Finally, in addition to state laws enacted to allow states to assume
responsibility for enforcing federal environmental laws, other state
environmental laws provide authority to respond to contaminant releases,
including perchlorate. For example, EPA and state officials told us that
both California and Nevada state agencies have required cleanup at some
sites under state water quality laws.
Parties Responsible for Perchlorate Findings Generally Have Complied with
Regulations Requiring Sampling and Cleanup
According to EPA and state officials, private industry and public water
suppliers have generally complied with regulations requiring sampling,
such as those under (1) the RCRA and NPDES permit programs, where
responsible parties have been required to sample and report hazardous
releases to state environmental agencies, or (2) the Safe Drinking Water
Act's Unregulated Contaminant Monitoring Regulation, which required
sampling for unregulated contaminants, such as perchlorate, between 2001
and 2003. Further, according to EPA and state officials, private industry
has generally responded by reducing perchlorate and cleaning up when
required by regulation or directed by EPA or state agencies.
DOD's Policy Requires Sampling for Perchlorate under Certain Conditions
DOD's perchlorate sampling policy requires the military services to sample
where the particular installation must do so, under laws or regulations
such as the Clean Water Act's NPDES permit program, or where a reasonable
basis exists to suspect that a perchlorate release has occurred as a
result of DOD activities and that a complete human exposure pathway is
likely to exist. However, DOD's policy on perchlorate sampling does not
address cleanup. We found DOD has sampled for perchlorate on closed
installations when requested by EPA or a state agency and cleaned up on
active and closed installations when required by a specific environmental
law, regulation, or program, such as the environmental restoration program
at formerly used defense sites. For example, at EPA's request, the U.S.
Army Corps of Engineers (Corps) installed monitoring wells and is sampling
for perchlorate at Camp Bonneville, a closed installation near Vancouver,
Washington. Utah state officials told us DOD is removing soil containing
perchlorate at the former Wendover Air Force Base in Utah, where the Corps
found perchlorate in 2004.
According to EPA and state officials, DOD has been reluctant to (1) sample
on or near active installations because there is no specific federal
regulatory standard for perchlorate or (2) sample where DOD determined the
criteria to sample were not met as outlined in its policy. Except where
there is a legal requirement to sample at a particular installation, DOD's
perchlorate policy does not require sampling unless the two conditions of
release and exposure are met. Utah state officials told us the agency
asked the Department of the Army to sample for perchlorate at two active
installations, Dugway Proving Grounds and Deseret Chemical Depot.
Previously, in 1998, the Army reported that perchlorate had been used at
Dugway for more than 20 years. According to state agency officials, the
Army said there was not a clear potential for human exposure to
perchlorate at these sites, and it would not sample unless a higher Army
level approved the sampling. In February 2005, Utah officials told us
Dugway Proving Grounds had not requested permission from Army headquarters
to sample, and they did not know whether Deseret requested permission to
sample.
In fiscal years 2004 and 2005, several provisions to federal law were
enacted that encourage DOD to conduct health studies and evaluate
perchlorate found at military sites. For example, the Ronald W. Reagan
National Defense Authorization Act for Fiscal Year 2005 states that the
Secretary of Defense should develop a plan for cleaning up perchlorate
resulting from DOD activities, when the perchlorate poses a health hazard,
and continue evaluating identified sites.7 In October 2004, DOD and
California agreed to a procedure for prioritizing perchlorate sampling at
DOD facilities in California. The procedure includes steps to identify and
prioritize the investigation of areas on active installations and military
sites (1) where the presence of perchlorate is likely based on previous
and current defense-related activities and (2) near drinking water sources
where perchlorate was found. Although DOD has been urged by Congress to
evaluate sites where the presence of perchlorate is suspected, DOD's
September 2003 perchlorate policy continues to require sampling on active
installations only where there is a suspected release due to DOD
activities and a likely human exposure pathway, or where required under
specific laws, such as the Clean Water Act.
EPA and States Are Cleaning Up, Requiring Cleanup, or Taking Action to Clean
Up 51 Sites Where Perchlorate Was Found
EPA, state agencies, and responsible parties are cleaning or planning to
clean up at 51 of the 395 sites we identified. At 23 sites, EPA, states,
and responsible parties are cleaning up or working to reduce perchlorate
releases. For example, EPA required several defense, petroleum, and other
companies to clean up perchlorate in Baldwin Park, California, a CERCLA
site. The cleanup involves extracting and treating up to 26 million
gallons of water per day, after which the water is distributed to several
nearby communities. Texas required Longhorn Army Ammunition Plant, a
closed DOD facility, to clean up by limiting perchlorate releases to a
daily average concentration of 4 parts per billion (and a maximum of 13
parts per billion per day) under the NPDES program. Kerr-McGee Chemical, a
former perchlorate manufacturer in Nevada, is cleaning up using an ion
exchange system. According to officials, Nevada required the facility to
clean up perchlorate under a state water law after perchlorate
concentrations up to 3.7 million parts per billion were found in the
groundwater.
At 28 sites, EPA and state agency officials told us that federal and state
governments and private parties are evaluating the extent of perchlorate
and potential cleanup methodologies. Unidynamics, an Arizona propellant
manufacturer located at a CERCLA site, responded to EPA's concern about
perchlorate at the site and is investigating perchlorate treatment
methods. According to officials, after Kansas asked Slurry Explosives to
clean up perchlorate under a state environmental law, the manufacturer
began investigating a biological method to clean up.
7Pub. L. No. 108-375, S: 318, 118 Stat. 1811, 1845 (2004).
The remaining 344 sites are not being cleaned up for a variety of reasons.
The reason most often cited by EPA and state officials was that they were
waiting for a federal requirement to do so. In some instances, officials
said they would not clean up sites where perchlorate was naturally
occurring or where subsequent sampling was unable to find perchlorate.
DOD and EPA Sponsored Numerous Studies of Perchlorate Exposure, but Findings
about Perchlorate's Health Effects Are Inconsistent
Since 1998, EPA and DOD have sponsored a number of studies of the health
risks of perchlorate using experimental, field study, and data analysis
methods. We reviewed 90 of these studies and found that 44 offered
conclusions or observations on whether perchlorate had a health effect. Of
these, 26 studies found that perchlorate had an adverse effect. However,
in some of these studies, it was unknown whether the observed adverse
effects would be reversible over time. In January 2005, NAS issued its
report on EPA's draft health assessment and the potential health effects
of perchlorate. The NAS report considered many of the same health risk
studies that we reviewed and concluded that an exposure level higher than
initially recommended by EPA may not adversely affect a healthy adult, but
recommended more study of the effects of perchlorate on pregnant women and
children.
Study Findings Differed on the Health Effects of Perchlorate Exposure
DOD, industry, and EPA sponsored the majority of the 90 health studies we
reviewed; the remaining studies were conducted by academic researchers and
other federal agencies. Of these 90 studies, 49 used an experimental
design methodology to determine the effects of perchlorate on humans,
mammals, fish, and/or amphibians by exposing these groups to differing
dose amounts of perchlorate over varied periods of time and comparing the
results with other groups that were not exposed. Twelve were field studies
that compared humans, mammals, fish, and/or amphibians in areas known to
be contaminated with the same groups in areas known to be uncontaminated.
Both methodologies have limitations; that is, the experimental studies
were generally short in duration, and the field studies were generally
limited by the researchers' inability to control whether, how much, or how
long the population in the contaminated areas was exposed. Finally, 29
studies used a data analysis methodology where researchers reviewed
several publicly available human and animal studies and used data derived
from these studies to determine the process by which perchlorate affects
the human thyroid and the highest exposure levels that did not adversely
affect humans. The 3 remaining studies used another or
unknown methodology.8 Appendix III provides data on these studies,
including who sponsored them; what methodologies were used; and, where
presented, the author's conclusions or findings on the effects of
perchlorate.
Many of the studies we reviewed contained only research findings, not
conclusions or observations, on the health effects of perchlorate. Only 44
studies had conclusions on whether perchlorate had an adverse effect. Of
these, 29 studies evaluated the effect of perchlorate on development, and
18 found adverse effects resulting from maternal exposure to perchlorate.
Adverse effects of perchlorate on the adult thyroid are difficult to
evaluate because they may happen over longer time periods than can be
observed in a research study. However, the adverse effects of perchlorate
on development can be more easily studied and measured within study time
frames. Moreover, we found different studies used the same perchlorate
dose amount but observed different effects. The different effects were
attributed to variables such as the study design type or age of the
subjects, but the precise cause of the difference is unresolved. Such
unresolved questions are one of the bases for the differing conclusions in
EPA, DOD, and academic studies on perchlorate dose amounts and effects.
According to EPA officials, the most sensitive population for perchlorate
exposure is the fetus of a pregnant woman who is also nearly
iodine-deficient. However, none of the 90 studies we reviewed considered
this population. Some studies reviewed pregnant rat populations and the
effect on the thyroid, but we did not find any studies that considered
perchlorate's effect on nearly iodine-deficient pregnant populations and
the thyroid.
The National Academy of Sciences Reported That Evidence Was Insufficient to
Show Perchlorate Causes Adverse Effects
In January 2005, NAS issued its report on EPA's draft health assessment
and the potential health effects of perchlorate. NAS reported that
although perchlorate affects thyroid functioning, there was not enough
evidence to show that perchlorate causes adverse effects at the levels
found in most environmental samples. Most of the studies NAS reviewed were
field studies, the report said, which are limited because they cannot
control whether, how much, or how long a population in a contaminated area
is exposed. NAS concluded that the studies did not support a clear link
between perchlorate exposure and changes in the thyroid function in
newborns and hypothyroidism or thyroid cancer in adults. In its report,
8The number of study types is greater than the total number of studies
because 3 studies used a combination of experimental design and data
analysis methodologies.
NAS noted that only 1 study examined the relationship between perchlorate
exposure and adverse effects on children, and that no studies investigated
the relationship between perchlorate exposure and adverse effects on
vulnerable groups, such as low-birth-weight infants. NAS concluded that an
exposure level higher than initially recommended by EPA may not adversely
affect a healthy adult. The report did not recommend a drinking water
standard; however, it did recommend that additional research be conducted
on perchlorate exposure and its effect on children and pregnant women.
Conclusions Perchlorate has been found in the groundwater, surface water,
drinking water, or soil in 35 states, the District of Columbia, and 2
commonwealths of the United States where concentrations reported ranged
from 4 parts per billion to millions of parts per billion. According to
EPA and state environmental agency officials, a leading known cause of the
perchlorate found was defense-related activities. In addition, EPA and
state officials attributed the cause of the perchlorate found at more than
one-half of sites to natural occurrence or undetermined sources. State and
other federal agencies do not always report perchlorate detections to EPA,
however, because EPA, other federal agencies, and the states do not have a
standardized approach for reporting perchlorate data nationwide. As a
result, a greater number of sites with perchlorate may already exist.
Further, EPA does not track the status of cleanup at sites where
perchlorate has been found. Without a formal system to track and monitor
perchlorate findings and cleanup activities, EPA and the states do not
have the most current and complete accounting of perchlorate as an
emerging contaminant of concern, including the extent of perchlorate found
and the extent or effectiveness of cleanup projects.
Recommendation for Executive Action
In order to ensure that EPA has reliable information on perchlorate and
the status of cleanup efforts, and to better coordinate lessons learned
between federal agencies and states on investigating and cleaning up
perchlorate, we recommend that, in coordination with states and other
federal agencies, EPA use existing authorities or seek additional
authority, if necessary, to establish a formal structure to centrally
track and monitor perchlorate detections and the status of cleanup efforts
across the federal government and state agencies.
Agency Comments and Our Evaluation
In its April 26, 2005, letter (see app. V), EPA agreed with our findings
and conclusions on the extent of perchlorate in the United States and that
defense-related activities have been found to be associated with
perchlorate detections. However, EPA did not agree with our recommendation
that it establish a formal structure to centrally track and monitor
perchlorate detections and the status of cleanup efforts across the
federal government and state agencies. In its letter, EPA stated that it
already had significant information and data on perchlorate concentrations
in various environmental media, where much of the information was provided
by other federal and state agencies as well as private parties. EPA also
asserted that the development and maintenance of a new tracking system
would require additional resources or the redirection of resources from
other activities. To justify a tracking system, EPA would have to analyze
its associated costs and benefits.
As our report explains, however, state and other federal agencies do not
always report perchlorate detections to EPA. Further, without a formal
system to track and monitor perchlorate findings and cleanup activities,
EPA does not have the most current and complete accounting of perchlorate
as an emerging contaminant of concern. To underscore our point, in
commenting on a draft of this report, DOD provided a listing of four sites
where it found perchlorate between 2000 and 2004. These sites were not in
EPA's database. (We added these sites to our listing in app. II.) With
regard to the cost benefit aspect of EPA's comments, we believe that EPA
is misconstruing the extent of work necessary to implement a more
formalized and structured system to track perchlorate. We are not
proposing an elaborate new system but, instead, believe that EPA needs to
work toward a more structured process than what is currently in place to
track and monitor perchlorate routinely. Currently, EPA's regions are
spending time and effort contacting their counterparts in other federal
agencies and states on an ad hoc basis to obtain more current information
about perchlorate. However, this is being done without any structure or
consistency related to how and when contacts are made, how frequently they
are made, or what specific information is collected. As a result, we found
that EPA does not have complete, current, or accurate information to track
the occurrence of perchlorate-the type of information that would be needed
when making a determination about the need for regulation. We continue to
believe that such information is necessary and that it can be obtained
without an elaborate or costly undertaking.
In contrast to EPA's view of our report's accuracy, DOD said in its April
26, 2005, letter (see app. VI), that our report did not provide an
accurate assessment of perchlorate issues and activities. DOD asserted
that our report mischaracterized DOD's response to perchlorate and cited
examples of where DOD has sampled and invested in cleanup technologies,
even though perchlorate is currently unregulated. We disagree with DOD's
position. Our report credits DOD with actions it has taken but also points
out where DOD has not acted. For example, our report acknowledges that DOD
is sampling for perchlorate as required under various environmental laws,
or when certain criteria exist as specified in DOD's sampling policy; that
is, where the presence of perchlorate is suspected based on prior or
current DOD activities and a complete exposure pathway to humans is likely
to exist. While DOD states that it has a policy that establishes an
affirmative obligation to sample and not a limitation, that view is not
shared by some regulators. As we point out in our report, there have been
a number of instances where EPA or state agencies asked the services to
sample but service officials declined because they did not believe the
conditions met with DOD's sampling policy. As such, DOD has used its
policy to limit testing for perchlorate that environmental regulators
believed was necessary.
With regard to DOD's point that perchlorate is unregulated, we are well
aware that many other contaminants, like perchlorate, are not specifically
regulated, yet are being addressed and cleaned up as hazards under various
environmental laws.
DOD also stated that we did not accurately summarize the findings of the
NAS study and other scientific and technical data. We believe our report
accurately summarizes key information from both NAS as well as 90 other
studies of the potential health risks of perchlorate, as specified by the
requester of this report.
Finally, DOD disagreed with our recommendation that EPA establish a more
formal structure to centrally track and monitor perchlorate because it was
not clear that such a system will provide added value. DOD stated that it
will continue to share its information on perchlorate. As previously
noted, in commenting on this report, DOD provided information on four
locations where perchlorate has been found, in one case as long as 5 years
ago, and which do not appear on EPA's list of perchlorate detection sites.
Whether this omission occurred as a result of a DOD or an EPA oversight is
unknown, but it underscores the need for a more structured and formalized
system.
Both EPA and DOD provided technical comments as enclosures to their
letters, which we incorporated in our report as appropriate.
As agreed with your office, unless you publicly announce the contents of
this report earlier, we plan no further distribution until 30 days from
the report date. At that time, we will send copies of this report to the
appropriate congressional committees; the Administrator, Environmental
Protection Agency; the Secretary of Defense; and other interested parties.
We will also provide copies to others upon request. In addition, the
report will be available, at no charge, on the GAO Web site at
http://www.gao.gov.
If you or your staff have any questions, please call me or Edward Zadjura
at (202) 512-3841. Contributors to this report are listed in appendix VII.
Sincerely yours,
John B. Stephenson Director, Natural Resources
and Environment
Appendix I
Objectives, Scope, and Methodology
We identified (1) the estimated extent of perchlorate nationwide; (2) what
actions the federal government, state governments, and responsible parties
have taken to clean up or eliminate the source of perchlorate found; and
(3) what studies of the potential health risks from perchlorate have been
conducted and, where presented, the author's conclusions or findings on
the health effects of perchlorate.
To provide an estimate of the extent of perchlorate in the United States,
we compiled and analyzed data on perchlorate detections from the
Environmental Protection Agency (EPA), the Department of Defense (DOD),
the U.S. Geological Survey, and state agencies. For each site, our review
shows the highest perchlorate concentration reported for all media sampled
as of January 2005, although officials may have sampled the site more than
once, in varying locations and media, and found differing levels of
perchlorate. We also interviewed officials from EPA headquarters and
regional offices, DOD, and selected state agencies to determine the
accuracy and completeness of our compiled list of perchlorate detections.
To identify what actions the government and private sector have taken to
address perchlorate and the extent to which responsible parties have taken
action to clean up and eliminate the source of perchlorate, we reviewed
federal and state laws, regulations, and policies on water quality and
environmental cleanup and interviewed EPA and state agency officials on
their roles, responsibilities, and authorities to monitor and respond to
instances of perchlorate found. We interviewed officials from EPA
headquarters and each of its 10 regions. We also interviewed officials
from state environmental agencies in California, Oregon, Texas, and Utah.
We selected these states because they (1) had higher estimated numbers of
sites where perchlorate was found and higher perchlorate concentration
levels and/or (2) had taken steps to investigate and respond to
perchlorate. During interviews with state agency officials, we discussed
whether parties responsible for perchlorate had taken action to clean up
and whether federal or local governments required that they stop
activities causing the release of perchlorate. Finally, we reviewed and
analyzed data from federal and state agencies to determine the status and
extent of cleanup efforts.
To identify studies of the potential health risks from perchlorate, we
conducted a literature search for studies of perchlorate health risks
published since 1998. We also interviewed DOD and EPA officials to obtain
a list of the studies they considered important in assessing perchlorate
health risks. We examined the references for each study so that we could
include any other key studies that we had not obtained through the
Appendix I
Objectives, Scope, and Methodology
literature search and DOD and EPA interviews. We identified 125 studies of
perchlorate and the thyroid but did not review 35 of these studies because
they were not directly related to the effects of perchlorate on the
thyroid. Our review of 90 studies included the title; the author and
publication information; the sponsor or recipient; a description of the
study subjects; the type of research design and controls; and, where
presented, the author's conclusions or findings about the adverse effects
of perchlorate on health.
We conducted our work from June 2004 to March 2005 in accordance with
generally accepted government auditing standards, including an assessment
of data reliability and internal controls.
Appendix II
Facilities and Sites Where Perchlorate Was Found and Concentration Levels, as of
January 2005
Highest detection reporteda State Facility/Site name Amount (ppb)b Media Cleanup
statusc
Page 29 GAO-05-462 Perchlorate
Anniston Atmore Daphne Hickory Apache Brook Far West Scottsdale Tucson
Army Utility Utilities Fort Mobile Authority, Redstone Space Corporation), Ridge System, Hot Springs Schumaker Aerodyne Apache Powder Water Camp Chaparral City of Water Fort Glendale Phoenix Municipal Water Dept
AL Depot, 11 Groundwater AL Board, 9 Drinking AL Board, 7 Drinking AL McClellan, 32 Soil AL County 6 Mobile AL Montgomery 11 County AL Army 220,000 Groundwater Flight 12,200 Surface 280 Soil AR Aerojet Soil City of East 12,500 Surface AR Cross 6 Cross AR Waterworks, 7 Drinking AR Naval 850 Groundwater Camden AZ Gila River 18 Groundwater of AZ Nitrogen 670 Groundwater Company), AZ Company, 6 Drinking AZ Navajo, 39 Surface AZ City 6 County 17 AZ Mesa, 7 Drinking 18 AZ Company, 4 Drinking 19 AZ Huachuca, 27,000 Soil 20 AZ Municipal 6 County 21 AZ Municipal 5 County 22 AZ Water, 7 Drinking 23 AZ Municipal, 12 Drinking 24 AZ 80 Groundwater 30
Calhoun Escambia water Baldwin water City of Water and County Water Arsenal Center) water (Formerly Camden water County County Garland water Ammunition Indian Chandler Products City of La Paz water City of water Water Maricopa water City of water Cochise Water Water Maricopa water Pima water Unidynamics/Phoenix
County County County Anniston Fire Drinking Works, Drinking (NASA Atlantic Rural Drinking County Depot, Reservation, (formerly Benson County Bellemont Company, Drinking County Yuma County Company, Drinking System, Drinking County County Goodyear Airport, of Drinking
Protection water Montgomery water Marshall Research 2,708,700 Water water City of City Planning known as Planning Maricopa water Maricopa water Maricopa water City Planning Goodyear water
Appendix II
Facilities and Sites Where Perchlorate Was
Found and Concentration Levels, as of
January 2005
(Continued From Previous Page)
Highest detection reporteda State Facility/Site name Amount (ppb)b Media Cleanup
statusc
Page 30 GAO-05-462 Perchlorate
Yuma Azusa Beale
Universal Marine Yuma Aerojet Force Alpha Light Air Pomona, Dominguez, Los Carmichael Casmalia China City of City of City of City of
Propulsion City of Corps Drinking Surface Yuma Proving Surface General, Aerojet Drinking Base, Explosives, and Drinking Force Los Los California Angeles California Monterey California San California Altos, Water Resources, Lake Anaheim, Drinking City of Drinking Brawley, Drinking Chino, San Drinking Chino Drinking City of
AZ Company, 130 Groundwater Planning Phoenix AZ Air 150 Soil 4 water 5 water AZ Municipal 6 County AZ Ground, 5 water CA City of 877 Groundwater CA General, Groundwater 260 water CA Air Force 4,550 Groundwater Kern CA City of 67,000 Groundwater CA Water, 11 water CA Base, 492 Groundwater CA California 6 Angeles CA California 9 Angeles CA Water 8 County CA Water 22 County CA Water 5 Joaquin CA Water 5 Santa 41 CA District, 4 County 42 CA City of 58 Groundwater 43 CA Naval 921 Groundwater County 44 CA Orange 5 water 45 CA Bakersfield, 8 water 46 CA Imperial 5 water 47 CA Bernardino 21 water 48 CA Hills, San 4 water 49 CA Colton, 8
Incorporated, Station, Water City of Chino City of Research County Lincoln Los Yuba State County Water County Service Service Service County Service Clara Sacramento Casmalia Weapons County Kern County County County Bernardino San
City of Department, Drinking Yuma Hills Rancho Under Laboratory, Under Angeles County Polytechnical Drinking Service Drinking Company Drinking Company - Drinking Company - Drinking Company - Drinking County Drinking Center, County Bernardino Drinking
Yuma Yuma water Cordova 640,000 way Edwards Air way County University - water Company - water -ELA, Los water Salinas, water Stockton, water Suburban water water Kern County water
Appendix II
Facilities and Sites Where Perchlorate Was
Found and Concentration Levels, as of
January 2005
(Continued From Previous Page)
Highest detection reporteda State Facility/Site name Amount (ppb)b Media Cleanup
statusc
Page 31 GAO-05-462 Perchlorate
City City of City of City of City of City City of City of Desert East El Centro El Toro Imperial Irvine
City of City of of City of Loma Ontario, City of Pomona, Rialto, City of of Stockton, Tracy, City of Coachella Community, Cucamonga Water Valley Eastern Naval Air Marine EMBEE, Fort G.E. Santa Valley Ranch
CA Corona, 12 Drinking CA Escondido, 4 Drinking CA Garden 4 Drinking CA Hemet, 7 Drinking CA Linda, San 5 Drinking CA San 12 Drinking CA Patterson, 4 Drinking CA Los 10 Drinking CA San 21 Drinking CA Riverside, 42 Drinking CA City of San 7 County CA Santa 4 Drinking CA San 19 Drinking CA San 21 Drinking CA Tustin, 9 Drinking CA Valley 6 Riverside 66 CA Water 9 County 67 CA 460 Soil County 68 CA Agency, 6 Drinking 69 CA Water 16 County 70 CA Municipal 8 County 71 CA Facility, 5 Drinking 72 CA Corps Soil County 460 Groundwater 73 CA Incorporated, 1,900 Groundwater 74 CA Ord, 35 Soil 75 CA Plastics, 1,100,000 Groundwater 76 CA Great Oaks 4 Clara 77 CA College, 6 Drinking 78 CA Water 6
Riverside water San Diego water Grove, water Riverside water Bernardino water Bernardino water Stanislaus water Angeles water Bernardino water Riverside water Bernardino, Ana, water Joaquin water Joaquin water Orange water Water County District, Denova Riverside water District, Water Imperial water Air Orange County Monterey Orange Water County Imperial water District,
County County Orange County County County County County County County San Drinking Orange County County County District, Drinking San Drinking Environmental, County San Drinking District, Drinking County Station, County County Company, Drinking County Orange Drinking
County Bernardino water County Cove water Bernardino water San Bernardino Bernardino water Riverside water Orange 1,600 Incorporated, water County water
Appendix II
Facilities and Sites Where Perchlorate Was
Found and Concentration Levels, as of
January 2005
(Continued From Previous Page)
Highest detection reporteda State Facility/Site name Amount (ppb)b Media Cleanup
statusc
Page 32 GAO-05-462 Perchlorate
Mather Olin
Jet Jurupa of Energy Lincoln Air Monte Morris Ocean Safety
Propulsion Base, Community, Drinking Experimental Avenue Lockheed of Force Drinking City of City of California, Vista Dam Surveillance Amador Clara National parties), Propulsion), Flare,
CA Laboratory, 2,100,000 Soil Kern 160,000 Groundwater CA Riverside 5 water CA Lawrence 84 Groundwater Site 300, CA Water 5 County CA Lockheed Groundwater Beaumont CA Propulsion 87 Redlands CA Base, Groundwater Cordova 120 water CA McClellan 15 Groundwater County CA McCormick, 5,500 Groundwater Hollister CA Groundwater Rancho CA 7 Los Angeles CA Water 4 County CA Naval 65 Groundwater Center, Los County CA MP Soil County CA NASA, Jet Pasadena CA National 120 Groundwater County 95 CA Technical 320 Soil County 96 CA North 820 City of 97 CA OEA 350 Groundwater Solano 98 CA City 1,000 Groundwater 15
Edwards Air County County National City of Company, Propulsion Company City Air Force Selph (same McDonnell-Douglas Cordova Metropolitan County District, Command, Angeles Associates, Propulsion Semiconducter Systems, Rialto Area Rialto Aerospace County of
Force Laboratories, Under Tracy Los Drinking Company, (Former), Drinking Under of Base, as TDY Under and Aerojet Under Water Dist. Drinking San Drinking Control Incorporated, Laboratory, Drinking Under Corporation, Under Los (multiple Drinking Under (formally Morgan Under Drinking
Department way Angeles water City of 141,000 Planning City water way Rancho 1,900 Sacramento industries), way Corporation, 32,000 way of Southern water Bernadino water and City of Ione, 957,000 City of 13,300 water way Santa way Angeles responsible water way Universal Planning Hill way water
Appendix II
Facilities and Sites Where Perchlorate Was
Found and Concentration Levels, as of
January 2005
(Continued From Previous Page)
Highest detection reporteda State Facility/Site name Amount (ppb)b Media Cleanup
statusc
Page 33 GAO-05-462 Perchlorate
San
Pyrite Rancho San Operable Gabriel Operable Area, San Sierra
Pasadena Purity Canyon, California Division, San San Operable Gabriel Unit, Valley Unit City Gabriel Operable San San San Santa Rocketdyne Los Seal Army
CA Water 35 Drinking County 100 CA Oil Soil Cordova 101 CA City of 2,100 Groundwater 102 CA Water 4 County 103 CA 67 San 104 CA Riverside 5 Bernardino 105 CA 10 Riverside 106 CA San 9 Angeles 107 CA Fernando 13 Groundwater Glendale 108 CA Gabriel 21 Groundwater Unit, 109 CA Valley Groundwater City of 159 Drinking 110 CA (Area 17 Groundwater (Includes of 111 CA Valley 18 Groundwater Unit, 112 CA Gabriel 15 Bernadino 113 CA Gabriel 4 County 114 CA Santa 47 County 115 CA Clarita 4 County 116 CA Santa 750 Groundwater Division Angeles 117 CA Beach Soil County 118 CA Depot, 8 Groundwater 119 CA 5
Department, water Delta Glen District, Redlands City Bernardino Highland County Rubidoux County Fernando County Valley Valley City of (Area Baldwin water 1), Nike 14 South (Area City of Valley County Water Clarita Water Susanna (Department County Naval Lassen Sonoma
Los Angeles Gunnite, Avon Riverside Municipal County Water Community City Water (Area (Area El Monte 2), Park South Launcher El 4), Industry Water District, Site Company, Field of Energy), Weapons County County
City of Drinking Utility Drinking Company, Drinking Services Drinking Under Department, Drinking 2), City 1), El Baldwin Under El Under Monte Puente Company, Drinking Los Drinking Assessment, Drinking Los Drinking Laboratory, Under Station, Site Drinking
Rancho 13,000 water District-Water water San water District, water way Los water of Monte Planning Park 2,180 way Monte way Valley Planning Fontana, water Angeles water Los Angeles water Angeles water Boeing- way Orange 2,460 Assessment water
Appendix II
Facilities and Sites Where Perchlorate Was
Found and Concentration Levels, as of
January 2005
(Continued From Previous Page)
Highest detection reporteda State Facility/Site name Amount (ppb)b Media Cleanup
statusc
Page 34 GAO-05-462 Perchlorate
South United (formerly Pueblo Spring Atlantic
California South Special Los Stringfellow Trabuco Tulare States Nicholas Vandenburg West San West Whittaker Whittaker Colorado Chemical Naval Valley Beach Kissimmee
120 CA Water 6 Drinking County 121 CA Pasadena 5 Angeles 122 CA Devices 82 Groundwater Angeles 123 CA Superfund 87,000 Groundwater Planning 124 CA Suburban 7 Angeles 125 CA Canyon 5 County 126 CA County 11 Drinking 127 CA United Groundwater Hollister 128 CA United Groundwater County 129 CA Navy 20 Island, 130 CA Air Force 517 Groundwater Under 131 CA Vernon 5 County 132 CA Bernardino 8 Valley Bernardino 133 CA Bermite Groundwater Clarita 134 CA Ordnance, 510,000 Groundwater Under 135 CO Rocky 14 Groundwater Adams 136 CO Depot, 180 Groundwater Planning 137 CT Submarine 4 Groundwater London 138 DC Superfund 58 Groundwater defense 139 DC Washington 8 Groundwater 140 FL Water 200 Drinking 141 FL Eastern 5 Osceola 142 FL Manatee 30
Company, water City Water County Incorporated, County Site, City Water County Water Site water Defense (FMC Technologies Firing Ventura Base way Water County Water County Ordnance, City of way Mountain City of Base New County Site, a site Aqueduct System, water Regional, County County
Orange Department, Drinking City of of Glen Avon Systems-San Drinking District, Drinking Assessment Corporation), Corporation, Under Range, Drinking County Department, Drinking Water Drinking District), City of Hollister Arsenal, Pueblo London, formerly Duval North Drinking Utilities Drinking
Los water Newhall, Jose, Los water Orange water City of 2,600 Santa Clara 1,282,000 way San water Los Angeles water District water San Santa 64,000 City of Planning New used County Bermuda, water Operations water Department
Appendix II
Facilities and Sites Where Perchlorate Was
Found and Concentration Levels, as of
January 2005
(Continued From Previous Page)
Highest detection reporteda State Facility/Site name Amount (ppb)b Media Cleanup
statusc
Page 35 GAO-05-462 Perchlorate
Three Chanute City of City of National Savanna Naval United St. ATK
Royal Palm Sebring Worlds City of Feagin City City Iowa Army Air Joliet, Rock Wildlife (Department Army Surface States Tri-County Airfield), City of Charles Aberdeen Alliant City of City of
143 FL Beach 17 Drinking County 144 FL Water and 70 County 145 FL Camp 5 Drinking 146 GA Watkinsville, 38 Drinking 147 GA Fayette 5 Drinking 148 GA Mill, 5 Drinking 149 IA of 29 Groundwater 150 IA 372 Groundwater 52 Drinking 151 IA of 11 Groundwater 152 IA Ammunition 9 Groundwater Planning 153 IL Force 5 Groundwater 154 IL Will and 4 Drinking 155 IL Island, 8 Drinking 156 IL Sangamo 1,200 Groundwater Refuge, of the 157 IL Depot 12 Groundwater 158 IN Warfare 470 Soil Martin 67 Groundwater 159 IN Army 100 Soil City of 160 KS City of 36,000 Surface Planning 161 KS Airport 9 Groundwater City of 162 LA Shreveport, 10 Drinking 163 LA Water 24 Drinking 164 MA Clinton 6 County 165 MA 134,000 Soil Barnstable 500 Groundwater 166 MD Proving 15,000 Soil 3,500 Groundwater 17 Sediment 167 MD Tech 2,020 Groundwater Planning 168 MD Aberdeen, 19 Drinking Chapel
Utilities, water Sewer Resort, water Oconee County water County water Houston water Ewart City water Napier Plant, Base, Kendall water Rock water Electric City of Interior) Activity, Center, County Jefferson Madison Hallowell water (Former Herington Caddo water District water Water Massachusetts County Grounds, System, Harford water Hill,
Palm Beach System, Drinking Polk County of Middletown Rantoul Counties Island Dump/Crab Carterville City of Crane Proving Herington Parrish Number Department, Drinking Military Under City of City of County Harford Drinking
Highlands water County Hills County Orchard Savanna Division, Ground, Army One Worchester water Reservation, way Aberdeen Planning Elkton 169 MD County 20 water
Appendix II
Facilities and Sites Where Perchlorate Was
Found and Concentration Levels, as of
January 2005
(Continued From Previous Page)
Highest detection reporteda State Facility/Site name Amount (ppb)b Media Cleanup
statusc
Page 36 GAO-05-462 Perchlorate
Corps Vick's
City of Fort Naval White City of ICI Explosives Hilldale City of City of Cliffdale Former Air New Mobil City of City of Nebraska Montclair New Park Ridge
Hagerstown, Drinking George Surface Surface Oak Surface Surface New Drinking City of Drinking USA Lake City Water Drinking Highpoint, Drinking Kinston, Drinking West, Drinking Camp Station Hanover Home Drinking Lewiston, North Drinking Ordnance Fort Dix, Middlesex Drinking Water Drinking Jersey Water Drinking
170 MD Washington 4 water 171 MD Meade, 70 Groundwater 172 MD Warfare Soil 276,000 Groundwater 230 Sediment 4 water 173 MD Federal Soil Warfare 880 Groundwater 9 water 174 MN Brighton, 5 water 175 MN Northfield, 6 water 176 MO Expert Groundwater Incorporated), Joplin 177 MO Army 79 Groundwater Independence 178 MS District, 20 water 179 NC Guilford 14 water 180 NC Kinston 4 water 181 NC Cumberland 9 water 182 NC Butner, 10 Counties 183 NC 9 Groundwater New 184 NC County 7 Wilmington 185 NC Park, 6 water 186 NE Pawnee 5 Groundwater 187 NE Platte, 7 water 188 NE Plant, 24 Groundwater 189 NJ Pemberton 28 Groundwater 190 NJ County 7 water 191 NJ Bureau , 5 water 192 NJ American 5 Lakewood 193 NJ Department, 13 water 194 NJ Picatinny 627 Groundwater
County City of Center, Research Center) Ramsey Rice County Management City of Ammunition Warren County Lenoir County Granville Marine Corps River, Water Nash County Lincoln City of Township Essex Water City of Arsenal,
Odenton Indian Center County Incorporated Plant, County County and Drinking Base Camp Onslow System, Drinking County County Mead County Company, Drinking Bergen Morris
Head 480,000 (Naval 1,400 Planning (formerly 107,000 Planning City of Durham water Lejeune/Marine County City of water City of water County 500 Soil
Appendix II
Facilities and Sites Where Perchlorate Was
Found and Concentration Levels, as of
January 2005
(Continued From Previous Page)
Highest detection reporteda State Facility/Site name Amount (ppb)b Media Cleanup
statusc
Page 37 GAO-05-462 Perchlorate
Township Melrose New Henderson Mohave
of Vineland Cannon City of City Alamos Air Mountain Mexico Sandia White Boeing-Rocketdyne Water Generating PEPCON Southern Bethpage
195 NJ Hammonton 4 Drinking County 196 NJ Water and 6 County 197 NM Air 46 46 Groundwater 6 Soil 198 NM Deming, 20 Drinking 199 NM of Des 5 Drinking 200 NM Fort 3,180 Soil 2,890 Groundwater 201 NM Holloman Surface 7,600 Soil 7,600 Sediment 202 NM Kirtland Soil 13 Groundwater 203 NM Los Alamos Groundwater (Department 204 NM Force 480 Soil Clovis 41 Groundwater 205 NM View 5 Valley 206 NM American 7 of 207 NM National Soil (Department 208 NM Sands 32,900 Groundwater 209 Northern Commonwealth 14 Mariana Islands 210 NV Test Site, City 400 Groundwater 211 NV Company, 23 Drinking 212 NV Kerr-McGee Groundwater Clark 120,000 Surface 24 Drinking 213 NV Station, 7 Drinking 214 NV (Former), Groundwater County 215 NV Nevada 17 County 216 NY Water 5
Water water Sewer Force Luna water Moines water Wingate Air Force water Air Force National of Energy) Bombing Albuquerque, Water Clovis Labs, City of Energy) Missile Utilities of Reno Clark water Chemical, County water water Clark water City of Water District,
Dept, Utility, Drinking Base, Drinking County Depot, Base, Base, Laboratory, Range, City of Drinking Company, Drinking of Range Corporation, Drinking County City of Under County Henderson, System, Drinking Nassau Drinking
Atlantic Cumberland water Clovis water Gallup Planning Alamogordo 16,000 Albuquerque 50,500 City of Los 1,662 City of South water City water Albuquerque 1,040 Saipan water Henderson, 3,700,000 way Clark 600,000 Planning Clark water County water
Appendix II
Facilities and Sites Where Perchlorate Was
Found and Concentration Levels, as of
January 2005
(Continued From Previous Page)
Highest detection reporteda State Facility/Site name Amount (ppb)b Media Cleanup
statusc
Page 38 GAO-05-462 Perchlorate
City Greenlawn Hicksville Plainview Water Westbury Defiance Hecla Water Bixby
of Garden Water Water Water South Suffolk Town of Authority Water City of City of City of Water Association System, Ravenna Public City of City of Edmond Arkema Former Adjacent
217 NY Glen 4 Drinking 218 NY City of Groundwater 16 Drinking 219 NY City of 122 Groundwater 26 Drinking 220 NY City, 4 Drinking 221 NY District, 6 Drinking 222 NY District, 8 Drinking 223 NY District, 11 Drinking 224 NY Huntington 5 County 225 NY County 12 Drinking 226 NY Hempstead 9 Drinking 227 NY of 6 Drinking 228 NY District, 14 Drinking 229 OH Berea, 5 Drinking 230 OH City of 27 Drinking 231 OH City of 7 Drinking 232 OH Painesville, 9 Drinking 233 OH Ravenna, 5 Drinking 234 OH Treatment, 6 Drinking 235 OH -Plant 32 Lawrence 236 OH Army 25 Surface Ravenna 237 OH 17 County 238 OK Works 11 Drinking 239 OK Enid, 30 Drinking 240 OK Moore, 13 Drinking 241 OK City of 13 Drinking 242 OK Public 13 Drinking 243 OR Incorporated Groundwater of 244 OR Boardman 20 Groundwater 14 Surface 245 OR to the 23 Groundwater
Cove, water Westhampton, water Yaphank, water Nassau water Suffolk water Nassau water Nassau water Water Water water Water water Western water Nassau water Cuyahoga water Fairfield water Loveland water Lake County water Portage water City of water Public County Ammunition water Wright-Patterson Authority, water Garfield water Cleveland water Woodward water Works water (formerly Portland Air water Navy
Nassau Suffolk Suffolk County County County County District, Drinking Authority District Nassau County County County Defiance Water Drinking Plant, Air Force Base, Drinking Tulsa County County Authority Atofina), Force Boardman
County County 3,370 Planning County Suffolk water County water City of Greene water County City 370,000 Planning Range Bombing Range
Appendix II
Facilities and Sites Where Perchlorate Was
Found and Concentration Levels, as of
January 2005
(Continued From Previous Page)
Highest detection reporteda State Facility/Site name Amount (ppb)b Media Cleanup
statusc
Page 39 GAO-05-462 Perchlorate
Umatilla Columbia Shaw Air Talatha Arnold Acuff Addison Barr Blackwell Blair Blue Casselman Cave
Ammunition Morrow, Water Erie City City Cassatt Darlington Hartsville Force Water Air Force Crossville Steak private private private private Bledsoe Nile Camp Camp private private
246 OR Demolition 25 Groundwater City of 247 PA Ambler Boro 10 County 248 PA Company, 12 Drinking 249 PA Water 5 Drinking 250 PA 7 Huntingdon 251 PA Meadville 33 County 252 PA Muhlenberg 4 City of 253 PR of 420 Drinking 254 SC Water 5 Kershaw 255 SC County 7 and 256 SC Base, 8 Groundwater County 257 SC District, 4 Drinking 258 TN Base, 1,000 Groundwater 259 TN Water 9 Drinking 260 TX Ackerly 4 Groundwater County 261 TX House, 10 Groundwater 262 TX well, 23 Groundwater 263 TX Andrews 24 Groundwater 264 TX well, 5 Groundwater 265 TX well, 4 Groundwater 266 TX well, 14 Groundwater 267 TX Water 8 Groundwater County 268 TX Water 6 Groundwater 269 TX Bullis, 424 Groundwater Planning 270 TX Post, 8 Groundwater 271 TX well, 12 Groundwater 272 TX well, 19 Groundwater 273 TX City of 6 Groundwater
Area, Hermiston Water Lancaster water Authority water Huntingdon County Area Water Township Reading Utuado water Company County Water and Darlington Poinsett Aiken water City of Department water Water Supply Lubbock Terry County Howard Midland Midland Service Company, Bexar Garza Midland Martin Amherst,
North Department, Drinking County Boro Water Drinking Authority, Drinking Municipal Drinking Number Drinking Sewer Drinking Counties Range, County Tullahoma Corporation, County County County County County Company, Midland County County County County Lamb
Montgomery water Department, water Crawford water Authority, water One, water Authority, water Sumter Dawson Cochran County County
Appendix II
Facilities and Sites Where Perchlorate Was
Found and Concentration Levels, as of
January 2005
(Continued From Previous Page)
Highest detection reporteda State Facility/Site name Amount (ppb)b Media Cleanup
statusc
Page 40 GAO-05-462 Perchlorate
City County
City of City of El City of City of City of City of City of City of City of City of City of City of City of City of City City of City of Cosner Cotton Cotton Line County Cranfill Crucher Cunningham Duke Florey Flowing
Andrews, of Paso, Drinking Georgetown, Drinking Under Jayton, City of Drinking Lamesa, Lefors, Levelland, Drinking Midland, Drinking O'Donnell, Quitaque, Seagraves, Seminole, Slaton, Stanton, of Whiteface, Wickett, Cooper private Gin, private Gin, Road private private private Energy Andrews Park, Wells Furlow
274 TX Andrews 8 Groundwater 275 TX Crane, 14 Groundwater 276 TX El 6 water 277 TX Williamson 5 water way 278 TX Kent 5 Groundwater 279 TX Kingsville 9 water 280 TX Dawson 26 Groundwater 281 TX Gray 5 Groundwater 282 TX Hockley 123 water 283 TX Midland 46 water 284 TX Lynn 6 Groundwater 285 TX Briscoe 10 Groundwater 286 TX Gaines 10 Groundwater 287 TX Gaines 25 Groundwater 288 TX Lubbock 5 Groundwater 289 TX Martin 4 Groundwater 290 TX Sudan, 18 Groundwater 291 TX Cochran 9 Groundwater 292 TX Ward 5 Groundwater 293 TX Independent 5 Groundwater County 294 TX well, 6 Groundwater 295 TX Patricia, 8 Groundwater 296 TX well, 10 Groundwater 297 TX Borden 4 Groundwater 298 TX 404, 8 Groundwater 299 TX well, 5 Groundwater 300 TX well, 4 Groundwater 301 TX well, 7 Groundwater 302 TX Field 16 Groundwater County 303 TX ExxonMobil 6 Groundwater County 304 TX Andrews 9 Groundwater 305 TX School 12 Groundwater County 306 TX private 7 Groundwater
County Crane Paso County County County County County County County County County County County County Lamb County County School Midland Dawson Midland and Winkler Midland Terry Midland Services Production County District well,
County County County District, County County County Dawson County County County County Fullerton Company, One, Lynn
Lubbock County Plant, Andrews Martin County
Appendix II
Facilities and Sites Where Perchlorate Was
Found and Concentration Levels, as of
January 2005
(Continued From Previous Page)
Highest detection reporteda State Facility/Site name Amount (ppb)b Media Cleanup
statusc
Page 41 GAO-05-462 Perchlorate
Gaines Gaines Galian Gill Girard Glosson Hancock Henry Huber Johns Jones Jones Kadir Klondike Loller Loop Lucas
County County private private Post private Greenwood Subdivision, private private Gardens Mobile private private private High private Lone Star Longhorn Water Lubbock private Luckie
307 TX Golf 27 Groundwater 308 TX Park, 19 Groundwater 309 TX well, 5 Groundwater 310 TX Gardendale 4 Groundwater Ector 311 TX well, 7 Groundwater 312 TX Office, 9 Groundwater 313 TX well, 29 Groundwater 314 TX Greenwood 8 Groundwater Midland 315 TX Terrace 5 Groundwater Midland 316 TX Greenwood 7 Groundwater County 317 TX Greenwood 4 Groundwater County 318 TX well, 5 Groundwater 319 TX well, 21 Groundwater 320 TX Estates, 5 Groundwater 321 TX Home 5 Groundwater 322 TX well, 6 Groundwater 323 TX well, 17 Groundwater 324 TX well, 5 Groundwater 325 TX Kent KWIK 10 Groundwater County 326 TX School, 11 Groundwater 327 TX well, 6 Groundwater 328 TX Army 186 Sediment County 157 Soil 23 Groundwater 6 Surface 329 TX Army Groundwater County 163,000 Soil 11,000 Sediment 330 TX Service 6 Groundwater 331 TX Public 9 Groundwater County 332 TX well, 10 Groundwater 333 TX private 6 Groundwater
Course, Gaines Midland Country County Lynn Kent Midland Independent County Mobile County Ventures, Water Midland Gaines Ector Park, Andrews Midland Midland Convenience Dawson Yokum Ammunition water Ammunition Company, Water Midland well,
Gaines County County Water, County County County School Home Incorporated, Corporation, County County County Midland County County County Store 312, County County Plant, Plant, Under Gaines System, County Midland
County Incorporated, District, Midland Midland County Midland Texarkana Harrison 320,000 way County Lubbock County
Appendix II
Facilities and Sites Where Perchlorate Was
Found and Concentration Levels, as of
January 2005
(Continued From Previous Page)
Highest detection reporteda State Facility/Site name Amount (ppb)b Media Cleanup
statusc
Page 42 GAO-05-462 Perchlorate
Maple McClain McMurries Minnix Mobile Nelms Nobels North North North O'Brien Offield Pantex Peck Posey Ray Jr. Rivera Small
Water private McGregor Plant, private private Home private private State University West private private Plant, private private private Red River private Sid private Southland
334 TX Service 8 Groundwater 335 TX Martin 32 Groundwater 336 TX well, 7 Groundwater 337 TX Naval Soil McLennan 91,000 Groundwater 6,600 Surface 720 Sediment 338 TX well, 10 Groundwater 339 TX well, 5 Groundwater 340 TX Park, 4 Groundwater 341 TX well, 8 Groundwater 342 TX well, 4 Groundwater 343 TX Highway 6 Groundwater 344 TX Estates, 5 Groundwater 345 TX Yoakum, 8 Groundwater 346 TX well, 59 Groundwater 347 TX well, 6 Groundwater 348 TX City of 5,000 Soil (Department 408 Groundwater 349 TX 7 Groundwater Midland 350 TX 7 Groundwater Midland 351 TX well, 8 Groundwater 352 TX well, 26 Groundwater 353 TX well, 25 Groundwater 354 TX Army 417 Surface 226 Soil 7 Groundwater 355 TX well, 4 Groundwater 356 TX Roosevelt 20 Groundwater Lubbock 357 TX Sherwood 10 Groundwater Midland 358 TX Richardson 12 Groundwater County 359 TX well, 8 Groundwater 360 TX Independent 7 Groundwater
Company, County Midland Weapons County water Martin Midland Lubbock Midland Midland 115, Lubbock Yoakum Dawson Midland Amarillo, of Energy) Pecan Acres County Pecan Acres County Midland Howard Howard Depot, water Midland Independent County Estates County Carbon Midland School
Bailey County Industrial Under County County County County County Winkler County County County County Carson Homeowners Water Supply County County County Texarkana County School Manufactured Company, County District,
County Reserve 1,800,000 way County County Association, Corporation, County District, Town, Howard Garza
County
Appendix II
Facilities and Sites Where Perchlorate Was
Found and Concentration Levels, as of
January 2005
(Continued From Previous Page)
Highest detection reporteda State Facility/Site name Amount (ppb)b Media Cleanup
statusc
Page 43 GAO-05-462 Perchlorate
Tahoka Twin West Dyno Hill
Spade Water Spring Public Tate Tellinghuisen Texland Oaks Valley Warren Water Weitzel Weltie West Texas Yoakum City Promotory Dyno Nobel, Air Magna
Supply Meadow Water private private well, Great Mobile View private Runners, private private Cedar Henderson Animal Cochran County Yoakum ATK Works, Alliant of ATK Point), Nobel, Lehi, Tooele Hill, Force Kennecott Works, Alliant City Water
361 TX Corporation, 5 Groundwater County 362 TX Mobile 4 Groundwater County 363 TX System, 12 Groundwater 364 TX well, 10 Groundwater 365 TX Midland 10 Groundwater 366 TX Plains 6 Groundwater County 367 TX Home 10 Groundwater 368 TX Mobile 9 Groundwater County 369 TX well, 30 Groundwater 370 TX Incorporated, 4 Groundwater 371 TX well, 8 Groundwater 372 TX Welch Water 14 Groundwater County 373 TX well, 9 Groundwater 374 TX Creek 8 County 375 TX Clinic, 13 Groundwater 376 TX Whiteface 6 Groundwater County 377 TX Park 6 Groundwater County 378 UT Thiokol, Groundwater Tech Systems, West 379 UT Thiokol, Groundwater City of 380 UT Site B Soil Utah 381 UT Test Soil Tooele 382 UT Base, 70 Groundwater County 383 UT Utah 61 Tech Systems, of 384 UT Company, 8
Lamb Home Lynn Martin County Water Park, Home Gaines Midland Midland Supply Midland Municipal Scurry Independent and Bacchus Incorporated), Valley Promotory Brigham (Pelican County Site, County City of Copper Incorporated), Magna Salt
Park, County County Company, Midland Park, County County County Corporation, County Utility Drinking County School Golf ( former (former Point), City of Layton, (former Drinking Lake Drinking
Midland Gaines County Midland Dawson District, water District, Course, Bacchus 19,000 Planning Thiokol, 60,000 Planning City of 1,300,000 Planning Topliff 41,900 Davis Planning Bacchus water Planning County water
Appendix II
Facilities and Sites Where Perchlorate Was
Found and Concentration Levels, as of
January 2005
(Continued From Previous Page)
Highest detection reporteda State Facility/Site name Amount (ppb)b Media Cleanup
statusc
385 UT Wendover Air Force Base, Tooele 1,200 Soil Under way
County
386 VA Atlantic Research Corporation 17 Groundwater Planning
387 VA Naval Surface Warfare Center, Groundwater
Dahlgren 2,700
1,200 Soil
120 Sediment
7 Surface water
388 VA Purdue Farms, Incorporated, 4
Accomack Drinking water
County
389 VA Radford Ammunition Plant 11 Groundwater
390 WA Camp Bonneville, City of Vancouver 380 Groundwater Under way
391 WA City of Puyallup, Pierce County 8 Drinking water
392 WA Firgrove Mutual, Incorporated, 6 Drinking water
Pierce County
393 WA Lacey Water Department, Thurston 9 Drinking water
County
394 WA Lakewood Water District, Pierce 6 Drinking water
County
395 WV Allegheny Ballistics Lab, City of Soil
Rocket Center 35,000
34,900 Groundwater
880 Sub-soil
690 Surface water
190 Sediment
Sources: Environmental Protection Agency, Department of Defense, U.S.
Geological Survey, and state environmental agencies.
Note: For the purposes of this report, a site refers to the physical
location where perchlorate was found. Our listing includes both points of
origin as well as locations where perchlorate was found away from the
origin or source. This table lists the highest detection reported and the
media in which it was found, such as groundwater or soil.
aIn some instances, officials have not confirmed initial sampling results
through subsequent tests. For example, subsequent sampling may have found
lower concentrations or could not find perchlorate.
bParts per billion (ppb).
cData in column reflect the status of cleanup at 51 of the almost 400
sites where perchlorate was found.
Appendix III
Perchlorate Health Risk Studies Published Since 1998
Author's
findings/
conclusions
about the
adverse
effects
Publica- of
Sponsor/ Subject Design perchlorate
Study Author Design controls on health
tion year title Recipient description type
2000 The Effect Mann Environmental Animal Review/ New Not
of diagnostic identified/
Ammonium Protection Reanalysis criteria Unknown.
of (see
Perchlorate Agency studies/data original
on study
Thyroids for
experimental
controls)
2001 Statistical Dunson Environmental Animal Review/ Established Adverse
Analysis effects
of the Protection Reanalysis incidence indicated.
Tumors of
Observed in Agency studies/data probabilities
Male
F1 Rats at (see original
Week
19 in the study for
Argus
(1999) Two- experimental
Generation controls)
Reproduction
Study of
Ammonium
Perchlorate
2000 Report of the Wolf Environmental Animal Review/ New Adverse
Peer diagnostic effects
Review of Protection Reanalysis criteria for indicated.
Thyroid of
Histopathology Agency studies/data reviewing
data
from Rodents (see
and original
Rabbits study for
Exposed to
Ammonium experimental
Perchlorate in controls)
the
Drinking Water
2001 Revised Analysis Crofton Environmental Animal Review/ See original Nonadverse
of the Thyroid Protection Reanalysis study for effects
of indicated.
Hormone Data Agency studies/data experimental No
information
from the Mouse controls available
on
adverse
Immunotoxicology effects.
Study (from Keil
et
al., 1999)
5 2001 Revised Analysis Crofton Environmental Animal Review/ See original Nonadverse
of the Thyroid Protection Reanalysis study for effects
of indicated.
Hormone Data Agency studies/data experimental Adverse
effects to
from the Rat controls development
Developmental indicated.
"effects" Study-
Argus
Protocol1416-003
Appendix III
Perchlorate Health Risk Studies Published
Since 1998
(Continued From Previous Page)
Author's
findings/
conclusions
about the
adverse
effects
Publica- of
Sponsor/ Subject Design perchlorate
Study Author Design controls on health
tion year title Recipient description type
Keil, Department Dose,
1998 Effects of et of Animal Experimental duration, Nonadverse
al.
Ammonium Defense design age, sex, and effects
indicated.
Perchlorate on weight Information
on
Immunotoxicologi- (dose levels adverse
effects is
cal, independently incomplete.
Hematological,
and Thyroid verified)
Parameters in
B6C3F1 Female
Mice
Keil, Dose,
1999 Effects of et Department of Animal Experimental duration, Nonadverse
al.
Ammonium Defense and design age, sex, effects
strain, indicated.
Perchlorate on Environmental and weight No adverse
Immunotoxicologi- Protection (dose levels effects
indicated.
cal, Agency independently
Hematological,
and Thyroid verified)
Parameters in
B6C3F1 Female
Mice [Final
report]
1998 A 90-day Siglin ManTech Animal Experimental Dose, Nonadverse
Drinking duration, and
Water Environmental design sex, and adverse
Toxicity weight effects
Study in Technology, indicated.
Rats With
Ammonium Inc.
Perchlorate
[Final
Report]
1998 A York ManTech Animal Experimental Dose and Nonadverse
Neurobehavioral
Developmental Environmental design duration effects and
Study of Technology, adverse
Ammonium Inc. developmental
Perchlorate effects
indicated.
Administered
Orally in
Drinking
Water to Rats
Appendix III
Perchlorate Health Risk Studies Published
Since 1998
(Continued From Previous Page)
Author's
findings/
conclusions
about the
adverse
effects
Publica- of
Sponsor/ Subject Design perchlorate
Study Author Design controls on health
tion year title Recipient description type
10 2001 Hormone, Thyroid and Neurohistological Effects of Oral (drinking
water) Exposure to Ammonium Perchlorate in Pregnant and Lactating Rats and
in Fetuses and Nursing Pups Exposed to Ammonium Perchlorate During
Gestation and Via Maternal Milk
York Perchlorate Animal Experimental Dose and Nonadverse Study Group
design duration effects and adverse developmental effects indicated.
11 2000 A Neurodevelop-Bekkedal, et Department of Animal Experimental Dose
and age No mental Study of al. Defense design developmental Ammonium
effects indicated. Perchlorate Exposure on the Motor Activity of
Pre-weanling Rat Pups
12 2003 An Assessment Boyes, Environmental Animal Review/ See original Adverse
of et al. effects to
Issues Protection Reanalysis study for development
Regarding of
Neurotoxic Agency studies/data experimental indicated.
Effects
of controls
Developmental
Exposure to
Perchlorate
Appendix III
Perchlorate Health Risk Studies Published
Since 1998
(Continued From Previous Page)
Author's
findings/
conclusions
about the
adverse
effects
Publica- of
Sponsor/ Subject Design perchlorate
Study Author Design controls on health
tion year title Recipient description type
13 2003 Hormone, Thyroid Consultants Review: Animal Review/ Dose,
duration, Adverse effects to and in Veterinary Environmental Reanalysis of
and age development Neurohistological Pathology Protection studies/data
indicated.
Effects of Oral (drinking water) Exposure to Ammonium Perchlorate in
Pregnant and Lactating Rats and in Fetuses and Nursing Pups Exposed to
Ammonium Perchlorate During Gestation and Via Maternal Milk
Agency/ Original study: Perchlorate Study Group
14 2001 Statistical Dunson Environmental Animal Review/ Dose, Adverse
Analysis duration, effects to
of the Effects Protection Reanalysis and age development
of of
Perchlorate on Agency studies/data indicated.
Neurobehavioral
(motor
activity) in
SD Rats
15 2001 Profile Gellar Environmental Animal Review/ Dose and Adverse
Analysis of effects to
Brain Protection Reanalysis duration development
Morphometry of
data from Agency studies/data indicated.
Argus/Primedica
"Effects"
Protocol
1416-003
16 2003 Revised Brain Gellar Environmental Animal Review/ See original Adverse
effects to
Morphometry Protection Reanalysis study for development
of
Analysis Agency studies/data experimental indicated.
Incorporating controls
Consultant in
Veterinary
Pathology
(2003)
Review of
Morphometry
Data
from Argus
1416-
003
Appendix III
Perchlorate Health Risk Studies Published
Since 1998
(Continued From Previous Page)
Author's
findings/
conclusions
about the
adverse
effects
Publica- of
Sponsor/ Subject Design perchlorate
Study Author Design controls on health
tion year title Recipient description type
17 2001 Re: Comments on Original Experimental Design, Study Performance,
and Brain Morphometry Results of Argus Research Laboratories, Inc., 14
March 2001 Study (Protocol Number 1416-003) and Supplemental Materials
Provided by Dr. Robert Garman, Consultants in Veterinary Pathology, Inc.
Harry Environmental Animal Review/ See original Effects not
Protection Reanalysis of study for studied.
Agency studies/data experimental
controls
18 1999 Oral York Perchlorate Animal Experimental Dose, Adverse
(Drinking duration, effects to
Water) Two Study Group design and sex development
Generation indicated.
(one
Litter Per
Generation)
Reproduction
Study of
Ammonium
Perchlorate
19 2000 Oral York Perchlorate Animal Experimental Dose No adverse
(Drinking
Water) Study Group design developmental
Developmental effects
indicated.
Toxicity
Study of
Ammonium
Perchlorate
in Rats
[Final
report]
20 2000 Ammonium Dourson Perchlorate Animal Experimental Dose and Nonadverse
and and
Perchlorate: Dollarhide Study Group design duration adverse
Effect effects
on Immune indicated.
Function
21 2000 Addendum to Dourson Perchlorate Animal Experimental Dose Nonadverse
and and
Ammonium Dollarhide Study Group design adverse
effects
Perchlorate: indicated.
Effect
on Immune
Function
Appendix III
Perchlorate Health Risk Studies Published
Since 1998
(Continued From Previous Page)
Author's
findings/
conclusions
about the
adverse
effects
Publica- of
Sponsor/ Subject Design perchlorate
Study Author Design controls on health
tion year title Recipient description type
22 2000 Ammonium Brechner, Not Human Field Dose, Nonadverse
et identified/ study
Perchlorate al. Unknown comparison/ effects
indicated.
Contamination control town, No
of information
Colorado race/ethnicity, available
River on
Drinking and age adverse
Water is effects.
Associated
With
Abnormal
Thyroid
Functions in
Newborns in
Arizona
23 2002 Health Effects Greer, Perchlorate Human Experimental Dose and Nonadverse
et al.
Assessment for Study Group design external effects
data indicated.
Environmental and audit No
National information
Perchlorate Institute available
of on
Contamination: Health adverse
effects.
The Dose
Response for
Inhibition of
Thyroidal
Radioiodine
Uptake in
Humans
24 2000 The Effect Lawrence, Perchlorate Human Experimental Baseline Nonadverse
of Short- et blood
Term al. Study design and urine effects
Low-Dose Group, tests, indicated.
Perchlorate National and No adverse
on statistical
Various Institute controls effects.
Aspects of of for time
Thyroid Health, and and
Function duration
the Thyroid
Center for
Excellence
25 2003 Estimating Marcus Environmental Human Review/ Statistical Nonadverse
Human
Dose-Response Protection Reanalysis controls, such effects
of indicated.
Functions for Agency studies/data as No
the information
Greer et al. autocorrelation available
(2000, on
2002) and adverse
Merrill effects.
(2001a) Data
on
Thyroid
Radioactive
Iodide
Uptake (RAIU)
After
Perchlorate
Ingestion
Appendix III
Perchlorate Health Risk Studies Published
Since 1998
(Continued From Previous Page)
Author's
findings/
conclusions
about the
adverse
effects
Publica- of
Sponsor/ Subject Design perchlorate
Study Author Design controls on health
tion year title Recipient description type
26 2003 Analysis of Marcus Environmental Human Review/ Statistical Nonadverse
Dose-
Response Protection Reanalysis controls, effects
of such indicated.
Functions Agency studies/data as No
for circadian information
Effects of rhythms, available
on
Perchlorate gender, adverse
on dose, effects.
Serum and
Hormone duration
from Data
of Greer
et al.
(2000,
2002)
and Merrill
(2001a)
27 2001 Gestational Schwartz California Human Field Gender, Nonadverse
study
Exposure to Department multiple effects
of birth, indicated.
Perchlorate Health birth Potential
is weight, adverse
Associated Services blood developmental
With sample,
Measures of age, and effects
indicated.
Decreased ethnicity
Thyroid
Function in
a
Population
of
California
Neonates
Anion Van Not
28 2003 Selectivity Sande, Ministere de Cells Experimental identified/ Nonadverse
by
the Sodium et al. la Politique design Unknown effects
Iodide indicated.
Symporter Scientifique, No
information
and Fonds available
on
adverse
effects.
29 1998 Perchlorate Wolff Not Not Review/ Not Nonadverse
and the identified/ identified/ identified/
Thyroid Unknown Unknown Reanalysis Unknown effects
Gland of indicated.
studies/data No
information
available
on
adverse
effects.
30 1998 Differences in the Yoshida, Not Cells Experimental Not Effects
et identified/ identified/ not
Electrophysiologi- al. Unknown design Unknown studied.
cal Response To
I- and the
Inhibitory
Anions SCN-and
CIO-4 Studied in
FRTL-5 Cells
Appendix III
Perchlorate Health Risk Studies Published
Since 1998
(Continued From Previous Page)
Author's
findings/
conclusions
about the
adverse
effects
Publica- of
Sponsor/ Subject Design perchlorate
Study Author Design controls on health
tion year title Recipient description type
31 2002 ConsultativeLetter: Yu Environmental Animal Experimental Dose and Nonadverse
Intravenous Protection design duration effects
indicated.
Kinetics of Radio Agency and No
information
Labeled Iodide and Department of available on
Perchlorate in Defense adverse
Tissues of developmental
Pregnant and effects.
Lactating Spraque
Dawley Female
Rats Dosed With
Perchlorate and/or
Carrier Free 125I-
32 2001 ConsultativeLetter: Clewell, Environmental Animal Review/ Statistical Effects not
et
Physiologically- al. Protection Reanalysis controls, studied
of such (model
Based Agency and studies/data as time, developed).
body
Pharmacokinetic Department of weight
Model for the Defense changes,
Kinetics of mammary
Perchlorate- tissue,
blood
Induced Inhibition flow,
cardiac
of Iodide in the output, and
Pregnant Rat and body fat
Fetus
33 2001 ConsultativeLetter: Clewell, Environmental Animal Statistical Effects not
et Review/
Physiologically- al. Protection Reanalysis controls, studied
of such (model
Based Agency and studies/data as time, developed).
body
Pharmacokinetic Department of weight
Model for the Defense changes,
Kinetics of mammary
Perchlorate- tissue,
blood
Induced Inhibition flow,
cardiac
of Iodide in the output, and
Lactating and fractional
body
Neonatal Rat fat
34 2001 Consultative Merrill Environmental Human Audit of Not Effects
Letter: identified/ not
Audit Report for Protection documentation Unknown studied.
the
Study of Agency and from a prior
Perchlorate Department of study
Pharmacokinetics Defense
and Inhibition
of
Radioactive
Iodine
Uptake (RAIU) by
the Thyroid in
Humans
Appendix III
Perchlorate Health Risk Studies Published
Since 1998
(Continued From Previous Page)
Author's
findings/
conclusions
about the
adverse
effects
Publica- of
Sponsor/ Subject Design perchlorate
Study Author Design controls on health
tion year title Recipient description type
35 2001 Consultative Merrill Environmental Human Review/ Statistical Effects not
Letter:
PBPK Model Protection Reanalysis controls studied
for of (model
Perchlorate- Agency and studies/data developed).
Induced Department of
Inhibition
of Defense
Radioiodide
Uptake in
Humans
36 2001 Consultative Letter: Revision To AFRL-HE-WP-CL-20010010,
Comparison of Internal Dosimetrics Using PBPK Models for
Perchlorate-Induced Inhibition of Thyroid Iodide Uptake and Sensitivity
Analysis for Male Rat Model
Merrill Environmental Animal Review/ Statistical Effects not Protection
Reanalysis of controls studied (model Agency and studies/data developed).
Department of Defense
Carr,
37 2001 Uptake and et Strategic Amphibian Experimental Dose and Nonadverse
al.
Elimination of Environmental design duration effects
indicated.
Perchlorate in Research and No adverse
American
Bullfrog Development developmental
Larvae, Rana Program effects
indicated.
Catesbeiana
Carr,
38 2001 et Adverse
Response of al. Strategic Amphibian Field study Dose,
Native Adult Environmental contaminated/ developmental
and
Larval Anurans Research and noncontami- effects
in indicated.
Their Natural Development nated sites,
Environment to Program oxygen level,
Ammonium temperature,
Perchlorate conductivity,
Contamination: salinity, pH,
and
Assessment of species
Reproductive
and
Thyroid
Endpoints
Appendix III
Perchlorate Health Risk Studies Published
Since 1998
(Continued From Previous Page)
Author's
findings/
conclusions
about the
adverse
effects
Publica- of
Sponsor/ Subject Design perchlorate
Study Author Design controls on health
tion year title Recipient description type
39 2002 The Effects of Contaminated and Reference Surface Waters on
Metamorphosis in Xenopus Laevis Using a Modified US Environmental
Protection Agency Endocrine Disruptor Screening and Testing Advisory
Committee (EDSTAC, US Environmental Protection Agency, 1998)-Tier 1 Tail
Resorption Assay
Carr, et al. Strategic Amphibian Experimental Dose and Adverse
Environmental design plus duration developmental Research and field study
effects indicated. Development Program
40 2001 Lethal Concentration Determination of Sodium Perchlorate and
Ammonium Chloride on Xenopus Laevis Eggs and Developing Juveniles During a
5 Day Exposure
Carr, et al. Strategic Amphibian Experimental Dose Adverse Environmental
design developmental Research and effects indicated. Development Program
41 2004 Perchlorate Klaassen Not Human Review/ See original Effects not
Toxicity identified/ and
and Risk Unknown animal Reanalysis study for studied
of
Assessment studies/data experimental (reference
dose
controls developed).
Thyroid Lamm, Field Dose No
42 1999 Health et American Human study exposure nonadverse
al. or
Status of Pacific level, and adverse
effects
Ammonium Corporation, screening indicated.
for
Perchlorate Las Vegas, underlying
Workers: A NV thyroid
Cross- and
Sectional health
problems
Occupational
Health Study
Appendix III
Perchlorate Health Risk Studies Published
Since 1998
(Continued From Previous Page)
Author's
findings/
conclusions
about the
adverse
effects
Publica- of
Sponsor/ Subject Design perchlorate
Study Author Design controls on health
tion year title Recipient description type
43 1998 Genotoxicity Sharma, Perchlorate Animal, Experimental Dose, No adverse
et repeated
Assays for al. Study bacteria, design study, effects
Group, and bacteria indicated.
Ammonium Toxicology cells strain,
and sex
Perchlorate Excellence
for
Risk
Assessment,
Cincinnati,
OH
44 2000 Consultative Mahle Department Animal Experimental Dose, duration, Nonadverse
Letter: of
Hormone and Defense design and switched effects
indicated.
Perchlorate exposed/control No
Data information
from Cross- litters with available on
Fostering adverse
Study exposed/
control dams developmental
effects.
45 2001 Consultative Mahle Department Animal Nonadverse
Letter: of Experimental Dose, duration,
Hormone and Defense design and switched effects
indicated.
Perchlorate exposed/ No
Data information
from Cross- control litters available on
Fostering adverse
Study with exposed/
control dams developmental
effects.
46 2000 Consultative Merrill Department Human Review/ Statistical Effects not
Letter: of
Human PBPK Defense Reanalysis controls, studied
of such (model
Model for studies/data as body developed).
weight,
Perchlorate urinary
Inhibition excretion
of Iodide rate
Uptake in
the constants,
Thyroid thyroid
maximum
velocities,
and
inhibition
affinity
constants
47 2000 Consultative Mattie Department Human Experimental Dose and Not
Letter: of identified/
Hormone Data Defense design duration Unknown.
from Brabant
Human
Perchlorate
(1.0 and
12.0
mg/kg-day)
Kinetics
Drinking
Water Study
Appendix III
Perchlorate Health Risk Studies Published
Since 1998
(Continued From Previous Page)
Author's
findings/
conclusions
about the
adverse
effects
Publica- of
Sponsor/ Subject Design perchlorate
Study Author Design controls on health
tion year title Recipient description type
48 2002 Uptake of Theodorakis Strategic Fish Experimental Dose and Nonadverse
and
Ammonium Environmental design duration adverse
effects
Perchlorate Research and indicated.
and
Thyroid
Status in Development
Native Fish Program
49 2001 In Situ Theodorakis Fish
Exposure of Strategic Field study Dose, Findings not
Fish and Environmental contaminated/ used--design
Amphibians Research and clean sites, limitations
for too
Determination Development duration, pH,
of great.
Contaminant Program oxygen
levels,
Effects at conductivity,
the
Longhorn Army and
Ammunition temperature
Plant, of
Jefferson test sites
County,
Texas
50 2002 Fish and Theodorakis Strategic Fish Field study Dose, No adverse
Amphibians as Environmental contaminated/ effects
indicated.
Aquatic Research and clean sites,
Sentinels
for Development duration, pH,
Perchlorate
Exposures and Program oxygen
levels,
Effects at conductivity,
the
Longhorn Army and
Ammunition temperature
Plant, of
Jefferson test sites
County,
Texas
51 1998 Tsui, et Ions Room Effects not
Stability and al. Department of Experimental
Concentration Defense design temperature, studied.
Verification light,
of humidity,
Ammonium and
light/dark
Perchlorate cycle
Dosing
Solutions
Assessment Field No
52 2001 of Smith Strategic Animal study Dose, and nonadverse
or
Perchlorate Environmental contaminated adverse
in effects
Terrestrial Research and areas indicated.
Mammalian Development compared
with
Receptors: Program uncontami-
Raccoons nated
(Procyon
Lotor)
and
Opossums
(Didelphis
Virginiana)
Appendix III
Perchlorate Health Risk Studies Published
Since 1998
(Continued From Previous Page)
Author's
findings/
conclusions
about the
adverse
effects
Publica- of
Sponsor/ Subject Design perchlorate
Study Author Design controls on health
tion year title Recipient description type
53 2000 ConsultativeLetter: Yu Department Animal Experimental Dose and Nonadverse
of
Tissue Distribution Defense design duration effects
indicated.
and Inhibition of No
information
Iodide Uptake in available on
the Thyroid by adverse
Perchlorate With developmental
Corresponding effects.
Hormonal Changes
in Pregnant and
Lactating Rats
(Drinking Water
Study)
54 2001 ConsultativeLetter: Yu Department Animal Experimental Time Nonadverse
of after
Intravenous Defense design dosing effects
and indicated.
Kinetics of before No
death information
Radiolabeled available on
Iodide in Tissues adverse
of
Adult Male developmental
Sprague Dawley effects.
Rat Dosed With
125I-Plus Carrier
55 1998 Consultative Department Animal Dose No adverse
Letter: Zeiger of Experimental
Salmonella Health and design effects
indicated.
Mutagenicity Human
Testing of Services,
Ammonium National
Perchlorate Institute
of
Health
York, Department
56 2003 Oral (Drinking et of Animal Experimental Dose Nonadverse
al.
Water) Defense design effects
indicated.
Developmental Adverse
effects to
Toxicity Study development
of
Ammonium indicated.
Perchlorate in
Sprague-Dawley
Rats
Appendix III
Perchlorate Health Risk Studies Published
Since 1998
(Continued From Previous Page)
Author's
findings/
conclusions
about the
adverse
effects
Publica- of
Sponsor/ Subject Design perchlorate
Study Author Design controls on health
tion year title Recipient description type
57 2003 Consultative Wolf Environmental Amphibian Review/ Dose Adverse
Letter: effects
Review of the Protection Reanalysis indicated.
of
Thyroid Agency studies/data
Histopathology
from Xenopus
Laevis Exposed
to
Ammonium
Perchlorate in
the
Water
58 2004 Evidence for Clewell, Department of Human Review/ See original Nonadverse
et and
Competitive al. Defense and animal Reanalysis study for effects
of indicated.
Inhibition of National studies/data experimental No
Iodide information
Uptake by Aeronautics controls available
on
Perchlorate and Space adverse
and effects.
Translocation Administration
of
Perchlorate
into the
Thyroid
59 2000 A 90-Day Siglin, Not Animal Experimental Duration, Nonadverse
Drinking et al. identified/ dose, and
Water Unknown design and adverse
Toxicity recovery effects
Study in Rats period indicated.
of the
Environmental
Contaminant
Ammonium
Perchlorate
60 2004 A Rat Neurodevelopmental Evaluation of Offspring, Including
Evaluation of Adult and Neonatal Thyroid, From Mothers Treated With
Ammonium Perchlorate in Drinking Water
York, et Department of Animal Experimental Duration and Nonadverse
al.
Defense and design dose effects indicated.
ManTech Adverse
Geo-Centers developmental
Joint Venture effects indicated.
Oral York, Not
61 2001 (Drinking et identified/ Animal Experimental Dose Nonadverse
al.
Water) Unknown design effects
indicated.
Developmental No adverse
Toxicity developmental
Study of
Ammonium effects
indicated.
Perchlorate
in New
Zealand White
Rabbits
Appendix III
Perchlorate Health Risk Studies Published
Since 1998
(Continued From Previous Page)
Author's
findings/
conclusions
about the
adverse
effects
Publica- of
Sponsor/ Subject Design perchlorate
Study Author Design controls on health
tion year title Recipient description type
York, Not
62 2003 Oral (Drinking et identified/ Animal Experimental Dose Nonadverse
al.
Water) Unknown design effects
indicated.
Developmental No adverse
Toxicity Study developmental
of
Ammonium effects
indicated.
Perchlorate in
Sprague-Dawley
Rats
63 2000 Does Perchlorate in Drinking Water Affect Thyroid Function in
Newborns or School-Age Children?
Crump, et al. Kerr-McGee Chemical, Oklahoma City Oklahoma
Human Field study Dose (cities with high, medium and no levels of
perchlorate in water), age, sex, and urinary iodine concentration, whether
living in the study city since birth or moving there in the past year No
adverse developmental effects indicated.
64 1998 Evaluation Gibbs, Not Human Field Dose (high, No adverse
of a et al. identified/ study
Population Unknown low/control effects
With air indicated.
Occupational exposure
Exposure to groups),
dose
Airborne estimation
(shift
Ammonium and
lifetime),
Perchlorate race,
For gender,
Possible age, hours
Acute or
Chronic awake prior
Effects On to
Thyroid shift,
Function hours
slept, time
of
day, and
shift
length
Appendix III
Perchlorate Health Risk Studies Published
Since 1998
(Continued From Previous Page)
Author's
findings/
conclusions
about the
adverse
effects
Publica- of
Sponsor/ Subject Design perchlorate
Study Author Design controls on health
tion year title Recipient description type
65 2004 Letter To Gibbs, Not Human Field Dose (cities Effects
The et al. identified/ study not
Editor: Unknown with high, studied.
Crump Et
Al. Study medium and no
Among
School levels of
Children in
Chile:
Subsequent perchlorate in
Urine and water), age,
Serum
Perchlorate sex, and
Levels urinary
Are iodine
Consistent
With
Perchlorate concentration,
in
Water in whether living
Taital in
the study city
since birth or
moving there
in
the past year
Greer, Dose
66 2002 Health Effects et al. Perchlorate Human Experimental and Nonadverse
sex
Assessment for Study Group design effects
indicated.
Environmental and No adverse
National
Perchlorate Institute effects
of indicated.
Contamination: Health
The Dose
Response
Inhibition of
Thyroidal
Radioiodine
Uptake in
Humans
67 2001 Letter To Lawrence, Not Human Experimental Not No effects
The et identified/ identified/
Editor: Low al. Unknown design Unknown indicated.
Dose
Perchlorate
(3mg
Daily) and
Thyroid
Function
68 2000 The Effect Lawrence, Perchlorate Human Experimental Baseline Nonadverse
of Short- et tests
Term al. Study design performed effects
Low-Dose Group, to indicated.
Perchlorate Thyroid ensure No
on subjects information
Various Center for had no available
Aspects of prior of
Thyroid Excellence, thyroid adverse
Function effects.
and problems
National
Institute
of
Health
69 2001 Perchlorate Soldin, Not Human Review/ See original Not
Clinical et al. identified/ identified/
Pharmacology Unknown Reanalysis study for Unknown.
and of
Human studies/data experimental
Health: A
Review controls
Appendix III
Perchlorate Health Risk Studies Published
Since 1998
(Continued From Previous Page)
Author's
findings/
conclusions
about the
adverse
effects
Publica- of
Sponsor/ Subject Design perchlorate
Study Author Design controls on health
tion year title Recipient description type
70 2003 Predicting Fetal Perchlorate Dose and Inhibition of Iodide
Kinetics During Gestation: A Physiologically-Based Pharmacokinetic
Analysis of Perchlorate and Iodide Kinetics in the Rat
Clewell, et Department of Animal Experimental Dose, duration, Effects not
al. Defense design and and model studied (model review/ controls
developed). reanalysis of studies/data
71 2003 Predicting Clewell, Department Animal Experimental Dose, Effects not
et of duration,
Neonatal al. Defense design and and model studied
(model
Perchlorate Dose review/ controls developed).
and Inhibition reanalysis
of of
Iodide Uptake in studies/data
the Rat During
Lactation Using
Physiologically-
Based
Pharmacokinetic
Modeling
72 2003 PBPK Merrill, Department of Animal Review/ Dose, Effects not
Predictions et al. duration,
of Defense and Reanalysis and model studied
Perchlorate of (model
Distribution National studies/data controls developed).
and its
Effect on Aeronautics
Thyroid
Uptake of and Space
Radioiodide Administration
in the
Male Rat
73 2005 PBPK Model Merrill, Department of Animal Review/ Dose, Effects not
for et al. duration,
Radioactive Defense and Reanalysis and model studied
Iodide of (model
and National studies/data controls developed).
Perchlorate
Kinetics and Aeronautics
Perchlorate- and Space
Induced Administration
Inhibition
of Iodide
Uptake in
Humans
Appendix III
Perchlorate Health Risk Studies Published
Since 1998
(Continued From Previous Page)
Author's
findings/
conclusions
about the
adverse
effects
Publica- of
Sponsor/ Subject Design perchlorate
Study Author Design controls on health
tion year title Recipient description type
Yu, Dose,
74 2002 The et Department of Animal Experimental duration, Nonadverse
al.
Pharmacokinetics Defense and design and model effects
indicated.
of Perchlorate National controls No
and information
its Effect on the Aeronautics available
on
adverse
Hypothalamus- and Space effects.
Pituitary-Thyroid Administration
Axis in the Male
Rat
75 2004 Reference Strawson, Toxicology Human Review/ Statistical Effects not
Dose for et
Perchlorate al. Excellence Reanalysis controls, studied
Based for of such
On Thyroid Risk studies/data as (reference
dose
Hormone Assessment Environmental developed).
Change
in Pregnant Protection
Women as Agency
the
Critical protocols on
Effect
Reference
Dose risk
assessment,
and
uncertainty
factors
76 1999 In Vitro San and Perchlorate Animal Experimental Dose, No adverse
Mammalian effect
Cell Gene Clarke Study Group design established indicated.
Mutation
Test criteria
(L5178Y/TK for a
Mouse mutagenesis
Lymphoma
Assay) assay
77 2001 Uptake of Anderson Plants Dose, Effects
the Strategic Experimental duration, not
Perchlorate Environmental design plant type, studied.
Anion and
Into water v.
Various and Research sand
Plant
Species Development
Program
78 2001 Effects of Anderson Strategic Earthworms Experimental Dose, Effects
the duration, not
Perchlorate Environmental design and studied.
Anion dermal v.
on and Research soil
Earthworms contact
Development
Program
Appendix III
Perchlorate Health Risk Studies Published
Since 1998
(Continued From Previous Page)
Author's
findings/
conclusions
about the
adverse
effects
Publica- of
Sponsor/ Subject Design perchlorate
Study Author Design controls on health
tion year title Recipient description type
79 2001 Hormone, Thyroid, and Neurohistological Effects of Oral (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
Consultants Perchlorate Animal Experimental Duration and Adverse effect on
in Veterinary Study Group design dose development Pathology indicated.
80 1999 Consultative Channel Environmental Animal Experimental Dose No effects
Letter:
Kinetic Data Protection design indicated.
for
Iodide Agency and
Uptake
Inhibition Department of
in the
Thyroid by Defense
Perchlorate
(2-
Week
Drinking
Water Study)
81 1999 Consultative Channel Department of Human Review/ See original Effects not
Letter:
Summary of Defense and Reanalysis study for studied
of (model
Human National studies/data experimental developed).
Kinetic
Data on Aeronautics controls
Perchlorate and Space
Administration
82 2003 Effect of Tietge Environmental Dose and Nonadverese
and Amphibians Experimental
Perchlorate Degitz Protection design duration effects
on indicated.
Amphibian Agency Adverse
effects to
Development development
indicated.
83 1998 Benchmark Geller Environmental Animal Review/ See original Effects not
Dose
Calculations Protection Reanalysis study for studied
on of
Thyroid Data Agency studies/data experimental (bechmark
from dose
Studies controls developed).
Submitted
for
Evaluation
of
Perchlorate
Appendix III
Perchlorate Health Risk Studies Published
Since 1998
(Continued From Previous Page)
Author's
findings/
conclusions
about the
adverse
effects
Publica- of
Sponsor/ Subject Design perchlorate
Study Author Design controls on health
tion year title Recipient description type
84 2004 Solid-State Rosso and National Ammonium Experimental Temperature Effects
Proton not
Conduction: Tuckerman Science Perchlorate design levels, and studied.
An Ab pure
Initio Foundation Crystal crystal v.
Molecular
Dynamics and neutral
Research
Investigation Corporation ammonia
of doped
Ammonium Research crystal
Perchlorate Innovations
Doped
With Neutral
Ammonia
85 2002 Community Cancer Morgan Not Human Field Incidence No adverse
and identified/ study rates,
Assessment in Cassady Unknown effects
age, sex, indicated.
Response to Long- race/ethnicity,
Time Exposure to population
size,
Perchlorate and and
Trichloroethylene
in demographic
Drinking Water features
86 2004 Interspecies Lewandow- Not Human Review/ From Effects
identified/ and original not
Differences in ski, et Unknown animal Reanalysis studies studied.
al. of
Susceptibility studies/data
to
Perturbation
of
Thyroid
Homeostasis: A
Case Study
With
Perchlorate
87 2002 In Utero Thuett, Strategic Animal Experimental Dose and Adverse
and et al. effects to
Lactational Environmental design duration development
Exposure to and Research indicated.
Ammonium Development
Perchlorate Program
in
Drinking
Water:
Effects on
Developing
Deer
Mice at
Postnatal
Day 21
Appendix III
Perchlorate Health Risk Studies Published
Since 1998
(Continued From Previous Page)
Author's
findings/
conclusions
about the
adverse
effects
Publica- of
Sponsor/ Subject Design perchlorate
Study Author Design controls on health
tion year title Recipient description type
88 2002 Effects of In Utero and Lactational Ammonium Perchlorate Exposure
On Thyroid Gland Histology and Thyroid Sex Hormones in Developing Deer
Mice (Peromyscus Maniclatus) Through Postnatal Day 21
Thuett Strategic Animal Experimental Dose and
Environmental design breeding pairs
and Research (analysis with
Development paired groups
Program and individual
pups)
Nonadverse effects indicated. Adverse effects to development indicated.
Iodide Harrison,
89 Since Transport et Howard Amphibian Experimental Dose Effects not
in
1998 Xenopus al. Huges design studied.
Laevis
(precise Gut and Medical
Skin
year Institute and
unknown) Texas Tech
University
90 2004 Ammonium McNabb, Birds Dose and Nonadverse
et Strategic Experimental
Perchlorate al. Environmental design duration effects
Effects indicated.
on Thyroid Research and No
information
Function Development available on
and
Growth In Program adverse
Bobwhite developmental
Quail
Chicks effects.
Source: GAO review of publicly available studies on perchlorate health
effects.
Note: For the purposes of this study, we have categorized nonadverse
effects as including, for example, transitional changes in thyroid
hormones from perchlorate exposure. We have categorized adverse effects as
including, for example, adenomas, increased thyroid or organ weights,
follicular cell hypertrophy and hyperplasia, and changes in brain
structure of developing subjects resulting from perchlorate exposure.
(Lists are not inclusive of all criteria.)
Appendix IV
Summary of Certain Environmental Laws and Regulations
The Resource Conservation and Recovery Act
The Resource Conservation and Recovery Act (RCRA) was enacted as an
amendment to the Solid Waste Disposal Act to create a framework for the
management of hazardous and nonhazardous solid waste. It authorizes EPA to
control hazardous waste from the point where waste is generated through
its transportation, treatment, storage, and disposal. EPA regulations
define hazardous waste to include waste specifically listed in the
regulation as well as those defined as "characteristic waste."
Characteristic hazardous waste is defined as waste that is ignitable,
corrosive, reactive, or toxic. A federal district court in California
ruled, in part, that perchlorate is a hazardous waste under RCRA because
it is ignitable, under certain conditions.1
RCRA requires owners and operators of facilities that treat, store, and
dispose of hazardous waste, including federal agencies, to obtain permits
specifying how they will safely manage waste. Under RCRA's corrective
action provisions, facilities seeking or holding RCRA permits can be
required to clean up their hazardous waste contamination. Under RCRA, EPA
has the authority to order a cleanup of hazardous waste when there is an
imminent and substantial endangerment to public health or the environment.
EPA may authorize states to administer their own programs in lieu of the
federal program, as long as these programs are equivalent to and
consistent with the federal program and provide for adequate enforcement.
Under RCRA, state agencies have required RCRA permit holders to sample for
and report on perchlorate detections and prevent additional releases.
Comprehensive Environmental Response, Compensation, and Liability Act
The Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA), commonly known as Superfund, governs the cleanup of releases or
threatened releases of hazardous substances, pollutants, or contaminants.
CERCLA's definition of a hazardous substance includes substances regulated
under various other environmental laws, including RCRA, the Clean Air Act,
the Clean Water Act, and the Toxic Substances Control Act. Under section
120 of CERCLA, the federal government is
1Castaic Lake Water Agency v. Whittaker Corp, 272 F. Supp. 2d 1053 (C.D.
Cal. 2003). The conclusion that perchlorate is a hazardous waste was the
first step in the court's analysis of whether perchlorate is a hazardous
substance under the Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA). (The definition of hazardous substances under
CERCLA includes hazardous waste under RCRA.)
Appendix IV
Summary of Certain Environmental Laws and
Regulations
subject to and must comply with CERCLA's requirements to the same extent
as any nongovernmental entity. CERCLA provides broad authority to EPA to
respond to releases or threatened releases of hazardous substances or
pollutants or contaminants that may endanger public health or the
environment. Under these provisions, DOD has responded to perchlorate
found on military installations and facilities. CERCLA establishes
prohibitions and requirements for contaminated sites; provides for the
liability for hazardous substances at these sites; and provides for the
use of the Hazardous Substances Superfund, a trust fund to provide for
cleanup, for example, when a responsible party cannot be identified. The
law authorizes short-term removal-where actions may be taken to address
releases or threatened releases requiring prompt response-and long-term
response-where actions may be taken to permanently reduce the danger
associated with a release. EPA identifies the most hazardous sites, those
requiring long-term action, by listing them on the National Priorities
List.
The Clean Water Act The Clean Water Act authorizes EPA to regulate the
discharge of pollutants into waters of the United States. EPA may
authorize states to carry out a state program in lieu of the federal
program if the state program meets the requirements of the Clean Water
Act, including providing for adequate enforcement. The act defines a
pollutant to include virtually all waste material. The act provides for
the establishment of national discharge limitations, water quality
standards, and a permit program and has provisions for addressing oil and
toxic substance spills. Covered private parties as well as federal
facilities must comply with the requirements of the act. According to EPA,
since pollutants are defined broadly in the act to include most waste
material, perchlorate would likely fall within this definition.
Under the Clean Water Act's National Pollution Discharge Elimination
System (NPDES) program, facilities discharging pollutants into waters of
the United States from point sources are required to obtain an NPDES
permit from EPA or authorized states. NPDES permits include specific
limits on the quantity of pollutants that may be discharged and require
monitoring of those discharges to ensure compliance. Industrial,
municipal, and other facilities must obtain permits to discharge specific
pollutants if their discharges go directly to waters of the United States.
Sites with NPDES permits are required to routinely sample and report to
state regulatory agencies on the release of specified pollutants, which
may include contaminants such as perchlorate.
Appendix IV
Summary of Certain Environmental Laws and
Regulations
The Federal Facility Compliance Act
Under section 107 of the Federal Facility Compliance Act of 1992,2 EPA was
required, in consultation with DOD and the states, to issue a rule
identifying when military munitions become hazardous waste under RCRA and
to provide for protective storage and transportation of that waste. Under
the rule issued by EPA, used or fired military munitions become waste
subject to RCRA regulation if, among other things, (1) they are
transported off-range for waste management purposes or (2) they or their
constituents are recovered, collected, and then disposed of by burial on
or off a range.3 Unexploded, used, and fired military munitions are known
sources of perchlorate. Under RCRA, as amended by the Federal Facility
Compliance Act, EPA maintains that DOD installations may be required to
sample and monitor off-range for perchlorate as well as other contaminants
associated with military munitions where EPA has evidence that the
contaminants are creating an imminent and substantial endangerment to
health or the environment.
The Safe Drinking Water Act
The Safe Drinking Water Act authorizes EPA to issue national primary
drinking water regulations setting maximum contaminant-level goals and
maximum contaminant levels for drinking water that must be met by public
water systems.4 EPA may authorize states to carry out primary enforcement
authority for implementing the Safe Drinking Water Act if, among other
things, the states adopt drinking water regulations that are no less
stringent than the national primary drinking water regulations. EPA has
set standards for approximately 90 contaminants in drinking water;
however, most of the more than 200 chemical contaminants associated with
munitions use, including perchlorate, are currently unregulated under the
Safe Drinking Water Act.5
2Section 107 of the Federal Facility Compliance Act of 1992 amended RCRA
by adding a new section 3004(y), codified at 42 U.S.C. S: 6924(y) (2004).
340 C.F.R. 266.202 (2004).
4A public water system is subject to the Safe Drinking Water Act if the
system has at least 15 service connections or regularly serves at least 25
individuals.
5The Safe Drinking Water Act regulates ammonium nitrate, benzene, cadmium,
chromium, and lead-constituents commonly found in munitions.
Appendix IV
Summary of Certain Environmental Laws and
Regulations
The 1996 amendments to the Safe Drinking Water Act required EPA to (1)
establish criteria for a monitoring program for unregulated contaminants,
where a maximum contamination level has not been established, and (2)
publish a list of contaminants chosen from those not currently monitored
by public water systems. EPA's regulation, referred to as the Unregulated
Contaminant Monitoring Regulation, was issued in 1999 and supplemented in
2000 and 2001.6 The purpose of the regulation was to determine whether a
contaminant occurs at a frequency and in concentrations that warrant
further analysis and research on its potential effects, and to possibly
establish future drinking water regulations. The first step in the most
recent program required public water systems serving more than 10,000
customers-and a sample of 800 small public water systems serving 10,000 or
fewer customers-to monitor drinking water for perchlorate and 11 other
unregulated contaminants over a consecutive 12-month period during 2001
and 2003 and to report the results to EPA. According to EPA, large public
water systems provide drinking water to about 80 percent of the U.S.
population served by public water systems.
640 C.F.R. 141.40.
Appendix V
Comments from the Environmental Protection Agency
Appendix V
Comments from the Environmental
Protection Agency
Appendix VI
Comments from the Department of Defense
Appendix VI
Comments from the Department of Defense
Appendix VII
GAO Contacts and Staff Acknowledgments
GAO Contacts John B. Stephenson (202) 512-3841 Edward Zadjura (202)
512-9914
Staff In addition to the individuals named above, John Delicath,
Christine Frye, Alan Kasdan, Karen Keegan, Roderick Moore, Edith Ngwa,
James Rose,
Acknowledgments and Rebecca Shea made key contributions to this report.
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