CAROL VAN STRUM 7493 East Five Rivers Road Tidewater. Oregon 97390 Telephone: (503) 528?7151 Telefax: (503) 528-7105 March 10. 1992 John Miller Stillaguamish Tribe of Indians 3439 Stoluckquamish Lane Arlington. Washington 98223 Re: Norris Dost paper Dear John. Enclosed is a hasty review of the Norris Dost paper you sent. Please feel free to put your or Pat's name on it and/or rewrite as you see fit (just watch your grammarl). Paul took his footnote program with him to Tennessee. so I had to put references right in the text; if you do any rewrite. you might want to fix that. If you or Pat want copies of any of the references. I can send them. As you might surmise from the review. my already poor opinion of Norris Dost has sunk to a new low. Let me know how things develop. Say hi to everyone. and I hope we'll see you in a few months. Love. Carol P.S. I'm sticking in a copy of a recent Wall St. Journal article you might enjoy; it's based almost entirely on material I sent the reporter out of Paul's Tennessee litigation. I think I?ve found my true calling at last. an Anonymous Source. March 10. 1992 Comments on Norris Dost. "Proposed Surface Water quality Criteria for Selected Pesticides Used for Forest Management and Management of Forest Tree Seedling Nursery and Christmas Tree Plantations in Oregon and Washington" (December 18. 1991) The careless grammar of this paper reflects the quality of its "science." Grammatical howlers on almost every page suggest a general sloppiness of thought and preparation that extends to its content. Such sloppiness is manifest in the nearly total lack of references for key assumptions and "factual" assertions made by the authors. and in the exclusion of several references essential to any discussion of nursery and Christmas tree uses of pesticides in Oregon and Washington. Without access to the sources of the authors' information. it is impossible to comment meaningfully on the criteria they recommend. In the short time available. these comments will therefore be limited to?a brief ?critique of unreferenced assumptions and factual statements that are crucial to the authors' Conclusions. 1. Assumptions regarding toxicity among different species The authors base their water quality criteria on the stated assumption that "preventing adverse effects in humans will also prevent adverse effects in other mammals [because] human criteria are derived from testing done on other animals. and is (sic) usually baSed on.the lowest identifiable no-observable-effect? lavel in any of the commonly used test animals." (Page 2. Norris no.5 This unreferenced assumption is extremely misleading and defeats a primary purpose of the entire paper. ?to permit evaluation of the effect of pesticide use on aquatic organisms.and on humans and animals which consume water from forest areas." (Page 1. Norris Dost) 'The word "animals" presumably means all classes of animal life. but with their dubious assumption that "preventing adverse effects in humans will also prevent adverse effects in other mammals." the authors at the outset exclude from their criteria any basis for protection of non-mammalian species. birds. reptiles. fish. amphibians. or insects. Furthermore, although the authors state that human criteria are "usually based on the lowest identifiable no-observable? effect?level in any of the commonly used test animals.? they state later in the same paragraph that they derived their criteria from "the lowest identifiable median tolerance limit (usually for cold? water invertebrate and fish species)." (Page 3. Norris Dost) The obvious discrepancy between a lowest no-observable-effect level and a median tolerance level is nowhere explained or justified. nor do the authors anywhere explain. justify. or reference their assumption that median tolerance limits for cold??v water invertebrate and fish species (with applied safety factors) can be used to establish concentrations that will not adversely affect birds. reptiles. amphibians. humans and other mammals. Such unfounded assumptions and serious discrepancies within both the animal classifications and the baseline data used to derive-"safe" pesticide concentrations render the authors? calculated criteria useless either for meaningful comment or for regulatory decision-making. II. Short-term versus Long?term Effects Norris and Dost exclude consideration of long?term effects (cancer. mutations. birth defects. reproductive damage. immune system impairment. neurological and behavioral disorders) on the dubious and unfounded presumption that exposure via water contamination would not reach or exceed a threshold level for cancer alone. ("Our assumption is that exceedance of the water quality criteria we recommend will almost certainly be of short duration. and at levels that would provide a miniscule dose in terms of carcinogenic effect.? Norris Dost. p. 5) The authors' presumption of a threshold for carcinogenic effects flies in the face of current EPA policy on carcinogens; not even-the U.S. Forest Service. a historic advocate of pesticide use. would support such a presumption ("It is assumed that carcinogenicity is not a threshold phenomenon; that is. any dose of these chemicals has some probability of causing cancer. no matter how small the dose." Forest Service. Nursery Pest Management EIS. 1989. p. E-4-6). Indeed. Dr. Dost's suggestion that a "miniscule dose" of a carcinogen will not cause cancer was specifically rejected by the federal courts in Save Our EcoSystems 3L Clark. wherein Dost 4 testified to the same assumption. 91353. 747 Fed 2nd 1240 [Ninth Circ. 1984]) The Ninth Circuit Court of Appeals in that case required the.U.S. Forest Service and Bureau of Land Management to assume that 39 safe levels or threshold doses for cancer. birth defects. and mutations existed for seven of the - pesticides (atrazine. dalapon. dicamba. picloram. and simazine) assumed by Norris and Dost to have such a threshold 1242. n. 1). Two other herbicides assumed by the authors to have "safe? or threshold doses for carcinogenicity have been specifically prohibited for use on Northwest National Forest lands by the U.S. Forest'Service. The first of these. Amitrole. was banned by the Forest Service because "routine operations" could expose both workers and the public to toxic doses. and because "there is strong evidence from animal studies that amitrole-has high cancer potency.? (Record of Decision for USDA Forest Service. Pacific orthwest Region. Final Environmental Impact Statement. Managing Competing and Unwanted Vegetation. November. 1988. p. 6) The second herbicide. fosamine. was banned by the Forest Service because "there is insufficient information for conducting a full toxicological evaluation" of its hazard. Another herbicide included in Norris's and Dost's recommended criteria is 2.4-D. The U.S. Forest Service does not use 2.4-D at all in its Northwest tree nurseries (U.S. Forest Service. Pacific Northwest Region. October 1989 Nursery Pest Management. Final EIS Summary, p. 8, Appendices, p. 4) and will use 2.4-D in Northwest forest management "only as a last resort," because of conflicting studies about its cancer causing potential and because of its "demonstrated potential for adverse neurotoxic. reproductive and developmental effects." (U.S. Forest Service 1989 Record of DeciSion, p. 6) The authors apparently assume that their fictional ?threshold" for carcinogenic effects would also protect humans and other animals from all other long-term effects, which are omitted entirely from discussion with no explanation or justification. The justification given for basing their criteria solely on short-term effects is "the patterns of water contamination expected," yet the authors nowhere define what those "patterns" are. They provide no monitoring data showing how such ?patterns" affect water quality, nor do they demonstrate how such patterns and their resultant contamination levels justify ignoring serious long term effects of pesticide residues in water. The authors' exclusion of long-term health effects from their risk assessment renders their entire analysis false and dangerously misleading. Pesticides Used The authors cite no references whatsoever for the pesticides they identify as commonly used in forestry. nursery, and Christmas tree management. nor do they explain their basis for estimating risks only from ?selected pesticides" used in these categories. It is therefore impossible to assess the accuracy or validity of either the lists of pesticides used or their potential individual or aggregate effects on water quality. Two readily available references, which are not included among Norris's and Dost's limited references. raise strong questions about the accuracy of their lists of pesticides used in tree nurseries and Christmas tree plantations. The U.S. Forest Service 1989 Nursery Pest Management EIS identifies l7 pesticides used in Forest Service tree nurseries that are not included in Norris and Dost: The Oregon State Extension Service identifies 12 pesticides (three of them also. ?listed by the Forest Service) commonly used in Oregon Christmas tree plantations but omitted by Norris and Dost. (See appendices. pp. 2.4.) Between them. these two authorities identify 26 pesticides not included in Norris's and Dost's analysis. These significant omissions raise doubts about the accuracy of their list of pesticides for forestry use. which is also unreferenced. and undermine the validity and completeness of the authors' risk analyses. IV. Inert Ingredients It is difficult to attribute Norris's and Dost's misleading discussion of inert ingredients to honest incompetence. Their discussion relates solely to forest use pesticides, stating . categorically that "The only inert ingredient of toxicological significance in this group are (sic) kerosene and diesel fuel used as a diluent in some formulations." (Norris Dost. p. 6) They neglect to point out that the U.S. Forest Service. the apparent source of their information on inerts. also found that some formulations of carbaryl contain formaldehyde as an inert ingredient; nor do they point out that the Forest Service intends to discontinue use of all formulations containing kerosene. diesel fuel. formaldehyde. or any other inert ingredients identified by EPA as known or likely to be "carcinogens. developmental toxicants. neurotoxins. or potential ecological hazards." (U.S.D.A. Forest Service Nursery Pest Management E18. 1989. p. 27. description of EPA "List 1" and "List see appendices. p. 6.7.) Norris and Dost omit altogether any discussion of inerts in pesticides used in nurseries and Christmas tree plantations. At least one chemical -- acephate -- on their own dubious list of such pesticides is identified by the Forest Service as containing toxic inert ingredients proscribed by the Forest Service (see appendices. p. 7) Five other nursery and Christmas tree pesticides listed by the Forest Service and Oregon Extension Service but not by the authors also contain inerts known or likely to be carcinogens. developmental toxins. neurotoxins. or potential ecological hazards (compare appendices. pp. 2.4 to p. 7) These toxic inerts are not limited to kerosene and diesel. but include such poisons as cyclohexanone. xylene. dioctyl sodium sulfosuccinate. and formaldehyde. (Appendices. p. 7) Norris and Dost cite no sources for their information about pesticides used in forestry. nurseries. and Christmas tree plantations. nor do they anywhere explain the basis for their selection. Their misleading discussion of inerts underscores the significance of their failure to document sources or to explain their numerous omissions. V. Degradation Products. Metabolites. and Contaminants The authors' single paragraph devoted to degradation products and metabolites is so grossly misleading as to defy comment. Again. they cite not a single reference for their "factual" statements. which are indistinguishable from pulp fiction. They state categorically that only one pesticide included in their report -- acephate "degrades to a product with toxicity equal to or greater than that of the parent." Their lack of references for this statement makes it impossible to assess its validity; however. the extensive discussion devoted by the Forest Service to potentially toxic metabolites in nursery pesticides casts severe doubt on Norris's and Dost?s cavalier assertion. see. U.S.D.A. Forest Service 1989 Nursery Pest Management EIS. pp. 15 through The authors' scanty discussion even of acephate and its metabolite. metamidophos. is highly questionable. They state that "Approximately 5-10% [of applied acephate] forms metamidophos. but the rate of formation is slow enough that significant amounts do not accumulate." (Norris Dost. p. Not even the U.S. Forest Service a historic champion of pesticide use -- dismisses metamidophos so Contrary to Norris's and Dost's claim that only of acephate degrades to metamidophos (an unreferenced assertion apparently invented for the occasion). the Forest Service (citing numerous sourcesl reports that "between lg agg_gg_percent of applied acephate is transformed to methamidophos in other animals. plants. and environmental media.? (U.S.D.A. Forest Service 1989 Nursery Pest Management EIS. p. and notes that methamidophos is classified "as very toxic by and is ?10 to 70 times more acutely toxic than acephate." The referenced Forest Service data challenges the credibility of Norris's and Dost's unfounded conclusion that "None of the pesticides" in their report degrade to compounds that contribute significantly to the toxicity of the parent pesticide. The Journal of Pesticide Reform (JPR) article on atrazine (Appendices. pp. 8-12) further illustrates the scope of Norris's and Dost's omissions. JPR's in?depth. fully_referenced article. revealing widespread contamination of ground and surface waters with toxic levels of both atrazine and its metabolites from routine uses. contrasts sharply with Norris's and Dost's sweeping. unsupported conclusions. The authors omit altogether any discussion of toxic contaminants of the pesticides in their report. Again. even the U.S. Forest Service has recognized the significance of some of these contaminants (see U.S.D.A. Forest Service 1989 Nursery Pest Management'EIS. pp. through Highly toxic. 10 persistent, bioaccumulative contaminants such as hexachlorobenzene in atrazine (Appendices, pp. 9?10) present a serious health and environmental hazard, because even "miniscule" amounts of such compounds can persist in aquatic and terrestrial ecosystems for many years, increasing with each pesticide application and continuing to build up in the food chain long after applications cease. Any attempt to calculate environmental hazards from current and future pesticide use must address the cumulative impact not only of persistent contaminants in current or proposed pesticides. but also of persistent residues from previous pesticide applications. Highly toxic chlorinated dioxin residues from historic use of phenoxy herbicides in forest management, for example, have been found in both wildlife and aquatic sediments in the Northwest (Appendices, pp. 14-24); Norris and Dost nowhere take into account the cumulative impact of adding more chlorinated compounds to that toxic load. Dr. Norris himself participated in Forest Service dioxin monitoring efforts and can hardly be unaware of their significance. (Appendices. p. 15.) Norris's and Dost's failure to address pesticide contaminants in their report suggests either gross incompetence or shameless bias. VI. Synergism The authors' discussion of synergism (pp. 6-7) is again totally unreferenced and deceptive. They state at the outset that studies on synergism among pesticides are not available and 11 furthermore not necessary. because studies of synergism between pharmaceutical agents (drugs) somehow demonstrate that synergism will not occur at predicted levels of pesticide exposure. (The authors not only provide no source for this extraordinary conclusion. they further include no data whatsoever on exposure levels found in water monitoring tests following forestry. nursery. or Christmas tree pesticide applications.) The well-known example of synergism between the pesticide Thiram and alcohol in tree planters handling treated seedlings (see U.S.D.A. Forest Service. 1989 Nursery Pest Management EIS. p. casts the authors' preposterous synergism fiction in an unholy light; the Forest Service also notes synergistic effects from the combination of and picloram two of the pesticides in Morris?s and Dost's report. VII. Exposure Routes Norris and Dost do not consider exposure to pesticides by any routes other than consumption of surface water. This limitation alone renders their report useless. Even the Forest Service recognizes that surface water contamination can not be considered as an isolated phenomenon. Surface water is by nature mobile; it flows. meets with other surface and groundwater sources. combining with any contamination they carry: "In many basins streams are fed by both grdund water and surface runoff. thus the quality g?_water 12 resources are interrelated." (U.S.D.A. Forest Service. 1989 Nursery Pest Management EIS. p. E-3-35) Indeed. the Forest Service notes that several of its own nurseries are located both near surface water and over groundwater sources. with the potential to contaminate both. Furthermore. to assume that human and animal exposure will occur solely through drinking contaminated water defies all reason and logic. For terrestrial animals. including humans. the moSt serious route of exposure via contaminated surface water is not only consumption of the water itself. but consumption of contaminated fish and other aquatic organisms in addition to or exclusive of any water consumed. (See. U.S. EPA. 1984 Ambient Water Quality Criteria for 2.3.7.B-Tetrachlorodibenzo-p- dioxin. pp. 1-180 through 182; excerpted table and discussion in Appendices. p. 25.) The dangerous fallacy of assuming exposure only through water consumption is dramatically illustrated by the tragic aftermath of the railroad spill of metam sodium last year in the Sacramento River. where aquatic predators -- herons. eagles. ospreys. otters. raccoons. etc. -- succumbed after eating contaminated fish. The EPA drinking water advisories used by the authors to determine "safe" levels of pesticides in surface water are irrelevant and meaningless. because the EPA advisories do not address wildlife and human consumption of contaminated aquatic species. 13 Adjusting Criteria for Different Patterns of Use Norris and Dost "adjust" their criteria from forest uses to nursery and Christmas tree uses based on a series of flawed. unfounded assumptions that defy readily available data. The authors acknowledge that little or no water monitoring data are available for pesticide uses in Christmas tree plantations or tree nurseries. (Page 3. Norris Dost). Without such data. however. and without a single reference or explanation of how they derived such a number. the authors assume that applying a safety factor of 0.2 to their dubious criteria levels for forest-use pesticides will suffice to protect human and animal life from poisoning by nursery and Christmas tree pesticides. The use of a safety factor apparently pulled out of a hat precludes any meaningful comment on the criteria developed by the authors for tree nursery and Christmas tree plantations. For all three categories of criteria forest. nursery. and Christmas tree uses -- the authors assume that in each category. "applications of pesticides are discontinuous. Exposures are not likely to 'run together'." The authors provide ng_references whatsoever to support this crucial assumption; assuming. however. that pesticide use in 0.5. Forest Service tree nurseries is typical of Northwest nursery practice. Forest Service data on pesticide application times shows not only frequent use of 14 individual pesticides in successive months. but also considerable overlap of two or more pesticides during the same month (see appendices. p. l3. Table 3-8 from U. S.?Forest Service 1989 Final Environmental Impact Statement on Nursery Pest Management). ?The Forest Service data suggests that. contrary to Norris's and Dost's unfounded assumption. exposures are in fact very likely to "run together." and such exposures would very likely be to more than one pesticide.? Norris and Dost confound their erroneous assumption about cumulative exposure with yet another unfounded assumption that ?Even use in?a nursery can result in only occasional movement to water. and then almost certainly it must result from overland flow. not drift. and is readily controllable." Norris Dost. pp. 3-4) Again. the authors provide no reference whatsoever for this extraordinary statement. which is belied by the detailed and extensive attention devoted by the Forest Service to the problems of both drift and surface runoff from Forest Service nurseries (U.S.D.A. Forest Service. 1989 EIS on Nursery Pest Management. pp. E-3-32 through E-3-47). The authors further aSsume that because overland flow is ?readily controllable." it will not occur Oby this logic. because cars are controllable. collisions will not occur and traffic laws would be obsolete). On this faulty. unfounded basis. they have "adjusted? their already flawed forestry criteria for nursery and Christmas tree pesticide use. 15 IX. Conclusion With their extraordinary dearth of references. Norris and Dost apparently expect the reader to accept on faith their recommended criteria for "safe" pesticide residues in surface water. This cursory review suggests that such faith on the part of the public or state regulators would be dangerously misplaced. 16 .w . .- - .5.K?u 24/0/33 natce?, Lab'ii?sl'?'i is; no? Rate of Times Jihated? Pounds Common Name Trade Name Application (3.1.) Applied Treatment Acres Used Plant Growth Regulator Ethepbon Etbrel - 0.625 lb 1 Foliar 1300 790 Gibberellic acid Pro-Gibb 4% 1 Foliar 1100 76 Vertebrate Poison 0.025 - 0.04 1 Bait 280 9 Zinc phosphidc 0.1 - 0.25 lb 1 Bait 290 45 CHRISTMAS TREES Counties Reporting 10 out of 17 18970 Acres Fungicides Chlorothalonil Bravo 1.0 - 4.0 1 Foliar 7500 14000 Herbicides Estcron - 2.0 1 Foliar 1000 1300 Atrazine AAtrex 2.0 - 4.0 1 Soil 5200 38000 Dalapon DOW'pon 3.0 - 11.0 1 Soil 78 370 Roundup 1.0 2.0 1 Foliar 1800 10000 Hexazinone Velpar 1.0 - 2.0 1 Soil 4700 14000 Oxy?uorfen Goal 1.0 - 2.0 1 Soil 20 100 Pronamide Kerb 1.0 - 2.0 1 Soil 420 820 Sethoxydim Poast 03 - 0.5 lb 1 Foliar 63 190 Simazine Princep 2.0 - 4.0 1 Soil 200 7200 Triclopyr Garlon - 3.0 1 Foliar 100 52 Insecticides Accpbate Ortbene - 1.0 1 - 3 Foliar 200 4500 Carbaryl Sevin - 1.0 lb 100 gal 1 Foliar 450 450 Diazinon - 0.5 lb/ 100 gal 1 Foliar 240 140 Dicofol Kelthane - 0.9 lb 1 Foliar 990 Endosulfan Thiodan 2.0 1 Foliar 1300 6300 Malathion - 1 Foliar 210 110 Oxydemeton methyl Metasystox 0.25 - 3.0 1 Foliar 300 Prepargite Omitc - 1 Foliar 170 500 CLOVER VETCH SEED CROP Counties Reporting 12 out of 12 51850 Acres Percent Acres Reported 100% Herbicides 0.75 - 15 lb 1 Foliar 1100 790 Benc?n 331311 0.75 - 1.5 1 Soil 750 900 Dinoseb 1.125 - 3.0 1 Soil 200 200 Diquat Diquat 05 - 0.7511: 1 Foliar 2700 3900 Diuron Karmex - 1.6 lbs. 1 Soil 9600 15000 EPTC Eptam 2.0 - 3.0 1 Soil 1400 3700 MCPA - 0.25 lb 1 Foliar 5000 1400 Pronarnidc Kerb 0.75 - 2.0 1 Soil 5700 6400 Tri?uralin Trc?an 0.5 - 0.75 lb 1 Soil 750 560 Insecticides Chlorpyrifos Lorsban 0.25 -1.0 lb 1 Soil, foliar 550 550 Demeton Systox 0.375 - 0.5 lb 1 - 2 Foliar 1900 2600 Dicofol 0.6 - 1.5 1 Foliar 100 100 Malathion 1.0 - 15 1 Foliar 3600 3800 1.2 - 2.4le 1 Bait 3000 7000 Marlate 2.0 - 3.0 1 Foliar 4800 7100 methyl Metasystox 0.375 - 0.5 lb 1 Foliar 5600 2800 Propargite Comite 1.3 - 1.6 1 Foliar 300 490 15 ??pendt ces, p. 9. United States Department of Agriculture Forest Service Pacmc Nonhwea Hegmn October 1989 paw-w: NursetyPest Management. Final Environmental Impact Statement Summary r- .. it i 8 Summary Chemical Pest Control Methods biological pesticides, allelopathy, and pathogens, are still considered experimental for bareroot conifer nurseries. Four categories of chemical pesticides are used in the nurseries: '0 herbicides are used to control weeds (before 1984 ban) 0 fungicides are used to control diseases caused by fungi - insecticides are used to control insects 0 fumigants are used to control weeds, insects, and diseases Table 5-1 lists the 18 chemical pesticides used at the Pacific Northwest Region nurseries. Each nursery uses a combination of some of these, but not all of them. For more information about these chemicals, see Appen- dices and of the FEIS. Summary-B Table 5-1 Chemicals Used at-th'e Nurseries Generic Nanie Common Trade Name Herbicides (used before the 1984 ban) Bifenox Modown?D DCPA Dacthal?? Dicamba Banvel" Diphenamid Dyrnid" Roundupa Oxy?uorfen Goalo Fungicides Benomyl Benlatea Captan Captan?, Orthocide? Chlorothalonil Bravo?, Daconil" DCNA Botran?? Metalaxyl Subduem Insecticides Carbai'yl Bevin? Chlorpyrifos Dursban? Fenvalerate Pydrin? Malathion Malathion" Acephate Orthene? Fumigants Dazomet? Basamid" Methyl bromide DowfumeQ, Chloropicrin Terr-O Gas? Chemical Controls - Target Pests: Botrytis, fusarium, and other nursery root rot fungi have been the primary targets. The formulations also control nema- todes, weed seeds, and all life stages of insects. The material is a soil sterilent. Potential Non-Target Effects or Use Limitation: Methyl bromide is colorless and odorless. While chloropicrin has a relatively low volatil- ity compared to methyl bromide, it is used as a warning agent because of its noxious odor and irritating effects at very low concentrations. The compounds have good penetrating abilities in dry soils. A liabil- ity of the material is that bene?cial soil microorganisms will also be killed. Soil Effects: Persistence in soils is short, due to breakdown by biologi- cal and chemical degradation. Methyl bromide is readily adsorbed and metabolized. It is mobile in the soil as a result of leaching by water and gaseous diffusion. Chloropicrin adSorbs to soil particles and ?is subject to photodecomposition at or near the soil surface. Wildlife Effects: Methyl bromide chloropicrin is toxic to microor- ganisms, invertebrates, and ?sh. It is most toxic to mammals by inhalation. Human Health Effects: Methyl bromide is classi?ed as a moderately toxic pesticide. Systemic effects observed in laboratory animals ex- posed to methyl bromide included histopathological abnormalities in the forestomach and pulmonary damage and paralysis. Methyl bro- mide was considered a weak mutagen in this analysis based on avail- able data from mutagenicity assays. Chlor0picrin is Classi?ed as a severely toxic pesticide. Systemic effects observed in laboratory animals include decreased liver and spleen weights. Chloropicrin ivas found to be weakly mutagenic. The tumor?causing potential of chloropicrin cannot be evaluated based on available data. lnerts Listing for Formu-Iatlons Inert ingredients in pesticide formulations are an increasingly impor- tant issue, especially?when some testing has shown that they may have detrimental effects to the environment, human health,- and wildlife species. An inert ingredient'is de?ned as any intentionally added ingredient in a pesticide product which is not pesticidally active. They see Pest Control . Methods may be solvents, surfactants, emulsifiers, ?ow conditioners, and other functional ingredients of the herbicide formulation. Cumulative effects of the known ingredients and the full formulations on lethal, sublethal, acute, chronic, and indirect effects to wildlife are relatively unknown. The inert ingredients may exert independent effecB or interact synergistically with the known ingredients. Generally, these inert ingredients are proprietary information of the pesticide manufacturer. The Environmental Protection Agency's (EPA) toxicological tests for registration purposes have regularly concentrated only on the active ingredient(s) of the formula? tion, rather than the formulation as a whole. The listing of inert ingre- dients in categories isan effort to help provide data where unknown chemical combinations have not been tested for their effects on human health and the environment. The Environmental Protection Agency (EPA) has identi?ed about 1,200 inert ingredients that are used in registered pesticides. EPA reviewed the existing human health data on inert ingredients (which include common carriers). The existing data include laboratory studies, epidemiological studies and activity/ structure relationships. EPA categorized inert ingredients into one of four categories: List 1 Contains approximately 55 inert ingredients that have been shown to be carcinogens, developmental toxicants, neurotoxins, or potential ecological hazards. These ingredients are the highest priority for regulatory action. List 2 Contains approximately 50 inert ingredients that have been given high priority for testing because the data is suggestive, but not conclusive, of possible adverse health effects or because they have structures similar to chemicals on List 1. List 3 Contains approximately 800 inert ingredients that are of lower priority for testing-because no evidence from data or similarity of structure to chemicals in List 1 support concern for toxicity or risk. List 4 Contains approximately 300 inert ingredients that are generally recognized as safe. The Forest Service has recommended to its resource managers that they not use products containing inert ingredients found on List 1 or List 2 If no product on List 3 or List 4'15 available, then use of another product is allowed, with the understanding that they will 325 evaluate the risk of the inert ingredient. Otherwise, use of products Alamo-dicing, p. C: Pest Control Methods Table B-4 Pesticide Formulations That Contain inert ingredients on EPA List 1 or EPA List 2 (Inert Concern Listed) Active Chemlcal Product . EPA Ingredient . Company Name . Registration. Number (H) ROHM HAAS COAL 707-174 Inert: CYLOHEXANONE XYLENE ACEPHATE (D ORTHO CHEVRON ORTHENE 75 s? zen-2413* ORTHO CHEVRON ORTHENE FOREST 239-244? ORTHO CHEVRON ORTHENE TREE AND ORNAMENTAL 239-242? (F) DUPONT 352409? Inert: SODIUM SULFOSUCCINATE . CARBARYL (I) DREXEL .CARBARYL 19713-49* - UNION CARBIDE SEVIN XLR 254-333* Inert: FORMALDEHYDE CARBARYL (I) - UNION CARBIDE SEVIN 4 - 254-32? UNION CARBIDE SEVIN 4 OIL 41? . 264-337* Inert: PETROLEUM HYDROCARBONS (KEROSENE) CHLORPYRIFOS (I) DOW DURSBAN 464-360* DOW DURSBAN 454-524* DOW DURSBAN 464-589 FENVALERATE (I) DUPONT 352-485 DUPONT (SHELL) 201-401 MALATHION (1) UNITED AGRI PROD. (HOPKINS) . 2393-280* UNIROYAL MALATHION 400,199.: UNIROYAL MALATHION 400-217* DREXEL MALATHION 5 19713-217* Inert: XYLENE Use of these formulations will be limited to stock on hand. Formulations containing inerts not on EPA List 1 or List 2 are available for these chemical pesticides. 3-30 P- '7 If Atrazine By Bob Uhler Atrazine (2-chloro-4?ethylamino?6- isopropyiamino-l,3,5-triazine; see Fig- ure 1), is a chlorinated triazine herbi- cide used to control certain weeds in corn, sorghum, sugarcane, pineapple. macadamia nuts, and citrus fruits. It is also used for general weed control on industrial and nonagricultural land.1 Herbicides with atrazine as the ac- tive ingredient have been sold under trade names of Atrazine, AAtrex, Atratol, Gesaprim, and Zeaphos.2 Atrazine is also a component of other herbicides such as Alazine,3 Bicep,2 Bullet, Extrazine, Prozine, Rastra,3 Stuazine,2 and Tomahawk.3 Manufac- turers of atrazine include Ciba-Geigy Corp., E.I. du Pont de Nemours Co. Inc., Drexel Chemical Co., Oxon Italia, and Industria Prodotti Chimici.2 Atrazine has been widely used in the United States since 1958. The most recent market estimates from the US. Environmental Protection Agency (EPA) show that more atrazine (70 to 90 million pounds of active ingredient annually) is used than any other US. pesticide. excluding wood preserva- tives. Mode of Action Atrazine kills plants by binding to the cell membrane on which photo- occurs and inhibiting pho- Death occurs when the plant is starved because sis is stopped, from bleaching of the plant's or from the release of free radicals, highly reactive mol- ecules.5 Atrazine is absorbed primarily through the roots and translocated to above ground parts of the plant.?3 Corn, a crop on which atrazine is heavily used, is resistant to atrazine because it can detoxify the poison by means of an enzyme present in its leaves. In addition, corn roots contain a substance that helps break down atrazine molecules.T Acute Toxicity According to the National Institute Bob Uhfer is NGtiP?s information ser- vices coordinator: gram) adult male. for Occupational Safety and Health, atrazine is a mild skin irritant and a severe irritant. The oral mm, the dese that will kill 50 percent of a population oi test animals, is 672 milli- grams per kilogram of body weight in rats.8 If the human LD50 is similar, less than two ounces would be a toxic dose for a typical (70 kilo- Chronic toxicity Chronic toxicity tests of technical grade atrazine have demonstrated di- minished weight gain, increased irrita- bility, and prObable anemia in rats. (The No Observable Effect Level (NOEL) for these effects was 70 parts per million (ppm). NOELs are used by EPA and other regulatory agencies to establish permissible exposure stan- dards.) Chronic feeding studies in dogs9 demonstrated increased mortal- ity, decreased food consumption and weight gain, increased liver, ovary and heart weights (in females) with related electrocardiographic changes in the heart accompanied by detectable pa- thology~ in both sexes. (The NOEL for these effects was 15 ppm.) Other studies have also demonstrated changes in liver and kidney func- tion-10,11 Carcinogenicity Tests of atrazine?s ability to cause cancer in rats using technical atrazine (the active ingredient only, not formu- lated products) found dose-related breast tumors in females and tumors in the testicles of males. The NOEL was 10 in females and 500 in males.9 Another rat study found a dose related increase in combined (cancer of the system) incidence, an increase in benign mammary tumors in males, and an increase in cancer of the uterus in females.12 Commercial (formulated) atrazine products given by injection under the skin or into the viscera of mice at 2.ppm resulted in the devel- opment of and mesotheliomas (another cancer).13 In humans, use of triazine herbi- cides has been associated with an in- crease in tumors of the ovary.? Women previously exposed to tria- zines developed the tumors times as frequently as unexposed women. A study of eastern Nebraska residents found that exposure to atrazine was associated with an elevated risk of an- other cancer, lym- phoma.15 (See Figure 2.) Atrazine is classified by EPA as a possible human carcinogen (Class C) based on the increased incidence of mammary tumors in female rats.2 Mutagenicity While neither atrazine nor extracts from untreated plants appeared muta- genic, a water soluble extract from maize plants grown in the presence of Aatrex 80W (with active ingredient atrazine) contained a mutagenic agent(s) when tested on strains of yeast.? Rats given high oral doses of atrazine suffered DNA lesions in the stomach, kidney, and liver." in addi- tion, field tests with commercial atr- - azine products have demonstrated genotoxic effects on maize pollen.?a Reproductive Effects Treatment of- rat mothers with atr- azine and one of its metabolites dur- ing pregnancy and nursing resulted in slow maturation of their sexual organs. As a consequence, pi- tuitary activity was modified in both male and female and certain hormone receptors were strongly in- hibited.?9 Treatment of rat mothers with atra- zine caused a reduction in the weight of their The NOEL for this effect was 0.5 Atrazine also produced dose-related pattern of tox- icity in the mothers, including mortal- ity at high doses and decreases in food consumption, body weight, and body weight gain?" The maternal NOEL was estimated to be 10 per day. At high doses (700 mg/kg/day) maternal 32 JOURNAL OF REFORM 1991 11, No. 4 Appendices, f" .4 - Figure 2 ?Non- 4Hodgkin' - 11.:113 .. a - - 1 . plans typ'phome (ogds?ario ask or peaihrrom non-Hod {1:5 years"; . .. 1 .. .. .:,Ovarian Lianeer2 margarine) 0 1 Risk of?Deafh from ovarian passer: . ?Qt. ?w Fess-?than- 10 years - ., 5'ka .. .. .. Duration ofAtragine Exposure AllWemen I Agricultural Workers i phema r1 eastern NEDraska. Amer.- J. fed M2111 .. Hearth 15: 533 peopie. Cancer Risks and Airs-zine EXpasure 6-15'years- 16e207fyears Dyer21years; Duration ofAtrazfpe EXposUre IETen'years or more . 1. Weisenbu er, 3b; 1990 Erivifo?nrhental epidemiology of non 5Hedgitin? 2. onna, Adalbene, e: at 1989. Triazine herbicides and ovariesn epithelial :?Both the odds- ratio and the riskratio are equal to. one for unexposed 39"1. Fig? 11-., 't'a 5111?? No or -251. . :33 a .. ?ref-5"? b??1312 Deefhydatrazine r: .. Hexachiorobene?ne- (HUB) N- Nitrosoatrazme .11tetrachiorodibenzofuran (T008 atrazine degradation in soil, up to 80 percent of radio-la- beled atrazine was recovered intact, and less than 1 percent of the parent material was completely metabolized to . carbon'dioxide after 70 days. Atrazine may hydrolyze fairly rapidly in either acidic or ba? sic environments. yet is fairly resistant to hydrolysis under neutral conditions. in a lab study, the half-life of atrazine i .w was less than 40 days under acid conditions, but was al? most twenty times as long under neutral conditions.25 Two of atrazine's metabo- lites, deethylatrazine and deisopropylatrazine (see Fig- ure 3) have been character- ized by atrazine manufac- turer, Ciba?Geigyl as having a . toxicology that' 'can be as- sumed to be similar to that i of atrazine." in some samples of groundwater, deethylatra? .. zine has been measured at concentrations four times as high as the concentration of atrazine.? Mobility in soil: Problems with atrazine?s persistence are compounded by its mo- bility in the soil. A Connecti- cut study detected atrazine '4 Cl Environmental Fate Degradation and persis- tence: Atrazine can persist in the soil from one growing season to the next and in- jure sensitive crops. For ex- ample, it can injure soybeans or alfalfa when they follow corn in a rotation.22 The persistence of s-triazine her- bicides is dependent on a number of soil factors in- mortality was 78 percent and clinical signs included salivation, bloody vul- vae, and swollen abdomens. Rabbits also experienced similar effects: bloody vulvae, reduction in feed con- sumption, body weight, and body weight gain in mothers. Reduced fetal weights, increased skeletal abnormali- ties, and increases in embryo loss were associated with this maternal toxicity. The maternal NOEL was 1 mg/kg/day and the fetal NOEL was 5 mg/kg/day.20 JOURNAL OF PESTICIDE REFORM 1991 (VOL. 11, NO. 4 cluding pH, moisture, tem- perature and microbiological activity. Breakdown of atrazine in the field ap- pears to be slower under winter than summer conditions?" in Nebraska and Minnesota, atrazine'residues have persisted for over a year in agricul- tural loam soils.? At least eleven degradation prod- ucts (metabolites) have been deter- mined for atrazine.?1 However, the triazine ring of atrazine is fairly resis- tant to degradation. in one study of continuously from the surface to the water table at 7.5 feet. Finding residues at this level is signifi- cant because numerous studies have shown that microbial degradation is slower in the subsoils. Thus, herbicide residues detected in deep soils could be sources of leaching to groundwa- ter for many years.27 Under no-tillage conditions, the leaching potential of atrazine was evidenced by concentra- tions greatly exceeding those in con? trol plots in the lowest sampled depths (up to 1.5 m, almost 5 feet) at 14, 42, and 124 days.2E While the movement of agrochemicals through soil is in?u- enced by soil properties, soil manage- ment, weather conditions, and degra- dation processes, in general, atrazine is expected to maintain a very high to medium mobility in soils and should not strongly adsorb to sediments.25 Water Contamination: Considering atrazine's high rate of usage, its po- tential to migrate through the soil; and its relatively long half-life, it is not sur- prising to find atrazine as a common 33 14/0522!de ?23, water contaminant. It has been found in groundwater. rivers, high mountain lakes. drinking water supplies. rain: and even fog.? a Under the Safe Drinking Water Act. EPA establishes maximum contami- nant levels (MCLs) for public water supplies. The MCL for atrazine is 3 pg! 1 and is based on the NOEL of 0.5 mg/ kg/day for reproductive effects in the rat study described earlier. Possible carcinogenic effects are not part of this study: EPA applies an uncertainty fac- tor of 10 in its calculations of the MCL to account for th Estimates of the em and midwestern states sampled. Whilehighest concentrations of atra- ii?e were found in Illinois. lndiana, lowa. Nebraska. and Kansas where atrazine usage is highest. atrazine was also found in nonfarm areas. Highest concentrations were four to?five. pg/l, exceeding the In an Iowa study. samples of treated drinking water were collected from 33 public water supplies using surface water sources. Atrazine was detected in 30 of the 33 samples. The results indicate that current water treatment technology is ineffective in substan- to be the cause of its presence in rain and in the high mountain lakes.? Surveys of European Community member states reveal that atrazine is present in drinking water sources in France. Italy. the Netherlands. Ger- many. United Kingdom. Spain, and ?Inerts? and Contaminants There is no publicly available infor- mation about the "inert" (secret) in- gredients in atrazine formulations. NCAP has filed a lawsuit to force dis? closure of the complete formulations cancer risk posed by lifetime consumption of drinking water con- taminated with atrazine at the MCL are ap- proximately one excess cancer death per hun- dred thousand people exposed.single chemi- cal, and does not apply to metabolites. How- ever. midwestern groundwater contami- nation specialists have proposed that the lev- els should either apply to the total concentra- tion of atrazine plus metabolites. or be made more stringent for atrazine alone.?i in the national sur- vey of pesticides in Figure 4 States with Atrazine-contaminated Groundwater Aquiferstsi? 1. U.S. EPA 1988. Pesticides in groundwater databse. Interim report. Washington. no. 2. Parsons. D.W. and Mid. Witt. 1939. Pesticidesin roundwater in the United States otAmerica. A report of a 1988 survey of state lead agencies. 8406. Corvallis. OR: Oregon State University Extension Service. 3. DeLuca. T. et at. 1989. A surve of pesticide residues in groundwaterin Montana. Helena. MT: Montana Department of Agdcu ture. 4. Erickson. D. and Norton. D. 1990. Washington state agricultural chemicals pilot study. Final report. Olympia. Wk Washington State Department of Ecology. of several, herbicides. in- cluding Aatrx 80W which contains atrazine as the active ingredient. Hexachlorobenzene (see Figure 3) is a reac? tion side product in the production of atrazine."2 In addition, a recent confidential report indi- cates that a tetrachloro? dibenzofuran (see Figure 3) has been found in atrazine. NCAP is in the process of obtaining this report from EPA. NNr?trosoatrazr'ne A special concern re- lated to atrazine?s pres- ence in ground and sur- face water is the pos- sible production of N- njtrosoatrazine drinking water wells in the United Sates, atrazine was the sec- ond most frequently detected pesti- cide analyte. Approximately 1,570 community water system wells and 70,800 rural domestic wells are esti- mated to contain atrazine.?2 it has been found in grdundwater in 24 states. (See Figure 4.) A recent survey of water in the Mis- sissippi 'River33 by the US. Geological Survey (USGS) found atrazine in all of the samples collected in April. May. and June. Over one-quarter of the samples exceeded the MCL (3 pg/l) and the median concentration was over half of the MCL. The highest- atrazine concentrations were over three times the MCL (up to 10 pg/l) and were found in the smallest tribu? taries where a high proportion of the drainage area was cropland. . Another USGS study ?found atrazine in the rainwater in all 23 of the east- 34 (O tially reducing or eliminating atrazine from drinking-water.35 More compli- cated and expensive33 processes (granular activated charcoal filtration and ozonation) are required to remove atrazine and its metabolites.36 A study of rural ponds in Ontario. Canada found that atrazine was the most common contaminant. Eighty- nine percent of the contaminations were due to drift or runoff; the rest were due to spills.? Atrazine and one of its metabolites were found in 89 to 100 percent of .samples taken. from the Sydenham River in Ontario over a seven year period.33 A Swiss study found triazine herbi- cides in all (18) of the lakes tested. with atrazine being the major herbi- cide present. Atrazine was also de- tected in rainwater during the warmer season. Volatilization and wind erosion of treated soil particles are theorized see Figure 3). N-Nitroso derivatives as a class are potent car- cinogens and are formed by the reac- tion of an amine (atrazine. for example) with nitrates (from, for example. ni- trogen fertilizers):l3 NNAT has been formed from atrazine under laboratory is persistent in soil when no sunlight is present, and is more soluble than atrazine in water and thus is a potential groundwater contaminant:13 Extensive groundwater contamination by nitrate and atrazine has been reported.15 in hamsters, NNAT is a strong mutagenfs and al- though a laboratory test of its carci- nogenicity in mice was negative.?5 in- creased incidence of non-Hodgkin's has been documented in Nebraska counties with nitrate-con? taminated wells.15 Effects on Nontarget Organisms Ecosystem level studies have shown. JOURNAL OF PESTICIDE REFORM I WINTER 1991 11. NO. 4 that a whole ecosystem can produce or experience the effects of the chemi- cal that are difficult to identify when only a portion of the ecosystem is used for the assessment."7 The detrimental effects of atrazine on plankton, algae, cynobacteria, and aquatic plants have been demonstrated in streams, ponds, and estuaries. Evidence includes re- duction in biomass, inhibition of pho- and changes in water chemistry. These effects have been found at concentrations as low as- 0.1 parts per billion Atrazine also affects animal species. Studies using experimental ponds show that as little as 20 of atr- azine significantly affects the diet and reproductive success of bluegill al- though the bluegill feeds on insects that would not be directly harmed by atrazine.52 (See Figure 5.) Atrazine also produced physiologic changes in carp.53 Earthworms exposed to atr- azine experienced weight loss, repro? ductive failure, and death.54 Atrazine has been shown to have strong nega- tive effects on the total abundance of several species of insects at concen? trations as low as 20 ppb. Species richness, total abundance of emerging insects, and the total number of her- bivorous insects were all reduced.55 Resistance Around 1970 farmers first noticed that weeds were becoming resistant to atrazine. As of 1983, more than two dozen weed species in Europe, Canada, and the U.S. were resistant to atrazine. Researchers found that a change in a single gene can account for the devel- opment ofiresistance.56 Not only is atrazine resistance spreading, but this resistance is associated with resis- tance to other herbicides. Atrazinere? sistant species have also been found to be resistant to phenmedipham, lenacil, fenuron, and diuron.57 Resistant species and biotypes have also been found in nonagricultural systems. In some of the experimental pond studies mentioned above, re? searchers found that after?initial de? creases in populations of phytoplank- ton, algae and vascular aquatic plants, communities often recovered in mass. However, there was a change in the community profile, and resistant spe- cies became Regulatory Issues In 1990, EPA classified atrazine as a restricted use pesticide and made label revisions in an effort to reduce worker exposure and groundwater contami- nation. EPA took these steps in re- sponse to a voluntary request by the manufacturers, but also noted that additional action may be necessary to reduce groundwater contamination.2 Other governments are also acting to protect their citizens from exposure to atrazine. The Wisconsin Board of Agriculture, Trade, and Consumer Protection has tightened its restriction of atrazine use in the state. Regula- tions expected to be in place by, the 1992 growing season (pending another round of public hearings) will prohibit atrazine application on 24,000 acres and restrict use on an additional 700,000 acres?3 These regulations are designed primarily to reduce ground- water contamination. As of March 29, 1991, the German government banned all atrazine-con- taining products. In addition, Germany and Holland have proposed that use of atrazine be banned by the whole European Community.? Conclusion Atrazine is one? of the most widely used pesticides in the world, and it is also one of the most commonly found contaminants of water. There are three major concerns associated with atr- azine-contaminated water: effects on consumers of water, phytot0xicity of irrigation water to non-target plants, and toxicity to aquatic organisms.60 Atrazine has caused tumors, damaged genes, adversely affected reproduc- tion, and resulted in a wide variety of other chronic effects in tests on labo ratory animals. It is also a skin and irritant. In humans, exposure to atrazine has been linked to two forms of cancer. Studies have shown atrazine to have significant impacts on aquatic ecosystems, and numerous plant spe? cies have developed resistance to this herbicide. Regulatory action has been taken by the US. government, state govern? ments, and governments of other countries to limit the use of atrazine in order to protect workers from ex- posure and water supplies from con? tamination. Additional restrictions on the use of atrazine seem imminent, but widespread implementation of nonchemical alternatives to atrazine's use is required to protect ourselves and our ecosystem from this toxin. ,?ji-i?i-ii? offend r: Hm .3: ch -. .352 1 . riffs/1.5mm: is I . arer's?gtf?sr ?933?: '2 fly-m?? *thimbtriaf "a 3k: 5? ?i ponds treated: With alanine:- Jamal 38- 52:. (J55 JOURNAL OF PESTICIDE REFORM 11. NO. 4 35 Fr References EPA 1989. Health advisory summary: Atrazine. Washington. D.C. U. 5. EPA. Office of Public Affairs. 1990. EPA restricts pesticide atrazine. Press ad- visory. Washington. D.C. (January 26.) 1991 Farm Chemicals Handbook. Willoughby. OH: Meister Publishing Co. Aspelin. A.L.. A. H. Grube. and V. Kibler. 1991. Pesticide industry Sales and Usage: 1989 Market Estimates. Washington. D.C.: US. EPA. Economic Analysis Branch. Gressel. J. 1986. Modes and genetics of herbi- cide resistance in plants. in National Re- search Councii. Pesticide resistance: Strategies and tactics for management. Washington. D.C.: National Academy Press. Weed Science Society of America. 1983. Her- bicide handbook. Fifth edition. Champaign. 11.. Brown. A. 1978. Ecology of Pesticides. New York. NY: John Wiley 8: Sons. US. Department of Health and Human Ser- vices. National institute for Occupational Safety and Health. 1991. Registry of Toxic EF recs Oi" Chemical Substances. Cincinnati. OH. . California Department of Food and Agri- culture. 1990. Summary of toxicology data: Atrazine. Sacramento. CA. Santa Maria. et al. 1986. Subacute atr- azine effects on rat renal function. Bull. Environ. Contam. Toxicol. 36: 325-331. Santa Maria. C., .i Moreno and Lopez- Campos. 1937. Hepatotoxicity induced by the herbicide atrazine in the rat. J. Appl. Toxicol. 7(6) :373-378. Pinter. A. et al. 1990. Long-term carcinoge- nicity bioassay of the herbicide atrazine in F344 rats. Neoplasma 37(5): 533 - 544. Donna. A. et al. 1981. Preliminary experi- mental contribution to the study of pos? sible carcinogenic activity of two herbi- cides containing atrazinesimazine and trifuralin as active principles Pathologica 73: 707-721. Donna. A. et al. 1989. Triazine herbicide and ovarian epithelial neoplasms. Scand. J. Work Environ Health 15: 47-53. Weisenburger. DD. 1990. Environmental epi- demiology oi non-Hodgkin's in eastern Nebraska Amer: J. ind. Med 18: SIBSOS. Fiona. M. and Gentile. 1976. Mutagenic- ity of atrazine: a maize-microbe bioassay. Mutation Research 38: 287-292. Pino. Maura. and P. Grillo. 1988. DNA damage in stomach. kidney. liver. and lung of rats treated with atrazine. Mutation Re- search. 209: 145-147. Plewa. M. et al. 1984. An evaluation of the genotoxic properties of herbicides follow- ing plant and animal activation. Mutation Research 136: 233-245. Kniewaid. J. et al. 1987. indirect influence of s-triazines on rat gonadotropic mecha- nism at early postnatal period. Journal of Steroid Biochemistry. 1095-1100. . lnfuma. R. et al. 1988. Teratological evalu- ations of atrazine technical. a triazine her- bicide. in rats and rabbits. J. Toxicol. Environ Health. 24: 307-319. US. EPA. Of?ce of Drinking Water. 1988. Atra? zine health advisory. Washington. D.C. 36 Leavitt. RA. et al. 1991. Assessing atrazine persistence in soil following a severe drought. Bull. Environ Contam. Toxicol. 46: 22-29 . Frank. R. and G. Sirons. 1985. Dissipation of atrazine residues from soil. Bull. Environ 24. 26. 27. 28. 30. 31. 32. 33. 35. 37. 39. 40. 41. Contam. Toxicol. 34:541-548 DeLuca. Debbie. 1988. Second auan?eriy re- port: Anaiytical determination of pesticide parent and degradation product concentra- tions in groundwater. Madison. WI: Univer- sity of Wisconsin. Madison. . Howard. Phillip. ed. 1991. Handbook ot'En- vironmental Fate and Exposure Data for 0r- ganic Chemicals. Vol ill: Pesticides. Chelsea. Ml: Lewis Publishers. Belluck. D.A.. S.L. Ben] amin. and T. Dawson. 1991. Groundwater contamination by atra- zine and its metabolites: Risk assessment. policy and legal implications. in Somasundaram. L. and .I.R. Coats (eds.) Pesticide transformation products: Fate and significance in the environment. Washing- ton. D.C.: American Chemical Society. Huang. L.Q. and CR. Frink. 1989. Distribu- tion of atrazine. simazine. alachlor. and metolachlor in soil profiles in Connecticut. Bull. Environ. Contam. Toxicol. 43: 159-164. Helling. C. et aL 1988. Persistence and leaching of atrazine. alachlor. and cyanazine under no-tillage practices. Che- mosphere . Glotfelty. D.E.. J.N. Seiber and LA. Liljedahl. 1987. Pesticides in fog. Nature 325: 602 - 605. U.S. EPA. 1991. Rule; and Regulations. Federal Register (January 30). Belluck. DA. and S.L. Benjamin. 1991. Risk assessment. policy and legal implications of atrazine metabolites in groundwater and drinking water. in North American Association for Environmental Education Conference Pro- ceedings. St. Paul. MN. U.S. EPA. Office of Pesticides and Toxic Substances. Office of Water. 1990. National survey of pesticides in drinking water wells: Phase 1 Report. 57019-904115. Washington. D.C. (November). Food Chemical News. Inc. 1991. Atrazine. alachlor over MCLs in Mississippi River. USGS finds. Pesticide and Toxic Chemical News (November 20). . Goering. 1991. it's raining pesticides. US.GS. says. Chicago Tribune (lune Wnuk. M. et al. 1987. Pesticides in water supplies using surface water sources." (abstract) lowa Dept. of Natural Resources Report it . Adams. C.D. et al. 1990. Atrazine and its degradation products in soil and ground water. and the effectiveness of water- treatment processes for their removal. Proceedings from the 40th Annual Univer- sity of Kansas Environmental Engineering Conference. Lawrence. KS. (February 7). Frank. R. et al. 1990. Contamination of ru- ral ponds with pesticide. 1971 - 85. Ontario. Canada. Bull. Environ Contam. Toxicol. 44: 401 - 409. . Frank. R. et al. 1990. Triazine and chlor- acetamide herbicides in Sydenham River water and municipal drinking water. Dresden. Ontario. Canada. 1981 - 1987. Arch. Environ. Contam Toxicol. 19: 319 -324. Buser. H. 1990. Atrazine and other s-triazine herbicides in lakes and in rain in Switzerland. Environ. Sci. Technol. 24(7): 1049 - 1059. Battaglia. G. 1988. Current levels of pesti- cides in drinking water sources in EC member states. in The EEC Directive 80/ 778 on the Quality of Water Intended for Human Consumption: Pesticides. May 5 6. 1988. Como. itaiy. (Seminar). Albanis. T.A.. PJ. Pomonis and A.T. Sdoukos. 42. 43. 44. 45. 46. 47. 48. 49. 50. 51. 52. 53. 55. 57. 58. 59. 1986. Seasonal ?uctuations of organochiorine and triazine pesticides in the aquatic system of ioannina Basin (Greece). 'IheScience of the Total Environment. 58: 243 - 253. Verschueren. K. 1983. Handbook of envi- ronmental data on organic chemicals. New York: Van Nostrand Reinhold Co. Wolfe. at al. 1976. NlNitrosamine for- mation from atrazine Bull. Environ. Contam. Toxicol. Weisenburger. D.D. et al. 1987. N4niti'oso- atrazine (NNAT). chemical properties. acute toxicity and mutagenic- ity. Proc. AACR 31:103 Weisenburger. D.D. et al. 1988. Mutagen? esis tests of atrazine and nitrosoatrazine: Compounds of special interest to the Mid- west. Proc. AARC 29:106. . Weisenburger. D.D. et al. 1990. Carcino- genesis tests of atrazine and nitroso? atrazine - compounds of special interest to the Midwest. Proc. AARC 31:102. deNoyelles. F. et al. 1989. Use of experi- mental ponds to assess the effects of a pesticide on the aquatic environment. in Voshell. J. Using mesocosms to assess the aquatic ecological risk of pesticides: Theory and practice. Lanham. MD: Ento- mological Society of America. Lampert. W. 1989. Herbicide effects on planktonic systems of different complex- ity. Hydrobiofogia 188/189: 415-424. Stratton. G. 1984. Effects of the herbicide atrazine and its degradation products. alone and in combination. on phototropic microorganisms. Arch. Environ Contam. Toxicol. 13(1): 35-42. Kosinsid. R. 1984. The effect of terrestrial herbicides on the community structure of stream periphyton. Environ Poll. 36: 165-189. Correll. D. and T. Wu. 1982. Atrazine toxic- ity to submersed vascular plants in simu- lated estuarine microcosms. Aquatic Botany 14: 151-158. Kettle. W. Dean et al. 1987. Diet and repro- ductive success of bluegill recovered from experimental ponds treated with atrazine. Bull. Environ. Contam. Toxicol. 38: 47 -52. Gluth. G. and W. Hanke. 1984. A compari- son oi physiologic changes in carp. Cyprinus carpio. induced by several pollut- ants at sublethal concentration. Comp. Biochem. Physiol. 79(1): 39 - 45. . Fischer. E. 1989. Effects of atrazine and paraquat-cOntaining herbicides on Eisenia ioetida (Annelida. Oligoohaeta). Zool. Anz. 291-300. Dewey. 5. 1986. Effects of the herbicide atr- azine on aquatic insect community structure and emergence. Ecology 67(1): 148 - 162. . Marx. .I. 1988. Plants resistance to herbi- cide pinpointed. Science 220: 41-42 Solymosi. P. and E. Lehoczki. 1988. Co-re sistance of atrazineresistant Chenopodium and Amaranthus biotypes to other photo- system if inhibiting herbicides. Z. Naturt?orschung 44c:l 19:1 27 ?Legislative Watch: State News.? 1991. Farm Chemicals National Coalition Against the Misuse of Pesticides. 1991. UK and Germany move against tria'zines. Technical Re- port . Plonke. H.B. and D.W. Glotfelty. 1990. Con- tamination of groundwater by atrazine and selected metabolites. Chemosphere 21 (6): 813 - 822. JOURNAL OF PESTICIDE REFORM 1891 IVOL. 11. N0. 4 IqO/Jer/Ldtcas, p. F155. Tltnal Eih?, can q%ust I Table 3-8-Pesticide'application times by month of average programs for each Region 6 nurserya Region 6 nurseries Bend Wind Pine, Dorena, Stone, River, Pesticide Oregon Oregon Oregon thhington HErbicides . Bifenox Apr.-Aug. - May-Oct. - DCPA - - - Apr., Aug. Dicamba - - Apr.? - Diphenamid - - Apr.-Aug. Aug.-Dec. July, Apr.- Mar.- June, Aug.c' Sept. Oct.c Ang.? Oxyfluorfen Jun., sept. - - Sept. -Nov. Fungicides Benomyl June, July May-July May-Dec. Apr.-Aug., . Oct. Captan June - - - Chlorothalonil June NOv.-Feb. May-Dec. Apr.-Aug., . Oct. DCNA - - May-Dec. - Metalaxyl June May-June March-Oct. - Insecticides Acephate - Apr.-Aug. - - Carbaryl July-Aug. - - - Chlorpyrifos - - Aug. - Fenvalerate - - Jane-Sept. - Halathion -- Apr.-Sept. - - aUsed to estihate approximate times of exposure for mixer/loader/applicators and seed treaters. Cover crop. cHonor-op. 0. L3 I .i 2 - meme . .IC, PACIFIC FINAL ENVIRONMENTAL VEGETATION MANAGEMENT-WITH HERBICIDES (Revised) -. Prepared in Accordance with Section 102(2)(c) of Public Law 9l- i90 'The National Environmental Policy Act of l969 E'Responsible Official for National Forest LandSi Ry E. Worthington REQional Forester Pacific.Northwest Region Forest?service-USDA P. 0. Box 3623 Portland, OR 97208 Summary I. Draft Final (X) il. Forest Service Administrative (X) Legislative IV. DESCRIPTION OF PROPOSED ACTION Approximately 150,000 out of 2h,333,612.acres of National Forest lands within the Pacific Northwest Region of the U. 5. Forest Service are proposed for vegetation management with herbicides for the Fiscal Year l978. The areas are located on National Forest lands in Washing- ton, Oregon, and Del NOrte and Siskivou counties in California. The preferred alternative is to use all the methods available to the Region for vegetation methods Include using all the registered herbicides available at this time, mechanical clearing, manual clearing, biological control, and prescribed burning. In addition to the'preferred alternatiVe-, four other alternatives are discussed and evaluated. These. alternatives vary the combination of vegetation management methods and funding levels to accomplish vege- tation control. Environmental impacts of the preferred and other alter- natives are deScribed for both immediate and cumulative effects. The proposed action has been reviewed in light of the guidelines set forth in the Interim Directions issued to implement the National Forest Hanagement Act (P. L. 9h-588), and is determined to be consistent with those' guideli.nes. EXHIBIT 8 3 ?37 Sb": 9 UNIT ED STATES r?tL PROT ECTION AGENCY ?inmate? WASHINGTON n..c 20460 OCT 19 THE ADMINISTRATOR Mr. John R. McGuire Chief Forest Service U. S. Department of Agriculture P.O. Box 2417 washington, D.C. 20013 Dear Mr. MCGuire: As promised in my letter of June 24, 1977, IEam providing a more detailed response regarding the analyses of animal samples submitted to this Agency by Dr. Logan Norris of your Corvallis Laboratory. we greatly appreciate the Forest Service's c00peration in the TCDD monitoring program and sincerely regret that you feel you have not been kept informed on the status of-the program. You may not be aware that a draft of the EPA position_document (PD) on TCDD was forwarded to USDA for review and comment on May 4, 1977. A response was prepared by Dr. Ralph Ross, USDA, and forwarded to this Agency?in June. A copy of the PD is enclosed for your information. Ewe redraft of the PD is nearly complete and, once released, will represent the Agency?s position on the dioxin (TCDD) monitoring program. I hope the following information will further enable you to complete your report of this study: A) List of samples submitted for analysis Please refer to Table 7 (enclosed). B) Description of the analytical nethodology. Please refer to Analytical Methodology (enclosed). C) Results of analysis. Please refer to Table 7 (enclosed). 11?82 Ala/In 1AA: r-n u. I. D) E) F) G) .2- Evaluation of negative and ppssible_positive residues reported. The forest samples ?were analyzed using the direct probe mass ?spectrometric technique. As you are ?aware,'the Agency suspended the hearings in 1974 due to serious reservations about the adequacy.of this analytical method. Specifically, the DPMS method failed to eliminate major sources of interference. The results of the forest samples analyzed in-l973-74, therefbre, are not accepted by this Agency as a precise, quantitative representation of the amount of TCDD present in these samples. Rather, these data indicate a potential TCDD residue which needed confirmation by an acceptable analytical technique. The samples reported in'section of this letter represent an attempt to confirm the 1973?74-forest sample data using present analytical techniques. Some of the samples analyzed in 1973?74 still appear positive fer TCDD. Unfortunately, the results from the two laboratories participating in the confirma- tion vary widely. The confirmation analyses, therefore, still do not give a precise quanti? fication of the amount of TCDD present. It does appear, however, from a qualitative standpoint that TCDD was present in a small percentage of the forest samples collected in 1973. Disposition of samples at the end of the 1973? I 74 EPA_study effert. Remaining sample media are now in storage at our Pesticide MDnitoring Laboratory (PML), Technical Services Division, Mississippi Test Facility, Bay St. Louis, Mississippi. Listing of samples taken for confirmatory analysis since mid-1974. Please refer to Results of Reanalysis chart (enclosed). Future plans for samples from this study. Study of these samples has been completed. No further analysis of the samples is anticipated. ??83 AO?nmAlra: H) Other similar studies (and principal investigators) either completed or presently underway. Environmental samples analyzed under Phase I of the Dioxin Implementation Plan (DIP) consisted of 128 beef samples (combined adipose and liver). Participating laboratories included: our PML at Bay St. Louis, Mississippi, Dow Chemical Company, Harvard University, Northrup Laboratories under contract to EPA's ReSearch Triangle Park Laboratories, Wright State University, and University of Utah. The conclusions of the collaborators concerning Phase I beef analyses are contained in the June 1976 memorandum (see enclosure). Additional Phase I research now underway is designed to determine the optimal combination of TCDD cleanup and analytical techniques. This study involves Harvard University, the University oerebraska, and our PML at Bay St. Louis, Mississippi. The duration of the study is approximately 90 days. Once the determination is made, analysis of the fbllowing Phase II samples will begin: l6? human milk, liver, and adipose samples collected from persons in Mississippi and Arkansas who might have been eXposed to TODD through the Use of on rice; an additional 110 beef fat and liver samples; and human milk and adipose samples collected in Oregon (elective biopsy program, monitoring to begin shortly.) It has not yet been deterwdned which laboratories will perform the analyses of these samples. Further, under the Phase II Urban Monitoring Program, the Agency is collecting several hundred samples of soil, water, water sediments, soil microorganisms, small mammals, birds, etc., as part of an overall effort to determine the potential fer TCDD to accumulate in the environment. ??84 Akymumimnry p. .. 4.. If ypu require additional information, do not: hesitate to contact me or Carolyn K. Offutt, Dioxin Project Manager (WH9566), at (202) 755-9336. sincqrely yours, . Actm k/ 8 Douglas M. Costle- Enclosures H-BS Appendzc?g or or 115m mmnom-nmm. ORIGINALLY HY omncr PROBE mas sracraormv (197M accession 19'1?! analysis Harvard 0. wright St. II. (1976) amnle tvpe no. no. recover-v dfat. Jinil?. TCDD level 1 reco?rmlimi t. TCDD level teem? TCDD ln? 1. Pcuicks Wren 329 003 31.2 383 21 135 i-h 10;] 2h 9 In, his 2.. non: House 267 new 3h 11.0 1h.h- 38 152 - .133 '10 28 3. Peuicks um; 337 010 3? 3m: $132331 016? 3h 1 21.6 9 136.1 sample not. analyzed .155 30 0 5. Sfellers Jay 251' 017? 1'3 7.5 312.? sample not analy'zed 52 10 0-51 '61 ?gavlpweddbr Varied Thrust 3 Golden Crowned Sparrows 2 I?M-ino- hA?n 'l ll 1: il'l ll'l' li'ml'l ll. i.n'.TCDD Collected/ Application Level in Accession Sample Rec. Corr. Percent TCDD Det. TC Type of Sample Sprayed Site Number Rate {lb/AI Lot No.7 2.4.5-T Number Weight For Recoverx Level Oregon Headow'?ouse Hobo Unit A 4-26-326 5.0 N02 102 66.0 no Hermit Thrush 332 5.0 Yes 32 20.0 ND Bewicks Hren 329 3.0 N02 41 11.2 01 llairy woodpeckei' 336 20.0 No3 55 3.0 m1? Downy-Hoodpeeker Hebo Unit 3 a Amehem 60.1 2010 N01 43 1426 RB Rainbow Trout 5 6310 Deer House 320 5.0 Yea 65 9.6 ND Bewicks Wren 3 330 10.0 No 43 14.6 ND Dendrocopos Pubescens - - - - - - - - - - - - Hairy ?oodpecker 240 20.0 Yes 40 25 ND, - Hermit Thrush 253 10.0? Yes 28 19 ND Deer Hice 4' 260 10.0 Yes 40 44.0 ND Hinier Hrens 261 5.0 Yes 40 21 ND Rainbow Trout Downy Woodpecker 334 10.0 Yes 02 0.4. 00-, Deer House 320 5.0 Yes 65 0.6 00. - Bewicks Wren 1' - 330 10.0 Moi. 43 14.6 110:2. Dendrocopos Pubescens 333 10.0 Yes 29 35.0 Song Sparrow Haldport Unit A 327 0.0 No3 60 4.0 Steilers Jay Haldport Unit 16 3 Amchem 300 >30 Atrazine 0.07 0.007 0.45 0.045 BT 1.0 0.1 5.0 0.5 CarbaryI 0.0006 0.00006 0.07 0.007 Chiorothaioni] Data not Iocated 0.005 0.005 Daiapon 0.1 0.01 34 3.4 Dicamba 0.39 0.039 3.5 0.35 DieseI 1.4 0.14 0.019 0.0019 2.4-0 amine 0.4 0.04 10 1 2,4-0 ester 0.12 0.012 0.06 0.006 ester? 0.12 0.012 0.06 0.005 Fosamine 152 15.2 37 3.7 eiyphosate 0.3 0.03 0.24 0.024 Hexazinone 5.6 0.56 32 3.2 Imazapyr 10 1.0 11 1.1 Picioram 0.005 0.0005 0.15 0.015 Simazine 0.1 0.01 0.28 0.028 Suifmeturonmethyl 1.2 0.12 1.2 0.12 Triciopyr, amine 5.6 0.56 11.7 1.17 TricIopyr, ester 0.032 0.0032 0.07 0.007 1Vaiues based on 2.4-0 because of lack of adequate data base for and chemical simiIarity between 2.4?0 and 2 Vaiues estimated, based on 167 foid higher toxicity of tricIopyr ester to fish compared to tricIopyr amine 25 TabIe 4. Forest tree seediing nursery and'Christmas tree plantation management-? Surface water quaiity advisory criteria which provide protection for aquatic organisms. Pesticide Aquatic Organism Invertebrates Fish Instantaneous 24-hour . Instantaneous 24-hour maximum average maximum average Acephate 0.13 0.013 1.0 0.1 Amitroie 0.36 0.036 1.4 0.14 Asuiam Data not Iocated 1500 150 Atrazine 0.014 0.001 0.09 0.009 Bifenthrin 0.00004 0.000004 0.000002 0.0000002 Chiorothaionii Data not Iocated 0.001 0.0001 DieseI 0.28 0.028 0.004 0.0004 Dienochior Data not Iocated 0.001 0.0001 Endosuifan 0.00004 0.000004 0.00002 0.000002 Hexazinone 1.12 0.11 6.4 0.64 Hancozeb - 0.01 .0.001 0.03 0.003 Propargite Data not Iocated 0.002 0.0002 Simazine 0.02 0.002 0.05 0.005 26 The following is a brief synopsis of the basis for the values in Tables 3 and 4. Acephate: than 50 mg/liter for yellow perch, most values are greater than 100 mg/liter for trout of various species. Rainbow trout had LCso for 1100 mg/liter, other tests with this species report LCso values of Z30 mg/liter. For this report we use the 50 mg/liter figure as a conservative value for fish. The value for invertebrates is for the stonefly Amitrole: The most sensitive L050 value found for invertebrates is 18 mg/liter for the copepod, Cyclops vernalis. For fish, the most sensitive L05o value found was 70 mg/liter for yearling coho salmon. Other values are 325 mg/liter for the same species, age not specified. Asulam: No data was found for invertebrates. The [Igo was more than 5000 mg/liter for rainbow trout, and more than 3000 mg/liter for bluegill. Atrazine: The midge (Chironomus tentans) was the most sensitive invertebrate tested with atrazine (L050 0.72 mg/liter). In other tests with daphnia, scud, and Gammarus fasciatus (an amphipod) the LC.50 values were 5 to 9 mg/liter. Fish are less sensitive, with the most sensitive Lc?,value being 4.5 mg/liter in rainbow trout. Brook trout and bluegill had of 6 and 8 mg/liter. 27 Bacillus thurinqiensis: BT had an 10 mg/liter for stone fly and 50 mg/liter for juvenile coho salmon. In other tests the 1150 was 70 to 370 mg/liter for rainbow trout, depending on the fbrmulation. Carbaryl:? Shrimp (glass, mysid) are quite sensitive, with glass shrimp showing an Lcm,value of 0.0056 mg/liter. Stonefly.and daphnia are in the same range, while scud are less sensitive. Fish are less sensitive with the most sensitive 0.69 mg/liter in lake trout, 1.95 mg/liter in rainbow trout and 4.3 mg/liter in coho salmon. Chlorothalonil: No data located on invertebrates. The fish values is for rainbow trout with an LCm,value of 0.05 mg/liter. Dalapon: The most sensitive LC?JFound for invertebrates was 1 mg/liter for stonefly for the sodium salt of dalapon. In other tests, the L05o for stonefly was more than 100 mg/liter and for the dragonfly more than 1600 mg/liter, all for the sodium salt. The lower value was used in this report. The most sensitive LCso for fish was 340 mg/liter for trout. This is the value used in this report. Values for other species include 115 and 500 mg/liter for bluegill, Isomewhat dependent of formulation. The sodium salt of dalapon as it is used in common commercial formulation caused Lc?,values of: 500 mg/liter for bluegill and 340 mg/liter for trout. Dicamba: The amphipod, Gammarous lacustris is the most sensitive invertebrate to dicamba, with an LC?,of 3.9 mg/liter. Other invertebrates such as daphnia and scud are less sensitive at 11 and more than 100 mg/liter. Rainbow 28 trout showed an LL50 of 35 mg/liter and bluegill showed 130 mg/liter. Coho salmon on the other hand showed no effect at 100 mg/liter. Diesel: EPA reported Lc?lvalue for fresh water fish of 0.19 mg/liter for diesel and 1.2 mg/liter for No. 2 fuel oil. This is believed to be the concentration dissolved in the water, rather than a surface residue. American shad had an Lc?,value of 125 mg/liter but this test included surface residues. This distinction is important, indicating water quality tests must distinguish between surface (floating) oil film residues and residues in the water. We suggest water samples analyzed for diesel oil or fuel oil be centrifuged and the surface layer discarded before analysis. The data for invertebrates is for blue crab, with an [Igo of 14.1 for No. 2 fuel oil. Weeks, et al., (1988b) =report no other values. amine: There are many different values for the toxicity to invertebrates of the many amine forms of The most sensitive value found was 4 mg/liter for daphnia for the dimethyl amine salt. The scud and crayfish are less sensitive to this form, with 11g, values of more than 100 mg/liter. Chinook salmon and rainbow trout showed Lc?lvalues of 100 mg/liter for dimethyl amine 2,4?0 (bluegill were 188 mg/liter). ester: The propylene glycol butyl ether ester'was the most toxic form of ester to invertebrates. The [?50 value used irI the report is 1.2 mg/liter for daphnia, although there is one report of an llgo value of 0.1 mg/liter. This single report seems at odds with the several other values in the 29 range of 1.2 to 5 mg/liter. Crayfish had an? L05.o value of more than 100 mg/liter. Stonefly were 2.6 mg/liter, cutthroat, rainbow and lake trout all showed L05o values of mg/liter for the propylene glycol butyl ether ester. Bluegill were more sensitive at 0.6 mg/liter and in another test, cutthroat trout had an LC?fof 0.8 mg/liter. Tests with other formulations show consistently higher LCSD values. Dienochlor: Data for invertebrates were not located. The L050 is 0.05- mg/liter for rainbow trout and 0.6 mg/liter for bluegill. Fosamine: The LCSO for fosamine for invertebrates is 1524 mg/liter (daphnia), based on a single test reported. For fish the value is 367 mg/liter (for rainbow trout yolk?sack fry). The egg stage was much less sensitive (LCso 1456 mg/liter) and coho salmon showed no response at 200 mg/liter. Daphnia showed the most sensitive LCso for invertebrates at 3 mg/liter to the Roundup formulation. Other species had LCso values of 18 mg/liter (midge, Chirononus plumosus), 62 mg/liter (amphipod) and more than 1000 mg/liter for crayfish. In other tests the [?50 for daphnia was 5.3 and 192 mg/liter for this same formulation. Among cold water fishes tested, rainbow trout is most sensitive with 1150 values of 8.3 and 48 mg/liter for Roundup formulation. The surfactant in the formulation is apparently alnajor contributor to this toxicity, since formulations without the surfactant (such as Rodeo) show Lc?,values which are much higher. The Lc?,for the surfactant is 2 mg/liter for rainbow trout and 3 mg/liter for:bluegill.? 30 Hexazinone: The invertebrate value is 56 mg/liter on grass shrimp and 152 mg/liter for daphnia. In another test (a 21?day life cycle test) the 33 mg/liter with a no-effect level of 20 mg/liter. The rainbow trout shows an LCSD value of 320 mg/liter (bluegill was 370 mg/liter). Imazapyr: Daphnia had an Lc?1value greater than 100 mg/liter for technical imazapyr, 750 mg/liter for isopropylamine salt and 350 mg/liter for Arsenal formulation. Fish are similar in sensitivity, with rainbow trout showing an LCso of 100 mg/liter and bluegill 180 mg/liter for Arsenal. Mancozeb: The EPA Fact Sheet on this pesticide reports what we believe is the LC50 in daphnia as 0.58 mg/liter and 1.54 mg/liter in rainbow trout. Picloram: Propargite: Data not located on invertebrates. Rainbow trout and bluegill show LCso values of 0.12 and 0.1 mg/liter. Simazine: The invertebrate value in this report is based on an Lcso?value of 1.1 mg/liter for daphnia. Other species are less sensitive (amphipod L050, 13 mg/liter; crayfish LCSO, 100 mg/liter; stonefly L650, 1.9 mg/liter). Rainbow 'trout have a similar level-of sensitivity, with values in various test of 2.8, 5.6, 5 mg/liter. Other tests show much higher values. Other species are less sensitive. 31 Sulfmeturonmethyl: The daphnia, rainbow trout and bluegill all have L350 values greater than 1215 mg/liter, but a specific is not identified for these species. Thus, we have used the 12.5 value as a conservative estimator of the LCSO. Triclopyr, amine: The daphnia showed an LC50 value of 1140 mg/liter for triclopyr triethylamine salt in test (with replacement of test solution three times per week). Some salt water species appear to much more sensitive. For instance, shrimp (representative of crustaceans) had a of 895 mg/liter and oysters (representative of mollusks) had an LC?lvalue of 56 mg/liter. We use this later value as the guide for this report. For fish, the triclopyr llgo value is 117 mg/liter for rainbow trout and 148 mg/liter for bluegill exposed to the triethylamine salt. The formulated product Garlon 3A is less toxic with LCSO values of 552 mg/liter for rainbow trout and 841 mg/liter for bluegill. Triclopyr, ester: Specific data for invertebrates are lacking. For fish the LC50 is 0.74 mg/liter for rainbow trout and 0.87 mg/liter for bluegill for exposure to Garlon 4 (the butoxyethyl ester). For invertebrates we assume the ester is 167 times more toxic than the amine, the relationship reported for fish. 32 SECTION 3 HATER QUALITY STANDARDS TO ASSURE PROTECTION OF HUMAN HEALTH, AQUATIC ORGANISHS AND OTHER ANIHALS In forestry operations it is desirable to set water quality standards that trigger a management response at some concentration less than consideredl virtually safe by regulatory bodies. With that approach, the response to exceedance of standards need not be an immediate health protective action, but rather an examination of the practices leading.to the finding to determine if procedures should be changed. The concentrations of pesticides in surface water identified in Tables 1-4 are those which if not exceeded we believe will assure protection of human health, aquatic organisms, and other animals, depending on the pattern of use. Based on current knowledge, we are confident in these values because the assumptions used in their derivation are conservative and margins of safety are incorporated to provide for uncertainty and for extrapolation of laboratory data to field settings. In this section we identify (Tables 5 and 6) the concentration (criteria) of each pesticide?which will protect aquatics (24-hour average exposure), and humans and other animals (10-day exposure). These criteria are for use of pesticides according to the label and best management practice in forest management (Table 5), and forest tree seedling nursery and Christmas tree plantation management (Table 6). We believe these criteria can be the basis for establishing water quality standards. 33 Tab1e 5. Forest management--Recommended reguiatory and management critreria for concentrations of selected pesticides in surface water. Pesticides Concentration which most sensitive Recommended protects both group of maximum aquatics and humans organisms permissibie (except as noted) concentration Asuiam2 1.0 human 1.0 Atrazine 0.007 aquatic 0.007 BT 0.1 aquatic 0.1 Carbaryi 0.00006 aquatic 0.00006 Chiorothaioniiz 0.005 aquatic 0.005 Daiapon 0.01 aquatic 0.01 Dicamba 0.04 aquatic 0.04 Diesel 0.002 aquatic 0.002 2,4-0 amine 0.04 aquatic 0.04 ester 0.006 aquatic 0.006 ester 0.006 aquatic 0.006 Fosamine 2.0 human 2.0 Giyphosate 0.02 aquatic 0.02 Hexazinone 0.56 aquatic 0.56 Imazapyr 1.0 aquatic 1.0 Picioram 0.0005 aquatic 0.0005 Simazine 0.01 aquatic 0.01 Suifmeturonmethyi 0.1 human 0.1 Triciopyr, amine 0.5 human 0.5 Triciopyr, ester; 0.007 aquatic 0.007 1 Protection for aquatics on a 10?day exposure. 2 Data lacking on aquatic is based on 24?hour average exposure 1eve1 and humans invertebrate organisms. 34 Table 6. Forest tree seedling nursery and Christmas tree planthtion management?-Recommended regulatory and management criteria for concentrations of selected pesticides in surface water. Concentration which Pesticides most sensitive Recommended protects both group of maximum aquatics and humans organisms permissible (except as noted) concentration Acephate3 0.001 human 0.001 Amitrole 0.01 human 0.01 Asulam 0.2 human 0.2 Atrazine 0.001 aquatic 0.001 Bifenthrin 0.000002 aquatic 0.000002 Chlorothal on112 0.0001 aquatic 0.0001 Diesel 0.0004 aquatic 0.0004 Dienochlor 0.0001 aquatic 020001 Endosulfan 0.000002 aquatic 0.000002 Hexazinone 0.11 aquatic 0.11 Mancozeb 0.01 human 0.01 Propargitez' 0.02 human 0.02 Simazine 0.002 aquatic 0.002 Data lacking on aquatic invertebrate organisms. Protection for aquatics is based on 24-hour average exposure level and humans on a 10-day exposure except for those noted exposure level. which are based on a lifetime Human toxicity value based on lifetime exposure to reflect lack of water quality monitoring data for forest nurseries and Christmas tree operations. 35 As a general philosophy, we be1ie?e it is essential to ?ag exceed water quality criteria and it is prudent to minimize exposure of aquatic organisms, humans, and other animais. There are legitimate reasons to use pesticides to_ achieve the objective for which any property is managed. Then, we subscribe to not exceeding the surface water quality criteria, and in addition to minimizing surface water contamination whiie achieving those management goais. 36 CONCLUSIONS Based on our analysis we conclude it is possible to identify water quality criteria which when rationally applied for management and regulatory purposes will protect human health and the welfare of aquatic and other organisms. We have identified these criteria as surface water concentrations which if exceeded should trigger evaluation of the practice, and perhaps other actions. We have developed separate criteria for two broad classes of pesticide use, a) forest management and b) the management of forest tree seedling nurseries and Christmas tree plantations. These criteria for nurseries and Christmas tree operations are more conservative because we lack a significant data base for' water contamination from this pattern of pesticide use. Our criteria in this case are provisional, and they should be reevaluated when monitoring data is available. Any analysis of risk (which leads to the water quality criteria) is based on the knowledge available at the time. It is likely more information on toxicity and exposure will be available in the future. It is important that.water quality criteria which guide management and regulatory programs be reviewed periodically to ensure the criteria remains consistent with the goals and the best available data. 37 References British Crop Protection Council. 1983. The District. Manual. 7th edition. C.R. Worthing and Barrie Walker Bureau of Foods. 1981. The FDA Surveillance index for pesticides. U.S. Food and Drug Administration, Washington, D.C. 525 p. EPA. 1989. Drinking water health advisories - Pesticides. U.S. Environmental Protection Agency. Lewis Publishers, Inc. Chelsea, Michigan. 819 p. - EPA. 1987. Pesticide Fact Sheet, Maneozeb. Fact Sheet Number 325. U.S. EPA, Washington, DC. FAD, various dates. Pesticide residues in food:. toxicology. A series of reports on specific pesticides. Food and Agriculture Organization, United Nations. Rome. Mayer, F.L. Jr. and N.R. Ellersieck. 1986. Manual of acute toxicity: Interpretation and data base for 410 chemicals and 66 species of freshwater animals. USDI, Fish and ?Wildlife Service, Resource Publication 160. Washington, D.C. 579 p. Norris, L.A., H.W. Lorz and S.V, Gregory. 1983. Forest Chemicals. USDA Forest Service General Technical Report PNW 149. Pacific Northwest Forest and Range Experiment Station, Portland Oregon. 95 p. Norris, L.A., H.W. Lorz, and S.V. Gregory. 1991. Forest Chemicals. pp. 207?296. In W.R. Meeham Influences of Forest and Rangeland Management on Salmonid Fishes and their Habitats. American Fisheries Society Special Publication 19. American Fisheries Society. Bethesda, Maryland. National Academy of Sciences. 1973. Water Quality Criteria. 1972.. USEPA Ecol. Res. Series EPA-R3-73-033. Washington, D.C. 594 p. Royal Society of Chemistry. 1983. The Agrochemical Handbook. The Royal Society of Chemistry, Nottingham England. A.M., M.L. H099, K.S. Crump, and R.L. Kodell. 1986. Worst case analysis study on forest plantation herbicide use. K.S. Crump and Co., Inc., Ruston,. LA. Prepared for Forest Land Management ngision, Department of Natural Resources, State of Washington. 2 6 p. Sprague, J.B. 1971. Measurement of pollutant toxicity ot fish: Sublethal effects and "safe" concentrations. Water Research 5:245- 266. 38 Forest Service. 1984. Pesticide Background Statements. Vol.1. Herbicides. Agriculture Handbook 633. U. S. Dept. Agric., Washington, D. C. 1071 p. USDA Forest Service. ,1986. Pesticide Background Statements. Vol. II. Fungicides and fumigants. Agriculture Handbook 661. U.S. Dept. Agric., Washington, D.C. USDA Forest Service. ?1987. Pesticide Background Statements. Vol. Nursery pesticides. Agriculture Handbook 670. U.S. Dept. Agric., Washington, D.C. USDA Forest Service. 1989. Pesticide Background Statements. Vol. IV. Insecticides. Agriculture Handbook 685. U.S. Dept. Agric., Washington, D.C. Weeks, J.A. et al. 1988. Risk Assessment for the use of herbicides in the southern region, USDA Forest Service. USDA Forest Service Management Bulletin R8-MB-23. Final Environmental Impact Statement, Volume II. Weeks, J.A., G.H. Drindel, R.S. Jugan, T.E. HcManus and P.J. Sczerzine. 1988b. Diesel oil and keroses background statement. Labat?Anderson Inc. For USDA Forest Service, Washington DC. 29 p. WHO. 1984. Endosulfan. Environmental Health Criteria 4D. World Health Organization. Geneva._ WSSA. 1989. Herbicide Handbook. 6th Ed. Weed Science Society of America. Campaign IL. 39