Carbaryl, Carbofuran, and Methomyl - National Marine Fisheries ...

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NMFS batched the consultations on carbaryl, carbofuran, and methomyl into one Opinion because these compounds have the same mechanism of action, i.e., they target the same site of action in the exact same way. However, NMFS evaluated the effects of each a.i. independently. Additionally, cumulative exposure to the three a.i.s is expected given they have overlapping uses and detections in surface water samples. Active and Other Ingredients. Carbaryl, carbofuran, and methomyl are the a.i.s that kill or otherwise affect targeted organisms (listed on the label). However, pesticide products that contain these a.i.s also contain inert ingredients. Inert ingredients are ingredients which EPA defines as not “pesticidally” active. EPA also refers to inert ingredients as “other ingredients”. The specific identification of the compounds that make up the inert fraction of a pesticide is not required on the label. However, this does not necessarily imply that inert ingredients are non-toxic, non-flammable, or otherwise non-reactive. EPA authorizes the use of chemical adjuvants to make pesticide products more efficacious. An adjuvant aides the operation or improves the effectiveness of a pesticide. Examples include wetting agents, spreaders, emulsifiers, dispersing agents, solvents, solubilizers, stickers, and surfactants. A surfactant is a substance that reduces surface tension of a system, allowing oil-based and water-based substances to mix more readily. A common group of non-ionic surfactants is the alkylphenol polyethoxylates (APEs), which may be used in pesticides or pesticide tank mixes, and also are used in many common household products. Nonylphenol (NP), one of the APEs, has been linked to endocrine-disrupting effects in aquatic animals. Formulations. Pesticide products come in a variety of solid and liquid formulations. Examples of formulation types include dusts, dry flowables, emulsifiable concentrates, granulars, solutions, soluble powders, ultra-low volume concentrates, water-soluble bags, and powders. The formulation type can have implications for product efficacy and exposure to humans and other non-target organisms. Tank Mix. A tank mix is a combination by the user of two or more pesticide formulations as well as any adjuvants or surfactants added to the same tank prior to application. 20
Typically, formulations are combined to reduce the number of spray operations or to obtain better pest control than if the individual products were applied alone. The compatibility section of a label may advise on tank mixes known to be incompatible or provide specific mixing instructions for use with compatible mixes. Labels may also recommend specific tank mixes. Pursuant to FIFRA, EPA has the discretion to prohibit tank mixtures. Applicators are permitted to include any combination of pesticides in a tank mix as long as each pesticide in the mixture is permitted for use on the application site and the label does not explicitly prohibit the mix. Pesticide Registration. The Pesticide Registration Improvement Act (PRIA) of 2003 became effective on March 23, 2004. The PRIA directed EPA to complete REDs for pesticides with food uses/tolerances by August 3, 2006, and to complete REDs for all remaining non-food pesticides by October 3, 2008. The goal of the reregistration program is to mitigate risks associated with the use of older pesticides while preserving their benefits. Pesticides that meet today’s scientific and regulatory standards may be declared “eligible” for reregistration. The results of EPA’s reviews are summarized in RED documents. EPA issued REDs for carbaryl and methomyl in 2007 and 1998, respectively. The IRED for carbofuran was issued in August 2006. EPA considered the registration eligibility determination for carbofuran complete upon issuance of the cumulative assessment for the NMC pesticides in 2007 (http://www.epa.gov/pesticides/reregistration/REDs/carbofuran_red.pdf). Accordingly, EPA treated the carbofuran IRED as its RED. The REDs for all three a.i.s include various mitigation measures, including the cancellation of all registered uses of carbofuran due to ecological and occupational risks. These mitigation components were considered part of the proposed action. Duration of the Proposed Action. EPA’s goal for reassessing currently registered pesticide a.i.s is every 15 years. Given EPA’s timeframe for pesticide registration reviews, NMFS’ evaluation of the proposed action is also 15 years. 21
Page 1 and 2: Ms. Debbie Edwards Director, Office
Page 3 and 4: National Marine Fisheries Service E
Page 5 and 6: Snake River Spring/Summer-Run Chino
Page 7 and 8: Commercial, Recreational, and Subsi
Page 9 and 10: Critical Habitat Risk Hypotheses ba
Page 11 and 12: Table of Figures Figure 1. Stressor
Page 13 and 14: Table of Tables Table 1. Registered
Page 15 and 16: Table 31. Area of Land Use Categori
Page 17 and 18: Table 67. . Examples of published f
Page 19 and 20: Agency: Activities Considered: Nati
Page 21 and 22: This Opinion is based on NMFS’ re
Page 23 and 24: activities that may improve EPA’s
Page 25 and 26: affect but is not likely to adverse
Page 27 and 28: On November 13, 2008, EPA provided
Page 29 and 30: On January 21, 2009, the agencies a
Page 31 and 32: in California, Idaho, Oregon, and W
Page 33 and 34: On that same date, EPA e-mailed NMF
Page 35 and 36: After registering a pesticide, EPA
Page 37: isk assessment. With these and othe
Page 41 and 42: EPA also issued generic and product
Page 43 and 44: pecans, peppers, pistachios, plums,
Page 45 and 46: Use Site plants, woody plants CRP a
Page 47 and 48: are subject to a four year phase-ou
Page 49 and 50: Table 2. Registered uses and applic
Page 51 and 52: mildews and other fungal diseases.
Page 53 and 54: methomyl are 32.4 lb a.i./acre/year
Page 55 and 56: would not likely adversely affect C
Page 57 and 58: In the final steps of our analyses,
Page 59 and 60: Evidence Available for the Consulta
Page 61 and 62: sustaining in the natural environme
Page 63 and 64: Stressors of the Action (see Figure
Page 65 and 66: Species Risk Hypotheses We construc
Page 67 and 68: habitats is then assessed. This por
Page 69 and 70: The problem formulation phase as ar
Page 71 and 72: Risk Characterization We follow the
Page 73 and 74: the probability of risk. In the Ris
Page 75 and 76: Figure 5. Map showing extent of inl
Page 77 and 78: Opinion. Summaries of the status an
Page 79 and 80: Chinook salmon are dependent on the
Page 81 and 82: Eureka Figure 6. CC Chinook salmon
Page 83 and 84: Table 6. CC Chinook salmon--prelimi
Page 85 and 86: Table 7 identifies populations with
Page 87 and 88: The CV drainage as a whole is estim
Page 89 and 90:
have greatly reduced or eliminated
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Portland Salem Figure 9. LCR Chinoo
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important life history type remains
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Table 9. UCR Chinook salmon - preli
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In the most recent five-year geomet
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Figure 11. Puget Sound Chinook dist
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Status and Trends Puget Sound Chino
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flow, temperature, sediment load, w
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San Francisco Figure 12. Sacramento
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of historic spawning areas. Additio
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Status and Trends SR fall-run Chino
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Critical Habitat Critical habitat f
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Portland Seattle Spokane Figure 14.
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and five-year old fish, after two t
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surface and ground water and degrad
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Life History UWR Chinook salmon exh
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Bay, California. Historically, chum
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quality in the freshwater, estuarin
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Life History Chum salmon return to
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catastrophic events. Overall, the p
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Figure 17. Hood Canal Summer-run Ch
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improvements in 2000, with upward t
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ground water and degrade water qual
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San Francisco Figure 18. CCC Coho s
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Information on the abundance and pr
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Table 16 identifies populations wit
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Life History Although run time vari
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programs. The three major river sys
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Data on population abundance and tr
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Figure 21. Oregon Coast Coho salmon
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Preliminary spawner survey data for
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channels, backwaters, terrace tribu
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Figure 22. Ozette Lake Sockeye salm
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the 1997 status review due to resam
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Seattle Portland Figure 23. SR Sock
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Adult returns to Redfish Lake durin
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esume migration in early spring to
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Central California Coast Steelhead
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Status and Trends The CCC steelhead
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San Francisco Figure 25. California
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and Jackson 1996; McEwan 2001). Ste
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Olympia Portland Salem Figure 26. L
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hatchery fish in naturally-spawning
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species includes the only populatio
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Life History Most MCR steelhead smo
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Critical Habitat Critical habitat w
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Eureka Figure 28. Northern Californ
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may affect steelhead migration patt
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Of the 21 populations in the Puget
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Seattle Spokane Figure 30. SR Basin
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and spawner estimates for the Tucan
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San Jose Figure 31. S-CCC steelhead
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Figure 32. Southern California stee
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extinction,” with the remaining 1
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Portland Figure 33. UCR Steelhead d
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“low” for the Wenatchee and Met
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Figure 34. UWR Steelhead distributi
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Molalla/Pudding, Yamhill, Tualatin,
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Natural Mortality Factors Available
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Marine Mammal Predation Marine mamm
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downstream of Bonneville Dam. Socke
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Oceanographic Features and Climatic
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coincides with relatively poor ocea
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from streams in watersheds with agr
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chemicals used has decreased (Table
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California, Idaho, Oregon, and Wash
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to disease, decrease the ability of
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characterized by emergent aquatic p
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subregions and accounting units for
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Region USGS Subregion Central Calif
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Table 31. Area of Land Use Categori
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Table 33. Land uses and population
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(Table 34). See species ESU/DPS map
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undeveloped sites in the Santa Ana
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and grazing. Dams and water diversi
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Artificial Propagation Anadromous f
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water resources is handled by Calif
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containers at time of use. • Cond
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Table 36. Area of land use categori
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Columbia River Basin The most notab
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Ranching practices have led to incr
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17% of mainstem Yakima River sample
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detected in samples from all sites,
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Whitney 1979). Similarly, over one
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nation’s silver output has come f
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(USBR 1998 in (FCRPS 2008); providi
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The States of Oregon and Wasington
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Columbia River chum salmon are not
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including brown and brook trout, At
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density residential with some agric
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Although urban areas occupy only 2%
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Habitat Modification Much of the re
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Table 42. Pollutants of Concern in
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the 1950s. The vast majority of the
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pugettensis). An NPDES permit is re
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Habitat loss through wetland fills
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afted and moved to market or downst
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Oregon is in the process of develop
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Effects of the Proposed Action The
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Carbaryl dissipates in the environm
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high water solubility, low Kow, and
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Table 46. Environmental fate charac
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Species General Life History Descri
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Table 48. Examples of registered us
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Table 49. PRZM-EXAMS exposure estim
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estimate do not represent the highe
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BE provides a peak EEC of 5.5 μg/L
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alcoves, channel edge sloughs, over
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Carbaryl can also be applied at 8 l
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habitat had a downwind width of 10
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Depth of aquatic habitat (meters) B
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monitored in California, Idaho, Ore
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5.2 μg/L for carbofuran, 0.0150 -
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Summary information for carbaryl, c
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after flooding (Nicosia, Carr et al
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pesticide concentrations in the dis
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flowing water habitats, it is not s
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egistered products that contain mor
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potential ingredients in tank mixtu
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low maximum application rate. Howev
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occupy shoreline habitats of only a
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vertebrates and invertebrates (Walk
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Temperature and toxicity We found n
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exposure concentrations. Moreover,
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Summary of Toxicity Information Pre
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at several times during an experime
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Table 64. Assessment endpoint toxic
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fish, number of eggs per mature fem
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varigatus), an estuarine species, b
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included a NOAEC of 9.8 μg/L and a
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730 μg/L for D. magna (freshwater
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TEP) are contained in Appendix D-1.
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the uncertainties related to experi
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capacity (Little and Finger 1990).
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consumed relative to unexposed fish
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24 hr exposure (Zinkl, Shea et al.
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We located studies that measured ol
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endpoints of salmonids remains a re
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items (Courtemanch and Gibbs 1980;
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single pulse of chlorpyrifos was in
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Table 65. Study designs and results
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Chemical Taxa/species Assessment me
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Chemical Taxa/species carbofuran ca
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Chemical Taxa/species carbofuran ca
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macroinvertebrate community did not
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Jardine, MacLatchy et al. 2005; Luo
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Risk Characterization In this secti
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survival appears to be the most sen
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factor in the degree of toxicity of
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Figure 41. Methomyl exposure concen
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Table 67. . Examples of published f
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Additionally, the macroinvertebrate
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Measured Concentrations in Willapa
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up to 100 m off the carbaryl applic
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average initial concentration from
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• Unrelated (0): Conclusive evide
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the fish to determine the cause of
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Dose-addition assumes the cumulativ
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Table 73. Predicted AChE inhibition
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habitats during aerial applications
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The second line of evidence is whet
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D. Impair swimming which leads to r
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F. Exposure to mixtures of carbaryl
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used surfactant/adjuvant mixed with
Page 417 and 418:
In a second modeling exercise, we t
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Carbaryl’s thresholds for the fou
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Table 75. Modeled output for Stream
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Table 77. Modeled output for Sockey
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The likelihood of scenarios 2 and 3
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The three insecticides are highly t
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A. B. C. Figure 43. Probability plo
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elatively low survival EC50 values
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dominated by agricultural or urban
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Figure 45. Percent change in lambda
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Table 80. Multiple application scen
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Because olfaction plays an importan
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expect co-occurrence of the three i
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support one or more lifestages. For
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We attempted to compare expected co
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Cumulative Effects Cumulative effec
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entry into freshwater systems. Carb
Page 451 and 452:
Integration and Synthesis The Integ
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carbofuran applications could cause
Page 455 and 456:
The Status of Listed Resources and
Page 457 and 458:
also exposed to poor water quality
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Given the life history of LCR Chino
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Chinook salmon. Furthermore, there
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all three a.i.s are expected to be
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completing migration to the Pacific
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The major threats to this ESU ident
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Land use data indicate that the Col
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Central California Coast Coho Salmo
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Pesticide use and detections in LCR
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effects. In several streams, one or
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ESU is evergreen forest. Between 19
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miles where agricultural crops are
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The Status of Listed Resources and
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carbofuran application to potatoes,
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The major threats to this DPS ident
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lowland areas (below 1,000 ft eleva
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consequences and subsequent populat
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and surface waters within the heavi
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1994). Most juvenile steelhead spen
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salmon, Northern California steelhe
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natural cover such as submerged and
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The precise change in the conservat
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coho salmon, LCR coho salmon, South
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Table 81. Jeopardy and Non-Jeopardy
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Reasonable and Prudent Alternatives
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The RPA is comprised of six require
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Table 83. Mandatory pesticide no ap
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items will die from these exposures
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action will attain this level in th
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proposed action. Therefore, inciden
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1. Minimize the amount and extent o
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met within the next 15 years, then
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Arunachalam, S., K. Jeyalakshmi, et
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Bortleson, G. C. and J. C. Ebbert (
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CDFG (1995). "Letter dated 30 March
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Davies, P. E. and L. S. J. Cook (19
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FCRPS (2008). "Endangered Species A
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Haggerty, M. J., A. C. Ritchie, et
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IEPSPWT (1999). "Monitoring, assess
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government from 1896 to 1945." Repo
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Matthews, G. M. and R. S. Waples (1
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NMFS (2004). Five-year integrated p
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PSAT (2004). "State of the Sound 20
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Schroder, S. L. (1977). "Assessment
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Tufts, D. F. (1990). "Control of bu
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Williams, A. K. and C. R. Sova (196
Page 549 and 550:
Introduction To assess the potentia
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ocean-type and stream-type Chinook
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incorporates empirical data when av
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given a percentile value of 50 (i.e
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species-appropriate growth period (
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For Figure 3C, an exposure pulse wo
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the n x n square matrix (A) by assi
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spawn (Pess et al. 2002). Survival
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distributed survival and reproducti
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Figure 1: Life-History Graphs and T
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Table 1. List of values used for co
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Table 4. Matrix transition element
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Figure 2. 555
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Figure 4. 557
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Brewer, S.K., Little, E.E., DeLonay
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Higgs, D.A., MacDonald, J.S., Levin
Page 581 and 582:
Morgan, M.J., and Kiceniuk, J.W. 19
Page 583 and 584:
Scholz, N.L., Truelove, N.K., Frenc
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Appendix 2. Species and Population
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Chinook Salmon (continued) ESU Popu
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Chum Salmon ESU Population λ - H=0
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Coho Salmon (continued) ESU Populat
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Steelhead (continued) DPS Populatio
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Appendix 3: Abbreviations 7-DADMax
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FQPA Food Quality Protection Act ft
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PPE Personal Protection Equipment P
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Appendix 4: Glossary 303(d) waters
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Salmon fall to head upriver to its
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Main channel The stream channel tha
Page 607 and 608:
Smolt A juvenile salmon or steelhea
Page 609:
WQS “A water quality standard def
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