Caltha LLP Project Summary
Project: Summary of the Occurrence of Herbicide in Surface Water To Support Comments On USDA Draft Environmental Assessment
Client: Agricultural Chemical Manufacturer
Location(s): California, Illinois, Texas, Minnesota
Key Elements: Acquisition and review of state water quality monitoring data; statistical analysis of the occurrence and concentrations of herbicide in surface water, preparation and submittal of public comments to Department of Agriculture Draft Environmental Assessment
Overview: Caltha was contracted by this multinational agricultural chemical company to prepare a review and analysis of the occurrence of a specific common use herbicide, 2,4-D, in waters of the United States. Caltha first reviewed and summarized nationwide data in the US EPA STORET database and U.S Geological Survey (USGS) National Water-Quality Assessment (NAWQA) Program database. Caltha staff then contacted State agencies which implemented long-term Statewide water quality monitoring programs, including California, Texas, Illinois and Minnesota. All data were then compiled to provide a summary of 2,4-D concentrations in surface waters dating from the 1970s through 2012.
Caltha then conducted a review of federal and state regulatory standards for 2,4-D in surface waters, including:
• Federal Water Quality Criteria
• State Water Quality Standards
• Federal Safe Drinking Water Act Maximum Contaminant Level
• Office of Pesticide Program Aquatic Life Benchmarks
Finally, Caltha conducted an analysis of the exceedance of applicable regulatory standards based on the comprehensive analysis of reported herbicide concentrations. All analyses were summarized in a report which was submitted to the US Department of Agriculture through its public comment process for a Draft Environmental Assessment document.
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