Atrazine: Potential MOA Revisions Discussion with Technical Registrants

November 3, 2009 2:00 – 4:00 p.m. EDT

Conference Call Requested By: EPA Office of Pesticide Programs

Participants:

Office of Pesticide Programs, EPA – Richard Keigwin , Robert McNally, Eric Olson, Melanie Biscoe, Mary Frankenberry

Atrazine Technical Registrants –

SYNGENTA

Janis McFarland Dan Campbell

AGAN CHEM MFG, LTD

MAKHTESHIM-AGAN OF NORTH AMERICA INC

Kris Venkatesh

DREXEL CHEMICAL COMPANY Roy Olson

OXON ITALIA S.P.A.

Maria Ciccotelli

SIPCAM AGRO USA, INC Joe Burley

Meeting Notes

Introductions

Meeting participants introduced themselves. EPA in dicated that the meeting notes would be placed in the atrazine Special Review docket within 10 days of the call, and that any CBI should be noted during the meeting.

Discussion of Potential MOA Modifications:

1. Monitoring to capture peak, single-day exposure s in Community Water Systems.

Syngenta said that it is trying to think of data th at can be pulled together to address EPA’s concerns in a timely manner. Syngenta indicated th at with the total weight-of-evidence from Syngenta’s database (nearly a quarter-million sampl es) as well as other databases, the likelihood2

of missing peak concentrations is quite low. Synge nta has recently developed a trend report that looks at the variability of all the data within sur face water systems, and proposed that Syngenta

and EPA scientists meet to examine and discuss the data. Syngenta indicated that the primary data sets that can be provided to the Agency for th e purpose of knowing if we are capturing peaks are the Peri-reservoir databases that include daily sampling, the Heidelberg data that include flow-based sampling, and the ecological mon itoring data set that includes daily sampling as well as flow data (within the ecological monitor ing program, there are approximately 11 sites that have daily monitoring). Syngenta indicated th at these three data sets would represent a worst-case scenario, as they include data on system s with “flashier” data than typical drinking water systems. Syngenta would like to do a bootstr ap analysis on these data sets to determine if peaks are actually being captured.

Syngenta also said that AWWA may also have daily dr inking water data.

EPA asked Syngenta to clarify whether it just has t he data sources available or whether it has already evaluated the data from those sources.

Syngenta indicated that it has recently submitted a frequency of monitoring report which includes information on different types of watershe ds and the vulnerability at different sites. (EPA confirmed that it received that report). Syng enta said that AWWA has also done its own analysis, but that their approach is geared toward annual averages.

Syngenta stated that it has, in its database, searc hed for the highest atrazine concentrations and know what the highest concentrations would be in an y of the different types of sites sampled.

EPA asked Syngenta whether its data is for atrazine -only or whether it is for metabolites and/or

TCT.

Syngenta said that metabolites and TCT data are ava ilable for the 2009 ecological monitoring

systems.

EPA wanted to clarify whether these data will be su bmitted for EPA to evaluate in preparation for the April SAP, or whether Syngenta will underta ke analyses themselves. EPA wanted a sense of who would do what, when.

Syngenta indicated that it wants to conduct analyse s in a way that makes sense and then provide those analyses to EPA in a timely and efficient way

.

EPA summarized that Syngenta currently has informat ion that meets the Agency’s needs, and that we all want to make sure that the Agency can l ook at it and meet with Syngenta’s scientists in a timely manner. At that meeting where Syngenta and Agency scientists examine the data, any need for additional monitoring could be address ed at that time.

Syngenta agreed with EPA that there is time to look at all the data and act, if needed, by the 2010 growing season.3

EPA and Syngenta agreed that a face-to-face meeting of scientists in the following two weeks could work. Syngenta added that a year-to-year ana lysis would be interesting to pursue. Syngenta expressed its confidence that it has data that will make everyone feel comfortable.

EPA noted that it should check with OW and USDA con cerning any additional daily atrazine monitoring data that may be available.

2. Providing drinking water monitoring data to the public more quickly.

Registrants discussed how there is a long public re cord of notifying CWSs and the public of the MCL exceedences in terms of not causing fear in peo ple.

Registrants stated that there are short term MCLs t hat aren’t monitored for very often. They also state that there is a public notification handbook used to determine which situations require public notification so that public fear isn’t gener ated, and that the precedent of requiring additional notification as EPA proposed in this mee ting is inconsistent with these other notification guidelines.

Registrants asserted that CWSs work under rules of what is reportable, and when and none of the data fall under those rules, the data are not repor ted to the public.

EPA summarized that on its web page all the monitor ing data is available. The web page also puts the data into context.

Registrants stated that the OPP web page should exp lain what the data mean in terms of EPA’s levels of concern. With regards to the data themse lves, the registrants would prefer that data released reference data by county instead of by spe cific CWS. The registrants assert that they would need to figure out how to keep CWSs in the pr ogram if EPA releases data specified for

each CWS.

The registrants asked why the data need to be put o ut for the public when the level of concern is

not exceeded. EPA discussed the desire to be more transparent with the data.

3. Prohibiting atrazine use in the watershed after one exceedance of the 37.5 ppb 90-day rolling

average.

Registrants stated that prohibiting atrazine use in the watershed after one exceedance of the 37.5 ppb 90-day rolling average in raw water would go ag ainst precedence

Registrants indicated that they would like to have a meeting with EPA scientists to discuss why EPA scientists feel that there is uncertainty aroun d the endpoint that would warrant prohibiting

atrazine use in the watershed after one exceedance of the 37.5 ppb 90-day rolling average in raw

water.

EPA asked if registrants would agree to prohibiting atrazine use in the watershed after one exceedance of the 37.5 ppb 90-day rolling average i n finished water. Registrants stated that this4

would go against precedence. Registrants added tha t the MCL is not mitigated in that fashion – specifically, people still drink their water when t he MCL is exceeded. Registrants indicated that they would like to meet with EPA to discuss uncerta inty with the endpoint.

4. Establishing a performance standard for the 298 ppb one-day drinking water level of concern
established in the Atrazine RED.

Registrants stated that there is no precedence for regulating on the acute endpoint. EPA stated that this endpoint is in the RED and there is a per ception issue surrounding the Agency not regulating on this acute endpoint.

Meeting Notes Prepared by: Melanie Biscoe and Eric Olson