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Clopyralid Ecological Risk Assessment Final U.S. Department of Interior Bureau of Land Management Washington, D.C. Clopyralid Ecological Risk Assessment Final March 2014 Clopyralid Ecological Risk Assessment Final U.S. Department of the Interior Bureau of Land Management Washington, D.C. March 2014 EXECUTIVE SUMMARY EXECUTIVE SUMMARY The United States Department of the Interior (USDOI) Bureau of Land Management (BLM) administers about 247.9 million acres in 17 western states in the continental United States (U.S.) and Alaska. One of the BLM’s highest priorities is to promote ecosystem health, and one of the greatest obstacles to achieving this goal is the rapid expansion of invasive plants (including noxious weeds and other plants not native to an area) across public lands. These invasive plants can dominate and often cause permanent damage to natural plant communities. If not eradicated or controlled, invasive plants will jeopardize the health of public lands and the activities that occur on them. Herbicides are one method employed by the BLM to control these plants. In 2007, the BLM published the Vegetation Treatments Using Herbicides on Bureau of Land Management Lands in 17 Western States Programmatic Environmental Impact Statement (17-States PEIS). The Record of Decision (ROD) for the 17-States PEIS allowed the BLM to use 18 herbicide active ingredients, including clopyralid, available for a full range of vegetation treatments in 17 western states. The BLM is proposing the continued use of the active ingredient clopyralid to treat vegetation. This Ecological Risk Assessment (ERA) evaluates the potential risks to plants and animals from the use of the herbicide clopyralid, including risks to rare, threatened, and endangered (RTE) plant and animal species. The BLM previously relied upon the clopyralid risk assessment conducted on behalf of the U.S. Department of Agriculture Forest Service (Forest Service). This ERA updates information in the Forest Service risk assessment and evaluates risks to plants and animals based on treatment methods and application types and rates used by the BLM. Herbicide Description Clopyralid is a selective, systemic herbicide used primarily in the control of broadleaf weeds and woody brush. It is a plant growth regulator and acts as a synthetic auxin or hormone, altering the plant’s metabolism and growth characteristics and often causing a proliferation of abnormal growth that interferes with the transport of nutrients throughout the plant. Clopyralid is used for vegetation control in the BLM’s Rangeland, Public-Domain Forestland, Energy and Mineral Sites, Rights-of-Way, and Recreation programs. Herbicide application is carried out through aerial and ground dispersal. Aerial applications are performed using airplanes and helicopters. Ground applications are executed on foot or on horseback with backpack sprayers or from all-terrain vehicles, utility vehicles, or trucks equipped with spot or boom/broadcast sprayers. The BLM typically applies clopyralid at 0.25 pounds (lbs) acid equivalent (a.e.) per acre (ac), with a maximum application rate of 0.5 lbs a.e. /ac. ERA Objectives and Methods The main objectives of this ERA were to evaluate the potential risks to the health and welfare of non-target plants and animals and their habitats from the use of clopyralid, and to provide risk managers with a range of generic risk estimates that vary as a function of site conditions. The ERA consisted of the following steps based on guidance in the Vegetation Treatments Programmatic EIS Ecological Risk Assessment Protocol Final Report (Methods Document). The guidance was used in conducting analyses for the 18 herbicide active ingredients evaluated in the 17-States PEIS, and was developed by the BLM in cooperation with the United States Environmental Protection Agency (USEPA), National Oceanic and Atmospheric Administration National Marine Fisheries Service, and USDOI U.S. Fish and Wildlife Service. 1. Exposure pathway evaluation – The effects of clopyralid on several ecological receptor groups (in other words [i.e.], terrestrial animals, non-target terrestrial plants, fish and aquatic invertebrates, and non-target aquatic plants) via particular exposure pathways were evaluated. The resulting exposure scenarios included the following: • direct contact with the herbicide or a contaminated water body; BLM Vegetation Treatments ERA - Clopyralid ES-1 March 2014 BLM Order No. L10PD04555 AECOM Project No. 6018.6154 EXECUTIVE SUMMARY • indirect contact with contaminated foliage; • ingestion of contaminated food items; • off-site drift of spray to terrestrial areas and water bodies; • surface runoff from the application area to off-site soils or water bodies; • wind erosion resulting in deposition of contaminated dust; and • accidental spills to water bodies. 2. Definition of data evaluated in the ERA – Herbicide concentrations used in the ERA were based on typical and maximum application rates provided by the BLM. These application rates were used to predict herbicide concentrations in various environmental media (for example [e.g.], soils, water). Some of these calculations required computer models: • AgDRIFT® was used to estimate off-site herbicide transport due to spray drift. • GLEAMS was used to estimate off-site transport of herbicide in surface runoff and root zone groundwater. • AERMOD and CALPUFF were used to predict the transport and deposition of herbicides sorbed to wind- blown dust. 3. Identification of risk characterization endpoints – Endpoints used in the ERA included acute mortality; adverse direct effects on growth, reproduction, or other ecologically important sublethal processes; and adverse indirect effects on the survival, growth, or reproduction of salmonids. Each of these endpoints was associated with measures of effect such as the no observed adverse effect level and the median lethal effect dose and concentration (LD50 and LC50). 4. Development of a conceptual model – The purpose of the conceptual model was to display working hypotheses about how clopyralid might pose hazards to ecosystems and ecological receptors. These hypotheses are shown via a conceptual model diagram of the possible exposure pathways and the receptors for each exposure pathway. In the analysis phase of the ERA, estimated exposure concentrations (EECs) were identified for the various receptor groups in each of the applicable exposure scenarios via exposure modeling. Risk quotients (RQs) were then calculated by dividing the EECs by herbicide- and receptor-specific or exposure media-specific Toxicity Reference Values (TRVs) selected from the available literature. These RQs were compared to Levels of Concern (LOCs) established by the USEPA Office of Pesticide Programs (OPP) for specific risk presumption categories (in other words [i.e.], acute high risk, acute high risk potentially mitigated through restricted use, acute high risk to endangered species, and chronic high risk). Uncertainty Uncertainty is introduced into the herbicide ERA through the selection of surrogates to represent a broad range of species on BLM lands, the use of mixtures of clopyralid with other herbicides (pre-mixes or tank mixtures) or other potentially toxic ingredients (i.e., degradates, inert [other] ingredients, and adjuvants), and the estimation of effects via exposure concentration models. The uncertainty inherent in screening level ERAs is especially problematic for the evaluation of risks to RTE species, which are afforded higher levels of protection through government regulations and policies. To attempt to minimize the chances of underestimating risk to RTE and other species, the lowest toxicity levels found in the literature were selected as TRVs, uncertainty factors were incorporated into these TRVs, allometric scaling was used to develop dose values; model assumptions were designed to conservatively estimate herbicide exposure, and indirect as well as direct effects on species of concern were evaluated. BLM Vegetation Treatments ERA - Clopyralid ES-2 March 2014 BLM Order No. L10PD04555 AECOM Project No. 6018.6154 EXECUTIVE SUMMARY Herbicide Effects Literature Review According to the Ecological Incident Information System database run by the USEPA OPP, clopyralid has been associated with 205 reported “ecological incidents” involving damage or mortality to non-target flora or fauna. In 99 of these 205 incidents, it was listed as probable (95 incidents) or highly probable (4 incidents) that clopyralid was responsible for the given incident. A review of the available ecotoxicological literature published since 20041 was conducted in order to evaluate the potential for clopyralid to negatively directly or indirectly affect non-target taxa. This review was also used to identify or derive TRVs for use in the ERA. Peer-reviewed literature was only used in the ERA if the study conformed to specific suitability parameters related to the test material, test species, exposure route, and toxicity endpoint as described in the Methods Document. Studies were excluded if they did not meet the requirements defined in the suitable study parameters. The sources identified in this review indicate that clopyralid poses little to no acute toxicity hazard to mammals via dermal and oral exposure. The herbicide also has little toxic impact on birds, terrestrial invertebrates, fish, aquatic invertebrates, and aquatic plants. However, non-target terrestrial plants are susceptible to clopyralid toxicity at application rates recommended for noxious weed control. Concentrations of clopyralid as low as 0.0027
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