November 30, 2017

Transcription

1 Post Office Box 151 Bakersfield, CA 9332 Tel: (661) Fax: (661) November 3, 217 Pamela Creedon, Executive Officer Central Valley Regional Water Quality Control Board 1685 E Street Fresno, CA RE: Revised Pesticide Evaluation Protocol Proposal Dear Ms. Creedon: The Kern River Watershed Coalition Authority (KRWCA) is re-submitting a Pesticide Evaluation Protocol Proposal (Proposal) in response to monitoring requirements described in the Monitoring and Reporting Program required by Waste Discharge Requirements, General Order for Growers in the Tulare Lake Basin that are Members of a Third-Party Group, Order No. R (General Order). In November of 216 the Executive Officer issued a Pesticides Evaluation Protocol (Protocol) to be used by coalition groups to determine appropriate pesticides to be monitored under the Monitoring and Reporting Program for surface water. The KRWCA originally submitted a Protocol to the Regional Water Quality Control Board (RWQCB) on August 31, 217. The KRWCA received comments from RWQCB staff on October 5, 217. This re-submittal incorporates a revised relative risk ratio as well as clarification of exclusions for pesticide monitoring. The Protocol describes a process by which coalitions should evaluate pesticide use data to create monitoring prioritization based on aquatic life and human health reference values, as well as evaluating existing monitoring data, environmental fate factors, and availability of analytical methods. The resulting list is intended to be watershed specific and updated annually with the submittal of the Surface Water Monitoring Plan Update. Monitoring Plan Updates are due sixty days prior to the start of the coalitions monitoring year, which is October 1 st. The Executive Officer has granted an extension of 3 days for completion of the first year s Proposal, due September 1, 217. The steps detailed in the Protocol were followed to analyze relevant pesticide use records within the KRWCA boundary area. Pesticide application data was obtained through the Department of Pesticide Regulation s (DPR s) California Pesticide Information Portal (CalPIP) for Kern County for the years 213 to 215. Only pesticide use data in KRWCA surface water monitoring areas, Chanac Creek and El Paso Creek sub-watersheds, were selected from available CalPIP data. Pesticide application records for the watersheds were filtered to only chemicals included in the Executive Officer List of Pesticides for Consideration (Protocol, Attachment A). The monitoring proposal includes and prioritizes pesticides relevant to each defined step. The application records defined the total cumulative use for each month and annual use averaged by month in pounds of chemical, as well as the quantity of degradates and impurities resulting from application. These application results were grouped and ranked relative to aquatic life reference values and the percent annual application per month. Available surface water monitoring data was queried for the pesticides applied to determine if detections greater than 1% of the reference value were found in the watershed. Environmental fate of identified pesticides was reviewed to define those unlikely to be

2 KRWCA Pesticide Evaluation Protocol Proposal Page 2 of 3 found in the water column. Site and chemical specific considerations were reviewed, along with the availability of chemical analysis methods to determine pesticides which may not require monitoring. The list of proposed pesticides to monitor (see Attachment 1, Monitoring Proposal) illustrates months for which applications were significant relative to aquatic life reference values, and therefore monitoring is anticipated to occur. The enclosed CD contains worksheets detailing decisions to monitor, or not monitor, for each evaluated pesticide. As the Protocol was completed several determinations were made which are clarified below: CalPIP data was clipped to surface water monitoring areas using GIS selecting for sections within watershed or sub-watershed boundaries. Watersheds were determined using topographical information to delineate lines of highest elevation. For areas with minimal elevation variance, other factors such as physical barriers and intersecting waterways (canals or ditches) were used to determine the area of influence within the KRWCA boundary (see map, Attachment 2). The prioritization for human health reference values was omitted. The Water Quality Control Plan for the Tulare Lake Basin (Basin Plan) identifies the beneficial uses which apply to surface waters (Table II-1). The waterbodies monitored by the KRWCA are classified as Other East Side Streams which are not designated as having a Municipal and Domestic Supply beneficial use. Additionally, pesticides with Maximum Contaminant Levels (MCLs), but no other aquatic life protection limits or reference values, were eliminated from the Proposal based on beneficial uses identified in the Basin Plan. Given arid conditions, collected monitoring data is extremely limited in the KRWCA area. A description of available monitoring data is included in Attachment 3, Evaluation of Available Monitoring Data. The Protocol recommends a minimum of 2 samples, collected within 5 years, for sufficient quantity of data to be excluded from the ranking list; however, the Protocol also allows for coalition recommended criteria. Therefore, due to limited precipitation events and the ephemeral nature of monitored waterbodies, the KRWCA requests to extend the monitoring period for collected data from 5 years to 1 years. Additionally, if no detections for a specific pesticide occur within 1 years, the KRWCA requests to use a minimum of 5 samples to justify an exclusion for monitoring. The KRWCA will continue to work with RWQCB staff to determine how to appropriately incorporate previously collected surface water monitoring data to determine pesticides to be monitored. Legacy pesticide degradates included in previously submitted Management Plans were not included in the Proposal. Upon approval of submitted Management Plans the KRWCA will monitor for legacy pesticide degradates based on the agreed upon monitoring schedule. This re-submittal addresses comments previously received from RWQCB staff. Upon approval, the KRWCA will begin immediate implementation of the proposed pesticide monitoring. The KRWCA intends to continue to work with RWQCB staff to determine how to appropriately incorporate previously collected surface water monitoring data to establish pesticides to be monitored and will implement the approved proposal in the interim period.

3 KRWCA Pesticide Evaluation Protocol Proposal Page 3 of 3 Please contact our office if you or your staff have any questions. Respectfully, I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel or represented Members properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for knowingly submitting false information, including the possibility of fine and imprisonment for violations. Nicole Bell Manager Attachments: 1 - Monitoring Proposal 2 - Map, CalPIP Data Sections 3 - Summary of Available Surface Water Monitoring Data Pesticide Proposal Workbook (CD) cc: Sue McConnell, Central Valley Regional Water Quality Control Board David Sholes, Central Valley Regional Water Quality Control Board Susan Fregien, Central Valley Regional Water Quality Control Board Henry Jones, Central Valley Regional Water Quality Control Board

4 Attachment 1: Monitoring Proposal Pesticide Evaluation Protocol Proposal Attachment 1: Monitoring Proposal Table 1. Chanac Creek Monitoring Proposal April May June July Total Copper X X 2 Pyridaben X X 2 Grand Total Kern River Watershed Coalition Authority November 217 Attachment 1-1

5 Attachment 1: Monitoring Proposal Pesticide Evaluation Protocol Proposal Table 2. El Paso Monitoring Proposal Jan. Feb. March April May June July Aug. Sept. Oct. Nov. Dec. Total Bifenthrin X X X 3 Chlorpyrifos X X X X X X X 7 Copper X X X 3 Cyfluthrin X X X X X X X 7 Cypermethrin X X X 3 Fenpropathrin X X X 3 Flumioxazin X X 2 Imidacloprid X 1 Methomyl X X 2 Oxyfluorfen X X X X 4 Paraquat dichloride X X X X X X X X X 9 Pendimethalin X X 2 Simazine X 1 Grand Total Kern River Watershed Coalition Authority November 217 Attachment 1-2

6 Attachment 2: CalPIP Data Sections Chanac Creek # # El Paso Creek Sources: Esri, HERE, DeLorme, Intermap, increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN, GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri Japan, METI, Esri China (Hong Kong), swisstopo, MapmyIndia, OpenStreetMap contributors, and the GIS User Community I 5 Miles # 1 Existing Monitoring Site Outside RWQCB Region 5 KERN RIVER WCA Selected Section Kern River WCA - Primary Surface Water Monitoring Chanac Creek Watershed Kern River WCA - Supplemental El Paso Creek Watershed Select Sections for Pesticide Data Review

7 Attachment 3: Evaluation of Available Monitoring Data Pesticide Evaluation Protocol Proposal Attachment 3: Summary of Available Monitoring Data Readily available monitoring data was obtained as described in the Protocol, for the most recent 5 years ( ), within the sub-watersheds monitored by the KRWCA (Chanac Creek and El Paso Creek). Results of data queries are included in the enclosed CD. A search was completed in the California Environmental Data Exchange Network on July 6, 217. Query fields were selected for Kern County, Pesticides, Organics, and Pyrethroids. CEDEN data records in the applicable time period ( ) were only available for October 1, 212 through June 26, 214. No records were available for any dates after June 26, 214. Review of monitoring sites with available records resulted in no sites within the KRWCA boundary. Pesticide monitoring data collected by KRWCA was compiled for those records not available in CEDEN. Samples were collected at Chanac Creek and El Paso Creek for the following dates: Table 1. Collection Dates for Chanac Creek and El Paso Creek Chanac Creek El Paso Creek July 2, 215 January 6, 217 August 18, 215 September 15, 215 Samples were analyzed for pesticides as required by the 28 Conditional Waiver, Monitoring and Reporting Program. Pesticide monitoring results were non-detect except for samples of DDE (count 4), Carbaryl (count 1) and Glyphosate (count 1). A Management Plan for DDE and a completed source identification study were submitted to the Regional Water Quality Control Board for review on November 1, 216. A search was completed using the California Department of Water Resources, Surface Water Database (SURF) on July 25, 217. Sites proximate to those monitored by the KRWCA were identified on the SURF map. One SURF site was within the Chanac Creek sub-watershed, no SURF sites were within the El Paso Creek sub-watershed. Monitoring data was retrieved for the Chanac Creek monitoring site. All reported results were collected by the former Southern San Joaquin Valley Water Quality Coalition, collected in 21, and therefore outside of the date range identified within the Protocol. A search was conducted for surface water monitoring results in the United States Geologic Survey s National Water Information System. The Mapper tool was used to identify monitoring sites within the sub-watersheds monitored by KRWCA. No monitoring sites within the monitored sub-watersheds were identified ( Kern River Watershed Coalition Authority November 217 Attachment 3-1