FW: [waterpests] Request for Pesticides Monitoring Data

Sylvester, Susan - DNR 

t

o

:

Jordan Page 02/05/2010 09:44 AM

 Jordan, not sure if we are suppose to send you information directly, but the 

attached list are the Wisconsin monitoring sites. Please let me know if you 

can use this information or if you need something else.

Susan Sylvester

Susan L. Sylvester

Chief, Permits Section

Bureau of Watershed Management

Wisconsin Department of Natural Resources

(*) phone: (608) 266-1099

(*) fax: (608) 267-2800

(*) e-mail: Susan.Sylvester@wi.gov

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-----Original Message-----

From: Schreiber, Kenneth W - DNR 

Sent: Friday, February 05, 2010 8:25 AM

To: Sylvester, Susan - DNR

Cc: Masnado, Robert G - DNR

Subject: RE: [waterpests] Request for Pesticides Monitoring Data

Susan,

My contact at DATCP has been Rick Graham and attached are the streams we plan 

to sample this summer. Also, following is a the web site of a report he put 

together for monitoring we did in 2008: 

http://www.datcp.state.wi.us/arm/agriculture/land-water/environ_quality/monit_

proj.jsp 

Let me know if you have any questions.

P Ken Schreiber

TMDL Monitoring Coordinator

>Water Evaluation Section

>Bureau of Watershed Management

>Wisconsin Department of Natural Resources

(() phone: (715) 839-3798

(() fax: (715) 839-6076

(+) e-mail: kenneth.schreiber@dnr.state.wi.us

-----Original Message-----

From: Faulk.Jack@epamail.epa.gov [mailto:Faulk.Jack@epamail.epa.gov]

Sent: Thursday, February 04, 2010 12:10 PM
To: Waterpests Mailing List

Subject: [waterpests] Request for Pesticides Monitoring Data

All,

I am following up with you after our two-day face to face meeting in Dallas on 

January 20-21 to discuss the NPDES Pesticides General Permit.

One of the items that we discussed at that meeting was to clarify our request 

for additional monitoring data to support our permit approach in addressing 

water quality and monitoring as necessary to effectively manage discharges 

from pesticide applications. Davis Daiker, from the Florida Department of 

Agriculture, and also the Committee Chair for the SFIREG Working Committee on 

Environmental Quality Issues, sent an email dated January 27 to many of his 

state co-regulators requesting that states submit any available water quality 

monitoring data to EPA (Jordan

Page) for our use in building our record for our draft permit. I want to 

thank Davis for sending out the request and would like to clarify the type of 

information that would be most useful for us and to notify others of this 

request.

For those of you that did not receive Davis' email, here are excerpts of what 

was requested:

"The EPA is seeking data/information that demonstrates that the 

technology-based effluent limits (TBEL) actively employed today (i.e., FIFRA 

labels) are sufficient to protect surface water quality and meet many state 

requirements of "no toxics in toxic amounts". Further, the EPA hopes to be 

able to demonstrate, if needed, that the TBELs proposed in the draft permit 

(FIFRA-approved labels combined with IPM and various BMP requirements) will be 

increasingly sufficient to protect waters of the US."

"EPA is specifically interested in receiving any surface water monitoring data 

on pesticide active ingredients. Although, data from more controlled studies, 

where application rates, dates, etc. are known, are preferred, the EPA would 

be interested in any ambient monitoring data demonstrating protection of water 

resources. They did not specify whether they only want data from pesticide use 

scenarios covered under the permit (aquatic weed control), so I would see what 

data you have available and provide it to the Agency."

While this is an accurate representation of the type of data that would be 

helpful to us, we would also ask for your help in providing a summary of any 

submitted data, particularly with respect to:

 - The purpose of the sampling

 - The timeframe of the sampling

 - How that sampling relates to the timing of pesticide

 applications (i.e., to address the fact that the permit

 regulates pesticide residues not pesticides when they are

 performing as intended)

 - Any assessment of the frequency of detections and the

 detections above water quality standards or other water quality

 benchmarks, if known

 - Identification of sources of pesticides in water, where

 available, to help delineate those activities covered under our

 permit and those that are not (e.g., stormwater runoff and

 irrigation return flow)

 - A summary of the results

 - Any conclusions and recommendations drawn by the state or

 others on the results.
As such, monitoring data that focuses on the specific aspects of the 

activities we are covering (e.g., aquatic nuisance weeds) and the time at 

which our permit applies (e.g., dissipation of pesticide concentrations in 

waters over time) are much more valuable than merely monitoring data for 

pesticides present in waters of the U.S. That being said, if you have ambient 

water quality monitoring for pesticides that you think may help us better 

assess the discharges to be covered under our permit, we would very much like 

to receive that information. If the information is available on the Internet, 

feel free to just send us the URL of the site.

An example summary to include with the sampling data may look something like 

this:

 In 2006, NAWQA released a 10-year (1992-2001) study of 51 major river 

basins and aquifer systems that account for more than 70 percent of total U.S. 

water use and more than 50 percent of the U.S. drinking water supply. Most 

NAWQA samples were analyzed for 75 pesticides and eight degradation products, 

including 20 of the 25 most commonly used herbicides and 16 of the 25 most 

commonly used insecticides. Water samples were collected at 186 stream sites 

for analysis of pesticides and degradates dissolved in water. The samples 

were collected from streams throughout the year, including high-flow and 

low-flow conditions. Sampling was most intensive during the time of highest 

pesticide use and runoff - generally weekly or twice monthly for a 4- to 

9-month period.

 For environmental effects, the USGS compared the concentrations found in 

the NAWQA sampling with two general types of aquatic life benchmarks (1) 

ambient water quality criteria (AWQC) for the pesticide and (2) benchmarks 

derived from the lowest acute and chronic ecological effects endpoint for the 

pesticide (OPP benchmarks). Acute AWQC and all acute OPP benchmarks were 

compared with each measured concentration for the most complete year of data 

for each NAWQA stream. Chronic AWQC were compared with 4-d moving average 

concentrations, chronic OPP benchmarks for invertebrates were compared to 21-d 

moving average concentrations, and chronic fish OPP benchmarks were compared 

to 60-d average moving concentrations. AWQC were available for 7 of the 83 

pesticides and degradates analyzed by NAWQA. One or more OPP benchmarks were 

available for 60 of the 83 NAWQA analytes, including 5 of the 7 that had AWQC. 

A total of 62 of the pesticide compounds analyzed in water by NAWQA had one or 

more aquatic-life benchmarks.

Results

 For aquatic life, 57 percent of agricultural streams and 83 percent of 

urban streams had one or more samples that exceeded one or more aquatic-life 

benchmark during the year when they were most intensively sampled. A total of 

20 pesticides or degradate exceeded an EPA benchmark in agricultural streams 

and/or urban streams (see Table 1 for a complete list of pesticides/degradates 

that had exceedances).

In agricultural streams, most concentrations greater than a benchmark involved 

chlorpyrifos, azinphos-methyl, atrazine, p,p'-DDE and alachlor.

In urban streams most concentrations greater than a benchmark involved 

diazinon, chlorpyrifos, and malathion. The USGS report states that most 

concentrations that exceeded benchmarks, particularly by the greatest amounts, 

occurred during seasonal periods of high concentrations. The number, type, 

and degree of benchmark exceedances vary widely among sites, however, and 

meaningful generalization are difficult.

Finally, if you have, please send any data and summaries to Jordan Page 

(page.jordan@epa.gov). We would like to have this information within the next 
three weeks (by February 25th) but please let use know if you need more time

to compile the data. If you have questions or comments, feel free to call me 

(202-564-0768) or Jordan (202-564-2952).

Thank you very much.

Jack

Water Permits Division

US Environmental Protection Agency

EPA East (4203M)

1200 Pennsylvania Avenue, NW

Washington, DC 20460

Telephone (202) 564-0768

Fax (202) 564-6431

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