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Status of California NPDES Permit

Status of California NPDES Permit. TIMELINES. SEPTEMBER 2010-DRAFT PERMIT AVAILABLE FOR PUBLIC COMMENT OCTOBER 19, 2010-PUBLIC HEARING NOVEMBER 2 ND , 2010-PUBLIC COMMENTS DUE TO SWRCB JANUARY 4 TH , 2011-DRAFT PERMIT UP FOR SWRCB ADOPTION APRIL 2011-PERMIT ENACTED.

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Status of California NPDES Permit

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  1. Status of California NPDES Permit

  2. TIMELINES SEPTEMBER 2010-DRAFT PERMIT AVAILABLE FOR PUBLIC COMMENT OCTOBER 19, 2010-PUBLIC HEARING NOVEMBER 2ND, 2010-PUBLIC COMMENTS DUE TO SWRCB JANUARY 4TH, 2011-DRAFT PERMIT UP FOR SWRCB ADOPTION APRIL 2011-PERMIT ENACTED

  3. WHAT IS NEEDED FOR NPDES COMPLIANCE? • FILE A NOTICE OF INTENT (NOI) • PESTICIDE APPLICATION PLAN (PAP) • ADMINSTRATIVE FEE -$1500 ANNUALLY SWRCB STAFF WILL REVIEW THE APPLICATION PACKET-NO LONGER THROUGH THE REGIONAL BOARDS

  4. PROVISION COMPLIANCE • STANDARD PROVISIONS • FOLLOW FIFRA, BMPS, ETC • MONITORING • CHEMISTRY AND TOXICITY SAMPLING • RECORDKEEPING • 3 YEAR HISTORY • REPORTING • MONTHLY AND ANNUAL REQUIREMENTS

  5. WHAT DO WE HAVE TO MONITOR FOR? • LARVICIDES • TEMEPHOS • ADULTICIDES • PYRETHRIN, PERMETHRIN, RESMETHRIN, SUMITHRIN, PRALLETHRIN, ETOFENPROX, PIPERONYL BUTOXIDE, NALED, MALATHION, MGK 264 SAMPLING WILL BE DONE IN THREE ENVIRONMENTS-URBAN, AGRICULTURAL, WETLAND

  6. HOW MANY SAMPLES NEED TO BE TAKEN? EACH PRODUCT • 6 EVENTS EACH YEAR IN • URBAN • AGRICULTURAL • WETLAND • CHEMISTRY ANALYSIS • TOXICITY ANALYSIS • OTHER (TEMP, pH, DO, EC, TURBIDITY)

  7. CHEMISTRY ANALYSIS • 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

  8. TOXICITY SAMPLE • BACKGROUND SAMPLE • DONE WITHIN 24 HOURS BEFORE APPLICATION • EVENT SAMPLE • DONE WITHIN 24 HOURS AFTER APPLICATION

  9. WHAT NEXT? IF CHEMISTRY SAMPLES EXCEED TRIGGERS OR TOXICITY SAMPLE FAILS THEN MORE ANALYSIS COULD BE REQUIRED BY SWRCB (48 HR SAMPLE, 72 HR SAMPLE, ETC)

  10. HOW MUCH? WORST CASE-11 CONSTITUENTS CHEMISTRY • 18 SAMPLES PER ENVIRONMENT • 3 ENVIRONMENTS 11 X 18 X 3 = 594 SAMPLES @ $500 EACH = $297,000 TOXICITY • 12 SAMPLES PER ENVIRONMENT • 3 ENVIRONMENTS 11 X 12 X 3 = 396 SAMPLES @ $1000 EACH = $396,000 TOTAL COST FOR SAMPLING $693,000

  11. OTHER COSTS • COST OF PROGRAM MANAGER • FUTURE INVESTIGATION COSTS-DEPENDING ON FINDINGS FROM EXCEEDING TRIGGERS OR FAILED TOXICITY • TEMPERATURE, pH, DO, etc

  12. NEXT STEPS DEVELOP COALITION CONTINUE TO WORK WITH SWRCB STAFF TO MINIMIZE OUR REQUIREMENTS IN THE FUTURE WORK ON A FEDERAL LEGISLATIVE FIX

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