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STATUS OF CALIFORNIA NPDES PERMIT

STATUS OF CALIFORNIA NPDES PERMIT. 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

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STATUS OF CALIFORNIA NPDES PERMIT

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  1. STATUS OF CALIFORNIA NPDES PERMIT

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

  3. WHAT IS NEEDED FOR NPDES COMPLIANCE? • File a Notice of Intent (NOI) • Pesticide Application Plan (PAP) • Monitoring and Reporting Plan • 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 • Meet the Requirements of the Monitoring Component of the Permit-Attachments B and C of the permit

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

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

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

  7. IMPAIRED 303 (d) LISTED WATERWAYS IN CALIFORNIA CALIFORNIA PERMIT PROHIBITS APPLICATIONS OF PRODUCTS TO WATERBODIES THAT ARE LISTED ON THE 303 (d) LISTING Pyrethrin none Permethrin none Resmethrin none Sumithrin none Prallethrin none Etofenprox none Naled none Malathion ONE CURRENTLY-THE SWRCB WILL BE INCLUDING THE SAME CLASS OF THOSE ABOVE THE MVCAC IS REQUESTING THIS PROVISION BE REMOVED

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

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

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

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

  12. 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

  13. 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

  14. QUESTIONS

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