### RE: a few more questions Kolosseus, Andrew (ECY) t o : Jordan Page 07/16/2009 02:16 PM

Cc: "Jennings, Jonathan (ECY)", "Weaver, Duane (ECY)", "Rockett, Derek (ECY)", "Hamel, Kathy (ECY)" History: This message has been replied to.

Jordan -- I manage Washington's general permit for aquatic pesticide use in irrigation canals. The permit is available at http://www.ecy.wa.gov/programs/wq/pesticides/irrigation/irrigation_index .html. Yes, monitoring data for this permit has shown noncompliance. The issues of noncompliance have been addressed using everything from informal technical assistance to formal enforcement actions and monetary fines. While the fines have been low, from a few hundred to a couple thousand dollars, they have been very effective at gaining compliance. This permit also has an IVMP (integrated vegetation management plan) requirement. On the whole the IVMP is not a huge factor; it does require the permittee to think through every step and decision which is helpful. Ecology does need to approve the IVMP and they are publicly disclosable, but Ecology does not post them to our website. Technically I guess Ecology would need to approve the plan before a new permittee would be in compliance with the permit, but that issue hasn't come up. Let me know if you have any questions.

Andrew Kolosseus Washington State Dept. of Ecology Water Quality Program PO Box 47600 Olympia, WA 98504-7600 (360) 407-7543 -----Original Message----- From: Hamel, Kathy (ECY) Sent: Thursday, July 16, 2009 11:01 AM To: Kolosseus, Andrew (ECY); Rockett, Derek (ECY) Cc: Jennings, Jonathan (ECY); Page.Jordan@epamail.epa.gov; Weaver, Duane (ECY) Subject: FW: a few more questions Hi Andrew and Derek, I got this information request from EPA (see below). I was able to answer most of the questions and Jon is addressing mosquito permit questions. However there was one question that I couldn't answer for the permits that you manage. Could you either respond to Jordan directly or I could forward your response to him. His question is below. If you have anything else to add to his other questions, I am sure that he would appreciate that too. Jordan's question - Up to this point, have the results of any monitoring exercise indicated an instance of noncompliance, triggered a need for permit modification, or been a flag for any other type of problem?Thanks, Kathy -----Original Message----- From: Page.Jordan@epamail.epa.gov [mailto:Page.Jordan@epamail.epa.gov] Sent: Monday, July 13, 2009 11:35 AM To: Hamel, Kathy (ECY) Subject: a few more questions Kathy, Thank you for all of the very helpful information you have provided thus far. I have a few more questions concerning Washington's monitoring scheme... In your previous email, you mentioned that you had enough information to remove monitoring requirements for shoreline/streamside spraying of glyphosate, triclopyr, and imazapyr. Are there any more agents or use patterns for which Ecology has determined that no further monitoring in necessary? Was it determined that these scenarios resulted in negligible environmental impact? In the mosquito larvicide permit, I notice that the monitoring requirement directs the permittee only to report larvicide application quantities. Is this the requirement for the restricted use chemical larvicides as well (which I understand may only be used under special conditions in WA)? Has there been any discussion on what monitoring would be required for an adulticide permit? I am unclear on the monitoring requirement for moth control. Does this permit require water samples to be analyzed for residuals of Btk or are the requirements more similar to those found in the mosquito larvicides permit? Why did Ecology revoke the Nuisance Plant and Algae Permit, and what will its replacement entail? Who in Washington is required to submit an NOI for coverage under a general permit and under what circumstances? Up to this point, have the results of any monitoring exercise indicated an instance of noncompliance, triggered a need for permit modification, or been a flag for any other type of problem? For those permits that require the submission of an IPM plan or any variant, muts Ecology review these plans prior to coverage becoming effective for the permittee? Are the plans made available to the public?

Thanks again for your all your help.

Jordan Page, ORISE Fellow Office of Wastewater Management, Permits Division U.S. Environmental Protection Agency 1200 Pennsylvania Ave, NW Washington DC 20460 Phone: 202.564.2952Page.Jordan@epa.gov