Unregulated and Emerging Contaminants JSEM August 2004 Unregulated

Unregulated and Emerging Contaminants JSEM August 2004

Unregulated and Emerging Contaminants JSEM August 2004 1

What are they? n Unregulated Contaminants Monitoring Rule – Perchlorate – DNT – RDX 2

What are they? n. New set standards being –TCE and Naphthalene inhalation 3

What are they? n. Emerging issues –Nanomaterials 4

Other U&EC w/ Relevancy to Do. D n n n n 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 CL 20 5

Do. D’s U&EC Challenges U&EC issues generate uncertainties and strains resources and impacts Do. D mission accomplishment by affecting: n Acquisition n Research, and development investments n Operations n Readiness and range management n Occupational health and safety n Environmental management (compliance & clean-up) 6

High Recognition of the U&EC Issues n 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) n Congressional Interest remains high n n n – Letters – Legislation: Appropriations and Authorization 7

Perchlorate: the U&EC Poster Child n Fundamental information is lacking; Interpretation is a challenge n Science processes need improvement n Community concern drives issues n Engagement early at appropriate levels n Funding n Authority questions raised n Policy practices need to be put in place Cross cutting nature lack of ownership management challenges n 8

Perchlorate issues n Vital to mission accomplishment – Stable oxidant used in training and field – Not unique to Do. D, but Do. D large consumer Water supply q/q link & droughts n Do. D as deep pockets n 9

Perchlorate Science Issues n Detection Methodology – False positives – Used for other than drinking water Controversy over Health Risk n Determining sources and responsibility n Costly technical remediation solutions n 10

Perchlorate & other recent adventures with U&EC demonstrate larger issues n 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 Rf. Ds and guidelines used by states to promulgate regulation in advance of risk assessment process n Data Quality Act – Accurate and defensible reporting n Cost not a persuasive argument 11

Types of Issues Posed by U&EC Legacy Current Future Mission Critical Valuable Clean up Costs 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. 12

Not Every U&EC will be an issue to Do. D; not all issues will be the same size n n n n Is it vital to Do. D mission accomplishment? Will its regulation change the way we do business? To what effect? Is it unique to Do. D? Is it, was it, might it be widely used by Do. D? Equally effective substitutes readily available? Where are they? Widespread? Conditions at site? Potential exposure risk to health and environment? 13

Coordinating U&EC Issues Will n Identify upcoming issues and their relevance and impact to military readiness and program execution. n Minimize disruption of ongoing operations. n Develop robust, consistent information and data management approaches. n Integrate, support and promote targeted science and technology. 14

Outcomes of Focused Energy n Resource Planning & Integration n Improve mission performance and reduce costs 15

How Are We Going to Do That? n Risk Identification – Early warning; – Advanced characterization n Sources, activities, and places at risk – Improve science of risk assessment 16

How Are We Going to Do That? n Risk Management – Reduce risks – Provide solutions – Increase confidence, flexibility, cooperation 17

How Are We Going to Do That? Think Leverage Bridge gaps Look Forward & act Communicate Find solutions Integrate Listen Coordinate Synergize Team Work 18

Near Term Products n Identify – contaminants or chemicals that merit evaluation or review. n 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. n Prioritize – based on the characterization, contaminants or issues requiring action by key decision makers. n Share and Coordinate – Establish mechanisms to share this knowledge with the appropriate decision makers for further consideration and action. 19

Policies & Practices for Implementation n OSD September 2003 Sampling policy – Release – Human exposure n n n California Sampling Prioritization Protocol ITRC – expanding and expediting approvals of new technologies Catalyzing partnerships to test & demo technologies 20

Guiding Philosophies n Sustainability n Transparency n Accountability n Responsibility – Ensure sustainable ranges; Mission accomplishment; Human health; Relationships – Prompt notification, explanation, – Accomplishments – Ensure robust science, quality data, solid interpretation – Cost effective actions – Informed decisionmaking and action – Maintain and enhance our credibility 21

What we’re not going to do… 22