AgdaPkt 2016-02-22 Closed and Interview and Joint SA PFA

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City of Redwood City, Public Works Division Initial Study & Mitigated Negative Declaration Document Date: October 15, 2015 Revision Date: January 25, 2016 Page 42 Blankinship & Associates, Inc. herbicide Material Safety Data Sheet (MSDS) (an example is provided in Appendix D), and the DPR Worker Health and Safety Branch Pesticide Safety Information Series (PSIS). The PSIS and the MSDS have specific information that describes precautions to be taken during the use of the aquatic herbicide. 4. The condition of the portion of the Lagoon being treated is field-evaluated to ensure that the application is necessary, feasible and can be conducted safely and according to label. This evaluation considers target weed species, level of infestation, water and flow conditions, alternate control methods, and amount of aquatic herbicide to be applied. 5. Prior to an application, the water operator will confirm no water is being pumped out of the portion of the Lagoon being treated. 6. The location(s) at which the aquatic herbicide is introduced into the lagoon is continuously staffed until the application is complete. Staff who are performing lagoon inspection are in continuous cell phone or radio contact with staff making applications. In the event that lagoon pumps are turned on while the application is being made, the addition of aquatic herbicide will stop if it is deemed that the herbicide-treated water may be pumped out of the lagoon. Not until the pump is turned off does aquatic herbicide application resume. Overview of Aquatic Herbicide Use Depending on weed presence, aquatic herbicides containing copper may be applied as necessary at different locations between the months of April and November. Some years, no copper-containing aquatic herbicides will be applied. Item a): Potentially Significant Unless Mitigation Incorporated. As presented in Section 1.2, the City intends to obtain coverage under the 2013 General Permit that requires compliance with the SIP and the CTR. The City is also requesting an exception under Section 5.3 of the SIP to allow short-term or seasonal applications of aquatic herbicides that contain copper. Copper Discussion Within the San Francisco Bay, copper has been a pollutant of concern since the late 1980s (CEP, 2004). In 1989, the lower South San Francisco Bay was declared impaired by copper, leading businesses and government agencies to invest significantly in the identification of copper sources and control measures. As a result of these activities, a wealth of information has been produced on copper releases to surface waters. Identified sources of copper in San Francisco Bay surface waters are numerous and include vehicle brake pads, architectural copper, copper pesticides, industrial copper use, copper air emissions, soil erosion, copper in domestic water discharged to storm drains, vehicle fluid leaks and dumping, marine antifouling coatings, and copper algaecides applied directly to surface waters. Among these sources, vehicle brake pads have been identified as the predominant contributor representing around 42% of all copper loading (point and non-point sources) to the Bay (CEP, 2004). Other significant sources and their contributions are wastewater treatment plants at 28% and other non-point sources such as natural erosion and reservoir spills at 19% of total load to the Bay. Copper applied as a pesticide to surface waters represents an even smaller fraction of the total load to the Bay. A significant factor in 6.3.A. - Page 50