EPA Deliberative Draft - Do Not Distribute, Copy, or Cite (BAT Workgroup)

Created on November 23, 2009 1 

## BAT WORKGROUP EDITS AS OF November 20, 2009

2.0.Technology-Based Effluent Limitations: Minimize Pesticide Discharges into Waters of the United States.

You must implement control measures to minimize the discharge of pesticides to waters of the United States. The term “minimize” means to reduce and/or eliminate pesticide discharges to waters of the United States to the extent achievable using control measures consistent with best management practices that are technologically available and economically practicable and achievable. To minimize th e discharge of pesticides into waters of the United States, all permittees must do the following:

1. Use the effective amount of pesticide pr oduct per application and lowest number of application per season necessary to control the target pest.

2. Perform regular maintenance activities to minimize potential for leaks, spills, and unintended/accidental release of pesticides fr om both pesticide containers and application equipment to waters of the United States.

3. Calibrate and maintain equipment to ensu re effective pesticide application and pest control. [Maintain equipment in peak operating condition by calibrating and cleaning/repairing on a regular basis.]

2.1.Technology-Based Effluent Limitations: Integrated Pest Management Practices.

[General Comment: Since we have lumped the uses together, we need to more explicitly explain who is covered. Consider adding a little more language in the permit and then even more in the fact sheet. I defer to OECA on how much they need to make the permit enforceable.] [For every subsection describing “P est Management”, a traditional IPM format is laid out. This is unnecessary, since all you would need to do is refer the permitee to Section 6, where the IPM strategy is described. Why duplicate it so many times – traditional IPM strategies follow the same format for any pest control operation.]

All permittees must evaluate, select, and implement control measures. Control measures are the specific actions taken to comply with the technology-based effluent limits. The evaluation, selection, and implementation of these control measures must be in accordance with the best management practi ces. Note that you may deviate from best management practices if the best management practices are not technologically available or economically practicable. If you are required to draft and maintain an IPM plan and you deviate from best manageme nt practices stated in th at plan, you must provide justification for such deviation in your plan. [See Part 6 [IPM Plan]]. If you or EPA finds that your control measures are not minimizing pollutant discharges, you must modify these control measures as expeditiously as practicable. See Part 5, Corrective Action. In addition to the technology-based effluent limitations contained in Part 2, there are Comment [mlk1]: Note: if they don’t provide a justification it is only a record keeping violation not an effluent violation.EPA Deliberative Draft - Do Not Distribute, Copy, or Cite (BAT Workgroup)

Created on November 23, 2009 2 documentation and recordkeeping permit c onditions in Parts 6 [IPM Plan] and 10 [Recordkeeping].

2.1.1.Mosquito Control (Larvicides and Adulticides) and Aquatic Nuisance Insect Control 2.1.1.1.Identify the Problem . The following permit conditions apply to you if

you are a Public Entity, Quasi-Public Entity, or a For-Hired [ForHire] Applicator. Prior to the first pesticide application covered under this permit and prior to the first pesticide application, at a minimum, each year you must do the following for each treatment area: 2.1.1.1.1.: Establish targeted densities for larval and adult mosquito or aquatic nuisance insect populations which serve as action threshold [s] for implementing pest management strategies. 2.1.1.1.2. Identify mosquito or aquatic nuis ance insect species in order to develop a best control strategy based on developmental and behavioral considerations for each species. 2.1.1.1.3. Identify known and potential breeding sites for source reduction, larval control program, and habitat management. 2.1.1.1.4. Analyze existing surveillance data to identify new/unidentified sources of mosquito or aquatic nuisance insect production as well as sites that have recurring pest problems.

In the event site data are not availabl e to identify the pest problem at your treatment area, you must document why it is not available and the assumptions you used to develop your management strategies and action threshold for the treatment area. (See Part 6, IPM Plan)

2.1.1.2.Pest Management . The following permit conditions apply to you if you

are a Public Entity, Quasi-Public Entity, or a For-Hired [Hire] Applicator. Prior to the first application covered under this permit and prior to the first application, at a minimum, each year you must select and implement for each treatment area the most efficient and effectivemeans of pest management options, including pesticides and nonpesticide methods. In developing your pest management strategies, you must evaluate the following management options considering human health and ecological impact, pest resistance, feasibility, and cost effectiveness:

• No action.

• Prevention [NOTE: includes source reduction ]

• Mechanical/physical methods.

• Cultural methods.

• Biological control agents.

• Pesticides. [Replace the above section by re ferring the permitee to Section 6.]EPA Deliberative Draft - Do Not Distribute, Copy, or Cite (BAT Workgroup)

Created on November 23, 2009 3 2.1.1.3.Pesticide Use The following permit conditions apply to you if you are a Public Entity, Quasi-Public Entity, or a For-Hired [Hire] Applicator. If pesticide is selected for managing mosquitoes or aquatic nuisance insects and pesticide will be discharg ed on or over, including near water of the United States, you must: 2.1.1.3.1. Conduct larval and/or adult surveillance using best management practices prior to each pesticide application toassess the treatment area and to determine when preestablished conditions (pest action threshold) are met which necessitate the need for pest management. 2.1.1.3.2. Assess environmental conditions prior to each pesticide application (e.g. temperature, pr ecipitation, and wind speed in the treatment area from a weather station(s) as close to the treatment area(s) as possible to identify conditions which support development of pest populations and are suitable for control activities. 2.1.1.3.3. Minimize the impact on the environment and non-target organisms by applying larvicides and adulticides for pest control only when the action thresholds have been met or disease is present. 2.1.1.3.4. Use larvicides as the primary pesticide for mosquito or aquatic nuisance insect control. 2.1.1.3.5. Use adulticides only where the adult action threshold has been met and/or under emergency condition (e.g. flooding, disease outbreak). 2.1.1.3.6. Do not apply adulticides over waters of the United States, except when necessary to target areas where adult mosquitoes or insect pests are present, and when weather conditions will facilitate movement of pesticide product away from the water to minimize incidental deposition into the water body. [NOTE: Fact sheet [s] could include a discussion of unavoidable as incidental deposition.]

2.1.2.Aquatic Weed Control in Lakes, Po nds, Rivers, Streams, Irrigation Canals and Drainage Systems

2.1.2.1.Identify the Problem. The following permit conditions apply to you if

you are a Public Entity, Quasi-Public Entity, Commercial, Regional Association, Farmer, or a For-Hired [Hire] Applicator. Prior to the first application covered under this permit and prior to the first application, at a minimum, each year you must do the following for each

treatment area: 2.1.2.1.1. Identify problem weed areas and application areas, including water use goals not attained (e.g. wildlife habitat, fisheries, vegetation, and recreation); [is this another way of saying why the application is needed?]EPA Deliberative Draft - Do Not Distribute, Copy, or Cite (BAT Workgroup)

Created on November 23, 2009 4 2.1.2.1.2. Identity targeted weed species; 2.1.2.1.3. Identify possible sources of the problem (e.g., nutrients, invasive species, etc); and 2.1.2.1.4. Establish past or present pest weed densities which serve as action threshold for implementing pest management strategies.

In the event site data are not availabl e to identify the pest problem at your treatment area, you must document why it is not available and the assumptions you used to develop your management strategies and action threshold for the treatment area. (See Part 6, IPM Plan) [If an applicator can’t identify the pest problem at the treatment area, it seems logical that they wouldn’t know the water body needed treatment in the first place.]

2.1.2.2.Pest Management. The following permit conditions apply to you if you

are a Public Entity, Quasi-Public Entity, Commercial, Regional Association, Farmer, or a For-Hired [Hire] Applicator. Prior to the first pesticide application covered under this permit and prior to the first pesticide application, at a minimum, each year you must select and implement for each treatment area the most efficient and effective means of pest management options, including pesticides and non-pesticide methods. In developing your pest management strategies, you must evaluate the following management options considering human health and ecological impact, pest resistance, feasibility, and cost effectiveness:

• No action.

• Prevention

• Mechanical/physical methods.

• Cultural methods.

• Biological control agents.

• Pesticides. [Replace the above section by re ferring the permitee to Section 6.]

2.1.2.3.Pesticide Use. The following permit conditions apply to you if you are

a Public Entity, Quasi-Public Entity, Commercial, Regional Association, Farmer, or a For- Hired[Hire] Applicator. If pesticide is selected for managing weeds in lakes, ponds, rivers, streams, irrigation canals or drainage systems and pesticide will be discharged on or over, including near water of the United States, you must: [Isn’t it redundant to say “If pesticide is selected ...and pesticide will be discharged”? If a pesticide is selected to apply to an aquatic sight, that seems to clearly demonstrate the applicator and/or permit holder has decided to discharge on/over/near water.] 2.1.2.3.1. Conduct surveillance using best management practices prior to each pesticide application to assess the treatment area and to determine when pre-established conditions (pest action threshold) are met which necessitate the need for pest management;EPA Deliberative Draft - Do Not Distribute, Copy, or Cite (BAT Workgroup)

Created on November 23, 2009 5 2.1.2.3.2. Conduct surveillance using best management practices after each pesticide application to determine effectiveness of the

treatment. 2.1.2.3.3. Minimize the impact on the environment and non-target organisms by minimizing the use of pesticides for aquatic weed control when the action thresholds (see Part 2.1.2.1.2) have been met. 2.1.2.3.4. For managing weeds in rivers, streams, or irrigation canals, do not apply herbicides over waters of the United States, except when necessary to target areas where weeds are present, and when weather conditions will facilitate movement of pesticide product away from the water to minimize incidental deposition into the water body. [This statement will confuse many pesticide applicators, since by definition, application of herbicides to aquatic sites “facilitates movement” into the water body. The way it is worded, it sounds like a) don’t treat the water except b) you need to treat the water but c) don’t let the treatment get in the water.”]

2.1.3.Area Wide [Wide Area?] Pest Control (Insect, Weed, and Pathogen) and Forestry

2.1.3.1.Identify the Problem . The following permit conditions apply to you if

you are a Public Entity, Quasi-Publ ic Entity, or a For-Hired [Hire] Applicator. Prior to the first application covered under this permit and prior to the first application, at a minimum, each year you must do the following for each treatment area: 2.1.3.1.1. Establish target pest densities which serve as action threshold for implementing pest management strategies. 2.1.3.1.2. Identify target species in order to develop a best control strategy based on developmental and behavioral considerations for each species. 2.1.3.1.3. Identify current distribution of the target pest and assess potential distribution in absence of control measures.

In the event site data are not availabl e to identify the pest problem at your treatment area, you must document why it is not available and the assumptions you used to develop your management strategies and action threshold for the treatment area. (See Part 6, IPM Plan) [Same comment as before for this statement: How does an applicator even know they have a problem if they don’t have data available to identify the problem?]

2.1.3.2.Pest Management. The following permit conditions apply to you if you

are a Public Entity, Quasi-Public Entity, or a For-Hired [Hire] Applicator. Prior to the first pesticide application covered under this permit and prior to the first pesticide application, at a minimum, eachEPA Deliberative Draft - Do Not Distribute, Copy, or Cite (BAT Workgroup)

Created on November 23, 2009 6 year you must select and implement for each treatment area the most efficient and effective means of pest management options, including pesticides and non-pesticide met hods. In developing your pest management strategies, you must evaluate the following management options considering human health and ecological impact, pest resistance, feasibility, and cost effectiveness:

• No action.

• Prevention

• Mechanical/physical methods.

• Cultural methods.

• Biological control agents.

• Pesticides. [Replace the above section by referring the permitee to Section 6.]

2.1.3.3.Pesticide Use. The following permit conditions apply to you if you are a Public Entity, Quasi-Public Entity, or a For-Hired [Hire] Applicator. If P [p] esticide is selected to manage area wide [wide area] pests and pesticide will be discharged on or ove r, including near waters of the United States, you must: [Same comment as before, if an applicator has elected to use a pesticide, they are obviously going to apply pesticide to/over/near water.] 2.1.3.3.1. Conduct surveillance using best management practices prior to each application to assess the treatment area and to determine when pre-established conditions (pest action threshold) are met which necessitate the need for pest management. 2.1.3.3.2. Conduct surveillance using best management practices after each pesticide application to determine effectiveness of the

treatment. 2.1.3.3.3. Assess environmental conditions (e.g. temperature, precipitation, and wind speed) in the treatment area from a weather station(s) as close to the treatment area(s) as possible to identify conditions which support target pest development and are conducive for treatment activities. 2.1.3.3.4. Minimize the impact on the environment and non-target organisms by minimizing the use of pesticides when the action thresholds have been met. 2.1.3.3.5. Use pesticides against the most susceptible developmental stage. 2.1.3.3.6. Use pesticides only where the action threshold has been met and/or under emergency condition (e.g. invasive species). 2.1.3.3.7. Do not apply pesticide over waters of the United States, except when necessary to target areas where target pests are present, and when weather conditions will facilitate movement of pesticide product away from the water to minimize incidental deposition into the water body. [Same comment as before.EPA Deliberative Draft - Do Not Distribute, Copy, or Cite (BAT Workgroup)

Created on November 23, 2009 7 Maybe it would be more understandable if the term “incidental” was replaced with “excessive”.]

2.1.4.Aquatic Nuisance Animals Control in Lakes, Ponds, Rivers, and Streams (Fish, Lamprey, and Mollusk)

2.1.4.1.Identify the Problem. The following permit conditions apply to you if

you are a Public Entity, Quasi-Publ ic Entity, or a For-Hired [Hire] Applicator. Prior to the first application covered under this permit and prior to the first application, at a minimum, each year you must do the following for each treatment area: 2.1.4.1.1. Identify problem aquatic nuisanc e animal areas and application areas, including water use goals not attained (e.g. wildlife h a bitat, fisheries, vegetation, and recreation); [same comment as before, couldn’t this be stated as beneficial uses lost due pest infestations?] 2.1.4.1.2. Identify targeted aquatic nuisance animal species; 2.1.4.1.3. Identify possible sources of the problem (e.g., nutrients, invasive species, etc.); and 2.1.4.1.4. Establish past or present aquatic nuisance animal densities which serve as action threshold for implementing pest management strategies.

In the event site data are not available to identify the pest problem at your treatment area, you must document why it is not available and the assumptions you used to develop your management strategies and action threshold for the treatment area. (See Part 6, IPM Plan) [Same comment as before for this statement: How does an applicator even know they have a problem if they don’t have data available to identify the problem?]

2.1.4.2.Pest Management. The following permit conditions apply to you if you

are a Public Entity, Quasi-Public Entity, or a For-Hired Applicator. Prior to the first pesticide application covered under this permit and prior to the first pesticide application, at a minimum, each year you must select and implement for each treatment area the most efficient and effective means of pest management options, including pesticides and non-pesticide methods. In developing your pest management strategies, you must evaluate the following management options considering human health and ecological impact, pe st resistance, feasibility, and cost effectiveness:

• No action.

• Prevention

• Mechanical/physical methods.

• Cultural methods.

• Biological control agents.

• Pesticides.EPA Deliberative Draft - Do Not Distribute, Copy, or Cite (BAT Workgroup)

Created on November 23, 2009 8 [Replace the above section by re ferring the permitee to Section 6.]

2.1.4.3.Pesticide Use. The following permit conditions apply to you if you are

a Public Entity, Quasi-Public Entity, or a For-Hired [Hire] Applicator. If pesticide is used to control aquatic nuisance animals in lakes, ponds, rivers and streams and pesticide will be discharged on or over, including near waters of the United States you must: 2.1.4.3.1. Conduct surveillance using best management practices prior to each application to assess the treatment area and to determine when pre-established conditions (pest action threshold) are met which necessitate the need for pest management; 2.1.4.3.2. Conduct surveillance using best management practices after each pesticide application to determine effectiveness of the

treatment. 2.1.4.3.3. Minimize the impact on the environment and non-target organisms by minimizing the use of pesticides for aquatic nuisance animal control in lakes, ponds, rivers, and streams when the action thresholds have been met.

6.0. Integrated Pest Management (IPM) Plan If you are required to submit an NOI, you must prepare an IPM plan for each treatment area or for several similar tr eatment areas within the same watershed before submitting your NOI for permit coverage. The IPM plan does not contain effluent limitations; the limitations are contained in Parts 2.0 and 3.0 of the permit. The IPM plan is intended to document the evaluation and selection of control measures. The additional documentation requirements (see Part 10, Recordkeeping) are intended to document the implementation (including inspection, maintenance, monitori ng, and corrective action) of the permit requirements. [There is no reason to include a reference to Part 10 in this section. Record keeping is not a part of an IPM strategy, it is a stand-alone requirement for all NPDES permits under the CWA (as I understand it) and s hould be considered a part of the overall permit.]

6.1 Contents of Your IPM Plan For coverage under this permit, you must docum ent in your IPM Plan all of the following elements: 1. IPM Team [Does the term “team” imply a single individual is not allowed to do all the work?] 2. Problem Description 3. Control Measures Description 4. Pest Surveillance 5. Spill Prevention and Response Procedures [See comments in section 6.1.5.1]
6. Adverse Incident Response Plan [See comments in section 6.1.5.2]
7. Pesticide Monitoring 8. Documentation to Support Eligibility Considerations Under Other Federal
Laws. [See comments in section 6.1.6]
9. Signature Requirements.EPA Deliberative Draft - Do Not Distribute, Copy, or Cite (BAT Workgroup)

Created on November 23, 2009 9 Where your IPM plan refers to procedures in other documents, such as spill control plans, copies of the relevant portions of those documents must be kept with your IPM plan.

6.1.1 IPM Team

You must identify the staff members (by name or title) that comprise the team as well as their individual responsibilities, including:

a. Staff member(s) responsible for managing pests in relation to the treatment area described below; b. Staff member(s) responsible for de veloping and revising the IPM plan;

c. Staff member(s) responsible for taking corrective actions where required; and d. Staff member(s) or for-hire applicator responsible fo r pesticide applications. [I think this entire section overestimates th e capacity for most pest control programs.]

6.1.2 Problem Description

You must document the following:

a. Site Description; b. Objective;

c. Pest biology; d. Action threshold(s) [NOTE: may include disease status report as threshold.]

e. Description of the geographic boundaries and waterbodies to which the plan applies, including the applicable water quality standards; and f. A general location map (e.g., USGS quadr angle map, a portion of a city or county map, or other map) with enough detail to identify the geographic boundaries of the area to which the plan applies and location of the treatment area and waters of the United States.

g. Source of the data and any assumptions used to meet conditions in Parts 2.1.1.1, 2.1.2.1., 2.1.3.1., 2.1.4.1., and 2.1.5.1 6.1.3 Control Measures Description

You must document the management tools evaluated and control measures selected to minimize pesticide discharges into waters of the United States. The evaluation must include the following management t ools and considering human health and ecological impact, pest resistance, feasibility, and cost effectiveness:

a. No action b. Prevention

c. Mechanical/physical methods d. Cultural methods

e. Biological control agents f. Pesticides For mosquito control and aquatic nuisance insect control, you must document why larviciding is not the primary pesticide to manage mosquitoes [See Part 2.1.1.3.4.] [Same comment as before for applying an IPM strategy.]

6.1.4 Pest Surveillance

You must document pre and post pest surveillance procedures. ’[NOTE: allow to reference surveillance work other groups have done in the area.] Comment [mlk2]: Do we want the name, etc. we should specify what we want here instead of just saying pesticides. Maybe “Name of Pesticide Product used with its corresponding EPA Registration Number,”

Comment [mlk3]: I think this is supposed to be for mosquitoes only? The sentence includes aquatic nuisance n the beginning but focuses on mosquito at the end.EPA Deliberative Draft - Do Not Distribute, Copy, or Cite (BAT Workgroup)

Created on November 23, 2009 10 6.1.5 Schedules and Procedures You must document the following schedules and procedures in your IPM plan:

6.1.5.1 Spill Prevention and Response Procedures – Procedures for preventing and responding to spills and leaks. In lieu of drafting your own spill prevention and response procedures, you may reference the existence of other plans for spill prevention that were developed for pesticide application, provided that you keep a copy of that other plan with your IPM plan and make it available for review consistent with Part 6.3. [Spill Prevention and Response Procedures have never been a part of any IPM strategy I have seen or been involved in developing. The control and cleanup of spills and leaks is driven by both the pesticide label and RCRA. This requirement appears to be overly burdensome and not mandated by the CWA.] 6.1.5.2 Adverse Incident Response Plan - Procedures for responding to adverse incident [s] resulting from pesticide applications. You must identify and document the following:

• Course of action or responses to any incident resulting from pesticide

applications;

• Chain of command notification for the incident, both internal to your

agency/organization and external;

• Timelines of the response;

• State/Federal contacts with phone numbers;

• Name, location, and telephone of ne arest emergency medical facility;

• Name, location, and telephone of ne arest hazardous chemical responder

(including police and fire department); and

• Name and telephone number for the National Pesticide

Telecommunications Network at 800-858-7378. [Again, an Adverse Incident Response Plan is not part of a traditional IPM strategy. This is something better suited for the permit in general, which then requires the applicant to submit an IPM plan as part of the application.] 6.1.5.3 Pesticide Monitoring – You must document the procedures for monitoring consistent with the requirements in Part 8.0 including:

 The process for determining the location of any monitoring;

 A schedule and procedures for any monitoring;

 The person (or position) responsible for conducting monitoring; and

 Procedures for documenting an y incidents of noncompliance observed. 6.1.6 Documentation to Support Eligibility Considerations Under Other Federal Laws. [to be determined] [I am completely unfamiliar with whether this is a mandatory requirement under the CWA. Because of that, I am concerned that it will create a pitfall for anyone who might also be unfamiliar with the myriad Federal laws that might come into play during a pesticide application. Are we going to have the states and regional offices cross trained for utility easements, Federal airspace restrictions, interstate highway rightsof-way, illegal immigrant labo r or intrastate commerce?] 6.1.7 Signature Requirements. Comment [mlk4]: Shouldn’t we require, not the permittee determine when to respond to an incident in so many hours????EPA Deliberative Draft - Do Not Distribute, Copy, or Cite (BAT Workgroup)

Created on November 23, 2009 11 You must sign and date your IPM plan in accordance with Appendix B, Subsection B.11.

6.2 IPM Plan Modifications You must modify your IPM plan whenever n ecessary to address any of the triggering conditions for corrective action in Part 5.1 to en sure that they do not reoccur, or to reflect changes implemented when a review following the triggering conditions in Part 5.1 indicates that changes to your control measures are necessary to meet the effluent limits in this permit. Changes to your IPM plan must be made in accordance with the corrective action deadlines in Parts 5.2 and 5.3, and mu st be signed and dated in accordance with Appendix B, Subsection B.11

You must review your IPM plan at a minimum once per year or whenever necessary to address any new pest problem at your treatment area(s).

6.3 IPM Plan Availability You must retain a copy of the current IPM plan, along with all supporting maps and documents, at the address provided on the NOI and it must be immediately available to EPA; a State, Tribal, or local agency governing pesticide applications; and representatives of the U.S. Fish and Wildlife Service (USFWS) or the National Marine Fisheries Service (NMFS) upon request. EPA may provide access to portions of your IPM plan to a member of the public upon request. Confidential Business Information (CBI) may be withheld from the public, but ma y not be withheld from those staff cleared for CBI review within EPA, USFWS, or NMFS.

10. Recordkeeping 10.1.You are required to keep the following documentation. These records are to be complete and maintained at your facility, so as to demonstrate your full compliance with the conditions of this permit. 1. A copy of this permit (an electronic copy easily available is also acceptable) 2. A Pest Management log. Your log mu st be completed within 5 days of pest management activities. You must maintain records of the following information: 1. The name(s) of the recordkeeper; 2. Times and date(s) of pest management activities; 3. The location(s) of the management area(s) (e.g., waterbody, or map coordinates); 4. Target Pest; 5. Pest management strategies used and what action threshold has been met 6. Pesticide used: a. Kinds and amounts of pesticides used, including EPA registration number b. Any observed non-target impacts resulting from your discharge; c. When the application equipment was calibrated; [This is not required in normal pesticide application record keeping] d. For mosquito control and aquatic nuisance insect control, if applicable, why larviciding is impractical. Comment [mlk5]: Consider breaking this up into a couple of sentences, slightly confusing as is.

Comment [mlk6]: Not sure what this means – application of pesticides or each time you complete a condition of the

p ermit?

Comment [mlk7]: Technically – if they don’t use a pesticide they don’t need a permit. Made some edits.EPA Deliberative Draft - Do Not Distribute, Copy, or Cite (BAT Workgroup)

Created on November 23, 2009 12 10.2. If you are required to submit an NOI, as identified in Part 1.2.2, you are alsorequired to keep the following documentation. These records are to be complete, up-todate, and maintained so as to demonstrate your full compliance with the conditions of this permit:

• A copy of the NOI submitted to EPA along with any correspondence exchanged between you and EPA specific to coverage under this permit;

• A copy of the acknowledgment letter you received from the NOI Processing Center or eNOI system assigning your permit tracking numbers;

• An IPM Plan as detailed in Part 6.0 [.]

10.3.You must retain copies of documentation outlined in Part 10.1 and, if applicable, Part 10.2 (including any modifications made to the IPM plan during the term of this permit), annual reports, adverse incident reports, corrective action reports, and any monitoring information required in Part 8 for a period of at least 3 years from the date that your coverage under this permit expires or is terminated.