September 1980
national enforcement investigations center
            denver federal center bldg 53, box 25227 denver. ro 80225


                September 1980
                Robert Campbell
                  Repository Material
                  'ermanent Collection
                Denver, Colorado
                Region V
                Chicago, Illinois

                           US EPA
              Headquarters and Chemical Libraries
                  EPA West Bldg Room 3340
                   1301 Constitution Ave NW
                     Washington DC 20004

       OBSERVATIONS	      3
       EVALUATION	••  •      5

       OBSERVATIONS	      6
       EVALUATION	      8
       RECOMMENDATIONS 	      9



                             I.   INTRODUCTION
     The Michigan  Department  of Agriculture (MDA) and  the  United States
Department of  Agriculture,  Animal  and  Plant Health Inspection Service,
Plant Protection and Quarantine Program (USDA, APHIS, PPQ) Cooperated in a
gypsy moth  [ Porthetria  dispar (Linn.)] eradication program  during the
spring of 1980.  The  objective of the program was to provide maximum pro-
tection to the  forestry,  recreation,  and aesthetic resources in the State
of Michigan.

     Approximately 24,744  acres within a  boundary of  48,160 acres were
scheduled to  receive  two applications  of  gypsy  moth control pesticides
within 10 days.

     The 1980 integrated gypsy moth management program necessitated the use
of two proven  chemical pesticides,  Sevin-4-Oil and Dimilin  .  In  addition,
experiments were to be  conducted  using two  formulations of Disparlure  (a
synthesized sex lure trap bait to attract male gypsy moths), mass trapping,
and sterile male release as possbile effective interventions.

     The areas selected for Sevin-4-Oil  treatment were in southern Michigan
and consisted  of Calhoun,  Oakland, and Van  Buren  counties.   These three
counties contained a  gross  area of 3,200  acres with a  proposed treatment
area  of  2,220  acres.   Immediately prior to  spraying  activities,  adverse
public response to spraying in Oakland country reduced  the total  pesticide
application area to a total of 1,600 acres [Appendix A].

     Dimilin® applications were principally  confined to central  northern
Michigan in  the counties of Clare, Isabella, Mecosta,  Montcalm, and Osce-
ola.   The total area  scheduled to  receive treatment consisted  of 22,544
acres.  For  a  period,  this program was in jeopardy as  a result of  objec-
tions to the  spraying expressed by a group  of organic  farmers  located  in
the proposed treatment area [Appendix A].

     As in previous years,  the USDA/MDA conducted an intensive public re-
lations program to advise individuals within the application areas to exer-
cise caution  during  the spraying period.  This  information  was provided
through public meetings, the news media, the Cooperative Extension Service,
township supervisors, and local government units.

     Because of environmental  and possible  legal  considerations associated
with the USDA  and MDA program, the  EPA,  Region V Pesticides Enforcement
Division requested the  NEIC to provide technical review and evaluation of
the USDA/MDA  gypsy moth eradication program procedures, and their compli-
ance with  the  Federal Insecticide,  Fungicide, and Rotenticide  Act  (FIFRA).

     Observations from  May  14  to May 24,  1980 included:   (1) evaluation  of
pesticide storage, (2) mixing and loading operations, (3) application meth-
ods and techniques,  (4) cleanup and  disposal,  (5)  personnel  safety.   No
attempt was  made  to  evaluate the USDA/MDA  pesticide monitoring program.

     Spraying activities for Calhoun County were conducted from the Kellog
Regional Airport  in  the  town of Battle Creek.  The  area treated in the
county consisted  of  approximately  1,200 acres in Section 25, the south Jj
and the NE  h of Section 24, and the north h  of Section  36.  The area was
essentially urban.


     Prior  to application activities both Sevin-4-Oil* and Dimilin ** were
stored in a well-marked, secure USDA shed on the outskirts of Battle Creek.

     Helicopeter  spray system  calibration  was conducted by USDA personnel
and adjusted  to  produce  a  75 ft swath  of  spray  at an equivalent rate of
1 lb/ acre to conform with contract specifications.

     Mixing  the  final  formulation  was accomplished at a  remote area of the
Kellog  Regional  Airport  by  pumping both the  Sevin-4-Oil  and diesel  fuel
into a  1,000-gal-capacity truck-mounted holding tank.   Agitation produced
within the tank resulted in a homogenous mixture.   The ratio of ingredients
was 32 oz. of Sevin-4-Oil to 8 oz.  of fuel.

     Loading  the  final pesticide mix into the helicopter holding tanks was
done by a hose  with  appropriately  equipped  shut-off  valves;  this procedure
 *  Sevin-4=0il EPA Reg. No. 264-323.
**  Dimilin  EPA Reg. No. 148-1258.

is called "open  loading".  Personnel conducting the mixing and loading op-
eration wore  proper safety  clothing  and made  every  effort to prevent

     When weather permitted, spray activities commenced during the earliest
morning hours.  On  May 19,  1980 at 9:30 a.m., Sevin-4-Oil was sprayed  in
Calhoun County.  The  spray  helicopter applied the pesticide  in an essen-
tially east-west, west-east course at an approximate altitude of 60 to 75 ft.
Correct alignment of the spray paths was controlled by ground crews manning
aerial kytoons  (balloons).   At the completion of each  pass,  the  kytoons
were moved about 75 ft along the perimeter of the unsprayed area to create
a target for the next spray path.   Throughout the entire spraying operation
a spotter plane observed the procedure from a higher altitude and supervised
the overall operation.  All  personnel maintained radio communication during
the entire application.

     Spraying operations terminated  at  about 11:30 a.m. because increased
wind velocity created  potential  uncontrolled spray drift.   About 4 of the
assigned area had  been treated when application ceased.  On the following
day, May 20,  weather  conditions were suitable to complete  the  spraying.

     Procedures for the cleanup of used containers closely followed the EPA
guidelines.  All pesticide containers (55-gal drums) were triple-rinsed and
stored in  a  security  warehouse for later collection by a local barrel re-
conditioning company.


     The pesticide spraying  program  of Sevin-4-Oil in Calhoun County re-
flected extensive planning by  both USDA and the MDA.  All operations ad-
hered to the prescribed planned procedures except for several minor infrac-
tions involving protective clothing.   Close scrutiny and training of less
experienced personnel could remedy this.

     Improved safety practices  are necessary for the ground crews respon-
sible for positioning the kytoons.  Unlike the crews marking the boundaries
of a proposed section, the crews  controlling the spray paths are  subjected
to repeated contact  with pesticide particles each  time the  aircraft fin-
ishes or begins a  run.   It is stated in the program regulations that "all
members of  kytoon crews  will wear raincoats and a  head covering  of their
choice  during  spraying  operations".    Although  crew members during this
operation wore adequate headgear and gloves, they were provided with inade-
quate raingear (ponchos) which  did not  sufficiently cover them.   Satisfac-
tory protection could  be provided with throw-away, long-sleeved coveralls
or raingear which covers the wrists and reaches below the knees.   Full-face
protection using a face  shield would, for example, also contribute to em-
ployee safety.   If these crews are involved in more concentrated dosages of
pesticide spary,  respirators and goggles will also be necessary.

     The base of  operations  for the central Michigan Dimilin  program was
the Airport at Mt. Pleasant.  The area treated comprised 22,544 acres dis-
persed in the counties of Clare, Isabella,  Mecosta, Montcalm, and Osceola.
The target areas are essentially rural.
     The 25-Ib containers  of  Dimilin  were transported from Battle Creek
and stored at  the  Mt.  Pleasant Airport in a security building distinctly
posted with warning signs.

     Five fixed-wing aircraft  were  checked and calibrated by USDA person-
nel, and their flat  fan spraying systems were adjusted to provide a flow
rate of h gal/acre at 40 psi over a swath with 75 ft.

     The pesticide spray solution  was prepared at a secluded area of the
airport.  Before mixing, the dilution water obtained from the Mt. Pleasant
municipal supply was acidified to a  pH of 6.5 to 7.0 with phosphoric acid.
To assure a pesticide application rate of 0.015 Ib/acre, the mixture ratio
of ingredients to dilution water was 25 Ib of Dimilin  to 200 gal of water.
These mixtures were  prepared  on  a batch basis usually 600 to 800 gal  at a

     The aircraft were  loaded  using a closed metered pumping system which
reduced the liklihood of spillage.


     The Dimilin®  treatment  program began during the early morning hours
May 22,  1980.   Weather conditions were favorable.   Kytoon  crews  were in
position and  five  fixed-wing aircraft were treating three  sections under
the supervision of three MDA observer planes.

     Aerial spraying was  accomplished  by  two  planes  flying  in  tandem  at  an
altitude of about  50  to 60 ft.  Spray paths were marked by red aerial ky-
toons  (balloons) manned by ground personnel.   At the  completion  of each
pass,  the  kytoons  were moved 150  ft along the road bordering the  treatment

     Organic farmers and others objecting to pesticide applications did not
want their land sprayed.  Therefore, to prevent any mishaps, the perimeters
of these sensitive areas were clearly marked with white kytoons.  The spray
plane pilots were directed not to fly over these areas.  Spraying activities
in the  vicinity of a  sensitive area  (organic farm)  were observed by EPA
personnel  and  every  precaution to avoid  overspary of  this  area was fol-

     Upon  completion of spraying  operations on May 24,  1980 about h of the
8,800  ha (22,000  acres) had received  their first treatment of Dimilin .

     Procedures for the cleanup of used containers closely followed the EPA
guidelines:  all  containers  were  triple-rinsed,  punctured, and  stored in  a
security warehouse area.

     Disposal  of  used containers  does  not pose  an immediate  problem  in the
State of Michigan.  Although the  state does not  have a dump  site especially
designed for  the  disposal  of highly  toxic or  environmentally damaging com-
pounds  or  containers, referred to as a Class  I  dump  site,  the Michigan De-
partment of  Natural  Resources issues  special permits  to allow  controlled

dumping at selected sites.   This is the procedure being followed during the
1980 gypsy moth eradication program.


     Observations during the  first few days of the Dimilin  program indi-
cated that  it  was  well  planned with every effort made to make it success-
ful.  However,  a few unsafe  practices  were noted in the mixing-loading
zone.  The  contractor personnel  conducting the mixing did not have proper
protective  clothing, wearing  short-sleeve  shirts  during mixing.  Moreover,
in  performing  the  mixing,  the  25-lb pesticide  containers  were emptied
through the top  portal  of the mixing tank.  A cover was not immediately
placed over the  opening to prevent the escape  of Dimilin  dust into the
surrounding atmosphere.   To prevent  contact with this dust  by  the crews
supervising loading operations,  employees  should  be provided with  suitable
safety equipment such as respirators and goggles.  Personnel not so equip-
ped need to remain a safe distance from the mixing area.

1.    Kytoon crews marking the spray paths during Sevin-4-Oil application
     should be equipped with long-sleeved throw-away coveralls or knee-
     length raincoats, face shields, or respirators and goggles.

2.    Proper safety clothing should be worn constantly during pesticide
     mixing operations.

3.    A method should be devised to prevent the escape of Dimilin dust from
     the mixing tank during the mixing operation.

4.    Ground crews supervising loading operations should be equipped with
     suitable safety equipment or retreat a safe distance during the pesti-
     cide mixing operation.

     These recommendations were conveyed to Mr. Carl Erickson, Pesticide In-
spector, Region V in a telephone conversation on May 28, 1980 [Appendix B].

 (Newspaper Articles)

                                                                       Aerial  spraying  to  kill
                                                                       insects  sparks  flaps
                                Sunday, May 18,1980

   Fears that  aerial  sprays or
 Insecticides may pose a risk to
 pregnant women — while elimi-
 nating populations of birds and
 ecologically valuable insects —
 have triggered furors In several
 targeted  Michigan   communi-

   In  Bloomfleld Township,  a
planned aerial spraying of 600
acres of wooded residential area
by the State Department of Agri- •
culture  —  to  eradicate  o
concentration of dreaded gypsy
moth  caterpillars  — was can-
celed by the township board of
supervisors last week following
o public protest.

  Object of the current protests is
the chemical  Sevin. manufactured
by Union Carbide The department
soys tlie chemical has been used for
27 years throughout the world —
without any reported ill effects — to
treat vegetables, fruits,  poultry and
livestock for pests It is sold in retail
stores to home gardeners

  SINCE THE 1960's the state has been
trying to check the  spread of the
gypsy moih with the use of traps,
various  hormones and  sprays  The
moth caterpillar began stripping for-
ests in New England and Pennsylva-
nia in the 19SO's and hitched rides
  Shaded area on map indicates
  the 600 acres to be sprayed.
 west  on  cars  and  recreational
  But wherever the state has sought
 to halt the spread  It has  run into
  The  Dloomfeld critics voice the
 concerns  of  most  protesters  To
 some, the issue bolls down to trees
,vs  the health risk to humans and
  Critics of  aerial  spraying argue
 that It causes  birth defects and may
 be  carcinogenic  (a  cancer-causing
  "Nature is too complex to try fix-
 ing Spraying  is only buying a little
 time There are safer alternatives,"
 insists James P Wells, a botanist at

             Continued on  Pag* 10B
  Continued from Page 1B            j
; Cranbrook Institute who helped lead •
 the protect in Bloomfleld Township  !
   WELLS SAYS, "too often, in getting
 rid of one pest, the habitat is chang^
 ed so much that another moves in "
   He says the public doesn't trust
 government researchers "after PBB
 and Three Mile Island "
   But Homer Case, a  Bloomfleld
 Township supervisor caught in the
 center of the controversy, replies
 bluntly "Hogwash "              "
   "Scvm hasn't been proven danger-
 ous The stuff is on the vegetables
 you buy in the market and nobody
 thinks anything about  that." said
 Case, whose  family  has  been using
 chemicals for three  generatnons in
 raising fruits
   "1 handled by hand arsenated lead
 and DDT and I'm still healthy, insists
 the M-year-old supervisor, who bos
 held his township post for 24 years. -
   "The whole hullaloo comes from
 the outcry over the use of Agent
 Orange in Vietnam." said Case Agent
 Orange is a defoliant that has been
 suspected of causing  cancer  and
 genetic diseseas
   THE FUROR OVER  chemical spray-
 ing  isn't confined  to  Bloomfleld
 Township State  officials have been
 engaged  in  court  battles  outstate
 over the use of Dimlm, a more potent
 chemical, in wooded areas  infested
 with the g)psy moth
   But under  coui t guidelines to pro-
 tect organic farming, the state is pro-
 ceeding with aerial  applications of
 Dimlm this week in the Kalamazoo-
 Battle Creek area as well as in five
 counties in central Michigan    >•,'
   Critics of aerial spraying say tbe
 federal government's ban last March
 against use of a  powerful presticide
I — 2.4.5-T — on forests of Oregon and
 Washington  should  be extended to
 other chemicals Some women in
 Washington  and Oregon  blamed
 2,4.5-T for miscarriages
   Even the experts within the Envi.
 ronmental Protection Agency (EPA)
 are divided as to the advisability of
 aerial spraying                '
   Mama Marshall, director of EPA's
 pesticide research program  believes
 Sevin "does  not pose an imminent
 hazaid " But  she concedes "unneces-
 sary exposure"  should  be  avoided
 and no one can conclude "Ilie risk is
     IN  HIS   RESEARCH,  WcllS Sa>S
 othei  r.PA researchers have found
 Carbaiyl  (from which Sevin is
 made) causes birth detects in rats
and shouldn't be used near water —
where it can become a part of the
food chain
  Officials of tbe agriculture depart-
ment, which  conducts  the  aenal
spray programs for gypsy  moth in
Michigan, claim precautionary steps
were being  taken in  Bloomfleld
  Lakes and ponds were off limits to
aerial spraying, as were school  bus
stops The area around George Way
Elemtnary School was to be doused
at 6 30 a m, long before classes start-
ed The wooded area to be sprayed is
bounded by Telegraph. Long Lake
Lahser and Timberlake
  But the spraying was called off
after, Case  says,  "outsiders stam-
peded" a  hearing called to discuss
ihe program  "They" were people
mostly outside the township, along
with environmentalists  and Cran
brook people "
  Mrs John Selick, who  heads  a
homeowner group within the area to
be sprayed, claims that 103 of 110
members in her organization backed
the spraying
  "We carefully researched and dis-
cussed the sprajmg before we de-
cided we wanted it," she said
  MUCH  OF  THE 600 acres  to be
sprayed contains  virgin growth ol
oak  on  which  the gypsy  moth
thrives It  also likes the leaves of
maple and crab  apple trees that a-
bound in the area
  Case.  Mrs  Selick  and  other
residents are incensed over a leaflet
sent home with elementary students
from Way School, in the spray areas
which was headed "Important Warn-
  The unsigned leaflet warned that
"one of the recent  theories concern-
ing Reye's Syndrome (which has kill
ed four youngstes in Michigan so far
this year) is that the disease mat
have a direct relation to insecticide
spraying "
  Way school officials say the leafle.
was distributed by "a small group" o
a  Parent-Teachers  Organization,  ;
decision which is now being review
ed because of protests  There is m
scientific evidence that the chemica
contributes to the ailment
  CASE WANTS THE state and federa
officials  "to resolve  conllictm.
claims" so the spraj mg program ca:
be  carried  out  next  May  Aeria
spraying is effective only when th.
larva emerges from its  egg masse
and begins  feeding on Icates Iron
mid to-late May

. MT  PLEASANT-Chemical warfare against
 the  gypsy moth  caterpillar  will commence
 tomorrow. Thursday,  if  central  Michigan
 weather  conditions are favorable  for aerial
I spraying
   A  ruling  issued last  Wednesday in  the
 Ingham  County  Circuit  Court  gave   the
 Michigan  Department of Agriculture (MDA)
 the  go-ahead  to  conduct  the  spraying as
   An  airplane loaded  with  the  pesticide
 Dimilm W 25 is slated for take-off from the Ml
 Pleasant  City  Airport at daybreak  to begin
 MDA's 19SO gypsy moth management plan
   The  plan calls for Dimilm to be used in the
 treatment of wooded areas in portions of Clare.
 Isabella.   Mccosta,  Monlcalm .  and  Osccola
   Other   chemical,  trapping  or  biological
 measures  are  planned  for Bcrnen, Calhoun.
 Van Burcn and Wayne counties
   A planned spraying with the pesticide Sevin
 over 600 acres of wooded residential property
 in Oakland County was cancelled last week by
 the Bloomfield Township board
   Concerns   among   Bloomfield  Township'
 residents that Sevin may pose a human health
1 hazard match thnsc of area critics who oppose
 the use of the more potent Dimilm.
   MDA has  enlisted  the  aid  of the U. S.
 Department of  Agriculture  (USDA)  in  con-
 ducting and  funding its  program aimed at
 eradicating the gypsy moth in Michigan.
   Agriculture officials  claim the pesticide.'
 they use are safe, and that Dimilm, in  par
 ticular. is the most effective pesticide available
 for eradicating the foliage-consuming pest.
   If the gypsy moth is not controlled,  they say
 defoliating  whole forests by  the  insect could
 have a severe aesthetic and economic impact
 on the state                            '  <
   Last Wednesday's hearing before Judge Ray,
 Hotchkiss was  the  result of a  preliminary
 injunction  the  judge  issued  against  th,
 spraying in 1978.
   The 1978 court action was brought about by '
 a Clare  County based citizens group. Citizens
 Against  Chemical   Contamination   (CACC),
 which formed that year to oppose the spraying.
   Ann  Hunt, a  Surrey  Township  organic
 farmer  and  co-chairwoman  'of CACC,  said
 Wednesday's  ruling  imposed   the  same
 restrictions  on the spray program that were
 applied in 1979.
   The 1978 injunction  requires prior court
 approval  before  MDA   can  conduct spray
 programs  Last  year,  the  injunction  was
 modified to  allow limited spraying in wooded
   Exempted from  treatment  with  Dimilin,
 both last year and this year, are the properties
 of organic farmers who request the exemption
 and incorporated villages
   Persons who identify themselves as,organic
 farmers in writing to MDA are allowed a 100-
 foot buffer zone between  their properties and a
 designated spray area
   The only incorporated village affected by the
 ruling, according to  Hunt, is Winn The Winn
•area  is  where  MDA officials believe  the
 current   gypsy  moth infestation  in  central
 Michigan originated
   Incorporated villages,  as designated in  the
 ruling, are allowed a 250-foot buffer zone, and
 do not need to apply for  the exemption, ac-
 cording to Hunt
   The Dimilin spraying  is scheduled  for two
 applications  in the designated areas  Weather
 permitting, the first  application tomorrow will
 be followed by another in seven to ten days
   Dick Moore, district director for  USDA's
 Animal and  Plant Health  Inspection  Service
 (APHIS), said the treatment program should
 be completed by June 12 or 14.
   Hunt suggested that persons wishing to be
 exempted from the  spraying might consider
, putting in an organic garden to qualify.
   Jeffrey Eibling, USDA plant protection and
 quarantine inspector based in  Mt  Pleasant,'
 said, however, that the exemption may apply
 only to bonafidc organic farmers
   This may be a point of contention, he said
 "People  who have a 10 by 20 plot  .. I don't
 know if they'd be exempted or not."
   Hunt noted that there still  may be time in
 get an exemption if the weather is unfavorable
 for spraying tomorrow, and before the second
   The request for exemption must be made in
 writing to Dean Lovitt (chief  of MDA's plant
 industry  division),  Michigan  Department  of
 Agriculture, Lewis Cass Building, P 0. Box
,30017. Lansing. MI 48909
   Areas in the Buyer's Guide  circulation area
 to be  treated with Dimilin are  listed below.
 Spraying will be conducted primarily in the
 wooded portions of the areas listed
   Broomfield  Township  Sections 2 (EVi).  5
 (S'/i).  8  through 17. 20  through 27, and 34
 through 36
   Deer field Township Sections 16 through 21.
 and 28 through 33.
   Fremont Township Sections 4  through 9, 16
 through 17.20 through 21. and 28  through 33
   Gilmore Township- Sections 5(W'/i)and 6
   Holland Township: Sections 1  through 3,  4
 (EVi).  9(E'/, andSVil. 10.12(N'/i),21 (S'/i), 25
   Sherman Township-Sections 25. and 36(NVi
 and SWA)
  Spraying  in Isabella County will involve  a
 total designated spray  area of 40,640 acres of
 which  20,044  wooded acres will actually be
              CLARE COUNTS
  Spraying in  Section 31  of Surrey Township
 involves a designated spray area of 640  acres
 of which 560  wooded acres will actually be
  Dimilm spraying will also be  conducted in
 about 320 acres of Mccosta  County's Sheridan
Township, 160  acres in Montcalm County's Day
Township and 320 acres in Ferns Township,
and  400  acres  in  Osceola County.

              APPENDIX B


Carl Erickson
Pesticide Inspector, R-V
	 _____ 	 £
(Record of item checked above)
Campbell ^^ 5/?K/Bn
Michigan Gypsy Moth Control Program
             Called to inform Mr. Erickson of my intended suggestions  or  recommendations
        concerning safety precautions relating to the Michigan pesticide  application
        program.  This information was related with the intention of implementing  these
        suggestions before the program was completed rather than waiting  for  submission
        of a written report to Region V.

             The following suggestions were conveyed to Mr. Erickson:

             1.    Additional protective clothing for the contracted applicator
                  conducting the mixing operation in the form of rainwear and boots.
                  Other necessary protection was worn.

             2.    Kytoon crews during Sevin application by helicopter  should, in
                  addition to head gear and ponchos, wear face shield  or  goggles.

             3.    During mixing operations a method should be devised  to  prevent
                  escape of pesticide dust through the loading port.

             4.    Personnel  in loading areas retreat to a safe distance during
                  mixing operations to prevent contact with escaping pesticide dust.
       Mr. Erickson will  relate  this  information to the appropriate parties super-
       vising the spraying  program.
      /Harp, Schneider
e°* Form 1300.4 (7-72)   REPLACES EPA
                             MQ roau sjoo-s WHICH MAY BE USED UNTIL SUPPLY 15 EXHAUSTED.