Pesticide-Related Experience

Since the mid-1990s, Dr. Moran has worked on projects designed to evaluate and reduce impacts of pesticides on water quality.  These projects included:

• Regulatory activities-On behalf of San Francisco Bay Area wastewater treatment plants, she managed the successful effort to obtain a regional prohibition of the sale and use of copper-based root control products and tributyltin cooling water additives.  She has monitored and prepared comments on U.S. EPA and California Department of Pesticide Regulations actions on behalf of local and state government agencies.  She has extensively explored regulatory control options for pesticides that pose water quality problems.
• Education and training-She has given numerous presentations on pesticide issues, particularly in relation to water quality.  She developed and participated in programs to reduce or eliminate use of problem pesticides, such as copper-based root control chemicals, tributyltin cooling water additives, and urban uses of diazinon.
• Technical studies-She directed preparation of the reports detailing sources and reduction strategies for diazinon, tributyltin, copper-based pesticides, and chlorinated pesticides.  She has investigated uses and discharge sources of numerous pesticides, including diazinon, chlorpyrifos, tributyltin, mercury and copper-containing pesticides, and lindane.

Pesticide Market Trends and Potential Water Quality Implications:  On behalf of the San Francisco Estuary Project (and with funding from the San Francisco Bay Regional Water Quality Control Board), TDC Environmental is investigating the water quality issues associated with the phase-out of most urban uses of two common insecticides (diazinon and chlorpyrifos).   The project will involve developing a list of pesticides most likely to replace diazinon and chlorpyrifos in the urban marketplace and assessing their risks to surface water quality.  Key project objectives are to identify those replacement pesticides likely to gain significant market share; to estimate the potential for these pesticides to adversely affect water quality; and to recommend future strategies to protect water quality.  The information developed from this project will help Regional Water Quality Control Boards and other government agencies focus on potential future sources of pesticide-related urban surface water toxicity.

Monitoring Pesticide Regulatory Agency Actions:  On behalf of the San Francisco Bay Regional Water Quality Control Board, TDC Environmental monitors all U.S. EPA Office of Pesticide Programs and California Department of Pesticide Regulations regulatory notices in order to identify agency activities that may have implications for surface water quality.  Dr. Moran reviews associated technical documents, summarizes issues important for water quality, and  drafts comment letters, when the Regional Board wishes to provide information for pesticide regulatory agency consideration.

Copper Pesticide Use Analysis:  At the request of the City of Palo Alto, TDC Environmental has conducted two analyses of copper-containing pesticide use in Santa Clara Valley.  These analyses are part of the City's annual Copper Action Plan Report.

Diazinon & Chlorpyrifos Products:  Screening for Water Quality Implications:  On behalf of the San Francisco Estuary Project (and with funding from the California Department of Pesticide Regulation), TDC Environmental LLC conducted an analysis of the relative potential for release of various diazinon and chlorpyrifos products into surface water.  Diazinon and chlorpyrifos are among the most commonly used insecticides.  In California, the presence of diazinon and chlorpyrifos in surface waters has proven to be of great concern, because elevated levels of the two pesticides have been linked to findings of toxicity in wastewater treatment plant effluent, storm water runoff, urban creeks (including all San Francisco Bay area urban creeks), estuaries (including San Francisco Bay), and the Sacramento River.  Much of this toxicity occurs in urban areas, apparently reflecting urban releases—rather than agricultural releases—of diazinon and chlorpyrifos.  The intent of this study was to explore whether certain urban sites of use (by their location) or certain pesticide formulations when applied to common urban application sites are especially likely to release diazinon and chlorpyrifos to surface water, and thus likely to be linked to the identified toxicity.  The study  involved developing an analytic approach that should be useful in evaluating the potential for other urban-use pesticides to reach surface waters. (Download report)

Diazinon and Chlorpyrifos Risk Assessments Technical Review: On behalf of the California Stormwater Quality Task Force (SWQTF), Dr. Moran conducted detailed technical peer reviews of the U.S. EPA risk assessments for the re-registration of diazinon and chlorpyrifos (Dursban).  Both diazinon and chlorpyrifos have been linked to toxicity in urban runoff and wastewater treatment plant effluent.  She identified numerous water quality issues in each of the multi-volume risk assessments, suggesting methods and resources to incorporate water quality considerations in the re-registration risk assessment process.  The most important issue identified for both risk assessments was the need to evaluate pesticide sites of use and formulations for water quality impacts.  The review comments, which were submitted by the SWQTF to the U.S. EPA, also identified opportunities for U.S. EPA to use the re-registration process to resolve disparities between water regulatory approaches mandated by the Clean Water Act and pesticide regulatory approaches mandated by the Federal Insecticide, Fungicide, and Rodenticide Act.

Urban Runoff Toxicity Reduction Program: Dr. Moran has been one of the leaders of San Francisco Bay regional efforts to eliminate toxicity in creeks and San Francisco Bay from diazinon in urban runoff.

• She directed preparation of the report Diazinon in Urban Areas (prepared by Ashli Cooper while working as an intern at the Palo Alto Regional Water Quality Control Plant; available online in the pesticides section of the City of Palo Alto publications page), the first analysis of sources of toxic diazinon discharges in urban runoff.  That report looked at diazinon uses, applications, formulations, and fate and transport processes related to releases into urban runoff and wastewater treatment plants.
• She chaired the Regulatory Subcommittee of the San Francisco Bay Area/Central Valley Urban Pesticides Committee, a cooperative group intending to develop a toxicity control strategy for urban runoff.  The products of this subcommittee included a comprehensive summary of agency authorities related to surface water quality protection from problems with pesticides and an analysis of possible regulatory agency actions to reduce toxicity in San Francisco Bay Area and Central Valley urban runoff.
• She was a technical peer reviewer for a series of reports produced by Alameda County Flood Control and Water Conservation District under a U.S. EPA grant, including the “Strategy to Reduce Diazinon Levels in Creeks in the San Francisco Bay Area,” and for a regional project involving local governments and independent garden and hardware stores (the Less-Toxic Home and Garden IPM partnership, 1998-1999).

Pesticide Regulations to Protect Water Quality: On behalf of the City of Palo Alto, Dr. Moran lead a successful legislative and regulatory effort to eliminate use of copper-based root control products and tributyltin-containing pesticides to protect San Francisco Bay. The regulation adopted by the California Department of Pesticide Regulation to enact the sale and use prohibition was not opposed by manufacturers and was supported by San Francisco Bay Area businesses and wastewater treatment plants. (The key elements of this project are summarized in a California EPA press release).

Trainer: Dr. Moran has organized and given presentations at numerous training sessions relating to pesticides. Sample topics: "Pesticides and Water Quality," "Diazinon in Urban Areas," "Developing Cooperative Relationships with the Department of Pesticide Regulation," "Mercury, Dioxins, PCBs and Organochlorine Pesticides: Sources & Pollution Prevention." Sponsors included the California Water Environment Association, the National Pollution Prevention Roundtable, the Oregon Association of Clean Water Agencies, the Water Environment Research Foundation, Stanford University, the University of California Santa Cruz, and U.S. EPA. She has given more than 60 professional presentations in the last five years.

Manager of Environmental Control Programs, City of Palo Alto Water Quality Program: Dr. Moran managed a combined environmental compliance and pollution prevention program for a wastewater treatment plant and storm water runoff program (Palo Alto is a member of the Santa Clara Valley Urban Runoff Pollution Prevention Program).  That program addressed pesticides and other pollutants of concern in surface water discharges.  Working with both large and small businesses, the program achieved high compliance rates with what are probably among the nation's most strict storm water runoff requirements.  She initiated and annually conducted innovative storm water and wastewater pollution prevention program planning and evaluation process, documented in the Clean Bay Plan. Dr. Moran received a letter of commendation from San Francisco Bay Regional Water Quality Control Board for work done at the City of Palo Alto. The Palo Alto Water Pollution Prevention Program won numerous awards under Dr. Moran's management; in 1998, it was named the Nation's Most Valuable Pollution Prevention Program (MVP2 Award) by the National Pollution Prevention Roundtable.

Pollutant Source Identification Studies And Pollution Prevention Plans Addressing Pesticides: Dr. Moran directed development of wastewater and storm water source identification studies and pollution prevention plans for various pollutants including diazinon and organochlorine pesticides (available online in the pesticides and pollution prevention sections of the City of Palo Alto publications page).  She analyzed results of low-detection limit pesticide sampling studies and coordinated a local government's strategy to respond to anticipated future discharge requirements for these pollutants.  She was a manager, technical reviewer, and conducted data compilation, analysis, and interpretation for pesticide sampling programs for storm water runoff, creeks, and wastewater in the Palo Alto area.  She was one of the first local government representatives to submit data for inclusion in the California Department of Pesticide Regulations’ (DPR’s) surface water quality database, using the DPR data reporting forms.

Residential and Commercial Source Control Assessment: Dr. Moran was a technical advisor for a project identifying sources and evaluating effectiveness of control measures for pollutants of concern in urban storm water runoff and wastewater, including pesticides. The project produced a critical assessment and research needs document, published by the Water Environment Research Foundation.

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