Surface Water Quality Management Plan: Chlorpyrifos in Ulatis … · SVWQC ii May 2017 Appendix D:...

M A Y 2 0 1 7

SACRAMENTO VALLEY

WATER QUALITY COALITION

Surface Water Quality

Management Plan:

Chlorpyrifos in Ulatis Creek

prepared by

LARRY WALKER ASSOCIATES

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Table of Contents 1 Introduction and Background ................................................................................ 1

1.1 Constituent of Concern (COC) .......................................................................... 2

1.2 Trigger Limits ..................................................................................................... 2

1.3 Management Plan Boundaries .......................................................................... 3

2 Physical Setting and Information .......................................................................... 3

2.1 Land Use Characterization and Beneficial Uses ............................................... 3

2.2 Constituent of Concern Sources, Fate, and Transport ...................................... 6

2.3 Baseline Practices Inventory ............................................................................. 9

2.4 Constituent of Concern: Water Quality Data ................................................... 11

3 Management Plan Strategy .................................................................................. 12

3.1 Management Plan Approach ........................................................................... 12

3.2 Actions and Tasks ........................................................................................... 13

3.2.1 Summary of Actions Taken to Date ............................................................. 13

3.2.2 Performance Goals...................................................................................... 18

3.2.3 Member Education ...................................................................................... 18

3.2.4 Management Practices ................................................................................ 19

3.2.5 Management Plan Implementation Schedule .............................................. 19

3.3 Duties and Responsibilities ............................................................................. 23

4 Monitoring Design ................................................................................................. 24

4.1 Monitoring ........................................................................................................ 25

5 Data Evaluation ..................................................................................................... 25

5.1 Evaluation of Management Plan Effectiveness ............................................... 25

6 Records and Reporting......................................................................................... 26

6.1 Documentation and Reporting ......................................................................... 26

Appendix A: Chlorpyrifos Pesticide Use Report Data in the Cache Slough Represented Drainages .............................................................................................. A-1

Appendix B: Pathways for Transport of Agriculturally Applied Chlorpyrifos to Surface Waters and Practices to Minimize Risk of Off-site Transport ................... B-1

Appendix C: Chlorpyrifos Interim Recommended Permit Conditions ................... C-1

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Appendix D: Dixon/Solano Coalition Targeted Educational Outreach Efforts Regarding Chlorpyrifos Exceedances and Associated Management Practices: 2011 – 2016 .................................................................................................................. D-1

Table of Contents Figure 1: Management Plan Boundaries for the Cache Slough Represented Drainages.

.................................................................................................................................. 4

Figure 2: Land Use Characterization of the Cache Slough Represented Drainages. ...... 5

Figure 3: Chlorpyrifos Applications in Cache Slough Represented Drainages, 2003 – 2014. ....................................................................................................................... 12

Figure 4: Comparison of Irrigation Practices Implementation Based on Targeted Chlorpyrifos Management Practices Surveys (2012 – 2013) and Farm Evaluation Surveys (2014 – 2015). ........................................................................................... 15

Figure 5: Ulatis Creek Management Plan for Chlorpyrifos – Project Organization ........ 24

Table 1: Summary of Scope of Management Plan Implementation. ................................ 2

Table 2: Land Use Characteristics for Cache Slough Drainage and Represented Drainages. ................................................................................................................. 6

Table 3: Beneficial Uses Designated for Cache Slough and Represented Drainages. ... 7

Table 4: Baseline Summary of Practices Implemented in the Cache Slough and Represented Drainages to Prevent Chlorpyrifos from Entering Surface Waters. ..... 9

Table 5: Chlorpyrifos Exceedances Observed in the Cache Slough Drainage: February 2006 – May 2015. ................................................................................................... 11

Table 6: Irrigation System and Irrigation Water Management Practices in the Dixon/Solano Subwatershed Approved for Financial Assistance from the USDA NRCS EQIP Bay Delta Initiative during 2013 – 2016. ............................................. 15

Table 7: USDA NRCS EQIP Funding for Projects Administered through the NRCS Dixon Service Center: 2013 – 2016. ....................................................................... 16

Table 8: Management Practice Performance Goals for Chlorpyrifos Applications in the Cache Slough Drainage and Represented Drainages. ........................................... 20

Management Practices Implementation and Performance Goals: Chlorpyrifos in Ulatis Creek

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1 Introduction and Background The purpose of this Management Plan is to provide the Central Valley Water Board with an update to the Management Plan Implementation and Performance Goals (MPIPG) submitted in March 2013 and to document the progress made to date and the plan and schedule to address agricultural causes of chlorpyrifos exceedances observed in Sacramento Valley Water Quality Coalition (Coalition) Irrigated Lands Regulatory Program (ILRP) monitoring in Ulatis Creek. The elements included in this Management Plan Update conform to the Coalition’s Waste Discharge Requirements (WDR), Order No. R5-2014-0030-R1, as issued under the ILRP, as well as incorporate new requirements from the classification of chlorpyrifos as a state-restricted material in 2015. The need for performance goals related to chlorpyrifos was confirmed in the July 2012 document Source Evaluation Report: Chlorpyrifos in Ulatis Creek1. The relevant conclusions established in the 2012 Source Evaluation Report are as follows:

Agriculture was a likely contributing source of the observed chlorpyrifos exceedances. Coalition participants farming on high-priority parcels in the represented drainages were previously surveyed for crop type, pesticide use, and other management practice implementation relevant to pesticide applications. The Dixon/Solano Resource Conservation District (RCD) Agricultural Water Quality Coalition (Dixon/Solano Coalition) was identified to re-evaluate the results of earlier surveys to determine if additional information is needed to establish new implementation goals for the chlorpyrifos Management Plan for Ulatis Creek.

Alfalfa, walnuts, and almonds accounted for the majority of agricultural applications relevant to observed chlorpyrifos exceedances. These crops should be the priority for surveys and outreach.

Early irrigation season return flows appeared to be the likely source of at least one exceedance (May 2011), and storm runoff was a probable contributor to one (March 2012) of the three exceedances that had occurred up through March 2012. Overspray or drift from aerial and ground applications were also identified as potential contributing transport mechanisms for at least one exceedance (September 2011).

Additional chlorpyrifos exceedances observed in Ulatis Creek since the release of the Source Evaluation Report were evaluated in the Coalition’s Annual Monitoring Reports for the years 2012 and 2015, and were linked to the application of chlorpyrifos to alfalfa prior to the observance of both the May 2012 and May 2015 exceedances.

The Ulatis Creek monitoring location (Ulatis Creek at Brown Road (UCBRD)) is in the Cache Slough Drainage in the Solano Subwatershed. The UCBRD monitoring location

1 Source Evaluation Report: Chlorpyrifos in Ulatis Creek. Sacramento Valley Water Quality Coalition. July 2012.


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is currently used by the Coalition as a representative monitoring location for the Irrigated Lands Regulatory Program (ILRP). The Cache Slough drainage represents the drainages of Putah Creek South, Southwest Yolo Bypass, and the Sacramento River drainage in the Solano Subwatershed (Sacramento River – Solano).

The implementation goals presented in this document are intended to address and minimize chlorpyrifos discharges and exceedances due to agricultural uses of chlorpyrifos in the Cache Slough, Putah Creek South, Southwest Yolo Bypass, and Sacramento River – Solano drainages. The geographic scope and crops targeted for the implementation of these practices are summarized in Table 1.

Table 1: Summary of Scope of Management Plan Implementation.

Management Plan Category (PRIORITY) Registered Pesticides (HIGH)

Subwatershed Solano

Representative Water Body Ulatis Creek

Represented Drainages Cache Slough, Putah Creek South, Southwest Yolo Bypass, and Sacramento River - Solano

Analyte(s) of concern Chlorpyrifos

Crops Identified in Source Evaluation Alfalfa, Almonds, Walnuts

Season Alfalfa: Late Winter, pre-Irrigation Season (March)

Almonds and Walnuts: Irrigation Season (May – September)

1.1 CONSTITUENT OF CONCERN (COC)

Chlorpyrifos is a crystalline organophosphate insecticide and is the constituent of concern addressed in this Management Plan. Chlorpyrifos is categorized as a registered pesticide and is determined to have a high priority for development of management plan implementation and performance goals when its concentrations at Coalition monitoring sites are observed to exceed applicable water quality objectives (WQOs) or trigger limits. Chlorpyrifos has also been identified as a high priority constituent by the California Department of Pesticide Regulation (CDPR) and was classified as a state-restricted material2 in 2015.

1.2 TRIGGER LIMITS

The Coalition’s Order requires that Members comply with all adopted WQOs and established federal water quality criteria applicable to their discharges. The Order specifies the use of applicable numeric and narrative WQOs in the Water Quality Control

2 State-restricted materials are pesticides deemed to have a higher potential to cause harm to public health, farm workers, domestic animals, honeybees, the environment, wildlife, or other crops compared to other pesticides. Additional information available at: http://www.cdpr.ca.gov/docs/enforce/permitting.htm


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Plan for the Sacramento River and San Joaquin River Basins (Basin Plan), and the criteria in USEPA’s 1993 National Toxics Rule (NTR) and 2000 California Toxics Rule (CTR), which constitute numeric WQOs when combined with the Basin Plan’s beneficial use designations. The numeric objectives from these sources are compiled in Table 5 of the Order’s Monitoring and Reporting Program (MRP).

The Order’s MRP establishes management plan trigger limits that are equivalent to the applicable Basin Plan numeric WQOs. The Coalition is required to prepare exceedance reports if surface water monitoring results show exceedances of adopted numeric WQOs or trigger limits that are based on interpretations of narrative WQOs. In locations where management plan trigger limits are exceeded, water quality management plans must be developed that will form the basis for reporting which steps have been taken by growers to achieve compliance with numeric and narrative WQOs.

The ILRP management plan trigger limit (a Basin Plan WQO) for chlorpyrifos is 0.015 µg/L. This concentration is the chronic (4-day average exposure) WQO included in the Basin Plan to protect aquatic life, wildlife, and humans. The Basin Plan also includes an acute (1-hour average exposure) WQO of 0.025 µg/L. The Coalition compares all of its chlorpyrifos monitoring data to both of these WQOs.

1.3 MANAGEMENT PLAN BOUNDARIES

As described above, the geographic boundaries of the Management Plan for Ulatis Creek includes the representative Cache Slough drainage, as well as the represented drainages of Putah Creek, Southwest Yolo Bypass, and Sacramento River – Solano. All four drainages and the Coalition monitoring site (UCBRD) on Ulatis Creek are shown in Figure 1.

2 Physical Setting and Information

2.1 LAND USE CHARACTERIZATION AND BENEFICIAL USES

The boundaries, crop categories, and land uses within each of the four drainages considered by this Management Plan are shown in Figure 2. The boundaries and land use characteristics for the Cache Slough drainage and the three represented drainages are also listed in Table 2.

Designated beneficial uses that are relevant to the implementation of the ILRP are municipal and domestic water supply (MUN), agricultural water supply (AGR), contact recreation (REC-1), and aquatic life uses including freshwater habitat, migration, and spawning for cold water and warm water species (WARM, COLD). Specific beneficial uses have been designated in the Central Valley Basin Plan only for the Sacramento River and direct perennial tributaries to the Sacramento River in this subwatershed.


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Figure 1: Management Plan Boundaries for the Cache Slough Represented Drainages.


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Figure 2: Land Use Characterization of the Cache Slough Represented Drainages.


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Table 2: Land Use Characteristics for Cache Slough Drainage and Represented Drainages.

Drainage Drainage Acres(1)

Irrigated Acres (non-

rice)(1)(2)

% Irrigated Acres (non-

rice)(1)(2) Major Crop Types(3)

Cache Slough 236,346 86,108 36.4 Pasture, Alfalfa, Tomatoes, Almonds, Walnuts, Wheat, Triticale, Sunflowers, Corn

Putah Creek South

38,230 13,684 35.8 Tomatoes, Walnuts, Alfalfa, Sunflowers, Wheat

Southwest Yolo Bypass

22,658 13,839 61.1 Pasture, Alfalfa, Sunflowers, Tomatoes

Sacramento River – Solano

24,836 247 1.0 Alfalfa, pasture, grapes

1. California Department of Water Resources (DWR). 2013. Land Use Surveys by County. Vector data available at http://www.water.ca.gov/landwateruse/lusrvymain.cfm. Accessed September 2014.

2. California Department of Pesticide Regulation (DPR). 2013. Pesticide Use Reporting (PUR) Field Boundaries Land Use Data. GIS file. Accessed November 2013 by county from County Agricultural Commissioner.

3. Crop type information from 2015 Farm Evaluation Survey results.

The beneficial uses for Cache Slough and each of the represented drainages shown in Table 3 are taken from Table II-1 of the Basin Plan. Various water bodies in the Cache Slough drainage are identified in the Basin Plan (Appendix 42) as Delta Waterways. Those reaches of these Delta Waterways that reside in the “Legal” Delta are assigned the beneficial uses designated for the Sacramento-San Joaquin Delta. Beneficial uses for the Putah Creek South drainage are those designated for the Putah Creek: Lake Berryessa to Yolo Bypass surface water body segment; beneficial uses for the Southwest Yolo Bypass drainage are those designed for the Yolo Bypass surface water body; and the beneficial uses for the Sacramento River drainage in the Solano Subwatershed are those designated for the Sacramento-San Joaquin Delta.

2.2 CONSTITUENT OF CONCERN SOURCES, FATE, AND TRANSPORT

Pesticide application data from the California Department of Pesticide Regulation (CDPR) presented in the Source Evaluation Report: Chlorpyrifos in Ulatis Creek describes the agricultural application of chlorpyrifos on alfalfa during late winter and the pre-irrigation season (March) and on almonds and walnuts (typically May through September) for the control of insects. These application periods are supported by more recent CDPR pesticide use report (PUR) data from 2012 – 2014 that show peak chlorpyrifos application in the months of July and August, followed by March, May, February, and April, with more modest applications made in September, June, October and January (see Figure 1A in Appendix A).


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Table 3: Beneficial Uses Designated for Cache Slough and Represented Drainages.

Beneficial Uses for Surface Water as Defined in Basin Plan

Cache Slough(1)(2)

Putah Creek

South(3) SW Yolo Bypass(4)

Sac River – Solano(5)

Municipal and Domestic Supply (MUN) E(6)(7) E E

Agricultural Supply: Irrigation (AGR) E E E E

Agricultural Supply: Stock Watering (AGR)

E E E E

Industrial Process Supply (PRO) E E

Industrial Service Supply (IND) E E

Water Contact Recreation (REC 1) E E E E

Non-contact Water Recreation (REC-2) E E E E

Warm Freshwater Habitat (WARM) E E E E

Cold Freshwater Habitat (COLD) E(6) or P P P E

Migration of Aquatic Organisms: Warm Water (MIGR)

E(6) or n/a E E

Migration of Aquatic Organisms: Cold Water (MIGR)

E(6) or n/a E E

Fish Spawning, Warm Water (SPWN) E(6) E E E

Fish Spawning, Cold Water (SPWN) E(6) or n/a E

Wildlife Habitat (WILD) E E E E

Commercial and Sport Fishing (COMM) E or n/a E E

Legend/Notes:

E = Existing Basin Plan Designated Beneficial Use, P = Potential Beneficial Use;

Source: Water Quality Control Plan for the Sacramento River and San Joaquin River Basin, Fourth Edition, Revised July 2016 (CVRWQCB, 2016).

1. The following water bodies in the Cache Slough Drainage are identified as Delta Waterways (Basin Plan Appendix 42) having all or a portion of their extent residing within the legal Delta boundary: Alamo Creek (Old Alamo Creek, New Alamo Creek), Barker Slough, Cache Slough, Elkhorn Slough, Haas Slough, Lindsey Slough, Miner Slough, Prospect Slough, Steamboat Slough, Sweany Creek, and Ulatis Creek) and there beneficial uses are those designated for the Sacramento-San Joaquin Delta.

2. For all or a portion of the extent of the following water bodies that reside outside of the legal Delta boundary, it is assumed that their beneficial uses are the same as those designated for Putah Creek: Lake Berryessa to Yolo Bypass segment: Alamo Creek (Old Alamo Creek, New Alamos Creek), Barker Slough, Encinosa Creek, English Creek, Gibson Canyon Creek, Laguna Creek, Putah South Canal, Sweany Creek, and Ulatis Creek.

3. Beneficial uses for the Putah Creek South Drainage are described in the Basin Plan by the Putah Creek: Lake Berryessa to Yolo Bypass segment.

4. Beneficial uses for the Southwest Yolo Bypass Drainage are described in the Basin Plan by the Yolo Bypass segment.

5. Beneficial uses for the Sacramento River drainage in the Solano Subwatershed are described in the Basin Plan as those beneficial uses designated for the Sacramento-San Joaquin Delta.

6. MUN, COLD, MIGR, and SPWN do not apply to Old Alamo Creek (Basin Plan II-2.00).


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7. New Alamo Creek and Ulatis Creek are designated with the MUN beneficial use (Basin Plan IV-37.05).

The crop receiving the greatest application of chlorpyrifos on a pounds (lbs.) applied basis is alfalfa, followed by walnuts and almonds (see Figure A2 in Appendix A). The Coalition’s 2015 Farm Evaluation Survey data show that alfalfa, walnuts, and almonds account for approximately 34% of the total reported acreage in the Cache Slough drainage. Information contained in 2012 – 2014 PURs also shows that small amounts of chlorpyrifos are applied for insect control in Solano County for the following non-agricultural uses: rights of way, structural pest control, and : landscape maintenance (see Figure A3 in Appendix A). PUR data collected from 2003 – 2014 show that acres treated with chlorpyrifos in the Cache Slough drainage have varied over time, as they have in the Cache Slough represented drainages. The annual variability in chlorpyrifos-treated acreage shows no discernable trend or pattern for either the Cache Slough drainage or the represented drainages (see Figures A4 and A5, respectively, in Appendix A).

Chlorpyrifos has low solubility in water and partitions fairly strongly to organic compounds and particles. Due to these characteristics, chlorpyrifos is not transported readily in the dissolved form. However, chlorpyrifos is also a moderately persistent chemical – it breaks down by photolysis (half-life of 30 days) and hydrolysis (half-life of 25 days) and has an estimated typical field dissipation half-life of 21 days. Based on these characteristics, chlorpyrifos applications have a moderate potential to persist and be transported to surface waters in detectible concentrations up to two months after applications; although this risk is much greater within one month of application.

Based on potential transport pathways, effective best management practices (BMPs) that could be employed, and in many cases are already employed, by growers and applicators to reduce the risks of chlorpyrifos contamination in surface waters include:

Using alternative pest control materials (i.e., using non-chlorpyrifos pesticides)

Reducing the quantity of pesticides applied by monitoring pest and beneficial populations to determine need for pesticides and the best timing for maximum control

Reducing the quantity of pesticides applied with spray buffers at field edges and near ditches

Reducing drift by regular calibration of sprayers for pesticide applications

Reducing drift by using electrostatic sprayer equipment

Reducing drift by using effective drift control mechanisms

Maximizing time between application and planned irrigation runoff and/or predicted storm runoff events in order to reduce loss of applied pesticides from foliage, transport on soils, and transport of pesticides dissolved in tailwater

Changing to more efficient application methods (e.g., ground vs. aerial applications and/or equipment that provides more precise applications)

Installation of vegetated filters between application areas and ditches and/or allowing vegetation to grow in drainage ditches to reduce movement of pesticides bound to soil


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particles and contamination from aerial overspray (Note: vegetated BMPs may be less effective for very fine-textured clay soils.)

Reducing irrigation tail water through conversion from flood or furrow irrigation to buried drip, sprinkler, or micro-irrigation where applicable

Reducing irrigation tailwater with tailwater return systems

Reducing or delaying irrigation tailwater through irrigation water management

A diagram showing the general pathways for transport of agriculturally applied chlorpyrifos to surface waters and practices to minimize the risk of off-site chlorpyrifos transport is provided in Appendix B.

2.3 BASELINE PRACTICES INVENTORY

The Coalition’s 2015 Farm Evaluation Survey data show that growers and applicators in the Cache Slough drainage and represented drainages are currently implementing a suite of practices in the following two categories that contribute to preventing chlorpyrifos from entering surface waters: pesticide application practices and cultural practices to manage sediment and erosion. A baseline summary of practices by (1) practice category and (2) number of acres represented by an individual practice is provide in Table 4.

Table 4: Baseline Summary of Practices Implemented in the Cache Slough and Represented Drainages to Prevent Chlorpyrifos from Entering Surface Waters.

PRACTICE CATEGORY Acres

Reported

Percent of Total Acres

(125,454 acres) Individual Practice

PESTICIDE APPPLICATION PRACTICES

Follow label restrictions 114,978 91.7

Avoid surface water when spraying 113,366 90.4

Monitor wind conditions 112,606 89.8

County permit followed 111,290 88.7

Use PCA recommendations 110,728 88.3

Attend trainings 107,574 85.7

Monitor rain forecasts 106,129 84.6

Use appropriate buffer zones 104,664 83.4

End of row shutoff when spraying 104,087 83.0

Use drift control agents 101,979 81.3

Sensitive areas mapped 75,733 60.4

Reapply rinsate to treated field 68,238 54.4


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PRACTICE CATEGORY Acres

Reported

Percent of Total Acres

(125,454 acres) Individual Practice

Use vegetated drain ditches 47,343 37.7

Target sensing sprayer used 18,702 14.9

No pesticides applied 10,799 8.6

Other1 6,414 5.1

Chemigation 6,338 5.1

No Selection 152 0.1

CULTURAL PRACTICES TO MANAGE SEDIMENT AND EROSION

Soil water penetration has been increased through the use of amendments, deep ripping and/or aeration.

87,137 69.5

Crop rows are graded, directed and at a length that will optimize the use of rain and irrigation water.

70,962 56.6

Minimum tillage incorporated to minimize erosion. 58,597 46.7

Vegetated ditches are used to remove sediment as well as water soluble pesticides, phosphate fertilizers and some forms of nitrogen.

47,738 38.1

Cover crops or native vegetation are used to reduce erosion.

42,193 33.6

Storm water is captured using field borders. 40,325 32.1

Berms are constructed at low ends of fields to capture runoff and trap sediment.

26,184 20.9

Sediment basins / holding ponds are used to settle out sediment and hydrophobic pesticides such as pyrethroids from irrigation and storm runoff

23,511 18.7

Subsurface pipelines are used to channel runoff water. 23,356 18.6

Creek banks and stream banks have been stabilized. 17,426 13.9

Vegetative filter strips and buffers are used to capture flows.

15,443 12.3

Hedgerows or trees are used to help stabilize soils and trap sediment movement.

12,439 9.9

No storm drainage due to field or soil conditions. 8,842 7.0

Other 8,479 6.8

Field is lower than surrounding terrain. 3,429 2.7

No Selection 1,662 1.3


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2.4 CONSTITUENT OF CONCERN: WATER QUALITY DATA

The Coalition has observed six exceedances of the 0.015 µg/L chronic Basin Plan objective for chlorpyrifos in the Cache Slough drainage since it began sampling in February 2006. Concentrations in three of those samples also exceeded the 0.025 µg/L acute Basin Plan objective for the pesticide. The total number of sample events with exceedances for chlorpyrifos in the drainage is six out of 843 sample events. The current monthly monitoring performed by the Delta Regional Monitoring Program (Delta RMP) since July 2015 has observed no exceedances of the 0.015 µg/L chronic Basin Plan objective for chlorpyrifos through March 2017. Chlorpyrifos exceedances observed in the Cache Slough drainage from February 2006 through March 2017 are shown in Table 5. The most recent exceedance observed in May 2015 was likely caused by application of chlorpyrifos to alfalfa based on pesticide use reports.

A trend analysis of chlorpyrifos data collected at the UCBRD monitoring location was performed as part of the Coalition’s 2015 Annual Monitoring Report. The data were initially evaluated using the Spearman’s non-parametric test for detection of a trend (concentration vs sample date). The Spearman’s test found a significant increasing trend in chlorpyrifos concentrations in Ulatis Creek over time when evaluating the data set that extends from February 28, 2006 (Event 9) to August 18, 2015 (Event 114). However, the trend since the Management Plan was triggered is predominantly improving with the exception of the most recent exceedance in May 2015. Chlorpyrifos use in the represented drainages varies annually due to pest pressures and cultural conditions (rainfall, temperature, crop choices, etc.), but has generally exhibited a decreasing pattern from the peak use observed in 2008. Although chlorpyrifos applications in 2014 are comparable to higher levels seen in the mid-2000s. The overall use pattern in the represented drainages (see Figure 3) is very similar to that in the Cache Slough drainage (Figures A4 and A5, Appendix A).

Table 5: Chlorpyrifos Exceedances Observed in the Cache Slough Drainage: February 2006 – May 2015.

Site Date Event Replicate Analyte (µg/L) Result

UCBRD 02/28/2006 9 2

Chlorpyrifos - Unfiltered

0.0225

05/17/2011 63 1 0.0368(1)

09/20/2011 67 1 0.0162

03/14/2012 73 1 0.0222

05/15/2012 75 1 0.038(1)

05/19/2015 111 1 0.035(1)

1. Chlorpyrifos concentration measured in sample also exceeded the 0.025 µg/L acute Basin Plan objective

3 Eighty-four (84) sample events included 63 samples collected by the Sacramento Valley Water Quality Coalition and 21 samples collected by the Delta Regional Monitoring Program.


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Figure 3: Chlorpyrifos Applications in Cache Slough Represented Drainages, 2003 – 2014.

3 Management Plan Strategy Because chlorpyrifos is a registered pesticide that has been determined to have high potential for affecting aquatic life, high probability of direct agricultural use, and high probability for the successful implementation of management actions to control its discharge to surface waters, Dixon/Solano Coalition Members in the Cache Slough represented drainages are required to implement a chlorpyrifos management strategy to reduce the risk of exceedances of the pesticide above its WQO and thus, help to improve surface water quality in the drainage.

3.1 MANAGEMENT PLAN APPROACH

Efforts to address chlorpyrifos exceedances observed in Ulatis Creek began in 2011 and have been ongoing and effective. The focus from 2011 through 2013 was intensive outreach and education at all levels (growers, applicators, pest control advisors (PCAs)) to ensure that all past, current, and potential users of chlorpyrifos were aware of the exceedances, the likely methods of transport of chlorpyrifos, and the recommended practices to address discharge of the pesticide to surface waters. The Dixon/Solano Coalition documented its Management Plan approach in these early years in the Management Practices Implementation and Performance Goals: Chlorpyrifos in Ulatis Creek Report4. In 2012 through 2016, growers have implemented practices focused on management of irrigation tailwater (installation of irrigation systems and/or irrigation

4 Management Practices Implementation and Performance Goals: Chlorpyrifos in Ulatis Creek. Prepared by the Dixon/Solano Resource Conservation District Agricultural Water Quality Coalition and Larry Walker Associates. March 2013.


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management measures that reduce velocity and amount of tailwater), the use of alternative pest control materials, and additional pesticide application practices.

The Subwatershed’s current and future approach to managing chlorpyrifos exceedances in the Cache Slough drainage and represented drainages includes two main elements. The first is to maintain the high degree of awareness of the past chlorpyrifos exceedances in Ulatis Creek and the implementation of management practices currently employed in the Cache Slough drainage and represented drainages related to pesticide application practices and cultural practices to manage sediment and erosion. These are practices that are known to control or reduce the risk of discharges of chlorpyrifos to surface waters. Based on the results of the 2015 Farm Evaluation Survey, as summarized in the Baseline Practices Inventory provided in Table 4, nearly all growers in the four drainages are already implementing the agricultural practices necessary to prevent discharges of chlorpyrifos to surface waters. The Dixon/Solano Coalition will continue to encourage Coalition Members in the Cache Slough represented drainages to continue implementation of the practices summarized in Table 4 under this Management Plan. The second element of the approach is to coordinate with the Solano County Agricultural Commissioner’s office to further educate growers and applicators about application requirements and recommended practices to reduce or prevent off-site discharges through implementation of required restricted materials permits for chlorpyrifos. All growers or applicators choosing to use chlorpyrifos will receive this information when interacting with Solano County Agricultural Commissioner’s staff with respect to chlorpyrifos use, and this interaction is expected to further increase implementation of effective practices by growers in the Cache Slough represented drainages.

3.2 ACTIONS AND TASKS

3.2.1 Summary of Actions Taken to Date

The following specific actions have been taken to date to address the historical chlorpyrifos exceedances observed in Ulatis Creek:

2011 – 2012 Monitoring Years Targeted Outreach: Chlorpyrifos exceedances were discussed in annual newsletters and relevant outreach events since the exceedances were first observed. Since the Management Plan was triggered in 2011, newsletters discussing the exceedances were mailed to 581 members, and 114 members attended seven different meetings or workshops for that discussed management practices relevant to reduce or prevent the discharge of chlorpyrifos to surface waters. In March 2012, Dixon/Solano Coalition staff conducted individual phone calls to 18 growers who had applied chlorpyrifos to alfalfa in 2011 to alert them to the issue and let them know that applications for alfalfa weevil control appeared to be a likely source of the exceedances.

2013 Monitoring Year Targeted Outreach: In January 2013, Dixon/Solano Coalition staff sent Pre-Spring Insecticide Season of Use Water Quality Alerts to all alfalfa and orchard growers in Solano County within the Central Valley Regional Water Quality Control Board’s jurisdiction (120 growers in total). The same information was also sent to


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our entire Dixon/Solano Coalition memberships (580 members) and 25 commercial applicators and PCAs.

2013 Monitoring Year Chlorpyrifos Management Practices Survey: In February – March 2013, Dixon/Solano Coalition staff conducted phone surveys with 46 registered users of chlorpyrifos products (applied to roughly 63,000 acres of crops), as well as seven PCAs used by these registered users and two commercial applicators.

2014 Monitoring Year Chlorpyrifos Management Practices Survey: In February – March 2014, Dixon/Solano Coalition staff conducted phone surveys with the same 46 registered users of chlorpyrifos products that were surveyed in 2013, as well as four additional individuals who used chlorpyrifos in 2013 that had not used the pesticide in 2011 or 2012.

2014 Monitoring Year Targeted Outreach: Dixon/Solano Coalition staff presented information regarding past chlorpyrifos exceedances and practices to prevent future exceedances at three (3) Solano County Agricultural Commissioner applicator trainings with 104 total participants. Season of Use reminders were sent on March 6, 2014, via email or mail to 59 alfalfa growers and 35 PCAs/professional applicators along with alternative product research results and recommended management and application practices.

2015 Monitoring Year Targeted Outreach: Dixon/Solano Coalition staff presented information regarding past chlorpyrifos exceedances and practices to prevent future exceedances at two (2) Solano County Agricultural Commissioner applicator trainings with 68 total participants (34 participants on Nov. 20, 2014 and 34 participants on Dec. 11, 2014). Coalition staff sent an email ALERT on August 2015 regarding the May 2015 chlorpyrifos exceedance observed in Ulatis Creek to 82 individuals (36 PCAs, 35 growers, and 11 advisors). Coalition staff also held three (3) meetings with 35 participants in total (15 PCAs on Nov. 5, 2014, 10 growers that farm multiple landowners on Dec. 10, 2014, and 10 PCAs on Jan. 27, 2015) to review new farm reporting requirements and to discuss past chlorpyrifos exceedances in Ulatis Creek.

2016 Monitoring Year Targeted Outreach: Dixon/Solano Coalition staff presented information regarding past chlorpyrifos exceedances and practices to prevent future exceedances at three (3) Solano County Agricultural Commissioner applicator trainings with 121 total participants (30 participants on Nov. 19, 2015, 45 participants on Dec. 10, 2015, and 46 participants on Jan. 21, 2016).

Increased installation of microirrigation systems and irrigation water management practices: The Dixon/Solano Coalition and its technical agency partners have stressed the value of irrigation management in addressing offsite movement of pesticides to surface waters. A comparison of percentages of implemented irrigation types compiled from targeted chlorpyrifos survey responses from 2012 and 2013 as compared to Farm Evaluation survey results from 2014 and 2015 shows a steady increase in installation of microirrigation (including microsprinkler and drip systems) over this time period (see Figure 4). United States Department of Agriculture Natural Resources Conservation Service (USDA NRCS) and the Solano County Water Conservation Committee have been key partners in providing technical and financial assistance to help install new systems, as well as to provide education on improved irrigation water management. The number of acres approved for financial assistance for water quality-related irrigation practices from USDA NRCS are presented in Table 6.


SVWQC 15 May 2017

USDA NRCS Cost-Share Assistance: In 2013 – 2016, the local NRCS Dixon Service Center received $500,000 in additional Environmental Quality Incentives Program (EQIP) funding specifically to assist local growers in addressing water quality issues. Since 2013, 56 EQIP contracts covering 6,034 acres of crop and pasture land have been approved for funding under this program (see Table 7). These contracts have included 48 water quality-related practices.

Figure 4: Comparison of Irrigation Practices Implementation Based on Targeted Chlorpyrifos Management Practices Surveys (2012 – 2013) and Farm Evaluation Surveys

(2014 – 2015).

Table 6: Irrigation System and Irrigation Water Management Practices in the Dixon/Solano Subwatershed Approved for Financial Assistance from the USDA NRCS EQIP Bay Delta Initiative during 2013 – 2016.

Practice 2013 2014 2015 2016 Total

Microirrigation (acres) 512.4 359.2 310.3 82.6 1264.5

Irrigation System, Sprinkler (acres) 133.6 111.7 38.7 18.5 302.5

Irrigation Water Management (acres) 459.6 194.3 1288.6 399.9 2342.4

Total 1105.6 665.2 1637.6 501.0 3909.4

0%

20%

40%

60%

80%

100%

2012 2013 2014 2015

2012 - 2015 Coalition Survey Responses regarding Irrigation Practices Implemenation

(total acres surveyed varies by year)

Percentage of Total Acres Surveyed using Microirrigation

Percentage of Total Acres Surveyed using Flood/Furrow Irrigation


SVWQC 16 May 2017

Table 7: USDA NRCS EQIP Funding for Projects Administered through the NRCS Dixon Service Center: 2013 – 2016.

Fiscal Year

Number of

Contracts

Water Conservation

Practices

Water Quality

Practices

Wildlife Habitat

Practices Obligations Acres

2013 22 34 19 18 $724,067 2,036

2014 16 34 9 13 $800,941 1,621

2015 12 39 19 10 $733,777 1,911

2016 6 16 1 0 $263,536 466

Total 56 123 48 41 $2,522,321 6,034

Agricultural Water Conservation Committee Outcome Metrics: The numbers of growers participating in irrigation water management activities including system evaluations, pump tests, weather data subscriptions of evapotranspiration (ET) calculations, and soil moisture monitoring equipment.

o Forty-four (44) growers subscribe to the Committee’s agricultural weather forecast at a cost of $120/year. The forecast is emailed daily, and also provides a link to the Committee’s weather website (www.westerwx.com/sid).

o Sixty-nine (69) growers participated in the soil moisture monitoring program. A total of 148 fields, orchards, and vineyards have soil sensors and data-logger meters installed. The program is free-of-charge to growers who attend the Committee’s annual irrigation workshops or subscribe to the forecast.

o Mobile lab irrigation evaluations were performed for 20 growers, free-of-charge.

o Irrigation pump efficiency tests were performed for 27 sites, free-of-charge.

In addition to continuation of the existing management practices implemented in the Cache Slough drainage and represented drainages that are summarized in Table 4, Coalition Members in the Cache Slough represented drainages who apply products containing chlorpyrifos are required to obtain a restricted materials permit that is signed by a certified applicator. This is serving as an additional mechanism for the education of growers and applicators seeking to apply the chlorpyrifos in the represented drainages. Enhanced education regarding the appropriate techniques and conditions for application of chlorpyrifos, as described in CDPR’s Chlorpyrifos Interim Recommended Permit Conditions (see Appendix C), is viewed as an effective means to minimize its discharge to surface waters and eliminate exceedances. On May 6, 2015, CDPR filed the final documentation to add chlorpyrifos to the list of state-restricted materials. This rule, which became effective on July 1, 2015, affects all products containing chlorpyrifos as an active ingredient (AI) when labeled for production of an agricultural commodity. Chlorpyrifos, as a state-restricted material, is subject to the following restrictions:

Chlorpyrifos can only be sold to, purchased by, possessed or used by, a person who holds a restricted material permit issued by the local County Agricultural Commissioner.


SVWQC 17 May 2017

Chlorpyrifos must be added to an applicator’s restricted materials permit. The local County Agricultural Commissioner’s office must be contacted to amend a restricted materials permit to include the use of chlorpyrifos.

A Notice of Intent (NOI) must be submitted to the local County Agricultural Commissioner’s office at least 24 hours prior to the use of chlorpyrifos.

Coalition Members in the represented drainages are required to amend their restricted materials permits in order to legally apply chlorpyrifos and are required to provide NOI submittals to the Solano County Agricultural Commissioner’s office at least 24 hours prior to application of the pesticide. Additionally, the designation of chlorpyrifos as a state-restricted material puts in place the requirement for sellers, purchasers, and applicators of chlorpyrifos to possess a restricted materials permit for the pesticide. In order for an entity to legally purchase chlorpyrifos, the person must show proof of possession of a restricted materials permit for chlorpyrifos to a certified seller before the sale can occur. This requirement ensures that those legally obtaining chlorpyrifos have received information from the Solano County Agricultural Commissioner’s office on how to apply the pesticide in a manner that reduces or prevents off-site discharges to surface waters.

Growers and applicators adding chlorpyrifos to their restricted materials permits are provided with information on pesticide use permit conditions to minimize the risk of chlorpyrifos discharges and exceedances (see Appendix C). Each restricted materials permit applicant will be required to sign a permit conditions statement which demonstrates proof of receipt. The Solano County Agricultural Commissioner’s office maintains records of those who have applied for a restricted materials permit for chlorpyrifos, as well as those who have submitted a NOI to apply chlorpyrifos. Once a NOI is filed, the Solano County Agricultural Commissioner’s office is responsible for reviewing the NOI and informing the permittee of additional restrictions for the application of chlorpyrifos related to weather conditions, sensitive areas, etc., as necessary.

Additionally, the NOI process allows the Solano County Agricultural Commissioner’s office to perform a site inspection prior to a chlorpyrifos application (known as a “pre-site” inspection), if it determines one is warranted. The Solano County Agricultural Commissioner’s office maintains records describing such pre-site inspections. The tracking of educational outreach (via Grower Meetings) provided by the Solano County Agricultural Commissioner’s office can be used by the Subwatershed to assess chlorpyrifos education of Members associated with this Management Plan.

With reference to the existing level of management practices implementation (measured as a percent of total acres reported for a particular practice – see Table 4) identified by the 2015 Farm Evaluation Survey, it is anticipated that Coalition Members in the Cache Slough represented drainages will increase the total acres protected by the following agricultural practices as a result of obtaining a restricted materials permit for chlorpyrifos and complying with CDPR’s Chlorpyrifos Interim Recommended Permit Conditions (see Appendix C):


SVWQC 18 May 2017

End of row shutoff when spraying

Use of mechanisms to control drift

General drift minimization

End of row shutoff when spraying is a recommended practice for airblast applications of chlorpyrifos. Use of various mechanisms to control drift may also increase with implementation of good agricultural practices designed for “general drift minimization”, which is a condition of CDPR’s Chlorpyrifos Interim Recommended Permit Conditions (see Appendix C). General drift minimization practices due to physical changes in application techniques (e.g., control droplet size by selecting appropriate volume, pressure, number of nozzles, and nozzle type and orientation) are also expected to increase as a result of conditions included in the restricted materials permit for chlorpyrifos. Implementation of the above actions by Coalition Members in the Cache Slough represented drainages are believed to be sufficient to minimize discharge of chlorpyrifos to surface waters and eliminate exceedances of chlorpyrifos WQOs.

3.2.2 Performance Goals

With the designation of chlorpyrifos as a state-restricted material, Coalition Members in the Cache Slough represented drainages will be the recipients of additional educational outreach associated with restricted materials permit issuance and NOI submittals, and will be subject to the pesticide use permit conditions placed on chlorpyrifos that are anticipated to increase the level of implementation of three agricultural practices: end of row shutoff when spraying, use of mechanisms to control drift, and general drift minimization. The enhancement of these actions is expected to minimize the discharge of chlorpyrifos to surface waters and thus, achieve compliance with the Order’s receiving water limitations for the pesticide. The effectiveness of these actions implemented by growers and applicators in the Cache Slough drainage will be evaluated through review of Management Plan monitoring data, evaluation of future Farm Evaluation Survey results as compared to baseline results, and Subwatershed and Solano County Agricultural Commissioner chlorpyrifos education activities. The Dixon/Solano Subwatershed and Coalition Members in the Cache Slough represented drainages seek to meet the six performance goals shown in Table 8 as they relate to the application of chlorpyrifos.

3.2.3 Member Education

Member education takes the forms of general outreach to all members of the Dixon/Solano Subwatershed and more targeted outreach to growers/applicators who have used chlorpyrifos or have the potential to use it during sensitive periods (e.g., alfalfa, almond, and walnut growers). General outreach at the subwatershed level is directed to landowners, farm operators, and/or wetland managers regarding the cause(s) of exceedance(s) of the WQO for chlorpyrifos and the adoption of best management practices (BMPs) that prevent the movement of the pesticide into Sacramento Valley


SVWQC 19 May 2017

surface waters. These general outreach efforts are carried out through presentations at grower meetings or via direct outreach (mailings, phone calls, emails).

Targeted outreach has been directed to landowners/growers and pest control advisors operating in high priority lands near Ulatis Creek and throughout the Cache Slough represented drainages. The Coalition identifies its members growing the high priority crops and mails to them pre-season advisory notices along with information on options to address chlorpyrifos exceedances using BMPs. During the 2012 through 2016 monitoring years, the Dixon/Solano Coalition provided the targeted outreach listed in Appendix D.

The effectiveness of future Management Plan outreach efforts will be assessed by tracking the number of attendees at meetings, tracking management practice implementation related to irrigation systems and management, pesticide application practices and cultural practices to manage sediment and erosion, and compliance with WQOs for Management Plan monitoring events.

3.2.4 Management Practices

Coalition Members in the Cache Slough represented drainages are expected to continue to employ at high levels the agricultural management practices known to prevent the movement of chlorpyrifos into surface waters (see Table 4). Additionally, Coalition Members in the represented drainages are complying with the state-restricted material requirements for chlorpyrifos, and this is also serving as an additional mechanism to instruct growers and applicators on the additional effective practices to reduce or prevent the discharge of the pesticide to surface waters. The performance goals for increased implementation of select existing management practices and enhanced education through implementation of restricted materials permit requirements for chlorpyrifos are provided in Table 8. The effectiveness of these actions implemented by growers and applicators in the Cache Slough drainage and represented drainages will be evaluated through review of Management Plan monitoring data, evaluation of future Farm Evaluation Survey results as compared to baseline results, and Subwatershed and Solano County Agricultural Commissioner chlorpyrifos education activities. In the event that a future exceedance of the ILRP management plan trigger limit for chlorpyrifos is observed, Dixon/Solano Coalition staff will use Solano County Agricultural Commissioner’s records (list of chlorpyrifos restricted materials permittees and NOIs) and CDPR PUR data to identify a possible source of the observed exceedance.

3.2.5 Management Plan Implementation Schedule

The Coalition’s Order requires that the implementation of Management Plans and management practices result in the compliance of a constituent of concern with its applicable WQOs or trigger limits as soon as is reasonably practicable, but no longer than 10 years from submittal of the Management Plan to the Regional Water Board for approval. The Coalition Members in the Cache Slough drainage anticipate that implementation of this Management Plan and its proposed management practices will continue to result in compliance with the 0.015 µg/L WQO for chlorpyrifos (as it has


SVWQC 20 May 2017

since June 2015) through May 2018, or approximately one year from the submittal of the plan for approval by the Regional Water Board. Because the Dixon/Solano Coalition has implemented a Management Plan for chlorpyrifos in Ulatis Creek pursuant to the 2013 MPIPG that it prepared, and an exceedance of the WQO for chlorpyrifos has not been observed since May 19, 2015, the coalition anticipates that Ulatis Creek will have achieved three years of compliance with the 0.015 µg/L WQO for chlorpyrifos by May 2018. The following schedule of actions is proposed for completing this Management Plan:

May 2017: Development and submittal of an UPDATE to the Management Practices Implementation and Performance Goals (MPIPG) originally submitted in March 2013 to the Regional Water Board for approval.

May 2017 – May 2018: Receive and process chlorpyrifos permit applications; Continue outreach and education to permit applicants; Implement new management practices required by permits; Continued implementation of existing management practices; Continued Management Plan monitoring; Annual reporting of management practice implementation.

May 2018: If no additional exceedances are observed for chlorpyrifos during one (1) additional year of Management Plan monitoring, then continue to document water quality and management practices implementation and effectiveness, followed by submittal of a request to Central Valley Water Board Executive Officer for approval of completion of Management Plan.

Table 8: Management Practice Performance Goals for Chlorpyrifos Applications in the Cache Slough Drainage and Represented Drainages.

Performance Goal Mechanism of

Achieving Goal

Quantitative Measure of Progress

Schedule for Achieving Goal

1. Chlorpyrifos applied by entity receiving pesticide use permit information from Solano County Agricultural Commissioner’s office.

Solano County Agricultural Commissioner’s office to provide applicators with pesticide use permit conditions for chlorpyrifos.

100% of pest control operators and pesticide use permittees will receive information on pesticide use permit conditions for chlorpyrifos.

Reporting Basis:

Number of permittees that received pesticide use permit information.

Ongoing: 100% achievement of this performance goal will occur in every year that chlorpyrifos is listed as a state-restricted material.


SVWQC 21 May 2017


Achieving Goal



2. Increased education and awareness of end of row shutoff when spraying.

Dixon/Solano Coalition to provide Chlorpyrifos Management Plan Updates annually through presentations at three Solano County Ag Commissioner pesticide applicator trainings, written updates in annual newsletter, and direct season of use mailings (through email and US mail) to all Coalition members who grow alfalfa, walnuts and almonds.

The updates will include information to educate applicators in the Cache Slough and represented drainages on (1) end of row shutoff when spraying, (2) mechanisms to control drift, and (3) how to minimize drift through consideration of weather conditions when applying chlorpyrifos, as well as other relevant BMPs. Mailings and/or phone calls to growers regarding these topics will also be counted as successful completion of these goals.

Achievement of these performance goals will be measured based on attendance and/or receipt of outreach materials by those growers applying chlorpyrifos. Outreach activities to be documented in Annual Monitoring Report and tabulated in annual Management Plan Progress Report.

Reporting Basis:

Meeting dates, number of attendees at meetings, and recipients of mailings and/or phone calls covering these management practice topics.

Ongoing: 100% achievement of this performance goal will occur in every year from the date the Management Plan is submitted for approval to the Executive Officer.

3. Increased education and awareness of mechanisms to control drift.

4. Increased education and awareness of drift minimization.


SVWQC 22 May 2017


Achieving Goal



5. Ensure through ongoing outreach and education that current high usage of management practices that are effective in reducing or preventing discharge of chlorpyrifos to surface waters is continued by growers in the Cache Slough and represented drainages.

Maintain awareness of growers, PCAs, and applicators in the Cache Slough drainage and represented drainages through outreach activities and reminders about management practices that are effective in reducing or preventing discharge of chlorpyrifos to surface waters.

Achievement of this performance goal will be measured by comparing and reporting management practices implemented and reported in the 2015 Farm Evaluation (see Table 4) to those reported in the Farm Evaluations from the 2016 and 2017 crop years.

Reporting Basis:

Acreages of implemented management practices in the Cache Slough and represented drainages.

Achievement of this performance goal will occur within one year from the date the Management Plan is submitted for approval to the Executive Officer (with consideration of the fact that the Management Plan has been in effect since submittal of the 2013 MPIPG).

6. Maintain chlorpyrifos concentrations in Ulatis Creek at Brown Road to below trigger limit.

Educate applicators in the Cache Slough and represented drainages through outreach activities on how to reduce or prevent discharge of chlorpyrifos to surface waters.

Achievement of this performance goal will be measured through evaluation of the Coalition’s chlorpyrifos data collected in Ulatis Creek at Brown Road.

Reporting Basis:

All annual monitoring results, including exceedance reports, if applicable.

Maintain 100% compliance with the ILRP trigger limit through the 3-year compliance timeframe (June 2015 – May 2018) with consideration of the fact that the Management Plan has been in effect since submittal of the 2013 MPIPG.


SVWQC 23 May 2017

3.3 DUTIES AND RESPONSIBILITIES

Implementation of the various elements of the Management Plan will be carried out by the Coalition and their contractors, Dixon/Solano Coalition staff, and Coalition Members according to the organizational chart shown in Figure 5. Substantial assistance is being provided by the Solano County Agriculture Commissioner’s office through issuance of restricted materials permits for chlorpyrifos pursuant to the pesticide’s designation as a state-restricted material. The roles and responsibilities of the individuals and groups specified in the organizational chart who will continue to implement the various elements of this Management Plan are described below.

Solano County Agricultural Commissioner’s Office – Responsible for issuing restricted materials permit for chlorpyrifos; responsible for notifying permittee of pesticide use permit conditions; responsible for notifying permittee of requirement to file a NOI at least 24 hours prior to chlorpyrifos application; and responsible for reviewing the NOI and informing the permittee of additional restrictions for the application of chlorpyrifos related to weather conditions, sensitive areas, etc., as necessary.

Sample Collection Lead – Kristin Worrell, Pacific EcoRisk: Ms. Worrell will be responsible for directing the field sample collection efforts for this Management Plan.

Water Quality Data Lead – Steve Maricle, Larry Walker Associates: Mr. Maricle will have primary responsibility for processing and managing water quality data.

Quality Assurance Lead – Mike Trouchon, Larry Walker Associates: Mr. Trouchon will oversee water quality data management and has primary responsibility for quality assurance of water quality data.

Management Practice Data Lead – Martha McKeen, Dixon RCD: Ms. McKeen will provide primary oversight for collection, processing, and reporting of Farm Evaluation Survey and management practice data.

Reporting Lead – Steve Maricle, Larry Walker Associates: Mr. Maricle will oversee preparation of the required annual Management Plan Progress Reports (MPPR).

Project Lead – Kelly Huff, Dixon RCD: Ms. Huff will provide general oversight, review, and schedule tracking for Management Plan implementation, including coordination of needed assistance from the Solano County Agricultural Commissioner. In the event of a future exceedance of the ILRP management plan trigger limit for chlorpyrifos, Ms. Huff will review Solano County Agricultural Commissioner’s records (list of chlorpyrifos restricted materials permittees and NOIs) and CDPR PUR data to identify a possible source of the observed exceedance.

Education and Outreach Lead – Kelly Huff, Dixon RCD: Ms. Huff will be responsible for development of outreach materials, and tracking and documenting member outreach and education for the Management Plan.

Coalition Members in Represented Drainages: Coalition Members in the Cache Slough represented drainages are responsible for continued implementation of the agricultural management practices needed to comply with WQOs, as well as complying


SVWQC 24 May 2017

with the requirements associated with the designation of chlorpyrifos as a state-restricted material, which includes applying for a restricted materials permit for chlorpyrifos from the Solano County Agricultural Commissioner’s office. Coalition Members are also responsible for providing information requested and collected by the Coalition pursuant to the implementation of this Management Plan and management practices.

Figure 5: Ulatis Creek Management Plan for Chlorpyrifos – Project Organization

4 Monitoring Design Surface water quality monitoring performed in support of this Management Plan (i.e., Management Plan monitoring) is designed to measure effectiveness at achieving the goals and objectives of the Comprehensive Surface Water Quality Management Plan (CSQMP). This will be achieved by conducting Management Plan monitoring in the representative Cache Slough drainage at the Ulatis Creek at Brown Road (UCBRD) monitoring location (see Figure 1) that is being used by the Coalition for its Assessment monitoring. The Coalition submitted its Annual Monitoring Plan Update for the 2017 monitoring year (October 2016 – September 2017) on October 12, 2016, and it was approved by the Central Valley Water Board on October 17, 2016. The proposed

Sacramento ValleyWater Quality Coalition

Dixon/Solano SubwatershedProject Lead:

Kelly Huff (Dixon RCD)Education and Outreach Lead:

Kelly Huff (Dixon RCD)Management Practice Data Lead:

Martha McKeen (Dixon RCD)

Subwatershed MembersManagement Practice

Implementation and Reporting

ContractorsSample Collection Lead:

Kristin Worrell (PER)Water Quality Data Lead:

Steve Maricle (LWA)Quality Assurance Lead:

Mike Trouchon (LWA)Reporting Lead:

Steve Maricle (LWA)

Assisting AgencySolano County Agricultural Commissioner’s Office

Dixon RCD = Dixon Resource Conservation DistrictLWA = Larry Walker AssociatesPER = Pacific EcoRisk


SVWQC 25 May 2017

monitoring for the Management Plan is part of the Annual Monitoring Plan Update submitted annually in August to the Regional Water Board for approval.

4.1 MONITORING

Management Plan monitoring in the Cache Slough drainage included in the Annual Monitoring Plan Update for the 2017 monitoring year is focused on 12 monitoring events scheduled each month from October 2016 through September 2017 and performed by the Delta Regional Monitoring Program. These monthly monitoring events will cover the months of March, April, July, and August when historical usage of chlorpyrifos in the drainage to control insects (alfalfa pre-irrigation season and almond/walnut irrigation season) is most prevalent. Based on previously reported elevated chlorpyrifos application during these months, future monitoring is scheduled to occur during the time when chlorpyrifos use and the risk of discharges and exceedances is estimated to be highest. Sample collection and analysis for chlorpyrifos during Management Plan monitoring will be identical to that employed by the Coalition during Assessment monitoring. Monitoring results are submitted electronically to the Regional Water Board with the quarterly data submittals required by the WDR.

5 Data Evaluation The effectiveness of this Management Plan will be evaluated through (1) review of progress made toward implementation of education and outreach activities proposed to raise awareness of water quality issues as they pertain to pesticide application, (2) assessment of agricultural management practices known to limit the transport of agriculturally-applied chlorpyrifos to surface waters, and (3) collection of surface water quality data to determine the effectiveness of management practices implementation in reducing the exceedances of the chlorpyrifos water quality objective in the Ulatis Creek drainage. Farm Evaluation Survey data (e.g., pesticide application practices and cultural practices to manage sediment and erosion) collected in the Cache Slough drainage and represented drainages will be used to track progress in implementing specific agricultural practices identified to reduce or eliminate the discharge of chlorpyrifos in spray drift, irrigation tailwater, and storm runoff to ambient surface waters.

5.1 EVALUATION OF MANAGEMENT PLAN EFFECTIVENESS

The effectiveness of this Management Plan primarily will be judged on maintaining improvements in surface water quality since May 2015 as measured in the representative Cache Slough drainage. Continued lack of exceedances of the chlorpyrifos water quality objective, or chlorpyrifos detections, along with documentation of the implementation of management practices described in the Actions and Task subsection, will be used to link observed surface water quality improvements to the actions of growers in the drainage. Additionally, management plan effectiveness will also be assessed with regard to the progress made toward implementation of those management actions identified to improve surface water quality in the Cache Slough


SVWQC 26 May 2017

drainage. Status and effectiveness of this Management Plan will be described annually in the MPPR through presentation of the following information:

Time series plot of chlorpyrifos data collected at the Ulatis Creek at Brown Road (UCBRD) monitoring location;

Tabular summary of meeting annual Dixon/Solano Coalition outreach and education goals; and

Tabular summary of management practices implemented under this Management Plan for comparison to baseline management practices implemented in the year prior to initiation of Management Plan activities.

6 Records and Reporting The Coalition submits a Management Plan Progress Report (MPPR) annually on May 1 that summarizes the progress made to date on each Management Plan. The MPPR will contain the reporting components required for this Management Plan, as well as all other Management Plans. The Coalition also submits a Monitoring Plan Update report (annually on August 1) with the monitoring schedules and constituents for the upcoming monitoring year, including those required by Management Plans. These reports and schedules are consistent with the requirements in Appendix MRP-1 of the WDR.

6.1 DOCUMENTATION AND REPORTING

The water quality monitoring data collected pursuant to this Management Plan (i.e., Management Plan monitoring data) will be submitted electronically to the Central Valley Water Board on a quarterly basis along with all other monitoring data collected by the Coalition. An event-based water quality exceedances report is also provided to the Central Valley Water Board on a more or less monthly schedule. Management Plan monitoring data will be evaluated by the Water Quality Data Lead and Quality Assurance Lead (Steve Maricle and Mike Trouchon, respectively, of LWA) to ensure that data conform to the Coalition’s Quality Assurance Project Plan (QAPP) and meet the requirements of the WDR. The exceedance reports and quarterly submittal of Management Plan monitoring data will provide adequate and timely information regarding compliance of ambient water quality with the chlorpyrifos water quality objective. The Subwatershed Project Lead (Kelly Huff) will provide data on the progress toward achievement of management practices implementation and performance goals and interim milestones as set forth in this Management Plan and the Education and Outreach Lead (Kelly Huff) will report on education and outreach efforts for inclusion in the MPPR. All required information will be summarized annually in the MPPR, along with the most recent and previous year’s Management Plan monitoring data.


SVWQC A-1 May 2017

Appendix A: Chlorpyrifos Pesticide Use Report Data in the Cache Slough Represented Drainages

Figure A1: Pounds of chlorpyrifos applied per month in the Cache Slough Drainage, 2012 – 2014.

Figure A2: Agricultural chlorpyrifos applications in the Cache Slough Drainage, 2012 – 2014.


SVWQC A-2 May 2017

Figure A3: Irrigated agricultural and non-agricultural applications of chlorpyrifos in Solano County, 2012 – 2014.


SVWQC A-3 May 2017

Figure A4: Acres per year treated with chlorpyrifos in the Cache Slough Drainage, 2003 – 2014.

Figure A5: Acres per year treated with chlorpyrifos in the Cache Slough Represented Drainages, 2003 – 2014.


SVWQC B-1 May 2017

Appendix B: Pathways for Transport of Agriculturally Applied Chlorpyrifos to Surface Waters and Practices to Minimize Risk of Off-site Transport


SVWQC C-1 May 2017

Appendix C: Chlorpyrifos Interim Recommended Permit Conditions Taken from California Department of Pesticide Regulation web site:

http://www.cdpr.ca.gov/docs/county/cacltrs/penfltrs/penf2015/2015atch/attach0904.pdf

Appendix O

Chlorpyrifos Interim Recommended Permit Conditions

Introduction

These are recommended permit conditions to minimize bystander exposure and offsite movement of chlorpyrifos during applications and reduce runoff after applications. These recommendations apply to products containing chlorpyrifos labeled for the production of an agricultural commodity.

Setback distances to protect bystanders

Use the following minimum application setback distances for applications adjacent to sensitive sites as defined by the label or designated by the commissioner:

Application Method Minimum Setback Distance (fee)

Ground Boom 25

Chemigation 25

Airblast 50*

Aerial (Fixed wing or rotary) 150

* Dormant applications must comply with 3 CCR section 6960

The setback distance extends in all directions from the edge of the sensitive site to the edge of the treatment area. Setbacks are in effect only during the application.

Application conditions

1. All applications must take place with a minimum wind speed of 3 mph and not more than 10 mph as measured at a height of four feet above the ground;

Appendix O Chlorpyrifos Interim Recommended Permit Conditions (07/15)


SVWQC C-2 May 2017

2. For airblast applications:

a. Spray the outside crop row from outside in, directing the spray into the treatment area and shutting off nozzles on the side of the sprayer away from the treatment area.

b. Shut off top nozzles when treating smaller trees, vines, or bushes to minimize spray movement above the canopy.

3. Incorporate or clean-up granules that are spilled during loading or are visible on the soil surface in turn areas.

Appendix O Chlorpyrifos Interim Recommended Permit Conditions (07/15)


SVWQC D-1 May 2017

Appendix D: Dixon/Solano Coalition Targeted Educational Outreach Efforts Regarding Chlorpyrifos Exceedances and Associated Management Practices: 2011 – 2016

Date and Location

Where Outreach

Conducted

Number Attending Meeting/

Receiving Information

Outreach Type Focus of Outreach Document Titles

Docs Provided?

10/01/2011, Direct Mailing

581 Coalition Members

Newsletter Update to members re: water quality exceedances

Dixon/Solano Coalition Annual Newsletter 2011-2012

Yes

11/01/2011, Dixon May Fair Grounds

6 Meeting Update to members re: water quality exceedances

Irrigated Lands Regulatory Program Meeting Nov. 1, 2011

Yes

12/01/2011, Solano Co. Ag Dept., Fairfield

34 Meeting Pesticide use and water protection for PCA/CCA Training

Pesticide Regulations Update and Agricultural Commissioner’s Meeting

Yes




Yes




Yes

03/07/2012 – 03/30/2012, Phone Call

18 Phone Call

ALERT to alfalfa growers who used chlorpyrifos in 2011

n/a No

04/10/2012, Local Grower’s Shop

8 Meeting Furrow Irrigation Workshop to Foreman and Irrigators (in Spanish)

Solano Irrigation District PowerPoint presentation in Spanish

Yes

04/11/2012, Solano Irrigation District Office

9 Meeting Furrow Irrigation Workshop to Foreman and Irrigators (in Spanish)


Yes

04/12/2012, Solano Irrigation District Office

10 Meeting Furrow Irrigation Workshop to Foreman and


Yes


SVWQC D-2 May 2017

Date and Location

Where Outreach

Conducted




Docs Provided?

Irrigators (in Spanish)


120 (targeted to alfalfa, almond & walnut growers)

Flyer Water Quality ALERT (Spring Insecticides) and advertise USDA NRCS cost-share availability for WQ practices

General Insecticide Issues Flyer, Feb. 2013, and BDI_brochure_HQPrint

Yes

02/20/2013 – 03/26/2013, Phone Call

46 applicators, 7 PCAs

Phone Call

Phone call re: Chlorpyrifos Management Practices Survey to those who applied the pesticide in 2012

n/a No


580 Coalition Members

Flyer Advertise USDA NRCS cost-share availability for WQ practices

General Insecticide Issues Flyer, Feb. 2013, and BDI_brochure_HQPrint

Yes


35 PCAs Flyer Advertise USDA NRCS cost-share availability for WQ practices

General Insecticide Issues Flyer, Feb. 2013, BDI_brochure_HQPrint, and PCA applicator note

Yes

Feb – Mar 2014, Phone Call

50 applicators Phone Call

Phone call re: Chlorpyrifos Management Practices Survey to those who applied the pesticide in 2013

n/a No


59 growers, 35 PCAs/ applicators

Email (26) or Letter by Post (33)

Season of Use Reminder; alternative products; recommended management and application practices

030614_Alfalfa_Chlorpyrifos_Reminder

Yes

11/05/2014, Dixon RCD Office

15 PCAs Meeting PCA Informational Meeting

Handouts_PCA_Grower_Farm_Reporting_Mtgs

Yes


34 pesticide applicators

Meeting Solano Ag Commissioner Pesticide Applicator Training (Ag)

11_20_2014 Ag Comm Meeting

Yes

12/10/2014, Dixon RCD Office

10 tenants w/ large acreages and

Meeting PCA Informational Meeting


Yes


SVWQC D-3 May 2017

Date and Location

Where Outreach

Conducted




Docs Provided?

multiple landowners

12/11/2014 34 pesticide applicators


12_11_2014 Ag Comm Meeting

Yes

01/27/2015, Harvey Lyman Office, Walnut Grove

10 PCAs Meeting PCA Informational Meeting


Yes


82 individuals (36 PCAs, 35 growers, 11 advisors)

Email with Flyer

Notification of chlorpyrifos exceedance, recommended practices and restricted use designation

Chlorpyrifos list of practices updated 08-2015; July 1, 2015, Chlorpyrifos Restricted Use Designation for Ag Solano Ag Commissioner Letter

Yes




15_16 Ag Comm Meeting Presentation

Yes





Yes


45 Coalition members



Yes

Surface Water Quality Management Plan: Chlorpyrifos in Ulatis … · SVWQC ii May 2017 Appendix D:...

Documents

Transcript of Surface Water Quality Management Plan: Chlorpyrifos in Ulatis … · SVWQC ii May 2017 Appendix D:...