PROGRAMS AND PLANS--Dyes for Water Tracers In Reply Refer To: July 21, 1986 WGS-Mail Stop 415 OFFICE OF SURFACE WATER TECHNICAL MEMORANDUM NO. 86.08 Subject: PROGRAMS AND PLANS--Dyes for Water Tracers Surface Water Branch Technical Memorandum 81.05 provided a statement from the Environmental Protection Agency (EPA) that EPA would not object to the use of rhodamine WT dye as a tracer in lieu of additional information on human toxi- cology or a change in the position of the Food and Drug Administration. A 1982 paper by S. L. Abidi (U.S. Fish and Wildlife Service, National Fishery Research Laboratory, La Crosse, Wisconsin) showed that diethylnitrosamine (DENA), a recognized carcinogen, can be formed under laboratory conditions when rhodamine WT dye is added to nitrite-rich water. An advance copy of a paper by T. R. Steinheimer and S. M. Johnson was dis- tributed with Water Resources Division Memorandum 85.82. This report has since been published in Water-Supply Paper 2290 (1986, pages 37-49). This paper showed that nitrosamine (NDEA) formation didnotoccur in nitrite- enriched river-water samples injected with rhodamine WT at concentrations typically used in the field. It also was determined that the rate of photo- chemical decomposition of NDEA in the presence of dissolved oxygen and nitrite at environmental levels is approximately the same as its rate of formation from the dye, so NDEA becomes a transient species with a very short half life in river water. Steinheimer's and Johnson's analysis also did_not detect_NDEA in any samples tested from four rivers where rhodamine WT was injected in water known to contain nitrite. Attached for your information are two letters from Crompton and Knowles Corporation, the manufacturer of rhodamine WT, one of which includes a risk- assessment report to evaluate the potential risk associated with the genera- tion of DENA as a result of the use of rhodamine WT. Also attached is a copy of a report by P. L. Smart entitled "A Review of the Toxicity of Twelve Fluorescent Dyes Used for Water Tracing." The letter dated October 28, 1982, from Crompton and Knowles Corporation supports the work of Steinheimer and Johnson in showing that DENA degrades rapidly in water by photolysis and that DENA which may result from the use of rhodamine WT would be transient. The letter dated September 27, 1983, from Crompton and Knowles Corporation shows that the risk associated with a typical use of rhodamine WT is expected to be several orders of magnitude less than the risk believed to be acceptable to EPA. OFFICE OF SURFACE WATER TECHNICAL MEMORANDUM NO. 86.08 2 The report by P. L. Smart provides information on the toxicities of some dyes used in the U.S. Geological Survey for water tracing. The most commonly used water-tracing dye, rhodamine WT, couldnotbe demonstrated to provide either a carcinogenic or mutagenic hazard. The author states that, "Based on the experimental results reviewed . . ., there is no evidence of either a short or long-term toxic hazard to dye users or those drinking water containing tracer dyes." However, he also points out that rhodamine WT is a severe irritant to the eyes and is moderately irritating to the skin. He therefore recommends that all personnel handling dyes should wear protective gloves and clothing and that all skin areas contaminated by dye be washed immediately with soap and water and that any splashes in the eye be flushed with copious quantities of water. Based on the above-summarized information, the policy concerning concentra- tions at intakes, as specified in Water Resources Division Memorandum 66.90, is still in effect. In that memorandum, the policy specifically referred to the use of rhodamine B. The statement has since been extended to the use of rhodamine WT (Wilson and others, 1984, page 11). The pertinent policy state- ment is that 10 ppb (parts per billion is equivalent to micrograms per liter) shall be the maximum allowable concentration passing any water intake that ultimately results in direct or indirect human consumption. It also is recommended that rubber or plastic gloves be worn when handling concentrated dye solutions. When the dye does come into contact with the skin, it should be washed off immediately. If dye gets into an eye, the eye should be immediately and thoroughly flushed with water. Also, pipetting of dye solutions should be done with a squeeze bulb or by using a long piece of flexible tubing to prevent accidental ingestion of the dye (Wilson and others, 1984, page 11). Reference: Wilson, James E., Jr., Cobb, Ernest D., and Kilpatrick, Frederick A., 1984, Fluorometric procedures for dye tracing: U.S. Geological Survey Open- File Report 84-234, 53 pages (to be printed as U.S. Geological Survey Techniques of Water-Resources Investigations, Book 3, Chapter A12, revised). Verne R. Schneider Chief, Office of Surface Water 3 Attachments WRD Distribution: A, B, S, FO, PO, SL This memorandum supersedes WRD memoranda 66.90 and 85.82 and SWB memorandum 81.05.