Exhibit 6a Annual Requirements NPDES Rep.pdf

NPDES Reporting Requirements for esticide Applications.

General Reporting Requirements that can be used for all States (from EPA requirements). Note: review individual State requirements to determine if anything else is needed, reporting dates, etc. E.g. Nevada asks for photo records.

A. Operator Information (from NOI)

a. Permit tracking or authorization no.

b. Operator Name

c. Operator Contact

i. Name

ii. Title

iii. Address

iv. Telephone

v. Email

B. Adverse Incident and Corrective Action Information

a. If no adverse incidents, state in the report that there were none!

b. If adverse incidents, follow permit requirements for your state’s Pesticide General

Permit. These should also have been outlined in your PDMP.

C. Pest management area information (Forests may have 1 – several per Forest i.e. Anadromous and NonAnadromous). State if pesticide application occurred within WOTUS (within high water mark or directly to water surface). If yes, provide:

a. Description of area. Use same description as the NOI. We don’t need to specify each water body treated. We will be reporting on all WOTUS within the pest management area. For non-EPA states include the map or digital image that was submitted with the NOI.

b. Use Pattern (aquatic weeds & algae, forest canopy, etc.)

c. Name/Location of waterbodies. Use GIS map intersecting buffered water bodies to create WOTUS layer with treatments layer. Contact me if you need help with this. If GIS map not available will have to create map, describe or estimate area.

d. Total area treated. Get data from GIS intersection of treatments and WOTUS layers for weed treatments; add information for forest canopy treatments such as preventive tree spraying in campgrounds.

e. Targeted pest(s). List of pests by Use Pattern

f. Discharge to NMFS Listed Resources of Concern, yes/no, if yes, treatment dates. This will only apply to Idaho forests reporting through EPA electronically.

g. Applicator(s) info. If different than Operator (note this will be the Forest unless some is done through county agreements or contracts, then include those as well:

i. Company/Organization Name

ii. Contact Name

iii. Address

iv. Phone

v. Email

h. Was discharge addressed in PDMP? Y/N Answer will be yes, they were included.

i. Product Information. The total amount of products used during the calendar year -Note: – This is the amount of registered product not the quantity after water or other substances are added. This will be a summary of the total amount applied within the high water mark of areas treated by product and registration number.

i. Product Name

ii. EPA Reg. No.

iii. Amount applied (AI/AE lbs or gal)

iv. Application method (aerial fixed wing, aerial rotary, land-based, aquatic vehicle, direct mixture, Chemigation, other.) Our applications will all be land based.

D. Preparer and Certifier Information

a. For Wyoming and Nevada, the Forest Supervisor will sign the reports based on the 2150 letter of Feb 24, 2012 delegating signature authority for reports to Forest Supervisors.

For Idaho, the NOI certifier was the Regional Forester. With the delegation of authority for signing reports to the Forest Supervisor, he/she will need to be set up in the EPA electronic submission process as the certifying agent. When the electronic report is submitted, you will specify the Forest Supervisor as the submitter and add his/her email address. The Forest Supervisor will be sent an email with a certification key which will be used to sign into the EPA system for certification.

b.

ALL Forests – Need to review records and update PDMPs Include

• Daily Logs

• Applicator Information (all applicators must be listed)

• Pesticide use for Area within high water mark – from reports (use spreadsheets, maps, etc.)

• Map of WOTUS area (within high water mark) treated. For most of this, develop a buffered water body layer that approximates the area within the high water mark and intersect with treatment layer.

• Maintenance and calibration records

• Monitoring

• Adverse incident reports

Note that Forests will need to pay state fees for permits for 2013 before any treatments can be implemented.

• Idaho and Utah – no fees required

• Nevada $200 Annual fee

• Wyoming - $100 Annual fee based on their fiscal year of July 1 through June

Utah Requirements. An annual report is not required unless there has been an adverse incident.

See the general permit and your PDMP for adverse incident requirements. The Forest is required to keep the following records as part of their PDMP:

Records of acres or linear miles treated for all applicable use patterns covered under this general permit.

All operators must keep the following records:

a. A copy of this permit

b. A copy of any Adverse Incident Reports (See Part III. G)

c. Your rational for any determination that reporting of an identified adverse incident is not required consistent with allowances identified in Part III.G.l.

d. A copy of any corrective action documentation (See Part III.I)

2. Records listed below are required to be kept at the address provided on the NOI, as identified in Part I.A. Records of equipment maintenance and calibration are to be maintained only by the entity performing the pest application activity (on behalf of self or client).

http://www.waterquality.utah.gov/UPDES/Pesticides_General_Permit.pdf

a. A copy of the NOI submitted to DWQ, any correspondence exchanged between you and DWQ specific to coverage under this permit, and a copy of the DWQ acknowledgment letter assigning your permit tracking number;

b. The date on which you knew or reasonably should have known that you would exceed an annual treatment area threshold during any calendar year, as identified in Part I. Table 1.;

c. Surveillance method(s) used, date(s) of surveillance activities, and findings of surveillance;

d. Target pest(s);

e. Pest density prior to pesticide application;

f. Company name and contact information for pesticide applicator

g. Pesticide application date(s);

h. Description of treatment area, including location and size (acres or linear feet) of treatment area and identification of any waters, either by name or by location, to which you discharged any pesticide(s);

1. Name of each pesticide product used including the DWQ registration number;

J. Quantity of pesticide applied (and specify if quantities are for the pesticide product as packaged or as formulated and applied)

k. Concentration (%) of active ingredient in formulation;

I. For pesticide applications directly to waters, the effective concentration of active ingredient required for control;

m. Any unusual or unexpected effects identified to non-target organisms

n. Documentation of any equipment cleaning, calibration, and repair (to be kept by pesticide application equipment operator);

o. A copy of your PDMP, including any modifications made to the PDMP during the term of this permit.

3. All required records must be documented as soon as possible but no later than 14 days following completion of such activity. You must retain any records required under this permit for at least five years from the date that your coverage under this permit expires or is terminated. You must make available to DWQ, including an authorized representative of DWQ, all records kept under this permit upon request and provide copies of such records, upon request.

Nevada requirements. Annual report required by January 28, 2013.

C.1.6. Records Retention: All records and information resulting from the monitoring activities required by this pesticide general permit, including all records of analyses performed and calibration and maintenance of instrumentation and recordings from continuous monitoring instrumentation, shall be retained for a minimum of three (3) years after approval to discharge under NVG880001, or longer if required by the Administrator.

C.2.1. Annual Reporting: Annual monitoring results obtained pursuant to Section C. of the permit are due each January 28th, (following the 4th Quarter) of the applicable calendar year. Reports shall be summarized and submitted in a written report. The initial annual report is due on January 28th, 2013. The operator shall also submit the data in an electronic format provided by the Division to the address in Section C.2.9. below.

C.2.3. The annual report (for each NOI) shall contain the following information:

C.2.3.1. Operator’s name, number and contact information C.2.3.2. Contact person name, title, e-mail address (if any), and phone number C.2.3.3. For each pest treatment area, report the following information:

C.2.3.3.1. Identification of any waters or other treatment area, including size, either by name or by location, to which you discharged any pesticide(s); (note that I talked with Nevada and they are OK with a map showing treated areas.

They want a summary of information, not a massive list of information by stream.

C.2.3.3.2. Pesticide use pattern(s) (i.e., mosquito and other flying insects, aquatic weeds and algae, aquatic nuisance animals, or forest canopy) and target pest(s);

C.2.3.3.3. Company name(s) and contact information for pesticide applicator(s), if different from the NOI submitter; (This will generally be the Forest unless Counties, CWMAs or contracts treated on the NFS lands, then add their information as well as the Forests.

C.2.3.3.4. Total amount of each pesticide product applied for the reporting year by the EPA registration number(s) and by application method (e.g., aerially by fixed-wing or rotary aircraft, broadcast spray, etc.); (Sum totals by product and EPA number for the NOI area. Application method should be by broadcast spray. You don’t need to break out amounts by back-pack, UTV, etc.)

C.2.3.3.5. Information regarding how pest control activity was addressed in your PDMP prior to pesticide application; (Note that the treatment followed direction identified in the PDMP. Be sure to update the PDMP if you did something different!)

C.2.3.3.6. If applicable, an annual report of any adverse incidents as a result of these treatment(s), for incidents described in Section C.; (If no incidents, state that no adverse incidents occurred.)

C.2.3.3.7. A description of any corrective action(s), including spill responses, resulting from pesticide application activities and the rationale for such action(s).

C.2.3.3.8. Photographic evidence. Submit photographs of treatment activities.

Don’t need a lot of them.

C.2.9. Address for Submittal: All monitoring results and annual reports shall be submitted to the Division; an original signed copy of all reports required herein, shall be submitted to the Division at the following address:

Division of Environmental Protection Bureau of Water Pollution Control ATTN: Compliance Coordinator 901 South Stewart Street, Suite 4001 Carson City, Nevada 89701

Wyoming requirements. Annual report required by Feb 28.

4.0 MONITORING AND REPORTING

4.1 Monitoring Requirements for Pesticides Applicators.

The applicator must monitor the amount of pesticide applied to ensure that the applicator is using the lowest amount to effectively control the pest, being consistent with specific pesticide labeling instructions. The applicator must also monitor pesticide application activities to ensure that the application equipment is in proper operating condition by adhering to any manufacturer’s conditions, labeling instructions, and by calibrating, cleaning, and repairing equipment on a regular basis.

4.2 Visual Monitoring Requirements for Pesticide Applicators.

All applicators covered under this permit must conduct spot checks in the area to and around where pesticides were applied for possible and observable adverse incidents, as defined in Appendix A, caused by application of pesticides, including but not limited to the unanticipated death or distress of non-target organisms, and disruption of wildlife habitat, recreational, or municipal water use. Visual assessments of the application site must be performed.

4.3 Recordkeeping and Annual Reporting

4.3.1 Records Retention

The permittee shall retain records of all monitoring information, including all calibration and maintenance records and all original chart recordings for continuous monitoring instrumentation, copies of all reports required by this permit, and records of all data used to complete the application for this permit, for a period of at least three (3) years from the date of the sample, measurement, report or application. This period may be extended by request of the administrator at any time. A copy of this WYPDES permit, and a copy of the signed authorization, must be maintained on site during the duration of activity at the permitted location. Additionally, the following list of documents generated to fulfill the permit limitations of this Pesticides General Permit, shall be maintained on site for the duration of this permit term:

a. Copies of any adverse incident reports;

b. Copies of any corrective actions taken;

c. Copies of NOI‟s submitted to DEQ/WQD and any correspondence exchanged between the applicator/permittee and DEQ/WQD;

d. Current, up-to-date copy of the P4. (That is Wyoming’s PDMP)

4.3.2 Annual Reporting.

a. Monitoring results obtained during the previous twelve month calendar year shall be summarized and reported as outlined below. Legible copies and all other reports required herein, shall be signed and certified in accordance with the Signatory Requirements (see Part II, Section 1.6), and submitted to the state water pollution control agency at the following address no later than February 28 of the following year. All reporting periods are based upon the calendar year of January through December or any part therein. The first report is due on February 28, 2012.

Wyoming Department of Environmental Quality Water Quality Division Herschler Building, 4 West 122 West 25th Street Cheyenne, WY 82002 Telephone: (307) 777-7781

If no discharge (no pesticide applications within any of the use patterns identified in Part 1, Section 1.1.1 a-e) occurs during the reporting period, then "no discharge" shall be reported.

If the effective date of the authorization is December 1st or later the permittee is not required to Submit an annual report for that first partial year, but must submit annual reports thereafter. The First permitted report shall include any information concerning any pesticide applications for that first partial year that the applicator held an authorization.

b. Each annual report must contain the following information for each NOI:

1. Applicator‟s name, address, telephone number, and email address (if available);

2. The WYPDES authorization number for the applicator‟s authorization;

3. Contact person name, title, telephone number, and email address (if available) if different from number 1;

4. Identification of all waters or other treatment areas, including size, either by name (owner name and address) or location, to which pesticides were discharged under any of the pesticide use patterns listed in Part 1, Section 1.1.1 that exceed thresholds; or if applying to class 1 waters of the state (a list of class 1 waters of the state are included in Appendix B). ( Use map showing the areas within the high water mark (WOTUS) where pesticides were applied. Intersect treatment area layer with buffered stream/water body layer that approximates area within the high water mark. If you used the new NRIS Invasives reporting process, you will have a treatment area layer.

If you didn’t, you will have to build one or describe all the areas where treatments occurred within the high water mark.)

5. Total amount of each pesticide product applied for the reporting year by the EPA registration number(s) and by application method (e.g. aerially fixed wing, broadcast sprayer, etc.); (The application method will be “broadcast”, you don’t need to separate by back-pack, UTV, etc. Summarize the amount of pesticide applied by product name and EPA registration no.)

7. Whether this pest control activity was addressed in the permittee P4 prior to pesticides application taking place; (State that application of this pesticide was covered in the PDMP. If it wasn’t, modify the PDMP to include it.)

8. If applicable, copies of all adverse incident reports associated with these treatment areas;

9. A description of any corrective action(s), including spill responses, resulting from pesticide application activities and the rationale for each action(s).

Idaho. EPA report required by Feb 15th. Must be filed electronically through EPA electronic submission system.

E. Operator Information (from NOI)

a. Permit tracking no.

b. Operator Name

c. Operator Contact

i. Name

ii. Title

iii. Address

iv. Telephone

v. Email

F. Adverse Incident and Corrective Action Information

a. If no adverse incidents, state in the report that there were none!

b. If adverse incidents, follow permit requirements for your state’s Pesticide General

Permit. These should also have been outlined in your PDMP.

G. Pest management area information (Forests may have 1 – several per Forest i.e. Anadromous and NonAnadromous). State if pesticide application occurred within WOTUS (within high water mark or directly to water surface). If yes, provide:

a. Description of area. Use same description as the NOI.

b. Use Pattern (aquatic weeds & algae, forest canopy, etc.)

c. Name/Location of waterbodies. Use GIS map intersecting buffered water bodies to create WOTUS layer with treatments. If GIS map not available will have to create map, describe or estimate.

d. Total area treated. Get data from GIS intersection of treatments and WOTUS layers.

e. Targeted pest(s). List of pests by Use Pattern

f. Discharge to NMFS Listed Resources of Concern, yes/no, if yes, treatment dates.

g. Applicator(s) info. If different than Operator:

i. Company/Organization Name

ii. Contact Name

iii. Address

iv. Phone

v. Email

h. Was discharge addressed in PDMP? Y/N

i. Product Information. The total amount of products used during the calendar year -Note: – This is the amount of registered product not the quantity after water or other substances are added.

i. Product Name

ii. EPA Reg. No.

iii. Amount applied (AI/AE lbs or gal)

iv. Application method (aerial fixed wing, aerial rotary, land-based, aquatic vehicle, direct mixture, Chemigation, other – most will be land based.)

H. Preparer and Certifier Information

a. Certifier is Regional Forester, however; 2150 letter of Feb 24, 2012 delegates signature for reports to Forest Supervisor. Will have to set Forest Supervisors up in EPA system as certifiers before submitting electronic reports to do this.