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HomeMy WebLinkAbout2006-06-13; City Council; 18602 Attachment 2; Precise Development Plan and Desalination PlantCouncii Internet Mailbox - CITY OF CARLSBAD I CONTACT US Page 1 From: <mgohl4@adelphia.net> To: <Council@[205.142.109.13]> Date: Sun, Jun 11, 2006 10:51 AM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: I urge approval of the Desalination Project. We need to move forward as a community to meet the growing needs of our own city and the surrounding communities. The argument by the Sierra Club is an old tired one. Their solution is always to "conserve" never create. They want us to do without or less. Don't listen to the tactic of the environmental left. Wise and efficent use of resources is important but not at the cost of creating new sources of drinking water. Mark Gohl 7023 Ivy Carlsbad, CA 92011 mgohl4@adelphia.net Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1; .NET CLR 1.1.4322) 68.65.212.221 AGENDA ITEM #. c; Mayor City Council City Manager City Attorney City Clerk Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US AGENDA ITEM #. Maybf Pagelc: From: <bchartman@adelphia.net> To: <Council@[205.142.109.13]> Date: Tue, Jun 13, 2006 8:02 AM Subject: CITY OF CARLSBAD | CONTACT US City Council City Manager City Attorney City Clerk A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: I have serious concerns about Carlsbad's proposed desalination plant. Issues brought to my attention by Surfride are valid. Please consider all sides to this issue when making a decision. Be wary of anyones motives when they make a financial profit by doing something. William R. Hartman Carlsbad Resident Retired Teacher, Coach of National Champion Surf Teams, 1995-2005 William Hartman ) bchartman@adelphia.net Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1) 68.65.250.138 Page 1 of 1 Marilyn Strong - desalination plant From: "Norma Wolk" <jeanwolk@webtv.net> To: <mstro@ci.carlsbad.ca.us> Date: 06/12/2006 1:26 PM Subject: desalination plant Mayor Lewis, and Council Members, Tuesday, the final nail on the road to financial ruin, for the taxpayers. Followed the Posidon salesmen, since the '80s, great theory...too expensive, as the Saudis have found, as stated in November, Union Tribune. Has any one called Morro Bay (Central Coast) to find out why they closed down theirs, soon after completion. Boondoggle! Norma J Wolk 2457 Levante ST la costa 92009 760-632-7344 file://C:\Documents and Settings\Mstro\Local Settings\Temp\GW} 00001 .HTM 06/12/2006 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <nicholasrrorick@cs.com> To: <Council@[205.142.109.13]> Date: Tue, Jun 13, 2006 5:17 AM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE.********************************************** Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! NICHOLAS RORICK, M.D. 110 S PACIFIC ST OCEANSIDE, CA 92054-2918 nicholasrrorick@cs.com Mozilla/5.0 (Windows; U; Windows NT 5.1; en-US; rv:0.9.4.2) Gecko/20021112 CS 2000 7.0/7.0 205.188.117.7 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <marcoaguilera@hotmail.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 11:28 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You Marco Aguilera 2611 Jefferson St. Apt. E Carlsbad, CA 92008 marcoaguilera@hotmail.com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1) 68.69.230.14 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <lkap501@yahoo.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 11:08 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You, L. Kaplan I kaplan carlsbad, ca Ikap501 @yahoo.com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1; .NET CLR 1.1.4322) 216.103.1.7 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <pauldeke@yahoo.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 11:06 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ******************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE.******** Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You, Paul Paul Dekleermaker Gravilla St La Jolla, Ca 92037 USA pauldeke@yahoo.com Mozilla/5.0 (Macintosh; U; PPC Mac OS X; en-US; rv:1.0.2) Gecko/20020924 AOL/7.0 207.200.116.7 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <jacquegamboa@hotmail.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 10:49 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You Jacque Gamboa Jacque Gamboa La Jolla, CA jacquegamboa@hotmail.com Mozilla/5.0 (Macintosh; U; PPC Mac OS X; en) AppleWebKit/312.8 (KHTML, like Gecko) Safari/312.6 66.75.52.157 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <seanhome@adelphia.net> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 10:18 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You Sean Adams seanhome@adelphia.net Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1; .NET CLR 1.1.4322) 67.23.72.123 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <jsa3211@hotmail.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 9:33 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You jsa3211@hotmail.com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1; .NET CLR 1.1.4322) 67.23.72.123 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <soldiahouz@yahoo.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 9:26 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You Matt Barmore Matthew Barmore 5255 Cass st San Diego, CA 92109 usa soldiahouz@yahoo.com Mozilla/5.0 (Windows; U; Windows NT 5.1; en-US; rv:1.7.8) Gecko/20050511 Firefox/1.0.4 70.95.235.180 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <koberlin1@hotmail.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 9:21 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Council member, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You Kent Oberlin 2619 Fallsview Road San Marcos, Ca 92078 United States koberlinl @hotmail.com Mozilla/5.0 (Macintosh; U; PPC Mac OS X; en) AppleWebKit/418 (KHTML, like Gecko) Safari/417.9.3 72.192.140.151 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <apohlers@yahoo.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 9:01 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You apohlers@yahoo.com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1; .NET CLR 1.1.4322) 68.7.206.207 Council Internet Mailbox - CITY OF CARLSBAD j CONTACT US Page 1 From: <gotsoccer4me@yahoo.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 8:30 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You Erin Martin ) gotsoccer4me@yahoo. com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1) 68.65.251.138 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <surfinberg@yahoo.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 8:23 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You Brian Bergen Brian Bergen 3104 Serrano Dr Carlsbad, CA 92009 surfinberg@yahoo.com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1; .NET CLR 1.1.4322) 75.18.115.125 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <juneymike@sbcglobal.net> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 8:16 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You June Honsberger June honsberger Leuca, juneymike@sbcglobal.net Mozilla/5.0 (Macintosh; U; PPC Mac OS X Mach-O; en-US; rv:1.8.0.4) Gecko/20060508 Firefox/1.5.0.4 71.136.104.243 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <jeffreygere@hotmail.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 7:27 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE.*********** Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You Jeffrey Gere Jeffrey gere carlsbad, ca 92011 jeffreygere@hotmail.com Mozilla/5.0 (Macintosh; U; PPC Mac OS X; en) AppleWebKit/312.8 (KHTML, like Gecko) Safari/312.6 68.65.230.90 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <windswell@hotmail.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 7:10 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Please don't approve Desalt in Carlsbad. Thank You Jon Severino Jon Severino 1930 Skyknoll Way Encinitas, CA 92024 USA windswell@hotmail.com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.0; .NET CLR 1.1.4322) 206.190.72.205 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <hollands@mill.net> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 7:01 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE.********************************************** Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thanks, Tyler Tyler Rowden 861 H avenue Coronado, Ca. 92118 hollands@mill.net Mozilla/5.0 (Windows; U; Windows NT 5.1; en-US; rv:1.7.2) Gecko/20040804 Netscape/7.2 (ax) 74.62.18.123 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <arneydana@hotmail.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 6:45 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE.********************************************** Below, please find the information that was submitted: Please vote no to the desalinization plant in Carlsbad. Thank you for your time. dana arney i arneydana@hotmail.com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; FunWebProducts; SV1; .NET CLR 1.1.4322) 68.230.95.5 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <sblouie@hotmail.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 4:59 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. ********************************************** Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You sblouie@hotmail.com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1; lnfoPath.1) 72.192.138.240 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <jjet65@yahoo.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 4:45 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmembers, I am writing to let you know of my opposition to the proposed desalination plant. Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You John Swan 2907 Corte Celeste Carlsbad, CA 92009 jjet65@yahoo.com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1; .NET CLR 1.1.4322) 68.66.138.101 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <caluckyme@aol.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 4:31 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, SURFRIDER says: Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! please be SURE about this!! this is sooooooo important the Kessler family peg kessler 7781 falda pi carlsbad, ca 92009 caluckyme@aol.com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; YPC 3.0.0; SV1; .NET CLR 1.1.4322) 71.136.118.70 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <james_gilmore@ml.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 3:21 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You James Gilmore 6435 Flamenco Street Carlsbad, CA 92009 james_gilmore@ml.com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1; .NET CLR 1.1.4322) 199.43.32.25 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <kelleeisOQ7@yahoo.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 2:57 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. *************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE.********************************************** Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You, Kellee Kellee Carlsbad, CA 92009 kelleeis007@yahoo.com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1; .NET CLR 1.1.4322) 209.242.160.2 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <snowflake97@aol.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 2:42 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You Melissa Brannen i snowflake97@aol.com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1) 69.63.194.194 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <gustavoy68@sbcglobal.net> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 2:40 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You Gustavo A Yanez Gustavo Yanez 6911 Petit Street San Diego, CA 92111 USA gustavoy68@sbcglobal.net Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.0; .NET CLR 1.1.4322) 207.137.19.2 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <larry_92108@yahoo.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 1:58 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. ********************************************** Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal exploitation at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! I have previously heard that desalinazition costs 4 times as much as other water. 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You Larry Barker Attorney at Law Larry Barker 5987 Caminito Yucatan San Diego, CA 92108 larry_92108@yahoo.com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1) 70.95.197.153 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <Carolnoceanside@cs.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 1:53 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You Carolyn Krammer, Chairperson Citizens for the Preservation of Parks & Beaches 904 Leonard Avenue, Oceanside, CA. 92054 Carolyn Krammer 904 Leonard Avenue Oceanside, Carol noceanside@cs .com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1) 74.62.25.37 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <bbwoods22@yahoo.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 1:51 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ************************* FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Council member, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You Betsy Woods t bbwoods22@yahoo.com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1; .NET CLR 1.1.4322) 70.131.149.39 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <harrisons@saic.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 1:37 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. ********************************************** Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You Scott Harrison Scott Harrison san diego, harrisons@saic.com Mozilla/5.0 (Windows; U; Windows NT 5.1; en-US; rv:1.8.0.4) Gecko/20060508 Firefox/1.5.0.4 198.151.12.8 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <belinda@garymanufacturing.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 1:35 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: I am a business owner, and understand then need for water, but conservation efforts should be first and foremost the plan. Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You Belinda Smith 6199225972 Belinda Smith i belinda@garymanufacturing.com Mozilla/5.0 (Windows; U; Windows NT 5.1; en-US; rv:1.8.0.1) Gecko/20060111 Firefox/1.5.0.1 66.146.188.58 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <acanfield@haleyaldrich.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 1:35 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ********************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Sirs/Madames; I am writing in opposition to the plans for a desalinisation plant in northern San Diego County. As an environmental professional, I am working, on a daily basis, with projects that try to correct the actions taken by government, bussinesses, or individuals who did not fully ponder the effects of their actions. Usually at the behest of the government, I am tasked to undo environmental messes. Usually, these messes are the result of people trying to solve problems plaguing society. Unforntunitally, most project I see cost huge amounts of money to make very bad situations a little less bad. Rarely do environmental problems every return to the state in which they were pre-pollution. Our ecosystems can only be taxed so far; there is a breaking point. By increasing the amount of potable water (at a HUGE cost, no less), we only invite developers who seek only to fatten their wallet with inpunity (to their wake left in our communities). As a citizen of San Diego County, I strongly ! oppose the construction of, and as a result, life-extention of once-through cooling waters, the proposed desalinatization plant. Sincere Regads, Adam Michael Preece Canfield Hydrogeologist Adam Canfield 2669 Figueroa Boulevard San Diego, California 92109 USA acanfield@haleyaldrich.com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.0; .NET CLR 1.1.4322) 12.147.5.146 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <iwasakimiki@yahoo.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 1:32 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You Miki Iwasaki j iwasakimiki@yahoo.com Mozilla/5.0 (Windows; U; Windows NT 5.1; en-US; rv:1.8.0.4) Gecko/20060508 Firefox/1.5.0.4 71.136.132.21 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <anita@surfdog.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 1:18 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You Anita Strine 1126 South Coast Hwy 101 Encinitas, Ca 92024 anita@surfdog.com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1; .NET CLR 1.1.4322; .NET CLR 2.0.50727) 63.193.59.130 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <dave@surfdog.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 1:17 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You Dave Kaplan Dave Kaplan 1126 South Coast Hwy 101 Encinitas, Ca 92024 dave@surfdog.com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1; .NET CLR 1.1.4322; .NET CLR 2.0.50727) 63.193.59.130 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <brianmccaffery12@hotmail.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 12:53 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You brianmccafferyl 2@hotmail.com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; .NET CLR 1.1.4322) 70.95.237.230 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <looneyk@cox.net> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 12:53 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You looneyk@cox.net Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1) 216.79.95.56 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <craigsac@cox.net> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 12:47 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1 . Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You Craig Sacchetti Craig Sacchetti San Diego, Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1; .NET CLR 1.1.4322; .NET CLR 2.0.50727; lnfoPath.1) 68.101.161.87 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <kulongos@hotmail.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 12:47 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands offish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You Justin Kulongoski 412 10th Del Mar, CA 92014 kulongos@hotmail.com Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <jdraves@san.rr.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 12:43 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You Jim Draves Jim Draves Cardiff by the Sea, Ca 92007 USA jdraves@san.rr.com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.0; .NET CLR 1.1.4322) 66.27.118.196 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <tamara_rosenbaum@hotmail.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 12:38 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You Tamara Rosenbaum Tamara Rosenbaum tamara_rosenbaum@hotmail.com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1; .NET CLR 1.1.4322; lnfoPath.1) 216.52.215.232 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <JenHardin10@aol.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 12:38 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You Jennifer , USA JenHardinl 0@aol.com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1; .NET CLR 1.1.4322) 67.125.181.25 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <jeg2@adelphia.net> To: <Council@[205.142.109.13]> Date: Mon, Jun12, 2006 12:33 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You Jill Gravender jeg2@adelphia.net Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1; .NET CLR 1.1.4322) 71.116.219.202 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <siobahn268@yahoo.com> To: <Council@[205. 142.1 09. 13]> Date: Mon, Jun 1 2, 2006 1 2:32 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tarnpa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You Joan Am berg Joan Am berg i siobahn268@yahoo.com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1; .NET CLR 1.1.4322; lnfoPath.1; .NET CLR 2.0.50727) 70.167.122.27 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <alspaugh@scmv.com> To: <Council@[205.142.109.13J> Date: Mon, Jun 12, 2006 12:25 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You John Alspaugh John Alspaugh 3313 Camino Coronado Carlsbad, alspaugh@scmv.com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1) 206.71.188.157 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <akingthomas@hotmail.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 12:24 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. ********************************************** Below, please find the information that was submitted: ar Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You, Alan Thomas Alan Thomas 1300 W 7th Ave #112 Anchorage, AK 99501 akingthomas@hotmail.com Mozilla/5.0 (Macintosh; U; PPC Mac OS X; en) AppleWebKit/418 (KHTML, like Gecko) Safari/417.9.2 216.67.8.163 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <psmiller7@yahoo.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 12:23 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE.********************************************** Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You. Pamela Miller Pamela Lawton PO Box 270504 San Diego, CA 92198 psmiller7@yahoo.com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1) 72.197.207.149 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <bhowerton@heroldsagerlaw.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 12:20 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ****************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You bhowerton@heroldsagerlaw.com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1) 70.167.121.70 Council Internet Mailbox - CITY OF CARLSBAD [ CONTACT US Page 1 From: <jjw@pgsdesign.com> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 12:13 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: As a member of SurfRider, I agree with their position on the Desal plant so: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You Jeff Jeff Walker 2305 Ivy Road Oceanside, CA 92054 USA jjw@pgsdesign.com Mozilla/5.0 (Macintosh; U; PPC Mac OS X; en) AppleWebKit/418 (KHTML, like Gecko) Safari/417.9.3 70.167.112.4 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <bill@surfridersd.org> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 10:25 AM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE.********************************************** Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You Bill Hickman i bill@surfridersd.org Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1) 74.62.25.37 Council Internet Mailbox - CITY OF CARLSBAD j CONTACT US """ ' '" Page 1 From: <farrensms@comstock.navy.mil> To: <Council@[205.142.109.13]> Date: Tue, Jun 13, 2006 11:30 AM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You Michael S. Farrens Michael Farrens 4368 Felton St SAN DIEGO, CA 92104 usa farrensms@comstock.navy.mil Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.0) 192.207.114.20 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <mjmoser007@yahoo.com> To: <Council@[205.142.109.13]> Date: Tue, Jun 13, 2006 12:38 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You, Melissa Moser Melissa Moser 4930 Del Monte Ave. San Diego, CA 92017 USA mjmoser007@yahoo.com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1) 66.122.251.98 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <emmalcook@yahoo.com> To: <Council@[205.142.109.13]> Date: Tue, Jun 13, 2006 1:32 PM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, In San Diego, we live in the midst of such an enviromental marvel - to think that this desal action will not have an equally substantial reaction (destruction of habitat as well as ecosystems), would be extremely naive as well as irresponsible. Please use extreme caution while pursuing this "panacea". Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You! emmalcook@yahoo.com Mozilla/5.0 (Windows; U; Windows NT 5.1; en-US; rv:1.7.2) Gecko/20040804 Netscape/7.2 (ax) 132.239.71.68 Council Internet Mailbox - CITY OF CARLSBAD | CONTACT US Page 1 From: <bill@surfridersd.org> To: <Council@[205.142.109.13]> Date: Mon, Jun 12, 2006 10:25 AM Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear Councilmember, Contrary to what you may have heard, desal water will not offset water taken from the delta or Colorado River. It will increase coastal development at the cost of our environment. Here are some of the problems with the desalination project proposed in Carlsbad: 1. Unproven technology - This will be the largest desal plant on the Pacific Coast and the largest desal plant in the Western Hemisphere. The desal plant built by Poseidon in Tampa Bay, Florida doesn't work! 2. Extends the life of the Encina Power Plant - the Desal Plant will use the intake and outfall from a power plant that is over 50 years old, inefficient and obsolete. The Power Plant kills hundreds of thousands of fish and millions of eggs, larvae and small sea creatures every year. California is phasing out once through cooling systems for power plants. The Desal Plant will extend the life of this giant marine life sucking vacuum cleaner. The slaughter of the ocean must stop! 3. Expensive - It takes between 4.6 and 5.3 Megawatts per hour to convert each acre foot of water of seawater! That does not include delivery of the water to the San Diego County Water Authority or maintenance of the plant. The water will be 30% to 50% more expensive than imported water! 4. Privatization of Drinking Water - Our drinking water will be in the hands of business interests, with a profit motive. The only way Poseidon will make a profit is to get water subsidies from the government. Meaning we will all pay for the increase costs of water, whether we use the water or not. 5. Water Conservation Works - In fact, according to Carlsbad itself, there is no need for the desalination plant. It will simply be a redundant water supply. Don't build it, if you don't need it! Thank You Bill Hickman bill@surfridersd.org Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1) 74.62.25.37 O S £DON E June 13, 2006 Honorable Mayor Lewis and Councilmembers City of Carlsbad 1200 Carlsbad Village Drive Carlsbad, CA 92008 A c. U R C TEM#. sfy Council ( 5 y Manager «. :y Attorney City Clerk Dear Mayor Lewis and Councilmembers: Poseidon Resources is pleased to provide information in response to the letter from the Coast Law Group representing the Surfnder Foundation in regard to Boron and NDMA. We have worked closely with the City of Carlsbad to ensure that the water produced at the Carlsbad Desalination facility is fully protective of the public's health and complies with all state and federal drinking water standards. We offer the following information related to Boron and NDMA in response to the issues raised by the Coast Law Group: Boron; The proposed seawater desalination facility will be designed to produce potable water which will be in compliance with all regulatory requirements applicable to this project at this time, including with the boron "action level" established by the California Department of Health Services of 1 mg/L. The World Health Organization Guidelines are guidelines, not regulations, and do not have direct relevance to this project nor are they accepted as governing water quality regulations in the U.S. and in many other developed countries in the world. For example, the European Union's drinking water quality limit for boron is 1 mg/L as well and the boron drinking water standard in Canada is 5 mg/L. The US Environmental Protection Agency has not established a limit for boron - i.e. there is no boron removal requirement in the Safe Drinking Water Act. Poseidon Resources corporate technical director, Mr. Nikolay Voutchkov is one of the two dozen technical water quality experts tasked by the World Health Organization (WHO) to develop new guidelines for desalinated water for use by the member countries of the United Nations. The new guidelines are planned to be issued by WHO by the end of this year. In these guidelines the boron guidance level will be relaxed from 0.5 mg/L to 1 mg/L. The existing WHO limit was established based on studies completed in the late 1960s and does not reflect the newest research in this area that shows that boron at a level of up to 2 mg/L does not present a health treat. To take a conservative approach however, the guidelines will relax the boron level to 1 mg/L rather than 2 mg/L. The U.S. EPA on their internet site provides very in-depth discussion of why Federal regulatory requirement for boron is not necessary. CITY OF CARLSBAD CITY CLERK'S OFFICE Poseidon Resources Corporation 501 West Broadway, Suite 840, San Diego, CA 92101, USA 619-595-7802 Fax: 619-595-7892 Executive Office: 1055 Washington Boulevard, Stamford, CT 06901 • The newest generation seawater reverse osmosis membranes planned to be used at the Carlsbad seawater desalination facility have boron removal efficiency of 85 to 88 % which allows desalinated water to comply with the boron product water quality action level requirement of 1 mg/L using a single-stage membrane reverse osmosis system. The Carlsbad seawater desalination facility is projected to produce potable water which will have boron concentration typically in a typical range of 0.6 to 0.8 mg/1 (average of 0.75 mg/L). • Poseidon and the City of Carlsbad have completed a comprehensive study to evaluate the effect of the content of boron in the desalinated water on the site-specific ornamental plants cost common in the city. The results of this study indicate that a desalinated water of average boron concentration of 0.75 provides adequate protection from the effects of boron described in the Surfrider Foundation Comment Letter. • The high boron removal efficiency of the proposed reverse osmosis membranes has been tested and proven at Poseidon Resources' seawater desalination demonstration plant located in Carlsbad, California. This plant uses the same single-stage seawater reverse osmosis membrane system configuration as that proposed for the full-scale seawater desalination facility. The Poseidon demonstration plant has been in operation for over three years and has been producing high-quality desalinated water using actual Encina power plant condenser seawater. This demonstration plant uses the newest generation high-rejection seawater desalination membranes which allow to consistently produce potable water of boron levels below 1 mg/L, and to comply with all applicable product water quality requirements. • In May this year, the work completed by Poseidon on studying boron removal at the Carlsbad pilot plant was recognized by the American Academy of Environmental Engineers, which awarded Poseidon Resources the 2006 Grand Prize for Research - the highest award given by the Academy for innovative applied research in the environmental field. • The Coast Law Group letter cites a study at UC Davis by Professor Stephen R. Grattan related to boron's effect on crop yields. Dr. Grattan is one of three boron experts advising the City of Carlsbad on determining the appropriate boron standard for the proposed project. It should be noted that Dr. Grattan has reviewed and approved of the boron level established for the proposed project. • If the applicable regulations change in the future and more stringent boron limit is introduced, than the applicant is required to upgrade the project as necessary to accommodate future boron or other water quality limits. NDMA Typically seawater is free from NDMA. Over the last three years, Poseidon has completed a comprehensive source water quality and desalinated product water quality characterization for the Carlsbad project. Poseidon has measured NDMA both in the source seawater and in the product water generated by the Carlsbad seawater desalination demonstration plant. The water quality analysis was completed by a California Department of Health Services (CDHS) certified laboratory. The test results show that both the source seawater and the product water are free from NDMA, i.e. the concentration of NDMA in both the source water and the product water was below the detection level established by CDHS. Another researcher noted in the Coast Law Group letter is Professor Daivd Sedlak. Poseidon Resources works in cooperation with Professor David Sedlak on studying water quality of desalinated water and is familiar with Dr. Sedlak's research in the field of desalinated water quality. In fact, Poseidon Resources' corporate technical director, Mr. Nikolay Voutchkov is on the Scientific Review Committee formed by the American Waterworks Association's Research Foundation to guide Dr. Sedlak's work in this area. Thank you for the opportunity to provide you with this information. I am always available for consultation or for further explanation of these or any other issue related to water quality at your request. Poseidon is committed to creating a safe, reliable, high quality water supply for the residents of Carlsbad and we look forward to working with you in the future. Sincerely, Nikolay Voutchkov Corporate Technical Director Poseidon Resources Corporation 06/12/2006 00:37 6192347403 SDCTA PAGE 01 San Diego CountyTaxpayersAssociation 110 West C Slreet. Suite 714, San Diego, CA 92)01 • P: (619)234-6423 • F: (619) 234-7403 • www.sdcfc.wg AGENDAITEM0 c: Mayor City Council City Manager City Attorney City Clerk VIA FACSIMILE 760-720-9461 The Honorable Mayor Lewis and Councilmembers City of Carlsbad Re: Seawater Desalination Project • * Dear Mayor Lewis and Councilmembers, On behalf of the Board of the San Diego County Taxpayers Association (SDCTA), I wish to reaffirm our Association's full support of the proposed agreement between Poseidon Resources and the City of Carlsbad. Given the significant utility rate increases that have impacted San Diego's ratepayers in the past few years, we support the efforts made by the City of Carlsbad and Poseidon resources to develop new potable water supplies. The water purchase agreement ensures the cost of water to be equal to or less than the cost of imported water, as well as includes the dedication of over 15 acres of ocean front and lagoon front property for marine restoration and enhance of public access and recreation opportunities. This project will generate revenues for local governments including $2.4 million in property tax per year for the next 30 years, as well as an estimated $10.4 million in sales tax during construction, and $2.9 million per year thereafter. SDCTA has consistently urged the region's water resource agencies to explore all options in order to meet the water needs of our growing region and economy. San Diego must diversify its supply portfolio if our region is to remain competitive and improve the quality of life for all of our residents. Public/Private partnerships, such as the one that your City has developed with Poseidon, go a long way toward meeting that goal. By taking the leadership role in advancing this public/private partnership, Carlsbad has shown itself as a true regional leader and set an outstanding example. Again, SDCTA fully supports this action and urges the Carlsbad City Council to certify the EIR and approve the Development Agreement and related permits. Should you have any questions or need further information, please do not hesitate to contact our office at (619)234-6423. Sincerely, Lani Lutar President & CEO IIIV 1 3 ?'T-r>JUi\ I •_' -.-'V/i/ CITY OF CARLSBADCITY CLERK'S OFFICE June 6, 2006 Mayor Lewis & Councilmembers City of Carlsbad 1200 Carlsbad Village Drive Carlsbad, CA 92008 RE: Support EIR 03-05 / PDF 00-02 - Precise Development Plan and Desalination Plant Dear Mayor Lewis & Councilmembers: As a resident of Carlsbad and a member of the Carlsbad Desalination Project Citizen's Advisory Committee for the past 18 months, I have learned a great deal about the Project and its benefits. I am pleased to see our City focus on solutions that will make us more self-reliant and less dependent on imported water. I strongly support the efforts made between the City and Poseidon to generate locally- controlled, affordable water with a proposed desalination plant. This facility will create jobs, generate much needed tax revenue for local governments, improve our water quality and enhance water reliability with a new drought-proof supply. The City of Carlsbad should be commended for its efforts to create highly reliable supplies of water. By supporting this project, you will move us forward to addressing this critical need facing our region. Sincerely, Bailey FARM BUREAU SAN DIEGO COUNTY 1670 East Valley Parkway, Escondido CA 92027-2409 Phone: (760) 745-3023 • Fax: (760) 489-6348 E-mail: sdcfb@sdfarmbureau.org • Website: www.sdfarmbureau.org June 7, 2006 The Honorable Claude A. "Bud" Lewis City of Carlsbad 1200 Carlsbad Village Drive Carlsbad, CA 92008 Dear Mayor Lewis: As the 12th largest farm economy among all counties in the nation, the farmers of San Diego County recognize the importance of developing environmentally responsible and affordable water supplies. San Diego is host to more than 5,000 farmers and an agriculture industry that contributes more than $1.4 billion to the local economy. When all economic factors are considered, including payroll, purchase of goods and transportation, agriculture has a total value to the local economy of $5.1 billion. Due to San Diego's dependence on imported water supplies, our region endures water prices that are among the highest in the nation. For many local farmers, the cost of water can adversely impact then- daily operations. With the heavy demand and lack of supply of water in mis region, we feel it is imperative mat San Diego develop new sources to meet mis demand and escalating costs. In the long run, imported water will become even more expensive due to the cost of transportation, storage, and the likely economic and environmental mitigation costs for the damage caused by extracting that water from its current use. To that end, we encourage the efforts made by the City of Carlsbad and Poseidon Resources to develop locally-controlled, affordable water supplies in an environmentally responsible manner. It is apparent the cost of importing water to this region will only continue to escalate, and desalinated water will eventually be the more affordable source of water. To maintain agriculture in San Diego county, water must be abundant and affordable. Creating new local water supplies through desalination will help offset expected price increases that could be damaging to San Diego's farm economy. We applaud the efforts of the City of Carlsbad and Poseidon Resources for taking the steps to develop new potable water supplies and urge your approval of the EIR. Si Eric Larson Executive Director cc: Mayor Pro Tern Matt Hall Councilmember Ann J. Kulchin Councilmember Mark Packard Councilmember Norine Sigafbose Serving San Diego County Agriculture Since 1913 ,SRN DIEGO NORTH Economic Development Council ALL RECEIVED June 5, 2006 Mayor Lewis & Councilmembers City of Carlsbad 1200 Carlsbad Village Drive Carlsbad, CA 92008 RE: Support EIR 03-05 - Precise Development Plan and Desalination Plant Dear Mayor Lewis & Councilmembers: We applaud the efforts of the City of Carlsbad to advance the construction of water supply infrastructure in partnership with the private sector. Expanding the water supply in Southern California is important to attracting industry to the North County, and will offer many benefits to the region. The San Diego North Economic Development Council is a coalition of the private and public sector working together to sustain and carefully grow the economic base of North County. Our goal is to market the area in an effort to retain and attract quality businesses and create additional, higher paying jobs. Additionally, we undertake initiatives to establish North County as a "business-friendly" region and promote a regional approach to marketing North County as "San Diego's Smart Place to Grow" a business... as well as a family. The development of an affordable water supply solution will greatly assist local businesses with maintaining their operations in the San Diego region. The region's excessive dependence on a fragile imported water system has made it increasingly difficult to sustain and grow water reliant industry in this region, which is why we must move forward to create highly reliable supplies of water. After reviewing the EIR and staff report for the proposed Carlsbad Desalination Project, it is clear this project will provide San Diego's residents and businesses with a new source of affordable drinking water in an environmentally responsible manner, while creating significant economic benefit for the employers and employees of the region. The EIR addresses numerous issues surrounding the construction and operation of the desalination plant, and did not identify any significant, unavoidable impacts. Thank you for the opportunity to comment on this important piece of our region's infrastructure. Sincerely, President & CEO San Diego Norm Economic Development Council 760.598.9311 fax: 760.598.9311 www.sandiegonorthedc.org 100 N. Rancho Santa Fe Road, Suite 124, San Marcos, CA 92069 June 5, 2006 Mayor Lewis & Council members City of Carlsbad 1200 Carlsbad Village Drive Carlsbad, CA 92008 RE: Support of the Carlsbad Desalination Project Dear Mayor Lewis & Councilmembers: I am writing you as a taxpayer and resident of Carlsbad to encourage you to vote yes on the desalination plant. After almost a decade of discussion and environmental reports, I believe it is time to move forward with the plant proposed by Poseidon Resources. Consumption of water has grown in the past decade while the supply has basically remained unchanged. At the same time, San Diego has continued to depend on imported water supplies rather than developing new sources. I support the efforts made by the City of Carlsbad and Poseidon Resources to develop a new water supply - at no risk to taxpayers. This partnership will not rely on us to pay the bill, unlike most infrastructure projects such as road improvements and public facilities. It is my understanding that the cost of our desalted water will be the same, or less than what we are now paying for imported water. Additionally, the dedication of more than 15 acres of ocean front and lagoon front property for marine restoration will create better public access and recreation opportunities for all of us. As you know, open space is one of the main priorities of the citizens of Carlsbad. It is my understanding that the Poseidon desal plant will provide better quality water with increased reliability at a price not to exceed what we would pay for imported water. I believe it is time for Carlsbad to move forward with this project, and I would appreciate your vote to approve. I thank you for being pro-active on this extremely important issue, and for all your efforts at making Carlsbad a leading community. What happens here will benefit Carlsbad, the region, and perhaps the world. Sincerely, Don Christiansen 3715 Longview Drive Carlsbad JUn UD Ub r • INDUSTRIAL ENVIRONMENTAL ASSOCIATION Leaders of Environmental Responsibility June 1, 2006 Mayor Claude Lewis and Members of the City Council City of Carlsbad 1200 Carlsbad Village Drive Carlsbad, CA 92008 RE: Support EIR 03-05 - Precise Development Plan and Desalination Plant Dear Mayor Lewis and Councilmembers: The Industrial Environmental Association (IE A) promotes environmental responsibility through effective communication and interaction with our members, government, regulatory agencies, business, and the community. We use proven technology, scientific methods, and common sense to achieve a beneficial relationship between environmental protection, public health, and economically sustainable growth. IE A wholeheartedly supports the Carlsbad Desalination Project and urges approval of the Planning Commission's recommendation to certify the EIR and approve local permits. After reviewing the Environmental Impact Report for the desalination facility, IEA believes that the proposed desalination project can be constructed and operated in an environmentally responsible manner. This project has been designed and will be executed with extreme sensitivity to the environment around it. Of the areas studied, including air, soil and water quality, hazardous materials and noise, the EIR does not identify any significant, unmitgatable impacts to the surrounding neighborhoods or coastal region, After thoroughly reviewing this report I feel that there is no environmental impact from this plant that cannot be mitigated. IEA wholeheartedly supports the Carlsbad desalination project and urges approval of the staff recommendation. Sincerely, Patti Krebs Executive Director 701 B Street • Suite 1040 - San Diego. CA 92101 • (619) 544-9684 - FAX (619) 544-9514 San Diego County Building & Construction Trades Council, AFL-CIO June 1,2006 Mayor Lewis & Councilmembers City of Carlsbad 1200 Carlsbad Village Drive Carlsbad, CA 92008 RE: Support EIR 03-05 - PDF 00-02 - Precise Development Plan and Desalination Plant Dear Mayor Lewis & Councilmembers, We urge your approval of the EIR and local permits for the Carlsbad Desalination Project. This Project will bring this region one step closer to a safe, reliable and cost-effective water supply, which will greatly reduce our region's dependence on imported water. San Diego's labor community believes in a strong economy and protecting the environment. These goals can be accomplished by reducing our region's dependence on imported water, which is one of the reasons why we support the Carlsbad Desalination project. The desalination facility will create jobs, generate much needed tax revenue for local governments, improve our water quality and enhance water reliability with a new drought-proof supply. Based on our review, the Environmental Impact Report provides sufficient information to conclude the project could be constructed and operated without significant impacts to marine life and ocean water quality. Construction of the desalination plant will not require any modification of the Encina power plant, which is a must run facility, and the plant is being configured to allow for the future modernization of the power plant. This project will create 2,100 jobs for San Diegans and generate more than $170 million in spending during construction, as well as $37 million in annual spending throughout the region once the desalination plant is online. Thank you for the opportunity to comment on this important project. We applaud you on leading the County in securing a new, reliable, local water supply. Respect Artcujan Building Trades Council 3737 Camino del Rio So. Suite 202, San Diego, CA 92108 Telephone: (619) 521-2914 Fax (619) 521-2917 Jun 05 2006 12:49PM San Diego Building Trades 1-619-521-2917 p.2 ALL RECEIVED San Diego County Building & Construction Trades Council, AFL-CIO June 1,2006 Mayor Lewis & Councilmembers City of Carlsbad 1200 Carlsbad Village Drive Carlsbad, CA 92008 RE: Support EIR 03-05 -PDF 00-02 - Precise Development Plan and Desalination Plant Dear Mayor Lewis & Councilmembers, We urge your approval of the EIR and local permits for the Carlsbad Desalination Project. This Project will bring this region one step closer to a safe, reliable and cost-effective water supply, which will greatly reduce our region's dependence on imported water. San Diego's labor community believes in a strong economy and protecting the environment. These goals can be accomplished by reducing our region's dependence on imported water, which is one of the reasons why we support the Carlsbad Desalination proj ect. The desalination facility will create jobs, generate much needed tax revenue for local governments, improve our water quality and enhance water reliability with a new drought-proof supply. Based on our review, the Environmental Impact Report provides sufficient information to conclude the project could be constructed and operated without significant impacts to marine life and ocean water quality. Construction of the desalination plant will not require any modification of the EncLna power plant, which is a must run facility, and the plant is being configured to allow for the future modernization of the power plant. This project will create. 2,100 jobs for San Diegans and generate more than $170 million in spending during construction, as well as $37 million in annual spending throughout the region once the desalination plant is online. Thank you for the opportunity to comment on this important project. We applaud you on leading the County in securing a new, reliable, local water supply. Respi ArtTujan Building Trades Council 3737 Caraino del Rio So. Suite 202, San Diego, CA 92108 Telephone: (619) 521-2914 Fax (619) 521-2917 TU EMERALD PLAZASAN DIEGO 402 West Broadway, Suite 1000 REGIONAL San Diego, California 92101 -3585 COMMERCE www.sdchamber.org ALL RECEIVED June 1,2006 Hon. Claude A. "Bud" Lewis and Members, Carlsbad City Council City of Carlsbad 1200 Carlsbad Village Drive Carlsbad, CA 92008 RE: Support EiR 03-05 / PDF 00-02 - Precise Development Plan and Desalination Plant Dear Mayor Lewis and Members of the Council: The San Diego Regional Chamber of Commerce supports the Carlsbad Desalination Project because it addresses the development of our own local supply and presents an environmentally responsible way to increase our water portfolio. We urge the Carlsbad City Council to adopt the Planning Commission recommendation to support this project. In reviewing the Environmental Impact Report (EIR), the Chamber believes adequate safeguards are in place to address environmental issues, including the impact to marine life which is minimal, and that no endangered or at risk species are located in waters in the project vicinity. This project achieves its stated objectives in an environmentally and economically acceptable manner. The proposed project implements the desalination element of a comprehensive local and regional water supply strategy that is intended to lessen the reliance on imported water and improve water supply reliability by complementing ongoing water conservation and water recycling efforts. Additionally, the development of infrastructure through a public-private partnership has the benefit of limiting risk to the citizens and taxpayers of California. The Chamber concurs with the findings of the EIR that there are no significant impacts that cannot be mitigated. We urge the Carlsbad City Council to adopt the staff recommendation. Sincerely, Scott D. Alevy Vice President, Public Policy & Communications SDA:av June 1, 2006 Mayor Lewis & Councilmembers City of Carlsbad 1200 Carlsbad Village Drive Carlsbad, CA 92008 RE: Support of Carlsbad Desalination Project Dear Mayor Lewis & Councilmembers: As a resident of Carlsbad and a member of the desalination stakeholder group for the past 18-months, I have learned a great deal about this project and its benefits. This project will result in enough high-quality water for not only the City of Carlsbad but for many other areas throughout the region. More importantly, the plant can be built in a manner that will not harm the environment or cause any significant noise, traffic, growth- inducement, air and water quality, or land use impacts. It is apparent San Diego must reduce its dependence on imported water and the City of Carlsbad's public-private partnership with Poseidon Resources makes an effort to address this issue by building and operate a desalination plant, at no risk to the city and us taxpayers. The cost of water is only rising and we must increase supply now before it truly impacts our quality of life. I have made a concerted effort to talk with my friends and neighbors, who have all expressed support for this important project. I urge your support for this project which will address our water supply needs for years to come. Sincerely, Joni Miringoff 5600 AVENIDA ENCINAS SUITE 100 CARLSBAD, CA 92008 TELEPHONE 760 930-9123 FAX 760 431-9020 www.theflowerfields.com Jun Ub ua:uup ua i uoasr. n.QalC&ast BOARD OF DIRECTORS: Chair Pam Slater-Price y' District, San Diego County Vice Chair Ann Kulchin Mayor Pro Tern City of Carlsbad Supervisor Tom Wilson5M District, Orange County Council Member Stephinl* DoreyCity of SanCIs mania Supervisor Don Knabe4th Dist LA County Cptncfl Member Frank Colonna3^ District. City of Long Beach Brian BrennanCounci Mentor. City of Ventura Supervisor Susan Rose2" DisL Sanla Barbara County Council Member Emily RallyCity of Sana Cruz (Rao. AM9AG) AMBAG BEACON SANDAG SCAG Courty of Los Angeles County of Orange County of San Diego County of Santa Barbara County of Ventura Orange County Sanitation Dos. City or Cans bad CilyorCarpinteria CityorCapiMa CttyofCoronaoo City of Dana Point City of Del Mar CilyofEnclnitas City of Hat Moon Bay Cily of Hermosa Beach City ol Hunttngton Beach Crty of Imperial Beach City of Laguna Beach City of Long Beach Coy of Los Angeles City of Malibu City of Manhattan Beach City of Monterey CityofMorrc Bay City or Newport Beach City or OceansIda CiV of Pacific Grove City of Plsmo Beach Cily of Port Hueneme City of Redondo Beach City of Raneho Patos Verde CityofSanClemenli City of Sand City City of San Diego City ol San Francisco City of Santa Barbara City of Santa Cruz Cily or Sanla Monica City or Seal Beach City oT Solaria Beacn City or Ventura California Coastal Coalition 1133 Second Street Suite G Encinitas, CA 92024 STEVEN ACETI, J.D. Executive Director 760.944.3564 tel 760.944.7852 fax steveaceti@calcoa st.org Via Facsimile: (76(D 720-9461 June 2, 2006 Mayor Lewis & Councilmembers City of Carlsbad 1200 Carlsbad Village Drive Carlsbad, CA 92008 Dear Mayor Lewis & Councilmembers: The Carlsbad Desalination Project would offer many benefits to the citizens of California and the California Coastal Coalition is pleased to offer our full support of the Carlsbad Seawater Desalination Project. The California Coastal Coalition (CalCoast) is a non-profit advocacy group comprised of 35 coastal cities; five counties; the Association of Monterey Bay Area Governments, the San Diego Association of Area Governments and the Southern California Association of Governments; along with business associations and allied groups committed to restoring California's coast through sand replenishment, increasing the flow of natural sediment, wetlands recovery and improved water quality. As a co-sponsor of the California Public Beach Restoration Act (AB 64-Ducheny), our organization is especially concerned about any potential impacts to the coastline during the construction and operation of the desalination plant. We have given considerable consideration to Poseidon's proposal and find that the project includes the necessary design, protections and mitigation for one to conclude it represents an appropriate use of coastal property and public trust resources. The project impacts on the coastal environment are benign and in many aspects are beneficial, for example: • The dedication of land for increased public access and recreation opportunities; (Please see item f on page 37 of the staff report) CalCoast is an advocacy organization comprised of coastal communities and interest groups www.caicoast.org jun uc: uo uo:uup • Restore and enhance the marine environment; (Please see item g on page 37 of the staff report) • Generate revenue for South Carlsbad Coastal Redevelopment plan to be used for enhancement of public infrastructure in the coastal zone. (Please see item d on page 36 of the staff report) It is clear upon reviewing the Environmental Impact Report for the proposed desalination plant, a comprehensive review process has been conducted and very few negative environmental impacts have been identified. Sincerely, Steve Aceti, JD Executive Director California Coastal Coalition CalCoast is an advocacy organization comprised of coastal communities and interest groups www.calcoast org JUN. 5.2006 3:46PM VALLEY CENTER II K D. VALLEY CENTER MUNICIPAL WATER DISTRICT A Public Agency Organised July 12.1954 NO. 3676 P. 2 June 5, 2006 Mayor Lewis & Council Members City of Carlsbad 1200 Carlsbad Village Drive Carlsbad, CA 92008 Board oi Directors Gary/..Broomed Presidanl Robert A. Polllo Vits President Merle J.AIeshlre Director Charles W. Stone, Jr. Director Randy D.Haskell director ALL RECEIVED RE: Support EIR 03-05 - Precise Development Plan and Desalination Plant Dear Mayor Lewis & Council Members: The proposed Carlsbad Desalination Project is important to your city, my agency, and the greater San Diego region. It will provide over 50,000 acre feet of a new, high quality and highly reliable water supply which will be needed to meet the needs of our growing population and economy for many decades to come. As such, we would urge you to approve the recommendation from the Carlsbad Planning Commission for the Poseidon Resource's seawater desalination plant. Valley Center MWD is a public water agency serving 25,000 residents and 24,000 acres of agricultural land within the unincorporated communities of Valley Center, Jesmond Dene, Hidden Meadows, Circle R and Welk' Village with 40,000 to 50,000 acre feet of imported water annually. 80% of the water we deliver goes to serve a diverse agricultural customer base. In terms of imported water purchases, in most years, we are second only to the city of San Diego. With a 100 square-mile service area, we are the third largest Authority member agency in terms of land area, with only the City of San Diego and the Otay Water District covering more territory. We, along with the City of Carlsbad and the Rincon del Diablo Municipal Water District, have a 30-year agreement to purchase water from the proposed Poseidon Seawater Desalination Plant. Our agreement calls for my agency to purchase up to 7,500 acre feet of water annually to be used by our domestic and commercial water users. My Board of Directors was motivated to enter into the purchase agreement for several reasons: 1. Given the onerous political, regulatory and environmental constraints to developing new fresh surface water supplies they believe that the notion of desalting seawater is a good one. To the extent that entering into the agreement with Poseidon furthered that cause, they felt it was the prudent thing to do at this time; 29300 Valley Center Road • P.O. Box 67 • Valley Center, CA 92082 (760) 749-1600 • FAX (760) 749-6478 • TDD (760) 749-2665 • www.vcmwd.org « e-mail vcwater@vcmwrj.org JUN. 5.200b' J:4bfM VALLM itmK M. w. u. ««. oo/u r. Mayor Lewis and Council Members June 5, 2006 2. By our agreement, water purchased from Poseidon will never be anymore expensive than our imported supplies. In the long-term, water purchased under this agreement has the potential of actually being less expensive than future imported supplies. Consequently, through this agreement we get a higher level of price stability over time and the potential for a price advantage compared to our imported sources. 3. With this agreement, we have the potential of securing a secondary source of supply, thus diversifying our supply portfolio and increasing the overall supply reliability for our growing community. The supply reliability advantage of having some level of alternative local supply has been underscored by the policy principles and allocation formula contained in the Draft SDCWA Drought Management Plan, adopted by the San Diego County Water Authority Board last month. With the availability of the desalinated water, Valley Center's domestic and commercial customers would be immune from imported water cutbacks until the shortages exceed 50%. Again, we would urge you to approve the recommendation before you for the Carlsbad Desalination Project. Sincerely, Jary Arant General Manager Valley Center Municipal Water District G:\WPFlLES\DesalPrpjectCarisbadCityCoundlLtr.doc ALL RECEIVED June 1,2006 d . _^ ^_x .A, ^ecaaes..-.°fbcientmcExcellence Mayor Lewis & Councilmembers City of Carlsbad 1200 Carlsbad Village Drive Carlsbad, CA 92008 RE: EIR 03-05 Precise Development Plan and Desalination Plant Project Dear Mayor Lewis & Councilmembers: I would like to provide the Carlsbad City Council with comments on the Final Environmental Impact Report for the Precise Development Plan and Desalination Plant (EIR 03-05 - SCH# 2004041081) dated December 2005. Hubbs-SeaWorld Research Institute's Leon Raymond Hubbard, Jr. Marine Fish Hatchery is located on the Agua Hedionda Lagoon, across from the proposed desalination facility. Accordingly, we are concerned that all development along the Lagoon be conducted in a manner to conserve the Lagoon's vital and productive marine life, and to ensure that the conservation program supported by our hatchery facility is not adversely impacted. Because of our Institute's unique dependence on the Lagoon habitat, I have reviewed the sections of the EIR pertaining to biological impacts. The report's authors conclude that any environmental impacts to the receiving waters, the surrounding habitats and/or the organisms that inhabit those habitats should be insignificant. Based on my review of the methodology and results reported, these conclusions appear to be correct. The biological survey work undertaken, the assay experimentation conducted, and the mathematical modeling performed appear to be a scientifically valid and authoritative approach to answering the biological impact questions posed by the environmental review process. The recommendation to conduct on-going environmental sampling should allow the appropriate regulatory agencies to test the assumptions that went into the models and also provide an adequate level of assurance that significant negative impacts are not occurring Furthermore, this sampling regime should afford a wealth of information, which will be invaluable to resource agencies charged with management of our coastal living marine resources. In conclusion, I do not believe that the desalination facility will have an adverse impact on the marine environment, the Agua Hedionda Lagoon, or our hatchery's operations. 2595 Ingraham Street I San Diego, CA 92109 I 1:619.226.3870 I F: 619.226.3944 6295 Sea Harbor Drive I Orlando, FL 32821 I 1:407.370.1650 I F: 407.370.1659 I www.hswri.org Thank you for affording our Institute the opportunity to provide an opinion on the impacts of the proposed desalination facility during your review of this project. Sincerely, Donald B. Kent President, Hubbs-SeaWorld Research Institute & Co-Principal Investigator, Ocean Resources Enhancement and Hatchery Program San Diego Regional Economic Development Corporation ALL June 5,2006 Mayor Lewis and Councilmembers City of Carlsbad 1200 Carlsbad Village Drive Carlsbad, CA 92008 RE: Support EIR 03-05 - Precise Development Plan and Desalination Plant Dear Mayor Lewis & Councilmembers: I am writing on behalf of the San Diego Regional Economic Development Corporation (EDC). For the past 40 years, EDC has worked to develop a diverse, successful, technology-driven economy throughout San Diego. We are focused on issues of regional competitiveness and actively pursue the growth and expansion of high-wage, high-growth industries in the region. My organization would like to offer our full support of the Carlsbad desalination plant. We urge you to approve this project as expeditiously as possible and move our region one step closer to an affordable, high quality water supply. In a region entirely dependent on imported water, our current and future economic development relies on having an affordable and reliable supply of water. Desalination will help meet these needs, ensuring that infrastructure will be adequate to accommodate future growth and providing valuable economic benefits to the region. Poseidon Resources has been working with the City of Carlsbad and local water agencies since 1998 on development of the desalination facility - a public-private partnership that will provide San Diego County residents with 50 million gallons of drinking water per day at a guaranteed price, while protecting public agencies and taxpayers from financial risk. The Carlsbad desalination project will have significant economic benefit for the region, specifically as it relates to the region's emerging high technology and bio-technology cluster that relies on high-quality water for manufacturing. 530 B Street Seventh Floor San Diego CA92101 Ph: 619-234-8484 Fax:619-234-1935 \v\v\v.sanr lie Mayor Lewis and Councilmembers City of Carlsbad June 5,2006 Page Two The economic benefits attributable to project construction and operation include an estimated $170 million in spending during construction, 2,100 jobs created during construction, and $37 million in annual spending throughout the region once the desalination plant is operational. For the region, the desalination facility will create jobs, generate tax revenue, improve water quality and enhance water reliability with a new drought-proof supply. Thank you for the opportunity to comment on this important piece of the County's future water infrastructure. Sincerely, Julie Meier Wright President & CEO Rincon del Diablo Municipal Water District ALL RECEIVED A Public Agency Serving the Greater Escondido Valley Since 1954 Dr. Hanno E. G. Ix President Division IV Diana L Towne Vice President Division V John B. Hinrichs Treasurer Division III Dr. Gregory M. Quist Director Division I David A. Drake Director Division II Annette S. Hubbell General Manager Redwine and Sherrill General Counsel Willis G. Cornelius Director Emeritus June 5, 2006 The Honorable Mayor Lewis & Councilmembers City of Carlsbad 1200 Carlsbad Village Drive Carlsbad, CA 92008 RE: Support EIR 03-05 - Precise Development Plan and Desalination Plant Dear Mayor Lewis & Councilmembers: The Rincon del Diablo Municipal Water District is committed to delivering quality water to meet present and future needs in an environmentally and economically responsible manner, maintaining infrastructure integrity and excellence in service as stewards of a natural resource for the public trust, and fostering conservation. As part of diversifying our water supply in anticipation of future droughts, Rincon recently approved a Water Purchase Agreement involving the Carlsbad desalination plant. With the availability of this new supply, a repeat of the 1989-92 drought would mean a 11% water supply cutback for Rincon customers rather than the catastrophic 30% cutbacks our customers experiences in 1990-91. This agreement will ensure Rincon will receive 4,000 acre-feet per year of drinking water over a 30-year period, at a price of water not exceed that which would have been paid for the imported water supply from the San Diego County Water Authority. The water will meet or exceed all drinking water regulatory standards under the law, and Rincon will never be obligated to accept or pay for water that does not meet the quantity, quality and reliability standards specified in the Agreement. Additionally, Poseidon will be responsible for all costs and risks associated with the financing, development, construction, and operation of the plant. Rincon del Diablo Municipal Water District submits the comments below in response to the EIR for the proposed Carlsbad Seawater Desalination facility. • The project EIR has evaluated the unique project-specific conditions and considerations and concluded it would not have a significant impact on the local environment. 1920 North Iris Lane, Escondido, CA 92026 Phone (760) 745-5522 Fax (760) 745-4235 The Honorable Mayor Lewis & Councilmembers - City of Carlsbad June 5, 2006 Page 2 • The environmental impacts of the proposed project have been found to be less than significant with the added benefit of relieving future pressure on environmentally sensitive imported water systems such as the Sacramento-San Joaquin Bay-Delta and the Colorado River. • Co-location with the Encina Power Station provides optimum use of available coastal property. The project achieves the project objectives in an environmentally and economically acceptable manner. • The proposed project implements the desalination element of a comprehensive local and regional water supply strategy that is intended to reduce the reliance on imported water and improve water supply reliability by complementing ongoing water conservation and water recycling efforts. This project would support Rincon's ongoing efforts to secure and protect our water resources, and provide our customers with a drought-proof and affordable water supply. Sincerely, Annette Hubbell General Manager Rincon del Diablo Municipal Water District H:\My Documents\My Documents\Hubbell\Lewis, Mayor Bud Carlsbad Desal Proj 060606.doc ALL RECEIVED WILLIAM. J. CARROLL 2315 Rue des Chateaux Carlsbad, CA. 92008 June 6, 2006 Mayor Lewis and Council Members City of Carlsbad 1200 Carlsbad Village Drive Carlsbad, CA. 92008 Subject: Support of the Carlsbad Desalination Project Dear Mayor Lewis and Council Members: As a citizen of Carlsbad, I strongly support the Carlsbad Desalination Project as proposed by Poseidon Resources. I have read all the Project Reports, both on the Project Design and the Environmental effects, and believe the Project will be of major benefit to the water resources of the City and the surrounding territory. As possibly some of you on the Council know, I have spent 55 plus years in the Water Resource profession, and am a strong believer that the Pacific Ocean will be a sustaining source of water for California in the future decades. I applaud the City in being proactive in entering a public-private partnership with Poseidon in bringing this proposed project to fruition. Being a Civil Engineer, and Past National President of the American Society of Civil Engineers, I was very pleased when Poseidon's Carlsbad Pilot plant, incorporating the proposed treatment processes and facilities, won the "2006 Grand Prize for Excellence in Environmental Engineering in the Research Category" of the American Academy of Environmental Engineers. I was also President of this Academy in 1980, and understand the national significance of this award. I am sorry I cannot attend the Council Meeting on May 13, as I would rather present my opinions in person, rather than thru a letter. I hope you don't mind me reciting a little history, but my first appearance in front of the City Council was 50 years ago. (June, 1956). At that time, I presented an Appraisal Report on the value of the Carlsbad Mutual Water Company and the Terramar Water Company, which the City was considering acquiring. I was the Project Engineer on the Appraisal for my Company, James M. Montgomery, now Montgomery Watson Harza (MWH). I worked closely with the then City Manager, Mr. Herbert Nelson, Mr. Dennis Wood of the Carlsbad Mutual Water Company, and Mr. W. D. Cannon, owner of the Terramar Water Company. The values of the systems at that time were $1,360,000 for the Mutual Water Company, and $154,000 for Terramar. At that time the sources of water for Carlsbad were 6 wells in the Mission Basin of the San Luis Rey River, and a connection to the City of Oceansides's lateral pipeline connecting Oceanside to the San Diego County Water Authority pipeline. The water supply for the City of Carlsbad has changed considerably since that time, and the addition of the Desalination Plant will greatly enhance the sustainability of the water resources of this community I appreciated the opportunity of presenting my views to you. Sincerely William J. Carroll June 1,2006 Mayor Lewis & Councilmembers City of Carlsbad 1200 Carlsbad Village Drive Carlsbad, CA 92008 RE: Support EIR 03-05 - Precise Development Plan and Desalination Plant Dear Mayor Lewis & Councilmembers: The Agua Hedionda Lagoon Foundation supports the recommendation before you from the Planning Commission regarding certification of the EIR and local permits for the Carlsbad Desalination Project. This project is good for the environment and the community and it will assure continued stewardship of the Lagoon and surrounding watershed. The Agua Hedionda Lagoon Foundation was established as a non profit corporation in 1990 to help conserve, restore and enhance the environmental features of the Agua Hedionda Lagoon, marsh, wetlands and watershed area, to protect sensitive land through acquisition or other means and to promote balanced recreational and commercial uses consistent with assured future lagoon vitality. The Foundation serves as an advocate for the lagoon and is a strong supporter of public access, trails and recreational opportunities. The final environmental impact report for the Carlsbad Desalination Project closely studied numerous issues related to the marine environment and land use around the proposed project site and confirms that the desalination facility can be built and operated in an environmentally responsible manner without significant unmitigated impacts. The report also confirms that the proposed operation would ensure the continued biological diversity in and around Agua Hedionda Lagoon through sustainable use of marine resources and stewardship the lagoon and surrounding watershed. Specifically: 1. The project provides for optimum use of available coastal property through co- location with the Encina Power Station (FEIR Section 4.8.4). 2. The project achieves the project objectives in an environmentally responsible manner without significant unmitigated impacts (PEER Sections 4.1 through 4.11). 3. The FEIR demonstrates that the proposed project will not cause significant entrainment losses to marine organisms. The FEIR found that the incremental entrainment effect of larval fishes from the desalination plant operations would be A California Non-Profit Corporation, 1580 Cannon Road, Carlsbad CA 92008 • 760-804-1969, www.aguahedionda.org between 0.01 and 0.28 percent. Species of direct recreational and commercial value constitute less than one percent of the entrained organisms, and considering the fact that in general, less than one percent of all fish larvae become reproductive adults, the operation of the desalination plant would not result in significant impacts on those species. (PEER, pages 4.3-35 through 4.3-43). 4. The FEIR found that under all operating conditions the desalination plant would not result in salinity levels exceeding the identified thresholds of significance. Therefore, operation of the desalination plant would not result in significant impacts related to elevated salinity levels. A mitigation measure has been included for purposes of requiring monitoring of the combined operations of the desalination plant and the Encina Power Station to ensure that salinity levels remain within the parameters that have been analyzed. (FEIR pages 4.3-43 through 51). 5. The project would require a separate National Pollutant Discharge Elimination System (NPDES) permit from the San Diego Regional Water Quality Control Board that satisfies the requirements of the federal Clean Water Act; California Ocean Plan; and the Comprehensive Water Quality Control Plan for the San Diego Region. (FEIR page 3-32). 6. The proposed mitigation measures require that the information generated by the ocean monitoring programs described in the FEIR would be available to the public (FEIR Mitigation Measure 4.3-6). 7. The FEIR also evaluates potential Lagoon enhancements that include easements for use, leases, or the dedication of land to the City of Carlsbad for general public benefit. These features include the land located on the north side of the lagoon just west of the railroad tracks, next to Hubbs Sea World Research Institute. The site is approximately two acres in size and is proposed to be used as a site for expansion of the fish hatchery and aquatic research uses. (FEIR page 4.11-7). The Agua Hedionda Lagoon Foundation supports this project because it is good for the environment and the community and because it will assure continued stewardship of the Lagoon and surrounding watershed. Sincere] iCen Alfrey Agua Hedionda Lagoon Foundation JUN 1 3 2005 June 9, 2006 CITY OF CARLSBADCITY CLERK'S OFFICE City Manager City Attorney City Clerk 169 Saxony Road Suite 204 Encinitas, CA 92024 tel 760-942-8505 fax 760-942-8515 www.coastlawgroup.com City of Carlsbad Mayor and City Council 1200 Carlsbad Village Drive Carlsbad, CA 92008 Re: Comments in Opposition to Item #10. AB #18,602 - DEVELOPMENT PLAN AND DESALINATION PLANT . Specific Plan Amendment 144(H); certifying EIR 03-05, as modified, and adopting the Candidate Findings of Fact as modified, Statement of Overriding Considerations and the Mitigation Monitoring and Reporting Program; approving a Precise Development Plan, PDF 00-02, and the proposed Carlsbad Seawater Desalination Plant; and approving a Development Agreement, DA 05-01, with Poseidon Resources (Channelside) LLC for the construction of the Carlsbad Seawater Desalination Plant at the Encina Power Plant site. Introduction of Ordinance No. NS-805. Introduction of Ordinance No. NS-806. Introduction of Ordinance No. NS-807. Resolution No. 2006-156. To consider certifying EIR 03-05, as modified, and adopting the Candidate Findings of Fact as modified, Statement of Overriding Considerations, and the Mitigation Monitoring and Reporting Program; and approving Redevelopment Permit, RP 05-12, for the portion of the Desalination Plant project that is located in the South Carlsbad Coastal Redevelopment Area. Resolution No. 419. Resolution No. 420. Honorable Mayor and City Council: The Surfrider Foundation is a nonprofit, grass-roots environmental organization dedicated to the preservation and enjoyment of the World's oceans, waves and beaches through conservation, activism, research and education. These comments are submitted on behalf of the San Diego Chapter of the Surfrider Foundation and are intended to supplement comments already submitted by the Surfrider Foundation. The Surfrider Foundation opposes the desalination project as proposed and urges the City Council to deny the project. There does not appear to be a need for the project. In fact, the project specifically notes that project would simply "supplement" the existing water supplies. (EIR 1-2). City of Carlsbad RE: Surfrider Foundation Comments in Opposition to Proposed Desalination Plant Page 3 of3 "THE ADDITIONAL RESPONSES TO COMMENTS ON THE FINAL EIR-03-05" REQUIRE THE RE-CIRCULATION OF THE EIR. On une 9, 2006, the City of Carlsbad (City) published numerous resolutions, and also provided a document entitled " The Additional Responses to Comments on the Final EIR." The additional comments allegedly address impacts of the desalination project "as a stand alone project". There is simply not sufficient time to adequately consider the new responses to comments and properly evaluate the applicant's contention that a stand alone project will have no significant impact on the environment. If the applicant wishes to analyze the desalination plant as a stand alone project, it must recirculate the EIR to allow the public to fully comment on such alternative. Further, a true stand alone desalination project is significantly different than a desalination project that uses the intake of the Encina Power Station (EPS) without the EPS station online. A proper analysis of a stand alone desalination facility would have to explore the potential alternative for other intake configurations, such as beach intake wells. We urge the City and applicant to "flesh out" the stand alone analysis and recirculate the EIR to permit the public to consider and comment on such analysis. Sincerely, Todd T. Cardiff, Esq. Advisory Board Member Surfrider Foundation San Diego Chapter City of Carlsbad RE: Surfrider Foundation Comments in Opposition to Proposed Desalination Plant Page 2 of3 There is no need for the City Council to rush into approving a project at this time. We urge the City to deny the project until further studies of adverse impacts are conducted. THE EIR FAILS TO ANALYZE THE IMPACTS OF BORON AND NDMA IN THE SOURCE WATER. The EIR discusses the various permits, approvals and surveys that must be conducted to determine the suitability of source water. (EIR 4.7-12 to 4.7-13). However, there is no attempt to even determine whether the water in the Agua Hedionda Lagoon is suitable as a source of drinking water and whether the desalination plant will produce safe drinking water. Boron is commonly found in ocean water and should be removed to a safe level. (See Exhibit 1: http://www.greenfacts.org/links/ webmaster/summary-page/html/en/borno.htm) N-nitrosdimethylamine (NDMA) can be created by the combinations of chemicals in the pre- treatment of the source water, and should be removed completely from all water. While the RO filters will take out the organisms and salts, it will not remove elements from the source waters such as boron and NDMA. The World Health Organization recommends that boron levels in drinking water be below 0.5 mg/L. (Exhibit 2: "Chemicals Hazards in Drinking Water - Boron, at http://www.who.int/ water_sanitation_health/dwq/chemicals/boronsum.pdf and http://www.who.int/water_sanitation_ health/dwq/boron.pdf). The California Department of Health Services requires special disclosure requirements if the level of boron exceeds 1 mg/L. (Exhibit 3: http://www.dhs.ca.gov/ps/ddwem/ chemicals/AL/allactionlevels2- 14-03.pdf) A report produced by the University of California at Davis, notes that boron levels as low as .5 ppm can reduce the yields of certain commercial crops such as beans, onions, garlic and strawberries. (Exhibit 4: Stephen R. Grattan, "Irrigation Water Salinity and Crop Production," (2002) p. 6, http://anrcatalog.ucdavis.edu/pdf/8066.pdf). NDMA can be more problematic. Although NDMA is commonly created from leather and rubber processing, it is the Surfrider Foundation's concern that it can be carried to the source water by storm water run-off and other processes. NDMA can also be inadvertently created through the use of chlorine and other organic compounds in the pretreatment of the source water in the plant. (Exhibit 5: WHO, N-NITROSODIMETHYLAMINE (2002), Section 4.1-4.2, http://www.inchem. org/documents/cicads/cicads/cicad38.htm#l 1.2.2 ). In fact, U.C. Berkeley is currently conducting a research project on NDMA created due to chlorination of seawater for the purpose of desalination. (Exhibit 6: "Civil and Environmental Engineering URO Project", by Professor David Sedlak, http://www.coe.berkeley.edu/current_students/uro/sedlak.html.) NDMA is highly toxic and carcinogenic. NDMA has produced tumors in rats and mice at levels as low as .01 mg/litre of drinking water. (Exhibit 4 p. 26). NDMA can cause a whole host of problems ranging from liver damage to chromosomal damage (ie. mutations.) (Exhibit 4, p. 26-31). The California Department of Health Services sets the "action level" for NDMA at .0001 mg/L. (Exhibit 3). Because of the extreme toxicity of NDMA, the pre-treatment desalination treatment process must be closely scrutinized prior to approving the project and certifying the EIR. Exhibit 1 Boron Summary page Page 1 of 4 Summary Page Generator alcohol - arsenic - aspartame - biodiversity - boron - climate change - dioxins - ecosystem change - endocrine disruptors - fluoride - fisheries - gm-crops - mercury - power-lines - respiratory-deseases - tobacco - water disinfectants | YOUR HEADER | Facts on Boron 1. What is boron? 2. Where is boron found? 3. What levels of boron are found? 4. What are the effects of boron oj3_hujTiajis_5ndjTiajTim_e!ls? 5. What...are the effects of boron orLQiganisms in the environment? 6. Conclusions The answers to these questions are GreenFacts' faithful summaries of the IPCS report. 1. What is boron? Boron is a naturally occurring element. In the environment, boron is combined with oxygen and other elements in compounds called borates. Borates are widely found in nature, and are present in oceans, sedimentary rocks, coal, shale and some soils. There are several commercially important borates, including borax, boric acid, sodium perborate, and the minerals ulexite and colemanite. Different borates react differently with water. More. . . top 2. Where is boron found? Boron is primarily obtained from boron mines, located in arid regions of Turkey and the USA, and also in Argentina, Chile, Russia, China, and Peru. Boron can also be found in different final products made from these boron minerals, including fibreglass, borosilicate glass, fire retardants, laundry bleach, agricultural fertilizers and herbicides, and many others. More... Boron enters the environment mainly from the weathering of boron-containing rocks, from seawater in the form of boric acid vapour and from volcanic and other geothermal activity such as geothermal steam. Boron is also released, though to a lesser extent, from human activities. These include the use of borate-containing fertilizers and herbicides, the burning of plant-based products such as wood, coal, or oil, and the release of waste from borate mining and processing. Borates also reach the environment due to the use of borates and perborates in the home and in industry, through leaching from treated wood or paper, and from sewage and sewage sludge disposal. More. . . Borates dissolved in the water can adsorb onto, and desorb from, the many different surfaces which can be found in rivers and streams. This is the only significant reaction that these boron- containing compounds will undergo. Borates are also adsorbed onto soil particles. The degree of adsorption depends upon the type of soil. Plants can accumulate boron, which is necessary for plant growth. Boron can build up in http://www.greenfacts.org/links/webmaster/summary-page/htrnl/en/boron.htm 6/8/2006 Boron Summary page Page 2 of 4 plants, but does not subsequently accumulate to a greater extent along the food chain, i.e. in animals which eat the plants, or in predatory animals which eat these animals. More... tOfi 3. What levels of boron are found? Boron occurs at different concentrations in soil, water or air. Boron accumulates to different degrees in aquatic and terrestrial plants and animals, but does not increase in concentration through the food-chain. More... Humans are exposed to boron from their diet, from drinking water, and from some consumer products. They may also, to a much smaller extent, ingest boron from the soil, or breathe in boron from the air. Overall, more than half of the average total exposure to boron comes from the diet. More... tQE 4. What are the effects of boron on organisms in the environment? Boron acts in the same way in humans as in other mammals. These similarities help to make it possible to make reliable predictions of effects on humans from effects observed on laboratory animals such as rats. When swallowed and inhaled, boron is widely distributed throughout the body, and some is taken up by the bones. It is then rapidly excreted, with boron incorporated in bone taking a longer time to be eliminated. More... In laboratory animals, boron can affect reproduction and the development of the fetus. Animal studies on mice and rats show no evidence of boron carcinogenicity. More..,. Because of the lack of human data and the limited amount of animal data, the EPA has classified boron as "not classifiable as to human carcinogenicity" in 1994. The very few studies on humans showed that short-term exposure to boron can cause irritation of the eye, the upper respiratory tract, and the nasopharynx. This irritation disappears when the exposure stops. No long-term health effects have been found. No effects have been found of boron exposure on human fertility. However, further study is needed to identify groups of people that might be sensitive and to evaluate reproductive effects more fully. More,,, top 5. What are the effects of arsenic on laboratory animals? Different organisms in the environment are affected differently when exposed to boron: • Bacteria are relatively tolerant towards boron, as are freshwater green algae and blue- green algae. • Protozoa are more sensitive to boron than bacteria. • Invertebrates, such as worms and mussels, are less sensitive to boron than bacteria and protozoa. • Adult fish are relatively tolerant towards boron, with rainbow trout and zebra fish being the most sensitive. However, boron may be more toxic during the early life stages of some fish, especially rainbow trout. • Boron is an essential nutrient for plants, but different plant species require different boron levels for optimum growth. In some plants, there is only a narrow margin between too little or too much boron. More... http://www.greenfacts.org/links/webmaster/sumrnary-page/htrnl/en/boron.htrn 6/8/2006 Boron Summary page Page 3 of 4 top 6. Conclusions Boron is a naturally occurring element that is found in oceans, sedimentary rocks, coal, shale, and some soils. Boron is released into the environment from the oceans, volcanic and other geothermal activities such as geothermal steam, and natural weathering of boron-containing rocks. Boron is also released, to a lesser extent, by human activities. Boron is an essential micronutrient for plants, with differences between plant species in the levels required for optimum growth. There is a narrow margin between boron deficiency and toxicity in some plants. The risk of adverse effects of high boron concentrations on aquatic ecosystems is small because boron levels are generally low, and below the no-observed-effect concentration. For humans, boron exposre occurs primarily through the diet but also through drinking-water. Animal experiments have shown harmful effects on reproduction and development, but only at boron levels that are approximately 100 to 1000 times greater than normal exposure levels. Though there is insufficient toxicity data for humans, a Tolerable Intake (TI) of boron has been established based on animal data. More... top © GreenFacts 2004. All rigths reserved. This text is a faithful summary of the leading scientific consensus report produced in 1998 by the IPCS (International Programme on Chemical Safety) "Executive Summary of the Environmental Health Criteria for Boron (EHC 204)" YOUR FOOTER http://www.greenfacts.org/links/webmaster/summary-page/htrnl/en/boron.htm 6/8/2006 Boron Summary page Page 4 of 4 http://www.greenfacts.org/links/webmaster/sunimaiy-page/html/en/boron.htm 6/8/2006 Exhibit 2 12.CHEMICAL FACT SHEETS benzene based on human leukaemia data from inhalation exposure applied to a linear multistage extrapolation model. The 1993 Guidelines estimated the range of benzene concentrations in drinking-water corresponding to an upper-bound excess lifetime cancer risk of 10~5 to be 0.01-0.08 rag/litre based on carcinogenicity in female mice and male rats. As the lower end of this estimate corresponds to the estimate derived from epidemiological data, which formed.the basis for the previous guideline value of 0.01 mg/litre associated with a 10~5 upper-bound excess lifetime cancer risk, the guideline value of 0.01 mg/litre was retained. -Assessment date The risk assessment was originally conducted in 1993. The Final Task Force Meeting in 2003 agreed that this risk assessment be brought forward to this edition of the Guidelines for Drinking-water Quality. Principal reference WHO (2003) Benzene in drinking-water. Background document for preparation of WHO Guidelines for drinking-water quality. Geneva, World Health Organization (WHO/SDE/WSH/03.04/24). 12.14 Boron Boron compounds are used in the manufacture of glass, soaps and detergents and as flame retardants. The general population obtains the greatest amount of boron through food intake, as it is naturally found in many edible plants. Boron is found naturally in groundwater, but its presence in surface water is frequently a consequence of the discharge of treated sewage effluent, in which it arises from use in some deter- gents, to surface waters. Provisional guideline value 0.5 mg/litre The guideline is designated as provisional because it will be difficult to achieve in areas with high natural boron levels with the treatment technology available. Occurrence Concentrations vary widely and depend on the surrounding geology and wastewater discharges. For most of the world, the concentration range of boron in drinking-water is judged to be between 0.1 and 0.3 mg/litre. TDI 0.16 mg/kg of body weight, based on a NOAEL of 9.6 mg/kg of body weight per day for developmental toxicity (decreased fetal body weight in rats) and an uncertainty factor of 60 (10 for interspecies variation and 6 for intraspecies variation) Limit of detection 0.2 ug/litre by ICP/MS; 6-10 ug/litre by ICP/AES 313 GUIDELINES FOR DRINKING-WATER QUALITY Treatment achievability Conventional water treatment (coagulation, sedimentation, filtration) does not significantly remove boron, and special methods need to be installed in order to remove boron from waters with high boron concentrations. Ion exchange and reverse osmosis processes may enable substantial reduction but are likely to be prohibitively expensive. Blending with low-boron supplies may be the only economical method to reduce boron concentrations in waters where these concentrations are high. Guideline derivation • allocation to water 10%ofTDI • weight 60-kg adult • consumption 2 litres/day lexicological review Short- and long-term oral exposures to boric acid or borax in laboratory animals have demonstrated that the male reproductive tract is a consistent target of toxicity. Tes- ticular lesions have been observed in rats, mice and dogs given boric acid or borax in food or drinking-water. Developmental toxicity has been demonstrated experimen- tally in rats, mice and rabbits. Negative results in a large number of mutagenicity assays indicate that boric acid and borax are not genotoxic. In long-term studies in mice and rats, boric acid and borax caused no increase in tumour incidence. History of guideline development The 1958, 1963 and 1971 WHO International Standards for Drinking-water did not refer to boron. In the first edition of the Guidelines for Drinking-water Quality, pub- lished in 1984, it was concluded that no action was required for boron. A health-based guideline value of 0.3 mg/litre for boron was established in the 1993 Guidelines, while noting that boron's removal by drinking-water treatment appears to be poor. This guideline value was increased to 0.5 mg/litre in the addendum to the Guidelines pub- lished in 1998 and was designated as provisional because, with the treatment tech- nology available, the guideline value will be difficult to achieve in areas with high natural boron levels. Assessment date The risk assessment was originally conducted in 1998. The Final Task Force Meeting in 2003 agreed that this risk assessment be brought forward to this edition of the Guidelines for Drinking-water Quality. Principal reference WHO (2003) Boron in drinking-water. Background document for preparation of WHO Guidelines for drinking-water quality. Geneva, World Health Organization (WHO/SDE/WSH/03.04/54). 314 WHO/SDE/WSH/03.04/54 English only Boron in Drinking-water Background document for development of WHO Guidelines for Drinking-water Quality Originally published in Guidelines for drinking-water quality, 2nd ed. Addendum to Vol. 2. Health criteria and other supporting information. World Health Organization, Geneva, 1998. © World Health Organization 2003 All rights reserved. Publications of the World Health Organization can be obtained from Marketing and Dissemination, World Health Organization, 20 Avenue Appia, 1211 Geneva 27, Switzerland (tel: +41 22 791 2476; fax: +41 22 791 4857; email: bookorders@who.int). Requests for permission to reproduce or translate WHO publications - whether for sale or for noncommercial distribution - should be addressed to Publications, at the above address (fax: +41 22 791 4806; email: permissions@who.int). The designations employed and the presentation of the material in this publication do not imply the expression of any opinion whatsoever on the part of the World Health Organization concerning the legal status of any country, territory, city or area or of its authorities, or concerning the delimitation of its frontiers or boundaries. The mention of specific companies or of certain manufacturers' products does not imply that they are endorsed or recommended by the World Health Organization in preference to others of a similar nature that are not mentioned. Errors and omissions excepted, the names of proprietary products are distinguished by initial capital letters. The World Health Organization does not warrant that the information contained in this publication is complete and correct and shall not be liable for any damages incurred as a result of its use. Preface One of the primary goals of WHO and its member states is that "all people, whatever their stage of development and their social and economic conditions, have the right to have access to an adequate supply of safe drinking water." A major WHO function to achieve such goals is the responsibility "to propose regulations, and to make recommendations with respect to international health matters ...." The first WHO document dealing specifically with public drinking-water quality was published in 1958 as International Standards for Drinking-Water. It was subsequently revised in 1963 and in 1971 under the same title. In 1984—1985, the first edition of the WHO Guidelines for drinking-water quality (GDWQ) was published in three volumes: Volume 1, Recommendations; Volume 2, Health criteria and other supporting information; and Volume 3, Surveillance and control of community supplies. Second editions of these volumes were published in 1993, 1996 and 1997, respectively. Addenda to Volumes 1 and 2 of the second edition were published in 1998, addressing selected chemicals. An addendum on microbiological aspects reviewing selected microorganisms was published in 2002. The GDWQ are subject to a rolling revision process. Through this process, microbial, chemical and radiological aspects of drinking-water are subject to periodic review, and documentation related to aspects of protection and control of public drinking- water quality is accordingly prepared/updated. Since the first edition of the GDWQ, WHO has published information on health criteria and other supporting information to the GDWQ, describing the approaches used in deriving guideline values and presenting critical reviews and evaluations of the effects on human health of the substances or contaminants examined in drinking- water. For each chemical contaminant or substance considered, a lead institution prepared a health criteria document evaluating the risks for human health from exposure to the particular chemical in drinking-water. Institutions from Canada, Denmark, Finland, France, Germany, Italy, Japan, Netherlands, Norway, Poland, Sweden, United Kingdom and United States of America prepared the requested health criteria documents. Under the responsibility of the coordinators for a group of chemicals considered in the guidelines, the draft health criteria documents were submitted to a number of scientific institutions and selected experts for peer review. Comments were taken into consideration by the coordinators and authors before the documents were submitted for final evaluation by the experts meetings. A "final task force" meeting reviewed the health risk assessments and public and peer review comments and, where appropriate, decided upon guideline values. During preparation of the third edition of the GDWQ, it was decided to include a public review via the world wide web in the process of development of the health criteria documents. During the preparation of health criteria documents and at experts meetings, careful consideration was given to information available in previous risk assessments carried out by the International Programme on Chemical Safety, in its Environmental Health Criteria monographs and Concise International Chemical Assessment Documents, the International Agency for Research on Cancer, the joint FAO/WHO Meetings on Pesticide Residues, and the joint FAO/WHO Expert Committee on Food Additives (which evaluates contaminants such as lead, cadmium, nitrate and nitrite in addition to food additives). Further up-to-date information on the GDWQ and the process of their development is available on the WHO internet site and in the current edition of the GDWQ. Acknowledgements The first draft of Boron in Drinking-water, background document for development of WHO Guidelines for Drinking-water Quality, was prepared by C. Smallwood, USA, to whom special thanks are due. The work of the following coordinators was crucial in the development of this document and others in the Addendum: P. Chambon, Health Environment Hygiene Laboratory of Lyon, Lyon, France (inorganic constituents) U. Lund, Water Quality Institute, Horsholm, Denmark (organic constituents) H. Galal-Gorchev, Urban Environmental Health, World Health Organization, Geneva, Switzerland (pesticides) E. Ohanian, Environmental Protection Agency, Washington, DC, USA (disinfectants and disinfection by-products) The coordinators for the overall administrative and technical aspects of this document were, respectively, J. Kenny and H. Galal-Gorchev, Urban Environmental Health, WHO, Geneva, Switzerland. Ms Maria Sheffer of Ottawa, Canada, was responsible for the scientific editing of the document. The efforts of all who helped in the preparation and finalization of this document, including those who drafted and peer reviewed drafts, are gratefully acknowledged. The preparation of this document was made possible by the financial support afforded to WHO by Canada, the European Commission, Japan and the USA. GENERAL DESCRIPTION Identity Boron (CAS no. 7440-42-8) is never found in the elemental form in nature. It exists as a mixture of the 10B (19.78%) and UB (80.22%) isotopes (Budavari et al., 1989). Boron's chemistry is complex and resembles that of silicon (Cotton & Wilkinson, 1988). Physicochemical properties Elemental boron exists as a solid at room temperature, either as black monoclinic crystals or as a yellow or brown amorphous powder when impure. The amorphous and crystalline forms of boron have specific gravities of 2.37 and 2.34, respectively. Boron is a relatively inert metalloid except when in contact with strong oxidizing agents. Sodium perborates are persalts, which are hydrolytically unstable because they contain characteristic boron-oxygen-oxygen bonds that react with water to form hydrogen peroxide and stable sodium metaborate (NaBO2-nH2O) Boric acid is a very weak acid, with a pK3 of 9.15, and therefore boric acid and the sodium borates exist predominantly as undissociated boric acid [B(OH)3] in dilute aqueous solution at pH <7; at pH >10, the metaborate anion B(OH)4" becomes the main species in solution. Between these two pH values, from about 6 to 11, and at high concentration (>0.025 mol/litre), highly water soluble polyborate ions such as B3O3(OH)4", B4O5(OH)4", and B5O6(OH)4" are formed. The chemical and toxicological properties of borax pentahydrate Na2B4O7-5H2O, borax Na2B4O7- 10H20, boric acid, and other borates are expected to be similar on a molar boron equivalent basis when dissolved in water or biological fluids at the same pH and low concentration. Major uses Boric acid and borates are used in glass manufacture (fibreglass, borosilicate glass, enamel, frit, and glaze), soaps and detergents, flame retardants, and neutron absorbers for nuclear installations. Boric acid, borates, and perborates have been used in mild antiseptics, cosmetics, pharmaceuticals (as pH buffers), boron neutron capture therapy (for cancer treatment), pesticides, and agricultural fertilizers. Environmental fate Waterborne boron may be adsorbed by soils and sediments. Adsorption-desorption reactions are expected to be the only significant mechanism influencing the fate of boron in water (Rai et al., 1986). The extent of boron adsorption depends on the pH of the water and the concentration of boron in solution. The greatest adsorption is generally observed at pH 7.5- 9.0 (Waggott, 1969; Keren & Mezuman, 1981; Keren et al., 1981). In natural waters, boron exists primarily as undissociated boric acid with some borate ions. As a group, the boron-oxygen compounds are sufficiently soluble in water to achieve the levels that have been observed (Sprague, 1972). Mance et al. (1988) described boron as a significant constituent of seawater, with an average boron concentration of 4.5 mg/kg. ANALYTICAL METHODS A spectrometric method using azomethine-H is available for the determination of borate in water. The method is applicable to the determination of borate at concentrations between 0.01 and 1 mg/litre. The working range may be extended by dilution (ISO, 1990). A widely used method for the analysis of boron in bone, plasma, and food is inductively coupled plasma atomic emission spectroscopy (Hunt, 1989). This method is also used for water (ISO, 1996) and wastewater (Huber, 1982). Detection limits in water range from 6 to 10 ug of boron per litre. Inductively coupled plasma mass spectroscopy (ICP-MS) is a widely used non- spectrophotometric method for the analysis of boron, as it uses small volumes of sample, is fast, and applies to a wide range of materials (fresh and saline water, sewage, wastewater, soils, plant samples, and biological materials). ICP-MS can detect boron down to 0.15 ug/litre (WHO, in press). Using direct nebulization, ICP-MS can give a detection limit of 1 ng/g in human blood, human serum, orchard leaves, and total diet (Smith et al., 1991). ENVIRONMENTAL LEVELS AND HUMAN EXPOSURE Air Boron is not present in the atmosphere at significant levels (Sprague, 1972). Because borates exhibit low volatility, boron would not be expected to be present to a significant degree as a vapour in the atmosphere. Atmospheric emissions of borates and boric acid in a particulate (<1—45 urn in size) or vapour form occur as a result of volatilization of boric acid from the sea, volcanic activity, mining operations, glass and ceramic manufacturing, the application of agricultural chemicals, and coal-fired power plants. Water The natural borate content of groundwater and surface water is usually small. The borate content of surface water can be significantly increased as a result of wastewater discharges, because borate compounds are ingredients of domestic washing agents (ISO, 1990). Naturally occurring boron is present in groundwater primarily as a result of leaching from rocks and soils containing borates and borosilicates. Concentrations of boron in groundwater throughout the world range widely, from <0.3 to >100 mg/litre. In general, concentrations of boron in Europe were greatest in southern Europe (Italy, Spain) and least in northern Europe (Denmark, France, Germany, the Netherlands, and the United Kingdom). For Italy and Spain, mean boron concentrations ranged from 0.5 to 1.5 mg/litre. Values ranged up to approximately 0.6 mg/litre in the Netherlands and the United Kingdom, and approximately 90% of samples in Denmark, France, and Germany were found to contain boron at concentrations below 0.3, 0.3, and 0.1 mg/litre, respectively (WHO, in press). Monthly mean values of boron in the Ruhr River, Germany, ranged from 0.31 to 0.37 mg/litre in a survey conducted during 1992-1995 (Haberer, 1996). The majority of the EarthOs boron occurs in the oceans, with an average concentration of 4.5 mg/litre (Weast et al., 1985). The amount of boron in fresh water depends on such factors as the geochemical nature of the drainage area, proximity to marine coastal regions, and inputs from industrial and municipal effluents (Butterwick et al., 1989). Boron concentrations in fresh surface water range from <0.001 to 2 mg/litre in Europe, with mean values typically below 0.6 mg/litre. Similar concentration ranges have been reported for water bodies within Pakistan, Russia, and Turkey, from 0.01 to 7 mg/litre, with most values below 0.5 mg/litre. Concentrations ranged up to 0.01 mg/litre in Japan and up to 0.3 mg/litre in South African surface waters. Samples taken in surface waters from two South American rivers (Rio Arenales, Argentina, and Loa River, Chile) contained boron at concentrations ranging between 4 and 26 mg/litre in areas rich in boron-containing soils. In other areas, the Rio Arenales contained less than 0.3 mg of boron per litre. Concentrations of boron in surface waters of North America (Canada, USA) ranged from 0.02 mg/litre to as much as 360 mg/litre, indicative of boron-rich deposits. However, typical boron concentrations were less than 0.1 mg/litre, with a 90th-percentile boron concentration of approximately 0.4 mg/litre. Concentrations of boron found in drinking-water from Chile, Germany, the United Kingdom, and the USA ranged from 0.01 to 15.0 mg/litre, with most values clearly below 0.4 mg/litre. These values are consistent with ranges and means observed for groundwater and surface waters. This consistency is supported by two factors: (i) boron concentrations in water are largely dependent on the leaching of boron from the surrounding geology and wastewater discharges, and (ii) boron is not removed by conventional drinking-water treatment methods. Food The general population obtains the greatest amount of boron through food intake. Concentrations of boron reported in food after 1985 have more validity because of the use of more adequate analytical methods. The richest sources of boron are fruits, vegetables, pulses, legumes, and nuts. Dairy products, fish, meats, and most grains are poor sources of boron. Based on the recent analyses of foods and food products, estimations of daily intakes of various age/sex groups have been made (WHO, in press). The estimated median, mean, and 95th-percentile daily intakes of boron were 0.75, 0.93, and 2.19 mg/day, respectively, for all groups, and 0.79, 0.98 and 2.33 mg/day, respectively, for adults aged 17 and older. Using food included in US Food and Drug Administration Total Diet Studies, lyengar et al. (1988) determined the mean adult male daily intake of boron to be 1.52 mg/day, whereas Anderson et al. (1994) determined the intake to be 1.21 mg/day. Based on the United Kingdom National Food Survey (MAFF, 1991), the dietary intake of boron in the United Kingdom ranges from 0.8 to 1.9 mg/day. It should be noted that increased consumption of specific foods with high boron content will increase boron intake significantly; for example, one serving of wine or avocado provides 0.42 and 1.11 mg, respectively (Anderson et al., 1994). Estimated total exposure and relative contribution of drinking-water The mean daily intake of boron in the diet is judged to be near 1.2 mg/day (Anderson et al., 1994). Concentrations of boron in drinking-water have wide ranges, depending on the source of the drinking-water, but for most of the world the range is judged to be between 0.1 and 0.3 mg/litre. Based on usage data, consumer products have been estimated to contribute a geometric mean of 0.1 mg/day to the estimate of total boron exposure (WHO, in press). The contribution of boron intake from air is negligible. The total daily intake can therefore be estimated from mean concentrations and concentration ranges to be between 1.5 and 2 mg. KINETICS AND METABOLISM IN LABORATORY ANIMALS AND HUMANS Numerous studies have shown that boric acid and borax are absorbed from the gastrointestinal tract and from the respiratory tract, as indicated by increased levels of boron in the blood, tissues, or urine or by systemic toxic effects of exposed individuals or laboratory animals. Clearance of boron compounds is similar in humans and animals. The ratio of mean clearance values as a function of dose in non-pregnant rats versus humans is approximately 3- to 4-fold — i.e. similar to the default value for the toxicokinetic component of the uncertainty factor for interspecies variation [Report of informal discussion to develop recommendations for the WHO Guidelines for drinking-water quality — Boron. Cincinnati, OH, 28-29 September 1997. Report available from WHO, Division of Operational Support in Environmental Health, Geneva] (WHO, 1994). Elimination of borates from the blood is largely by excretion of >90% of the administered dose via the urine, regardless of the route of administration. Excretion is relatively rapid, occurring over a period of a few to several days, with a half-life of elimination of 24 hours or less. The kinetics of elimination of boron have been evaluated in human volunteers given boric acid via the intravenous and oral routes (Jansen et al., 1984; Schou et al., 1984). Absorption is poor through intact skin but is much greater through damaged skin. EFFECTS ON EXPERIMENTAL ANIMALS AND IN VITRO TEST SYSTEMS Acute exposure The oral LDso values for boric acid or borax in mice and rats are in the range of about 400- 700 mg of boron per kg of body weight (Pfeiffer et al., 1945; Weir & Fisher, 1972). Oral LD50 values in the range of 250-350 mg of boron per kg of body weight for boric acid or borax exposure have been reported for guinea-pigs, dogs, rabbits, and cats (Pfeiffer et al., 1945; Verbitskaya, 1975). Signs of acute toxicity for both borax and boric acid in animals given single large doses orally include depression, ataxia, convulsions, and death; kidney degeneration and testicular atrophy are also observed (Larsen, 1988). Short-term exposure In a 13-week study, mice (10 per sex per dose) were fed diets containing boric acid at approximately 0, 34, 70, 141,281, or 563 mg of boron per kg of body weight per day. At the two highest doses, increased mortality was seen. Degeneration or atrophy of the seminiferous tubules was observed at 141 mg of boron per kg of body weight per day. In all dose groups, extramedullary haematopoiesis of the spleen of minimal to mild severity was seen (NTP, 1987). In a study in which borax was given in the diet to male Sprague-Dawley rats (18 per dose) at concentrations of 0, 500, 1000, or 2000 mg of boron per kg of feed (approximately equal to 0, 30, 60, or 125 mg of boron per kg of body weight per day) for 30 or 60 days, body weights were not consistently affected by treatment. Organ weights were not affected by 500 mg of boron per kg of feed; at 1000 and 2000 mg of boron per kg of feed, absolute liver weights were significantly lower after 60 days, and epididymal weights were significantly lower (37.6% and 34.8%, respectively) after 60 days, but not after 30 days. Weights of prostate, spleen, kidney, heart, and lung were not changed at any dose (Lee et al., 1978). In a 90-day study in rats (10 per sex per dose) receiving 0, 2.6, 8.8, 26, 88, or 260 mg of boron per kg of body weight per day in the diet as boric acid or borax, all animals at the highest dose died within 3-6 weeks (Weir & Fisher, 1972). In animals receiving 88 mg of boron per kg of body weight per day, body weights in males and females were reduced; absolute organ weights, including the liver, spleen, kidneys, brain, adrenals, and ovaries, were also significantly decreased in this group. Organ-to-body-weight ratios for the adrenals and kidneys were significantly increased, but relative weights of the liver and ovaries were decreased. A pronounced reduction in testicular weights in males in the 88 mg of boron per kg of body weight per day group was also observed. Boric acid or borax was also fed to beagle dogs for 90 days or for 2 years. In the 90-day boric acid study (weight-normalized doses of 0, 0.44, 4.4, or 44 mg of boron per kg of body weight per day; five animals per sex per dose), testis weight was significantly lower than controls in the middle and upper dose groups (reduced by 25% and 40%, respectively). Although testicular microscopic structure was not detectably abnormal in the controls and middle dose group, four of five dogs in the high-dose group had complete atrophy, and the remaining high-dose dog had one-third of tubules showing some abnormality. In the borax study, testis weights in the low-, middle-, and high-dose groups were 80%, 85%, and 50% of controls, respectively; only the last was significantly different from controls. No mention was made of the testicular microscopic structure of the controls or low-dose animals; middle-dose animals were not detectably altered (aside from the considerable fixation-induced artifact in the outer third of the tissue), whereas four of five high-dose dogs had complete testicular atrophy, and the remaining high-dose dog had "partial" atrophy. No other clinical or microscopic signs of toxicity were reported in any animals (Weir & Fisher, 1972). In the 2-year study, the dogs (four per sex per dose) received the boric acid or borax in the diet at weight-normalized doses of 0, 1.5, 2.9, or 8.8 mg of boron per kg of body weight per day. An additional group received 29 mg of boron per kg of body weight per day for 38 weeks. Testicular atrophy was observed in two test dogs receiving borax at 26 weeks and in the two and one dogs, respectively, killed after 26 or 38 weeks of boric acid consumption. The authors stated that boric acid caused testicular degeneration in dogs, including spermatogenic arrest and atrophy of the seminiferous epithelium. The study was terminated at 38 weeks. In these studies, the number of dogs was small and variable (one or two dogs at each of three time points) and inadequate to allow statistical analysis. All three treated dogs had widespread and marked atrophy in 25—40% of the seminiferous tubules. A common control group was used for both the borax and boric acid studies. Testicular lesions occurred in the controls (one of four controls had slight to severe seminiferous tubular atrophy, another had moderate to severe atrophy, whereas a third had a detectable but insignificant reduction in spermatogenesis and 5% atrophic seminiferous tubules) (Weir & Fisher, 1972). These studies were conducted before the advent of Good Laboratory Practices (GLPs). Confidence in these studies is low, and they were considered not suitable for inclusion into the risk assessment because of 1) small and variable numbers of dogs, 2) variable background lesions in controls leading to uncertainty of the strength of the response to treatment, 3) lack of GLPs, and 4) other, more recent studies of greater scientific quality with findings at similar intake levels of boron (Ku et al., 1993; Price et al., 1996a). Long-term exposure A 2-year study in mice (50 per sex per dose) receiving approximately 0, 275, or 550 mg of boric acid per kg of body weight per day (0, 48, or 96 mg of boron per kg of body weight per day) in the diet (NTP, 1987; Dieter, 1994) demonstrated that body weights were 10-17% lower in high-dose males after 32 weeks and in high-dose females after 52 weeks. Increased mortality rates were statistically significant in males, with significant lesions in male mice appearing in the testes and no significant non-neoplastic lesions in female mice. In a 2-year study, rats (35 per sex per dose) were administered weight-normalized boron doses of 0, 5.9, 18, or 59 mg/kg of body weight per day in the diet (Weir & Fisher, 1972). High-dose animals had coarse hair coats, scaly tails, hunched posture, swollen and desquamated pads of the paws, abnormally long toenails, shrunken scrotum, inflamed eyelids, and bloody eye discharge. The haematocrit and haemoglobin levels were significantly lower than controls, the absolute and relative weights of the testes were significantly lower, and relative weights of the brain and thyroid gland were higher than in controls. In animals in the mid- and low-dose groups, no significant effects on general appearance, behaviour, growth, food consumption, haematology, serum chemistry, or histopathology were observed. Reproductive and developmental toxicity Short- and long-term oral exposures to boric acid or borax in laboratory animals have demonstrated that the male reproductive tract is a consistent target of toxicity. Testicular lesions have been observed in rats, mice, and dogs administered boric acid or borax in food or drinking-water (Truhaut et al., 1964; Weir & Fisher, 1972; Green et al., 1973; Lee et al., 1978; NTP, 1987; Ku et al., 1993). The first clinical indication of testicular toxicity in dogs is shrunken scrota observed during treatment; significant decreases in absolute and relative testicular weight are also reported. After subchronic exposure, the histopathological effects range from inhibited spermiation (sperm release) to degeneration of the seminiferous tubules with variable loss of germ cells to complete absence of germ cells, resulting in atrophy and transient or irreversible loss of fertility, but not of mating behaviour. In time-response and dose-response reproductive studies (Linder et al., 1990), adult male Sprague-Dawley rats were administered two doses in one day, with a total dose of 0 or 350 mg of boron per kg of body weight in the time-response experiment (animals were sacrificed at 2, 14, 28, or 57 days post-treatment) and a total dose of 0, 44, 87, 175, or 350 mg of boron per kg of body weight in the dose-response experiment (animals were sacrificed after 14 days). Adverse effects on spermiation, epididymal sperm morphology, and caput sperm reserves were observed during histopathological examinations of the testes and epididymis. The NOAEL for male reproductive effects in the dose-response study was 87 mg of boron per kg of body weight per day. In a multi-generation study, doses of 0, 117, 350, or 1170 mg of boron per kg of feed (as borax or boric acid) were administered to male and female rats (Weir & Fisher, 1972). At the highest dose, rats were found to be sterile, males showed atrophied testes in which spermatozoa were absent, and females showed decreased ovulation. The NOAEL in this study was 350 mg of boron per kg of feed, equivalent to 17.5 mg of boron per kg of body weight per day. To investigate the development of testicular lesions, boric acid was fed at 61 mg of boron per kg of body weight per day to male F344 rats; sacrifice of six treated and four control rats was conducted at intervals from 4 to 28 days. At 28 days, there was significant loss of spermatocytes and spermatids from all tubules in exposed rats, and basal serum testosterone levels were significantly decreased from 4 days on (Treinen & Chapin, 1991). In another study, the activities of enzymes found primarily in spermatogenic cells were decreased, and enzyme activities associated with premeiotic spermatogenic cells were significantly increased in rats exposed to 60 or 125 mg of boron per kg of body weight per day for 60 days (Lee et al., 1978). Mean plasma follicle-stimulating hormone levels were significantly elevated in a dose-dependent manner in all treatment groups (30, 60, or 125 mg of boron per kg of body weight per day) in this study after 60-day exposures. Reversibility of testicular lesions was evaluated by Ku et al. (1993) in an experiment in which F344 rats were dosed at 0, 3000,4500, 6000, or 9000 mg of boric acid per kg of feed (equivalent to 0, 26, 39, 52, or 78 mg of boron per kg of body weight per day) for 9 weeks and assessed for recovery up to 32 weeks post-treatment. Inhibited spermiation was exhibited at 3000 and 4500 mg of boric acid per kg of feed (5.6 ug of boron per mg of tissue), whereas inhibited spermiation progressed to atrophy at 6000 and 9000 mg of boric acid per kg of feed (11.9 ug of boron per mg of testes); there was no boron accumulation in the testes to levels greater than those found in the blood during the 9-week period. After treatment, serum and testis boron levels in all dose groups fell to background levels. Inhibited spermiation at 4500 mg of boric acid per kg of feed was reversed by 16 weeks post-treatment, but focal atrophy, which did not recover up to 32 weeks post-treatment, was detected. Developmental toxicity has been demonstrated experimentally in rats, mice, and rabbits (NTP, 1990; Heindel et al., 1992; Price et al., 1996b). Rats were fed a diet containing 0, 14, 29, or 58 mg of boron per kg of body weight per day as boric acid on gestation days 0-20 (Heindel et al., 1992). An additional group of rats received boric acid at 94 mg of boron per kg of body weight per day on gestation days 6-15 only. Average fetal body weight per litter was significantly reduced in a dose-related manner in all treated groups compared with controls. The percentage of malformed fetuses per litter and the percentage of litters with at least one malformed fetus were significantly increased at =29 mg of boron per kg of body weight per day. Malformations consisted primarily of anomalies of the eyes, the central nervous system (CNS), the cardiovascular system, and the axial skeleton. The most common malformations were enlargement of lateral ventricles in the brain and agenesis or shortening of rib XIII. The LOAEL of 14 mg of boron per kg of body weight per day (the lowest dose tested) for rats occurred in the absence of maternal toxicity; a NOAEL was not found in this study. Price et al. (1996a) did a follow-up to the Heindel et al. (1992) study in Sprague-Dawley (CD) rats to determine a NO AEL for fetal body-weight reduction and to determine whether the offspring would recover from prenatally reduced body weight during postnatal development. Boric acid was administered in the diet to CD rats on gestation days 0-20. Dams were terminated and uterine contents examined on gestation day 20. The intake of boric acid was 0, 3.3, 6.3, 9.6, 13, or 25 mg of boron per kg of body weight per day. Fetal body weights were 99, 98, 97, 94, and 88% of controls for the low- to high-dose groups, respectively. Incidences of short rib XIII (a malformation) or wavy rib (a variation) were increased in the 13 and 25 mg of boron per kg of body weight per day dose groups relative to control litters. There was a decreased incidence of rudimentary extra rib on lumbar 1 (a variation) in the high-dose group that was deemed biologically but not statistically significant. The NO AEL in this study was 9.6 mg of boron per kg of body weight per day, based on a decrease in fetal body weight at the next higher dose. Developmental toxicity and teratogenicity of boric acid in mice at 0, 43, 79, or 175 mg of boron per kg of body weight per day in the diet were investigated (Heindel et al., 1992). There was a significant dose-related decrease in average fetal body weight per litter at 79 and 175 mg of boron per kg of body weight per day. In offspring of mice exposed to 79 or 175 mg of boron per kg of body weight per day during gestation days 0-20, there was an increased incidence of skeletal (rib) malformations. These changes occurred at doses for which there were also signs of maternal toxicity (increased kidney weight and pathology); the LOAEL for developmental effects (decreased fetal body weight per litter) was 79 mg of boron per kg of body weight per day, and the NO AEL was 43 mg of boron per kg of body weight per day. Developmental toxicity and teratogenicity of boric acid in rabbits were investigated by Price et al. (1996b) at doses of 0, 11, 22, or 44 mg of boron per kg of body weight per day, given by gavage. Frank developmental effects in rabbits exposed to 44 mg of boron per kg of body weight per day included a high rate of prenatal mortality, an increased number of pregnant females with no live fetuses, and fewer live fetuses per live litter on day 30. At the high dose, malformed live fetuses per litter increased significantly, primarily because of the incidence of fetuses with cardiovascular defects, the most prevalent of which was interventricular septal defect. Skeletal variations observed were extra rib on lumbar 1 and misaligned sternebra. The NO AEL for maternal and developmental effects was 22 mg of boron per kg of body weight per day. Mutagenicity and related end-points The mutagenic activity of boric acid was examined in the Salmonella typhimurium and mouse lymphoma assays, with negative results. No induction of sister chromatid exchange or chromosomal aberrations was observed in Chinese hamster ovary cells (NTP, 1987). Sodium borate did not cause gene mutations in the S. typhimurium preincubation assay (Benson et al., 1984). Borax was not mutagenic in cell transformation assays with Chinese hamster cells, mouse embryo cells, and human fibroblasts (Landolph, 1985). Carcinogenicity Tumour incidence was not enhanced in studies in which B6C3F] mice received 0, 2500, or 5000 mg of boric acid per kg of feed for 103 weeks (NTP, 1987) and Sprague-Dawley rats received diets containing 0, 117, 350, or 1170 mg of boron per kg of feed (as borax or boric acid) for 2 years (Weir & Fisher, 1972). EFFECTS ON HUMANS Available human data on boron compounds for routes other than inhalation focus on boric acid and borax. According to Stokinger (1981), the lowest reported lethal doses of boric acid are 640 mg/kg of body weight (oral), 8600 mg/kg of body weight (dermal), and 29 mg/kg of body weight (intravenous injection). Stokinger (1981) stated that death has occurred at total doses of between 5 and 20 g of boric acid for adults and <5 g for infants. Litovitz et al. (1988) stated that potential lethal doses are usually cited as 3-6 g total for infants and 15-20 g total for adults. A case-series report of seven infants (aged 6-16 weeks) who used pacifiers coated with a borax and honey mixture for 4-10 weeks concluded that exposures ranged from 12 to 90 g, with a very crudely estimated average daily ingestion of 18-56 mg of boron per kg of body weight (OD Sullivan & Taylor, 1983). [Estimates given here are corrected values, as intakes reported in this publication were underestimated by a factor of 3 (M. Taylor, personal communication to M. Dourson, in a letter dated 28 August 1997).] Toxicity was manifested by generalized or alternating focal seizure disorders, irritability, and gastrointestinal disturbances. Although infants appear to be more sensitive than adults to boron compounds, lethal doses are not well documented in the literature. Goldbloom & Goldbloom (1953) reported four cases of boric acid poisoning and reviewed an additional 109 cases in the literature. The four cases were infants exposed to boric acid by repeated topical applications of baby powder. Toxicity was manifested by cutaneous lesions (erythema over the entire body, excoriation of the buttocks, and desquamation), gastrointestinal disturbances, and seizures. Approximately 35% of the 109 other case reports of boric acid poisoning involved children <1 year of age. The mortality rate was 70.2% for children, compared with 55.0% for all cases combined. Death occurred in 53% of patients exposed by ingestion, 75% of patients subjected to gastric lavage with boric acid, 68% of patients exposed by dermal application for treating bums, wounds, and skin eruptions, and 54% of patients exposed by other routes. Information on signs and symptoms for 80 patients showed that gastrointestinal disturbances were prevalent (73%), followed by CNS effects (67%). Cutaneous lesions were prevalent in 76% of the cases and in 88% of cases involving children <2 years of age. Gross and microscopic findings were reported for 45% of fatal cases. In general, boric acid caused chemical irritation primarily at sites of application and excretion and in organs with maximum boron concentrations. The most common CNS findings were oedema and congestion of the brain and meninges. Other common findings included liver enlargement, vascular congestion, fatty changes, swelling, and granular degeneration. In addition to case reports, poison centres have published case-series reports. Unlike the case reports reviewed by Goldbloom & Goldbloom (1953), more recent reports suggest that the oral toxicity of boron in humans is milder than previously thought. Litovitz et al. (1988) conducted a retrospective review of 784 cases of boric acid ingestion reported to the National Capital Poison Center in Washington, DC, USA, during 1981-1985 and the Maryland Poison Center in Baltimore, MD, USA, during 1984-1985; approximately 88.3% of the cases were asymptomatic. All but two of the cases had acute (single) ingestion, and 80.2% involved children <6 years of age. No severe toxicity or life-threatening effects were noted, although boric acid levels in blood serum ranged from 0 to 340 ng/ml. The most frequently occurring symptoms, which involved the gastrointestinal tract, included vomiting, abdominal pain, diarrhoea, and nausea. Other symptoms (primarily CNS and cutaneous) occurred in fewer cases: lethargy, rash, headache, light-headedness, fever, irritability, and muscle cramps. The average dose ingested was estimated at 1.4 g. According to Litovitz et al. (1988), 21 of the children <6 years of age, 15 of whom were <2 years of age, ingested the reported potential lethal dose of 3 g; eight adults ingested the reported potential lethal dose of 15 g without clinical evidence of lethal effects. Linden et al. (1986) published a retrospective review of 364 cases of boric acid exposure reported to the Rocky Mountain Poison and Drug Center in Denver, CO, USA, between 1983 and 1984. Vomiting, diarrhoea, and abdominal pain were the most common symptoms given by the 276 cases exposed in 1983. Of the 72 cases reported in 1984 for whom medical records were complete, 79% were asymptomatic, whereas 20% noted mild gastrointestinal symptoms. One 2-year-old child died, presumably from repeated ingestion of an insecticide containing 99% boric acid. Overall, owing to the wide variability of data collected from poisoning centres, the average dose of boric acid to produce clinical symptoms is still unclear, presumably in the range of 100 mg to 55.5 g, reported by Litovitz et al. (1988). Findings from human experiments show that boron is a dynamic trace element that can affect the metabolism or utilization of numerous substances involved in life processes, including calcium, copper, magnesium, nitrogen, glucose, triglycerides, reactive oxygen, and estrogen. Although the first findings involving boron deprivation of humans appeared in 1987 (Nielsen et al., 1987), the most convincing findings have come mainly from two studies in which men over the age of 45, postmenopausal women, and postmenopausal women on estrogen therapy were fed a low-boron diet (0.25 mg/2000 kcal) for 63 days and then fed the same diet supplemented with 3 mg of boron per day for 49 days (Nielsen, 1989, 1994; Nielsen et al., 1990, 1991, 1992; Penland, 1994). These dietary intakes were near the low and high values in the range of usual dietary boron intakes. The major differences between the two studies were the intakes of copper and magnesium: in one experiment, they were marginal or inadequate; in the other, they were adequate. The marginal or inadequate copper and magnesium intakes caused apparent detrimental changes that were more marked during boron deprivation than during boron repletion. Although the function of boron remains undefined, boron is becoming recognized as an element of potential nutritional importance because of the findings from human and animal studies. PROVISIONAL GUIDELINE VALUE The TDI of boron is derived by dividing the NOAEL (9.6 mg/kg of body weight per day) for the critical effect, which is developmental toxicity (decreased fetal body weight in rats), by an appropriate uncertainty factor, which is judged to be 60. The value of 10 for interspecies variation (animals to humans) was adopted because of lack of toxicokinetic and toxicodynamic data to allow deviation from this default value. Available toxicokinetic data do support, however, reduction of the default uncertainty factor for intraspecies variation from 10 to 6 (WHO, 1994). Interspecies (toxicokinetic) variations for boron relate primarily to clearance. The ratio of mean clearance values in non-pregnant rats versus non-pregnant humans for boron (based on all of the data considered suitable for inclusion) is 3-4. In view of the lack of adequate kinetic studies in rats and hence less than optimum confidence in much of the data that serve as the basis for the ratio, replacement of the default for the toxicokinetic component of the interspecies factor is considered premature at this time. The total uncertainty factor for interspecies variation is 10. Intraspecies variation (toxicokinetics) for boron relates also primarily to variations in clearance. As the critical effect that serves as the basis for the TDI is developmental, pregnant women are the subgroup of interest in this regard. Based on pooled individual data from available studies, the mean glomerular filtration rate (GFR) in 36 healthy women was 145 ± 23 ml/minute in early pregnancy and 144 ± 32 ml/minute in late pregnancy. The standard deviation represented 22% of the mean value in late pregnancy. Based on division of the mean GFR (144 ml/minute) by the GFR at two standard deviations below the mean (80 ml/minute) to address variability for approximately 95% of the population, the ratio for the toxicokinetic component of interspecies variation is 1.8 (compared with the default value for this component of 3.2). As there are no data to serve as a basis for replacement of the default value for the toxicodynamic component of the uncertainty factor for intraspecies variation, the total uncertainty factor for intraspecies variation is 1.8 x 3.2 = 5.7 (rounded to 6) [Report of informal discussions to develop recommendations for the WHO Guidelines for drinking- water quality — Boron. Cincinnati, OH, 28-29 September 1997. Report available from WHO, Division of Operational Support in Environmental Health, Geneva]. Using an uncertainty factor of 60, the TDI is therefore 0.16 mg/kg of body weight. With an allocation of 10% of the TDI to drinking-water and assuming a 60-kg adult consuming 2 litres of drinking-water per day, the guideline value is 0.5 mg/litre (rounded figure). Conventional water treatment (coagulation, sedimentation, filtration) does not significantly remove boron, and special methods would have to be installed in order to remove boron from waters with high boron concentrations. Ion exchange and reverse osmosis processes may enable substantial reduction but are likely to be prohibitively expensive. Blending with low- boron supplies might be the only economical method to reduce boron concentrations in waters where these concentrations are high (WRc, 1997). The guideline value of 0.5 mg/litre is designated as provisional, because it will be difficult to achieve in areas with high natural boron levels with the treatment technology available. REFERENCES I.Anderson DL, Cunningham WC, Lindstrom TR (1994) Concentrations and intakes of H, B, S, K, Na, Cl and NaCl in foods. Journal of food composition and analysis, 7:59-82. 2. Benson WH, Birge WJ, Dorough HW (1984) Absence of mutagenic activity of sodium borate (borax) and boric acid in the Salmonella preincubation test. Environmental toxicology and chemistry, 3:209-214. 3. Budavari S et al., eds. (1989) The Merck index, 11th ed. Rahway, NJ, Merck and Co., Inc. Butterwick L, de Oude N, Raymond K (1989) Safety assessment of boron in aquatic and terrestrial environments. Ecotoxicology and environmental safety, 17:339-371. 4. Cotton PA, Wilkinson L (1988) Advanced inorganic chemistry, 5th ed. New York, NY, John Wiley & Sons, pp. 162-165. 5. 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Biological trace element research, 22:201-220. 12. ISO (1990) Water quality— Determination of borate— Spectrometric method using azomethine-H. Geneva, International Organization for Standardization (ISO 9390:1990). 10 13. ISO (1996) Water quality— Determination of 33 elements by inductively coupled plasma atomic emission spectroscopy. Geneva, International Organization for Standardization (ISO 11885:1996 (E)). 14. lyengar GV et al. (1988) Lithium in biological and dietary materials. In: Proceedings of the 5th international workshop on trace element analytical chemistry in medicine and biology, pp. 267-269. 15. Jansen JA, Andersen J, Schou JS (1984) Boric acid single dose pharmacokinetics after intravenous administration to man. Archives of toxicology, 55:64-67. 16. Keren R, Mezuman U (1981) Boron adsorption by clay minerals using a phenomenological equation. Clays and clay minerals, 29:198-204. 17. Keren R, Gast RG, Bar-Yosef B (1981) pH-dependent boron adsorption by Na- montmorillonite. Soil Science Society of America journal, 45:45-48. 18. Ku WW et al. (1993) Testicular toxicity of boric acid (BA): relationship of dose to lesion development and recovery in the F344 rat. Reproductive toxicology, 7:305-319. 19. Landolph JR (1985) Cytotoxicity and negligible genotoxicity of borax and borax ores to cultured mammalian cells. American journal of industrial medicine, 7:31-43. 20. Larsen LA (1988) Boron. In: Seiler HG, Sigel H, eds. Handbook on toxicity of inorganic compounds. New York, NY, Marcel Dekker, pp. 129-141. 21. Lee IP, Sherins RJ, Dixon RL (1978) Evidence for induction of germinal aplasia in male rats by environmental exposure to boron. Toxicology and applied pharmacology, 45:577-590. 22. Linden CH et al. (1986) Acute ingestion of boric acid. Journal of toxicology. Clinical toxicology, 24:269-279. 23. Linder RE, Strader LF, Rehnberg GL (1990) Effect of acute exposure to boric acid on the male reproductive system of the rat. Journal of toxicology and environmental health, 31:133- 146. 24. Litovitz TL et al. (1988) Clinical manifestation of toxicity in a series of 784 boric acid ingestions. American journal of emergency medicine, 31:209-213. 25. MAFF (1991) Household food consumption and expenditure 1991. Annual report of the National Food Survey Committee. London, Ministry of Agriculture, Fisheries and Food. 26. Mance G, ODDonnell AR, Smith PR (1988) Proposed environmental quality standards for List II substances in water: Boron. Medmenham, Water Research Centre (Report TR 256, March 1988; ISBN 0-902-15663-2). 27. Nielsen FH (1989) Dietary boron affects variables associated with copper metabolism in humans. In: Aulse M et al., eds. Proceedings of the 10th international trace element symposium. Vol. 4. Jena, Friedrich-Schiller-Universitat, pp. 1106-1111. 28. Nielsen FH (1994) Biochemical and physiological consequences of boron deprivation in humans. Environmental health perspectives, 102 (Suppl. 7):59-63. 29. Nielsen FH et al. (1987) Effect of dietary boron on mineral, oestrogen, and testosterone metabolism in postmenopausal women. The FASEB journal, 1:394-397. 30. Nielsen FH, Mullen LM, Gallagher SK (1990) Effect of boron depletion and repletion on blood indicators of calcium status in humans fed a magnesium-low diet. Journal of trace elements in experimental medicine, 3:45-54. 31 .Nielsen FH, Mullen LM, Nielsen EJ (1991) Dietary boron affects blood cell counts and hemoglobin concentrations in humans. Journal of trace elements in experimental medicine, 4:211-223. 32. Nielsen FH et al. (1992) Boron enhances and mimics some effects of oestrogen therapy in postmenopausal women. Journal of trace elements in experimental medicine, 5:237-246. 33.NTP(1987) Toxicology and carcinogenesis studies of boric acid (CAS no. 10043-35-3) in B6C3Ft mice (food studies). Research Triangle Park, NC, US Department of Health and Human Services, Public Health Service, National Institutes of Health, National Toxicology Program (NTP Technical Report Series No. 324).NTP (1990). 34. NTP Final report on the developmental toxicity of boric acid (CAS no. 10043-35-3) in Sprague-Dawley rats. Research Triangle Park, NC, US Department of Health and Human Services, Public Health Service, National Institutes of Health, National Toxicology Program (NTP Report No. 90-105). 11 35. O'Sullivan K, Taylor M (1983) Chronic boric acid poisoning in infants. Archives of diseases in childhood, 58:737-739. 36. Penland JG (1994) Dietary boron, brain function and cognitive performance. Environmental health perspectives, 102 (Suppl. 7):65-72. 37. Pfeiffer CC, Hallman LF, Gersh I (1945) Boric acid ointment: A study of possible intoxication in the treatment of burns. Journal of the American Medical Association, 128:266- 274. 38. Price CJ et al. (1996a) Developmental toxicity NOAEL and postnatal recovery in rats fed boric acid during gestation. Fundamental and applied toxicology, 32:179-193. 39. Price CJ et al. (1996b) The developmental toxicity of boric acid in rabbits. Fundamental and applied toxicology, 34:176-187. 40. Rai D et al. (1986) Chemical attenuation rates, coefficients, and constants in leachate migration. Vol. 1: A critical review. Report to Electric Power Research Institute, Palo Alto, CA, by Battelle Pacific Northwest Laboratories, Richland, WA (Research Project 2198-1). 41. Schou JS, Jansen JA, Aggerbeck B (1984) Human pharmacokinetics and safety of boric acid. Archives of toxicology, Suppl. 7:232-235. 42. Smith FG et al. (1991) Measurement of boron concentration and isotope ratios in biological samples by inductively coupled plasma mass spectrometry with direct injection nebulization. Analytica ChimicaActa, 248:229-234. 43. Sprague RW (1972) The ecological significance of boron. Anaheim, CA, US Borax Research Corporation, 58 pp. 44. Stokinger HE (1981) Boron. In: Clayton GD, Clayton FE, eds. Patty's industrial hygiene and toxicology. Vol. 2B. Toxicology, 3rd ed. New York, NY, John Wiley & Sons, pp. 2978- 3005. 45. Treinen KA, Chapin RE (1991) Development of testicular lesions in F344 rats after treatment with boric acid. Toxicology and applied pharmacology, 107:325-335. 46. Truhaut R, Phu-Lich N, Loisillier F (1964) [Effects of the repeated ingestion of small doses of boron derivatives on the reproductive functions of the rat.] Comptes Rendus de I'Academie des Sciences, 258:5099-5102 (in French with English abstract). 47. Verbitskaya GV (1975) [Experimental and field investigations concerning the hygienic evaluation of boron-containing drinking water.] Gigiena i Sanitariya, 7:49-53 (in Russian with English abstract). 48. Waggott A (1969) An investigation of the potential problem of increasing boron concentrations in rivers and water courses. Water research, 3:749-765. 49. Weast RC, Astle MJ, Beyer WH, eds. (1985) CRC handbook of chemistry and physics, 69th ed. Boca Raton, FL, CRC Press, Inc., pp. B-77, B-129. 50. Weir RJ, Fisher RS (1972) Toxicologic studies on borax and boric acid. Toxicology and applied pharmacology, 23:351-364. 51. WHO (1994) Assessing human health risks of chemicals: derivation of guidance values for health-based exposure limits. Geneva, World Health Organization, International Programme on Chemical Safety (Environmental Health Criteria 170). 52. WHO (in press) Boron. Geneva, World Health Organization, International Programme on Chemical Safety (Environmental Health Criteria monograph). 53. WRc (1997) Treatment technology for aluminium, boron and uranium. Document prepared for WHO by the Water Research Centre, Medmenham, and reviewed by S. Clark, US EPA; A. van Dijk-Looijaard, KIWA, Netherlands; and D. Green, Health Canada. 12 Exhibit 3 California Department of Health Services—Drinking Water Program DHS DRINKING WATER ACTION LEVELS Action levels are health-based advisory levels for unregulated contaminants in drinking water. They are used by the California Department of Health Services (DHS) to provide guidance to drinking water systems. Detections of contaminants above action levels prompt certain notification requirements and recommendations. For more about the derivation and application of action levels, as well as contaminant-specific information, see the Drinking Water Program's website: http://www.dhs.ca.gov/ps/ddwem/AL/actionlevels.htm DHS DRINKING WATER ACTION LEVELS Contaminant Action Level (milligrams per liter) Contaminants of Current Interest Boron Chlorate Dichlorodifluoromethane 1,4-Dioxane Formaldehyde N-Nitrosodimethylamine (NDMA) Perchlorate Tertiary butyl alcohol 1,2,3-Trichloropropane Vanadium 1 0.8 1 0.003 0.1 0.00001 0.004 0.012 0.000005 0.05 Historic or Rarely Detected Contaminants Aldicarb Aldrin Baygon a-Benzene Hexachloride b- Benzene Hexachloride n-Butylbenzene sec-Butylbenzene tert-Butylbenzene Captan Carbaryl Carbon disulfide Chloropicrin 2-Chlorotoluene 4-Chlorotoluene Chlorpropham (CIPC) Diazinon 1,3-Dichlorobenzene Dieldrin Dimethoate 0.007 0.000002 0.03 0.000015 0.000025 0.07 0.26 0.26 0.0015 0.7 0.16 0.056 0.14 0.14 1.2 0.006 0.6 0.000002 0.001 January 2003 Page 1 of 2 California Department of Health Services—Drinking Water Program DHS DRINKING WATER ACTION LEVELS, Continued Contaminant 2,4-Dimethylphenol Diphenamide Ethion Ethylene glycol Isopropylbenzene Malathion N-Methyl dithiocarbamate (Metam sodium) Methyl isobutyl ketone (MIBK) Methylisothiocyanate Methyl parathion Naphthalene Parathion Pentachloronitrobenzene Phenol n-Propylbenzene 2,3,5,6-Tetrachloroterephthalate 1,2,4-Trimethylbenzene 1, 3, 5-Trimethyl benzene Trithion Action Level (milligrams per liter) 0.1 0.2 0.004 14 0.77 0.16 0.02 0.12 0.05 0.002 0.17 0.04 0.02 4.2 0.26 3.5 0.33 0.33 0.007 For more information, please visit the DHS Drinking Water Program's website: http://www.dhs.ca.gov/ps/ddwem/AL/actionlevels.htm February 14, 2003 Page 2 of 2 Exhibit 4 PUBLICATION 8066 FWQP REFERENCE SHEET 9.10 UNIVERSITY OF CALIFORNIA Agriculture and Natural Resources http://anrcatalog.ucdavis.edu In partnership with ANRCS Natural Resources Conservation Service http://www.nrcs.usda.gov Farm Water Quality Planning A Water Quality and Technical Assistance Program for California Agriculture http://waterquality.ucanr.org This REFERENCE SHEET is part of the Farm Water Quality Planning (FWQP) series, developed for a short course that provides training for grow- ers of irrigated crops who are interested in implementing water quality protection prac- tices. The short course teaches the basic concepts of water- sheds, nonpoint source pollution (NPS), self-assessment tech- niques, and evaluation tech- niques. Management goals and practices are presented for a variety of cropping systems. UCI PEER& REVIEWED Irrigation Water Salinity and Crop Production STEPHEN R. GRATTAN, Plant-Water Relations Specialist, University of California, Davis Irrigation water quality can have a profound impact on crop production. All irrigation water contains dissolved mineral salts, but the concentration and composition of the dissolved salts vary depending on the source of the irrigation water. For example, snow melt or water supplies from the Sierra Nevada contain very small amounts of salt whereas groundwater or wastewater typically has higher salt levels. Too much salt can reduce or even prohibit crop production while too little salt can reduce water infiltration, which indirectly affects the crop. An understanding of the quality of water used for irrigation and its potential negative impacts on crop growth is essential to avoid problems and to optimize production. For more information on any of the issues found in this publication, please contact your local University of California Cooperative Extension office. DISSOLVED SALTS Dissolved salts in irrigation water form ions. The most common salts in irrigation water are table salt (sodium chloride, NaCl), gypsum (calcium sulfate, CaSO4), Epsom salts (magnesium sulfate, MgSO4), and baking soda (sodium bicarbonate, NaHCO3). Salts dissolve in water and form positive ions (cations) and negative ions (anions). The most common cations are calcium (Ca2+), magnesium (Mg2+), and sodium (Na+) while the most common anions are chloride (Cl~), sulfate (SO4 2~), and bicarbonate (HCO3~). The ratios of these ions, however, vary from one water supply to another. Potassium (K+), carbonate (CO32~), and nitrate (NO3~) also exist in water supplies, but concentrations of these constituents are comparatively low. In addition, some irrigation waters, particularly from groundwater sources, contain boron at levels that may be detrimental to certain crops. It should be noted that substantial salinization potential is realized through nat- ural weathering and dissolution of soil parent materials, and these salt contributions will attenuate or augment irrigation water ionic constituents. CHARACTERIZING SALINITY There are two common water quality assessments that characterize the salinity of irrigation water. The salinity of irrigation water is sometimes reported as the total salt concentration or total dissolved solids (TDS). The units of TDS are usually expressed in milligrams of salt per liter (mg/L) of water. This term is still used by commercial analytical laboratories and represents the total number of milligrams of salt that would remain after lliter of water is evaporated to dryness. TDS is also often reported as parts per million (ppm) and is the same numerically as mg/L. The higher the TDS, the higher the salinity of the water. The other measurement that is documented in water quality reports from com- mercial labs is specific conductance, also called electrical conductivity (EC). EC is a much more useful measurement than TDS because it can be made instantaneously and easily by irrigators or farm managers in the field. Salts that are dissolved in water ANR Publication 8066 Irrigation Water Salinity and Crop Reproduction conduct electricity, and, therefore, the salt content in the water is directly related to the EC. The EC can be reported based on the irrigation water source (ECw) or on the saturated soil extract (ECe). Units of EC reported by labs are usually in mil- limhos per centimeter (mmhos/cm) or decisiemens per meter (dS/m). One mmho/cm = 1 dS/m. EC is also reported in micrommhos per centimeter (umhos/cm). 1 umho = Viooo mmho. Often conversions between ECw and IDS are made, but caution is advised because conversion factors depend both on the salinity level and composition of the water. For example: IDS (mg/L) = 640 x ECw (dS/m) when ECw < 5 dS/m IDS (mg/L) = 800 x ECw (dS/m) when ECw > 5 dS/m Sulfate salts do not conduct electricity in the same way as other types of salts. Therefore, if water contains large quantities of sulfate salts, the conversion factors are invalid and must be adjusted upward. IRRIGATION WATER SALINITY, SOIL SALINITY, AND LEACHING Many irrigation water supplies contain a substantial amount of salt. For example, a water source with an EC of 1.0 mmho/cm, a quality suitable for irrigation of most crops, contains nearly 1 ton of salt in every acre-foot of water applied. Irrigation can contribute a substantial amount of salt to a field over the season. Salts accumulate in the rootzone by two processes: the upward movement of a shallow saline-water table and salts left in the soil due to insufficient leaching. To control salinity from high saline water tables, drains must be installed in the field. To battle against salts that accumulate in the rootzone from the irrigation water, the soil must be adequately leached. Leaching is the process of applying more water to the field than can be held by the soil in the crop rootzone such that the excess water drains below the root sys- tem, carrying salts with it. The more water that is applied in excess of the crop water requirement, the less salinity there is left in the rootzone despite the fact that more salt has actually been added to the field. The term leaching fraction (LF) is used to relate the fraction or percent of water applied to the field that actually drains below the rootzone. For example, if 1 acre-foot of water is applied to 1 acre of land, and 0.1 acre-foot drains below the rootzone, the leaching fraction is Vio (10 percent). Below are some useful relationships between the salinity in irrigation water (electrical conductivity of irrigation water, ECw) and the average rootzone salinity (ECe). These relationships were developed by Ayers and Westcot (1985) and assume steady state conditions. ECe is the electrical conductivity of the saturated soil paste (soil samples are saturated with distilled water, the soil water is then extracted, and the EC is measured on the extracted water). These relationships predict what will happen over the long term if the leaching fractions indicated are achieved and assuming that the ECe in the rootzone increases with depth (which would be evi- dence of leaching). LF 10% leads to ECw x 2.1 = ECe LF 15-20% leads to ECw x 1.5 = ECe LF 30% leads to ECw = ECe ANR Publication 8066 Irrigation Water Salinity and Crop Reproduction ESTIMATING YIELD POTENTIAL How could you use these relationships to estimate the yield potential? Maas and Grattan (1999) provide an extensive list of salinity coefficients for a number of hor- ticultural and agronomic crops. These coefficients consist of a threshold and slope. The salinity threshold (a) is the maximum average soil salinity (ECe) the crop can tolerate in the rootzone without a decline in yield. The slope coefficient (b) is the percent loss in relative yield the crop will experience for every unit increase in ECe above the threshold. Using these coefficients, the yield potential (% Yield) can be estimated from the following expression: % Yield = 100 - b (ECe - a) Tables 1 and 2 provide water quality guidelines for the most commonly grown crops in California. Table 1 assumes that the soil is well drained and that an LF of 15 to 20 percent is achieved. It is based on the formulas above and provides guide- lines for trees and vines. Table 2 provides the same type of guidelines for vegetable and row crops. These tables provide the salinity level in the irrigation water (ECw) that, if used continuously to achieve an LF of 15 to 20 percent, would result in yield potentials of 100, 90, 75, and 50 percent. The ECw values at 100% yield represent the poorest quality water that, if used continuously, will produce ECe levels equal to the salinity thresholds. For example, lettuce has the following salinity coefficients: a = 1.3 dS/m and b = 13 when expressed as ECe If the average rootzone ECe throughout the season was 3.2 dS/m, then the yield potential is 75 percent. If the average rootzone salinity value of 3.2 is then convert- ed to irrigation water salinity assuming an LF of 15 to 20 percent, ECw is 2.1 dS/m. The guidelines also assume that all other factors such as fertility, irrigation schedul- ing, and pest control are managed to optimize crop performance. It is important to note that most of the experiments that were used to generate these guidelines were conducted in the interior regions of California where the cli- mate is hot and dry during the summer. Crops grown in the coastal regions where the climate is milder will likely tolerate greater salinities than indicated above. Furthermore, much of the groundwater used for irrigation in coastal areas of California contains high levels of dissolved gypsum, which elevates the salinity of the water. However, crops irrigated with this water do not suffer the same detri- mental effects as Cl-dominated waters with an equal EC. In fields where salinity has increased in the rootzone to damaging levels, recla- mation leaching is recommended. A common rule of thumb is that the salinity in the top 1 foot of the rootzone can be reduced 80 to 90 percent by intermittently apply- ing 1 acre-foot of water per acre of land. ANR Publication 8066 Irrigation Water Salinity and Crop Reproduction Table 1. Estimated yield of tree and vine crops with long-term use of irrigation water with different levels of soil salinity (potential yields are based on a 15 to 20 percent leaching fraction and do not account for the effects of specific elements) ECw (mmhos/cm) Tree and vine crops Almond Apple } Apricot Avocado Blackberry Boysenberry Cherry Date Palm Fig3 , Grape Grapefruit Lemon Lime Olive Orange Peach Pear Pecan Persimmon Pistachio Plum Pomegranate Walnut3 100% 1.0 — 1.1 — 1.0 1.0 — 2.7 — 1.0 1.2 1.0 — — 1.1 1.1 — — — — 1.0 — Yield potential1 90% 75% 1.4 — 1.3 — 1.3 1.3 — 4.5 — 1.7 1.6 1.5 — — 1.6 1.5 — — — — 1.4 — — 1.9 — 1.8 — 1.5 1.8 — 7.3 — 2.7 2.2 2.3 — — 2.2 1.9 — — — — 1.9 — 50% 2.8 — 2.5 — 2.5 2.5 — 12.0 — 4.5 3.3 3.6 — — 3.2 2-7 — — — — 2.9 — ^^ Rating S s S ss s s T MT MS S S s MT S S s MS S MS-MT S MS S — Data not available. Based on data from Maas and Grattan 1999. Tolerance to soil salinity is rated as sensitive (S), moderately sensitive (MS), moderately tolerant (MT), and tolerant (T). Tolerance is based on growth or injury rather than yield. ANR Publication 8066 Irrigation Water Salinity and Crop Reproduction Table 2. Estimated yield of vegetable and row crops with long-term use of irrigation water of different qualities (potential yields are based on a 15 to 20 percent leaching fraction and do not account for the effects of specific elements) ECw (mmhos/cm) Vegetable and row crops Asparagus Bean Beet, red Broccoli Cabbage Carrot Cauliflower Celery Corn, sweet Cucumber Eggplant Lettuce Onion Pepper Potato Radish Spinach Squash, scallop Squash, zucchini Strawberry Sweet potato Tomato Turnip 100% 2.7 0.7 2.7 1.9 1.2 0.7 1.9 1.2 1.1 1.7 0.7 0.9 0.8 1.0 1.1 0.8 1.3 2.1 3.1 0.7 1.0 1.7 0.6 Yield potential 90% 75% 6.1 1.0 3.4 2.6 1.9 1.1 2.6 2.3 1.7 2.2 1.7 1.4 1.2 1.5 1.7 1.3 2.2 2.6 3.8 0.9 1.6 2.3 1.3 11.1 1.5 4.5 3.7 2.9 1.9 3.7 3.9 2.5 2.9 3.1 2.1 1.8 2.2 2.5 2.1 3.5 3.2 4.9 1.2 2.5 3.4 2.5 Rating 50% 19.4 2.4 6.4 5.5 4.6 3.0 5.5 6.6 3.9 4.2 5.6 3.4 2.9 3.4 3.9 3.4 5.7 4.2 6.7 1.7 4.0 5.0 4.3 Salt T S MT MS M S MS MS MS MS MS MS S MS MS MS MS MS MT S MS MS MS Boron VT S T MS MT MS MT VT VT MS — MS S MS MS — — MT MT S — T MT — Data not available. Based on data from Maas and Grattan 1999. Sensitive (S), moderately sensitive (MS), moderately tolerant (MT), tolerant (T), and very tolerant (VT). ANR Publication 8066 Irrigation Water Salinity and Crop Reproduction CROP TOXICITY TO SPECIFIC ELEMENTS In addition to salinity, some crops are injured by certain elements, notably sodium (Na+), chloride (Cl~), and boron (B). With drip and furrow irrigation, chloride and sodium injury do not generally occur in vegetable and row crops unless salinity in irrigation water is severe. Leaf injury can occur in strawberries, however, particular- ly under hot, dry conditions. Under sprinkler irrigation, injury may occur to wetted leaves of susceptible plants such as pepper, potatoes, and tomato if the ECw exceeds 1.5 mmhos/cm. Some vegetable and row crops are sensitive to boron. Generally, leaf injury must be severe to cause reduced yields and crop quality. Long-term use of irrigation water containing more than 0.5 ppm boron can reduce the yields of bean, onion, garlic, and strawberry; 0.7 ppm can reduce the yields of broccoli, carrot, potato, and let- tuce; and concentrations greater than 2 ppm can reduce yields of cabbage and cau- liflower. Under cool, moist climatic conditions, greater levels of boron can be tolerated, and for short-term use, boron levels given here can be doubled. In addition, soil properties influence the time it takes for injury to occur. The finer the soil texture, the longer it will take for injury to occur. Unlike most annual crops, tree and vine crops are generally sensitive to boron, chloride, and sodium toxicity. Tolerances vary among varieties and rootstocks. Tolerant varieties and rootstocks resist the uptake and accumulation of toxic ions in the stem and leaf tissue. Continued use of irrigation water with boron concentra- tions in excess of 0.75 ppm can reduce the yields of grapes and many deciduous tree and fruit crops. This represents a threshold concentration and does not imply that irrigation water with boron at or slightly above this level cannot be used successfully. Chloride moves readily with the soil water and is taken up by the roots. It is then transported to the stems and leaves. Sensitive berries and avocado rootstocks can toler- ate only up to 120 ppm of chloride, while grapes can tolerate up to 700 ppm or more. The ability of a tree to tolerate sodium varies considerably. Sodium injury on avocado, citrus, and stone-fruit trees has been reported at concentrations as low as 115 ppm. Initially, sodium is retained in the roots and lower trunk, but after 3 to 4 years the conversion of sapwood to heartwood apparently releases the accumulated sodium, which then moves to the leaves causing leaf burn. INFILTRATION OF IRRIGATION WATER There are two water quality parameters to consider when assessing irrigation water quality for potential water infiltration problems. These are the ECw and the sodium adsorption ratio (SAR). The SAR is an indicator of the amount of sodium in the water relative to calcium and magnesium. The higher the ratio of sodium to calcium plus magnesium, the higher the SAR. Both a low salt content (low ECw) and high SAR can mean there is a high potential for permeability or water infiltration problems. A low ECw or high SAR can act separately or collectively to disperse soil aggre- gates, which in turn reduces the number of large pores in the soil. These large pores are responsible for aeration and drainage. A negative effect from the breakdown of soil aggregates is soil sealing and crust formation. Below is a table that can be used to assess the likelihood of potential water infiltration problems based on both ECw and SAR. ANR Publication 8066 Irrigation Water Salinity and Crop Reproduction Table 3 indicates that water infiltration problems are likely if the ECw is less than 0.3 mmho/cm regardless of the SAR. For example, if the ECw falls below 0.3 mmho/cm, infiltration rates can drop to less than 0.1 inch per hour. An infiltration rate of 0.1 inch per hour would require 30 hours for a full irrigation of 3 inches to infiltrate the soil. Therefore, pure water or very high-quality water such as that in the Friant-Kern Canal (ECw 0.05 and SAR 0.6) will cause infiltration problems even when applied on soils with high sand content. The good news is that infiltration problems due to low salt content or high SAR can easily be improved by the addition of gypsum to either the irrigation water or soil. When the irrigation water comes into contact with gypsum, it dissolves into Ca2+ and SO4 2" ions that slightly increase the salinity of the water while simultane- ously reducing the SAR. The Ca2+ cations are then free to displace Na+ cations adsorbed onto the negatively charged clay particles, thereby enhancing flocculation, improving soil structure, and increasing the water infiltration rate. Estimating the amount of gypsum to be applied to the irrigation water can be achieved by calculating how much CaSO4 is needed to increase the EC or decrease the SAR. For example, Friant-Kern Canal water has an average ECw of only 0.05 mmho/cm and SAR of 0.6. By adding 6 meq/L Ca2+ (equivalent to 1,400 Ib pure gyp- sum per acre-ft), the ECw will increase to 0.65 and SAR will drop to 0.2. According to table 3, this will substantially improve the quality of this water in terms of reduc- ing its permeability hazard. Determining how much gypsum to add to the soil is a bit more complicated than determining how much to add to the irrigation water. The amount to apply depends on the soil, how much sodium is adsorbed onto the clay surfaces, how much Ca2+ is needed to replace the adsorbed Na+, and to what depth you intend to reclaim the soil. Usually, no more than 1 to 2 tons of gypsum per acre should be applied at any one time. Lighter, more frequent applications of gypsum tend to be more effective than a single heavy application. Table 3. Combined effect of electrical conductivity (ECw) of irrigation water and sodium adsorption ratio (SAR) on the likelihood of water infiltration (permeability) problems , .. . . ^ ^. Water infiltration problemSodium adsorbtion ration 1 (SAR) of irrigation or soil Unlikely when ECw (dS/m) is more than Likely when ECw (dS/m) is less than 0-3 0.6 0.3 3-6 1.0 0.4 6-12 2.0 0.5 12-20 3.0 1.0 20-40 5.0 2.0 Source: Ayers and Westcot 1985. ANR Publication 8066 Irrigation Water Salinity and Crop Reproduction 8 OTHER WATER QUALITY CONSTITUENTS Irrigation water supplies, particularly those from wells, can contain other constituents that may affect water quality. Of particular concern are nitrate (NO3~) and bicarbonate (HCCV). Nitrates are often measured as NO3-N, which refers to the nitrogen concentration in the water that is in the nitrate form. From a public health perspective, there are con- cerns when excessive levels of nitrates are found in domestic wells. The public drinking water standard is set at 10 mg/L (or ppm) NO3-N. From an irrigation perspective, NO3~ in the groundwater can be viewed as a resource. For example, 27 pounds of nitrogen is applied to a field with each acre-foot of water if the water supply contains 10 ppm NO3- N (45 ppm when expressed as NO3"). It is important that the grower with water of such quality reduces the nitrogen application rates in the field accordingly to accommodate this extra input of nitrogen. Should this be ignored, there may be problems associated with excessive vegetative growth and contamination of the groundwater. Excessive amounts of bicarbonate can also be problematic. In fields that are irri- gated with low-pressure systems, such as drip or mini-sprinklers, calcite or scale can build up near the orifice of the sprinkler or emitter, which can reduce the water dis- charge. This type of problem can be corrected by injecting acid-forming materials (such as sulfuric acid) in the irrigation water. In addition, bicarbonate could increase the SAR of the soil water by precipitating calcium and magnesium. This can be cor- rected by frequent gypsum applications to the soil surface. REFERENCES Ayers, R. S., and D. W. Westcot. 1985. Water quality for agriculture. Food and Agricultural Organization (FAO) of the United Nations. FAO Irrigation and Drainage Paper 29. Maas, E. V, and S. R. Grattan. 1999. Crop yields as affected by salinity. In R. W. Skaggs and J. van Schilfgaarde, eds., Agricultural Drainage. Agron. Monograph 38. ASA, CSSA, SSSA, Madison, WI. Hanson, B., S. R. Grattan, and A. Fulton. 1999. Agricultural salinity and drainage. Oakland: University of California Division of Agriculture and Natural Resources Publication 3375. ANR Publication 8066 Irrigation Water Salinity and Crop Reproduction FOR MORE INFORMATION You'll find detailed information on many aspects of turfgrass management in these titles and in other UC ANR products: Agricultural Salinity and Drainage, Publication 3375 Irrigation and Drainage, Slide Set 93/105 Drip Irrigation for Row Crops, Publication 3376 To order these products, visit our online catalog at http://anrcatalog.ucdavis.edu You can also place orders by mail, phone, or fax, or request a printed catalog of publications, slide sets, and videos from University of California Agriculture and Natural Resources Communication Services 6701 San Pablo Avenue, 2nd Floor Oakland, CA 94608-1239 Telephone: (800) 994-8849 or (510) 642-2431 FAX: (510) 643-5470 E-mail inquiries: danrcs@ucdavis.edu vcmPKRVM REVIEWED An electronic version of this publication is available on the ANR Communication Services website at http://anrcatalog.ucdavis.edu Publication 8066 ©2002 by the Regents of the University of California, Division of Agriculture and Natural Resources. All rights reserved. The University of California prohibits discrimination against or harassment of any person employed by or seeking employment with the University on the basis of race, color, national origin, religion, sex, physical or mental disability, medical condition (cancer-related or genetic characteristics), ancestry, marital status, age, sexual orientation, citizenship, or status as a covered veteran (special disabled veteran, Vietnam-era veteran or any other veteran who served on active duty during a war or in a campaign or expedition for which a campaign badge has been authorized). University Policy is intended to be consistent with the pro- visions of applicable State and Federal laws. Inquiries regarding the University's nondiscrimination policies may be directed to the Affirmative Action/Staff Personnel Services Director, University of California, Agriculture and Natural Resources, 300 Lakeside Drive, 6th floor, Oakland, CA 94612-3550; (510) 987-0096. For a free catalog of other publications, telephone (800) 994-8849. For help downloading this publication, call (530) 754-5112. pr-06/02-GM/VFG This publication has been anonymously peer reviewed for technical accuracy by University of California scien- tists and other qualified professionals. This review process was managed by the ANR Associate Editor for Natural Resources. Exhibit 5 N-Nitrosodimethylamine (CICADS 38, 2002) Page 1 of 70 Howe 7V-NITROSODIMETHYLAMINE This report contains the collective views of an international group of experts and does not necessarily represent the decisions or the stated policy of the United Nations Environment Programme, the International Labour Organization, or the World Health Organization. Concise International Chemical Assessment Document 38 First draft prepared by R.G. Liteplo and M.E. Meek, Health Canada, Ottawa, Canada, and W. Windle, Environment Canada, Ottawa, Canada Published under the joint sponsorship of the United Nations Environment Programme, the International Labour Organization, and the World Health Organization, and produced within the framework of the Inter-Organization Programme for the Sound Management of Chemicals. World Health Organization Geneva, 2002 The International Programme on Chemical Safety (IPCS), established in 1980, is a joint venture of the United Nations Environment Programme (UNEP), the International Labour Organization (ILO), and the World Health Organization (WHO). The overall objectives of the IPCS are to establish the scientific basis for assessment of the risk to human health and the environment from exposure to chemicals, through international peer review processes, as a prerequisite for the promotion of chemical safety, and to provide technical assistance in strengthening national capacities for the sound management of chemicals. The Inter-Organization Programme for the Sound Management of Chemicals (IOMC) was established in 1995 by UNEP, ILO, the Food and Agriculture Organization of the United Nations, WHO, the United Nations Industrial Development Organization, the United Nations Institute for Training and Research, and the Organisation for Economic Co-operation and Development (Participating Organizations), following recommendations made by the 1992 UN Conference on Environment and Development to strengthen cooperation and increase coordination in the field of chemical safety. The purpose of the IOMC is to promote coordination of the policies and activities pursued by the Participating Organizations, jointly or separately, to achieve the sound management of chemicals in relation to human health and the environment. WHO Library Cataloguing-in-Publication Data N-Nitrosodimethylamine. (Concise international chemical assessment document; 38) 1 .Dimethylnitrosamine - toxicity 2.Risk assessment 3.Environmental exposure http://www.inchem.org/documents/cicads/cicads/cicad3 8 .htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 2 of 70 4.Occupational exposure I.International Programme on Chemical Safety II.Series ISBN 92 4 153038 3 (NLM Classification: QZ 202) ISSN 1020-616 The World Health Organization welcomes requests for permission to reproduce or translate its publications, in part or in full. Applications and enquiries should be addressed to the Office of Publications, World Health Organization, Geneva, Switzerland, which will be glad to provide the latest information on any changes made to the text, plans for new editions, and reprints and translations already available. ©World Health Organization 2002 Publications of the World Health Organization enjoy copyright protection in accordance with the provisions of Protocol 2 of the Universal Copyright Convention. All rights reserved. The designations employed and the presentation of the material in this publication do not imply the expression of any opinion whatsoever on the part of the Secretariat of the World Health Organization concerning the legal status of any country, territory, city, or area or of its authorities, or concerning the delimitation of its frontiers or boundaries. The mention of specific companies or of certain manufacturers' products does not imply that they are endorsed or recommended by the World Health Organization in preference to others of a similar nature that are not mentioned. Errors and omissions excepted, the names of proprietary products are distinguished by initial capital letters. The Federal Ministry for the Environment, Nature Conservation and Nuclear Safety, Germany, provided financial support for the printing of this publication. Printed by Wissenschaftliche Verlagsgesellschaft mbH, D-70009 Stuttgart 10 TABLE OF CONTENTS FOREWORD 1. EXECUTIVE SUMMARY 2. IDENTITY AND PHYSICAL/CHEMICAL PROPERTIES 3. ANALYTICAL METHODS 4. SOURCES OF..HUMAN..AND ENVIRONMENTAL EXPOSURE 4.1 Natural sources 4.2 Anthropogenic sources http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 3 of 70 .,3 Productipn and use 5. ENVIRONMENTAL TRANSPORT. DISTRIBUTION. AND TRANSFQRMATIQN 5.1 Air 5.2 Water 5,3Sediment 5.4 Soil 5.5Biota 5.6 Environmental partitioning 6. ENVIRONMENTAL LEVELS AND HUMAN EXPOSURE 6.1 Environmental levels 6.1.1 Ambient air 6.1.2 Indoor air 6.1.3 Water 4LL4_SedjrQent_and_soil 6.1.5 Human tissues 6.1.6 Food 6.1.7 Consumer products 6.2 Human exposure: environmental 6.3 Human exposure: occupational 7. COMPARATIVE KINETICS AND METABOLISM IN LABORATORY ANIMALS AND HUMANS 8. EFFECTS ON LABORATORY MAMMALS AND IN VITRO TEST SYSTEMS 8.1Single exposure 8.2 Irritation and sensitization 8.3 Short- and medium-term exposure 8.4 Carcinogem'city 8.5 Genotoxicity and related end-points 8.6 Reproductive toxicity http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 4 of 70 8 J_NeurQtQxicity _ajad 8. 8 Mode of action 9. ..... EFFECTS ON HUMANS 10. EFFECTS ON OTHER ORGANISMS IN THE LABORATORY AND FIELD 10 J Aquatic .enyuronnient 1 1 . EFFECTS EVALUATION 11.1 Evaluation of health effects 11.1.1 Hazard identification 11.1.1.1 Carcinogenicity 11.1.1.2 Non-neoplastic effects 1 1 . 1 .2 Dose-response analyses IL L2 • 1 Carcinogenicity 1 1.1.2.2 Non-neoplastic effects 1 1.1.3 Sample risk characterization 1 1.1.4 Uncertainties and degree of confidence in human health risk characterization 11.2 Evaluation of environmental effects 11.2.1 Terrestrial assessment end-points 1 1 .2.2 Aquatic assessment end-points 11.2.3 Sample environmental risk characterization 1 1.2.3.1 Aquatic organisms 1 1 .2.4 Discussion of uncertainty 12. PREVIOUS EVALUATIONS BY INTERNATIONAL BODIES REFERENCES APPENDIX 2 — CICAD PEER REVIEW APPENDIX 3 — CICAD FINAL REVIEW BOARD APPENDIX 4 — CALCULATION OF TUMQRIGENIC http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 5 of 70 DQSE05 MTERNATIQNAL CHEMICAL SAFETY CARD RESUME D'ORIENTATION RESUMEN DE ORIENTACION FOREWORD Concise International Chemical Assessment Documents (CICADs) are the latest in a family of publications from the International Programme on Chemical Safety (IPCS) — a cooperative programme of the World Health Organization (WHO), the International Labour Organization (ILO), and the United Nations Environment Programme (UNEP). CICADs join the Environmental Health Criteria documents (EHCs) as authoritative documents on the risk assessment of chemicals. International Chemical Safety Cards on the relevant chemical(s) are attached at the end of the CICAD, to provide the reader with concise information on the protection of human health and on emergency action. They are produced in a separate peer-reviewed procedure at IPCS. They may be complemented by information from IPCS Poison Information Monographs (PIM), similarly produced separately from the CICAD process. CICADs are concise documents that provide summaries of the relevant scientific information concerning the potential effects of chemicals upon human health and/or the environment. They are based on selected national or regional evaluation documents or on existing EHCs. Before acceptance for publication as CICADs by IPCS, these documents undergo extensive peer review by internationally selected experts to ensure their complete ness, accuracy in the way in which the original data are represented, and the validity of the conclusions drawn. The primary objective of CICADs is characterization of hazard and dose-response from exposure to a chemical. CICADs are not a summary of all available data on a particular chemical; rather, they include only that information considered critical for characterization of the risk posed by the chemical. The critical studies are, however, presented in sufficient detail to support the conclusions drawn. For additional information, the reader should consult the identified source documents upon which the CICAD has been based. Risks to human health and the environment will vary considerably depending upon the type and extent of exposure. Responsible authorities are strongly encouraged to characterize risk on the basis of locally measured or predicted exposure scenarios. To assist the reader, examples of exposure estimation and risk characterization are provided in CICADs, whenever possible. These examples cannot be considered as representing all possible exposure situations, but are provided as guidance only. The reader is referred to EHC 170- for advice on the derivation of health-based guidance values. While every effort is made to ensure that CICADs represent the current status of knowledge, new information is being developed constantly. Unless otherwise stated, CICADs are based on a search of the scientific literature to the date shown in the executive summary. In the event that a reader becomes aware of new information that would change the conclusions drawn in a CICAD, the reader is requested http://www.inchem.org/documents/cicads/cicads/cicad3 8 .htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 6 of 70 to contact IPCS to inform it of the new information. Procedures The flow chart shows the procedures followed to produce a CICAD. These procedures are designed to take advantage of the expertise that exists around the world — expertise that is required to produce the high-quality evaluations of lexicological, exposure, and other data that are necessary for assessing risks to human health and/or the environment. The IPCS Risk Assessment Steering Group advises the Co- ordinator, IPCS, on the selection of chemicals for an IPCS risk assessment, the appropriate form of the document (i.e., EHC or CICAD), and which institution bears the responsibility of the document production, as well as on the type and extent of the international peer review. http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002)Page 7 of70 CICAD PREPARATION FLOW CHART SELECTION OF PRIORITY CHEMICAL SELECTION OF HIGH QUALITY HATIONAL/REGIONAL ASSESSMENT DOCUMENT(S) FIRST DRAFT PREPARED PRIMARY REVIEW BY ICPS 1 r REVIEW BY IPCS CONTACT POINTS/ SPECIALIZED EXPERTS REVIEW OF COMMENTS PREPARATION OF SECOND DRAFT 1 FINAL REVIEW BOARD ' FINAL DRAFT APPROVAL BY DIRECTOR,IPCS PUBLICATION 1 Taking into account the comments From reviewers. 2 Th« second draft of documents is submitted to the Final Review Board together with the reviewer;' comments. 3 Includes any revisions requested by the Final Review Board. The first draft is based on an existing national, regional, or international review. Authors of the first draft are usually, but not necessarily, from the institution that developed the original review. A standard outline has been developed to encourage consistency in form. The first draft undergoes primary review by IPCS and one or more experienced authors of criteria documents to ensure that it meets the specified criteria for CICADs. The draft is then sent to an international peer review by scientists known for their particular expertise and by scientists selected from an international roster compiled by IPCS through recommendations from IPCS national Contact Points and from IPCS Participating Institutions. Adequate time is allowed for the selected experts to undertake a thorough review. Authors are required to take reviewers' comments into http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 8 of 70 account and revise their draft, if necessary. The resulting second draft is submitted to a Final Review Board together with the reviewers' comments. A consultative group may be necessary to advise on specific issues in the risk assessment document. The CICAD Final Review Board has several important functions: • to ensure that each CICAD has been subjected to an appropriate and thorough peer review; • to verify that the peer reviewers' comments have been addressed appropriately; • to provide guidance to those responsible for the preparation of CICADs on how to resolve any remaining issues if, in the opinion of the Board, the author has not adequately addressed all comments of the reviewers; and • to approve CICADs as international assessments. Board members serve in their personal capacity, not as representatives of any organization, government, or industry. They are selected because of their expertise in human and environmental toxicology or because of their experience in the regulation of chemicals. Boards are chosen according to the range of expertise required for a meeting and the need for balanced geographic representation. Board members, authors, reviewers, consultants, and advisers who participate in the preparation of a CICAD are required to declare any real or potential conflict of interest in relation to the subjects under discussion at any stage of the process. Representatives of nongovernmental organizations may be invited to observe the proceedings of the Final Review Board. Observers may participate in Board discussions only at the invitation of the Chairperson, and they may not participate in the final decision-making process. 1. EXECUTIVE SUMMARY This CICAD on N-nitrosodimethylamine (NDMA) was prepared jointly by the Environmental Health Directorate of Health Canada and the Commercial Chemicals Evaluation Branch of Environment Canada based on documentation prepared concurrently as part of the Priority Substances Program under the Canadian Environmental Protection Act (CEPA). The objective of assessments on Priority Substances under CEPA is to assess potential effects of indirect exposure in the general environment on human health as well as environmental effects. Although occupational exposure was not addressed in the source document (Environment Canada & Health Canada, 2001), information on this aspect has been included in this CICAD. Data identified as of the end of August 1998 (environmental effects) and August 1999- (human health effects) were considered in this review. Other reviews that were also consulted include IARC (1978), ATSDR (1989), OME (1991, 1998), and BIBRA Toxicology International (1997, 1998). Information on the nature of the peer review and availability of the source document is presented in Appendix 1. Information on the peer review of this CICAD is presented in Appendix 2. This CICAD was approved as an international assessment at a meeting of the Final Review Board, held in Geneva, Switzerland, on 8-12 January 2001. Participants at the Final Review Board meeting are listed in Appendix 3. The International Chemical Safety Card for NDMA (ICSC 0525), produced by the International Programme on Chemical Safety (IPCS, 1993), has also been reproduced in this document. W-Nitrosodimethylamine (NDMA) is the simplest dialkylnitrosamine. It is no longer used industrially or commercially in Canada or the USA but continues to be released as a by-product and contaminant from http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 9 of 70 various industries and from municipal wastewater treatment plants. Major releases of NDMA have been from the manufacture of pesticides, rubber tires, alkylamines, and dyes. NDMA may also form under natural conditions in air, water, and soil as a result of chemical, photochemical, and biological processes and has been detected in drinking-water and in automobile exhaust. Photolysis is the major pathway for the removal of NDMA from surface water, air, and land. However, in surface waters with high concentrations of organic substances and suspended matter, photodegradation is much slower. In subsurface water and in soil, biodegradation is the removal pathway of importance. NDMA is unlikely to be transported over long distances in air or to partition to soil and sediments. Because of its solubility and low partition coefficient, NDMA has the potential to leach into and persist in groundwater. It is metabolized and does not bioaccumulate. NDMA is generally not detectable in surface waters, except for localized contamination from industrial sites, where end-of- pipe effluent concentrations as high as 0.266 ug/litre have been measured. In limited surveys in the country on which the sample risk characterization is based (i.e., Canada), NDMA has not been detected in ambient air, except in the vicinity of industrial sites. Low concentrations of NDMA — formed in water treatment plants or from groundwater contaminated by industrial effluents, for example — have been measured in drinking-water. The presence of NDMA has been demonstrated in some foods, most frequently in beer, cured meat, fish products, and some cheeses, although levels of NDMA have decreased in these products in recent years owing to changes in food processing. Exposure can also result from the use of consumer products that contain NDMA, such as cosmetics and personal care products, products containing rubber, and tobacco products. Based upon laboratory studies in which tumours have been induced in all species examined at relatively low doses, NDMA is clearly carcinogenic. There is overwhelming evidence that NDMA is mutagenic and clastogenic. While the mechanism by which NDMA induces tumours is not fully elucidated, DNA adducts (in particular, O -methylguanine) formed by the methyldiazonium ion generated during metabolism likely play a critical role. Qualitatively, the metabolism of NDMA appears to be similar in humans and animals; as a result, it is considered highly likely that NDMA is carcinogenic to humans, potentially at relatively low levels of exposure. Data on non-neoplastic effects in laboratory animals associated with exposure to NDMA are limited, attributable primarily to the focus on its carcinogenicity. Effects on the liver and kidney in repeated-dose toxicity studies, embryo toxicity and embryo lethality in single- dose developmental studies, and a range of immunological effects (suppression of humoral- and cell-mediated immunity) reversible at lowest concentrations have been reported. Cancer is clearly the critical end-point for quantitation of exposure-response for risk characterization of NDMA. In addition to it being best characterized, in general, tumours occur at lowest concentration, compared with those typically reported to induce non-cancer effects. The lowest tumorigenic doseQ5 for the development of hepatic tumours in male and female rats exposed to NDMA in the critical study was 34 M-g/kg body weight per day for the development of biliary cystadenomas in female animals. This equates to a unit risk of 1.5 x 10~3 per ug/kg body weight. Based on estimated intakes of NDMA in ambient air and contaminated drinking-water (groundwater) in the sample risk characterization, risks in the vicinity of industrial point sources are >10~5. Those for ambient drinking-water are between 10~7 and 10~5. NDMA is a genotoxic carcinogen, and exposure should be reduced to the extent possible. Acute and chronic toxicity data are available for aquatic organisms. The toxic effect that occurred at lowest concentration was a reduction in the growth of algae at 4000 jig/litre. In the sample risk http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002)Page 10 of 70 characterization, concentrations of NDMA in surface waters in the source country are less than the threshold for adverse effects estimated for aquatic organisms. Data on concentrations of NDMA in sediments or in soil in the sample country were not identified. 2. IDENTITY AND PHYSICAL/CHEMICAL PROPERTIES N-Nitrosodimethylamine, or NDMA, is the simplest dialkylnirrosamine, with a molecular formula of C2H6N2O and a relative molecular mass of 74.08 (ATSDR, 1989) (Figure 1). NDMA belongs to a class of chemicals known as ./V-nitroso compounds, characterized by the 7V-nitroso functional group (-N— N=O), and to the family of nitrosamines, which, in addition, possess an amine function (-NR2, where R is H or an alkyl group). NDMA is also known as dimethylnitrosamine, dimethymitrosoamine, NJf- dimethylnitrosamine, N-methyl-Af-nitrosomethanamine, A'-nitroso-jVrAr-dimethylamine, DMN, and DMNA. NDMA has the Chemical Abstracts Service (CAS) registry number 62-75-9. H3C H3C N—N=0 Figure 1: Chemical structure of NDMA. NDMA is a volatile, combustible, yellow, oily liquid. It is susceptible to photolytic breakdown due to its absorption of ultraviolet light (Sax & Lewis, 1987). The physical/chemical properties relevant to the environmental fate of NDMA and utilized in the modelling of environmental partitioning (section 5.6) are presented in Table 1. Additional properties are presented in the International Chemical Safety Card reproduced in this document. Table 1: Physical and chemical properties of NDMA. Physical/chemical property Melting point (°C) Boiling point (°C) L°g*ow Vapour pressure Henry's law constant Solubility Value3 50 151-154 0.57 1080 Pa (25 °C) 3.34Pam3/mol(25°C) miscible http://www.inchem.org/documents/cicads/cicads/cicad3 8 .htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 11 of 70 Includes experimental and calculated values listed in Callahan et al. (1979); Clayton & Clayton (1981); ATSDR (1989); Budavari et al. (1989); OME (1991); DMER & AEL (1996). The conversion factor for NDMA in air is 1 ppm = 3.08 mg/m~ 3. ANALYTICAL METHODS Analytical methods for NDMA consist of concentration followed by chromatographic separation of the components in the extract and detection of the JV-nitrosamine. Concentration steps include liquid-liquid extraction and solid-phase extraction. Chromatographic separations have been achieved almost exclusively by gas chromatography. Detection of NDMA has been accomplished by flame ionization detectors (Nikaido et al., 1977), nitrogen-phosphorus detectors (US EPA, 1984), the Hall electrolytic conductivity detector operated in the reductive mode (von Rappard et al., 1976; US EPA, 1984), the thermal energy analyser or chemiluminescent nitrogen detector (Fine et al., 1975; Fine & Rounbehler, 1976; Webb et al., 1979; Kimoto et al., 1981; Parees & Prescott, 1981; Sen & Seaman, 1981a; Sen et al., 1994; Tomkins et al., 1995; Tomkins & Griest, 1996), and mass spectrometry. NDMA is also analysed by electron ionization low-resolution mass spectrometry (Sen et al., 1994), high-resolution mass spectrometry (Taguchi et al., 1994; Jenkins et al., 1995), chemical ionization tandem mass spectrometry on an ion trap mass spectrometer (Plomley et al., 1994), and laser ionization time-of-flight mass spectrometry (Opsal & Reilly, 1986). Liquid chromatography has also been used in conjunction with a photolysis reactor and (electrospray ionization) mass spectrometry (Volmer et al., 1996). Detection limits range from 0.150 ug/litre using nitrogen-phosphorus detectors (US EPA, 1984) to 0.002 ug/litre using a gas chromatograph-thermal energy analyser (Kimoto et al., 1981; Tomkins et al., 1995; Tomkins & Griest, 1996) to 0.001 ug/litre using gas chromatography-high-resolution mass spectrometry (Taguchi et al., 1994; Jenkins et al., 1995). Comparable detection limits are possible with chemical ionization tandem mass spectrometry on an ion trap mass spectrometer (Plomley et al., 1994). 4. SOURCES OF HUMAN AND ENVIRONMENTAL EXPOSURE Data on sources and emissions from the source country of the national assessment on which the CICAD is based (i.e., Canada) are presented here as an example. Sources and patterns of emissions in other countries are expected to be similar, although quantitative values may vary. 4.1 Natural sources NDMA can be formed as a result of biological, chemical, or photochemical processes (Ayanaba & Alexander, 1974). It may be present in water, air, and soil due to chemical reaction between ubiquitous, naturally occurring precursors classified as nitrosatable substrates (secondary amines) or nitrosating agents (nitrites) (OME, 1998). For example, NDMA may form in air during nighttime as a result of the atmospheric reaction of dimethylamine (DMA) with nitrogen oxides (Cohen & Bachman, 1978). Soil http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 12 of 70 bacteria may also synthesize NDMA from various precursor substances, such as nitrate, nitrite, and amine compounds (ATSDR, 1989). NDMA precursors are widespread throughout the environment, occurring in plants, fish, algae, urine, and faeces (Ayanaba & Alexander, 1974). 4.2 Anthropogenic sources NDMA is produced as a by-product of industrial processes that use nitrate and/or nitrites and amines under a range of pH conditions. This is due to inadvertent formation when alkylamines, mainly DMA and trimethylamine, come into contact and react with nitrogen oxides, nitrous acid, or nitrite salts or when trans-nitrosation via nitro or nitroso compounds occurs (ATSDR, 1989). Therefore, NDMA may be present in discharges of such industries as rubber manufacturing, leather tanning, pesticide manufacturing, food processing, foundries, and dye manufacturing and, as a result, in sewage treatment plant effluent. Almost all of the releases in the source country (i.e., Canada) are to water. NDMA has also been detected in emissions from diesel vehicle exhaust (Goff et al., 1980). NDMA may form directly in sewage as a result of the biological and chemical transformation of alkylamines in the presence of nitrate or nitrite (Ayanaba & Alexander, 1974; ATSDR, 1989). It may also be released into the environment as the result of application of sewage sludge to soils rich in nitrate or nitrite. NDMA may also be formed during the treatment of drinking-water (OME, 1994). NDMA's precursor, DMA, together with nitrite, may enter surface water streams from agricultural runoff (V. Y. Taguchi, personal communication, 1998). Water treatment plants incorporating a chlorination process (e.g., sodium hypochlorite) will produce NDMA from these precursors (Jobb et al., 1993; Graham et al., 1996). Ultraviolet treatment can decompose NDMA to DMA (Jobb et al., 1994). How ever, it is also possible to generate/regenerate NDMA from the DMA within distribution systems that have post- chlorination (V.Y. Taguchi, personal communication, 1998). NDMA may be released into the environment as a result of use of certain pesticides contaminated with this compound (Pancholy, 1978). NDMA is present in various technical and commercial pesticides used in agriculture, hospitals, and homes as the result of its formation during the manufacturing process and during storage. The following DMA formulation pesticides may contain NDMA as a microcontaminant: bromacil, benazolin, 2,4-D, dicamba, MCPA, and mecoprop (J. Ballantine, personal communication, 1997; J. Smith, personal communication, 1999). Since 1990, in testing in Canada of over 100 samples of formulated pesticidal products (DMA salt of phenoxy acid herbicides) potentially contaminated by NDMA, the compound was detected in 49% of the samples, with an average concentration of 0.44 |J.g/g. Only six samples contained concentrations abovel.O |ig/g, with a range from 1.02 to 2.32 ug/g. Concentrations in pesticides have decreased over time. In 1994, approximately 1 million kilograms of DMA-formulated phenoxy acid herbicides for commercial use were applied to the terrestrial environment in Canada (G. Moore, personal communication, 1999). Based on the average concentration of NDMA mentioned above and per cent estimate of detection, it was calculated that approximately 200 g of NDMA may have been released into the environment through the use of these herbicides. 4.3 Production and use There are no industrial or commercial uses of NDMA in Canada or the USA. NDMA was used in Canada in the past and may still be used in other countries in rubber formulations as a fire retardant and http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 13 of 70 in the organic chemical industry as an intermediate, catalyst, antioxidant, additive for lubricants, and softener of copolymers (ATSDR, 1989; Budavari et al., 1989). 5. ENVIRONMENTAL TRANSPORT, DISTRIBUTION, AND TRANSFORMATION 5.1 Air NDMA has a low vapour pressure (1080 Pa at 25 °C), and, if emitted to or formed in air, it is not likely to adsorb to airborne particulate matter and is expected to exist almost entirely in the vapour phase. In daylight, it degrades rapidly by direct photolysis to form dimethylnitramine. The photolytic half-life of NDMA vapour exposed to sunlight ranges between 0.5 and 1.0 h (Hanst et al., 1977). Half-lives for the reaction with hydroxyl radicals range from 25.4 to 254 h in air (Atkinson, 1985). Modelling of environmental partitioning (section 5.6) is based on a half-life for NDMA in air of 5 h (DMER & AEL, 1996). The short half-lives for NDMA in air suggest that it is not persistent in this compartment. 5.2 Water Since NDMA is miscible in water and has a low vapour pressure and a low octanol/water partition coefficient (log KQVf of 0.57), it is not likely to bioaccumulate, adsorb to particulates, or volatilize to any significant extent (Thomas, 1982; ATSDR, 1989; OME, 1991). Oxidation, hydrolysis, biotransformation, and biodegradation are not significant factors affecting the fate of NDMA in lake water (Tate & Alexander, 1975). Photodegradation is the main process for removing NDMA from the aquatic environment. The efficiency of removal of NDMA depends on the characteristics of the particular water environment. Typically, photodegradation of NDMA is much slower in waters with high concentrations of organic substances and suspended solids than in clear water bodies. The rate of degradation through photolysis may be significantly decreased in the presence of interferences with light transmission, such as ice cover on receiving water bodies (Conestoga-Rovers & Associates, 1994; E. McBean, personal communication, 1999). This observation is supported in the groundwater compartment, where, in the absence of light, NDMA has the potential to persist (OME, 1991). Modelling of environmental partitioning (section 5.6) is based on a mean half-life of 17 h for NDMA in surface water at 25 °C (DMER & AEL, 1996). Howard et al. (1991) reported a half-life range for NDMA in groundwater of 1008-8640 h, based on estimated unacclimated aqueous aerobic biodegradation. 5.3 Sediment Modelling of environmental partitioning (section 5.6) is based on a mean half-life of 5500 h for NDMA in sediment at 25 °C (DMER & AEL, 1996). Factors that slow degradation include anoxic conditions and lack of illumination, the former by preventing the generation of oxidants and the latter by preventing photolysis and the generation of oxidants by photolytic processes. 5.4 Soil On soil surfaces, photolysis and volatilization rapidly remove NDMA. Oliver (1979) reported that 30- http://www.inchem.org/documents/cicads/cicads/cicad3 8 .htm 6/9/2006 N-Nitrosodimethylamine (CICADS 3 8, 2002) Page 14 of 70 80% of an unreported concentration of NDMA volatilized from the soil within the first few hours of application to the soil surface. Once incorporated into subsurface soil, however, NDMA will be highly mobile, with the potential to migrate into groundwater supplies. Subsurface biodegradation is slightly slower under anaerobic than under aerobic conditions (ATSDR, 1989). Soil type only slightly affects biodegradation of NDMA. Aeration of soil improved biodegradation compared with waterlogged soil. Pre-exposure of bacteria to NDMA increased biodegradation in soil (Mallik & Tesfai, 1981). Modelling of environmental partitioning (section 5.6) is based on a mean half-life of 1700 h for NDMA in soil at 25 °C (DMER & AEL, 1996). 5.5 Biota Although NDMA is not present in plants under natural conditions, it can be taken up from the growth medium. Lettuce and spinach plants absorb NDMA from sand, soil, and water after exposure for 2 days to concentrations ranging from 10 to 100 mg NDMA/kg wet weight, with 3.25% and 0.38% being taken up from the growth medium by lettuce and spinach plants, respectively (Dean-Raymond & Alexander, 1976). A bioconcentration factor of 0.2 has been estimated for NDMA (Bysshe, 1982). However, conventional estimates of bioconcentration factors (correlation with KQVf) are precluded, since, generally, biota can biotransform NDMA (OME, 1998). 5.6 Environmental partitioning Fugacity modelling provides an overview of key reaction, intercompartment, and advection (movement out of a system) pathways for NDMA and its overall distribution in the environment. A steady-state, non-equilibrium model (Level III fugacity model) was run using the methods developed by Mackay (1991) and Mackay & Paterson (1991). Values for physical/chemical properties utilized in the modelling are presented in Table 1; those for half-lives in various media are presented in sections 5.1-5.4 above. Modelling was based on an assumed default emission rate of 1000 kg/h into a region of 100 000 km2, which includes a surface water area (20 m deep) of 10 000 km2. The height of the atmosphere was assumed to be 1000 m. Sediments and soils were assumed to have an organic carbon content of 4% and 2% and a depth of 1 cm and 10 cm, respectively. The estimated per cent distribution predicted by this model is not affected by the assumed emission rate. Modelling predicts that when NDMA is continuously released into a medium, most of it will be present in that medium at steady state. For example, if NDMA is discharged into water, almost all of it will be present in the aqueous phase, with very small amounts in air and soil. Almost all of the NDMA is removed by reaction in water. Similarly, most NDMA released to air will exist in the atmosphere, with very small amounts in soil and water. Finally, when NDMA is discharged continuously to soil, almost all of the substance is transported to surface water, and about a third goes into the atmosphere. However, since NDMA is much more persistent in soil than in water or air at steady state, almost all of the NDMA is present in soil, with very little in surface water, and even less in the atmosphere (DMER & AEL, 1996). In summary, the Level III fugacity model predicts that if NDMA is emitted into water or air, it will be found in, and react in, the medium of discharge. Emission of NDMA into water or air will tend to result in localized contamination of short duration. If emitted to soil, NDMA moves to the water or air compartments, where it undergoes reaction, or it reacts slowly in the soil. Because rates of volatilization, adsorption, runoff, and reaction in soil are relatively slow compared with reaction in air and water, the http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 15 of 70 persistence of NDMA emitted to soil is longer, and there is potential for NDMA to move into the groundwater compartment (DMER & AEL, 1996). 6. ENVIRONMENTAL LEVELS AND HUMAN EXPOSURE Data primarily on concentrations in the environment from the source country of the national assessment on which the CICAD is based (i.e., Canada) are presented here as a basis for the sample risk characterization. Patterns of exposure in other countries are expected to be similar, although quantitative values may vary. 6.1 Environmental levels 6.1.1 Ambient air There is little information on the presence or concentrations of NDMA in ambient (i.e., outdoor) air in Canada or elsewhere. Limited Canadian data are restricted to the province of Ontario, where short-term measurements have been taken in the immediate vicinity of potential point sources of discharge to the atmosphere, for comparison with background measurements from other urban locations. No data on airborne concentrations at rural locations were identified. At industrial and urban locations in Ontario in 1990, based on seven samples taken in five cities, concentrations of NDMA were all below the detection limit (detection limits ranged from 0.0034 to 0.0046 ug/m3).3- In surveys during 1990 of ambient air in the vicinity of a chemical production facility in Elmira, Ontario, concentrations of NDMA in 41 samples ranged from not detected (detection limits ranged from 0.0029 to 0.0048 ug/m3) to 0.230 ug/m3; concentrations in 20 of the 41 samples were at or above the detection limit.3 The highest concentrations were measured within the perimeter of the production facility, while the maxi mum concentration measured beyond this perimeter was 0.079 ug/m . Concentrations of NDMA in samples taken in the vicinity of an industrial site in Kitchener, Ontario, were similar.^ 6.1.2 Indoor air Available data indicate that levels of NDMA were elevated in indoor air contaminated with environmental tobacco smoke (ETS) in the USA (Brunnemann & Hoffmann, 1978) and Austria (Stehlik et al., 1982; Klus et al., 1992). The maximum concentration of NDMA in ETS-contaminated indoor air was 0.24 ug/m , whereas NDMA was not detected (i.e., <0.003 ug/m ) when the indoor air of a residence of a non-smoker was sampled in the same manner (Brunnemann & Hoffmann, 1978). Concentrations of NDMA in ETS-contaminated indoor air in these countries were generally between 0.01 and 0.1 ug/m3 (Health Canada, 1999). 6.1.3 Water Releases of NDMA to water in Canada have been measured primarily in Ontario and vary considerably. As an example, in 1996, a chemical plant released wastewater containing NDMA into the St. Clair River http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 16 of 70 at a concentration of 0.266 ug/litre (Environment Canada, 1997). In April 1997, concentrations of NDMA at the point of release to surface water ranged from 0.096 to 0.224 ug/litre for this company. These concentrations are expected to decrease, as the company installed a wastewater treatment plant in!998. In a survey of sewage treatment plant effluent in Ontario in 1990, NDMA was detected in 27 of 39 samples, with the maximum concentration being 0.22 ug/litre (OME, 1991). In 390 samples of raw surface water from 101 water treatment plants sampled for NDMA in Ontario from 1990 to July 1998, concentrations were detectable (>0.001 ug/litre) in the raw water at 37 plants. The average concentration in raw water was 1.27 * 10~3 ug/litre. The highest concentration of NDMA in raw water was 0.008 ug/litre from two water treatment plants in 1996 (Ontario Ministry of Environment and Energy, unpublished data, 1996; P. Lachmaniuk, Ontario Ministry of the Environment, unpublished data, 1998). In 1990, concentrations of NDMA in 24 groundwater samples taken from various locations in Ontario were below detection limits (detection limits ranged from 0.001 to 0.010 ug/litre). Concentrations of NDMA in the municipal aquifer in Elmira ranged from 1.3 to 2.9 ug/litre, attributed to contamination from a nearby chemical facility (Kornelsen et al., 1989). The municipal wells using this aquifer were closed in 1989 (Ireland, 1989). In 1994 and 1995, concentrations of up to 0.005 ug NDMA/litre (detection limit 0.001 ug/litre) in raw surface water and groundwater supplies in rural areas in southern Ontario were reported (OME, 1991). In 313 samples of treated water analysed from 100 locations within Ontario between 1994 and 1996, NDMA was detected (i.e., at greater than 0.001 ug/litre) in at least one sample at 40 of these 100 sites. The censored mean concentration was 0.0027 ug/litre. The highest concentrations were measured in samples from drinking-water plants using a specific pre-blended polyamine/alum water treatment coagulant (Ontario Ministry of Environment and Energy, unpublished data, 1996). These included a concentration of 0.04 ug/litre at the water treatment plant in Huntsville, Ontario. NDMA was detected in all (i.e., at greater than 0.001 ug/litre) 20 samples collected from four water treatment plants using the specific coagulant. The mean concentration of NDMA in these 20 samples was 0.012 ug/litre, whereas the (censored) mean concentration in the remaining 293 samples for the locations where the specific coagulant was not used was 0.002 ug/litre. Treatment studies on groundwater at a chemical plant in southern Ontario indicated that activated sludge can accumulate NDMA, particularly when nitrification and denitrification are applied to increase the age of the sludge. Concentrations of NDMA sampled in activated sludge ranged from 5 to 10 mg/litre (J. Kochany, personal communication, 1999; E. McBean, personal communication, 1999). In the USA, NDMA has been reported to be a common constituent of sewage sludge. Concentrations ranged from 0.6 to 45 ug/g in the dried sludge from 14 of 15 cities (Mumma et al., 1984). 6.1.4 Sediment and soil No data on concentrations of NDMA in sediments or soils in Canada were identified. Levels of NDMA up to 15.1 ng/g have been measured in soils collected in the vicinity of industrial facilities in the USA (IARC, 1978). 6.1.5 Human tissues NDMA has been quantified in a variety of tissues and biological fluids. In a study conducted in Quebec, http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 17 of 70 Canada, Cooper et al. (1987) detected NDMA in the liver, kidneys, brain, and pancreas from four (non- occupationally exposed) individuals at postmortem; concentrations ranged from approximately 0.12 to 0.9 ng/g tissue. In studies conducted outside of Canada, reported levels of NDMA in the blood or plasma of non- occupationally exposed individuals have ranged from approximately 0.03 to 1.5 ng/ml (Fine et al., 1977; Lakritz et al., 1980; Yamamoto et al., 1980; Garland et al., 1982; Gough et al., 1983; Dunn et al., 1986). In other studies, concentrations of NDMA in breast milk ranged from 0.1 to 1.8 ng/g (Lakritz & Pensabene, 1984; Mizuishi et al., 1987; Uibu et al., 1996). NDMA has been detected in the urine of individuals having no clearly defined exposure to this nitrosamine; reported concentrations from studies conducted in Canada (Kakizoe et al., 1979) and elsewhere (Lakritz et al., 1982; Webb et al., 1983) have ranged from 0.02 to 0.2 ng/ml. 6.1.6 Food NDMA can be formed during food processing, preservation, and/or preparation from precursor compounds already present in, or added to, the specific food items. The foodstuffs that have been most commonly contaminated with NDMA can be classified into several broad groups: • foods preserved by the addition of nitrate and/or nitrite, such as cured meat products (in particular, bacon) and cheeses (since these methods of preservation introduce nitrosating species into the food); • foods preserved by smoking, such as fish and meat products (since oxides of nitrogen in the smoke act as nitrosating agents); • foods dried by combustion gases, such as malt, low-fat dried milk products, and spices (since combustion gases can contain oxides of nitrogen); • pickled and salt-preserved foods, particularly pickled vegetables (since microbial reduction of nitrate to nitrite occurs); and • foods grown or stored under humid conditions, leading to nitrosamine formation by contaminating bacteria. It should be noted, however, that most data on levels of NDMA in foodstuffs have been derived from studies conducted in the 1970s and 1980s and may not be reliable with respect to estimating current exposure to this substance, owing to the analytical methodology available at the time. Moreover, efforts have been made to reduce the potential for exposure to NDMA in foodstuffs in Canada and other countries through continued reduction of allowable nitrite levels during preservation, suspension of the use of nitrate for certain food groups, or increased use of nitrosation inhibitors, such as ascorbate or erythorbate (Cassens, 1997; Sen & Baddoo, 1997). For example, in Canada, in regulations amended in 1975, permissible levels of nitrite in cured meat products were lowered and the use of nitrate was eliminated, except for a few classes of products (including "slow-cured" meats) (G. Lawrence, personal communication, 1999). The use of nitrate in seafood preservation was suspended in 1965.- Data concerning the concentrations of NDMA in food items in Canada from each of the groups in which there is potential for exposure are limited and largely predate the introduction of controls outlined above. Concentrations of NDMA in 121 samples of various meat products in Canada ranged from less than 0.1 jig/kg (the limit of detection) to a maximum of 17.2 (ig/kg in a sample of bacon (Sen et al., 1979, 1980b). Concentrations of NDMA in 63 samples of various fish and sea food products in Canada ranged from less than 0.1 (J.g/kg (the limit of detection) to a maximum of 4.2 ug/kg in a sample of salted/dried fish (Sen et al., 1985). Concentrations of NDMA in 62 samples of cheese (31 of Canadian origin and 31 imported) purchased in Canada ranged from less than 1 |J.g/kg (the limit of detection) to a maxi mum of 68 jig/kg in a sample of wine cheese (Sen et al., 1978). http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 18 of 70 NDMA was generally not detected in samples of milk products, except for skim milk powder, where it was present in all 11 samples, at a maximum concentration of 0.7 ug/kg (Sen & Seaman, 1981b). In other countries, the presence of NDMA in non-fat dried milk powders has been attributed to the use of natural gas for direct fired heating (Kelly et al., 1989; Scanlan et al., 1994). In Canada, in other foods dried directly, NDMA was detected in 1 of 10 samples of instant coffee at a concentration of 0.3 ug/kg and in 2 of 20 samples of dried soup with a maximum concentration of 0.25 ug/kg (Sen & Seaman, 1981b). NDMA was not detected (at limits of detection ranging from 0.1 to 0.5 ug/kg) in 25 samples of baby food, including formula, cereal, and mixed food containing meat, analysed from 1979 to 1981 (Sen et al., 1979, 1980b; Sen & Seaman, 1981b). In a survey of other food products in 1979, NDMA was not detected in apple juice or drink, ketchup and other sauces, Ovaltine, margarine, butter, lard, or (fresh and canned) mushrooms (Sen et al., 1980b). The limit of detection was 0.1 ug/litre or 0.1 ug/kg. NDMA was detected at a trace level (<0.2 ug/kg) in 1 of 11 samples of pizza and pizza toppings (Sen et al., 1980b). Among the cured meat products analysed, bacon was unique, in that it was generally free of nitrosamines in the raw stage. Nitrosamines were formed in bacon only during high-heat frying (Sen et al., 1979). Various factors control the formation of NDMA in fried bacon, including the initial and residual levels of nitrite, processing conditions, the diet of the pigs, the lean to adipose tissue ratio, the presence of inhibitors, frying temperatures, and cooking methods (Sen, 1986). The cooked-out fat contains higher (approximately twice as high) levels of nitrosamines than the cooked lean bacon, and steam-volatile nitrosamines such as NDMA are volatilized in the fumes produced during frying (Sen, 1986). Concentrations of NDMA in bacon currently consumed in Canada are unlikely to be as high as the maximum of 17.2 ug/kg reported previously (Sen et al., 1979,1980b), as a result of the introduction of controls on the use of nitrate and nitrite in cured meat products in 1975. However, quantitative data are not available to support this conclusion. There is consensus among the literature surveyed that concentrations of NDMA in foods from developed countries were an order of magnitude lower in the late 1980s and!990s than in the 1970s (Tricker et al., 1991a; Cornee et al., 1992; Sen et al., 1996). The reduction in the concentrations of preformed NDMA in foods is attributed to improvements in food cooking and preservation techniques. However, no data are available with which to determine whether the concentrations of preformed NDMA in foods in Canada or elsewhere have continued to decline throughout the 1990s or remain at the levels measured in the late 1980s and 1990s. Most malt beverages, including beer and most brands of whiskey, regardless of origin, contain NDMA (ATSDR, 1989). The presence of NDMA in beer was first reported in 1977 (Sen et al., 1980a; OME, 1991). Malt was found to be the main source of NDMA contamination in beer, and NDMA was shown to be formed during direct drying of malt using hot flue gases — a practice that was common prior to 1980 (Spiegelhalder et al., 1980). Improved malt drying techniques (direct to indirect in 1981) have now significantly reduced the levels of NDMA in malt and beer (OME, 1991; Sen et al., 1996). It is currently believed that NDMA is only a minor component of the total A'-nitroso compounds in beer and that the major contribution is made by as yet unidentified non-volatile A'-nitroso compounds (Massey et al., 1990; UK MAFF, 1992). Among samples of beer produced in Canada, a maximum concentration of 4.9 ug/litre was reported in a beer from Ontario in 1978, while in more recent samples (i.e., 1988-1989), the maximum concentration was 0.59 ug/litre. Among imported beers purchased in Canada, a maximum concentration of 9.2 ug/litre was reported in a beer sampled in 1991-1992, while in more recent samples (i.e., October-December 1994), the maximum concentration was 3.2 ug/litre. http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 19 of 70 NDMA may also be endogenously produced in vivo from precursor compounds contained in the food ingested (e.g., DMA in meats and fish and nitrate/nitrite in vegetables) and/or already present in the human body (e.g., nitrate, nitrite) (Vermeer et al., 1998). However, available data are inadequate to serve as a basis for determining the quantities of endogeneous NDMA formed or their relative contribution to exposure via ingestion compared with that from the exogenous presence of NDMA in food (Cornee et al., 1992). 6.1.7 Consumer products Exposure can result from the use of consumer products that contain NDMA, such as cosmetics and personal care products, products containing rubber, and tobacco products. NDMA has been detected in a variety of personal care and cosmetic products (e.g., shampoos, hair conditioners and toners, bath and shower gels, creams and oils, face tonics, cleansers), likely due to the reaction of nitrosating agents such as nitrite and/or nitrogen oxides, which occur frequently therein (Spiegelhalder & Preussmann, 1984), with amine-containing compounds, which are used extensively in ingredients of personal care products. Examples include surfactants, detergents, foam boosters, protein additives, and colouring agents (ECETOC, 1990). Nitrosation of precursor compounds in cosmetic matrices, which likely include quaternary ammonium compounds, betaines, and amine oxides (ECETOC, 1991), is often slow, but cosmetic products may remain on store shelves and in consumers' cabinets for extended periods of time, during which nitrosamines can continue to form in the products (Havery & Chou, 1994). Fifty (or 34.5%) of 145 products surveyed in Germany in 1984 contained NDMA, at a maximum concentration of 24 ng/kg in one shampoo (Spiegelhalder & Preussmann, 1984). In some countries, controls have been introduced to limit levels of nitrosamines in cosmetics. For example, in Canada, manufacturers who submit cosmetic notifications for formulations that include combinations of such precursor substances are requested to provide evidence that the level of nitrosamines present in the product or formed over a period equivalent to the shelf life of the product does not exceed 10 ng/kg. Failing this, manufacturers are required to reformulate the products to remove either the amines/ amides or the nitrosating agents (R. Green, personal communication, 1995). Rubber-containing products that come into contact with human skin are another potential source of exposure to NDMA, since dialkylamines used in rubber vulcanization as accelerators and stabilizers can react with nitrosating agents to form nitrosamines (Biaudet et al., 1997). NDMA has been detected in a diverse selection of workplace, consumer, and medical products containing rubber (Health Canada, 1999). The maximum concentration of NDMA detected (i.e., 329 mg/kg) was in latex disposable protective gloves in the USA. However, only a small proportion of the total nitrosamines in the gloves would be expected to be leached out and dermally absorbed (Fiddler et al., 1985). //-Nitrosamines have been detected in baby bottle rubber nipples and pacifiers in Canada. The maximum concentrations of NDMA reported in the published literature were 25 mg/kg in baby bottle rubber nipples and 8.6 mg/kg in rubber pacifiers (Sen et al., 1984). The nitrosation of natural constituents of tobacco during curing and fermentation results in the formation of three major classes of 7V-nitroso compounds in tobacco and tobacco products — volatile, non-volatile, and tobacco-specific 7V-nitrosamines (Hoffmann et al., 1984; Tricker et al., 1991b). In addition, the combustion of cigarette tobacco results in the pyrolytic formation of volatile N-nitrosamines, including NDMA (Tricker & Preussmann, 1992). The yields of these volatile 7V-nitrosamines in cigarette smoke from combustion of tobacco depend on many chemical and physical parameters, including the amounts of organic nitrogen and nitrate present (Hoffmann et al., 1987). Furthermore, nicotine serves as a specific precursor for formation of NDMA (Hoffmann et al., 1987). http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002)Page 20 of 70 The NDMA content of cigarette and oral tobacco and the amounts of NDMA in mainstream smoke, sidestream smoke, and ETS have been assessed in several studies (Health Canada, 1999). The levels of preformed volatile 7V-nitrosamines in the cigarette tobacco are considerably lower than the corresponding levels in the mainstream smoke (Tricker et al., 1991b), and the levels of NDMA in • sidestream smoke are generally 1 or 2 orders of magnitude greater than in the mainstream smoke from the same cigarette (Health Canada, 1999). The average ETS emission factor for NDMA for six US commercial cigarette brands was 570 ±120 ng/ cigarette (Daisey et al., 1994; Mahanama & Daisey, 1996). These data have been extrapolated to estimate the concentration of NDMA in indoor air spaces of defined volume and air exchange rates. The predicted concentrations of NDMA in indoor air ranged from 0.002 to 0.005 mg/m3 (Mahanama & Daisey, 1996). Predicted concentrations based on data from other studies ranged from 0.011 to 0.037 mg/m3 (Mahanama & Daisey, 1996). These modelled concentrations are similar to the measured concentrations of NDMA in indoor air contaminated with ETS, summarized in section 6.1.2. 6.2 Human exposure: environmental Point estimates of daily intake (per kilogram body weight), based on available data that are limited in both spatial and temporal scope and reference values for body weight, inhalation volumes, and amounts of food and drinking-water consumed daily, are presented for six age groups in Table 2. These are ranges of reasonable worst-case estimates of daily intake, based on historic data, and indicate that daily intake of NDMA may be as high as 0.03 ug/kg body weight per day. It is not possible to develop defensible estimates of the current average daily intakes of NDMA for the general population due to the limitations of the (particularly recent) available Canadian data. If, despite these limitations, the lower ends of the ranges of reasonable worst-case estimates are considered upper bounds of average population exposure estimates, the daily intake of NDMA from outdoor air (in the vicinity of point sources), water, and food for the general population is unlikely to exceed 0.008 ng/kg body weight per day. Based on the assumptions underlying the reasonable worst-case estimates, most of the daily intake can be attributed to consumption of food contaminated with NDMA during processing, preservation, and/or preparation. It should be noted, though, that the data on which the estimates in food are based may not be representative of the situation today, due to the impact of subsequent introduction of changes in food processing and controls to limit formation in food. Intake of NDMA due to inhalation of air contaminated by atmospheric discharges from industrial point sources contributes somewhat less to the total daily intake,^ and an even smaller contribution is attributed to consumption of drinking-water containing NDMA, based on a survey of water treatment plants in Ontario. However, although possibly unrepresentative, available data indicate that contaminated groundwater in the vicinity of industrial point sources can, in some cases, lead to intakes that are greater than those from all other media combined. Table 2: Reasonable worst-case estimates of daily intake of NDMA by the general population in the sample country. Media Reasonable worst-case estimates of daily intake of NDMA (fig/kg body weight per day) II AirS Water*1 0-0.5 years* 0.0005-0.005 0.0013-0.004 0.5-^1 yearsb 0.001-0.011 0.0006-0.002 5-11 years0 0.0008-0.009 0.0004-0.001 12-19 yearsd 0.0004-0.005 0.0002-0.001 20-59 years' 0.0004-0.004 0.0003-0.001 II II II II II 60+ yearsf 0.0003-0.004 0.0003-0.001 http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002)Page 21 of 70 Food'j 0.0004- 0.0065-0.016 0.001k Subtotals 0.0022-0.0 101 Indoor air- 0.06 ETSm 0.0081-0.029 0.13 Groundwater" 0.14-0.31 0.06-0.13 Beer0 Shampoop | 0.0045-0.011 0.0057-0.021 0.0036-0.009 0.0043-0.011 0.0036-0.009 0.0042-0.015 0.005-0.016 0.0042-0.014 0.10 0.06 0.05 0.04 0.05-0.10 0.03-0.06 0.03-0.06 0.03-0.06 I O.0002 0.0009 0.00002 0.00002 O.0004 0.00002 Assumed to weigh 7.5 kg, to drink 0.8 litres/day of total tap water (as infant formula), and to breathe 2.1 m3 of air per day (EHD, 1998). Assumed to weigh 15.5 kg, to drink 0.7 litres/day of total tap water, and to breathe 9.3 m3 of air per day (EHD, 1998). Assumed to weigh 31.0 kg, to drink 1.1 litres/day of total tap water, and to breathe 14.5 m3 of air per day (EHD, 1998). Assumed to weigh 59.4 kg, to drink 1.2 litres/day of total tap water, and to breathe 15.8 m3 of air per day (EHD, 1998). Assumed to weigh 70.9 kg, to drink 1.5 litres/day of total tap water, and to breathe 16.2 m3 of air per day (EHD, 1998). Assumed to weigh 72.0 kg, to drink 1.6 litres/day of total tap water, and to breathe 14.3 m3 of air per day (EHD, 1998). These reasonable worst-case estimates of intake by inhalation are based on short-term measurements of MDMA in outdoor air in the close vicinity of point sources of atmospheric discharge in Ontario. The minimum estimates are based on the lowest limit of detection (i.e., 0.0017 ^ig/m3) for half-hour averaging times for Trace Atmospheric Gas Analyser (TAGA) measurements of NDMA in Kitchener, Ontario, in 1992 (technical memorandum from A. Ng to M. Lusis dated 24 July 1992 regarding the Kitchener (1992) survey: NC Rubber Products Inc. — Results of the mobile TAGA 6000; with covering memorandum dated 28 July 1992 from M. Lusis to D. Ireland regarding the mobile TAG^ 6000 survey of NC Rubber Products Inc.; Toronto, Ontario, Ontario Ministry of the Environment). The maximum estimates are based on the censored mean concentration (i.e., 0.019 ng/m3) for half-hour averaging times for TAGA measurements of NDMA (« = 74) in Elmira and Kitchener, Ontario (technical memorandum from A. Ng to M. Lusis dated 24 July 1992 [see above]; technical memorandum from A. Ng to G. De Brou dated 27 April 1990 regarding the Elmira (1990) survey: Results of the mobile TAGA; with covering memorandum dated 5 May 1990 from L. Lusis to E. Piche regarding the Elmira NDMA survey report, April 1990; Toronto, Ontario, Ontario Ministry of the Environment). Concentrations equivalent to one-half the appropriate limits of detection were assumed for half-hour averages during which NDMA was not detected. It was assumed that the population would be exposed to similar concentrations for 24 h daily, and that concentrations in the indoor air would be the same as those in outdoor air, in th( immediate vicinity of the point sources. These reasonable worst-case estimates of intake by ingestion of drinking-water are based on concentrations of NDMA measured in drinking-water in Ontario. The minimum estimates are based on the mean concentration (i.e., 0.012 Hg/litre) for 20 samples from four water treatment plants in Ontario where elevated concentrations of NDMA were attributed to the use of a pre-blended polyamine/alum product in the water treatment plant (Ontario Ministry of Environment and Energy, unpublished data, 1996). The maximum estimates are based on the maximum concentration (i.e., 0.04 ng/litre) among these 20 samples, measured at the water treatment plant in Huntsville, Ontario (Ontario Ministry of Environment and Energy, unpublished data, 1996). http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 22 of 70 i Daily consumption rates (i.e., grams/person per day) of 181 food items by six age groups of Canadians (EHD, 1998) are the basis for the calculation of the reasonable worst-case daily intake of NDMA from ingestion of foods. In Canada, NDMA has been detected in 10 food items for which these daily consumption rates are available. (Intakes from an 11th food item [i.e., beer] are not included in these intake estimates.) The maximum concentrations of NDM.A reported for each of the 10 food items (Sen et al., 1978, 1979, 1980b, 1985) were selected for calculation of the maximum estimates of intake from foods for the six age groups. Concentrations of NDMA in the remaining 171 food items were assumed to be zero. j The maximum concentrations in each of the 10 food items (i.e., referred to in footnote i) were reduced in proportion tc the frequencies of detection of NDMA in the food item for calculation of the minimum estimates of intake from foods for the six age groups (EHD, 1998). The number of samples of each of the 10 food items referred to in footnote i ranged from 2 (for cottage cheese) to 55 (for cured pork). The frequencies of detection of NDMA in the 10 food items were calculated and ranged from 25% to 100%. Concentrations of NDMA in the remaining 171 food items were assumed to be zero. k The estimates of intake of NDMA by infants were based on the assumption that these infants consume table-ready foods at rates indicated in EHD (1998). 1 The total daily intake of NDMA by infants is overestimated, since the infants are assumed to be consuming both formula (i.e., reconstituted with drinking-water) and table-ready foods on a daily basis. m Based on the assumption that the population spends 21 h/day (EHD, 1998) breathing ETS-contaminated indoor air containing NDMA at the maximum reported concentration (0.24 ng/m3) measured in a bar in the USA (Brunnemann & Hoffmann, 1978). n Based on the minimum (1.3 ng/litre) and maximum (2.9 ng/litre) concentration of NDMA in well water in Elmira, Ontario (Kornelsen et al., 1989), resulting from contamination of groundwater by a nearby industrial facility, and average daily rates of water consumption (EHD, 1998). o Based on the most recent maximum concentration (0.59 ng/litre) of NDMA in Canadian beer (Sen et al., 1996) and average daily rates of intake of beer from EHD (1998). Intake from imported beer may be higher. P Dermal intake only. These estimates are based on the Canadian regulatory limit (i.e., 10 ng/kg) for nitrosamines in personal care products (R. Green, personal communication, 1995). Shampoo was selected, as the maximum reported concentration of NDMA (24 ug/kg) in such products has been in shampoo in Germany (Spiegelhalder & Preussmann, 1984). Dermal intake was estimated by a generalized approach involving product use scenarios (ECETOC, 1994). If it is assumed that the population is exposed to the maximum concentration of NDMA in ETS- contaminated indoor air (0.24 ug/m3) for 21 h/day (EHD, 1998), the upper-bounding estimates of intake by inhalation range from 0.04 to 0.13 ug/kg body weight per day. If it is assumed that an average adult smoker consumes 20 cigarettes a day and that the mainstream smoke contains between 4 and 278 ng/cigarette (Adams et al., 1987; Kataoka et al., 1997), the estimated intake of NDMA is 0.080-5.6 ug/smoker per day, or 0.001- 0.08 ug/kg body weight per day. The upper end of this range of estimates of daily intake for smokers (i.e., 0.08 ug/kg body weight per day) is 5 times greater than the upper end of the range of reasonable worst-case estimates of intakes for adults from air, water, and food (i.e., 0.016 ug/kg body weight per day, as summarized in Table 2). Reasonable worst-case estimates of daily intake of NDMA for all age groups from ingestion of contaminated groundwater range from 0.03 to 0.31 ug/kg body weight per day (see Table 2). These estimates are based on the minimum (i.e., 1.3 ug/litre) and maximum (i.e., 2.9 ug/litre) confirmed concentrations of NDMA in supply wells in Elmira, Ontario, in 1989 (Kornelsen et al., 1989). The groundwater was contaminated by discharges from a nearby industrial facility. Estimates of daily intake of NDMA from ingestion of beer are not included in the reasonable worst-case estimates of intake from food in Table 2. For comparison, the most recent maximum concentration (i.e., 0.59 ug/litre) of NDMA in Canadian beer- (Sen et al., 1996) and average daily rates of consumption of http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 23 of 70 beer (EHD, 1998) are the basis for reasonable worst-case estimates of daily intake, which range from O.0002 to 0.0009 ng/kg body weight per day. Based on the limit (i.e., 10 ng/kg) for nitrosamines in cosmetics in Canada (R. Green, personal communication, 1995), the potential dermal uptake of NDMA from a shampoo was estimated based on product use scenarios (ECETOC, 1994). A shampoo was selected for this calculation, as the maximum reported concentration (i.e., 24 |ig/kg) of NDMA in personal care products was in a shampoo in Germany (Spiegelhalder & Preussmann, 1984). The estimated uptake of 0.000 02 ug/kg body weight per day resulting from this calculation (Health Canada, 1999) is several orders of magnitude less than the reasonable worst-case estimates of combined daily intakes from air, water, and food that are summarized in Table 2. 6.3 Human exposure: occupational Although NDMA is not used directly, workplaces in which there is potential for exposure to NDMA (as a by-product of manufacturing processes) include, but are not necessarily limited to, leather tanneries, rubber and tire industries, rocket fuel industries, dye manufacturers, soap, detergent, and surfactant industries, foundries (core-making), fish processing industries (fish meal production), pesticide manufacturers, and warehouses and sales rooms (especially for rubber products) (ATSDR, 1989). Occupational exposure may result from inhalation or dermal contact (ATSDR, 1989). The National Occupational Exposure Survey (1981-1983) indicated that 747 workers, including 299 women, were potentially exposed to NDMA (NIOSH, 1984) in the USA. US Occupational Safety and Health Administration regulations concerning NDMA (OSHA, 1993) designate strict procedures to avoid worker contact. Mixtures containing >1.0% NDMA must be maintained in isolated or closed systems, workers must observe special hygiene rules, and certain procedures must be followed for movement of the material and in case of accidental spills or emergencies. Synthetic cutting fluids, semisynthetic cutting oils, and soluble cutting oils may contain nitrosamines, either as contaminants in amines or as products from reactions between amines and nitrite. Concentrations of nitrosamines ranging from 1 to 1000 mg/litre have been determined in certain synthetic cutting oils. There are approximately 8-12 additives that could be responsible for nitrosamine formation in cutting oils. Approximately 750 000- 780 000 workers employed by more than 1000 cutting fluid manufacturing firms are potentially exposed to nitrosamines in cutting oils. In addition, there is potential exposure of an undetermined number of machine shop workers who use these fluids. Kauppinen et al. (2000) estimated that in the early 1990s, about 14 000 workers in the European Union likely had occupational exposure to NDMA. Based upon monitoring studies conducted in a number of rubber manufacturing facilities in Europe, reported maximum concentrations of NDMA in workplace air have ranged from about 1 |ig/m into the hundreds of micrograms per cubic metre (Ducos & Gaudin, 1986; Daubourg et al., 1992; Solionova et al., 1992; Rogaczewska & Wroblewska-Jakubowska, 1996; Oury et al., 1997; Straif et al., 2000). http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 24 of 70 .CH^^O j HOCH2N-N=0 CH3 N02- + CH3N=CH2 | Nitrite N-Methylformaldimine I a/pha-Hydroxymethyl nitrosamine CH20 + CH3NH2 I Methylamine Formaldehyde CH3NHN=0 + CH20 Monomethylnitrosamine Formaldehyde I CH3N=NOH M ethyl di a z o hyd roxi de 1 CH3N+sN Methyldiazonium ion i + X = macromotecule CH3-X + Methylated macromlecule Figure 2: Pathways of NDMA metabolism (adapted from ATSDR, 1989; Haggerty & Holsapple, 1990; Lee et al., 1996). 7. COMPARATIVE KINETICS AND METABOLISM IN LABORATORY ANIMALS AND HUMANS While quantitative data in humans have not been identified, on the basis of studies conducted with laboratory animals, ingested NDMA is absorbed rapidly and extensively (i.e., >90%) (Daugherty & Clapp, 1976; Diaz Gomez et al., 1977; Kunisaki et al., 1978), primarily from the lower intestinal tract (Phillips et al., 1975; Hashimoto et al., 1976; Agrelo et al., 1978; Pegg & Perry, 1981). Detection of NDMA in the urine of rats and dogs exposed by inhalation indicates that the nitrosamine is absorbed through the lungs; however, reliable quantitative information on the absorption of NDMA following inhalation was not identified. Although quantitative data were not identified, absorption through the skin may be inferred from the results of a study in which small amounts (i.e., 0.03%) of NDMA were detected in the urine of rats following epicutaneous (dermal) administration of a solution containing 350 Hg NDMA (Spiegelhalder et al., 1982). Once absorbed, NDMA and its metabolites are distributed widely (Daugherty & Clapp, 1976; Anderson et al., 1986) and likely passed to offspring through mothers' milk (Diaz Gomez et al., 1986). The nitrosamine and its metabolites have been detected in the fetuses of pregnant rodents injected with the http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 25 of 70 substance (Althoff et al., 1977; Johansson-Brittebo & Tjalve, 1979). Pharmacokinetic analyses of NDMA injected intravenously into a number of laboratory species have revealed that the nitrosamine is cleared rapidly from the blood, with metabolism involving both hepatic and extrahepatic components. NDMA and its metabolites may be excreted in the urine or exhaled as carbon dioxide. Quantitative information from studies on the metabolism of NDMA in individuals was not identified. However, based upon a few studies in which the metabolic conversion of NDMA in human liver preparations has been examined, there appear to be no qualitative differences in the metabolism of NDMA between humans and laboratory animals. The metabolism of NDMA involves either the alpha- hydroxylation or denitrosation of the nitrosamine (Figure 2). Both pathways are considered to proceed through a common intermediate radical [CH3(CH2)N-N=O], generated by the action of the cytochrome P450 [CYP2E1]-dependent mixed-function oxidase system (Haggerty & Holsapple, 1990; Lee et al., 1996). Along the a//>/za-hydroxylation pathway, the hydroxymethylnitrosamine (HOCH2CH3N-N=O) formed from the intermediate radical decomposes to formaldehyde (itself ultimately converting to carbon dioxide) and monomethylnitrosamine (CH3NHN=O); the monomethylnitrosamine, owing to its instability, under goes rearrangement to the strongly methylating methyldiazonium ion (CH,N+ N), which alkylates biological macromolecules such as DNA, RNA, and proteins. Metabolic conversion of the intermediate radical via denitrosation may lead to the formation of methylamine (CH3NH2) and formaldehyde. 8. EFFECTS ON LABORATORY MAMMALS AND IN VITRO TEST SYSTEMS NDMA has been consistently potently carcinogenic in all experimental species examined. Since exposure to NDMA occurs principally through its occurrence as a contaminant in media to which the general population is exposed, this end-point is expected to be limiting; hence, the focus of testing and, as a result, assessment has been carcinogenicity. Other end-points have not been well investigated; available data are considered inadequate as a basis for their meaningful characterization. In addition, exposure in available studies has been restricted primarily to ingestion; hence, meaningful dose- response analyses for other routes of exposure, even for the critical end-point (e.g., carcinogenicity), are precluded. 8.1 Single exposure NDMA is highly acutely toxic after oral administration to rats, with LD5Qs ranging from 23 to 40 mg/kg body weight. It is also highly acutely toxic via inhalation; 4-h LC5Qs are 78 ppm (240 mg/m3) for rats and 57 ppm (176 mg/m3) for mice. One day after three dogs were exposed (via inhalation) to 16 ppm (49 mg/m3) NDMA for 4 h, one had died, and the others were moribund (ATSDR, 1989). In all three species, acute inhalation exposure produced haemorrhagic necrosis in the liver; an increased blood clotting time was reported for the NDMA-exposed dogs (ATSDR, 1989). Following intraperitoneal exposure, LD5Qs of 43 mg/kg body weight in rats and 20 mg/kg body weight in mice have been reported (IARC, 1978). In other laboratory species, acute exposure to NDMA produced effects in the liver (hepatotoxicity), kidney (tumours), and testes (necrosis of the seminiferous epithelium) (Magee & Barnes, 1962; Schmidt & Murphy, 1966; Hard & Butler, 1970a,b; McLean & Magee, 1970; OME, http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 26 of 70 1991). 8.2 Irritation and sensitization Data on the potential of MDMA to induce sensitization and/or irritation were not identified. 8.3 Short- and medium-term exposure Hepatic effects (i.e., hepatocyte vacuolization, portal venopathy, and necrosis/haemorrhage), often associated with reduced survival, have been observed in a number of mammalian species exposed orally under various conditions (e.g., in rats receiving 1, 3.8, or 5 mg NDMA/kg body weight per day for 30, 7-28, or 5-11 days, respectively; in mice receiving 5 mg/kg body weight per day for 7-28 days; in hamsters receiving 4 mg/kg body weight per day for 1-28 days; in guinea- pigs, cats, and monkeys receiving 1 mg/kg body weight per day for 30 days or 5 mg/kg body weight per day for 5-11 days; in dogs receiving 2.5 mg/kg body weight per day, 2 days/week, for 3 weeks; and in mink receiving 0.32 mg/kg body weight per day for 23-34 days) (summarized from IARC, 1978; ATSDR, 1989). In addition to effects in the liver, "congestion" in a variety of organs (i.e., kidneys, lung, spleen, and myocardium) has been reported following examination of rats receiving 3.8 mg NDMA/kg body weight per day in the diet for 1-12 weeks (Khanna & Pun, 1966). Gastrointestinal haemorrhage has been observed in rats receiving dietary doses of 10 mg NDMA/kg body weight per day for 34-37 days (Barnes & Magee, 1954) and in mink receiving 0.3 or 0.6 mg NDMA/kg body weight per day in the diet for 23-34 days (Carter et al., 1969). Effects in the kidneys (including glomerulus dilatation and slight thickening of the Bowman's capsule) were observed in mink receiving 0.2 mg NDMA/ kg body weight per day from the diet (period not specified) (Martino et al., 1988). 8.4 Carcinogenicity Although most studies would be considered limited by current standards (e.g., small group sizes, single dose levels, limited histopathological examination), there has been clear, consistent evidence of Carcinogenicity in a number of studies in which rodents (i.e., rats, mice, hamsters) were exposed to NDMA orally, via inhalation, or by intratracheal instillation. NDMA increased the incidence of liver and Leydig cell tumours in rats ingesting this nitrosamine from drinking- water or the diet (Terao et al., 1978; Arai et al., 1979; Ito et al., 1982; Lijinsky & Reuber, 1984); increased tumour incidences were noted at concentrations of NDMA of about 5 mg/litre in drinking-water and 10 mg/kg in the diet. Increased incidences of nasal, hepatic, pulmonary, and renal tumours were observed in rats exposed to NDMA via inhalation (Moiseev & Benemanskii, 1975; Klein et al., 1991); increases in the incidence of hepatic, pulmonary, and renal tumours were observed following exposure to NDMA at a concentration of 0.2 mg/m3 (Moiseev & Benemanskii, 1975). Hepatic, pulmonary, and renal Carcinogenicity was observed in mice admin istered NDMA via drinking-water (Terracini et al., 1966; Clapp & Toya, 1970; Anderson et al., 1979, 1986, 1992) or through inhalation (Moiseev & Benemanskii, 1975); increases in tumour incidence were observed at concentrations of NDMA in drinking-water ranging from 0.01 to 5 mg/litre. Moreover, in some cases (e.g., Terracini et al., 1966), the period of exposure to NDMA was relatively short (i.e., 3 weeks). NDMA increased the incidence of liver tumours in hamsters exposed intratracheally (Tanaka et al., 1988). The administration of NDMA to pregnant rats (by intraperitoneal injection) or mice (by stomach tube) increased the frequency of hepatic and renal tumours in the offspring (Alexandrov, 1968; Anderson et al., 1989). An increased incidence of renal tumours has also been observed in rats administered either a single oral (Magee & Barnes, 1962) or intraperitoneal (Hard & Butler, 1970a; McLean & Magee, 1970) dose of NDMA (at levels of 30-60 mg/kg body weight). http ://www.inchem.org/documents/cicads/cicads/cicad3 8 .htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 27 of 70 In a more recently conducted comprehensive carcinogenicity bioassay (designed to provide detailed information on exposure-response) involving lifetime exposure, 15 dose groups of 60 male and 60 female Colworth-Wistar rats were provided with drinking-water containing a wide range of concentrations of NDMA8 (Tables 3 and 4) (Brantom, 1983; Peto et al., 1991a,b). The estimated daily intakes of NDMA ranged from 0.001 to 0.697 mg/kg body weight in the males and from 0.002 to 1.224 mg/kg body weight in the females. A control group of 120 males and 120 females received drinking- water without NDMA (Brantom, 1983; Peto et al., 1991a,b). Groups of animals were taken for interim sacrifice after 12 and 18 months of study. Survival of the animals was reduced with increasing dose; animals in the highest dose group did not survive longer than 1 year. There were no significant differences in body weight between the exposed animals and the controls. Dose-related increases in tumour incidence were observed only in the liver in both males and females (see Tables 3 and 4). The increase in tumour incidence was greatest for hepatocellular carcinoma and biliary cystadenoma. Non- neoplastic effects observed in the liver included hyperplastic nodules and the shrinkage of hepatocytes. 8.5 Genotoxicity and related end-points In numerous studies conducted in vitro in bacterial and mammalian cells, there has been overwhelming evidence that NDMA is mutagenic and clastogenic (reviewed in IARC, 1978; ATSDR, 1989). Increased frequencies of gene mutations, chromosomal damage, sister chromatid exchange, and unscheduled DNA synthesis have been observed in a wide variety of cell types, in assays conducted in the presence or absence of metabolic activation. Positive results have been observed in human as well as rodent cells. Similarly, clear evidence of genetic effects has also been observed in in vivo studies. Clastogenic effects (e.g., micronuclei, sister chromatid exchange, chromosomal aberrations) in hepatocytes (Tates et al., 1980, 1983, 1986; Mehta et al., 1987; Braithwaite & Ashby, 1988; Cliet et al., 1989; Neft & Conner, 1989; Sawada et al., 1991), bone marrow cells (Bauknecht et al., 1977; Wild, 1978; Neal & Probst, 1983; Collaborative Study Group for the Micronucleus Test, 1986; Neft & Conner, 1989; Krishna et al., 1990; Sato et al., 1992; Morrison & Ashby, 1994), spleen cells (Neft & Conner, 1989; Krishna et al., 1990), and peripheral blood lymphocytes (Tates et al., 1983; Sato et al., 1992), as well as in oesophageal (Mehta et al., 1987) and kidney cells (Robbiano et al., 1997), have been observed in rodents (rats, mice, or hamsters) administered NDMA either orally or by intraperitoneal injection. Increased frequencies of micronucleated cells were observed at doses as low as 5 mg/kg body weight in rats (Trzos et al., 1978; Mehta et al., 1987). Effects in germ cells (i.e., micronucleated spermatids) were observed in mice given 6 or 9 mg NDMA/kgbody weight via intraperitoneal injection (Cliet et al., 1993). The inhalation exposure of female mice to 1030 mg NDMA/m3 increased the frequency of micronucleated bone marrow cells (Odagiri et al., 1986). Evidence of genotoxicity (e.g., chromosomal aberrations, micronuclei, gene mutation, DNA strand breaks) has also been observed in the offspring of hamsters (Inui et al., 1979) and mice (Bolognesi et al., 1988) administered NDMA during gestation. In rodents (rats, mice, or hamsters) administered NDMA either orally or by intraperitoneal injection, evidence of DNA damage has been observed in the liver, kidneys, and lungs (Laishes et al., 1975; Petzold & Swenberg, 1978; Abanobi et al., 1979; Mirsalis & Butterworth, 1980; Brambilla et al., 1981, 1987; Bermudez et al., 1982; Cesarone et al., 1982; Barbin et al., 1983; Doolittle et al., 1984; Kornbrust & Dietz, 1985; Loury et al., 1987; Mirsalis et al., 1989; Pool et al., 1990; Brendler et al., 1992; Jorquera et al., 1993; Asakura et al., 1994; Tinwell et al., 1994; Webster et al., 1996). DNA damage in thymus (Petzold & Swenberg, 1978), sperm (Cesarone et al., 1979), and nasal and tracheal cells (Doolittle et al., 1984) has also been noted. NDMA was mutagenic at the lad locus (in the liver) in in vivo assays involving transgenic mice (Mirsalis et al., 1993; Tinwell et al., 1994; Butterworth et al., 1998). Effects (i.e., increased unscheduled hepatic DNA synthesis) have been observed in rats at doses as low as 0.1 mg NDMA/ kg body weight (Mirsalis & Butterworth, 1980). http://www.inchem.org/documents/cicads/cicads/cicad3 8 .htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002)Page 28 of 70 Table 3: Carcinogenicity study with male rats.3 Exposure group NDMA concentration in drinking- water (mg/litre) Estimated intake (mg/kg body weight per day)b 1 1 1 0 0 2 0.033 3 0.066 4 0.132 5 0.264 6 7 0.001 0.003 0.005 0.011 0.528 0.022 1.056 0.044 8 1.584 0.065 9 2.112 0.087 10 2.640 0.109II [Iii ii 11 3.168 12 4.224 0.131 0.174 13 5.280 0.218 14 6.336 0.261 15 8.448 16 I 16.896 0.348 0.697 Animals with hepatic tumours (%)c Carcinoma 1 2 Haemangiosarcoma Biliary H cystadenoma ' 1 ' 0 4 2 | 0 | 4 4 2 6 10 2 4 0 4 4 2 2 2 13 2 8 10 13 13 25 29 33 58 13 23 29 21 6 27 25 29 60 15 40II II 77 6 88 6 29 4 Brantom (1983); Peto et al. (1991a,b). Animals were provided, for their entire lives until natural death, drinking-water containing the indicated concentrations of NDMA. The animals were sacrificed and necropsied if moribund or exhibiting palpable liver alterations. Intakes estimated by authors (Peto et al., 1991b). http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002)Page 29 of 70 Proportion of animals with tumours specified at each dose level; n = 192 for unexposed controls (treatment group 1); i = 48 for each dose level (treatment groups 2-16) (Brantorn, 1983). 8.6 Reproductive toxicity Available data are inadequate as a basis for assessment of the reproductive or developmental toxicity of NDMA. Interpretation of the results of most identified investigations is complicated by the high doses administered, likely to have induced acute or repeated-dose organ toxicity. In a report by Anderson et al. (1978), time to conception in female mice provided with drinking-water containing 0.1 nig NDMA/litre for 75 days prior to mating was about 3 days longer than in unexposed controls; no other reproductive effects were assessed in this study. In a study conducted with male rats, a single intraperitoneal injection of 30 or 60 mg NDMA/kg body weight induced testicular damage (necrosis or degeneration of the seminiferous epithelium) (Hard & Butler, 1970b). In a single-generation study (Anderson et al., 1978) in which the reproductive effects of a number of substances were examined, groups of 20 female mice were provided with drinking-water containing 0 or 0.1 mg NDMA/litre for 75 days prior to mating and throughout pregnancy and lactation (estimated daily and total intakes of 0.02 mg/kg body weight per day and 2 mg/kg body weight, respectively). The proportion of deaths (based upon the total number of stillborn and neonatal deaths) was increased (P < 0.05) 2-fold in the NDMA-exposed animals compared with controls (i.e., 20% and 9.9%, respectively), due in large part to an increase in the number of stillborn animals. Exposure to NDMA had no effect upon maternal fluid consumption, litter size, or average body weight of the weanlings, and no consistent gross or histopathological abnormalities were observed in the stillborn fetuses or dead neonates to account for the increased mortality. In a somewhat more recent study with mice administered higher doses of the nitrosamine, a single intraperitoneal injection of 37 mg NDMA/kg body weight on day 16 or 19 of gestation resulted in the deaths of all fetuses in exposed dams; information on maternal toxicity was not provided (Anderson et al., 1989). Notably, this dose is greater than the LD50 for this route in these animals of 20 mg/kg body weight (IARC, 1978). In the same study, lethality was not observed following the administration of 7.4 mg NDMA/kg body weight (Anderson et al., 1989). Table 4: Carcinogenicity study with female rats.a Exposure group 1 2 3 NDMA concentration in drinking- water (ing/litre) 0 0.033 0.066 Estimated intake (mg/kg body weight per day)b 0 0.002 0.005 Animals with hepatic tumours (%)c Carcinoma Haemangiosarcoma Biliary cystadenoma 1 0 0 ' 1 * > I > 0 8 http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002)Page 30 of 70 4 0.132 5 6 7 8 0.264 0.528 1.056 1.584 9 2.112 10 11 2.640 3.168 12 4.224 13 14 15 5.280 6.336 8.448 16 16.896 0.010 0.019 0.038 4 4 10 2 0 0 6 2 10 0.076 6 4 15 0.115 0.153 0.191 0.229 0.306 0.382 0.459 10 2 10 6 8 J 13 6 15 4 25 0 71 69 83 92 90 85 38 0 69II II 0.612 69 1.224 73 6 33 10 8 Brantom (1983); Peto et al. (1991a,b). Animals were provided, for their entire lives until natural death, drinking-water containing the indicated concentrations of MDMA. The animals were sacrificed and necropsied if moribund or exhibiting palpable liver alterations. Intakes estimated by authors (Peto et al., 1991b). Proportion of animals with tumours specified at each dose level; n = 192 for unexposed controls (treatment group 1); i = 48 for each dose level (treatment groups 2-16) (Brantom, 1983). Fetal body weight was significantly (P < 0.05) reduced after a single oral dose of 20 mg NDMA/kg body weight was administered to pregnant rats on day 15 or 20 of gestation (Nishie, 1983). Although information on fetal survival or teratogenicity was not provided, toxic effects (reduced weight gain, hepatotoxicity, and death) were observed among the dams. Fetal deaths were noted in a number of studies (cited in ATSDR, 1989) conducted with rats in which NDMA was admin istered to pregnant dams 1) as a single oral dose (30 mg/kg body weight) on one of days 1-12 (Alexan drov, 1974) or 1-15 (Napalkov & Alexandrov, 1968) of gestation; 2) as repeated gavage doses of 1.4-2.9 mg/kg body weight per day for 7 or more days during gestation (Napalkov & Alexandrov, 1968); or 3) in the diet (intake of 5 mg/kg body weight per day) from an unspecified day of pregnancy to sacrifice on day 20 of gestation (Bhattacharyya, 1965). Although no teratogenic effects were reported in these studies, interpretation of these investigations is difficult owing to insufficient information on experimental design and results, lack of controls, and lack of information on maternal toxicity (ATSDR, 1989). The doses administered in some of these studies were close to the LD™. http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 31 of 70 8.7 Neurotoxicity and effects on the immune system Data concerning effects on the brain or central nervous system in animals exposed to NDMA were not identified. Similarly, available data are inadequate as a basis for assessment of the immunological effects of NDMA. Interpretation of the results of most identified investigations is complicated by likely toxicity associated with the high doses administered. In studies in which B6C3Fj female mice were administered repeated intraperitoneal injections of 1.5, 3, or 5 mg NDMA/kg body weight per day for 14 days, observed effects on the immune system included suppression of humoral immunity with declines in the IgM antibody-forming cell response to sheep red blood cells and reductions in splenocyte proliferation in response to lipopolysaccharide (reviewed in Haggerty & Holsapple, 1990). Also observed were reductions in T-lymphocyte function (i.e., reduced cell-mediated immunity) with a decline in proliferative responses to various T-cell mitogenic stimuli, suppression of the mixed lymphocyte response, and selected delayed hypersensitivity responses, as well as significant reductions in host resistance to infection with Listeria monocytogenes, Streptococcus zooepidemicus, or the influenza virus or to challenge with B16F10 tumour cells. Reductions in antibody formation and in vitro lymphoproliferative responses were observed in male BALB/c mice admin istered 5 mg NDMA/kg body weight intraperitoneally for 14 days (Jeong & Lee, 1998). Female CD-I mice provided with drinking-water containing 5 or 10 mg NDMA/litre for 30-120 days exhibited marked suppression of humoral- and cell- mediated immunity (Desjardins et al., 1992); however, effects were reversible within 30 days of cessation of exposure. No effects were observed in animals consuming drinking-water containing 1 mg NDMA/litre. 8.8 Mode of action There is strong evidence that the toxicological effects of NDMA are directly dependent upon the CYP2E1-dependent metabolic conversion of this nitrosamine to highly reactive species. Lee et al. (1996) attributed the hepatotoxicity of NDMA to the methyldiazonium ion formed via the alpha- hydroxylation pathway; denitrosation was considered to make little contribution to the overall hepatotoxic effect of this nitrosamine in rats. The principal DNA adduct formed following exposure to NDMA is ./V -methylguanine (representing about 65% of all adducts formed initially upon exposure); O6-methylguanine is a secondary adduct (representing about 7% of all adducts formed initially). Other DNA adducts formed in smaller amounts include JV -methyladenine and Cr-methylthymine. A^-Methylguanine may undergo depurination yielding apurinic sites, which, if not repaired prior to DNA replication, can result in guanine to thymine transversions (Swenberg et al., 1991). O - Methylguanine and C^-methylthymine (formed at about 1% of the amount of O -methylguanine) are strongly promutagenic by direct mispairing. O6-Methylguanine gives rise to guanine:cyto sine to adenine:thymine (i.e., G:C to A:T) transitions, while C^-methylthymine causes A:T to G:C transitions (Swenberg et al., 1991; Souliotis et al., 1995). Available data are consistent with the formation and persistence of the secondary adduct, O6-methyl guanine, being associated with both the carcinogenicity and mutagenicity of NDMA (reviewed in Haggerty & Holsapple, 1990; Swenberg et al., 1991; Souliotis et al., 1995). The ability of cells to repair DNA adducts (by removing O -methylguanine through the action of a specific O -methylguanine DNA- methyltransferase) prior to cell division likely plays a critical role in determining the susceptibility of http://www.inchem.org/documents/cicads/cicads/cicad3 8 .htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 32 of 70 tissues to tumour development. In monkeys administered (orally) 0.1 mg NDMA/ kg body weight, 06-methylguanine was detected in 32 tissues examined (Anderson et al., 1996). The highest levels were in the gastric mucosa and liver, but elevated levels were also present in white blood cells, the oesophagus, ovaries, pancreas, bladder, and uterus. O -Methylguanine DNA-methyltransferase activity varied over a 30-fold range; the highest activities were in the gastric mucosa, liver, kidneys, and lungs. The formation of O6- methylguanine was detected in fetal liver, lung, kidney, spleen, and brain in a study in which pregnant patas monkeys were administered (intragastrically) a single dose of 1 mg NDMA/kg body weight (Chhabra et al., 1995). The greater persistence of O -methylguanine DNA adducts in the kidney compared with the liver in rats administered a single oral dose of 20 mg NDMA/kg body weight parallels earlier findings in which the acute oral or intraperitoneal administration of NDMA to rats at such dose levels increased the incidence of kidney but not liver tumours (Magee & Barnes, 1962; Schmidt & Murphy, 1966; Hard & Butler, 1970a; McLean & Magee, 1970). In contrast, the long-term oral administration of low doses of NDMA (i.e., <2 mg/kg body weight per day) increased the incidence of liver but not kidney rumours in these animals (Brantom, 1983; Lijinsky & Reuber, 1984; Peto et al., 1991a,b), a finding attributed to the first- pass metabolism of NDMA in the liver (Swenberg et al., 1991). There are quantitative age- and species-related differences in hepatic O6-methylguanine, possibly associated with variations in the activity of the transferase, consistent with observed variations in the carcinogenicity of the compound among species and strains exposed under various conditions. These include greater hepatic activity in adults versus newborn mice (Coccia et al., 1988), in rats versus mice (Lindamood et al., 1984), and between strains of mice (greater in C3H than in C57BL) (Lindamood et al., 1984). Evidence supporting a role for O6-methylguanine formation in tumour development following exposure to NDMA was recently reviewed by Souliotis et al. (1995). G:C to A:T transitions have been observed in the ras oncogene in mouse lung tumours induced by NDMA (Devereux et al., 1991), in the livers of lad transgenic mice administered a single dose of 4 mg NDMA/kg body weight (Mirsalis et al., 1993), and in the liver, kidney, and lung of lad transgenic mice administered five daily doses of 1 mg NDMA/kg body weight (Wang et al., 1998). Moreover, transgenic mice expressing high levels of O6- methylguanine DNA-methyltransferase in the liver were less susceptible than normal controls to NDMA-induced hepatocarcinogenesis (Nakatsuru et al., 1993). However, Souliotis et al. (1995) also reported that the dose-response relationship for the accumulation of O6-methylguanine in hepatic DNA in rats administered drinking-water (for 28 days) containing concentrations of NDMA similar to those used in the study conducted at BIBRA Toxicology International (Brantom, 1983; Peto et al., 1991a,b) did not strictly parallel the dose-response for the development of hepatic tumours in the carcinogenicity bioassay. 9. EFFECTS ON HUMANS Two deaths linked to the acute ingestion of NDMA, as well as a third attributed to the consumption of at least four doses of approximately 250-300 mg NDMA over a 2-year period, have been reported (Fussganger & Ditschuneit, 1980; Pedal et al., 1982). Liver failure was observed in all three cases; the two acutely exposed decedents also exhibited cerebral haemorrhage. In two fatalities involving exposure http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 33 of 70 to unknown concentrations of NDMA fumes, a tender and enlarged liver, splenic enlargement, abdominal distension, and the accumulation of yellow fluid in the peritoneal cavity were observed in one man prior to death (Freund, 1937); in the other death, liver cirrhosis was observed at autopsy (Hamilton & Hardy, 1974). In two other non-fatal cases involving exposure to NDMA fumes, effects included jaundice, the accumulation of fluid in the peritoneal cavity, exhaustion, headaches, abdominal cramps, soreness on the left side, nausea, and vomiting (Freund, 1937; Hamilton & Hardy, 1974). Relevant epidemiological studies include case- control investigations in which the potential risks of cancer of the stomach (Risch et al., 1985; Gonzalez et al., 1994; La Vecchia et al., 1995; Pobel et al., 1995), upper digestive tract (Rogers et al., 1995), and lung (Goodman et al., 1992; De Stefani et al., 1996) associated with the ingestion of NDMA have been assessed. In some of these reports (Goodman et al., 1992; Gonzalez et al., 1994; Pobel et al., 1995), the estimated intake of NDMA was based upon recollection of an individual's typical diet consumed in the year preceding the onset of illness, as well as the reported levels of this nitrosamine in the foodstuffs consumed, derived from other studies. In the studies conducted by De Stefani et al. (1996) and Rogers et al. (1995), subjects were asked to recall their typical diet in the 5 and 10 years, respectively, prior to the onset of illness. In three of four case-control studies,- there was a positive relationship with evidence of exposure- response for the intake of NDMA and gastric cancer (Gonzalez et al., 1994; La Vecchia et al., 1995; Pobel et al., 1995), although not in an additional study in which oral, laryngeal, and oesophageal cancers were investigated separately (Rogers et al., 1995). In two case-control studies— in which matching or control for confounders was rather more extensive than that for the investigations of gastric cancer mentioned above, there were clear exposure-response relationships for NDMA and lung cancer (Goodman et al., 1992; De Stefani et al., 1996). In almost all studies, associations between the cancers of interest and nitrate, nitrite, and NDMA were examined; results were relatively consistent in this regard, with there being an association with cancer most commonly with NDMA; results for nitrite were mixed, and there was an inverse association with nitrate. In a population-based cohort study that assessed the risks of head and neck, stomach, and colorectal cancer associated with the dietary intake of NDMA, the relative risk (RR) of colorectal cancer was increased for the group having the highest intake of NDMA— (Knekt et al., 1999). The highest intake group had increased and reduced RRs of head and neck (RR = 1.37; 95% CI = 0.5-3.74) and stomach cancer (RR = 0.75; 95% CI = 0.37-1.51), respectively, compared with the lowest quartile (reference group). There appears to be no qualitative difference between rodents and humans in the formation of DNA adducts following exposure to NDMA. In a case of suspected NDMA poisoning in a human male, methylation of liver DNA was evident at both the TV7 and O6 positions of guanine (Herron & Shank, 1980). Using an immunohistochemical technique, Parsa et al. (1987) detected the formation of O6- methylguanine in human pancreatic explants incubated in vitro with NDMA. 10. EFFECTS ON OTHER ORGANISMS IN THE LABORATORY AND FIELD 10.1 Aquatic environment http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 34 of 70 Green algae (Selenastrum capricornutum) and blue-green algae (Anabaena flos-aqud) were exposed to NDMA over a 13-day period in static systems. The test was conducted to determine effects on algal growth rate, cell number, maximum standing crop, and dry weight. The 13-day EC5Qs for growth were 4 mg/litre and 5.1 nig/litre for the green and blue-green algae, respectively (Draper & Brewer, 1979). Draper & Brewer (1979) reported a 96-h LC50 of 940 mg/litre for fathead minnow (Pimephales promelas) and a 96-h LC50 of 1365 mg/litre for flatworms (Dugesia dorotocephald). For scud (Gammarus limnaeus), 96-h LC50 values ranged from 280 to 445 mg/litre (Draper & Fisher, 1980). Both studies were conducted in static renewal systems. The LC50 values for a saltwater fish, the common mummichog (Fundulus heteroclitus), in a static non- renewal system were 8300 mg/litre at 24 h, 5500 mg/litre at 48 h, 4700 mg/litre at 72 h, 3300 mg/litre at 96 h, and 2700 mg/litre at 120 h (Ferraro et al., 1977). Grieco et al. (1978) reported a dose-related increase in hepatocellular carcinomas in a study in which rainbow trout (Oncorhynchus mykiss) received 3, 200, 400, or 800 mg NDMA/kg in the diet over 52 weeks. Tumours did not form in trout receiving 3 mg/kg, although body weight was reduced. OME (1998) observed that growth reduction in rainbow trout was a more sensitive response than tumour induction. Frogs (Rana temporarid) were exposed to 5 mg NDMA/litre in water for 63 days and 203 days. In both studies, the frogs developed hepatocellular carcinomas as well as adenomas and tumours of the haematopoietic system. Approximately 44% of the frogs exposed for 203 days developed tumours (Khudoley, 1977). In another species of frog (Xenopus borealis) exposed for 52 weeks to 400 mg NDMA/litre in aquarium water, 54% of the test animals developed liver and kidney tumours (Khudoley & Picard, 1980). The authors believed that amphibians were more sensitive (shorter latency period and higher tumour incidence) than fish to the carcinogenic effects of the nitrosamine. 11. EFFECTS EVALUATION 11.1 Evaluation of health effects 11.1.1 Hazard identification Although NDMA is acutely toxic and induces hepatic damage in several species at dose levels of approximately 1 mg/kg body weight per day in short- term experiments, the main concern is its carcinogenicity: NDMA has been consistently shown to be a potent carcinogen in all experimental species studied. Data on other end-points are very limited. Available data are consistent with the toxicological effects of NDMA being due, in large part, to the alkylation of biological macromolecules (e.g., DNA, RNA, proteins) by the methyldiazonium ion formed during metabolism. Putative pathways for the metabolism of NDMA are similar in rodents and humans. 11.1.1.1 Carcinogenicity http ://www .inchem.org/docunients/cicads/cicads/cicad3 8 .htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 35 of 70 Information relevant to assessment of the carcinogenicity of NDMA has been derived from epidemiological (case-control) studies of the general population, carcinogenesis bioassays involving laboratory animals, and supporting data related to the genotoxicity, metabolism, and interaction of this compound with biological macromolecules. Although the database is rather limited, data from epidemiological studies are at least suggestive of an association between exposure to NDMA and several forms of cancer (i.e., gastric and lung), with some consistency of evidence for gastric cancer and for exposure-response for lung cancer, the latter in studies in which matching or control for confounders was most extensive. Although estimated intakes in these investigations were based on dietary recall, and although confounding factors such as alcohol were not accounted for, the data fulfil, at least in part, some of the traditional criteria for causality of an association between ingestion of NDMA and cancer. With the exception of a very extensive recent study, the identified carcinogenesis bioassays for NDMA are considered limited by current standards (e.g., single dose levels, small group sizes, limited histopathological examination). The weight of evidence of the carcinogenicity of NDMA in mammalian species is consistent and convincing. Moreover, the pattern of tumour development is characteristic of that for a mode of action of carcinogenesis involving direct interaction with genetic material. In available studies, NDMA has induced tumours in all species examined (mice, rats, hamsters), at relatively low doses in some cases, irrespective of the route of exposure (oral, inhalation); tumours were induced in a wide range of tissues, including the liver, Leydig cells, lungs, kidney, and nasal cavity, in the absence of significant non-neoplastic effects, in the limited number of studies in which these were well examined. Where it was reported, time to first tumour was relatively short. The incidence of specific tumours has been increased following administration of even a single dose or repeated doses for short periods (i.e., 2-3 weeks); tumours have also been observed in the offspring of exposed pregnant rats and mice. NDMA has been consistently mutagenic and clastogenic in human and rodent cells exposed in vitro. Clear evidence of genetic effects has also been observed in a number of tissues from animals exposed to this substance. Notably, genotoxic effects have been observed in tissues (i.e., liver, kidney, lung) where tumours commonly arise following experimental exposure to NDMA and in germ cells. DNA adducts (in particular, O -methylguanine) formed by the methyldiazonium ion generated during metabolism likely play a critical role in NDMA carcinogenicity. Observed variations in carcinogenicity among species and strains correlate well with variations in activity of O -methylguanine DNA- methyltransferase. Putative pathways for the metabolism of NDMA are similar in rodents and humans, and indeed the formation of O6-methylguanine has been detected in human tissues exposed to NDMA. Therefore, owing to the considerable evidence of carcinogenicity of NDMA in laboratory species, evidence of direct interaction with DNA consistent with tumour formation, and the apparent lack of qualitative species-specific differences in the metabolism of this substance, NDMA is highly likely to be carcinogenic to humans. 11.1.1.2 Non-neoplastic effects Information on adverse health effects other than cancer in humans associated with exposure to NDMA is limited. In case reports, liver failure, brain haemorrhage, and death have been attributed to the ingestion of NDMA. Effects resulting from exposure to unspecified amounts of airborne NDMA have included an enlarged liver and spleen, hepatic cirrhosis, jaundice, ascites, and death. http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 36 of 70 Data on non-neoplastic effects in laboratory animals associated with exposure to NDMA are also inadequate, attributable primarily to the focus on its carcinogenicity. Effects on the liver and kidney in repeated-dose toxicity studies (>0.2 mg NDMA/kg body weight per day), embryo toxicity and embryo lethality in single-dose developmental studies (20-30 mg/kg body weight), and a range of immunological effects (suppression of humoral- and cell-mediated immunity) reversible at lowest concentrations (5 mg NDMA/litre) have been reported. 11.1.2 Dose-response analyses The principal route of human exposure to NDMA for the general population, including those exposed in the vicinity of point sources, is ingestion.— Moreover, information on exposure-response for the critical end- point following inhalation and dermal exposure to NDMA is limited. Therefore, quantitation of dose-response is limited here to exposure via ingestion. Scaling for variations in the ratios of surface area to body weight between rodent species and humans was not considered appropriate for the measures of exposure-response developed on the basis of experimental data in animals, since it is highly probable that the carcinogenicity of NDMA is mediated primarily through the generation of an active metabolite (i.e., the methyldiazonium ion). 11.1.2.1 Carcinogenicity Cancer is clearly the critical end-point for quantitation of exposure-response for risk characterization of NDMA. This has been the best characterized end-point for this substance. Moreover, in general, tumours occur at lowest concentration, compared with those typically reported to induce non-cancer effects. An increased incidence of hepatic tumours was observed at doses as low as approximately 0.1 mg/kg body weight per day in rats (Brantom, 1983; Peto et al., 1991a,b), and the genotoxicity of NDMA (including formation of putatively critical adducts with DNA), for which the weight of evidence is exceedingly consistent and convincing, undoubtedly plays a critical role in tumour induction. A 2-fold increase in stillbirths and neonatal deaths (combined) was observed in mice receiving an estimated daily intake of 0.02 mg NDMA/kg body weight per day for 75 days prior to mating and throughout pregnancy and lactation. However, exposure to NDMA had no effect upon maternal fluid consumption, litter size, or average body weight of the weanlings, and there were no consistent gross or histopathological abnormalities in the stillborn fetuses or dead neonates to account for the increased mortality. Moreover, increased mortality was not observed in another study in which mice were administered higher doses of the nitrosamine (i.e., a single intraperitoneal injection of 7.4 mg NDMA/ kg body weight on day 16 or 19 of gestation) (Anderson et al., 1989). Quantitation of exposure-response for cancer for NDMA is based on studies in laboratory animals, since existing epidemiological data, although suggestive of a possible association between ingestion of NDMA and cancer, are inadequate to serve as a basis for characterization of exposure-response. There appear to be no qualitative differences in metabolism of NDMA between humans and laboratory animals, and there is no reason to believe that humans would respond qualitatively differently. By far the most suitable study for exposure-response analyses of the carcinogenic effects of NDMA is that reported by Brantom (1983) and Peto et al. (1991a,b), which involved the administration of NDMA in drinking-water to a large number (n = 15) of large dose groups (« = 60) of male and female rats. Other available bioassays are considerably more limited — i.e., single dose groups, small group sizes, and histopathological examination often restricted to one tissue. Quantitation of exposure-response for cancer involved calculation of the tumorigenic dose05 (TDQ5; i.e., http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 37 of 70 the dose level that causes a 5% increase in tumour incidence over background).— The lowest TDQ5 was 34 ug/kg body weight per day for the development of biliary cystadenomas in female rats. This equates to a unit risk of 1.5 x 10~3 per ug/kg body weight (i.e., 0.05/34). 11.1.2.2 Non-neoplastic effects Information on non-neoplastic effects in humans and experimental animals associated with exposure to NDMA is inadequate to characterize exposure-response. Effects on the liver (i.e., hepatocyte vacuolization, portal venopathy, and necrosis/haemorrhage) and kidney (i.e., glomerulus dilatation and slight thickening of the Bowman's capsule), "congestion" in the spleen and lungs, and gastrointestinal haemorrhage have been reported in short- and medium-term studies of animals receiving greater than 0.2 mg NDMA/kg body weight per day. Embryo toxicity and embryo lethality have been observed in a number of inadequately reported studies of often non-standard protocol following oral exposure to high (maternally toxic) doses in the range of 20-30 mg/ kg body weight per day or lower doses upon repeated exposure (1.4—2.9 mg/kg body weight per day by gavage or 5 mg/kg body weight per day in diet); teratogenicity has not been reported. In one report of a single- generation study (Anderson et al., 1978) in mice, the number of stillbirths and neonatal deaths (combined) was increased 2-fold at 0.1 mg/litre (estimated daily intake of 0.02 mg NDMA/kg body weight per day). However, confidence in the significance of this observation is mitigated by the lack of a more reliable estimate of intake, the absence of significant effects on other reproductive parameters, the lack of histopathological changes to account for the increased mortality, as well as the observation of no increased fetal mortality in dams administered a higher total dose of NDMA (Anderson et al., 1989). Although suppression of cell- and humoral-mediated immune responses was reported in mice consuming doses greater than approximately 1 mg/kg body weight per day in drinking-water for 30-120 days, effects were fully reversible within 30 days of cessation of exposure. Based on available documented studies, therefore, non-neoplastic effects of NDMA, where they have been observed, have typically occurred (except for one report of the single-generation reproduction study) at doses greater than those at which increases in tumour incidence have been reported in other studies (i.e., the latter was observed at doses as low as about 0.1 mg/kg body weight per day in rats). In addition, in view of the likely critical role of the genotoxicity of NDMA in the induction of tumours, for which the weight of evidence is consistent and convincing, cancer is clearly the critical end-point for quantitation of exposure-response for risk characterization. Measures based on this end-point will be protective for other reported non-neoplastic effects. 11.1.3 Sample risk characterization For substances such as NDMA, for which it is likely that the mode of action for the induction of tumours involves direct interaction with genetic material, quantitative estimates of carcinogenic potency (i.e., the TDQ5) may be compared with estimates of exposure to characterize risk. In the sample country (Canada), with the exception of monitoring of NDMA in water supplies in Ontario, most of the sampling and analyses for this contaminant in the general environment have been source directed — i.e., confined to foodstuffs in which it is most likely to be present or media in the vicinity of industrial sources.— The margins between the lowest value for the TDQ5 (i.e., 34 ug/kg body weight per day) and the highest reasonable worst-case estimates for the intake of NDMA by individuals in Canada (see Table 2) — that is, for children (0.5-4 years) with intakes from air, water, and food (0.029 ug/kg body weight per day), for children (0.5-4 years) exposed to ETS-contaminated indoor air (0.13 ug/kg body weight http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 38 of 70 per day), or for infants (0-0.5 years) consuming contaminated groundwater (0.31 fig/kg body weight per day) — are low (approximately 1 170, 260, and 110, respectively), equating to low dose risks of >10~5. Risks for ambient drinking-water are between 10~7 and 10~5. It should be noted that the estimates of intake from food representative of the situation today are probably lower, due to the impact of subsequent introduction of changes in food processing and controls to limit the formation of NDMA. NDMA is a genotoxic carcinogen, and exposure should be reduced to the extent possible. 11.1.4 Uncertainties and degree of confidence in human health risk characterization Non-neoplastic effects associated with exposure to NDMA have not been well studied. Although non- neoplastic effects in laboratory animals have typically been observed only at dose levels higher than those associated with increased tumour incidence (approximately 0. 1 mg/kg body weight per day in rats), in one report, stillborn and neonatal deaths (combined) were observed in a single-generation study in mice receiving an estimated intake of approximately 0.02 mg/kg body weight per day for 75 days. While there is uncertainty surrounding the biological significance of this finding, further experimental work in this area would provide more definitive information concerning potential reproductive effects linked to long-term exposure to low levels of NDMA. There is a high degree of certainty that the genotoxicity of NDMA (likely involving the formation of <96- methylguanine in DNA) is critical in the mechanism of carcinogenicity of this substance. Also, due to the unusually large number of dose groups in the critical study, characterization of exposure-response for induction of tumours by NDMA in laboratory animals is considered to be optimal. Comparison of the highest TO,^ identified from the study in which exposure-response was best characterized (i.e., 82 ug/kg body weight per day for hepatic carcinomas in female rats) with the highest reasonable worst- case estimates for the intake of NDMA by individuals in Canada (in section 1 1.1.3) would yield margins approximately 2.4-fold (i.e., 82 |ag/kg body weight per day -^ 34 jig/kg body weight per day) higher than those derived (section 1 1.1.3) on the basis of the hepatic biliary cyst adenomas in female rats. 11.2 Evaluation of environmental effects 11.2.1 Terrestrial assessment end-points Since NDMA is not persistent in the environment, environmental effects are most likely to occur near point sources. Results of various industry and municipal surveys indicate that most releases of NDMA are to water. When NDMA is released to water, nearly all of it remains and reacts in the water phase. Based on the short half-life of NDMA in air and the amounts being released to air, it is unlikely that effects will occur on wildlife near point sources. Since there are no detectable releases to sediment and soil, and as NDMA does not move from water to these compartments, effects on wildlife do not appear to be of concern. Therefore, the assessment of NDMA released to water focuses on organisms exposed in water near point sources. 11.2.2 Aquatic assessment end-points Assessment end-points include abundance and survival of fish, invertebrates, amphibians, and algae. These organisms are an integral part of ecosystems, as each trophic level provides food for higher levels in the aquatic food-chain. For example, algae are primary producers, forming the base of the food-chain. The abundance and productivity of phytoplankton are important to aquatic ecosystems, because http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 39 of 70 phytoplankton provides food for a variety of planktivorous organisms and thus controls energy flow in a portion of the ecosystem. Cladocerans such as Daphnia magna consume bacteria and phytoplankton and are themselves consumed by many fish species. Various fish species feed on aquatic vegetation, phytoplankton, zooplankton, benthic invertebrates, benthic vertebrates, etc. Vertebrate omnivores provide food for vertebrate carnivores. The most sensitive measurement end-point identified for aquatic species was growth of the green alga (Selenastrum capricornutum). As NDMA is a potent inducer of acute toxic and chronic neoplastic lesions in aquatic species, assessment end-points reflecting these effects are mentioned here. In nearly all of the studies conducted on a variety of species at different trophic levels, tumours have resulted from exposure to NDMA. Although a tumorigenic end-point is not traditionally used as an indicator of a population-level effect, it may have implications if an endangered species is found in the area of discharge of effluent containing NDMA. At this time, however, implications of tumour induction in environmental species are unclear. 11.2.3 Sample environmental risk characterization 11.2.3.1 Aquatic organisms Based on the sources and fate of NDMA, and because data on concentrations in ambient water near point sources are not available, end-of-pipe concentrations in final effluent were used as a measure of exposure of aquatic organisms. Recent concentrations have been selected to reflect present exposures. The highest concentration of NDMA in wastewater discharged to a water body was 0.266 jug/litre. Although this concentration is expected to decrease, as the company installed a waste water treatment plant in!998, this value is used as the estimated exposure value (EEV) in the hyperconservative analysis of long-term exposure for aquatic plants and animals. For long-term exposure of aquatic organisms to NDMA, the critical toxicity value (CTV) is 4000 ug/litre, based on a 13-day EC50 for inhibition of growth in the green alga (Selenastrum capricornutum). This value was selected from a data set composed of several studies conducted on at least eight species of aquatic organisms, which include phytoplankton, zooplankton, fish, amphibians, and invertebrates. It is important to note that in the second most sensitive study, tumours were present in the organism. Khudoley (1977) reported that liver tumours were induced in 44% of frogs (Rana temporarid) after 203 days of exposure at a concentration of 5000 ug/litre. Again, as was indicated in section 11.2.2 , the implications of tumour induction as a population-level effect cannot be determined at this time. For a hyperconservative analysis, the estimated no- effects value (ENEV) is derived by dividing the CTV by an application factor of 100. This accounts for the uncertainty surrounding the conversion of a short-term EC50 to a chronic no-effects value, the extrapolation from laboratory to field conditions, and interspecies and intraspecies variations in sensitivity. As a result, the ENEV is 40 ug/litre. The hyperconservative quotient is calculated by dividing the EEV of 0.266 ug/litre by the ENEV for green algae as follows: Quotient = EEV ENEV = 0.266 ug/litre 40 ug/litre http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38,2002) Page 40 of 70 = 0.007 Since the hyperconservative quotient is less than one, it is unlikely that NDMA releases will cause adverse effects on populations of aquatic organisms in the sample country. 11.2.4 Discussion of uncertainty Regarding effects of NDMA on aquatic organisms, there is uncertainty in the extrapolation from available toxicity data to potential ecosystem effects. The toxicity data set for aquatic biota, however, is considered adequate, as it includes a variety of species from different trophic levels. While some of the studies are relatively old (1960s-1980s), they are generally of good quality and are considered acceptable for the assessment. 12. 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APPENDIX 1 — SOURCE DOCUMENT Environment Canada & Health Canada (2001) http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 57 of 70 Copies of the Canadian Environmental Protection Act Priority Substances List assessment report (Environment Canada & Health Canada, 2001) and unpublished supporting documentation for NDMA may be obtained from: Commercial Chemicals Evaluation Branch Environment Canada 14th floor, Place Vincent Massey 351 St. Joseph Blvd. Hull, Quebec Canada Kl A OH3 or Environmental Health Centre Health Canada Address Locator: 0801A Tunney's Pasture Ottawa, Ontario Canada Kl A OL2 Initial drafts of the supporting documentation and assessment report for NDMA were prepared by staff of Health Canada and Environment Canada. H. Hirtle contributed additional information in the preparation of the draft CICAD. Environmental sections of the assessment report were reviewed externally by J. Ballantine (Health Canada), A. McLarty (Ontario Ministry of the Environment), E. McBean and J. Kochany (Conestoga- Rovers & Associates), and D. Carlisle (Brez-Carlisle Inc.). In order to address primarily adequacy of coverage, sections of the supporting documentation pertaining to human health were reviewed externally by B. Birmingham (Ontario Ministry of the Environment) and R. Brecher (Globaltox International Consultants, Inc.). Accuracy of reporting, adequacy of coverage, and defensibility of conclusions with respect to hazard characterization and dose-response analysis were considered at a panel meeting of the following members, convened by Toxicology Excellence for Risk Assessment (TERA) on 12 August 1999 in Ottawa, Ontario: M. Bogdanffy, DuPont Haskel Laboratory J. Christopher, California Environmental Protection Agency http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 58 of 70 M. Dourson, TERA S. Felter, Procter & Gamble J. Mandel, Exponent R. Rudel, Silent Spring Institute V. Walker, New York State Department of Health APPENDIX 2 — CICAD PEER REVIEW The draft CICAD on NDMA was sent for review to institutions and organizations identified by IPCS after contact with IPCS national contact points and Participating Institutions, as well as to identified experts. Comments were received from: A. Aitio, International Programme on Chemical Safety, World Health Organization, Geneva, Switzerland M. Baril, International Programme on Chemical Safety/ Institut de Recherche en Sante et en Securite du Travail du Quebec, Montreal, Quebec, Canada R. Benson, Drinking Water Program, US Environmental Protection Agency, Denver, CO, USA R. Gary, Health and Safety Executive, Bootle, Merseyside, United Kingdom R. Chhabra, National Institute of Environmental Health Sciences, National Institutes of Health, Research Triangle Park, NC, USA C. Elliott-Minty, Health and Safety Executive, Bootle, Merseyside, United Kingdom E. Frantik, National Institute of Public Health, Center of Industrial Hygiene and Occupational Diseases, Praha, Czech Republic R. Hertel, Federal Institute for Health Protection of Consumers and Veterinary Medicine, Berlin, Germany T.G. Hrnsi, National Institute of Public Health, Oslo, Norway A.P. Hugenholtz, Bureau of Chemical Safety, Health Canada, Ottawa, Ontario, Canada E. Srderlund, National Institute of Public Health, Oslo, Norway U. Steinus, Karolinska Institute, Stockholm, Sweden Y.-W. Stevens, Agency for Toxic Substances and Disease Registry, Atlanta, GA, USA http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 59 of 70 K. Ziegler-Skylakakis, Commission of the European Communities/European Union, Luxembourg APPENDIX 3 — CICAD FINAL REVIEW BOARD Geneva, Switzerland, 8-12 January 2001 Members Dr A.E. Ahmed, Molecular Toxicology Laboratory, Department of Pathology, University of Texas Medical Branch, Galveston, TX, USA Mr R. Gary, Health and Safety Executive, Merseyside, United Kingdom (Chairperson) Dr R.S. Chhabra, General Toxicology Group, National Institute of Environmental Health Sciences, National Institutes of Health, Research Triangle Park, NC, USA Dr S. Czerczak, Department of Scientific Information, Nofer Institute of Occupational Medicine, Lodz, Poland Dr S. Dobson, Centre for Ecology and Hydrology, Cambridgeshire, United Kingdom Dr O.M. Faroon, Division of Toxicology, Agency for Toxic Substances and Disease Registry, Atlanta, GA, USA Dr H. Gibb, National Center for Environmental Assessment, US Environmental Protection Agency, Washington, DC, USA Dr R.F. Hertel, Federal Institute for Health Protection of Consumers and Veterinary Medicine, Berlin, Germany Dr A. Hirose, Division of Risk Assessment, National Institute of Health Sciences, Tokyo, Japan Dr P.D. Howe, Centre for Ecology and Hydrology, Cambridgeshire, United Kingdom (Rapporteur) Dr D. Lison, Industrial Toxicology and Occupational Medicine Unit, Universite Catholique de Louvain, Brussels, Belgium Dr R. Liteplo, Existing Substances Division, Bureau of Chemical Hazards, Health Canada, Ottawa, Ontario, Canada Dr I. Mangelsdorf, Chemical Risk Assessment, Fraunhofer Institute for Toxicology and Aerosol Research, Hanover, Germany Ms M.E. Meek, Existing Substances Division, Safe Environments Program, Health Canada, Ottawa, Ontario, Canada ( Vice- Chairperson) Dr S. Osterman-Golkar, Department of Molecular Genome Research, Stockholm University, Stockholm, http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 60 of 70 Sweden Dr J. Sekizawa, Division of Chem-Bio Informatics, National Institute of Health Sciences, Tokyo, Japan Dr S. Soliman, Department of Pesticide Chemistry, Faculty of Agriculture, Alexandria University, El- Shatby, Alexandria, Egypt Dr M. Sweeney, Education and Information Division, National Institute for Occupational Safety and Health, Cincinnati, OH, USA Professor M. van den Berg, Environmental Sciences and Toxicology, Institute for Risk Assessment Sciences, University of Utrecht, Utrecht, The Netherlands Observers Dr W.F. ten Berge, DSM Corporate Safety and Environment, Heerlen, The Netherlands Dr K. Ziegler-Skylakakis, Commission of the European Communities, Luxembourg Secretariat Dr A. Aitio, International Programme on Chemical Safety, World Health Organization, Geneva, Switzerland Dr Y. Hayashi, International Programme on Chemical Safety, World Health Organization, Geneva, Switzerland Dr P.G. Jenkins, International Programme on Chemical Safety, World Health Organization, Geneva, Switzerland Dr M. Younes, International Programme on Chemical Safety, World Health Organization, Geneva, Switzerland APPENDIX 4 — CALCULATION OF TUMORIGENIC DOSE05 The tumorigenic doseQ5 (TD05; i.e., the dose level that causes a 5% increase in tumour incidence over background) was calcu lated by first fitting the multistage model to the dose-response data. The multistage model is given by where d is dose, k is the number of dose groups in the study minus one, P(d) is the probability of the http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002)Page 61 of 70 animal developing a tumour at dose d, and qi >0,i=l,...,k are parameters to be estimated. TDQ5s were then calculated as the dose D that satisfies P(D) - 1 - P(0)= 0.05 A chi-square lack of fit test was performed for each of the three tumour types. The degrees of freedom for this test are equal to k minus the number ofq's for which estimates are non-zero. A P-value less than 0.05 indicates a significant lack of fit. The study reported by Brantom (1983) and Peto et al. (1991a,b) contained 15 dose groups and controls, which is unusually large. Upper dose groups for which there was downturn in the dose-response curve were first eliminated from calculations of the TDQ5. These dose groups add no information to the shape of the dose-response curve in the range of the TDQ5 and contribute to lack of fit of the model. In addition, extreme downturn is likely a sign that animals are dying of some other cause before having a chance to develop the tumour of interest. Two methods were used to fit models to the large number of dose groups. In the first method, quadratic models (i.e., models with k = 2) were fit to the full set of data, less any dose groups contributing to downturn at the upper end of the dose-response curve. Any model with k larger than 2 did not converge when fitting models to the full data set. The second method involved reducing the number of dose groups to 10 (or less) by first eliminating upper dose groups with downturn and then collapsing adjacent similar dose groups together. Collapsing was accomplished by averaging the dose level and totalling the number of tumours for the two groups. Global82 (Howe & Crump, 1982) was then used to fit full multistage models to the reduced data. With the exception of biliary cystadenomas in females, these models did not show significant lack of fit. However, they generally appeared to overestimate the risk in the range of the TD05, resulting in TD05 values that might be overly conservative. There was no evidence of a dose-response relationship for haemangiosarcomas in females; these data were not modelled, therefore, for the purpose of calculating a After reducing the data to 10 dose groups, the multistage model still occasionally exhibited lack of fit, due in large part to a levelling off of the dose-response relationship at higher doses. Since a good fit in the range of the TD05 is required, upper dose groups were systematically eliminated until a reasonable fit was achieved. The data finally used to compute TDQ5s for hepatic tumours in the male and female rats from the Brantom (1983) and Peto et al. (1991a,b) study are presented in Tables A-l and A-2. Table A-l : Data on hepatic carcinogenicity in male rats used for modelling. Carcinoma Intake (mg/kg body weight per day) Incidence Haemangiosarcoma Intake (mg/kg body weight per day) 1 II II Incidence Biliary cystadenoma Intake (mg/kg body weight per day) Incidence II 1 http ://www .inchem.org/documents/cicads/cicads/cicad3 8 .htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002)Page 62 of 70 0 2/192 0.0020 2/96 0.0080 0.0330 3/96 4/96 0.0760 11/96 0.1200 26/96 0.1960 44/96 0.3045 66/96 0 2/192 0 0.002 0/96 0.005 0.011 0.022 0.044 0.065 2/192 0.0020 4/96 1/48 0.0080 2/48 0/48 1/48 1/48 0.0330 0.0760 0.1200 4/96 2/96 10/96 24/96 0.1960 26/96 1 0.087 6/48 0.3045 33/96 1 II 0.109 6/481 II 0.131 14/48 Table A-2: Data on hepatic carcinogenicity in female rats used for modelling. Carcinoma Intake (mg/kg body weight per day) 0 0.0035 0.0145 0.057 0.134 0.210 0.344 0.459 0.612 Incidence 2/192 0/96 4/96 8/96 10/96 10/96 19/96 18/48 33/48 Biliary cystadenoma Intake (mg/kg body weight per day) 0 0.002 0.005 0.010 0.019 0.038 0.076 0.115 Incidence 4/192 1/48 4/48 0/48 3/48 5/48 7/48 34/48 1 http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002)Page 63 of 70 After comparing the two methods of model fitting, the second was judged to provide a better description of the dose-response relationship in the range of the TDQ5. These fits were used to generate the final TDQ5s. The TDQ5s and model-fitting information are presented in Table A-3 and Figure A-l. Table A-3: TD05s for NDMA. TD05 Oig/kg body weight per day) 95% lower confidence limit on TDQ5 Male rats Hepatic carcinoma Hepatic haemangiosarcoma Hepatic biliary cystadenoma 38 78 35 24 48 29 Chi-square 2.17 7.67 10.25 df P- value 5 6 6 0.82 0.26 0.11 Female rats Hepatic carcinoma Hepatic biliary cystadenoma 82 34 61 18 7.36 7.036 5 5 0.19 0.22 http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002)Page 64 of 70 Hepatic carcinoma in male rats Biliary cystadenoma in male rats c 5 0.6 - 1 I 0.4 Sia. £ 0.2 - 0.0-TD05 = 0.04 0.0 0.1 0.2 0.3 Dose (mg/kg body weight per day) Haemangiosarcoma in male rats 0.0-1 = 0.08 0.0 0.04 0.08 0.12 Dose (mg/kg body weight per day) 0.4 - _ 0.3 - Mo J 0.2 H o£ £ ? 0.1 j 0.0 -H TD05 = 0.04 0.0 0.1 0.2 0.3 Dose (mg/kg body weight per day) Hepatic carcinoma in female rats 0.8 - §1°"6 1^0.4o :£ ^ f 0.2 - 0.0-= 0.08 0.0 0.2 0.4 0.6 Dose (mg/kg body weight per day) Biliary cystadenoma in male rats 0.06 ' 0.10 Dose (mg/kg body weight per day) http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 65 of 70 Figure A-l: TDQ5s for NDMA. INTERNATIONAL CHEMICAL SAFETY CARD N-NITROSODIMETHYLAMINE ICSC:Q525 RESUME D'ORIENTATION Ce CICAD relatif a la N-nitrosodimethylamine (NDMA) a ete prepare conjointement par la Direction de FHygiene du Milieu de Sante Canada et la Direction de FEvaluation des produits chimiques commerciaux d'Environnement Canada a partir d'une documentation redigee simultanement dans le cadre du programme sur les substances prioritaires prevu par la Lot canadienne sur la protection de I'environnement (LCPE). Les etudes sur les substances prioritaires prescrites par la LCPE ont pour objectif d'evaluer les effets potentiels sur la sante humaine d'une exposition indirecte a celles de ces substances qui sont presentes dans Fenvironnement ainsi que leurs effets sur Fenvironnement lui-meme. Bien que Fexposition professionnelle n'ait pas ete le sujet du document initial (Environnement Canada & Sante Canada, 2001), des donnees sur la question ete incluses dans le present CICAD. La presente mise au point prend en compte les donnees publiees jusqu'en aout 1999 en ce qui concerne les effets sanitaires et jusqu'a fin fin aout 1998 en ce qui concerne les effets sur Fenvironnement. — D'autres mises au point ont ete egalement consultees, a savoir celles du CIRC (1978), de FOME (1991, 1998) et de BIBRA Toxicology International (1997, 1998). Des renseignements sur la nature de Fexamen par des pairs et la disponibilite du document de base sont donnes a Fappendice 1. Les informations concemant Fexamen par des pairs du present CICAD figurent a Fappendice 2. Ce CICAD a ete approuve en tant qu'evaluation Internationale lors d'une reunion du Comite d'evaluation finale qui s'est tenue a Geneve (Suisse), du 8 au 12 Janvier 2001. La liste des participants a cette reunion se trouve a Fappendice 3. La fiche Internationale sur la securite chimique de la NDMA (ICSC 0525), preparee par le Programme international sur la securite chimique (IPCS, 1993), est egalement reproduite dans le present document. La ./V-nitrosodimethylamine (NDMA) est la plus simple des dialkylnitrosamines. Bien que n'etant plus utilisee dans Findustrie ou le commerce ni au Canada, ni aux Etats-Unis, elle continue neanmoins d'etre liberee dans Fenvironnement comme sous-produit ou contaminant par diverses installations industrielles et par les stations municipales de traitement des eaux usees. Ce sont les usines de pesticides, de pneumatiques, de colorants et les unites de production d'alkylamines qui en rejettent le plus. De la NDMA peut egalement se former dans les conditions naturelles dans Fair, Feau et le sol par suite de certains processus chimiques, photochimiques ou biologiques et on en a mis en evidence dans Feau de boisson et dans les gaz d'echappement des automobiles. C'est principalement par photolyse que la NDMA s'elimine des eaux de surface, de F atmosphere et du sol. Toutefois, dans les eaux superficielles riches en substances organiques et matieres en suspension, la photodecomposition est tres ralentie. Dans les eaux des nappes phreatiques et dans le sol, c'est la biodegradation qui constitue la voie d'elimination predominate. La NDMA a vraisemblablement peu de chances d'etre transported sur de longues distances ou de se repartir dans le sol et les sediments. En raison de sa solubilite et de la faible valeur de son coefficient de partage, la NDMA a la possibilite de passer par lessivage dans les eaux souterraines et de s'y maintenir. Elle subit une metabolisation et ne http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 66 of 70 s'accumule pas. Elle n'est pas presente en quantites decelables dans les eaux de surface, sauf en cas de contamination localisee aux alentours de sites industriels, ou 1'on apu mesurer des concentrations allant jusqu'a 0,266 jag par litre au debouche de certains emissaires. Selon des enquetes limitees effectuees dans le pays sur lequel on s'est base pour caracteriser le risque type (le Canada), la NDMA n'est pas decelable dans 1'air ambiant, sauf a proximite de sites industriels. En revanche, de faibles concentrations de NDMA - provenant de stations de traitement ou d'eaux souterraines contaminees par des effluents industriels - ont etc mesurees dans de 1'eau de consommation. On a egalement mis en evidence la presence de NDMA dans diverses denrees alimentaires, le plus souvent dans de la biere, des salaisons ou des fumaisons, des produits pisciaires et dans certains fromages avec, il est vrai, une diminution de la concentration ces deraieres annees en raison d'un changement dans le mode de traitement de ces produits. Le consommateur peut egalement etre expose a la NDMA contenue dans d'autres produits tels que les cosmetiques et les produits de soins, les objets en caoutchouc et le tabac. La NDMA est indubitablement cancerogene, comme le montrent les recherches en laboratoire selon lesquelles ce compose provoque Fapparition de tumeurs a dose relativement faible chez toutes les especes erudiees. On a en outre la preuve indiscutable du pouvoir mutagene et clastogene de la NDMA. Le mecanisme de la cancerisation induite par ce compose n'est pas encore totalement elucide, mais on sail qu'au cours de sa metabolisation, il donne naissance a un ion methyldiazonium dont les adduits avec 1'ADN (notamment YO -methylguanine) jouent sans doute un role determinant. Qualitativement, le metabolisme de la NDMA est analogue chez FHomme et 1'animal; on estime par consequent que ce compose est tres probablement egalement cancerogene pour FHomme, sans doute a concentration relativement faible. Comme on s'est surtout interesse au pouvoir cancerogene de la NDMA, on ne dispose que de resultats de laboratoire limites concemant ses effets non neoplasiques. L'administration de doses repetees provoque des effets sur le foie et le rein et des etudes sur le developpement consistant a administrer une dose unique ont mis en evidence une toxicite pour Fembryon pouvant aller jusqu'a la mort. Par ailleurs, on a fait etat de divers effets immunologiques (depression de 1'immunite humorale et de Fimmunite a mediation cellulaire) qui sont reversibles a faible concentration. II est clair que, s'agissant de la quantification de la relation dose-reponse en vue de la caracterisation du risque, c'est le cancer qui constitue le point d'aboutissement essentiel de Faction toxique de la NDMA. Outre que ce sont les effets les mieux caracterises, en regie generate, ces tumeurs apparaissent a des concentrations beaucoup plus faibles que celles auxquelles des effets non neoplasiques sont habituellement observes. La dose tumorigene la plus faible (CTQ 5) pour Fapparition de tumeurs hepatiques (cystadenomes biliaires chez des rats femelles apres exposition d'animaux des deux sexes) determinee lors de F etude qui a fourni les donnees essentielles sur ce point, a ete de 34 ug/kg de poids corporel par jour. Cette valeur correspond a un risque unitaire de 1,5 x 10~3 par ug de substance et par kg de poids corporel. En se basant sur Festimation de la dose de NDMA absorbee avec Fair ambiant et une eau de boisson contaminee (eau souterraine) lors de la caracterisation du risque type, le risque au voisinage de sources industrielles ponctuelles de NDMA est evalue a >10 . En qui concerne le risque inherent a la consommation d'eau de boisson contaminee, la valeur se situe entre 10 et 10 . La NDMA est un cancerogene genotoxique et Fexposition a ce compose doit etre la plus faible possible. On possede des donnees sur la toxicite aigue et chronique du compose pour les organismes aquatiques. L'effet toxique constate a la concentration la plus faible (4000 ug/litre) a consiste en une reduction de la croissance chez des algues. Cette caracterisation du risque type tient compte du fait que dans le pays http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 67 of 70 retenu, la concentration en NDMA dans les eaux de surface est infer!eure au seuil estimatifd'apparition d'effets nocifs chez les organismes aquatiques. On n'a pas trouve de donnees concernant la presence de NDMA dans les sediments ou le sol du pays temoin. RESUMEN DE ORIENTACION Este CICAD sobre la vV-nitrosodimetilamina (NDMA), preparado conjuntamente por la Direction de Higiene del Medio del Ministerio de Salud del Canada y la Division de Evaluacion de Productos Quimicos Comerciales del Ministerio de Medio Ambiente del Canada, se basa en la documentation preparada al mismo tiempo como parte del Programa de Sustancias Prioritarias en el marco de la Ley Canadiense de Protection del Medio Ambiente (CEPA). Las evaluaciones de sustancias prioritarias previstas en la CEP A tienen por objeto valorar los efectos potenciales para la salud humana de la exposicion indirecta en el medio ambiente general, asi como los efectos ecologicos. Aunque en el documento original no se abordo la exposicion ocupacional (Ministerios de Medio Ambiente y de Salud del Canada, 2001), en el presente CICAD se ha incluido information sobre este aspecto. En este examen se analizaron los datos identificados hasta el final de agosto de 1998 (efectos medioambientales) y agosto de 1999— (efectos en la salud humana). Tambien se consultaron otros examenes, entre ellos los del CIIC (1978), ATSDR (1989), OME (1991, 1998) y BIBRA Toxicology International (1997,1998). La inforrnacion relativa al caracter del examen colegiado y la disponibilidad del documento original figuran en el apendice 1. La information sobre el examen colegiado de este CICAD aparece en el apendice 2. Este CICAD se aprobo como evaluacion internacional en una reunion de la Junta de Evaluacion Final celebrada en Ginebra (Suiza) del 8 al 12 de enero de 2001. La lista de participantes en esta reunion figura en el apendice 3. La Ficha internacional de seguridad quimica (ICSC 0525) para la NDMA, preparada por el Programa Internacional de Seguridad de las Sustancias Quimicas (IPCS, 1993), tambien se reproduce en este documento. La yV-nitrosodimetilamina (NDMA) es la dialquilnitrosamina mas sencilla. Aunque ya no se utiliza con fines industriales o comerciales en el Canada o los Estados Unidos de America, se sigue liberando como subproducto y contaminante a partir de diversas industrias y de instalaciones de depuration de aguas residuales municipales. Las emisiones mas importantes de NDMA proceden de la fabrication de plaguicidas, neumaticos de caucho, alquilaminas y colorantes. La NDMA se puede formar tambien en condiciones narurales en el aire, el agua y el suelo como resultado de procesos quimicos, fotoquimicos y biologicos, y se ha detectado en el agua de bebida y en los gases de escape de los automoviles. La fotolisis es la via principal de eliminacion de la NDMA de las aguas superficiales, el aire y el suelo. Sin embargo, en las aguas superficiales con concentraciones elevadas de sustancias organicas y materia en suspension, la fotodegradacion es mucho mas lenta. En las aguas no superficiales y en el suelo, la biodegradacion es la via de eliminacion mas importante. Es poco probable que la NDMA recorra largas distancias suspendida en el aire o que se distribuya en el suelo y los sedimentos. Debido a su solubilidad y a su bajo coeficiente de reparto, la NDMA puede filtrarse a las aguas freaticas y persistir en ellas. Se metaboliza y no se bioacumula. En general, la NDMA no es detectable en las aguas superficiales, excepto en la contamination localizada de zonas industriales, en las que se han medido concentraciones de efluentes de la etapa final de production de hasta 0,266 u.g/1. En estudios limitados en el pais en el cual se basa la caracterizacion del riesgo de muestra (es decir, el Canada), no se ha detectado NDMA en el aire, salvo en las inmediaciones de zonas industriales. Se han detectado concentraciones bajas de NDMA en el agua de bebida, por ejemplo en instalaciones de tratamiento del agua o a partir de aguas freaticas contaminadas por efluentes industriales. Se ha http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 68 of 70 demostrado la presencia de NDMA en algunos alimentos, en particular la cerveza, la carne curada, los productos pesqueros y algunos quesos, aunque en los ultimos anos las concentraciones de NDMA en estos productos ban disminuido debido a cambios en la elaboration de los alimentos. Tambien se puede sufrir exposicion a la NDMA por el uso de productos de consumo que la contienen, por ejemplo cosmeticos y productos de cuidado personal, productos que contienen caucho y productos de tabaco. Sobre la base de los estudios de laboratorio en los cuales se han inducido tumores en todas las especies examinadas a dosis relativamente bajas, la NDMA es claramente carcinogenica. Hay pruebas abundantes de que la NDMA es mutagenica y clastogenica. Aunque no se conoce completamente su mecanismo de induccion de tumores, los aductos de ADN (en particular la O6-metilguanina) formados por el ion metildiazonio generado durante el metabolismo tienen probablemente un papel decisivo. Desde el punto de vista cualitativo, el metabolismo de la NDMA parece ser semejante en las personas y los animales; en consecuencia, se considera muy probable que sea carcinogenica para las personas, incluso a niveles de exposicion relativamente bajos. Los datos sobre los efectos no neoplasicos en animales de laboratorio asociados con la exposicion a la NDMA son limitados y pueden atribuirse principalmente a la atencion que se presta a su carcinogenicidad. Se han notificado efectos en el higado y el rifton en estudios de toxicidad de dosis repetidas, toxicidad y letalidad embrionarias en estudios de desarrollo de dosis linica y una serie de efectos inmunologicos (supresion de la inmunidad humoral y mediada por celulas) reversibles con las concentraciones mas bajas. El cancer es sin duda el efecto final critico para la cuantificacion de la exposicion-respuesta en la caracterizacion del riesgo de la NDMA. Ademas de ser el mejor caracterizado, en general, los tumores se producen con la concentracion mas baja, en comparacion con las notificadas normalmente como inductoras de efectos distintos del cancer. La dosis tumorigenica0 5 mas baja para la induccion de tumores hepaticos en ratas macho y hembra expuestas a la NDMA en el estudio critico fue de 34 ng/kg de peso corporal al dia para la formation de cistadenomas biliares en hembras. Esto equivale a un riesgo unitario de 1,5 x 10~3 por ug/kg de peso corporal. Basandose en la ingesta estimada de NDMA en el aire y en el agua de bebida contaminada (agua freatica) en la caracterizacion del riesgo de muestra, los riesgos en las inmediaciones de fuentes puntuales industriales son >10 . Los relatives al agua de bebida son de 10 a 10 . La NDMA es un carcinogeno genotoxico y la exposicion se debe reducir en la medida de lo posible. Hay datos disponibles de toxicidad aguda y cronica para los organismos acuaticos. El efecto toxico que se produjo con la concentracion mas baja fue una reduction del crecimiento de las algas con 4000 ^g/1. En la caracterizacion del riesgo de muestra, las concentraciones de NDMA en las aguas superficiales del pais en el que se ha realizado es inferior al umbral para los efectos adversos estimados en los organismos acuaticos. No se encontraron datos sobre las concentraciones de la NDMA en los sedimentos o en el suelo del pais de muestra. ENDNOTES International Programme on Chemical Safety (1994) Assessing human health risks of chemicals: derivation of guidance values for health-based exposure limits. Geneva, World Health Organization (Environmental Health Criteria 170). fjNew information flagged by the reviewers and in a literature search conducted prior to the Final http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 69 of 70 Review Board meeting has been scoped to indicate its likely impact on the essential conclusions of this assessment, primarily to establish priority for its consideration in an update. More recent information not critical to the hazard characterization or exposure-response analysis, considered by reviewers to add to informational content, has been added. 3Technical memorandum from A. Ng to G. De Brou dated 27 April 1990 regarding the Elmira (1990) survey: Results of the mobile TAGA; with covering memorandum dated 5 May 1990 from L. Lusis to E. Piche regarding the Elmira MDMA survey report, April 1990. Toronto, Ontario, Ontario Ministry of the Environment. 4Technical memorandum from A. Ng to M. Lusis dated 24 July 1992, regarding the Kitchener (1992) survey: NC Rubber Products Inc. - Results of the mobile TAGA 6000; with covering memorandum dated 28 July 1992, from M. Lusis to D. Ireland regarding the mobile TAGA 6000 survey of NC Rubber Products Inc. Toronto, Ontario, Ontario Ministry of the Environment. Internal memorandum dated 13 September 1999 from J. Salminen, Bureau of Chemical Safety, Food Directorate, to B. Meek, Bureau of Chemical Hazards, Environmental Health Directorate, Health Canada, Ottawa, Ontario (File No. FP99072001-597). 6Since MDMA was not detected in the one available survey of air not impacted by industrial point sources (i.e., Windsor, Ontario) (Ng & Karellas, 1994b), data were considered inadequate as a basis for estimation of the intake of NDMA in ambient air by the general population residing in an urban area, without point sources. Intake from imported beer may be higher. 8The concentrations of NDMA were 33, 66,132, 264, 528, 1056, 1584, 2112, 2640, 3168, 4224, 5280, 6336, 8448, and 16 896 ug/litre. 9In Gonzalez et al. (1994), the odds ratios (ORs) for gastric cancer were 1, 1.86, 1.79, and 2.09 among individuals with intakes of NDMA in the first (reference group), second, third, and fourth quartiles, respectively (P = 0.007 for trend). Pobel et al. (1995) reported ORs (95% confidence intervals [CIs]) (adjusted for age, sex, occupation, and total caloric intake) of 1, 4.13 (0.93-18.27), and 7.0 (1.85-26.46) among individuals with intakes of NDMA in the first (reference group), second, and third tertiles, respectively (P = 0.04 for trend). In La Vecchia et al. (1995), ORs (95% CIs) (adjusted for age, sex, education, family history of gastric cancer, combined food score index, intake of beta-carotene, vitamin C, nitrite, nitrate, and total calories) for stomach cancer were 1,1.11 (0.9-1.4), and 1.37 (1.1-1.7) among individuals with intakes of NDMA in the first (reference group), second, and third tertiles, respectively (P<0.01 for trend). 10In Goodman et al. (1992), ORs (95% CIs) (adjusted for age, ethnic group, smoking status, pack-years of cigarette use, and beta-carotene intake) for those in the second, third, and fourth quartiles of NDMA intake (compared with the first quartile) were (among men) 1.7 (0.9-3.2), 2.8 (1.4-5.3), and 3.3 (1.7- 6.2) and (among women) 1.4 (0.7-2.9), 1.8 (0.7-4.2), and 2.7 (1.0-6.9), respectively (trends were P = 0.006 and 0.04 for males and females, respectively). De Stefani et al. (1996) reported ORs (95% CIs) for all types of lung cancer (com bined) among individuals in the first, second, third, and fourth quartiles of NDMA intake of 1, 0.88 (0.53-1.48), 1.77 (1.06-2.96), and 3.14 (1.86-5.29), respectively (/>< 0.001 for trend). http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 N-Nitrosodimethylamine (CICADS 38, 2002) Page 70 of 70 RRs (95% CIs) (adjusted for age, sex, municipality, smoking, and energy intake) of colorectal cancer among those with intakes of NDMA in the first (reference), second, third, and fourth quartiles were 1, 1.47 (0.69-3.11), 1.95 (0.95- 3.99), and 2.12 (1.04-4.33), respectively (P = 0.47 for trend). 12Estimated exposure would be higher if the population is assumed to be exposed continuously to the maximum concentration of NDMA in indoor air (see Table 2). 13 Additional information on calculation of the TDQ5 is presented in Appendix 4. 14NDMA was not detected in a single survey of ambient air not impacted by point sources. 15Les nouvelles donnees notees par les auteurs et obtenues par un depouillement de la litterature effectue avant la reunion du Comite d' evaluation finale ont ete examinees compte tenu de leur influence probable sur les conclusions essentielles de la presente evaluation, le but etant avant tout d'etablir si leur prise en compte serait prioritaire lors d'une prochaine mise a jour. Les auteurs ayant estime qu'elles apportaient des elements d'information supplementaires, on a ajoute des donnees plus recentes encore que non essentielles pour la caracterisation des dangers ou Fanalyse des relations dose-reponse. Se ha incluido nueva informacion destacada por los examinadores y obtenida en una busqueda bibliografica realizada antes de la reunion de la Junta de Evaluacion Final para sefialar sus probables repercusiones en las conclusiones esenciales de esta evaluacion, principalmente con objeto de establecer la prioridad para su examen en una actualization. Se ha anadido informacion mas reciente, no esencial para la caracterizacion del peligro o el analisis de la exposition- respuesta, que a juicio de los examinadores aumentaba el valor informative. See Also: Taxi cologica 1_ Abbr evi ation s N i t r o sod i me t h yJLam i ne , n - _( I CSC) Nitrosodimethylamine, N- (IARC Summary & Evaluation, Volume 17, 1978) http://www.inchem.org/documents/cicads/cicads/cicad38.htm 6/9/2006 Exhibit 6 Berkeley College of Engineering - URO Project Info Page 1 of2 Contact Us Search Site Map Give to Engineering Civil and Environmental Engineering URO Project Professor David Sedlak 609 Davis Hall NDMA Formation in Desalination Systems Nitrosodimethylamine (NDMA) is a potent carcinogen that can be formed when water is disinfected with chlorine. The organic compounds that act as precursors of NDMA have not been identified; however, if these compounds are present in seawater then NDMA could be formed when seawater is chlorinated prior to desalination. The presence of NDMA precursors in seawater could pose significant challenges to the many desalination programs proposed throughout the world. The purpose of this research project is to assess the formation of NDMA in seawater and estuarine waters. The student will learn how to use gas chromatography/tandem mass spectrometry to measure NDMA. The student also will learn how to conduct studies on the partitioning and biotransformation of NDMA precursors. Preference will be given to students with a strong background in chemistry. The project may continue through the summer of 2006 and opportunity for continued participation during the spring semester and summer are possible. Quick Links URO Info & Forms • URO Home Page • News • How to get involved in research & find a URO position • URO projects • Names of selected • I've been selected. Now what? • FACULTY forms (signup, etc.) & timeline of action items . STUDENT forms (application, etc.) & timeline of action items • How do I get my stipend? • Frequently asked questions • Comments • y RQcoord inator contact info • OtherResearch Qrjppjtynjties (link to outside UCB research site) To find something on the URO site, please click the "Search" link on the left menu bar. (Please note that this feature searches the whole coe.berkeley.edu domain, rather than just the URO domain.) Current Students | College & University Resources | Engineering News | Academic Departments | Student Societies | Advising | Page updated 7/21/05 http ://www. coe .berkeley. edu/current_students/uro/sedlak .html 6/9/2006 Berkeley College of Engineering - URO Project Info Page 2 of 2 Career Development | Senior Class Gift UC Berkeley © UC Regents Privacy Statement Feedback http://www.coe.berkeley.edu/current_students/uro/sedlak.html 6/9/2006 00-0£.JP MM, HMPP JUN 1 3 2006 CITYO CITYCL F CARLSBAD ERK'S OFFICE