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Department of the Air Force

Guidance for Addressing Perchlorate Sampling


December 2003

1. This guidance implements and supplements the DoD Interim Policy on Perchlorate Sampling
issued on 29 September 2003. The purpose of this guidance is to provide a consistent framework
for addressing perchlorate sampling resulting from ongoing activities as well as past practices.
This guidance applies to Air Force active (including Reserve/Air National Guard) installations
located within the United States and its territories under the Environmental Protection Agency
(EPA) jurisdiction.

2. This guidance outlines:


a. Internal Air Force requirements for ascertaining potential perchlorate contamination
resulting from DoD activities at all eligible defense sites that have federal missions.
b. Guidelines for determining the existence of a potential human-health exposure pathway.
c. Guidelines for conducting sampling, where justified, prior to promulgation of a federal
health-based standard.
d. Guidelines for reporting data (i.e., office will receive/compile all reporting requirements).

3. The Air Force will adhere to, and comply with, any federal legal requirement to sample,
assess, or otherwise investigate suspected perchlorate contamination. The Air Force will comply
with any properly promulgated state legal requirement to sample, assess, or otherwise investigate
suspected perchlorate contamination to the extent that Congress has clearly and unambiguously
authorized a waiver of sovereign immunity for this purpose. The Commander of active
installations will determine, in consultation with legal counsel, if any federal, state or local
statutes and/or regulations are applicable to the installation. Perchlorate sampling required by
federal, state, or local laws and regulations should be implemented, to the extent possible,
consistent with the guidance below, to include the data reporting.

4. In the absence of an applicable legal driver, Air Force may address possible perchlorate
contamination if all the following conditions are satisfied:

a. A reasonable basis exists to suspect a potential release of perchlorate that is associated


with DoD activities at the installation,
b. A pathway exists for the potential contamination to threaten public health, and
c. SAF/IEE provides Authorization.

5. Determining the potential for perchlorate contamination: Installations may have the potential
for perchlorate contamination if the installation has a history of perchlorate use. This includes
the following:
a. Manufacture of missiles, rockets, and/or munitions containing perchlorate;
b. Using perchlorate-containing munitions for testing or training purposes;

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c. Demilitarizing perchlorate-containing munitions, such as performing hog-out of rockets
and missiles containing solid propellant or conducting open burn/open detonation (OB/OD)
operations; or
d. Using perchlorate-containing missiles/rockets in launch operations.

Note: Information on munitions containing perchlorate is available on the Defense


Environmental Network Information Exchange (DENIX): https://www.denix.osd.mil. To the
extent possible, information should be gleaned on the perchlorate related activity, intensity of
activity and likelihood of a perchlorate release.

The installation commander is responsible for determining current and historical uses of
perchlorate-related activities for installation and tenant activities.

6. Determining Potential Pathways for Perchlorate Presence: The public may encounter
perchlorate contamination in the environment through exposure to groundwater, surface water,
soil, or sediment. Perchlorate may reach human receptors via several pathways. To determine
whether a pathway exists, Air Force installations shall do the following:

a. Determine if there is any drinking water source that may be impacted by groundwater or
surface water on or leaving the site.
b. Determine if any drinking water systems on or near the defense site have been sampled
for perchlorate or if perchlorate has otherwise been detected. Most drinking water system
can be found listed in the EPA Unregulated Contaminants database at
http://www.epa.gov/ogwdw000/data/ucmrgetdata.html.
c. Determine through personal knowledge/interviews and record searches if any soil or
sediment potentially contaminated with perchlorate is being used for fill material, topsoil,
or other uses that may threaten public health.
d. Review relevant information provided by personnel as well as existing documentation of
environmental and/or hydrogeological investigations performed at the installation.
e. Work with regulators and the public, as appropriate, to identify potential exposure
scenarios and pathways.

Note: The active installation Surgeon General office (bioenvironmental engineer) should be the
final authority for determining the pathway existence.

7. Conflict Resolution: Should the public or regulator disagree with the Air Force about
potential perchlorate contamination and/or possible exposure routes, the issue should be elevated
for resolution to SAF/IEE through HQ USAF/ILEV.

8. Public Affairs: All communication with the public and/or the media regarding potential or
confirmed perchlorate contamination shall be reviewed and approved prior to release by the Air
Force public affairs entity responsible for the installation in question. The responsible public
affairs entity shall furnish a copy of this information to the SAF/PAM, public affairs Point of
Contact (POC) for perchlorate.

9. If an installation commander determines sampling is required, then the following must occur:

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a. For active installations a written plan shall be developed that describes:
(1.) Reasons for suspecting the perchlorate contamination.
(2.) Potential human-health receptors and pathways leading to them.
(3.) Sampling locations, frequency, and rationales.
(4.) Analytical method to be used for sample analysis.

b. Laboratory Analysis: The laboratory must analyze for perchlorate using an appropriate
analytical method, currently only EPA Method 314.0 is approved. The Air Force
Institute for Occupational Health (AFIOH/RSR) will provide any updates to approved
analytical methods. AFIOH/SDC will perform all the Quality Assurance/Quality Control
(QA/QC) requirements. The laboratory shall comply with the DoD Quality Systems
Manual for Environmental Laboratories. The method detection limit (MDL) must be
lower than the reporting limit. The reporting limit must be at or below the lowest action
level. The reporting level cannot be lower than the lowest standard of the calibration
curve. If there is a positive result, the result must be confirmed by a liquid
chromatography tandem mass spectrometry (LC/MS/MS) analysis.

c. Laboratory Selection: The installation shall choose a laboratory from an approved list
developed by AFIOH/SDC. The laboratory shall have a quality system that meets the
requirements of the International Organization for Standardization (ISO) Standard 17025.
The laboratory should be accredited in the National Environmental Laboratory
Accreditation Program (NELAP).

d. If regulators want to sample: The regulator should make their request in writing and
outline what will be done if perchlorate is found. If the regulating agency is conducting
the sampling, the installation should collect and analyze split-samples in accordance with
the protocols outlined in subparagraph b. Additionally, the appropriate chain of
command shall be notified. Actions shall be coordinated through the chain of command
and notify the appropriate Air Force Center for Environmental Excellence (AFCEE)
Regional Environmental Office (REO) prior to sampling.

Review of Plan: All plans must be coordinated prior to implementation with U.S. Air Force
Legal Services Agency, Environmental Law Division (AFLSA/JACE) who will coordinate with
Office of Secretary of Defense POCs.

10. Final Authorization:

a. Perchlorate Sampling Approval and Authorization: All requests for perchlorate sampling
at active installations shall be made in writing through the chain of command to SAF/IEE
by the installation commander. The written requests shall provide justification by
detailing why sampling is necessary, as outlined above and be copied to the appropriate
AFCEE REO. The decisions can be made by the MAJCOMs after EPA promulgates an
MCL.

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b. Responses: If regulators are requiring a response action to address perchlorate, the
installation will immediately notify SAF/IEE through the chain of command and copy the
local REO for direction on how to answer such request. The regulator should make their
request in writing and outline what will be required. The MAJCOM, with the appropriate
AFCEE REO, may work with the regulators to resolve the requirement before forwarding
to SAF/IEE.

11. Reporting: Results of previous and current perchlorate sampling must be provided to the
MAJCOM/CEVR for active installations. The attached spreadsheet is to be completed at a
minimum and forwarded to HQ USAF/ILEVR whenever requested, because it will be used to
update Office of Secretary of Defense POCs.

The following information shall be provided:


Installation name.
Media sampled.
Date sampled.
Location of sample.
Important, a description that would allow re-identification of the sampling point.
If available, Lat/long coordinates detailing a sample location.
Activity associated with sample location (i.e., OB/OD, production facility, etc.)
(Note: Specifically state if the sample was obtained from an operational training range
and/or there is cause to believe a detection is the result of current training activities.)
Level found/analytical method.
Point of Contact (POC).

12. Installations/MAJCOMs are encouraged to contact and coordinate with the following Air
Force POCs for Perchlorate Issues:

AFMSA/SGZE -- Maj T. Mukoda, (202) 767-4327, Timothy.Mukoda@pentagon.af.mil


SAF/IEE -- Lt Col J. Cornell, (703) 693-7705, Jeffrey.Cornell@pentagon.af.mil
HQ USAF/ILEVR -- Mr. D Carrillo, (703) 604-0561, David.Carrillo@pentagon.af.mil
HQ AFCEE/CCR-A -- Mr David Bretzel, (404) 563-4200, David.brentzel@brook.af.mil
HQ AFCEE/CCR-D -- Mr Ike Heise, (214) 767-4653, Ike.heise@brooks.af.mil
HQ AFCEE/CCR-S -- Mr Robert Lowery, (415) 977-8881, Robert.lowery@brooks.af.mil
SAF/PAM -- Ms. M. Miclat, (703) 693-9091, Marriane.Miclat@pentagon.af.mil
AFLSA/JACE -- Maj S. Sinay, (703) 696-8507, Sandra.Sinay@pentagon.af.mil

This guidance is effective until promulgation of a federal regulatory standard, or until the Office
of the Secretary of Defense provides further guidance, whichever occurs first.