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 

GAO-05-462


a
May 2005 

PERCHLORATE 

A System to Track Sampling and Cleanup 

Results Is Needed 

Why GAO Did This Study 

Highlights 

Accountability Integrity Reliability 

www.gao.gov/cgi-bin/getrpt?GAO-05-462. 

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact John B. 

Stephenson at (202) 512-3841 or 

stephensonj@gao.gov. 

Highlights of GAO-05-462, a report to the 

Chairman, Subcommittee on Environment 

and Hazardous Materials, House 

Committee on Energy and Commerce 

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. chlorate 

has been found in drinking water, 

groundwater, surface water, and 

soil in the United States. he 

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. 

What GAO Recommends 

GAO recommends that EPA work 

with federal agencies and the states 

to establish a structure to track and 

monitor perchlorate detections and 

cleanup efforts. 

EPA agreed with our findings but 

DOD did not. ther agency 

agreed with our recommendation. 

GAO believes its findings are 

sound; further, DOD’s citation of 

sites not on EPA’s list underscores 

the need for this recommendation. 

Per

T

Nei

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 

Appendix II: Facilities and Sites Where Perchlorate Was Found and 

Concentration Levels, as of January 2005 29 

Appendix III: Perchlorate Health Risk Studies Published Since 1998 45 

Appendix IV: Summary of Certain Environmental Laws and Regulations 66 

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 Agency 70 

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


Page i GAO-05-462 Perchlorate 
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 

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reproduce this material separately. 

Page ii GAO-05-462 Perchlorate 
Page 1 GAO-05-462 Perchlorate 

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. 

Page 1 GAO-05-462 Perchlorate 
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 

Page 2 GAO-05-462 Perchlorate 
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 

Page 3 GAO-05-462 Perchlorate 
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 

Page 4 GAO-05-462 Perchlorate 
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. 

Page 5 GAO-05-462 Perchlorate 
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 

1

Although 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. 

Page 6 GAO-05-462 Perchlorate 
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, 

2

Previously, 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. 

3

Hypothyroidism 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. 

Page 7 GAO-05-462 Perchlorate 
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 

Page 8 GAO-05-462 Perchlorate 
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 

Page 9 GAO-05-462 Perchlorate 
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 

4

Sampling for perchlorate was required under this regulation between 2001 and 2003 (see 

app. IV). 

5

Edwards 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. 

6

GAO, 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). 

Page 10 GAO-05-462 Perchlorate 
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). 

Page 11 GAO-05-462 Perchlorate 
Page 12 GAO-05-462 Perchlorate

Figure 1: aximum Perchlorate Concentrations Reported in any Media and Number of Sites, January 2005

AZ

17

MD

8

NY

13

WV

1

TX

118

MO

2

UT

8

KY

SD

WY

NM

12

MA

2

OR

4

WI

CA

106

CT

1

IL

5

Northern

Mariana

Islands

1

MT ND

KS 

2

AR

4

AL

7

NV

6

VA

4

DC

2

PR

1

NJ

NE 8

3

MS 

1

LA

2

IA

4

MI

OH

9

PA

6

GA

3

OK

5

Sources: Environmental Protection Agency, Department of Defense, U.S. Geological Survey, and state environmental agencies.

MN

2

NC

7

SC

4

AK

HI

ME

NH

VT

DE

MI

TN

2

CO

2

WA

5

FL

6

ID

IN

2

No perchlorate reported

Between 4 - 100 parts per billion

Between 4 - 1,000 parts per billion

Between 4 - 5,000 parts per billion

Between 4 - 100,000 parts per billion

Between 4 - 500,000 parts per billion

From 4 to over 500,000 parts per billion

Detection level

M
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 

10% 

21% 

65% 

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 

Page 13 GAO-05-462 Perchlorate 
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 

Page 14 GAO-05-462 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. 

Page 15 GAO-05-462 Perchlorate 
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: 

•	 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. 

•	 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. 

•	 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: 

Page 16 GAO-05-462 Perchlorate 
•	 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. 

•	 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. 

•	 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. 

•	 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: 

•	 Nevada is requiring Pepcon, a former perchlorate manufacturing site, to 

install a cleanup system to remove perchlorate from groundwater. 

•	 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. 

•	 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. 

Page 17 GAO-05-462 Perchlorate 
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: 

•	 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. 

•	 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. 

•	 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. 

Page 18 GAO-05-462 Perchlorate 
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, 

Page 19 GAO-05-462 Perchlorate 
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. 

7

Pub. L. No. 108-375, § 318, 118 Stat. 1811, 1845 (2004). 

Page 20 GAO-05-462 Perchlorate 
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 

Page 21 GAO-05-462 Perchlorate 
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, 

8

The 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. 

Page 22 GAO-05-462 Perchlorate 
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. 

Page 23 GAO-05-462 Perchlorate 
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. 

Page 24 GAO-05-462 Perchlorate 
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. 

Page 25 GAO-05-462 Perchlorate 
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 

Page 26 GAO-05-462 Perchlorate 
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 

Page 27 GAO-05-462 Perchlorate 
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. 

Page 28 GAO-05-462 Perchlorate 
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 

AL Anniston Army Depot, Calhoun County 11 Groundwater 

AL Atmore Utility Board, Escambia County 9 Drinking water 

AL Daphne Utilities Board, Baldwin County 7 Drinking water 

AL Fort McClellan, City of Anniston 32 Soil 

AL Mobile County Water and Fire Protection 6 Drinking water 

Authority, Mobile County 

AL Montgomery Water Works, Montgomery 11 Drinking water 

County 

AL Redstone Army Arsenal (NASA Marshall 220,000 Groundwater 

Space Flight Center) 12,200 Surface water 

280 Soil 

AR Aerojet (Formerly Atlantic Research 2,708,700 Soil 

Corporation), City of East Camden 12,500 Surface water 

AR Hickory Ridge Cross County Rural Water 6 Drinking water 

System, Cross County 

AR Hot Springs Waterworks, Garland County 7 Drinking water 

AR Schumaker Naval Ammunition Depot, City of 850 Groundwater 

Camden 

AZ Aerodyne Gila River Indian Reservation, City 18 Groundwater Planning 

of Chandler 

AZ Apache Nitrogen Products (formerly known as 670 Groundwater Planning 

Apache Powder Company), City of Benson 

AZ Brook Water Company, La Paz County 6 Drinking water 

AZ Camp Navajo, City of Bellemont 39 Surface water 

AZ Chaparral City Water Company, Maricopa 6 Drinking water 

County 

17 AZ City of Mesa, Maricopa County 7 Drinking water 

18 AZ Far West Water Company, City of Yuma 4 Drinking water 

19 AZ Fort Huachuca, Cochise County 27,000 Soil 

20 AZ Glendale Municipal Water Company, Maricopa 6 Drinking water 

County 

21 AZ Phoenix Municipal Water System, Maricopa 5 Drinking water 

County 

22 AZ Scottsdale Municipal Water, Maricopa County 7 Drinking water 

23 AZ Tucson Water Dept Municipal, Pima County 12 Drinking water 

24 AZ Unidynamics/Phoenix Goodyear Airport, City 80 Groundwater Planning 

of Goodyear 30 Drinking water 

Page 29 GAO-05-462 Perchlorate 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 
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 

AZ Universal Propulsion Company, Incorporated, 130 Groundwater Planning 

City of Phoenix 

AZ Yuma Marine Corps Air Station, City of Yuma 150 Soil 

4 Drinking water 

5 Surface water 

AZ Yuma Municipal Water Department, Yuma 6 Drinking water 

County 

AZ Yuma Proving Ground, City of Yuma 5 Surface water 

CA Aerojet General, City of Chino Hills 877 Groundwater 

CA Aerojet General, City of Rancho Cordova 640,000 Groundwater Under way 

260 Drinking water 

CA Air Force Research Laboratory, Edwards Air 4,550 Groundwater Under way 

Force Base, Kern County 

CA Alpha Explosives, City of Lincoln 67,000 Groundwater 

CA Azusa Light and Water, Los Angeles County 11 Drinking water 

CA Beale Air Force Base, Yuba County 492 Groundwater 

CA California State Polytechnical University - 6 Drinking water 

Pomona, Los Angeles County 

CA California Water Service Company - 9 Drinking water 

Dominguez, Los Angeles County 

CA California Water Service Company - ELA, Los 8 Drinking water 

Angeles County 

CA California Water Service Company - Salinas, 22 Drinking water 

Monterey County 

CA California Water Service Company - Stockton, 5 Drinking water 

San Joaquin County 

CA California Water Service Company - Suburban 5 Drinking water 

Los Altos, Santa Clara County 

41 CA Carmichael Water District, Sacramento 4 Drinking water 

County 

42 CA Casmalia Resources, City of Casmalia 58 Groundwater 

43 CA China Lake Naval Weapons Center, Kern 921 Groundwater 

County 

44 CA City of Anaheim, Orange County 5 Drinking water 

45 CA City of Bakersfield, Kern County 8 Drinking water 

46 CA City of Brawley, Imperial County 5 Drinking water 

47 CA City of Chino, San Bernardino County 21 Drinking water 

48 CA City of Chino Hills, San Bernardino County 4 Drinking water 

49 CA City of Colton, San Bernardino County 8 Drinking water 

Page 30 GAO-05-462 Perchlorate 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 
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 

CA City of Corona, Riverside County 12 Drinking water 

CA City of Escondido, San Diego County 4 Drinking water 

CA City of Garden Grove, Orange County 4 Drinking water 

CA City of Hemet, Riverside County 7 Drinking water 

CA City of Loma Linda, San Bernardino County 5 Drinking water 

CA City of Ontario, San Bernardino County 12 Drinking water 

CA City of Patterson, Stanislaus County 4 Drinking water 

CA City of Pomona, Los Angeles County 10 Drinking water 

CA City of Rialto, San Bernardino County 21 Drinking water 

CA City of Riverside, Riverside County 42 Drinking water 

CA City of San Bernardino, San Bernardino 7 Drinking water 

County 

CA City of Santa Ana, Orange County 4 Drinking water 

CA City of Stockton, San Joaquin County 19 Drinking water 

CA City of Tracy, San Joaquin County 21 Drinking water 

CA City of Tustin, Orange County 9 Drinking water 

CA Coachella Valley Water District, Cove 6 Drinking water 

Community, Riverside County 

66 CA Cucamonga Water District, San Bernardino 9 Drinking water 

County 

67 CA Denova Environmental, San Bernardino 460 Soil 

County 

68 CA Desert Water Agency, Riverside County 6 Drinking water 

69 CA East Valley Water District, San Bernardino 16 Drinking water 

County 

70 CA Eastern Municipal Water District, Riverside 8 Drinking water 

County 

71 CA El Centro Naval Air Facility, Imperial County 5 Drinking water 

72 CA El Toro Marine Corps Air Station, Orange 1,600 Soil 

County 460 Groundwater 

73 CA EMBEE, Incorporated, Orange County 1,900 Groundwater 

74 CA Fort Ord, Monterey County 35 Soil 

75 CA G.E. Plastics, Orange County 1,100,000 Groundwater 

76 CA Great Oaks Water Company, Incorporated, 4 Drinking water 

Santa Clara County 

77 CA Imperial Valley College, Imperial County 6 Drinking water 

78 CA Irvine Ranch Water District, Orange County 6 Drinking water 

Page 31 GAO-05-462 Perchlorate 

50 

51 

52 

53 

54 

55 

56 

57 

58 

59 

60 

61 

62 

63 

64 

65 
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 

CA Jet Propulsion Laboratory, Edwards Air Force 2,100,000 Soil 

Base, Kern County 160,000 Groundwater 

CA Jurupa Community, Riverside County 5 Drinking water 

CA Lawrence National Laboratories, Department 84 Groundwater Under way 

of Energy Experimental Site 300, City of Tracy 

CA Lincoln Avenue Water Company, Los Angeles 5 Drinking water 

County 

CA Lockheed Propulsion Company, City of 141,000 Groundwater Planning 

Beaumont 

CA Lockheed Propulsion Company (Former), City 87 Drinking water Under way 

of Redlands 

CA Mather Air Force Base, City of Rancho 1,900 Groundwater 

Cordova 120 Drinking water 

CA McClellan Air Force Base, Sacramento 15 Groundwater 

County 

CA McCormick, Selph (same as TDY industries), 5,500 Groundwater Under way 

City of Hollister 

CA McDonnell-Douglas and Aerojet Corporation, 32,000 Groundwater Under way 

City of Rancho Cordova 

CA Metropolitan Water Dist. of Southern 7 Drinking water 

California, Los Angeles County 

CA Monte Vista Water District, San Bernadino 4 Drinking water 

County 

CA Morris Dam Naval Command, Control and 65 Groundwater 

Ocean Surveillance Center, Los Angeles 

County 

CA MP Associates, Incorporated, City of Ione, 957,000 Soil 

Amador County 

CA NASA, Jet Propulsion Laboratory, City of 13,300 Drinking water Under way 

Pasadena 

CA National Semiconducter Corporation, Santa 120 Groundwater Under way 

Clara County 

95 CA National Technical Systems, Los Angeles 320 Soil 

County 

96 CA North Rialto Area (multiple responsible 820 Drinking water Under way 

parties), City of Rialto 

97 CA OEA Aerospace (formally Universal 350 Groundwater Planning 

Propulsion), Solano County 

98 CA Olin Safety Flare, City of Morgan Hill 1,000 Groundwater Under way 

15 Drinking water 

Page 32 GAO-05-462 Perchlorate 

79 

80 

81 

82 

83 

84 

85 

86 

87 

88 

89 

90 

91 

92 

93 

94 
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 

CA Pasadena Water Department, Los Angeles 35 Drinking water 

County 

100 CA Purity Oil Delta Gunnite, City of Rancho 13,000 Soil 

Cordova 

101 CA Pyrite Canyon, City of Glen Avon 2,100 Groundwater 

102 CA Rancho California Water District, Riverside 4 Drinking water 

County 

103 CA Redlands City Municipal Utility District-Water 67 Drinking water 

Division, San Bernardino County 

104 CA Riverside Highland Water Company, San 5 Drinking water 

Bernardino County 

105 CA Rubidoux Community Services District, 10 Drinking water Under way 

Riverside County 

106 CA San Fernando City Water Department, Los 9 Drinking water 

Angeles County 

107 CA San Fernando Valley (Area 2), City of 13 Groundwater 

Glendale 

108 CA San Gabriel Valley (Area 1), El Monte 21 Groundwater Planning 

Operable Unit, City of El Monte 

109 CA San Gabriel Valley (Area 2), Baldwin Park 2,180 Groundwater Under way 

Operable Unit, City of Baldwin Park 159 Drinking water 

110 CA San Gabriel Valley (Area 1), South El Monte 17 Groundwater Under way 

Operable Unit (Includes Nike 14 Launcher 

Area, City of South El Monte 

111 CA San Gabriel Valley (Area 4), Puente Valley 18 Groundwater Planning 

Operable Unit, City of Industry 

112 CA San Gabriel Valley Water Company, Fontana, 15 Drinking water 

San Bernadino County 

113 CA San Gabriel Water District, Los Angeles 4 Drinking water 

County 

114 CA Santa Clarita Site Assessment, Los Angeles 47 Drinking water 

County 

115 CA Santa Clarita Water Company, Los Angeles 4 Drinking water 

County 

116 CA Santa Susanna Field Laboratory, Boeing- 750 Groundwater Under way 

Rocketdyne Division (Department of Energy), 

Los Angeles County 

117 CA Seal Beach Naval Weapons Station, Orange 2,460 Soil 

County 

118 CA Sierra Army Depot, Lassen County 8 Groundwater 

119 CA Sonoma County Site Assessment 5 Drinking water 

Page 33 GAO-05-462 Perchlorate 

99 
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 

120 CA South California Water Company, Orange 6 Drinking water 

County 

121 CA South Pasadena City Water Department, Los 5 Drinking water 

Angeles County 

122 CA Special Devices Incorporated, City of Newhall, 82 Groundwater 

Los Angeles County 

123 CA Stringfellow Superfund Site, City of Glen Avon 87,000 Groundwater Planning 

124 CA Suburban Water Systems-San Jose, Los 7 Drinking water 

Angeles County 

125 CA Trabuco Canyon Water District, Orange 5 Drinking water 

County 

126 CA Tulare County Site Assessment 11 Drinking water 

127 CA United Defense (FMC Corporation), City of 2,600 Groundwater 

Hollister 

128 CA United Technologies Corporation, Santa Clara 1,282,000 Groundwater Under way 

County 

129 CA United States Navy Firing Range, San 20 Drinking water 

Nicholas Island, Ventura County 

130 CA Vandenburg Air Force Base 517 Groundwater Under way 

131 CA Vernon Water Department, Los Angeles 5 Drinking water 

County 

132 CA West San Bernardino County Water District 8 Drinking water 

(formerly West Valley Water District), San 

Bernardino County 

133 CA Whittaker Bermite Ordnance, City of Santa 64,000 Groundwater 

Clarita 

134 CA Whittaker Ordnance, City of Hollister 510,000 Groundwater Under way 

135 CO Colorado Rocky Mountain Arsenal, City of 14 Groundwater Planning 

Adams 

136 CO Pueblo Chemical Depot, City of Pueblo 180 Groundwater Planning 

137 CT Naval Submarine Base New London, New 4 Groundwater 

London County 

138 DC Spring Valley Superfund Site, a formerly used 58 Groundwater 

defense site 

139 DC Washington Aqueduct 8 Groundwater 

140 FL Atlantic Beach Water System, Duval County 200 Drinking water 

141 FL Kissimmee Eastern Regional, North Bermuda, 5 Drinking water 

Osceola County 

142 FL Manatee County Utilities Operations 30 Drinking water 

Department 

Page 34 GAO-05-462 Perchlorate 
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 

143 FL Royal Palm Beach Utilities, Palm Beach 17 Drinking water 

County 

144 FL Sebring Water and Sewer System, Highlands 70 Drinking water 

County 

145 FL Three Worlds Camp Resort, Polk County 5 Drinking water 

146 GA City of Watkinsville, Oconee County 38 Drinking water 

147 GA Fayette County 5 Drinking water 

148 GA Feagin Mill, Houston County 5 Drinking water 

149 IA City of Ewart 29 Groundwater 

150 IA City of Hills 372 Groundwater 

52 Drinking water 

151 IA City of Napier 11 Groundwater 

152 IA Iowa Army Ammunition Plant, Middletown 9 Groundwater Planning 

153 IL Chanute Air Force Base, Rantoul 5 Groundwater 

154 IL City of Joliet, Will and Kendall Counties 4 Drinking water 

155 IL City of Rock Island, Rock Island County 8 Drinking water 

156 IL Sangamo Electric Dump/Crab Orchard 1,200 Groundwater 

National Wildlife Refuge, City of Carterville 

(Department of the Interior) 

157 IL Savanna Army Depot Activity, City of Savanna 12 Groundwater 

158 IN Naval Surface Warfare Center, Crane Division, 470 Soil 

Martin County 67 Groundwater 

159 IN United States Army Jefferson Proving Ground, 100 Soil 

City of Madison 

160 KS City of Hallowell 36,000 Surface water Planning 

161 KS Tri-County Airport (Former Herington Army 9 Groundwater 

Airfield), City of Herington 

162 LA City of Shreveport, Caddo Parrish 10 Drinking water 

163 LA St. Charles Water District Number One 24 Drinking water 

164 MA Clinton Water Department, Worchester 6 Drinking water 

County 

165 MA Massachusetts Military Reservation, 134,000 Soil Under way 

Barnstable County 500 Groundwater 

166 MD Aberdeen Proving Grounds, City of Aberdeen 15,000 Soil Planning 

3,500 Groundwater 

17 Sediment 

167 MD ATK Alliant Tech System, City of Elkton 2,020 Groundwater Planning 

168 MD City of Aberdeen, Harford County 19 Drinking water 

169 MD City of Chapel Hill, Harford County 20 Drinking water 

Page 35 GAO-05-462 Perchlorate 
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 

170 MD City of Hagerstown, Washington County 4 Drinking water 

171 MD Fort George Meade, City of Odenton 70 Groundwater 

172 MD Naval Surface Warfare Center, Indian Head 480,000 Soil 

276,000 Groundwater 

230 Sediment 

4 Surface water 

173 MD White Oak Federal Research Center (Naval 1,400 Soil Planning 

Surface Warfare Center) 880 Groundwater 

9 Surface water 

174 MN City of New Brighton, Ramsey County 5 Drinking water 

175 MN City of Northfield, Rice County 6 Drinking water 

176 MO Expert Management Incorporated (formerly 107,000 Groundwater Planning 

ICI Explosives USA Incorporated), City of 

Joplin 

177 MO Lake City Army Ammunition Plant, City of 79 Groundwater 

Independence 

178 MS Hilldale Water District, Warren County 20 Drinking water 

179 NC City of Highpoint, Guilford County 14 Drinking water 

180 NC City of Kinston, Kinston Lenoir County 4 Drinking water 

181 NC Cliffdale West, Cumberland County 9 Drinking water 

182 NC Former Camp Butner, Granville and Durham 10 Drinking water 

Counties 

183 NC Marine Corps Base Camp Lejeune/Marine 9 Groundwater 

Corps Air Station New River, Onslow County 

184 NC New Hanover County Water System, City of 7 Drinking water 

Wilmington 

185 NC Vick's Mobil Home Park, Nash County 6 Drinking water 

186 NE City of Lewiston, Pawnee County 5 Groundwater 

187 NE City of North Platte, Lincoln County 7 Drinking water 

188 NE Nebraska Ordnance Plant, City of Mead 24 Groundwater 

189 NJ Fort Dix, Pemberton Township 28 Groundwater 

190 NJ Middlesex County 7 Drinking water 

191 NJ Montclair Water Bureau , Essex County 5 Drinking water 

192 NJ New Jersey American Water Company, City of 5 Drinking water 

Lakewood 

193 NJ Park Ridge Water Department, City of Bergen 13 Drinking water 

194 NJ Picatinny Arsenal, Morris County 627 Groundwater 

500 Soil 

Page 36 GAO-05-462 Perchlorate 
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 

195 NJ Township of Hammonton Water Dept, Atlantic 4 Drinking water 

County 

196 NJ Vineland Water and Sewer Utility, Cumberland 6 Drinking water 

County 

197 NM Cannon Air Force Base, Clovis 46 Drinking water 

46 Groundwater 

6 Soil 

198 NM City of Deming, Luna County 20 Drinking water 

199 NM City of Des Moines 5 Drinking water 

200 NM Fort Wingate Depot, Gallup 3,180 Soil Planning 

2,890 Groundwater 

201 NM Holloman Air Force Base, Alamogordo 16,000 Surface water 

7,600 Soil 

7,600 Sediment 

202 NM Kirtland Air Force Base, Albuquerque 50,500 Soil 

13 Groundwater 

203 NM Los Alamos National Laboratory, City of Los 1,662 Groundwater 

Alamos (Department of Energy) 

204 NM Melrose Air Force Bombing Range, City of 480 Soil 

Clovis 41 Groundwater 

205 NM Mountain View Albuquerque, City of South 5 Drinking water 

Valley 

206 NM New Mexico American Water Company, City 7 Drinking water 

of Clovis 

207 NM Sandia National Labs, City of Albuquerque 1,040 Soil 

(Department of Energy) 

208 NM White Sands Missile Range 32,900 Groundwater 

209 Northern Commonwealth Utilities Corporation, Saipan 14 Drinking water 

Mariana 

Islands 

210 NV Boeing-Rocketdyne Test Site, City of Reno 400 Groundwater 

211 NV Henderson Water Company, Clark County 23 Drinking water 

212 NV Kerr-McGee Chemical, City of Henderson, 3,700,000 Groundwater Under way 

Clark County 120,000 Surface water 

24 Drinking water 

213 NV Mohave Generating Station, Clark County 7 Drinking water 

214 NV PEPCON (Former), City of Henderson, Clark 600,000 Groundwater Planning 

County 

215 NV Southern Nevada Water System, Clark 17 Drinking water 

County 

216 NY Bethpage Water District, Nassau County 5 Drinking water 

Page 37 GAO-05-462 Perchlorate 
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 

217 NY City of Glen Cove, Nassau County 4 Drinking water 

218 NY City of Westhampton, Suffolk County 3,370 Groundwater Planning 

16 Drinking water 

219 NY City of Yaphank, Suffolk County 122 Groundwater 

26 Drinking water 

220 NY Garden City, Nassau County 4 Drinking water 

221 NY Greenlawn Water District, Suffolk County 6 Drinking water 

222 NY Hicksville Water District, Nassau County 8 Drinking water 

223 NY Plainview Water District, Nassau County 11 Drinking water 

224 NY South Huntington Water District, Suffolk 5 Drinking water 

County 

225 NY Suffolk County Water Authority 12 Drinking water 

226 NY Town of Hempstead Water District 9 Drinking water 

227 NY Water Authority of Western Nassau County 6 Drinking water 

228 NY Westbury Water District, Nassau County 14 Drinking water 

229 OH City of Berea, Cuyahoga County 5 Drinking water 

230 OH City of Fairfield 27 Drinking water 

231 OH City of Loveland 7 Drinking water 

232 OH City of Painesville, Lake County 9 Drinking water 

233 OH City of Ravenna, Portage County 5 Drinking water 

234 OH Defiance Water Treatment, City of Defiance 6 Drinking water 

235 OH Hecla Water Association - Plant Public Water 32 Drinking water 

System, Lawrence County 

236 OH Ravenna Army Ammunition Plant, City of 25 Surface water 

Ravenna 

237 OH Wright-Patterson Air Force Base, Greene 17 Drinking water 

County 

238 OK Bixby Public Works Authority, Tulsa County 11 Drinking water 

239 OK City of Enid, Garfield County 30 Drinking water 

240 OK City of Moore, Cleveland County 13 Drinking water 

241 OK City of Woodward 13 Drinking water 

242 OK Edmond Public Works Authority 13 Drinking water 

243 OR Arkema Incorporated (formerly Atofina), City 370,000 Groundwater Planning 

of Portland 

244 OR Former Boardman Air Force Range 20 Groundwater 

14 Surface water 

245 OR Adjacent to the Navy Boardman Bombing 23 Groundwater 

Range 

Page 38 GAO-05-462 Perchlorate 
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 

246 OR Umatilla Ammunition Demolition Area, North 25 Groundwater 

Morrow, City of Hermiston 

247 PA Ambler Boro Water Department, Montgomery 10 Drinking water 

County 

248 PA Columbia Water Company, Lancaster County 12 Drinking water 

249 PA Erie City Water Authority 5 Drinking water 

250 PA Huntingdon Boro Water Department, 7 Drinking water 

Huntingdon County 

251 PA Meadville Area Water Authority, Crawford 33 Drinking water 

County 

252 PA Muhlenberg Township Municipal Authority, 4 Drinking water 

City of Reading 

253 PR City of Utuado 420 Drinking water 

254 SC Cassatt Water Company Number One, 5 Drinking water 

Kershaw County 

255 SC Darlington County Water and Sewer Authority, 7 Drinking water 

Hartsville and Darlington Counties 

256 SC Shaw Air Force Base, Poinsett Range, Sumter 8 Groundwater 

County 

257 SC Talatha Water District, Aiken County 4 Drinking water 

258 TN Arnold Air Force Base, City of Tullahoma 1,000 Groundwater 

259 TN Crossville Water Department 9 Drinking water 

260 TX Ackerly Water Supply Corporation, Dawson 4 Groundwater 

County 

261 TX Acuff Steak House, Lubbock County 10 Groundwater 

262 TX Addison private well, Terry County 23 Groundwater 

263 TX Andrews County 24 Groundwater 

264 TX Barr private well, Howard County 5 Groundwater 

265 TX Blackwell private well, Midland County 4 Groundwater 

266 TX Blair private well, Midland County 14 Groundwater 

267 TX Bledsoe Water Service Company, Cochran 8 Groundwater 

County 

268 TX Blue Nile Water Company, Midland County 6 Groundwater 

269 TX Camp Bullis, Bexar County 424 Groundwater Planning 

270 TX Camp Post, Garza County 8 Groundwater 

271 TX Casselman private well, Midland County 12 Groundwater 

272 TX Cave private well, Martin County 19 Groundwater 

273 TX City of Amherst, Lamb County 6 Groundwater 

Page 39 GAO-05-462 Perchlorate 
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 

274 TX City of Andrews, Andrews County 8 Groundwater 

275 TX City of Crane, Crane County 14 Groundwater 

276 TX City of El Paso, El Paso County 6 Drinking water 

277 TX City of Georgetown, Williamson County 5 Drinking water Under way 

278 TX City of Jayton, Kent County 5 Groundwater 

279 TX City of Kingsville 9 Drinking water 

280 TX City of Lamesa, Dawson County 26 Groundwater 

281 TX City of Lefors, Gray County 5 Groundwater 

282 TX City of Levelland, Hockley County 123 Drinking water 

283 TX City of Midland, Midland County 46 Drinking water 

284 TX City of O'Donnell, Lynn County 6 Groundwater 

285 TX City of Quitaque, Briscoe County 10 Groundwater 

286 TX City of Seagraves, Gaines County 10 Groundwater 

287 TX City of Seminole, Gaines County 25 Groundwater 

288 TX City of Slaton, Lubbock County 5 Groundwater 

289 TX City of Stanton, Martin County 4 Groundwater 

290 TX City of Sudan, Lamb County 18 Groundwater 

291 TX City of Whiteface, Cochran County 9 Groundwater 

292 TX City of Wickett, Ward County 5 Groundwater 

293 TX Cooper Independent School District, Lubbock 5 Groundwater 

County 

294 TX Cosner private well, Midland County 6 Groundwater 

295 TX Cotton Gin, Patricia, Dawson County 8 Groundwater 

296 TX Cotton private well, Midland County 10 Groundwater 

297 TX County Line Gin, Borden and Dawson County 4 Groundwater 

298 TX County Road 404, Winkler County 8 Groundwater 

299 TX Cranfill private well, Midland County 5 Groundwater 

300 TX Crucher private well, Terry County 4 Groundwater 

301 TX Cunningham private well, Midland County 7 Groundwater 

302 TX Duke Energy Field Services Fullerton Plant, 16 Groundwater 

Andrews County 

303 TX ExxonMobil Production Company, Andrews 6 Groundwater 

County 

304 TX Florey Park, Andrews County 9 Groundwater 

305 TX Flowing Wells School District One, Martin 12 Groundwater 

County 

306 TX Furlow private well, Lynn County 7 Groundwater 

Page 40 GAO-05-462 Perchlorate 
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 

307 TX Gaines County Golf Course, Gaines County 27 Groundwater 

308 TX Gaines County Park, Gaines County 19 Groundwater 

309 TX Galian private well, Midland County 5 Groundwater 

310 TX Gardendale Country Water, Incorporated, 4 Groundwater 

Ector County 

311 TX Gill private well, Lynn County 7 Groundwater 

312 TX Girard Post Office, Kent County 9 Groundwater 

313 TX Glosson private well, Midland County 29 Groundwater 

314 TX Greenwood Independent School District, 8 Groundwater 

Midland County 

315 TX Greenwood Terrace Mobile Home 5 Groundwater 

Subdivision, Midland County 

316 TX Greenwood Ventures, Incorporated, Midland 7 Groundwater 

County 

317 TX Greenwood Water Corporation, Midland 4 Groundwater 

County 

318 TX Hancock private well, Midland County 5 Groundwater 

319 TX Henry private well, Gaines County 21 Groundwater 

320 TX Huber Gardens Estates, Ector County 5 Groundwater 

321 TX Johns Mobile Home Park, Midland County 5 Groundwater 

322 TX Jones private well, Andrews County 6 Groundwater 

323 TX Jones private well, Midland County 17 Groundwater 

324 TX Kadir private well, Midland County 5 Groundwater 

325 TX Kent KWIK Convenience Store 312, Midland 10 Groundwater 

County 

326 TX Klondike High School, Dawson County 11 Groundwater 

327 TX Loller private well, Yokum County 6 Groundwater 

328 TX Lone Star Army Ammunition Plant, Texarkana 186 Sediment 

County 157 Soil 

23 Groundwater 

6 Surface water 

329 TX Longhorn Army Ammunition Plant, Harrison 320,000 Groundwater Under way 

County 163,000 Soil 

11,000 Sediment 

330 TX Loop Water Service Company, Gaines County 6 Groundwater 

331 TX Lubbock Public Water System, Lubbock 9 Groundwater 

County 

332 TX Lucas private well, Midland County 10 Groundwater 

333 TX Luckie private well, Midland County 6 Groundwater 

Page 41 GAO-05-462 Perchlorate 
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 

334 TX Maple Water Service Company, Bailey County 8 Groundwater 

335 TX Martin County 32 Groundwater 

336 TX McClain private well, Midland County 7 Groundwater 

337 TX McGregor Naval Weapons Industrial Reserve 1,800,000 Soil Under way 

Plant, McLennan County 91,000 Groundwater 

6,600 Surface water 

720 Sediment 

338 TX McMurries private well, Martin County 10 Groundwater 

339 TX Minnix private well, Midland County 5 Groundwater 

340 TX Mobile Home Park, Lubbock County 4 Groundwater 

341 TX Nelms private well, Midland County 8 Groundwater 

342 TX Nobels private well, Midland County 4 Groundwater 

343 TX North State Highway 115, Winkler County 6 Groundwater 

344 TX North University Estates, Lubbock County 5 Groundwater 

345 TX North West Yoakum, Yoakum County 8 Groundwater 

346 TX O'Brien private well, Dawson County 59 Groundwater 

347 TX Offield private well, Midland County 6 Groundwater 

348 TX Pantex Plant, City of Amarillo, Carson County 5,000 Soil 

(Department of Energy) 408 Groundwater 

349 TX Pecan Acres Homeowners Association, 7 Groundwater 

Midland County 

350 TX Pecan Acres Water Supply Corporation, 7 Groundwater 

Midland County 

351 TX Peck private well, Midland County 8 Groundwater 

352 TX Posey private well, Howard County 26 Groundwater 

353 TX Ray Jr. private well, Howard County 25 Groundwater 

354 TX Red River Army Depot, Texarkana County 417 Surface water 

226 Soil 

7 Groundwater 

355 TX Rivera private well, Midland County 4 Groundwater 

356 TX Roosevelt Independent School District, 20 Groundwater 

Lubbock County 

357 TX Sherwood Estates Manufactured Town, 10 Groundwater 

Midland County 

358 TX Sid Richardson Carbon Company, Howard 12 Groundwater 

County 

359 TX Small private well, Midland County 8 Groundwater 

360 TX Southland Independent School District, Garza 7 Groundwater 

County 

Page 42 GAO-05-462 Perchlorate 
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 

361 TX Spade Water Supply Corporation, Lamb 5 Groundwater 

County 

362 TX Spring Meadow Mobile Home Park, Midland 4 Groundwater 

County 

363 TX Tahoka Public Water System, Lynn County 12 Groundwater 

364 TX Tate private well, Martin County 10 Groundwater 

365 TX Tellinghuisen private well, Midland County 10 Groundwater 

366 TX Texland Great Plains Water Company, Gaines 6 Groundwater 

County 

367 TX Twin Oaks Mobile Home Park, Midland County 10 Groundwater 

368 TX Valley View Mobile Home Park, Midland 9 Groundwater 

County 

369 TX Warren private well, Gaines County 30 Groundwater 

370 TX Water Runners, Incorporated, Midland County 4 Groundwater 

371 TX Weitzel private well, Midland County 8 Groundwater 

372 TX Welch Water Supply Corporation, Dawson 14 Groundwater 

County 

373 TX Weltie private well, Midland County 9 Groundwater 

374 TX West Cedar Creek Municipal Utility District, 8 Drinking water 

Henderson County 

375 TX West Texas Animal Clinic, Scurry County 13 Groundwater 

376 TX Whiteface Independent School District, 6 Groundwater 

Cochran County 

377 TX Yoakum County Park and Golf Course, 6 Groundwater 

Yoakum County 

378 UT ATK Thiokol, Bacchus ( former Bacchus 19,000 Groundwater Planning 

Works, Alliant Tech Systems, Incorporated), 

City of West Valley 

379 UT ATK Thiokol, Promotory (former Thiokol, 60,000 Groundwater Planning 

Promotory Point), City of Brigham 

380 UT Dyno Nobel, Site B (Pelican Point), City of 1,300,000 Soil Planning 

Lehi, Utah County 

381 UT Dyno Nobel, Tooele Test Site, City of Topliff 41,900 Soil 

Hill, Tooele County 

382 UT Hill Air Force Base, City of Layton, Davis 70 Groundwater Planning 

County 

383 UT Kennecott Utah Copper (former Bacchus 61 Drinking water Planning 

Works, Alliant Tech Systems, Incorporated), 

City of Magna 

384 UT Magna Water Company, Salt Lake County 8 Drinking water 

Page 43 GAO-05-462 Perchlorate 
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 County 1,200 Soil Under way 

386 VA Atlantic Research Corporation 17 Groundwater Planning 

387 VA Naval Surface Warfare Center, Dahlgren 2,700 Groundwater 

1,200 Soil 

120 Sediment 

7 Surface water 

388 VA Purdue Farms, Incorporated, Accomack 4 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, Pierce County 6 Drinking water 

393 WA Lacey Water Department, Thurston County 9 Drinking water 

394 WA Lakewood Water District, Pierce County 6 Drinking water 

395 WV Allegheny Ballistics Lab, City of Rocket Center 35,000 Soil 

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. 

a

In 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. 

b

Parts per billion (ppb). 

c

Data in column reflect the status of cleanup at 51 of the almost 400 sites where perchlorate was 

found. 

Page 44 GAO-05-462 Perchlorate 
Appendix III 

Perchlorate Health Risk Studies Published 

Since 1998 

Author’s 

findings/ 

conclusions 

about the 

adverse effects 

Publica- Sponsor/ Subject Design of perchlorate 

tion year Study title Author Recipient description Design type controls on health 

2000 The Effect of Mann Environmental Animal Review/ New diagnostic Not identified/ 

Ammonium Protection Reanalysis of criteria (see Unknown. 

Perchlorate on Agency studies/data original study 

Thyroids for experimental 

controls) 

2001 Statistical Analysis Dunson Environmental Animal Review/ Established Adverse effects 

of the Tumors Protection Reanalysis of incidence indicated. 

Observed in Male Agency studies/data probabilities 

F1 Rats at Week (see original 

19 in the Argus study for 

(1999) Two- experimental 

Generation controls) 

Reproduction 

Study of 

Ammonium 

Perchlorate 

2000 Report of the Peer Wolf Environmental Animal Review/ New diagnostic Adverse effects 

Review of Thyroid Protection Reanalysis of criteria for indicated. 

Histopathology Agency studies/data reviewing data 

from Rodents and (see original 

Rabbits Exposed to study for 

Ammonium experimental 

Perchlorate in the controls) 

Drinking Water 

2001 Revised Analysis Crofton Environmental Animal Review/ See original Nonadverse 

of the Thyroid Protection Reanalysis of study for effects indicated. 

Hormone Data Agency studies/data experimental No information 

from the Mouse controls available on 

Immunotoxicology adverse effects. 

Study (from Keil et 

al., 1999) 

5 2001 Revised Analysis Crofton Environmental Animal Review/ See original Nonadverse 

of the Thyroid Protection Reanalysis of study for effects indicated. 

Hormone Data Agency studies/data experimental Adverse effects to 

from the Rat controls development 

Developmental indicated. 

“effects” StudyArgus 

Protocol1416-003 

Page 45 GAO-05-462 Perchlorate 

1 

2 

3 

4 
Appendix III


Perchlorate Health Risk Studies Published


Since 1998 


(Continued From Previous Page) 

Author’s 

findings/ 

conclusions 

about the 

adverse effects 

Publica- Sponsor/ Subject Design of perchlorate 

tion year Study title Author Recipient description Design type controls on health 

1998 Effects of Keil, et al. Department of Animal Experimental Dose, duration, Nonadverse 

Ammonium Defense design age, sex, and effects indicated. 

Perchlorate on weight Information on 

Immunotoxicologi- (dose levels adverse effects is 

cal, Hematological, independently incomplete. 

and Thyroid verified) 

Parameters in 

B6C3F1 Female 

Mice 

1999 Effects of Keil, et al. Department of Animal Experimental Dose, duration, Nonadverse 

Ammonium Defense and design age, sex, strain, effects indicated. 

Perchlorate on Environmental and weight No adverse 

Immunotoxicologi- Protection (dose levels effects indicated. 

cal, Hematological, Agency independently 

and Thyroid verified) 

Parameters in 

B6C3F1 Female 

Mice [Final report] 

1998 A 90-day Drinking Siglin ManTech Animal Experimental Dose, duration, Nonadverse and 

Water Toxicity Environmental design sex, and weight adverse effects 

Study in Rats With Technology, indicated. 

Ammonium Inc. 

Perchlorate [Final 

Report] 

1998 A Neurobehavioral York ManTech Animal Experimental Dose and Nonadverse 

Developmental Environmental design duration effects and 

Study of Technology, adverse 

Ammonium Inc. developmental 

Perchlorate effects indicated. 

Administered 

Orally in Drinking 

Water to Rats 

Page 46 GAO-05-462 Perchlorate 

6 

7 

8 

9 
Appendix III


Perchlorate Health Risk Studies Published


Since 1998 


(Continued From Previous Page) 

Author’s 

findings/ 

conclusions 

about the 

adverse effects 

Publica- Sponsor/ Subject Design of perchlorate 

tion year Study title Author Recipient description Design type controls on health 

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 of Boyes, et al. Environmental Animal Review/ See original Adverse effects to 

Issues Regarding Protection Reanalysis of study for development 

Neurotoxic Effects Agency studies/data experimental indicated. 

of Developmental controls 

Exposure to 

Perchlorate 

Page 47 GAO-05-462 Perchlorate 
Appendix III


Perchlorate Health Risk Studies Published


Since 1998 


(Continued From Previous Page) 

Author’s 

findings/ 

conclusions 

about the 

adverse effects 

Publica- Sponsor/ Subject Design of perchlorate 

tion year Study title Author Recipient description Design type controls on health 

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 Analysis Dunson Environmental Animal Review/ Dose, duration, Adverse effects to 

of the Effects of Protection Reanalysis of and age development 

Perchlorate on Agency studies/data indicated. 

Neurobehavioral 

(motor activity) in 

SD Rats 

15 2001 Profile Analysis of Gellar Environmental Animal Review/ Dose and Adverse effects to 

Brain Morphometry Protection Reanalysis of duration development 

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 of study for development 

Analysis Agency studies/data experimental indicated. 

Incorporating controls 

Consultant in 

Veterinary 

Pathology (2003) 

Review of 

Morphometry Data 

from Argus 1416-

003 

Page 48 GAO-05-462 Perchlorate 
Appendix III


Perchlorate Health Risk Studies Published


Since 1998 


(Continued From Previous Page) 

Author’s 

findings/ 

conclusions 

about the 

adverse effects 

Publica- Sponsor/ Subject Design of perchlorate 

tion year Study title Author Recipient description Design type controls on health 

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 (Drinking York Perchlorate Animal Experimental Dose, duration, Adverse effects to 

Water) Two Study Group design and sex development 

Generation (one indicated. 

Litter Per 

Generation) 

Reproduction 

Study of 

Ammonium 

Perchlorate 

19 2000 Oral (Drinking York Perchlorate Animal Experimental Dose No adverse 

Water) Study Group design developmental 

Developmental effects indicated. 

Toxicity Study of 

Ammonium 

Perchlorate in Rats 

[Final report] 

20 2000 Ammonium Dourson and Perchlorate Animal Experimental Dose and Nonadverse and 

Perchlorate: Effect Dollarhide Study Group design duration adverse effects 

on Immune indicated. 

Function 

21 2000 Addendum to Dourson and Perchlorate Animal Experimental Dose Nonadverse and 

Ammonium Dollarhide Study Group design adverse effects 

Perchlorate: Effect indicated. 

on Immune 

Function 

Page 49 GAO-05-462 Perchlorate 
Appendix III


Perchlorate Health Risk Studies Published


Since 1998 


(Continued From Previous Page) 

Author’s 

findings/ 

conclusions 

about the 

adverse effects 

Publica- Sponsor/ Subject Design of perchlorate 

tion year Study title Author Recipient description Design type controls on health 

22 2000 Ammonium Brechner, et Not identified/ Human Field study Dose, Nonadverse 

Perchlorate al. Unknown comparison/ effects indicated. 

Contamination of control town, No information 

Colorado River race/ethnicity, available on 

Drinking Water is and age adverse effects. 

Associated With 

Abnormal Thyroid 

Functions in 

Newborns in 

Arizona 

23 2002 Health Effects Greer, et al. Perchlorate Human Experimental Dose and Nonadverse 

Assessment for Study Group design external data effects indicated. 

Environmental and National audit No information 

Perchlorate Institute of available on 

Contamination: Health adverse effects. 

The Dose 

Response for 

Inhibition of 

Thyroidal 

Radioiodine 

Uptake in Humans 

24 2000 The Effect of Short- Lawrence, et Perchlorate Human Experimental Baseline blood Nonadverse 

Term Low-Dose al. Study Group, design and urine tests, effects indicated. 

Perchlorate on National and statistical No adverse 

Various Aspects of Institute of controls for time effects. 

Thyroid Function Health, and and duration 

the Thyroid 

Center for 

Excellence 

25 2003 Estimating Human Marcus Environmental Human Review/ Statistical Nonadverse 

Dose-Response Protection Reanalysis of controls, such effects indicated. 

Functions for the Agency studies/data as No information 

Greer et al. (2000, autocorrelation available on 

2002) and Merrill adverse effects. 

(2001a) Data on 

Thyroid 

Radioactive Iodide 

Uptake (RAIU) 

After Perchlorate 

Ingestion 

Page 50 GAO-05-462 Perchlorate 
Appendix III


Perchlorate Health Risk Studies Published


Since 1998 


(Continued From Previous Page) 

Author’s 

findings/ 

conclusions 

about the 

adverse effects 

Publica- Sponsor/ Subject Design of perchlorate 

tion year Study title Author Recipient description Design type controls on health 

26 2003 Analysis of Dose- Marcus Environmental Human Review/ Statistical Nonadverse 

Response Protection Reanalysis of controls, such effects indicated. 

Functions for Agency studies/data as circadian No information 

Effects of rhythms, available on 

Perchlorate on gender, dose, adverse effects. 

Serum Hormone and duration 

from Data of Greer 

et al. (2000, 2002) 

and Merrill (2001a) 

27 2001 Gestational Schwartz California Human Field study Gender, Nonadverse 

Exposure to Department of multiple birth, effects indicated. 

Perchlorate is Health birth weight, Potential adverse 

Associated With Services blood sample, developmental 

Measures of age, and effects indicated. 

Decreased Thyroid ethnicity 

Function in a 

Population of 

California 

Neonates 

28 2003 Anion Selectivity by Van Sande, Ministere de Cells Experimental Not identified/ Nonadverse 

the Sodium Iodide et al. la Politique design Unknown effects indicated. 

Symporter Scientifique, No information 

and Fonds available on 

adverse effects. 

29 1998 Perchlorate and the Wolff Not identified/ Not identified/ Review/ Not identified/ Nonadverse 

Thyroid Gland Unknown Unknown Reanalysis of Unknown effects indicated. 

studies/data No information 

available on 

adverse effects. 

30 1998 Differences in the Yoshida, et Not identified/ Cells Experimental Not identified/ Effects not 

Electrophysiologi- al. Unknown design Unknown studied. 

cal Response To 

I- and the Inhibitory 

Anions SCN- and 

CIO-4 Studied in 

FRTL-5 Cells 

Page 51 GAO-05-462 Perchlorate 
Appendix III


Perchlorate Health Risk Studies Published


Since 1998 


(Continued From Previous Page) 

Author’s 

findings/ 

conclusions 

about the 

adverse effects 

Publica- Sponsor/ Subject Design of perchlorate 

tion year Study title Author Recipient description Design type controls on health 

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, et Environmental Animal Review/ Statistical Effects not 

Physiologically- al. Protection Reanalysis of controls, such studied (model 

Based Agency and studies/data as time, body developed). 

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, et Environmental Animal Review/ Statistical Effects not 

Physiologically- al. Protection Reanalysis of controls, such studied (model 

Based Agency and studies/data as time, body developed). 

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 Letter: Merrill Environmental Human Audit of Not identified/ Effects not 

Audit Report for the Protection documentation Unknown studied. 

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 

Page 52 GAO-05-462 Perchlorate 
Appendix III


Perchlorate Health Risk Studies Published


Since 1998 


(Continued From Previous Page) 

Author’s 

findings/ 

conclusions 

about the 

adverse effects 

Publica- Sponsor/ Subject Design of perchlorate 

tion year Study title Author Recipient description Design type controls on health 

35 2001 Consultative Letter: Merrill Environmental Human Review/ Statistical Effects not 

PBPK Model for Protection Reanalysis of controls studied (model 

Perchlorate- Agency and studies/data developed). 

Induced Inhibition Department of 

of Radioiodide Defense 

Uptake in Humans 

36 2001	 Consultative Letter: 

Revision To AFRLHE-WP-CL-2001­

0010, Comparison 

of Internal 

Dosimetrics Using 

PBPK Models for 

PerchlorateInduced 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 

37 2001 Uptake and Carr, et al. Strategic Amphibian Experimental Dose and Nonadverse 

Elimination of Environmental design duration effects indicated. 

Perchlorate in Research and No adverse 

American Bullfrog Development developmental 

Larvae, Rana Program effects indicated. 

Catesbeiana 

38 2001 Response of Carr, et al. Strategic Amphibian Field study Dose, Adverse 

Native Adult and Environmental contaminated/ developmental 

Larval Anurans in Research and noncontami- effects 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 

Page 53 GAO-05-462 Perchlorate 
Appendix III


Perchlorate Health Risk Studies Published


Since 1998 


(Continued From Previous Page) 

Author’s 

findings/ 

conclusions 

about the 

adverse effects 

Publica- Sponsor/ Subject Design of perchlorate 

tion year Study title Author Recipient description Design type controls on health 

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 Toxicity Klaassen Not identified/ Human and Review/ See original Effects not 

and Risk Unknown animal Reanalysis of study for studied 

Assessment studies/data experimental (reference dose 

controls developed). 

42 1999 Thyroid Health Lamm, et al. American Human Field study Dose exposure No nonadverse or 

Status of Pacific level, and adverse effects 

Ammonium Corporation, screening for indicated. 

Perchlorate Las Vegas, underlying 

Workers: A Cross- NV thyroid and 

Sectional health problems 

Occupational 

Health Study 

Page 54 GAO-05-462 Perchlorate 
Appendix III


Perchlorate Health Risk Studies Published


Since 1998 


(Continued From Previous Page) 

Author’s 

findings/ 

conclusions 

about the 

adverse effects 

Publica- Sponsor/ Subject Design of perchlorate 

tion year Study title Author Recipient description Design type controls on health 

43 1998 Genotoxicity Sharma, et Perchlorate Animal, Experimental Dose, repeated No adverse 

Assays for al. Study Group, bacteria, and design study, bacteria effects indicated. 

Ammonium Toxicology cells strain, and sex 

Perchlorate Excellence for 

Risk 

Assessment, 

Cincinnati, 

OH 

44 2000 Consultative Letter: Mahle Department of Animal Experimental Dose, duration, Nonadverse 

Hormone and Defense design and switched effects indicated. 

Perchlorate Data exposed/control No information 

from Cross- litters with available on 

Fostering Study exposed/ adverse 

control dams developmental 

effects. 

45 2001 Consultative Letter: Mahle Department of Animal Experimental Dose, duration, Nonadverse 

Hormone and Defense design and switched effects indicated. 

Perchlorate Data exposed/ No information 

from Cross- control litters available on 

Fostering Study with exposed/ adverse 

control dams developmental 

effects. 

46 2000 Consultative Letter: Merrill Department of Human Review/ Statistical Effects not 

Human PBPK Defense Reanalysis of controls, such studied (model 

Model for studies/data as body weight, developed). 

Perchlorate urinary 

Inhibition of Iodide excretion rate 

Uptake in the constants, 

Thyroid thyroid 

maximum 

velocities, and 

inhibition affinity 

constants 

47 2000 Consultative Letter: Mattie Department of Human Experimental Dose and Not identified/ 

Hormone Data Defense design duration Unknown. 

from Brabant 

Human Perchlorate 

(1.0 and 12.0 

mg/kg-day) 

Kinetics Drinking 

Water Study 

Page 55 GAO-05-462 Perchlorate 
Appendix III


Perchlorate Health Risk Studies Published


Since 1998 


(Continued From Previous Page) 

Author’s 

findings/ 

conclusions 

about the 

adverse effects 

Publica- Sponsor/ Subject Design of perchlorate 

tion year Study title Author Recipient description Design type controls on health 

48 2002 Uptake of Theodorakis Strategic Fish Experimental Dose and Nonadverse and 

Ammonium Environmental design duration adverse effects 

Perchlorate and Research and indicated. 

Thyroid Status in Development 

Native Fish Program 

49 2001 In Situ Exposure of Theodorakis Strategic Fish Field study Dose, Findings not 

Fish and Environmental contaminated/ used--design 

Amphibians for Research and clean sites, limitations too 

Determination of Development duration, pH, great. 

Contaminant Program oxygen levels, 

Effects at the conductivity, 

Longhorn Army and 

Ammunition Plant, temperature of 

Jefferson County, test sites 

Texas 

50 2002 Fish and Theodorakis Strategic Fish Field study Dose, No adverse 

Amphibians as Environmental contaminated/ effects indicated. 

Aquatic Sentinels Research and clean sites, 

for Perchlorate Development duration, pH, 

Exposures and Program oxygen levels, 

Effects at the conductivity, 

Longhorn Army and 

Ammunition Plant, temperature of 

Jefferson County, test sites 

Texas 

51 1998 Stability and Tsui, et al. Department of Ions Experimental Room Effects not 

Concentration Defense design temperature, studied. 

Verification of light, humidity, 

Ammonium and light/dark 

Perchlorate Dosing cycle 

Solutions 

52 2001 Assessment of Smith Strategic Animal Field study Dose, and No nonadverse or 

Perchlorate in Environmental contaminated adverse effects 

Terrestrial Research and areas indicated. 

Mammalian Development compared with 

Receptors: Program uncontamiRaccoons nated 

(Procyon Lotor) 

and Opossums 

(Didelphis 

Virginiana) 

Page 56 GAO-05-462 Perchlorate 
Appendix III


Perchlorate Health Risk Studies Published


Since 1998 


(Continued From Previous Page) 

Author’s 

findings/ 

conclusions 

about the 

adverse effects 

Publica- Sponsor/ Subject Design of perchlorate 

tion year Study title Author Recipient description Design type controls on health 

53 2000 ConsultativeLetter: Yu Department of Animal Experimental Dose and Nonadverse 

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 of Animal Experimental Time after Nonadverse 

Intravenous Defense design dosing and effects indicated. 

Kinetics of before death No information 

Radiolabeled available on 

Iodide in Tissues of adverse 

Adult Male developmental 

Sprague Dawley effects. 

Rat Dosed With 125I

- Plus Carrier 

55 1998 Consultative Letter: Zeiger Department of Animal Experimental Dose No adverse 

Salmonella Health and design effects indicated. 

Mutagenicity Human 

Testing of Services, 

Ammonium National 

Perchlorate Institute of 

Health 

56 2003 Oral (Drinking York, et al. Department of Animal Experimental Dose Nonadverse 

Water) Defense design effects indicated. 

Developmental Adverse effects to 

Toxicity Study of development 

Ammonium indicated. 

Perchlorate in 

Sprague-Dawley 

Rats 

Page 57 GAO-05-462 Perchlorate 
Appendix III


Perchlorate Health Risk Studies Published


Since 1998 


(Continued From Previous Page) 

Author’s 

findings/ 

conclusions 

about the 

adverse effects 

Publica- Sponsor/ Subject Design of perchlorate 

tion year Study title Author Recipient description Design type controls on health 

57 2003 Consultative Letter: Wolf Environmental Amphibian Review/ Dose Adverse effects 

Review of the Protection Reanalysis of indicated. 

Thyroid Agency studies/data 

Histopathology 

from Xenopus 

Laevis Exposed to 

Ammonium 

Perchlorate in the 

Water 

58 2004 Evidence for Clewell, et Department of Human and Review/ See original Nonadverse 

Competitive al. Defense and animal Reanalysis of study for effects indicated. 

Inhibition of Iodide National studies/data experimental No information 

Uptake by Aeronautics controls available on 

Perchlorate and and Space adverse effects. 

Translocation of Administration 

Perchlorate into the 

Thyroid 

59 2000 A 90-Day Drinking Siglin, et al. Not identified/ Animal Experimental Duration, dose, Nonadverse and 

Water Toxicity Unknown design and recovery adverse effects 

Study in Rats of the period indicated. 

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 al. Department of Animal Experimental Duration and Nonadverse 

Defense and design dose effects indicated. 

ManTech Adverse 

Geo-Centers developmental 

Joint Venture effects indicated. 

61 2001 Oral (Drinking York, et al. Not identified/ Animal Experimental Dose Nonadverse 

Water) Unknown design effects indicated. 

Developmental No adverse 

Toxicity Study of developmental 

Ammonium effects indicated. 

Perchlorate in New 

Zealand White 

Rabbits 

Page 58 GAO-05-462 Perchlorate 
Appendix III


Perchlorate Health Risk Studies Published


Since 1998 


(Continued From Previous Page) 

Author’s 

findings/ 

conclusions 

about the 

adverse effects 

Publica- Sponsor/ Subject Design of perchlorate 

tion year Study title Author Recipient description Design type controls on health 

62 2003 Oral (Drinking York, et al. Not identified/ Animal Experimental Dose Nonadverse 

Water) Unknown design effects indicated. 

Developmental No adverse 

Toxicity Study of developmental 

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 of a Gibbs, et al. Not identified/ Human Field study Dose (high, No adverse 

Population With Unknown low/control air effects indicated. 

Occupational exposure 

Exposure to groups), dose 

Airborne estimation (shift 

Ammonium and lifetime), 

Perchlorate For race, gender, 

Possible Acute or age, hours 

Chronic Effects On awake prior to 

Thyroid Function shift, hours 

slept, time of 

day, and shift 

length 

Page 59 GAO-05-462 Perchlorate 
Appendix III


Perchlorate Health Risk Studies Published


Since 1998 


(Continued From Previous Page) 

Author’s 

findings/ 

conclusions 

about the 

adverse effects 

Publica- Sponsor/ Subject Design of perchlorate 

tion year Study title Author Recipient description Design type controls on health 

65 2004 Letter To The Gibbs, et al. Not identified/ Human Field study Dose (cities Effects not 

Editor: Crump Et Unknown with high, studied. 

Al. Study Among medium and no 

School Children in levels of 

Chile: Subsequent perchlorate in 

Urine and Serum water), age, 

Perchlorate Levels sex, and urinary 

Are Consistent iodine 

With Perchlorate in concentration, 

Water in Taital whether living in 

the study city 

since birth or 

moving there in 

the past year 

66 2002 Health Effects Greer, et al. Perchlorate Human Experimental Dose and sex Nonadverse 

Assessment for Study Group design effects indicated. 

Environmental and National No adverse 

Perchlorate Institute of effects indicated. 

Contamination: Health 

The Dose 

Response 

Inhibition of 

Thyroidal 

Radioiodine 

Uptake in Humans 

67 2001 Letter To The Lawrence, et Not identified/ Human Experimental Not identified/ No effects 

Editor: Low Dose al. Unknown design Unknown indicated. 

Perchlorate (3mg 

Daily) and Thyroid 

Function 

68 2000 The Effect of Short- Lawrence, et Perchlorate Human Experimental Baseline tests Nonadverse 

Term Low-Dose al. Study Group, design performed to effects indicated. 

Perchlorate on Thyroid ensure subjects No information 

Various Aspects of Center for had no prior available of 

Thyroid Function Excellence, thyroid adverse effects. 

and National problems 

Institute of 

Health 

69 2001 Perchlorate Clinical Soldin, et al. Not identified/ Human Review/ See original Not identified/ 

Pharmacology and Unknown Reanalysis of study for Unknown. 

Human Health: A studies/data experimental 

Review controls 

Page 60 GAO-05-462 Perchlorate 
Appendix III


Perchlorate Health Risk Studies Published


Since 1998 


(Continued From Previous Page) 

Author’s 

findings/ 

conclusions 

about the 

adverse effects 

Publica- Sponsor/ Subject Design of perchlorate 

tion year Study title Author Recipient description Design type controls on health 

70 2003	 Predicting Fetal 

Perchlorate Dose 

and Inhibition of 

Iodide Kinetics 

During Gestation: 

A PhysiologicallyBased 

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, et Department of Animal Experimental Dose, duration, Effects not 

Neonatal al. Defense design and and model studied (model 

Perchlorate Dose review/ controls developed). 

and Inhibition of reanalysis of 

Iodide Uptake in studies/data 

the Rat During 

Lactation Using 

PhysiologicallyBased 

Pharmacokinetic 

Modeling 

72 2003 PBPK Predictions Merrill, et al. Department of Animal Review/ Dose, duration, Effects not 

of Perchlorate Defense and Reanalysis of and model studied (model 

Distribution and its National studies/data controls developed). 

Effect on Thyroid Aeronautics 

Uptake of and Space 

Radioiodide in the Administration 

Male Rat 

73 2005 PBPK Model for Merrill, et al. Department of Animal Review/ Dose, duration, Effects not 

Radioactive Iodide Defense and Reanalysis of and model studied (model 

and Perchlorate National studies/data controls developed). 

Kinetics and Aeronautics 

Perchlorate- and Space 

Induced Inhibition Administration 

of Iodide Uptake in 

Humans 

Page 61 GAO-05-462 Perchlorate 
Appendix III


Perchlorate Health Risk Studies Published


Since 1998 


(Continued From Previous Page) 

Author’s 

findings/ 

conclusions 

about the 

adverse effects 

Publica- Sponsor/ Subject Design of perchlorate 

tion year Study title Author Recipient description Design type controls on health 

74 2002 The Yu, et al. Department of Animal Experimental Dose, duration, Nonadverse 

Pharmacokinetics Defense and design and model effects indicated. 

of Perchlorate and National controls No information 

its Effect on the Aeronautics available on 

Hypothalamus- and Space adverse effects. 

Pituitary-Thyroid Administration 

Axis in the Male 

Rat 

75 2004 Reference Dose for Strawson, et Toxicology Human Review/ Statistical Effects not 

Perchlorate Based al. Excellence for Reanalysis of controls, such studied 

On Thyroid Risk studies/data as (reference dose 

Hormone Change Assessment Environmental developed). 

in Pregnant Protection 

Women as the Agency 

Critical Effect protocols on 

Reference 

Dose risk 

assessment, 

and uncertainty 

factors 

76 1999 In Vitro Mammalian San and Perchlorate Animal Experimental Dose, No adverse effect 

Cell Gene Mutation Clarke Study Group design established indicated. 

Test (L5178Y/TK criteria for a 

Mouse Lymphoma mutagenesis 

Assay) assay 

77 2001 Uptake of the Anderson Strategic Plants Experimental Dose, duration, Effects not 

Perchlorate Anion Environmental design plant type, and studied. 

Into Various Plant and Research water v. sand 

Species Development 

Program 

78 2001 Effects of the Anderson Strategic Earthworms Experimental Dose, duration, Effects not 

Perchlorate Anion Environmental design and dermal v. studied. 

on Earthworms and Research soil contact 

Development 

Program 

Page 62 GAO-05-462 Perchlorate 
Appendix III


Perchlorate Health Risk Studies Published


Since 1998 


(Continued From Previous Page) 

Author’s 

findings/ 

conclusions 

about the 

adverse effects 

Publica- Sponsor/ Subject Design of perchlorate 

tion year Study title Author Recipient description Design type controls on health 

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 Letter: Channel Environmental Animal Experimental Dose No effects 

Kinetic Data for Protection design indicated. 

Iodide Uptake Agency and 

Inhibition in the Department of 

Thyroid by Defense 

Perchlorate (2-

Week Drinking 

Water Study) 

81 1999 Consultative Letter: Channel Department of Human Review/ See original Effects not 

Summary of Defense and Reanalysis of study for studied (model 

Human Kinetic National studies/data experimental developed). 

Data on Aeronautics controls 

Perchlorate and Space 

Administration 

82 2003 Effect of Tietge and Environmental Amphibians Experimental Dose and Nonadverese 

Perchlorate on Degitz Protection design duration effects indicated. 

Amphibian Agency Adverse effects to 

Development development 

indicated. 

83 1998 Benchmark Dose Geller Environmental Animal Review/ See original Effects not 

Calculations on Protection Reanalysis of study for studied 

Thyroid Data from Agency studies/data experimental (bechmark dose 

Studies Submitted controls developed). 

for Evaluation of 

Perchlorate 

Page 63 GAO-05-462 Perchlorate 
Appendix III


Perchlorate Health Risk Studies Published


Since 1998 


(Continued From Previous Page) 

Author’s 

findings/ 

conclusions 

about the 

adverse effects 

Publica- Sponsor/ Subject Design of perchlorate 

tion year Study title Author Recipient description Design type controls on health 

84 2004 Solid-State Proton Rosso and National Ammonium Experimental Temperature Effects not 

Conduction: An Ab Tuckerman Science Perchlorate design levels, and pure studied. 

Initio Molecular Foundation Crystal crystal v. 

Dynamics and Research neutral 

Investigation of Corporation ammonia doped 

Ammonium Research crystal 

Perchlorate Doped Innovations 

With Neutral 

Ammonia 

85 2002 Community Cancer Morgan and Not identified/ Human Field study Incidence rates, No adverse 

Assessment in Cassady Unknown age, sex, effects 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 identified/ Human and Review/ From original Effects not 

Differences in ski, et al. Unknown animal Reanalysis of studies studied. 

Susceptibility to studies/data 

Perturbation of 

Thyroid 

Homeostasis: A 

Case Study With 

Perchlorate 

87 2002 In Utero and Thuett, et al. Strategic Animal Experimental Dose and Adverse effects to 

Lactational Environmental design duration development 

Exposure to and Research indicated. 

Ammonium Development 

Perchlorate in Program 

Drinking Water: 

Effects on 

Developing Deer 

Mice at Postnatal 

Day 21 

Page 64 GAO-05-462 Perchlorate 
Appendix III


Perchlorate Health Risk Studies Published


Since 1998 


(Continued From Previous Page) 

Author’s 

findings/ 

conclusions 

about the 

adverse effects 

Publica- Sponsor/ Subject Design of perchlorate 

tion year Study title Author Recipient description Design type controls on health 

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. 

89 Since Iodide Transport in Harrison, et Howard Amphibian Experimental Dose Effects not 

1998 Xenopus Laevis al. Huges design studied. 

(precise Gut and Skin Medical 

year Institute and 

unknown) Texas Tech 

University 

90 2004 Ammonium McNabb, et Strategic Birds Experimental Dose and Nonadverse 

Perchlorate Effects al. Environmental design duration effects indicated. 

on Thyroid Research and No information 

Function and Development available on 

Growth In Program adverse 

Bobwhite Quail developmental 

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.) 

Page 65 GAO-05-462 Perchlorate 
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 

1

Castaic 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.) 

Page 66 GAO-05-462 Perchlorate 
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. 

Page 67 GAO-05-462 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 

2

Section 107 of the Federal Facility Compliance Act of 1992 amended RCRA by adding a new 

section 3004(y), codified at 42 U.S.C. § 6924(y) (2004). 

3

40 C.F.R. 266.202 (2004). 

4

A 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. 

5

The Safe Drinking Water Act regulates ammonium nitrate, benzene, cadmium, chromium, 

and lead—constituents commonly found in munitions. 

Page 68 GAO-05-462 Perchlorate 
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. 

6

40 C.F.R. 141.40. 

Page 69 GAO-05-462 Perchlorate 
Appendix V 

Comments from the Environmental 

Protection Agency 

Page 70 GAO-05-462 Perchlorate 
Appendix V


Comments from the Environmental 


Protection Agency


Page 71 GAO-05-462 Perchlorate 
Appendix VI 

Comments from the Department of Defense


Page 72 GAO-05-462 Perchlorate 
Appendix VI


Comments from the Department of Defense


Page 73 GAO-05-462 Perchlorate 
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. 

(360484) Page 74 GAO-05-462 Perchlorate 
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