FW: a few more questions

Jennings, Jonathan (ECY) to: Jordan Page 07/15/2009 12:27 PM

History: This message has been forwarded.

Jordan,

Kathy Hamel forwarded me some questions you had about Washington's

aquatic pesticide permits. Kathy has the historical knowledge about

these permits so I've answered your questions about the mosquito and

invasive moth permits. Please let me know if you have further

questions.

2. 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?

Answer:

Annual reporting of application quantities is required for restricted

use larvicides the same as non-restricted larvicides.

Monitoring for adulticides is an issue that we are still discussing. We

would prefer to have any monitoring be meaningful and answer questions

we have about adulticide use and its fate in the environment. One

current idea is phased monitoring. This would mean that applicators

would monitor for the presence of adulticides (or a surrogate) before

and after an application. This monitoring would occur in each area that

has adulticides applied. Based on the monitoring, if no pesticides or

residues are detected, monitoring could then be phased out.

3.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?

Answer:

Annual reporting is very similar to the mosquito larvicide permit.

Total amount of acres sprayed, and volume of pesticide and adjuvant

applied are required to be reported each year that treatment occurs.

Pesticides applications under the coverage of the invasive moth permit

have not happened for a couple years, but the permit is still active in

case WSDA needs to do moth control.

On years where spraying for invasive moths occur, only one grab sample

is necessary for that season. This sample is taken from a single area

(where spraying occurred over water) before and immediately after the

treatment occurs and must be analyze for concentrations of active

ingredient - in this case, Btk residuals.

Jon Jennings

Water Quality Program
Washington Department of Ecology

Phone: 360.407.6283

Fax: 360.407.6426

Email: joje461@ecy.wa.gov

-----Original Message-----

From: Hamel, Kathy (ECY) 

Sent: Monday, July 13, 2009 11:42 AM

To: Page.Jordan@epamail.epa.gov

Cc: Jennings, Jonathan (ECY)

Subject: RE: a few more questions

Hi Jordan, I am just about to leave for a meeting out of town. I'll see

if I can get somebody to answer your mosquito questions and I'll work on

the other answers when I am back in the office Wed. or Thur. 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