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: 202.564.2952
Page.Jordan@epa.gov