### Re: Working Draft EPA's NPDES Pesticides General Permit Jeff DeBessonet to: Jack Faulk 01/25/2010 01:45 PM Cc: "Crystal Rippy"

Jack, from SC's NPDES program, here are a few comments: 1. page 1: Section 1.1.2.1, if the water is impaired, is the implication "no application" or an individual permit? 2. page 4: Section 1.2.2, can a contract operator file an NOI? In one of EPA's power point presentations earlier, it says: "The NOI filer, in most cases, would be the organization responsible for deciding to conduct the pesticide applications, as opposed to the person performing the applications." We would prefer to have the NOI from the organization "responsible" and not a contractor. 3. page 15: Section 3.0, It says "EPA may impose additional water quality-based limitations or ...", in what way would that be done (e.g., NOI coverage letter?). 4. page 21: Section 6.2, after a description of "as soon as practicable" the text states: "The schedule is included in this permit". Did I miss a schedule in the permit? 5. After this permit would expire, can a new NOI be filed (before the time when the new permit were to be reissued)? (i.e., can new coverage be granted while the permit is expired?) 6. page 1: Typo? Under section 1.1.1, first paragraph, should the word "residue" be added to the text reads: "chemical pesticides which leave a RESIDUE for the following pesticide use patterns"? 7. page 1: Awkward? Under section 1.1.2.1, seems like you could end the sentence after the word "degradates" (assuming degradates is a word. 8. If EPA wanted to write a permit to cover SC, that would be OK (just like vessels). :-)

Thanks. Jeff deBessonet, Director Water Facilities Permitting Division SC Dept. of Health and Env. Control >>> <Faulk.Jack@epamail.epa.gov> 1/13/2010 6:48 PM >>> All, Attached is a copy of EPA's current working draft NPDES Pesticides General Permit (PGP) for your review and comment. First, we ask that you not share this draft, either electronically or in paper form, with others. This permit, by nature of the discharge, is not a typical NPDES permit and, as you know, we are working through some challenging issues. Until we feel comfortable with our approach, we'd prefer not to have to discuss the details of our working drafts with entities outside of our co-regulator family. We hope to receive that input from you directly!We will be public noticing the draft permit around the end of April 2010 at which point anybody and everybody, including states, will have an opportunity to review and comment on that version of the permit. We do not have a copy of the permit fact sheet to share with you. The permit writing has been quite a dynamic process and trying to keep up with a fact sheet has not been so successful. We hope, although cannot guarantee, to be able to share a copy of a draft fact sheet with you at some point before issuance of the permit. Thanks for your understanding. Tomorrow, January 14, from 1-3 pm eastern time, we will be discussing this permit on a free webcast, to prepare folks for reviewing the permit and for participating in our two-day face-to-face meeting in Dallas On January 20-21. If you have not yet done so, you can register to participate in the webcast (must be done in advance) at http://event.on24.com/r.htm?e=183080&s=1&k= 17604CA8BF94523AA10DE0009E2B2EFF . You can register for the meeting in Dallas at http://www.tetratech-ffx.com/npdes_pesticides/. We would like your comments on this working draft but ask that you submit those comments electronically no later than close of business Monday, January 25, 2010. Please send those comments to me at faulk.jack@epa.gov. We plan to read and consider all comments we receive from you by that time. We will also be documenting the discussion in Dallas and considering those comments as well. One additional item to consider. This permit includes several comments asking for your specific input on certain permit language. If you have limited time for which to review the permit, we would ask that you at least take a look at those few comments and provide your thoughts on those. Thanks for your patience and understanding and enjoy your reading.

(See attached file: PGP working draft 011310 pm.doc)

Jack

Water Permits Division US Environmental Protection Agency EPA East (4203M) 1200 Pennsylvania Avenue, NW Washington, DC 20460 Telephone (202) 564-0768 Fax (202) 564-6431