June 2008-November 2010 Meeting Log for Atrazine Sp ecial Review Docket Page 1 of 10

March 5, 2009 , 1-1:30 PM

EPA/OPP conference call with Syngenta regarding Atr azine Monitoring Program (AMP)

data.

The purpose of this conference call was to explain to Syngenta how data are used to calculate Margins of Exposure (MOEs) for Community Water Systems (CWSs) in the Atrazine Monitoring Program (AMP).

Calculation of the MOE uses actual atrazine, simazi ne, and 3 atrazine metabolite

measurements from finished water. These measuremen ts are added together and converted to parts per million (ppm). The data fro m sampling are scattered throughout the year, but calandex requires daily residue level s to calculate an MOE. Because of this, daily residue levels are calculated using linear in terpolation between the data points.

Prior to 2006, some of the data points are sparse. This is because EPA/OPP’s Environmental Fate and Effects Division (EFED) used only total chlorotriazine (TCT) data, rather than using more prolific atrazine data from immunoassays to calculate TCT levels via a regression equation. This approach is consistent with the approach in the

2006 Triazine Cumulative Risk Assessment. EFED exa mined the data to ensure that the data interpolations between points were not substan tially overestimating residue levels. There was only one CWS (Westport) in which this cou ld have posed a problem.

Once EPA interpolates the data, the data can be run through calandex. The calandex model first calculates the 90-day rolling averages, then multiplies this value with the consumption data from CSFI, and compares the result to an endpoint of 1.8. Calandex does this ten times and then the average of the ten repetitions is used as the final MOE.

For all non-detect samples EPA assumed that half th e Limit of Quantification (LOQ) was

present.

Levels of 9-12 ppm in 90-day averages tend to have an MOE below 300.

Discussion about data from specific CWSs:

• Aqua, IL – discussed the number and type of samples we have, and which were

used for the MOE calculation.

• Piqua Gravel Pit should be raw-water only. Are we running finished or raw data for Piqua Gravel Pit, or is it a copy-paste error?

• Vermont—do we have the TCT data for it for 2007?

• Hettick – Syngenta has documentation from Hettick’s Drinking Water Watch Website that says the source switched. Is that doc umentation OK? We’ll confirm with Bob. Syngenta will check the SDWA data to mak e sure the states aren’t monitoring in Hettick—if they are, that means that its community switched back to its original drinking water source.

• EPA provided the names of systems with MOEs below 3 00 for year 2003 toJune 2008-November 2010 Meeting Log for Atrazine Sp ecial Review Docket Page 2 of 10

Syngenta.

Participants: Melanie Biscoe, PRD/OPP/EPA Nader Tadayon, HED/OPP/EPA Mary Frankenberry, EFED/OPP/EPA Jack Arthur, HED/OPP/EPA Anne Overstreet, PRD/OPP/EPA Brian Christiansen, Syngenta (on phone) Paul Hendley, Syngenta (on phone) Dan Campbell, Syngenta (on phone) Ron Williams, Syngenta (on phone) Andrew Merritt, Syngenta (on phone)

Meeting notes prepared by – Melanie Biscoe

November 20, 2009 , 10-11 AM

EPA/OPP meeting with Alan Roberson of American Wate r Works Association (AWWA).

Alan Roberson requested this meeting

OPP and AWWA discuss the possibility of monitoring for peaks through the Atrazine Monitoring Program (AMP). AWWA indicates that it h as worked with a statistician on this and can present it to EPA.

AWWA indicated it was interested in learning what t he results would be of OW’s 6-year

review of the atrazine MCL.

OPP asked AWWA about its perspective on disseminati ng atrazine monitoring data to the public. AWWA indicated it would be supportive of a compromise that could work. AWWA indicated that a select few chemicals require more monitoring under SDWA if they exceed half of the MCL, and that from the regu latory perspective that may be an option (although it is not AWWA’s position to suppo rt this as a measure per se).

OPP and AWWA discussed issues surrounding provision of data to the public, including whether fears are raised by releasing data, right-t o-know issues, and differentiating

between raw and finished water data.

OPP asked AWWA how people respond to media articles and reports like those published on atrazine. AWWA indicated that there h as been a similar situation occurring with pharmaceuticals in drinking water. AWWA indic ated that Community Water Systems (CWSs) are getting few calls from consumers compared to calls from political figures and newspapers. (AWWA discussed how its si ster organization, Water Research Foundation, has been conducting research on this is sue). AWWA also indicated that,June 2008-November 2010 Meeting Log for Atrazine Sp ecial Review Docket Page 3 of 10

from its perspective, the news cycle in the Midwest took its course and there wasn’t substantial impact of the news reports concerning a trazine.

OPP asks AWWA whether it thinks OPP is missing syst ems through the current trigger

for CWSs to enter the AMP. AWWA indicates that it’ s possible but really unlikely that EPA is missing systems.

AWWA asked OPP about the atrazine re-evaluation. O PP indicated that it will be conducting a re-evaluation of the science underlyin g atrazine regulation for human health with no prejudged outcomes. OPP indicated that aft er the human health evaluation is complete, ecosystem issues will undergo review. OPP discussed how the atrazine reevaluation would utilize the SAP. OPP also mention ed that registration review for

atrazine would commence in 2013.

OPP indicated that AWWA’s perspective on the impact of atrazine alternatives on drinking water and CWSs would be valuable.

Meeting notes prepared by – Melanie Biscoe

Participants: Melanie Biscoe, PRD/OPP/EPA Robert McNally, PRD/OPP/EPA Eric Olson, PRD/OPP/EPA Alan Roberson, American Water Works Association (AW WA) December 4, 2009 , 1-2 PM

EPA conversation with stakeholders on providing atr azine drinking water monitoring

data.

EPA requested this conference call.

OPP discussed the purpose of the conference call, w hich was to acquire stakeholder input to explore better ways to inform the public more qu ickly about results of atrazine drinking water monitoring, with particular focus on FIFRA-required monitoring conducted by Syngenta Crop Protection under the Off ice of Pesticide Programs’ Atrazine Monitoring Program (AMP).

Natural Resources Defense Council (NRDC) discussed how consumers should have timely notification of seasonal spikes of atrazine occurring in drinking water in the Midwest. They indicated that it is important for c onsumers to be able to access the data as they come out.

Triazine Network wanted NRDC to clarify whether it thinks the Community Water Systems (CWS) or the public (or both) ought to be n otified of the atrazine levels; NRDC indicated that it would depend on who is doing the notification, but that ultimately the

water consumers themselves hould be able to access the information. Triazine NetworkJune 2008-November 2010 Meeting Log for Atrazine Sp ecial Review Docket Page 4 of 10

indicated that atrazine levels cannot be tested in a 24-hour timeframe, and that there are logistical issues in getting the data analyzed.

American Water Works Association (AWWA) said that i n terms of getting the atrazine drinking water data out in a timely manner, there i sn’t really a mechanism to do this, particularly in terms of a media outlet. This woul d be the case even if a spike lasts for two weeks. NRDC responded that the internet could be used as an outlet – that the information doesn’t have to be put out on every bro adcast. Consumers deserve the right to know what is in their water so they can choose t o filter it.

Triazine Network said that there are lots of contam inants that have spikes below levels of concern, and wondered why there was so much of a fo cus on atrazine. NRDC indicated that it would gladly have other contaminant data wh ere levels are below levels of concern, but today the topic is atrazine. NRDC dis cussed how USGS has water monitor gages active all the time and that you can look at data history, averages, or graphs.

AWWA expressed its support for having all of Syngen ta’s data available but indicated that there could be issues regarding how the water systems feel about providing this information if the burden is on the water systems t hemselves to provide it.

OPP discussed the protocol for the data as it stand s right now, and that CWS have access to it as soon as it’s available. EPA added that QA /QC for data as it comes in would add a couple weeks to posting on the internet. OPP discu ssed how there’s no way to get data in a 24 hour period. OPP also said that Syngenta requ ired to notify EPA w/in 30 days if there is an exceedence of the 90-day Level of Conce rn (LOC) in raw water. OPP asked for thoughts on annual posting of the monitoring da ta.

Triazine Network and AWWA discussed how the turn-ar ound time to meet a need for

instantaneous data would be a week or two at a mini mum.

NRDC talked about need to present actual numbers, a nd that otherwise it would make EPA look like it’s hiding information. NRDC discus sed its belief that there is a sperm motility issue at 10 days of atrazine exposure, so quick turnaround of the data is important. In addition, NRDC discussed how it want s to see raw data, explanation and context for levels of concern, and rolling average calculations all publicly available. NRDC cited NHANES data as an example where you’d ha ve graphs, summary data and raw data put into context. AWWA indicated that NRD C’s proposal would be fine under the AMP, but not appropriate for SDWA quarterly sam ples.

Triazine Network objected to notion that atrazine i s the contaminant of most concern in drinking water, as suggested in this discussion. T riazine Network indicated that the LOCs an individual may perceive have not been vette d through the regulatory community and would not warrant a weekly monitoring update.

Triazine Network also discussed its belief that it’ s well established what the application season is, and that people would know about the sea sonal increases during applicationJune 2008-November 2010 Meeting Log for Atrazine Sp ecial Review Docket Page 5 of 10

times. The public has the ability to deal with thi s even in the absence of data. Triazine Network said that it is questionable whether the da ta would really provide added value to people.

Triazine Network was also concerned about how water systems would react to data provisions. Triazine Network indicated that CWSs m ay drop out of the AMP because it puts an additional burden on the system in terms of the effort to monitor as well as the scrutiny from the media. Triazine Network indicate d that there is a potential for CWS to quit the AMP en mass, and said that it knows CWSs t hat aren’t participating in the AMP because of the potential for increased scrutiny.

OPP asked whether CWSs are concerned about monitori ng data being put on the web more frequently or about making information on CWS locations public. Triazine

Network indicated that it had heard from several CW Ss that do not conduct monitoring for the AMP because of the SDWA monitoring they’re already doing. AWWA indicated that it had talked with Syngenta earlier in the wee k, and that Syngenta is trying to get more information about the perspectives of the wate r systems on this.

OPP asked whether frequent reporting was equivalent to frequent scrutiny. AWWA indicated that it’s more the issue of putting the L OC into context – providing risk communication along with the numbers. Triazine Net work said that the presence of data is not the issue; rather, it’s the issue of the Age ncy providing proper risk communication.

Triazine Network indicated that with the recent New York Times article there was a distinct lack of risk communication in the reportin g, and believed that a lot of heightened

concern about risks would not have been raised if t he risk communication piece had been in place. Triazine Network did not believe that th e issue was about the data being

available more often.

EPA asked how the stakeholders define a “spike” in atrazine levels. Triazine Network discussed how atrazine levels are, generally, highe r in May than in any other time of year

. NRDC described its perspective on spikes as atrazin e levels that go from below 1 ppb on average to 10, 12 and 20 ppb on average, which main ly occurs in the spring.

OPP discussed how if there’s no question that there are higher levels of atrazine after use historically, providing information to people may b e useful but if people know it spikes in the spring they may just buy filters anyway. Tr iazine Network and AWWA agreed with this. NRDC indicated that there may be system s that didn’t historically show problems that could be a problem, and that it would be valuable to have data on those particular systems.

AWWA indicated that the turnaround time for analyzi ng a sample is 2 weeks, per its prior communication with Sygnenta. NRDC discussed how having timely data during spring and summer is important, and that one would not need immediate information on atrazine concentrations during other times of year. NRDC indicated that in spring and

summer one would want to shorten that 2-week turnar ound time for analysis. OPP indicated that it could look into whether the logis tics can be sped up.June 2008-November 2010 Meeting Log for Atrazine Sp ecial Review Docket Page 6 of 10

OPP said that it currently makes information/data a vailable on its Atrazine Updates website, and asks whether stakeholders believe ther e are other ways EPA could make the data accessible. AWWA indicated that you would rea lly have to rely on the systems involved, but not all of them have websites or emai l.

OPP asked how comfortable stakeholders would you fe el if the data were not QA/QCed by EPA before posting. AWWA indicated that it woul d be concerned if the raw data were not QA/QCed by the laboratory and Syngenta. N RDC indicated that it didn’t want the data posted without a QA/QC, and asked what the steps are for a QA/QC. OPP explained the difference between the Syngenta and O PP QA/QC process. NRDC stated that it was comfortable with OPP posting AMP data w ithout QA/QC by OPP’s

Environmental Fate and Effects Division.

OPP asked stakeholders whether they believed that t he public was aware of the atrazine data on the Atrazine Updates website. Triazine Net work said that, in rural America, not a lot of people are looking for information on a part icular contaminant. Triazine Network said that if people think there is an issue, they b elieve that the contaminant would be regulated and reported accordingly, and that they a re not going to be looking for these data. NRDC indicated that it gets calls from peopl e in small towns about contaminants. NRDC said that when they ge these calls, they tell people to talk directly with their CWS

and to contact EPA. Triazine Network said it belie ved that NRDC received those calls as a result of the “Poisoning the Well” report it issu ed regarding atrazine.

Meeting notes prepared by – Melanie Biscoe

Participants: Robert McNally – EPA/OPP

Eric Olson – EPA/OPP

Melanie Biscoe – EPA/OPP Eric Burneson – EPA/OW (on phone) Francine St.-Denis – EPA/OW (on phone) Alan Roberson – American Water Works Association (A WWA) (on phone) Jennifer Sass – Natural Resources Defense Council ( NRDC) (on phone) Mae Wu – Natural Resources Defense Council (NRDC) ( on phone) Jere White – Triazine Network (on phone) Tyler Wegmeyer – American Farm Bureau Federation (o n phone)

January 6, 2010 , 10-11:30 AM

Meeting with American Water Works Association (AWWA ) on Frequency of Monitoring

AWWA offered to present its work on frequency of mo nitoring to EPA, and OPP accepted this offer.

In addition to the power point presented by Jeff Ro sen of Clancy EnvironmentalJune 2008-November 2010 Meeting Log for Atrazine Sp ecial Review Docket Page 7 of 10

Consultants (CEC), which is also posted in docket n umber EPA-HQ-OPP-2004-0319, the following items were discussed:

• The percentile used not being the absolute maximum

• The possibility of monitoring something orthogonal to the data to inform sampling times

• Breaking down sampling plans based on the history i n an individual watershed

• Thinking about how many of the Community Water Syst ems (CWSs) in the Atrazine Monitoring Program (AMP) use carbon filtra tion vs. those that do not

• The cost of monitoring – approximately $100 per sam ple analyzed using Gas Chromatography/Mass Spectrometry (GC/MS), not inclu ding the “burden” cost on of someone physically collecting the sample and sending it to the lab.

• Syngenta providing AWWA with data from the AMP (whi ch they had already done)

AWWA mentioned that it had developed a analytical t ool that may be useful for EPA in its frequency of monitoring evaluation, and that it is free for anyone to use. AWWA also offered to do conduct additional analyses based on EPA feedback. OPP thought it might be valuable to look at upper percentiles for a 3-4 day average.

Meeting notes prepared by – Melanie Biscoe

Participants: Dana Spatz, EPA/OPP/EFED Mike Messner, EPA/OW Wynne Miller, EPA/OW Mary Frankenberry, EPA/OPP/EFED Nelson Thurman, EPA/OPP/EFED Melanie Biscoe, EPA/OPP/PRD Elizabeth Mendez, EPA/OPP/HED David Miller, EPA/OPP/HED Jack Arthur, EPA/OPP/HED Nader Tadayon, EPA/OPP/HED Steve Nako, EPA/OPP/HED Aaron Niman, EPA/OPP/HED Alan Roberson, American Water Works Association (AW WA) Jeff Rosen, Clancy Environmental Consultants (CEC) Anna Lowit, EPA/OPP/HED David Hrdy, EPA/OPP/HED Russell Erickson EPA/ORD (on phone)

November 30, 2010 , 11:30 AM-12:30 PM

Call with Wisconsin State to discuss details about their atrazine restrictions for groundwater protection.

EPA/OPP requested the conference call.June 2008-November 2010 Meeting Log for Atrazine Sp ecial Review Docket Page 8 of 10

Wisconsin state officials discussed the timing and rationale for the atrazine restriction program in Wisconsin, which has been in effect for twenty years. They discussed how there are now 101 prohibition areas covering approx imately 1.1 million acres of Wisconsin, impacting less than 10% of the 3.5-4 mil lion acres of corn in Wisconsin.

EPA asked whether there were atrazine management ar eas with restrictions short of prohibition. Wisconsin state officials indicated t hat there had been a number of atrazine management areas triggered by monitoring results fr om private wells, but that there were so many of these areas that in 1993 the entire stat e of Wisconsin reduced atrazine rates state-wide, effectively making all of Wisconsin an atrazine management area.

Wisconsin state officials noted that Wisconsin’s gr oundwater law requires prohibition of

the use of a contaminant that has exceeded a state enforcement standard unless someone can prove that a measure short of prohibition is ef fective. To-date, no one has shown that a lesser measure is effective in atrazine prohibiti on areas.

Wisconsin state officials discussed how they had co nsidered rolling back atrazine prohibition areas; however, even at reduced rates t here were still exceedences of 3 parts per billion in monitoring wells, so reintroduction of atrazine into prohibition areas was not considered an option.

Wisconsin state officials indicated that groundwate r quality in prohibition areas is greatly improving. Every year they continue to look and se e if new/expanded prohibition areas needed. Periodic expansion of prohibition areas do es occur, but in general Wisconsin is not finding whole new areas where prohibition would be proposed.

EPA asked whether the reduced rates are effective f or target pests. Wisconsin state

officials indicated that the reduced rates of atraz ine are effective for broadleaf weeds, but not grasses. They discussed how the National Agric ultural Statistics Service (NASS) is conducting a survey of growers to look at the impac t of the prohibition areas on growers. They discussed some of the preliminary results of t his survey, and indicated that the final report would be available in January or February.

EPA was interested to know what the population of g rowers and numbers of corn acres were in the prohibition areas. Wisconsin state off icials discussed how the farm sizes vary dramatically. They also indicated that corn is gro wn on both livestock farms and farms that just grow cash crops (generally on a corn and soybean rotation).

EPA also asked what the primary alternatives are fo r atrazine in prohibition areas. Wisconsin state officials indicated that glyphosate the primary alternative, and that it does not pose groundwater concerns. Simazine had b een used as an alternative in one area, but the simazine metabolites contaminated the groundwater and the state had to prohibit the use of atrazine as well as simazine in that area. (Because the area was so small with so few growers, the state had individual agreements and administrative orders with those growers to stop use of simazine in that area). Wisconsin indicated thatJune 2008-November 2010 Meeting Log for Atrazine Sp ecial Review Docket Page 9 of 10

mesotrione is also an alternative to atrazine in th ese areas, but they are not aware of any groundwater concerns for this chemical or other alt ernatives used for broadleaf weed

control. Wisconsin officials indicated that metola chlor and acetochlor are used for control of grassy weeds and that they are both seen in groundwater but not at levels where the state would take action to prohibit use.

EPA wanted to know whether farmers were going out o f farming or growing less corn as a result of the prohibition areas. Wisconsin indic ated that to-date, there has not been evidence that farmers in prohibition areas are grow ing less corn or going out of farming. In fact Dane County, which has about two-thirds of its land in an atrazine prohibition area, remains one of the top corn producing countie s in the state.

EPA asked about ecological concerns due to atrazine use in the state. Wisconsin indicated that there are no impaired waters in Wisc onsin specific to pesticide use, although there are not the same standards for surfa ce waters in Wisconsin as there are for groundwater. The Wisconsin Department of Natural R esources does conduct monitoring of pesticides and detects them at various levels in groundwater and surface water, but

there have not been detections at levels where the state would take action.

Wisconsin officials described how they conducted th eir investigations to expand the boundaries of a prohibition area. They indicated t hat when a particular well sample exceeds the 3 part per billion standard, the state collects confirmation samples within a one-mile radius around that particular well. They then determine whether the well contamination is from field use, a spill, or some k ind of backflow event. The state

conducts interviews and collects atrazine use recor ds for the previous five years within

the one-mile radius of the well. When it is determ ined that there were no point sources for the contamination, the state proceeds with prop osing the expansion of the prohibition area. They’ve found generally that well contaminat ion is correlated with atrazine use intensity.

EPA asked whether there are compliance issues in pr ohibition areas. Wisconsin officials indicated that there are some compliance issues, an d that they conduct soil tests, observe applications, and check dealer records to prevent u se in the prohibition areas. They indicated that occasionally the use in prohibition areas is intentional, but sometimes growers buy pre-mix products and don’t realize that the pre-mix contains atrazine. In general, however, Wisconsin believed that overall c ompliance is pretty good, as evidenced by decreased levels of atrazine in the gr oundwater monitored in the prohibition

areas.

EPA wanted to know what stakeholder responses have been to prohibition area proposals.

Wisconsin officials indicated that there has been m ore stakeholder comment than usual, in part due to EPA’s scientific evaluation of the h uman health effects of atrazine announced in October 2009. In prior years, however , no one would show up to stakeholder meetings, with the exception of when th e prohibition areas were initially created in the early 1990s. Wisconsin officials in dicated that growers would attend public meetings, but property owners with contamina ted wells would attend publicJune 2008-November 2010 Meeting Log for Atrazine Sp ecial Review Docket Page 10 of 10

meetings in support of creating the prohibition are as.

EPA wanted to know whether well construction was co nsidered an issue with regard to

atrazine contamination. Wisconsin officials indica ted that well depth is not a good predictor of atrazine levels in a well, and that th e most important variable in contamination is intensity of use.

EPA was interested in having the grower survey ment ioned earlier in the discussion, and Wisconsin officials offered to provide it when it b ecame available.

Meeting notes prepared by – Melanie Biscoe

Participants: Anne Overstreet, EPA/OPP/PRD Melanie Biscoe, EPA/OPP/PRD Peter Caulkins, EPA/OPP Nelson Thurman, EPA/OPP/EFED Bill Chism, EPA/OPP/BEAD Bill Phillips, EPA/OPP/BEAD David Donaldson, EPA/OPP/BEAD Timothy Kiely, EPA/OPP/BEAD Jonathan Becker, EPA/OPP/BEAD Jeff Postle, Wisconsin Department of Agriculture, T rade and Consumer Protection (on phone) Jim Vanden Brook, Wisconsin Department of Agricultu re, Trade and Consumer Protection (on phone) Lori Bowman, Wisconsin Department of Agriculture, T rade and Consumer Protection (on phone)