Test Fish
Erwin/Arlee strain rainbow trout were obtained from the U.S. Fish and Wildlife Service, Ennis National Fish Hatchery (Ennis, Montana) as eyed eggs. Eggs were hatched in culture and raised until 30–60 days post swim-up and acclimated to ASTM soft water (~ 40 mg/L as CaCO3 using D1126-17 methods; ASTM International 2014) three days prior to the start of each assay at 12°C ± 1.5°C.
Test Products
Two long-term ammonium-based fire retardants (Phos-Chek LC95A-R and Phos-Chek MVP-Fx; Perimeter Solutions, Clayton, Missouri), which are both on the USFS Qualified Products List in 2024 in 2024, were tested (USDA Forest Service 2024). LC95A-R is a liquid concentrate formulation composed of ammonium polyphosphate, a gum thickening agent, and iron oxide as a coloring agent (Perimeter Solutions 2019). MVP-Fx is a powder concentrate formulation composed of a combination of monoammonium phosphate and diammonium phosphate, a gum thickening agent, and iron oxide as a coloring agent (Perimeter Solutions 2018). The concentrates are mixed with water according to manufacture specifications, resulting in solutions that are between 11 and 22% product prior to application on the landscape. The formulations of these fire retardants vary, and some information is proprietary; therefore, total ammonia nitrogen (TAN, un-ionized ammonia [NH3] plus ammonium [NH4+]) concentration and specific conductance were used to explore effects on biota between products.
Substrate Collection
Four substrates were selected for the study: duff, gravel, high organic content soil (HOC), and low organic content soil (LOC). The HOC was collected from a hardwood forest (University of Missouri Baskett Wildlife Research and Education Center, Ashland, Missouri) by removing any deciduous leaf litter and using shovels to collect the top 10 cm of soil. The LOC was a 1:1 ratio by volume mixture of the HOC and sand (HTH Pool Filter Sand; Innovative Water Care, Amboise, France). The tested soils were chosen because the percentage of organic matter content may affect the toxicity of these fire retardants, and wildfire impacts a variety of different soil types across the United States. The duff was a mixture of decomposing woody material (litter) collected near Missoula, Montana in a coniferous pine-fir forest. The gravel substrate was a mixture of river rock with an average diameter of 3.8 cm. The soils (HOC and LOC) were analyzed for total fertility (pH, neutralizable acidity, organic matter, available phosphorous, calcium, magnesium, and potassium), particle size (percent sand, silt, and clay), base saturation, and CEC at the University of Missouri’s Soil and Plant Testing Lab in Columbia, Missouri prior to the start of the assays (Table 1). Soil characteristics were measured and assessed using standard protocols outlined in Nathan et al. (2012). Duff samples were analyzed for pH and percentage of moisture by the same laboratory.
Table 1
Characteristics of underlying duff and soil substrates (HOC = high organic content soil, LOC = low organic content soil) used for testing the environmental persistence of two current use long-term fire retardants (LC95A-R and MVP-Fx). Shown are average values with standard deviation in parentheses (n = 3 samples per substrate type). NM indicates not measured. Gravel was not tested for nutrients in this study.
| Substrate Characteristics | Substrate |
| Duff | HOC | LOC |
| pH | 5.3 (0.1) | 5.9 (0.1) | 6.2 (0.1) |
| Neutralizable Acidity (mEq/100 g) a | NM | 2.3 (0.3) | 0.5 (0.0) |
| Organic Matter (%) | NM | 6.8 (0.5) | 1.5 (0.1) |
| Bray-1 P (mg/kg) b | NM | 14.8 (1.0) | 11.3 (0.6) |
| Ca (mEq/100 g) a | NM | 9.2 (0.4) | 4.4 (0.2) |
| Mg (mEq/100 g) a | NM | 2.3 (0.1) | 1.0 (0.1) |
| K (mEq/100 g) a | NM | 0.4 (0.0) | 0.2 (0.0) |
| Moisture (%) | 22.8 (1.4) | NM | NM |
| Sand (%) | NM | 25.0 (0.0) | 74.2 (1.4) |
| Silt (%) | NM | 62.5 (0.0) | 19.2 (2.9) |
| Clay (%) | NM | 12.5 (0.0) | 6.7 (1.4) |
| Textural Classification | NM | Silty loam | Sandy loam |
| CEC (mEq/100 g) a,c | NM | 28.1 (0.8) | 6.3 (1.1) |
a mEq/100 g = milliequivalents per 100 grams
b Available phosphate
c Cation exchange capacity (ammonium acetate distillation method)
Experimental Design
To simulate environmental weathering of long-term retardants, we applied either LC95A-R, MVP-Fx, or control water (ASTM soft water) to substrate treatments and weathered them outside for 7 to 56 days. We used 4 replicates per treatment [4 replicates x 3 test waters (2 products and control) x 4 substrates x 4 weathering periods (7, 14, 28, and 56 days)] resulting in 192 total containers (i.e., experimental units). Each container (5-gallon [18.9-liter] polyethylene bucket) received 1 L of substrate, which amounted to a depth of approximately 3 cm. Product or control water was then applied to the surface of the substrate using a backpack sprayer to produce an even application of approximately 210 mL (200.1 mL [± 4.33 mL]) to achieve an application rate of 8 gallons/100 square feet (3.3 L/m2), which is the highest application rate the USFS uses (USFS 2011). Containers were covered nightly and during inclement weather to prevent debris from entering and further dilution of product by rain.
Upon the completion of a weathering period (7, 14, 28, and 56 days), sets of containers (48 buckets per weathering period) were transferred inside the U.S. Geological Survey, Columbia Environmental Research Center (CERC, Columbia, Missouri) where a 96-hr toxicity assay was conducted. Each container received 10 L of ASTM soft water resulting in nominal concentration of 5360 mg/L LC95A-R and 2300 mg/L of MVP-Fx. Containers were aerated and held in a water bath to maintain a temperature of 12°C ± 1°C during the assay. After substrate settled for 1 hr, 10 juvenile rainbow trout (30–60 days post swim-up) were added. For some treatments (i.e., duff), substrate was still suspended in the water column, hindering daily visual observations. If visible, fish that were dead, immobile with no visible opercular movement, were removed daily. All surviving fish at the conclusion of the 96-hr assay were enumerated and euthanized with an excess dose of buffered tricaine methanesulfonate (MS-222).
Water Chemistry Measurements
We monitored water chemistry at the start of each assay, as fish were exposed to the highest chemical concentration during this period. Temperature, dissolved oxygen, specific conductance, pH, alkalinity, total hardness, and TAN were measured following established protocols (APHA 2023). Temperature and dissolved oxygen were measured using a YSI Pro20 dissolved oxygen meter (Xlyem Inc., Washington, D.C.). Specific conductance was measured using a portable Orion Star A325 multiparameter meter (Thermo Fisher Scientific, Waltham, Massachusetts). An HQD HQ440d benchtop meter (HACH Company; Loveland, Colorado) equipped with IntelliCAL electrodes was used to measure pH (PHC301), alkalinity (PHC301), and TAN (ISENH3181). Total hardness was measured using the EDTA (Ethylenediaminetetraacetic acid) titration method. Composite samples of all replicates per treatment were collected for pH, alkalinity, and total hardness. Temperature, dissolved oxygen, and specific conductance measurements were collected from one randomly chosen replicate. The TAN measurements were collected from a composite of replicate samples from the first weathering period treatment and each replicate per weathering period treatment thereafter. A duplicated sample was also collected for one random treatment each sampling event. Given that the relationship between TAN and un-ionized ammonia (NH3) is controlled by temperature and pH, proportions of un-ionized ammonia from the TAN concentrations were calculated using the following equation (Emerson et al. 1975; Guan et al. 2010):
$$\:{NH}_{3}=\frac{{NH}_{3}+{NH}_{4}^{+}}{1+{10}^{\left(pKa-pH\right)}}\:,$$
where pKa is a calculated (pKa = 0.09018 + 2729.92/T; T = temperature in Kelvin) ammonia-TAN equilibrium constant value. When comparing our measured TAN concentrations in the overlying water to the acute water quality criteria set by the U.S. Environmental Protection Agency (U.S. EPA), we normalized those concentrations to a pH of 7 using the following equation (US EPA 2013):
$$\:A{V}_{t,7}=\frac{A{V}_{t}}{(\frac{0.0114}{1+{10}^{7.204-pH}}+\frac{1.6181}{1+{10}^{pH-7.204}})},$$
where \(\:{AV}_{t}\) is the TAN concentration. All instruments were calibrated prior to sample measurement and certified standards were measured at the beginning and end of each sampling event to verify the accuracy of those measurements. If standards measured outside of certified ranges, the instrument was recalibrated.
Statistical Analysis
Total mortality of rainbow trout at the end of each assay was summarized. We tested for differences in mortality between products and among weathering periods and substrate types using generalized linear models (GLM) with a binomial distribution and a logit link. Mortality data were logit transformed to meet model assumptions of GLMs using the “glm” function in the “lme4” package (Bates et al. 2015). All fixed-effect variables were evaluated using Analysis of Deviance table (Type III tests) with the “Anova” function in the “car” package (Fox and Weisberg 2019). For all significant relationships, Tukey’s multiple comparison test was performed to identify differences among treatments. Analyses were conducted in the R statistical programming language (v 4.3.3; R Core Team 2022). Trout mortality and water chemistry data are available in Puglis et al. (2023).