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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 the discharge of pesticides into 

waters of the United States, all permittees must do the following: 

1. Use the effective amount of pesticide product 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 from both pesticide containers and application 

equipment to waters of the United States. 

3. Calibrate and maintain equipment to ensure 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 “Pest 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 practices. 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 management practices stated in that 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. 
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Created on November 23, 2009 2 

documentation and recordkeeping permit conditions 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 nuisance 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 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) 

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 effective 

means 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 referring the permitee to Section 6.] 
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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 discharged 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 to 

assess 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, 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 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, Ponds, 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?]
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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 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) [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 referring 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; 
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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-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 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 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?]

2.1.3.2.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, each 
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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 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 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 over, 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. 
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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-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 do the 

following for each treatment area: 

2.1.4.1.1.Identify problem aquatic nuisance animal areas and application 

areas, including water use goals not attained (e.g. wildlife 

habitat, 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, pest resistance, feasibility, and cost 

effectiveness: 

• No action. 

• Prevention 

• Mechanical/physical methods. 

• Cultural methods. 

• Biological control agents. 

• Pesticides. 
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Created on November 23, 2009 8 

[Replace the above section by referring 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 treatment 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, monitoring, 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 should be considered a part of the overall 

permit.]

6.1 Contents of Your IPM Plan 

For coverage under this permit, you must document 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. 
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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 developing 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 for pesticide applications. 

[I think this entire section overestimates the 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 quadrangle 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 tools 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. 
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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 nearest emergency medical facility; 

• Name, location, and telephone of nearest 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 any 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 labor 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???? 
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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 necessary to address any of the triggering 

conditions for corrective action in Part 5.1 to ensure 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 must 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 may 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 must 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 

permit?

Comment [mlk7]: Technically – if 

they don’t use a pesticide they don’t need 

a permit. Made some edits. 
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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 also 

required 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.