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HomeMy WebLinkAboutCOUNCIL - AGENDA ITEM - 03/10/2009 - REVIEW OF CHEMICAL MATERIALS EMPLOYED IN CITY OPER DATE: March 10, 2009 WORK SESSION ITEM STAFF: Carol Webb FORT COLLINS CITY COUNCIL SUBJECT FOR DISCUSSION Review of Chemical Materials Employed in City Operations: Snow/Ice Control Products,Fertilizers, and Pesticides. EXECUTIVE SUMMARY City staff has conducted a review of snow and ice control products, fertilizers, and pesticides used in City of Fort Collins operations. A team consisting of Regulatory and Government Affairs, Streets,Parks,Natural Resources,and Purchasing staff conducted the review and prepared a written report. The scope of the review focused on chemical products used in these departments in the largest volumes. Information provided includes environmental impacts, performance, cost, best management practices,and purchasing strategies for these chemicals.Comparisons have been made to products used by other municipalities/jurisdictions in our general region. Some recommendations have been made based on a review of environmental and industry best practices. GENERAL DIRECTION SOUGHT AND SPECIFIC QUESTIONS TO BE ANSWERED Does Council have any comments or concerns on the snow/ice control products, fertilizers, and pesticides employed in City operations? BACKGROUND In early 2008, Regulatory and Government Affairs, Streets, Parks, Natural Resources, and Purchasing staff conducted a review of the primary snow and ice control products, fertilizers, and pesticides employed in City operations. Research was conducted on the types.of products employed, environmental impacts, cost, performance, and best management practices associated with management of these chemicals. The report was updated in February 2009. General conclusions found in the report are as follows: SNOW/ICE CONTROL PRODUCTS The City of Fort Collins Streets Department operates a snow and ice control program very similar in both products and best practices to other north Front Range agencies. Of those agencies researched,the majority employ both solid and liquid chloride-based snow/ice control products and utilize similar best management practices for storage,product selection,and applications strategies. While Fort Collins does not utilize abrasives (sand/salt mixtures) as part of its snow/ice control program, a few agencies researched still apply a sand/salt mixture under certain conditions. The City discontinued use of a sand/salt mixture in 1996 due to its negative effects on air and water March 10, 2009 Page 2 quality. The City utilizes the same liquid magnesium chloride product that is used by the Colorado Department of Transportation (CDOT), who has conducted extensive studies on chloride-based deicing products. Chloride-based deicers utilized by the City have the potential to impact water quality and vegetation. These impacts are minimized through effective best management practices. Acetate-based deicers also have potential impacts on water quality and are considerably more expensive than liquid chloride deicers. The non-chloride acetate-based deicer currently used by the City is more than five times more expensive per gallon than the most expensive liquid chloride-based product. Streets staff employs standard best management practices established by the snow and ice control community, including other municipalities and departments of transportation across the United States and Canada. These practices are clearly defined and followed by staff and are essential in minimizing environmental impacts and controlling costs. The best management practices employed help ensure that snow/ice control products are selected that meet industry defined specifications and that product is stored properly and not over-applied to roadways. Several recommendations have been made based on a review of current practices as compared to environmental and industry best practices. Recommendations are as follows: • City staff should investigate the possibility of utilizing an anti-icing program (application of snow and ice control materials before a weather event). Effective,properly managed anti- icing programs have been shown to considerably reduce the amount of chemical that is applied compared to deicing strategies. Streets staff will continue to research anti-icing program alternatives. • Continue to research non-chloride product alternatives and stay abreast of new products. • An enhanced training program will be implemented to provide more comprehensive training for all snow equipment operators. • An ongoing water quality data collection program could be developed to evaluate parameters specific to those chemicals found in snow/ice control products. A thorough cost analysis should be conducted to determine associated costs with monitoring wet weather flows. • An environmental management system should be implemented to thoroughly evaluate and minimize environmental impacts of Streets operations. • A method for evaluating salt sensitive habitats, such as salt-sensitive vegetative communities, habitats for species at risk, and small ponds and lakes, may be an option for reducing the environmental impact of deicer application. • Environmental stewardship practices should be incorporated into the siting and operation of snow storage facilities. March 10, 2009 Page 3 PESTICIDES AND FERTILIZERS Several City Departments utilize fertilizers and pesticides. Fertilizer products are selected and applied based on specific vegetation needs and sometimes based on soil analysis. The City primarily uses general use pesticides, which do not require a license to purchase or use. The City's Natural Area Program uses two restricted use pesticides. One product is used to control Canadian Thistle, while the other is used for prairie dog management. These products require a license to purchase and use. The City follows an"Integrated Pest Management Approach"(IPM),an industry-wide best practices approach to managing pests by the most economic means with the least hazard to people,property, and the environment. For herbicide application,this approach aims to minimize chemical use while maximizing chemical effectiveness by identifying target periods during plant growth during which the herbicide is most effective, and by continually altering the mode of chemical attack. All pesticide applications by City staff of both general use and restricted use pesticides are done following label instructions carefully and precisely to ensure safe use. City staff responsible for product selection regularly assess available products to ascertain the best product for use in specific situations. Products are evaluated in terms of environmental risk and product effectiveness. City staff attends training regarding the potential health and environmental hazards of chemicals to which they are exposed. Employees who work with restricted use pesticides are required to obtain professional licenses for pesticide application. Other employees who work with general use pesticides are encouraged to obtain applicator licenses. Following the IPM approach,the City's Natural Areas program utilizes alternatives to chemical use including prescribed fire, sheep grazing, and non-toxic chemicals. Effective weed control utilizes herbicides in conjunction with alternative methods that introduce stress to the invasive plant thereby decreasing the overall quantity of herbicides used. Implementation of an environmental management system is recommended to systematically evaluate and minimize environmental impacts of fertilizer and pesticide application. ATTACHMENTS 1. Evaluation of Chemical Materials Employed in City Operations. 2. PowerPoint presentation. ATTACHMENT City of Fort Collins 0,000 EVALUATION OF CHEMICAL MATERIALS EMPLOYED IN CITY OPERATIONS INCLUDING: SNOW AND ICE CONTROL PRODUCTS FERTILIZERS PESTICIDES By Carol A. Webb, Regulatory and Government Affairs Manager In Cooperation with: Larry Schneider, Streets Superintendent Neal Jaspers, Streets Supervisor Mike Calhoon, Parks Crezo Chief John Stephen, Senior Buyer Errin Henggeler, Environmental Regulatory Specialist Matt Parker, Natural Areas Crew Chief March 21, 2008 Revised April 25, 2008 Revised February 9, 2009 Page 1 of 23 Contents EXECUTIVE SUMMARY............................................................................. 3 SNOW AND ICE CONTROL PRODUCTS Typesof Products................................................................................. 6 Products Used by Other Agencies........................................................... 8 PurchasingStrategies.....................:..................................................... 9 Environmental Impacts......................................................................... 10 Corrosion........................................................................................... 11 Best Management Practices.................................................................... 12 Conclusions and Recommendations........................................................ 14 PESTICIDES AND FERTILIZERS Fertilizers........................................................................................... 16 Pesticides........................................................................................... 16 Chemical Toxicity and Environmental Characteristics................................ 18 Best Management Practices................................................................... 19 Conclusions and Recommendations........................................................ 22 Page 2 of 23 EXECUTIVE SUMMARY PROBLEM STATEMENT A chemical materials review was conducted of snow and ice control products, fertilizers, and pesticides used in City of Fort Collins operations. A team consisting of Regulatory and Government Affairs, Streets, Parks, Natural Resources, and Purchasing conducted the review. The scope of the review focused on chemical use in these departments in the largest volumes. Chemicals used infrequently in minute quantities(such as less than 10 gallons/year)were not included in the scope. Information provided includes general information on environmental impacts, performance, cost, purchasing strategies, and best management practices for these chemical products.Comparisons have been made to products used by other municipalities/jurisdictions in our general region, depending on the information available. Material Safety Data Sheets' are available upon request. GENERAL CONCLUSIONS SNOW/ICE CONTROL PRODUCTS • The City of Fort Collins snow and ice control program is very similar in both products and best practices as other north Front Range agencies. Of those agencies researched, the majority employ both solid and liquid chloride-based snow/ice control products and utilize similar best management practices for storage, product selection, and applications strategies. • The City selects products based on standards set by The Pacific Northwest Snowfighters (PNS), a consortium of states and Canadian provinces. PNS has developed a list of physical, environmental, and corrosion-related specifications for qualification of snow and ice control materials. Roadway management agencies across the U.S. and Canada utilize PNS for product selection. • The City follows best management practices used by roadway management agencies in Colorado and across the country that are recommended by the Center for Environmental Excellence by the American Association of State Highway and Transportation Officials (AASHTO), a resource for transportation professionals seeking technical assistance, training, information exchange, partnership-building opportunities, and quick and easv access to environmental tools. Fort Collins does not utilize abrasives (sand/salt mixtures)as part of its snow/ice control program. A few agencies researched still apply a sand/salt mixture under certain conditions. The City of Fort Collins discontinued use of a sand/salt mixture in 1996 due to its negative effects on air and water quality. • Chloride-based deicers have the potential to impact water quality and vegetation. These impacts can be minimized through effective best management practices. Acetate-based deicers also have potential impacts to water quality and are considerably more expensive than liquid chloride deicers. • The City utilizes the same liquid magnesium chloride product that is used by the Colorado Department of Transportation, who has conducted extensive studies on deicing products. Material Safety Data Sheets are used to catalog information on chemicals,chemical compounds,and chemical mixtures. MSDS information may include instructions for the safe use and potential hazards associated with a particular material or product. Page 3 of 23 • The City utilizes defined purchasing criteria to ensure that snow/ice control products employed meet industry standards. • The non-chloride acetate-based deicer currently used by the City is over five times the cost per gallon than the most expensive liquid chloride-based product. • Streets staff employs standard best management practices established by the snow and ice control community including other municipalities and departments of transportation across the United States and Canada. These practices are clearly defined and followed by staff. The best management practices employed help ensure that snow/ice control products are selected that meet industry defined specifications and that product is stored properly and not over-applied to roadways as to minimize environmental impacts. Recommendations • City staff should investigate the possibility of utilizing an anti-icing program (application of snow and ice control materials before a weather event). Effective, properly managed anti- icing programs have been shown to considerably reduce the amount of chemical that is applied compared to deicing strategies. Streets staff will continue to research anti-icing program alternatives. • Streets staff will continue to research non-chloride product alternatives and stay abreast of new products. Staff continues to stay involved in trade groups and associations in order to stay current on new trends and practices in the snow and ice control industry. • An enhanced training program will be implemented to provide more comprehensive training for all snow equipment operators. • An ongoing water quality data collection program should be developed to evaluate parameters specific to those chemicals found in snow/ice control products. A thorough cost analysis should be conducted to determine associated costs with monitoring wet weather flows. • An environmental management system should be implemented to thoroughly evaluate and minimize environmental impacts of Streets operations. • A method for evaluating salt sensitive habitats, such as salt-sensitive vegetative communities, habitats for species at risk, and small ponds and lakes, could be an option for reducing the environmental impact of deicer application. Environmental stewardship practices should be incorporated into the siting and operation of snow storage facilities. PESTICIDES AND FERTILIZERS Several City Departments utilize fertilizers and pesticides. The City follows an "Integrated Pest Management Approach' (I PM), an industry-wide best practices approach to managing pests by the most economic means, with the least hazard to people, property, and the environment. • Fertilizer products are selected and applied based on specific vegetation needs and the application and sometimes based on soil analysis • Colorado state law requires that landowners, both public and private control noxious weeds. • The City uses primarily general use pesticides, which do not require a license to purchase or use. • The City's Natural Area Program uses two restricted use pesticides. One product is used to control Canadian Thistle, while the other is used for prairie dog management. These products require a license to purchase and use. • All pesticide applications by City staff of both general use and restricted use pesticides are done following label instructions carefully and precisely to ensure safe use. Page 4 of 23 • Toxicity risk labels on pesticides used in City operations range from "Caution" to "Danger", with the restricted use pesticides having more acute toxicity. City staff responsible for product selection regularly assesses available products to ascertain the best product for use in specific situations. Products are evaluated in terms of environmental risk and product effectiveness. City staff attends training regarding the potential health and environmental hazards of chemicals to which they are exposed. Employees who work with restricted use pesticides are required to obtain professional licenses for pesticide application. Many employees who work with general use pesticides also obtain applicator licenses. Following the 1PM approach, the City's Natural Areas program utilizes alternatives to chemical use including prescribed fire, sheep grazing, and non-toxic chemicals. Effective weed control utilizes herbicides in conjunction with alternative methods that introduce stress to the invasive plant thereby decreasing the overall quantity of herbicides used. Recommendations Continue the extensive training programs provided to employees who work with hazardous chemicals. • Continue use of the IPM approach and to explore alternatives to pesticide use. • Implementation of an environmental management system should be considered. Page 5 of 23 SNOW AND ICE CONTROL PRODUCTS General Information The Citv of Port Collins utilizes a variety of snow and ice control products to ensure that roadways are properly maintained during weather events. Product selection criteria include cost, performance, and potential environmental impacts. The City's snow and ice control strategies and products have changed over the years due to changes in industry practices, availability of nes-v products, and changing markets. The City Streets Department has remained current on trends in the snow and ice control industry and has tested new products as they become available in order to use the best products for the safety of our community while placing an extremely high value on environmental protection and cost considerations. Types of Products The City currently uses three types of deicers for roadway snow and ice control: chloride-based granular deicers, chloride-based liquid deicers, and acetate-based liquid deicers. Additional deicers are used in smaller quantities on sidewalks surrounding city facilities, in city parks, and on high traffic pedestrian areas where slip hazards occur regularly. These are primarily chloride- based granulars, with the exception of urea (a nitrogen-based product), which will be addressed later in this section. Material Safety Data Sheetsz (MSDS) for all materials discussed in this review are available. The bulk of this section will address those deicers used for roadway snoti,/ice control. Chloride-based Granular Deicers The City utilizes two types of chloride-based granular deicers for road maintenance. "Ice Buster", the City's primary granular product, is a complex chloride containing primarily sodium chloride(NaCl), magnesium chloride(MgCl2), and calcium chloride(CaC12).This salt comes from a salt mine in Kansas and is grey in color. The City pre-wets Ice Buster with a chloride-based liquid deicer prior to application to reduce corrosion. "Ice Slicer", the City's secondary granular product, is a complex chloride very similar to Ice Buster. Ice Slicer is mined in Utah and is reddish in color. Ice Slicer contains less sodium chloride and more calcium chloride than Ice Buster.3 Two types of chloride-based granular products are used for pedestrian walkways. "Safe Step Ice Melter" is a sodium chloride, potassium chloride mix and "Meltdown Near Zero" is a complex chloride of sodium, potassium, and magnesium chlorides. Chloride-based Liquid Deicers The City utilizes three chloride-based liquid deicers. "Meltdown Apex" is the City's primary liquid product. The base product for Apex is a corrosion inhibitor derived from organic polymers and blended with a 30 percent magnesium chloride solution. Caliber M1000 is used as a secondary liquid product and is also a 30 percent magnesium chloride solution. Caliber M1000 has a corrosion inhibitor base derived from corn products. "Ice Ban" is used as a substitute 'Material Safety Data Sheets are used to catalog information on chemicals,chemical compounds,and chemical mixtures.MSDS information may include instructions for the safe use and potential hazards associated with a particular material or product. Sanders,Thomas G.and Christopher M. Safford,Colorado State University."Deicers:Melting Away Winier's Woes"', Snow and Ice Magazine,August 2002. Page 6 of 23 liquid deicer when Meltdown Apex and Caliber M1000 are unavailable. Ice Ban has a corn- derived base blended with a 25 percent magnesium chloride solution. Acetate-based Liquid Deicers NC3000, a potassium acetate, non-chloride product, is applied to bridge decks and concrete areas. This product is used sparingly in part due to its high cost. Potassium acetate is produced by reacting high-grade acetic acid with dolomite limestone. The high cost of this product is a result of the costly production process:' Urea Urea, a nitrogen fertilizer, is used as a deicer on pedestrian walkways around some City facilities. Urea is not corrosive to metals, but can be corrosive to concrete. It is used because of its ease of application and because it is friendlier to surrounding vegetation than other deicers. However, as Urea can be corrosive to concrete, this product is used sparingly. The table below provides detailed information on each commercial brand of deicer. City of Fort Collins Snow/Ice Control Products (2008) Corrosion fi : µ Product Commercial tt =` z�t „t g W+"A z Rate Flo r T, + y , Type _ Naive '_'. Com osihon. ", ,.�. Desch bon-� :Effectiveness» '�-�, .A'�' hcahon,-'5 ,E - NaCl(pre-wetted - -- — - Ice Buster with chloride- Solid 30.0 Primary granular based li uid) product for roads CaC12(pre-wetted Chloride- Ice Slicer with chloride- Solid 30.0 Secondary granular based product for roads granulars based liquid)Safe Step Ice NaCl, KCI Solid NA For pedestrian Melter walkways Meltdown For pedestrian Near Zero NaCl,KCI,MgCI_ Solid NA walkways Liquid derived Meltdown Liquid Chloride- Apex liquid A 30%MgCI from organic 25.1 product polymers P P Caliber Liquid derived Secondary liquids liquid based 30%MgCI 20.8 M1000 from corn product Liquid derived Substitute when Ice Ban 25%MgCl from corn 8.4 Caliber and Apex is not available Non- Contains 30% Used to spot treat chloride NC3000 Potassium Acetate carbohydrate -3.5 bridge decks and liquid material concrete areas Nitrogen Used on sidewalks Urea Nitrogen Fertilizer 46-0-0 NA around City facilities, Fertilizer arks a"Guidelines for the Selection of Snon and lce Control Materials to Mitigate Environmental hvpacts National Cooperative Highway Research Program,Report 577,page 12,2007. As determined by Pacific Northwest Snow Fighters Product Specifications and Test Protocols,Qualified Product List, September 2007. Page 7 of 23 The following chart details the amount of product used for roadway snow/ice control from 2005- 2007. Total Amount of Snow/Ice Control Product Used _ Product_ : - °2005, `. : 2006 ;, 2007 2008 Ice Buster(tons) 1,882 2831 3,129 1461 Ice Slicer(tons) 960 540 0 Total Tons granular product 1,882 3,791 3,669 1461 Caliber M1000(gal) 244,798 Meltdown Apex (gal) 47,469 433,031 463,116 308,517 Ice Ban (gal) 19,594 0 NC3000(gal) 1,385.00 1,430.00 1,340 215 Total Gallons liquid deicer 293,652 434,461 484,050 308,732 Snow/Ice Control Products used by Other Local Agencies Northern Colorado Front Range agencies who operate deicing programs utilize the same or similar snow and ice control products as the City of Fort Collins. Some agencies operate both a granular and liquid deicing program, while some utilize only granular products. A few agencies researched still apply a sand/salt mixture under certain conditions. The City of Fort Collins discontinued use of a sand/salt mixture in 1996 due to its negative effects on air and water quality. The Table below lists agencies and types of products employed as determined via email and/or phone or by review of available literature. North Front Range Agencies Snow/Ice Control Product Comparison 6 xs&�a ezz � n 9 _ iltl ,.,<y t a Chlonde=based . . MagChlonde based Sand or Sand/Salt .. � a.�. "s..: �E gianulai;dercer k ;, 'hgmddercer Fort Collins X X Lon month X X Larhfi County't X X :BouIdeiB X X Lovelani39;__� . X X Colorado;Dept of Tr`ansporta6onio -" X X X Greeley?? X X X Larimer County staff stated that sand is applied in some areas of the County due to lack of suitable storage for chloride-based products.12 The Colorado Department of Transportation e "City of Longmont Snore and Ice Connvl Plan`,page 24. September 2007. 7 Dennis Morrison,Larimer County Road R Bridge Department,phone conversation,2/29/08. s Felix Gallo,Boulder Transportation Coordinator,email correspondence from February 27,2008. 9"Snow Removal Mitch More that Plowing, The Loveland City Update",November 2005. 10 Wilson,Bob."CDOT Announces Snow and Ice Battle Plat",page 3. November 20,2007. n Jerry Pickett,City of Greeley Streets Department,phone conversation,2/28/08. 1'Dale Miller, Larimer County Road and Bridge Department,phone conversation,3/5/08. Page 8 of 23 (CDOT)employs both liquid and granular deicing programs. They use the same liquid deicer, Meltdown Apex, as the City of Port Collins, in conjunction with a sand/salt mixture in some areas of the state. CDOT believes that the liquid magnesium chloride product they are using is the most effective and cost efficient chemical deicer available.13 Boulder utilizes the same commercial brand of liquid deicer and also operates a granular deicing program. Boulder staff stated that they do apply sand/salt mixtures in emergency situations when other products are unavailable." Liquid magnesium chloride products are sometimes used by roadway management agencies to reduce fugitive dust on non-paved roads. It is important to note that, in this application, MgC12 is applied in much higher concentrations than the concentration used in deicing applications. Where snow/ice control application rates are 30-60 gallons of MgCL per two-lane mile, dust suppression application rates are 1200-2000 gallons per two-lane mile. These applications also take place during the active growing season for vegetation. Purchasing Strategies The City belongs to a state cooperative group, Multiple Assembly of Procurement Officials (M.A.P.0)which is comprised of all state, municipal, county, or other local area government agencies throughout Colorado.The City combines the needs and quantities and solicits bids for road salt, pesticides, fertilizers, and other chemicals, since most government agencies use those products.Using M.A.P.O, we are assured that we are getting the best price possible for the products that the City needs. Many local agencies, including Boulder and City of Denver, participate in this bidding process for road salt. The City utilizes CDOT bids for a few products, including Ice Slicer, a granular chloride product. CDOT buys large quantities of these products and the City piggybacks on those agreements to ensure the best price is procured. Cost Comparisons for Roadway Snow/Ice Control Products 2007 Amount � ,� 1200&m�,w-, Amonnt $Cost/Ton Used rn $Cost/Ton of Used m , 2008 Product or Gallon 2007 ,'2007 CostH Gallon ' 2008' Cosh Ice Buster 44.30 3,129 $138,615 48.70 1461 $71,150 Ice Slicer 74.00 540 $39,960 Meltdown 0.62 463,116 $287,132 0.66 308,517 $203,621 Apex Ice Ban 0.69 19,594 $13,520 NC3000 3.97 1 1340 $5,320 3.97 215 $854 As seen in the chart, NC3000, the non-chloride acetate-based product is over five times the cost per gallon than the most expensive liquid chloride-based product. 13 Prof. Yunping Xi and Zhaohui Xie,­CorrOS(on Effects of Magnesium Chloride and Sodilon Chloride on Automobile Components ,CDOT Research Branch, Report No.CDOT-DTD-R-2002-4, May 2002. 14 Felix Gallo,2/27/08. Page 9 of 23 Environmental Impacts In 2007, the National Cooperative Highway Research Program conducted an extensive evaluation of the cost, performance, and environmental and infrastructure impacts of snow/ice materials.75 In addition, CDOT has conducted several studies and has a particular interest in this issue due to the large quantities of products they must use to improve roadway conditions and protect public safety across the State of Colorado.76,17,78 These studies draw general conclusions concerning sand, granular, and liquid deicers and their potential impacts to the environment. The main concerns identified were air pollution, affects on air quality, water quality and aquatic habitat, vegetation, and corrosion. Air Quality The use of abrasives(sand)as a snow/ice control product can result in air pollution due to the increase in airborne fine particulates or PM1019. In addition, abrasives have been found to cause lung disease and are a listed carcinogen. In mountain regions with localized air sheds and limited recharge, PM10 is of particular concern. Chloride-based granular deicers may have a limited effect on air quality when the material dries on roadways and is picked up by wind and air currents, however pre-wetting the material with a liquid deicer helps in limiting this effect. Liquid deicing products have little to no effect on air quality and are considered to have a net air quality benefit due to the reduction in the use of abrasives. Water Quality Sand contributes significantly to sedimentation and turbidity in surface waters, impacting aquatic life. Chloride-based granular and liquid deicers may lead to excessive chloride loading in surface waters, however acute toxicity of chloride-based deicers to aquatic life is generally low. Contaminants such as phosphorus, ammonia, and heavy metals found in some chloride-based deicers have the potential to impair surface waters and to exceed water quality standards for the protection of aquatic life. These contaminants can be adequately controlled through product specifications and laboratory testing of available products. Both chloride-based and acetate deicers may contain large amounts of organic matter, potentially causing oxygen depletion in surface water. Estimated dilution of deicers from roadway to surface water is 100 to 500-fold, which reduces potential impacts to aquatic habitat. Vegetation Chloride-based deicers contain a number of ions that cause foliar and root damage to vegetation within "10 to 20 meters of the roadway. Studies conducted to date indicated that damage to vegetation is primarily from chlorides rather than from sodium, magnesium, potassium, and calcium cations. This damage can occur in a number of ways, including splashing from the roadway or uptake through the soil. Actively growing plants (e.g. conifers)are the least tolerant to chloride damage. Sodium can degrade soil structure, which results in osmotic stress on vegetation. -`'Guidelines for the Selection of Snow and Ice Control Materials to Mitigate Environmental Impacts", National Cooperative Highway Research Program, Report 577,2007. 1° Lewis,William,"Studies of Environmental Effects of Magnesium Chloride Deicer in Colorado',CDOT Research Bank, Report No.CDOT-DTD-R-99-10,November 1999. 1' Fischel.Marion,"Evaluation of Selected Deicers Based on a Review of the Literature`,CDOT Research Bank, Report No.CDOT-DTD-R-2001-15,October 30,2001. 's Lewis, William,.-Evaluation and Comparison of Three Chemical Deicers for Use in Colorado",CDOT Research Bank, Report No.CDOT-DTD-R-2001-17,August 2001. 19 Particulate matter smaller than 10 microns in size Page 10 of 23 The magnitude of the effect of deicing materials depends on a number of factors including site and soil characteristics and the amount of material applied. Although acetate-based deicers do not contain chlorides, additional research is needed on potential impacts to vegetation. The three studies conducted by CDOT evaluated several commercial brands of deicers similar to those used by Fort Collins. Some deicers studied contain contaminants that may cause some of the negative environmental impacts listed above. Corrosion inhibitors, although they reduce the corrosiveness of chloride-based deicers, can contain nutrients in levels that may damage the aquatic environment. Product specifications are very important in the selection of deicers to ensure they do not contain these contaminants. The City's method for ensuring products selected meet specifications is discussed later in this section. The City uses one non-chloride deicer, NC3000, to spot treat bridge decks and concrete areas. This is an acetate-based deicer, and although these types of deicers tend to cause less corrosion, they do have potential environmental impacts. Corrosion Chloride-based deicers are corrosive to both concrete and steel structures, although magnesium chloride has been found to be more corrosive to concrete than other chloride-based deicers. The addition of corrosion inhibitors reduce the corrosion potential, but increase the impact to water quality. Acetate-based deicers are generally non-corrosive. There is growing concern about the corrosion caused by chloride-based deicers to vehicles, bridges, and utilities. The Pacific Northwest Snowfighters(PNS), a consortium of states and Canadian provinces, has developed a list of physical, environmental, and corrosion-related specifications for qualification of snow and ice control materials. PNS has developed test protocols for evaluating corrosion rates of different deicers.The PNS requires that tests for corrosion rates in deicers be conducted using specific test methods for corrosion.20 In order for a deicer to be approved by PNS, a corrosion inhibited chemical deicer, is required to be 70%less corrosive to mild steel than sodium chloride(straight salt). Fhe following graph illustrates the corrosion rate for each deicer as determined by PNS compared to sodium chloride(salt): Snow/Ice Control Products Corrosion Comparison 100.0% 80_0% - - - --- — -- -- -- --- }k i b 40.0/0 — (f � El Salt MgC12 Ice Buster Ice Slicer Meltdown Caliber Ice Ban water N5=0 Apex M1000 -20.0 Deicing Material Best Management Practices Pacific Northwest Snowfighters,"PNS Snow and Ice Control Specifications and Test Protocols', April 2006. Page 77 of 23 The City's Streets Department utilizes a snow removal operations manual that serves as a guide for winter road operations. This manual provides established procedures to the department on industry best management practices to adequately maintain roadways in a safe condition and to provide such service in an environmentally responsible manner. These practices are used by roadway management agencies in Colorado and across the country and are recommended by the Center for Environmental Excellence by the American Association of State Highway and Transportation Officials(AASHTO), which serves as a resource for transportation professionals to environmental best management practices. Training Snow removal equipment operators attend least 16 hours of mandatory training each fall prior to the snow/ice season. Topics discussed included deicing material application, emergency operations, and cooperation with other City departments. Employees discuss problems encountered the previous snow season and any changes to procedures. As part of the annual training, snow equipment operators conduct "dry-run' demos of snow equipment. Novice drivers are teamed with experienced drivers to ensure that best practices are followed. Storage The City receives its solid deicing materials via rail car at the Streets Facility. The City's Snow Removal Operations Manual contains specific instructions on proper unloading of rail cars to ensure that product is delivered in safe and timely manner while minimizing the chance for a spill. The solid materials storage building is a state of the art facility with a runoff control system to allow for collection of materials for reuse. The facility is inspected regularly to ensure that the desired level of cleanliness, appearance, and integrity is maintained, and that solid materials are properly stored to prevent the release of stored materials into the environment. The City of Fort Collins was awarded the Salt Institute's 2008 Excellence in Storage Award for high standards of environmental consciousness,best management practices, and effective management of winter material storage.The City of Fort Collins was one of 10 city and state transportation agencies across North America that received the award. Eight—21,000 gallon above-ground storage tanks (ASTs)containing liquid deicer are located at the Streets Facility. The liquid tank storage area has adequate secondary containment to contain and recapture spills or the volume released from a tank rupture. Pumps and hoses are properly sized for quick loading. The ASTs also have recirculation capability to maintain product consistency should settling occur. Purchasing Specifications City Streets staff utilizes the Qualified Products List(QPL) developed by PNS to select snow/ice control products. Specifications determined by PNS via standardized protocols include maximum concentrations for pH, metals, phosphorus, and cyanide.21 Manufacturers are also required to provide analyses on the nitrogen series, biological and chemical oxygen demand, and to conduct toxicity testing on sensitive species. All of the granular and liquid deicers utilized by the City of Fort Collins are listed on the PNS Qualified Products List. Application Methods 21 Pacific Northwest Snowfighters,"PATS Snow and Ice Control Specifications and Test Protocols", April 2006,page 2. Page 12 of 23 Appropriate equipment is needed for handling and applying snow and ice control chemicals. Streets equipment operators conduct thorough inspections of equipment prior to commencing work to ensure that equipment is in good working order and operating efficiently. Snow plow operators are instructed to plow down to bare pavement to reduce the amount of solid or liquid deicer applied to the roadway. During granular and liquid deicing applications, the amount of deicer applied is regulated to prevent over application of material and to decrease runoff concentrations.The City's snow plow trucks are equipped with calibration devices for spreaders that aid operators with the proper application of granular and liquid material. This calibration of equipment is extremely important to achieve control of the rate of application.Operators are advised to use the"automated" mode for dispensing material for proper application. Conditions are continually monitored to appropriately adjust application methods as needed during a storm event. Road and Weather Conditions Evaluation There are six Road and Weather Information Stations (RWIS) located throughout the City. These stations actively monitor roadway temperature, precipitation, wind speed, subsurface temperature, and other weather conditions to ensure that deicing strategies under given conditions are adjusted accordingly. Automated deicing application systems have been installed in two locations-Timberline Bridge and West Trilby. These systems automatically apply acetate- based products on the approach to and over bridges to ensure public safety and minimize corrosion. Application Strategies Anti-icing-Anti-icing involves application of snow and ice control materials before a weather event. The City does not conduct anti-icing operations. Past experiences in the Streets Department have shown that when anti-icing agents are applied and the storm does not develop, ice crystals accumulate and make the road more slippery. However, studies do show that an effective anti-icing program can reduce product application rates, and is an industry best practice.''-'-Streets staff continues to research alternatives for anti-icing. Deicing- Deicing involves application of snow and ice control materials on top of snow and/or ice. Streets staff utilizes deicing techniques combined with pre-wetting(discussed below). Deicing alone without pre-wetting can result in a loss of material to the roadside environment.''-' Pre-wetting—Pre-wetting is injecting or spraying a liquid chemical on solid chemicals or abrasives to enhance their effectiveness and reduce material loss and other forms of waste.za Streets staff ensures that granular chloride products are pre-wetted with a liquid magnesium chloride-based product prior to application. Pre-wetting provides moisture to make brine, resulting in faster melting action that reduces overall application rates.The wet salt also has less of a tendency to bounce or be blown off the road by traffic, which can reduce application rates by an estimated 20 to 30 percent. The table below describes the application strategies used by the City Streets department. Z'Report 577,page 19. z'Report 577,page 19. 2' Report 577,page 19. Page 13 of 23 City of Fort Collins Application Strategy Tablets - CONDITION_ ,, _ ,_ 4_ _,, ,, , =APPLICATION, Temperature Precipitation Road Surface - Product Process Snow,sleet or Apex Meltdown at 30 gallons If snow or sleet continues Near 30" wet or sticky and/or salt at 120lbs per two- and accumulates,plow and freezing rain lane mile add material simultaneously. Meltdown Apex at 30-50 Below 30"or Snow,sleet or gallons and/or salt at 120-300 As snowfall continues and falling freezing rain Wet lbs per two-lane mile, accumulates plow and repeat depending on accumulation material application. rate. Plow ASAP.Apex Meltdown Continue to plow and patrol Below 20"and Dry snow Dry at 50 gallons and/or salt at to check for wet,packed or Falling icy spots;treat them with 120-200 Ibs per two-lane mile. heavy salt applications If snow or sleet continues Apply Apes Meltdown at 30- and accumulates,plow and Below 20" Snow,sleet or apply liquids or salt freezing rain Wet 50 gallons and/or salt al 150- simultaneously 300 Ibs per two-lane mile. Continue until safe pavement is obtained Accumulation of Plow when snow or ice Below 10" Snow or freezing packed snowApplv Apex Meltdown at 30- becomes slushy. Repeat rain 52 gallons application and plowing as and ice. necessary. Selection of a strategy, or sequence of strategies, can affect the total loading of a snow and ice control material.Streets staff utilizes all available information to determine the proper strategy needed to apply the least amount of deicing material with the greatest level of effectiveness. Post-Application Procedures Following a storm event,Streets staff follows documented procedures for inspecting and cleaning snow removal equipment. Trucks, spreaders, and plows are washed and cleaned thoroughly in an indoor facility to ensure run-off is captured by the sanitary sewer. An after action review of the storm event is conducted to review the deicing application strategy, successes, and opportunities for improvement. The amount of deicing material used during each storm event is reviewed and the application strategy is adjusted accordingly. Conclusions and Recommendations Each of the deicers employed by the City of Fort Collins, and anv deicer used by any agency, has potential impacts on the environment. Each product has advantages and disadvantages which must be considered in choosing the right product for the right application. Granular chloride products are very effective and inexpensive, but can cause corrosion and have the potential to impact vegetation and water quality. Liquid deicers, also effective and inexpensive, are less corrosive than granular products but may cause impacts to vegetation closer to the roadway and to the aquatic environment. Non-chloride products such as acetates are effective and non- corrosive, but are expensive and may also impact the aquatic environment. The products that the City is using for snow and ice control are identical to or similar in composition to those used by other north front range agencies, including CDOT, which does tc Streets Department Operations Manual, February 2008,page 7. Page 14 of 23 conduct extensive research on snow/ice control materials and their environmental effects. City Streets staff stays abreast of new products available in their industry and actively participates in studies to determine what is the most effective product available factoring in cost and environmental impacts. Industry best practices are followed from product receiving, storage, through product application. The City does not operate an anti-icing program because Streets staff has had difficulties developing an effective anti-icing program. Streets staff should continue to investigate this possibility. The City should continue to participate in working groups in the snow/ice control industry to stay abreast of new research and to participate in these studies. Larry Schneider, Streets Superintendent, is currently the chairman of the Western States Snow & Ice committee, a member of the American Public Works National Snow Conference committee, and a member of Clear Roads, a cooperative program aimed at funding research to meet the needs of winter operations professionals around the world.As many new products come available, their benefits and disadvantages will be researched and considered in selection of the snow/ice control materials used in City operations. The Streets Superintendent is currently developing a comprehensive training program for all snow control equipment operators. This program would build on the 16 hours of training already required, adding an additional 24 hours per year of required training for each operator. A certification would be issued upon successful completion of testing administered following the training. Consideration should be given to administering an ongoing surface water monitoring program targeted to parameters such as magnesium, sodium, chlorides, conductivity,and other water quality indicators during and following storm events to gauge the impact of snow/ice control products on water quality. A collaborative water testing program between Streets and Stormwater may be of benefit to both departments. Wet weather sampling does come with inherent difficulties and can be costly to conduct. A thorough investigation into the feasibility, type, and costs of an ongoing water quality monitoring program should be conducted. The Streets Department would greatly benefit from implementation of an Environmental Management System (EMS). An EMS provides a framework for integrating environmental considerations and objectives into on-going management decisions. While a concerted effort is made by Streets staff to consider environmental impacts, there is currently not a formal system of policies and procedures in place to ensure environmental impacts are taken into account. A method for evaluating salt sensitive habitats, such as salt-sensitive vegetative communities, habitats for species at risk, and small ponds and lakes, could be an option for reducing the impact of deicer application. Planting salt tolerant species in medians and other high exposure areas may help reduce impact to vegetation. Further investigation would need to be completed to evaluate the feasibility of this management practice. Environmental stewardship practices should be incorporated when siting snow storage facilities. Site conditions should be evaluated to determine potential impacts to nearby surface waters, site hydrology, and the proximity to any salt-sensitive habitats. A plan should be implemented to manage any snow melt discharge from the site. Page 15 of 23 FERTILIZERS AND PESTICIDES Several City departments including the Natural Areas Program, Parks/Cemeteries/Golf/Forestry (Parks) Division, and Utilities use and apply fertilizers and pesticides. These departments incorporate industry best management practices into product selection and application to ensure that the best services are provided, regulations are followed, worker health and safety is protected, and environmental impacts are considered. The City follows an "Integrated Pest Management Approach` (IPM), a common-sense approach to managing pests by the most economic means, with the least hazard to people, property, and the environment. Fertilizers The City's Natural Areas Program, Parks Division, and Utilities use fertilizer applications to address soil nutrient deficiencies and for grounds maintenance. The Natural Areas Program uses fertilizer applications as part of a limited number of restoration projects. To date, the need to supplement the soil has solely been related to the presence of sugar beet processing waste that now occupies Kingfisher Point Natural Area.The Parks Division maintains approximately 800 acres of irrigated turf with nearly 100 sports fields, three golf courses, and two cemeteries. Fertilizer is also applied at Utilities facilities as part of the grounds maintenance program. MSDSs for each fertilizer used are available upon request. Fertilizer Selection and Application Fertilizer products are selected and applied based on specific needs of plants and vegetation. When practical and appropriate, fertilizer selection and application is based on soil analysis. For example, fertilizers applied to City golf course fairways, tees, and the rough are slow release formulations that prevent large releases of nutrients at any one time. These formulations feed nutrients to the turf at a rate that it can be used by the plant and not leached through the soil into the groundwater. Fertilizers applied to putting greens are applied at a lower rate and more frequently than other areas of the golf course. This practice allows the Golf Division staff to micromanage turf needs through the season based on soil tests and the needs of the plant during different seasonal conditions. A combination of granular applications and spray nutrient applications are made through the growing season. In any situation, staff is careful not to over apply fertilizers. Manufacturer directions are followed, applying the minimum amount recommended, which is best for the health of the plant and minimizes run-off of fertilizers into the storm drain system. Pesticides Before a pesticide can be sold or distributed in the United States, the product must obtain registration from the Environmental Protection Agency (EPA).The process of registration includes examination by the EPA of the ingredients of the pesticide, where and how it will be used, and storage and disposal practices. Prior to registration, EPA requires more than 100 different scientific studies and tests to assess a wide variety of potential human health and environmental effects associated with use of the product.This assessment ensures that the pesticide can be used for its intended purpose with reasonable certainty that it will not cause harm to human health or the environment.26 26 United States EPA,"Evaluating Potential New Pesticides and Uses", http://wwa.epa.eov/pesticides/reeulating/index.hun#c\,al,accessed March 20,2008. Page 16 of 23 The EPA may register a pesticide as "general use" or "restricted use". A general use pesticide can be used by the general public without any special licenses or training. The vast majority of the pesticides used in City operations fall into this category. Some pesticides are classified as "restricted use". Restricted use pesticides are not available to the general public and can only be used by a certified pesticide applicator or under the direct supervision of a certified applicator. Pesticides are generally restricted due to safety concerns including potential environmental impacts, toxicity to humans and non-target plants or animals, and the application method (e.g. fumigants). The City Natural Areas Program utilizes two restricted use pesticides. Although manufacturers and formulas vary, the City departments primarily use.pesticide products with the following major active ingredients and/or their derivatives.''-' Additional information can be found on MSDS sheets. General Use Pesticides 2,4-D-(2,4-Dichlorophenoxyacetic Acid)a systemic herbicide used to control many types of broadleaf weeds. 2,4-D is the active component of many commercial pesticides and has manv derivatives. Glyphosate-a non-selective herbicide found in many commercial pesticide products including Roundup and Rodeo. It is a general use pesticide and does not require a license to use or purchase. • Dicamba - used as a weed control herbicide. • Triclopyr-used for controlling broadleaf weeds and woody vegetation. Imazapyr—a non-selective herbicide used to control grasses and broadleaf plants. Persistent in soil, breaks down rapidly in water, uptake in plants through foliage and roots. Aminopyralid—an herbicide used to control thistle and other weeds. • Clopyralid—an herbicide with similar application as Aminopyralid. • Imazapic- a selective herbicide for control of annual and perennial grasses and some broadleaf weeds. Deltamethrin—an insecticide in dust form used to control fleas in prairie dog colonies during relocation projects(required by Colorado Division of Wildlife) and as a public health measure where public trails intersect prairie dog colonies with active plague outbreaks. When used as a public health measure, the Natural Areas program consults with the Larimer County Department of Health and Environment. General use pesticides are used by the Parks Division, Utilities, and Natural Areas in a variety of applications. All pesticides are widely used by the general public. Noxious weeds present perhaps the most significant ecological threat to Natural Areas system wide and must be properly controlled. Landowners, both public and private are mandated to control noxious weed species as defined by the State of Colorado Noxious Weed Law (Title 35 Article 5.5). Restricted Use Pesticides Picloram: Picloram is the active ingredient in the herbicide Tordon. In adherence with best management practices, Picloram is used periodically as one of a suite of chemicals utilized to control noxious weeds,among them Canada thistle.Although Picloram is widely seen as the most effective and cost efficient chemical for control of Canada thistle '-' This list is not intended to be exhaustive, rather to represent dte primary active ingredients used in City operations. Page 17 of 23 and other Noxious weeds, due to its high environmental risk (if used improperly), Picloram is not used routinely, nor annually on any given infestation.Staff has found use of Picloram eliminates repeat applications. Picloram is restricted due to its potential to contaminate groundwater, and its ability to damage non-target plants.'.'-s Aluminum Phosphide: Aluminum Phospide is the active ingredient in the pesticide Fumitoxin. Fumitoxin is a fumigant used by the City's Natural Areas Program to control and manage prairie dogs. Fumitoxin is restricted primarily due to the acute inhalation toxicity of hydrogen phosphide,9 City Natural Areas staff participates in a prairie dog management working group that includes other front range city, county and governmental agencies that manage prairie dogs. This group remains current on management techniques and the prairie dog's role in the ecological system. Other agencies participating in this group utilize Fumitoxin for prairie dog control and consider it to be the most effective, and cost efficient control tool. All applications by City staff of both general use and restricted use pesticides are done following label instructions carefully and precisely to ensure safe use. The assessments conducted by the EPA are used to develop acceptable use conditions and required personal protective equipment. Human risk is represented by risk labels (from least risk to greatest risk- Caution, Warning, Danger). Environmental risk is represented by an environmental hazards discussion on the label. The label is a legal document and therefore applications conducted outside the allowable conditions on the label are subject to legal action against the individual applicator(if the applicator is licensed by the Colorado Department of Agriculture), or against the Qualified Supervisor(if the applicator is not licensed and therefore under the guidance of the QS). Chemical Toxicity and Environmental Characteristics Chemical toxicity is measured in either lethal dose LD90(when ingested orally or dermally) or lethal concentration, LC%(when inhaled). Lethal dose/concentration describes the dose of a pesticide that will kill 1/2 of a group of test animals from a single dose. A pesticide with a lower LDso is more toxic than one with a higher number because it takes less of the pesticide to kill half of the test animals. Toxicity risk labels range from "Caution" to "Danger", with the restricted use pesticides having more acute toxicity. The following environmental characteristics for herbicides are cited from Latimer County's "Herbicide Reference Guide for Small Acreage Owners" and describes general information regarding transport through soil and water.'' Pesturde .gin '.`Enwrcmmental,Characte sh cs n„ 2,4-D Little to no soil activity, uptake in plants is through foliage.Do not apply to water. Glyphosate Active through foliar uptake, has no soil activity. Labeled for use up to water's edge. At least one formulation, Rodeo, labeled for use in and around water. Dicamba Water soluble, should not be applied near water.Active on target 21ants 'S US Department of Agriculture, US Forest Service,"Picloram: Herbicide Information Profile", httu://w%vw.fs.fed.us/1-6/ndtid/pubsu,eb/piclo.pdf;July 25,2000. 29 PestCon Systems,"Applicators Manual for Fumitoxin",w%vw.pestcon.cont,Accessed March 20,2008. '0 Larimer County,"Herbicide Reference Guide for Small Acreage Owners", http://www.co.laiimer.co.ushveeds/herbicide.litm,accessed March.20,2008. Page 18 of 23 -., - i ,a t _. Pe6tlCt T de ��'.,, Environmental#Charactenstres ..._ _ primarily through foliar uptake, with root uptake to a lesser degree. Do not apply near desirable trees and shrubs. Dicamba is a volatile product that can damage off-target vegetation through vapor drift.Do not use when temperatures are expected to exceed 85 degrees Fahrenheit within 24 hours of application. Triclopyr Some soil activity but is primarily taken up by plants through foliage and/or vascular tissue (cut-stump or basal bark treatment). Restrictions near water vary with formulation. Not for use on irrigation ditchbanks. Imazapyr Persistent in soil, breaks down rapidly in water, uptake in plants through foliage and roots. Restrictions with water vary with formulation. Not for use on irrigation ditchbanks. Aminopyralid Can be applied to water's edge. Active on target plants through foliar and root uptake. Not for use on irrigation ditchbanks. Clopyralid Water soluble, should not be applied near water. Active on target plants rimarily throu h foliar uptake, with root uptake to a lesser degree. Imazapic Has soil residual activity, uptake in plants through foliage and roots.This product has runoff potential and should not be used on hillsides sloping towards water. Do not apply to water, or inside irrigation ditches. Application timing, use rate and choice of surfactant can be critical, read the label carefully. Picloram Soluble in water and persistent in soil.Should not be applied on ditchbanks (Tordon) or bottoms, near water, or under desirable trees and shrubs. Residually active in the soil, and taken into a plant through foliar absorption and/or root uptake. Deltamethrin Dust formulated insecticide providing residual control in indoor and outdoor applications. Not to be used near water. Application for fleas in prairie dog colonies re uires treatment of 18" around burrow opening. Best Management Practices Product Selection and Application City staff responsible for product selection regularly assesses available products to ascertain the best product for use in specific situations.Products are evaluated in terms of environmental risk and product effectiveness. Product selection includes an understanding of how much chemical is required (use rate), how quickly the chemical breaks down (in soil and water), and selection of the appropriate chemical for the current plant growth stage. Further, it is a basic tenant of IPM to continually alter the mode of injury on target species, i.e. in any 5 year period it is important to treat a single infestation with chemicals that attack different areas within the plant, thereby alleviating the development of chemical resistance.Some examples of how this on-going assessment has changed practices in the Natural Areas program include: Using glyphosate(lower aquatic environmental risk—lower weed control effectiveness— lower product cost) on Russian olives rather than triclopyr(high aquatic environmental risk—higher weed control effectiveness—higher product cost). Minimizing use of 2,4-D, which is a widely used pesticide throughout vegetation management due to its allowable use near water, effectiveness on aquatic related noxious weeds(Canada thistle), and its low cost.Although 2,4-d is still used in some cases, Page 19 of 23 Natural Areas has also begun using product such as Habitat(Imazapyr). Although this product costs more, it is better suited for applications near water because it is applied at a lower per acre rate and is more effective on the target species. • Minimizing use of Tordon (Picloram), which is seen as the most effective chemical control of Canada thistle due to its multi-year residual effect.Although Picloram is still used, it is not used repeatedly on the same infestation as the need arises. Rather it is used in a rotation of alternative chemicals, i.e.—Representative Canada thistle infestation- Year 1 —apply Picloram,Year 2—No treatment(no above ground plant material), Year 3 —Mow the infestation, apply Aminopyralid, Year 4—apply Glyphosate as needed, Year 5 burn, seed competitive plants, Year 6-10—monitor and treat as needed. The following chart details herbicide use by the City Natural Areas and Parks Department(in gallons) r — =gin -Park' ,_.Year �_� �:Natural.eireasr � _ Parks ' 2004 289 112 2005 228 142 2006 218 96 2007 170 152 2008 224 309 In years 2004—2007 herbicide use decreased in Natural Areas due to an increase in the use of lower application rate(lower ounces per acre rate) chemicals not previously on the market and the success of an IPM approach that results in an overall reduction in the acreage of noxious weeds. In 2008 herbicide use increased due to both the cyclical nature of weed control, i.e. previously suppressed infestations expressed above ground growth, and the increased active management of Soapstone Prairie Natural Area. In 2008, 82 gallons of 2,4-D was applied by a contractor to target nuisance weeds in the City's parks system. Applicator Requirevients As a Public/Commercial Pesticide Applicator, the Natural Areas Program and the Parks Division are subject to periodic inspection by the Colorado Department of Agriculture.These inspections ensure that applicators are licensed, properly trained,required records are kept, and that storage and mixing facilities meet federal, state, and local standards. City departments applying pesticides employ the Integrated Pest Management approach, which is the vegetation management equivalent to Best Management Practices.This approach aims to minimize chemical use while maximizing chemical effectiveness by identifying target periods during plant growth during which the herbicide is most effective, and by continually altering the mode of chemical attack. Additionally, alternative methods of management are used to increase plant stress.These methods include prescribed fire, mowing, grazing, introducing predatory insects, and promoting the health of native plants to provide competition. Staff Training Employees are expected to stay well informed on best practices in their industry. In-house training provided includes Hazard Communication to all employees who work with fertilizers, pesticides, and other chemicals to ensure they are aware of the potential hazards those chemicals Page 20 of 23 may present. The importance of reading chemical labels, Material Safety Data Sheets(MSDSs), and following directions are emphasized. Good Housekeeping/Pollution Prevention training is provided to ensure chemicals and waste are properly managed so as to not enter and negatively impact local waterways. Employees maintain professional certifications and licenses as required and appropriate. Training, Licensing, and Continuing Education for pesticide application is administered and regulated by the Colorado Department of Agriculture.At least one staff member must be licensed as a Qualified Supervisor by the State. Anyone performing application of Restricted Use pesticides must be licensed (at least to the level of Certified Operator)or applications of Restricted Use pesticide may be applied by unlicensed "Technicians" (as described by CO Dept of Ag) under the on-site supervision of a Qualified Supervisor. Restricted Use pesticides are those that require the possession of a Pesticide Applicator's License to purchase and/or apply. Restricted Use pesticides typically are classified as such because they present an increased risk to the environment and therefore require,additional regulation. City staff is highly trained in the area of pesticide application. Currently, the Parks Division has 7 Qualified Supervisors and one Certified Operator. In the Natural Areas Program, all Classified Resource Management field personnel are required to hold Qualified Supervisors licenses. During the summer field season, Natural Areas hires an additional 10—14 seasonal employees, of which typically 80%will obtain Certified Operator licenses. All Natural Areas seasonal employees receive at least 40 hours of instruction related to pesticide handling, use, and storage. Additionally, two members of our staff are recognized as Certified Managers of Invasive Plants. The CMIP program is administered through the North American Weed Management Association. NAWMA is recognized as the association for invasive species management professionals.The CMIP program serves to identify those individuals who have demonstrated their practice of an integrated management approach to invasive species management. Storage and Disposal Chemicals used by the Parks Division are stored in a restricted,controlled access area. The area is well signed, does not have a drain, and is separately ventilated and temperature controlled. Chemicals used by the Natural Areas Program are housed at the Nix Maintenance Facility within a locked hazardous materials storage container.This container protects against temperatures outside the appropriate range for chemical stability and includes a basin containment floor to capture any potential chemical spill and its own fire suppression system. PEA is aware of the storage container location and contents and the correct hazards warning sign is clearly visible. After consultation with chemical manufacturers, the Colorado Department of Agriculture, and recycling vendors, the Natural Areas Program is recycling all 2.5 gallon herbicide containers. Supplemental Treatments to Reduce Chemical Use An Integrated Pest Management approach does not attempt to alleviate the use of chemicals. Rather, it is an approach that is geared towards the elimination of non-strategic chemical applications. In an 1PM approach, chemicals are strategically used as a well planned strike against species that will also suffer from additional stress introduced by the other methods. The City's Natural Areas program is in a unique position to utilize some of these alternatives to chemical use, while other City departments that maintain grounds in a more urban setting have to use more traditional approaches. Page 21 of 23 Prescribed Fire The Natural Areas Program employs prescribed fire in order to affect improvement of vegetation health and assist in the management of invasive weeds.We have found this tool to be cost effective and of the highest benefit to the vegetation community while providing the lowest level of environmental risk. Narrow windows of environmental conditions(dry vegetation, low to moderate winds, low fire danger,etc)and a lack of in-house fire resources prevent the Natural Areas Program from conducting more prescribed fires. Sheen Grazing Since 2006, the Natural Areas Program has cooperated with a local stock grower to utilize sheep to graze cheatgrass(Bromus Inermis)on five natural areas along the foothills.The program began with roughly 200 head of sheep and has now expanded to approximately 600 head.These bands of sheep are closely managed by an on-site shepherd who moves them to areas of cheatgrass infestation.An accurate estimate of acreage affected does not exist, but the shepherd is able to move these sheep through roughly 1500 acres.Currently, the Natural Areas program is limited in its application of sheep grazing on foothills properties by the presence of wild bighorn sheep populations as per requirement of the Colorado Division of Wildlife. Predatory Insect Release Between 1999 and 2004 the Natural Areas Program embarked on an aggressive effort to utilize biological species to manage leafy spurge, a Class B Noxious Weed on the State Noxious Weed List. Under the guidance of the US Department of Agriculture—Animal and Plant Health Inspection Service(APHIS) the Natural Areas Program made releases of insect that predate upon Leafy spurge. USDA—APHIS manages the development of biological control organisms to combat invasive species throughout the Unites States.This effort amounted to 64 beetle releases on 7 different natural areas. These releases saw variable rates of success and continue to serve as a source of leafy spurge eating beetles.The Natural Areas Program continually assesses infestation sites for possible beetle releases. Native Grass Seeding/Cover Crop Seeding As part of an Integrated Pest Management program (IPM) it is essential to provide competitive desirable plantings in order to mitigate the presence of weed species.To this end and to progress the enhancement of natural habitat mission of the program, the Natural Areas routinely invests in native grassland seeding projects.Although the timeframe of germination is highly dependant upon uncontrollable climatic factors, the program works diligently to facilitate successful restoration projects. In order to eliminate the risk associated with the highly specific germination requirements of native grass seed, cover crops (cultivar species of wheat, sorghum, etc)are often seeded to provide a dependable germinating source of competition against weed species. Alternative Non-Toxic Chemical Options Corn Gluten-Corn Gluten has received a great deal of attention lately as an all natural weed control.At this time corn gluten is not registered for rangeland use. Current pricing would be in neighborhood of$2,500+per acre. BurnOut II -BurnOut 11 is typical of products marketed as non-toxic and environmentally, friendly. This product is a mix of clove oil and citric acid.The mode of action is that the citric acid Page 22 of 23 burns the cell walls, thereby killing the plant.The application of these products requires large quantities of product for each application ("apply to runoff' vs. traditional application of dispersed droplets over the leaf surface.This dramatically increases the water requirement from approximately 10—13 gallons per acre to somewhere near the scale of 100+gallons per acre. Additionally, these products break down cell walls and therefore injure both forbs and grasses indiscriminately (non-selective). Conclusions and Recommendations The fertilizers and pesticides applied by the City of Fort Collins are carefully selected by staff based on the necessary application, the cost, and effectiveness of the product. Each product possesses varying degrees of health and environmental risks, which are managed through industry best practices and staff training. Employees are well-informed regarding the proper use and the hazards associated with each product. The general use pesticides used by the City are widely used and accepted by many agencies. The MSDSs for these products indicate they are in general of low toxicity and when managed properly will have minimal impact on the environment. The two restricted use pesticides used by Natural Areas are more acutely toxic, but have been carefully evaluated by staff and chosen based on appropriate criteria. City staff makes a concerted effort to explore and employ alternative pesticide control methods when appropriate for the application. This is an appropriate and thorough approach to fertilizer and pesticide management. As recommended above, the implementation of an Environmental Management System would provide a framework for systematically identifying environmental considerations with a focus on complying with legal requirements, pollution prevention, and continual improvement. Page 23 of 23 Review of Chemical Materials Employed in City Operations : Snow and Ice Control Products Pesticides Fertilizers Carol A . Webb, Regulatory and Government Affairs Manager F�t` Collins Direction Sought By City Council • What comments or concerns does Council have concerning snow/ice control products , fertilizers , and pesticides employed in City operations ? City of Fort Collins 1 Background • Chemical materials review conducted in early 2008 , updated in early 2009 — Snow/ Ice Control Products — Pesticides — Fertilizers — Chemical products used in largest quantities Fort Collins Background • Reviewed environmental impacts , performance , cost, and purchasing strategies for these chemicals . • Made comparisons to products used by other municipalities/jurisdictions in our general region . • Reviewed best management practices used by City staff in employment of these chemicals • Made recommendations based on industry and environmental best practices 1 `ityt of 2 Snow/Ice Control Products Product Evaluation Process • Performance • Cost • Environmental Impacts • Infrastructure Impacts _ Of FOI�'t�`S Snow/Ice Control Products • Chloride-based granular — Ice Buster - Complex salt pre-wetted with liquid deicer • Chloride-based liquid — Meltdown Apex • Organic polymer with corrosion inhibitor • 30 percent magnesium chloride solution • Acetate-based liquid — NC3000 • Potassium acetate , non-chloride product • Used to spot treat bridge decks CRYt Wins 3 Snow/Ice Control Products 2007 $ 2008 Cost/Ton Amount $ Amount or Used in 2007 Cost/Ton Used in 2008 Product Gallon 2007 Cost or Gallon 2008 Cost Ice Buster (ton) 44.30 31129 $138,615 48.70 1461 $71,150 Meltdown Apex (gallon) 0.62 463,116 $287,132 0.66 308,517 $204,527 NC3000 (gallon) 3.97 1340 $5,320 3.97 215 $854 °Collins Snow/Ice Control Products Regional Comparison Granular Sand or Sand/Salt Chlorides Liquid Chlorides Mixture Fort Collins X X Longmont X X Larimer County X X City of Boulder X X City of Loveland X X CDOT X X X City of Greeley X X X x Fort Collins 4 Snow/Ice Control Products Environmental Impacts • All products have potential environmental and/or infrastructure impacts • The magnitude of the effect depends on = ' — Types of materials — Best management practices , — transport pathways ` — Site-specific characteristics r � ,.,Forte`s Snow/Ice Control Products Environmental Impacts • Pathway — Material becomes airborne — Drains to surface water via roadside drainage or via soil — Splashes on roadside vegetation 1 `�t Collins 5 Snow/ Ice Control Products Air Quality Impacts • Sand — Fine particulates degrade air quality • Chloride - based solids & liquids — Little/no effect • Acetate - based deicers — Little/no effect Fort` Collins im Snow/ Ice Control Products Water Quality Impacts • Sand j — Increase in turbidity , sedimentation • Chloride- based solids & liquids c — Excessive chloride AA loading , nutrients , organic material , heavy metals • Acetate-based deicers — organic material , heavy metals City of Fort Collins 6 Snow/Ice Control Products Impacts to Vegetation • Chloride-based solids & liquids 4: — Sodium , potassium , magnesium , 4' i\I it chloride — foliar and root damage — Damage generally highest in areas • With chemical splash/spray or runoff • Containing salt-sensitive species r,►t +' • Greatest on actively growing plants (e .g . conifers) • Acetate-based deicers Little/no effect 1 ,,, t�h`s Snow/Ice Control Products Corrosion • Corrosion — Chloride-based deicers • corrosion to metals , concrete t 1 — PNS • Requires corrosion testing • 70% less corrosive to mild steel than NaC12 for approval — Corrosion inhibitors added to liquid deicers , � of Fort` inS 7 Snow/ Ice Control Products Corrosion Snow/Ice Control Products Corrosion Comparison t 00.0% 80.0% 0 60.0% Z 0 40.0% 0 U 0 20.0% 0.0% salt MgC12 Ice Buster Meltdown Apex NC3000 -20.0% Deicing Material Fort Collins Snow/Ice Control Products Best Management Practices • Documented by Streets Dept • Recommended by transportation professional organizations • Utilized by peers in the roadway management industry • Assist in managing environmental/infrastructure impacts Fort Collins ANELL Snow/ Ice Control Products Best Management Practices • Employee Training — 16 hours mandatory training — " Dry- run " demos — Novice drivers paired with experienced drivers during first storm event . — More comprehensive training program under development . F�t` Collins Snow/ Ice Control Products Best Management Practices • Snow/Ice Control Product Storage — Solid materials handling • received via rail car • Documented loading/unloading procedures to minimize spillage • Awarded the Salt Institute 's 2008 Excellence in Storage Award — Liquid materials • Above ground storage with secondary containment — Stormwater Runoff Control Plan City of Fort Collins 9 Snow/Ice Control Products Best Management Practices • Purchasing Specifications — Qualified Products List (QPL ) • Specifications for contaminants • Lab analyses � , rt��s Snow/Ice Control Products Best Management Practices • Product Application Methods — Equipment inspections — Plowing — Automated deicer application — Snow plow trucks equipped with calibration devices `fty of tins 10 Snow/ Ice Control Products Best Management Practices • Road and Weather Conditions Evaluation — Six Road and Weather Stations — Monitor roadway temperature , precipitation , wind speed , and other weather conditions — Ensure right deicing strategy F�t` Collins Snow/ Ice Control Products Best Management Practices • Post-Application Procedures — Equipment cleaning and inspection — After Action Review City of Fort Collins 11 Snow/Ice Control Products Conclusions • Conclusions — FC products same/similar as other agencies — Management of impacts via BMPs — Research/test new products f Wins 10 Snow/Ice Control Products Best Management Practices • Application Strategies — "The right application at. the right time with the right chemical . " — Pre-wetting — Analysis of available information CRY ollins 12 Snow/ Ice Control Products Recommendations • Anti - icing program • Water quality monitoring program • Environmental Management System • Comprehensive snow storage facility siting evaluation F�t` Collins Fertilizers • Natural Areas Program — Restoration Projects • The Parks Division — Approx . 800 acres of irrigated turf • Utilities — Facilities grounds maintenance Fortes 13 Fertilizers • Selection — Specific needs of plants and vegetation — Soil analysis • Application — Combination of granular applications and spray nutrient applications without over application — Follow manufacturer directions F�t` Collins ftwL� Pesticides • General use pesticides — Parks , Utilities , and Natural Areas — Used widely by the general public — No special licenses or training required — Natural Areas • Mandated to control noxious weed species City of Fort Collins 14 General Use Pesticides Active Ingredient Use 294-D systemic herbicide - broadleaf weed control Glyphosate non-selective herbicide - Roundup and Rodeo Dicamba weed control herbicide Triclopyr broadleaf weeds and woody vegetation Imazapyr non-selective herbicide - grasses and broadleaf plants Aminopyralid herbicide - thistle and other weeds Clopyralid herbicide — thistle and other weeds Imazapic selective herbicide - grasses and broadleaf weeds Deltamethrin insecticide - control fleas in prairie dog colonies rt�h`s Pesticides • General Use pesticides — Most restricted around water — Active primarily via foliar uptake — Follow manufacturer's application instructions Fort Collins 15 Pesticides • Restricted Use Pesticides — Natural Areas Program - utilizes two restricted use pesticides . — Restricted due to safety concerns — Potential environmental impacts — Toxicity to humans — Non -target plants or animals — Application method (e . g . fumigants ) . — Require special licensing , training Fort Collins Pesticides • Restricted Use Pesticides — Picloram - the active ingredient in the herbicide Tordon . • Noxious weed , Canada thistle control . • Potential to contaminate groundwater, damage non- target plants — Aluminum Phosphide - active ingredient in the pesticide Fumitoxin . • Control and management of prairie dogs • Acute inhalation toxicity of hydrogen phosphide `ty of 16 Herbicide Application ( gallons ) Year Natural Areas Parks 2004 289 112 2005 228 142 2006 218 96 2007 170 152 2008 224 309 F� Collins Pesticides Best Management Practices • The Integrated Pest Management Approach — Managing pests by the most economic means , with the least hazard to people , property , and the environment . — Minimize chemical use , maximize effectiveness City of Fort Collins 17 Pesticides Best Management Practices • Product Selection and Application — Regularly assesses available products — Evaluated in terms of environmental risk and product effectiveness . • Use Rate • Chemical break down • Appropriate chemical for the current plant growth stage . — Alteration of mode of injury F�t` Collins Pesticides Best Management Practices • Applicator Requirements — Public/Commercial Pesticide Applicator • Subject to periodic inspection by the Colorado Department of Agriculture . • Not required for general use application City of Fort�iins 18 Pesticides Best Management Practices • Employee Training — In-house training — Professional certifications and licenses • Parks Division — 7 Qualified Supervisors — One Certified Operator • Natural Areas — All Classified Resource Management field personnel Qualified Supervisors — Majority of seasonal employees obtain Certified Operator licenses . — All seasonal employees - 40 hours of pesticide use instruction — Two Certified Managers of Invasive Plants . City of Fort Collins Pesticides Best Management Practices • Supplemental Treatments — Natural Areas Program • Prescribed Fire • Sheep Grazing • Predatory Insect Release • Native Grass Seeding / Cover Crop Seeding • Alternative Non -Toxic Chemical Options City of Fort Collins 19 Pesticides & Fertilizers Conclusions & Recommendations • Managed risk via best practices and staff training • Product selection criteria - Application , cost , effectiveness • General use pesticides widely used • Restricted use pesticides carefully evaluated by staff and chosen based on appropriate criteria . • Implementation of an environmental management system is recommended . City f Collins For 20