STATUS OF CALIFORNIA NPDES PERMIT

TIMELINES September 2010-Draft permit available for public comment October 19 TH, 2010-Public hearing on Vector Control Permit November 2 ND, 2010-Public comments due to SWRCB February 11 TH, 2011-Revised Draft Permit released March 1 st, 2011-SWRCB Approved the California Permit March 3 rd, EPA requests an extension to October 31 st Extension Granted-Permits Mandate on October 31st

WHAT IS NEEDED FOR NPDES COMPLIANCE? File a Notice of Intent (NOI) File a Notice of Intent (NOI) Pesticide Application Plan (PAP) Pesticide Application Plan (PAP) Monitoring and Reporting Plan Monitoring and Reporting Plan Initial Administrative Fee -$136 for the life of the permit Initial Administrative Fee -$136 for the life of the permit The SWRCB anticipates changing the fee schedule in FY 2011/2012 to $1200 plus a 21% water quality monitoring fee for a total of $1452 annually The SWRCB anticipates changing the fee schedule in FY 2011/2012 to $1200 plus a 21% water quality monitoring fee for a total of $1452 annually Meet the Requirements of the Monitoring Component of the Permit-Attachments B and C of the permit Meet the Requirements of the Monitoring Component of the Permit-Attachments B and C of the permit

WHAT’S IN THE PERMIT ? SWRCB demanded water quality monitoring SWRCB demanded water quality monitoring Visual Monitoring Visual Monitoring Physical Monitoring-pH, temp, EC, turbidity Physical Monitoring-pH, temp, EC, turbidity Chemical Monitoring Chemical Monitoring Public Posting of the dischargers PAP for 30 day public comment period Public Posting of the dischargers PAP for 30 day public comment period Application Prohibitions-303(d) list Application Prohibitions-303(d) list

WHAT DO WE HAVE TO MONITOR FOR? Larvicides Larvicides Temephos Temephos Adulticides Adulticides Pyrethrin, Permethrin, Resmethrin, Sumithrin, Prallethrin, Etofenprox, Piperonyl Butoxide, Naled, Malathion, MGK 264 Pyrethrin, Permethrin, Resmethrin, Sumithrin, Prallethrin, Etofenprox, Piperonyl Butoxide, Naled, Malathion, MGK 264 Results will be compared to monitoring triggers for each active ingredient Results will be compared to monitoring triggers for each active ingredient

PROVISION COMPLIANCE Standard Provisions Standard Provisions Follow FIFRA, BMPS, Etc Follow FIFRA, BMPS, Etc Recordkeeping Recordkeeping 3 Year History 3 Year History Reporting Reporting Annual Requirements and Updates if Requested by State or Regional Boards Annual Requirements and Updates if Requested by State or Regional Boards Report to State or Region 24 hr before application or earliest feasible time Report to State or Region 24 hr before application or earliest feasible time Monitoring Monitoring Visual-Done by Individual Districts Visual-Done by Individual Districts Physical and Chemistry-Done by Coalition Physical and Chemistry-Done by Coalition URS will be developing a new Monitoring and Reporting Document URS will be developing a new Monitoring and Reporting Document

IMPAIRED 303 (d) LISTED WATERWAYS IN CALIFORNIA CALIFORNIA PERMIT PROHIBITS APPLICATIONS OF PRODUCTS TO WATERBODIES THAT ARE LISTED ON THE 303 (d) LISTING Pyrethrinnone Permethrinnone Resmethrinnone Sumithrinnone Prallethrinnone Etofenproxnone Nalednone MalathionONE CURRENTLY-THE SWRCB WILL BE INCLUDING THE SAME CLASS OF THOSE ABOVE THE MVCAC IS REQUESTING THIS PROVISION BE REMOVED

MONITORING BACKGROUND SAMPLE BACKGROUND SAMPLE DONE WITHIN 24 HOURS BEFORE APPLICATION DONE WITHIN 24 HOURS BEFORE APPLICATION EVENT SAMPLE EVENT SAMPLE DONE WITHIN 24 HOURS AFTER APPLICATION DONE WITHIN 24 HOURS AFTER APPLICATION POST EVENT SAMPLE POST EVENT SAMPLE DONE WITHIN 7 DAYS AFTER APPLICATION DONE WITHIN 7 DAYS AFTER APPLICATION

DISTRICT MONITORING Visual Monitoring Visual Monitoring Each Active Ingredient-Larvicides and Adulticides Each Active Ingredient-Larvicides and Adulticides 10% of all applications to Waters of the U.S. 10% of all applications to Waters of the U.S. Monitoring area description (pond, lake, open waterway, channel, etc.) Monitoring area description (pond, lake, open waterway, channel, etc.) Appearance of the waterway (sheen, color, clarity, etc.) Appearance of the waterway (sheen, color, clarity, etc.) Weather conditions (fog, rain, wind, etc.) Weather conditions (fog, rain, wind, etc.) Background, Event, Post Event Monitoring Background, Event, Post Event Monitoring

COALITION MONITORING EACH PRODUCT 6 EVENTS EACH YEAR IN 6 EVENTS EACH YEAR IN URBAN URBAN AGRICULTURAL AGRICULTURAL WETLAND WETLAND CHEMISTRY ANALYSIS CHEMISTRY ANALYSIS PHYSICAL (TEMP, pH, DO, EC, TURBIDITY) PHYSICAL (TEMP, pH, DO, EC, TURBIDITY) VISUAL MONITORING VISUAL MONITORING

PHYSICAL MONITORING Coalition will be responsible for collecting the physical requirements (temp, pH, turbidity, electrical conductivity, dissolved oxygen) Coalition will be responsible for collecting the physical requirements (temp, pH, turbidity, electrical conductivity, dissolved oxygen) Adulticides and Temephos will be done by URS Adulticides and Temephos will be done by URS Larvicides will be done by the Coalition Larvicides will be done by the Coalition Coalition will need volunteers to help collect data Coalition will need volunteers to help collect data Procedures will be developed to standardize the process and URS will provide training Procedures will be developed to standardize the process and URS will provide training

TOXICITY STUDY SWRCB REMOVED THE REQUIREMENT FOR TOXICITY FROM THE PERMIT HOWEVER, THE SWRCB WILL FUND A TOXICITY STUDY TO BE CONDUCTED BY THE UNIVERSITY OF CALIFORNIA FOR $500,000 SWRCB STAFF WOULD LIKE THE COALITION TO PARTICIPATE IN A “PILOT STUDY” THIS YEAR TO PREPARE FOR NEXT YEAR’S FULL IMPLEMENTATION THE COALITION WILL ONLY PARTICIPATE IF IT MEETS OUR NEEDS

WHAT NEXT? IF CHEMISTRY SAMPLES EXCEED TRIGGERS THEN MORE ANALYSIS COULD BE REQUIRED BY SWRCB (48 HR SAMPLE, 72 HR SAMPLE, ETC) TOXICITY STUDY RESULTS ARE YET UNDETERMINED AND COULD BE ADDED TO THE PERMIT LATER OPENS THE DOOR FOR MORE SAMPLING AND MORE MONEY

QUESTIONS