SURVEILLANCE, and the EPA NPDES EPA NPDES

Pesticides General Pesticides General Permit (PGP)Permit (PGP)

Rosmarie KellyRosmarie KellyPublic Health EntomologistPublic Health EntomologistGeorgia Division of Public HealthGeorgia Division of Public Health

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What are NPDES permits?

As authorized by the Clean Water Act (CWA), the NPDES permit program controls water pollution by regulating point sources that discharge pollutants into waters of the United States (http://cfpub.epa.gov/npdes/).

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PROBLEM

pesticides are NOT pollutants

pesticides are licensed by EPA

some pesticides are labeled for use in water

the LABEL is (already) the LAW

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So, what does this have to do with mosquito control?

Since its inception, the EPA has regulated mosquito control through enforcement of standards instituted by the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).

FIFRA covers the production, labeling, use, and safety of pesticides, but how pesticides were applied was a point of contention for some environmental groups.

Over the past 10 years, many lawsuits sought to determine whether the Clean Water Act (CWA) covered pesticide applications.

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Public health officials across the country are considering widespread spraying of pesticides to control the mosquito-borne West Nile virus.

Anti-pesticide environmentalists claim spraying will devastate bird populations and other wildlife, but sound science shows the pesticides are safe and necessary.

The Controversy

“The application of a pesticide to waters of the United States consistent with all relevant requirements under FIFRA does not constitute the discharge of a pollutant that requires an NPDES permit in the following two circumstances:

1. The application of pesticides directly to waters of the US to control pests. Examples of such applications include applications to control mosquito larvae, aquatic weeds, or other pests that are present in waters of the US; and

2. The application of pesticides to control pests that are present over waters of the US, including near such waters, where a portion of the pesticides will unavoidably be deposited to waters of the US to target the pests effectively; for example when insecticides are aerially applied to a forest canopy where waters of the US may be present below the canopy or when pesticides are applied over or near water for control of adult mosquitoes or other pests.”

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Nov. 27, 2006 - Final CWA Pesticides Rule

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Challenge to 2006 Rule

√ In December, 2006 petitions for review were filed in all 11 Circuit Courts. Petitions were consolidated in the 6th Circuit Court of Appeals.

√ On 1/7/09 the 6th Circuit vacated the CWA pesticides rule, stating that the rule was not a reasonable interpretation of the CWA.

· Biological pesticides – Court considered “biological materials” a“pollutant” under the CWA stating all biological pesticides are pollutants because they “undeniably alter the physical integrity of the waters.”

· Chemicals pesticides – Court considered “chemical wastes” pollutants also stating that chemical pesticides are pollutants if they leave a residue (or “waste”).

√ On 06/08/09, the 6th Circuit granted EPA’s request and ordered a two year stay of the mandate until 04/09/11.

BackgroundBackground

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Result of Court Actions

√ Bottom Line: EPA’s rule stating that NPDES permits are not required for pesticide applications applied to or over, including near waters of the US, remains in effect until April 9, 2011.

√ As of April 9, 2011, discharges into a water of the US from pesticide applications will require coverage under an NPDES permit.

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Types of Permits

• Individual each permit uniquely drafted e.g. municipality, industry even mobile home park

• General similar activities under one permit

• Deemed permitted activity if done using best management needs no permit e.g swimming pool draining

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Georgia Program

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-Apply for permit through GA EPD-Depending on the amount of pesticide discharge a NOI (Notice of Intent) may have to be filed-The NOI must include information about:

-what you are doing, -equipment, -pesticide usage, -number of applications, -area of coverage, -receiving waters, -etc

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All permittees must:

• Comply with effluent limits• Technology-based- use the lowest amount of

pesticides to minimize discharges• Apply according to label• Calibrate• Equipment maintenance

• Water-Quality based• Apply according to label• Must meet applicable numeric and narrative

State Water Quality standards 391-3-6-.03• Site monitoring – look for problems

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• Corrective action – use best professional judgment• Adverse incident report – must be in or near state

waters - includes:• Fish kill• Other non-target effects• Citizen complaints

• Report to District EPD office(Already report spills of any significance to GA Dept of Agriculture)

• KEEP GOOD RECORDS• Copy of all paperwork• Copy of permit• Equipment maintenance records• Calibration information• Adverse incidence reports

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Programs exceeding the annual threshold are also required to have a Pesticide Discharge Management Plan.

MUST INCLUDE:•Pesticide Discharge Management Team.•Pest Management Area Description.•Control Measure Description.•Schedules and Procedures.

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Beside filing a NOI there are other requirements that are mandatory.-I. Use of IMM methods in mosquito control is stressed.

- 1. ID or access the pest problem using an action threshold- 2. Source reduction of standing water, use biological

control, eliminate vegetation harboring mosquitoes- 3. Follow appropriate procedures (calibration,

maintenance)- 4. Education

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II. Monitoring. Pre-spray numbers versus post-spray numbers of mosquitoes, adverse incidents after an application, etc

III. Reporting. An biennial report will be requiredIV. Record keeping. Will be very important. Includes

how much discharge, how much acreage, pesticide used, spray flow and rates, etc, for each treatment

V. Equipment Maintenance. Follow label recommendations for calibration, keep equipment working properly

Integrated Mosquito Management

Source ReductionLarval Surveillance - Larval Control Adult Surveillance - Adult Control Community Education / CommunicationMapping / Record Keeping

Arboviral Surveillance (where appropriate)

Best Management PracticesBest Management Practices

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Complaints should ALWAYS be followed up by a site visit.

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Basic Cornerstone of Surveillance

LANDING COUNTS

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"Landing Rate" - the number of mosquitoes that land on

the observer over a designated period of time.

It is suggested that they be taken over either a 1 or 5 min

period. If the landing rates exceed 50 in 30 sec, the interval

can be shortened to protect observers that are expected to

conduct numerous counts.

Landing rates may involve identification, but they are

normally employed in areas where a single, known

species is the sole cause of annoyance.

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•Wait a period of time before starting to collect.

•Disturb the vegetation before starting.

•Wear light solid-colored clothes.

•Wear no repellents.

•Wear no perfumes or aftershave.

•Stand up and stand still while taking count.

•Remember, mosquitoes react differently to each individual

Guidelines

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Information to Collect:

Collector's NameCountySite DateTimeLocation on Body

For counts of less than one minute, multiply to get landings per minute.

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Thresholds for Landing Counts Vary

Excessive Landing Rate Counts:

•In populated areas >25 mosquitoes/minute•In relatively unpopulated areas >50 mosquitoes/ minute

THIS WILL VARY ACCORDING TO LOCATION, MOSQUITO SPECIES, AND HUMAN POPULATION

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Landing counts are useful for determining if adult mosquito control is needed.

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Landing counts should be done at the time of day when the mosquitoes are said to be active.

If this is not possible, stand in a shady area when taking the landing counts.

ADULT MOSQUITO SURVEILLANCEADULT MOSQUITO SURVEILLANCE

CDC light trapCDC light trap

gravid trapgravid trap

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What Kind of Trap Should You Use?

depends on your need and your budget

Mosquito Gravid Trap Operation

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Gravid Traps

• USE – primarily for monitoring container breeding mosquitoes

• Used in the WNV surveillance program• NOT USEFUL for monitoring most nuisance

species• NOT USEFUL for monitoring EEE

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Mosquito Light Trap OperationMosquito Light Trap Operation

Mosquito CDC Trap Overview

The CDC traps are portable, battery-operated traps that are useful for investigating newly identified mosquito problem areas, and regular trapping sites.

CDC traps are ideal for collecting mosquitoes for species identification.

CDC type traps attract mosquitoes with a small light and are generally baited with carbon dioxide (dry ice).

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Larval Surveillance – “get them before they get you” 41

FACTS ABOUT MOSQUITO LARVAE

• All larvae are found in water• What types of water?

– ALL TYPES! Each species has its own water requirements

• How much water is required? – FROM A JAR LID TO HUGE RESERVOIRS TO PITCHER

PLANTS!• How long from egg to adult?

– IT DEPENDS ON THE SPECIES, BUT MOST TAKE 7-10 DAYS!

• Where should I look for larvae? – ANYWHERE YOU FIND WATER, REGARDLESS OF

SIZE!• What is the best stage of the mosquito to control?

– THE LARVAL STAGE! 42

WHY YOU NEED TO KNOW ABOUT MOSQUITO LARVAL HABITATS?

• The best method to control mosquitoes is by targeting the larval stage. IF NO ADULTS EMERGE, YOU WIN THE GAME!

• If you wait until the adults emerge, they fly in all directions, are not concentrated like larvae, and are harder to control.

Targeting mosquito larvae for control is very “PROACTIVE”.

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Equipment

http://www.rci.rutgers.edu/~insects/dipping.htm44

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An action point is a trigger for initiating a control measure. It is a point at which pest populations or environmental conditions indicate that pest control action must be taken

USING THE DATA – when should control occur

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For nuisance species, a threshold can be set based on numbers of complaints and/or mosquito population size.

EIL – economic injury level; angry population

ET – economic threshold; acceptable level of complaints

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MAPPING

A picture is worth a thousand words.

1. Map complaints2. Map service calls3. Map breeding sites4. Map adverse

incidents

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USEFUL TIP – Google Maps

http://health.state.ga.us/epi/vbd/mosquito.asp

http://www.GAmosquito.org

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Any Questions?50