### 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 ProgramWashington Department of Ecolog y 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 becomingeffective for the permittee? A re 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