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 (just 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, NW

Washington DC 20460

Phone: 202.564.2952

Page.Jordan@epa.gov