RE: [CPEO-MEF] New Perchlorate Policy

[CPEO Moderator <cpeo@cpeo.org>]

[The following reply was posted by an anonymous federal official.]


Good analysis. I also see another glaring shortcoming in the policy. It
does not address where you would most likely will find perchlorate,
therefore you don't have a starting basis for your analysis. Absent of
that, it will require some type of historical operations review,
assuming you know what you are looking for. My experience to date is
that records review performed by most installations in the early 80s (as

well as by EPA) did not have standards for performing this effort. As a
result, many of the early preliminary assessments were not very
thorough, and are particularly weak in relating operational history with

the potential for releases.

When one couples that with the fact of new chemicals coming to the
forefront of concern today (some 2 decades later), which were not even
looked at during those initial preliminary assessments, you certainly
have a major DATA GAP. I see this as a large looming issue that does not
seem to be addressed from a big policy and procedure standpoint. When
you look at it this way you would then need to balance the cost of doing
that versus just going out and doing the sampling within the sampling
networks already in existence. My feeling is you could gain a quicker
understanding regarding the contaminant by doing that and then targeting

your records and operational history review where you need to. Finally,
when will a process be set up that looks at more than just a single
contaminant of the day? Others are heading down the pipeline as well
(i.e. 1-4 Dioxane, Arsenic, etc), will we continue to be reactive to
these things. Over time I believe the current approach will erode the
publics confidence that we even know what it means to say, "is
protective of public health and the environment"....

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~