NCG560067_Updated PDMP_20240507

Pesticide Discharge Management Plan
(PDMP)
BlueGreen US Water Technologies, Inc.
Mailing Address: 301 South Hills Village Ste LL200 #452
Pittsburgh, PA 15241
Decision-maker(s):
Permit and Treatment Decision Makers (Manager, Supervisor, Owner, etc.):
Dr. Jessica Frost — US Science Director
BlueGreen US Water Technologies, Inc.
Jessica.frost(c bluegreenwatertech.com
Cell: 941.224.2218
Person(s) Responsible for PDMP Development and Implementation:
Dr. Jessica Frost — US Science Director
BlueGreen US Water Technologies, Inc.
iessica.frost(a�bluegreenwatertech.com
Cell: 941.224.2218

PDMP Preparation/Revision Date: Aug 29, 2023 PDMP Implementation Date: June/July 2024
1. PDMP Team
a. Persons responsible for managing pests in the pest management area?
Dr. Jessica Frost
*Pests is defined as cyanobacteria (aka bluegreen algae)
*Management area defined as Lake Mattamuskeet, North Carolina
b. Persons responsible for developing and revising the PDMP?
Dr. Jessica Frost
c. Persons responsible for developing, revising, and implementing corrective actions and other
effluent limitation requirements?
Dr. Jessica Frost
d. Persons/Teams/Companies responsible for pesticide applications?
Dr. Jessica Frost (BlueGreen)
BlueGreen is hiring applicators as subcontractors. Once the permit application is approved, a
subcontractor will be selected. List of potential subcontractors:
Modica & Associates
SOLitude
WSB
2. Pest Management Area Description
a. Pest Problem Description.
Lake Mattamuskeet is the largest natural freshwater lake in North Carolina. It lies next to
the Pamlico Sound in eastern North Carolina. The 40,000 acre lake makes up the majority
of the Mattamuskeet National Wildlife Refuge, which is managed by USFWS. The lake is
nearly centrally located along the Atlantic Flyway, a route migratory birds use to move south
for the winter. The refuge is extremely valuable for wintering waterfowl to stop, rest and eat
along their journey. According to USFWS, the refuge attracts more than 200,000 ducks,
geese and swans from November through February. About 58,000 people visit the refuge
annually to observe the birds, or to hunt and fish in the summer. For rural Hyde County, this
brings important economic stimulation. Since the 1980's, water quality declines have been
monitored in the lake. Results consistently show pH and chlorophyll a levels above normal
limits, indicating algae blooms in the water. These blooms are caused by excess nutrients

in the water, such as nitrogen and phosphorus. Toxic algal blooms (aka HABs) have also
been monitored. These blooms have some of the highest concentrations of algal toxins in
the country, bordering on federal limits for recreational contact. In 2016, the lake was listed
on the state 303(d) list for impaired waters due to elevated levels of pH and chlorophyll -a.
The water quality within the lake has drastically declined due to significant increases in
nutrients and suspended sediments that have been contributed from over a century of
landscape alterations and hydrologic modifications. In addition, monitoring by the U.S. Fish
and Wildlife Service (USFWS) has indicated that most of the submerged aquatic vegetation
(SAV), an important habitat for fish and food source for waterfowl was lost in the lake by
2017. The algae blooms are blocking sunlight from making it to the lake bottom. When this
happens for long periods of time, grass begins to disappear. The source of these HABs is
cyanobacteria, which is known to produce toxins of varying levels. Monitoring results also
indicates algae blooms containing a cyanotoxin, cylindrospermopsin, at concentrations that
border the federal limits for recreational contact has become a more frequent occurrence.
Note: Information herein is referenced in the 2018 Lake Mattamuskeet Watershed
Restoration Plan.
b. Action Thresholds.
In collaboration with University of North Carolina (UNC) Collaboratory, subject matter
experts from UNC Institute for Marine Sciences, and the US Fish and Wild Service,
BlueGreen is engaged in monitoring to establish treatment dosages in alignment with best
practices and the product label. Our research project includes monitoring using remote
satellite -based analysis, in -situ field measurements and direct water sampling with
laboratory analysis provided by UNC IMS.

Product Label Excerpt:
APPLICATION RATES
The best method by which to apply Lake GuardO Oxy granules to water is by broadcasting (dusting) it
over a well-defined contamination zone, at early bloom stages, when harmful algallcyanobacteria
numbers are at 5,000 to 20.000 celWML (and below TO pg chlorophyll-arliter).
Determination of surface area to be treated
Determine the size of the infested area as follows: (1) in small infested reservoirs, under than 250 acres,
obtain surface area by measuring of regular shaped ponds or mapping of irregular ponds or by reference
to previously recorded engineering data or maps. (2) In water bodies larger than 250 acres (or smaller
ponds with a defined contaminated zone) outline the infested area by a combination of the following
instruments: microscopical count, pigment extraction, toxin evaluation, probes that detect specific
pigments that are known to serve as a correlated proxy for algaelcyanobacteria biomass, satellite
imaging, etc. NOTE; evaluation of the state of the infestation should be done by professional personnel.
Determination of the application rate
For control of harmful algaelcyanobacteria infestation it is essential to begin Lake Guardl, Oxy treatment
when harmful aigaelcyanobacteria cell numbers are in the range of 5,000-20,000 cellimL (or below 10 pg
chlorophyll-alliter). Apply 0.5-5 Ibs,lacre Lake GuardO Oxy at these alga Vcyanobacterial cell -densities.
Always start with the lower rate. At higher infestation rates, when cyanobacterial cell density is between
20,000-100.000 cellslmL (or between 10.50 pg chlorophyll-alliter} use 5-30ibs.lacre LAe Guardo Oxy.
If treatment is delayed until algallcyanobacteriai cell numbers exceed 100,000 celllmIL (or equivalently,
above 50 pg chlorophyll-alliter), an increase in the quantities of the Lake GuardO Oxy will be required, as
well as in treatment frequency. Therefore, in heavy blooms. when cyanobacterial scum or aggregates are
visible to the naked eye (more than 100,000 cellslmL of algaelcyanobacteria or over 50 pg chlorophyll-
alliter). treat with doses between 30-98 Ibs.lacre. If doses exceed H Ibs./acre, treat no more than one-
half of the water area in a single application. Maximum single application rate allowed should not exceed
294 Ibs.facre of the Lake Guard" Oxy. NOTE: when cyanobacterial aggregated could be seen with the
naked aye, the cyanobacterial cell density in the water is estimated to exceed 100,000 cells per mi.
When a single application dose is below 30 Ibs.lacre, minimum retreatment interval is 12 hours. When a
single application dose is between 30-96 Ibs.lacre, minimum retreatment interval is 24 hours. When a
single application dose exceeds 98 Ibs,lacre, the minimum retreatment interval is 48 hours.
4

c. Provide Location and Treatment Area Maps or refer to NO1 maps.
Treatment area is defined as the water surface of Lake Mattamuskeet:
VW
Lin
C—
Figure 1: Mop of Hyde County, MC, General wotershed area ootfined
RESEARCH PROJECT PLAN SITE DETAILS:
Site Location
Area Size
(Acres)
Perimeter Size
(miles)
Turbidity Curtain Total Size
(miles)
WESTBASIN
West Treatment A
131.0
2.8
0.1
West Control A
145.0
2.5
0.5
West Treatment B
40.6
1.1
0.3
West Control B
8.8
0.6
0.1
West Treatment Total Acres
171.6
West Site Locations Total
Acres
325.4
EASTBASIN
East Treatment A
212.0
2.5
0.6
East Control
95.9
1.7
0.6
East Treatment B
6.5
0.4
0.1
East Control B
80.0
1.5
0.5
East Treatment Total Acres
218.5
East Site Locations Total
Acres
394.4

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Red lines indicate perimeter of the waterbody. White lines indicate position and length of turbidity curtains.
d. Water Quality Standards.
Since this is a research project in collaboration between BlueGreen, UNC Collaboratory,
UNC IMS, and USFWS, the following is a comprehensive list of parameters that will be
collected and analyzed:
Chlorophyll a
Phycocyanin
Accessory pigments by HPLC
Phytoplankton species microscopy
Chlorophyll a fluorescence
Phycocyanin fluorescence
Nutrients (N and P)
Cylindrospermopsin toxin
Microcystin toxin
BMAA (emergent toxin of concern for eastern North Carolina)
Dissolved oxygen
pH
Zooplankton biomass/community structure
Turbidity
Colored dissolved organic matter
PAR attenuation
Salinity
Temperature

Remote sensing
Control Measure Description
BlueGreen includes our EPA registered product label and SIDS as an attachment to this
document. The active ingredient in Lake Guard Oxy® is sodium percarbonate, which forms
hydrogen peroxide when mixed with water. The hydrogen peroxide is activated only on the
upper surface of the water and releases H2O and 02 molecules as byproducts. Control
measures are typically based on adherence to the EPA product label and optimizing
outcomes based on minimum application rates, not to exceed the EPA product label. In
collaboration and agreement amongst BlueGreen, UNC Collaboratory, UNC IMS, and
USFWS, this research project demonstrates due diligence beyond adherence to the EPA
product label by taking extra precautions that are specifically designed for Lake
Mattamuskeet, primarily driven by an abundance of caution. More specifically, BlueGreen
voluntarily performed a variety of EPA recognized and standardized toxicology tests that
included Ceriodaphnia dubia, Apis mellifera, and northern bobwhite quail (in lieu of mallard
ducks that were initially tested, however, because of a strong regurgitation response, and
LD50 was not possible to determine for mallard ducks). BlueGreen includes all toxicology
final reports as attachments to this document. As a result of the toxicology tests, the project
team created thresholds for dose application and contingencies for stopping treatment.
These thresholds and contingencies are outlined below as a part of the mitigation protocol
for Lake Mattamuskeet, as agreed by upon BlueGreen, UNC Collaboratory, UNC IMS, and
USFWS.
• LAKE GUARD OXY® TREATMENT CASE SCENARIOS
TREATMENT
AREAS
SCENARIO BASED
ESTIMATED
MONITORING
ON CYANOBACTERIA
MAXIMUM
MONITORING
FREQUENCY
CELL DENSITY
IF
THEN
DOSE USE
METRICS
T IN HOURS)
1.
CYANOBACTERIA
LAKE GUARD
WEST BASIN:
CELL COUNTS
@ T0, T12, T24, T36, T48,
CELL DENSITY
OXY DOSE @
15,600 LBS
T72, T96, T120, T144 OR
>100,000 CELLS/ML
50LBS/ACRE
EAST BASIN:
UNTILTARGET
(18.4 PPM)
14,600 LBS
CYANOBACTERIA CELL
DENSITY 20,000
CELLS/ML IS MET,
WHICHEVER COMES
FIRST
2.
CYANOBACTERIA
LAKE GUARD
WEST BASIN:
CELL COUNTS
@ T0, T12, T24, T36, T48,
CELL DENSITY
OXY DOSE @
9,360 LBS
T72, T96, T120, T144 OR
>20,001-100,000
30LBS/ACRE
EAST BASIN:
UNTILTARGET
CELLS/ML
(11.04 PPM)
8,760 LBS
CYANOBACTERIA CELL
DENSITY 20,000
CELLS/ML IS MET,
WHICHEVER COMES
FIRST
3.
CYANOBACTERIA
LAKE GUARD
WEST BASIN:
CELL COUNTS
@ T0, T12, T24, T36, T48,
CELL DENSITY
OXY DOSE @
1,560 LBS
T72, T96, T120, T144; A
10

>5,000-20,000
5LBS/ACRE
EAST BASIN:
MAINTENANCE
CELLS/ML
(1.84 PPM)
1,460 LBS
STRATEGY TO ENSURE
CYANOBACTERIA CELL
DENSITY DOES NOT
EXCEED 20,001
CELLS/ML
FOR LAKE MATTAMUSKEET:
A TREATMENT EVENT IS DEFINED AS 2 WEEKS IN DURATION
PERIOD OF PERFORMANCE IS DEFINED AS APRIL 1-OCTOBER 31, 2024
THE MAXIMUM # OF TREATMENTS BASED ON THE ABOVE IS 2 PER MONTH (OR A TOTAL OF 14).
IN CONCERT WITH THE ABOVE TABLE OF LAKE GUARD OXYO TREATMENT CASE SCENARIOS, WATER
SAMPLES TO MEASURE CYANOTOXINS AFTER TREATMENT WILL BE COLLECTED @ TO, T12, T24, T36, T48,
T72, T96, T120, T144.
*Note -Lake Guard Oxy® EPA product label stipulates the following as guidelines for retreatment instructions:
When a single application dose is below 30 Ibs/acre, minimum retreatment interval is 12 hours.
When a single application dose is between 31-98 Ibs/acre, minimum retreatment interval is 24 hours.
When a single application dose exceeds >98 Ibs/acre, minimum retreatment interval is 48 hours.
• STOP TREATMENT CONTINGENCIES
CONTIGENCY
PLAN BASED ON
MONITORING
DO
IF
THEN
METRICS
MONITORING FREQUENCY
1.
DISSOLVED OXYGEN
STOP
DO
YSI-CONTINUOUS DATA LOGGING
< 4 MG/L FOR GREATER
TREATMENT
THAN 8 HOURS
2 MG/LATANYTIME
Lake Mattamuskeet estimated annual average DO: 106% or 9.56 mg/L.
CONTIGENCY
PLAN BASED ON
MONITORING
PH
IF
THEN
METRICS
MONITORING FREQUENCY
2.
PH > 10.5
STOP
PH
YSI-CONTINUOUS DATA LOGGING
PH < 6
TREATMENT
Lake Mattamuskeet 2023 pH ranged 7.5-9.
4. Schedules and Procedures
January 2023-present: Continuous baseline data collection and monitoring.
April 1-October 31, 2024: Period of performance for mitigation activities.
July 2024: Target month for first mitigation treatment, followed by continuous monitoring and data
collection to guide subsequent actions, which may include re -treatment, or dose recommendation.
Please refer to the above treatment case scenarios for decision making.
a. Document Control Measures.
1) Application rate and frequency. Include procedures for determining the lowest effective

amount of pesticide product per application and the optimum frequency of applications
necessary to control the pest while reducing the potential for pest resistance.
The EPA product label establishes baseline dosage amounts and frequencies.
Optimizing outcomes to establish lowest effective dosage / application is influenced
by our team of scientists and USFWS and in consideration of best practices,
including:
i. Time of day
ii. Wind and weather patterns
iii. Historical analysis and trend modeling
iv. Cell counts
v. Remote satellite -based monitoring
vi. In -situ probe measurements
b. The mode of action of the product is a slow, time -release of sodium percarbonate
that converts immediately to hydrogen peroxide when mixed with water and further
disassociates to molecules of water and oxygen. Hydrogen peroxide is a Reactive
Oxygen Species (ROS) that causes oxidative stress, to which cyanobacteria are
known to be the most susceptible and is accredited for triggering a Programmed
Cell Death (PCD) cycle within the cyanobacteria colony.
c. Frequency of application adheres to the EPA label and is influenced by the
cyanobacteria's movement within the vertical water column and overall
concentration of cell density.
2) Spill prevention. Procedures and schedule of maintenance for preventing spills and leaks
of pesticides associated with the application of pesticides.
a. Spill prevention procedures are established by adhering to the EPA product label,
the Safety Data Sheet (SDS) and ensuring the use of licensed applicators. (Safety
Data Sheet included as attachment).
3) Pesticide application equipment. Schedules and procedures for maintaining application
equipment in proper operating condition to prevent spills and overapplication, including
calibrating, cleaning, and repairing equipment.
a. BlueGreen will be contracting with a licensed subcontractor.
b. Licensed subcontractor(s) are responsible for the maintenance of internal fleet
records, insurances and certifications, and timely communications with project
manager.
4) Pest surveillance. Procedures and methods for conducting pre -application pest
surveillance.
a. BlueGreen has and is conducting field -based observations, remote monitoring
based on satellite imagery analysis, in -situ measurements, and water sampling.
Additionally, BlueGreen has analyzed historical datasets available from 3rd party
sources, such as USGS, Mattamuskeet National Wildlife Refuge, and the Lake
Mattamuskeet Technical Working Group, across multiple years.
b. UNC IMS has and is conducting monthly field -based operations for water quality.
5) Assessing environmental conditions. Procedures and methods for assessing
environmental conditions before and after treatments in the treatment area.
a. Both BlueGreen and UNC IMS continue to conduct field -based observations,
remote monitoring based on satellite imagery analysis, in -situ measurements, and
12

water sampling. Additionally, BlueGreen has analyzed historical datasets available
from 3rd party sources, such as USGS, Mattamuskeet National Wildlife Refuge, and
the Lake Mattamuskeet Technical Working Group, across multiple years.
b. Environmental conditions will include additional attributes, such as temperature,
dissolved oxygen, pH and similar water quality parameters (please refer to Section
2 d. for a comprehensive list of parameters).
b. Other Actions to Minimize Discharges.
1) Spill response procedures.
a. Procedures for expeditiously stopping, containing, and cleaning up leaks, spills, and
other releases. Employees who may cause, detect, or respond to a spill, leak, or
overapplication must be trained in these procedures and have necessary spill response
equipment available.
BlueGreen's spill response procedures are detailed within our Safety Data Sheet, which is
included as an attachment, with excerpt below.
6. ACCIDENTAL RELEASE MEASURES
8.1
sptlis
Ensure adequate ventilation. Avoid contact with eyes or clothing. Evacuate personnel to safe areas. Keep people away
from and upwind of spill/leak _ ELIMINATE all ignition sources (no smoking, flares, sparks, or flames in immediate area).
Do not touch damaged containers or spilled material unless wearing appropriate protective clothing. See section 8 for
more information. Stop leak if you can do it without risk_ Use personal protective equipment as required. Keep
combustibles (wood, paper, oil, etc.) away from spilled material. DO NOT GET WATER INSIDE CONTAINERS.
Ventilate the area. Refer to protective measures listed in Sections 7 and 8.
Stop leak if you can do it without risk. Cover with DRY earth, DRY sand or other non-combustible material followed with
plastic sheet to minimize spreading or contact with rain.
With clean shovel place material into clean, dry container and cover loosely; move containers from spill area. Flush area
with flooding quantities of water. Prevent product from entering drains, Cover powder spill with plastic sheet or tarp to
minimizespreading and keep powder dry.
b. Procedures for notification of appropriate facility personnel, emergency response
agencies, and regulatory agencies.
BlueGreen's spill response procedures are detailed within our Safety Data Sheet, which
is included as an attachment. Any applicators shall be licensed accordingly and
onboarded to the SIDS through routine best practices.
Additional points of contract shall include first responders (if needed), BlueGreen project
manager, USFWS who manages Lake Mattamuskeet, North Carolina Department of
Environmental Quality, Hyde County Health Department, and any other points of contact
that agencies deem necessary.
2) Adverse incident response procedures.
a. Procedures for responding to any incident resulting from pesticide, biological agents, or
chemical applications.
13

6. ACCIDENTAL RELEASE MEASURES
6.1
spills:
Ensure adequate ventilation. Avoid contact with eyes or clothing. Evacuate personnel to safe areas. Keep people away
from and upwind of spillfleak. ELIMINATE all ignition sources (no smoking, flares, sparks, or flames in immediate area).
Do not touch damaged containers or spilled material unless wearing appropriate protective clothing. See section 8 for
more information_ Stop leak if you can do it without risk_ Use personal protective equipment as required_ Keep
combustibles (wood, paper, oil, etc.) away from spilled material. DO NOT GET WATER INSIDE CONTAINERS.
Ventilate the area. Refer to protective measures listed in Sections 7 and 8.
Stop leak if you can do it without risk. Cover with DRY earth, DRY sand or other non-combustible material followed with
plastic sheet to minimize spreading or contact with rain.
With clean shovel place material into clean, dry container and cover loosely; move containers from spill area. Flush area
with flooding quantities of water. Prevent product from entering drains. Cover powder spill with plastic sheet or tarp to
minimizespreading and keep powder dry.
b. Procedures for notification of the incident, both internal to your agency/organization and
external. Contact information for state/federal permitting agency, nearest emergency
medical facility, and nearest hazardous chemical responder must be in locations that
are readily accessible and available.
BlueGreen's spill response procedures are detailed within our Safety Data Sheet, which
is included as an attachment. Any applicators shall be licensed accordingly and
onboarded to the SDS through routine best practices.
9_ PRODUCT & COMPANY IDENTIFICATION
1.1
Pr°°.``Name:
BLUEGREEN® LAKE GUARDT"' OXY
1.2
Chemical Name:
Sodium Percarbonate Mixture
1.3
syr,°r,y—
NA
1.4
Trade Names:
BlueGreen Lake Guard7" Ox
1 5
Pred..t use±_
Alga ecide/Biocide
1.6
Distributor's Name:
BlueGreen Water Technologies Ltd_
1 7
❑istributor'sAddri
3/15 Kachal Street, Tzur Hadassah 9987500 Israel
1_a
EmergercyPhone[
CHEMTEL+1 800 255-3924
1_0
as,.ess Phone J Fax r Email
Tel: -972 2 630-1166 / Fax: [phone] / Email: info b techs.com
BlueGreen Points of Contact:
Dr. Jessica Frost (Project Manager); c: 941.224.2218;
e:jessica.frost(L-bbluegreenwatertech.com
Mike Pelz (Project Contract Manager); c: 828.384.5146;
e: mike. pelz(obluegreenwatertech.com
Applicator Points of Contact:
TBD once permit approval is attained
USFWS Mattamuskeet National Wildlife Refuge Point of Contact:
- Kendall Smith (Refuge Manager); c: 252.473.0241; e: kendall_smith(a fws.gov
North Carolina Department of Environmental Quality Point of Contact
- Julie Grzyb, Deputy Director; p: Office: [phone] 1 Cell: [phone];
e: iulie.grzyb([e-mail]
Hyde County Department of Health
- 1151 Main St., Swanquarter, North Carolina, 27885; p: 252.926.4399
Emergency Hospitals
- Engelhard Medical Center (open 0800-1700)
33270 US-264, Engelhard, North Carolina, 27824; p: 252.925.7000
- Washington Regional Medical Center (open 24 hours)
14

958 US-64, Plymouth, North Carolina, 27962; p: 252.793.4135
3) Pesticide monitoring schedules and procedures.
a. The process for determining the location of any monitoring.
Lake Mattamuskeet will be monitored by a combination of in situ measurements, remote
satellite -based analytics, and monthly water quality sampling prior to mitigating
cyanobacteria. High frequency, approximately daily, water quality sampling monitoring will
be conducted immediately following treatment by resumption of twice monthly sampling for
the summer after treatment and monthly monitoring for fall and winter.
b. A schedule for monitoring.
Ongoing continuous, with the finest resolution of data collection occurring every 30 seconds via
in situ measurements.
c. The person (or title) responsible for conducting monitoring.
Dr. Jessica Frost — BlueGreen US Scientific Director
d. Procedures for documenting any observed impacts to non -target organisms resulting from
pesticide application/discharge.
Formal Report will be issued by Dr. Jessica Frost
5. Signature Requirements
Operators must sign, date, and certify the PDMP.
Certification Statement: "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 gathered and evaluated the
information contained therein. Based on my inquiry of the person or persons who
manage the system, or those persons directly responsible for gathering the information,
the information contained 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 knowing violations."
Authorized Person Signature:
Date: _Aug. 29,2023
15