Comment submitted by B. Sachau

THIS AGENCY SHOULD BE CALLED THE ENVIRONMENTAL NON PROTECTION AGENCY SINCE IT DOES NOT PROTECT AMERICAN CITIZENS. PUBLIC COMMENT ON FEDERAL REGISTER OF 8/16/06 VOL 71 #158 PG 47101 40 CFR 180 DOCKET 2005 0018 FRL 8080-7 I OBJECT AND REQUEST A HEARING AND NEW FINDINGS. THE RISK LEVEL BEING USED BY THIS AGENCY IS FAR TOO LOW AND INDEED REPRESENTS SEVERE RISK FOR THE AMERICAN PUBLIC SINCE NO COMBINANT TESTING IS DONE. WHEN TOXICS COMBINE, THEY CAN BE TWO THOUSAND TIMES AS TOXIC AS INDIVIDUALLY. THIS SHOULD NOT BE RELEASED BECAUSE OF ABSOLUTELY NO TESTING IN THIS REGARD. I SEE ABSOLUTELY NO REASON WHY WE SHOULD ALLOW THIS PRODUCT TO GO ON THE MARKET AND MAKE FISH CARRY TOXIC CHEMICALS IN ITS SYSTEM. I SEE NO JUSTIFICATION FOR THAT POSITION BY EPA IN ITS DECISIONS. I SEE THE LACK BY EPA OF JUSTIFYING WHY FISH SHOULD CARRY ANY RESIDUE OVER ZERO OF THIS TOXIC CHEMICAL IN ITS BODY TO BE COMPLETELY UNJUSTIFIED. What are the Health Effects? Short-term: EPA has found endothall to potentially cause the following health effects when people are exposed to it at levels above the MCL for relatively short periods of time: depressed breathing and heart rate. Long-term: Endothall has the potential to cause the following effects from a lifetime exposure at levels above the MCL: increase in size of some internal organs, particularly the stomach and intestine. How much Endothall is produced and released to the environment? EPA estimated total domestic usage in 1982 to have been approximately 1.5 million lbs. Release of endothall to the environment is expected to occur primarily during its use as a pre-emergence, post-emergence, turf and aquatic herbicide and harvest aid. Other sources of release include loss during manufacturing, formulation, packaging or disposal of this herbicide. What happens to Endothall when it is released to the environment? Endothall is expected to be quickly broken down by microbes in soil or water. It is also able to leach through soil into ground water; however, rapid degradation would limit the extent of leaching. Endothall is not likely to accumulate in aquatic life. How will Endothall be Detected in and Removed from My Drinking Water? The regulation for endothall became effective in 1994. Between 1993 and 1995, EPA required your water supplier to collect water samples every 3 months for one year and analyze them to find out if endothall is present above 9 parts per billion. If it is present above this level, the system must continue to monitor this contaminant. If contaminant levels are found to be consistently above the MCL, your water supplier must take steps to reduce the amount of endothall so that it is consistently below that level. The following treatment methods have been approved by EPA for removing endothall: Granular activated charcoal. I SEE NO REASON FOR THIS TOXIC CHEMICAL TO BE INTRODUCED INTO DRINKING WATER. B. SACHAU 15 ELM ST FLORHAM PARK NJ 07932