### Fw: Washington Aquatic Pesticides Permit Monitoring Requirements Dirk Helder to: Jordan Page 07/09/2009 06:00 PM

Jordan, I am glad you have received most of the information from Kathy Hamel at WA Dept. of Ecology, she and others at WA have been very helpful. In addition, Kathy is pulling together some additional water monitoring information they have for irrigation systems and the piscicide rotenone. I'll have her submit that data to both of us when she has that available. Regards, Dirk Helder Office of Pesticide Programs U.S. Environmental Protection Agency (208) 378-5749 helder.dirk@epa.gov ----- Forwarded by Dirk Helder/R10/USEPA/US on 07/09/2009 03:51 PM -----

From: "Hamel, Kathy (ECY)" <kham461@ECY.WA.GOV> To: Dirk Helder/R10/USEPA/US@EPA Date: 07/09/2009 02:42 PM Subject: FW: Washington Aquatic Pesticides Permit Monitoring Requirements

From: Hamel, Kathy (ECY) Sent: Wednesday, July 08, 2009 3:59 PM To: Page.Jordan@epamail.epa.gov Subject: RE: Washington Aquatic Pesticides Permit Monitoring Requirements

Hi Jordan, We have a lot of the monitoring data from the noxious weed permit and the aquatic plant and algae permit on our website at http :// www

. ecy

. wa

. gov / programs / wq / pesticides / final

_ pesticide

_ permits / noxious / monitoring

_ data / monitori ng

_ index

. html I am behind on posting so there is still some data not on-line. Also posted here: http :// www

. ecy

. wa

. gov / programs / wq / pesticides / final

_ pesticide

_ permits / noxious / noxious

_ index

. html



### We don't have any monitoring data from the irrigation permit, rotenone permit, or burrowing shrimp posted on-line, but dischargers under these permits do quite extensive monitoring. The permit managers for these permits have this information and could provide it to you on request.

When the first NPDES permits for aquatic pesticides were written, the permit writer set us some monitoring goals such as persistence of the herbicide residue after treatment, off target movement, and efficacy of treatment. The understanding to our permit holders was that as we got in data and it answered our questions, we would not necessarily make them monitor after each treatment.

The noxious weed permit is issued to Agriculture and they develop a monitoring plan each year. It is in that plan that we determine what the monitoring should be for the next treatment season. We feel we have enough data now to not require more information

### from shoreline or streamside spraying using glyphosate, triclopyr, or imazapyr. We are now asking Agriculture to do some sediment studies on long-term persistence of glyphosate and imazapyr in spartina beds. Also in this last permit we required them to do a risk assessment for imazpyr treatment of ditch bank plants ( j ust submitted to Ecology this week).

For the aquatic plant and algae permit (in-lake weeds), we require anybody who has a grant from Ecology and sprays to monitor. This is a subset of the issued coverage's. We did this because we have a state law that says that we are not to overburden noxious weed efforts and about half of the coverage's are for noxious weeds. This way our grant pays 75 percent of the monitoring costs for selected projects. We write in the monitoring requirements into each grant scope of work. If they treat for multiple years and if we think we have enough data, we relieve them of further monitoring. We try and make monitoring meaningful and not just a rote exercise that we put people through. I try and post all the lakes and shoreline monitoring on-line where it can be useful to others. Nobody has ever objected to this level of monitoring and most have found it useful. Yes, I think that this monitoring is very useful to Ecology, other agencies, and to lake residents, weed boards, local governments. Here are some reasons: 1. Because people seem to only want to trust data from their own state or from water bodies that are just like the ones that they live on. It makes the agency seem more credible if you can show them results from their lake or the lake next door. 2. It keeps the applicators honest (not that I am saying that they are not), but I think that it is good for the applicators to know that somebody will be sampling for herbicide residues. 3. It helps us fine tune application rates to achieve contact time versus concentration. It helps explain treatment failures too. I just got in some information from a lake where we are using triclopyr to eradicate variable-leaf milfoil (Class A weed). The residue showed that we achieved a high enough rate for a long enough contact time to get a good kill. The lake has some flow through issues. 4. We had a woman at another lake claim that triclopyr damaged her eyes. Because the lake manager had herbicide residue data, they were able to demonstrate that her eye problem was not related to the chemical treatment (no measurable chemical in the area where she had been swimming). This saved the project proponent paying out her medical bills and possibly averted a lawsuit. 5. We have lakes where people drink the water. It is important to monitor before water intakes are turned back on.

I feel very strongly that agencies should not make people monitor just for the sake of monitoring under these pesticide permits. Monitoring should be for a purpose and agencies should use the information, not stick it in a file. Pesticide discharges into water are not like a sewage treatment plant discharge where the discharge is variable. The applicators measure out the chemicals to achieve a specific concentration.

I am very comfortable with the level of monitoring that we require. It is not burdensome and over the seven years that these permits have been operating, we have gotten a lot of great information. We are currently collaborating with the University of Washington on a publication about impacts of herbicides on salmon and are using the data from the NPDES monitoring to demonstrate actual lake concentrations after typical herbicide

### treatment.

Let me know if you would like more information. I'll be in the office tomorrow if you want to call prior to the phone call.

Kathy

From: Page.Jordan@epamail.epa.gov [ mailto:Page.Jordan@epamail.epa.gov] Sent: Wed 7 / 8

/

2009 2:38 PM To: Hamel, Kathy (ECY) Subject: Washington Aquatic Pesticides Permit Monitoring Requirements

Kathy,

Would you be able to answer some questions about the water monitoring requirements that are found some WA aq pesticides discharge permits? We understand that many of these requirements have since been removed, and we would like to know the circumstances behind the decision to strike them. What was done with the original monitoring reports? Did DEC find the information useful? If you will be participating in tomorrow's call in, this will very likely come up for discussion.

Thank you!

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