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 Alaska Department of Environmental 

Conservation (ADEC) Pesticide Cooperative Agreement with the 

U.S. Environmental Protection Agency (EPA). The Pesticide Cooperative 

Agreement work plan describes the yearly priorities and work activities for 

ADEC with regards to pesticide enforcement and compliance, applicator 

certification and training, worker protection education, endangered species 

protection and water quality protection. This Alaska Pesticide 

Management Plan to Protect and Restore Water Quality describes 

ADEC’s approach to preventing and responding to pesticide contamination 

of water, while the yearly Cooperative 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 water that results from the normal, 

legal use of EPA and ADEC registered pesticides. Implementation of this 

Plan provides additional protections for Alaska waters beyond that 

provided by EPA’s pesticide registration process. When registering a 

pesticide under the Federal Insecticide, 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 provide 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 pesticide contamination. The Plan 

places a strong emphasis on prevention of contamination to protect the 
1

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 and 

healthy 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, spiritual 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 million acres of wetlands, 44,000 miles of 

coastline and 11 Ecosystems. Sixty percent 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 water 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 federally regulated public water 

systems (PWS) in the State of Alaska. 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 percent of Alaska’s public drinking 

water systems are supplied by groundwater. A small number of public 
2

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 water 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 most areas of Alaska, except in the 

northern part of the state where permafrost 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 occur in the Anchorage and Fairbanks 

areas and, to a lesser extent, the Matanuska-Susitna and Kenai Peninsula 

Boroughs in the south-central 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 streams. Producing aquifers are typically 

unconfined (i.e., not protected by a layer 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 groundwater quality (e.g., nonpoint pollution 

in urban areas, natural resource extraction activities in remote locations, 

and a wide range of potential point sources of pollution). The cost of 

cleaning up (remediating) contaminated 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 groundwater 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. contains 103,000,000 acres of wetlands, 

comprising approximately 5% of the surface area. Significant percentages 

of wetlands in urbanized areas including Anchorage, Juneau, Fairbanks, 

the Matanuska Susitna Valley and the North Slope, have been lost or 

impacted. Because there is a strong correlation between water bodies 

that are listed as impaired by DEC and areas where wetlands have been 

impacted or developed, wetlands need restoration and mitigation of 
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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 exploration, seafood processing, food 

plants, aquaculture, forest management, 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 annually 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 agricultural areas of the state are located in 

the Matanuska Susitna Borough, Fairbanks, Delta Junction, and Kenai 

Peninsula. Invasive weeds are also becoming a significant problem on 

government-owned land. The greatest volume of use continues to be 

biocides and disinfectants. There are 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 overall economic and social well-being.” 

 [Alaska Statutes, Section 46.03.010] 

Contamination Prevention

The Pesticide Program places a high priority on preventing contamination. 

Even if pesticides are not detected in water, the Program will continue 

their State-wide efforts to prevent contamination. These activities range 

from providing general information on protecting water quality for the 
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public to State-wide bans on the use of certain pesticides. Rather than 

responding to contamination of a pesticide – or a mixture of pesticides for 

which the toxic effects may not be well documented – detected through a 

limited monitoring network, the Pesticide Program believes the people of 

Alaska are best served through a strong State-wide prevention program. 

ADEC will continue to select the appropriate prevention actions based on 

sound data. ADEC will continue to base these decisions largely on 

toxicological and environmental data available from EPA, such as that 

provided in Re-registration Eligibility Decisions. See: 

http://www.epa.gov/pesticides/reregistration/status.htm. 

Many of the prevention activities described here will also be used in a 

more locally focused way if contamination 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 level 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 Department 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 current Cooperative Agreement Work plan 

contains information on the number of these 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 water from pesticide contamination. 

The emphasis of public education is on the use of pesticides by 

homeowners. This is typically done through 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 operates a toll-free telephone to answer 
5

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 pesticide users is a key part of the 

prevention program. Voluntary pesticide applicator education will continue 

through the Pesticide Program’s newsletter, 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 protection at professional meetings 

attended by pesticide applicators. 

Mandatory education of certain pesticide applicators will continue to be a 

primary focus of the prevention program. 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 the 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 training and testing, users of Restricted 

Use Pesticides are expected to be more knowledgeable and in better 

compliance with the additional use restrictions 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 the waters of the state from pesticide 

contamination [18 AAC 90.215(b)(3)]. Although they are not EPA 

Restricted Use, ADEC currently classifies products containing the 

following active ingredients as State Restricted Use due to water quality 

concerns: dacthal (DCPA), sulfometuron 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 applicators are required to keep their 

knowledge up-to-date. A person’s certification 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 certification requirements [18 AAC 90.020 – 

90.030]. They conduct routine inspections of certified dealers to ensure 

that these dealers are only selling Restricted Use Pesticides to certified 

applicators. The Program also conducts inspections of marketplaces 
6

where pesticides are sold to ensure that 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 these 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 pesticide products contain restrictions 

on how the product can be used. Under 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 required 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 current 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. Compliance 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], including water quality. However, if 

ADEC finds that the pesticide would still present an unreasonable adverse 

effect when used even with additional conditions, the Department will, at 

its discretion, deny that permit. The 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, with which the Program routinely coordinates, the 

Program’s interaction with these other programs typically occurs only 

when pesticide issues arise. 

University of Alaska Cooperative Extension 

Includes Integrated Pest Management, Sustainable Agriculture 

Research and Education, Pesticide 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 Resources – 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 water 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 to 
8

demonstrate that those management actions 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 monitoring. 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 confirmed 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 State for pesticides. The results of 

that monitoring are posted on the state 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 Water Program before taking steps to 

address any detection. Arrangements are being made with the Drinking 

Water Program for the Pesticide Program 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 owners are notified about the monitoring 

results may depend on the agency procedures conducting the monitoring. 

Since the ADEC Drinking Water Program does not have the authority to 

regulate private wells, and this is an issue that still needs some resolution. 

The pesticide program in conjunction 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. New 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 these types of studies through literature 

searches and contacts at the U.S. Geological Survey (USGS), the 

University of Alaska, the Municipality of Anchorage, and other programs 

within ADEC. 

As it has in the past, the Pesticide Program may conduct limited sampling 
9

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 included in the pesticide permit issued by 

ADEC are effective in preventing contamination. 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 the detection. The first step will be to 

verify the detection. The site where the detection occurred will be 

investigated by ADEC Pesticide Program staff or other cross-utilized 

ADEC staff to determine the likely source and extent of the contamination. 

 Dealers and users of Restricted Use Pesticides 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 conducting that monitoring. Options may 

include requiring additional monitoring 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 Pesticide Program will use water quality 

monitoring or other methods to determine 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 Program may instead choose to conduct 

inspections 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 substances” 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/water/acwa/acwa_index.htm. Under ACWA, 

the ADEC Division of Water works with the Department of Natural 

Resources and Department of Fish and Game to focus State and federal 

resources on the waters of greatest 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 Management Plan (QMP), which have 

been approved by EPA. The Pesticide Program will consult with the 

ADEC Water Quality Assessment and Monitoring Program regarding the 

design of any monitoring studies. 

Data obtained from other sources 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 only be used when it is of sufficient 

quality for the intended purpose. For example, data of questionable 

quality would not be used to create regulations but would be used to 

initiate follow-up sampling and to increase 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 pesticide management actions that prevent 

unreasonable adverse effects on human health, wildlife or the 

environment, taking into account the economic, social, and environmental 

costs and benefits of a pesticide’s use. [18 AAC 90.225 and 90.990(54)] 

A variety of voluntary and regulatory 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 toxicological reference point for 

judging the severity of risk to human 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 value 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 consider 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 sources 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 State 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 important 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/wqsar/waterbody/2006_final_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 Program 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 surface 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 the 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 pesticides from reaching a State water 

quality criterion, with an ultimate goal of returning the water to pristine (no 

pesticide detection). 

Groundwater – Coordination with State and Federal Programs

ADEC does not currently have a separate groundwater protection 

program. Responsibilities for groundwater protection are spread among 

several ADEC divisions and EPA. Protection of Alaska’s groundwater is 

largely accomplished through the regulation of contaminated sites, storage 

tanks, spill response, and specific waste 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 Development, 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 significant impact on groundwater quality 

in Alaska. 

The Pesticide Program will coordinate its activities in response to any 

groundwater contamination 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 contamination and geographical extent of the 

contamination by conducting a site-specific 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. Because the Drinking Water Program only 

works with public drinking water systems, the Pesticide Program will take 

the lead for working with private well owners if their wells become 

contaminated with pesticides. If the Pesticide 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, legal 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 those 
13

listed in the Contamination Prevention section. In developing the 

response strategy, the Pesticide Program will solicit the involvement of 

representatives of affected pesticide users, environmental groups, and 

water users. The response strategy will coordinate actions among water 

quality protection programs, describe the specific management actions 

that ADEC and other agencies/programs 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 management options for the pesticide, 

the economic value of the pesticide’s use, the likelihood of adoption of 

voluntary measures, and the Pesticide Program’s ability to enforce 

mandatory measures. ADEC will also consider the likelihood of the 

pesticide contaminating areas of the 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 pesticide 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 additional requirements to a pesticide’s 

use under a permit, limiting its application rate or frequency, or prohibiting 

a pesticide’s use in designated areas or the whole State. 

As described in the Monitoring section, the Pesticide Program will use 

water quality monitoring or other methods to determine if the implemented 

actions have been effective. If the actions have not been effective, more 

stringent actions will be needed. The Pesticide Program will then modify 

the original response strategy, in consultation 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 pesticide management measures that are 

increasingly stringent in response to higher contamination concentrations. 

 The table below does not replace ADEC’s consideration of its legal 

mandates but provides insight into the stringency of possible management 
14

actions at various levels of contamination 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 (instead 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 State 
15

Performance Measures and Reporting 

Under the Pesticide Cooperative Agreement, the Pesticide Program will 

use the performance measures described in the 2008 – 2010 Pesticide 

Cooperative Agreement to evaluate the 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 three-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 registration 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 Program 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 quantifying the number of pesticides for 

which some form of management has demonstrated progress toward 

keeping (or returning) pesticide concentration 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 managed 
16

Again, the Pesticide Program will measure 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 reaching the goals will be incorporated into 

the yearly Pesticide Cooperative 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 pesticides of national interest 
18

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