# ALASKA PESTICIDE MANAGEMENT PLAN TO
PROTECT AND RESTORE WATER QUALITY

31 October 2007



### “We think of our land and water and human resources not as static and sterile possessions but as life-giving assets to be directed by wise provisions for future days.” Franklin D. Roosevelt

## ALASKA PESTICIDE MANAGEMENT PLAN TO
PROTECT AND RESTORE WATER QUALITY

Introduction – the Plan’s Context and Purpose

The Alaska Pesticide Management Plan to Protect and Restore Water Quality (the Plan) is part of the Al aska Department of Environmental Conservation (ADEC) Pesticide Cooperative Agreement with the U.S. Environmental Protection Agen cy (EPA). The Pesticide Cooperative Agreement work plan describes the yearly priorities and work activities for ADEC with regards to pesticide enfor cement and compliance, applicator certification and training, worker protection education, endangered species protection and water quality protection. This Alaska Pesticide Management Plan to Protect and Rest ore Water Quality describes ADEC’s approach to preventing and responding to pesticide contamination of water, while the yearly Cooperativ e Agreement work plan describes the water quality work priorities to implement this Plan during a specific year. That yearly work plan is available by contacting the ADEC Pesticide Program at 800-478-2577.

The primary purpose of this Plan is to prevent and respond to pesticide contamination of ground and surface wate r that results from the normal, legal use of EPA and ADEC registered pes ticides. Implementation of this Plan provides additional protections for Alaska waters beyond that provided by EPA’s pesticide registrati on process. When registering a pesticide under the Federal Insectic ide, Fungicide, and Rodenticide Act (FIFRA), EPA considers the potential impact of the pesticide to water quality. EPA places restrictions or advisory statements on the pesticide label to mitigate that impact. However, those national level controls may not always produce the desired effects for the people of Alaska. Implementation of this Plan will prov ide additional protection to prevent contamination from occurring or, if it does occur, to reduce that

contamination.

The Plan describes the lead role that the ADEC Pesticide Program – in cooperation with other State agencies and ADEC programs – will take to protect ground and surface water from pes ticide contamination. The Plan places a strong emphasis on prevention of contamination to protect the1 quality of this critical resource for all Alaskans. The Pesticide Program is already doing many of the activities described in this Plan.



### Background – the Water Resource and the Use of

Pesticides

Alaska is home to over 600,000 people from a wide variety of cultural and socioeconomic backgrounds. Clean, abundant water andhealthy aquatic habitat are critical to Alaska's social and economic wellbeing. Alaska's waters and resources are the backbone of Alaska's economy, from fisheries to tourism. These same resources are the heart of the traditional subsistence lifestyle and are vitally important for nutrition, cultural integrity, sp iritual well-being, and the quality of life Alaskans

treasure.

The state is huge in size, encompassing over 589,000 square miles or 378,000,000 acres, an area roughly equivalent to one-fifth of the contiguous 48 states. Alaska contains over 3 million lakes, 365,000 miles of rivers and streams, over 174 milli on acres of wetlands, 44,000 miles of coastline and 11 Ecosystems. Sixty per cent of the land is federal, 28% State of Alaska, 11.7 % native land and 0.3 % private land. A remarkable

40% of the nation’s water resources are in Alaska. Alaskans use approximately 90 million gallons of wa ter each and every day for domestic use. About 60 million gallons comes from surface waters and 30 million from groundwater.

There are approximately 1,598 f ederally regulated public water systems (PWS) in the State of Ala ska. PWS are those systems that provide drinking water to a group of individuals and do not include single family homes or duplexes with their own private wells. Many “new” small community-type systems are starting up in the areas of rapid growth, such as Alaska’s Matanuska-Susitna Valley. Alaska is a primacy state for drinking water and has direct oversight of public water systems within the

state. Both the State of Alaska and the federal government regulate public water systems regardless of the source of drinking water, whether groundwater or surface waters.

Alaska’s groundwater resources may be among the greatest in the nation. However, very few of Alaska’s aquifers have been studied (or even located) and little water quality data is available. Groundwater is a source of drinking water for about 50% of Alaska’s population and 90%of the state’s rural residents. Eighty-seven per cent of Alaska’s public drinking water systems are supplied by groundw ater. A small number of public2 water systems (e.g. Anchorage and several southeastern communities) serve a large number of people from primarily surface water sources. Ninety percent of private drinking wa ter supplies are groundwater. Of the 275 million gallons of water used each day for domestic, commercial, industrial and agricultural purposes in Alaska, roughly 23% is derived from aquifers. Groundwater is available in mo st areas of Alaska, except in the northern part of the state where perma frost is very deep. South-central and interior Alaska has the greatest dependence on groundwater. Residents living in arctic, western, and southeastern Alaska make more frequent use of streams, rivers, lakes, and rainwater catchments. The largest groundwater withdrawals o ccur in the Anchorage and Fairbanks areas and, to a lesser extent, the Matanuska-Susitna and Kenai Peninsula Boroughs in the south-centra l portion of the state.

General Groundwater Withdrawals in Alaska Private Water Supplies 9.8% Agriculture 0.3% Industrial, Commercial & Power Production 22.5%

Commercial 13.7% Public Water Supplies 53.7%

Most of Alaska’s aquifers consist of unconsolidated materials derived from glaciers, rivers, and str eams. Producing aquifers are typically unconfined (i.e., not protected by a laye r of clay or silt), and the depth to groundwater can range from a few feet to more than 400 feet. Although water quality data is sparse, most of the state’s groundwater is suitable for domestic, agriculture, aquaculture, commercial, and industrial uses with moderate or minimal treatment. A range of activities either have affected or have the potential to affect groundw ater quality (e.g., nonpoint pollution in urban areas, natural resource extrac tion activities in remote locations, and a wide range of potential point sour ces of pollution). The cost of cleaning up (remediating) contami nated groundwater can be staggering. For instance, using 2003 information, the EPA estimated that the average cost for remediating hazardous waste sites ranges from $1 million to $3 million. Estimates of the present and potential costs of remediation of contaminated Alaskan groundwat er have not been compiled.

Alaska has 174,683,900 acres of wetlands comprising approximately 43% of the surface area of the state. By comparison, the

entire remainder of the U.S. c ontains 103,000,000 acres of wetlands, comprising approximately 5% of the su rface area. Significant percentages

of wetlands in urbanized areas in cluding Anchorage, Juneau, Fairbanks, the Matanuska Susitna Valley and t he North Slope, have been lost or impacted. Because there is a st rong correlation between water bodies that are listed as impaired by DE C and areas where wetlands have been impacted or developed, wetlands need restoration and mitigation of3 impacts associated with development and/or protection. Specifically, wetland functions need to be maintained to enhance or protect water quality for drinking water, spawning, and other uses.

Historically, pesticide use in Alaska has been relatively low compared to other states primarily because of the small population and the limited number of pests. The amount of pesticide use has continually increased along with the population growth and the introduction of new pest species. Pesticide use has the potential to occur in a large array of Alaskan industries including oil and gas expl oration, seafood processing, food plants, aquaculture, forest managemen t, agriculture, and landscaping. There is additional use of pesticides by private and government, including military users. Currently there are no pesticide manufacturers or

formulators in the state. Because of the vast and remote nature of the state, pesticide regulation poses some unique challenges. There are over 6,000 pesticide products registered annua lly in the state, and some of these pesticides have the potential to contaminate ground and/or surface water. The majority of the pesticide use is in urban, agricultural and industrial areas, such as the North Slope. 2, 4 D and glyphosate are the most commonly used herbicides for landscaping and carbaryl for spruce bark beetle control in urban settings. Various fungicides and herbicides are used in agricultural to manage Late Blight in potatoes and invasive weeds in hay production. The agricultura l areas of the state are located in the Matanuska Susitna Borough, Fa irbanks, Delta Junction, and Kenai

Peninsula. Invasive weeds are al so becoming a significant problem on government-owned land. The greatest volume of use continues to be

biocides and disinfectants. There ar e also a few communities that have ADEC issued permits to control mosquitoes and biting flies, several of these products are applied directly to water.



### State Water Protection Policy

“It is the policy of the state to conserve, improve, and protect its natural resources and environment and control water, land, and air pollution, in order to enhance the health, safety, and welfare of the people of the state and their overa ll economic and social well-being.” [Alaska Statutes, Section 46.03.010]



### Contamination Prevention

The Pesticide Program places a high pr iority on preventing contamination. Even if pesticides are not detected in water, the Program will continue their State-wide efforts to prevent c ontamination. These activities range from providing general information on protecting water quality for the4 public to State-wide bans on the use of certain pesticides. Rather than responding to contamination of a pestici de – or a mixture of pesticides for which the toxic effects may not be well documented – detected through a limited monitoring network, the Pestic ide Program believes the people of Alaska are best served through a str ong State-wide prevention program.

ADEC will continue to select the appr opriate prevention actions based on sound data. ADEC will continue to base these decisions largely on toxicological and environmental data av ailable from EPA, such as that provided in Re-registration Eligibility Decisions. See: http://www.epa.gov/pesticides/r eregistration/status.htm

.

Many of the prevention activities described here will also be used in a more locally focused way if contami nation is detected. The Pesticide Program’s response to actual contamination is described later in this Plan.

State Pesticide Registration Although EPA registers pesticides under federal regulations, ADEC also registers pesticides at the State leve l to ensure that they do not pose an “unreasonable adverse effect on human health, safety, or welfare, animals, or the environment.” ADEC will continue to use its pesticide registration authority under Title 18 of the Alaska Administrative Code, Sections 90.200 – 90.235 [18AAC 90.200-90.235] to evaluate and possibly place limitations on pesticides to protect the waters of the State from pesticide contamination. The D epartment may refuse to register a pesticide which would make its sale and use illegal in Alaska. During the registration process, ADEC can also classify a pesticide as Restricted Use, prohibit its use in designated areas , require a permit for its use, or limit its application rate or frequency [18 AAC 90.215]. For example, the Pesticide Program currently has denied State registration for all products containing picloram and outdoor use of any products containing atrazine due to water quality concerns. The Pesticide Program will continue to conduct marketplace and pesticide use inspections to enforce State registration restrictions. The curr ent Cooperative Agreement Work plan

contains information on the number of t hese inspections that are projected to be accomplished each fiscal year.

Education of the Public The Pesticide Program will continue to provide information to the public on ways to protect ground and surface wate r from pesticide contamination. The emphasis of public education is on the use of pesticides by homeowners. This is typically done th rough displays at fairs, workshops and conferences plus presentations at schools and meetings. The Program also has relevant information on its website. For example, see “Consumer Tips” at: http://www.dec.state.ak.us/eh/pest/index.htm . The ADEC Pesticide Program also oper ates a toll-free telephone to answer5 any and all inquiries about safe and legal pesticide use. All these phone calls are logged and reviewed.

Education of Pesticide Applicators and State Restricted Use Classification Voluntary and mandatory education of pes ticide users is a key part of the prevention program. Voluntary pesti cide applicator education will continue through the Pesticide Program’s newslette r, which is mailed to all certified pesticide applicators in the State and typically provides information on protecting water quality. The Program will also continue to make presentations on water quality prot ection at professional meetings attended by pesticide applicators.

Mandatory education of certain pesti cide applicators will continue to be a primary focus of the prevention progr am. According to 18 AAC 90.300 - 90.315, all users of “Restricted Use Pesticides” plus commercial applicators of general use pesticides must be adequately trained, pass an examination, and be certified in t he proper pesticide category of use before they can apply these pesticides. Pesticide products are classified as Restricted Use if they present a serious hazard to human health or the environment. Due to the required trai ning and testing, users of Restricted Use Pesticides are expected to be more knowledgeable and in better compliance with the additional use rest rictions on the product label that are aimed at mitigating the pesticide’s hazards.

Although some pesticides are classified as Restricted Use by EPA due to water quality concerns, ADEC may classify other pesticides as State Restricted Use in order to protect t he waters of the state from pesticide contamination [18 AAC 90.215(b)(3 )]. Although they are not EPA Restricted Use, ADEC currently cl assifies products containing the following active ingredients as Stat e Restricted Use due to water quality concerns: dacthal (DCPA), sulfom eturon methyl, and sulfentrazone.

In Alaska, pesticide applicator training includes information on preventing water quality impacts and the tests contain questions related to water quality protection. Certified applic ators are required to keep their knowledge up-to-date. A person’s ce rtification must be renewed every three years by attending a training session, completing a correspondence course, or obtaining a minimum of twelve continuing education hours approved by ADEC; plus, they must pass a written or oral renewal

examination.

The Pesticide Program will continue to enforce the Restricted Use classification and applicator certific ation requirements [18 AAC 90.020 – 90.030]. They conduct routine inspections of certified dealers to ensure that these dealers are only selling Rest ricted Use Pesticides to certified applicators. The Program also conducts inspections of marketplaces6 where pesticides are sold to ensure t hat Restricted Use Pesticides are not being sold by unlicensed dealers to the general public. The Program also conducts inspections of pesticide users to ensure they are properly

certified. Please see the current Cooperative Agreement work plan for

information on the number of each of t hese inspections projected to be accomplished and for more information on the “Certification and Training”

program.

Enforcement of Pesticide Label Restrictions As mentioned above, the labels on pesti cide products contain restrictions on how the product can be used. U nder FIFRA, ADEC has primary responsibility for enforcing these use restrictions. According to 18 AAC 90.020, it is illegal for any person to use a pesticide inconsistent with its labeling instructions. ADEC will continue to enforce the label directions designed to protect water quality as a basic component of its prevention approach.

The Pesticide Program will continue to conduct inspections and investigations to ensure compliance with water quality protection requirements on pesticide labeling. Those inspections include routine inspections of pesticide labeling in the marketplace to ensure that the labeling includes the restrictions r equired by EPA and routine inspections of pesticide users to ensure they are following those label restrictions. The Program also will continue to conduct investigations of all complaints of pesticide misuse. Again, the curr ent Cooperative Agreement work plan

contains information on the numbers of these inspections projected to be accomplished.

Pesticide Application Permits Under 18 AAC 90.500 – 90.540, ADEC-issued permits are required for pesticide use on state-owned land or on land owned separately by two or more people, for pesticides applied by aircraft and for pesticides applied to the waters of the State. Compli ance with the use requirements on the pesticide label is one of the basic requirements of a permit. The Department will continue to include additional conditions, for example “buffers” around surface water bodies, in a permit to protect human health and the environment [18 AAC 90.525], incl uding water quality. However, if ADEC finds that the pesticide woul d still present an unreasonable adverse

effect when used even with additional conditions, the Department will, at its discretion, deny that permit. T he Pesticide Program will continue to conduct pesticide use inspections to enforce permit conditions. All ADEC Pesticide Permits require the permittee to submit a “Summary of Treatment Results” 90 days after the permit expires according to 18 AAC 90.535 which includes monitoring results and any observed effect on human health, safety or welfare, animals, or the environment.7 Coordination with other programs The agencies and programs listed below actively participate in activities that protect water quality in Alaska. With the exception of the Alaska Cooperative Extension, wit h which the Program rout inely coordinates, the Program’s interaction with these ot her programs typically occurs only when pesticide issues arise.

University of Alaska Cooperative Extension Includes Integrated Pest Managem ent, Sustainable Agriculture Research and Education, Pestici de Safety Education Program, and Water Quality Program.

See: http://www.uaf.edu/ces/ programs/lrpro.html

ADEC Drinking Water Program and Source Water Program

See: http://www.dec.state.ak.us/eh/dw/index.htm and http://www.dec.state.ak.us/eh/dw/DWP/source_water.html

ADEC Nonpoint Source Water Pollution Control Program Includes storm water, wetlands, restoration and protection, and forestry sections

See: http://www.dec.state.ak.us /water/wnpspc/index.htm

Alaska Department of Natural Resour ces – Divisions of Agriculture and Forestry

See: http://www.dnr.state.ak.us/ag/ and http://www.dnr.state.ak.us/forestry/

Alaska State Soil and Water Conservation Districts http://www.alaskaswcds.org/alaska/

EPA Underground Injection Control Program See: http://yosemite.epa.gov/R10/water.nsf/476d8e2e8829cf19882565d 400706530/51bbc02148429af1882568730082f6fa!OpenDocument

EPA Hazardous Waste Program See: http://yosemite.epa.gov/R10/OWCM.NSF/webpage/homepage?ope

ndocument



### Water Quality Monitoring

The Pesticide Program will use wate r quality monitoring to identify

contamination to define the extent and likely source of contamination so that appropriate pesticide management actions can be chosen and also to8 demonstrate that those management acti ons to reduce contamination are

effective. While EPA’s 2008-2010 Pesticide Cooperative Agreement Guidance encourages pesticide programs to conduct water quality monitoring, EPA does not require it. The Guidance allows state pesticide programs to rely on available monitori ng. Nevertheless, if additional water quality monitoring is necessary to respond to contamination in Alaska, the Pesticide Program will identify and pursue available options.

Currently, there have been very few conf irmed detections of pesticides in water in Alaska. This may be because pesticide use is relatively low but it also may be because there is little routine water quality monitoring for pesticides, especially for the more recently registered pesticides in the

State.

Pesticide Program Approach to Monitoring Monitoring conducted by public drinking water systems is the major monitoring conducted throughout the Stat e for pesticides. The results of that monitoring are posted on the st ate website “Drinking Water Watch” at: http://map.dec.state.ak.us/eh/dww/index.jsp

. The Pesticide Program will review these monitoring results at least quarterly each year and coordinate with the ADEC Drinking Wa ter Program before taking steps to address any detection. Arrangements are being made with the Drinking Water Program for the Pesticide Progr am to be notified if there are any pesticide detections at or above the MCL.

Several government agencies may also monitor for private drinking water wells and the Pesticide Program will also evaluate that information when it

becomes available. How well owner s are notified about the monitoring results may depend on the agency procedures conducting the monitoring. Since the ADEC Drinking Water Progr am does not have the authority to regulate private wells, and this is an issue that still needs some resolution. The pesticide program in conjunc tion with the Alaska Cooperative Extension and the toxicologist at the Alaska Department of Health and Social Services Division of Public Health, Section of Epidemiology will notify and educate the private well owners about the toxicological significance of the detection. Ne w options for managing private well

contamination will be identified and pursued as the plan evolves.

The Pesticide Program will also evaluate any special pesticide water quality studies that become available. Each year, the Pesticide Program will continue its efforts to identify thes e types of studies through literature

searches and contacts at the U.S. Geological Survey (USGS), the University of Alaska, the Municipa lity of Anchorage, and other programs

within ADEC.

As it has in the past, the Pestici de Program may conduct limited sampling9 of ground or surface water and analyze those samples via immunoassay. The Program does not consider immunoassay results to be appropriate for regulatory purposes but may use this cost-saving technique as an initial screening for other monitoring purposes. Any positive immunoassay results will be confirmed via standard pesticide analysis methods.

Pesticide application permits will also be a source of water quality data. When appropriate, the Department will continue to require the permit holder to submit an approved monitoring plan and conduct water quality monitoring as a condition of the permit. Monitoring is usually required to ensure that the stipulations incl uded in the pesticide permit issued by ADEC are effective in preventing cont amination. The Pesticide Program will continue to review this monitoring data.

The Pesticide Program will investigate all pesticide detections in water as soon as the Program is aware of t he detection. The first step will be to verify the detection. The site where the detection occurred will be investigated by ADEC Pesticide Pr ogram staff or other cross-utilized ADEC staff to determine the likely sour ce and extent of the contamination.

Dealers and users of Restricted Use Pe sticides are required to maintain records of all sales and applications and make them available to ADEC on request [18 AAC 90.400 – 90.415]. The Pesticide Program may survey dealers and users in an area to help determine the source of contamination. However, additional monitoring will likely be needed. The Program will explore options for conducti ng that monitoring. Options may include requiring additional monitori ng from a permit holder, shifting funding to monitoring from within the Pesticide Program cooperative agreement or from the State pesticide registration program, requesting the manufacturer conduct some monitoring as a condition of state registration, or working with other agencies or ADEC programs to conduct the monitoring.

Following implementation of actions to control the use of a pesticide (see Response to Contamination); the Pest icide Program will use water quality monitoring or other methods to determi ne if those actions are effective. As described in the previous paragraph, the Pesticide Program will explore options for conducting water quality monitoring. Because water quality monitoring can be expensive, the Pr ogram may instead choose to conductinspections to assess compliance with proven controls, such as Statewide or local bans on the sale and use of a pesticide.

Water Quality Monitoring and Assessment Strategy The ADEC long term Water Quality Monitoring and Assessment Strategy (June 2005) addresses pesticides under the terms “toxic and other deleterious organic and inorganic s ubstances” and “persistent organic pollutants.” See the link to the Strategy on:10 http://www.dec.state.ak.us /water/wqsar/index.htm . In the Strategy, a key mechanism for prioritizing surface water monitoring is Alaska’s Clean Water Actions (ACWA) initiative. See: http://www.dec.state.ak.us/w ater/acwa/acwa_index.htm . Under ACWA,

the ADEC Division of Water wor ks with the Department of Natural Resources and Department of Fish and Game to focus State and federal resources on the waters of greates t need. The Pesticide Program will work with the Division of Water to identify surface water monitoring needs for pesticides.

Quality Assurance The Pesticide Program will collect water samples using the "Quality Assurance Project Plan for State of Alaska/EPA Pesticide Cooperative Agreement" (QAPP) and Quality M anagement Plan (QMP), which have been approved by EPA. The Pestici de Program will consult with the ADEC Water Quality Assessment and Monitoring Program regarding the design of any monitoring studies.

Data obtained from other source s is expected to be collected and analyzed using their quality assurance procedures. In those cases, the Pesticide Program will examine the quality control that was used in collecting the data. The data will onl y be used when it is of sufficient quality for the intended purpose. Fo r example, data of questionable quality would not be used to create regulations but would be used to initiate follow-up sampling and to in crease outreach activities until the follow-up results are available.



### Response to Contamination

As the lead agency for regulating pesticide use, ADEC has the responsibility for selecting pestici de management actions that prevent unreasonable adverse effects on human health, wildlife or the environment, taking into account t he economic, social, and environmental costs and benefits of a pesticide’s us e. [18 AAC 90.225 and 90.990(54)] A variety of voluntary and regulator y measures are available to the Department that may allow continued use of a beneficial pesticide while minimizing its risk.

Reference Points The Pesticide Program will utilize a to xicological reference point for judging the severity of risk to hum an health and the environment posed by

the contamination. The severity of contamination relative to the pesticide’s reference point will be a major factor in ADEC’s selection of pesticide management measures.11 For those pesticides for which a State or federal standard exists, the reference point will be the established State Maximum Contaminant Level (MCL), EPA Health Advisory Level (HAL), or State Water Quality Criterion

as described in the Alaska Water Quality Criteria Manual

, ( http://www.dec.state.ak.us/water /wqsar/wqs/pdfs/70wqsmanual.pdf .) The State Water Quality Criteria apply to groundwater and surface water. If an MCL, HAL, or Water Quality val ue exist for a pesticide, the Pesticide Program will choose the most restrictive value.

For pesticides that do not have a State standard of any kind or an EPA HAL, the Pesticide Program will cons ider using information from other sources, such as human health benchmarks calculated by USGS or EPA aquatic life benchmarks. See: http://www.epa.gov/oppefed1/ecorisk _ders/aquatic_life_benchmark.htm

. These reference points from other s ources might not be appropriate to use as a basis for regulatory action but could serve as a means to judge the severity of contamination until a Stat e criterion is set. Because many currently used pesticides do not have numerical State standards of any kind, the Pesticide Program will work closely with the ADEC Division of Water and Drinking Water Program to ensure that an appropriate reference point is used.

Surface Water – Coordination with ADEC Division of Water

The ADEC Division of Water identifies “impaired waters” that do not meet State water quality standards. An impor tant mechanism for focusing State and federal resources to restore waters of greatest need is the Alaska Clean Water Actions (ACWA) initiative. See: http://www.state.ak.us/dec/water/acwa/acwa_index.htm

.

Currently, no impaired water bodies due to pesticides are listed in the Final 2006 Integrated Water Quality Monitoring and Assessment Report. However, this may change as additional water quality monitoring

information becomes available.

See: http://www.dec.state.ak.us/water/wqs ar/waterbody/2006_f inal_integrated_ report.htm The Pesticide Program will review subsequent integrated reports to identify any impairment due to pesticides. Should a pesticide be the reason for impairment, the Pesticide Pr ogram will offer its expertise plus the pesticide management options discussed in this Plan to assist the Division of Water in developing and implementing a TMDL. If the Pesticide Program identifies any surf ace water monitoring data that might lead to an impairment designation or might lead to removal of a future designation, the Program will share that data with t he Division of Water.12 The Pesticide Program will work with the ADEC Division of Water to respond to pesticide detections in surface waters that are not listed as impaired. Under ADEC’s charge to protect waters of the State from pesticide contamination [18 AAC 90. 215], the Program will take action (described below) to prevent pestici des from reaching a State water quality criterion, with an ultimate goal of returning the water to pristine (no pesticide detection).

Groundwater – Coordination wit h State and Federal Programs ADEC does not currently have a separate groundwater protection program. Responsibilities for groundw ater protection are spread among

several ADEC divisions and EPA. Prot ection of Alaska’s groundwater is largely accomplished through the regulat ion of contaminated sites, storage tanks, spill response, and specific wa ste disposal activities under state and federal programs at this time. ADEC manages several programs that contribute to the protection of groundwater, including ADEC’s Contaminated Sites, Storage Tank, Prevention & Emergency Response, Industry Preparedness & Pipeline, Solid Waste, Pesticides, Drinking Water, Wastewater, Watershed Devel opment, Water Quality Protection, and Community Assistance & Information programs. US EPA’s Underground Injection Control Program and a number of other important EPA programs, can also have a signi ficant impact on groundwater quality

in Alaska.

The Pesticide Program will coordinate it s activities in response to any groundwater contaminati on with the ADEC Drinking Water Program, other appropriate ADEC divisions, and EPA.

Development of Response Strategy If a pesticide is detected in ground or surface water, the Pesticide Program’s first steps will be to confirm the detection and determine the likely source of the contaminat ion and geographical extent of the contamination by conducting a site-spec ific investigation. The Program will work with the State Department of Health toxicologist and the Alaska Cooperative Extension to ensure that the well owner and/or well users are notified and provide appropriate information on the toxicological significance of the detection. Bec ause the Drinking Water Program only works with public drinking water system s, the Pesticide Program will take the lead for working with private well owners if their wells become contaminated with pesticides. If the Pest icide Program determines that the contamination resulted from illegal use, spills, or illegal disposal of the pesticide, it will pursue enforcement action under 18 AAC 90.020 or refer

the case to EPA for enforcement under federal hazardous waste law. If the contamination is from normal, l egal use of a pesticide, the Pesticide Program will take a lead role in developing a response strategy in consultation with other water quality protection programs such as those13 listed in the Contamination Prevent ion section. In developing the response strategy, the Pesticide Progr am will solicit the involvement of representatives of affected pestici de users, environmental groups, and water users. The response strategy will coordinate actions among water quality protection programs, descri be the specific management actions that ADEC and other agencies/pr ograms will take, describe the geographic scope of those actions, and describe Pesticide Program responsibilities for informing pesticide users of the management actions.

Pesticide Management Response Actions

ADEC will choose pesticide management actions that, based on available information and ADEC’s judgment, will return the water to pristine conditions (no pesticide detection). In selecting a management action, ADEC will consider factors such as the availability of information demonstrating the effectiveness of m anagement options for the pesticide, the economic value of the pesticide’ s use, the likelihood of adoption of voluntary measures, and the Pestic ide Program’s ability to enforce mandatory measures. ADEC will also consider the likelihood of the pesticide contaminating areas of t he State where it has not yet been detected and may implement management actions in those areas.

The management actions described in the Contamination Prevention section of this Plan will typically be those considered in response to pesticide detections in water. These actions include voluntary measures such as general education of pestici de applicators and implementation of best management practices (BMPs) or integrated pest management practices. Other management options involve ADEC regulatory action, such as requiring pesticide applicator education by classifying a pesticide as State Restricted Use, adding additi onal requirements to a pesticide’s use under a permit, limiting its applicati on rate or frequency, or prohibiting a pesticide’s use in designated areas or the whole State.

As described in the Monitoring sect ion, the Pesticide Program will use water quality monitoring or other met hods to determine if the implemented actions have been effective. If the actions have not been effective, more stringent actions will be needed. The Pe sticide Program will then modify the original response strategy, in c onsultation with representatives of the group that helped develop it.

Contamination Action Levels To meet its goal of protecting the waters of the State from pesticide contamination, ADEC will select pes ticide management measures that are increasingly stringent in response to higher contamination concentrations. The table below does not replace AD EC’s consideration of its legal mandates but provides insight into the stringency of possible management14 actions at various levels of contami nation compared to the reference point.

Contamination Action Levels and Prevention / Response Options

* These options may be modified if contamination is detected in multiple locations

Concentration Relative

to Reference Point Potential Prevention / Response Options

Action Level 1 –

No Detection Conduct Statewide water quality education Include stipulations/restrictions in permits Classify as State Restricted Use Pesticide Deny or place additional conditions on State registration

Action Level 2 –

Detection to 50%

of Reference Point Level 1 actions plus: Implement voluntary actions (e.g., BMPs) in local area per response strategy Implement similar actions in other areas of similar vulnerability

Action Level 3 – 50% up to 100%

of Reference Point Levels 1 & 2 actions plus: Implement mandatory (ins tead of voluntary)

use restrictions in local area

Action Level 4 –

100% or more

of Reference Point Revoke/deny permits in local area

Prohibit use in local area Prohibit sale, distribution, and use in State15 

### Performance Measures and Reporting

Under the Pesticide Cooperative Ag reement, the Pesticide Program will use the performance measures de scribed in the 2008 – 2010 Pesticide Cooperative Agreement to evaluate t he implementation of this Plan.

These EPA measures do not influence the mechanisms that ADEC uses to protect waters of the State or respond to contamination.

The Pesticide Program will use EPA’s th ree-tier approach. The steps are: 1) evaluate “pesticides of interest,” 2) manage “pesticides of concern,” and 3) demonstrate progress of the management actions.

A “pesticide of interest” is one that is listed in the EPA Guidance (see Appendix) plus any pesticides that the ADEC has deemed “of interest” only in Alaska. The Pesticide Program will evaluate these pesticides to determine if they are likely to be detected in ground or surface water in Alaska, consistent with the pesticide regi stration criterion of “protection of waters of the state from pesticide contamination” [18 AAC 90.215]. The evaluation will be based on the Program’s review of information on use of the pesticide in Alaska, available water quality monitoring data, and environmental fate data. The Progr am may decide that some of the pesticides on the EPA list are not likely to be detected in Alaska. The EPA performance metric is:

Evaluated pesticides of interest X 100% Number of pesticides of interest

The Program will consider a “pesticide of concern” to be one that is likely

to be detected in ground or surface water in Alaska and therefore needs to be managed under this Plan. The EPA performance measure is:

Number of pesticides of concern managed X 100% Number of pesticides of concern identified

EPA’s third measure is aimed at quant ifying the number of pesticides for which some form of management has demonstrated progress toward keeping (or returning) pesticide concent ration in water below a reference point. This measure is:

Number of pesticides of concern managed for which there is demonstrated progress toward reduction or maintenance of concentrations below the reference point x 100% Number of pesticides of concern managed16 Again, the Pesticide Program will m easure progress toward returning water to pristine (no pesticide detection) conditions. For all three metrics the goal is to reach 100%. However, it may take many years to reach that goal. Therefore, milestones in reac hing the goals will be incorporated into the yearly Pesticide Cooperativ e Agreement work plan.

Under the Cooperative Agreement, the Program will report progress on these three performance measures plus certain information upon which

the measures are based. EPA is currently (2007) developing a database that will compile this information so that it can be shared within EPA and among states.17 

# APPENDIX

Pesticides that are listed as p esticides of national interest18 

### and also in Alaska 2007

Pesticide Leachability Registration Status

in Alaska Detects?

Acetochlor High Leachability Not Registered in Alaska No Detects Acifluoren High Leachability Not Registered in Alaska No Detects Alachlor Medium Leachability Not Registered in Alaska No Detects Aldicarb High Leachability Not Registered in Alaska No Detects Atrazine High Leachability Not Registered in Alaska No Detects Bentazon High Leachability No Detects Bromacil High Leachability No Detects Carbaryl High Leachability No Detects Carbofuran High Leachability Not Registered in Alaska No Detects

Dacthal High Leachability State RUP No Detects Diazinon Medium Leachability No Detects Dicamba High Leachability No Detects Diuron High Leachability No Detects EPTC Medium Leachability Not Registered in Alaska No Detects Fenamiphos High Leachability Not Registered in Alaska No Detects Fluometuron High Leachability Not Registered in Alaska No Detects Hexazinone High Leachability No Detects Lindane High Leachability Not Registered in Alaska No Detects Linuron High Leachability No Detects Metalaxyl High Leachability Not Registered in Alaska No Detects Methomyl High Leachability No Detects Metolachlor High Leachability Not Registered in Alaska No Detects Metribuzin High Leachability No Detects Norflurazon Medium Leachability Not Registered in Alaska No Detects Picloram High Leachability Not Registered in Alaska No Detects * Prometon High Leachability No Detects Propachlor Medium Leachability Not Registered in Alaska No Detects Simizine High Leachability No Detects Terbufos High Leachability Not Registered in Alaska No Detects Tebuthinuron High Leachability Not Registered in Alaska No Detects

*Detect 8 years ago in Public Drinking Water system (not near MCL). Investigation could not find a cause, and system undetectable now for 6 years.19 

### Additional Alaska State Interests:

Pesticide Leachability Registration Status

in Alaska Detects?

2,4 D High Leachability No Detects**

Sulfometuron Methyl High Leachability State RUP No Detects

Bromoxynil High Leachability No Detects Butachlor High Leachability Not Registered in Alaska No Detects Diclofopmethyl High Leachability Not Registered in Alaska No Detects Propazine High Leachability Not Registered in Alaska No Detects Terbacil High Leachability Not Registered in Alaska No Detects Triallate High Leachability Not Registered in Alaska No Detects

DCPA High Leachability State RUP No Detects

Sulfentrazone State RUP No Detects

** 2 detects one surface water (pond in Anchorage), private well (in Mat-Su Valley) 7 years ago, currently no detects.

Rosemarie T.G. Lombardi V.M.D Environmental Program Specialist Alaska Department of Environmental Conservation Pesticide Program 1700 E. Bogard Rd. Bldg. B Ste 103 Wasilla, Alaska 99654

PH: 907-376-1866 FAX: 907-376-2382

Toll Free In-state 1-800-478-2577 rosemarie.lombardi@alaska.gov