October 22, 2009

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

RE: Atrazine Evaluation Docket EPA-HQ-OPP-2009-0759

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 appreciates the opportunity to comment on the new comprehensive evaluation of atrazine. AWWA has been closely following the re-r egistrations for atrazine and the other triazines since Maximum Contaminant Levels (M CLs) for these herbicides were promulgated in the early ‘90s. Atrazine and other triazine herbicides have been a significant issue for AWWA and its member utilities for many years, due to the potential for groundwater and surface water contamination fro m these herbicides. Protection of drinking water sources and prevention of contaminat ion should be the ultimate objective for EPA’s regulatory programs.

Many surface water utilities in the Midwest had to install carbon treatment (and pass on those costs to their customers) to comply with thes e MCLs in the ‘90s. Typical carbon treatments used in water treatment plants to remove these herbicides have significant operation and maintenance costs (beyond the initial capital construction costs) that will be borne by their customers in perpetuity. EPA’s r egulatory programs should address this cost shifting issue within its regulatory prog rams so that the registrants are ultimately responsible for these life-cycle costs. Government Affairs Office
1401 New York Avenue
Suite 640 Washington, DC 20005
T 202.628.8303
F 202.628.2846

www.awwa.org

Headquarters Office 6666 W. Quincy Avenue
Denver CO 80235
T 303.794.7711
F 303.347.0804 The Authoritative Resource on Safe Water SMDocket EPA-HQ-OPP-2009-0759

October 22, 2009 Page 2

For more than 20 years, AWWA has written multiple l etters to EPA and Congress expressing our concern with the impacts of agricult ural chemicals, including the triazines, on drinking water supplies. AWWA has written exten sive comments on EPA’s proposals as part of the atrazine reregistration process. Ad ditionally, AWWA and the Water
Research Foundation have conducted substantial rese arch on the impacts of these herbicides to utilities, and a list of some of the published papers resulting from that

research is included at the end this letter.

AWWA would like to emphasize three issues to EPA an d the Scientific Advisory Panel (SAP) as part of the comprehensive evaluation of at razine:

1. AWWA strongly supports the use of “...the best availa ble, peer-reviewed science...” in the regulatory development process, as this specific language is one of the cornerstones of the Safe Drinking Water Act (SDWA). AWWA supports
EPA and the SAP in its efforts to evaluate the new scientific evidence and determine how this new evidence might (or might not ) impact the agency’s

human health risk assessment of atrazine.

2. AWWA believes that the policies and regulations fro m both the Office of Pesticide Programs (OPP) and the Office of Groundwa ter and Drinking Water (OGWDW) must protect drinking water sources. Atraz ine MCL violations have been reduced from 81 in 1995 to three in 2007, but what is not known is how much of the reduction is due to improved stewardshi p at the farm level or whether the reduction is due to many surface water utilitie s in the Midwest installing carbon treatment, as previously discussed.

3. AWWA supports registrant monitoring requirements be ing a typical component of the re-registration process for pesticides with moderate to significant drinking water exposure. The monitoring data developed by S yngenta has been useful in developing a better understanding of atrazine drink ing water exposure. This type of monitoring program should be a typical component of the re-registration requirements in OPP.

The regulatory policies in both OPP and OGWDW must assure that the use patterns of the pesticides are managed and water supply contami nation prevented so that drinking water suppliers are not left with the major respons ibility to prevent or limit human risks. The primary control of human exposures and the pote ntial public health impacts of pesticides and herbicides must reside with the prod ucers, users, and applicators of these agricultural products.

It is not clear how OGWDW will incorporate the risk assessments put forward by OPP in its Six-Year Review process, as there has been a fu ndamental difference in how the two
offices have addressed these risk assessment issues in their own separate rulemakings. Essentially, OPP must conclude that the likely expo sures do not exceed its level of concern and will therefore, approve the use of the pesticide. In contrast, OGWDW must
establish MCLGs and MCLs.Docket EPA-HQ-OPP-2009-0759

October 22, 2009 Page 3

Regardless on how the risk assessment is incorporat ed into rulemaking, when OGWDW issues an MCL, the usual quarterly monitoring regim en of chemical contaminants in drinking water may or may not be appropriate for th ese herbicides for surface water utilities in the Midwest because of the application occurs during a limited period of time during the year, and therefore, runoff will result in contamination in some watersheds during limited times. Seasonal or stratified monit oring may be (or may not be) necessary. Regulatory controls under OPP to address potential ecological effects may or may not result in any revisions to the atrazine drinking wa ter standard. We are finalizing a paper to submit to a peer-reviewed journal of our multi-y ear statistical analysis of the atrazine monitoring data that should provide a foundation fo r future monitoring requirements, if OGWDW ultimately determines that the monitoring req uirements need to be revised
based on the final OPP risk assessment.

It is not completely clear at this time whether OGW DW will revise some of the individual standards for the parent compound as par t of it Six-Year Review process, develop standards for the degradation products, or develop a combined standard. EPA needs to clearly articulate how the agency plans to reconcile the differences in the risk assessment, regulatory development, and decision po licies and processes between OPP
and OGWDW.

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-2009-0759

October 22, 2009 Page 4



### Peer-Reviewed Publications Resulting from Triazine Research

• Graziano, N., McGuire, M., Adams, C., Roberson, A., and Blute, N. National Atrazine Occurrence Monitoring Program (2003) 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-Triazines in Wat er 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 Atrazine 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 Monitoring Progra m 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-Linked Immuno assay Tests for Atrazine.
Journal AWWA , 96:12:126 (December, 2004).

• Jiang, H., Adams, C., and Koffskey, W. Determinati on of Chloro-s-Triazines Including Didethylatrazine Using Solid-phase Extrac tion Coupled with Gas Chromotography-Mass Spectrometry. Journal-Chromotography-A , 1064:2:219.