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)

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                                    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)

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                                    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)

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                                    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)

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                                    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)

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                                    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)

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                                    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)

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                                    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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