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fiti«.Vui'.W»ly» » r»i j . . ; !-J ., b: 06-'--:- -' \ . : . ; - - -June 10,2002Mr. John TaceloskyPennsylvania Dept of AgricultureLand Recycling & Env. Remediation Program2301 N.Cameron St.Harrisburg, PA 17117-9408Dear John:We only recently learned of the proposed rules for Pennsylvania's Agricultural Chemical SiteRemediation Program. Although we understand that the formal comment period has passed, I wouldlike to provide you with our viewpoint on the proposed regulations.It was encouraging to learn that implementing regulations had been proposed for the Ag-chemical SiteRemediation bill which was passed several years ago. Several other states have put similar programsin place that permit the land spreading of soils contaminated with agricultural chemicals. Theseprograms are well received and appear to offer a "win-win" solution for both the owner of the site andfor the state as a solution to the problem of contaminated agricultural chemical dealer sites.In reading Pennsylvania's proposed regulations, I am concerned that they may not be as "user friendly"as those of other states. Consequently the programrisksbeing underutilized, or possibly not utilized atall.As an example, the proposed rules require "detailed analysis" that fully characterizes the physicalproperties and chemical composition of each type of waste that may ever have been present. This is astringent and expensive requirement that could easily exceed the logical responsibility of the businessowner who wishes to clean up a mixing/loading site. This type of requirement is not likely to attractmany participants especially in today's depressed agricultural economic environment I believe theproposal would be better received if it were to focus only on agricultural chemicals that were handled onthe site in significant quantities within the past five or ten years.In a similar vein, the proposed rule would prohibit grazing on any land to which soil or groundwater froma remediated site had been applied. While this may be an appropriate safeguard in some cases, itignores the fact that many agricultural chemicals have meat and milk tolerances established by the USEPA. It seems inconsistent to allow grazing on land that is routinely treated with an agriculturalchemical labeled for that crop & site, but to disallow grazing on land to which soil or water containingthe same chemical has been applied.The proposed rules may be seen by some potential participants as unreasonably intrusive. Forexample, they require the landowner where remediated soils or water are to be applied to provideirrevocable written consent for entry on his or her property by agents of the Commonwealth. This is anappropriate requirement, but not necessarily so in such an unlimited capacity. The consent to enter thetreated properly should not be carte blanche, but should be limited to the inspection of land or recordsassociated with the remediation process.In general, the proposed rules do not appear to take into consideration the extraordinary health andsafety database that supports the use of agricultural chemicals. Because these materials are so

Page 2June 10,2002thoroughly studied, it is not a difficult task to establish safe or permissible levels for residues of thesematerials in a variety of media. There is no similar database to facilitate establishing such levels for themajority of industrial non-agricultural chemicals.I believe some of the apparent shortcomings of the proposed regulations are because they aresubordinate to the Department of Environmental Protection's Solid Waste Management ActMoreover, that act may appear to be a bit onerous to small agricultural chemical businesses.This leads to another aspect of the proposed rules that I am afraid will limit their usefulness. As written,it appears that anyone wishing to avail themselves of the program would be required to pursue permitsfrom at least two state agencies (Agriculture & DEP) and possibly more. Given the independent natureof farmers and small businessmen, this requirement may be seen as a disincentive to participation.It was our hope that the original legislation would allow an exemption from the Solid WasteManagement Act for such small agricultural chemical businesses. Under this exemption the StateDepartment of Agriculture would craft regulations specific to the remediation of agricultural chemicalcontamination at dealer sites that were consistent with the goals of the Solid Waste Management Act.In ail fairness, John, I am not familiar with Pennsylvania's Solid Waste Remediation Act, and I may bemissing some important elements as I write these comments. Nonetheless, I think we can all agreethat the most preferred scenario is for the state to provide a mechanism whereby well intentionedbusinessmen are encouraged to apply for assistance to remediate any contamination that may bepresent on their site as a result of their prior activities. Properly executed, such an approach will servethe best interests of Pennsylvania's agricultural industry and the citizens of the state.Sincerely,Robert B. FugittGovernmental Affairs ManagerDuPont Crop ProtectionCC:The Honorable Michael L. Waugh, ChairmanCommittee on Agriculture and Rural AffairsThe Honorable Michael A. O'Pake, Minority ChairmanCommittee on Agriculture and Rural AffairsThe Honorable Raymond J. Bunt Jr., ChairmanAgriculture and Rural AffairsThe Honorable Peter J. Daily, Democratic ChairmanAgriculture and Rural AffairsJohn R. McGinley, Jr., ChairmanIndependent Regulatory Review Commission

ORIGINAL:2267syngentaDavid FlakneState Government Relations ManagerSyngenta Crop Protection22 Bishops Hill CircleMadison, WI 53717Tel:608-831-8599Fax:608-831-8990Mobile: 336-255-0322da ve. fl akn e@syngenta. comJune 4, 2002To: John NikoloffFrom: David FlakneSubject: Comments on PA Land Application Rule.Below you will find my comments on the Department of Agriculture's proposal toestablish Chapter 130d, relating to application of soil and groundwater contaminated withagricultural chemicals to agricultural lands.I am very concerned that, as written, the rule will effectively prevent land-spreading frombeing a viable option for most facilities. Agricultural chemicals are unique. They havebeen thoroughly studied and have been determined to be safe when apply to agriculturallands at labeled rates. The legislature recognized this and has provided the departmentwith the authority to facilitate the process of landspreading. The language as writtencomplicates a very simple and scientifically defensible approach to cleaning upagrichemical facilities. By having to sample for everything under the sun at thesefacilities the process can be effectively stopped due to an insignificant finding of someother chemical. My comments on the rule itself are below.PROPOSED RULEMAKINGDEPARTMENT OF AGRICULTURE[7 PA. CODE CH. 13Od]Application of Soil and Groundwater Contaminated with AgriculturalChemicals to Agricultural Lands[32 Pa.B. 1965]The Department of Agriculture (Department), under the specificauthority conferred by section 904(d) of the Land Recycling andEnvironmental Remediation Standards Act (act) (35 P. S. § 6026.904(d)),proposes to establish Chapter 13Od (relating to application of soil andgroundwater contaminated with agricultural chemicals to agriculturallands). Section 904(d) of the act delineates the duties of theDepartment and directs the Department to '. . . promulgate regulationsproviding for the option of safely reusing soil and groundwatercontaminated with agricultural chemicals generated as a result ofremediation activities at agricultural chemical facilities through theland application of these materials on agricultural lands.11 Theregulations are required to ''. . , provide for the appropriateapplication rates of such materials,either alone or in the combinationwith other agricultural chemicals,and prescribe appropriate operations

controls and practices to protect the public health, safety and welfareand the environment at the site of land application. 'The proposed regulations specify general procedures and rules forpersons who solicit or receive approval from the Department to applysoil or groundwater contaminated with agricultural chemicals, generatedas a result of remediation activities at agricultural chemicalfacilities, to agricultural land. These proposed regulations apply onlyto the application of soil or groundwater contaminated withagricultural chemicals, generated as a result of remediationactivities, at agricultural chemical facilities and applied toagricultural lands. The Department has no power to issue final approvalfor the land application of contaminated soil or groundwator generatedQO the result of remediation activities that wore undertaken at anagricultural chemical facility,—whore the ooil or groundwater iocontaminated (Contaminated may be the operative term here. Is rueredetection constitute contaminated. If so you will never be abl e tclandspread under this rule because you will always be able to detectsomething else . May need to add language as to significance see below)with chemicals or oubotancco -other than agricultural chemicals. TheDepartment will not approve the land application of soil or groundwatercontaminated with chemicals other than agricultural chemicals. Wherethe contaminated soil or groundwater contains s igrii ficant levels ofchemicals or substances other than agricultural chemicals, the P tlD D*L wiJ-i JdS with the other applicant must receive approval forland application ofchcmioalo or substances from the appropriateregulatory agenciesy to insure that insignificant levels or backgroundlevels of detected compounds do not prevent the use of the landa ELy- a5ion provisions provided for in the rule or the act. &Emustprocccd under the alternative provisions of the act,—whichJrReJrudcholding the ooii and groundwatcr onsitc under the regulationsrcgardingonoitc storage of waste or processing the ooil and groundwaterin amannor consistent with the type of waoto contained in the ooil pileorgroundwater. The applicant may be is responsible for obtaining theafty additionalpcrmito or approvals necessary for the application of the contaminatedmedia which contain significant levels of contaminants other than . L L L L chemicals. The Department hag no power to ioouc finalapproval for the landapplication of contaminated ooil or groundwatorthat was generated ao the rcoult of remediation activities that werenot undertaken at an agricultural chemical facility or where thecontaminated -soil or groundwatcr will bo applied to land other thanagricultural land.BackgroundThe act requires the Department to promulgate regulations providing forthe option of safely reusing soil and groundwater contaminated withagricultural chemicals generated as a result of remediation activitiesat agricultural chemical facilities through the land application ofthese materials on agricultural lands. The Department takes veryseriously its duty to protect the health and safety of the generalpublic and to preserve the quality and productivity of agriculturallands in this Commonwealth. These proposed regulations are intended toaddress the safety of the application of soil and groundwatercontaminated agricultural chemicals and to protect and assure theproductivity and viability of the agricultural lands to which thismedia is applied. In addition, the Department of EnvironmentalProtection, under the Solid Waste Management Act (35 P. S. §§ 6018.101-6018.1003) has regulations in place concerning the land application of

residual waste in 25 Pa. Code Chapter 291 (relating to land applicationof residual waste),including regulations specifically regardingapplication to agricultural land in 25 Pa. Code Chapter 291, SubchapterD (relating to additional requirements for the agricultural utilizationof residual waste).1'Residual waste1' as defined by the Solid Waste Management Actincludes agricultural waste. The act does not exempt the application ofsoil and groundwater contaminated with agricultural chemicals toagricultural lands, from the regulations promulgated under the SolidWaste Management Act. Therefore, the Department has endeavored toassure these regulations are consistent with the residual wasteregulations pertaining to application of residual waste to agriculturalland.In the interest of carrying out its statutory duties and providing asafe alternative use for soil and groundwater contaminated withagricultural chemicals the Department has promulgated these proposedregulations. The regulations are intended to establish safe standards,criteria and procedures for the application of the contaminated mediato agricultural lands . (Where are the standards. Jhey should be labeIedapplication rate based standards for soil containing agriculturalchemical s)Summary of Major FeaturesSection 130d.l (relating to definitions) defines various terms to addclarity to the regulations. Although many of the terms are also definedin the act and the Pennsylvania Pesticide Control Act of 1973 (3 P. S.§§ lll.21--ili.61), the Department included them in the proposedregulations to provide the regulated community and interested personswith easy and immediate access to definitions which clarify theregulations.Section 130d.2 (relating to scope) details the narrow scope of theDepartment's authority, sets forth the Department's powers and dutiesand clarifies the type of contaminated material eligible forconsideration to be applied to farm lands under the act and theproposed regulations.Section 130d.3 (relating to continuing authority) delineates the intentthat these proposed regulations do not amend, repeal or modify theprovisions of any other act or the regulations promulgated there underand denotes the continuing authority of the Department to takeregulatory action under those statutes.Section 130d.ll (relating to scope) sets forth the requirement thatpersons receiving approval to apply soil and groundwater contaminatedwith agricultural chemicals shall comply with the act, the regulationsand the environmental protection acts.Section 130d.l2 (relating to reports) establishes the duty ofapplicators to file annual and final reports with the Department andsets forth the information which shall be contained in the reports.Section 130d.13 (relating to chemical analysis of waste) creates therequirement for the detailed chemical analysis of soil and groundwatertaken from the agricultural chemical facility and sought to be appliedto agricultural lands. It defines the type of analysis that shall bedone and sets forth testing requirements and protocols.Section 130d.l4 (relating to waste analysis plan) delineates therequirements for a waste analysis plan and what shall be included inthat plan.

Section 130d.l5 (relating to application site analysis) establishes therequirement for an application site analysis and sets forth thecriteriafor and procedures to be used in analyzing the site.Section 130d.l6 (relating to retained recordkeeping) details whichrecords shall be retained and the retention time for the records.Section 130d.l7 (relating to public notice by applicant) denotes therequirement to comply with the notice provisions of the PennsylvaniaPesticide Control Act.Section l30d.21 (relating to general requirements for land applicationproposal form) sets forth the requirements for submittal and delineatesthe documentation, information and affirmations which shall becontained in the application proposal.Section l30d.22 (relating to insurance) establishes the insurancerequirements for persons seeking to apply soil and groundwatercontaminated with agricultural chemicals to agricultural lands.Section 130d.23 (relating to right of entry and agreement withlandowner) sets forth the requirements that the person seeking to applysoil and groundwater contaminated with agricultural chemicals toagricultural lands shall submit documents establishing their right toenter onto the land upon which the agricultural chemicals will beapplied and a signed consent agreement. In addition, the landownershall sign a form, prepared by the Department, authorizing theDepartment or its agents to enter onto the land.Section l30d.24 (relating to identification of interest) details thetype of information pertaining to the applicant which shall becontained in the land application proposal.Section 130d.25 (relating to compliance information) the landapplication proposal shall contain proof that the proposed applicationwill comply with the applicable Federal, State and local laws andregulations.Section 130d.26 (relating to environmental assessment) sets forth therequirement for an environmental assessment to be included in the landapplication proposal. It delineates the criteria for the environmentalassessment, including detailing the potential impact of the applicationof the soil and groundwater contaminated agricultural chemicals to theapplication site, potential harmful effects of the application and amitigation plan.Section 130d.31 (relating to criteria for approval and denial)establishes the criteria the Department will use and follow inevaluating a land application proposal.Section 13 0d.32 (relating to receipt of land application proposal andcompleteness review) delineates the criteria to determine date ofreceipt and completeness of a land application proposal.Section 130d.33 (relating to review period) establishes a time periodfor Department review of an administratively complete land applicationproposal and sets forth the procedures and process to be followed uponreceipt of an incomplete land application proposal.Section l30d.34 (relating to review process) sets forth the processwhich the Department will follow in reviewing land applicationproposals.Section 130d.41 (relating to general) details terms, conditions andcriteria which shall be met before, during and subsequent to landapplication of soil and groundwater contaminated with agriculturalchemicals.Section 130d.42 (relating to operating plan) sets forth the information

which shall be included in the operating plan.Section 13 0d.43 (relating to maps and related information) delineatesthe type of maps which shall be included in the land applicationproposal and the information which those maps shall contain.Section 130d.51 (relating to general requirements) sets forth thegeneral requirements for applying to the Department to use groundwatercontaminated with agricultural chemicals as tank mix. It establishesthe review procedures and delineates ongoing testing and cancellationrequirements.Section l3 0d.52 (relating to general exceptions) establishes thestandards the Department will follow in determining whether groundwatercontaminated with agricultural chemicals can be utilized as tank mix.In additiony delineates the Department's authority to waive certainother provisions of the proposed regulations, when the Departmentdetermines the groundwater contaminated with agricultural chemicals canbe used as tank mix. It also sets forth certain provisions of theproposed regulations that will not be waived by the Department.Section 13 0d.61 (relating to general provisions) sets forth the overallcompliance criteria for application of the soil and groundwatercontaminated with agricultural chemicals.Section 130d.62 (relating to standards for land application of soil andgroundwater contaminated with agricultural chemicals) delineates thegeneral criteria and standards that shall be accounted for and compliedwith when applying soil and groundwater contaminated with agriculturalchemicals to agricultural lands.Section 130d.63 (relating to land application rates and procedures)establishes application rates and procedures which shall be followedwhen applying soil and groundwater contaminated with agriculturalchemical's to agricultural lands.Section 130d.64 (relating to additional application requirements) setsforth some additional information that shall be contained in theoperating plan, such as a projected 3-year crop rotation plan andinformation regarding any additional pesticides or fertilizers thatwill be placed on the application site.Section 130d»65 (relating to limitations on land application of soiland groundwater contaminated with agricultural chemicals) delineatescriteria and factors which shall be included in and accounted for inthe applicant's operating plan. The Department will consider thesecriteria and factors in its review of the applicant's land applicationproposal. These criteria and factors establish limitations on how soiland groundwater contaminated with agricultural chemicals shall beapplied to agricultural lands.Section 130d.66 (relating to prohibited applications) establishesprohibitions on the application of soil and groundwater contaminatedwith agricultural chemicals to agricultural lands.Section 130d.67 (relating to nuisance minimization and control)establishes requirement for an approved applicant to minimize potentialnuisances.Section 130d.68 (relating to daily operational records) establishes therequirement to keep daily operational records during the application ofthe soil and groundwater contaminated with agricultural chemicals toagricultural lands and defines the information which shall be includedin those records.Section l30d.69 (relating to annual operational report) establishes therequirement to produce an annual operational report and defines theinformation which shall be included in that report.Section 130d.71 (relating to site closure plan) establishes the

requirement for a site closure plan and delineates what that plan shallinclude.Section 130d.72 (relating to final report) establishes the requirementfor a final report and the criteria for what shall be included in thatreport.Fiscal ImpactCommonwea1thThe proposed regulations will impose additional administrative costsand have some fiscal impact upon the Commonwealth. The proposedregulations will require the Department to commit a substantial amountof time and manpower to review of applications and inspections ofapplication sites.Political SubdivisionsThe proposed regulations will impose no costs and have no fiscal impactupon political subdivisions. The proposed regulations do not impose anyadditional burden of enforcement of review on political subdivisions.Private SectorFor the most part the proposed regulations will impose minimal or nocosts on the private sector. Companies wishing to apply soil andgroundwater contaminated with agricultural chemicals, generated as theresult of remediation activities undertaken at an agriculturalfacility, to agricultural lands will have to bear the costs of testingimposed by the regulations and the time and manpower costs of preparingthe land application proposal. However, proceeding under the proposedregulations is not mandatory. The industry has other approved methodsof disposing of soil and groundwater contaminated with agriculturalchemicals, all of which impose costs on the industry. The industryseeking to proceed under the alternative presented by the act and theseproposed regulations will have to determine whether or not it is theleast cost alternative or is the best approach for them. The privatesector will benefit through an alternative means of disposal, theliability protections for the remediated site in the act and theability to utilize the land at the remediated site.General PublicThe proposed regulations will impose no costs and have no fiscal impacton the general public. The general public will benefit through analternative means of disposal of contaminated soil and groundwater andthe ability to utilize what was once a contaminated ''brownfields''site. The owner of the agricultural land upon which the contaminatedsoil and groundwater will be applied will have to weigh the benefitsoffered by the company seeking to apply the contaminated soil andgroundwater against any potential harm the application could pose tothe productivity of the agricultural land.Paperwork RequirementsThe proposed regulations may result in a substantial increase ofpaperwork. The Department will have to develop application forms andreview complicated proposals. The review and approval will have to bedone by experienced Department staff and Department chiefs withexpertise in the fields covered by the regulations.Public Comment Period

Interested persons are invited to submit written comments regarding theproposed regulations within 30 days following publication in thePennsylvania Bulletin.Regulatory ReviewUnder section 5(a) of the Regulatory Review Act (71 P. S. § 745.5(a)),on April 10, 2002, the Department submitted a copy of this proposedrulemaking to the Independent Regulatory Review Commission (IRRC) andthe Chairpersons of the House Agriculture and Rural Affairs Committeeand the Senate Agriculture and Rural Affairs Committee. In addition tosubmitting the proposed rulemaking, the Department has provided IRRCand the Committees with a copy of a detailed Regulatory Analysis Formprepared by the Department in compliance with Executive Order 1996-1,1'Regulatory Review and Promulgation. ' A copy of this material isavailable to the public upon request.Under section 5(g) of the Regulatory Review Act, if IRRC has objectionsto any portion of the proposed rulemaking, it will notify theDepartment within 3 0 days of the close of the Committees' reviewperiod. The notification shall specify the regulatory review criteriathat have not been met by the portion of the proposed rulemaking towhich an objection is made. The Regulatory Review Act specifiesdetailed procedures for review, prior to final publication of therulemaking, by the Department, the General Assembly and the Governor ofobjections raised.Contact PersonFurther information is available by contacting the Department ofAgriculture, Land Recycling and Environmental Remediation StandardsProgram, 2301 North Cameron Street, Harrisburg, PA 17110-9408; Attn:John Tacelosky, (717) 772-5217.Effective DateThis proposed regulations will be effective upon final-form publicationin the Pennsylvania Bulletin.SAMUEL E. HAYES, Jr., SecretaryFiscal Note: 2-116. (1) General Fund; (2) Implementing Year 2001-02 is 0; (3) 1st Succeeding Year 2002-03 is 50,000; 2nd Succeeding Year2003-04 is 53,000; 3rd Succeeding Year 2004-05 is 55,000; 4thSucceeding Year 2005-06 is 57,000; 5th Succeeding Year 2006-07 is 60,000; (4) 2000-01 Program-- n/a; 1999-00 Program-- n/a;1998-99-- n/a; (7) General Government Operations; (8) recommendsadoption.Annex ATITLE 7. AGRICULTUREPART V. BUREAU OF PLANT INDUSTRYCHAPTER 130d. APPLICATION OF SOIL AND GROUNDWATER CONTAMINATED WITHAGRICULTURAL CHEMICALS TO AGRICULTURAL LANDSSubch.A.GENERAL PROVISIONSB.DUTIES OF APPLICATORSC.GENERAL REQUIREMENTS FOR PERMISSION TO APPLY SOIL ANDGROUNDWATER CONTAMINATED WITH AGRICULTURAL CHEMICALS TO AGRICULTURALLANDD.LAND PROPOSAL REVIEW PROCEDURESE.GENERAL REQUIREMENTS FOR LAND APPLICATION OF SOIL ANDGROUNDWATER CONTAMINATED WITH AGRICULTURAL CHEMICALSF.GENERAL REQUIREMENTS AND EXCEPTIONS FOR USE AND APPLICATION OF

GROUNDWATER CONTAMINATED WITH AGRICULTURAL CHEMICALS AS TANK MIXG.GENERAL OPERATING REQUIREMENTS FOR LAND APPLICATION OF SOIL ANDGROUNDWATER CONTAMINATED WITH AGRICULTURAL CHEMICALSH.CLOSURESubchapter A. GENERAL .3.Continuing authority.§ 130d.l. Definitions.The following words and terms, when used in this chapter, have thefollowing meanings, unless the context clearly indicates otherwise:Act--The Land Recycling and Environmental Remediation Standards Act (35P. S. §§ 6026.101--6026.908).Active ingredient-(i) In the case of a pesticide other than a plant regulator, defoliantor desiccant, an ingredient which will prevent, destroy, repel ormitigate any pest.(ii) In the case of a plant regulator, an ingredient which, throughphysiological action, will accelerate or retard the rate of growth orrate of maturation or otherwise alter the behavior of ornamental orcrop plants or the product thereof.(iii) In the case of a defoliant, an ingredient which will cause theleaves or foliage to drop from a plant.(iv) in the case of a desiccant, an ingredient which will artificiallyaccelerate the drying of plant tissue.Agricultural chemical--A substance defined as a fertilizer, soilconditioner or plant growth substance under 3 Pa.C.S. Chapter 67(relating to fertilizer) or a substance regulated under thePennsylvania Pesticide Control Act of 1973 (3 P. S. §§ 111.21--111.60).Agricultural chemical facility--A facility where agricultural chemicalsare held, stored, blended, formulated, sold or distributed (we may want.tP .rj]li2S jL Lo ded/. and/or transported." This should then allow thedepartment to address spills in or adjacent to fields or anytransportation spills to and from the field, .The term does not include facilities identified by SIC 28 79 (availablefrom the Department of Agriculture, Bureau of Market Development, 2301N. Cameron St., Harrisburg, PA 17110, (717) 787-6041) whereagricultural chemicals are manufactured.Agricultural land or farmland--Land in this Commonwealth that iscapable of supporting the commercial production of agricultural crops,livestock or livestock products, poultry products, milk or dairyproducts, fruit or other horticultural products.Animal--All vertebrate and invertebrate species, including man andother mammals, birds, fish and shellfish.Application site--The farmland area approved to receive an applicationof soil or groundwater contaminated with agricultural chemicals anddelineated in a final plan containing and detailing the exact locationof the farmland upon which the soil or groundwater contaminated withthe agricultural chemicals is to be applied, including the propertyboundaries of the farmland and each field upon which the contaminatedsoil or groundwater will be applied.Applicator--A certified applicator, private applicator, commercialapplicator or public applicator.(i) Certified applicator. An individual wh

Oct 02, 2006 · fiti«.Vui'.W»l y i j.» » r» ;!-J ., b: 06 June 10,2002 Mr. John Tacelosky Pennsylvania Dept of Agriculture Land Re

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