PA/600/R-01/047
  I States
  mmental Protection
nyency       . »
Office of Research and
Development
Cincinnati-, OH 45268
EPA/600/R-01/047
May 2001
www.epa.gov
               Survey of Fertilizers and
               Related Materials for
               Perchlorate (CIO4~)

               Final Report
I

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                                                           EPA/600/R-01/047
                                                                May 2001
Survey of Fertilizers  and  Related

 Materials for  Perchlorate (CIO4~)




                    Final  Report

                              By

                       Edward Todd Urbansky
                  U.S. Environmental Protection Agency
                       Cincinnati, OH 45268

                        Timothy W.Collette
                  U.S. Environmental Protection Agency
                        Athens, GA 30605

                        Wayne P. Robarge
                    North Carolina State University
                      Raleigh, NC 27695-7619

                          William L. Hall
                           IMC-Global
                        Mulberry, FL 33860

                         James M. Skillen
                       The Fertilizer Institute
                       Washington, DC 20002

                          Peter F. Kane
            Office of Indiana State Chemist and Seed Commisioner
                    West Lafayette, IN 47907-1154
    This study was conducted in cooperation with North Carolina State University,
      IMC-Global, The Fertilizer Institute, the Office of Indiana State Chemist and
      Seed Commissioner, and the International Fertilizer Development Center.
              National Risk Management Research Laboratory
                  Office of Research and Development
                  U.S. Environmental Protection Agency
                       Cincinnati, OH 45268

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                                         Notice

       The U.S. Environmental Protection Agency, through the National Risk Management Research
Laboratory of its  Office of Research and  Development, managed and collaborated in the research
described here. It has been subjected to  the agency's peer and administrative review and has been
approved for publication as an EPA document. Mention of trade names or commercial  products does
not constitute endorsement or recommendation for use. In an effort to save paper and reduce  printing
costs, this report is being issued by the EPA only as an Adobe Acrobat portable document format (pdf)
file. Adobe Acrobat Reader is available free of charge via the Adobe website.

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                                        Foreword

        The U.S. Environmental Protection Agency is charged by Congress with protecting the nation's
land, air, and water resources. Under a mandate of national  environmental laws, the agency strives
to formulate and implement actions leading to a compatible balance between human activities and the
ability of natural systems to support and nurture life. To meet  this mandate, EPA's research program
is providing data and technical support for solving environmental problems today and building a science
knowledge base  necessary to manage our ecological resources wisely, understand  how  pollutants
affect our health, and prevent or reduce environmental risks in the future.

        The National Risk Management Research  Laboratory  is the agency's center for investigation
of technological and  management approaches for preventing and  reducing risks from  pollution that
threatens human health  and  the environment.  The focus of the laboratory's research program  is on
methods and their cost-effectiveness for prevention and control of pollution to air, land, water, and
subsurface resources; protection of water quality in public water systems; remediation of contaminated
sites, sediments  and ground water; prevention and control of indoor air pollution; and restoration of
ecosystems. NRMRL collaborates  with  both public  and private sector partners to foster technologies
that reduce the cost of compliance  and to anticipate emerging problems. NRMRL's research provides
solutions to environmental problems by developing and promoting technologies that protect and improve
the  environment; advancing  scientific and  engineering information  to support regulatory and policy
decisions; and providing the  technical support  and  information transfer to ensure implementation of
environmental regulations and strategies at the national, state, and community levels.

        This publication has been produced as part of the laboratory's strategic long-term research
plan. It is published and made available by EPA's  Office of Research and  Development to assist the
user community and to link researchers with their clients.
                                              E. Timothy Oppelt, Director
                                              National Risk Management Research Laboratory

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                                         Contents

Notice 	ii

Foreword  	 iii

Abstract	 iv

Contents	v

Tables and figures 	 vi
1   Environmental perchlorate- what role for fertilizer?  	 1
    1.1 Introduction 	 1
    1.2 Fertilizer manufacture and use	 1
        1.2.1 Nutrient availability	 1
        1.2.2 Nitrogen sources  	 2
        1.2.3 Phosphate sources 	 5
        1.2.4 Potassium sources 	 5
        1.2.5 Information sources	 6
    1.3 Previous fertilizer analysis studies	 7

2   Survey of fertilizers and related materials  	 9
    2.1 Objectives 	 9
    2.2 Phase 1—Evaluation of laboratories	 9
    2.3 Phase 2—Analysis of samples	 10
        2.3.1 Sampling and analysis strategy 	 10
        2.3.2 Results 	 11
        2.3.3 Discussion	 11

3   Implications for vascular plants	 18
    3.1 Introduction 	 18
    3.2 Complicating factors 	 18
        3.2.1 Chemical influences on ion transport  	 19
        3.2.2 Concentration  	 19
        3.2.3 Tissue-specific accumulation 	 20
        3.2.4 Soil sorption	 20
        3.2.5 Summary  	 20
    3.3 Difficulties in analysis 	 21
    3.4 Implications of perchlorate absorption and accumulation  	 21
References  	 23

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                                 Tables and Figures

Tables

1.1  Some common agricultural fertilizers used in production farming	 2

1.2  Consumption (in tons) of nitrate salts in regions of the continental United States
    for the year ending June 30,1998	 4

1.3  Annual consumption/application (in tons) of some nitrogen fertilizers for several states	 4

1.4  Annual production (tonnage) of nitrate salts by some manufacturers who
    supplied the U.S. marketplace	 5

2.1  Fertilizers and related materials surveyed for perchlorate	 13

2.2  Summary results for perchlorate concentration detected by replicate
    analyses of samples listed in Table 2.1 	 15

2.3  Tested fortifications (spikes) and recoveries in solutions of samples listed in
    Tables 2.1-2.2 	 17


Figures

1.1  Schematic of urea production  	 2

1.2  Synthesis of nitric acid by the redox reaction of ammonia and atmospheric oxygen 	 4

1.3  Schematic of ammonium nitrate production	 4

1.4  Operational schematic of phosphate rock processing	 5

1.5  Bucketwheel used in mining phosphate rock	 5

1.6  Agricultural DAP 	 5

1.7  The mineral sylvite (KCI)	 6

1.8  Canadian potash mines can be kilometers below the surface  	 6

1.9  Sylvite  and sylvinite can be mined by dissolving the minerals in the water and
    pumping the brine to the surface	 6

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                                                Acknowledgments
    We acknowledge the following individuals and institutions for their assistance in the completion of this project. This includes the services of
participating laboratories, state regulatory agencies, and industry employees.
Jay Johnson & Kent W. Richman
American Pacific Corporation
Cedar City, Utah

Stanley Kobata, Harry Welte & Paul Roos
California Department of Food and Agriculture
Sacramento, California

Thomas E. Carville, Carol F. Schexnaydor & Jesus I. Peralta
CF Industries
Donaldsonville, Louisiana, and Washington, D.C.

D.H. Thomas, P.E. Jackson & J.S. Rohrer
Dionex Corporation
Sunnyvale, California

Catherine A. Kelty, Stephanie K. Brown, Matthew L. Magnuson, J.
Jackson Ellington & John J. Evans
U.S. Environmental Protection Agency
Cincinnati, Ohio, and Athens, Georgia

David F. Graves & John B. Sargeant
Florida Department of Agriculture and Consumer Services
Tallahassee, Florida, and Lakeland, Florida

Steve Gamble
IMC-Kalium
Carlsbad, New Mexico

Linda Weber, David Gadsby, Bonnie Lingard,
Daphne Williams, Charles Kinsey, Julie Thompson,
Pam Burgess & Dennis Sebastian
IMC-Phosphates Environmental Laboratory
Bradley, Florida

George A. Kennedy, Celia G. Calvo, Bobby W. Biggars,
& Steven J. Van Kauwenbergh
International Fertilizer Development Center
Muscle Shoals, Alabama
Ali Haghani and Andrew Eaton
Montgomery Watson Laboratories
Pasadena, California

Tina Sack
New Mexico Department of Agriculture
Roswell, New Mexico

Michael Hancock
Office of Indiana State Chemist and Seed Commissioner
West Lafayette, Indiana

George W. Latimer
Office of Texas State Chemist
College Station, Texas

Guillermo Ramirez
North Carolina State University
Raleigh, North Carolina

Baohua Gu
Oak Ridge National Laboratory
Oak Ridge, Tennessee

Richard A. Beidelschies
Ohio Department of Agriculture
Reynoldsburg, Ohio

B.H. James, A.A. Coe & Ray Poole
PCS Phosphate
Aurora, North Carolina

Gene H. Williams & Sanford Simon
Pursell Industries
Orrville, Ohio, and Birmingham, Alabama

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                                                         Chapter 1
                        Environmental perchlorate:  what role for fertilizer?
1.1. Introduction
     Perchlorate was discovered in U.S. waterways in the late 1990s.
Most perchlorate salts are used as solid oxidants or energy boosters in
rockets or  ordnance; therefore, much  of the perchlorate-tainted
waterways in the U.S. can be traced to military operations, defense
contracting,  or manufacturing facilities. Perchlorate ion is  linked to
thyroid dysfunction, due to its similarity in ionic radius to iodide
(Clark, 2000). Becauseperchlorate-tainted waters are used for irrigation,
there are questions about absorption, elimination, and retention in food
plants. Furthermore, recent reports have suggested that fertilizers could
represent another source of perchlorate in the environment. Sporadic
findings of perchlorate in fertilizers were initially alarming because of
the widespread use of fertilizers in production farming. Because of the
dependence ofU.S. agriculture on chemical commodity fertilizers, it was
clear that assessment of any  possible role of fertilizers would require
investigation.

     Attention has been drawn to the possible roles of fertilizers in
environmental perchlorate contamination for  two reasons. First,
perchlorate-tainted agricultural runoff could lead to pollution of natural
waterways used as drinking water sources. Second, there is a potential
for food plants to take up soluble compounds—including perchlorate
salts—and thus provide an alternate route of exposure. It has long been
known that Chile possesses caliche ores rich in sodium nitrate (NaNO3)
that  coincidentally are also a natural source of perchlorate (C1O4~)
(Schilt, 1979; Ericksen, 1983). The origin of the sodium perchlorate
(NaClO4) remains an area of debate, but it is nonetheless present  and
can be incorporated into any products made from the caliche.

1.2. Fertilizer manufacture and use
     American farmers apply about 54 million tons of fertilizer yearly.
As with many commodity chemicals, large scale purchases are dictated
by cost of raw materials, which are in turn normally influenced by
transportation costs. Thus, proximate (rather than distant) sources of
agricultural  chemicals are likely  to play the greatest roles in local
ecosystems involved in production farming. In addition, processingaids
(e.g., clays) are likely to  be derived from the closest possible source.
Production farming relies on cheap and available sources of primary
plant nutrients (macronutrients): nitrogen, phosphorus, and potassium.
Fertilizer grades  (or guaranteed analyses) are expressed using the
convention of Samual Johnson, a student of Justus Liebig, who has been
called the "father of the fertilizer industry." In the Johnson convention,
nitrogen is expressed as a mass fraction (weight percent) as it was
originally  determined by  the Kjeldahl method.  Phosphorus and
potassium are denoted in terms of the minerals formed by ashing at high
temperature. Thus, phosphorus is expressed as the mass fraction of the
empirical formula of its oxide, diphosphorus pentoxide (P2O5), and
potassium is expressed as the mass fraction of its oxide, potassium
oxide (K2O). This nomenclature does not reflect the actual composition
of the fertilizer, however, nor current practice in assaying it.

1.2.1. Nutrient availability
     To minimize the need for multiple applications and to prevent
overdosing, timed-, delayed-, or controlled-release fertilizers are used in
both agricultural  and horticultural  applications.  There are  two
mechanisms to delay nutrient release. The first is to use essentially
insoluble minerals that are not readily converted to absorbable aqueous
phase  nutrients,  for example phosphate rock or other  calcium
phosphates.  The  second is  to coat the soluble fertilizer with an
insoluble material, such as a urea-based polymer or sulfur. This is often
done with consumer products, e.g., lawn fertilizers. Most urea-based
polymers  are  methylene ureas or urea-methanal  blends. As urea
polymers are hydrolyzed, they too serve as a source of nutrients.

     Many commodity chemicals used as agricultural fertilizers contain
fairly high concentrations of one, or sometimes two, of the primary
plant nutrients (Table  1.1).  Trace  metals (e.g., boron, copper,
magnesium) can be  applied separately or along with these primary
nutrients on a farm site. Fertilizer application in production farming is
highly dependent on the crop and the native soil. Crops are influenced
by climate, weather, topography, soil type, and other factors that are
generally similar within a geographical  region; therefore, crops and
fertilizer use are also similar within such a region. This is of course
unsurprising and consistent with agricultural production of dairy foods,
com, tobacco, wheat, etc. Because all plants require the same primary
nutrients, there is some usage to provide theseregardless of crop. Local
soil conditions also  dictate what nutrients should be augmented, and
there can be large regional variations.
                                                               1

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Table 1.1. Some common agricultural fertilizers used in produc-
tion farmingf	
  Chemical name
   Chemical
    formula
Grade
(N-P-K
 ratio)
  Ammonia
  (anhydrous)
  Ammonium nitrate
  Urea
  Ammonium
  monohydrogen
  phosphate
  (diammonium
  phosphate)
  Potassium chloride
  (pure)
  Potassium
  magnesium sulfate
  Triple super-
  phosphate
      NH,
82-0-0
NH4NO3
(NH2)2CO
(NH4)2HP04
34-0-0
46-0-0
18-46-0
      KCI
   K2Mg2(S04)3
0-0-62
0-0-22
Ca(H2PO4)2'H2O*      0-46-0
tMostsolidfertilizers contain processing aids (e.g., clays) that
keep the product from becoming a  solid  mass. Granular
products are often dusted with these.  'Triple superphosphate
is a somewhat ill-defined substance, being a slightly hydrous
mixtureofcalcium hydrogen phosphates (variable protonation).
It is represented here as calcium dihydrogen phosphate mono-
hydrate, but that compound is the main component and not the
only component.

    On the other hand, consumer products can be distributed over
larger geographical regions because of the  nature of the market. For
example, major manufacturers have a limited number of sites dedicated
to blending multiple-nutrient formulations. These products are often
sold as bagged fertilizers through home-improvement centers, nurseries,
florists, horticulturists, and department (or other retail) stores. Unlike
agricultural fertilizers, consumer products  are usually multi-nutrient
formulations. In addition, trace metals are  sometimes  incorporated
directly into them. Because the average user will apply only a very
small  amount of trace metals (or even primary nutrients) relative to a
production farm, it  is more  economical,  more practical, and more
convenient touse multiple-nutrient formulations. Moreover, the average
consumer does not have the wherewithal to disperse careful doses  of
several single-component fertilizers at the appropriate  times of the
growing season.

    Multiple-component fertilizers can be timed (controlled) releaseor
soluble blends.  Many multiple-component products are intended for
soil amendment to lawns or gardens, e.g., 10-10-10, and other common
multiple-macronutrient formulations. Water-soluble blends are used to
supply nutrients rapidly to growing plants and are generally applied
repeatedly during a growing season (as with each watering), whereas
timed-release fertilizers allow water t o leach nutrients slowly for release
to the soil and plants. They are applied perhaps once or twice a year,
e.g., a lawn winterizer. Obviously,  soluble and  insoluble fertilizers
cannot be entirely identical chemically. However, the distinction is
essentially irrelevant for agricultural fertilizers, which are applied to
fortify particular nutrients. Of course, allowances must be made forthe
bioavailability of these nutrients.  As a general rule,  agricultural
fertilizers are soluble chemicals. Because  fertilizer application on
production farms is geographically delimited, there is considerable
interest in knowing  which  commodity chemicals might contain
perchlorate and how much. Such information might suggest regions for
further investigation. Moreover, it will be important to know what
crops might potentially be affected—if any.

1.2.2. Nitrogen sources
                                                                     urea •«H1ttntriftigt"
                                      Figure 1.1. Schematic of urea production.

                                          The simplest nitrogen source is anhydrous liquid ammonia. Liquid
                                     ammonia is stored in bulk tanks and injected directly into the soil. No
                                     fertilizer has a higher nitrogen content. Ammonia is made using the
                                     Haber process, which entails  heating desiccated nitrogen (separated
                                     from liquified air) and hydrogen (usually from methane) in the presence
                                     of a catalyst at 500-700 °C.
                                          Urea is also a common source of nitrogen. Highly soluble in water,
                                     urea hydrolyzes to carbonic  acid and ammonia, given time.  The
                                     industrial process used to synthesize urea is shown in Figure 1.1. In
                                     addition to its use as a fertilizer, a special feed grade of urea is used to
                                     supplement cattle feed.

                                          Nitrate salts are also used as fertilizers. Ammonium nitrate is the
                                     primary  nitrate salt used  in production  farming. Most—if not
                                     all—ammonium nitrate today is made from atmospheric gases. None of
                                     the  major nitrogen fertilizer producers  [Potash  Corporation of
                                     Saskatchewan (PCS), Agrium, Coastal, Mississippi Chemical, Kemira
                                     Dansmark, and IMC] use natural saltpeters in manufacturing. IMC and
                                     PCS do not sell nitrate-based fertilizers, focusing instead on urea,
                                     ammonium  phosphates,   and  similar  nitrogenous  compounds.
                                     Consequently, perchlorate contamination is not possible from the raw
                                     materials. Ammonium nitrate is prepared from nitric acid and ammonia.
                                     Nitric  acid is manufactured by  the  process shown in Figure  1.2.
                                     Ammonium nitrate is produced as shown in Figure 1.3.

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                    stone
                dehydrating
                    tower
                                     90%HN03gas
                                    -75% HzSO4 liquid
Figure 1.2. Synthesis of nitric acid by the redox reaction of
ammonia and atmospheric oxygen. A1:9 ratio of ammonia
and air pass through Rh/Pt gauze. The cooled nitric oxide
and oxygen pass into an absorber where more air is added
and the NO  is converted to nitrogen dioxide. The nitrogen
dioxide undergoes hydrolytic disproportionationtogive nitric
acid with NO as a byproduct. After dehydration, the nitric
acid vapor is recovered from the gas phase.
                          95%
                        NH«NOj

      IMeter •-
                                                product
 Figure 1.3. Schematic of ammonium nitrate production.
 Aqueous  nitric  acid  and   anhydrous  ammonia  are
 combined to produce the salt, which is then prilled and
 dried.
    The alkali metal saltpeters (sodium andpotassiumnitrates) are also
used as nitrogen sources. Their mineral forms are known as soda niter
(nitratine) and potash niter (nitrine), respectively.  Chile  saltpeter
(NaNO3) is mined from  caliche ores in the North. The mined rock
contains veins rich in sodium nitrate. The ore is crushed and mixed with
water to dissolve the soluble salts. The sodium nitrate is then recovered
from the leachate. Chile's Sociedad Quimica y Minera S.A. (SQM)
reports annual production of about 992,000 tons of nitrate products.
SQM North America sold some 75,000 tons to U.S. farmers in 1998.
The company touts its products primarily for cotton, tobacco, and
citrus fruits. It  is the caliche ores that contain naturally  occurring
perchlorate. No other company sells a product derived from caliche as
of this writing;  however, Potash Corporation of Saskatchewan does
own caliche mines in Chile (Searls, 1999; EIU,  1999)

    Because nitrate salts (saltpeters) find use as fertilizers, these
natural resources have been mined and refined to produce commercial
fertilizers for domestic use or for export. Chilean nitrate fertilizers
(NaNO3 and KNO3) are manufactured by SQM. SQM markets  its
products in the U.S. under the name Bulldog Soda.  Chilean nitrate salts
are sold to agricultural operations, chemical suppliers, and consumer-
oriented companies such as Voluntary PurchasingGroups, Inc., or A.H.
Hoffman, Inc., who repackage and resell it as Hi-Yield* or Hoffman®
nitrate of soda, respectively. Also, secondary  users may incorporate
Chilean nitrate salts into water-soluble plant foods, lawn fertilizers, and
other retail (specialty) products.

    Due to their  cost  and availability,  Chilean  nitrates  are niche
fertilizers. SQM markets its products to growers of tobacco, citrus
fruits, cotton, and some vegetable crops, particularly emphasizing that
the products are low in chloride content (CNC,  1999). As noted above,
typical American fertilizer consumption is 54 million tons per year;
consequently,most U.S. fertilizers arederived from other raw materials.
For example, ammonium nitrate (NH4NO3), which is often used for
purposes similar to NaNO3, is manufactured from methane, nitrogen,
and oxygen. There is no evidence that any ammonium nitrate is derived
from Chilean caliche. On account of its low usage, perchlorate from
Chilean nitrates cannot represent a significant anthropogenic source of
perchlorate nationwide, regardless of the perchlorate content.  Recent
examination of two manufacturing lots found perchlorate concentrations
below  2 mg g"1, i.e., < 0.2% w/w, with some lot-to-lot variability
(Urbansky, 2001). However, in a recent letter to  EPA, SQM North
America's President Guillermo Farias indicated that SQM had modified
its refining process to produce fertilizer containing less than  0.01%
perchlorate (<0.1 mg g"1); this corresponds to a reduction of 90-95%.
SQM monitors  its production stream every 2 hours  to  verify the
perchlorate concentration. Accordingly, previous data on perchlorate
content are only applicable in a historical sense rather than being
reflective of ongoing fertilizer use.

    As Table 1.2 indicates, there is limited  application of natural
saltpeters as fertilizers in the U.S. based simply on total consumption.
There just is not enough production of the natural materials. Some
states keep  detailed records on fertilizer use, especially of chemical
commodities used in production farming,  but others do not. For
example, the Office of Indiana State Chemist is required to keep track
of only the top ten fertilizers; even ammonium nitrate is not among the
top ten in Indiana. As a result, it is not easy to discern the potential
distribution of minor fertilizers known to contain traces of perchlorate
salts.  Table  1.2 gives the tonnage for a few  nitrogen  fertilizers for
several states. Many states do not keep records as  detailed as those of
the Office of the Texas State Chemist, which tracks each fertilizer by
grade (N-P-K ratio) and tonnage. The Corn Belt relies heavily on urea

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and anhydrous ammonia as nitrogen sources, as shown by Indiana and
Ohio  consumption  of these two chemicals in Table 1.3, while
ammonium nitrate finds greater use in tobacco-farming states.

Table 1.2. Consumption (in tons) of nitrate salts in regions of
the continental United States for the year ending June 30,1998
Region
New
England
Mid-Atlantic
South
Atlantic
Midwest
Great Plains
East South
Central
West South
Central
Rocky
Mountain
Pacific
U.S. Total*
NH4*
2,469
33,556
162,035
81,585
436,371
489,603
338,618
254,168
148,340
1,946,868
Na*
194
260
14,87
0
189
409
7,786
4,192
831
10,28
1
39,01
3
K*
142
12,06
4
17,30
8
1,496
296
2,122
652
9,022
146
46,10
0
Na*/K*
0
0
21,76
2
5
55
914
2,851
0
0
22,76
2
Key: New England (ME, NH, VT, MA, Rl, CT); Mid-Atlantic (NY,
NJ, PA, DE,  MD, WV); South Atlantic (VA, NC, SC, GA, FL);
Midwest (OH, IN, IL, Ml, Wl); Great Plains (MN, IA, MO, ND, SD,
NE,  KS); East South  Central  (KY, TN, AL, MS); West South
Central (AR, LA, OK, TX); Rocky Mountain (MT, ID, WY, CO, NM,
AZ, UT, NV); Pacific (CA, OR, WA); *Total U.S. includes HA, AK,
PR.  Source:  Association of  American  Plant  Food  Control
Officials/The  Fertilizer Institute, Commercial Fertilizers 1998.
D.L. Tern/and B.J. Kirby, Eds. Universityof Kentucky: Lexington,
KY, 1998.

    Sodium and potassium nitrates make up a small fraction of the
nitrate application in the United States; however, prior to the establish-
ment of nitric acid and ammonia factories, natural saltpeters played
significant roles in American agriculture. In addition, ammonium nitrate
was  manufactured from Chile saltpeter before  the industrialized
oxidation of ammonia to nitric acid became commonplace  in the 1940s.
Decades ago, ammonium nitrate was prepared from Chilean sodium
nitrate by ion exchange rather than from gaseous reactants. Historical
use of ammonium nitrate previous to or in the first half of the 20th
century might  be linked to contaminated groundwater, and has been
attributed toonemanufacturingfacility in Arizona (EPA, 1999). On the
other hand, a recent survey of water supplies forperchloratewas unable
to detect perchlorate in nearly  all of them,  and concluded  that
perchlorate contamination is generally  localized and related to point
sources (Gullick, 2001). Reliable data on the use of natural saltpeters
appear to be unavailable. While most nitrate salt manufacturers rely on
ammonia oxidation (Table 1.4), which  is a chlorine-free process, the
possibility of contamination from products derived from Chile saltpeter
cannot be ignored.

    The lack of information on natural attenuation as well as limited
knowledge of hydrogeology makes it difficult to determine where and
how such problem sites might be found.  For this reason, monitoring for
perchlorateunderthe EPA's Unregulated Contaminant MonitoringRule
for drinking water can be expected to provide some of the most useful
information. Meanwhile, it is instructive to consider the processes by
which major nutrients are produced so as to evaluate the possibilities
for contamination.
                                                              Table 1.3. Annual consumption/application (in tons) of some
                                                              nitrogen fertilizers for several states	
                                                                                 NH3'
                                                                               82-0-0
                              Urea
                             46-0-0
NH4NO3      KNO3
 34-0-0   14-0-46
  State

  Arkansas*       1,207    465,737     62,003     N.R.t

  Georgia0        3,859      15,084     56,215       N.R.

  Indiana*       193,347     48,478       N.R.       N.R.

  Maryland§       1,155      11,614      9,518       N.R.

  New           13,747     34,348      2,725       N.R.
  Mexico*

  Ohio*          86,499    115,180      7,516       N.R.

  Texas"       142,383     74,235     80,120     1,115

  West              390      4,476      1,283       N.R.
  Virginia*
•Anhydrous. *1998. §July 1998-June 1999. *1997. **March-
August 1998. tN.R. = not reported. DJuly 1998-June  1999.
Sources: Arkansas State Plant Board; Association of American
Plant Food Control Officials; PlantFood, Feed, & Grain Division,
Georgia Department of Agriculture; Office of Indiana State
Chemist and Seed Commissioner; Maryland Department of
Agriculture, Office of Plant Industries and Pest Management,
State ChemistSection; Feed, Seed, andFertilizerBureau.New
Mexico  Department of Agriculture; Office of the Texas State
Chemist; West Virginia Agricultural Statistics Service.

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Table 1.4. Annual production (tonnage) of nitrate salts by some manufacturers who supplied the U.S. marketplace*
Company
Agrium§
Calgary, Alberta, Canada
Coastal Chem, Inc.
Cheyenne, WY§§
Kemira Danmark§
Fredericia, Denmark
Vicksburg Chemical Co.§
Vicksburg, MS
ammoxt
KNO3
npfl
np
3239
151,000
ammox
NaNOa
np
np
np
np
ammox
NH,NO3
630,000
306,180
np
np
ammox
HN03
np
245,164
np
np
Chilean
NaNOj
546J
np
np
np
Chilean
KNO3
652t
np
np
np
*Anumberof companies with smaller production outputs make NH4NO3 and urea, such as Apache Nitrogen Products Inc., which
manufactured 50,000 tons of fertilizer in 2000. This table excludes sales from SQM.fTheterm "ammox" refers to use of ammonia
oxidation to produce nitric acid. §Actual or estimated production for 2000. IfThe designation "np" means that the manufacturer
reported to EPA that this material was not a product. JThis  material was sold by Western Farm
Services, an Agrium subsidiary, and was reported to have "little to no detectable  perchlorate" *«>(:
according to information provided by Agrium to EPA. §§Actual production for 1999.
1.2.3. Phosphate sources
    Phosphate rock is mined in a number of states, including Florida,
Idaho, and Montana. Florida's phosphate rock deposits are near the
surface (~8 m down) and formed 5-15 million years ago. They are
obtained by removingthe overburden (coveringrock). Figure 1.4 shows

                                                                                         Figure 1.5. Bucketwheel used
                                                                                         in   mining  phosphate  rock.
                                                                                         Photo © PCS Phosphate. Used
                                                                                             permission.
phosphate rock processing In
North Carolina,  overburden is
taken up via bucketwheel (Figure
1.5). Natural phosphate rocks
usually contain a mixture of the
apatite minerals. Fluoroapatite
has  the   empirical   formula
Ca5(PO4)3F.
    Ammonium monohydrogen
phosphate, (NH4)2HPO4, is commonly referred to as DAP in  the
agricultural chemical industry, short fordiammonium phosphate. DAP
is a source of both nitrogen and phosphorus and has a grade of 18-46-0.
The ACS reagent is a white crystalline material; MIST sells J.T. Baker
Ultrex ammonium monohydrogen phosphate as SRM 694 for use by
fertilizer manufacturers in assaying this material. However, agricultural
DAP is generally a mixture of gray, brown, and/or black pellets (Figure
1.6). Some of this color is due to
residual calcium  minerals  (e.g.,
apatites, gypsum) and some is
due to natural organic matter.
Most agricultural DAP contains
6-15  mol%  NH4H2PO4 or
monoammonium   phosphate
(MAP).
                            Figure  1.6.  Agricultural  DAP,
    In the Corn Belt, granular product provided courtesy of CF
triple superphosphate or GTSP industries.
(0-46-0) and DAP, dominate the
market. About 82% of the ort/io-phosphoric acid produced in the U.S.
goes into fertilizer manufacture, with 49% into DAP and 10% into
MAP.
Figure 1.4. Operational schematic of phosphate
rock processing. MGA refers  to merchant grade
acid. © PCS Phosphate. Used with permission.

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Figure 1.7.The mineral sylvite (KCI). The red or brown color
comes  from  occluded  hematite  (Fe203)   or  limonite
(Fe(O)OHv?H2O). Materials provided courtesy of Kova, Inc.,
(left) and CF Industries, Inc. (right).

1.2.4. Potassium sources
     Essentially no potash (K2O/K2CO3) is used as a fertilizer today,
but many products are referred to as potash for historical reasons.
Potassium nitrate and potassium chloride (muriate of potash, MOP)
dominate this market. Sylvite (KCI) is mined in Canada, and is the most
popular potassium source in the Corn Belt. Both Saskatchewan and
New Brunswick have sylvite and/or sylvinite mines.  The red material
on the left in Figure 1.7 has a guaranteed analysis of 0-0-60, while the
purer material on the right is guaranteed at 0-0-62, which represents the
maximum, within the limits of experimental error.

     Sylvinite (43% KCI, 57% NaCl) deposits occur in New Mexico
and can be refined to remove much of the halite (NaCl). New Mexico
also  has reserves of sylvite and langbeinite [potassium magnesium
sulfate, K2M§2(864)3 or 2K2SO4'MgSO4]. Langbeinite is popular in
dairy country as a source of magnesium.

     Like Chile saltpeter, these minerals are marine evaporites resulting
from the drying up of terminal inland seas.  In most cases, deposits of
                 H
                         /\
                                  [1-OreSMBB
                               D
Figure 1.8. Canadian potash mines can be kilometers
below  the  surface. ©  PCS  Potash.  Used  with
permission.
                              Ewaottn
                        Floating   \
                        Dredge     V
                                                                                                                    Injection
       Figure  1.9.  Sylvite  and  sylvinite can be mined  by
       dissolving the minerals in water and pumping the brine
       to the surface. © PCS Potash. Used with permission.

sylvite are hundreds or thousands of meters below the surface, having
been covered over by sedimentary rock formations over some 300
million years.

    The market is  dominated by two producers, IMC-Kalium and
PCS. PCS has deep mines that rely  on traditional techniques (Figure
1.8) and solution mines that make use of the solubility of the minerals
(Figure 1.9).

1.2.5.  Information sources
    Information on fertilizer production and application comes from
a variety of sources, including trade organizations, manufacturers, and
government (state/federal) agencies. Both the U.S. Census Bureau and
the U.S. Geological Survey track fertilizer commodities. The Census
Bureau's Economics and Statistics Administration publishes an annual
report  (MA325B, formerly MA28B) as well as quarterly reports
(MQ28B) on inorganic fertilizer materials and related products. The
Geological Survey publishes reports on fertilizer minerals that cover
manufacture, use, regulation, litigation, and other matters (Cf. Lemons
1996;Searls, 1999). Natural Resources Canada also publishes aminerals
yearbook (Cf. Prud'homme, 1998). Most publications are available
online.

    Because data are  obtained through many sources, it is common for
there  to  be inconsistencies  as  well as apparent  inconsistencies.
Apparent inconsistencies sometimes stem from how  materials  are
tracked. For example, an apparent inconsistency  in the data between
Tables 1.2 and 1.4 relates to ammonium nitrate production (-940,000
tons)  versus consumption (1.8 million  tons). However, Table  1.4
neither includes all manufacturers, nor product blends. In addition, the
tables do not account  for normal fluctuations in inventory. In other

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words, a material produced in one year may be  sold or used the
following year. Taken together, these factors increase the difficulty in
monitoring  the  application  of or  tracking transactions  involving
perchlorate-containing materials.

1.3. Previous fertilizer analysis studies
     Aside from the analyses of Chilean caliche, there were no studies
to suggest that any other processed fertilizer or raw material might
contain perchlorate prior to 1998. That year the Ecosystems Research
Division of the EPA's National Exposure Research Laboratory (EPA-
ORD-NERL-ERD) found perchlorate in several samples that were not
derived from Chile saltpeter (Susarla, 1999D). This finding was later
duplicated  by other investigators from  the North  Carolina State
University  Department of Soil Science. However, the presence  of
perchlorate could only be confirmed in consumer products, and not in
agricultural fertilizers. Moreover, subsequent analyses of different bags
(likely different lots) of many of the same brands and grades did not
show perchlorate (Susarla,  2000; Williams, 2001). The choice  of
fertilizers is  problematic because the same raw materials may be used
in a variety  of products at a point in time. Additionally, a few major
companies are responsible for makinga large number of products under
several brand names. Furthermore, some companies rely  on  toll
manufacturing so that  the products are actually  made by another
company to meet a specific formulation.  Accordingly, an error or
contamination associated with one raw material could affect a variety of
products without regard to company or application. Since those early
days, each subsequent study on fertilizer has attempted to address more
issues, and study designs have been continually refined based on what
was learned in previous investigations.

     The EPA-ORD-NERL-ERD study brought to light a number of
important issues for trace analysis  of  fertilizers. First, most of the
research on determining perchlorate to  that time had been focused on
either finished potable water or raw source water (Urbansky, 2000F).
Second, fertilizers are considerably more  complicated matrices  than
dilute water solutions. Third, solid fertilizers are not homogeneous. In
fact, some  are macroscopically heterogeneous,  for example, multi-
component formulations used as lawn and garden  fertilizers. It is
possible to sort out  the particles  by hand. Thus,  representative
samplingbecomes akey issue. Fourth, the effectiveness of the leaching
step must be evaluated. Fifth, the materials must be carefully selected
to properly reflect the market of interest, e.g., production farming, lawn
treatment, vegetable gardens, houseplant foods.

     About the same time as the EPA-ORD-NERL-ERD study, the
U.S.  Air Force Research Laboratories (AFRL) performed a study to
assess interlaboratory corroboration, that is, the ability of different labs
to analyze the same sample and get the same result (Eldridge, 2000).
Samples of a variety of lawn and garden fertilizers were selected from
around the  country. The AFRL  study used a  number of products.
These included four brand name products from New York, three from
Missouri, and one from California. Overall, these represented multiple
lots of four brand name fertilizer products, with some different lots of
the same products coming from different cities. The AFRL study did
not account  for the sources of the commodity chemicals blended into
these products, and it did not link manufacturing lots with lots of raw
materials. Even bagged fertilizers from different manufacturing lots may
be  comprised from  some of the  same raw  materials.  Therefore,
limitations in choice of products prevent extrapolating the results to
large scale fertilization (as in production agriculture).

     An AFRL contractor was  tasked with leaching or dissolving the
materials and parceling out the liquid samples to 7 laboratories running
1C  and 3 using other techniques (capillary  electrophoresis,  tetra-
phenylstibonium titrimetry, and Raman spectrometry). Each laboratory
was sent a sample of the same test solution for analysis. Laboratories
were permitted to use any means of analysis. Ion chromatography,
capillary electrophoresis, titrimetry, and Raman spectrometry were all
employed. Interlaboratory agreement was generally good, indicatingthat
laboratories  were  able to  determine  perchlorate  in the fertilizer
solutions, despite matrix complexity. Quality control checks  were
limited to performance  on deionized water  blanks and perchlorate
solutions prepared from deionized water; laboratories were not required
to show performance on fortified samples (spike recovery). Some of the
samples failed to show Raman scattering lines consistent with their
major components; this matter was not addressed.

     While interlaboratory agreement was  good on the liquid solutions,
values  for leachates derived from different samples of the same lot of
material varied substantially in some cases. Heterogeneity of bagged
fertilizer products  (especially multiple  component  products) was
therefore demonstrated to be a significant matter by the AFRL study.1
Specifically, duplicate samples of solid from  bagged fertilizers  gave
aqueous leachates withconsiderable differences in measured perchlorate
concentration: 5.8 ± 0.5 mgg"1 versus 2.8  ± 0.3 mg g~' for one product
and 0.98 ± 0.14 mg g~' versus 2.7 ± 0.3 mgg~' for another [values here
are the average and estimated standard deviation for 10 results (each of
which is  an average for one of 10 methods]. Such variation may be
attributable to sampling error and does not necessarily reflect an actual
difference. EPA-ORD-NERL-ERD has observed even wider variation
in grab samples, with some measured concentrations as  much as 5-7
times larger than others.  When some of the  same products  were
subjected to sampling scheme intended to yield a more representative
sample, considerably  lower intersample variability  was observed
(Williams, 2001). Less striking variation in perchlorate distribution
within and among bags of sodium nitrate fertilizer has been seen for
small grab samples of solids, but can be  eliminated by more rigorous
sampling or by choosing larger sample sizes (Urbansky, 2001).

     For one product in the AFRL study, perchlorate concentrations in
the first  solid sample taken were below the detection  limit  in one
'Here,  we call  these products bagged fertilizers even  though some are  sold
in  boxes or jars; this contrasts with bulk  fertilizers sold by railway  car or
track and  then used  for  agricultural  purposes  (or  eventually  incorporated
into a bagged fertilizer). Such  products are usually referred to  as specialty
fertilizers  within  the  industry.  While  some   products  are  specifically
manufactured so as to  assure  uniform distribution  of  macronutrients  and
micronutnents,  it is unclear whether  perchlorate contamination would  also
be  homogeneous.

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leachate, according to all labs. A second solid sample contained 2.7 ±
0.3 mg g"1, based on its leachate [value is the average and estimated
standard deviation for 10 results (each of which is an average for one of
10 methods)]. It is unclear whether sampling error alone can account for
the disparate values. The  analytical laboratories were sent the same
leachate (one for each solid) and were not working with different
portions of the solid. While the  AFRL used the data only to assess
interlaboratory  corroboration  of fertilizer analysis  by ion chroma-
tography, the results also confirm that there was perchlorate in some of
the materials purchased during a specific time period. However, no
conclusions should be drawn regarding perchlorate concentrations in
specific lots or brands of fertilizer because the inconsistencies in the
data were  not  explored  further and  the  sampling approach  was
restrictive in nature.

     Subsequently, the Water Supply and Water Resources Division of
the EPA's  National Risk Management Research Laboratory (EPA-
ORD-NRMRL-WSWRD) conducted its own survey of fertilizers in a
collaboration with the Department of Energy's Oak Ridge National
Laboratory (Urbansky, 2000A;  Urbansky, 2000D). In addition to a
variety of products purchased from home improvement, garden supply
or department  stores, products were purchased from farming supply
stores (e.g., 50-lb bags of urea or ammonium nitrate)  in Indiana, Ohio,
Kentucky,  Pennsylvania,  and Tennessee. In addition,  commodity
chemical samples were collected from  local distributors in Ohio and
Indiana.  These included urea, potassium  chloride,  ammonium
monohydrogen phosphate, and granular triplesuperphosphate, among
others.  Samples  were  leached or dissolved and subjected  to
complexationelectrospray ionization mass spectrometry (cESI-MS) or
ion chromatography (1C).  All 1C analyses were performed by the Oak
Ridge National Laboratory, which received separate portions of the
solid materials. The only products that  were  found to contain any
perchlorate were those based on Chile saltpeter. While this study was
the first to include the same products used on production farms, it did
not address the issue of sampling.

     Sampling strategies for commodity chemicals are alwaystricky.lt
is  essentially impossible to sample 23,000 tons of urea piled in a
warehouse representatively. These products are moved with heavy
machinery  and transferred to railcars and trucks from barges using
conveyor systems and other heavy equipment. It is worth noting that
the  equipment used  for transfer  and  transportation of  these
commodities is not normally  cleaned thoroughly between uses  for
different commodities. A common practice is to run a few tons of gravel
through the system. Accordingly, traces from residual products  are
possible.

     Fertilizers are normally sampled by taking repeated cores through
the piles using a Missouri D  tube sampler. The core samples  are
combined, riffled, divided, and analyzed. These practices are standard
within the fertilizer industry and regulatory bodies. Across the nation,
state chemists or  agriculture departments are obligated to examine
fertilizers  to verify the manufacturers' reported grades. Sampling
practices have evolved to fill those needs. Previous studies generally did
not take these practices into  account, concentrating instead on  the
analysis of the solid once a grab sample had been collected. Sampling is
of course important to obtain representative results. The distribution of
perchlorate is not  uniform in Chilean sodium nitrate. For example, in
two lots with average concentrations of 1.5 and 1.8 mg g"1, individual
10.0-g grab samples ranged from 0.74 to 1.96mgg~' (Urbansky, 2001).
Information from previous studies and from standard industry practices
was used to guide the study reported on in Chapter 2.

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                                                       Chapter 2
                               Survey of fertilizers and related materials
2.1. Objectives
     In an effort to take into account the difficulties of the matrix, the
problems with sampling, and the applicability of the results, this study
was undertaken. No single study can say once and for all whether there
is perchlorate in fertilizers. However, it is  possible to provide a
snapshot of current fertilizers commodities. The EPA entered into a
collaboration with The Fertilizer Institute, the International Fertilizer
Development  Center, the Fertilizer Section of the Office of Indiana
State Chemist and  Seed Commisioner, the North  Carolina State
University Department of Soil Science (which serves  as  part of the
North Carolina Agricultural Research Service), and IMC-Global for this
purpose.

     This study was composed of two distinct phases. Phase 1 was
designed to evaluate laboratory performance and the ruggedness of the
method.  Laboratory participation  was on  a voluntary   basis.
Laboratories were required to use ion chromatography, but were
permitted to choose columns and operating conditions on their own,
within certain limits. Phase 1 test samples included a wide variety of
fertilizer matrices. In Phase 2, samples of materials were collected from
around the nation and sent to the participating laboratories. All data
were provided to EPA for evaluation and analysis.

2.2. Phase 1—Evaluation of laboratories
     These spanned commodity chemicals, water-soluble plant foods,
and  granulated/pelletized lawn fertilizers. Phase  1  samples were
prepared by  EPA-ORD-NRMRL-WSWRD  and  sent  directly  to
participating laboratories under custody seal. A combination of solid
and liquid (aqueous) samples was sent to each laboratory. All of the
liquid samples were made  by leaching  or dissolving the solid  in
deionized water at a ratio of 10 g dL~' (-10% w/w).  All of the raw
materials were either American Chemical Society (ACS) reagent grade
or demonstrated to be perchlorate-free (within the limits of experimental
error) by EPA analyses (Urbansky,2000A). Cations of the perchlorate
salts used to  fortify these materials are identified in parentheses.
Laboratories were required to demonstrate recovery of fortifications,
reproducibility, and ruggedness in real matrices. They were also required
to supply  experimental  details and calibration data.  Lastly, quality
control specifications were  established with regard to  number  of
replicates, blanks, spike recovery, accuracy, and precision. Laboratories
were required to estimate limits of detection within each matrix using a
standardized procedure. The method has been released as EPA/600/R-
01/026, and details covered in the method will not be repeated here.

     A set of performance evaluation samples was prepared by EPA-
ORD-NRMRL-WSWRD. The identities of these were as follows:

1.   agricultural GTSP
2.   1:1 bentonite:kaolinite + 990 u.g g"1 C1O4" (Na+)
3.   agricultural DAP
4.   agricultural grade NH4NO3 + 620 ng g'1 CKV (Na+)
5.   agricultural grade NH4NO3 + 310 jig g"1 C1O4" (Na+)
6.   duplicate of no. 5
7.   ACS reagent urea + 530 ng g'1 C1O4~ (Na+)
8.   ACS reagent urea
9.   agricultural KC1 (0-0-60)
10.  duplicate of no. 9
11.  10 g dL"1 aq. ACS reagent urea, K2SO4, NaCl, (NH4)2HPO4, and
     KNO3; xylene cyanole FF
12.  duplicate of no. 11
13.  no. 11 + 170 ng mL"1 CKV (Na+ salt)
14.  no. 11 + 170 ng mL"1 C1O4~ (NH4+ salt)
15.  Vigoro lawn winterizer, 22-3-14
16.  Scotts lawn winterizer, 22-3-14
17.  duplicate of no. 16
18.  no. 16 + 1.4 mg g"1 C1O4"
19.  10 g dL"1 (total solids/liquid) aq. agricultural (NH4)2HPO4;  ACS
     reagent urea, KC1, NaNO3, MgSO4, bentonite, CoCl2«6H2O, and
     NiCl2-6H2O
20.  no. 19 + 82 ng mL-1  C1CV (Na+ salt)
21.  no. 19 + 82 ng mL"1  CKV (K+ salt)
22.  no. 19 + 82 ng mL"1  C1O4" (NH4+ salt)
23.  no. 19 + 82 ng mL-'  C1O4" (NBu4+ salt)
24.  no. 19 + 82 ng mL"1  C1O4" (NOct/ salt)
25.  aq. 6.2 ng mL"1 C1O4" + FD&C Blue No.  1
26.  aq. 34 ng mL"1 C1O4" in Cincinnati tap water
27.  aq. 1.34 ng mL"1 C1O4" in Cincinnati tap water
28.  10 g dL"1 aq. Peter's water soluble plant food, 20-20-20
29.  10 g dL~' aq. Miracle Gro tomato food, 18-18-21
30.  10 gdL'1 aq. ACSreagent (NH4)2HPO4 + 12 ng mL"1 C1O4" (Na+)
31.  10 g dL~' aq. ACS reagent KC1 + 74 ng mL-1 CKV (Na+)

     Laboratories were required to demonstrate their ability to detect
perchlorate in fertilizers.  Some laboratories failed to adequately test

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aqueous samples with concentrations in the parts-per-billion, and were
cautioned not to dilute samples initially. In Phase 1, the matrix was not
identified to the laboratories. This made the process difficult,  time-
consuming, and resulted in higher errors because it was not possible to
initiate corrective measures to handle the needs of a particular matrix.
For this reason, major chemical constituents were identified for the
laboratories in Phase 2.

     The following laboratories  successfully  completed Phase  1:
California Department of Food and Agriculture, Dionex Corporation,
American Pacific Corporation (AMPAC), NCSU Department of Soil
Science,  Montgomery Watson Laboratories (MWL),  and  IMC-
Phosphates Environmental Laboratory.

2.3. Phase 2—Analysis of samples
2.3.1. Sampling and analysis strategy
     Phase 2 consisted of the testing of fertilizer samples. The materials
sampled  represented current major suppliers of production farm
fertilizers. Because these were raw materials, they also represented
materials used in consumer-oriented fertilizers. Clay additives and other
fertilizer products were included,  too  (e.g., ammonium sulfate).
Sampling sites were chosen to reflect national supplies and to provide
geographic coverage of raw materials. Samples were procured under the
direction of state regulatory agents duly authorized by  their agencies
and recognized by the Association of American Plant Food Control
Officials  (AAPFCO) for the collection and examination of fertilizers
using accepted procedures.

     A number of objectives were established for the choice of samples
and the means of collection. Appropriate measures were then taken to
achieve these objectives.

1.   To  verify  the  method  for  analyzing fertilizer materials for
    perchlorate ion.  To this end, a large number of materials was
     chosen  to  represent  common matrices  and ions that  might
     confound the analytical process. These materials included anions
     that might interfere with perchlorate determination, e.g., sulfate,
     chloride, phosphate, and nitrate.

2.   To  identify  individual  sources    of  contamination   if
    perchlorate  ion  is found by testing a broad cross section  of
     individual  raw  materials  and nutrient  sources  throughout
     the  U.S.  and   include  materials   from   each   category
     (nutrients and fillers)   that  represent  ingredients common
     to all products. To this end, we (1) enlisted the help of a large
     number of material manufacturers and producers; (2) selected
     products, and consequently materials, from diverse  geographic
     areas; (3) gathered at least three distinct samples of each major
    nutrient source material, for example, three DAP samples each
    from different suppliers in diverse  geographic locations; (4)
    identified certain materials as likely candidates for contamination
    to be sampled without  fail, specifically, Chilean  nitrate  salts,
     langbeinite ore, and potassium chloride; (5) included at least two
     samples of leading minor contributor sources such as iron oxide,
    limestone filler, and clay conditioners that are typically part of
     fertilizer blends. While many materials have been tested, the list is
     not exhaustive and was not intended to be. Rather, it focuses on
     major sources of many chemical commodities used in fertilizer
     manufacture. Sources ofmacronutrients and several micronutrients
     were the principal focus. While some fillers and minor ingredients
     were tested, the coverage was not comprehensive.

         Raw materials rather than finished products were focused on
     for two reasons:  (1) If perchlorate were  present in blended
     fertilizers, it would have had to come from a specific raw material
     in the blend  (assuming it was not intentionally added); finished
     product sampling would not identify a specific contaminant. (2)
     Raw   materials  should  contain  higher concentrations  than
     formulated products  (i.e., blending dilutes the analyte) and their
     analyses are  likely to suffer fewer matrix effects. Products are
     listed in Table 2.1.

3.   To ensure correct sampling and  third party validation, and
     to maintain  a  chain of  custody throughout  the  sampling,
     transport,  preparation,  and  distribution  process.  To  this
     end, samples were taken under the supervision of state officials
     authorized by state statutes to collect samples of fertilizers, such
     as state chemists or agriculture department officers. In addition to
     manuals from  The  Fertilizer Institute (TFI), Association of
     Official Analytical Chemists (AOAC, 2000a, 2000b), and the
     AAPFCO (1999), written  instructions were issued to  each
     inspector outlining  the  specific protocol  to be used.  These
     instructions  were in addition to and complementary  to the
     standard sampling practices. In a few cases, state inspectors were
     unavailable, and knowledgeable practioners  from industry were
     permitted to collect the sample; this has been noted in  Table 2.1.
     Sampling was conducted at the actual production site whenever
     possible  to  eliminate potential  for  contamination  by  other
     materials. The collected samples were sent under custody seal to
     the International Fertilizer  Development  Center (IFDC)  for
     riffling, grinding, and packaging. The IFDC sent the custody-sealed
     packages to the participating laboratories.

4.   To obtain  consensus  from  governmental,  industrial,  and
     academic interests on  how to  accomplish  these goals.  All
     documents and proposals were reviewed by TFI, IMC-Agrico,
     EPA-ORD-NERL-ERD,  EPA-ORD-NRMRL-WSWRD,  NCSU
     Department  of Soil  Science, Office of Indiana  State Chemist
     (OISC) Fertilizer Section, U.S. Air Force Research Laboratories,
     and the AOAC Fertilizer Referee.

     A series of quality control samples were prepared for Phase 2 by
EPA-ORD-NRMRL-WSWRD and sent to the IFDC for distribution to
the participating laboratories. Each laboratory submitted its results to
EPA-ORD-NRMRL-WSWRD   for  evaluation  and  tabulation.
Laboratories were required to submit chromatograms for the sample
solutions  and fortifications they made to demonstrate acceptable
recovery in the matrix. Laboratories were also required to submit proof
of the goodness of their calibrations, instrument performance, detection
limit, and  sensitivity.
                                                               10

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2.3.2. Results
     Table 2.2 shows the results obtained by the laboratories  that
elected to participate in Phase 2. All of the samples were tested by
NCSU, CDF A, IMC, and AMP AC; not all of the samples were tested
by Dionex. Positive hits above the assured reporting level (ARL) were
rechecked. The calculation of the assured reporting level is described in
detail in the method itself, EPA/600/R-01/026 (Collette, 2000).

     Other than nonzero results  reported by one lab, perchlorate was
detectable only in materials derived from Chilean caliche. It must be
emphasized that thesenonzero results were still below the ARL except
for item 48. In the case of item 48, a granular triplesuperphosphate, the
same lab obtained discrepant results of 26 ngg~' (with an ARL of 20 jig
g~') and undetectable (with an ARL of 100 p.g g~'). Given that no other
laboratory obtained similarresults, this suggests that the 26 jigg~' value
is erroneous, and it has been rejected as an outlier. Initially, this lab
found 44.5 ug g~'  in item 23, an ammonium dihydrogen phosphate
(MAP). However, it reported that perchlorate was undetectable when
requested to reanalyze the material. In addition, a portion of an archived
sample of item 23  was  sent to this  lab by  EPA-ORD-NRMRL-
WSWRD for analysis; this portion also failed to show detectable
perchlorate. Consequently, the original value was discarded as faulty.

     Samples of materials 5, 23, 40, and 42 were  analyzed indepen-
dently by MWL and by EPA-ORD-NERL-ERD. MWL found 2675 ^g
g~'  in item 42, while NERL found 2845  ug g~l. These values are
consistent with results reported by other laboratories. Perchlorate was
undetectable in 5,23, and 40, according to both MWL and EPA-ORD-
NERL-ERD.

     Recoveries of fortifications ranged from 81% to 111%, regardless
of the specific increase in concentration resulting  from  spiking.  The
increases in concentration, A[C1O4"], and the recoveries are reported in
Table 2.3. All laboratories demonstrated satisfactory performance in
this regard. Although not explicitly reported here, the ARLs can be
computed from the information in Table 2.3.

2.3.3. Discussion
     It is worth pointing out at  the U.S. Geological Survey and Air
Force Research Laboratories have found perchlorate in isolated samples
of sylvite taken from New Mexico (Harvey, 1999). USGS is engagedin
additional sampling of North American mining sites in order to assess
whether there are natural mineral deposits of potassium perchlorate in
sylvite or sylvinite. Because little is known about the mechanisms of
perchlorate formation in the natural environment (which are assumed to
be meteorological in nature),  it is not clear whether these findings
represent a low-level background to be expected in evaporite mineral
deposits or not. There is, of course, the possibility for anthropogenic
perchlorate formation to occur during blasting operations to mine
potassium  chloride,  but  it has  not  been observed.  Nonetheless,
perchlorate has not been detected in any samples of agricultural grade
potassium chloride (0-0-62 or 0-0-60) taken under the auspices of the
EPA (items 4,8, and 28). Nor was it found inalangbeinitesample (item
13), acquired via blasting. Current data are inadequate to demonstrate
that KC1 or K2Mg2(SO4)3 suffer from inclusions of perchlorate salts to
an environmentally relevant extent.

     Previous EPA-ORD-NERL-ERD and AFRL findings cannot be
applied to fertilizers as a whole because of the composition and nature
of the products investigated. Those findings may have  reflected a
temporal contamination of one or more raw materials or an error  in
manufacture.  The  only  fertilizers  unequivocally  and consistently
demonstrated to  contain perchlorate were bagged  products deriving
some or all of their nitrogen from Chilean nitrate salts, which are known
to vary in perchloratecontent. Even though perchlorate was previously
identified in some fertilizer products and was presumably introduced
through a contaminated raw material, this incident appears to have been
isolated and the source of the perchlorate remains an enigma, for some
of these products had no known link to Chile saltpeter. Furthermore,
awareness  within  the fertilizer industry and the  environmental
community is now substantially heightened.

    Based on the studies thus far (Collette, 2000; Gu, 2000; Urbansky,
2000A;Urbansky, 2000D; Urbansky, 2000E; Robarge, 2000), there is
a consensus among researchers that there is insufficient evidence for
fertilizers to be viewed as contributors to environmental perchlorate
contamination, except for imported Chile saltpeter or products derived
from it. The potential future  influence  of such products is further
reduced by SQM's modifiedrefiningprocess to lower perchlorate con-
centration in its products. Within the limits of experimental error and
current ion chromatographic technology,agricultural products tested by
EPA-ORD-NERL-ERD,ORNL,andEPA-ORD-NRMRL-WSWRDall
were devoid of perchlorate as  were all of the products in this survey
except for those known to contain or to be derived from mined Chile
saltpeter. While  the  results presented  herein reflect another such
snapshot, it is the most comprehensive examination of fertilizers and
related materials to date. As with any environmental contaminant, an
individual study is limited in applicability to the future. Nonetheless,
the weight of evidence obtained to date largely argues against fertilizers
as sources of environmental perchlorate. That notwithstanding, it would
not be imprudent for manufacturers, trade associations, or the industry
to establish periodic monitoringpractices to screen either raw materials
or finished products for perchlorate in a manner similar to how finished
drinking water is tested, perhaps with some allowance for periodic
phenomena.
                                                               11

-------
Table 2.1. Fertilizers and related materials surveyed for perchlorate
   Item    Composition
Manufacturer/supplier
Authority of
    1     Lawn fertilizer, 22-3-14
    2     Ammonium monohydrogen phosphate (DAP)
    3     Urea
    4     Potassium chloride (MOP)
    5     Iron oxide
    6     Limestone
    7     Potassium magnesium sulfate (Sul-Po-Mag)
    8     Potassium chloride (MOP)
    9     Osmocote 18-6-12
    10     Miracle Gro lawn fertilizer, 36-6-6
    11     Miracle Gro plant food, 20-20-20
    12     Langbeinite, mechanical mining
    13     Langbeinite, drill and blast
    14     Potassium magnesium sulfate (Sul-Po-Mag)
    15     Limestone
    16     Ammonium sulfate
    17     Urea
    18     Ammonium sulfate
    19     Ammonium monohydrogen phosphate (DAP)
    20     Potassium magnesium sulfate (Sul-Po-Mag)
    21     Potassium sulfate
    22     Ammonium sulfate
    23     Ammonium dihydrogen phosphate (MAP)
    24     Iron oxide
    25     Limestone
    26     Urea
    27     Clay
    28     Potassium chloride
    29     Urea
    30     Ammonium nitrate
Scotts Company, Marysville, OH            ODA
IMC-Agrico                             ODA
Potash Corporation of Saskatchewan       ODA
Potash Corporation of Saskatchewan       ODA
Sims Agriculture                        ODA
Millersville Lime                        ODA
IMC-Kalium, Carlsbad, NM                CDFA§
Mississippi Potash, Carlsbad, NM          CDFA§
Scotts, Marysville, OH                    ODA
Scotts, Port Washington, NY              ODA
Scotts, Port Washington, NY              ODA
IMC-Kalium, Carlsbad, NM                NMDA
IMC-Kalium, Carlsbad, NM                NMDA
IMC-Kalium, Carlsbad, NM                NMDA
Chemical Lime, Salinas, CA              CDFA§
Simplot, Pocatello, ID                    CDFA§
Unocalt                               CDFA§
Dakota Gasification, Bismarck, ND         CDFA§
IMC-Agrico                             FDACS$
IMC-Kalium                            FDACSJ
IMC-Kalium                            FDACSJ
Dutch State Mines (DSM)                  FDACSJ
IMC-Agrico                             FDACSt
Fritt Industries, Ozark, AL                  FDACSJ
E.R. Jahna, Lake Wales, FL               FDACSJ
Unocalt                               FDACSrJ:
Ag Sorb                               FDACSJ
PCS                                  FDACSt
CF Industries, Donaldsonville, LA          supplier
LaRoche, Atlanta, GA                    IFDC°
                                                    12

-------
Table 2.1 continued
   Item    Composition
                                                      Manufacturer/Supplier
                                      Authority of
    31     Ammonium monohydrogen phosphate (DAP)
    32     Ammonium dihydrogen phosphate (MAP)
    33     Potassium sodium nitrate
    34     Ammonium nitrate
    35     Potassium nitrate
    36     Sodium nitrate
    37     Ammonium nitrate
    38     Granular triplesuperphosphate
    39     Ammonium dihydrogen phosphate (MAP)
    40     Ammonium monohydrogen phosphate (DAP)
    41     Limestone
    42     Potassium nitrate
    43     Plant food, 10-10-10
    44     Clay
    45     Potassium magnesium sulfate
    46     Potassium nitrate
    47     Ammonium monohydrogen phosphate (DAP)
    48     Granular triplesuperphosphate
                                                      Agrium, Soda Springs, ID
                                                      Agrium, Soda Springs, ID
                                                      SQM                                  FDACS®
                                                      Mississippi Chemical, Yazoo City, MS       FDACS®
                                                      SQM                                  FDACS®
                                                      SQM                                  FDACS®
                                                      Mississippi Chemical, Yazoo City, MS       FDACS®
                                                      Cargill, Riverview, FL
                                                      Simplot, Pocatello, ID
                                                      Simplot, Pocatello, ID
                                                      Georgia Marble
                                                      SQM
                                                      SSC, Statesville, NC                     supplier
                                                      Oil Dry Co., Ripley, MS                   Pursell IndJ
                                                      IMC-Kalium, Carlsbad, NM                Pursell Ind.H
                                                      Vicksburg Chemical Co., Vicksburg, MS     manufacturer
                                                      PCS, Aurora, NC                        manufacturer
                                                      IMC-Agrico, Mulberry, FL                  manufacturer
  Quality control samples prepared by EPA-ORD-NRMRL-WSWRD (all solids)
    49     Potassium chloride + 6.8 mg CIO4~ g~'
    50
    51
    52
       Peter's water soluble plant food, 20-20-20
       + 6.2mgCICvg'
J.T. Baker (Phillipsburg, NJ) ACS reagent   EPA
KCI and KCIO4
Scotts (Marysville, OH) + GFS (Columbus,   EPA
OH) ACS reagent NaCIO4
       Granular triple superphosphate + 2.7 mg CIGy g '      A.H. Hoffman (Lancaster, PA) + GFS ACS    EPA
                                                      reagent NaCIO4
       Urea + 1.8 mg CIO4~g '

53     Potassium chloride (no analyte added)
D.W. Dickey & Son (Lisbon, OH) + Aldrich   EPA
(Milwaukee, Wl) ACS reagent NH4CIO4
    54
    55
       Ammonium nitrate (no analyte added)
       Chilean sodium nitrate (Chile saltpeter)0
CF Industries (Cincinnati, OH)
+ A. H.Hoffman
Cargill (Shelbyville, KY)
A.H. Hoffman (mfd. by SQM)
                                                                                                EPA
EPA
EPA
Key: Fertilizers: Sul-Po-Mag = sulfate of potash/magnesia, MOP = muriate of potash, DAP = diammonium phosphate, MAP =
monoammonium phosphate. Manufacturers/suppliers: PCS = Potash Corporation of Saskatchewan; SQM = Sociedad Quimica
y Minera. Authorities: CDFA = California Department of Food and Agriculture; FDACS = Florida Department of Agriculture and
Consumer Services; NMDA= New Mexico Departmentof Agriculture; ODA= Ohio Department of Agriculture. fUnocal is now owned
by Agrium. ^Sampled at Pursell Industries in Winterhaven, Florida. ®Sampled at Gro-Mor Co., Inc., Plant City, FL. §Sampled at
Pursell Industries, Los Angeles, California. IJPursell Ind. = Pursell Industries, a supplier for the manufacturers listed (located in
Orrville, Ohio). DMaterial was purchased by IFDC for this study. °This material had previously been found to contain 1.7 mg CIQ,~
g*' by EPA-ORD-NRMRL-WSWRD; no perchlorate salts were added to increase this value.
                                                     13

-------
Table 2.2. Summary results for perchlorate concentration detected by replicate analyses of samples listed in Table 2.1TI
Item
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
3D
Calif. Dept. of Food
& Agric.
[00.1 dilnt
pg g~1 1 to
u§
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
II
100
50
25
50
10
5
500
10
100
50
500
50
50
50
5
25
25
25
100
500
50
10
200
10
5
25
2
25
25
fi
NCSU Dept. of Soil
Science
[CIO/] diln
pg g-1 1 to
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
II
100
500
100
100
100
100
100
100
500
500
500
100
100
100
100
100
100
100
500
100
100
100
500
100
100
100
100
100
100
mn
American Pacific
Corporation
[00,1 diln
pg g-1 1 to
0.3*
u
2*
0.3*
0.6*
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
1.5*
u
1
u
0.4*
1.5*
0.3*
0.4*
II
10
100
50
10
10
1
10
10
100
1000
100
10
50
50
5
50
2
50
10000
10
50
50
50
10
1
10
50
10
10
?n
IMC Environ.
Laboratory
[CK)41 diln
tig g~1 1 to
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
LI
u
u
u
u
u
u
u
u
u
u
II
10
100
50
100
10
100
100
10
100
10
100
100
10
10
10
50
10
100
50
100
100
10
100
100
10
100
10
100
50
•m
Dionex Corporation
[CIO,1 diln
|ig g-1 1 to

u 100

u 100


u 100
u 100
u 100
u 100




u 100
u 100


u 100



u 100





u 100
                                                         14

-------
Table 2.2 continued
Item

31
31dJ
32
33
33d
34
34d
35
36
37
38
39
40
41
42
43
44
45
46
47
48
48d
49
50
51
52
53
54
55
Calif. Dept. of Food
& Agric.
[CICvl
M9JT1
u
u
u
3700
3925
u
u
2624
1860
u
u
u
u
u
2424
u
u
u
u
u
u
u
5720
5730
2540
1540
u
u
1550
dilnt
1to
100
500
250
4000
5000
5
5
4000
2000
5
1000
500
200
5
4000
100
2
50
25
250
1000
500
10000
5000
4000
2000
10
5
2000
NCSU Dept. of Soil
Science
[CICvl
Mgr1
u
u
u
4020
4270
u
u
2380
1950
u
u
u
u
u
2542
u
u
u
u
u
u
u
5960
5190
2700
1790
u
u
1580
diln
1to
500
500
500
5000
5000
50
10
2000
2000
100
500
500
500
100
2000
100
100
100
100
500
500
500
5000
5000
2000
2000
100
100
2000
American Pacific
Corporation
[CI041
M9£T1
u
u
u
4200
3700
0.9*
u
2100
1800
u
u
u
2.5*
u
2050
u
0.3*
u
u
u
26**
u**
6200
5100
2080
1430
0.5
u
1440
diln
1to
500
50
1000
10000
10000
10
50
5000
5000
10
1000
100
50
1
5000
100
10
50
5
100
100
1000
10000
10000
2000
1000
10
10
1000
IMC Environ.
Laboratory
[CI041
M9ST1
u
u
u
4066
4136
u
u
2288
2054
u
u
u
u
u
2455
u
u
u
u
u
u
u
6377
5737
2376
1511
u
u
1680
diln
1to
100
100
100
5000
5000
100
10
2000
2000
10
50
1000
100
10
2000
10
10
50
50
10
100
100
5000
5000
2000
1000
10
10
1000
Dionex Corporation
[CI04]
pgcr1


u
3860
3850

u
2240
1920

u

u
u
2340




u
u
u
6140
5430
2300
1810


1700
diln
1to


100
5000
5000

100
2000
2000

1000

1000
100
2000




100
1000
1000
10000
10000
10000
10000


2000
USample loops were 1000 uL exceptfor Dionex, which used 500 \iL. tDilution factor refers to subsequentdilution of a stock solution
prepared by leaching or dissolving the material at 10 g dL~1 (-10% w/w)4Samples 31, 33, 34, and 48 were supplied to the
laboratories as blind duplicates. §The designation "u" means undetected, i.e., no peak could be distinguished from the baseline.
*Values falls below the assured reporting level and therefore cannot be viewed as meaningful; see the method (EPA/600/R-01/026)
for details on how the ARL is determined. "See text for explanation.
                                                       15

-------
Table 2.3. Tested fortifications (spikes) and recoveries in solutions of samples listed in Tables 2.1-2.2
Item
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
Calif. Dept. of Food
& Agric.
A[CIO4'] recov
ugg-1 %
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
98
102
107
109.5
98
104
93
108
104
99
101
100
92
96
105
106
90
106
93
101
95
107
98
107
97
96
92
102
105
100
NCSU Dept. of Soil
Science
A[CICV] recov
M9JT1 %
10
50
50
10
10
10
50
30
50
50
50
10
50
50
10
50
10
50
50
50
50
50
50
10
10
10
10
30
10
10
101
98
93
93
87
98
85
96.5
101
101
95
88
89
88
96
86.5
96
94
97
88
91
81.5
99
84
96
97
92
94
95
95
American Pacific
Corporation
A[CIO4~] recov
M9ST1 %
10
10
10
10
10
10
10
10
10
10
10
10
10
20
10
10
10
10
10
10
10
10
50
10
10
10
10
10
10
10
93
90
103
97
97
93
106
93
103
93
109
91
92
90
91
95
108
97
107
106
96
95
92
106
99
106
93
94
91
101
IMC Environ.
Laboratory
A[CIO^ recov
M9ST1 %
200
200
200
200
200
200
200
200
200
200
200
200
200
200
200
200
200
200
200
200
200
200
200
200
200
200
200
200
200
57
85
100
102
98
89
100
103
87.5
96.5
97
99
104
80.5
88
117
99
93
97.5
97
102
103
85
95
103
93
102.5
107
98.5
105
96.5
Dionex Corporation
A[CICV] recov
ugg-1 %

10

10


10
10
10
10




10
10


10



10





10


107

103


96
101
98
96.5




108
106


110



106





110

                                                         16

-------

-------
Table 2.3 continued
Item

31
31dt
32
33
33d
34
34d
35
36
37
38
39
40
41
42
43
44
45
46
47
48
48d
49
50
51
52
53
54
55
Calif. Dept of Food
& Agric.
A[CI041
10
10
10
50
50
10
10
10
10
10
10
10
10
10
50
10
10
10
8
10
10
10
50
40
100
50
10
10
50
recov
100
95
97
90
102
100
102
109
107
94
95
101
94
93
108
96
94
91
104
103
110
92.5
104
95
93
105
102
101
103
NCSU Dept of Soil
Science
A[CI041
50
50
50
100
50
50
10
100
100
10
50
50
50
10
100
50
10
10
10
50
50
50
100
100
100
100
10
10
100
recov
95
97
97
100
107.5
81
97
98
98
99
108
95
98
98
99
93
91
91
94.5
99
99
105
97
109
111
97.5
92.5
100
100
American Pacific
Corporation
A[CI041
10
10
10
20
20
20
10
30
20
10
10
10
10
10
30
10
10
10
10
10
20
10
50
50
60
50
10
10
50
recov
91
94
93
95
103
106
102
104
105
102
100
92
93
103
98
109
93
102
105
92
102
103
95
93
105
91
91
109
94
IMC Environ.
Laboratory
A[CI041
200
200
400
57
57
57
200
57
57
57
200
200
200
200
57
200
200
200
200
200
200
200
20
57
20
20
200
200
57
recov
98
98
98
98
97
93.5
85
98.5
98
91
88
103
101
97
97
88.5
88.5
109
101
81
91
94
101
95
98
100
94
110
96
Dionex Corporation
A[CI041


10
100
100

10
100
100

10

10
10
100




10
10
10
50
40
20
20


100
recov


103
102
101

102
106
103

98

110
99
105




100
96
105
95
99
105
102


102
                                                      17

-------
                                                         Chapter 3
                                       Implications for vascular plants
3.1. Introduction
    In  the laboratory  setting,  some  plant  species will absorb
perchlorate when exposed to perchlorate via irrigation water. This has
been explored for possible phytoremediation (Nzengung, 1999; 2000).
Some investigators have speculated that bacteria are responsible for
perchlorate reduction in plants. Perchlorate-reducing monera have been
identified by several laboratories, and cultured from a variety of sources
(including Las  Vegas Wash sediments, food processing sludge, and
sewage  sludge) (Logan, 1998;  Coates,  1999;  Coates, 2000). This
suggests that perchlorate-reducingbacteriaare active in the environment.
On the other hand, the bacteria isolated thus far prefer oxygen over
nitrate over perchlorate. In order for perchlorate reduction t o occur, the
water must be  anoxic, and all of the nitrate must have been consumed.
Moreover, thesebacterial cultures require a suitably moist environment.
Arid soils or regions with low rainfall may not sustain their growth.
Natural  attenuation probably varies around the nation, depending on
local factors; therefore, it is not possible to draw any conclusions about
the ecological impact of using fertilizers that contain perchlorate, for
they may be applied in areas where bacterial degradation occurs.

    Due to the reported occurrence of perchlorate  in certain water
resources and in certain fertilizer products, several groups have begun
to address the extent and significance of perchlorate uptake by plants.
For example, if produce is grown using perchlorate-tainted irrigation
water or fertilizers and the perchlorate is retained in the edible portions,
this might constitute a route of human exposure. The possibility of
exposure would be further  increased if perchlorate were shown to
survive  various types  of processing. Unfortunately, experimental
results that definitively  gauge the extent of risk from this  route of
exposure have not yet been published. However, some significant
progress toward this goal has been made. Work is ongoing in  this area,
and several projects are proceedingat the Instituteof Environmental and
Human Health of Texas Tech University.

3.2.  Complicating factors
    One problem with uptake studies is the possibility of convolved
influences on uptake. There are perchlorateabsorption dataavailable for
only a few species ofvascularplants. The absorption and accumulation
of anionic solutes can be affected by many physical and chemical
properties, such as concentration, size, charge density, and aquation.
3.2.1. Chemical influences on ion transport
     Ion transport through  plasma membranes occurs via transport
proteins (Raven, 1999). At present, there are no published reports on
the transmembrane transport of perchlorate in plants at the molecular
or cellular  level.  In the absence of studies  specifically examining
influences on transmembrane perchlorate transport, it is necessary to
consider whether previously published or ongoinguptake studies have
accounted for likely influences.

     Pertechnetate (TcO4~)  is similar in size (ionic radius) and Gibbs
free energy of aquation (Moyer, 1997). In aerobic aquatic environments,
pertechnetate is highly mobile,  accumulated by plants,  and not
appreciably retained by many soils (Sheppard, 1991); therefore, it is
like perchloratein many respects.  One respect in which it differs is its
ease of reduction to an immobile species, TcO2 (Tagami, 1996). Unlike
perchlorate, many papers have been published on the fate and transport
of pertechnetate in food plants due to its release after use in medical
imaging or from nuclear installations. Given the similarities between
C1O4 and TcO4 , those factors that influence pertechnetate uptake
should be either accounted  for or ruled out in perchlorate uptake
studies. Depending  on  the plant, pertechnetate  absorption  and
accumulation can be affected by nitrate (Kriger, 2000; Echevarria, 1996;
1998), sulfate (Cataldo, 1978; 1983), and phosphate (Cataldo, 1978;
1983; Echevarria,  1996; 1998). No studies on perchlorate uptake have
attempted to account for the impacts of other ionic species.

3.2.2 Concentration
     Active transport of perchlorate has not been reported. However,
both active and passive  transport  of  an  ion are  affected by its
concentration (Raven,  1999). All  ions experience an electrochemical
gradient which is determined in part by the ion's concentration. Past
and ongoing studies have exposed plants to much higher concentrations
than are present in the environment.

     For example, Hutchinson and coworkers are presently  studying
greenhouse-grown  lettuce irrigated with perchlorate-tainted water.
Lettuce  is of particular importance for assessingthe risk of perchlorate
to the food supply since  much of the lettuce produced in the U.S. is
irrigated with perchlorate-tainted water. Also, lettuce has a high water
content  and virtually the entire aboveground plant is consumed without
cooking or  processing.  Lettuce plants  are watered with one of five
different concentrations of perchlorate (0.1,0.5, 1.0, 5.0, and 10.0 \ig
mL~') for a period of 90 days following planting.  At various intervals
                                                               18

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of time, whole plants were harvested and divided into green tissue and
root samples; each sample was analyzed for perchlorate. The analytical
method was adapted from Ellington and Evans  (2000). Levels of
perchlorate rise steadily over the first 50-60 days,  and then generally
level off. The amount of perchlorate detected in the leaves correlates
with dose. As an example, at about 50 days into the experiment, the
lettuce irrigated with 10.0 ng mLT1 perchlorate exhibits a perchlorate
content of about 3 mgg~' on a lettuce dry matter basis. Since lettuce is
about 90% water, this  would amount to about 0.30 mg g~' on a wet
mass basis. Experiments are underway todetermine whether lettuce has
the capability to degrade perchlorate if the supply of the contaminant
is stopped; however, initial data suggest that  increases in biomass are
responsible  for the apparent  reduction  in perchlorate  content.
Therefore, a decline in concentration (e.g., expressed as mgg~') does not
adequately reflect the situation. While the preliminary results from
these studies (Hutchinson, 2000) represent progress in understanding
perchlorate  in consumable produce, it must remembered  that the
perchlorate concentrations are about 500 times the concentrations in
perchlorate-tainted irrigation water and that results obtained under
laboratory growingconditions cannot be directly extrapolated to edible
agricultural produce.

3.2.3. Tissue-specific accumulation
     All studies of perchlorate occurrence in plants have focused on the
leaves, stalks, and wood. While the leaves of some plants (e.g., lettuce)
are consumed, the leaves of many others are not. Other than lettuce, no
studies have been conducted on absorption and accumulation in edible
fruits and vegetables. Therefore, information on uptake by Tamarix
ramosissima (Urbansky,  2000C), Salix  (Nzengung,  1999;  2000)
tobacco  (Wolfe,  1999)  and  Myriophyllum  aquaticum (Susarla,
1999B; 1999C)  cannot be directly applied or extrapolated to food
crops. While many ions are transported via the xylem, the phloem
supplies many of the nutrients  to fruit. Although  dissolved salts are
carried into the xylem alongwiththe water, the phloem relies on active
transport. Because the edible portions of many plants (e.g., tubers,
roots,  some fruits)  experience  little to   no  transpiration,  the
phloem—rather than the xylem—carries both inorganic and organic
materials for nutrition (Salisbury, 1992). For example, nitrate is almost
never present in phloem (Salisbury, 1992), and is rarely found in fruit.

     It is  worth pointing  out that studies on pertechnetate uptake
showed that this anion was selectively accumulated in specific parts of
plants and generally not in the consumable tissues. Cataldo (1986),
Echevarria (1997), and Gast (1978) demonstrated that a variety of food
plants could absorb and accumulate pertechnetate, withmost of the ion
in the roots  or leaves rather than edible portions.  While TcO4~ was
shown to  enter tomato leaf tissue via the xylem (Krijger, 1999), the
fruit—which is actually consumed—was never tested. Accordingly,
these observations demonstrate the importance of samplingconsumable
plant tissues and not just foliage. Furthermore, they warn against
drawing inferences about fruit (or other edible portions) based on
occurrence in foliage.

3.2.4. Soil sorption
     It is generally accepted that perchlorate adsorbs to soil particles
through outer-sphere complexes  where the ions engage  in simple
electrovalent bonds and serve to balance electric charge on the surface
(Sparks, 1995; Sposito, 1989). Such adsorption is often influenced by
pH due to protonation of mineral oxo moieties,  as is the  case with
goethite (Gurol, 2000; Sasaki, 1983) or y-Al2O3 (Sasaki, 1983). Similar
outer-sphere behavior has been observed by others as well,  especially
when perchlorate salts have been used to vary ionic strength and to
provide a competitor to probe adsorption of another anion (Bourg,
1978; Gisler, 1980; Hundal, 1994; Ji, 1992; Kummert, 1980; Rhue,
1990; Sadusky, 1991; Sigg, 1981; Zachara,  1988; Zhang, 1996). The
number of available  binding/exchange sites  is finite, but very large,
permitting soil to act as a reservoir for anions. Outer-sphere complex
formation is reversible and generally labile, but the sheer number of
active sites can lead to a buffering effect on aqueous ion concentration,
especially  if the soil is  far  from saturated  with the ion.  This
phenomenon is further affected by ionic strength. Under high ionic
strength conditions (i.e., large concentrations of soluble and dissociable
salts), less adsorption is possible for any one particular ion. In the case
of diffuse ion swarms, where aquated counterions  (anions in this case)
hover near the surface in an ion-pair like situation,  association with the
positively charged surface is fleeting and constantly changing, with no
real effect on availability of the ion to the aqueous phase.

     Even though soil scientists routinely use perchlorate salts as
indifferent electrolytes, it is possible that some soil types could resist
desorption. In addition, sorption phenomena in  soil are often more
complicated than those in simpler (e.g., aqueous) chemical systems.
Despite the principle of microscopic reversibility, which requires that
the same pathway for adsorption be available  for desorption, the
thermodynamics of the sorption equilibrium affect the activation energy
of the desorption process. Consequently, it is not  unusual for desorp-
tion  to occur via a different mechanism than the simple reverse of the
one for adsorption (Sparks, 1995). Sorption phenomena have not been
accounted for in any of the adsorption-accumulation studies conducted
thus far. Transport of ions through soil is also a complexprocess (Jury,
1992; Goldberg, 1992; Selim, 1992). It can be difficult to account for in
the laboratory setting due to the additional impacts of hydrologic,
meteorologic,  and geomorphologic factors,  which  are  location-
dependent. Moreover, ion exchange is often transport-controlled
(Sposito, 1994).

3.2.5.  Summary
     To be applicable, studies of perchlorate absorption and accumu-
lation must control for a variety of complicating factors. The presence
of other anions either from co-administration in fertilizers or background
salts present in the water supply may suppress uptake. Interspecies
variation in absorption mechanisms may lead to differing levels  of
absorption and differing locations of accumulation. It is important  to
know if accumulation occurs in fruits versus in leaves or as  a result of
foliar application versus root application (as in irrigation).The rate of
harvesting may lead to different rates of uptake by disrupting normal
physiological processes in the plants.  Lastly,  the effect  of soil
(primarily sorptive in nature) must be considered. Careful agronomic
studies are required to account for such influences, which are likely to
complicate studies on the impact of contaminated irrigation water, too.
                                                                19

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3.3. Difficulties in analysis
     Another problem that has delayed accurate and definitive studies
of perchlorate uptake by edible plants is the difficulty of analyzing for
perchlorate in plant materials. Ion chromatography is currently the
recommended method for routine analysis of inorganic ions such as
perchlorate. It is a sensitive, reliable, and easily-implemented technique
when perchlorate occurs in a matrix that has a relatively low level of
total dissolved solids (IDS). Unfortunately, in a matrix with high IDS
(which largely equates to high ionic strength), other ions can swamp the
conductivity detector and effectively mask the signal from perchlorate.
This has proven to be a very difficult problem with extracts of plant
materials, many of which exhibit high TDS. In addition to potentially
high levels of other inorganic ions, extracts of plant materials typically
contain amino acids, other carboxylates or carboxylic acids (e.g., citrate,
ascorbate, fatty acids) sugars, and nucleotides; all of which contribute
to the ionic environment of the sample (Ellington, 2000). Ion chromato-
graphy is not alone in this regard. Other techniques and  methods
suitable  for  reasonably  dilute drinking water matrices (Urbansky,
2000C; Magnuson, 2000A;  Magnuson, 2000B) cannot be readily
applied to fertilizers or botanical and physiological fluids. The problems
of trace ionic analysis have led to development of other methods that
rely  on  instrumentation  that  is  common  in  high-end  research
laboratories,  such as  asymmetric waveform  ion mobility mass
spectrometry (Handy, 2000; Ells, 2000) or tandem MS-MS systems
(Koester, 2000). Another option used for eliminating dissolved matter
is selective preconcentration of the perchlorate on an anion-exchange
resin (personal communication from Baohua Gu).

     Recently, Ellington and Evans (2000) have reported an IC-based
method for the analysis of perchlorate in plant materials, which greatly
reduces  interferences from high TDS.  Their  method involves first
freeze-drying the plant material and then grindingit through a 30-mesh
screen. The ground material is then mixed with water and heated for 0.5
hours in a boiling water bath  in order to saturate the dry material and to
precipitate proteins. The saturated samples are then shaken and stored
at 3°C overnight.Next, the samples arecentrifuged and the supernatant
is filtered. With most plant  materials, this produces a very highly
colored solution that contains numerous inorganic and organic ions.
Prior to analysis, Ellington and Evans add these highly colored extracts
to alumina sorbent (DD-6) and allow them to stand for 20 hours at 3
°C. Finally, the extracts are filtered through an activated cartridge that
contains  divinylbenzene. The highly colored extracts are  rendered
colorless, and the ionic level  is reduced dramatically.  The minimum
reporting level (MRL) of perchlorate in lettuce and tomato was found
to be approximately 250 ng g~' on a wet mass basis.

     Lettuce and tomato were chosen as representative plants because
they are  considered high priority candidates for screening studies of
perchlorate in foodstuffs (Ellington,  2000) However, it should be noted
that in this work, native perchlorate was not detected in any produce,
nor was the method applied to any edible plants that were grown with
intentional exposure to perchlorate. Instead, perchlorate was spikedinto
the extraction water for one half of the duplicate freeze-dried samples,
while one half were extracted with pure water; consequently, sorptive
loss to plant tissue is not entirely precluded. Ellington and Evans (2000)
were able to evaluate the efficacy of the clean-up procedure for lettuce
and  tomato  in  light  of  the  impact  on the  known  perchlorate
concentration  in  the  spiked extracts.  They observed  no  loss of
perchlorate in spite of the efficient removal of other inorganic (and also
organic)  ions. This  is tentatively attributed  to  preferential  and
competitive adsorption on the alumina. This assertion is supported by
the observation that 40% of perchlorate is lost from solution when
exposed  to alumina in the absence of other  ions. However,  loss of
perchlorate is not expected when the method is applied to plant material
becausemost extracts have high levels of TDS. Despite some remaining
uncertainties, the method of Ellington and Evans (2000) advances the
assessment of potential risk posed by  eating produce grown in the
presence of perchlorate-tainted irrigation water or fertilizer.

3.4. Implications of perchlorate
     absorption and accumulation
    An  obvious concern raised by finding measurable  perchlorate
concentrations in plant tissues is whether this ion can affect food crops.
Most domestic crops are fertilized usingcommodity chemicals with no
known link to perchlorate contamination. Some crops (e.g., corn, wheat,
and  rice)  are fertilized with nitrogen fertilizers that  should be
perchlorate-free because of the manufacturing processes.  There is no
reason to suspect any perchlorate associated with growing grains.

    The only crops with documented use of Chilean nitrate products
are tobacco and citrus  fruits. Data on application of perchlorate-
containing  fertilizers is sparse or nonexistent, and it is not possible to
estimate  the  ecological  impact in any  meaningful way. Modest
information is  available on uptake by tobacco, but this is not a food
crop, and  the use of Chilean nitrate salts appears  to  be  locale-
dependent.

    Depending on the season, sources of fresh and processed fruits and
vegetables vary considerably between domestic and imported. EPA has
no data regarding the reliance on perchlorate-containing fertilizers for
food crops grown outside the U.S.  It is not known whether fruits or
vegetables  absorb and retain perchlorate  ion under typical growing
conditions  (Cf. §3.2); accordingly, it is  not possible  to say whether
produce  can serve as  an exposure  route at this time. There are no
published data on perchlorate in imported produce, no published data
on perchlorate in domestic produce, and minimal data from controlled
laboratory or field experiments on absorption and accumulation in food
crops;  therefore, it  is  impossible to  assess  whether foodstuffs
contribute to perchlorate consumption in humans or whether drinking
water provides the entire body burden.

    Even if many food plants can be shown to absorb and retain
perchlorate under some conditions, the  primary  source of  this
contaminant is irrigation water. However, merely exposing the growing
plant to perchlorate does not imply absorption or accumulation in the
edible portions. In the studies on uptake by lettuce seedlings, the plants
have been subjected to perchlorate concentrations many times higher
than thoseencounteredin irrigation water. In addition,  the confounding
                                                               20

-------
factors described previously and the harvest conditions have not been
accounted for.

     Because aerospace industries, perchlorate manufacturers, and
military  bases  that  use  perchlorate  salts are  fairly  localized
geographically, most of the country's agricultural products should be
free from exposure via tainted irrigation water. On the other hand, some
produce is largely supplied by regions that irrigate with Colorado River
water, which is known to contain perchlorate. Therefore, such produce
represents  a potential exposure  route  for  consumers. There are
currently no investigations underway toexamine food crops with docu-
mented exposure to perchlorate via irrigation or fertilization.  In the
meantime, the gatheringof data by fertilizer manufacturers who  choose
to screen their finished products as part of routine  quality control
measures to prevent  any recurrence of perchlorate contamination is
welcome. Some state or local authorities (e.g., agriculture departments
or state chemists' offices)  may choose to conduct periodic screenings
in the  course of their normal operations of assaying fertilizers to
validate the grade. Unfortunately, it is impossible to be more specific
since the source of the contamination previously observed has never
been identified, but appears to have reflected an episodic, if not isolated,
incident. There  is inadequate evidence to suggest widespread or long-
term perchlorate contamination in  fertilizers  used for  the bulk of
production farming operations nationwide. In fact,mostevidencepoints
to the contrary,  but a modest level of continued vigilance would not be
inappropriate. While the likelihood of exposure via agricultural sources
is small due to the low consumption of Chilean nitrate salts and the low
perchlorate concentrations  therein,  the  significance  of  whatever
exposure does  occur is unknown in terms of food plant uptake or
ecological impact
                                                                21

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