April 7, 2010

U.S. Environmental Protection Agency Office of Pesticide Programs (OPP) Regulatory Public Docket (7502P) 1200 Pennsylvania Ave NW Washington, DC 20460-0001

RE: Re-Evaluation of Human Health Effects of Atrazi ne Docket EPA-HQ-OPP-2010-0125

Dear Docket:

The American Water Works Association (AWWA) is an i nternational, nonprofit, scientific and educational society dedicated to the improvement of drinking water quality and supply. Founded in 1881, the Association is th e largest organization of water supply professionals in the world. Our 57,000-plus member s represent the full spectrum of the drinking water community: treatment plant operators and managers, environmental advocates, engineers, scientists, academicians, and others who hold a genuine interest in water supply and public health. Our membership inc ludes more than 4,200 utilities that supply roughly 80 percent of the nation's drinking water.

AWWA and its member utilities are dedicated to safe water and we appreciate the opportunity to comment on potential statistical app roaches for drinking water monitoring frequency. Our staff and member utilities are not experts on the health effects issues and will leave those issues to the appropriate experts.

However, any potential changes to atrazine complian ce monitoring frequency has implications to our member utilities, particularly small-to-medium surface water utilities in the Midwest that are subject to wide variability of atrazine concentrations in their source water. Without re-stating the extensive lit erature on this issue, surface water utilities in the Midwest experience a spring “flush ” of atrazine in their source water, and the magnitude and duration of this depends on sever al factors such as application date, intensity and duration of the rainfall, the timefra me between application and rainfall, and

several other factors. In some Midwestern reservoi rs, this spring “flush” will remain in

the reservoir so that atrazine levels are elevated year-round.

At the same time, due to its use in right-of-ways a nd other widespread uses, atrazine is ubiquitous in almost all surface waters and in many groundwaters, albeit in low Government Affairs Office
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April 7, 2010 Page 2

concentrations. In a recent study by USGS, Trends in Pesticide Concentrations in CornBelt Streams, 1996-2006 , out of 4,652 samples, only eight were non-detects . In other words, atrazine was detected in 99.8% of the USGS s amples of potential sources of drinking water. This study did have a relatively l ow detection limit of 0.004 ppb and the samples were taken in what might be considered “vul nerable” areas.

AWWA has been closely following the regulatory deve lopment process for atrazine, simazine, and the other triazines since Maximum Con taminant Levels (MCLs) were promulgated in the early ‘90s. Compliance with the atrazine MCL is based on an annual average of quarterly samples.

Atrazine and other triazine herbicides have been a major issue for AWWA and its member utilities for many years, due to the potenti al for groundwater and surface water

contamination from these herbicides. For more than 20 years, AWWA has written multiple letters to EPA and Congress expressing our concern with the impacts of agricultural chemicals, including the triazines, on drinking water supplies. AWWA has written extensive comments on EPA’s proposals as pa rt of the atrazine reregistration process. AWWA has been concerned with the lack of data for making informed regulatory decisions, and EPA’s past Interim Reregi stration Eligibility Decisions (IREDs) have been a step in the right direction in mandatin g more monitoring data paid for by the registrants. These registrant-monitoring requireme nts should be a typical component of the reregistration process for ANY pesticide with potential for drinking water exposu re.

AWWA has submitted several sets of comments to EPA’ s Office of Pesticide Programs (OPP) throughout the atrazine special review and tr iazine reregistration processes. Our past comments have focused on several issues, but p rimarily, our main concern is the ongoing additional treatment burden that our utilit y members, and ultimately their customers, will have to pay in order to comply with the drinking water standards, primarily the current atrazine standard. Many surf ace water utilities installed additional treatment (either Granular Activated Carbon or Powd ered Activated Carbon) soon after the MCL was finalized in 1991 to comply with this n ew standard. The registrant and the growers have made some progress in controlling atra zine at the source, and this stewardship, combined with the additional carbon tr eatment by utilities, have contributed to atrazine violations decreasing from 81 in 1995 t o 3 in 2007. But keep in mind violations are based on finished drinking water, as opposed to the drinking water sources in the USGS study previously mentioned.

EPA’s recent release of finished water monitoring d ata from 44 states as part of its sixyear review of drinking water regulations (75 FR 15 500) basically parallels the above

violation data. Atrazine was detected in 4.23% of 161,690 samples. The median, the 90 th
percentile, and the maximum concentrations in this dataset ranged from 0.1-1.61 ppb, 0.1-4 ppb, and 0.1-27 ppb respectively. Generally, atrazine is found less frequently in finished drinking water as opposed to drinking wate r sources due to existing treatment to comply with the atrazine MCL.Docket EPA-HQ-OPP-2010-0125

April 7, 2010 Page 3

However, AWWA believes that additional regulatory a ctions (sooner rather than later) are necessary so that drinking water utilities (and their customers) are not continued to be

saddled with the additional costs of carbon treatme nt. EPA’s regulatory actions should be geared towards moving the costs from the utiliti es’ customers to the atrazine registrants and users.

To better understand triazine occurrence patterns a nd the relationships between the parent compounds and their degradation products, the Water Industry Technical Action Fund (WITAF) funded two extensive research efforts in 20 03 and 2004. The 2003 monitoring program was conducted at 38 plants using the EPA-ap proved Beacon/Syngenta immunoassay (IMA) analytical method as the primary analytical method. Dr. Craig Adams of the University of Missouri-Rolla (UMR) dev eloped a GC-MS analytical method for the triazine parents and their degradati on products. UMR also conducted treatability studies through separate funding from the Missouri Department of Natural Resources (DNR). All of the utilities monitored we ekly from March to September by collecting samples and shipping them to the Univers ity of Colorado-Boulder (CU) for IMA analysis. A smaller subset, consisting of 14 u tilities, conducted both weekly (IMA at CU) and daily monitoring (IMA onsite). Approxim ately 10% of the samples collected by both the daily and weekly samplers were sent to UMR for GC-MS analysis. Information on treatment practices and source water quality were collected at the same time as the samples.

In April 2003, problems with the Beacon/Syngenta IM A analytical method became apparent. Interferences from chlorine, chloramines , chlorine dioxide, Total Organic Carbon, and other compounds were investigated at UM R. Since this project was not a method validation project, all of the potential int erferences were not investigated. However, it is clear that this IMA method is precis e but not accurate, and generally biased high. The lack of robust IMA method perform ance was also confirmed by EPA’s Environmental Technology Verification (ETV) program conducted by Battelle in 2004. This IMA method can be used for screening but is no t accurate enough for drinking water compliance monitoring and that is important due to the higher cost of compliance monitoring using the approved analytical methods.

The 2004 monitoring program was conducted at 49 pla nts. This project was a partnership between the Water Industry Technical Action Fund (W ITAF) and the Awwa Research Foundation (AwwaRF, now the Water Research Foundati on). Monitoring was again conducted in the March-September timeframe and anal ysis was conducted using the

Abraxis IMA method at the offices of McGuire Enviro nmental Consulting. Again, approximately 10% of the samples were split and ana lyzed for triazine parents and their degradation products using GC-MS at UMR. The 2004 IMA monitoring data show some improvement compared to the 2003 data, with the res ults being precise but not accurate, and generally biased slightly high. Monte Carlo an alyses were conducted to understand the potential compliance impacts from different com pliance sampling regimes (biweekly, monthly, quarterly, etc.), but it became ap parent that more than one year of monitoring data was needed to analyze potential reg ulatory compliance monitoringDocket EPA-HQ-OPP-2010-0125

April 7, 2010 Page 4

options. A listing of the six peer-reviewed public ations that have resulted from this

research effort is enclosed at the end of these com ments.

Our latest effort is a statistical analysis of the multiple years of Syngenta monitoring data. As previously mentioned, it became apparent from th e previous research that more than one year of monitoring data was needed to better un derstand source water variability and to analyze potential monitoring options. Syngenta provided our contractor, Clancy Environmental Consultants, with their monitoring da ta from 1993 to 2005 in order to conduct a more robust statistical analysis. This a nalysis focuses on developing a high

confidence that measured values do not exceed the s pecific values established in a regulation (whatever those values might be). This project has found that the number of samples needed to characterize the “spring flush” a nd understand its potential impacts on compliance with a specific value varies depending o n the mean and standard deviation of the monitoring data. These potential monitoring r equirements can be very clearly and succinctly summarized. The results from this analy sis suggest that using historical data, sampling can be designed so that surface water syst ems that are “vulnerable” with high means and high variability need to sample more freq uently while systems that have low means and/or little variability do not need to samp le as frequently.

The economic implications for a required increase i n compliance monitoring for the small and medium surface water systems in the Midwest cou ld be significant. For example, assume a surface water system serves 500 connection s (approximately 1,500 people) in the Midwest and its customers have an average month ly water bill of $30. The total annual revenue for this system would then be $180,0 00. The analysis for a single compliance sample using the approved GC-MS analytic al methods costs approximately $200. Assuming an additional $100 for sample colle ction and shipping yields a cost of $300 for each additional compliance monitoring samp le. So increasing the compliance sampling from quarterly (four samples per year) to eight samples per year would increase the monitoring costs by $1,200, which is almost 1% of the total annual revenue for this example system.

One potential option to mitigate the additional mon itoring cost is to have the registrants and/or the users agree to pay for this additional c ompliance monitoring for a limited number of surface water systems in the Midwest. A regulatory framework would need to be developed so that this additional burden does no t end up with the utilities, and ultimately, in their customers’ rates.

If any revisions are needed to either the numerical standard or the compliance monitoring frequency, or if a total triazine standard needs to be developed, AWWA relies on EPA’s toxicological, epidemiological, and cost-benefit ex pertise to develop the appropriate risk management option for drinking water. AWWA recomme nds that EPA develop the appropriate drinking water risk management option a s soon as possible as the atrazine issue has dragged on since the special review start ed in the ‘90s. The media continues to publish stories about weed-killer in drinking water , and utilities and their customers need

a resolution to this issue once and for all.Docket EPA-HQ-OPP-2010-0125

April 7, 2010 Page 5

In conclusion, AWWA recommends that:

• EPA complete this new evaluation of atrazine as soo n as possible and continue to hold to its principles of good science and transpar ency;

• EPA use its toxicological, epidemiological, and cos t-benefit expertise to develop the appropriate risk management option for drinking water as soon as possible;

and

• The registrants and/or the users should pay for any additional compliance monitoring (if needed) for water utilities.

If you have any questions about these comments, ple ase feel to call Alan Roberson or me in our Washington Office at 202-628-8303.

Yours Sincerely,

Thomas W. Curtis Deputy Executive Director

cc: Peter Silva—OW

Steve Owens—OPPTS Bob McNally—OPP

Melanie Briscoe—OPP Cynthia Dougherty—OGWDW

Pam Barr—OGWDW

Ed Ohanian—OST

Alan Roberson

Steve ViaDocket EPA-HQ-OPP-2010-0125

April 7, 2010 Page 6



## Peer-Reviewed Publications Resulting from Triazine Research

• Graziano, N., McGuire, M., Adams, C., Roberson, A., and Blute, N. National Atrazine Occurrence Monitoring Program (20 03) Using the

Beacon ELISA Method. Journal AWWA , 98:10:111 (October, 2006).

• Jiang, H., Adams, C., Graziano, N., Roberson, A., M cGuire, M., and Khiari, D. Occurrence and Removal of Chloro-s-Tria zines in Water

Treatment Plants. Environmental Science & Technology (40:11:3609).

• Jiang, H., Adams, C., Graziano, N., Roberson, A., a nd McGuire, M. Enzyme Linked Immunoassay Analysis (ELISA) of Atraz ine in Raw

and Finished Water. Environmental Engineering Science (23:2:357).

• Graziano, N., McGuire, M., Roberson, A., Adams, C., Jiang, H., and Blute, N. 2004 National Atrazine Occurrence Monito ring Program Using the Abraxis ELISA Method. Environmental Science & Technology (40:4:1163).

• Adams, C., Jiang, H., McGuire, M., Graziano, M., Ro berson, A and Frey, M. Accuracy and Interferences for Enzyme-Lin ked Immunoassay Tests for Atrazine. Journal AWWA , 96:12:126 (December, 2004).

• Jiang, H., Adams, C., and Koffskey, W. Determinati on of Chloro-sTriazines Including Didethylatrazine Using Solid-ph ase Extraction Coupled with Gas Chromotography-Mass Spectrometry. JournalChromotography-A , 1064:2:219.