Appendix D 2013 DP Aquatic Control Technologies treatment report and treatment path

December 18, 2013

Wayland Surface Water Quality Committee Attn: Michael P. Lowery, Project Manager Wayland Town Building

41 Cochituate Road Wayland, MA 01778‐2614

Re: Year‐End Report for 2013 Renovate OTF Herbicide Treatment Program at Dudley Pond

Dear Mr. Lowery:

Please accept the following as our year‐end report for the Renovate OTF herbicide spot‐treatment program performed at Dudley Pond in 2010 for control of Eurasian watermilfoil (Myriophyllum spicatum). The treatment was performed in accordance with the product label directions, conditions of the Order of Conditions and Chapter 194 Permit for Dudley Pond (DEP 332‐698) issued by the Wayland Conservation Commission, and the License to Apply Chemicals (No. 13248) issued by MA DEP. The following report details the treatment program and monitoring tasks conducted by Aquatic Control Technology during the 2013 season.

Introduction and Management History

Dudley is a 90‐acre waterbody located in the Town of Wayland, Massachusetts. Eurasian watermilfoil (milfoil) was first confirmed in Dudley Pond in 1991 and several herbicide treatments and non‐chemical control strategies have been employed over the past two decades to manage the infestation.

In 2008, the Wayland Surface Water Quality Committee (WSWQC) prepared a long‐term milfoil management plan that was initiated with a whole‐pond Sonar (fluridone) herbicide treatment program during the 2008 season.

Follow‐up management has included annual diver hand‐pulling, spot‐treatment of 15 acres with Renovate OTF herbicide (triclopyr granular) in 2010, and diver hand‐pulling efforts to remove milfoil root crowns following the herbicide treatment programs. In 2013, the WSWQC identified seven distinct areas ranging in size from 1.8 acres to 4.8 acres. After minor modifications made immediately prior to treatment, a total of 18.1 acres were treated with Renovate OTF herbicide in June 2013.

2013 Treatment Program Chronology A chronology of the 2013 treatment program is provided below:

    

Order of Conditions and Chapter 194 Permit compliance .........................................(handled by WSWQC 2009‐2013) DEP License to Apply Chemicals issuance (# 13248) ................................................................................................6/25 Renovate OTF Herbicide Treatment.........................................................................................................................6/28 Triclopyr Herbicide residue monitoring (4 rounds collected by WSWQC) ...............................7/9, 7/16, 7/31 and 8/27 Late season survey by ACT.....................................................................................................................................10/11

Aquatic Control Technology 11 John Road ● Sutton, MA 01590-2509 ● (508) 865-1000 ● Fax (508) 865-1220 ● info@aquaticcontroltech.com

2013 Dudley Pond Renovate OTF Treatment Program Report

2013 Treatment Program Protocol Treatment areas (Figure 1) were provided by WSWQC and were reviewed with ACT immediately prior to treatment. Seven areas totaling approximately 18.1 acres were targeted for treatment. Renovate OTF was again selected for use in 2013. The granular formulation carries the active ingredient to the lake bottom, where it is released within 24‐48 hours following application. This helps maximize herbicide concentration‐exposure‐time with the targeted milfoil plants and helps limit dilution that might be attributed to surface currents and wind driven mixing. Renovate OTF was applied at 215 pounds per acre, which translates into approximately 2.0 ppm based on the bottom four feet of the water column. This rate was used effectively at Dudley Pond during the 2010 treatment. A total of 3,890 pounds of Renovate was were applied to the 18.1 acres.

WSWQC applied sandbags to the outlet structure prior to treatment to prevent any outflow. It was our understanding that still no outflow had occurred when the second round of water samples were collected for FasTEST analysis on 7/31/13.

Summary of 2013 Treatment

Milfoil plants were observed to have more than 5‐6 feet of active growth at the time of the June 28th treatment.

This treatment occurred almost six weeks later than the 2010 treatment. The milfoil plants were more mature at the time of the treatment, but we believe that was actually beneficial because there was more active plant biomass for herbicide absorption.

Weather conditions on the day of treatment were partly sunny. The air temperature was approximately 75 F. Wind was out of the south, estimated at less than 5 mph, resulting in calm water conditions. Prior to treatment, water temperature was measured using a YSI Temperature/Dissolved Oxygen meter at the outer edge of western treatment area.

Table 2: Temperature/Dissolved Oxygen Profile on 6/28/13 Depth (m)

Temperature (C)

Dissolved Oxygen (mg/L)

Surface 1 2

25.4 25.4 24.8

7.67 7.55 6.51

Water clarity was measured to the bottom or greater than 3 meters (10 feet) using a Secchi disk. The pH of the surface water was measured to be between 7.0‐7.5 using a Hach colorimeter.

The treatment was using an airboat equipped with a bow mounted electric cyclone spreader. A Differential GPS navigation system with the treatment areas pre‐loaded was used to insure that the herbicide was evenly applied to the designated treatment areas. A total of 3,890 pounds of Renovate OTF (granular) were applied to the designated treatment areas. Actual passes of the treatment boat were recorded with the DGPS unit and are depicted in Figure 2. The herbicide began at approximately 8:30 a.m. and was completed at 12:00 p.m. The treatment was completed in approximately 3.5 hours.

Herbicide Residue Testing Summary Following the treatment, water samples were collected from Dudley Pond by WSWQC for analysis of the remaining in‐pond triclopyr concentrations. Copies of the actual laboratory reports are provided in the Appendix.

The theoretical lake‐wide triclopyr concentration from the 3,890 pounds that were applied was roughly 200 ppb.

It is unlikely that this concentration was ever present in Dudley Pond at any one time, since triclopyr is released off of the granules over a period of several hours or days. On July 9th, 11 days after treatment (DAT), the measured 2

2013 Dudley Pond Renovate OTF Treatment Program Report

concentrations at the deep‐hole location and near the outlet averaged 70 ppb. On July 16th, 18 DAT, the in‐pond concentration was 50 ppb. On July 31st, 33 DAT, the concentration had dropped to 20 ppb. Finally, by August 27th, 60 DAT, the concentration had dropped to 6 ppb. This triclopyr degradation pattern is similar to what was seen in 2010 and at other waterbodies that we have treated with Renovate OTF in the Northeast. Low levels of triclopyr usually persist for several months post‐treatment.

Chart 1: Dudley Pond FasTEST Results 2013

Triclopyr concentration (ppb)

250 200 150

DP-Hole DP-Outlet

100 50 0 6/28/2013

7/9/2013

7/16/2013

7/31/2013

8/27/2013

According to the Renovate OTF product label, treated water can be used for potable purposes once the concentration drops below 0.4 ppm (400 ppb). The only water use restriction associated with concentrations less than 400 ppb is not to use treated water for irrigation. This restriction does not apply to established grasses.

Late Season Survey Aquatic Control Technology performed its late season survey on October 11th. The majority of the lake perimeter was toured by boat. No milfoil was encountered during the visual inspection or in several rake‐tosses. Non‐target plants that were observed during the survey included:

Table 3: Aquatic plants observed during late‐season survey Species

common name

type

Nitella Najas flexilis Vallisneria americana Potamogeton perfoliatus Potamogeton robbinsii Potamogeton crispus Chlorophyta Nymphaea odorata

stonewort slender naiad wild celery Clasping leaf pondweed Robbins pondweed curlyleaf pondweed filamentous green algae white waterlily

macro‐algae submersed submersed submersed submersed submersed (invasive) algae floating‐leaf

Any impacts to non‐target native plants were not evident by the time the late season survey was performed on September 24th. Some impact to other dicot plants, namely white waterlily, probably occurred immediately after treatment, but the triclopyr concentration was not lethal and the plants recovered by the end of the year. As anticipated, no impact was seen on the other invasive plant in Dudley Pond, curlyleaf pondweed, which is a monocot.

3

2013 Dudley Pond Renovate OTF Treatment Program Report

Table 4: Temperature/Dissolved Oxygen Profile on 10/11/13 Depth (m)

Temperature (C)

Dissolved Oxygen (mg/L)

Surface 1 2 3

17.9 17.6 17.5 17.5

9.62 9.27 9.22 10.72

Water clarity was measured to be 2.5 meters (8.2 feet) using a Secchi disk.

Summary and Ongoing Management Recommendations

Based on reports received from WSWQC and observations by made by Aquatic Control Technology on October 11th, the 2013 Renovate OTF herbicide treatment program appears to have achieved complete control of Eurasian watermilfoil.

Treating nearly 20% of the pond area and having no outflow for several weeks post‐treatment, probably resulted in prolonged exposure to lethal concentrations of triclopyr, which achieved pond‐wide milfoil control. As was seen following the 2010 treatment, we would expect that scattered milfoil regrowth will be found in 2014.

We recommend that the WSWQC continue its aggressive, integrated management program in the coming years.

Managing milfoil before it has an opportunity to recover and reestablish its root structures should prove to be an important factor in extending the duration of milfoil control.

We trust that this report adequately summarizes the 2013 Renovate OTF herbicide treatment program at Dudley Pond.

Again, we would like to thank Mike Lowery and the rest of the WSWQC for assistance and oversight on this project and commend you for your ongoing commitment to managing invasive Eurasian watermilfoil growth in Dudley Pond. Please feel free to contact us if you have any questions or require additional information at this time.

Sincerely,

AQUATIC CONTROL TECHNOLOGY

Marc D. Bellaud

President/Aquatic Biologist

Enclosures: Appendix

4

2013 Dudley Pond Renovate OTF Treatment Program Report

APPENDIX

 

Figure 1 Dudley Pond Renovate OTF Treatment Areas (prepared by WSWQC) Figure 2 GPS Track of Treatment

Herbicide Residue Data  Laboratory Reports

5

Figure 1 (prepared and provided by WSWQC)

Ü

Sources: USDA NAIP, MA GIS

DUDLEY POND Wayland, Massachusetts

2013 Actual Treatment Path FIGURE:

SURVEY DATE:

MAP DATE:

2

06/28/13

07/01/13

Legend

11 JOHN ROAD SUTTON, MASSACHUSETTS 01590 PHONE: (508) 865-1000 FAX: (508) 865-1220 WEB: WWW.AQUATICCONTROLTECH.COM

dudley_actualtreat_062813 ProposedTrt_2013_Lowery

0

220

440

660

880 Feet

LABORATORY REPORT

16013 Watson Seed Farm Road, Whitakers, NC 27891

Chain of Custody:

2013-11798-00

Page 1 of 1 Total Pages

Customer Company

Customer Contact

Company Name:

Aquatic Control Tech Inc

Contact Person:

Marc Bellaud

Address:

11 John Road

E-Mail Address:

mbellaud@aquaticcontroltech.com

Sutton, MA 01590-2509

Phone:

(508) 865-1000

Fax: Waterbody Information Waterbody:

Dudley Pond - MA

Sample Information Sample Lab ID Location 24902 DP- HOLE 24903

Waterbody Size (acres): 86.00

Test Method

Results

Depth Average: 8.0

Sampling Date

Sampling Temp at Time Receipt (C)

07/09/2013 Renovate/Triclopyr (Âľg/L)

77.9

Renovate/Triclopyr (Âľg/L)

62.4

DP-OUTLET

07/09/2013

ANALYSIS STATEMENTS: SAMPLE RECEIPT /HOLDING TIMES: All samples arrived in an acceptable condition and were analyzed within prescribed holding times in accordance with the SRTC Laboratory Sample Receipt Policy unless otherwise noted in the report.

PRESERVATION: Samples requiring preservation were verified prior to sample analysis and any qualifiers will be noted in the report.

QA/QC CRITERIA: All analyses met method criteria, except as noted in the report with data qualifiers.

COMMENTS: No significant observations were made unless noted in the report.

Laboratory Information Date Received: 07/11/2013 Time Received: 10:00 Date Results Sent: / /

Sample Preparation Date: Date Analysis Performed:

07/11/2013 / /

Disclaimer: The results listed within this Laboratory Report relate only to the samples tested in the laboratory. The analyses contained in this report were performed in accordance with the applicable certifications as noted. All soil samples are reported on a dry weight basis unless otherwise noted in the report. This Laboratory Report is confidential and is intended for the exclusive use of SRTC Laboratory and its client. This report shall not be reproduced, except in full, without written permission from SRTC Laboratory. The Chain of Custody is included and is an essential component of this report.

This entire report was reviewed and approved for release.

Reviewed By: SRTC Laboratory Manager CONFIDENTIALITY NOTICE: This electronic transmission (including any files attached hereto) may contain information that is privileged, confidential and protected from disclosure. The information is intended only for the use of the individual or entity named above and is subject to any confidentiality agreements with such party. If the reader of this message is not the intended recipient or any employee or agent responsible for delivering the message to the intended recipient, you are hereby notified that any disclosure, dissemination, copying, distribution, or the taking of any action in reliance on the contents of this confidential information is strictly prohibited. If you have received this communication in error, please destroy it immediately and notify the sender by telephone. Thank you

u_labresults15 Deacom version: 14.4.48

Original

LABORATORY REPORT

16013 Watson Seed Farm Road, Whitakers, NC 27891

Chain of Custody:

2013-12120-00

Page 1 of 1 Total Pages

Customer Company

Customer Contact

Company Name:

Aquatic Control Tech Inc

Contact Person:

Marc Bellaud

Address:

11 John Road

E-Mail Address:

mbellaud@aquaticcontroltech.com

Sutton, MA 01590-2509

Phone:

(508) 865-1000

Fax: Waterbody Information Waterbody:

Dudley Pond - MA

Sample Information Sample Lab ID Location 25146 DP- HOLE 25147

Waterbody Size (acres): 86.00

Test Method

Results

Depth Average: 8.0

Sampling Date

Sampling Temp at Time Receipt (C)

07/16/2013 Renovate/Triclopyr (Âľg/L)

54.1

Renovate/Triclopyr (Âľg/L)

46.8

DP-OUTLET

07/16/2013

ANALYSIS STATEMENTS: SAMPLE RECEIPT /HOLDING TIMES: All samples arrived in an acceptable condition and were analyzed within prescribed holding times in accordance with the SRTC Laboratory Sample Receipt Policy unless otherwise noted in the report.

PRESERVATION: Samples requiring preservation were verified prior to sample analysis and any qualifiers will be noted in the report.

QA/QC CRITERIA: All analyses met method criteria, except as noted in the report with data qualifiers.

COMMENTS: No significant observations were made unless noted in the report.

Laboratory Information Date Received: 07/17/2013 Time Received: 10:00 Date Results Sent: 07/19/2013

Sample Preparation Date:

07/17/2013

Date Analysis Performed:

07/19/2013

Disclaimer: The results listed within this Laboratory Report relate only to the samples tested in the laboratory. The analyses contained in this report were performed in accordance with the applicable certifications as noted. All soil samples are reported on a dry weight basis unless otherwise noted in the report. This Laboratory Report is confidential and is intended for the exclusive use of SRTC Laboratory and its client. This report shall not be reproduced, except in full, without written permission from SRTC Laboratory. The Chain of Custody is included and is an essential component of this report.

This entire report was reviewed and approved for release.

Reviewed By: SRTC Laboratory Manager CONFIDENTIALITY NOTICE: This electronic transmission (including any files attached hereto) may contain information that is privileged, confidential and protected from disclosure. The information is intended only for the use of the individual or entity named above and is subject to any confidentiality agreements with such party. If the reader of this message is not the intended recipient or any employee or agent responsible for delivering the message to the intended recipient, you are hereby notified that any disclosure, dissemination, copying, distribution, or the taking of any action in reliance on the contents of this confidential information is strictly prohibited. If you have received this communication in error, please destroy it immediately and notify the sender by telephone. Thank you

u_labresults15 Deacom version: 14.4.48

Original

LABORATORY REPORT

16013 Watson Seed Farm Road, Whitakers, NC 27891

Chain of Custody:

2013-12808-00

Page 1 of 1 Total Pages

Customer Company

Customer Contact

Company Name:

Aquatic Control Tech Inc

Contact Person:

Marc Bellaud

Address:

11 John Road

E-Mail Address:

mbellaud@aquaticcontroltech.com

Sutton, MA 01590-2509

Phone:

(508) 865-1000

Fax: Waterbody Information Waterbody:

Dudley Pond - MA

Sample Information Sample Lab ID Location 25468 HOLE 25469

Waterbody Size (acres): 86.00

Test Method

Results

Depth Average: 8.0

Sampling Date

Sampling Temp at Time Receipt (C)

07/31/2013 Renovate/Triclopyr (Âľg/L)

23.5

Renovate/Triclopyr (Âľg/L)

17.6

OUTLET

07/31/2013

ANALYSIS STATEMENTS: SAMPLE RECEIPT /HOLDING TIMES: All samples arrived in an acceptable condition and were analyzed within prescribed holding times in accordance with the SRTC Laboratory Sample Receipt Policy unless otherwise noted in the report.

PRESERVATION: Samples requiring preservation were verified prior to sample analysis and any qualifiers will be noted in the report.

QA/QC CRITERIA: All analyses met method criteria, except as noted in the report with data qualifiers.

COMMENTS: No significant observations were made unless noted in the report.

Laboratory Information Date Received: 08/01/2013 Time Received: 10:00 Date Results Sent: 08/02/2013

Sample Preparation Date:

08/01/2013

Date Analysis Performed:

08/02/2013

Disclaimer: The results listed within this Laboratory Report relate only to the samples tested in the laboratory. The analyses contained in this report were performed in accordance with the applicable certifications as noted. All soil samples are reported on a dry weight basis unless otherwise noted in the report. This Laboratory Report is confidential and is intended for the exclusive use of SRTC Laboratory and its client. This report shall not be reproduced, except in full, without written permission from SRTC Laboratory. The Chain of Custody is included and is an essential component of this report.

This entire report was reviewed and approved for release.

Reviewed By: SRTC Laboratory Manager CONFIDENTIALITY NOTICE: This electronic transmission (including any files attached hereto) may contain information that is privileged, confidential and protected from disclosure. The information is intended only for the use of the individual or entity named above and is subject to any confidentiality agreements with such party. If the reader of this message is not the intended recipient or any employee or agent responsible for delivering the message to the intended recipient, you are hereby notified that any disclosure, dissemination, copying, distribution, or the taking of any action in reliance on the contents of this confidential information is strictly prohibited. If you have received this communication in error, please destroy it immediately and notify the sender by telephone. Thank you

u_labresults15 Deacom version: 14.4.48

Original

LABORATORY REPORT

16013 Watson Seed Farm Road, Whitakers, NC 27891

Chain of Custody:

2013-13919-00

Page 1 of 1 Total Pages

Customer Company

Customer Contact

Company Name:

Aquatic Control Tech Inc

Contact Person:

Marc Bellaud

Address:

11 John Road

E-Mail Address:

mbellaud@aquaticcontroltech.com

Sutton, MA 01590-2509

Phone:

(508) 865-1000

Fax: Waterbody Information Waterbody:

Dudley Pond - MA

Sample Information Sample Lab ID Location 26081 DP- HOLE 26082

Waterbody Size (acres): 86.00

Test Method

Results

Depth Average: 8.0

Sampling Date

Sampling Temp at Time Receipt (C)

08/27/2013 Renovate/Triclopyr (Âľg/L)

6.8

Renovate/Triclopyr (Âľg/L)

5.4

DP-OUTLET

08/27/2013

ANALYSIS STATEMENTS: SAMPLE RECEIPT /HOLDING TIMES: All samples arrived in an acceptable condition and were analyzed within prescribed holding times in accordance with the SRTC Laboratory Sample Receipt Policy unless otherwise noted in the report.

PRESERVATION: Samples requiring preservation were verified prior to sample analysis and any qualifiers will be noted in the report.

QA/QC CRITERIA: All analyses met method criteria, except as noted in the report with data qualifiers.

COMMENTS: No significant observations were made unless noted in the report.

Laboratory Information Date Received: 08/28/2013 Time Received: 10:00 Date Results Sent: 08/28/2013

Sample Preparation Date:

08/28/2013

Date Analysis Performed:

08/28/2013

Disclaimer: The results listed within this Laboratory Report relate only to the samples tested in the laboratory. The analyses contained in this report were performed in accordance with the applicable certifications as noted. All soil samples are reported on a dry weight basis unless otherwise noted in the report. This Laboratory Report is confidential and is intended for the exclusive use of SRTC Laboratory and its client. This report shall not be reproduced, except in full, without written permission from SRTC Laboratory. The Chain of Custody is included and is an essential component of this report.

This entire report was reviewed and approved for release.

Reviewed By: SRTC Laboratory Manager CONFIDENTIALITY NOTICE: This electronic transmission (including any files attached hereto) may contain information that is privileged, confidential and protected from disclosure. The information is intended only for the use of the individual or entity named above and is subject to any confidentiality agreements with such party. If the reader of this message is not the intended recipient or any employee or agent responsible for delivering the message to the intended recipient, you are hereby notified that any disclosure, dissemination, copying, distribution, or the taking of any action in reliance on the contents of this confidential information is strictly prohibited. If you have received this communication in error, please destroy it immediately and notify the sender by telephone. Thank you

u_labresults15 Deacom version: 14.4.48

Original