Aquabiotics Corporation

PO Box 10576

Bainbridge Is, WA 98110

206/842-1708; fax: 206/842-7266

E-mail: Aquabiotics@gmail.com

Lance Wormell, Chemical Review Manager

US Environmental Protection Agency (7508C)

Office of Pesticide Programs

1200 Pennsylvania Ave NW

Washington, DC 20460

November 6, 2006

Dear Lance:

Attached are the documents you sent to me on October 2, 2006, with
comments added from Steve Moore, Bruce Rosenlund, and from me.  I have
no problems or comments concerning confidential business information. 
We have noted some misspellings and errors.  We have also included
comments and suggestions.

Comments in the attached documents are identified by:

MKR—Mary K. Romeo, President, Aquabiotics Corp.

BR—Bruce Rosenlund, CO Fish & Wildlife Mngmnt Assistance, 134 Union
Blvd, suite 675, Lakewood, CO 80228-1807, 303-236-4255.  He is
Fintrol’s most experienced user.  He has consulted in treatments
around the U.S.

SM—Steve Moore, Supervisory Fisheries Biologist, Great Smoky Mountains
National Park, 107 Park Headquarters Road, Gatlinburg, TN 37738, 865 436
1250  His experience with Fintrol is in treatments on the east coast
(deciduous forests) and in the National Parks.

I’d like to mention a few things we commented on.

As noted in the documents, Bruce Rosenlund is concerned about confusion
in the documents as to the difference between antimycin A percentages
and Fintrol percentages.  As EPA knows, but is not clear in the
documents, A Fintrol Fish Toxicant Kit contains a bottle of concentrate,
which is 23% w/w (20% weight/volume) antimycin A.  Applicators will be
dealing with it at this concentration, but because antimycin does not
solubilize in water, the concentrate must be mixed with the included
diluent before application.  This solubilizes it (antimycin will not
kill fish until it is solubilized); now the liquid has a concentration
of 10% weight/volume antimycin A.  Then, the label states it is to be
mixed in at least 5 gallons of water to help mixing, further reducing
the percent active ingredient antimycin A, as it is applied in the
environment.  (Because of the density, the weight/volume and
weight/weight percentages are different, which causes confusion to
readers; we use the weight/volume figures so our applicators can easily
calculate the application rates in volumes of water.)

Bruce says, “If Fintrol is 23% active ingredient antimycin, then that
should be stated at the start of each document, and after that, Fintrol
should be used for all references to applications.”

As I commented on p. 16 of the EFED report, in contrast to what it
states, I believe most Fintrol aquaculture use is for adult scaled fish;
a smaller portion is for fingerling production ponds.  I have been told
that my sales to catfish farmers will be very limited if a one-year hold
time is required.

Regarding p. 19 of the EFED report: “Another difficulty is that there
are comparatively little EPA-guideline fate data available for
evaluation of the fate of antimycin A in the environment.  The
registrant has submitted only a hydrolysis and an aerobic aquatic
metabolism study, both of which the EPA classified as providing only
supplemental information and not fulfilling the data requirement.” 
Former Aquabiotics President Nick Romeo and I never heard that these
studies did not fulfill the data requirement.  Nick worked with EPA &
ABC Labs to design these studies according to what EPA wanted.   Why are
you now not satisfied with them?  

I will send you by mail, a copy of these reports. 

Sincerely,

Mary K. Romeo

President

