Pesticide Discharge Management Plan

Pesticide Discharge Management Plan

for Treatments In, Over, or Near Waters of the Wildlife Division-Administered Lands

Michigan Department of Natural Resources

Wildlife Division

Prepared by:

Susan Tangora, Wildlife Biologist

Approved by:

______Date: ______

Russ Mason, Chief

Wildlife Division

Michigan Department of Natural Resources

530 West Allegan Street

Lansing, Michigan 48909-7757

Table of Contents

Pesticide Discharge Management Team 1

Pest Management Area Description 2

Control Measures 5

Schedules and Procedures 7

Signature of Responsible Party 9

Attachments:

·  NPDES General Permit for Aquatic Nuisance Plant and Algae Control

·  Wildlife Division Field Directory

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Pesticide Discharge Management Team

Pest Managers

Individuals responsible for managing pests in relation to the pest management area (DNR–Wildlife Division lands), and for developing, revising, and implementing corrective actions and other discharge limitation requirements:

·  Biologists and technicians for all state game areas, forests, and recreational areas (see attached field directory)

PDMP Developer

Individual responsible for developing and revising the Pesticide Discharge Management Plan (PDMP):

Permittee Name:
Susan Tangora / Title:
Wildlife Biologist
Mailing Address:
530 West Allegan Street / City:
Lansing / State:
MI / Zip Code:
48909
E-mail Address:
/ FAX (with area code):
---- / Telephone (with area code):
(517) 241-1153

Pesticide Applicators

Individuals responsible for applying pesticide in accordance with this plan:

·  Various state employees at game areas, forests, and recreational areas.

·  Various contractors, operating under a valid state contract

·  Volunteers, operating under a volunteer project agreement

·  All state employee and contract pesticide applicators will be Michigan Department of Agriculture (MDA) Certified Commercial Pesticide Applicators, with names and certification numbers documented on each treatment record

·  Contract applicators will operate under a state contract, and volunteers will operate under a volunteer project agreement, the terms of which will clearly specify the division of responsibilities between the contractor/volunteer applicator and the DNR project manager. Copies of these written agreements/contracts will be available at the local office conducting the treatment.

Pest Management Area Description

Pesticide use pattern for our Pest Management Area is for the Aquatic Nuisance Plant and Algae Control

Target Pests

Pest / Source of Problem / Source of Data Used to Identify the Problem
Invasive plants, including, but not limited to the following:
·  Asian bittersweet
·  Autumn olive
·  Black alder
·  Black locust
·  Bladder campion
·  Brazilian elodea
·  Chinese bush-clover
·  Chinese yam
·  Common and glossy buckthorn
·  European frog-bit
·  Flowering rush
·  Garlic mustard
·  Hedge parsley
·  Honeysuckle
·  Japanese barberry
·  Japanese knotweed
·  Lyme grass
·  Multiflora rose
·  Narrow-leaf bittercress
·  Narrow-leaf & hybrid cattail
·  Norway maple
·  Parrot feather
·  Periwinkle
·  Phragmites
·  Privet
·  Purple loosestrife
·  Reed canary grass
·  Smooth brome
·  Spotted knapweed
·  Swallow-wort
·  Sweet-clover
·  Tree-of-heaven
·  Water hyacinth
·  Water lettuce
Agricultural Weeds
Vegetation of any species that is growing within agricultural fields. / ·  Translocation of seed and other plant parts from infested areas by humans, wildlife, wind, water, and other means
·  Disturbance of natural processes such as hydrology, fire regime, windthrow, and nutrient cycling / ·  Periodic site surveys conducted by state employees, contractors, or other partners documenting the presence, relative abundance, and distribution of known invasive plant species
·  MISIN database, this is a citizen-science-based online mapping system to track invasive species found in Michigan

Action Thresholds

For invasive plants, the action threshold is one individual within any part of the pest management area. Early detection and rapid response to invasive plants is the most cost effective and environmentally benign response once an invasive plant has become established at a site. Invasive plants spread rapidly once established. Implementing control as early as possible will minimize the amount of management action needed, and minimize the quantity of pesticide needed when chemical control is used.

For agricultural weeds, the action threshold is the point at which a sufficient quantity of vegetation is present to significantly impact the development of target agricultural products.

General Location Map

The pest management area is defined as all state-owned, leased, or land under conservation programs like the Landowner Incentive Program (LIP) or the Hunter Access Program (HAP) that are administered by the Michigan Department of Natural Resources Wildlife Division. Also included are adjacent private and public partner lands where a written agreement is in place for treatments.

Control Measures

Pesticide discharge to waters of the state will be minimized by implementing the following procedures:

·  All requirements of the applicable National Pollutant Discharge Elimination System Point Source Discharge General Permits for Aquatic Nuisance Plant and Algae Control (MIG031000).

·  Pre-treatment surveillance will be conducted to determine whether the target pest exceeds the action threshold. In most cases the pre-treatment surveillance will be conducted by the Pesticide Applicator, Pest Manager, or another state employee capable of identifying the pest immediately preceding any treatment.

No Action

·  A “No Action” alternative will be considered first. If the target pest is not likely to reach the action threshold, or if it is likely to have minimal impacts and be reduced below the threshold on its own without management action then no treatment will be conducted.

Prevention

·  “Prevention” measures will be employed wherever cost effective and practical to reduce the potential for the target pests to become established in portions of the pest management area where they do not already occur. Examples of prevention measures may include:

o  boot brushes at trailheads to remove invasive plant seeds

o  Using native or non-invasive/non-native plant materials that don’t outcompete native species and harm an ecosystems biodiversity, functions and/or services it provides

o  preventing the establishment of new corridors such as utilities, roads, or trails in locations where they would facilitate the spread of invasive plants

Mechanical/Physical Methods

·  “Mechanical or physical” methods will be considered. Mechanical methods such as mowing, cutting, and hand pulling are preferred over pesticides in situations where they will be as effective or more effective at controlling the target pest, are practical to implement, and of similar or lower cost.

Cultural Methods

·  “Cultural” methods will be considered to make site conditions less favorable for the establishment of invasive plants and other pests. In natural settings, this may include ecological restoration practices such as prescribed burning and hydrological restoration to maintain biodiversity and ecological integrity of natural communities and increase their resilience and resistance to invasion.

Biological Control Agents

·  “Biological Control Agents” will be considered when available and practical. For example, the use of Galerucella beetles for purple loosestrife control may be appropriate in lieu of chemical pesticides in many situations. When considering biological controls, potential non-target impacts to native and beneficial species must be considered. The effectiveness of using biological control may also be impacted by population size and density of the target pest and other ongoing management practices.

Pesticides

·  Pesticides will be used in cases where the other alternatives have been evaluated and pesticides are determined to be the most effective, cost-effective, and practical control method, with the least negative environmental impact.

·  When pesticides are used, each application will use an appropriate chemical, quantity, timing, and application technique that will produce the best results with the least non-target damage and cost.

·  Only pesticides registered for use in Michigan by the Michigan Department of Agriculture (MDA) and applied by certified applicators that are labeled for use in aquatic environments will be used in areas covered by the NPDES permit. The list of pesticides that may be used by DNR, Wildlife Division when operating under this permit is available here: www.michigan.gov/documents/deq/wb-swas-anc-approvedherbicides_261935_7.pdf. This includes all pesticides currently approved by the Michigan Department of Environmental Quality (DEQ) for use in aquatic environments.

·  All pesticide storage and application equipment will be maintained and calibrated by trained personnel, according to manufacturer recommendations and standard industry practices, to reduce the likelihood of spills and leakage and to insure the proper dose of pesticide is applied.

·  A visual assessment of the treatment area will be performed by the Pesticide Applicator or Pest Manager following each treatment to look for adverse incidents such as unusual or unexpected death of non-target organisms, or turbidity, color, oil films, foams, or other deposits in surface water. Any adverse incidents will be reported as required in the applicable NPDES general permit.

Schedules and Procedures

Pre-application Pest Surveillance

Areas will be visually inspected prior to any treatments to determine whether the action threshold is exceeded for any target pests. In many instances the areas will be inspected by a Pest Manager or their designee earlier in the growing season, up to several months before the treatment window. At minimum, every area to be treated will be visually inspected immediately prior to treatment by the Pesticide Applicator or another designated individual capable of identifying the target pest(s). The pre-application surveillance will be documented as part of the treatment record.

Assessment of Environmental Conditions in the Treatment Area

A Pest Manager, Pesticide Applicator, or their designee will assess the condition of the treatment area prior to any treatments. This will include a visual assessment of the amount and location of standing water and wet areas and evidence of protected species or other non-target organisms that could be impacted by treatments.

Determination of the Treatment Method, Type of Chemical, and Lowest Effective Dose

A Pest Manager or their designee will use the “Control Measures” guidance in this plan (pages 8-9) to determine:

·  the necessity of action, based on action thresholds

·  the most effective, cost-effective, and practical control method, with the least negative environmental impact

·  for pesticide treatments, the appropriate chemical, dose, timing, and application technique that will produce the best results with the least non-target damage and cost

Maintenance Activities

The Pesticide Applicator or another trained individual will insure all equipment used for storage, handling, transport, and application of pesticides has been properly maintained, calibrated, and cleaned to manufacturer recommendations and industry standards prior to every use. Equipment will be visually inspected by the applicator for leaks or signs of damage immediately prior to use, and will be cleaned and inspected following application. During transport and storage, equipment and pesticides will be double-contained to prevent spills and leaks.

Spill Response Procedure

All locations where pesticide is stored, transported, and used will have a standard spill response kit. All Pesticide Applicators (and others as appropriate) will be trained on how to properly and expeditiously stop, contain, and clean up a spill or leak, including proper use of the spill response kit. Individuals who cause or detect a spill or leak must immediately notify an individual trained in spill response, and that individual must immediately take all practical measures to stop, contain, and clean up the spill or leak. All staff, contractors, or volunteers working with pesticides at a given location must be made aware of this procedure and who the trained individual(s) are for that location and time.

Spills must be reported immediately to an individual’s immediate supervisor, and all notification procedures specified in the NPDES general permit (Part II, Section B, Items 2, 3, and 4, as appropriate) must be followed. This includes 24-hour verbal reporting requirements and various levels of written reporting requirements depending on the nature of the spill.

Adverse Incident Response Procedure

An adverse incident is defined as an incident in which a person or non-target organism is exposed to a pesticide residue and suffers a toxic or adverse effect. Any unusual or unexpected exposure or non-target damage must be documented and reported by the person who discovered it, in conjunction with the applicable Pesticide Applicator and Pest Manager for that treatment. Adverse incident reporting requirements are described in detail in the NPDES general permit, Part II, Section B, Item 2 (page 19). Some adverse incidents require 24-hour reporting by phone, and all require written reporting within 30 days. The cause of all adverse incidents must be investigated and included in the required reports. Corrective action (described in the NPDES general permit) may be required if any permit conditions were violated.

Monitoring

The Pesticide Applicator or their designee will visually inspect the treatment area immediately after the pesticide application is complete. They will record any unusual or unexpected non-target kill or adverse effects as described above. The Pest Manager or designee will conduct spot inspections of pesticide treatment areas one or more days later, during a timeframe when the effects of the pesticide are expected to be visible. These spot inspections will assess the effectiveness of the treatment (amount of target pest kill) and again visually check for evidence of adverse effects to non-target organisms or water quality.

Record Keeping

The local project manager will retain all NPDES-related treatment records, adverse incident reports, copies of permits and certificates of coverage, and any corrective action documentation for a minimum of three years from the date of the activity. Those records, along with the current PDMP, will be available immediately upon request by DEQ.

Reporting

Each local project manager will prepare and submit an annual report to DEQ by November 30 each year, to include all NPDES-related pesticide treatment records for the Division.

Signature of Responsible Party

CERTIFICATION
Rule 323.2114(1-4), promulgated under the Michigan Act, requires that this Pesticide Discharge Management Plan must be signed as
follows:
A. For an organization, company, corporation, or authority, by a principal executive office, vice
president, or higher
B. For a partnership, by a general partner
C. For a sole proprietor, by the proprietor
D. For a municipal, state, or other public entity, by a principal executive officer or ranking
elected official (e.g., mayor, village president, city or village manager, or clerk)
Note: If the signatory is not listed above, but is authorized to sign the Pesticide Discharge
Management Plan, please provide documentation of that authorization.
“I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for having knowledge of violations.”
I understand that my signature constitutes a legal agreement to comply with the requirements of the NPDES Permit. I certify under penalty of law that I possess full authority on behalf of the legal owner/permittee to sign this Pesticide Discharge Management Plan.
Print Name:______Title:______
Signature:______Date:______
Preparer’s Name If Different From Certifier
Print Name:____Susan Tangora______Title:_____Invasive Species Coordinator ____
Signature:____________Date:______08/02/12______

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