Unregulated and Emerging Contaminants

1. Unregulated and Emerging Contaminants JSEM August 2004

2. Unregulated and Emerging Contaminants JSEM August 2004

3. What are they? • Unregulated Contaminants Monitoring Rule • Perchlorate • DNT • RDX

4. What are they? • New standards being set • TCE and Naphthalene inhalation

5. What are they? • Emerging issues • Nanomaterials

6. Other U&EC w/ Relevancy to DoD • Polybrominated Diphenyl Ethers (PBDEd) • Hexavalent Chromium (Cr VI) • N-Nitrosodimethylamine (NDMA) • Methyl tertiary-butyl ether (MTBE) • 1,4 Dioxane • 1,2,3 – Trichloropropane • Tungsten alloys • CL20

7. DoD’s U&EC Challenges U&EC issues generate uncertainties and strains resources and impacts DoD mission accomplishment by affecting: • Acquisition • Research, and development investments • Operations • Readiness and range management • Occupational health and safety • Environmental management (compliance & clean-up)

8. High Recognition of the U&EC Issues • USD memo on range sustainability provides overarching guidance (6/03) • Sampling policy (9/03) • Hired executive and Sr. Scientist to address issues fulltime (3/04) • SROC (5/04) • Congressional Interest remains high • Letters • Legislation: Appropriations and Authorization

9. Perchlorate: the U&EC Poster Child • Fundamental information is lacking; Interpretation is a challenge • Science processes need improvement • Community concern drives issues • Engagement early at appropriate levels • Funding • Authority questions raised • Policy practices need to be put in place • Cross cutting nature lack of ownership management challenges

10. Perchlorate issues • Vital to mission accomplishment • Stable oxidant used in training and field • Not unique to DoD, but DoD large consumer • Water supply q/q link & droughts • DoD as deep pockets

11. Perchlorate Science Issues • Detection Methodology • False positives • Used for other than drinking water • Controversy over Health Risk • Determining sources and responsibility • Costly technical remediation solutions

12. Perchlorate & other recent adventures with U&EC demonstrate larger issues • Science Process-Policy Interface • When/how are stakeholders appropriately involved in science-based decisions that have policy ramifications • Role and timing of peer review • EPA’s RfDs and guidelines used by states to promulgate regulation in advance of risk assessment process • Data Quality Act • Accurate and defensible reporting • Cost not a persuasive argument

13. Legacy Current Future Mission Critical Valuable Clean up Costs Monitoring Monitoring, Management Early ID of potential contaminants Trade offs Management or containment Clean up Full knowledge of risk of use. True Life cycle costs build in. Life cycle “Taxes” Clean up Substitution Avoidance or substitution, where possible. Types of Issues Posed by U&EC

14. Not Every U&EC will be an issue to DoD; not all issues will be the same size • Is it vital to DoD mission accomplishment? • Will its regulation change the way we do business? To what effect? • Is it unique to DoD? • Is it, was it, might it be widely used by DoD? • Equally effective substitutes readily available? • Where are they? Widespread? Conditions at site? • Potential exposure risk to health and environment?

15. Coordinating U&EC Issues Will • Identify upcoming issues and their relevance and impact to military readiness and program execution. • Minimize disruption of ongoing operations. • Develop robust, consistent information and data management approaches. • Integrate, support and promote targeted science and technology.

16. Resource Planning & Integration Improve mission performance and reduce costs Outcomes of Focused Energy

17. How Are We Going to Do That? • Risk Identification • Early warning; • Advanced characterization • Sources, activities, and places at risk • Improve science of risk assessment

18. How Are We Going to Do That? • Risk Management • Reduce risks • Provide solutions • Increase confidence, flexibility, cooperation

19. How Are We Going to Do That? Think Bridge gaps Leverage Look Forward & act Communicate Find solutions Integrate Listen Coordinate Synergize Team Work

20. Identify contaminants or chemicals that merit evaluation or review. Characterize the nature of identified issues better understand impacts on military mission (including costs), health, and environmental quality due to new or pending regulatory changes, new scientific information. Prioritize based on the characterization, contaminants or issues requiring action by key decision makers. Share and Coordinate Establish mechanisms to share this knowledge with the appropriate decision makers for further consideration and action. Near Term Products

21. Policies & Practices for Implementation • OSD September 2003 Sampling policy • Release • Human exposure • California Sampling Prioritization Protocol • ITRC – expanding and expediting approvals of new technologies • Catalyzing partnerships to test & demo technologies

22. Guiding Philosophies • Sustainability • Ensure sustainable ranges; Mission accomplishment; Human health; Relationships • Transparency • Prompt notification, explanation, • Accomplishments • Accountability • Ensure robust science, quality data, solid interpretation • Cost effective actions • Responsibility • Informed decisionmaking and action • Maintain and enhance our credibility

23. What we’re not going to do…