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

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
PESTICIDE USE OBSERVATIONS
MONROE COUNTY, FLORIDA
March-June 1979
January 1980
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
DENVER, COLORADO

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CONTENTS
PAGE
I INTRODUCTION-	i
II SUMMARY AND CONCLUSIONS	5
III METHODS	8
IV RESULTS AND DISCUSSION	12
Reconnaissance Survey	12
Water Samples	12
Air Samples	15
Oyster, Shrimp and Fish Samples	18
Crab Samples	20
Hydrographic Samples	22
Surface Film Samples	25
Mosquito Control Program Evaluation	27
REFERENCES	28
APPENDIX
A.	Analytical Methodology	30
B.	Investigation Participants	32
C.	Region IV Pesticides Inspector's Report	33
TABLES
1	Sampling Station Descriptions
Monroe County, Florida. June, 1979.	10
2	Analyses of Samples Collected During Reconnaissance Survey,
Monroe County, Florida. March, 1979. '	13
3	Analyses of Water Samples for Naled and Baytex,
Monroe County, Florida. June, 1979.	14
4	Analyses of Hi-Vol Filters for Naled and Baytex,
Monroe County, Florida. June, 1979.	17
5	Analyses of Oyster, Shrimp, and Fish for Naled and Baytex,
Monroe County, Florida. June, 1979.	21
6	Hydrographic Conditions Recorded at Everglades National
Park, June 3-13, 1979.	24
7	Analyses of Filters for Surface Film Detection of Naled
and Baytex, Monroe County, Florida. June, 1979.	26

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CONTENTS (Cont'd.)
FIGURES
Geographic Location of Pesticide Investigation, Florida.
June, 1979.
PAGE
2 Station Locations, Monroe County, Florida, June, 1979.
11

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PESTICIDE USE OBSERVATIONS
MONROE COUNTY, FLORIDA
I. INTRODUCTION
Annually, the Monroe County Mosquito Abatement Program in southern
Florida has, in late March or early April, applied organophosphate
insecticides Baytex and Naled (Dibrom 14)*, to control mosquito
infestations in urban and rural areas of the Florida Keys. In the
upper Keys, Naled is applied aerially and Baytex by ground application
along U.S. Highway 1 between Key Largo and the Florida mainland.
Allegedly, these pesticides enter Everglades National Park in water
currents, biotic food chains, direct overspray, drift, or runoff.
National Park Service personnel claim that these insecticide applications
are causing damage to the park and the surrounding marine environment.
These damages are declared to be most noticeable in the bait shrimp fishery,
and to a lesser extent in the general commercial finfish and shellfish
fisheries in the area of the insecticide applications. Recently, the death
of a brown pelican in the park area was attributed to Baytex ingestion.
As a result of inquiries from the National Park Service, the EPA
Region IV requested the National Enforcement Investigations Center (NEIC)
to conduct an investigation into the use of insecticides for mosquito
control in Monroe County, Florida. The objectives of the investigation
were 1) to determine if the applications are conducted according to the
pesticide label and FIFRA regulations, and 2) to determine the extent and
nature of environmental damage in Everglades National Park and the
surrounding marine environment as a result of insecticide applications.
* Dibrom 14, EPA Registration No. 239-1721-AA
Baytex, EPA Registration No. 3125-148-AA

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2.
The area under consideration lies at the southern tip of Florida
and comprises the marine portion of Everglades National Park and
Key Largo in Monroe County [Figure 1]. The Park system is southwest
of the causeway linking the mainland and the keys and west of the
intercoastal waterway which is considered the boundary. These waters
are separated by various narrow land masses and include Long Sound,
Little Blackwater Sound, Blackwater Sound, Little Buttonwood Sound,
Buttonwood Sound and Florida Bay. The area is also dotted with small
low-lying islands. Most of the Sounds are relatively shallow, averaging
about 5 feet (1.5m) with sandy or sandy-silt type bottoms.
Tidal differences in the inner Key waters are slight, usually
in a range of inches. Exchange of waters is principally controlled
by the direction and velocity of the wind. Tidal exchange was minimal
in the confined area of this study.
Naled (Dibrom 14) is applied aerially from a fixed wing aircraft
as a thermal fog at 0.48a (16 fluid ounces) per 0.4 ha (1 acre) using
the following formulation:
Ground application of Baytex is accomplished with gasoline-operated
Ultra Low Volume (ULV) Fog Generators mounted on 1/2 ton trucks.
Baytex 93% Liquid Concentrate Insecticide is applied at the rate of
0.03 i (1 fluid ounce) per minute at a truck speed of 16 km/hr (10 mph).
Dibrom 14
Ortho additive
No. 2 Diesel Fuel
X-Lite Fog oil
456 liters (120 gal.)
627 liters (165 gal.)
7,277 liters (1915 gal.)
3,040 liters (800 gal.)
11,400 liters (3,000 gal.)

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FIGURE 1.
Geographic Location of Pesticide
Florida. June, 1979.
Investigation

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4.
Aerial application when performed is from about 6:00AM to 8:00AM
and from approximately 7:30PM to 9:30PM. Ground fogging activities
when done are between sundown and sunrise. Appendix C.
To ascertain the effects of the Monroe County Mosquito Abatement
Program, NEIC conducted a pesticide use-observation which consisted of
pre-application sampling in March, 1979 followed by a thorough investiga-
tion in June, 1979. During both studies, samples were collected from the
marine environment of Everglades National Park and analyzed to determine
the levels of the insecticides Maled and Baytex. Appendix A. Samples
from the marine system consisted of fish, shellfish and water. In-situ
exposures of fish, shrimp, and shellfish were monitored during the June
investigation. Air sampling equipment was located on the perimeter of
2
the Everglades Park to determine spray drift characteristics .
Follow-up sampling of surface water film using filter paper was
done in July by National Park Service personnel. Except for on-site
hydrographic field analyses, all samples collected were preserved and
returned to NEIC for analysis.
The work was performed under established NEIC chain-of-custody
and document control procedures (i.e., each sample was tagged, custody
sheet completed, field data recorded in log book, etc.). Samples
collected during the investigation were in proper custody from the
time of collection until analyses were completed.
Field personnel followed applicable NEIC Safety Requirements during
the study which consisted of appropriate safety attire during boat
and land sampling,
o
Field sampling was conducted by NEIC personnel assisted by members of
the National Park Service. Analyses of environmental samples were com-
pleted by Chemistry Branch personnel at NEIC. Appendix B.

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5.
II SUMMARY AND CONCLUSIONS
From June 3 to 14, 1979, a pesticide use observation study was
conducted by the National Enforcement Investigations Center (NEIC)
in Monroe County, Florida- During the study, an EPA team evaluated
the environmental effects resulting from the aerial application of
Naled (Dibrom-14) arid ground application of Baytex for the control
of mosquitos.
SUMMARY
1.	A reconnaissance survey in March of the marine environment in
the Everglades National Park revealed no pesticide residues
were detected prior to the initiation of the mosquito control
program by Monroe County.
2.	Lack of precipitation in the spring reduced mosquito breeding
activities and consequently the necessity for intensified pesti-
cide applications. Records indicate only three aerial and two
ground applications occurred from June 3 to 14, 1979.
3.	Of the thirty-seven surface water samples collected from the
Everglades Park marine environment, two contained detectable
amounts of pesticide. At Station 10 on June 5, Naled was found
at a concentration of 0.02mg/l. On June 14 at Station 04, Naled
appeared at a concentration of 0.06yg/l. No Baytex was found
in the water samples.
4.	Pesticide drift into the area adjacent to the Park was confirmed
by the use of Hi-Vol air samplers at Station 12 (Ranger Station)
on three occasions. On June 4, filter paper in the Hi-vol
samplers captured 0.18ug of Baytex sprayed via ground appli-
cations. June 5 and 12 the air monitoring filters revealed a
capture of 0.06yg and 0.02yg respectively.

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6.
5.	Uptake by exposed marine organisms of the applied pesticide
was negligible. The only observed instance of uptake occurred at
Station 05 (Manatee Creek) where the oysters accumulated an
average of 0.0007pg/g of Naled. Baytex was not found in
detectable amounts.
6.	Field analyses of hydrographic conditions were made daily
throughout the 11-day study to determine if the aquatic environ-
ment affected the survival rate of the test animals. From
June 3 to 14, records revealed that conditions were at a
seasonal norm and as such appeared to have had no direct influence
on test organism survival during the exposure studies.
7.	The test to relate the presence of an oily film on the water
surface to a pesticide incursion into a nan-target area proved
inconclusive. Two filter paper samples of a surface film were
obtained and neither contained measurable amounts of Naled nor
Baytex.
8.	The Monroe County Mosquito Control District supervises the dis-
posal of used containers at a local sanitary landfill which oper-
ates a drum crusher. The Safety Director was advised that,
because Naled and Baytex are kept in Group II containers, it is
recommended that each empty container be triple rinsed and crushed
prior to disposal in a landfill.

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1.	Limited precipitation and the consequent diminishing of mosquito
control activities by Monroe County probably lessened an observable
pesticide impact on the Everglades National Park marine environment
during the study. However, indications of pesticide intrusion into
the Park or adjacent marine waters were recorded on six occasions
which involved both Naled and Baytex. These results imply that
more precise applications practices should be adopted by the Mosquito
Control District.
2.	Disposal methods of used containers by the Monroe County
Mosquito Control District were not in compliance with FIFRA regula-
tions. The District failed to triple rinse containers before crushing
and disposal as regulation [Sec. 165.9(b)] recommend. Although the
District was reminded of this fault, further efforts should be made to
determine if correct disposal practices are now being followed for used
containers and the resulting rinse waters.
3.	Except for failing to follow FIFRA regulations pertaining to
recommended disposal of used containers, the Monroe County Mosquito
Control District is in conformity with proper pesticide control
practices.

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8.
III. METHODS
Several species of local fauna were used to access the environ-
mental impact resulting from the possible influx of pesticides on
the Everglades National Park marine ecosystem. In some instances,
marine specimens were placed in-situ in pre-determined locations
and monitored throughout an eleven-day study while secondary efforts
were made to capture indigenous species for pesticide uptake analyses.
The test organisms used for in-situ experiments were pinfish, Loqodon
rhomboides, shrimp, Penaeus duorarum, and oysters, Ostrea frons.
Additional species were either trapped or caught by otter trawl and
consisted of blue crabs and a diverse assortment of small fish.
The pinfish and shrimp used for in-situ exposure were purchased
locally and the oysters were gathered in an area known as Joe Bay,
located several miles west of the zone under investigation. Ten fish
and ten shrimp and as many as eighty small oysters were placed in
perforated bait buckets near the water surface at six locations
(Table 1, Figure 2). The condition of the exposed animals was moni-
tored daily. The shrimp, because of their molting habits, were replaced
by fresh animals after seven days. The originally exposed fish
and oysters remained in-situ for the eleven-day study.
Field analyses of hydrographic conditions were obtained at the
six exposure locations to determine if the aquatic environment was
conducive to animal survival. These measurements of the marine
ecosystem involved daily recordings of dissolved oxygen, water temp-
erature, pH, and salinity.

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9.
Surface water and sediment samples, for pesticide analyses, were
collected at the same six locations on three occasions during the study.
Because of the rapid breakdown characteristics of Neled {Dibrom 14)
the water samples were immediately forwarded to NEIC for chemical
analyses.
Other exploratory sample collecting devices used were not
directly associated with the pesticide impact on the aquatic environ-
ment but rather were used to evaluate the likelihood of pesticide
drift into the Everglades National Park resulting from adverse air
currents during specific applications- The devices used were battery
operated high-volume air samplers equipped with B" x 10" (20x25cm)
paper filters located on the face plate to capture pesticide residue.
These devices were placed in operation when either a land or aerial
pesticide application was anticipated.
To test the theory that a surface film of oil might be associated
with pesticide drift (pesticide and diesel oil are mixed for fogging
applications), supplementary sampling was conducted following the June
survey. This sampling was done in the original survey zone by Forest
Service personnel using filter paper to absorb the surface film of
suspected oil and pesticide. The filter papers suspected of being
contaminated with pesticide were immediately forwarded to NEIC for
analysis.

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10.
TABLE 1
SAMPLES AND STATION DESCRIPTIONS
•PESTICIDE USE OBSERVATIONS
MONROE COUNTY, FLORIDA
RECONNAISSANCE SURVEY
Station Number
01
02
03
04
05
06
07
09
OBSERVATION STUDY
Station Number
01
04
05
08
09
10
10A
12
March, 1979
Description
Channel Marker #56
Channel Marker #54
Channel Marker #48A
Blackwater Canal
Manatee Creek
Shell Creek
Joe Bay
Davis Cove
June, 1979
Description
Channel Marker #56
Blackwater Canal
Manatee Creek
Blackwater Sound, West
Davis Cove
Blackwater Sound, East
Gilbert's Marina Dock
Ranger Station Dock, Key Largo
Base Data Samples
20	Tampa Shrimp Holding Water
(Bill's Bait Shop)
21	Tampa Shrimp (Bill's Bait Shop)
22	Biscayne Bay Shrimp
23	Control Shrimp (Bill's Bait Shop)
25	Pinfish Holding Water (Ron's Bait Shop)
26	Pinfish (Ron's Bait Shop)
27	Oysters (Joe Bay)
28	Pinfish (Buttonwood Sound, North)
SURFACE FILM STUDY	July, 1979
Station Number	Description
29	0.5 mi. West of Marker #57A
30	0.25 mi. N.W. of Marker #57A

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FIGURE 2. Station Locations, Monroe County, Florida, June, 1979.

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12.
IV. RESULTS AND DISCUSSION
Reconnaissance Survey, March, 1979
Prior to the full-scale pesticide use study scheduled for
June, 1979 a reconnaissance or pre-application investigation was under-
taken in the area of potential pesticide contamination. This survey
was in March, 1979 for the purpose of selecting areas to be monitored
and for the collection of various types of samples to determine back-
ground conditions. These samples consisted of surface water, local
fish species, and sediment. Seven of the water samples obtained
were analyzed and none contained Naled or Baytex. Analysis of fish
from Davis Cove and sediment from Blackwater Canal revealed no
detectable amounts of either Naled or Baytex [Table 2]. These results
provided evidence that the area to be investigated was uncontaminated
by any significant amount of Naled or Baytex prior to the initiation
of the 1979 mosquito control program.
Use Observation Study, June, 1979
Low mosquito abundance prior to and during the study, because
of an unseasonable decrease in local precipitation, resulted in a
less intensified program of pesticide application, both aerially and
from the ground. Records indicate only three aerial and two ground
applications occurred between June 3 and 14.
Water and Sediment Samples
Over a period of 11 days there were 37 surface water samples
collected from the Everglades Park marine environment. Separate

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13.
TABLE 2
ANALYSES OF SAMPLES COLLECTED DURING RECONNAISSANCE SURVEY
MONROE COUNTY, FLORIDA
March, 1979
Station
Number
Station Description
Date
Naled
to/1)
Baytex
Water
01	Marker 56
02	Marker 54
03	Marker 48A
04	Blackwater Canal
05	Manatee Creek
06	Shell Creek
07	Joe Bay
3/13/79
3/13/79
3/13/79
3/13/79
3/13/79
3/13/79
3/13/79
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Fish
09
Davis Cove
3/14/79
NDL
ND
Sediment
04
Blackwater Canal
3/14/79
ND
ND
None Detected - The detection limit for the preliminary study
was 1.0ug/l for Naled and 0.5yg/l for Baytex.
None Detected - The detection limit for the preliminary study
was 0.005pg/l for Naled and 0.02ng/l for Baytex.
c None Detected - The detection limit was 0.1m9/1 for both
Baytex and Naled.

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14.
TABLE 3
ANALYSES OF WATER SAMPLES FOR NALED AND BAYTEX
MONROE COUNTY, FLORIDA
June, 1979
Station


Naled
Baytex
Number
Station Description
Date
(pq/l)
(pq/1)
20
Bil11s Bait Shop,

a
h

Shrimp Holding Tank
Ron's Bait Shop
6/4/79
NA
ND°
25
6/4/79
NA
ND
01
Channel Marker #56,




Buttonwood Sound
6/5/79
ND
ND
04
Blackwater Canal
6/5/79
ND
ND
05
Manatee Creek
6/5/79
ND
ND
08
Blackwater Sound, West
6/5/79
ND
ND
09
Davis Cove
6/5/79
ND
ND
10
Blackwater Sound, East
6/5/79
0.02
ND
01
Channel Marker #56,




Buttonwood Sound
6/11/79
ND
ND
04
Blackwater Canal
6/11/79
ND
ND
05
Manatee Creek
6/11/79
ND
ND
08
Blackwater Sound, West
6/11/79
ND
ND
09
Davis Cove
6/11/79
ND
ND
10
Blackwater Sound, East
6/11/79
ND
ND
08
Blackwater Sound, West
6/13/79
NA
ND
01
Channel Marker #56,




Buttonwood Sound
6/14/79
ND
ND
04
Blackwater Canal
6/14/79
0.06
ND
05
Manatee Creek
6/14/79
ND
ND
08
Blackwater Sound, West
6/14/79
ND
ND
09
Davis Cove
6/14/79
ND
ND
10
Blackwater Sound, East
6/14/79
ND
ND
a Not analyzed.
b None Detected - The nominal detection limit for Naled was 0.02yg/l
and for Baytex O.Olpg/l. These limits varied due to sample size
and interferences.

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15.
samples were obtained at each station for analysis of Naled and Baytex.
The nominal detection limit for Naled is 0.02yg/l and for Baytex
O.Olyg/1 [Table 3]. Naled was the only pesticide detected. At
Station 10 on June 5, Naled was found at a just detectable concentra-
tion of 0.02yg/l. On June 14 at Station 04, Naled appeared at a
concentration of 0.06ug/l. Both of these stations are located at
the north-east zone of the study area and because the flight pattern
of the application plane is along U.S. Highway 1, they would likely
be susceptible to minor drift or overspray contamination.
An influx of pesticide into the area of Station 04 could
possibly be attributed to run-off or direct drift from an aerial
application. That found in the vicinity of Station 10 could also
be the result of run-off or the direct contamination of canal waters
traveling between Barnes Sound and Blackwater Sound.
Sediment samples were collected but not analyzed.
Hi-Volume Air Samples
Pesticide drift was monitored with high volume air samplers. For
the major part of the study one Hi-Vol sampler was assigned to
Station 12, the Ranger Station, Key Largo, and another was situated
at Station 10A, Gilbert's Marina Dock. At these two locations, the
air filtering devices were operated on a nightly basis for the capture
of ground applied Baytex. These stations were both situated on boat
docks over or adjacent to waters in the study area and would thus verify
a possible occurrence of pesticide drift into the marine environment.

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16.
Pesticide drift into the Buttonwood Sound area was confirmed
by air samples at Station 12 on three occasions. On June 4,
when Baytex was applied in the vicinity, 0.18yg was captured on the
filter paper. An all night operation on June 5 revealed a Baytex
capture in the amount of 0.06yg. A final instance of ground
applied pesticide drift took place during the evening of June 12
when 0.02ug of Baytex was collected on the filter [Table 4].
Prior notification of a scheduled aerial fogging application
of Naled on June 12 allowed the placement of five high volume air
sampling devices in the southern and north-eastern perimeter of the
study zone. These established positions were Stations 01 and 12
in Buttonwood Sound, Stations 08 and 10 in Blackwater Sound, and
Station 05 at Manatee Creek.
The air filtering device located at Station 10 was incapacitated
before the aerial application and therefore only four filter papers
were retrieved as samples.
Chemical analyses of the filter papers removed on the day of
the aerial application revealed that Naled was not present in
detectable amounts, indicating no major drift of the pesticide into
the marine environment from the aerial application on June 12.

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17.
TABLE 4
ANALYSES OF HI-VOL FILTERS FOR NALED AND BAYTEXa
MONROE COUNTY, FLORIDA
June 1979
Station ~ " Naled'3 Baytex
Number Station Description	Date	(yg)	(yg)
Hi-Vol Filters
12
Ranger Station Dock
6/3/79
..
NDC
12
Ranger Station Dock
6/4/79
--
0.18
10A
Gilbert's Dock
6/5/79
—
ND
12
Ranger Station Dock
6/5/79
—
0.06
10A
Gilbert's Dock
6/6/79
—
ND
12
Ranger Station Dock
6/6/79
—
ND
10A
Gilbert's Dock
6/7/79
—
ND
12
Ranger Station Dock
6/7/79
--
ND
12
Ranger Station Dock
6/8/79
—
ND
12
Ranger Station Dock
6/9/79
--
ND
12
Ranger Station Dock
6/10/79
--
ND
12
Ranger Station Dock
6/11/79
—
ND
01
Channel Marker #56,




Buttonwood Sound
6/12/79
ND
ND
05
Manatee Creek
6/12/79
ND
ND
08
Blackwater Sound,




West
6/12/79
ND
ND
12
Ranger Station Dock
6/12/79
ND
0.02
12
Ranger Station Dock
6/13/79
—
ND
12
Ranger Station Dock
6/14/79

ND
10A
Gilbert's Dock
6/14/79
—
ND
a The detection limit for Naled was 0.02yg, for Baytex O.Olpg.
b Air samples collected and analyzed for Naled on 6/12 only,
c Non detected.

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18.
Oyster Samples
Oysters from Joe Bay used iri the exposure tests at the six
established locations suffered varied and wide degrees of survival.
These differences in survival rates ranged from 83 at Station 01 in
Buttonwocd Sound to a high of 90% at Station 05, in Manatee Creek.
Per cent survival at the remaining stations were: 04 (76*), 08 {45%},
09 (80%) and 10 (16%). Hydrographic conditions observed during the
11-day exposure period appeared normal for the season and consequently
cannot be considered the attributing cause of the mortalities encountered
during the in-situ experiment. The paucity of confirmatory analytical
results relating mortality to pesticide uptake in oysters during this
study leaves the reason for the wide range of mortalities to either
poor initial handling or an unknown natural cause.
Oyster samples from Stations 01, 0^, 05, 09 and 10 were analyzed
for possible pesticide uptake. Of these only Station 05 in Manatee
Creek produced a trace of pesticide. Naled was found at an average
concentration of Q.0007pg/g [See Appendix]. The nominal detection
limits for both Naled and Baytex are 0.0003 pg/g- These limits varied
due to sample size and interferences [Table 5]. The intrusion of
Naled into Manatee Creek (Station 05} and its accumulation by the
in-situ oysters (Q.0007ug/g) "is confirmatory proof that the pesticide
was entering the Everglades National Park aquatic system via some
route. Whether this entrance was the result of aerial overspray, wind
drift or translocation from Manatee Bay by way of the connecting culvert,
is undetermined. Dilution and the rapid breakdown characteristics of

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19.
Naled are the probable reasons for its undetectability in water
samples from this general area.
Shrimp Samples
After seven days of exposure, all shrimp were removed from the
six in-situ test locations and replaced with fresh specimens.
Survival rate was between 70 and 100 percent for these initial
exposures. There appeared to be no definite relationship between
shrimp mortalities and the application of pesticides. Chemical
analyses for the determination of possible pesticide uptake were made
on the original shrimp from Stations 01, 04, 09 and 10. Neither
Baytex nor Naled was detected in the test shrimp. The nominal
detection limit for Naled was 0.003ijg/g and for Baytex it was
O.OOlyg/g. These limits varied due to sample size and interferences
[Table 5].
In-situ Fish Studies
Survival studies conducted for 11 days at the six locations in
the Everglades National Park marine environment were inconclusive.
Rates of fish survival at each station was between 10 and 20% and
consequently did not provide an adequate amount of sample for chemical
analyses. Poor survival rate was attributed to the delicate physio-
logical characteristics of the pinfish and possibly resulted from
the excessive handling that was necessary in preparing the fish for
exposure tests.

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20
To compensate for the high percentage of fish loss in the
exposure tests and the resulting small sample, additional pinfish for
chemical analyses were captured at three locations using a bottom
fishing otter trawl. Each location was fished on two occasions
during the late evenings of June 6 and 12. The particular areas
were situated near Stations 08, 10, and 28 in Buttonwood Sound. Fishing
time at each location was ten minutes and each catch was bagged,
labeled, and returned to NEIC.
Because a water sample on June 5 from Station 10 (Blackwater
Sound, east} indicated a trace of Naled, 0.02pg/l, pinfish collected
during a night fishing trip at Station 10 on June 12 were selected
for chemical analysis. Both the viscera and muscle from a random
sample of the catch, ten fish (7 to 10 cm total length) was used
for the analysis. Neither Naled nor Baytex was found in detectable
quantities in the sample. The detection limits for viscera were
0.005ug/g for Naled and 0.Q02yg/g for Baytex; for muscle they were
0.004jjg/g for Naled and 0.002ug/g for Baytex [Table 5],
Blue Crabs
In order to analyze a wide spectrum of commercial species in
the marine environment for possible pesticide contamination, attempts
were made to capture the blue crab, Callinectes sapidus. Two
baited commercial-type crab traps were set at each of the six
monitored locations in the study area. These traps were inspected
and re-baited on a regular basis during the study; however, insufficient
numbers of blue crabs were caught to perform chemical analyses for
pesticides.

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21
Table 5
Analyses of Oyster, Shrimp, and Fish for
Naled and Baytex
Monroe County, Florida
June, 1979
Station
Number
Station Description
Date
Naled
(yg/g)
Baytex
(yg/g)
Oysters




01
Channel Marker #56,
Buttonwood Sound
6/14/79
NDa
ND
04
Blackwater Canal
6/14/79
ND
ND
05
Manatee Creek
6/14/79
0.0007
ND
09
Davis Cove
6/14/79
ND
ND
10
Blackwater Sound,
East
6/14/79
ND
ND
Shrimp




01
Channel Marker #56,
Buttonwood Sound
6/11/79
NDb
ND
04
Blackwater Canal
6/11/79
ND
ND
09
Davis Cove
6/11/79
ND
ND
10
Blackwater Sound,
East
6/11/79
ND
ND
Fish (otter trawl)



10
Blackwater Sound,
East-Viscera
6/12/79
ND°
ND
10
Blackwater Sound,
East-Muscle
6/12/79
ND
ND
None Detected - The nominal detection limits for Naled and Baytex
were both 0.003 yg/g. These limits varied due to sample size and
interferences.
None Detected - The nominal detection limit for Naled was 0.003yg/g
and for Baytex it was O.OOlyg/g. These limits varied due to sample
size and interferences.
None Detected - The detection limits for viscera were 0.005yg/g for.
Naled and 0.002yg/g for Baytex; for muscle they were 0.0004yg/g
for Naled and 0.0002yg/g for Baytex.

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22.
Hydrographic Conditions
Field analyses of hydrographic conditions were made daily
throughout the study to determine if the aquatic environment affected
the survival rate of the test animals. From June 3 to 13, records
revealed that conditions were at a seasonal norm and as such
appeared to have had no direct influence on the exposure studies.
Average surface water temperature varied one or two degrees
centigrade at all locations and these differences were attributed
to either the time of day or degree and length of cloud cover. The
average range of water surface temperature was between 29.4°C
and 30.6°C [Table 6].
Unlike water temperature, the salinity varied according to
location and was influenced by the confines of land areas and the
exchange of waters from adjoining areas. Stations 01, 04, 08, and 10
were located in areas where free exchange of water was limited and evap-
oration the probable reason for high salinities. Contrasting these
high saline waters are those of more brackish waters at Station 05 and
09. Station 05 located at the eastern end of Manatee Creek had the widest
range of salinity (13.5-31.0 ppt) and the lowest average (20.4 ppt).
Tidal exchange between Manatee Creek and Manatee Bay, northeast of
Barnes Sound, through a 5 ft. (1.5m) diameter culvert, accounts for
this wide variation in salinity. Freshets from Glades Canal into
Manatee Bay appear to cause the occasional low saline waters found
in Manatee Creek. Moderate salinities at Station 09 in Davis Cove,
average 28.2 ppt, can be attributed to fresh water run-off from the
Everglades National Park lake system. The brackish waters in this
location probably fluctuate according to season.

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23.
The pH at all stations remained relatively steady throughout
the study and remained in the realm of that expected for sea water
(7.5-8.4)1.
Dissolved oxygen at most stations appeared normal during the
study and whatever differences were found were believed to be either
caused by the time of day the sample was collected or the intensity
and duration of cloud cover. Station 10 produced some unaccountable
results which ranged between a low of 2.5 and a high of 7.9. All
the samples at this location resulted in an average dissolved oxygen
content of 4.3.

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24.
TABLE 6
HYDROGRAPHIC CONDITIONS RECORDED AT
EVERGLADES NATIONAL PARK
JUNE 3-13, 1979
Nation
dumber
Temperature(°C)
Salinity^
PH
Dissolved
Oxygen

Range
Average
Range
Average
Range Average
Range
Sverage
01
27.4-32.2
29.6
36.2-38.2
36.8
7.9-8.3
4.9-7.6
6.1
04
28.6-32.1
30.6
29.8-37.0
33.5
7.8-8.3
4.2-8.3
6.2
'05
27.5-32.0
30.4
13.5-31.0
20.4
8.0-8.2
3.5-7.6
6.7
08
27.8-31.6
29.4
29.1-37.1
35.7
7.9-8.2
3.3-8.1
5.7
|o9
28.0-32.1
30.4
26.0-31.5
28.2
8.0-8.3
6.2-8.9
7.5
10	28.1-30.7 29.5 34.9-37.9 36.8 7.9-8.2	2.5-7.9 4.3

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25.
Surface Film Detection
Surface film samples were collected by Park Service personnel
on July 17, 1979 from a marine area south of Buttonwood Sound inside
the boundary of Everglades National Park. These samples were
obtained from an oil slick assumed to be related to pesticide drift
from a recent aerial application. Chemical analyses of these filter
papers for Baytex and Naled proved negative. The detection limits on
these samples were 0.2|ig for Naled and O.Ol^g for Baytex [Table 7].
Further efforts to collect surface film samples were suspended on
August 1, 1979.

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26.
TABLE 7
ANALYSES OF FILTERS FOR SURFACE FILM DETECTION
OF NALED AND BAYTEX
MONROE COUNTY, FLORIDA
JULY, 1979
Station.
Number
Station Description
Date
Time
Naled
(yg)
Baytex
(yg)
29
1/2M West of Intercoastal
Waterway Marker 57A,
Everglades National
Park
7/14/79
0830
NDa
ND
30
1/4M NW of Intercoastal
Waterway
7/14/79
0805
ND
ND
a None Detected - The detection limits were 0.2pg for Naled and
0.01 jag for Baytex.
b These stations were assigned new numbers to avoid duplicity.

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27.
Mosquito Control Program Evaluation
The Monroe County Mosquito Control District uses approximately 1500
gallons of Baytex and 2800 gallons of Naled annually. All pesticide
materials are received in 30 gallon drums which entails the disposal of
about 140 empty drums each year.
The District Safety Director supervises the disposal of all drums
at a local landfill located at Long Key. This facility is used because
of the availability of a drum crusher. Each empty container, although
unrinsed, is crushed to prevent possible reuse.
The Safety Director was advised by the EPA Region IV Pesticides
Inspector that because Naled and Baytex are stored in Group II containers,
O
it is recommended by FIFRA regulation [Sec. 165.9(b)] that each empty
container be triple rinsed and crushed prior to disposal in a landfill.
Appendix C.
Except for the above infraction, the Monroe County Mosquito Control
District is in conformity with proper pesticide control practices.
3 165.9 Recommended procedures for the disposal of pesticide containers
and residues, (b) Group II Containers. Non-combustible containers which
formerly contained organic or metallo-organic pesticides, except organic
mercury, lead, cadmium, or arsenic compounds, should first be triple-
rinsed. Containers in good condition may then be returned to the pesti-
cide manufacturer or formulator, or drum reconditioner for reuse with the
same chemical class of pesticide previously contained providing such reuse
is legal under currently applicable U.S. Department of Transportation
regulations including those set forth in 49 CFR 173.28. Other rinsed
metal containers should be punctured to facilitate drainage prior to
transport to a facility for recycle as scrap metal or for disposal. All
rinsed containers may be crushed and disposed of by burial in a sanitary
landfill, in conformance with State and local standards or buried in the
field by the user of the pesticide. Unrinsed containers should be dis-
posed of in a specially designated landfill, or subjected to incineration
in a pesticide incincinerator.

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28.
REFERENCES
1 Sverdrup, H. U., M. W. Johnson, R. H. Fleming. 1949.
The Oceans. Prentice-Hall, Inc., P. 194.

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APPENDIX A
ANALYTICAL METHODOLOGY

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30.
ANALYTICAL METHODOLOGY
Water - The water samples were analyzed by the NEIC as described
in "Method for Naled and DDVP in Environmental Water samples". No
cleanup procedures were necessary. The extracts were concentrated
to 1 ml to lower the detection limit.
Sediment, Shrimp, Oysters, Fish Viscera, and Fish Muscle -
These samples were analyzed by the NEIC as described in "Method for
Naled, DDVP, and Baytex in Soil, Vegetation, and Fish". The three
cleanup procedures were used as necessary. The final volume of
the extracts varied from 1 to 10 ml, depending on the level of inter-
ferences in the individual extracts.
Hi-Vol Filters - The filters were analyzed by the NEIC as
described in "Method for Baytex on Hi-Vol Filters". No cleanup pro-
cedures were necessary. The extracts were concentrated to 1 ml to
lower the detection limit.
Confirmation - All reported values of Naled and Baytex were
confirmed by dual-column chromatography. The retention times were
identical on both a non-polar column (6 ft, glass 10% 0V-101) and a
polar column (14 ft, nickel, 5% 0V-210).
QUALITY CONTROL PROCEDURE
Nineteen spike, twelve replicate, and fourteen blank samples were
analyzed during the survey. None of the blanks contained any substances
which interfered with Naled or Baytex. Only one of the replicate samples
contained detectable levels of either Naled or Baytex. This sample, an
oyster at Station 05, contained an average of 0.0007yg/g of Naled.

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31.



Naled



#1 #2
Replicate
Station Description
Date
(pg/g) (vg/g)
05
Manatee Creek
6/14/79
0.0002 0.0013
The results of the eight water spikes were consistent with the
recoveries expected from the method.
Amount	% Recoveries	Standard
Pesticide of Spike	#1 #2 #3 #4 Average Deviation
Water Spikes
Naled	10ug	57 52 62 85 64	13
Baytex	5pg	100 104 97 102 101	2.6
The results of the eleven spikes of other matrices varied widely
depending on the matrix and the type of cleanup procedure which was
employed.
Amount of
Matrix	Pesticide	Spike (pg)	% Recovery
Hi-Vol Filter
Naled
1
44

Baytex
0.04
62

Baytex
0.04
75
Shrimp
Naled
10
36

Baytex
10
58
Oysters
Naled
10
27

Baytex
10
96
Fish Viscera
Naled
10
44

Baytex
10
35
Fish
Naled
Baytex
10
10
38
27

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APPENDIX B
INVESTIGATION PARTICIPANTS

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32.
INVESTIGATION PARTICIPANTS
National Enforcement Investigations Center
Robert Campbell, Project Coordinator
Bruce A. Binkley, Biologist
John T. Ellison, Biologist
Geraldine Hilden, Environmental Protection Assistant
Kathleen Carl berg, Chemist
Konrad Nottingham, Chemist
EPA, Region IV, Pesticides Branch
James B. Griffin, Pesticides Inspector
Carlton Layne, Pesticides Inspector
National Park Service
Richard H. Dawson, Marine Biologist
H. C. Blatt, District Ranger
F. Whitehead, District Ranger

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APPENDIX C
REGION IV - PESTICIDES INSPECTORS REPORT

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United States
Environmental Protection
Agency
Region 4
345 Courtland Street NE
Atlanta GA 30308
Alabama, Georgia. Florida/	f
Mississippi. North Carolina, 33;
South Carolina, Tennessee.
Kentucky
ESTABLISHMENT INSPECTION REPORT
FIRM NAME: Monroe County Mosquito Control District
Stock Island
Key West, Florida
DATE OF INSPECTION: 3/13/.79 - 3/14/79
SUMMARY OF FINDINGS:
The Monroe County Mosquito Control District has held accession
numbers for two products. These are Dibrom Fog Solution" EPA
Accession number 10400, and "Ma lath ion Solution", EPA accession
number 10401. These two accession numbers were cancelled effective
February 26, 1979 on request of Mr. Robert J. Bent ley, Director
of the mosquito control district.
The district no longer does any pesticides manufacturing within
meaning of FIFRA. The district is still using "Dibrom" in a
liquid spray application and In thermal fogging. Use of Dibrom in
thermal fogging was approved in April 1977 by the State of Florida
under Section 24(c) of the FIFRA. Records in Atlanta office indicate
this 24(c) registration was cancelled by EPA in July, 1977.
This district no longer uses Malathion since the mosquitoes in this
area have developed resistance to this chemical.
The district uses "Baytex" for ground fogging for mosquito control.
The district also uses altosid and Larviciding Oil for mosquito
Larvae controI.
HISTORY OF ESTABLISHMENT:
This mosquito control district is funded by Monroe County and the State
of Florida on a. matching funds basis. The previous director,
Mr. Robert Bentley has been replaced as of December, 1978 by Mrs. Lois
Ryan who-is acting director.
Mrs. Ryan is assisted by Mr. John Chalbeck, Chief Pilot and Mr. Robert
Ferguson, Safety Director. Mr. Chalbeck has the overall responsibility
for thq, operation of the aircraft utilized in spraying "Dibrom".
Mr. Ferguson is In charge of disposal of pesticide containers as well
as the direction of the ditching and draining operations.
GOVERNMENT PRINTING OFFICE; 1978 — 746-732/1304

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34.
CONSUMER COMPLAINTS:
Mr. Chalbeck showed the Inspector a chart that had 8 different locations
where people have requested no spraying be done. These locations are
breeders of tropical fish and "Sea World". Mr. Chalbeck said they
instructed their pilots to cut out these areas. So far they had no
complaints that these areas have actually been sprayed.
DISPOSAL DATA:
Mr. Robert Ferguson stated he personally disposed of all empty con-
tainers. The district uses approximately 1500 gallons of Baytex and
2800 gallons of Dibrom annually. All materials are received in 30
gallon drums, therefore, there would be approximately 140 empty drums
to dispose of each year.
Mr. Ferguson said they did not rinse the drums prior to disposal.
All drums are disposed of at the Long Key landfill. This facility
Is utilized because they have a drum crusher. Mr. Ferguson makes
sure each drum Is crushed to prevent possible reuse.
DISTRICT OPERATION:
AERIAL APPLICATION:
Mrs. Ryan and Mr. Chalbeck stated the only product applied aerially is
Dibrom. Three methods of applicafton are utilized. These are:
1. Low Volume aerial spraying - Mix as follows:
Dibrom 14 Insecticjde - 120.0 gallons
Ortho additive	- 165.0 gallons
No. 2 Diesel Fuel -1915.0 gal Ions
X Lite Fog OiI	- 800.0 gal Ions
Yield - 3000.0 gaI Ions
ormulation applied at rate of 16.0 Fluid Ounces per acre.
2. Aerial Thermal Fogging - Mix as follows:
Dibrom 14 Insecticide - 120.0 gallons
Ortho additive	- 165.0 gallons
No. 2 Diesel Fuel	- 1915.0 gallons
X-Lite Fog 011	- 800.0 qa1 Ions
3000.0 gaI Ions
Formulation applied at rate of 16 fluid ounces per acre.
3. Ultra Low Volume Spraying
.75 to 1.0 fluid ounces Dibrom applied per acre. Equivalent
of .0875 to .1093 pounds technical "Naled" per acre.

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35.
Aerial application Is performed at dusk from approximately 7:30 P.M.
to 9:30 P.M. and at dawn from about 6:00 A.M. to 8:00 A.M. The
decision to treat a given area is based on mosquito landing rate
counts. New Jersey light trap collections, and telephone complaints.
GROUND APPLICATIONS OF CH6MICALS
LARVIC1DING
Application of Larviciding materials are made by 9 truck mounted
gasoline operated Larviciding Pump Units and 4 John Bean Larviciding
Units. Materials used for ground larviciding are as follows:
1.	Larviciding Oil Formulation:
Triton X207 - 3.0 Pints
30 Wt. ND Motor Oil - 1.0 gallons
No. 2 Diesel Fuel to make - 100 gallons
This material Is applied at rate of 4.0 gallons per acre.
2.	Altosid SR-10 Formulation
1.0 fluid ounce of altosid SR-10 to 1.0 gallon water.
Applied at rate of 4.0 fluid ounces altosid per acre.
ADULTICIDING - GROUND
Application of aduiticiding material Is accomplished with 12 gasoline oper-
ated ULV Fog Generators mounted on £ ton trucks.
Materials used: Baytex 93? Liquid Concentrate Insecticide - applied ULV
at the rate of one (I) fluid ounce per minute, truck speed 10 M.P.H.
All ULV fogging activities-wl11 be carried out between
the hours of sundown and sun-up.
DISCUSSION WITH MANAGEMENT:
The information In this report was supplied by Mrs. Lois Ryan, Acting
Director, Mr. John Chalbeck, Chief Pilot and Mr. Robert Ferguson,
Safety Director. These Individuals all stated no Baytex was applied
aerially. DIbrom is used exclusively for aerial application and while
they have previously used the ULV method in tests they have found this
is not effective in the Keys. The thermal fogging method is used almost
exclusively although some Low Volume liquid spraying may be done.
Aerial spraying will begin about April 1f 1979 and continue sporadically
through December. Historically the 3C-47's used by this district have
operated about 200 hours each annually for a totaf of 600 hours of aerial
spraying.

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36.
Ground equipment Is operated on a year round basis to cover any hot spots
of mosquitoes and areas that cannot be sprayed aerially. The ground
applications are made between the hours of sundown and sun-up. Baytex
is the chemical to be applied by ground equipment.
The Inspector pointed out to Mrs. Ryan and Mr. Ferguson that containers
should be triple rinsed prior to disposal In a landfill.
Attachments:
CR DOC
Notice of Inspection
Receipt for samples

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