ECOSYSTEM RESTORATION TOXAWAY CREEK AREA by liaoqinmei

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									            ECOSYSTEM RESTORATION, TOXAWAY CREEK AREA
              Andrew Pickens Ranger District, Sumter National Forest
                         Oconee County, South Carolina

This document is tiered to the Sumter National Forest Land and Resource Management
Plan (LRMP) and the Environmental Impact Statement for Vegetation Management in
the Appalachian Mountains (VMEIS).

TABLE OF CONTENTS

CHAPTER I. PURPOSE AND NEED
  A. Need for Proposal
  B. Proposal
  C. Existing Conditions
  D. Desired Future Condition
  E. Scope and Timing
  F. Location of Analysis Area
  G. Issues
  H. Responses to Issues

CHAPTER II. ALTERNATIVES
  A. Alternatives
  B. Mitigation Measures

CHAPTER III. ENVIRONMENTAL ANALYSIS
  A. Effects on Soils and Soil Productivity
  B. Effects on Water Quality and Aquatic Habitats
  C. Effects on Air Quality
  D. Effects on Vegetation and Forest Communities
  E. Effects on Management Indicator Wildlife Species (MIS) and Wildlife Habitats
  F. Effects on Proposed, Endangered, Threatened, and Sensitive Species (PETS)
  G. General Information about Triclopyr and Imazapyr
  H. Consequences to Environment
  J. Consequences to Humans and Animals
  I. Heritage and Recreation Resources
PURPOSE AND NEED

A. Need for Proposal

The proposed action is needed to restore Woodland and Table Mountain/Pitch Pine
Forest Communities in the Toxaway Creek Area.

The need for ecosystem restoration in the Toxaway Creek Area presents the opportunity
for the Southern Research Station of the U.S. Forest Service to monitor and conduct
research on the recovery methods proposed herein.

Woodland and Table Mountain/Pitch Pine Forest Communities are defined in the
Southern Appalachian Assessment (SAA) in Appendix C, Rare Community Descriptions,
Report 5 of 5. As stated on Page 185 (SAA), this communities occur on sharp ridges,
steep slopes, southern aspects, knobs, low elevation peaks, and may consist of shortleaf
pine, Virginia pine, and scarlet oak. In the absence of periodic fire, Woodland and Table
Mt./Pitch Pine Communities decline and, over time, may vanish.

A need exists to create areas for propagation of wildflowers and woodland forbs,
including the possible introduction of an endangered species, smooth purple coneflower.
With the aid of volunteers and the resources available at the Southern Research Station
at Clemson University, seed from this rare wildflower, and other woodland species,
would be collected and grown on suitable sites in the Toxaway Creek Analysis Area.

B. The Proposal

The Proposal consists of 5 actions, including:

   Herbicide Injection, 92 acres
   Prescribed burn (between East and West Toxaway Creek) repeated every 5 years, 630
    acres
   Foliar herbicide spray, 92 acres
   Native forb and grass seeding, 92 acres
   Day lighting and planting Road 2748 as linear wildlife strip, one mile

Herbicide Injection, 92 acres – Herbicide is injected under the bark of non-commercial or
low quality Virginia and loblolly pines and hardwoods. The herbicide Garlon 3A would
be injected using hack and squirt, hydro axes, or other similar methods on locations
where Woodland Communities are in decline or have been lost due to exclusion of fires
or due to past insect infestations (Refer to project scooping map for locations).

The bark of trees selected for injection would be frilled and a metered portion of Garlon
3A placed inside and just under the bark around the tree’s circumference at 3 inch
intervals. The herbicide application would follow EPA labeled instructions. Stocking
within the 92 acres would be reduced from the current 80 to 100 square feet of basal area
to 40 to 50 square feet of basal area per acre (BA/Ac). Pines with diameters less than 11
inches measured at chest height (DBH) and hardwoods of low quality (less than sawlog
grades) would be injected.

Prescribed Burn, 630 acres – Following the injection treatment, the area between East
Toxaway and West Toxaway Creeks would undergo a prescribe burned. Both creeks
would provide most of the fires control lines during prescribed burning. Fire lines
constructed by bulldozer, would occur in two locations as shown on the attached map.

Foliar herbicide spray, 92 acres – One to two years beyond the prescribed burning, a
foliar herbicide would be applied with backpack sprayers. The spray would be directed
onto foliage of sprouting shrubs and deciduous vegetation, including mountain laurel,
Red Maple, yellow poplar, blackgum, and other species currently encroaching onto the
92 acres of Table Mountain Pine and Woodland Sites. The herbicide application rate
would follow EPA label instructions. The herbicide would be intermittently applied with
backpack sprayers on the 92 acres shown on the scoping letter map. No treatment will
occur within 30 feet of any ephemeral drain, intermittent stream, or perennial waterway.

Native forb and grass seeding, 92 acres – The native forbs and grasses associated with
woodland habitats would be purchased from commercial seed nurseries and broadcast
over the 92 acres. The only known occurrence of Buffalo Clover, a species adaptive to
woodland habitats, in Oconee County exists near the Toxaway Creek Area, and seed
from these plants may be sown on the 92 acres. Table Mt. Pine seedlings would be
planted within the 92 acres where this species has recently been killed by s, on other
suitable sites where Table Mt. Pine is in decline, and on suitable sites where the species is
absent.

Day lighting and planting Road 2748 as linear wildlife strip, one mile – For a distance of
one mile, starting at the point where Road 2748 leaves the injection area, trees would be
thinned using chainsaws or hand tools to expose the road to sunlight to a depth of 50 feet
on either side of the road. Half of the basal area would be removed within the 50-foot
zone. The road surface would be disked and planted with various mixtures of seed and
fertilizer providing forage and browse for a wide range of wildlife

C. Existing Conditions

Approximately 34 percent of national forest lands in the Toxaway Creek Area are 46
years old. This large area of even-aged forest stands resulted from the 1954 Brasstown
Wildfire and subsequent salvage and reforestation efforts. The Brasstown Wildfire
burned and killed several thousand acres of timber, mostly confined to the Toxaway
Creek Area. After being salvaged, the Table Mountain Pine stands and mixed stands of
Shortleaf/Pitch pine and Upland Oak/Hickory reverted through natural seed fall to near
pure stands of low quality Virginia Pine. Fragmented remnants of Table Mountain/Pitch
Pine Communities exist in these areas and are in noticeable regression from
encroachment of off-site vegetation and recent infestations of s.
D. Desired Future Condition

Table Mt./Pitch Pine Communities and Woodland Savannahs would be reintroduced into
the Toxaway Creek Area.

The Nature Conservancy defines Table Mountain/Pitch Pine Communities and Woodland
Savannahs as “Open stands of trees with crowns not usually touching (generally forming
25 to 60 percent cover).”

The Southern Appalachian Assessment identifies Table Mt./Pitch Pine and Woodland
Savannahs as rare. The restored communities in the Toxaway Creek Area would be
maintained by periodic prescribed fire on exposed, sharp ridges, while plants associated
with woodland habitats would be established, including those uncommon to this area
such as Big Bluestem, native clover, legumes, and wildflowers associated
woodland/savannahs. The assemblages of wildlife, that associate with
woodland/savannahs, including Bob White Quail, Blue Birds, Wild Turkey, and Prairie
Warblers, would be restored onto their former habitats.

E. Scope and Timing

The actions considered herein are limited to rare forest community restoration and road
closure and wildlife linear strip planting. These actions in the selected alternative will be
implemented 45 days beyond the issuance of a final decision.

F.     Location of Analysis Area

The Toxaway Creek Area forms one self-contained watershed primarily drained by East
and West Toxaway Creeks. The defined analysis area exists west of Federal Highway
76, 8 miles west of the town of Westminster, and between Longcreek and Holly Springs
Communities. Prominent land features in the Toxaway Area include Rockhouse
Mountain, and East Toxaway and West Toxaway Creeks. The area is bordered by
Highway 76 on the east boundary, Little Longnose Mt. Road on the west boundary,
private lands on the south boundary, and Spy Rock Road (Rd. 748) west of Highway 76
on the north boundary.

G.   Issues

A scoping letter dated April 2, 2000, and mailed to 112 persons and organizations,
notified the public of the proposal to restore Woodland and Table Mt./Pitch Pine
Communities. The letter outlined the ecosystem restoration proposal in detail. Issue #1
was determined significant and resulted in development of Alternative 3. Respondents’
issues follow:
Significant Issues:

1. Converting restored Road 2748 into a linear wildlife strip would have negative effect
on the biotic integrity for terrestrial and aquatic ecosystems, causing fragmentation and
degradation of the intact interior forest. The benefits of a linear wildlife strip are
provided on adjacent private lands.
Response: Alternative 3 is developed to respond to this issue. Road 2748 would not be
converted into a linear wildlife strip. In its place, Road 748 would be closed at its
junction with 748K and managed as linear wildlife strip.

2. Arsenal is highly persistent in soil.
Response: This issue is analyzed in the EA Chapter III, in the section titled
“Consequences on Environment”. The unit of measure used to evaluate this issue is the
half-life of Imazapyr once applied in normal rates and under typical conditions.

3. Arsenal is mobile in water tables and threatens water supplies of people living in the
area.
Response: A unit of measure applied to analysis in this EA will be based on research
findings documenting herbicide mobility in ground water. The analysis is located in
Chapter III, in the section titled “Consequences on Environment”.

4. Triclopyr is mobile in water and may be found in streams, rainwater, and groundwater
following application.
Response: This issue is analyzed in EA in Chapter III, in the section titled
“Consequences on Environment”. The unit of measure used to analyze this issue will be
based on research findings in publications that document analysis of water samples taken
on herbicide application sites.

Non-Significant Issues:

5. The SCDNR expressed concern for species dependent upon early succession with
specific mention of bobcat, fox, and Black Bear. The respondent suggests lowering basal
area more than called for in Alternatives 2 to 4 and conducting commercial timber
harvests to achieve desired conditions and eliminating herbicide injecting.
Response: This issue is non-significant since the timber on the 92 acres targeted for
treatment is below operable standards for a commercial timber harvest. Once
encroaching vegetation is killed on the 92 acres, the area will retain grass and forb
characteristics of early succession. Prescribed fire, applied periodically, will retain this
habitat condition.

6. Endangered species could be at risk from use of Arsenal.
Response: There are no endangered species in the Toxaway Creek Area, therefore, its
highly unlikely that any alternative could adversely affect an endangered species. See
EA “Effects on PETS” section.
7. Arsenal retards or kills farmers’ crops.
Response: This issue was considered non-significant since there are no commercial
agricultural operations near the Toxaway Area.

8. Arsenal would harm residual trees.
Response: The respondent did not provide sufficient information to fully address this
issue, not stating which trees, in what locations, and in what manner the respondents feels
residual trees would be harmed. Herbicide injection is one of the safest methods to direct
and hold herbicide on the host tree because the herbicide is placed inside frilled bark.
Little to no herbicide could leave the vegetation being targeted with injection. Residual
trees could not be harmed by foliar spray since spraying would be directed at ground
level vegetation where tree canopies cannot be affected.

9. Arsenal is a health risk to Forest Service employees.
Response: The respondent did not identify how or why they believe Forest Service
employees are at risk. If Arsenal posed a substantial health risk, it is unlikely that the
product could have been registered with the EPA. The analysis contained herein is
limited to health risks when applied under typical conditions. See analysis in EA,
“Consequences to Humans and Animals” section.

10. Arsenal has potential to have impact on the health of neighboring human populations.
Response: The respondent has not identified how they feel herbicides would leave
Forest Service lands where it is prescribed for application, nor how application on Forest
Service lands could have adverse affects on humans living miles away. There are no
private homes near the proposed treatment site. To affect neighboring private lands, the
herbicides being prescribed under Alternatives 2 and 3 would have to travel long
distances, a highly unlikely probability. See analysis in EA, “Consequences to Humans
and Animals” section.

11. Early successional species such as Sweetgum, Red Maple, and Elm, will reoccupy the
area with succession and will be the first species to colonize the area following treatment.
This would lead to the need to repeat treatments, merely perpetuating a dangerous
addiction to herbicides.
Response: This issue is non-significant since analysis cannot be conducted concerning
species unrelated to the analysis area. Elm does not exist, and Sweetgum is rare, on the
Andrew Pickens Ranger District. Neither species exists in the Toxaway Creek Area.

12. The timber sale would lose money and Forest Service should not cut the seed trees.
Response: No logging proposed.

13. The amount of Triclopyr being prescribed is a lethal dosage to animals eating treated
vegetation. Just one ounce would kill an adult human.
Response: This issue is considered non-significant since such a scenario is not possible.
Triclopyr has no lethal risk unless wildlife are forcibly fed Triclopyr at full strength. See
EA Chapter III, “Consequences in Humans and Animals” section.
14. Triclopyr may be permanently stored in body tissues.
Response: EA Chapter III, “Consequences in Humans and Animals” section was taken
from research publications and the VMEIS. These publications indicate that neither
herbicide prescribed herein has tendency to bioaccumulate. Therefore, there is no means
for measuring bioacummulation.

15. There are no studies of the chronic toxicity of Triclopyr products nor its varied
components.
Response: This issue is considered non-significant since toxicity studies of Triclopyr
and its varied components are readily available from several research institutions.
Relevant parts of these same studies are used in the analysis in Chapter III.

CHAPTER II. THE ALTERNATIVES

A.      The Alternatives

Alternative 1, No Action – There would be no actions taken with further project planning
to take place at future time.

Alternative 2, The Proposed Action – Alternative 2 includes all those actions stated above
in Chapter I, “Proposal” section.

Alternative 3 – This alternative is essentially the same as Alternative 2 with two
exceptions. First, Road 2748 would not be day lighted and converted into a linear
wildlife strip. In its place, the last ¾ mile of Road 748, currently an open public road,
would be gated. The future use of this ¾ mile of Road 748 would be a conversion to a
linear wildlife strip. Secondly, if Alternative 3 were implemented, native plants
associated with woodland ecosystems would be grown from seed and planted in restored
Woodland and Table Mountain Pine Communities.

Alternative 4 – The 92 acres prescribed under Alternatives 2 and 3 with herbicide
injection and prescribed burning would be felled and burned under Alternative 4. The
same 92 acres of trees and vegetation prescribed with herbicide treatment under
Alternatives 2 and 3 would be cut using chainsaws or hand tools. The felled and burned
area would be planted to Shortleaf and Table Mountain Pine seedlings. No herbicides are
prescribed under Alternative 4.

Road 748, currently an open public road, would be gated at its junction with Road 748K.
The future use of this ¾ mile of Road 748 would be converted into a linear wildlife strip.

     B. Mitigation Measures

Some key sources that direct the implementation of mitigation measures include:
      VMEIS, The Environmental Impact Statement for Vegetation Management
              in the Appalachian Mountains
      SAA, The Southern Appalachian Assessment
       BMP’s, South Carolina’s Best Management Practices for Forestry
       LRMP, The Sumter Forest Land and Resource Management Plan

The implementation of mitigation measures in the Toxaway Creek Area may include, but
are not limited to, the following:

Mitigation of impact on Proposed, Endangered, Threatened, and Sensitive (PETS) for
such listing are afforded through the evaluation and documentation in the Biological
Evaluation (BE). The BE is prepared by biologists, and the BE examines the actions and
effects or risks to various levels of protected or rare species. The BE is available for
public review upon request.

Historic and prehistoric resource of significance are preserved as recommended by
documents prepared by the South Carolina’s SHPO and by Forest Service archeologists.
Each location with proposed ground-disturbing activities are tested, and results are
documented in cultural resource reports. The procedures used to determine whether or
not cultural resource sites are present, to assess their status under the National Historic
Preservation Act (NHPA), and to analyze protection measures for them are documented
in the report before soil disturbing actions occur. The treatment sites under each
alternative have been surveyed or otherwise assessed, and SHPO agreement has been
received.

Dead standing trees (snags) important for wildlife will be retained, (LRMP< page L-1
and page 17 to 19 of the Process Record for selection of Indictor Species and Their
Management Needs).

All wildlife den trees important to cavity nesting or dwelling species will be retained
(LRMP, page IV-4).

In compliance with the Clean Water Act, the South Carolina Forestry Commission
established best management practices for use during forestry related work. The
Commission’s handbook South Carolina’s Best Management Practices for Forestry is
the basis for conservation of soil and water resources during forestry-related practices.
The guidelines are designed to reduce non-point source water pollution and to protect
fisheries, aquatic habitats, and recreation. At a minimum, the actions described herein
will adhere to the State’s BMP’s. Copies of the State BMP’s may be reviewed at the
Andrew Pickens Ranger District office.

Health and Safety Code (11-1-99) at 22.11b specifies directions for pesticide application
and states, “Employees involved in pesticide work shall use the personal protective
equipment (PPE) as specified by the product label, material safety data sheet (MSDS),
and JHA (job hazard analysis). Refer to directions in 21.13 and 21.22 for identifying
PPE in the JHA."

The PPE requirements for pesticide application shown on pesticide labels may include:
      1. First Aid Kits
       2. Hand Protection
       3. Eye/Face protection
       4. Head/hearing Protection
       5. Respirator
       6. Chemical-Resistant Garments - Use chemical-resistant, disposable coveralls
(temperature permitting) and waterproof lower leg protection (for spraying on hot days)
to prevent chemical herbicide absorption through clothing.

The guiding documents emphasized in the direction are the label/MSDS/JHA. These
documents dictate the required worker protection and PPE for a particular pesticide
product application.

CHAPTER III. ENVIRONMENTAL ANALYSIS

   A. Effects on Soils and Soil Productivity

       Direct Effects (Soils and Soil Productivity)

              Alternative 1

              Under Alternative 1, actions would be deferred to a later time; therefore,
              no disturbances to soils or soil productivity would occur.

              Alternative 2

              Alternative 2 is the proposed action and is limited to herbicide
              applications, prescribed fire, and the day lighting and plowing of Road
              2748. There would be no soil disturbance associated with herbicide work;
              therefore, no soil erosion is associated with this activity. During
              prescribed burning, 1.5 miles of firebreaks, about 8 feet wide, and bladed
              into mineral soil, would be constructed with a bulldozer. Firebreaks have
              some potential to cause soil erosion but only in isolated locations. The
              erosion from the 1.5 miles of firebreaks would be too small for estimating
              soil displacement weights. Forest Road 2748 is a closed road mostly
              overgrown with saplings, is overtopped by a closed forest, and has the
              appearance of being obliterated in the past. Reopening of this road would
              create some localized erosion and deposition into the surrounding forest
              area. No sediment is expected to reach nearby forest streams. Soil
              erosion from the reopening for Road 2748 would cause a negligible
              amount of erosion and the estimated weight of sedimentation would be too
              small for computation. Soil erosion under Alternative 2 is inconsequential
              and would have no effect on soil productivity.

              Alternative 3
       Alternative 3 is essentially the same as Alternative 2 with one exception.
       Rather than converting Road 2748 into a linear wildlife strip, the open
       Road 748, starting at the junction with Road 748K, would be closed to
       year round traffic and converted into a linear wildlife strip. The effects on
       soil erosion and soil productivity would be the same as under Alternative 2
       with no substantial effects on soil productivity.

       Conditions would be created for propagation of wildflowers and woodland
       forbs, including the possible introduction of an endangered species,
       smooth purple coneflower. With the aid of volunteers and the resources
       available at the Southern Research Station located at Clemson University,
       seed and plants adapted to woodland/savannahs would be collected and
       planted.

       Alternative 4

       Under Alternative 4, the fell and burn actions would have essentially the
       same effects as Alternatives 2 and 3 since the only ground disturbing
       activity is associated with fire line construction. The difference under this
       alternative would be in the prescribed burning intensity.

       Prescribed burning under typical soil conditions consumes very little leaf
       duff as only the upper loose leaves are burned. Erosion caused by
       prescribed burning is usually associated with fire line construction. In the
       Toxaway Creek Area, there are several opportunities to take advantage of
       natural fuel breaks in the form of creeks and roads. Using creeks and
       roads adds further mitigation to those measures (seeding and water bars)
       to control runoff from fire lines. The application of prescribed burning
       under Alternative 4 would result in larger amounts of slash piles burning
       than the previous 2 alternatives. This would lead to larger areas of mineral
       soil exposure, not expected to exceed 15 percent of the total burned area.
       The increase in exposed mineral soil is not likely to cause more than a
       negligible increase in erosion.

Indirect Effects (Soils and Soil Productivity)

       There are no indirect soil erosion and soil productivity effects expected
       under any alternative.

Cumulative Effects (Soils and Soil Productivity)

       The Sumter Forest Plan Revision will be used as a basis for estimating
       future actions. The Plan Revision, in its current stage of development,
       would place the Toxaway Area in a location where mid- to late
       successional forest stages would be emphasized. Timber sales would be
       small and few in number. Past actions, which may have bearing on
         cumulative analysis of erosion and soil productivity are limited to existing
         open roads. No vegetation management or timber sales are anticipated
         beyond what is considered in this EA. It is more likely that roads in the
         Toxaway Area may be reduced or obliterated in the future, and timber
         sales would occur in areas other than the Toxaway Creek Area.

         Alternative 1

         The No Action Alternative would cause no adverse cumulative effects on
         soil erosion or soil productivity.

         Alternatives 2, 3, and 4

         Soil erosion would be reduced since the end of Forest Road 748 or 2748
         would be closed to year-round public traffic when reverted to a linear
         wildlife strip. When planted to wildlife forage, the bare road surfaces
         would attain a protective vegetative barrier, mitigating the erosion of fine
         road materials. There would be no adverse cumulative effects on erosion
         or soil productivity. In the long-term, positive cumulative effects are
         anticipated with the reduction of open system roads.

B. Effects on Water Quality and Aquatic Habitats

   Direct Effects (Water Quality and Aquatic Habitats)

         Alternative 1

         Under the No Action Alternative, there would be no change in water
         quality or aquatic habitats.

         Alternatives 2, 3, and 4

         The actions proposed which could have effects on water quality or aquatic
         habitats in East and West Toxaway Creeks would be limited to
         construction of fire breaks during prescribed burning and application of
         injected and foliar applied herbicides. The manual cutting and felling of
         vegetation under Alternative 4 is not anticipated to cause any change in
         water quality or aquatic habitats. However, manual cutting or felling prior
         to prescribed burning may increase the effective intensity of the controlled
         burning.

         Prescribed Fire – Prescribed burning has the potential to increase stream
         nutrients, storm flows, and sediment loads. In general, the amount of
         increase would depend on fire severity. Severity is determined by the type
         of fuels being burned and the prevailing weather and burning index for the
         forest fuels existing on the forest floor.
Under Alternatives 2 and 3, burning intensity would be mitigated by the
absence of slash piles; thus, no increase of fuel loading would occur. Fuel
loading remains essentially the same as before injection since the fuels in
the canopy remain aloft and out of reach of ground level flames. The
under burns would be carried through the area as they consume leaves.
Some fuels types, such as saplings and shrubs, would add to the burning
intensity. Fires of this type are considered moderate to light and have
negligible effects on storm flows. Moderate prescribed burns expose little
surface soils and have few effects on surface erosion. Moreover, the
injection is confined to upper ridge locations, providing at least a 300-foot
buffer between perennial streams and the injected area. The 92 acres of
treatment area are even further removed from East and West Toxaway
Creeks. No herbicide treatment would occur within 30 feet of ephemeral
drains. According to the VMEIS (Page IV-114), sediment increases are
minor when slash burns are not used and filter strips along streams are
employed. Aquatic habitats are unlikely to be negatively affected by
Alternatives 2 and 3.

Herbicide Injection and Foliar Spraying – Three herbicides are prescribed
under Alternatives 2 and 3, Garlon 3A, Garlon 4, and Arsenal AC. The
first two contain the same active ingredient, Tricolpyr; the former contains
an amine formula and the latter an ester formula. Garlon 3A is prescribed
herein by itself at full strength and injected under the bark of targeted
vegetation. Garlon 4 is diluted in water with a leaf sticking agent (Cide-
Kick) and a smaller amount of Arsenal AC added. The active ingredient
in Arsenal AC is Imazapyr.

There is little likelihood that any of the herbicides proposed under
Alternatives 2 and 3 would be found in streams or aquatic habitats since
applications are confined to the upper most ridgetops. At least 300 feet of
buffer would exist between proposed herbicide areas and perennial
streams and 30 feet from ephemeral drains. Most proposed treatment
areas will lay farther than 300 feet from perennial streams. No adverse
effects on streams in the Toxaway Area are anticipated.

Effects on aquatic habitats or animals would not occur since herbicides are
not planned nor proposed for use near perennial streams. With the
aforementioned buffers existing, herbicides are diluted to 0.001 PPM long
before reaching any perennial stream. Effects on aquatic habitats or
animals are not expected.

The herbicides considered in Alternatives 2 and 3 have little chance of
leaching into groundwater. Tricolpyr photodegrades rapidly and is
metabolized by bacteria. Its half-life is less than 10 hours in water. It is
moderately soluble and not strongly absorbed in the soil. Studies indicate
      that Triclopyr does not present a leaching problem under normal use.
      Imazapyr has a low adsorption coefficient and an intermediate half-life of
      19 to 34 days. It is degraded by microorganisms, photodecomposes, and
      does not bioaccumulate.

      Alternative 4

      Slash loading on the forest floor would increase due to chainsaw felling
      and hand tool cutting on the 92 acres of treatment area. This would
      become a factor during prescribed burning, leading to potentially intense
      fire. Such fires would expose more mineral soil than any other alternative
      considered herein. Most organic material is consumed where slash piles
      have been created. Channel sediment may increase in proportion to
      average peak flow, with first year estimates about 40 percent for moderate
      slash burns and up to 200 percent for severe slash burns. Firebreaks
      would be constructed with a bulldozer that blades 1.5 miles of lines to bare
      soil. Fire line construction would generate soil erosion but is substantially
      mitigated with application of BMP’s, and other measures that reduce
      erosion to moderate levels. Mitigating measures would include installing
      water-diverting earthen berms during fire line construction and applying
      seed and fertilizer to establish a vegetative cover. Fire line construction
      near streams or to floodplains would be carefully installed in order to
      prevent entry of sediment in nearby streams. Given the attention of
      mitigation measures, erosion and sediment would be negligible, and water
      quality and aquatic habitats would be mostly unaffected under Alternative
      4.

Indirect Effects (Water Quality and Aquatic Habitats)

      None of the alternatives are expected to have an indirect effect on water
      quality or on aquatic habitats.

Cumulative Effects (Water Quality and Aquatic Habitats)

      In the past 10 years, there have been no herbicide treatments in the
      Toxaway Creek Area. Herbicides may be used in the future, but only after
      several years have passed since the application of a selected alternative
      being considered herein. Given the half-life and relatively fast
      decomposition of the herbicides proposed, there is no chance that present
      actions would combine with those in the future to create a negative
      cumulative effect on water quality or on aquatic habitats.

      Prescribed burning may be reapplied 5 to 10 years after the initial
      prescribed burning outlined under Alternatives 2 and 3. The minor
      amounts of erosion or sediment generated under Alternatives 2 and 3
      would persist for no more than 3 years beyond the first prescribed burn.
          Therefore, the second application of prescribed fire on a 5 to 10 year
          rotation would not lead to a negative cumulative effect on water quality or
          aquatic habitats.

          Under Alternative 4, no further actions are predicted within 10 years. If
          Alternative 4 were implemented, there would be immediate response with
          thicker and shrubby conditions replacing the successional stages of grasses
          and forbs. This shrubby regrowth, if prescribed burned within 10 years,
          would generate fire intensity capable of killing timber. Under Alternative
          4, no adverse cumulative impacts are expected.

C. Effects on Air Quality from Prescribed Burning

   Direct Effects (Air Quality)

          Prescribed fire is the only activity being proposed which emits substantial
          amounts of gases and particulates into the atmosphere. This is largely
          mitigated by following planned smoke management guidelines which
          reduce impacts by enhancing flaming, reducing smoldering, and
          prescribed burning during atmospheric conditions that favor smoke
          dispersion. Detailed burning plans for the Toxaway Area will be prepared
          calling for conditions where smoke dispersion has the least effect on the
          public.

   Indirect Effect (Air Quality)

          No indirect effects on air quality are expected.

   Cumulative Effects (Air Quality)

          No cumulative effects on air quality are expected.

D. Effects on Vegetation and Forest Communities

   Direct and Indirect Effects (Vegetation and Forest Communities)

          Alternative 1

          Southern Pine Beetle infestations and the absence of prescribed buring fire
          would continue to have negative impact on Woodland and Table
          Mountain/Pitch Pine Forest Communities of the Toxaway Creek Area.
          Table Mountain Pine Communities would continue to decline due to
          beetle infestations and vegetation encroachment. In the long-term, and
          under Alternative 1, Table Mountain Pine may disappear from the
          Toxaway Creek Area.
Alternative 2

The proposed herbicide treatments and prescribed burning would have
marked changes on the 92 acres of upland sites. The injection would kill
smaller low quality and sub-merchantable trees, which, in recent years
have encroached upon and have begun threatening the sustainability of
Table Mountain Pine and Woodland Communities. The follow-up
treatment of prescribed burning would further decrease the amount of
woody vegetation suppressing these communities. After treatment
application, sunlight reaching the forest floor would increase, and
encroaching vegetation such as Mountain Laurel, Blackgum, Yellow
Poplar, and other light seed species would retreat down slope from the 92
acres of former woodland sites. Upland oaks, such as Blackjack, Southern
Red, and Post Oaks, which commonly associate with woodland
conditions, would be retained. Sprouting woody vegetation would be
treated with a foliar herbicide spray, further suppressing most deciduous
vegetation on woodland sites. Table Mountain Pine seedlings would be
reintroduced to the Toxaway Area, while the seed of native grasses and
forbs adaptive to woodland sites would be broadcast and grown in the
area. The existing canopy on the 92 acres dominated by heavily stocked
46-year-old Virginia pine would be replaced with a Savannah/Woodland
ecosystem.

The injection with Triclopyr and foliar spraying of Triclopyr and Imazapyr
would occur on the 92 acres at a considerable distance from private lands,
no closer than 1/5 mile over most of the treatment area. There is one
exception. The northern most part of the 92-acre treatment area borders
upon a small private apple orchard. The apple orchard is not managed for
commercial production. Many trees in the orchard are dead, and the
orchard does not receive annual maintenance nor is it closely managed. In
this area, the herbicide treatments would not affect the apple orchard since
spray drift residues from personal backpack sprayers are used to direct
herbicide spray onto the targeted plants, usually no farther away than 3 to
4 feet. Spray drift is normally associated with application from aircraft, or
to a lesser degree, application from vehicle mounted boom-spraying
equipment. Application, as prescribed under Alternative 2, does not
produce a spray drift, especially when mitigation measures are followed.
The areas outside the 92 acres would not likely be affected by the
herbicide spraying.

Prescribed fire on the 92 acres would simultaneously occur on 548 acres
between East Toxaway and West Toxaway Creeks (total of 640 acres).
The prescribed fire on the 548 acres would consume mostly leaves on the
forest floor since few other burning fuels exists in the shaded understory.
Outside the 92 acres of herbicide treated area, the prescribed fire would
top kill small woody vegetation in the mid- and understory, limited to
saplings and shrubs generally less than 3 or 4 inches in diameter
(measured at DBH). This would have the effect of increasing wildlife
browse beneficial to white-tailed deer. The dominant forest canopy on the
548 acres would be largely unaffected by controlled burning.

The day lighting and conversion of Forest Road 2748 into a linear wildlife
strip would have the effect of reducing mid/understory stocking and
increasing sunlight reaching this closed primitive road. The roadbed
would be planted with wildlife forage on an annual or semiannual basis.
The pine saplings and lower vegetation existing on the roadbed would be
replaced with a plowed surface and periodic planting and fertilizing of
clovers and grasses. Within 50 feet of each side of this road, the
understory vegetation would be injected at the same time that the 92 acres
is treated. The heavily shaded and open understory would become brushy
with growth of briars, forbs, and grasses, a condition desirable for creating
habitat for a wide range of wildlife from neotropical songbirds to white-
tailed deer.

Alternatives 3

The effects on vegetation are essentially the same as Alternative 2 with
one exception. Under Alternative 3, Forest Road 2748 would not be
converted into a linear wildlife strip and remains in its existing condition
as a primitive system road closed to public traffic. The road would be
only temporarily opened for access to researchers studying the effects of
prescribed fire on the Table Mountain Pine sites located at the end of Road
2748. Little change to the existing condition of Road 2748 would occur
while research activities are underway.

In place of day lighting Road 2748, the existing open Road 748, starting at
its junction with Road 748K, would be closed to public traffic and
converted to a linear wildlife strip. Since this road exists next to the
proposed 92 acres of injection and foliar spraying, additional day lighting
would not occur.

The injection with Triclopyr and foliar spraying of Triclopyr and Imazapyr
would occur on the 92 acres well away from private lands, no closer than
1/5 mile over most of the treatment area. There is one exception. The
northern most part of the 92-acre treatment area borders upon a small
private apple orchard. The apple orchard is not managed for commercial
production. Many trees in the orchard are dead and the orchard does not
receive annual maintenance nor is closely managed. In this area, the
herbicide treatments would not affect the apple orchard since spray drift
residues from personal backpack sprayers are used to direct herbicide
spray directly onto the targeted plants, usually no farther away than 3 to 4
feet. Spray drift is normally associated with application from aircraft and,
          to a lesser degree, from vehicles mounted with boom spraying equipment.
          Application, as prescribed under Alternative 3, does not produce a spray
          drift, especially when mitigation measures are followed. The area outside
          the 92 acres would not likely be affected by the herbicide spraying.

          Alternative 4

          The 92 acres and the same vegetation prescribed with restoration under
          Alternatives 2 and 3 would be felled and burned. Prescribed burning on
          the 92 acres would be intense due to the presence of numerous slash piles
          with heavy fuel loading. Shortleaf and Table Mountain Pine seedlings
          would be planted over the 92 acres. An early forest successional condition
          would exist for a period up to 3 to 5 years. Beyond this time, pine
          saplings begin to close canopy and grasses and forbs are gradually shaded
          out. The 92 acres would develop into an even-aged regeneration area. In
          the long-term, a multi-layered sapling and poletimber stand develops with
          a deciduous midstory and grasses and forbs associated with woodland and
          Table Mountain Pine Communities become mostly absent.

   Cumulative Effects (Vegetation and Forest Communities)

          There are no cumulative effects on vegetation anticipated.

E. Effects on Management Indicator Species (MIS) and Wildlife Habitats

          The MIS selected for this project are ovenbird and prairie warbler.

   Direct Effects (Management Indicator Species)

          Alternative 1

          There would be no change in the existing habitat conditions in the
          Toxaway Creek Area. Ovenbirds would continue to be found in the same
          areas as recorded during the last several years during annual breeding bird
          surveys. Prairie warblers decline in the existing regeneration areas where
          the most recent timber harvesting occurred 8 and 10 years ago.

          Alternatives 2, 3, and 4

          Alternatives 2, 3, and 4 would generate similar grass/forb habitat,
          therefore, the effects on both MIS would be the same in the short-term
          (within 3 to 5 years). Ovenbirds would be largely unaffected by the 92
          acres of treatment since they have not been located in these areas in the
          past. Ovenbirds are highly unlikely to forage or nest on the upland sites
          within the 92 acres. Under Alternatives 2, 3, and 4, prairie warblers will
          likely be found in greater numbers on the 92 acres if any of these
          alternatives are implemented.

   Indirect Effects (Management Indicator Species)

          Alternative 1

          Prairie warblers will continue in decline over the Toxaway Creek Area if
          no habitat management occurs in the long-term future. Ovenbirds may
          increase as forest stands continue to age.

          Alternatives 2 and 3

          Since the upland sites proposed for treatment are unsuited for ovenbird
          habitat, there would be little negative impact on interior forest habitats.
          With recurring prescribed burning on the 92 acres of upland sites, habitat
          restored for prairie warblers would likely continue into the long-term.

          Alternative 4

          Prescribed burning would only be planned once to prepare the 92 acres for
          planting of Table Mountain and shortleaf pine seedlings. In order to
          preserve the planted pine seedlings, prescribed burning would not occur in
          the Toxaway Creek Area for another 15 to 20 years after implementation
          of Alternative 4. After 15 to 20 years, saplings would grow large enough
          to survive effects of prescribed burning. As early successional habitat
          conditions begin to decline 3 to 5 years after even-aged regeneration, the
          occurrences of prairie warblers counted during breeding bird surveys are
          also likely to show decline.

   Cumulative Effects (Management Indicator Species)

          The private lands in the vicinity are managed for livestock pasture and
          timber production. To the south and northeast of the Toxaway Creek Area
          are private lands clearcut during the years 1997 to 1999. In the Brasstown
          Creek Valley are several pastures managed for hay production and
          livestock grazing. Although prairie warblers would decline in the
          Toxaway Creek Area over the long-term under the No Action Alternative,
          suitable habitat would persist on many private lands near the Toxaway
          Creek Area over the next 5 to 8 years.

F. Effects on Proposed, Endangered, Threatened, and Sensitive Species (PETS)

   Direct Effects (Proposed, Endangered, Threatened, and Sensitive Species)
         In conjunction with the preparation of this EA, a Biological Evaluation
         (BE) was simultaneously prepared. The BE was preceded by field surveys
         which uncovered the discovery of one sensitive species in the area
         prescribed with treatment under Alternatives 2 to 4.

         Sensitive species are periodically added or removed from the ranger
         district’s list. A new addition is sweet pinesap, a low growing fungus that
         occupies the upland woods. This species occurs in the Toxaway Creek
         Area and other surrounding areas in abundance. Analysis of sensitive
         species concerns reproductive viability. Although the actions under
         Alternatives 2 to 4 may remove some individual plants of sweet pinesap,
         no alternative would have a substantial negative effect on species viability
         for the whole of the Toxaway Creek Area.

         Under Alternatives 2 to 4, conditions would be created for propagation of
         wildflowers and woodland forbs, including the possible introduction of an
         endangered species, smooth purple coneflower. With the aid of volunteers
         and the resources available at the Southern Research Station located at
         Clemson University, seed from this rare wildflower would be collected.
         Smooth purple coneflower plants would be started in a greenhouse nursery
         and volunteers would plant containerized plants or broadcast seed directly
         onto restored woodlands in the Toxaway Creek Area. The same
         opportunity exists to establish other species adapted to woodland
         ecosystems.

         Since no endangered species exist in the Toxaway Creek Area, there
         would be no negative impact on PETS.

   Indirect Effects (Proposed, Endangered, Threatened, and Sensitive Species)

         No indirect effect on PETS is anticipated.

   Cumulative Effects (Proposed, Endangered, Threatened, and Sensitive
   Species)

         Since BE’s will be conducted as new project proposals are made in the
         future, there will not likely be adverse impact on PETS from future
         management activities.

G. Economic Analysis

   Direct Effects (Economic)

         Alternative 1
         The costs associated with implementation of the No Action Alternative
         would be limited to the field surveys by foresters, biologists, and
         administration for the purposes of planning and environmental analysis.
         The planning and cost of this EA is estimated at $5,000.00.

         Alternatives 2 and 3

         The cost of herbicide treatments, including labor, on the prescribed 92
         acres is estimated at $15,000. Prescribed burning of the 640 acres would
         be conducted in one day costing about $5000. The cost of collecting seed
         and planting approximately 3000 Table Mountain Pine seedlings is
         estimated at $1500. The cost of plowing and planting either of Roads 748
         or 2748 is about $500. Alternative 2 or 3 would have a total cost of
         approximately $27,000.

         Alternative 4

         The difference between this alternative and the previous two is the cost of
         felling. Alternative 4 would cost $21,200 to implement.

H. General Information about Triclopyr and Imazapyr

         Herbicides are applied according to labeling information and the site-
         specific analysis done for projects. This labeling and analysis are used to
         choose the herbicide, rate, and application methods for the site. They are
         also used to select measures to protect human and wildlife health, non-
         target vegetation, water, soil, and Proposed, Endangered, Threatened, and
         Sensitive species. Site conditions may require stricter constraints than
         those on the label, but labeling standards are never relaxed.

         Only herbicide formulations (active and inert ingredients) and additives
         registered by EPA and approved by the Forest Service are applied.

         Herbicides and application methods are chosen to minimize risk to human
         and wildlife health and the environment.

         The following criteria apply to herbicide classification:

                Class A herbicide/method combinations are first choice.

                Class B combinations are used only if no Class A herbicide can
                meet project objectives, and then only if adverse effects are
                mitigated to acceptable levels.
       Class C combinations are used only if no Class A or B herbicide
       can meet project objectives, and then only if adverse effects are
       mitigated to acceptable levels.

       Class D combinations are never used.

NOTE: The Regional Forester has, in this Record of Decision,
strengthened this mitigation as follows: No Class B or C chemical may be
used on any project, except with Regional Forester approval. Approval
will be granted only if a site-specific analysis shows that no other
treatment would be effective and that all adverse health and
environmental effects will be fully mitigated.

Herbicides are applied at the lowest rate effective in meeting project
objectives and according to guidelines for protecting human (NRC 1983)
and wildlife health (EPA 1986a).

Method and timing of application are chosen to achieve project objectives
while minimizing effects on non-target vegetation and other
environmental elements. Selective treatment is preferred over broadcast
treatment. Public safety during such uses as viewing, hiking, berry
picking, and fuelwood gathering is a priority concern. Application
methods from most to least selective are:

a.Cut surface treatments
b.Basal stem treatments
c.Directed foliar treatments
d.Soil spot (spot around) treatments
e.Soil spot (spot grid) treatments
f.Manual granular treatments
g.Manual/mechanical broadcast treatments
h.Helicopter treatments

Under Alternatives 2 and 3, the above methods proposed would include a
and c.

Weather is monitored and the project is suspended if temperature,
humidity, or wind becomes unfavorable as follows:


                  Temperatures         Humidity       Wind
                  Higher Than          Less Than      Greater Than

Ground:
 Hand (cut surface)   N.A.             N.A.           N.A.
 Hand (other)         98F              20%            15 mph
 Mechanical (liquid)       95F         30%            10 mph
 Mechanical (granular)     N.A.        N.A.           10 mph


Nozzles that produce large droplets or streams of herbicide are used.
Nozzles that produce fine droplets are used only for hand treatment where
distance from nozzle to target does not exceed 8 feet.

A certified pesticide applicator supervises each application crew in
personal safety, proper handling and application of herbicides, and proper
disposal of empty containers.

Each contracting officer's representative (COR), who must ensure
compliance on contract herbicide projects, is a certified pesticide
applicator. Contract inspectors are trained in herbicide use, handling, and
application.

Forest Service workers who handle herbicides must wear a long-sleeved
shirt and long pants made of tightly woven cloth that must be cleaned
daily. They must wear a hard hat with plastic liner, waterproofed boots
and gloves, and other safety clothing and equipment required by labeling.
They must bring a change of clothes to the field in case their clothes
become contaminated.

Each Forest Service crew must take soap, wash water separate from
drinking water, eyewash bottles, and first aid equipment to the field.

Contractors ensure that their workers use proper protective clothing and
safety equipment required by labeling for the herbicide and application
method.

Workers must not walk through areas treated by broadcast foliar methods
on the day of application.

Supervisors must ensure that monitoring is adequate to prevent adverse
health effects. Workers displaying unusual sensitivity to the herbicide in
use are medically evaluated and, if tested as sensitive to the herbicide in
use, are reassigned to other activities.

Notice signs (FSH 7109.11) are clearly posted, with special care taken in
areas of anticipated visitor use. People living within one-fourth mile of an
area to be treated aerially are notified during project planning and shortly
before treatment.
     No herbicide is broadcast within 100 feet of private land. Buffers are
     clearly marked before treatment so applicators can easily see and avoid
     them.

     Ensure availability of extra clothing, FSM R-8 Suppl. #21, 1/19/90 (one or
     two truck coveralls per crew for emergency change of clothing).
     The proposed action includes herbicide injection treatment (Garlon 3A) on
     92 acres, and herbicide foliar treatment (Garlon 4 plus Arsenal AC) on 92
     acres.

     The injection cuts are made downward at approximately waist height (3' to
     4' above ground level), so as to create a small "pocket" in the bark to catch
     and hold the herbicide until it is absorbed into the cambium

     The foliar spray mixture is a light directed spray applied with a backpack
     sprayer equipped with a spray wand over the growing tips of the foliage of
     target vegetation. The use rate depends upon the size and density of
     vegetation being treated, but would not exceed 5 gallons of mix per acre,
     and may be less.

TRICLOPYR (General Information)

     Triclopyr is a solution of the triethylamine salt of Triclopyr in water, with
     ethyl alcohol and proprietary adjuvants, and contains the acid equivalent
     of 3 pounds of Triclopyr per gallon. Garlon 4 is a solution of the butoxy
     ethly ester of Triclopyr in kerosene, with proprietary emulsifiers and
     adjuvants, and contains the acid equivalent of 4 pounds of Triclopyr per
     gallon. Arsenal AC is a solution of the isopropylamine salt of Imazapyr in
     water, with proprietary adjuvants, and contains the acid equivalent of 4
     pounds of Imazapyr per gallon.

     Triclopyr, a pyridine, is a selective systemic herbicide used for control of
     woody and broadleaf plants along rights-of-way, in forests, on industrial
     lands and on grasslands. There is no possibility of dioxin impurities
     occurring in Triclopyr.

IMAZAPYR (General Information)

     Arsenal is an imidaxoloinone chemical that is used as a board spectrum
     pre- and post-emergence herbicide. Arsenal contains isopropylamine salt
     of Imazapyr as the active ingredient or 4 pounds of active ingredient per
     gallon of the applicator concentrate. The herbicide also contains water
     and surfactant as inert ingredients. Arsenal was developed to and has
     excellent activity with residual control of a wide variety of annual and
     perennial grass and broad-leaved weeds and many brush and deciduous
     tree species. Imazapyr has a low rating of toxicity to humans and wildlife.
   INERT INGREDIENTS (General Information)

         Inert ingredient information is presented in the VMEIS risk assessment
         (Appendix A). Inert ingredients in Arsenal are either "Inerts of unknown
         toxicity" or "Inerts of minimal concern". There was no basis for listing the
         inerts in Arsenal as potentially toxic. Garlon 4 does contain kerosene and
         toxicity data are suggestive, but not conclusive, of chronic health effects
         from kerosene. The human health risk from kerosene is estimated in the
         exposure and risk analyses in sections 4 and 5 of the risk assessment in the
         VMEIS. When herbicides are applied at or below the rates specified in the
         VMEIS, the Margin of Safety meets or exceeds 100.

         Mixing is allowed only on the treatment site supervised by a certified
         applicator. The materials for cleanup would be available on site. Only the
         amount of herbicide needed would be transported which would limit
         effects from a spill. A spill plan has been developed for emergencies.
         Transportation and mixing would comply with federal regulations and a
         certified pesticide applicator would ensure compliance.

I. Consequences on Environment

         In natural soil and in aquatic environments, the two formulations rapidly
         convert to the acid, which in turn is neutralized to a salt. Triclopyr is not
         strongly absorbed to soil particles, has the potential to be mobile, and is
         fairly rapidly degraded by soil microorganisms. Concentrations of 500
         ppm had no apparent effects on the growth of common soil
         microorganisms. Triclopyr was tested but not found in a host of
         groundwater sites throughout the country

         The half-life in soil is from 30 to 90 days, depending on soil type and
         environmental conditions, with an average of about 46 days. The half-life
         of one of the breakdown products (trichloro-pyridinol) in 15 soils ranged
         from 8- 279 days with 12 of the tested soils having half-lives of less than
         90 days. Longer half-lives occur in cold or arid conditions.

         Breakdown by the action of sunlight is the major means of Triclopyr
         degradation in water. The half-life is 10 hours at 25 degrees C. The major
         metabolite is trichloropyridinol.

         Triclopyr is readily translocated throughout a plant after being taken up by
         either roots or the foliage. Cowberries with residues of 2.4 ppm at six days
         had 0.7-1.1 ppm at 30-36 days, and 0.2-0.3 ppm in 92-98 days. The
         estimated half-life in aboveground drying foliage as in a forest overstory is
         two to three months.
Triclopyr is a picolinic acid compound, which functions as an auxin-like
growth regulator. It is readily absorbed by plant roots and foliage, and
translocates upward and downward in plants, accumulating in the growing
meristems and at the root collar. It is metabolized and broken down by
bacteria in the soil; it also photodegrades rapidly. Its typical half-life in
soil is 46 days; in water, its half-life is less than 10 hours. Its residence
time on leaf surfaces would be short, due to absorption and
photodegredation, and dislodgeable amounts would disappear within one
to two days following application. While the amine salt (Garlon 3A) is
more likely to be mobilized by percolating water than the ester (Garlon 4),
neither presents leaching problems with normal forestry use. In injection
treatments, virtually all of the herbicide is absorbed and retained within
the treated tree; in directed foliar spray applications, a small portion of the
spray (5% to 15%) may pass through the foliage and reach the ground, but
this is almost always intercepted and absorbed by leaf litter or soil organic
matter. The possibility of detectable amounts of Triclopyr moving more
than a few feet from the application site in soil or groundwater with these
types of applications is essentially zero, and the designation of extensive
buffer strips between application sites and any surface water provides
assurance that no contamination of surface or ground water will occur.

Imazapyr is an imidazolinone compound and acts as a plant protein
production inhibitor. It is adsorbed by plant roots and foliage and moves
throughout treated plants, accumulating in roots and meristems. It is
broken down by soil microbes and sunlight, and has moderate half-life of
12 to 35 days on vegetation, and 19 to 34 days in soil, during warm
weather. In cold weather, Imazapyr is known to incubate in soil for period
of several months. It is a soil-active compound, meaning that application
to the soil would result in root uptake and subsequent plant injury.
However, the soil activity is limited to the spring growth period, and
growing season applications made after the period of spring leaf expansion
do not result in soil activity. Applications made in late summer of early
fall may produce limited soil activity the following spring due to
incubation. Imazapyr is not highly mobile in soil; it appears to be
adsorbed and loosely bound to soil particles, and is not leached from the
soil in significant amounts by percolating water. As with Triclopyr, the
risk of off-site movement of Imazapyr following injection or directed
foliar spray application is essentially zero.

Under Alternatives 2 and 3, indirect adverse effects on non-target
vegetation are not anticipated. The vegetation and trees naturally adapted
to woodland/savannah habitats would not be targeted for herbicide
treatment on the 92 acres. Table Mountain, shortleaf, and pitch pines, and
grasses and forbs are protected during treatment. Given the half-life and
biodegraded condition Triclopyr and Imazapyr shortly after being applied
onto target vegetation, residual vegetation and trees are not likely harmed.
J. Fate in Humans and Animals

         No herbicide applications would occur near enough to private lands to
         have adverse effect on the public. The use of buffer strips, the one time
         application, the low application rates and breakdown by sunlight and soil
         microbes reduce risks of exposure. There are no nearby homes or
         residents and it’s unlikely that a pet would wander into the area and eat
         treated vegetation. Should this unlikely situations occur, the Garlon 4 and
         Arsenal AC should pass out of its system. No tendency to bioaccumulate
         has been shown for these herbicides. Signs would be posted to reduce the
         possibility of someone wandering into the treatment area. If someone
         accidentally wanders into the area, the risk of exposure is very low. The
         low-level of applied herbicide plus the directed application reduce the risk
         of exposure. Triclopyr and Imazapyr have not been shown to
         bioaccumulate and are passed out the body through natural processes
         (USDA Forest Service 1989).

   IMAZAPYR (Fate in Humans and Animals)

         Imazapyr is practically non-toxic to aquatic and terrestrial organisms other
         than plants; the oral LD50 for both male and female rats is >5000 mg/kg,
         and the dermal LD50 for rabbits is >2148 mg/kg, although some
         formulations may be mildly irritating to rabbit eyes and skin. The IARC,
         OSHA, or NTP does not list Imazapyr as a human carcinogen; long-term
         research studies show no evidence mutagenicity, teratogenicity, or
         fetotoxicity.

         Imazapyr is slightly toxic to mammals based on acute oral LD50 ranging
         from greater than 2,000 mg/kg in mice to greater than 5,000 mg/kg in
         rates. Imazapyr and the Arsenal formulation are reported to be irritating to
         the eyes and mildly irritating to the skin of rabbits but are reported as
         nonsensitive to guinea pigs. No teratogenic effects were observed in rats
         or rabbits. Imazapyr does not appear to accumulate in animal tissues. The
         EPA characterizes Imazapyr as practically nontoxic to avian species.
         Acute oral LD50 of technical Imazapyr are greater than 2150 mg.kg in
         bobwhite quail and mallards. Dietary LC50 for Imazapyr are greater than
         5,000 ppm for mallards and bobwhite quail. No adverse doses were
         observed in any of these doses.

         Imazapyr appears to be relatively nontoxic to insects. The LD50 for
         honeybees is greater than 100 mg/kg. No effects were observed at this
         dose.

         Imazapyr has not been shown to bioaccumulate and is passed out the body
         through natural processes (VMEIS).
     Imazapyr is a mild eye irritant while Triclopyr has the potential to cause
     permanent corneal injury. Eye protection is required for Forest Service
     employees and contact personnel. A typical worker scenario and a
     maximum worker scenario were used to estimate a margin of safety
     (MOS). According to the National Research Council, acceptable level of
     risk for an herbicide can be estimated. Under the typical worker scenario,
     both herbicides had a MOS that exceeded 100. Applied at Region 8
     herbicide rates, grater heath protection is provided to workers than
     required by published health safety standards. The estimated applications
     rate is blow the limits listed in the VMEIS.

TRICLOPYR (Fate in Humans and Animals)

     Triclopyr is moderately toxic to mammals based on LD50 values that
     ranger from 310 mg/kg in guinea pigs to 729 mg/kg in male rats.
     Triclopyr is slightly irritating to the eyes and skin of rabbits. Gallon 4 is
     slightly toxic, with oral LD50 of 2,830 and 2,140 mg/kg in rats. Gallon 4
     may cause slight skin irritation but no eye irritation. Ponies exposed to 4
     daily doses of 60 mg/kg of Triclopyr exhibited no adverse effects,
     however, daily doses of 300 mg/kg causes depression, recumbence,
     decreased gastrointestinal activity, and respiratory and muscular distress.
     No teratorgenic effects have been observed in rats, but a rabbit study
     reported fetotoxic effects at the LDT of 10 mg/kg/day. Triclopyr is
     rapidly excreted, primarily as the parent compound, through the kidneys in
     animals. Small quantities of two other compounds are also excreted.
     Triclopyr does not bioaccumulate in animal tissues in any significant
     amount.

     Base on acute oral and dietary studies, Triclopyr and Gallon 4 are slightly
     toxic to birds. The acute oral LD50 of technical Triclopyr is 1,698mg/kg
     for mallard, and the dietary LC50 range from 2,935 to grater than 5,000
     ppm. The dietary LC50 of Gallon 4 is greater than 9,000 ppm. A one-
     generation reproduction study showed no reproductive effects, symptoms
     of toxicity, or abnormal behavior when mallards were given up to 500
     ppm in their diet for a 20-week period, including 10 weeks before egg
     laying and 10 weeks during egg laying. A similar study reported no
     reproductive or toxic effects in bobwhite quail exposed to dietary levels of
     up to 800 ppm for a 20-week period, including 11 weeks before egg laying
     and 8 weeks during egg lying.

     The acute contact LD50 of Triclopyr in honeybees is greater than 60
     mg/kg, indicating that it is relatively nontoxic to insects. The contact
     LD50 for honeybees is greater than 100 mg/kg based on a 1985 study.
      Triclopyr has not been shown to bioaccumulate and is passed out the body
      through natural processes (VMEIS).

      When rats were intravenously dosed at 5 mg/kg, most of the dose was
      excreted in urine. At 100 mg/kg urinary excretion still predominated. At
      higher doses, an increasing amount was in the feces. In dogs, 0.5 mg/kg of
      Triclopyr had a half-life of 14 hours for clearance from blood plasma, and
      a dose of 20 mg/kg had a half-life of 95 hours reflecting the unique
      capacity for excretion of organic acids by the dog. Excreted Triclopyr is
      mostly the parent compound but small quantities of breakdown products
      are also present.

      Triclopyr is low in mammalian toxicity, with oral LD50 values of 2574
      mg/kg and 1847 mg/kg for male and female rats, respectively. The LD50
      value for skin absorption in rabbits is >2000 mg/kg. Long-term research
      studies have shown that Triclopyr is not a carcinogen, mutagen, or
      teratogen, and does not interfere with mammalian reproduction

      Triclopyr was found in greater quantities in the liver and fatty tissue of the
      rat when compared to the blood plasma. The dog had higher levels in the
      kidney than in the blood plasma, and in monkeys, residues in all tissues
      were the same as in blood plasma. The compound is not expected to
      concentrate to any significant degree in the tissues of animals.

Direct Effects (Fate in Humans and Animals)

      Under Alternatives 2 and 3, human health effects are evaluated based on
      the analysis in Sections 3, 4, and 5 of the Environmental Impact Statement
      for Vegetation Management in the Appalachian Mountains (VMEIS),
      which documents analysis of Human Exposure Analysis. VMEIS analysis
      indicates no cause for concern for herbicide workers or the general public
      as related to application of Triclopyr and Imazapyr.

      The VMEIS contains extensive analysis, tables, and supporting research,
      and substantive determination on Page 5-36 under the section titled "Risk
      to Workers From Typical and from Maximum Exposures". Under typical
      exposures using application methods and tricolpyr and Imazapyr as
      described in the alternatives, workers chronically exposed should have no
      ill effects. The probability of workers receiving repeated daily high doses
      is stated in the VMEIS as being unlikely and would be less than a chance
      of one in one thousand. Thus, a worker involved in application would not
      be expected to experience toxic effects and would only be expected after
      unusually high exposure levels. Worker exposure is reduced by following
      the label instructions concerning protective clothing and similarly will
      reduce the chances of human health risks. These determinations are
      consistent with analysis in the VMEIS with specific references in Section
      5, Pages 5-1 to 5-51, to the methods prescribed under Alternatives 2 and 3.

      With implementation of the No Action Alternative, there would be no risk
      to human health and safety. Under the Proposed Action, human health
      effects are evaluated based on the analysis in the Syracuse Environmental
      Research Associates Risk Assessments for Triclopyr and Imazapyr.
      Hazard Quotients generated indicate no cause for concern for herbicide
      workers or the general public. If Alternative 4 were implemented, risk to
      human health would consist of injury from operating power or hand tools.
      The VMEIS (Summary, p. xv, supported by analysis in Chapter IV) states
      that "Accidental injuries from other methods pose greater risks to workers
      than health impacts from herbicides". Manual cutting using axes may also
      result in serious injury.

 Indirect Effects (Fate in Humans and Animals)

      Indirect effects on public human health and safety would be less than that
      expected by workers involved with application of Alternatives 2 or 3. On
      Page 5-30 of the VMEIS, the summation of analysis states the probability
      of the public receiving maximum exposure is unlikely. The probability is
      so low that chances of maximum exposure to the public is predicted at one
      in one million, and this prediction is for maximum application rates, high
      drift, and that the public would be present in the application area while
      applications occur.

Cumulative Effects (Fate in Humans and Animals)

      Cumulative effects could occur if pesticide applications and exposures
      occur from projects other than those being considered in this EA. No
      other proposals or decisions of any form on the Andrew Pickens Ranger
      District are planned on or near the Toxaway Creek Area. No cumulative
      effects on human health are expected.

      The proposed ground based applications have a very low potential to
      affect private lands, because they are conducted on small, localized areas.
      Long-term risks to human health and safety would be minimal with any
      alternative. Mitigation measures limit any long-term risks from herbicide
      or hand tool use or from prescribed burning.

      Synergistic effects in human should not result from herbicides applied on
      separate Forest Service projects. Projects are separated by both time and
      considerable space. Potential for public exposure is low. The herbicide
      proposed for use n Forest Service land should not cause chronic effects.
      On other National Forest herbicide projects, no synergistic effects have
      been found (VMEIS, Vol. II, Pages 5-46 to 5-49).
         Prescribed burning has the potential to impact human health from
         breathing particulates. Mitigation measures identify smoke sensitive areas
         and adjust burn plants to avoid these areas. Another potential impact to
         human safety is impaired visibility along roads. Similarly burn
         prescriptions are incorporating specific weather conditions to limit impacts
         to pave roads. Impacts to visibility are temporary.

K. Heritage

         Since no ground disturbing activities are proposed under Alternatives,
         cultural resource surveys will not be conducted prior to implementation of
         the selected alternative. As agreed to by the South Carolina Historical
         Preservation Office and according to section 106 of the National Historic
         Preservation Act, the actions under the alternatives are not undertakings.

         After implementation of prescribed fires, the forest archeologists will visit
         fire lines. A cultural resource report may be prepared if sites are
         discovered.


L. Recreation Resources

         There are no developed recreational facilities, no hiking trails, nor
         designated camping sites, in the Toxaway Creek Area. Recreational
         pursuits are mainly limited to deer, turkey, and squirrel hunting. Forest
         visitors may infrequently visit the analysis area for purposes of berry
         picking or sight seeing.

   Direct Effects (Recreation Resources)

         Under Alternative 1, hunting in the Toxaway Area will likely decline with
         the regression of early successional habitat which is an important life
         requisite for deer and turkey.

         Alternatives 2 to 4. Similar amounts of forestland would be treated with
         actions that effectively generate 92 acres of early successional habitat.
         Coupled with conversion of systems roads as linear wildlife strips,
         opportunities for hunting would likely improve.

   Cumulative Effects (Recreation Resources)

         Alternative 1

         Early successional habitat would be almost exclusively supplied on private
         lands with no such habitat being provided on National Forest lands in the
               Toxaway Creek Area. Hunting, and its indirect relationship with habitat
               management, would decline in the long-term. Conditions favorable to
               hunting of deer and turkey decline.

               Alternatives 2 and 3

               Vegetation management is likely to produce early successional conditions
               of a higher quality than under Alternatives 1 and 4. The combined use of
               herbicides and prescribed fire on a more frequent rotation than Alternative
               4 would prolong desirable conditions found in grass/forb habitats.
               Conditions favorable for hunting of deer and turkey improve for years into
               the future.

               Alternative 4

               Herbaceous growth and even-aged regeneration with tree seedlings and
               saplings would produce shorter duration of early successional habitat
               conditions. Deer and turkey foraging habitat would decline after 3 to 5
               years as saplings and multilayed vegetation shades out grasses and forbs.
               Conditions favorable for hunting of deer and turkey improve in the short-
               term, but decline after a few years.


AGENCY PERSONNEL

The persons contributing to the writing of this EA:
Paul B. Burris, District Silviculturists

REFERENCES

National Wildfire Coordinating Group. Fire Effects Guide. NFES #2394.

South Carolina Forestry Commission. 1994. South Carolina's Best Management
Practices for Forestry. March.

State of South Carolina. 1996. Smoke Management Guidelines for Vegetative Debris
Burning Operations. South Carolina Forestry Commission. May.

South Carolina Land Resources Commission. 1988. Assessment of Nonpoint Source
Pollution by Sediment. Submitted to the South Carolina Department of Health and
Environmental Control. April 12.

USDA Forest Service. 1985a. Land and Resource Management Plan. Sumter National
Forest. Southern Region. South Carolina.
USDA Forest Service. 1985b. Final Environmental Impact Statement. Land and
Resource Management Plan. Sumter National Forest. Southern Region. South Carolina.

USDA Forest Service. 1988. Final Environmental Impact Statement for Vegetative
Management in the Appalachian Mountains. Management Bulletin R8-MB-24. Southern
Region. Record of Decision for the Final Environmental Impact Statement for
Vegetative Management in the Appalachian Mountains.

USDA Forest Service. 1989. A Guide for Prescribed Fire in Southern Forest. Tech. Publ.
      R8-TP 11. February.

								
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