There has been
some concerns expressed on the use of imidacloprid based upon
discovery of the chemical in monitoring wells in Long Island,
NY. Below are
excerpts from a document entitled
”HYDROGEOLOGIC FRAMEWORK OF LONG ISLAND”
http://geophysics.geo.sunysb.edu/wen/Geo315/LIGr/LIGr.htm
This outlines the overall geology of Long Island.
The surface materials of the island consist primarily of
glacial drift and outwash including materials primarily of
sand and gravel sizes.
The text from Table 1 states:
“Mainly sand and gravel of moderate to high
permeability; also includes clayey deposits of low
permeability.”
The clays are generally incorporated as lenses within the
larger grained deposits and tend to not serve as a barrier to
water migration.
The
permeability of this material is very high with a porosity of 30
to 35% primarily in interconnected pore spaces.
The horizontal hydraulic conductivity (K) of this surface
deposit was measured at 230 ft/day and a vertical hydraulic
conductivity of 23 feet per day was measured in the sediments.
Hydraulic
conductivity, symbolically represented as K,
is a property of soil or rock, that describes the ease with
which water can move through pore spaces or fractures.These
are very high values. In
typical soil materials the hydraulic conductivity is measured in
inches or fractions of inches per day.
K (ft/day)
|
105
|
10,000
|
1,000
|
100
|
10
|
1
|
0.1
|
0.01
|
0.001
|
0.0001
|
10−5
|
10−6
|
10−7
|
Relative
Permeability
|
Pervious
|
Semi-Pervious
|
Impervious
|
Aquifer
|
Good
|
Poor
|
None
|
Unconsolidated
Sand
& Gravel
|
Well
Sorted Gravel
|
Well
Sorted Sand or Sand & Gravel
|
Very
Fine Sand, Silt, Loess,
Loam
|
|
Unconsolidated
Clay & Organic
|
|
Peat
|
Layered
Clay
|
Fat
/ Unweathered Clay
|
Consolidated
Rocks
|
Highly
Fractured Rocks
|
Oil
Reservoir Rocks
|
Fresh
Sandstone
|
Fresh
Limestone,
Dolomite
|
Fresh
Granite
|
Source:
modified from Bear, 1972
Long
Island is essentially a giant pile of sand.
On Long Island are acres and acres of lawn and many gold
courses. Private
land owners to some extent, and gold courses use extremely large
amounts of pesticides to treat their lawns.
A major if not the major chemical used for insect control
on the gold courses is imidacloprid.
If you dump tons of water containing imidacloprid on a
giant pile of sand some of it will seep through into the
groundwater aquifer.
The
comparison to the situation in Long Island to that of individual
hemlocks or hemlock groves being treated with imidacloprid to
kill the Hemlock Wooly Adelgid (HWA) is unrealistic and invalid.
The amount of pesticide being used differs by several
orders of magnitude as does the typical hydraulic conductivity
of the soil sediment. There
are two scenarios areas in which there may be some potential for
imidacloprid to leach into the groundwater in trace
amounts. The first
would be a scenario as exists on Long Island where the surface
materials consist of well sorted sand and gravels.
These may be found in some outwash and till deposits, or
on barrier islands, bars, or capes.
The other scenario are those in karst terrains.
Karst terrains are those in which the major land features
are derived or significantly altered by dissolution of bedrock
– essentially limestone and gypsum bedrock areas.
These if well developed have few or no surface runoff as
all the water not evaporated or transpirated
flows into the bedrock through discrete crevices,
sinkholes, or caves. If
imidacloprid were poured into such an opening it would reach the
groundwater table.
Bayer,
developer of imidacloprid http://www.beekeeping.com/articles/us/imidacloprid_bayer.htm
reports:
“What
happens to imidacloprid in the environment?
The success of imidacloprid as a crop protection product would
have been unthinkable had its short and long term impact on the
environment brought about any adverse effects or irreversible
changes. Assuming a use pattern which guarantees the desired
protective effects, the behavior in and between the compartments
of the environment, biosphere, soil, water, and atmosphere,
depends on physico-chemical and chemical properties defined
principally by the chemical structure. Climatic differences and
diversities of the soils must also be taken also into account.
Which of the theoretical outcomes will predominate following
application of a crop protection product, degradation,
persistence, binding to soil, volatilisation, translocation into
groundwater, runoff into surface due to rainfall after
application, must be established either from physico-chemical
data or by direct measurements.
In the case of imidacloprid it was proven beyond doubt that
persistence of residues in soil due to repetitive application
over several years; translocation into deeper soil horizons,
groundwater, adjacent crops or surface waters; volatilisation;
and transport through the air into other regions can be ruled
out. This has been confirmed again and again by world-wide and
long-term experience following its use in all major crops.
Degradation
in soil
There is broad evidence from research at Bayer, as well as from
independent sources that imidacloprid is degraded continuously
though not very rapidly. Practical trials conducted under
northern European conditions showed the half-life for
dissipation to be less than six months.
Degradation ends with complete mineralization to carbon dioxide,
though binding of intermediate degradates to soil also occurs.
It is important to draw a line between relatively long lasting
residence time and persistence in the soil. Imidacloprid cannot
be classified as being persistent as it does not accumulate.
Long-term trials under worst case conditions with the repeated
use of imidacloprid over several years have demonstrated that
maximum concentrations in soil will reach a plateau and will
decline if no further applications occur.
Mobility in soil and leaching into groundwater
The translocation behaviour and particularly the leaching
potential of a crop protection chemical from soil into
groundwater is equivalent to its inclination for hydrophilic
interactions or for interactions especially with water.
Imidacloprid contains in its molecular structure substituents
which cause a relatively high water solubility and a low
affinity to hydrophobic structures found in ordinary organic
matter. The parameters, which characterise this affinity, are
the partition coefficient for the system octanol-water (Pow-value)
and the soil adsorption coefficient normalised to the content of
organic carbon (Koc-value). Pow and Koc-values are in a range
where, translocation in soil and from soil is still negligible
under ordinary conditions, but where the mobility is already
sufficiently high for systemic action into the roots of plants
or within plants for pest control.
Behaviour in water
Though imidacloprid is not intended to be applied directly in
water, it nevertheless may enter water bodies due to spray drift
or in extreme situations by runoff from treated fields after
rainfall. It has been shown that no unacceptable harmful effects
would occur under these circumstances as the substance will
undergo complete elimination from water by photolytic reactions
and by microbial activity. Though the substance is stable in
sterile water in the dark, it decomposes readily under the
influence of light. Biotic processes under the influence of
microbes present in natural water and its sediments present
another mechanism for the elimination of imidacloprid.”
The key points
in this article is that the “Pow and Koc-values are in a range
where, translocation in soil and from soil is still negligible
under ordinary conditions, but where the mobility is already
sufficiently high for systemic action into the roots of plants
or within plants for pest control.”
The material does not translocate in the soils. It does
not accumulate over time except when it is being continuously
applied. It begins
to decline in concentrations as soon as applications of the
chemical ceases. And finally it degrades rapidly in water in the
presence of sunlight and bacteria.
Any comparisons
between the slight contamination found at long Island,
essentially a giant sand and gravel pile on which tons of
pesticides were dumped, and the treatment of individual trees
with a ground injection application of a few ounces of
imidacloprid in materials with generally magnitudes lower
permeability are inappropriate.
Edward Forrest
Frank, Hydrogeologist
July 18, 2007
-------------------------------------------------------------------------------
HYDROGEOLOGIC
FRAMEWORK OF LONG ISLAND
http://geophysics.geo.sunysb.edu/wen/Geo315/LIGr/LIGr.htm
Nassau and
Suffolk Counties with close to 3 million people are completely
dependent on groundwater for all of their freshwater needs. As a
result the hydrology of Long Island has been extensively
studied. Long Island is completely surrounded by salt water.
The
unconsolidated materials that overlie the bedrock constitute
Long Island ’s groundwater reservoir. These materials can be
classified into several hydrogeologic units on the basis of
hydrologic properties summarized in the following table. Three
major aquifers can be identified: an Upper Glacial aquifer at
the top, the Magothy aquifer in the middle and a deep less
accessible Lloyd aquifer lying just above the Paleozoic
metamorphic basement rocks.
Table 1.
Major hydrogeologic units of the Long Island groundwater
reservoir.
Hydrogeologic
Unit
|
Approximate
Maximum Thickness
|
Water-Bearing
Character
|
Upper
glacial aquifer
|
400’
|
Mainly
sand and gravel of moderate to high permeability; also
includes clayey deposits of low permeability.
|
Gardiners
Clay
|
150’
|
Clay,
silty clay, and a little fine sand of low to very low
permeability.
|
Jameco
aquifer
|
200’
|
Mainly
medium to coarse sand of moderate to high permeability.
|
Magothy
aquifer
|
1000’
|
Coarse
to fine sand of moderate permeability; locally contains
highly permeable gravel, and abundant silt and clay of
low to very low permeability.
|
Raritan
Clay
|
300’
|
Clay
of very low permeability; some silt and fine sand of low
permeability.
|
Lloyd
aquifer
|
300’
|
Sand
and gravel of moderate permeability; some clayey
material of low permeability.
|
Groundwater
Hydrology
Precipitation
enters the groundwater system by infiltration through the porous
soil at Long Island’s surface. The field capacity of soils in
the unsaturated zone is ~ 10-15%, and since the total porosity
of the capillary fringe is ~ 30-35%, the specific yield of these
materials is estimated to be on the order of 15-25%. A
relatively high percentage of wet precipitation can percolate
through the water table into the saturated zone.
The
groundwater flow has vertical and horizontal velocity
components. To simulate the flow, realistic estimates of the
vertical and horizontal conductivities are required. Table 5
compiles conductivity values (inferred from pumping tests) which
were adopted in a recent USGS study.
Table 5.
Horizontal and vertical hydraulic conductivities.
Hydrostratigraphic
Unit
|
Horizontal
Hydraulic Conductivity (ft/day)
|
Vertical
Hydraulic Conductivity (ft/day)
|
Aquifers
Upper
glacial
Outwash
Moraine
|
230
75
|
23
1
|
Magothy
Upper
Lower
|
50
75
|
0.5
0.75
|
Lloyd
|
40
|
0.4
|
Confining
units
Gardiners
|
not
estimated
|
0.004
|
Raritan
|
not
estimated
|
0.0014
|
The thing we
need to remember here is that we are not talking about
large scale applications in which large areas are drenched with
imidacloprid, but directed application to hemlocks through
ground
injections or surface drenching at the base of selected
scattered
hemlocks. We are not talking golf courses or sub-urban lawns. I
don't
think bees being threatened will be a factor in the targeted
applications as bees do not feed upon hemlock...
An off-list response referred to this document:
"A toxicology extension service run by Oregon State,
Cornell, and others
(http://extoxnet.orst.edu/pips/imidaclo.htm)
suggests that:
Effects on Aquatic Organisms: The toxicity of imidacloprid to
fish is
moderately low. The 96-hour LC50 of imidacloprid is 211 mg/l for
rainbow
trout, 280 mg/l for carp, and 237 mg/l for golden orfe. In tests
with
the aquatic invertebrate Daphnia, the 48-hour EC50 (effective
concentration to cause toxicity in 50% of the test organisms) was 85
mg/l (1[Kidd and James. 1991. The Agrochemicals Handbook]).
Products
containing imidacloprid may be very toxic to aquatic
invertebrates.
Breakdown of Chemical in Surface Water: The half-life in water
is much
greater than 31 days at pH 5, 7 and 9. No other information was
found.
Here is data below on the concentrations observed in Long
Island. As
you can see the levels detected are at a maximum of 6.9 ppb.
This
maximum is 30,000x less than the 210 mg/l concentrations that
had 50%
toxicity IN 96 hours for trout and carp, and 10,000x less than
the 50%
toxicity for daphnia.
I expect that soil invertebrates in the immediate area of
application
will be killed by the pesticide. That is what the pesticide is
designed
to do. But since this pesticide is applied to just the area
around the
base of the trees, that will not effect the overall population
of these
invertebrates in the forest in general.
Ed Frank
Letter from Bayer
http://pmep.cce.cornell.edu/profiles/insect-mite/fenitrothion-methylpara/imidacloprid/imidacloprid_nysdec_1004.pdf
Imidacloprid groundwater monitoring on Long Island has been
ongoing
since 1998 Less than 1% of all samples taken had any detections
of
imidacloprid residues and all were low levels (<7 ppb). These
low-level
detects are consistent with modeling originally and
independently
conducted by Bayer, EPA and NYSDEC prior to state approval. Upon
state
approval, an agreement between Bayer and NYSDEC established
mitigation
triggers of 10 and 25 ppb based on the NYSDEC default of 50 ppb
(this is
compared to EPA’s informal MCL of 399)
Imidacloprid NYS DEC Letter - Status of Imidacloprid in New York
State
10/03
http://pmep.cce.cornell.edu/profiles/insect-mite/fenitrothion-methylpara/imidacloprid/imidacloprid_let_1003.html
To date, imidacloprid has been identified at low levels (parts
per
billion), in groundwater samples from approximately twenty
monitoring
and private wells in Nassau and Suffolk Counties. Most
groundwater
detections have been very low, ranging from 0.1 ppb to 2.0 ppb.
However,
imidacloprid has been found in clusters of private wells
down-gradient
of farms, and a recent private well sample in Suffolk County
contained
6.7 ppb imidacloprid. Additionally, imidacloprid has now been
detected
at a golf course monitoring well and at monitoring wells near
trees that
have been treated with imidacloprid by injection. .. The
United
States Environmental Protection Agency (USEPA) Health Advisory
Level
(HAL) for imidacloprid is 399 ug/l.
Imidacloprid NYS DEC Letter - Registration of New Imidacloprid
Products
in New York State as Restricted-Use Products 10/04
http://pmep.cce.cornell.edu/profiles/insect-mite/fenitrothion-methylpara/imidacloprid/imidacloprid_let_1004.html
The first detection of imidacloprid in a private homeowner well
(far
removed from the intended monitoring zone) was in April 2000. To
date,
imidacloprid has been detected at concentrations (0.2 to 7 ppb)
in 12
monitoring wells and 16 down gradient private homeowner wells.
Imidacloprid has also been recently detected at 0.24 ppb in two
Suffolk
County community water supply wells (85 feet and 90 feet deep).
Additionally, imidacloprid has now been detected at a golf
course
monitoring well (0.43 ppb) and at monitoring wells near trees
(0.2 to
5.1 ppb) that have been treated with imidacloprid by trunk
injection for
the Asian Longhorned Beetle (ALB). ***See Notes
below
|