Poisoning The Well

Poisoning the Well
August 2009
How the EPA is Ignoring Atrazine

Contamination in Surface and Drinking
Water in the Central United States
Authors
Mae Wu
Mayra Quirindongo
Jennifer Sass Blank Page i

Andrew Wetzler
Poisoning the Well: How the EPA Is Ignoring Atrazine Contamination in Surface and Drinking Water in the Central United States
About NRDC
The Natural Resources Defense Council (NRDC) is a national nonprofit environmental organization with more than
1.2 million members and online activists. Since 1970, our lawyers, scientists, and other environmental specialists have
worked to protect the world’s natural resources, public health, and the environment. NRDC has offices in New York
City, Washington, D.C., Los Angeles, San Francisco, Chicago, Montana, and Beijing. Visit us at www.nrdc.org.
Acknowledgments
The Natural Resources Defense Council gratefully acknowledges the Holthues and the Park Foundation for their
generous support of our work. The authors would also like to thank those people that provided review and com-
ments on this report, including NRDC scientific staff and scientific experts from government and academia.
NRDC Director of Communications: Phil Gutis

NRDC Marketing and Operations Director: Alexandra Kennaugh
NRDC Publications Director: Lisa Goffredi
NRDC Publications Editor: Anthony Clark
Production: Tanja Bos, tanja@bospoint.com
Copyright 2009 by the Natural Resources Defense Council.
This report is printed on paper that is 100 percent post-consumer recycled fiber, processed chlorine free.
ii
Table of Contents
Executive Summary iv

Chapter 1: An Atrazine Primer 3
Atrazine’s Uses and Risks
The Recent Lackluster Regulatory Record

Chapter 2: Harmful Effects of Atrazine 5
Early Life Stages are Particularly Sensitive to Toxic Exposures
Atrazine is an Endocrine-Disrupting Chemical
Atrazine May Increase Risk of Cancer
Synergistic Effects of Atrazine with Other Pesticides
Additional Points of Concern

Chapter 3: Atrazine Contamination is a Widespread Problem 8
NRDC’s New Analysis and Synthesis of Atrazine Data
Watersheds are Excessively Contaminated with Atrazine
High levels of Atrazine in Drinking Water Systems is Cause for Alarm
There Are Minimal Benefits from Atrazine Use

Chapter 4: Atrazine Monitoring is Misleading and Its Regulation Insufficient 17
The EPA is Ignoring the Atrazine Problem
Monitoring Programs Were Not Designed to Find the Biggest Problems
Screening Levels Are Too Permissive
The EPA Monitoring Program Ignores More Than 1000 Vulnerable Watersheds
Chapter 5: Recommendations 21
Endnotes 23
iii
Executive Summary
B
anned in the European Union and clearly linked to harm to wildlife and
potentially to humans, the pesticide atrazine provides little benefit to offset
its risks. In this report, NRDC brings together for the first time the results
of surface water and drinking water monitoring required by the U.S. EPA to create
a more comprehensive analysis of atrazine pollution across the Midwestern and
Southern United States. We found that the U.S. EPA’s inadequate monitoring systems
and weak regulations have compounded the problem, allowing levels of atrazine in
watersheds and drinking water to peak at extremely high concentrations. Given the
pesticide’s limited usefulness and the ease with which safer agricultural methods can
be substituted to achieve similar results, NRDC recommends phasing out the use of
atrazine, more effective atrazine monitoring, the adoption of farming techniques that
can help minimize the use of atrazine and prevent it from running into waterways,
and the use of home filtration systems by consumers.
An Atrazine Primer The U.S. Environmental Protection Agency (EPA)

Atrazine is a selective herbicide applied to fields at regulates the use of atrazine as well as the presence of
the beginning of the growing season to kill weeds.1 In atrazine in drinking water. Under the Safe Drinking
the United States alone, between 60 and 80 million Water Act (SDWA), the EPA has determined that no
pounds of atrazine are used each year, mainly on corn more than 3 parts per billion (ppb) of atrazine (as a
crops. Because of its widespread use, atrazine is the running annual average)3 may be present in drinking
most commonly detected pesticide in U.S. waters. water. Under the Federal Insecticide, Fungicide, and
Approximately 75 percent of stream water and about Rodenticide Act (FIFRA), the EPA allows atrazine
40 percent of all groundwater samples from agricultural to be used on, among other things, corn, sorghum,
areas tested in an extensive U.S. Geological Survey sugarcane, and lawns. Despite the fact that atrazine
study contained atrazine.2 Although the European used in fields eventually ends up in surface water and
Union banned the pesticide in 2004, atrazine is still treated drinking water, the regulation of atrazine under
widely used in the United States. these two statutes is not coordinated.
iv
The Dangers of Atrazine Are Well 4 Nine of the monitored watersheds (22 percent)
Documented had at least one sample showing atrazine levels
The toxicity associated with atrazine has been above 50 ppb, and four watersheds (10 percent)
documented extensively. The adverse reproductive had peak maximum concentrations of atrazine
effects of atrazine have been seen in amphibians, exceeding 100 ppb. At Little Pigeon Creek in
mammals, and humans—even at low levels of Indiana, the annual average atrazine concentration
exposure. Concentrations as low as 0.1 ppb have been was 18.56 ppb, but the maximum concentration
shown to alter the development of sex characteristics was a staggering 237.5 ppb, detected in May 2005.
in male frogs, resulting in male frogs with female sex
characteristics, hermaphroditism and the presence of High Levels of Atrazine in Many Drinking
eggs in male frog testes.4 When exposure coincides with Water Systems are Also Cause for Alarm
the development of the brain and reproductive organs, Our analysis of the EPA’s Atrazine Monitoring Program
that timing may be even more critical than the dose.5, data also reveals disturbingly high levels of atrazine
6 Also of great concern is the potential for atrazine to contamination in the drinking water in some public
act synergistically with other pesticides to increase their water systems.
toxic effects. 4 More than 90 percent of the samples taken in 139
water systems had measurable levels of atrazine in
both 2003 and 2004.
NRDC’s New Analysis Reveals 4 Three water systems had running annual averages
Widespread Atrazine Contamination and for atrazine in finished (tap)7 water that exceeded
Inadequate Regulation and Monitoring the 3 ppb drinking water standard: Versailles
NRDC analyzed—in combination for the first Water Works in Indiana (4.60 ppb), Mount Olive
time—the results of surface water and drinking water Water Works in Illinois (3.79 ppb), and Evansville
monitoring required by the EPA across the Midwestern in Illinois (3.20 ppb).
and Southern United States. NRDC obtained these 4 Fifty-four water systems (39 percent) had a one-
data from the EPA’s Ecological Watershed Monitoring time peak atrazine concentration above 3 ppb. The
Program (surface water) and the EPA’s Atrazine highest peak concentration of atrazine in finished
Monitoring Program (drinking water) as part of the water among all tested public water systems
settlement of litigation brought against the EPA and in was 39.69 ppb in the Evansville water system in
response to two Freedom of Information Act (FOIA) Randolph County, Illinois.
requests submitted to the agency. Our analysis resulted
in seven major findings: The EPA is Ignoring the Atrazine Problem
Because of the potential adverse effects associated with
Watersheds are pesticides Contaminated even short exposures to atrazine, the spikes detected in
with Atrazine the watersheds and the public drinking water systems
Our analysis of the Ecological Monitoring Program are particularly alarming. Yet, because the EPA focuses
data confirms that the surface waters of the Midwestern on average concentrations of atrazine, it has ignored
and Southern United States suffer from pervasive these peaks.
contamination with atrazine.
4 All 40 watersheds tested showed detectable levels Monitoring Programs Were Not Designed
of atrazine, and 25 had average concentrations to Find the Biggest Problems
above 1 ppb, which is the concentration at which The EPA’s monitoring program for atrazine was poorly
the primary production of aquatic non-vascular designed and is not apt to find the most troubling
plants (such as algae) is reduced. results, which makes the statistics even more alarming.
4 The watersheds with the 10 highest peak For example, samples taken before a rainstorm washes
concentrations of atrazine are in Indiana, Missouri, pesticides into a watershed will show much lower
and Nebraska. concentrations of pesticide than samples taken after a
rainstorm, which can capture the contaminated field
v
MAXIMUM REGIONAL ATRAZINE CONCENTRATIONS

by EPA sampled watersheds
Minneapolis
MINNESOTA
MN-01
WISCONSIN
CANADA
Detroit
IL-01
IA-01
NEBRASKA Chicago
IL-02 Cleveland
IA-02 IOWA
NE-02 * IN-03 and IN-05 share the
OHIO
IL-03 same watershed. The color OH-01
Omaha IN-02
IN-03
represents the sample with
IN-01 the higher maximum atrazine
value.
IN-05
IL-04
NE-03 NE-01 IN-04
IL-05
OH-02
NE-04 and NE-07: OH-03
maximum values IN-09
IL-07 IN-06
of atrazine exceed
IL-06 IN-07 Columbus
100 ppb. MO-01:
NE-07 maximum value
NE-04 NE-05 OH-04
of atrazine exceeds MO-01 IN-10
NE-06
100 ppb.
* NE-04 and NE-07 share the IN-08
same watershed.
IL-08
IL-09
MO-02
MO-03 INDIANA
KANSAS
Saint Louis Louisville
Lexington
ILLINOIS KY-01
Mi
Maximum Atrazine Concentra ons (ppb) ss IN-11
iss
Watershed Name Watershed ID Max. Watershed Name Watershed ID Max.
ipp
i
KY-02
Pine Creek IL-02 Wichita 4.86 Whitewater, Nolans Fork IN-08 21.11
Riv
Suger Creek West Fork IL-06 5.26 Mad River OH-03 21.5 MISSOURI IN-11: KENTUCKY
er
Nishnabotna River IA-02 5.53 Grindstone Creek IL-07 21.75 maximum value
Spring Creek IL-03 5.63 Panther Creek IL-05 22.13 of atrazine exceeds
Mill Creek IN-01 8.63 Brashears Creek KY-01 22.4 100 ppb.
Wolf Creek IA-01 10.03 White River IN-07 22.55
Obion Middle Fork TN-01 10.7 Vermilion River, North IN-06 24.3
Iroquois River IL-04 11.5 Raccoon Creek IN-09 34.49
Pla e River NE-03 11.92 Crooked Creek NE-06 36.13
Peca onica River IL-01 13.18 Limber Lost Creek IN-05 41.3
Whitewater North Fork MN-01 15.03 Muddy Creek (NE) NE-05 49.87
Muddy Creek (IL) IL-09 16.02 Tulsa
Horse Creek IL-08 50.7 Max Atrazine (ppb) TN-01
Brandywine Creek IN-10 16.4 Youngs Creek MO-02 53.75
TENNESSEE
< 2.0
Eightmile Creek IN-03 16.9 Li le Sni-A-Bar Creek MO-03 59.03 2.1 - 3.0
3.1 - 6.0
Licking River, North Fork OH-02 18.13 Rock Creek IN-04 78.08 6.1 - 9.0
Kokosing River Oklahoma City
OH-01 18.34 Middle Loup Creek NE-02 82 9.1 - 25.0
Wahoo Creek NE-01 19.25 Big Blue River, Lower Gage NE-07 112.19 > 25.1
Twomile Creek KY-02 19.33 Big Blue River, Upper Gage NE-04 125 Memphis
Deer Creek OH-04 20.15 South Fabious River MO-01 182.75
Eel River IN-02 20.33 Li le Pigeon Creek IN-11 237.5 0 75 150
Miles
runoff. Similarly, sampling conducted when fields incorrectly predicting no significant adverse effects 8
have not yet been treated will result in low to no percent of the time. Although the EPA is considering
detections of contamination. Because the monitoring alternate models, its data analysis is still driven by
program was not designed to account for the timing effects on aquatic plants, effectively ignoring low-dose
of runoff in response to weather event or application, endocrine-disrupting effects.
the EPA’s watershed monitoring program probably
underestimates peak exposures. The EPA Monitoring Program is Ignoring
More Than 1000 Other Vulnerable
Screening Levels Are Too Permissive Watersheds
The EPA’s threshold of concern derived from The EPA has yet to act to reduce risks in most of
computer modeling considered the impact of atrazine the watersheds that it has identified as vulnerable to
contamination on plants, but not its toxic effects on atrazine contamination. In designing its watershed
aquatic animals that have been shown to occur at lower monitoring program, the EPA and the manufacturer of
levels. Therefore, the endocrine-disrupting effects of atrazine, Syngenta, in a secretly negotiated agreement,
atrazine on animals were not incorporated into the chose to examine just 40 watersheds for atrazine levels,
determination of the level of concern associated with after determining that atrazine concentrations in
the contamination in the watershed. In addition, the these watersheds would be statistically representative
U.S. Fish and Wildlife Service criticized the model for of the 1,172 most vulnerable watersheds in the
vi
country. Indeed, based on the results of its watershed of nonchemical techniques for weed control.
monitoring program, the EPA itself preliminarily These include crop rotation, the use of winter
estimated that 101 (9 percent) of the 1,172 watersheds cover crops, alternating rows of different crops,
would exceed the (inadequate) level of concern and mechanical weed control methods. Timing
for atrazine contamination and would require risk fertilizer applications to coincide with periods
mitigation measures.8 To date the EPA has still not of greatest nutrient uptake by crops can avoid
ordered mitigation steps in these watersheds. unnecessary fertilizer use that would fuel weed
growth.
Atrazine Use Brings Minimal Benefits
Data suggest that atrazine provides, at best, only 3. The EPA should monitor all vulnerable
minimal economic benefits to the farmers who use it. watersheds and require all future monitoring
The U.S. Department of Agriculture estimates a ban plans to identify worst case scenarios.
on atrazine would result in crop losses of only 1.19 The EPA should broaden the monitoring program
percent and decrease corn acreage in production by to assess all watersheds identified as vulnerable.
just 2.35 percent. Italy and Germany (both of which Future monitoring plans should be designed to
banned atrazine nearly 20 years ago) have not seen identify the worst case scenarios occurring in
any drop in corn productivity or total acreage of land vulnerable watersheds and in public water systems.
in production for corn since their ban on atrazine was Proper timing for sampling after big rainstorms
put in place, although this was due in part to the use and after fields have been treated with atrazine is
of other hazardous pesticides. However, Integrated Pest recommended. This would provide a much more
Management techniques could help farmers eliminate realistic view of the actual severity of the atrazine
the use of atrazine and control weeds while reducing problem.
their use of other dangerous chemicals.
4. The EPA should publish monitoring results
for each watershed and public water system
Recommendations for Protecting Human sampled.
Health and the Environment Monitoring results on the watersheds and the
NRDC recommends the following steps be taken public water systems that were sampled under the
to reduce atrazine contamination in U.S. waters two different monitoring programs were first made
and minimize its impacts on human health and the available to NRDC through FOIA requests and
environment: litigation. However, people who live downstream
of atrazine-treated fields have a right to know
1. The United States should phase out the use of about high levels of atrazine contamination in
atrazine. their watersheds or drinking water systems. A
Given the evidence of atrazine’s toxic effects on publicly available website posting sampling data
sensitive wildlife species and its potential risk to as it is analyzed and regular reports about spikes
human health, the currently high contamination of atrazine contamination would be a strong
levels in the Midwestern and Southern United step in the right direction, providing accessible
States, and the lack of compelling evidence that information to the public.
the herbicide is particularly useful to farmers,
NRDC strongly recommends that atrazine 5. The public should use home water filtration
be phased out of all uses in the United States, systems and demand transparency of
including home gardens and golf courses. information from their water utilities.
NRDC recommends that consumers concerned
2. Farmers should take interim steps to reduce about atrazine contamination in their water use
their atrazine use. a simple and economical household water filter,
Farmers can take immediate steps to reduce their such as one that fits on the tap. Consumers should
use of atrazine, including implementing a variety make sure that the filter they choose is certified
vii
by NSF International to meet American National

Standards Institute (ANSI) Standard 53 for VOC
(volatile organic compounds) reduction and
therefore capable of significantly reducing many
health-related contaminants, including atrazine
and other pesticides. A list of NSF/ANSI 53
certified drinking water filters is available at
http://www.nsf.org/certified/dwtu.
Make Our Drinking Water Safer

NRDC wants to know how public water
systems treat for atrazine and other dangerous
contaminants. Consumers should contact their
local water utility and ask about treatment of the
water supply, fill in the online form and send
NRDC the results. Providing this information to
NRDC will help us collect information on how
public water systems are treating for contaminants.
Visit the NRDC SimpleSteps site at

www.simplesteps.org/atrazine to view the
questions and form.
viii
Chapter 1
An Atrazine Primer
A
trazine, one of the most commonly used herbicides, is applied to soil before
crop planting to selectively suppress the growth of broadleaf and grassy
weeds. In the United States alone, an estimated 60 to 80 million pounds of
atrazine active ingredient are applied annually to corn, sugarcane, and sorghum crops.
Worldwide, approximately 154 million pounds of atrazine are produced annually,9
primarily by Syngenta Crop Protection, a Swiss-based company (formerly a unit of
Novartis and, before that, CibaGeigy).10
Atrazine’s Uses and Risks The Recent Lackluster Regulatory

Because it is applied in the spring before crops are Record
planted, when rains are frequent, atrazine is often The EPA registers pesticides under the authority of the
transported in runoff from fields to nearby streams and Federal Insecticide, Fungicide, and Rodenticide Act
other surface water. Atrazine is the most frequently (FIFRA). To approve a pesticide for use, the EPA must
detected pesticide in U.S. waters.11 Between 1992 find that it can be used without causing “unreasonable
and 2001, atrazine and its metabolites (over time, adverse effects on the environment.”14 This finding
atrazine breaks down into toxic and persistent chemical must “take into account the economic, social, and
compounds called chlorotriazines) were detected in environmental costs and benefits…that result from a
more than 75 percent of stream samples and about 40 use of a pesticide.”15 FIFRA also required the EPA to
percent of shallow groundwater samples in agricultural reevaluate and reregister all pesticides, such as atrazine,
areas across the United States.12 registered before November 1, 1984.16 If the EPA
This report compiles results collected by the U.S. determines that a pesticide poses a significant hazard,
Environmental Protection Agency (EPA) on atrazine it has the authority to conduct an administrative
concentrations in vulnerable rivers and streams and review of the chemical at any time. If it is shown
in raw and finished drinking water throughout the that continued use would pose unreasonable risks to
central and southern United States.13 Presented here humans or wildlife, the EPA is obligated to suspend
together for the first time, these data show that atrazine or cancel the pesticide’s registration to take it off the
is a frequent contaminant of our waterways at levels market.17
that pose an ongoing risk to wildlife and possibly also The EPA separately regulates atrazine contamination
human health, saddling many small municipal and in drinking water through the Safe Drinking Water Act
rural drinking water systems with costly treatment (SDWA). Under the SDWA, the EPA sets Maximum
burdens, and providing little economic benefit to Contaminant Level Goals (MCLGs) for drinking water
farmers.
1
at which “no known or anticipated adverse effects” on in particular that are at highest risk from atrazine
human health occur and that “allow for an adequate contamination. Subsequently, the EPA and Syngenta
margin of safety.”18 Once MCLGs are established for a privately negotiated that Syngenta would monitor
contaminant, the EPA then sets enforceable Maximum atrazine pollution for two to three years in a small
Contaminant Levels (MCLs) as close as is “feasible” subset of the 1,172 high-risk streams. They agreed
to the MCLGs, considering the costs and benefits of Syngenta would begin monitoring 20 of the highest
compliance.19 risk streams in 2004, and add 20 more in 2005, thus
Recently, the EPA’s regulatory decisions about ignoring more than 96 percent of the streams that it
atrazine have been riddled with questions of had identified as being at highest risk. The EPA has
impropriety because of the significant and illegal since done little to protect these and other at-risk
discussions and negotiations between the EPA and watersheds from atrazine contamination.
the manufacturer spanning two years.20 In the end, Worse yet, carefully documented investigations
the EPA allowed the continued widespread use of a by NRDC revealed that the EPA’s monitoring and
hazardous herbicide that is contaminating many of our assessment plans were based on reports from two
streams, rivers, and drinking water. advisory groups that were comprised solely of EPA
Atrazine was first registered for use in the United and Syngenta employees.28 One advisory group
States in 1958. In 1988, the EPA announced its was tasked with identifying the watersheds to be
preliminary intention to conduct a “special review” of monitored and designing the monitoring study. The
atrazine under FIFRA because of concerns about “the other group was tasked with establishing the amount
carcinogenic potential of atrazine and possible risks of atrazine that aquatic plants could be exposed to
resulting from exposure to atrazine in the diet from without adverse effects on the ecosystem. This use of
treated food and drinking water.”21 A few years later, non-public industry-government workgroups to make
in 1991, the EPA’s Office of Water began regulating regulatory determinations violated the Federal Advisory
atrazine in drinking water under the SDWA, by setting Committee Act (FACA). Based on all this improper
the MCL for atrazine in drinking water at 3 parts per assistance from the manufacturer of atrazine, the EPA
billion (ppb). This MCL is calculated as a running irresponsibly finalized its decision to allow atrazine to
annual average and is more permissive than the World remain on the shelves in the United States.
Health Organization’s international drinking water
guidance of an annual average of 2 ppb for atrazine.22,23
In 1991, Germany and Italy banned the use of
atrazine.24,25 In 2003, European regulators announced
their ban on atrazine use throughout the European
Union, because of an inability to keep levels below
0.1 ppb, the European Union’s uniform limit for any
pesticide residue in drinking and ground water.26
In 1994, the EPA initiated the special review of
the registration for atrazine. Despite determining
that there were ecological concerns associated with
the use of atrazine, the EPA nonetheless affirmed the
reregistration of atrazine in 2006, which allowed the
use of this herbicide to continue.27 Moreover, rather
than opting for a plan to reduce the use of atrazine, the
EPA instead chose to require only additional sampling
of watersheds vulnerable to atrazine contamination.
To implement the monitoring decision, the EPA
and Syngenta, the manufacturer of atrazine, together
identified some 10,000 watersheds at some risk
from atrazine contamination, and 1,172 watersheds
2
Chapter 2
Harmful Effects of Atrazine
N
RDC has been fighting for nearly a decade to phase out the use of atrazine
because of the adverse environmental and health effects associated with
its contamination of our waterways. The toxicity associated with atrazine
has been well documented, ranging from hormone-disrupting effects to carcinogenic
effects in animals and possibly in humans.
Early Life Stages are Particularly such as infertility or cancer, may not be obvious
Sensitive to Toxic Exposures until adulthood even though the exposure occurred
The regulation of hazardous materials in the U.S. is during fetal or neonatal life.33 This phenomenon has
generally based on the scientific dogma that the dose been demonstrated for atrazine in laboratory animals
makes the poison: the notion that larger doses are such as amphibians, where short exposures during
more toxic than smaller doses. This belief leads to the early developmental stages have had long lasting or
presumption that the chemical is “safer” at lower doses. even permanent irreversible effects on adult behavior
For this reason, and also because testing with low doses and longevity, including increased susceptibility to
is often not done for practical reasons, we rarely have infection,34 alterations in survival behavior,35, 36 and
reliable toxicity data of potential hazardous effects at reduced long-term survival.37 Laboratory studies and
low doses. Moreover, for chemicals that interfere with field studies have consistently reported that exposure
the development of critical organs or systems, such as of animals to atrazine during critical periods of early
organs of the immune system, reproductive system, development can lead to serious adverse health effects
and nervous system, there is now a substantial amount on hormone-dependent systems (discussed in more
of scientific proof that when exposure occurs at the detail in the following section).
same time that these critical systems are developing,
even transient low-dose exposures can cause irreparable
harm. That is, the timing of exposure may actually
be even more critical than the dose.29, 30 For example, Atrazine is an Endocrine-Disrupting
prebirth exposure to mercury, at levels so low that Chemical
effects are not detectable in an adult, will prevent Atrazine has been shown in numerous studies to
proper connections between the brain cells of the fetus, disrupt hormone activity in amphibians, particularly
resulting in lifelong alterations in brain structure and those exposed during early stages of development.38,39
function.31 Exposures to endocrine- (or hormone-) For example, exposure to 21 ppb of atrazine during
disrupting chemicals such as atrazine during critical metamorphosis for as little as two days has been shown
windows of development also have been shown to to impair development of the reproductive organs
have permanent effects.32 Some of these effects, in male and female frogs.40, 41 In fact, concentrations
3
as low as 0.1 ppb have been shown to affect the relevant to cancer risks from atrazine. The workgroups
development of female sex characteristics in male concluded that atrazine causes cancer in experimental
frogs and cause the development of eggs in male frog animals. However, the workgroups felt the evidence
testes.42 This suggests that exposure to elevated spikes from human data was insufficient to draw conclusions
of atrazine during critical windows of development, with confidence.55
even for short durations, may be the most relevant for While the EPA continues to classify atrazine as “not
predicting toxic effects. likely” to cause cancer in humans,56 this determination
The hormone-disrupting effects of atrazine are ignores the recommendations of its scientific advisory
not just limited to amphibians. Even before evidence panel that the EPA consider all the science, including
of hormone disruption activity had emerged in whether hormonal effects in childhood or adolescence
amphibians, EPA scientists and others had already may have an impact on cancer occurrence in later
reported that atrazine disrupts the normal progression years.57, 58
of sexual development in mammals. For example, one
study reported that atrazine reduced sperm motility in
male rats.43 In addition, there is disturbing evidence Synergistic Effects of Atrazine with
of reproductive effects, such as low sperm count Other Pesticides
and motility, in farm workers and rural populations Although many laboratory studies are designed with
exposed to atrazine and other triazine pesticides.44, 45, 46 care and precision to examine the effects of a single
The U.S. Fish and Wildlife Service (USFWS) chemical, usually at high doses, on biological systems,
has stated that “studies of the effects of atrazine this often represents an unlikely exposure scenario for
have documented potential adverse effects to fish wildlife and human populations, which are almost
and bivalves at exposure concentrations below those always exposed to multiple chemicals at the same time,
predicted by EPA and recorded through monitoring.”47 and often at lower doses than are tested in the lab.
Among those adverse effects are “organ tissue damage These single-chemical studies can thus underestimate
[and] disruption to endocrine and olfactory systems risks from exposure to a chemical when it is confronted
affecting important behavioral functions related to as a toxic mixture that commonly occurs in the
survival and reproduction….”48 The National Marine real world.59, 60 Atrazine has the potential to act
Fisheries Service has also noted risks of adverse effects synergistically with other chemicals to increase their
on the reproduction and behavior of fish and sea turtles toxic effects. For example, one assessment reported
from environmental concentrations of atrazine.49 that atrazine is more likely to cause non-Hodgkin’s
lymphoma in men when they are exposed to it in
combination with other pesticides.61 A laboratory
Atrazine May Increase Risk of Cancer study of frogs also reported an increase in mortality of
There is also evidence that links atrazine to cancer. tadpoles exposed to multiple pesticides at levels that
A robust review of all available science on atrazine were non-lethal when occurring individually
conducted by the International Agency for Research (0.1 ppb).62
on Cancer (IARC) reported numerous studies finding A recent study published in Nature provided strong
an increase in mammary gland tumors in female rats evidence from frog studies that atrazine suppresses
treated with atrazine from early life until adulthood.50 the immune system. This study found the presence of
Another series of rodent studies suggest that prenatal atrazine to be a strong predictor of parasitic flatworm
atrazine exposure may alter breast development and larvae, which can cause severe limb deformities
increase the risk of breast cancer in adulthood.51, 52 and kidney damage to amphibians, in declining
Limited studies of people occupationally exposed to populations of northern leopard frogs. Importantly, the
atrazine suggested that atrazine exposure may be linked study also concluded that the combination of atrazine
to an increased incidence of cancers in humans, in and phosphate—widely used in fertilizer for corn
particular non-Hodgkin’s lymphoma.53, 54 In 1991 and and sorghum production—significantly increased the
1999, the IARC Monographs Programme convened a presence of the flatworm.63
workshop of scientific experts to review available data
4
These studies raise serious concerns, since

simultaneous exposure to multiple pesticides is routine
for human and wildlife populations. A U.S. Geological
Survey study of 51 major hydrologic systems in the
U.S. found that about 90 percent of the time, stream
waters in agricultural, urban and mixed land use areas
contained two or more pesticides or their metabolites.64
About 20 percent of the time they contained ten or
more pesticide contaminants.65 By failing to consider
exposure to atrazine with other co-contaminants, the
risks posed by atrazine in the real world are likely to be
underestimated significantly.
Additional Points of Concern

The EPA recognized several endpoints of concern for
atrazine when developing its Interim Reregistration
Eligibility Decision (IRED) for atrazine in 2003, based
on laboratory and field studies involving exposure
to the pesticide for various durations. For example,
a particularly important ecological endpoint is
phytotoxicity: the reduction in aquatic plants that are
crucial to the proper functioning of the food chain in
a watershed. Just one week of exposure to atrazine at
1 ppb caused adverse effects on these aquatic plants,
as the EPA acknowledged in the IRED.66 The EPA
set its level of concern for the Ecological Watershed
Monitoring Program based on atrazine’s effects on
aquatic plants, but the model and assumptions it uses
fail to account for other effects occurring at lower
doses—such as endocrine-disrupting effects at levels
below 1 ppb—in establishing its benchmark level of
concern.
5
Chapter 3
Atrazine Contamination is a
Widespread Problem
T
his report provides the first publicly available analysis of the EPA’s monitoring
results for atrazine in surface water and in drinking water. NRDC obtained
and analyzed data on thousands of monitoring samples from rivers, streams,
and public drinking water systems in the Midwest and the South.
NRDC’s New Analysis and Synthesis of Raw water refers to drinking water before it is treated,
Atrazine Data and finished water refers to treated drinking water that
NRDC obtained these data directly from the EPA. has undergone disinfection and/or filtration and is
The data were collected under two separate agency ready to be sent to consumers. Samples from the 139
programs: the Ecological Watershed Monitoring public water systems in ten Midwestern and Southern
Program and the Atrazine Monitoring Program.67 states in the program were tested for both atrazine and
The Ecological Watershed Monitoring Program data total chlorotriazines (compounds formed from atrazine
were released as a condition of a lawsuit brought by as it degrades). These water systems were frequently
NRDC against the EPA for approving the continued tested for atrazine: once per week during the atrazine
use of atrazine without adequately considering its use season (spring and summer), and once every
risk to endangered species. The Atrazine Monitoring two weeks during the rest of the year. Sampling still
Program data were obtained through two Freedom of continues under the Atrazine Monitoring Program.
Information Act requests submitted to the EPA.
Under the Ecological Watershed Monitoring
Program, companies trying to register atrazine for use Watersheds are Excessively
under FIFRA were required to monitor surface water Contaminated with Atrazine
in vulnerable watersheds.68, 69 After identifying 1,172 After analyzing the data from the Ecological Watershed
watersheds at high risk of atrazine contamination, 40 Monitoring Program, we were alarmed to find that
watersheds (in nine Midwestern and Southern states) in all the areas sampled (especially large parts of the
were selected for stream water testing for atrazine. Midwest) atrazine contamination is pervasive. Not
The samples were taken every four days between April only was every watershed sampled contaminated
and late summer from 2004 to 2006. These results with some amounts of atrazine, the contamination
represent all the data taken under this program. in many watersheds exceeded atrazine concentrations
Under the Atrazine Monitoring Program, registrants that the EPA acknowledges are associated with adverse
are required to test both raw and finished drinking effects. Out of the 40 watersheds sampled, 25 had
water samples from selected public water systems.70, 71 annual average atrazine levels above 1 ppb—the level
6
associated with a reduction in primary production in these peaks one-day anomalies. Four watersheds had
non-vascular aquatic plants (e.g., algae). (See Figure 1.) peak concentrations above 25 ppb lasting at least three
In fact, the annual average concentration in 21 of those consecutive days, while three of those watersheds had
25 watersheds exceeded 1 ppb for two, and sometimes peak concentrations above 50 ppb for at least three
three, consecutive years. More importantly, because consecutive days. Atrazine contamination in one
this threshold is based on exposure to 1 ppb of atrazine watershed in Indiana peaked at a staggering 237.5 ppb.
for one week, it is particularly disturbing that 31 (See Table 1.) High peak concentrations of atrazine
watersheds had concentrations of atrazine higher than that last for a few days or weeks can pose significant
1 ppb for at least one week. risks to wildlife—especially if they occur during the
More worrisome than the average concentrations critical stages of development. (See Chapter 2.) The
of atrazine were the data showing that dangerously fact that the peak concentrations usually occur in the
high peak concentrations of atrazine were occurring spring, which coincides with the period of early life
in these watersheds. Nine watersheds had at least one development for aquatic organisms, only intensifies the
maximum peak above 50 ppb, and four watersheds concern about the contamination.
had maximum peaks exceeding 100 ppb. Nor were
AVERAGE ATRAZINE
Figure
by EPA sampled
CONCENTRATIONS
1:watersheds
Average
Regional Atrazine Contamination
Minneapolis Lake Hur on
MINNESOTA MN-01
WISCONSIN
CANADA
Lake Michigan
Detroit
IL-01
Lake Er ie
IA-01
NEBRASKA Chicago
IL-02 Cleveland
IA-02 IOWA
NE-02
IL-03 * IN-03 and IN-05 share the OHIO
same watershed. The color OH-01
Omaha IN-02
IN-03
the higher mean atrazine
IN-01 value.
IN-05
IL-04
NE-03 NE-01 IN-04
IL-05
OH-02
IN-09 OH-03
IL-07 IN-06
NE-07
NE-04 NE-05 OH-04
MO-01 IN-10
NE-06
same watershed. The color
represents the sample with IL-08
the higher mean atrazine
value. IL-09
MO-02
MO-03 INDIANA
KANSAS
Lexington
KY-01
Mi ILLINOIS
Average Atrazine Concentra ons (ppb) ss IN-11
iss
Watershed Name Watershed ID Mean Watershed Name Watershed ID Mean
ipp
i KY-02
Spring Creek IL-03 Wichita 0.21 Eightmile Creek IN-03 1.49
Riv
Suger Creek West Fork IL-06 0.34 Rock Creek IN-04 1.52 MISSOURI KENTUCKY
er
Wolf Creek IA-01 0.38 Vermilion River, North IN-06 1.53

Pla e River NE-03 0.43 Mad River OH-03 1.55
Whitewater North Fork MN-01 0.47 Whitewater, Nolans Fork IN-08 1.58
Pine Creek IL-02 0.55 Wahoo Creek NE-01 1.78
Panther Creek IL-05 0.57 Muddy Creek (IL) IL-09 1.80
Iroquois River IL-04 0.63 Twomile Creek KY-02 2.08
Nishnabotna River IA-02 0.65 Raccoon Creek IN-09 2.53
Brashears Creek KY-01 0.66 Horse Creek IL-08 2.72
Pecatonica River IL-01 0.67 Middle Loup Creek NE-02 2.77
Grindstone Creek IL-07 0.71 Tulsa
Limber Lost Creek IN-05 2.89 Mean Atrazine (ppb) TN-01
Mill Creek IN-01 0.71 Muddy Creek (NE) NE-05 3.12 < 1.0 TENNESSEE
1.1 - 2.0
Deer Creek OH-04 0.81 Li le Sni-A-Bar Creek MO-03 3.80 2.1 - 3.0
Kokosing River OH-01 0.86 Eel River IN-02 4.52 3.1 - 6.0
6.1 - 9.0
Crooked Creek Oklahoma City
NE-06 1.16 Big Blue River, Lower Gage NE-07 4.66
9.1 - 25.0
White River IN-07 1.26 Li le Pigeon Creek IN-11 7.50 > 25.1
Obion Middle Fork TN-01 1.31 Youngs Creek MO-02 7.56 Memphis
Licking River, North Fork OH-02 1.31 South Fabius River MO-01 8.78
Brandywine Creek IN-10 1.49 Big Blue River, Upper Gage NE-04 14.31 0 75 150
Miles
7
Table 1: Ten watersheds with the highest peak concentrations of atrazine,

Ecological Watershed Monitoring Program
Watershed name Sampling year Atrazine concentration (ppb)

Max. peak 75th percentile Average
Little Pigeon Creek, IN 2005 237.50 5.02 18.56
South Fabius River, MO* 2005 182.75 8.82 9.61
Big Blue River, Upper Gage, NE 2006 125.00 5.10 17.61
Big Blue River, Lower Gage, NE 2005 112.19 1.54 7.85
Middle Loup Creek, NE 2006 82.00 0.40 2.79
Rock Creek, IN 2004 78.1 0.68 2.76
Little Sni-A-Bar Creek, MO 2004 59.03 3.88 4.42
Youngs Creek, MO 2004 53.75 9.69 8.89
Horse Creek, IL 2006 50.7 0.85 2.58
Muddy Creek, NE 2005 49.87 1.97 4.67
* The South Fabious River wastershed had 3 of the 15 highest peak concentrations: 182.75 ppb (2005); 106 ppb (2006);
and 82.8 ppb (2006).
Figure 2 presents a map highlighting the maximum of atrazine in raw water during the monitoring period,
concentrations detected in each watershed sampled in as well as the spring quarter and the summer quarter
the Ecological Watershed Monitoring Program. To see averages in the year that the peak was measured. The
the sampling results for each state in the monitoring table also shows the concentration of atrazine in the
program, see Appendix A. next sample taken and the number of days between
readings. In some cases, the peak concentration fell
below 3 ppb within six or seven days after the peak
High Levels of Atrazine in Drinking reading; however, in a few cases (Missouri, Ohio, and
Water Systems Are Cause for Alarm Texas) the high concentrations remained up to two or
Our analysis of the drinking water data from the three weeks after the peak sample was taken. (Note,
Atrazine Monitoring Program was no less shocking. the table identifies both the atrazine concentration for
Based on more than 14,000 samples taken in 2003 and the sample(s) following the peak concentration and the
2004 representing 139 public water systems, we found number of days that sample(s) was taken after the first
atrazine was detected in more than 90 percent of the sample.) Not surprisingly, the quarter with the highest
samples each year. These water systems were located in peak concentration of atrazine usually had a higher
ten states in the Midwest and the South. average concentration.
For samples of raw water, we found that 87 We found three water systems with running annual
sampling sites (representing 81 water systems in nine averages of atrazine in finished water—that is, water
states) had maximum concentrations above 3 ppb.72 In ready for human consumption—that exceeded the
fact, the Winterset Water Treatment Plant in Winterset, federal drinking water standard of 3 ppb: Versailles,
Iowa had a maximum concentration of atrazine in raw Indiana (4.60 ppb), Mt. Olive, Illinois (3.79 ppb) and
water of 47.5 ppb. Evansville, Illinois (3.20 ppb). We further found that
In Table 2 (page 10), we identify the water system 56 sampling sites (representing 54 water systems) had
in each state that had the highest peak concentration one-time peak atrazine concentrations in finished water
8
MAXIMUM
Figure 2: Map
by EPA sampled
REGIONAL
of maximum
watersheds atrazineATRAZINE
concentrationsCONCENTRATIONS
in all watersheds sampled
Minneapolis
MINNESOTA
MN-01
WISCONSIN
CANADA
Detroit
IL-01
IA-01
NEBRASKA Chicago
IL-02 Cleveland
IA-02 IOWA
NE-02 * IN-03 and IN-05 share the
OHIO
IL-03 same watershed. The color OH-01
Omaha IN-02
IN-03
IN-01 the higher maximum atrazine
value.
IN-05
IL-04
NE-03 NE-01 IN-04
IL-05
OH-02
NE-04 and NE-07: OH-03
maximum values IN-09
IL-07 IN-06
of atrazine exceed
100 ppb. MO-01:
NE-07 maximum value
NE-04 NE-05 OH-04
of atrazine exceeds MO-01 IN-10
NE-06
100 ppb.
same watershed.
IL-08
IL-09
MO-02
MO-03 INDIANA
KANSAS
Lexington
ILLINOIS KY-01
Mi
Maximum Atrazine Concentra ons (ppb) ss IN-11
iss
Watershed Name Watershed ID Max. Watershed Name Watershed ID Max.
ipp
i
KY-02
Pine Creek IL-02 Wichita 4.86 Whitewater, Nolans Fork IN-08 21.11
Riv
Suger Creek West Fork IL-06 5.26 Mad River OH-03 21.5 MISSOURI IN-11: KENTUCKY
er
Nishnabotna River IA-02 5.53 Grindstone Creek IL-07 21.75 maximum value
Spring Creek IL-03 5.63 Panther Creek IL-05 22.13 of atrazine exceeds
Mill Creek IN-01 8.63 Brashears Creek KY-01 22.4 100 ppb.
Wolf Creek IA-01 10.03 White River IN-07 22.55
Obion Middle Fork TN-01 10.7 Vermilion River, North IN-06 24.3
Iroquois River IL-04 11.5 Raccoon Creek IN-09 34.49
Pla e River NE-03 11.92 Crooked Creek NE-06 36.13
Peca onica River IL-01 13.18 Limber Lost Creek IN-05 41.3
Whitewater North Fork MN-01 15.03 Muddy Creek (NE) NE-05 49.87
Muddy Creek (IL) IL-09 16.02 Tulsa
Horse Creek IL-08 50.7 Max Atrazine (ppb) TN-01
Brandywine Creek IN-10 16.4 Youngs Creek MO-02 53.75
TENNESSEE
< 2.0
Eightmile Creek IN-03 16.9 Li le Sni-A-Bar Creek MO-03 59.03 2.1 - 3.0
3.1 - 6.0
Licking River, North Fork OH-02 18.13 Rock Creek IN-04 78.08 6.1 - 9.0
Kokosing River Oklahoma City
OH-01 18.34 Middle Loup Creek NE-02 82 9.1 - 25.0
Wahoo Creek NE-01 19.25 Big Blue River, Lower Gage NE-07 112.19 > 25.1
Twomile Creek KY-02 19.33 Big Blue River, Upper Gage NE-04 125 Memphis
Deer Creek OH-04 20.15 South Fabious River MO-01 182.75
Eel River IN-02 20.33 Li le Pigeon Creek IN-11 237.5 0 75 150
Miles
above 3 ppb—with one peak reaching an astounding

39.69 ppb.73
In addition to the peak concentrations of atrazine
in finished water, Table 3 (page 11) provides the
average concentrations of atrazine in the spring quarter,
summer quarter, and the running annual average for
the whole year corresponding to the time that the
highest peak concentration was detected.
9
Table 2: Water systems with the highest atrazine concentrations in raw water
in each state, 2003–2004
State Water system City Peak Spring Summer Next reading after peak
concentration quarter quarter (time since peak reading)
(ppb) atrazine atrazine
average average
(ppb) (ppb)
Wayne City
33.08
Illinois (Skillet Fork Springfield 7.27 3.48 0.71 ppb (6 days later)
(27-May-03)
Creek)
24.75
Indiana Logansport Logansport 3.35 0.57 2.11 ppb (7 days later)
(10-May-04)
Winterset Water 47.50
Iowa Winterset 4.27 1.75 0.13 ppb (7 days later)
Treatment Plant (10-May-04)
Beloit Water 10.74
Kansas Beloit 2.34 1.60 1.68 ppb (7 days later)
Department (13-May-03)
Leitchfield Water 4.88
Kentucky Leitchfield 2.36 1.92 2.73 ppb (7 days later)
Works (26-Apr-04)
Iberville Water 12.38
Louisiana Plaquemine 2.50 1.28 2.36 ppb (6 days later)
District #3 (23-Mar-04)
Next three readings:
Vandalia Water 11.11 7.94 ppb (7 days later);
Missouri Vandalia 2.23 4.52
Treatment Plant (16-Jun-03) 5.68 ppb (14 days later);
4.7 ppb (21 days later)
North 1.71
Monroe Monroe 0.44 0.69 0.33 ppb (7 days later)
Carolina* (17-May-04)
Piqua (Reservoir 27.03 13.18 ppb (7 days later);
Ohio Piqua 13.03 2.27
and Finished) (12-May-03) 11.80 ppb (15 days later);
Marlin Water 7.71
Texas Marlin 2.06 1.05 6.33 ppb (14 days later)
Treatment Plant (10-Mar-03)
Note: * Only one system in North Carolina was sampled for atrazine under the Atrazine Monitoring Program.
10
Table 3: Water systems with the highest atrazine concentrations in finished water in each state, 2003–2004
State Water City Peak Spring Summer Running Next reading

system concentration quarter quarter annual after peak
in finished atrazine atrazine atrazine (time since
water concentration concentration average peak reading)
(ppb) average average (ppb)
(ppb) (ppb)

39.69 19.25 ppb (7 days later);
Illinois Evansville Evansville 7.27 1.23 3.20
(10-May-04) 14.38 ppb (14 days later);
Versailles 30.48 12.27 ppb (7 days later);
Indiana Versailles 4.76 3.22 4.60
Water Works (16-Jun-03) 7.25 ppb (14 days later);
Centerville
3.14
Iowa Municipal Centerville 1.83 1.07 1.35 1.93 ppb (5 days later)
(14-May-03)
Water Works
12.76
Kansas Erie Erie 2.45 0.77 1.20 2.13 ppb (7 days later)
(27-Apr-04)
Leitchfield 8.42
Kentucky Leitchfield 2.14 1.68 1.35 2.25 ppb (7 days later)
Water Works (16-Jun-03)
Iberville
11.38
Louisiana Water Plaquemine 2.24 1.21 1.36 1.78 ppb (6 days later)
(23-Mar-04)
District #3
5.91
Missouri Creighton Creighton 1.16 1.23 0.86 2.94 ppb (5 days later)
(1-Jun-04)
North 0.50*
Monroe Monroe 0.21 0.35 0.27 0.49 ppb (28 days later)
Carolina (15-Dec-03)
14.63
Ohio Blanchester Blanchester 1.93 1.57 1.35 2.28 ppb (7 days later)
(14-Jun-04)
Marlin
Water 8.65
Texas Marlin 2.33 0.75 1.77 3.97 ppb (5 days later)
Treatment (24-Mar-03)
Plant
Note: * Only one sample was taken in 2003. The maximum concentration among the 32 samples taken in 2004 was 0.49 ppb.
11
Figure 3: Atrazine concentrations in water systems
Figure 3 highlights the maximum concentrations average concentration of atrazine in the raw water
detected in each water system sampled in the Atrazine was 2.94 ppb, while the annual average concentration
Monitoring Program. Appendix A provides the in the finished water was 0.28 ppb, indicating that
sampling results in each state identifying the water the treatment used at the water facility was removing
systems with peak concentrations of atrazine exceeding atrazine. (See Figure 4.)
3 ppb in finished water. On the other hand, in Iberville, Louisiana in 2004,
In addition to the running annual averages and the atrazine levels in raw and finished water closely
the peak concentrations, we also compared the track each other, indicating that the treatment used at
concentration of atrazine samples in the raw water the Iberville facility removes almost no atrazine from
to those in the finished water taken on the same day, the raw water and therefore most of the atrazine is
as an indicator of whether the treatment facility was making its way into people’s taps. (See Figure 5.)
effectively removing atrazine. We looked specifically Under the Atrazine Monitoring Program, the
at those systems that were identified as having the samples from the water treatment systems were also
highest peak concentrations of atrazine in raw and tested for levels of total chlorotriazines (TCT), the
finished water from Table 2 and Table 3. We found sum of atrazine and its toxic metabolites. In the risk
that while some systems were effectively treating for assessment the EPA conducted for the reregistration
atrazine, other systems were not effectively removing of atrazine, the agency assumed that “the toxicity of
atrazine at all. For example, Vandalia, Missouri in atrazine’s chlorotriazine metabolites is considered to
2003 had an effective treatment regime: the annual be equivalent to that of parent atrazine and exposure
12
VANDALIA, (MO) 2003
12.00
Atrazine Concentration (ppb)

10.00 The peak concentrations of TCT were even
Figure 4: Concentrations of atrazine in raw
higher. (See Table 4.) The Evansville water system
water
8.00
and finished water in 2003 in
Raw Water
Vandalia, Missouri Finished Water in Evansville, Illinois, had the highest peak
6.00 concentration of all the water systems tested, 43.48
VANDALIA, (MO) 2003 ppb in finished drinking water. In fact, every state
4.00
12.00 (except North Carolina, where only one system was
2.00
10.00 tested) had at least one community water system
Raw Water
with a peak TCT concentration above 3 ppb. At the
0.00
8.00
Finished Water Evansville, Illinois and the Versailles Water Works,
10/13/03
12/13/03
11/13/03
5/13/03
6/13/03
2/13/03
3/13/03
7/13/03
8/13/03
9/13/03
4/13/03
1/13/03
6.00 Indiana systems, the peaks stayed above 3 ppb for up

to four weeks.
4.00 DATE
Just before publication of this report, NRDC
2.00 received, through FOIA requests, data from the
Atrazine Monitoring Program for 2005 through
0.00 10/13/03 2008. While we did not have time to conduct a
12/13/03
11/13/03
5/13/03
6/13/03
2/13/03
3/13/03
7/13/03
8/13/03
9/13/03
4/13/03
1/13/03
comprehensive analysis of the new data, we did find

that these trends continue. There are still high peak
DATE
concentrations of atrazine contaminating finished
water in different drinking water systems, and there
Figure 5: Concentration of atrazine in are still systems with annual average concentrations
raw water and finished water in 2004 in of atrazine that exceed 3 ppb. Specifically, we found
Iberville, Louisiana that drinking water systems in seven cities had
rolling averages that exceeded 3 ppb (Beloit, Kansas;
IBERVILLE, (LA) 2004 Blanchester, Ohio; Evansville, Illinois; Flora, Illinois;
14.00
Piqua, Ohio; Versailles, Indiana; and Wyaconda,
12.00 Missouri).
Raw Water
10.00
Finished Water
8.00
There Are Minimal Benefits from
6.00 IBERVILLE, (LA) 2004 Atrazine Use
14.00
4.00 The regulation of atrazine both under FIFRA and
12.00 SDWA requires the EPA to account not only for
2.00
Raw Water
10.00 adverse health effects associated with atrazine, but
0.00 Finished Water
also for the economic benefit arising from its use.
7/13/04
8/13/04
5/13/04
6/13/04
3/13/04
4/13/04
9/13/04
10/13/04
1/13/04
2/13/04
11/13/04
12/13/04
8.00
Two published studies by the U.S. Department of
6.00
DATE Agriculture (USDA) suggest that the corn yield
4.00 losses from phasing out atrazine use in the U.S.
2.00 would be modest. In 1994, the USDA estimated that
to those metabolites may occur.”74 Therefore, finding an atrazine ban would result in yield losses of only
0.00
high levels of TCT in finished drinking water is just as 1.19 percent and would decrease corn acreage in
7/13/04
8/13/04
5/13/04
6/13/04
3/13/04
4/13/04
9/13/04
10/13/04
1/13/04
2/13/04
11/13/04
12/13/04
troubling as finding high levels of atrazine alone. production by just 2.35 percent.75 Similar findings
At least two of the water systems
DATE that were were reported in 1997.76 Three other studies have
monitored from January to December had annual estimated greater losses, but two were funded by the
average concentrations of TCT that exceed 3 ppb. pesticide industry (including one by Syngenta), and
Since TCT and atrazine have the same toxicity profile, all have problems relating to their completeness,
these high concentrations of TCT should also be assumptions, and methodologies, according to an
considered to exceed the EPA's health-based standard. analysis by Tufts University economist Dr. Frank
Ackerman.77
13
Table 4: Water systems with the highest peak concentration of TCT in finished water and the corresponding
annual averages, by state, 2003–2004
Annual TCT Peak

Concentration readings following
State Water system City average TCT concentration
the peak TCT concentration
(ppb) (ppb)
Next four readings: 22.34 (7 days

4.23 43.48 later); 17.46 ppb (14 days later);
Illinois Evansville Evansville
(2004) (10-May-04) 10.17 ppb (22 days later); 5.33 ppb
(28 days later)
Next four readings: 16.48 (7 days
Versailles Water 4.37 36.70 later); 10.02 ppb (14 days later);
Indiana Versailles
Works (2003) (16-Jun-03) 7.21 ppb (21 days later); 3.5 ppb
(28 days later)
Osceola Municipal 1.65 3.95
Iowa Osceola No later measurements in 2003
Water Works (2003) (15-Dec-03)
1.41 14.34
Kansas Erie Erie 3.08 ppb (7 days later)
(2004) (27-Apr-04)
Leitchfield Water 2.25 10.21
Kentucky Leitchfield 3.24 ppb (7 days later)
Works (2003) (16-Jun-03)
Iberville Water 1.77 13.37
Louisiana Plaquemine 3.09 ppb (7 days later)
District #3 (2003) (2003)
1.19 6.32
Missouri Creighton Creighton 3.22 ppb (6 days later)
(2004) (1-Jun-04)
0.53 0.98
North Carolina Monroe Monroe 0.85 ppb (16 days later)
(2004) (12-Jan-04)
2.08 16.95
Ohio Blanchester Blanchester 3.432 ppb (7 days later)
(2004) (14-Jun-04)
Marlin Water 2.75 13.5
Texas Marlin 4.38 ppb (34 days later)
Treatment Plant (2003) (24-Mar-03)
In 1991, Italy and Germany banned the use of to corn production. In fact, “both Italy and (especially)
atrazine, followed by Sweden, Finland, and Denmark Germany show faster growth in harvested areas after
in 1994, and finally the entire European Union in banning atrazine than before….this is just the opposite
2004.78, 79, 80 Italy’s and Germany’s experience is of the pattern that would be expected if atrazine made
particularly illustrative as both countries are corn- a major contribution to profitability in corn.”81 It
producing nations. A study comparing American, is possible that in these cases atrazine was replaced
Italian, and German relative corn yields and changes in by other pesticides; a ban in the U.S. must thus be
corn-harvested acres found “no sign of yields dropping accompanied by a push towards non-chemical and
in Germany or Italy after 1991, relative to the U.S. reduced-risk chemical alternatives.
yield—as would be the case if atrazine were essential”
14
Chapter 4
Atrazine Monitoring is
Misleading and Its Regulation is
Insufficient
N
RDC’s analysis of atrazine sampling data indicate that there are troubling
concentrations of atrazine in the surface and drinking waters in the
Midwest and the South. However, what makes these findings even more
troubling is that the EPA relied on a fatally flawed analytical method to conclude that
there was no cause for concern.
The EPA is Ignoring the Atrazine than be concerned about finding 54 public drinking
Problem water systems with peak concentrations of atrazine in
The most glaring flaw in the EPA’s analysis of the the finished water exceeding 3 ppb, the EPA ignored
monitoring data for community water systems is its those findings and instead focused on 90-day average
exclusive focus on long-period running averages, rather concentrations of TCT which never exceeded the
than peak atrazine concentrations. The EPA decided to screening level in any public water system. Relying on
focus on a 90-day running average TCT concentration the average concentration of TCT obfuscates the real
to decide whether to order atrazine manufacturers to problem—that is, that high peak concentrations of
take risk mitigation measures and they ignored the atrazine are occurring in finished drinking water. (See
peak concentrations of atrazine detected. However, box on page 16 for example.)
the occurrence of peaks of atrazine contamination This flaw is compounded by the EPA’s decision to
may be just as important as the level of contamination set the level of concern at a 90-day average of 37.5
over many months. Overwhelming data described in ppb of TCT, despite the fact that TCT has a similar
this report show that amphibians raised in atrazine- toxicological profile as atrazine itself, according to
contaminated water for days or weeks show serious and its own findings. Therefore, rather than using its
irreversible effects, particularly on male reproductive own health-based standard of an annual average of 3
development. Because human fetuses also develop in ppb of atrazine in drinking water, the agency based
a completely aquatic environment, we are naturally its determinations on a weaker level of concern for
concerned about the risk of adverse human health atrazine metabolites in raw water to determine that no
effects associated with atrazine contamination. Rather water systems were of concern.
15
Ignoring Dangerous Levels of Atrazine
How do EPA regulations ignore the high spikes of atrazine? Averaging sampling data can easily mask the
presence of high—even dangerously high—levels of atrazine. In the Evansville Water System in Evansville,
Illinois, for at least 22 days, there were concentrations of atrazine above 3 ppb. In fact, some of the
concentrations were well above 3 ppb—peaking as high as 39.69 ppb. However, when the data taken from
other times of the year were averaged with this peak, the running annual average fell to 3.20 ppb. And
because the average TCT concentration for this system fell below 37.5 ppb, the EPA ignored the peak
atrazine concentrations.
ATRAZINE LEVELS IN FINISHED WATER IN EVANSVILLE WATER SYSTEM, ILLINOIS, 2004

45
40
35
30
25
20
15
10
Running Annual Average: 3.20 ppb
5
0
4/19/04
11/15/04
11/29/04
12/13/04
10/18/04
11/1/04
3/22/04
5/3/04
4/5/04
8/23/04
9/20/04
2/23/04
5/17/04
1/26/04
6/14/04
10/4/04
3/8/04
1/12/04
5/31/04
6/28/04
7/12/04
7/26/04
8/9/04
9/6/04
2/9/04
DATE
Astute readers may notice that this running annual average exceeds the MCL for drinking water. However,
the EPA Annual Compliance Report for the Drinking Water Program shows that there were no atrazine MCL
violations in 2004 for this system. Under the SDWA regulation, to monitor for MCL violations, systems take
one compliance sample each quarter—and these four sample concentrations are averaged to give the annual
average. The four compliance samples taken in 2004 by Evansville did not detect the high peak concentration
of atrazine that was found through the Atrazine Monitoring Program. Therefore, there was no MCL violation
despite the fact that in reality, the running annual average concentration of atrazine in this drinking water
system did exceed 3 ppb.
16
The EPA’s interpretation of the data did not account risk mitigation measures in that watershed. The
for the fact that 54 water systems had spikes of model—called the Comprehensive Aquatic Systems
atrazine in finished drinking water that exceeded 3 Model (CASM)—calculates the “community similarity
ppb. Because the drinking water standard is based on index” (CSI),84 which reflects the average change in
an annual average, these peak concentrations were biomass for individual plant species at a site. If atrazine
not regulatory violations. Even the drinking water exposure at a site is expected to result in a change in
MCL standard is problematic. It is based on a running CSI of 5 percent or more, atrazine concentrations
annual average, meaning that high levels exceeding 3 exceed the EPA’s “level of concern.” If the level of
ppb in the spring and summer (when most atrazine concern is exceeded during two years of monitoring,
contamination occurs) could be averaged with low atrazine manufacturers must employ an existing
readings from the winter and fall and this average Total Maximum Daily Load program, as established
would then hide levels of atrazine that should be of by the federal Clean Water Act and implemented
concern to the agency.82 by states, or establish a similar program, to reduce
atrazine contamination by continuing to monitor
concentrations in surface water, identifying the sources
Monitoring Programs Were Not of pollution, reaching out to users, managing uses in
Designed to Find the Biggest Problems the watershed and allocating atrazine loads between
Antoher troubling aspect of the EPA’s ignoring the sources.85 If the computer model predicts a CSI
peak concentration data is the fact that its water- change greater than 15 percent in any monitoring year,
monitoring program was not specifically designed to atrazine manufacturers must immediately implement
detect pesticide peaks. Atrazine is rapidly transported risk mitigation measures, without waiting for another
to surface water with rain runoff. If a water sample is year of data.
taken the day before rain washes over a treated field, Using this model, the EPA determined that atrazine
it will likely miss a large influx of pesticide into a manufacturers must undertake mitigation measures in
stream, whereas a sample taken the day of or day after only two watersheds of the forty that were monitored:
a rainstorm will be more likely to reflect a high peak of South Fabius River and Youngs Creek (both in
pesticide contamination, especially if the treated field is Missouri). These two sites were the only two to exceed
close by and if the pesticide was applied recently.83 The the CSI 5 percent level of concern for two years in
peaks in surface water may remain in the monitored the EPA's original assessment. However, the only
area for hours, days, or even weeks, depending on the mitigation measures being taken for the South Fabius
amount of rainfall, the duration of rainfall, and the River and Youngs Creek watersheds are outreach efforts
flow rate of the surface water. Or they may flush down to inform farmers about best management practices
the stream fairly rapidly. It is much more likely that a for reducing atrazine contamination and continued
monitoring program would miss peak concentrations monitoring for atrazine levels. No sites exceeded the 15
than catch them. Therefore, findings of high peak percent change screening level. Just before this report
concentrations in monitoring data should be treated went to press the EPA made the determination—after
seriously—not averaged away. additional review of its model—that the Big Blue River
watershed in Upper Gage County also exceeded the
Agency's level of concern and therefore ordered similar
Screening Levels Are Too Permissive mitigation measures.
The EPA has relied on a computer model to The EPA’s reliance on the CASM was misplaced.
determine whether the amount of atrazine exposure One major flaw with the CASM-derived level of
in a watershed would be likely to cause changes concern is that it is based on the effects of atrazine
in the plants and plant community structure in a contamination on plants in the aquatic system, which
particular watershed. For watersheds that exceeded the EPA says is the most sensitive endpoint. By
the screening level, the EPA would run the model focusing on plant effects, the EPA is ignoring the toxic
and, based on the results, determine whether to effects of atrazine at lower doses on the aquatic animals
require atrazine manufacturers to implement certain themselves. In other words, the CSI 5 percent level of
17
concern does not account for the endocrine-disrupting the Ecological Watershed Monitoring Program, the
and other harmful effects of atrazine contamination EPA identified 1,172 watersheds that are at highest
at very low doses that have been demonstrated in the risk from atrazine contamination. However, rather
literature. than sample all of those watersheds, in a private deal
Secondly, even if the impact on photosynthesis with the EPA, Syngenta agreed to monitor atrazine
were the only appropriate endpoint to consider, the pollution in only 40 streams, which were selected for
model itself has many problems. The United States monitoring to “give a statistical representation of the
Fish and Wildlife Service (FWS) has critiqued the third tier of 1,172 such watersheds predicted to be
CASM model.86 The FWS noted that the EPA’s own most potentially vulnerable.”94 As such, more than 96
verification efforts showed that the model had an 8 percent of the streams that the EPA has identified as
percent rate of false negatives for predicting significant being at highest risk were not monitored by Syngenta.
adverse effects (i.e., 8 percent of the time the model Based on the results of the Ecological Monitoring,
predicted no effects when, in fact, significant adverse the EPA made a preliminary estimate that 101 (9
effects could be expected) and a 16 percent rate of false percent) of the 1,172 most vulnerable watersheds may
negatives for slight effects.87, 88 The FWS concluded exceed its level of concern for two years, therefore
that “based on our current understanding, this model needing mitigation measures.95 Yet, to date, the EPA
may not be conservative enough in its estimation of has not taken steps to order atrazine manufacturers to
adverse effects thresholds to thoroughly predict effects address these watersheds. In fact, the EPA has done
to listed [threatened or endangered] species.”89 Indeed, very little to address the many unmonitored watersheds
both the FWS and the National Marine Fisheries in the Midwest and the South that are highly
Service noted that the scientific evidence indicates that vulnerable to routine atrazine contamination. New
atrazine concentrations below these screening levels ecological models now being considered by the EPA
are likely to have negative effects on aquatic plant may identify additional watersheds for mitigation.96
communities.90, 91
Given these two major flaws, the levels of concern
set by the EPA are simply too high to be protective
of the watershed. For example, exposure to 21 ppb
of atrazine for as little as two days has been shown
to impair development of the reproductive organs in
male and female frogs.92, 93 We discovered that 5 of the
40 watersheds sampled had at least one peak atrazine
concentration above 21 ppb for two or more days.
Only three of these watersheds were flagged by the
CASM for mitigation, leaving the other three without
any response.
As of the date of this report, the EPA is considering
two alternate computer models to determine which
watersheds will need risk mitigation. However, the
EPA is still setting its level of concern based on effects
on aquatic plants and is ignoring endocrine-disrupting
effects on wildlife.
The EPA Monitoring Program Ignores

More Than 1000 Vulnerable Watersheds
The Ecological Watershed Monitoring Program was
created ostensibly to focus on the watersheds that
are most vulnerable to atrazine contamination. For
18
Chapter 5
Recommendations
T
he widespread atrazine contamination in the waters of the Midwestern and
Southern United States is a serious problem. These levels of exposure are
likely having significant effects on wildlife populations. And there is concern
for the potential human health effects from elevated levels in drinking water. In
contrast, there are few, if any, benefits of continued atrazine use. NRDC makes the
following recommendations to address this problem.
Recommendation 1: The United States should phase often choose pesticides not because they are more
out the use of atrazine. effective than other farming methods, but because
Atrazine use is not essential to maintaining high yields they are familiar and cheap. As with many pesticides,
of corn and its phase-out would not significantly farmers can often use less atrazine than the label
decrease the number of acres of corn under production. recommendations, especially by using targeted spraying
As such, atrazine should fail the cost-benefit evaluation or by applying atrazine in a narrow band in crop
required for pesticide registration because the economic rows.97 Applying atrazine after the corn has emerged
benefits of the pesticide must outweigh its risks to could reduce runoff by half.98
human and environmental health. Given this evidence, Using Integrated Pest Management (IPM) for
it is difficult to justify the widespread contamination weed management relies on weed prevention, field
of the United States’ surface and drinking water caused monitoring, and the use of effective lower risk control
by the continued use of atrazine from either a legal or methods. Farmers set an action threshold—the point
public policy perspective. Atrazine use should therefore at which the number of weeds reaches a level that
be phased out in the United States. However, it should indicates that control is necessary, and control methods
be noted that in many cases other hazardous pesticides are utilized only when the action threshold is exceeded.
are substituted for atrazine. Rather than just risk- These methods include mechanical and natural
trading from one toxic chemical to another, NRDC methods of weed control and low-risk pesticides.
recommends reducing overall chemical use. Conventional pesticides are used only as a last resort.99
IPM techniques may include, among others:
Recommendation 2: Farmers should be encouraged
to take take interim steps to reduce their 4 Cover crops: Winter cover crops are a prevention
atrazine use. strategy that can greatly reduce weed growth
There are concrete steps that farmers can take to reduce by competing with weeds for light, water, and
their reliance on atrazine and other pesticides. Farmers nutrients, and protect soil from erosion. Legumes
19
used as cover crops can also increase nitrogen in have sensitive subpopulations—such as pregnant
the soil.100 women and infants—in their households. A publicly
4 Mechanical weed control methods: Rotary hoes available website posting sampling data as they are
can be used after weed seeds have germinated, but analyzed, or even regular reports about spikes of
before the weeds emerge, to significantly reduce atrazine contamination, would at least provide more
weed growth; cultivators can remove emergent information than the public receives now. Furthermore,
weeds before they become established. 101 the data must be presented comprehensively, rather
4 Delayed fertilizer application: Delaying than just in summary form. For example, drinking
application of half of the fertilizer used on corn water systems that have been monitored must be
crops until after the ears emerge can deprive weeds identified by name, along with the monitoring results.
of nutrients during key periods of growth, while
ensuring that these nutrients are available to the Recommendation 5: The public should use home
crop when it is best able to absorb them.102, 103 water filtration systems and demand transparency
4 Intercrops: Alternating rows of different crops of information from their water utilities.
helps reduce weeds and results in higher crop NRDC recommends that consumers who are
yields.104 concerned about atrazine in their drinking water use
4 Crop rotation: Weed density and pesticide use a water filter certified by NSF International to meet
can be reduced substantially by shifting from a NSF/American National Standard Institute (ANSI)
two-year corn/soy rotation, typical of Midwestern Standard 53 for VOC (volatile organic compounds)
agriculture, to a multi-species three- or four-year reduction. This standard includes some faucet-
rotation that adds species such as alfalfa and mounted charcoal filters. While systems that meet this
oats.105, 106 certification do not always eliminate atrazine entirely,
to earn NSF certification a filter must be able to reduce
Recommendation 3: The EPA should monitor atrazine levels in drinking water from 9 ppb of atrazine
all vulnerable watersheds and require all future to 3 ppb.107
monitoring plans to identify worst case scenarios.
Any future monitoring plans should be designed
to identify the worst case scenarios occurring in
vulnerable watersheds and in public water systems. Make Our Drinking Water Safer
Monitoring programs should be designed to increase Consumers should contact their local water utility
the chances of detecting contamination if it exists. This and ask what type of treatment they use, whether
would include requiring samples to be taken within a they are treating for atrazine and other
certain time after big rainstorms and after fields have pesticides, and how effectively atrazine is being
been treated with atrazine, which would increase the removed from their raw water.
likelihood of finding out the severity of the atrazine
problem. Consumers should then provide this
information to NRDC through our website
Recommendation 4: The EPA should publish www.simplesteps.org to help us to collect
monitoring results for each watershed and public information about how public water systems are
water system sampled. treating for contaminants.
Monitoring results on the watersheds and the
public water systems that were sampled under the
two different monitoring programs were first made
available through Freedom of Information Act
requests and through litigation. However, the public
has a right to know if there is an atrazine problem
which they must treat, especially people who live
downstream of atrazine-treated fields and who may
20
Endnotes 14 7 U.S.C. § 136a(c)(5)(C)

15 7 U.S.C. § 136(bb)
EXECUTIVE SUMMARY
16 7 U.S.C. § 136a-1(a).
1 Throughout this report we refer to atrazine as both an
17 7 U.S.C. § 136d.
herbicide and a pesticide. Pesticide is the overarching
term for describing a substance used to kill an unwanted 18 42 U.S.C. § 300g-1.
organism. An herbicide is a type of pesticide used 19 42 U.S.C. § 300g-1(b).
specifically to kill plants.
20 Sass JB and Colangelo A. 2006. European union bans
2 Gilliom RJ, et al. 2006. The Quality of Our Nation’s atrazine, while the United States negotiates continued use.
Waters: Pesticides in the Nation’s Streams and Ground Int J Occup Environ Health (Jul–Sep) 12(3): 260–267.
Water, 1992–2001. U.S. Geological Survey Circular 1291.
21 U.S. EPA. 2006. Atrazine: Finalization of Interim
3 A running annual average is calculated by averaging the Reregistration Eligibility Decision and Completion of
data from one date with all the data from the previous 365 Tolerance Reassessment and Reregistration Eligibility
days, then averaging the data from the next point and the Process (April), p. 9. http://www.epa.gov/oppsrrd1/REDs/
previous 365 days, and so on. atrazine_combined_docs.pdf.
4 Hayes TB, et al. 2002. Atrazine-induced hermaphroditism 22 U.S. EPA. 1991. Federal Register Notice (56 FR 3526).
at 0.1 ppb in American leopard frogs (Rana pipiens): January 30.
laboratory and field evidence. Environ Health Perspect
111:568–575. 23 World Health Organization. 2003. Atrazine in Drinking-
water; Background Document for Development of WHO
5 Colborn T. 2006. A case for revisiting the safety of Guidelines for Drinking-water Quality. WHO/SDE/
pesticides: a closer look at neurodevelopment. Environ WSH/03.04/32. https://www.who.int/water_sanitation_
Health Perspect 114(1):10–17. Review. health/dwq/atrazinerev0305.pdf.
6 Colborn T. 2004. Commentary: setting aside tradition 24 Giupponi C. 2001. The Substitution of Hazardous
when dealing with endocrine disruptors. ILAR J Molecules in Production Processes: The Atrazine Case
45(4):394–400. Review. Study in Italian Agriculture. Milan, Italy: Fondazione Eni
7 Finished water refers to drinking water that is ready for Enrico Mattei.
consumption. 25 Chynoweth E. 1992. Atrazine gets reprieve from European
8 U.S. EPA. 2007. Preliminary Interpretation of the Commission. Chemical Week, London, U.K. (July 22).
Ecological Significance of Atrazine Stream-Water 26 Only four pesticides have a cutoff of 0.3 ppb: aldrin,
Concentrations Using a Statistically-Designed Monitoring dieldrin, heptachlor, and heptachlor epoxide. European
Program. In Support of an Interim Reregistration Community Council Directive on the Quality of
Eligibility Decision on Atrazine. Submitted to the FIFRA Water Intended for Human Consumption, 98/83/EC,
Scientific Advisory Panel for Review and Comment November 3, 1998, Annex I. 1998; Commission E. Review
(November). http://epa.gov/oscpmont/sap/meetings/2007/ report for the active substance atrazine; Finalized in the
december/whitepaper_sap.pdf. Accessed August 12, 2008. Standing Committee on the Food Chain and Animal
Health at its meeting on 3 October 2003 in support of
a decision concerning the non-inclusion of atrazine in
CHAPTER 1
Annex I of Directive 91/414/EEC, and the withdrawal
9 U.S. EPA. 2003. Interim Reregistration Eligibility Decision of authorization for plant protection products containing
for Atrazine. Washington, DC: U.S. EPA (January 31). this active substance; European Commission Health
10 Ibid. and Consumer Protection Directorate-General; 2003;
SANCO/10496/2003-final.
11 Gilliom RJ, et al. 2006. The Quality of Our Nation’s Waters:
Pesticides in the Nation’s Streams and Ground Water, 1992– 27 U.S. EPA. 2006. Atrazine Reregistration Eligibility
2001. U.S. Geological Survey Circular 1291. Decision (RED). April. http://www.epa.gov/oppsrrd1/
REDs/atrazine_combined_docs.pdf.
12 Ibid.
28 Sass JB and Colangelo A. 2006. European Union bans
13 These data were obtained as part of an agreement to settle
atrazine, while the United States negotiates continued use.
litigation brought by NRDC and as the result of several
Int J Occup Environ Health (Jul–Sep) 12(3): 260–267.
requests under the Freedom of Information Act (FOIA).
21
of action studies. Birth Defects Res B Dev Reprod Toxicol

(Apr) 80(2): 98–112. Review.
CHAPTER 2
39 Much of the discussion of the science has been published
29 Colborn T. 2006. A case for revisiting the safety of
and is freely accessible in the following open-access
pesticides: a closer look at neurodevelopment. Environ
citation: Sass JB and Colangelo A. 2006. European union
Health Perspect 114(1):10–17. Review.
bans atrazine, while the United States negotiates continued
30 Colborn T. 2004. Commentary: setting aside tradition use. Int J Occup Environ Health (Jul–Sep) 12(3): 260–267.
when dealing with endocrine disruptors. ILAR J
40 Tavera-Mendoza L, et al. 2002. Response of the amphibian
45(4):394–400. Review.
tadpole (Xenopus laevis) to atrazine during sexual
31 Grandjean P, et al. 2008. The Faroes statement: human differentiation of the testis. Environ Toxicol Chem 21:527–
health effects of developmental exposure to chemicals 531.
in our environment. Basic Clin Pharmacol Toxicol (Feb)
41 Tavera-Mendoza L, et al. 2002. Response of the
102(2): 73–5.
amphibian tadpole Xenopus laevis to atrazine during sexual
32 Colborn T. 2004. Neurodevelopment and endocrine differentiation of the ovary. Environ Toxicol Chem 21:1264–
disruption. Environ Health Perspect (Jun) 112(9): 944–9. 1267.
Review; Crain DA, et al. 2008. Female reproductive
42 Hayes TB, et al. 2002. Atrazine-induced hermaphroditism
disorders: the roles of endocrine-disrupting compounds
at 0.1 ppb in American leopard frogs (Rana pipiens):
and developmental timing. Fertil Steril 90(4): 911–40.
laboratory and field evidence. Environ Health Perspect
Review; Main KM, Skakkebaek NE, and Toppari J.
111:568–575.
2009. Cryptorchidism as part of the testicular dysgenesis
syndrome: the environmental connection. Endocr Dev 43 Kniewald J, et al. 2000. Disorders of male rat reproductive
14:167–73. tract under the influence of atrazine. J Appl Toxicol 20:61–
8.
33 Grandjean P, et al. 2008. The Faroes statement: human
health effects of developmental exposure to chemicals 44 Swan SH, et al. 2003. Semen quality in relation to
in our environment. Basic Clin Pharmacol Toxicol (Feb) biomarkers of pesticide exposure. Environ Health Perspect
102(2): 73–5. 111:1478–84.
34 Kiesecker JM. 2002. Synergism between trematode 45 Swan SH. 2006. Semen quality in fertile US men in
infection and pesticide exposure: a link to amphibian limb relation to geographical area and pesticide exposure. Int J
deformities in nature? Proc Natl Acad Sci USA 99:9900–4. Androl 29:62–8.
35 Rohr JR and Palmer B. 2005. Aquatic herbicide exposure 46 Curwin BD, et al. Urinary and hand wipe pesticide levels
increases salamander desiccation risk eight months later in among farmers and nonfarmers in Iowa. 2005. J Expo Anal
a terrestrial environment. Environ Toxicol Chem 24:1253– Environ Epidemiol (Nov) 15(6): 500–8.
1258. 47 Letter from Marjorie A. Nelson, U.S. Fish and Wildlife
36 Moore A, et al. 2007. The impact of a pesticide on Service, to Arthur-Jean B. Williams, U.S. EPA, RE:
migratory activity and olfactory function in Atlantic Informal Consultation on the Effects of Atrazine
salmon (Salmo salar L.) smolts. Aquaculture 273:350–359. Re-registration on the Endangered Alabama Sturgeon and
Endangered Dwarf Wedgemussel. Dated February 11,
37 Rohr JR, et al. 2006. Exposure, post-exposure, and density-
2008. FWS/AES/DCHRS/032435.
mediated effects of atrazine on amphibians: Breaking down
net effects into their parts. Environmental Health Perspect 48 Ibid.
114:46–50. 49 Letter from James H. Lecky, National Marine Fisheries
38 There are at least two demonstrated mechanisms of toxicity Service, to Arthur-Jean Williams, U.S. EPA, RE:
for atrazine; one is activation of the enzyme aromatase Request for Endangered Species Act Section 7 Informal
which results in increased conversion of testosterone to Consultation on the Environmental Protection Agency’s
estrogens (i.e. males become females), and the other is Re-Registration and Use of Atrazine in the Chesapeake Bay
up-regulation of luteinizing hormone which is thought to Watershed, September 1, 2006. Dated May 29, 2007.
be the mechanism for mammary tumor formation observed 50 International Agency for Research on Cancer (IARC).
in lab rats treated with atrazine. Cooper RL, et al. 2007. 1999. Monographs of the evaluation of carcinogenic risks
Atrazine and reproductive function: mode and mechanism to humans. IARC Monograph 73:59–113.
22
51 Birnbaum LS and Fenton SE. 2003. Cancer and 62 Hayes TB, et al. 2006. Pesticide mixtures, endocrine
developmental exposure to endocrine disruptors. Environ disruption, and amphibian declines: Are we
Health Perspect 111:389–94; Rayner JL, et al. 2007. underestimating the impact? Environ Health Perspect (Apr)
Atrazine-induced reproductive tract alterations after 114(S-1): 40–50. doi:10.1289/ehp.8051.
transplacental and/or lactational exposure in male Long- 63 Rohr JR, et al. 2008. Agrochemicals increase trematode
Evans rats. Toxicol Appl Pharmacol (Feb 1) 218(3): 238– infections in a declining amphibian species. Nature (Oct
48. Epub 2006 Nov 23. Rayner JL, Enoch RR and Fenton 30) (455)7217: 1235–9.
SE. 2005. Adverse effects of prenatal exposure to atrazine
during a critical period of mammary gland growth. Toxicol 64 Gilliom RJ, et al. 2006. The Quality of Our Nation’s Waters:
Sci (Sep) 87(1): 255–66. Epub 2005 Jun 2. Pesticides in the Nation’s Streams and Ground Water, 1992–
2001. U.S. Geological Survey Circular 1291.
52 Enoch RR, et al. 2006. Mammary gland development as
a sensitive end point after acute prenatal exposure to an 65 Ibid.
atrazine metabolite mixture in female Long-Evans rats. 66 U.S. EPA. 2006. Atrazine: Finalization of Interim
Environ Health Perspect (Apr) 115(4):541–7. Epub 2006 Reregistration Eligibility Decision and Completion of
Dec 18. PubMed PMID: 17450222; PubMed Central Tolerance Reassessment and Reregistration Eligibility
53 Sass JB and Colangelo A. 2006. European union bans Process (April), p. 68. http://www.epa.gov/oppsrrd1/REDs/
atrazine, while the United States negotiates continued use. atrazine_combined_docs.pdf.
Int J Occup Environ Health (Jul–Sep) 12(3): 260–267.
54 IARC. 1999. Monographs of the evaluation of CHAPTER 3
carcinogenic risks to humans. IARC Monograph 73:59–
67 U.S. EPA. Atrazine Updates. http://www.epa.gov/oppsrrd1/
113.
reregistration/atrazine/atrazine_update.htm
55 Ibid.
68 U.S. EPA. Atrazine Ecological Study — Analytical Data.
56 U.S. EPA. 2006. Atrazine: Finalization of Interim Data provided by the U.S. EPA to NRDC as a result
Reregistration Eligibility Decision and Completion of of a settlement agreement signed with the EPA in 2006
Tolerance Reassessment and Reregistration Eligibility resulting from a lawsuit NRDC brought against the EPA
Process (April), p. 9. http://www.epa.gov/oppsrrd1/REDs/ for unlawfully approving the continued use of atrazine
atrazine_combined_docs.pdf. without adequately considering its risks to endangered
57 U.S. EPA. 2003. FIFRA Scientific Advisory Panel meeting: species.
Characterization of Epidemiology Data Relating to Prostate 69 U.S. EPA. 2008. Atrazine Updates. http://www.epa.gov/
Cancer and Exposure to Atrazine (EPA Dockets - OPP- pesticides/reregistration/atrazine/atrazine_update.htm.
2003-0186). Transmittal of Meeting Minutes of the FIFRA Accessed August 14.
Scientific Advisory Panel Meeting Held July 17, 2003
70 Merrit A. 2004. FIFRA Section 6(a)(2) Annual Report for
(August 29).
Atrazine and Total Chlorotriazine (TCT) Monitoring Data
58 U.S. EPA. 2000. FIFRA Scientific Advisory Panel Report. from the 2003 Voluntary Atrazine Monitoring Program
Atrazine: hazard and dose-response assessment and (VMP) and the 2003 Atrazine Monitoring Program
characterization. SAP Report No. 2000–05. Washington, (AMP) for Selected Community Water Systems (CWS) on
DC (June 27). http://www.epa.gov/scipoly/sap/2000/ Surface Water Sources [Syngenta Number T007009-04].
index.htm. Greensboro, NC: Syngenta Crop Protection.
59 Chevre N, et al. 2006. Including mixtures in the 71 Merrit A. 2005. FIFRA Section 6(a)(2) Annual Report for
determination of water quality criteria for herbicides in Atrazine and Total Chlorotriazine (TCT) Monitoring Data
surface water. Environ Sci Technol (Jan 15) 40: 426–35. from the 2004 Atrazine Monitoring Program (AMP) for
60 Christin MS, et al. 2004. Effects of agricultural pesticides Selected Community Water Systems (CWS) on Surface
on the immune system of Xenopus laevis and Rana pipiens. Water Sources [Syngenta Number T003233-05]. 2005.
Aquat Toxicol (Mar 30) 67: 33–43. Greensboro, NC: Syngenta Crop Protection.
61 De Roos AJ, et al. 2003. Integrative assessment of multiple 72 While these maximum levels exceeded 3 ppb, they are
pesticides as risk factors for non-Hodgkin’s lymphoma not a violation of federal drinking water standards. The
among men. Occup Environ Med 60:E11. drinking water standard for atrazine is based on the average
of at least four quarterly finished water samples, not the
maximum concentration in raw water. However, these
23
values indicate the widespread occurrence of elevated levels 83 Personal communication with Jennifer Sass, NRDC and
of atrazine in drinking water sources. Robert Gilliom, USGS
73 The peak spike occurred in Evansville water system in 84 This is also called Steinhaus Similarity Index.
Illinois. While these maximum levels are not by themselves 85 U.S. EPA. 2003. Revised Atrazine Interim Reregistration
a violation of the federal drinking water standard for Eligibility Decision (IRED). Washington, DC: U.S. EPA.
atrazine, which is based on annual average concentrations, October 31. http://www.epa.gov/pesticides/reregistration/
they indicate the widespread occurrence of elevated levels atrazine/atrazineadd.pdf
of atrazine in treated drinking water.
86 Letter from Marjorie A. Nelson, U.S. Fish and Wildlife
74 U.S. EPA. 2002. Revised Human Health Risk Assessment Service, to Arthur-Jean B. Williams, U.S. EPA, RE:
for Atrazine (April 16); U.S. EPA. 2002. Addendum to Informal Consultation on the Effects of Atrazine
the Revised Human Health Risk Assessment for Atrazine Re-registration on the Endangered Alabama Sturgeon and
(January 31). Table 2. Endangered Dwarf Wedgemussel. Dated February 11,
75 Ribaudo MO and, Bouzaher A. 1994. Atrazine: 2008. FWS/AES/DCHRS/032435.
Environmental Characteristics and Economics of 87 Ibid.
Management. United States Department of Agriculture
(USDA) Agricultural Economic Report. Number 699. 88 U.S. EPA. 2006. Risks of Atrazine Use to Federally Listed
Washington, DC: USDA. Endangered Barton Springs Salamanders (Eurycea sosorum),
Appendix B: Supporting Information for the Aquatic
76 Ribaudo MO. 1997. Economic and environmental effects Community-Level Threshold Concentrations (August 22).
associated with reducing the use of atrazine: An example http://epa.gov/oppfead1/endanger/litstatus/effects/atrazine/
of cross-disciplinary research. J Agricultural and Applied appendix-b.pdf.
Economics 29:87–97.
89 Letter from Marjorie A. Nelson, U.S. Fish and Wildlife
77 Ackerman F. 2007. The economics of atrazine. Service, to Arthur-Jean B. Williams, U.S. EPA, RE:
International Journal of Occupational and Environmental Informal Consultation on the Effects of Atrazine
Health 13(4):437–45. Re-registration on the Endangered Alabama Sturgeon and
78 Ibid. Endangered Dwarf Wedgemussel. Dated February 11,
2008. FWS/AES/DCHRS/032435, p. 10.
79 Sass JB and Colangelo A. 2006. European union bans
atrazine, while the United States negotiates continued use. 90 Ibid.
Int J Occup Environ Health (Jul–Sep) 12(3): 260–267. 91 Letter from James H. Lecky, National Marine Fisheries
www.ijoeh.com/pfds/IJOEH_1203_Sass.pdf Service, to Arthur-Jean Williams, U.S. EPA, RE:
80 European Commission. 2003. Opinion of the Scientific Request for Endangered Species Act Section 7 Informal
Committee on Plants on Specific Questions from the Consultation on the Environmental Protection Agency’s
Commission Concerning the Evaluation of Atrazine Re-Registration and Use of Atrazine in the Chesapeake Bay
in the context of Council Directive 91/414/EEC. Watershed, September 1, 2006. Dated May 29, 2007.
Brussels, Belgium: Health and Consumer Protection 92 Tavera-Mendoza L, et al. 2002. Response of the amphibian
Directorate-General, Scientific Committee on Plants. SCP/ tadpole (Xenopus laevis) to atrazine during sexual
ATRAZINE/002-Final. differentiation of the testis. Environ Toxicol Chem 21:527–
81 Ackerman F. 2007. The economics of atrazine. 531.
International Journal of Occupational and Environmental 93 Tavera-Mendoza L, et al. 2002. Response of the
Health 13(4):437–45. amphibian tadpole Xenopus laevis to atrazine during sexual
differentiation of the ovary. Environ Toxicol Chem 21:1264–
1267.
CHAPTER 4
94 U.S. EPA. 2006. Atrazine Reregistration Eligibility
82 Compliance with the Safe Drinking Water Act is based
Decision (RED). April. http://www.epa.gov/oppsrrd1/
on the requirement that a water system only take one
REDs/atrazine_combined_docs.pdf
sample each quarter, that is, four samples per year. Those
systems in the Atrazine Monitoring Program took samples 95 U.S. EPA. 2007. Preliminary Interpretation of the
more frequently, but for SDWA compliance, only the four Ecological Significance of Atrazine Stream-Water
“compliance” samples are used in the calculation. Concentrations Using a Statistically-Designed Monitoring
Program. In Support of an Interim Reregistration
24
Eligibility Decision on Atrazine. Submitted to the FIFRA 107 National Science Foundation (NSF). Contaminant Testing
Scientific Advisory Panel for Review and Comment Protocols. http://www.nsf.org/consumer/drinking_water/
(November). http://epa.gov/oscpmont/sap/meetings/2007/ dw_contaminant_protocols.asp?program=WaterTre
december/whitepaper_sap.pdf. Accessed August 12, 2008.
96 FIFRA Scientific Advisory Panel Public Meeting. The
Ecological Significance of Atrazine Effects on Primary
Producers in Surface Water Streams in the Corn and
Sorghum Growing Region of the United States (Part II).
Federal Register: February 20, 2009 (Volume 74, Number
33)

CHAPTER 5
97 Land Stewardship Project. Land Stewardship Project
Fact Sheet #18: Atrazine—Alternatives to a Controversial
Herbicide. http://www.landstewardshipproject.org/pdf/
factsheets/18_atrazine_alternatives_2009.pdf. Accessed
May 4, 2009.
98 Ibid.
99 U.S. EPA. 2008. Integrated Pest Management (IPM)
Principles. Factsheet. http://www.epa.gov/opp00001/
factsheets/ipm.htm. Accessed August 15, 2008.
100 Liebman M and Davis AS. 2000. Integration of soil, crop
and weed management in low-external-input farming
systems. Weed Res 40:27–47.
101 Franti TG, et al. Agricultural Management Practices to
Reduce Atrazine in Surface Water. 1996. Cooperative
Extension, Institute of Agriculture and Natural Resources,
University of Nebraska-Lincoln. http://www.p2pays.org/
ref/09/08380.htm. Accessed August 14, 2008.
103 National Research Council. 2000. Professional Societies
and Ecologically Based Management. Proceedings of a
workshop. Washington, DC. National Academies Press.
105 Liebman M, et al. 2008. Argomic and economic
performance characteristics of conventional and low-
external-input cropping systems in the central corn belt.
Agronomy J 100: 600–610.
106 Westerman P, et al. 2005. Are many little hammers
effective? Velvetleaf (Abutilon theophrasti) population
dynamics in two- and four-year crop rotation systems.
Weed Science 53:382–392.
25

Poisoning The Well

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Poisoning the Well

How the EPA is Ignoring Atrazine

Jennifer Sass Blank Page i

NRDC Director of Communications: Phil Gutis

Copyright 2009 by the Natural Resources Defense Council.

An Atrazine Primer The U.S. Environmental Protection Agency (EPA)

MAXIMUM REGIONAL ATRAZINE CONCENTRATIONS

by NSF International to meet American National

Make Our Drinking Water Safer

Visit the NRDC SimpleSteps site at

Atrazine’s Uses and Risks The Recent Lackluster Regulatory

Harmful Effects of Atrazine

These studies raise serious concerns, since

Additional Points of Concern

Minneapolis Lake Hur on

Wolf Creek IA-01 0.38 Vermilion River, North IN-06 1.53

Table 1: Ten watersheds with the highest peak concentrations of atrazine,

Watershed name Sampling year Atrazine concentration (ppb)

above 3 ppb—with one peak reaching an astounding

State Water City Peak Spring Summer Running Next reading

Next three readings:

Figure 3: Atrazine concentrations in water systems

Atrazine Concentration (ppb)

6.00 Indiana systems, the peaks stayed above 3 ppb for up

comprehensive analysis of the new data, we did find

Annual TCT Peak

Next four readings: 22.34 (7 days

Ignoring Dangerous Levels of Atrazine

ATRAZINE LEVELS IN FINISHED WATER IN EVANSVILLE WATER SYSTEM, ILLINOIS, 2004

The EPA Monitoring Program Ignores

Endnotes 14 7 U.S.C. § 136a(c)(5)(C)

of action studies. Birth Defects Res B Dev Reprod Toxicol

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