&EPA
United States
Environmental Protection
Agency
Enforcement and
Compliance Assurance
(2221-A)
EPA310-R-00-001
September 2000
Profile of the Agricultural
Crop Production Industry
'A
32nl
EPA Office of Compliance Sector Notebook Project
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Agricultural Crop Production Industry
Sector Notebook Project
EPA/310-R-00-001
EPA Office of Compliance Sector Notebook Project
Profile of the Agricultural Crop Production Industry
September 2000
U.S. Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Avenue, NW
Washington, DC 20460
For sale by the Superintendent of Documents, U.S. Government Printing Office
Internet: bookstore.gpo.gov Phone: (202) 512-1800 Fax: (202) 512-2250
Mail: Stop SSOP, Washington, DC 20402-0001
ISBN 0-16-050742-1
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Agricultural Crop Production Industry
General Information
GENERAL INFORMATION
This report is one in a series of volumes published by the U.S. Environmental Protection Agency
(EPA) to provide information of general interest regarding environmental issues associated with
specific industrial sectors. The documents were developed under contract by GeoLogics Corporation
(Alexandria, VA), Abt Associates (Cambridge, MA), Science Applications International Corporation
(McLean, VA), and Booz-Allen & Hamilton, Inc. (McLean, VA). A listing of available Sector
Notebooks is included on the following page.
Obtaining copies:
Electronic versions of all sector notebooks are available via Internet on the Enviro$en$e World
Wide Web at www.epa.gov/oeca/sector. Enviro$en$e is alfree, public, environmental exchange
system operated by EPA's Office of Enforcement and Compliance Assurance and Office of Research
and Development. The Network allows regulators, the regulated community, technical experts, and
the general public to share information regarding: pollution prevention and innovative technologies;
environmental enforcement and compliance assistance; laws, executive orders, regulations, and
policies; points of contact for services and equipment; and other related topics. The Network
welcomes receipt of environmental messages, information, and data from any public or private
person or organization. Direct technical questions to the "Feedback" button on the bottom of the
web page.
Purchase printed bound copies from the Government Printing Office (GPO) by consulting the
order form at the back of this document or order via the Internet by visiting the on-line GPO Sales
Product Catalog-at http://orders.access.gpo.gov/su_docs/sale/prf/prf.html. Search using the exact
title of the document "Profile of the XXXX Industry" or simply "Sector Notebook." When ordering,
use the GPO document number found on the order form at the back of this document.
Complimentary volumes are available to certain groups or subscribers, including public and
academic libraries; federal, state, tribal, and local governments; and the media from EPA's National-
Service Center for Environmental Publications at (800) 490-9198. When ordering, use the EPA
publication number found on the following page.
The Sector Notebooks were developed by the EPA's Office of Compliance. Direct general questions
about the Sector Notebook Project to:
Seth Heminway, Coordinator, Sector Notebook Project
US EPA Office of Compliance
Ariel Rios Building
1200 Pennsylvania Avenue, NW
Washington, DC 20460
(202)564-7017
For further information, and for answers to questions pertaining to these documents, please refer to
the contact names listed on the following page.
Sector Notebook Project
September 2000
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Agricultural Crop Production Industry
Table of Contents
SECTOR NOTEBOOK CONTACTS
Questions and comments regarding the individual documents should be directed to the specialists
listed below. See the Notebook web page at: www.epa.gov/oeca/sector for the most recent titles
and staff contacts. •
EPA Publication
Number
EPA/310-R-95-001.
EPA/310-R-95-002.
EPA/310-R-95-003.
EPA/310-R-95-004.
EPA/310-R-95-005.
EPA/310-R-95-006.
EPA/310-R-95-007.
EPA/310-R-95-008.
EPA/310-R-95-009.
EPA/310-R-95-010.
EPA/310-R-95-011.
EPA/310-R-95-012.
EPA/310-R-95-013.
EPA/310-R-95-014.
EPA/310-R-95-015.
EPA/310-R-95-016.
EPA/310-R-95-017.
EPA/310-R-95-018.
EPA/310-R-97-001.
EPA/310-R-97-002.
EPA/310-R-97-003.
EPA/310-R-97-004.
EPA/310-R-97-005.
EPA/310-R-97-006.
EPA/310-R-97-007.
EPA/310-R-
EPA/310-R-
EPA/310-R-
EPA/310-R-
EPA/310-R-
EPA/310-R-
EPA/310-R-
•97-008.
•97-009.
•97-010.
•98-001.
•99-006.
00-001.
00-002.
EPA/310-R-00-003.
Industry
Profile of the Dry Cleaning Industry
Profile of the Electronics and Computer Industry*
Profile of the Wood Furniture and Fixtures Industry
Profile of the Inorganic Chemical Industry*
Profile of the Iron and Steel Industry
Profile of the Lumber and Wood Products Industry
Profile of the Fabricated Metal Products Industry*
Profile of the Metal Mining Industry
Profile of the Motor Vehicle Assembly Industry
Profile of the Nonferrous Metals Industry
Profile of the Non-Fuel, Non-Metal Mining Industry
Profile of the Organic Chemical Industry *
Profile of the Petroleum Refining Industry
Profile of the Printing Industry
Profile of the Pulp and Paper Industry
Profile of the Rubber and Plastic Industry
Profile of the Stone, Clay, Glass, and Concrete Ind.
Profile of the Transportation Equipment Cleaning Ind.
Profile of the Air Transportation Industry
Profile of the Ground Transportation Industry
Profile of the Water Transportation Industry
Profile of the Metal Casting Industry
Profile of the Pharmaceuticals Industry
Profile of the Plastic Resin and Man-made Fiber Ind.
Profile of the Fossil Fuel Electric Power Generation
Industry
Profile of the Shipbuilding and Repair Industry
Profile of the Textile Industry
Sector Notebook Data Refresh-1997 **
Profile of the Aerospace Industry
Profile of the Oil and Gas Extraction Industry
Profile of the Agricultural Crop Production Industry
Profile of the Agricultural Livestock Production
Industry
Profile of the Agricultural Chemical, Pesticide and
Fertilizer Industry
Contact
Joyce Chandler
Steve Hoover
Bob Marshall
Walter DeRieux
• Maria Malave
Seth Heminway
Scott Throwe
Maria Malave
Anthony Raia
Debbie Thomas
Rob Lischinsky
Walter DeRieux
TomRipp '
Ginger Gotliffe
Seth Heminway
Scott Throwe
Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Steve Hoover
Emily Chow
Sally Sasnett
Rafael Sanchez
Anthony Raia
Seth Heminway
Anthony Raia
Dan Chadwick
Ginah Mortensen
Phone
202-564-7073
202-564-7007
202-564-7021
202-564-7067
202-564-7027
202-564-7017
202-564-7013
202-564-5027
202-564-6045
202-564-5041
202-564-2628
202-564-7067
202-564-7003
202-564-7072
202-564-7017
202-564-2310
202-564-7013
202-564-7057
202-564-7057
202-564-7057
202-564-7057
202-564-7007
202-564-7071
202-564-7074
202-564-
202-564-
202-564-
202-564-
202-564-
202-564-
913-551-
7028
6045
2310
7017
6045
7054
5211
Ginah Mortensen 913-551-5211
Michelle Yaras 202-564-4153
Government Series
EPA/310-R-99-001. Profile of Local Government Operations
202-564-2310
* Spanish translations available.
** This document revises compliance, enforcement, and toxic release inventory data for all profiles published in 1995.
Sector Notebook Project
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Agricultural Crop Prpduction Industry
Table of Contents
Table of Contents
LIST OF EXHIBITS v
LIST OF ACRONYMS vi
I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT 1
LA. Summary of the Sector Notebook Project 1
IB. Additional Information 2
E. INTRODUCTION TO THE AGRICULTURAL PRODUCTION INDUSTRIES: CROPS,
GREENHOUSES/NURSERIES, AND FORESTRY 3
II. A. General Overview of Agricultural Establishments 4
H.B. Characterization of the Crop Production Industry ... 8
H.B.1. Oilseed and Grain 10
II.B.2. Vegetables and Melons 11
E.B.3. Fruit and Tree Nuts . 11
H.B.4. Other Crops 12
E.G. Characterization of the Greenhouse, Nursery, and Floriculture
Production Industry 13
II.D. Characterization of the Forestry Production Industry 15
II.D.1. Definition of Forest Land '. ' 15
II.D.2. Consumption and Regeneration of Forest Products 18
II.E. Geographic Distribution and Economic Trends 19
IE. SUMMARY OF OPERATIONS, IMPACTS, AND POLLUTION PREVENTION
OPPORTUNITIES FOR THE AGRICULTURAL PRODUCTION INDUSTRIES:
CROPS, GREENHOUSES/NURSERIES, AND FORESTRY 21
ffl.A. Crop Production: Operations, Impacts, and Pollution Prevention Opportunities 25
HI.A.1. Preparing the Site/Soil for Crops 27
ELA.2. Planting/Tending Crops - 32
m.A.3. Applying Nutrients to Crops 33
m.A.4. Applying Pesticides and Pest Control 36
IE.A.5. Irrigating Crops 43
ffl.A.6. Harvesting Crops and Post-Harvesting Activities 47
HI. A.7. Maintaining and Repairing Agricultural Machinery
and Vehicles 49
in.A.8. Fuel Use and Fueling Activities 52
m.A.9. Maintaining the Facility • • • • 53
ELB. Greenhouses and Nurseries: Operations, Impacts, and Pollution Prevention
Opportunities 56
III.B.l. Preparing the Soil/Growing Media for Horticulture Crops 58
HI.B.2. Planting Horticulture Crops 60
HI.B.3. Applying Nutrients to Horticulture Crops 60
III.B.4. Applying Pesticides and Pest Control for Horticulture Crops 62
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Table of Contents
O.B.5. Irrigating Horticulture Crops 63
m.B.6. Tending and Harvesting Horticulture Crops 65
IH.B.7. Constructing and Maintaining Greenhouses • 66
m.B.8. Packaging, Loading, and Transporting Products 67
DI.B.9. Maintaining and Repairing Machinery and Vehicles at
Greenhouses/Nurseries 67
m.B.lO. Fuel Use and Fueling Activities at Greenhouses/Nurseries 68
EI.C. Forestry Production Industry: Operations, Impacts, and Pollution Prevention
Opportunities : 69
DI.C.1. Road Construction and Use 71
m.C.2. Timber Harvesting 75
ELC.3. Site Preparation 80
IH.C.4. Forest Regeneration 82
m.C.5. Prescribed Burning 83
m.C.6. Application of Chemicals 86
IV. SUMMARY OF APPLICABLE FEDERAL STATUTES AND REGULATIONS ... 89
IV.A. General Description of Major Statutes . 89
rV.B. Industry-Specific Requirements for the Agricultural Production Industries:
Crops, Greenhouses/Nurseries, and Forestry 107
IV.C. Proposed and Pending Regulations .....: 136
V. COMPLIANCE AND ENFORCEMENT HISTORY 139
V.A. Background .' '. 139
V.B. Compliance and Enforcement Profile Description 139
V.C. Compliance History for the Agricultural Production Industries: Crops,
Greenhouses/Nurseries, and Forestry 143
VI. REVIEW OF MAJOR LEGAL ACTIONS 153
VE. COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES 155
VH.A. Sector-Related Environmental Programs and Activities 155
Vlt.B. EPA Programs and Activities , 156
Vn.C. USDA Programs and Activities 160
Vn.D. Other Voluntary Initiatives 164
Vn.E. Summary of Trade Associations , 165
VIE. CONTACTS/RESOURCE MATERIALS/BIBLIOGRAPHY 169
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Agricultural Crop Production Industry
Table of Contents
LIST OF EXHIBITS
1. Agricultural Land Use in the U.S 4
2. Types of Cropland 5
3. . Acreage of Agricultural Establishments in the U.S '. 6
4. Agricultural Establishments by Value of Sales 6
5. Ownership Status of Agricultural Establishments in the U.S 7
6. 1997 NAICS Descriptions for Crop Production (NAICS 111) 8
7. Number of Farms • 9
8. Land in Acres vs. Acres of Harvested Cropland (in millions of acres) 9
9. Percent of Sales by Type of Establishment 10
10. Types of Grain Farms 1°
11. Noncitrus Fruit and Tree Nut Farms 11
12. Total Acres vs. Acres Harvested of Other Crops (in thousands of acres) 12
13. Value of Greenhouse, Nursery, and Floriculture Production Compared to Total Crop
Production • i4
14. Values of Greenhouse, Nursery, and Floriculture Production Sales 14
15. Distribution of U.S. Forested Land Area 16
16. Federal vs. Nonfederal Forest Lands 16
17. Timberland Ownership • 17
18. NFS Timber Sales, FY 1993-1998 • 18
19. Acres Seeded and Acres of Tree Planting (FY 1996) 19
20. Crop Production Activities, Raw Material Inputs, and Pollution Outputs 26
21. Greenhouse and Nursery Production Activities, Raw Material Inputs, and Pollution
Outputs • 57
22. Forestry Production Activities, Raw Material Inputs, and Pollution Outputs 71
23. Five-Year Enforcement and Compliance Summary for the Agricultural Crop
Production Industry • • • • 145
24. Five-Year Enforcement and Compliance Summary for the Forestry
Production Industry • • 146
25. Five-Year Enforcement and Compliance Summary for Selected Industries ..... 149
26. One-Year Enforcement and Compliance Summary for Selected Industries 150
27. Five-Year Inspection and Enforcement Summary by Statute for
Selected Industries 151
28. One-Year Inspection and Enforcement Summary by Statute for
Selected Industries 152
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Agricultural Crop Production Industry
List of Acronyms
LIST OF ACRONYMS
ACM Asbestos-Containing Materials
AFO Animal Feeding Operations
AFPA American Forest Paper Association
AFS AIRS Facility Subsystem (CAA database)
ANSI American National Standards Institute
BIF Boiler and Industrial Furnace
BLM Bureau of Land Management
BMP Best Management Practices
BOD Biochemical Oxygen Demand
Bt Bacillus thuringiensis
CAA Clean Air Act
CAAA Clean Air Act Amendments of 1990
CCAP Climate Change Action Plan
CDA Controlled Droplet Application
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CERCLIS CERCLA Information System (CERCLA database)
CESQG Conditionally Exempt Small Quantity Generator
CFC Chlorofluorocarbon
CFO Conservation Farm Option
CFR Code of Federal Regulations
CNMP Comprehensive Nutrient Management Plan
CPA Conservation Priority Area
CREP Conservation Reserve Enhancement Program
CRP Conservation Reserve Program
CWA Clean Water Act
CWAP Clean Water Action Plan
CZARA Coastal Zone Act Reauthorization Amendments
DOT United States Department of Transportation
DOJ United States Department of Justice
DUN Dun and Bradstreet
EMS Environmental Management Systems
EPA United States Environmental Protection Agency
EPCRA Emergency Planning and Community Right-to-Know Act
EQIP Environmental Quality Incentives Program
ESPP Endangered Species Protection Program
FDA United States Food and Drug Administration
FFDCA Federal Food, Drug and Cosmetic Act
FIFRA Federal Insecticide, Fungicide, and Rodenticide Act
FINDS Facility Indexing System
FQPA Food Quality Protection Act
FR Federal Register
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Agricultural Crop Production Industry
List of Acronyms
LIST OF ACRONYMS (CONTINUED)
FS Forest Service
FSA Farm Service Agency
FWS Fish and Wildlife Service
FY Fiscal Year
GPS Global Positioning System
HAP Hazardous Air Pollutant (CAA)
HSWA Hazardous and Solid Waste Amendments
HUD United States Department of Housing and Urban Development
IDEA Integrated Data for Enforcement Analysis
IPM Integrated Pest Management
ISO International Organization for Standardization
LDR Land Disposal Restrictions (RCRA)
LEPC Local Emergency Planning Committee
LQG Large Quantity Generator
MACT Maximum Achievable Control Technology (CAA)
MCL Maximum Contaminant Level
MCLG Maximum Contaminant Level Goal
MSDS Material Safety Data Sheet
NAAQS National Ambient Air Quality Standards (CAA)
NAICS North American Industrial Classification System
NASS National Agricultural Statistics Service
NCDB National Compliance Database, Office of Prevention, Pesticides and Toxic
Substances
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NICE3 National Industrial Competitiveness Through Energy, Environment, and
Economics
NO A Notice of Arrival
NPS Nonpoint Source Management Program
NESHAP National Emission Standards for Hazardous Air Pollutants
NFS National Forest System
NOAA National Oceanic and Atmospheric Administration
NPDES National Pollutant Discharge Elimination System (CWA)
NPL National Priorities List
NRC National Response Center
NRCS Natural Resources Conservation Service
NSPS New Source Performance Standards (CAA)
OECA Office of Enforcement and Compliance Assurance
- OMB Office of Management and Budget
OSHA Occupational Safety and Health Administration
PCB Polychlorinated Biphenyl
PCS Permit Compliance System
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Agricultural Crop Production Industry
List of Acronyms
LIST OF ACRONYMS (CONTINUED)
PESP Pesticide Environmental Stewardship Program
PMN Premanufacture Notice
POTW Publicly Owned Treatment Works
PWS Public Water Systems
RCRA Resource Conservation and Recovery Act
RCRIS RCRA Information System (RCRA database)
RMP Risk Management Plan
RQ Reportable Quantities
RUP Restricted Use Pesticides
SARA Superfund Amendments and Reauthorization Act
SDWA Safe Drinking Water Act
SEP Supplemental Environmental Project
SERC State Emergency Response Commission
SIC Standard Industrial Classification
SIP State Implementation Plan
SPCC Spill Prevention, Control, and Countermeasure
SQG Small Quantity Generator
TMDL Total Maximum Daily Load
TRI ' Toxic Release Inventory
TRIS Toxics Release Inventory System
TSCA , Toxic Substances Control Act
TSS Total Suspended Solids
UIC Underground Injection Control (SDWA)
USDA U.S. Department of Agriculture
UST Underground Storage Tank (RCRA)
WHIP Wildlife Habitat Incentives Program
WPS Worker Protection Standard Requirements for Users
WRP Wetlands Reserve Program
Sector Notebook Project
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Agricultural Crop Production Industry
Introduction
I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT
I. A. Summary of the Sector Notebook Project
Environmental policies based upon comprehensive analysis of air, water and
land pollution (such as economic sector, and community-based approaches)
are becoming an important supplement to traditional single-media approaches
to environmental protection. Environmental regulatory agencies are beginning
to embrace comprehensive, multi-statute solutions to facility permitting,
compliance assurance, education/outreach, research, and regulatory
development issues. The central concepts driving the new policy direction are
that pollutant releases to each environmental medium (air, water and land)
affect each other, and that environmental strategies must actively identify and
address these interrelationships by designing policies for the "whole" facility.
One way to achieve a whole facility focus is to design environmental policies
addressing all media for similar industrial facilities. By doing so,
environmental concerns that are common to the manufacturing of similar
products can be addressed in a comprehensive manner. Recognition of the
need to develop the industrial "sector-based" approach by the EPA Office of
Compliance led to the creation of this document.
The Sector Notebook Project was initiated by the Office of Compliance within
the Office of Enforcement and Compliance Assurance (OECA) to provide its
staff and managers with summary information for eighteen specific industrial
sectors. As other EPA offices, states, the regulated community, environmental
groups, and the public became interested in this project, the scope of the
original project was expanded. The ability to design comprehensive, common
sense environmental protection measures for specific industries is dependent
on knowledge of several interrelated topics. For the purposes of this project,
the key elements chosen for inclusion are: general industry information
(economic and geographic); a description of industrial processes; pollution
outputs; pollution prevention opportunities; federal statutory and regulatory
framework; compliance history; and a description of partnerships that have
been formed between regulatory agencies, the regulated community and the
public.
For any given industry, each topic listed above alone could be the subject of a
lengthy volume. However, to produce a manageable document, this project
focuses on providing summary information for each topic. This format
provides the reader with a synopsis of each issue, and references where more
in-depth information is available. Text within each profile was researched
from a variety of sources, and was usually condensed from more detailed
sources pertaining to specific topics. This approach allows for a wide
coverage of activities that can be explored further based upon the references
listed at the end of this profile. As a check on the information included, each
Sector Notebook Project
September 2000
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Agricultural Crop Production Industry
Introduction & Background
notebook went through an external document review process. The Office of
Compliance appreciates the .efforts of all those that participated in this process
and enabled us to develop more complete, accurate and up-to-date summaries.
I.B. Additional Information
Providing Comments
OECA's Office of Compliance plans to periodically review and update
notebooks and will make these updates available both in hard copy and
electronically. If you have any comments on the existing notebook, or if you
would like to provide additional information, please send a hard copy and
computer disk to the EPA Office of Compliance, Sector Notebook Project,
401 M St., SW (2223-A), Washington, DC 20460. Comments can also be
sent via the web page.
Adapting Notebooks to Particular Needs
The scope of the industry sector described in this notebook approximates the
relative national occurrence of facility types within the sector. In many
instances, industries within specific geographic regions or states may have
unique characteristics that are not fully captured in these profiles. For this
reason, the Office of Compliance encourages state and local environmental
agencies and other groups to supplement or repackage the information
included in this notebook to include more specific industrial and regulatory
information that may be available. Additionally, interested states may want to
supplement the "Summary of Applicable Federal Statutes and Regulations"
section with state and local requirements. Compliance or technical assistance
providers also may want to develop the "Pollution Prevention" section in more
detail. Please contact the appropriate specialist listed on the opening page of
this notebook if your office is interested in assisting us in the further
development of the information or policies addressed within this volume. If
you are interested in assisting in the development of new notebooks, please
contact the Office of Compliance at 202-564-2310.
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Agricultural Crop Production Industry
Introduction & Background
II. INTRODUCTION TO THE AGRICULTURAL PRODUCTION INDUSTRIES:
CROPS, GREENHOUSES/NURSERIES, AND FORESTRY
This section provides background information on three types of agricultural
production industries:
• Establishments that produce crops, including oilseed and
grains, vegetables and melons, fruit and tree nuts, and other
crops
• Greenhouses and nurseries
• Establishments engaged in forestry and logging.
The Office of Management and
Budget (OMB) has replaced the
Standard Industrial Classification
(SIC) system, which was used to
track the flow of goods and
services within the economy, with
the NAICS. The NAICS, which is
based on similar production
processes to the SIC system, is
being implemented by OMB.
This section defines these industries in
terms of their North American Industrial
Classification System (NAICS) codes.
According to NAICS, establishments that
produce crops and greenhouses/nurseries
are classified in NAICS code 111 (Crop
Production). Because
greenhouses/nurseries comprise a large
number of the entities in NAICS 111 and
are somewhat different in actual
practices, this notebook presents data and
information on them separately from
crop production. Greenhouse, nursery, and floriculture production is
classified as NAICS code 1114. Establishments engaged in forestry are
classified in NAICS code 113 (Forestry and Logging). The forestry
production industry has practices that differ significantly from those used for
crops and greenhouses/nurseries.
Establishments primarily engaged in crop production and forestry are
classified in subgroup(s), up to six digits long, based on the total value of sales
of agricultural products. An establishment would be placed in the group that
represents 50 percent or more of its total sales. For example, if 51 percent of
the total sales of an establishment is wheat, then it would be classified under
NAICS codes 1111 (Oilseed and Grain Farming) and 11114 (Wheat Farming).
Data for the notebook, specifically in this chapter, were obtained from the
U.S. Department of Agriculture (USD A) and the 1997 Agriculture Census (Ag
Census). All data are the most recent publicly available data for the source
cited.
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Agricultural Crop Production Industry
Introduction & Background
II. A. General Overview of Agricultural Establishments
This section presents a general overview of agricultural establishments to
provide background information regarding the number of such establishments
and production data. The USDA's National Agricultural Statistics Service
(NASS) defines an agricultural establishment (i.e., farm) based on production.
It defines a farm as a place which produced or sold, or normally would have
produced or sold, $1,000 or more of agricultural products during the year.
Agricultural products include all products grown by establishments described
in this profile, which are classified under NAICS codes 111,113, and 1114, as
well as those in NAICS code 112 - Animal Production, which are covered in
the Profile of the Agricultural Livestock Production Industry.
According to the 1997 Ag Census, there were'more than 1.9 million farms
(i.e., agricultural establishments) in the United States. Of these,
approximately 47 percent (902,372 farms) were classified as NAICS code 111
- Crop Production. The other 53 percent (1,009,487 farms) were classified as
NAICS code 112 - Animal Production. These 1.9 million agricultural
establishments represent
Exhibit 1. Agricultural Land Use
in the U.S. (1997 Ag Census)
nearly 932 million acres
of land, with the average
agricultural
establishment consisting
of 487 acres. (Note: 1
acre is approximately the
size of a football field.)
Both of these numbers—
932 million acres and
487 acres—are smaller
than those for 1992,
which were 946 million
acres and 491 acres,
respectively.
As shown in Exhibit 1,
of the 932 million acres
of agricultural land, the
overwhelming majority
(89%) consists of
cropland and
pastureland/rangeland.
46%
3%
43%
Cropland
Pastureland/Rangeland
Woodland
Other :
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Agricultural Crop Production Industry
Introduction & Background
Exhibit 2. Types of Cropland
(1997 Ag Census)
72%
9%
15%
p»| Cropland Harvested
H Cropland Pastured
| | Other Cropland (cover, crops failed, and summer fallow)
| Cropland Idle
As presented in Exhibit 2,
the 1997 Ag Census
describes cropland as:
• Harvested cropland —
Includes all acreage
from which crops are
harvested, such as: (1)
corn, wheat, barley,
oats, sorghum,
soybeans, cotton, and
tobacco; (2) wild or
tame harvested hay,
silage, and green chop;
and (3) vegetables.
It also includes land in
orchards and vineyards;
all acres in
greenhouses, nurseries,
Christmas trees, and
sod; and any other acreage from which a crop is harvested even if the crop
is considered a partial failure and the yield is very low.
• Cropland used only for pasture or grazing'— Includes land pastured or
grazed which could be used for crops without any additional improvement,
and land in planted crops that is pastured or grazed before reaching
maturity.
• Cropland used for cover crops — Includes land used only to grow cover
crops for controlling erosion or to be plowed under for improving the soil.
• Cropland on which all crops failed — Includes: (1) all land from which a
crop failed (except fruit or nuts in an orchard, grove, or vineyard being
maintained for production) and no other crop is harvested and which is not
pastured or grazed, and (2) acreage not harvested due to low prices or
labor shortages.
• Cultivated summer fallow — Includes cropland left unseeded for harvest,
and cultivated or treated with herbicides to control weeds, and conserve
moisture.
• Idle cropland — Includes any other acreage which could be used for crops
without any additional improvement and which is not included in one of
the above categories of cropland.
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Agricultural Crop Production Industry
Introduction & Background
The 1997 Ag Census describes pastureland and rangeland as land, other than
cropland or woodland pasture, that is normally used for pasture or grazing.
This land, sometimes called "meadow" or "prairie," may be composed of
bunchgrass, shortgrass, buffalo grass, bluestem, bluegrass, switchgrass, desert
shrubs, sagebrush, mesquite, greasewood, mountain browse, salt brush, cactus,
juniper, and pinion. It also can be predominantly covered with brush or
browse.
Exhibit 3. Acreage of Agricultural Establishments
As shown in Exhibit »n the U.S. (1997 Ag Census)
3, approximately 82 ,
percent of agricultural
establishments in 1997
consisted of fewer
than 500 acres; only 4
percent consisted of
2,000 or more acres.
30%
31%
According to the 1997
Ag Census, all
agricultural
establishments
combined to produce
approximately $197,
billion worth of
agricultural products.
1-49 acres
50-179 acres
180-499 acres
Exhibit 4. Agricultural Establishments
by Value of Sales (1997 Ag Census)
500 - 999 acres
1000-19999 acres
2000 acres or more
26%
24%
15%
< $2,500
$2,500 - $9,999
$10,000-$49,999
23%
$50,000 - $99,999
$100,000-$499,999
$500,000 or more
The market value of the
agricultural products sold
was split almost evenly
between crop production,
including nursery and
greenhouse crops (49.6%)
and livestock production
(50.4%).
As shown in Exhibit 4,
approximately 73 percent
of all agricultural
establishments produced
less than $50,000 worth
of agricultural products.
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Agricultural Crop Production Industry
Introduction & Background
In addition to tracking the number of agricultural establishments and the value
of products sold, the Ag Census tracks and identifies other characteristics of
agricultural establishments, such as ownership and organization. Exhibit 5
presents a breakdown of the ownership status of agricultural establishments in
the U.S. The Ag Census basically identifies the ownership status of
agricultural establishments by one of three categories:
Full ownership, in
which full owners
operate only the land
they own.
Partial ownership, in
which partial owners
operate land they
own and also land
they rent from
others.
Tenant/rental
arrangement, in
which tenants
operate only land
they rent from others
or work on shares
for others.
Exhibit 5. Ownership Status of Agricultural
Establishments in the U.S.
(1997 Ag Census)
60%
10%
30%
Full Ownership
Partial Ownership
Tenant
The Census further classifies agricultural establishment ownership by the
person or entity who owns the establishment. There are four distinct types of
organization: (1) individual or family (sole proprietorship); (2) partnership,
including family partnership; (3) corporation, including family corporation,
and (4) other, including cooperatives, estate or trust, and institutional.
Approximately 86 percent of all establishments are owned and operated by
individuals or families. Partnerships account for another 9 percent of the
establishments and corporations own just more than 4 percent of the
establishments. Fewer than 1 percent of all farms are owned by other
organizations. (1997 Ag Census).
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Agricultural Crop Production Industry
Introduction & Background
II.B. Characterization of the Crop Production Industry
This section provides data and information on the crop production industry.
For the purposes of this profile, crop production includes the four categories
of commodities presented in Exhibit 6. This notebook follows the structure
provided by the 1997 Ag Census, which classifies all of these commodity
production operations within NAICS code 111. Because the notebook is
addressing greenhouse, nursery, and floriculture products separately in the
next section, they are not included within this discussion.
Exhibit 6. 1997 NAICS Descriptions for Crop Production (NAICS 111)
Type of
Establishment
Oilseed and Grain
Vegetables and
Melons
Fruits and Tree
Nuts
Other Crops
NAICS
Code
1111
1112
1113
1119
SIC Code
0116,0119
0134, 0139,
0161
0171,0172,
0173, 0174,
0175,0179
0131,0132,
0133,0139,
0191, 0831,
2099
Description
Establishments primarily engaged
in: 1) growing oilseed and/or grain
crops and/or 2) producing oilseed
and grain seeds. These crops have
an annual growth cycle and are
typically grown in open fields.
Establishments primarily engaged
in growing root and tuber crops
(except sugar beets and peanuts)
or edible plants and/or producing
root and tuber or edible plant
seeds. The crops included in this
group have an annual growth
cycle and are grown in open
fields.
Establishments primarily engaged
in growing fruit and/or tree nut
crops. The crops included in this
industry group are generally not
grown from seeds and have a
perennial life cycle.
Establishments primarily engaged
in: 1) growing crops (other than
those listed previously), such as
tobacco, cotton, sugarcane, hay,
sugar beets, peanuts, agave, herbs
and spices, and hay and grass
seeds, or 2) growing a
combination of these crops.
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Agricultural Crop Production Industry
Introduction & Background
Exhibit 7. Number of Farms
(1997 Ag Census)
55%
9%
32%
In 1997, there were
845,180
establishments
producing the four
categories of
commodities
referenced above.
All these
establishments
combined covered
nearly 400 million
acres, of which more
than half (236 million
acres) was harvested r
cropland. The •
average crop p
producing £
establishment in 1997 *
was approximately
473 acres in size and averaged approximately 279 acres of harvested cropland.
Of the 845,180 crop producing establishments, more than 50 percent
(462,877) were classified as oilseed and grain farming (see Exhibit 7). Also,
as shown in Exhibit 8, oilseed and grain farming accounted for the majority of
the land in acres as well as harvested cropland.
Exhibit 8. Land in Acres vs. Acres of Harvested Cropland (in millions of acres)
(1997 Agriculture Census)
Oilseed and Grain Farming (NAICS 1111)
Vegetable and Melon Farming (NAICS 1112)
Fruit and Tree Nut Farming (NAICS 1113)
Other (NAICS 1119)
300 -f
I I T
Oilseed and Grain Vegetable and Melon Fruit and Tree Nut
Other
Land in Acres
[~] Acres of Harvested Cropland
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Agricultural Crop Production Industry
Introduction & Background
Exhibit 9. Percent of Sales by Type of
Establishment (1997 Ag Census)
51%
13%
22%
14%
[~] Oilseed and Grain
| Vegetable and Melon
P53 Fruit and Tree Nuts
Other Crops
In 1997, there were 462,877
oilseed and grain establishments
in the U.S.; 94,481 were oilseed
establishments and 368,396 were
grain establishments. As shown
in Exhibit 10, corn-producing
establishments comprise the
majority of the grain
'establishments in the U.S. On
average, each grain-producing
establishment is approximately
671 acres. Of those,
approximately 407 acres are
harvested cropland.
The four types of crop-producing
establishments defined above accounted
for approximately $87 billion worth of
products sold in 1997. Exhibit 9 presents
the distribution of those sales among the
four types of establishments.
II.B.l. Oilseed and Grain
Oilseed and grain accounted for the
majority of agricultural sales in the U.S.
in 1997. For the purposes of the 1997 Ag
Census, oilseed includes primarily
soybeans, but also dry peas and beans,
canola, flaxseeds, mustard seeds, oilseeds,
rapeseeds, safflower, sesame seeds, and
sunflowers. Grain includes wheat, corn,
rice, and other grains such as barley,
broomcorn, buckwheat, milo, oats, rye,
sorghum, and wild rice. These grains are
considered both food and feed grains,
meaning they may be used either in food
production or as feed for livestock.
Exhibit 10. Types of Grain Farms
(1997 Ag Census)
36%
14%
48%
Wheat Farms
Corn Farms
Rice Farms
Other Grain Farms
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Agricultural Crop Production Industry
Introduction & Background
II.B.2. Vegetables and Melons
Vegetable and melon farming accounts for 31,030 establishments, or just less
than 4 percent of the total crop-producing establishments in the U.S. An
average vegetable and melon establishment consists of approximately 330
acres, of which approximately 170 acres are harvested cropland. Potato
farming is the largest subgroup within vegetable and melon farming. It
comprises nearly 12 percent of all vegetable and melon farms. The average
potato-producing establishment has approximately 981 acres; approximately
730 of these acres are harvested cropland.
II.B.3. Fruit and Tree Nuts
Fruit and tree nut farming comprised the third largest group of crop-producing
establishments combining for 81,956 establishments. This category is
basically broken into two categories: 1) citrus fruits, and 2) noncitrus fruits
and tree nuts. Citrus-producing establishments (i.e., groves) accounted for
12,275 establishments, or approximately 15 percent of all fruit and tree nut
establishments. Noncitrus fruits and tree nuts, which include apples, grapes,
strawberries, other berries, tree nuts, and other noncitrus fruits, comprised the
remainder of the establishments (69,681) in 1997. (Tree nuts include
almonds, hazelnuts, walnuts, macadamia nuts, pecans, and pistachios.) The
percentages of noncitrus fruit and tree nut establishments are presented in
Exhibit 11.
hi 1997, the average fruit
and tree nut establishment
was 127 acres, with
approximately half of
those acres being
harvested. Orange groves
accounted for more than
75 percent of all citrus
fruit establishments.
Florida dominates citrus
fruit production, except for
lemons. Noncitrus fruits
are grown across the
country. Tree nuts are
grown primarily in
California and Hawaii.
Exhibit 11. Noncitrus Fruit
and Tree Nut Farms
(1997 Ag Census)
79%
19%
Noncitrus Fruit Farms
Tree Nut Farms
Combination
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Agricultural Crop Production Industry
Introduction & Background
II.B.4. Other Crops
The category of Other Crops comprised the second largest group of crop-
producing establishments in the U.S. in 1997. A total of 269,317 farms were
classified as NAICS code 1119 - Other Crops Farming. These other crops
include tobacco, cotton, sugarcane, and hay, as well as other specialty crops
such as honey and sugarbeets. Of the 269,317 other crop farms, 52 percent
were classified as hay farms. Tobacco farms accounted for 24 percent of these
establishments and cotton-producing establishments represented 7 percent.
Sugarcane farms accounted for less than 1 percent of all establishments in this
category. The remaining 17 percent were classified in the All Other Crops
category.
These establishments combined for a total land area of approximately 94
million acres, or approximately 349 acres per establishment. The average
number of acres harvested was 164 acres. Exhibit 12 provides a comparison
of total acres to acres harvested for other crops.
Exhibit 12. Total Acres vs. Acres Harvested of Other Crops
(in thousands of acres) (1997 Ag Census)
Tobacco Cotton Sugarcane
H Total Acres
Hay All Other Crops
Acres Harvested
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Agricultural Crop Production Industry
Introduction & Background
II.C. Characterization of the Greenhouse, Nursery, and Floriculture
Production Industry
Although the greenhouse, nursery, and floriculture industry is classified under
NAICS code 111, this profile separates it into its own section because its
practices and environmental impacts are different from those associated with
the crops discussed in Section II.B.
In 1997, according to the Ag Census, there were 57,192 farms classified as
NAICS code 1114, which is Greenhouse, Nursery, and Floriculture
Production. This industry group consists of establishments that primarily
grow crops of any kind under cover and/or grow nursery stock and flowers.
"Under cover" is generally defined as in greenhouses, cold frames, cloth
houses, and lath houses. The crops grown are removed at various stages of
maturity and have annual and perennial life cycles. The nursery stock includes
short rotation woody crops that have growth cycles of 10 years or less.
Of the 57,192 establishments classified as NAICS 1114, 97 percent were
nursery and floriculture production (NAICS code 11142). The remaining 3
percent were classified as NAICS code 11141 - food crops grown under cover.
Within the nursery and floriculture classification, there are two distinct
categories:
• Nursery and tree production, which consists of establishments
primarily engaged in growing nursery products, nursery stock,
shrubbery, bulbs, fruit stock, and sod, and those engaged in growing
short rotation woody trees with a growth and harvest cycle of 10 years
or less for pulp or tree stock, such as Christmas trees, under cover or in
open fields.
• Floriculture production, which consists of establishments primarily
engaged in growing and/or producing floriculture products, such as cut
flowers, cut cultivated greens (e.g., leatherleaf ferns, chamaedorea,
etc.), potted flowering and foliage plants, and flower seeds, under
cover or in open fields.
hi 1997, there were 33,935 nursery and tree production establishments and
21,824 floriculture establishments. These establishments combined for total
sales of nearly $10 billion, or approximately 10 percent of the total value of all
crops sold in 1997. The average size of nursery and tree production
establishments is nearly 92 acres, with an average of approximately 35 acres
being harvested cropland. Floriculture production establishments average 35
acres in size with approximately one-third of that acreage being harvested
cropland. California and Florida account for the majority of the
establishments, as well as sales, in the floriculture industry.
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Agricultural Crop Production Industry
Introduction & Background
Exhibits 13 and 14
show the value of
greenhouse,
nursery, and
floriculture
production
compared to total
crop production,
and the value of
greenhouse,
nursery, and
floriculture
production sales,
respectively.
Exhibit 13. Value of Greenhouse, Nursery, and
Floriculture Production Compared to Total Crop
Production (1997 Ag Census)
89% ($86.8 billion)
11% ($10.9 billion)
Greenhouse, Nursery, and Floriculture Production
Remainder of Crop Production
Exhibit 14. Values of Greenhouse, Nursery, and
Floriculture Production Sales
(1997 Ag Census)
45%
10%
45%
KX Nursery and Tree Production
|~~| Floriculture Production
• Food Crops Grown Under Cover (Greenhouse)
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Agricultural Crop Production Industry
Introduction & Background
II.D. Characterization of the Forestry Production Industry
This section pertains to the forestry industry as classified within NAICS code
113 - Forestry and Logging. As defined by NAICS, industries in this sector
grow and harvest timber on a long production cycle (i.e., 10 years or more).
Long production cycles use different production processes than short
production cycles, which require more horticultural interventions prior to
harvest, resulting in processes more similar to those found in the previous
sections of this profile. The three subsectors included within NAICS code 113
are:
• Timber tract operations (NAICS code 1131), which consist of
establishments engaged in operating timber tracts for the purpose of
selling standing timber.
Forest nurseries and gathering of forest products (NAICS code
1132), which primarily engage in growing trees for reforestation and
gather forest products, such as gums, barks, balsam needles, rhizomes,
fibers, Spanish moss, ginseng, and truffles.
Logging (NAICS code 1133), which consists of establishments
primarily engaged in cutting timber, cutting and transporting timber,
and producing wood chips in the field.
Industries usually specialize in different stages of the production cycle, as
indicated by the three NAICS codes. Reforestation requires production of
seedlings in specialized nurseries. Timber production requires natural forest
or suitable areas of land that are available for a long duration. The harvesting
of timber (except when done on an extremely small scale) requires specialized
machinery unique to the industry. Establishments gathering forest products,
such as gums, barks, balsam needles, rhizomes, fibers, Spanish moss, and
ginseng and truffles, are also included in this industry.
ILD.l. Definition of Forest Land
The U.S. Forest Service defines a forested area as "forest land" if it is at least
one acre in size and at least 10 percent occupied by forest trees of any size or
formerly having had such tree cover and not currently developed for non-
forest use. (Examples of non-forest uses include areas for crops, improved
pasture, residential areas, and other similar areas.) Forest land includes
transition zones, such as areas between heavily forested and nonforested lands
that are at least 10 percent stocked with forest trees and forest areas adjacent
to urban and built-up lands (36 CFR 219).,
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Agricultural Crop Production Industry
Introduction & Background
In the United States, there are approximately 736.7 million acres of forest
land. The distribution of this forest land among geographic regions is
presented in Exhibit 15.,
Exhibit 15. Distribution of U.S. Forested Land Area
Geographic
Region
Northeast
North Central
Pacific Northwest
Pacific Southwest
Great Plains
Southeast
South Central
Rocky Mountains
Total
Total Land Area
(in thousands of acres)
126,816
286,764
469,093
103,934
194,299
147,419
387,104
547,918
2,263,347
Forested Acres
(in thousands)
85,380
83,108
177,611
.39,011
4,232
88,078
123,760
135,499
736,679
Percent
Forested
67
29
38
38
2
60
32
25
Source: American Forest and Paper Association (AFP A), 1995
Federal Versus Nonfederal
Forest Lands
Of the 736.7 million acres,
approximately 249.1 million
acres (or 33.8 percent) are
owned by the federal
government. The remaining
487.6 million acres are
owned by nonfederal
entities, such as state or local
governments, private
citizens, or companies (see
Exhibit 16).
Exhibit 16. Federal vs. Nonfederal
Forest Lands (AFPA 1995)
66.2%
33.8%
Federal Forest Land
Nonfederal Forest Land
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Agricultural Crop Production Industry
Introduction & Background
Approximately 57 percent of all productive forest land in the U.S. is owned by
9.3 million non-industrial private landowners. These 353 million acres of land
produce more than half of the nation's wood supply (AFP A, 1995).
The majority of federal forest land is managed as the national forest system
(NFS). The NFS includes:
• National forest lands reserved from the U.S. public domain.
• National forest lands acquired through purchase, exchange,
donation, or other means.
• National grasslands.
Other lands, waters, or interests administered by the U.S.
Forest Service (FS) or designated for administration through
the FS as part of the system.
The NFS contains 191 million acres, or 77 percent, of federal forest lands.
(The remaining federal forest lands are managed by the Bureau of Land
Management, the National Park Service, and other federal agencies.) The
NFS is contained in 43 states and creates about 500,000 private sector jobs.
Of the remaining nonfederal forests, privately held commercial forest lands
make up the largest portion accounting for 347 million acres (71 percent).
Exhibit 17. Timberland Ownership
(AFPA 1995)
59%
Timberlands. Two-thirds of U.S. forest lands, or almost 490 million acres,
are classified as timberlands. Timberlands are defined as forest lands used for
the production of
commercial wood products.
Commercial timberland can
be used for repeated
growing and harvesting of
trees. Seventy percent of
timberlands are located in
the East (AFPA, 1995).
Exhibit 17 presents
additional information about
timberland ownership. Of
the 490 million acres of
timberland, federal, state,
and local governments own
131 million acres (27
percent) and non-industrial
private entities own 288
million acres (59 percent).
14%
20%
Private Non-Industrial Entities
Other Public Entities
National Forests
Forest Industry
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Agricultural Crop Production Industry
Introduction & Background
Private timberlands are mostly on small tracts of forest land. Only 600,000
landowners have holdings larger than 100 acres (AFPA, 1995). The forest
products industry owns about 70 million acres (14 percent) of commercial
timberland. One-third of the nation's annual timber harvest is from these
forests (AFPA, 1995).
II.D.2. Consumption and Regeneration of Forest Products
The United States is the world's leading producer and consumer of forest
products (e.g., paper products) and accounts for approximately one-fourth of
the world's production and consumption (AFPA, 1995). The United States is
also the world's largest producer,of softwood and hardwood lumber.
Specifically for timber, in 1996, total annual sales for commercial (i.e.,
nonfederal) timber and nontimber forest products were approximately $3.8
billion. Timber alone accounted for approximately 69 percent of those sales.
hi fiscal year 1998, the NFS sold approximately 174 million cubic feet (or 870
million board feet) of timber valued at approximately $80 million. NFS
timber sales from the past 6 years are presented in Exhibit 18. Also in fiscal
year 1998, BLM sold 43.7 million cubic feet (or 261 million board feet) of
timber. (A value was not provided for the BLM timber sales.)
Exhibit 18. NFS Timber Sales, FY 1993-1998
(from U.S. Forest Service)
Fiscal Year
1993
1994
1995
1996
1997
1998
Approx. Volume
(million cubic feet)
250
177
240
212
195
174
Value
$192,942,739
$125,340,385
$140,460,250
$125,226,853
$123,681,846
$80,195,720
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Agricultural Crop Production Industry
Introduction & Background
Exhibit 19. Acres Seeded and Acres
of Tree Planting (FY 1996)
^^^fc ^^0
National Forest System
Other Federal Land
Non-federal Public Land
Private Land
Exhibit 19 provides a breakout of where regeneration efforts occurred. To
replenish the forests, more than 2.4 million acres in the U.S. were either
seeded or planted with trees in government fiscal year 1996 (October 1995 -
September 1996). The overwhelming majority of the regeneration efforts
occurred on private lands where nearly 2.1 million acres were seeded or
planted.
II.E. Geographic Distribution and Economic Trends
According to the 1997 National Resource Inventory (NRI), some changes have
occurred in land use. Since 1982, federal land increased by 4.6 million acres,
nonfederal rural land decreased by 36.7 million acres, and developed land
increased by nearly 30 million acres. Cropland acreage, classified as irrigated,
non-irrigated, cultivated, or non-cultivated acreage, nationally decreased by
45.9 million acres between 1982 and 1997. Rangeland decreased by 12.4
million acres and pastureland decreased by almost 14 million acres.
Generally, a shift has occurred in irrigated agriculture from west to east across
the country.
The distribution of prime farmland by land cover/use has also changed in the
past 15 years. There were 330.6 million acres of prime farmland in 1997,
which was down 11.7 million acres from 1982. Most (64 percent) of the
prime farmland is in cropland, but large amounts are in pastureland (35.5
million acres) and forest land (47.7 million acres).
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Agricultural Crop Production Industry
Introduction & Background
For more information from the 1997 NRI, please visit the website
http://www.nhq.nrcs.usda.gov/NRI/1997. Additional information on the
geographic distribution of the crop production industries and their economic
trends is very extensive and available through many sources. National and
state-specific information can be accessed through the Internet from the 1997
Agriculture Census at http://www.nass.usda.gov/census/ and the National
Agriculture Statistics Service at http://www.usda.gov/nass/.
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Agricultural Crop Production Industry
Summary of Operations, Impacts,
& Pollution Prevention Opportunities
III. SUMMARY OF OPERATIONS, IMPACTS, AND POLLUTION PREVENTION
OPPORTUNITIES FOR THE AGRICULTURAL PRODUCTION INDUSTRIES:
CROPS, GREENHOUSES/NURSERIES, AND FORESTRY
This section provides an overview of commonly employed operations and
maintenance activities in the agricultural production industries of crops,
greenhouses/nurseries, and forestry. This discussion is not exhaustive; the
operations and maintenance activities discussed are intended to represent the
material inputs, major pollution outputs, and associated environmental
impacts from these agricultural production practices. General pollution
prevention and waste minimization opportunities are also discussed in the
context of each of the operations and maintenance activities.
The choice of practices or operations influences the material used and the
resulting pollution outputs,and environmental impacts. Keep in mind that
environmental impacts are relative, as some kinds of pollution outputs have
far greater impacts than others.
Impact of Agriculture on the Environment
The Clean Water Act Plan of
1998 called for the development
of the EPA/USDA Unified
National Strategy for AFOs to
minimize the water quality and
public health impacts of AFOs.
According to the EPA/USDA Unified
National Strategy for Animal Feeding
Operations (March 9, 1999), despite
progress in improving water quality, 40
percent of the Nation's waterways
assessed by States do not meet goals for
fishing, swimming, or both. While
pollution from factories and sewage
treatment plants has been dramatically
reduced, the runoff from city streets, agricultural activities, including AFOs,
and other sources continues to degrade the environment and puts
environmental resources (i.e., surface water, drinking water) at risk.
According to EPA's 1996 305(b) water quality report, the top two pollutants
from agriculture were identified as sediment and nutrients, respectively.
Additional agricultural pollutants, such as animal wastes, salts, and pesticides,
were identified by EPA1. The following presents a brief discussion of the
environmental impacts of effects of agricultural pollutants.
(1) Nutrients. Excess nutrients in water (i.e., phosphorus and nitrogen)
can result in or contribute to low levels of dissolved oxygen (anoxia),
1 Guidance Specifying Management Measures for Sources ofNonpoint Pollution in Coastal
Waters, U.S. Environmental Protection Agency, January 1993.
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Summary of Operations, Impacts,
& Pollution Prevention Opportunities
(2)
(3)
eutrophication, and toxic algal blooms. These conditions may be
harmful to human health and ecosystems; may adversely affect the
suitability of the water for other uses; and, in combination with other
circumstances, have been associated with outbreaks of microbes such
as Pfiesteria piscicida.
— Phosphorus. Phosphorus determines the amount of algae
growth and aging that occurs in freshwater bodies. Runoff and
erosion can carry some of the applied phosphorus to nearby
water bodies.
— Nitrogen. In addition to eutrophication, excessive nitrogen
causes other water quality problems. Dissolved ammonia at
' concentrations above 0.2 mg/L may be toxic to fish.
Biologically important inorganic forms of nitrogen are
ammonium, nitrate, and nitrite. Ammonium becomes adsorbed
to the soil and is lost primarily with eroding sediment. Even if
nitrogen is not in a readily available form as it leaves the field,
it can be converted to an available form either during transport
or after delivery to water bodies. Nitrogen in the form of .
nitrate, can contaminate drinking water supplies drawn from
groundwater. Nitrates above 10 ppm in drinking water are
potentially dangerous, especially to newborn infants.
Sediment. Sediment affects the use of water in many ways. Suspended
solids reduce the amount of sunlight available to aquatic plants, cover
fish spawning areas and food supplies, clog the filtering capacity of
filter feeders, and clog and harm the gills offish. Turbidity interferes
with the feeding habits of fish. These effects combine to reduce fish
and plant populations and decrease the overall productivity of waters.
In addition, recreation is limited because of the decreased fish
population and the water's unappealing, turbid appearance. Turbidity
also reduces visibility, making swimming less safe.
Animal Wastes. Animal waste includes the fecal and urinary wastes of
livestock and poultry; process water (such as from a milking parlor);
and the feed, bedding, litter, and soil with which fecal and urinary
matter and process water become intermixed. Manure and wastewater
from animal feeding operations have the potential to contribute
pollutants such as nutrients (e.g., nitrogen and phosphorus), organic
matter, sediments, pathogens, heavy metals, hormones, antibiotics, and
ammonia to the environment. Decomposing organic matter (i.e.,
animal waste) can reduce oxygen levels and cause fish kills. Solids
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Agricultural Crop Production Industry
Summary of Operations, Impacts,
& Pollution Prevention Opportunities
.deposited in water bodies can accelerate eutrophication through the
release of nutrients over extended periods of time.
Contamination of groundwater can be a problem if runoff results from
the misapplication or over application of manure to land or if storage
structures are not built to minimize seepage. Because animal feed
sometimes contains heavy metals (e.g., arsenic, copper, zinc), the
possibility for harmful accumulations of metals on land where manure
is improperly or over applied is possible.
(4) Salts. Salts are a product of the natural weathering process of soil and
geologic material. In soils that have poor subsurface drainage, high salt
concentrations are created within the root zone where most water
extraction occurs. The accumulation of soluble and exchangeable salts
(i.e., metal compounds in the soil that can chemically change) leads to
soil dispersion (i.e., movement of soil in air and water), structure
breakdown, decreased infiltration, and possible toxicity; thus, salts
often become a serious problem on irrigated land, both for continued
agricultural production and for water quality considerations. High salt
concentrations in streams can harm freshwater aquatic plants just as
excess soil salinity damages agricultural crops.
(5) Pesticides. The primary pollutants from pesticides are the active and
inert ingredients, diluents, and any persistent degradation products.
Pesticides and their degradation products may enter groundwater and
surface water in solution, in emulsion, or bound to soils. Pesticides
may, in some instances, cause impairments to the uses of surface
waters and groundwater. Both the degradation and sorption
characteristics of pesticides are highly variable. Some types of
pesticides are resistant to degradation and may persist and/or
accumulate in aquatic ecosystems. Pesticides may harm the
environment by eliminating or reducing populations of desirable
organisms, including endangered species.
At a crop production establishment, pesticides may be applied directly
to crops or to structures (e.g., barns, housing units) to control pests,
including parasites, vectors (i.e., an organism, such as a mosquito or
tick, that carries disease-causing microorganisms from one host to
another), and predators. Potential contamination from pesticides is
generally greatest when rainfall is intense and occurs shortly after
pesticide application, a condition during which water runoff and soil
losses are also greatest. Pesticides can be transported to receiving
waters either in dissolved form or attached to soil. Dissolved
pesticides may be leached into groundwater supplies.
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People, wildlife, and the environment can also be exposed to pesticide
residues in the form of spray drift. Spray drift is the physical
movement of a pesticide through air at the time of application or soon
thereafter, to any site other than that intended for application. A
number of factors influence spray drift including weather conditions,
topography, the crop or area being sprayed, and application equipment
and methods.
Pesticides are both suspected and known for causing immediate and
delayed-onset health hazards for humans. If exposed to pesticides,
humans may experience adverse effects, such as nausea, respiratory
distress, or more severe symptoms up to and including death. Animals
and birds impacted by pesticides can experience similar illnesses or
develop other types of physical distress.
Pollution Prevention/Waste Minimization Opportunities in Crop Production,
Greenhouses/Nurseries, and Forestry
\
The best way to reduce pollution is to prevent it in the first place. Industries
have creatively implemented pollution prevention techniques that improve
operations and increase profits while minimizing environmental impacts. This
can be done in many ways such as reducing material inputs* reusing
byproducts, improving management practices, and employing substitute toxic
chemicals.
To encourage these approaches, this section provides general descriptions of
some pollution prevention advances that have been implemented within the
agricultural production industries for crops, greenhouses/nurseries, and
forestry. While the list is not exhaustive, it does provide core information that
can be used as the starting point for establishments interested in beginning
their own pollution prevention projects. This section provides information
from real activities that may be or are being implemented by this sector.
When possible, information is provided that gives the context in which the
technique can be effectively used. Please note that the activities described in
this section do not necessarily apply to all facilities that fall within this sector.
Facility-specific conditions must be carefully considered when pollution
prevention options are evaluated, and the full impacts of the change must
examine how each option affects air, land, and water pollutant releases.
The use of pollution prevention technologies and environmental controls can
substantially reduce the volume and concentration of the contaminants
released/discharged into the surrounding environment. In some cases, these
pollution prevention approaches may be economically beneficial to the
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agricultural production industries because they decrease the amount of
chemicals needed, and therefore the cost of maintaining operations.
Waste minimization generally encompasses any source reduction or recycling
that results in either the reduction of total volume or the toxicity of hazardous
waste. Source reduction is a reduction of waste generation at the source,
usually within a process. Source reduction can include process modifications,
feedstock (raw material) substitution, housekeeping and management
processes, and increases in efficiency of machinery and equipment. Source
reduction includes any activity that reduces the amount of waste that exits a
process. Recycling refers to the use or reuse of a waste as an effective
substitute for a commercial product or as an ingredient or feedstock in an
industrial process.
It should be noted that as individual practices, these pollution prevention and
waste minimization practices can significantly reduce the environmental
impacts of agricultural operations. However, to get the full effect of the
practices and maximize pollution prevention potential, an agricultural
operation must consider its individual practices in the context of a system.
The practices, ranging from preparing the soil for planting to harvest and post-
harvest activities, combine to form an integrated system in which each
practice interacts with the others and is affected by the others. That is, outputs
from one practice may be inputs into one of the other practices, in effect
creating a closed-loop system that both maximizes profits and minimizes
environmental impacts. By considering their establishments as systems,
operators will be better able to evaluate and implement pollution prevention or
waste minimization opportunities.
III.A. Crop Production: Operations, Impacts, and Pollution Prevention Opportunities
The production of crops generally includes the following activities:
• Preparing the site/soil for crops
• Planting/tending crops
• Applying and storing nutrients
• Pest control
• Irrigating crops
• Harvesting crops and post-harvesting activities
• Crop field residue destruction
• Maintaining equipment and vehicles
• Fuel use and fueling activities
• Maintaining the site
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The additional activities,of planning and management are required for all of
the above processes to occur. Exhibit 20 presents the raw material inputs and
pollution outputs from each of these processes.
Exhibit 20. Crop Production Activities, kawMaterial Inputs,
and Potential Pollution Outputs
Activity
Raw Material Input
Potential Pollution Output
Preparing the site/soil,
including tilling, drainage
and erosion control
structures, and adjusting soil
pH
Mulch, seeds, and water
Alkaline material
Water
Air emissions (e.g., smoke and
dust)
Sediment, nutrient and pesticide
runoff from soil erosion
Spilled material or excessively
applied material
Planting/tending
— Seed, seedlings
Air emissions (e.g., dust,
emissions from planting
equipment)
Sediment, nutrient, pesticide
runoff from soil erosion
Plants, branches, leaves, etc.
Applying and storing
nutrients (e.g., fertilizers,
manure, biosolids)
Organic nutrients
Chemicals
Water
Runoff and leaching of unused
or misapplied nutrients
Chemical air emissions
Odor
Applying pesticides and pest
control
Pesticides (including insecticides,
rodenticides, fungicides, and
herbicides)
Runoff and leaching of unused
or misapplied pesticides
Chemical air emissions
Irrigating (not including
nutrient application)
Water
Chemicals
Air emissions
Potential runoff and leaching of
materials (e.g., manure,
chemicals, pesticides) from
saturated areas
Harvesting/post-harvesting
activities, including
harvesting; washing,
processing, packaging,
loading, and transporting
products; and destroying
crop residue
Water
Corrugated cardboard
Paper
Plastic and fabric packaging
materials
Unusable or spilled products
Worker exposure to pesticides
Organic- and pesticide-
contaminated wastewater
Discarded packaging materials
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Exhibit 20. Crop Production Activities, Raw Material Inputs,
and Potential Pollution Outputs
Activity
Raw Material Input
Potential Pollution Output
Maintaining and repairing
agricultural machinery and
vehicles
Oil
Lubricating fluid
Fuel
Coolants
Solvents
Tires
Batteries
Equipment parts
Used oil
Spent fluids
Spent batteries
Metal machining wastes
Spent organic solvents
Tires
Air, surface water, and soil
pollution resulting from spills
and/or releases of fluids
Groundwater pollution resulting
from spills or releases of fluids
and discharges to Class V wells
Fuel use and fueling
activities
- Fuel
Air emissions from machinery
Air, water, soil, and
groundwater pollution resulting
from spills
Maintaining the site:
(1) Providing water,
including drinking water and
water used for personal
hygiene
(2) Managing PCBs (i.e.,
PCBs in generators and
equipment)
(3) Renovation/demolition
- Water
PCB-containing oils and
equipment
Asbestos
Lead
— Contaminated water supply
— Spills or releases of PCBs
Airborne asbestos fibers
Lead-based paint, dust, and
chips
Soil contamination
III.A.1. Preparing the Site/Soil for Crops
Prior to planting crops, the site/soil must be prepared. Site/soil preparation
can involve tilling the soil or chemical cultivation, building drainage and
erosion control structures, and adjusting soil pH.
Preparing the Soil by Tilling or Chemical Cultivation
Tilling aerates the soil, allows seeds/seedlings to be placed in the soil, and
helps roots take hold of the soil. It also improves drainage and allows for
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better assimilation of nutrients and pesticides into the soil. Tillage methods
generally consist of intensive/conventional, reduced tillage, and conservation
tillage. The difference in the tillage methods is the amount of soil disturbed
and the amount of crop residue allowed to remain during the current planting.
• Intensive/conventional tillage is sometimes conducted in two phases -
primary tillage with a moldboard plow followed by secondary tillage
with a power tiller or disc harrow. Intensive/conventional tillage can
range from complete tillage of the entire field to tillage that allows 15
percent of the crop residue to remain.
• Reduced tillage consists of disturbing from 15 to 30 percent of the soil
and crop residue.
• Conservation tillage methods are designed to reduce the loss of soil
erosion caused by wind and water. Conservation tillage methods allow
30 percent or more of the soil and crop residue to remain undisturbed
and thus reduce soil erosion by water and/or maintain at least 1,000
pounds per acre of flat, small grain residue to reduce soil erosion by
wind. Common conservation tillage methods are no-till, strip-till,
ridge-till, and mulch till.
— No-till has minimal soil disturbance since the seed is planted
with essentially no tillage of the soil and no disturbance of the
crop residue.
— Strip-till involves tillage of a narrow strip of soil and planting
of the seed or seedling in that tilled area.
— Ridge-till methods disturb a narrow strip of soil that was
created during previous cultivation. The crop is planted on the
ridge and the crop residue remains between each ridge.
- Mulch-till involves disturbing the entire soil surface and then
applying a crop protection product and/or cultivation2.
In addition to tilling, soil may be prepared for planting by chemical
cultivation. Chemical cultivation includes the application of a systematic
herbicide to kill weeds and grasses.
2 1998 Crop Residual Management Survey Executive Summary, Top 10 Conservation
Tillage Benefits, Conservation Tillage Information Center.
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Potential Pollution Outputs and Environmental Impacts
The primary pollution output from preparing soil for planting is soil
erosion. Erosion can reduce the productivity of the soil and increase
the need for additional fertilizer and other inputs. Sediments and other
pollutants (e.g., nutrients, pesticides) that are transported offsite may
eventually enter surface waters, settle out, and cause degradation of the
water quality. When it settles, the sediments fill interstitial spaces in
lake bottoms or streambeds. - They can eliminate essential habitat,
cover food sources and spawning sites, smother bottom-dwelling
organisms, and be detrimental to many species offish. Sediment
deposition also reduces the capacity of stream channels to carry water
and of reservoirs to hold water. This decreased flow and storage
capacity can lead to increased flooding and decreased water supplies.
Sediments can also be suspended in surface waters, which causes
increased water turbidity. Water turbidity limits the depth to which
light can penetrate and adversely affecting aquatic vegetation
photosynthesis. Suspended sediments can also damage the gills of
some fish species, causing them to suffocate. Turbid waters tend to
have higher temperatures and lower dissolved oxygen concentrations.
Decreased dissolved oxygen levels can kill aquatic vegetation, fish,
and benthic invertebrates.
Pollution Prevention/Waste Minimization Opportunities
The primary pollution prevention opportunities arise from the use of
reduced or conservation tillage methods, which reduce soil erosion and
maintain the existing soil structure (the way the soil particles clump
together into larger, almost crystalline, units). Advantages of
conservation tillage include:
i/' Greater water retention/reduced water usage and energy used
for pumping (by increasing the water retention capacity of
irrigated soils, there may be opportunities to lengthen periods
between irrigation events, thereby saving energy that would
otherwise have been used for pumping irrigation water).
v' Reduced erosion of sediment and runoff of nutrients.
^ Reduced fuel use due to reduced equipment use.
*/" Reduced wind erosion resulting in less dust.
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S Shading which reduces weed growth and subsequent herbicide
use. The effectiveness of shading is dependent on the type of
crop and distance between plants.
S Prevention of the growth of some molds that have a much
lower overwinter survival if not incorporated into the soil.
S Crop residues left undisturbed provide habitats for many
beneficial insects and spiders that help control crop predators
(e.g., cereal leaf beetle), thereby reducing the need for
insecticides. In addition, crop residues help speed the
decomposition process and aid plant nutrient cycling.
One possible disadvantage of conservation tillage methods is the
carryover of pests (e.g., weeds, diseases, and some insects) in the crop
residue. This may result in a subsequent increased use of pesticides
and increased level of pesticides in runoff.
Building Drainage and Erosion Control Structures
Erosion control practices are necessary for agricultural operations to control
runoff and reduce the amount of soil erosion caused by that runoff. In areas
with good drainage, crops are better able to use nutrients and chemicals and
will benefit from these optimum growing conditions. When building erosion
control structures, newly-graded soil surfaces may be stabilized with mulch
prior to the establishment of a vegetative cover.
To establish good drainage, one or a combination of drainage and erosion
control structures can be built and used depending on the site characteristics
(e.g., slope, crop type, or climate). These structures include:
• Diversions. Diversions are vegetated channels across the slope that
intercept surface runoff and redirect it along a gradient to a controlled
outlet. Diversions can reduce the amount of soil/sediment and related
pollutants delivered to surface waters.
• Grassed -waterways. Grassed waterways, which are shaped or graded
to specified dimensions, are used for the stable conveyance of runoff.
Grassed waterways can reduce soil erosion in areas:, such as gullies or
ephemeral gullies, with concentrated flows.
Water and sediment control basins. Water and sediment control basins
are constructed to collect and store debris or sediment. They detain
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runoff, allowing the sediment to settle out in the basin before the water
is discharged to a waterway.
Filter strips. Filter strips are vegetated areas that are used to trap
sediment, organic matter, and other pollutants that are carried in
runoff. While filter strips require frequent maintenance and have
relatively short service lives, they are generally effective in removing
pollutants when a shallow sheet flow is passed through the vegetated
areas.
Riparian buffers. Herbaceous or forest riparian buffers are areas of
grasses, shrubs, or trees placed upgrade from waterways and water
bodies. These buffers prevent or minimize damage to surface waters
by containing eroded sediment, chemicals, nutrients, and organics. In
addition, buffers reduce the amount of these pollutants that leach into
shallow groundwater.
Terracing and contouring. Terracing and contouring are practices that
both use sloped surfaces to reduce or control soil erosion. Terracing
involves shaping an area so that it is sloped, and contouring involves
moving soil in an area so that it is sloped.
Drainage tiles. Surface and subsurface drainage tiles are often used to
remove standing water from fields and direct them to more structured
erosion control measures.
Potential Pollution Outputs and Environmental Impacts
As described above for tilling, soil erosion and its impact to surface
waters is a significant environmental concern and the primary pollution
from building drainage structures. Wetlands, the interface between
terrestrial and aquatic systems, are particularly susceptible to impacts
from runoff and soil erosion. Such impacts include damage to
watershed hydrology and water quality, and the habitat for many
animal and plant species.
Pollution Prevention/Waste Minimization Opportunities
The primary pollution prevention opportunities of drainage and erosion
control structures are the minimization of soil erosion and the
reduction of runoff which transports nutrients, sediments, and
pesticides to the environment.
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Preventing or controlling erosion is
based on two main concepts: (1)
disturb the smallest area of land
possible for the shortest period of
time, and (2) stabilize the disturbed
soils to prevent erosion from
occurring. ]
Drainage and erosion controls
can reduce the amount of
sediment that is transported
.offsite in runoff. Any of the
drainage and erosion control
structures described above can
be used to reduce soil erosion
and transport. Additional
examples of erosion control
structures or activities include: field borders; grade, stabilization
structures; sediment retention ponds; reestablished wetlands;
immediate seeding, mulch/mats, and sodding to stabilize exposed soil
surfaces; wind erosion controls; and scheduled grading and shaping
(e.g., construction of diversions) during dry weather.
Adjusting the Soil pH
Adjusting the soil pH helps ensure the soil contains the proper characteristics
to maximize crop production. Many crop producers add materials to soil to
achieve a soil pH that maximizes crop production. Typically, alkaline
materials, such as lime, lime sulfur, caustic soda, caustic potash, soda ash,
magnesia, and dolomitic lime, are added to increase the pH in acidic soils.
Potential Pollution Outputs and Environmental Impacts
The adjustment of soil pH typically results in little to no pollution
outputs and generally has little to no environmental impacts.
However, impacts to surface waters could occur if spilled or
misapplied alkaline materials are carried in runoff.
Pollution Prevention/Waste Minimization Opportunities
The primary pollution prevention opportunities for this activity include
properly storing the materials used to adjust pH to minimize spills, and
applying these materials in a manner that minimizes runoff.
III.A.2. Planting/Tending Crops
Planting involves the placement of seeds or seedlings into the soil. This
activity can be conducted either by hand (in small operations) or mechanically.
Tending the product involves any post-planting activities designed to
maximize crop production at harvest. Tending may involve hand labor (e.g.,
hoeing or pruning) or machine labor.
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Potential Pollution Outputs and Environmental Impacts
Pollution outputs from planting crops include air emissions,
particularly dust, and wastes such as seed bags. The planting process
is often combined with other operations, such as tilling or
fertilizer/pesticide application, which can pollute surface waters and
groundwater from runoff and leaching, respectively. Tending activities
that disturb the soil may result in soil erosion, the impacts of which are
similar to those previously discussed under tilling. Tending may also
produce wastes (e.g., plant branches or other parts).
Pollution Prevention/Waste Minimization Opportunities
Air emissions from planting activities can be minimized by properly
maintaining farm machinery. Sections in.A.7 details how to operate
and maintain farm vehicles and machinery in an environmentally
responsible manner.
By buying seeds in greater bulk, farms can reduce the volume of seed
bags that must be disposed of. Also, certain innovative methods of
collecting and dispersing seeds are now available that eliminate the
need for bags.
III.A.3. Applying Nutrients to Crops
During various phases of crop production, nutrients such as nitrogen,
phosphorus, potassium, and other nutrients are applied to crops to enhance
crop growth. Nutrient use has been encouraged by the adoption of high-
yielding seeds that are more responsive to nutrient application. Therefore,
nearly all acres planted with crops are treated with one or more sources of
nutrients, such as fertilizers, manure, and/or biosolids.
Nutrients are applied directly to plants or the soil surface, incorporated or
injected into the soil, or applied with irrigation water. Nutrient application
methods are mechanically intensive, requiring coverage of vast areas.
Fertilizers maybe solids, liquids, or gasses and, depending on the state of the
product, may be applied'using specialized trucks, tractors pulling sprayer
equipment, or pressurized tanks to apply anhydrous ammonia. Techniques
used to apply fertilizer include:
• Band placement is used to locate the fertilizer in an optimum position
relative to the seed. This increases the potential for full utilization of
the fertilizer by the crop and minimizes salt injury to the developing
roots.
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Broadcast application refers to the practice of distributing the product
uniformly over the soil surface. This method is preferred for lawns
and forage and pasture crops and is the most common method used for
crops. Tractors, airplanes, and helicopters are all used to broadcast
fertilizers.
Manure injection refers to the application of anhydrous ammonia. At
normal pressure, anhydrous ammonia (NH3) is a gas. For application
as a fertilizer, it is pressurized to form a liquid. Because it is a volatile
liquid, it is incorporated into the soil as a liquid under pressure to a
depth of 15 to 25 cm. In the soil, NH3 is converted to NH4+, which is
stable. Gaseous ammonia is lost if soil pH increases much above 7, or
as moisture fluctuates from field capacity. Liquid manure may be
subsurface injected.
Addition of fertilizer to irrigation water (i.e., fertigation) is a common
practice in some areas and is usually part of a drip irrigation system
that can apply water and fertilizer to a precise predetermined location.
Manure and biosolids may be applied to the soil surface as a solid
from a tractor-pulled box-type manure spreader as it makes passes
across the field. Slurry manure and biosolids are generally applied to
the soil surface by tractor-pulled or truck flail spreaders or to the
subsurface by tractor or truck injection equipment. Liquid manure
may be surface irrigated or subsurface injected. Manure and biosolid
solids and slurries may be mechanically incorporated into the soil
following application.
Potential Pollution Outputs and Environmental Impacts
There are several potential pollution outputs and environmental
impacts from nutrient application and spills including runoff and
leaching of nutrients which can contaminate surface water and
groundwater; air emissions; and increases in the amount of soluble
salts in soils. Runoff and leaching of nutrients typically occur when
nutrients are applied excessively or improperly. Excessive amounts of
soluble salts in the soil can prevent or delay seed germination, kill or
seriously retard plant growth, and possibly render soils and
groundwater unusable.
The degree of environmental impacts can depend on the application
method. The surface application of fertilizer, manure, or biosolids is
more likely to result in runoff than injection. Non-composted surface-
applied manure will volatilize and release ammonia to the air. Spills
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of nutrients may also negatively impact the environment since they
will be concentrated in one specific area.
Pollution Prevention/Waste Minimization Opportunities
There are several pollution prevention techniques that can be used to
reduce pollution arid impacts from nutrient application. These include:
i/ Application methods that prevent runoff (e.g., application by
injection).
«/ Restricting application in close proximity to surface waters.
«/ Applying nutrients at agronomic (scientifically determined)
rates to crops/cropland.
i/ Managing the site to eliminate erosion or reduce the runoff
potential.
«/^ Developing and implementing nutrient management plans.
The primary purpose of nutrient management is to achieve the
level of nutrients (e.g., nitrogen and phosphorus) required to
grow the planned crop by balancing the nutrients that are
already in the soil with those from other sources (e.g., manure,
biosolids, commercial fertilizers) that will be applied. At a
minimum, nutrient management can help prevent the
application of nutrients at rates that will exceed the capacity of
the soil and the planned crops to assimilate nutrients and
prevent pollution.
A site-specific nutrient management plan should be developed
prior to planting, reviewed annually, and updated as needed.
The plan, which will direct the application of one or more
nutrients to the cropland, may include:
• Soil and field maps that show setbacks and buffers, as
well as wetland and groundwater maps.
• Crops and rotations.
Soil tests.
• The calculated nutrient loading for each field.
Additional plan components may consist of manure and
biosolid test results; projected manure production, storage, and
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treatment; commercial fertilizer needs; application rates; and
the method and timing of application.
Soils, manure, and wastewater should be tested to determine
nutrient content. Retesting should be completed following
each significant change in the manure/biosolids source or
manure waste management system.
i/' Precision farming. One of the more advanced technologies
for improving nutrient application efficiency is known as
precision farming. Typically used by larger operations,
precision farming allows farmers to know their location in the
field via a Global Positioning System (GPS) so that
applications can be made according to a predetermined rate for
that specific location. Precision farming may result in more
precise applications of nutrients so there is little or no excess
leached to groundwater or washed to surface waters.
III.A.4. Applying Pesticides and Pest Control
Pesticides (e.g., insecticides, herbicides, fungicides) may be applied during all
phases of crop production, including during harvesting and post-harvesting
activities. For crop production, pesticides prevent insects and other pests,
including weeds and other unwanted plants, from harming crops. Pesticide
use has been encouraged by continuous cropping, which has created favorable
pest habitats in certain crops.
Pesticide application methods for crops are mechanically intensive, requiring
coverage of vast areas. Pesticides are applied directly to the plant or soil
surface, incorporated into the soil, or injected as a gas through fumigation.
One of the most common methods of applying pesticides to crops is liquid
spraying. Liquid spraying may be conducted by aircraft, tractor spray rigs, or
blasters.
Aerial methods are the
most common application
type with about two-thirds
of all insecticides and
fungicides applied in this
Citrus groves may be aerially treated 10
to 20 times per season with insecticides,
fungicides, and protectant oils.
manner.
Helicopters are often used because the turbulence from the
main rotor tends to push the pesticides down toward the crop.
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- Fixed-wing aircraft are more commonly used in crops such as
wheat and cotton.
Tractor spray rigs are often used to apply herbicides in row crops
because planting, fertilizing, and spraying can be accomplished in one
pass through the field.
• Blasters are used for applying insecticides and fungicides to tree crops.
Other than the Agency's ultra-low volume exemption, concentrated pesticides
must be applied according to label directions including any requirement to
mix with a diluent or water. The mixing and subsequent loading into the
application vehicle must be conducted in a contained area.
Biopesticides. Biopesticides (also known as biological pesticides) are certain
types of pesticides derived from, such natural materials as animals, plants,
bacteria, and certain minerals. At the end of 1998, there were approximately
175 registered biopesticide active ingredients and 700 products. Biopesticides
fall into three major classes:
Microbialpesticides contain a microorganism (e.g., a bacterium,
fungus, virus, or protozoan) as the active ingredient. These pesticides
can kill many different kinds of pests. For example, there are fungi
that control weeds, other fungi that control cockroaches, and bacteria
that control plant diseases. The most widely used microbial pesticides
include various types of the bacterium Bacillus thuringiensis, or Bt. Bt
acts by producing a protein that kills the larvae of specific insect pests.
One kind of Bt can control specific insects in cabbage, potatoes, and
other crops, while another type of Bt kills mosquitoes. Based on
available information, the bacterium appears to have no adverse effects
on humans or the environment. However, additional data are needed
to ensure that products containing this bacterium are safe for honey
bees, wasps, fish, and aquatic invertebrates.
• Plant pesticides are pesticidal substances that plants produce from
genetic material that has been added to the plants. For example,
scientists can introduce the gene for the Bt pesticidal protein into a
plant's genetic material. The plant will then manufacture the
substance that destroys the pest. Both the Bt protein and its genetic
material are regulated by EPA; the plant itself is not regulated.
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• Biochemical pesticides are naturally occurring substances that control
pests by nontoxic mechanisms, hi contrast, conventional pesticides are
synthetic materials that usually kill or inactivate the pest. Biochemical
pesticides include substances, such as pheromones, that interfere with
the growth or mating of a pest. Because it is sometimes difficult to
determine whether a natural pesticide controls the pest by a nontoxic
mode of action, EPA has established a committee to determine
whether a pesticide meets the criteria of a biochemical pesticide.
Some of the advantages of using biopesticides are:
They are inherently less harmful than conventional pesticides.
• They generally affect only the target pest and closely related
organisms.
• They are often effective in very small quantities and often decompose
quickly, thereby resulting in lower exposures and largely avoiding the
pollution problems caused by conventional pesticides.
To use biopesticides effectively, users should have a solid understanding of
how to manage pests. When used as a component of integrated pest
management (IPM) programs, biopesticides can greatly decrease the use of
conventional pesticides, while still allowing crop yields to remain high.
Potential Pollution Outputs and Environmental Impacts
Environmental impacts most likely result from pesticide applications
that are not conducted according to label directions. Potential
pollution outputs and environmental impacts from pesticide
application may include:
• Runoff or leaching of pesticides to surface water or
groundwater. Pesticides incorporated into soil may leach into
the groundwater. Soil fumigants will include releases to
groundwater through leaching. Pesticides applied through
chemigation, in which the pesticide is combined and applied
with irrigation water, may be released to surface water through
runoff or to groundwater through leaching.
• Air emissions. The application of pesticides using spray
systems is more likely to involve releases to air. Soil fumigants
will include releases to air through volatilization.
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Spills to soil and surface waters. The impacts of spills maybe
more significant since the spilled materials will be concentrated
in one specific area.
Potential human exposure and residue levels that exceed
tolerance on animals and products. Pesticides are both
suspected and known for causing immediate and delayed-onset
health hazards for humans. If exposed to pesticides, humans
may experience adverse effects, such as nausea, respiratory
distress, or more severe symptoms up to and including death.
To help reduce this potential exposure, tolerance levels have
been established for residues on agricultural products. Animals
and birds impacted by pesticides can experience similar
illnesses or develop other types of physical distress. Following
label directions for application, protective gear, and disposal
will help ensure such environmental impacts do not occur.
Pesticides that are applied to water-saturated soils or highly
alkaline soils may not degrade as quickly as those applied
properly or with the appropriate pH additive. When pesticides
do not degrade, or do not bond with the plant or soil surface,
they are more likely to be released to the environment through
runoff.
If not protected with backflow prevention devices, pesticides
applied through spray systems that are connected to water
supplies can siphon back to the water source and potentially
contaminate drinking water systems. Also, improperly cleaned
and disposed pesticide containers may cause releases to the soil
and/or surface waters.
Outputs from pesticide applications can inhibit crop production
through the resurgence of pests after treatment, occurrence of
secondary pest outbreaks, and development of pesticide
resistance in target pests. In addition, the control of insects by
broad-spectrum insecticides also destroys beneficial insect
populations. Populations of many previously innocuous
species may then increase rapidly and cause major economic
damage.
Crop losses have occurred when pesticides were applied
improperly or drifted from a treated crop to nearby susceptible
crops; when excess residues prevent crops from being planted
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in rotation or inhibit the growth of susceptible crops; and when
excessive residues of pesticides accumulate on crops, causing
the harvested products to be unmarketable.
Pollution Prevention/Waste Minimization Opportunities
Environmental impacts from pesticides are minimized by following
label directions for application, and preventing or minimizing their use
wherever possible. Pesticide use accounts for a substantial portion of
farm production costs. By reducing their use, agricultural
establishments cannot only reduce production costs, but also reduce
environmental impacts of their operations.
Pesticide use and impact can also be minimized by using integrated
pest management approaches, new technologies, efficient application
methods, controls, and basic preventive measures. Examples of these
are presented below.
i/ Integrated pest management (IPM). IPM is an effective and
environmentally sensitive approach to pest management that
relies on a combination of common sense practices. IPM
programs use current, comprehensive information on the life
cycles of pests and their interaction with the environment. This
information, in combination with available pest control
methods, is used to manage pest damage by the most
economical means, and with the least possible hazard to
people, property, and the environment.
Crop management is a vital part of IPM because it may reduce
the concentration of pests. Crop rotation can help prevent
disease buildup. Rotation is particularly important when
conservation tillage methods are used. For grain crops, other
methods include planting of hybrid plants that are resistant to
leaf blights and stalk rot, plowing under chopped corn stalks
and leaves (which can kill some overwintering disease fungi,
but also may promote the growth of others that live below the
surface), and maintaining good drainage. An IPM plan should
indicate that when a pesticide is needed, and its selection is
based on persistence, toxicity, and leaching and runoff potential
such that the most environmentally friendly pesticide is used.
»^ Precision farming. One of the more advanced technologies
for improving nutrient and pesticide application efficiency is
known as precision farming. Typically used by larger
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operations, precision farming allows farmers to know their
location in the field via a Global Positioning System (GPS) so
that applications can be made according to a predetermined rate
for that specific location. Precision farming may result in more
precise applications of nutrients and pesticides so there is little
or no excess leached to groundwater or washed to surface
waters.
Controlled droplet application (CDA). CDA produces spray
droplets that are relatively uniform in size and allows the
applicator to control droplet size, hi contrast, conventional
spray nozzles produce droplets that vary widely from small
droplets that may drift or evaporate before reaching the target,
to large droplets that concentrate too much of the pesticide in
one spot. CDA improves the efficiency of pesticide
application, thus reducing overall pesticide use and cost, hi
addition, CDA may require less than one gallon of water per
acre, compared with 20-30 gallons per acre with most
conventional herbicide sprayers. CDA also provides time and
fuel savings as well as less soil compaction. (Cornell
University, Dr. Russel R. Hahn, Controlled Droplet
Application)
Chemigation. Another method of more efficient pesticide
application is chemigation. Chemigation systems are irrigation
systems that are designed for chemical application by injection
with the irrigation water. The systems provide reduced water
pollution by allowing prescription chemical applications to be
made. If chemicals are applied frequently and only in amounts
required by the irrigated crop, the presence of excessive
amounts are avoided, thus preventing leaching from occurring.
(University of Florida Cooperative Extension Service, 1993)
Erosion control devices. To control pesticide losses to surface
water, a farm should control erosion and reduce the volume of
runoff water that leaves the field or farm. Practices such as
conservation tillage, terraces, strip-cropping, and contouring
reduce runoff and control erosion. Sediment basins, farm
ponds, and wetlands contain or trap sediments. Keeping the
chemicals in the field or trapping them in biologically active
areas (e.g., ponds or wetlands) provides the opportunity for
microorganisms to degrade the pesticides, eventually rendering
them harmless.
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Basic preventive measures. Waste minimization strategies
for pesticides include:
— Buy only the amount needed for a year or a growing
season.
— Minimize the amount of product kept in storage.
— Calculate how much diluted pesticide will be needed
for a job and mix only that amount.
- Apply pesticides with properly-calibrated equipment.
— Use all pesticides in accordance with label instructions.
— Purchase pesticide products packaged in such a way as
to minimize disposal problems.
— Work with the state to locate a pesticide handler who
can use the excess pesticide.
- Return unused product to the dealer, formulator, or
manufacturer.
— Implement setbacks from wellheads for application and
storage.
— Use contact pesticides that do not have to be
incorporated into the soil.
— Use row banding application techniques, where
appropriate, to limit the amount of pesticide applied.
If possible, choose nonleachable pesticides labeled for
the crop and pest. Nonleachable pesticides are
considered those that are less likely to migrate from
their target crop.
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III.A.5. Irrigating Crops
Irrigation transports water
to crops primarily for
growth, but also to ease the
shock following transplant
and to keep the crops cool
in arid or excessive heat
conditions.
Irrigation has always been a component of crop
production and provides many benefits. Over
the past 150 years, the practice of irrigation has
increased dramatically, increasing the number
of farmable acres, producing consistent and
often higher yields, and making agriculture
possible in areas previously unsuitable for
intensive crop production.
In addition to these recognized benefits of irrigation, other factors have
contributed to the increase in its use. Investment in equipment to transport
water for agricultural use has been stimulated by federal policies. Such
policies have included high commodity support prices, tax incentives that
include investment credits, and accelerated depreciation for equipment, water
depletion allowances, and low interest rates.
In the western United States, irrigation has been encouraged by federal law,
which has provided subsidized irrigation water to western growers for nearly a
.century. As this and other subsidy programs have declined, the number of
irrigated acres has decreased. However, in the eastern states that have not
received direct water subsidies in the past, the number of irrigated acres is
expected to increase.
There are many different irrigation systems, all of which are designed to move
water from its source to where it can be used for crop production. Irrigation ...
water is typically obtained from pumping groundwater or surface waters from
onsite sources or from offsite sources such as rivers, pipelines, canals and
aqueducts that are operated by irrigation districts and private water companies.
Irrigation methods may consist of flood, stationary, and traveling systems.
• Flood systems allow the water to gravity sheet flow across the
cropland.
• Stationary systems include subsurface drip or trickle systems and
aboveground systems, which are permanently piped and may or may
not have spray heads.
• Traveling systems may be center pivot, linear-move, hard-hose, or
cable-tow. Irrigation systems such as the center pivot and linear-move
usually have multiple spray heads (guns). Hard-hose and cable-tow
systems usually have a single spray head.
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Potential Pollution Outputs and Environmental Impacts
The potential pollution outputs from irrigation include runoff and
leachate contaminated with pollutants (e.g., nutrients and pesticides)
and salinization. Water depletion is one of the significant
environmental impacts of irrigation. Irrigation can deplete surface
water supplies, not only from the removal of water from these sources
to use for irrigation, but also from the reduced volume of water
returning to surface water due to evaporation losses. Irrigation can
also deplete groundwater supplies. Water tables have fallen,
particularly in drier western states, because of large volumes of
groundwater being used for irrigation. Not only has this resulted in
less water for agriculture and other uses, it has also resulted in an
increase in the cost of water for all users. Land subsidence of up to 10
feet has resulted in some areas because of groundwater withdrawals
occurring at rates that exceeded groundwater recharge.
Irrigation contributes to the movement of nutrients and pesticides into
surface waters and groundwater, particularly in sandy soils. The
impacts of pollutants (e.g., nutrients, pesticides, and sediments) from
irrigation-induced runoff are similar to those discussed in Section
Mineralization and salinization of soils are additional impacts of
irrigation. Irrigation water, whether from groundwater or surface water
sources, has a natural base load of dissolved mineral salts. As the
water is consumed by plants or lost to the atmosphere by evaporation,
the salts remain and become concentrated in the soil. This is referred
to as the "concentrating effect." The total salt load carried by irrigation
return flow is the sum of the salt remaining in the applied water plus
any salt picked up from the irrigated land. Irrigation return flows
provide the means for conveying the salts to the surface water or
groundwater supplies. If the amount of salt in the return flow is low in
comparison to the total stream flow, water quality may not be degraded
to the extent that use is impaired. However, if the process of water
diversion for irrigation and the return of salinated water is repeated
many times along a surface water, water quality will be progressively
degraded for downstream irrigation use as well as for other uses. In
the western states, major aquifers have been depleted or destroyed
through salinization, or when withdrawals exceeded recharge rates.
Pollution Prevention/Waste Minimization Opportunities
There are several pollution prevention opportunities for irrigating
crops. First, minimizing the use of irrigation will reduce erosiojn,
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runoff, groundwater depletion, and salinization. It can also save
money by reducing the costs associated with irrigation. Other
pollution prevention techniques include:
^ Using well-designed irrigation systems. A common cause of
environmental impacts from irrigation is poor system design.
Poorly designed systems may apply water nonuniformly,
allowing some areas to become oversaturated while others do
not receive adequate water. Areas not adequately irrigated may
suffer yield or quality reductions, while overirrigated areas may
suffer from the leaching of chemicals.
y Using efficient irrigation systems. There are several types of
efficient irrigation systems, including surge irrigation systems
and drip irrigation systems.
— With surge irrigation, water is sent through the furrows
between each row of crops. Rather than sending all the
water at once, small amounts are sent in bursts. In this
manner, erosion is reduced, more water reaches the •
plant, and less runoff of irrigated water occurs.
— In drip irrigation, plants are watered directly from the
irrigation source. While drip irrigation conserves water,
by watering only the plants' fruits and the soil
immediately around them, drip irrigation can also lead
to soil erosion. If drip irrigation is the sole method
used, the soil between rows of crops remains dry, thus
making it more susceptible to wind erosion.
The Texas Agricultural Extension Service has found irrigation
efficiency for surge irrigation up to 90 percent and drip irrigation to be
up to 98 percent. These systems significantly reduce the amount of
irrigation water that can runoff to surface waters, thus reducing
pollution. Conventional systems have a much lower efficiency rate.
The efficiency of all methods can be improved by varying application
volumes as water tables rise and fall.
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Calculating Fuel Use Efficiency for Irrigation Pumps
The Texas Agricultural Extension Service has developed a program to
determine the efficiency of various irrigation methods. The program
calculates a pumping plant's fuel use efficiency performance and compares it
to a given standard. The program also calculates the fuel cost per acre-inch
pumped and fuel cost savings if a pumping system is brought up to the
performance standard. The program can be used to evaluate the pumping
performance and fuel cost for the following fuels: (1) electricity, (2) natural
gas, (3) diesel, (4) gasoline, (5) propane, and (6) butane.
In addition to well-designed and efficient irrigation systems, there are
many inexpensive best management practices that can be used to
reduce runoff and erosion, and lower irrigation costs. These methods
include the following:
S Assure all irrigation systems are in good rep'air, with no leaks,
and that the sprinklers are adjusted to minimize misdirected
spray.
i/' Use low-volume spray heads and stop watering if puddling and
runoff is observed.
S Irrigate early in the morning or in the evening when it is
generally less windy and cooler. .
S Utilize efficient irrigation methods such as drip irrigation.
Many existing spray systems can be changed to function as drip
systems.
S Install check valves to prevent downhill sprinkler heads from
draining after the system has been shut off. This keeps water in
the pipes for the next sprinkling. Follow manufacturer's
instructions.
S Install "rainguards" that measure rainfall and stop operation of
the irrigation controller during rainfall.
S If nutrients are irrigated, calculate the discharge rate of the
system and irrigate only at desired loading.
S Replace worn irrigation nozzles (increased orifice size) that
may result in over application.
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III.A.6. Harvesting Crops and Post-Harvesting Activities
Harvesting crops involves digging, cutting, picking, or other methods of
removing the crops from the ground, stalks, vines, or trees. Small fruits and
other food crops (e.g., strawberries, melons) are typically harvested by hand,
though may be harvested by machine. Field crops (e.g., corn, barley, oats) are
typically harvested by machine. For specific crops, such as sugar cane, pre-
harvest burning may be conducted to improve access to the crop.
Post-harvesting activities include washing and processes products; packaging,
loading, and transporting products; and destroying crop residue (if
appropriate).
• Washing, processing, and packaging products. Crops may be washed
at the agricultural establishment or at the processing plant. Fresh
agricultural crops may be washed at the agricultural establishment and
then shipped directly to distribution centers or sales outlets.
Agricultural crops destined for use as processed foods (e.g., canned
fruits and vegetables or snack foods), are likely to undergo extensive
washing and processing at the processing plant. Unusable crops can
either be picked up manually or separated but from the usable stock
after the washing process.
Following processing, crops are packaged and prepared for delivery to
the appropriate customer.' Crops such as tobacco require drying during
the onsite curing processing. Crops may be packaged using various
materials, including corrugated cardboard, paper, and plastic/fabric
packaging materials.
• Loading and transporting products. While the loading operation will
vary between establishments, individually packaged crops (e.g.,
berries), are commonly loaded by forklift or by hand, while bulk
packaged crops (e.g., potatoes and apples) may be loaded by conveyor.
Crops are then transported typically by truck or rail to their final
destination.
• Destroying crop residue. Post-harvest crop residue destruction is a
practice used for specific crops, particularly in certain areas of the
United States. For example, rice and wheat stubble are often burned in
the southeast and northwest respectively after harvest is complete.
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Potential Pollution Outputs and Environmental Impacts
The potential pollution outputs of harvesting and post-harvesting
activities include air emissions from harvesting equipment and crop
residue burning; unusable or spilled crop; wastewater potentially
contaminated with organic wastes and pesticides from crop washing;
wastewater and waste product from processing; and damaged or
unusable packaging materials. If discharged to surface waters,
wastewater from crop washing can potentially cause BOD
contamination. Damaged or unusable packaging and unusable/spilled
crop may be managed as solid waste. Hydraulic lifts or conveyors used
in the loading process may leak oil, resulting in soil contamination.
Pollution Prevention/Waste Minimization Opportunities
There are several pollution prevention and waste minimization
opportunities for harvesting and post-harvesting activities. These
include:
i/ Maintaining harvesting machinery and vehicles. Section
HI. A.7. Maintaining and Repairing Agricultural Machinery
and Vehicles discusses various methods of keeping an
environmentally responsible farm vehicle.
«/ Using unusable product as nutrients. Unusable products can be
washed to remove pesticides and then composted for future use
as nutrients. This can prevent the disposal of these products as
solid wastes and reduce the amount of commercial fertilizers
used.
»/ Minimizing water use for product washing. Minimizing the
amount of water used for product washing can reduce potential
BOD contamination and reduce water costs. There are several
types of equipment that can be used to minimize water use
including control faucets and sprayers. These faucets and
sprayers control the flow of water, using significantly less
water than the faucets that supply a continuous flow of water.
Other simple techniques to minimize water use include the
following:
— Installing a time sequence sprayer that can minimize the
amount of water being used.
— Using a high-pressure, low-flow nozzle during cleaning
to significantly reduce water use.
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— Installing sideboards or splash guards to prevent
spillage.
— Shutting the water off during breaks.
S Prevent contamination from oil leaks. Place catch pans
underneath hydraulic lifts or conveyors to collect oil leaks and
prevent soil contamination. This oil can then be recycled.
S Prevent product spills. The use of sideboards on conveyors or
other equipment designed to transport products from the
ground into the vehicle can be used to prevent product spills.
Additionally, catch pans or containers underneath loading areas
can be used to collect any unusable products left on the ground.
These products can then be composted, if appropriate.
III.A.7. Maintaining and Repairing Agricultural Machinery and Vehicles
Day-to-day maintenance and repair activities keep agricultural machinery and
vehicles safe and reliable. Maintenance activities include oil and'filter
changes, battery replacement, and repairs, including metal machining.
Potential Pollution Outputs and Environmental Impacts
The wastes from maintenance and repair activities can include used
oil, spent fluids, spent batteries, metal machining wastes, spent organic
solvents, and tires. These wastes have the potential to be released to
the environment if not handled properly, stored in secure areas with
secondary containment,
protected from exposure
to weather, and properly
disposed of. If released
to the environment, the
impact of these releases
can be contamination of
surface waters,
groundwater, and soils,
as well as toxic releases
to the atmosphere.
Groundwater pollution
can also result from
discharges of wastes to
Class V wells.
Proper Disposal of Oil-Based Fluids.
Spent petroleum-based fluids and solids
should be sent to a recycling center
whenever possible. Solvents that are
hazardous waste must not be mixed with
used oil or, under RCRA regulations, the
entire mixture may be .considered
hazardous waste. Non-listed hazardous
wastes can be mixed with waste oil, and
as long as the resulting mixture is not
hazardous, can be handled as waste oil.
All used drip pans and containers should
be properly labeled.
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Pollution Prevention/Waste Minimization Opportunities
Preventive maintenance programs can minimize waste generation,
increase equipment life, and minimize the probability of significant
impacts and accidents. Where the wastes cannot be eliminated, safe
handling and recycling can minimize environmental impacts. The
following presents pollution prevention/waste minimization
opportunities for each type of waste.
Used Oil. The impact of oil changes can be minimized by preventing
releases of used oil to the environment, and recycling or reusing used
oil whenever possible. Spills can be prevented by using containment
around used oil containers, keeping floor drains closed when oil is
being drained, and by training employees on spill prevention
techniques. Oil that is contained rather than released can be recycled,
thus saving the farm money, and protecting the environment.
Recycling used oil requires equipment like a drip table with a used oil
collection bucket to collect oil dripping from parts. Drip pans can be
placed under machinery and vehicles awaiting repairs to capture any
leaking fluids. By using catch pans or buckets, rather than absorbent
materials to contain leaks or spills of used oil, the used oil can be more
easily recycled. To encourage recycling, the publication "How To Set
Up A Local Program To Recycle Used Oil" is available at no cost from
the RCRA/Superfund Hotline at 1-800-424-9346 or 1-703-412-9810.
Spent Fluids. Farm machinery and vehicles require regular changing
of fluids, including oil, coolant, and others. To minimize releases to
the environment, these fluids should be drained and replaced in areas
where there are no connections to storm 'drains or municipal sewers.
Minor spills should be cleaned up prior to reaching drains. Used fluid
should be collected and stored in separate containers. Fluids can often
be recycled. For example, brake fluid; transmission fluid, and gear oil
are recyclable. Some liquids are able to be legally mixed with used
motor oil which, in turn, can be reclaimed.
During the process of engine maintenance, spills of fluids are likely to
occur. The "dry shop" principle encourages spills to be cleaned
immediately so that spilled fluid will not evaporate to air, be
transported to soil, or be discharged to waterways or sewers. The
following techniques help prevent and minimize the impact of spills:
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/ Collect leaking or dripping fluids in designated drip pans or
containers. Keep all fluids separated so'they may be properly
recycled.
S Keep a designated drip pan under the vehicle while unclipping
hoses, unscrewing filters, or removing other parts. The drip
pan prevents splattering of fluids and keeps chemicals from
penetrating the shop floor or outside area where the
maintenance is occurring.
S Immediately transfer used fluids to proper containers. Never
leave drip pans or other open containers unattended.
Radiator fluids are often acceptable to antifreeze recyclers. This
includes fluids used to flush out radiators during cleaning. Reusing the
flushing fluid minimizes waste discharges. If a licensed recycler does
not accept the spent flushing fluids, consider changing to another
brand of fluid that can be recycled.
Batteries. Farm operators have three options for managing used
batteries: recycling through a supplier, recycling directly though a
battery reclamation facility, or direct disposal. Most suppliers now
accept spent batteries at the time of new battery purchase. While some
waste batteries must be handled as hazardous waste, lead acid batteries
are not considered hazardous waste as long as they are recycled. In
general, recycling batteries may reduce the amount of hazardous waste
stored at a farm, and thus reduce the farm's responsibilities under
RCRA.
The following best management practices are recommended to prevent
, used batteries from, impacting the environment prior to disposal:
S Place on pallets and label by battery type (e.g., lead-acid,
nickel, and cadmium).
S Protect them from the weather with a tarp, roof, or other means.
S Store them on an open rack or in a watertight secondary
containment unit to prevent leaks.
S Inspect them for cracks and leaks as they come to the farm. If a
battery is dropped, treat it as if it is cracked. Acid residue from
cracked or leaking batteries is likely to be hazardous waste
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under RCRA because it is likely to demonstrate the
characteristic of corrosivity, and may contain lead and other
metals.
S Neutralize acid spills and dispose of the resulting waste as
hazardous if it still exhibits a characteristic of a hazardous
waste.
«/ Avoid skin contact with leaking or damaged batteries.
Machine Shop Wastes. The major hazardous wastes from metal
machining are waste cutting oils, sp6nt machine coolant, and
degreasing solvents. Scrap metal can also be a component of
hazardous waste produced at a machine shop. Material substitution
and recycling are the two best means to reduce the volume of these
wastes.
The preferred method of reducing the amount of waste cutting oils and
degreasing solvents is to substitute with water-soluble cutting oils. If
non-water-soluble oils must be used, recycling waste cutting oil
reduces the potential environmental impact. Machine coolant can be
recycled, either by an outside recycler, or through a number of in-
house systems. Coolant recycling is most easily implemented when a
standardized type of coolant is used throughout the shop. Reuse and
recycling of solvents also is easily achieved, although it is generally
done by a permitted recycler. Most shops collect scrap metals from
machining operations and sell these to metal recyclers. Metal chips
which have been removed from the coolant by filtration can be
included in the scrap metal collection. Wastes should be carefully
segregated to facilitate reuse and recycling.
III.A.8. Fuel Use and Fueling Activities
Fuel is used to operate agricultural machinery, equipment, and vehicles that
are used throughout almost every step of crop production, including preparing
the site/soil, planting and tending the crops, applying nutrients and pesticides,
irrigating and harvesting the crops, and post-harvesting activities. Agricultural
machinery and vehicles are typically fueled using an aboveground fueling
dispenser that is connected to an aboveground or underground fuel tank.
Potential Pollution Outputs and Environmental Impacts
Agricultural machinery and vehicles that use fuel most likely emit
pollutants to the atmosphere. The activity of fueling itself can emit air
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pollutants, and spills of fuel can cause water, soil and groundwater
contamination. Underground fueling systems that are not monitored or
maintained properly can leak into the surrounding soils and eventually
contaminate groundwater.
Pollution Prevention/Waste Minimization Opportunities
Properly maintaining fuel tanks, lines, and fueling systems can
substantially reduce the probability of accidental fuel spills or leaks.
All leaking pipe joints, nozzle connections, and any damage to the
fueling hose (e.g., kinks, crushing, breaks in the carcass, bulges,
blistering, soft spots at the coupling, deep cracks or cuts, spots wet
with fuel, or excessive wear) should be fixed immediately to reduce
the amount of pollution to the environment. Spill and overflow
protection devices can be installed to prevent fuel spills and secondary
containment can be used to contain spills or leaks. Additional pollution
prevention techniques for fueling include the following:
t/ Inspect fueling equipment daily to ensure that all components
are in satisfactory condition. While refueling, check for leaks.
t/' If refueling occurs at night, make sure it is carried out in a well-
lighted area.
^ Never refuel during maintenance as it might provide a source
of ignition to fuel vapors.
»/ Do not leave a fuel nozzle" unattended during fueling or wedge
or tie the nozzle trigger in the open position.
v^ Discourage topping off of fuel tanks.
III.A.9. Maintaining the Facility
Providing Drinking Water
As part of maintaining the physical site,
an owner often is responsible for
providing and maintaining a safe source
of drinking water for those individuals
who live or work at the site. Water
provided from a surface water supply or
groundwater supply may be considered
a public water system and, as such, is
subject to federal regulations. To be
A public water system is a system
that receives water from a well,
river, reservoir, or other sources,
and serves piped water to at least
15 service connections or regularly
serves an average of 25 people
each day for at least 60 days.
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subject to the Safe Drinking Water Act, the system must meet set criteria such
that it is classified as one of the following water systems: community, non-
transient non-community, or transient non-community. To ensure the drinking
water source, whether surface or groundwater, is not contaminated, the
regulations require the owner of the public water system to conduct periodic
monitoring and analyses.
Potential Pollution Outputs and Environmental Impacts
Surface water supplies may become contaminated through runoff.
Groundwater supplies may become contaminated through a variety of
sources, including runoff and leaching, improperly grouted wellheads,
improperly constructed or sited wellheads, or faulty onsite septic
systems. Potential environmental impacts from contaminated drinking
water include a wide variety of health effects for those who ingest it.
Depending on the contaminant, the water may cause short-term
illnesses and may also lead to long-term health effects.
Pollution Prevention/Waste Minimization Opportunities
The primary concern with drinking water is to ensure it does not
become contaminated. The previous sections of this chapter discussed
the pollution prevention methods associated with crop production that
can help ensure that surface water or groundwater does not become
contaminated, and thus result in contaminated drinking water.
Managing Equipment Containing PCBs
Facility maintenance includes managing equipment that may contain PCBs,
such as generators, electrical transformers and their bushings, capacitors,
reclosers, regulators, electric light ballasts, and oil switches. Facilities must
ensure through activities related to the management of PCBs (e.g., inspections,
proper storage) that human food or animal feed are not exposed to PCBs.
Potential Pollution Outputs and Environmental Impacts
The potential pollution outputs are spills or leaks of PCB-containing
oil from this equipment and hazardous air emissions in the event of an
electrical fire. These releases can result in air, water, and soil
contamination. While the regulations do not establish a specific
distance limit, any item containing PCBs is considered to pose an
unacceptable exposure risk to food or feed if PCBs released in any
form have the potential to reach/contaminate food or feed.
Pollution Prevention/Waste Minimization Opportunities
There are, several techniques that can be used to prevent releases of
PCBs to the environment and contamination of food or feed These
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include replacing the PCB-containing equipment; replacing the PCB-
containing oil with oil that does not contain PCBs; providing
secondary containment of the equipment so that spills cannot
contaminate the soil or groundwater; and relocating the equipment to a
. location that does not present an exposure risk to food or feed. PCB-
. containing equipment should be inspected regularly for leaks and any
deterioration that may cause an electrical fire.
Renovating and Demolishing Structures
Asbestos and lead-based paint may be present in structures that are being
renovated or demolished. While EPA banned the use of many asbestos-
containing materials in the 1970s, buildings built before this are likely to have
asbestos-containing materials. Used as insulation and a fire retardant, asbestos
and asbestos-containing materials can be found in a variety of building
construction materials, including pipe and furnace insulation materials,
asbestos shingles, millboard, textured paint and other coating materials, and
floor tiles. It is also found in vehicle brake linings. Lead-based paint can .
typically be found on the interiors and exteriors of buildings constructed prior
to 1978. This is because EPA banned the manufacture and use of lead-based
paint and lead-based paint products in 1978.
Potential Pollution Outputs and Environmental Impacts
The renovation and demolition of structures can impact the
environment as materials that may have previously been trapped within
or on buildings become exposed to the environment. When
encapsulated, asbestos fibers do not impact human health or the
environment. However, during renovation or demolition, asbestos
fibers may be released. If inhaled or ingested, asbestos fibers can
cause respiratory damage.
Lead is a known carcinogen through any exposure pathway and may
result in significant health effects. As with asbestos, lead-based paint
that remains intact and is not chipping or otherwise deteriorating, does
not present health problems. However, when it does become damaged,
it should be properly removed, contained, and disposed of to prevent
exposure. The activity of paint removal has the potential to impact
human health and the environment as lead-containing fibers, dust, and
paint chips are released. Paint chips and dust can cause indoor air
contamination during renovation, and soil contamination from
demolition or improper disposal, hi addition, lead-based paint chips
and dust, if ingested, can create severe, long-term health effects,
especially for children.
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The potential impact can be mitigated by assuring any asbestos is
encapsulated within the building structure while the building is being
used, and properly contained during construction and demolition.
III.B. Greenhouses and Nurseries: Operations, Impacts, and Pollution Prevention
Opportunities
This section provides an overview of commonly employed operations and
maintenance activities at greenhouses and nurseries. This discussion is not
exhaustive; the operations and maintenance activities discussed are intended
to represent the major sources pollution outputs and environmental impacts
from producing greenhouse and nursery products. General pollution
prevention and waste minimization opportunities are also discussed in the
context of each operation.
Facilities that are engaged in greenhouse and nursery operations (e.g.,
horticulture), are responsible for growing and selling greenhouse and nursery
products. Many of the activities related to horticulture production are quite
similar to those necessary for production of crops. As a result, the material
inputs, pollution outputs, and potential environmental impacts are very similar
to those discussed throughout Section ni.A.
While this section focuses on those activities for operations that fall under
NAICS code 0114 (SIC code 018), many of these activities also take place
under other parts of NAICS code 011 - Crop Production (SIC code 01). In
contrast to food crops, horticultural production may include maintenance of
plants and trees for two or more growing seasons. While food crops are
harvested to be consumed, horticulture products are often sold live.
Furthermore, horticulture production includes activities that take place both
indoors and in the open air.
This section describes the following horticultural production activities:
• Preparing soil/growing media for horticulture crops
• Planting horticulture crops
Applying nutrients to horticulture crops
Applying pesticides and pest control for horticulture crops
• Irrigating horticulture crops
• Tending and harvesting horticulture crops
• Constructing and maintaining greenhouses
• Transporting products
• Maintaining and repairing equipment
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• Fuel use and fueling equipment
Exhibit 21 presents material inputs and pollution outputs from each of these
processes.
Exhibit 21. Greenhouse and Nursery Production Activities,
Raw Material Inputs, and Pollution Outputs
Activity
Preparing soil/growing media
Planting
Applying nutrients
Applying pesticides and pest
control
Irrigating (not including nutrient
application)
Tending and harvesting
Constructing and maintaining
greenhouses
Packaging, loading, and
transporting horticulture crops
Raw Material Input
- Soil, peat, or other synthetic
growing media
— Lime
- Seeds, seedlings
, — Organic nutrients
- Commercial nutrients
- Water
— Pesticides (including
insecticides, rodenticides,
fungicides, and herbicides)
- Water
- Chemicals
— Construction materials
— Fuel for heating and cooling
— Boiler chemicals
- Plastic, burlap or paper
packaging materials
Pollution Output
- Air emissions (e.g., dust)
- Sediment, nutrient, and
pesticides runoff from soil
erosion
— Air emissions (e.g., dust)
— Sediment, nutrient, and
pesticide runoff from soil
erosion
- Plants, branches, leaves, etc.
— Runoff and leaching of
unused or misapplied
nutrients
- Chemical air emissions
— Runoff and leaching of
unused or misapplied
nutrients
— Chemical air emissions
— Runoff contaminated with
sediments, salts, pesticides,
and nutrients
— Plant and tree clippings
— Construction wastes
— Air emissions
— Storm water runoff from
increased impervious area
- Spills of boiler chemicals
— Dead plants
— . Waste packaging materials
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Exhibit 21. Greenhouse and Nursery Production Activities,
Raw Material Inputs, and Pollution Outputs
Activity
Maintaining and repairing
equipment
Fuel use and fueling activities
Raw Material Input
- Oil
- Lubricating fluids
- Fuel
— Coolants
— Solvents
— Tires
— Batteries
— Equipment parts
- Fuel
Pollution Output
- Used oil
— Spent fluids
— Spent batteries
— Metal machining wastes
— Spent organic solvents
— Tires
— Air, water, soil, and
groundwater pollution
resulting from spilled and/or
spent fluids
— Air emissions from machinery
— Air, water, soil, and
groundwater pollution
resulting from spills
III.B.l. Preparing Soil/Growing Media for Horticulture Crops
Prior to planting, the soil or growing media3 must be prepared for growing
horticulture crops. For horticulture crops grown outdoors, soil preparation
generally involves tilling and the application of nutrients, primarily
commercial fertilizer. Tilling aerates the soil, allows seedlings to be placed in
the soil, and helps roots take hold of the soil. It also improves drainage and
allows for better assimilation of nutrients (i.e., fertilizers) and pesticides into
the soil. For greenhouse crops, proper soil or media preparation is key for
fostering plant growth. Due to the relatively shallow depth and limited
volume of greenhouse containers, soil must be amended to provide the
physical and chemical properties necessary for plant growth.4 Materials are
added to the soil that promote improved aeration, drainage, and water holding
capacity. These materials can include peat and peat-like materials, wood
residues, rice hulls, sand, vermiculite, calcined clays, expanded polystyrene,
urea formaldehydes, and bagasse (a waste byproduct of the sugar industry that
is often composted to promote aeration). In addition, soil pH is often
3 Note that many indoor growing operations use non-soil media consisting of peat moss,
compost, lime, and other material, rather than soil in order to provide a more porous growth
environment in a relatively small volume container.
4Texas Greenhouse Management Handbook, Dr. Don Wilkerson, Texas Agricultural
Extension Service, http://aggie-horticulture.tamu.edu/greenhouse/guides/green/green.html.
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adjusted by adding ground limestone, hydrated lime, or dolomitic lime to suit
the plants being grown.5
Potential Pollution Outputs and Environmental Impacts
The major environmental impacts of soil/growing media preparation in
horticulture operations is runoff that carries pollutants (e.g.,
soils/growing media, nutrients, pH adjusting agents, pesticides) to
groundwater or surface waters.
For outdoor operations, the primary pollution output is runoff
contaminated with pollutants (e.g., sediments, nutrients, and
pesticides) caused by soil erosion. Soil erosion causes damage both
onsite and offsite at horticulture operations. Onsite erosion can reduce
the productivity of the operation and increase the need for fertilizer and
other inputs. Pollutants (e.g., sediments, nutrients, and pesticides) that
are transported offsite by runoff may be deposited in surface waters,
leading to reduced oxygen content, increased algae growth, and overall
degradation of water quality.
Indoor operations can also be sources of water pollution. Runoff that
comes in contact with spills of soil/soil media, improperly managed
outdoor bulk soil/media piles, or discharges of floor washdown water
can transport sediments and other pollutants to surface waters. Spilled
or excessively applied lime also has the potential to contaminate
groundwater or surface waters.
Pollution Prevention/Waste Minimization Opportunities
When preparing soil for outdoor operations, runoff can be reduced by
planting and maintaining buffer strips of grass and sod. These strips
can slow runoff and trap sediment, reducing soil loss and potentially
preventing water contamination. Horticulture operations that maintain
grass strips between rows of plants or trees have been shown to
maintain 30 percent to 50 percent more soil than those that maintain
only bare soil.6
5Effect ofpHon Pesticide Stability and Efficacy, Winand K. Hock, Perm State University,
http://pmep.cce.coniell.edu/facts-slides-self/facts/gen-peapp-ph.html.
6 Best Management Practices for Field Production of Nursery Stock, North Carolina State
University Biological and Agricultural Engineering Extension Service, http://www.bae.ncsu.edu/
prbgrams/extension/ag-env/nursery/.
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Unnecessary application of materials that could potentially leach into
and pollute nearby water sources can be prevented through frequent
soil testing prior to application. Spills can be prevented by assuring
the integrity of the containers in which the materials are kept.
Containers should be routinely repaired and replaced if perforated.
III.B.2. Planting Horticulture Crops
Horticulture crops are planted after the soil/soil media is prepared. Planting
involves the placement of seeds or seedlings into the soil/soil media. Planting
is typically done by hand for greenhouse operations, while planting may be
done either by hand or mechanically for nursery operations.
Potential Pollution Outputs and Environmental Impacts
The major inputs in planting horticulture crops are the seeds and
energy used to plant them. The pollutant outputs include air emissions
from any planting equipment.
Pollution Prevention/Waste Minimization Opportunities
Pollution prevention opportunities during the planting process for
horticulture operations are similar to those discussed in Section m.A.2.
III.B.3. Applying Nutrients to Horticulture Crops
During all phases of the crop production process, nutrients (e.g., fertilizer,
manure, biosolids) can be applied to horticulture crops. Nutrients enhance
crop growth by providing essential nitrogen, phosphorus, potassium, and
micro-nutrients. Nutrients can be applied directly to the plant or soil surface,
incorporated into the soil, or applied with irrigation water through
chemigation.
Most greenhouse operations use liquid fertilizers, supplemented by granular or
slow release fertilizers which are added to the growing medium. While the
frequency of fertilizer application may vary, many operations continuously
fertilize through irrigation systems. For outdoor operations, nutrient
application is often more mechanically intensive, requiring coverage of large
. areas. Nearly all acres planted are treated with one or more types of nutrients
(e.g., fertilizers, manure, or biosolids). Depending on the timing of the seed
planting, the application may occur simultaneously.
For outdoor operations, fertilizers may be applied in solid, liquid, or gas form.
Depending on the state of the product, nutrients may be applied using
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specialized trucks to apply dry product, tractors to pull sprayer equipment for
liquids, and pressurized tanks to apply anhydrous ammonia. Techniques used
to apply fertilizer include the following:
• Band placement is used to locate the fertilizer in an optimum position
relative to the seed. This minimizes salt injury to the developing roots.
Broadcast application refers to the practice of distributing the product
uniformly over the soil surface. Tractors, airplanes and helicopters are
used to broadcast fertilizers.
Injection refers to the application of anhydrous ammonia. At normal
pressure, anhydrous ammonia (NH3) is a gas. For application as a
fertilizer, it is pressurized to form a liquid. Because it is a volatile
liquid, it is incorporated into the soil as a liquid under pressure to a
depth of 15 to 25 cm. In the soil, NH3 is converted to NH4+, which is
stable. Gaseous ammonia is lost if soil pH increases much above 7, or
as moisture fluctuates from field capacity.
Addition of fertilizer to irrigation water (known as fertigation), is
usually part of a drip irrigation system that can apply water and
fertilizer to a precise predetermined location.
• Manure and biosolids may be applied to the soil surface as a solid
from a tractor-pulled box-type manure spreader as it makes passes
across the field. Slurry manure and biosolids are generally applied to
the soil surface by tractor-pulled or truck flail spreaders or subsurface
by tractor or truck injection equipment. Liquid manure may be surface
irrigated or subsurface injected. Manure and biosolid solids and
slurries may be mechanically incorporated into the soil following
application.
Potential Pollution Outputs and Environmental Impacts
There are several potential pollution outputs and environmental
impacts from nutrient application and spills including runoff and
leaching of improperly or excessively applied nutrients which can
contaminate surface water and groundwater; air emissions; and
increases in the amount of soluble salts in soils. Excessive amounts of
soluble salts in the soil can prevent or delay seed germination, kill or
seriously retard plant growth, and possibly render soils and
groundwater unusable.
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The degree of environmental impacts depends on the application
method. The surface application of fertilizer, manure, or biosolids is
more likely to result in runoff than injection. Non-composted surface-
applied manure will volatilize and release ammonia to the air. Spills
of nutrients may also negatively impact the environment since they
will be concentrated in one specific area.
Pollution Prevention/Waste Minimization Opportunities
There are several pollution prevention techniques that can be used to
reduce pollution and impacts from nutrient application. These include:
^ Application methods that prevent runoff (e.g., application by
injection).
«/ Restricting application in close proximity to surface waters.
i/' Applying nutrients at agronomic rates to crops/cropland.
«/ Managing the site to eliminate erosion or reduce the runoff
potential.
«/ Developing and implementing nutrient management plans.
The primary purpose of nutrient management is to achieve the
level of nutrients (e.g., nitrogen and phosphorus) required to
grow the planned crop by balancing the nutrients that are
already in the soil with those from other sources (e.g., manure,
biosolids, commercial fertilizers) that will be applied. At a
minimum, nutrient management can help prevent the
application of nutrients at rates that will exceed the capacity of
the soil and the planned crops to assimilate nutrients and
prevent pollution. More information on nutrient management
plans is presented in Section m.A.3.
III.B.4. Applying Pesticides and Pest Control for Horticulture Crops
The pesticides commonly used in horticulture operations include insecticides,
fungicides, and herbicides. For large nursery operations, pesticides are often
applied through liquid spraying. As described in Section ni.A.4., liquid
spraying may be conducted by aircraft, tractor spray rigs, or blasters.
• Aerial methods are the most common spray applications, with about
two-thirds of all insecticides and fungicides applied in this manner.
Trees and shrubs may be aerially treated several times per season with
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insecticides, fungicides, and protec'tant oils. Helicopters are often used
because the turbulence from the main rotor tends to push the pesticides
down toward the plant.
Tractor spray rigs provide an advantage where horticulture crops are
grown in rows because planting, fertilizing and spraying can be
accomplished in one pass through the field.
Blasters can be used for applying insecticides and fungicides to trees.
Potential Pollution Outputs and Environmental Impacts
The potential environmental impacts from pesticide application are
runoff or leaching to surface water or groundwater, spills to surface
waters, potential human exposure, and soil contamination that could
leave land unproductive. These environmental impacts may all occur
if pesticides are not applied according to the label directions. Impacts
from pesticide application to horticulture crops are similar to those
discussed in Section III.A.4.
Pollution Prevention/Waste Minimization Opportunities
As discussed previously in Section III.A.4, the best way to prevent
environmental impacts from pesticide use is follow label directions for
application and prevent or minimize their use wherever possible.
Pesticide use accounts for a significant portion of horticulture
production costs. By reducing their use, horticulture operations cannot
only reduce production costs, but also reduce environmental impacts
from their operations. Pesticide use can be minimized by using
integrated pest management approaches, new technologies, efficient
application methods, controls, and basic preventive measures.
Pollution prevention opportunities for reducing or minimizing impacts
from application of pesticides are discussed in Section III.A.4.
III.B.5. Irrigating Horticulture Crops
Irrigation transports water to horticulture crops to nourish the crops, ease the
shock to the plants following transplant, and keep the crops cool in arid or
excessive heat conditions. There are many different irrigation systems, all of
which are designed to move water from its source to where it can be used for
crop production. Irrigation water is obtained from onsite groundwater and
surface water sources, as well as offsite sources such as rivers!, pipelines,
canals and aqueducts that are operated by irrigation districts and private water
companies.
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All greenhouse crops are irrigated on a regular basis (since they are enclosed
and do not receive water from rainfall events). Water is generally applied to
the upper surface of the soil/growing media by using overhead sprinklers, drip
or trickle irrigation systems, hand-held hoses, or a combination of methods.
The advantage of drip or trickle systems is that they minimize water use,
leaching of nutrients in the growth media, and reduce the probability of root
rot in excessively moist soil. Overhead sprinklers and hand water irrigation
methods are often less expensive to implement, but use more water per plant.7
Potential Pollution Outputs and Environmental Impacts
For indoor operations, the primary pollution outputs are wastewater
and runoff that contains nutrients and pesticides. For outdoor
horticulture operations, the pollution outputs from irrigation include
runoff and leaching of nutrients and pesticides, salinization, and
groundwater depletion. The impacts of pollutants (e.g., nutrients,
pesticides, and sediments) from irrigation-induced runoff are similar to
those discussed in Section III.A.5.
Pollution Prevention/Waste Minimization Opportunities
The primary pollution prevention opportunity for irrigation is the use
of irrigation methods which efficiently apply water, thereby reducing
water use and the potential for runoff. One efficient application
method is drip irrigation. Drip irrigation gradually applies water
directly to the soil surface over extended periods of time (i.e., 1, 2, or 5
gallons per hour), resulting in less water loss due to evaporation or
runoff. If nutrients are applied using drip irrigation, the amount of
fertilizer used can also be reduced if the nutrients are applied at the
utilization rate of the plant, hi addition to the environmental benefits,
drip irrigation tends to cause roots to concentrate within the limited
wetted soil area, thus creating a more concentrated root ball. More
concentrated root balls make the plants easier to ship and increase their
ability to survive through the sale and planting process.8 Section
m.A.5 describes other potential pollution prevention opportunities
associated with irrigation.
"] Texas Greenhouse Management Handbook, Dr. Don Wilkerson, Texas Agriculturall
Extension Service, http://aggie-horticulture.tamu.edu/greenhouse/guides/green/green.htrnl.
8 Best Management Practices for Field Production of Nursery Stock, North Carolina State
University Biological and Agricultural Engineering Extension Service, http://www.bae.ncsu.edu/
programs/extension/ag-env/nursery/.
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III.B.6. Tending and Harvesting Horticulture Crops
Horticulture crops must be maintained from planting through the point of sale.
Each plant may be tended for one or several growing seasons. Tending
horticulture crops involves applying water, nutrients, and pesticides;
transplanting crops from small to larger pots or from pots to outside areas; and
pruning trees and shrubs to enhance plant health and make them more
aesthetically pleasing.
Harvesting of horticulture crops involves digging, cutting, or other methods of
safely removing product from the ground, stalks, vines, or trees. Harvesting
must be done with care to protect the plant and assure that it remains alive
through the point of sale. For flowers, small plants, and greenhouse-grown
vegetables, harvesting is generally done manually. For larger trees and shrubs,
harvesting may be done by hand or by machine.
Potential Pollution Outputs and Environmental Impacts
The primary pollution outputs from tending and harvesting horticulture
crops are plant clippings (e.g., branches, leaves, and flowers) that have
been removed during the tending/pruning activities.
Pollution Prevention/Waste Minimization Opportunities
There are several pollution prevention and waste minimization
opportunities for tending and harvesting activities. These include:
• Maintaining harvesting machinery and vehicles. Section
m.A.7. Maintaining and Repairing Agricultural Machinery
and Vehicles discusses various methods of keeping an
environmentally responsible farm vehicle.
• Composting plant clippings. Plant clippings can be composted,
while tree clippings can be used as drying material to compost
the plant clippings. Tree clippings can also be ground as mulch
and reused in the fields or greenhouse. By placing wood waste
under covered structures or tarps, operators can also reduce the
decomposition and leaching from wood waste piles.9
9 Environmental Guidelines for Greenhouse Growers - Site Planning, British Columbia
Ministry of Agriculture and Food, 1998, http://www.agf.gov.bc.ca/resmgmt/fppa/pubs/environ/
greenhse/grnhse.htm.
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III.B.7. Constructing and Maintaining Greenhouses
Greenhouse construction and design can influence how effectively horticulture
crops grow, as well as the operation's ability to minimize environmental
impacts. Greenhouse construction includes building the structure and
ensuring that it meets the operational requirements of the horticulture
operation.
Greenhouse maintenance involves maintaining the structural integrity as well
as the appropriate climate conditions. Activities may include operating and
maintaining boilers that provide heat during cold weather; operating fans to
keep crops and workers cool during warm weather; and general maintenance
of the greenhouse itself.
Potential Pollution Outputs and Environmental Impacts
The potential pollutant outputs from greenhouse construction include
increased potential for storm water runoff during construction; air
emissions from construction equipment; and construction wastes
primarily consisting of packaging materials, steel or aluminum parts,
and waste concrete. Boilers used for heating greenhouse can produce
air emissions and potential spills of boiler chemicals can impact the
environment.
Pollution Prevention/Waste Minimization Opportunities
Many pollution prevention opportunities begin at the design and
construction stage. Pollution prevention opportunities in greenhouse
design include:
i/' Locating storage facilities for fuel, wood waste, fertilizer, or
pesticides far away and contained from any watercourse.
v^ Locating well water sites on the highest elevation on the
property and as far as possible from areas where fertilizer,
pesticides, and petroleum products are stored or handled.
»^ Designing the greenhouse so that it can accommodate efficient
drip irrigation systems.
»^ Planning facilities that can separate and disinfect irrigation or
wash water so that the water can be reused.
t/' Installing closed systems that minimize or prevent leaching
from irrigation systems. '
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Constructing foundations and floors that permit recovery of
leachate, such as lined soil zones and concrete floors.
Selecting efficient watering systems.
For outdoor areas, using well-drained gravel keeping
impervious pavement to a minimum.
10
Implementing these activities in the design and construction stage
helps facilitate their implementation throughout the production
process.
III.B.8. Packaging, Loading, and Transporting Products
Horticulture crops must be packaged, loaded, and transported,by truck or rail
to their destinations. Packaging materials may include plastic, burlap, or
paper.
Potential Pollution Outputs and Environmental Impacts
The primary pollution outputs include damaged or dead plants and
discarded packaging materials, all of which may be managed as solid
waste. Hydraulic lifts or conveyors used in the loading process may
leak oil, resulting in soil contamination.
Pollution Prevention/Waste Minimization Opportunities
Pollution prevention opportunities for packaging include reducing the
volume of packaging used and recycling any waste packaging
materials when possible. Pollution prevention ideas for reducing
emissions from transport vehicles are similar to those discussed in
Section III.A.7.
III.B.9. Maintaining and Repairing Machinery and Vehicles at Greenhouses/Nurseries
Horticulture operations operate and maintain heavy equipment that is used for
preparing soil, maintaining the crops, and transporting products for sale. Day-
to-day maintenance and repair activities keep machinery and vehicles safe and
reliable. Maintenance activities include oil and filter changes, battery
replacement, and repairs including metal machining.
10]
Environmental Guidelines for Greenhouse Growers - Site Planning, British Columbia
Ministry of Agriculture and Food, 1998, http://www.agf.gov.bc.ca/resmgmt/fppa/pubs/environ/
greenhse/grnhse.htm.
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Potential Pollution Outputs and Environmental Impacts
The wastes from maintenance and repair activities can include used
oil, spent fluids, spent batteries, metal machining wastes, spent organic
solvents, and tires. These wastes have the potential to be released to
the environment if not handled properly, stored in secure areas with
secondary containment, protected from exposure to weather, and
properly disposed of. If released to the environment, the impact of
these releases can be contamination of surface waters, groundwater,
and soils, as well as toxic releases to the atmosphere. Groundwater
pollution can also result from discharges of wastes to Class V wells.
Pollution Prevention/Waste Minimization Opportunities
Preventive maintenance programs can minimize waste generation,
increase equipment life, and minimize the probability of significant
impacts and accidents. Where the wastes cannot be eliminated, safe
handling and recycling can minimize environmental impacts.
Pollution prevention/waste minimization opportunities for these wastes
are similar to those discussed previously in Section ni.A.7.
HI.B.10. Fuel Use and Fueling Activities at Greenhouses/Nurseries
Fuel is used to operate agricultural machinery, equipment, and vehicles that
are used for horticulture crop production, including preparing the site/soil,
planting crops, applying nutrients and pesticides, irrigating, and post-
harvesting activities. Agricultural machinery and vehicles are typically fueled
using an aboveground fueling dispenser that is connected to an aboveground
or underground fuel tank.
Potential Pollution Outputs and Environmental Impacts
Agricultural machinery and vehicles that use fuel most likely emit
pollutants to the atmosphere. The activity of fueling itself can emit air
pollutants, and spills of fuel can cause water, soil and groundwater
contamination. Underground fueling systems that are not monitored or
maintained properly can leak into the surrounding soils and eventually
contaminate groundwater.
Pollution Prevention/Waste Minimization Opportunities
Properly maintaining fuel tanks, lines, and fueling systems can
substantially reduce the probability of accidental fuel spills or leaks.
All leaking pipe joints, nozzle connections, and any damage to the
fueling hose (e.g., kinks, crushing, breaks in the carcass, bulges,
blistering, soft spots at the coupling, deep cracks or cuts, spots wet
with fuel, or excessive wear) should be fixed immediately to reduce
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the amount of pollution to the environment. Spill and overflow
protection devices can be installed to prevent fuel spills and secondary
containment can be used to contain spills or leaks. Additional pollution
prevention techniques to prevent fuel spills and methods to more
efficiently refuel are discussed in Section III.A. 8.
III.C. Forestry Production Industry: Operations, Impacts, and Pollution Prevention
Opportunities
Nearly 500 million acres of forest land are managed for the production of
timber in the United States. This section provides an overview of commonly
employed operations and maintenance activities in the forestry industry. This
discussion is not exhaustive; the operations and maintenance activities
discussed are intended to represent the major sources of environmental
impacts from forestry. It also presents an overview of pollution prevention
and waste minimization opportunities within the industry.
Summary of General Potential Pollution Outputs and Environmental Impacts for
the Forestry Production Industry
EPA's National Summary of Water Quality Conditions (1998) lists
silviculture nonpoint source pollution as contributing to 7 percent of impaired
river miles, 7 percent of impaired acres of lakes, and 3 percent of impaired
square miles of estuaries. Forestry activities can contribute to nonpoint source
pollution and water quality degradation through erosion, removal of
streamside vegetation, destruction of habitat, and the use of pesticides and
nutrients, primarily commercial fertilizers. Habitat destruction can impact
various animals, including endangered species such as the spotted owl.
Eroded forest soils potentially are carried to surface waters where
sedimentation occurs and stream life is negatively impacted. The removal of
streamside vegetation increases the potential for erosion and also eliminates
shading of the waterbody. Turbidity from erosion and reduced shade result in
higher water temperatures and lower dissolved oxygen concentration.
Pesticides and fertilizers can be carried in runoff to waterbodies affecting
water quality.
Summary of General Pollution Prevention/Waste Minimization Opportunities for
the Forestry Production Industry
Best management practices applied to forestry operations can be classified as
1) prevention measures as part of planning, policy and management; and 2)
reduction measures applied to the land as an integral part of the silvicultural
activity. Prevention through management decision involves the incorporation
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of environmental protection into organizational policy and in the planning,
design and scheduling of forestry activities. At this stage, location and design
of logging access roads, intermediate activities, harvesting methods, and
reforestation decisions should be made to prevent or minimize the aggravation
of inherent pollution hazards.
The reduction measures to control erosion and sediment runoff generally
utilize some physical, biological, or chemical method or technique. Reduction
measures modify and reduce the unavoidable disturbances caused by an
activity, for example, revegetation of cleared areas, mulching of readouts and
fills", and removal of debris from watercourses, Reduction measures also .
include the construction of berms, rip-rapping, baffles, drop structures, catch
basins, cross-drains, and slope stabilization on road sites. Because of the
widespread nature of sediment runoff, erosion control measures must be a
principal thrust of the water quality management program on each forestry
management unit.
In areas where nutrients, pesticides, and other chemicals cause particular
problems on surface waters or groundwater, further control measures may be
necessary. These measures could relate to the application (timing methods
and amount), utilization, and management of fertilizers, pesticides, and fire
retardant chemicals. Particular attention should be taken to keep chemicals
away from streams. Care must be exercised to ensure that thermal problems
are not created in streams by excessive removal of shade canopy. Attention to
proper forest management, engineering, and harvesting principles can
substantially reduce pollution attributed to forestry.
The following considerations should be part of the pre-harvest planning stage:
threatened and endangered species and sensitive habitats, wetland areas,
streamside management area/width, cumulative effects analysis, timing of
operation (i.e., to avoid moisture), and identification of landslide potential and
other high risk areas.
Operations of the Forestry Production Industry
This section describes the following forestry production activities:
• Road construction and use
• Timber harvesting
• Forest Regeneration
• Site preparation
Prescribed burning
• Application of chemicals
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Exhibit 22 presents raw material inputs and pollution outputs from each of
these forestry production activities.
Exhibit 22. Forestry Production Activities, Raw Material Inputs,
and Pollution Outputs
Activity
Road construction and use
Timber harvesting
Forest regeneration
Site preparation
Prescribed burning
Application of chemicals
Raw Material Input
- Fuel and oil used in
construction equipment
— Fuel and oil used in
harvesting, chipping,
loading, and hauling
equipment
- Fuel used in planting
equipment
— Commercial fertilizers
- Fuel and oil used in
mechanical equipment
— Chemical herbicides
— Fuel to start fire
— Fertilizers
— Pesticides
- Water
— Fuel used in application
equipment
Pollution Output
— Sediment in runoff
from soil erosion
— Air emissions
— Sediment and organic
debris in runoff from
soil erosion
- Thermal pollution
— On-site leaks (i.e.,
hydraulic fluid)
— Air emissions
— Sediment in runoff
from soil erosion
— Nutrient in runoff from
fertilizer application
— Air emissions
— Sediment in runoff
from soil erosion
— Chemicals in runoff
from herbicide
application
— Air emissions
— Sediment in runoff
from soil erosion
— Air emissions (smoke)
— Chemical air emissions
- Runoff contaminated
with chemicals
III.C.1. Road Construction and Use
Building the road system to allow for harvesting involves clearing the roadway
of trees, grading soil, placing culverts for stream crossings, construction, and
surfacing. Following road construction, the forest becomes accessible for the
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logger to fall the trees and transport them to a landing where they will then be
loaded and transported to the mill.
There are several types of roads used in timber harvesting. The cheapest and
easiest road is the skid trail which is usually nothing more than a dirt path
used by the skidders to get the trees to the landing area. Skid trails must be
located outside of the Streamside Management Zone (SMZ) and must use a
bridge or culvert of acceptable design to cross perennial or intermittent
streams. The road from the landing to the main road is usually better than a
skid trail because it must support the trucks that haul the wood to the mill.
Some wood product companies build roads designed to last for many years.
However, these type of roads are too expensive for most landowners to
construct.
Rolling dips, water bars, cross-drains, water turnouts, and culverts are used to
control runoff and erosion, and allow vehicles to cross intermittent or
perennial streams.
Abandonment of roads, watercourse crossings, and landings must be planned
and conducted in a manner that provides for permanent maintenance-free
drainage to soil resources; minimizes concentration of runoff, soil erosion, and
slope instability; prevents unnecessary damage to soil resources; promotes
regeneration and protects the quality and beneficial uses of water.
Potential Pollution Outputs and Environmental Impacts
The primary pollution outputs during road construction and use may
include air emissions from road construction equipment and machinery
used for harvesting and soil erosion. Roads are considered to be the
major source of erosion from forested lands, contributing up to 90
percent of the total sediment production from forestry operations.
Erosion potential from roads is accelerated by increasing slope
gradients on cut-and-fill slopes, intercepting subsurface water flow,
and concentrating overland flow on the road surface and in channels.
Roads with steep gradients, deep cut-and-fill sections, poor drainage,
erodible soils, and road-stream crossings contribute to most of this
sediment load, with road-stream crossings being the most frequent
sources of erosion and sediment. Soil loss tends to be greatest during
and immediately after road construction because of the unstabilized
road bed and disturbance by passage of heavy trucks and equipment.
Pollution Prevention/Waste Minimization Opportunities
The primary pollution prevention methods in road construction and use
are designed to reduce erosion of soil and minimize delivery of
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sediment to surface waters. Proper road design and construction can
prevent road fill and road backslope failure, which can result in mass
movements and severe sedimentation. Proper road drainage prevents
concentration of water on road surfaces, thereby preventing road
saturation that can lead to rutting, road slumping, and channel
washout. Proper road drainage during logging operations is especially
important because that is the time when erosion is greatly accelerated
by continuous road use.
Surface protection of the roadbed and cut-and-fill slopes can:
S Minimize soil losses during storms.
S Reduce frost heave erosion production.
S Restrain downslope movement of soil slumps.
i/ Minimize erosion from softened roadbeds.
Although there are many commonly practiced techniques to minimize
erosion during the construction process, the most meaningful are
related to how well the work is planned, scheduled, and controlled by
the road builder and those responsible for determining that work
satisfies design requirements and land management resource
objectives. Most erosion from road construction occurs within a few
years of disturbance. Therefore, erosion control practices that provide
immediate results (such as mulching or hay bales) should be applied as
soon as possible to minimize potential erosion.
Drainage of the road prism, road fills in stream channels, and road fills
on steep slopes are the elements of greatest concern in road
management. Roads used for active timber hauling usually require the
most maintenance, and mainline roads typically require more
maintenance than spur roads. Use of roads during wet or thaw periods
can result in a badly rutted surface, impaired drainage, and excessive
sediment leading to waterbodies. Inactive roads, not being used for
timber hauling, are often overlooked and receive little maintenance.
The following pollution prevention practices can be used for road
construction and use:
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S Follow the design developed during preharvest planning to
minimize erosion by properly timing and limiting ground
disturbance operations.
S Design skid trail grades to be 15 percent or less. Do not locate
and construct roads with fills on slopes greater than 60 percent.
S Avoid construction during fish egg incubation periods on
streams with important spawning areas.
S Compact the road base at the proper moisture content,
surfacing, and grading to give the designed road surface
drainage shaping. Compact the fill to minimize erosion and
ensure road stability.
/" Use straw bales, straw mulch, grass-seeding, hydromulch, and
other erosion control and revegetation techniques to complete
the construction project. These methods are used to protect
freshly disturbed.soils until vegetation can be established.
/". Use turnouts, wing ditches, and dips to disperse runoff and
reduce road surface drainage from flowing directly into
watercourses.
S Install surface drainage controls to remove storm water from
the roadbed before the flow gains- enough volume and velocity
to erode the surface. Route discharge from drainage structures
onto the forest floor so that water will disperse and infiltrate.
S Install appropriate sediment control structures to trap
suspended sediment transported by runoff and prevent its
discharge into the aquatic environment.
i/ Revegetate or stabilize disturbed areas, especially at stream
crossings:
/" Protect access points to the site that lead from a paved public
right-of-way with stone, wood chips, corduroy logs, wooden
mats, or other material to prevent soil or mud from being
tracked onto the paved road.
S Construct bridges and install culverts during periods when
streamflow is low. Excavation for a bridge or a large culvert
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should not be performed in flowing water. The water should be
diverted around the work site during construction with a
cofferdam or stream diversion.
When soil moisture conditions are excessive, promptly suspend
earthwork operations and take measures to weatherproof the
partially completed work.
Locate burn bays away from water and drainage courses.
Maintain road surfaces by mowing, patching, or resurfacing as
necessary. Clear road inlet and outlet ditches, catch basins, and
culverts of obstructions. Blade and reshape the road surface to
conserve existing surface material to allow normal surface
runoff.
III.C.2. Timber Harvesting
Timber harvesting includes felling trees, preparing them by limbing, cutting
them into desired lengths, and moving them to a central, accessible location
for transport out of the forested area. The timber is removed (skidded or
yarded) to a temporary storage site or landing by one of three basic methods:
tractor/skidder (on skid trails), groundlead or highlead cable, or various
skyline cable methods. Balloons and helicopters are also used to a limited
extent in some areas.
The most common methods of harvesting in the United States are clearcutting,
shelterwood, selection, and partial cutting.
• Clearcutting is the harvesting of all trees in an area in one cut to create
a new even-aged stand. The area harvested is large enough to create an
open condition. Economically, clearcutting is most efficient for the
logger because all trees are removed, and the feller and skidder
operator are not continually confronted with avoiding trees spared
from harvest. However, because of the large volumes of material per
unit area removed during clearcutting, more trips are required by the
skidder, causing the greatest disturbance to the forest litter and
underlying forest soil of all harvesting systems.
• In shelterwood harvesting, a mature stand is removed in a series of
cuts. Regeneration of a new stand occurs under the cover of a partial
forest canopy. The final harvest cut removes the sheltering canopy and
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permits the new existing stand to develop in the open as an even-aged
stand.
Selection harvesting involves the removal of mature or immature trees
either alone or in groups at somewhat regular time intervals from a
forest stand. The objective of,this harvesting system is the
development and maintenance of an uneven-aged stand with trees of
different ages or sizes intermingled singly or in groups. Individual
(single) tree selection involves the removal of individual trees, while
group selection may remove several adjacent trees covering a small
fraction of an acre or larger numbers of trees covering areas as large as
one or two acres. Group selection is distinguished from clearcutting in
that the intent of group selection is ultimately to create a balance of age
or size classes in a mosaic of small contiguous groups throughout the
forest stand.
Potential Pollution Outputs and Environmental Impacts
The most detrimental effects of harvesting, which include soil
disturbance, soil compaction, and direct disturbance of stream
channels, are related to the movement of vehicles and machinery in the
forest area, and the skidding and loading of trees or logs. These effects
can be enhanced or minimized depending on logging operation
planning, soil and cover type, slope, and the construction and use of
haul roads, skid trails, and landings for access to and movement of
logs. Thus, harvesting method used directly affects the amount of
erosion, including the amount of sediment and organic debris that are
transported into streams from the forest floor.
Harvesting can also increase stream water temperatures (i.e., thermal
pollution) due to the removal of the canopy over streams, with the
greatest potential impacts occurring in small streams. Temperature is a
significant aspect of water quality. In some cases, it may strongly
influence dissolved oxygen concentrations and bacterial populations in
streams.
As with all harvesting methods, clearcutting can cause irreversible
adverse impacts to the environment and can destroy an area's
ecological integrity. These impacts include:
• The removal of forest canopy, which destroys the habitat for
many rainforest-dependent insects and bacteria.
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• The elimination offish and wildlife species due to soil erosion
and habitat loss.
• The destruction of buffer zones which reduce the severity of
flooding by absorbing and holding water.
• The removal of forest carbon sinks, leading to global warming
through the increased human-induced and natural carbon
dioxide build-up in the atmosphere.
• The destruction of aesthetic values and recreational
opportunities.
• Increased streamflow from removal of vegetation (resulting in
reduction in transpiration and evaporation functions), fish
passage barriers (i.e., improperly placed culverts), and
cumulative effects within the watershed.
Pollution Prevention/Waste Minimization Opportunities
The primary pollution prevention methods in timber harvesting are
designed to minimize sedimentation resulting from the siting and
operation of timber harvesting, and to manage petroleum products
properly. Logging practices that protect water quality and soil
productivity can reduce total mileage of roads and skid trails, lower
equipment maintenance costs, and provide better road protection and
lower road maintenance. Careful logging can disturb soil surfaces as
little as 8 percent, while careless logging practices can disturb soils as
much as 40 percent. Higher bulk densities and lower porosity of skid
road soils due to compaction by rubber-tired skidders result in reduced
soil infiltration capacity and corresponding increases in runoff and
erosion.
Locating landings for both groundskidding and cable yarding
harvesting systems according to preharvest planning minimizes erosion
and sediment delivery to surface waters. However, final siting of
landings may need to be adjusted in the field based on site
characteristics.
Landings and loading decks can become very compacted and puddled
and are therefore a source of runoff and erosion. Practices that prevent
or disperse runoff from these areas before the runoff reaches
watercourses will minimize sediment delivery to surface waters. Also,
any chemicals or petroleum products spilled in harvest areas can be
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highly mobile, adversely affecting the water quality of nearby surface
waters. Appropriate spill prevention and containment procedures are
therefore necessary to prevent petroleum products from entering
surface waters. Designation of appropriate areas for petroleum storage
will also minimize water quality impacts due to spills or leakage.
The following pollution prevention practices can be used during timber
harvesting operations.
Harvesting Practices
S Harvest trees so that they fall away from watercourses,
whenever possible, keeping logging debris from the channel,
except where debris placement is specifically prescribed for
fish or wildlife habitat.
S Any tree accidentally dropped in a waterway should be
immediately removed.
Practices for Landings
S Landings should be no larger than necessary to safely and
efficiently store logs and load trucks.
S The slope of landing fills should not exceed 40 percent, and
woody or organic debris should not be incorporated into fills.
S If landings are to be used during wet periods, protect the
surface with a suitable material such as wooden matting or
gravel surfacing.
S Install drainage structures for the landings such as water bars,
culverts, and ditches to avoid sedimentation. Disperse landing
drainage over sideslopes. Provide filtration or settling if water
is concentrated in a ditch.
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Groundskidding Practices
S Skid uphill to log landings whenever possible. Skid with ends
of logs raised to reduce rutting and gouging.
^ Skid perpendicular to the slope (along the contour), and avoid
skidding on slopes greater than 40 percent.
S Avoid skid trail layouts that concentrate runoff into draws,
ephemeral drainages, or watercourses.
»/ Suspend groundskidding during wet periods, when excessive
rutting and churning of the soil begins, or when runoff from
skid trails is turbid and no longer infiltrates within a short
distance from the skid trail. Further limitation of
groundskidding of logs, or use of cable yarding, maybe needed
on slopes where there are sensitive soils and/or during wet
periods.
S Retire skid trails by installing water bars or other erosion
control and drainage devices, removing culverts, and
revegetating.
Cable Yarding Practices
Y , Use cabling systems or other systems when groundskidding
would expose excess mineral soil and induce erosion and
sedimentation.
S Avoid cable yarding in or across watercourses.
i/ Yard logs uphill rather than downhill.
Petroleum Management Practices
i/ Service equipment where spilled fuel and oil cannot reach
watercourses, and drain all petroleum products and radiator
water into containers. Dispose of wastes and containers in
accordance with proper waste disposal procedures. Waste oil,
filters, grease cartridges, and other petroleum-contaminated
materials should not be left as refuse in the forest.
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Take precautions to prevent leakage and spills. Fuel trucks and
pickup-mounted fuel tanks must not have leaks.
Develop a spill contingency plan that provides for immediate
spill containment and cleanup, and notification of proper
authorities.
III.C.3. Site Preparation
Site preparation is a management activity designed to increase productivity of
a tract by controlling competing vegetation and debris that could slow seedling
growth. It includes removal or deadening of unwanted vegetation prior to
planting trees. Site preparation is accomplished by conducting prescribed
burning, using herbicides, or disking (or otherwise altering) the soil.
Potential Pollution Outputs and Environmental Impacts
The pollution outputs may include air emissions from the machinery
used, soil erosion during and after site preparation, and chemicals in
runoff. Mechanical site preparation by large tractors that shear, disk,
drum-chop, or root-rake a site may result in considerable soil
disturbance over large areas and has a high potential to degrade water
quality. Site preparation techniques that result in the removal of
vegetation and litter cover, soil compaction, exposure or disturbance of
the mineral soil, and increased storm flows due to decreased
infiltration and percolation, can contribute to increases in stream
sediment loads. However, erosion rates decrease over time as
vegetative cover grows back. Prescribed burning and herbicides are
other methods used to prepare sites that may also have potential
negative effects on water quality.
Pollution Prevention/Waste Minimization Opportunities
The primary pollution prevention methods in site preparation are
designed to minimize sediment runoff caused by soil-disturbing
machinery and chemicals in runoff from herbicide applications.
Leaving the forest floor litter layer intact during site preparation
operations for regeneration minimizes mineral soil disturbance and
detachment, thereby minimizing erosion and sedimentation.
Maintenance of an unbroken litter layer prevents raindrop detachment,
maintains infiltration, and slows runoff. Mechanical site preparation
can potentially impact water quality in areas that have steep slopes and
erodible soils, and where the prepared site is located near a waterbody.
Use of mechanical site preparation treatments that expose mineral soils
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on steep slopes can greatly increase erosion and landslide potential.
Alternative methods, such as dram chopping, herbicide application, or
prescribed burning, disturb the soil surface less than mechanical
practices.
The pollution prevention practices that can be used during site
preparation operations include:
S Mechanical site preparation should not be applied on slopes
greater than 30 percent.
S Mechanical site preparation should not be conducted in
streamside management areas. Also avoid mechanical site
preparation operations during periods of saturated soil
conditions that may cause ratting or accelerate soil erosion.
S Avoid working downhill or uphill. Always work along the
contour. Site preparation often involves soil disturbance and
can cause extensive erosion if done in a way that increases
runoff potential. Leave strips of undisturbed soil to help catch
any runoff on steep slopes.
S When moving slash and debris into rows, avoid pulling up
topsoil with the debris. Many sites are degraded by the
removal of topsoil. Make sure that the dozer operator monitors
the operation closely and modifies his/her approach if soil
begins to build up in the rows.
^ Use haystack piling where possible instead of windrows.
S Locate windrows and piles away from drainages to prevent
movement of materials during high-runoff conditions.
S Do not place slash in natural drainages, and remove any slash
that accidentally enters drainages.
S Provide filter'strips of sufficient width to protect drainages that
do not have streamside management areas from sedimentation
by the 10-year storm event.
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III.C.4. Forest Regeneration
Forest regeneration refers to the re-establishment of a forest cover on areas
from which trees have been removed by some past occurrence, such as
wildfire, timber harvesting, or temporary conversion to some other use than
the growing of trees. When trees have been absent from a site for a number of
years, regeneration must generally be achieved through seeding and planting.
Regeneration of a harvested area includes both the natural regenerative
process and man's activities in preparing the site and subsequent planting or
seeding. The method of regeneration is determined largely by the silvical
characteristics of the tree species involved, site limitations, economic
considerations, and the land manager's desire for forest composition. In some
plant communities, natural regeneration under any of the harvesting systems
may also occur by regrowth from roots or stumps.
Preparation, as well as protection of an area, is sometimes needed for regrowth
of a stand. Where site preparation for regrowth is needed, major activities
may include (1) debris removal to reduce fire hazard and allow use of
equipment for subsequent operations, (2) reduction or removal of brush or
shrub cover and undesirable tree species, and (3) cultivation of the soils.
Potential Pollution Outputs and Environmental Impacts ,
The pollution outputs may include air emissions from machinery used
for regeneration, sediment runoff caused by soil-disturbing machinery,
and nutrient runoff from fertilizer applications.
When used indiscriminately for site preparation, fire, chemicals, and
soil-disturbing machinery increase the potential for erosion and
sedimentation and other pollution to occur. The impacts from
sediment pollution as well as pollution from nutrients in runoff would
be similar to those discussed in Sections III.A.I and III.A.3,
respectively. The time required before such pollution occurs is
variable depending upon climatic factors, soil productivity and its
influence on the rate of plant growth, the species planted or seeded,
and the operational schedule. In some areas, the time span may be a
single growing season, while in others, it may cover several years.
Pollution Prevention/Waste Minimization Opportunities
The primary pollution prevention methods in forest regeneration are
designed to minimize sediment runoff caused by soil-disturbing
machinery and nutrient runoff from fertilizer applications.
Regeneration of harvested forest lands not only is important in terms
of restocking a valuable resource, but also is important to provide
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water quality protection from disturbed soils. Tree roots stabilize
disturbed soils by holding the soil in place and aiding soil aggregation,
decreasing slope failure potential. The presence of vegetation on
disturbed soils also slows storm runoff, which in turn decreases
erosion.
Mechanical planting using machines that scrape or plow the soil
surface can produce erosion rills, increasing surface runoff and
erosion. Natural regeneration, hand planting, and direct seeding
minimize soil disturbance, especially on steep slopes with erodible '
soils. Fertilizers are occasionally introduced into forests to promote
growth. Impacts of fertilizer application in forested areas could be
significantly reduced by avoiding application techniques that could
result in direct deposition into waterbodies and by maintaining a buffer
area along the streambank.
The pollution prevention practices that can be used for forest
regeneration operations include the following:
S Distribute seedlings evenly across the site.
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control low yalue hardwoods and unwanted shrub species, improve wildlife
habitat, provide disease control, and improve accessibility. Fire is used
deliberately under conditions where the area to be burned is predetermined
and the intensity of fire is controlled.
Potential Pollution Outputs and Environmental Impacts
The pollution outputs may include air emissions (smoke) from the fire
and soil erosion after the prescribed burning. Prescribed burning of
slash can increase erosion by eliminating protective cover and altering
soil properties. The degree of erosion following a prescribed burn
depends on soil credibility, slope, precipitation timing, precipitation
volume and intensity, fire severity, cover remaining on the soil, and
speed of revegetation. Burning may also increase storm runoff in areas
where all vegetation is killed. Such increases are partially attributable
to decreased evapotranspiration rates and reduced canopy interception
of precipitation. Erosion resulting from prescribed burning is
generally less than that resulting from roads and skid trails and from
site preparation that causes intense soil disturbance. However,
significant erosion can occur during prescribed burning if the slash
being burned is collected or piled, causing soil to be moved and
incorporated into the slash. The impacts of .erosion and sediment
runoff would be similar to those discussed in Section HI. A.I.
Air emissions (smoke) from prescribed burning can have adverse
effects on smoke sensitive areas such as airports, resorts or recreation
areas, schools, hospitals, stock barns and holding pens, etc. Smoke
can cause reduced visibility or smoke irritation to livestock and
humans which may cause material loss and adverse health effects.
Pollution Prevention/Waste Minimization Opportunities
The primary pollution prevention methods in prescribed burning are
designed to minimize sediment runoff caused by removal of surface
cover and smoke from fire. Prescribed burning is usually the least
expensive method of obtaining several specific goals in forest
management. However, it should be planned well in advance to assure
success. Aerial photographs can be very helpful. Areas that will
benefit most from a prescribed burn should be selected and priorities
should be set. High priority will probably be protection of
unmerchantable size stands. Burning stands can facilitate regeneration
and reduce site preparation costs.
If recommended burning techniques and weather conditions are
followed, most prescribed burning will not create smoke problems.
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First, land managers should determine if any smoke sensitive areas are
near the burn. These are places where reduced visibility or smoke
irritation to livestock and humans could cause material loss and
adverse health effects. Examples of smoke sensitive areas are:
airports, heavily traveled highways, communities, resorts or recreation
areas, schools, hospitals, factories, stock barns and holding pens.
Prescribed burning should not be implemented if any sensitive area is
within three fourths of a mile downwind of the burn. Different wind
direction should be sought in these type of situations. Also, burning
should not be conducted if the area already has air pollution or a
visibility problem. Burning should be carried out only when the
vertical dispersion is good (from fire weather forecast).
The pollution prevention practices that can be used during prescribed
burning operations include the following:
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Execute the burn with a trained crew and avoid intense
burning.
Avoid burning on steep slopes with high erosion hazard areas
or highly erodible soils.
III.C.6. Application of Chemicals
Chemicals are becoming more and more a part of forestry. Commercial
fertilizers are applied to sizeable areas of forests as a means of stimulating
growth of new plantations or established stands of trees. Herbicides are used
widely for site preparation and stand improvement. Insecticides are used less
extensively, but still comprise the major defense against damaging insects in
forests.
Potential Pollution Outputs and Environmental Impacts
The potential outputs from application of forest chemicals may include
runoff contaminated with chemicals associated with fertilizer and
pesticide application, and chemical air emissions. Fertilizer loss may
occur when fertilizers are improperly applied during the course of a
silvicultural operation. Soluble forms of fertilizers may reach surface
or groundwater through runoff, seepage, and/or percolation. Insoluble
forms may be adsorbed on soil particles and reach surface water
through erosion processes. Nutrients may also reach surface water by
direct washoff of slash, debris, and recently applied fertilizer.
Excessive nutrients can lead to imbalance in the natural life cycles of
water bodies.
Pesticides, when applied during forest management operations, may be
insoluble or soluble. Pesticides when applied aerially and in a
broadcast manner may directly enter the surface waters. These
chemicals then follow approximately the same pattern as nutrients.
Pesticides, applied by the above methods, in a manner inconsistent
with the label, may result in acute toxicity problems in water bodies.
Pollution Prevention/Waste Minimization Opportunities
The primary pollution prevention methods in operations associated
with the application of chemicals are designed to minimize runoff
contaminated with chemicals from fertilizer and pesticide application,
and chemical air emissions. Nutrient pollution from fertilization on
forest lands is controlled by using techniques which avoid direct
application to surface waters. Also involved are the elimination of
excessive applications, the selection of the proper fertilizer
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formulation, and the proper timing and method of application. The
key factors in the selection of the type of fertilizer and the method of
application which are most appropriate for pollution control are local
soil nutrient deficiencies, the physical condition of the soil, the plant
species requirements, cost factors, weather conditions, access, and
topography.
The most common mechanism of pesticide pollution is direct transport
by runoff. However, the mechanisms of leaching or subsurface flows
may be important in areas of highly porous geologic materials,
permeable soils, or high water tables. Practices that control erosion
and runoff also reduce loss of applied pesticides. In addition to these
practices, a number of other frequently used options exist. These
options involve manipulation of the pesticide itself such as form,
timing of application, etc. These can be used alone or in conjunction
with the erosion and runoff control measures.
The pollution prevention practices that can be used during the
application of forest chemicals include the following:
»/ For aerial spray applications, maintain and mark a buffer area
of at least 50 feet around all watercourses and waterbodies to
avoid drift or accidental application of chemicals directly to
surface water. Also use nozzles and spray equipment that will
reduce pesticide drift. With broadcast applications, use
thickening agents, lower pressures, and larger nozzle sizes to
keep the pesticide spray where it is applied.
S Apply pesticides and fertilizers during favorable weather
conditions.
S Always use pesticides in accordance with label instructions,
and adhere to all federal and state policies and regulations
governing pesticide use. The pesticide label may specify:
whether users must be trained and certified in the proper use of
the pesticide; allowable use rates; safe handling, storage, and
disposal requirements; and whether the pesticide can only be
used under the provision of an approved Pesticide State
Management Plan. Management measures and practices for
pesticides should be consistent with and/or complement those
in the approved Pesticide State Management Plans.
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Locate mixing and loading areas, and clean all mixing and
loading equipment thoroughly after each use, in a location
where pesticide residues will not enter streams or other
waterbodies.
Dispose of pesticide wastes and containers according to state
and federal laws.
Take precautions to prevent leaks and/or spills.
Develop a spill contingency plan that provides for immediate
spill containment and cleanup, and notification of proper
authorities.
Apply slow-release fertilizers, when possible.
Apply fertilizers during maximum plant uptake periods to
minimize leaching.
Base fertilizer type and application rate on soil and/or foliar
analysis.
Consider the use of pesticides as part of an overall program to
control pest problems.
Base selection of pesticide on site factors and pesticide
characteristics.
Check all application equipment carefully, particularly for
leaking hoses and connections and plugged or worn nozzles.
Calibrate spray equipment periodically to achieve uniform
pesticide distribution and rate.
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IV. SUMMARY OF APPLICABLE FEDERAL STATUTES AND REGULATIONS
This section discusses the federal regulations that may apply to this sector.
The purpose of this section is to highlight and briefly describe the applicable
federal requirements, and to provide citations for more detailed information.
The three following sections are included:
Section IV. A contains a general overview of major statutes
Section FV.B contains a list of regulations specific to this industry
Section IV.C contains a list of pending and proposed regulatory
requirements.
The descriptions within Section IV are intended solely for general
information. Depending upon the nature or scope of the activities at a
particular facility, these summaries may or may not necessarily describe all
applicable environmental requirements. Moreover, they do not constitute
formal interpretations or clarifications of the statutes and regulations. For
further information, readers should consult the Code of Federal Regulations
(CFR) and other state or local regulatory agencies. EPA Hotline contacts are
also provided for each major statute. For specific agricultural information,
contact The National Agricultural Compliance Assistance Center at
(888) 663-2155 or visit the website at http://www.epa.gov/agriculture.-
IV.A. General Description of Major Statutes
Clean Water Act
• The primary objective of the Federal Water Pollution Control Act, commonly
referred to as the Clean Water Act (CWA), is to restore and maintain the
chemical, physical, and biological integrity of the nation's surface waters.
Pollutants regulated under the CWA are classified as either "toxic" pollutants;
"conventional" pollutants, such as biochemical oxygen demand (BOD), total
suspended solids (TSS), fecal coliform, oil and grease, and pH; or "non-
conventional" pollutants, including any pollutant not identified as either
conventional or priority.
The CWA regulates both direct and "indirect" dischargers (those who
discharge to publicly owned treatment works). The National Pollutant
Discharge Elimination System (NPDES) permitting program (CWA §402)
controls direct discharges into navigable waters. Direct discharges or "point
source" discharges are from sources such as pipes and sewers. NPDES
permits, issued by either EPA or an authorized state (EPA has authorized 43
states and 1 territory to administer the NPDES program), contain industry-
specific, technology-based and water quality-based limits and establish
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pollutant monitoring and reporting requirements. A facility that proposes to
discharge into the nation's waters must obtain a permit prior to initiating a
discharge. A permit applicant must provide quantitative analytical data
identifying the types of pollutants present in the facility's effluent. The permit
will then set forth the conditions and effluent limitations under which a facility
may make a discharge.
Water quality-based discharge limits are based on federal or state water quality
criteria or standards, that were designed to protect designated uses of surface
waters, such as supporting aquatic life or recreation. These standards, unlike
the technology-based standards, generally do not take into account
technological feasibility or costs. Water quality criteria and standards vary
from state to state, and site to site, depending on the use classification of the
receiving body of water. Most states follow EPA guidelines which propose
aquatic life and human health criteria for many of the 126 priority pollutants.
Storm Water Discharges
In 1987 the CWA was amended to require EPA to establish a program to
address storm water discharges. In response, EPA promulgated NPDES
permitting regulations for storm water discharges. These regulations require
that facilities with the following types of storm water discharges, among
others, apply for an NPDES permit: (1) a discharge associated with industrial
activity; (2) a discharge from a large or medium municipal storm sewer
system; or (3) a discharge which EPA or the state determines to contribute to a
violation of a water quality standard or is a significant contributor of
pollutants to waters of the United States.
The term "storm water discharge associated with industrial activity" means a
storm water discharge from one of 11 categories of industrial activity defined
at 40 CFR §122.26. Six of the categories are defined by SIC codes while the
other five are identified through narrative descriptions of the regulated
industrial activity. If the primary SIC code of the facility is one of those ,
identified in the regulations, the facility is subject to the storm water permit
application requirements. If any activity at a facility is covered by one of the
five narrative categories, storm water discharges from those areas where the
activities occur are subject to storm water discharge permit application
requirements.
Those facilities/activities that are subject to storm water discharge permit
application requirements are identified below. To determine whether a
particular facility falls within one of these categories, the regulation should be
consulted.
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Category i: Facilities subject to storm water effluent guidelines, new source
performance standards, or toxic pollutant effluent standards.
Category ii: Facilities classified as SIC 24-lumber and wood products
(except wood kitchen cabinets); SIC 26-paper and allied products (except
paperboard containers and products); SIC 28-chemicals and allied products
(except drugs and paints); SIC 29-petroleum refining; SIC 311-leather tanning
and finishing; SIC 32 (except 323)-stone, clay, glass, and concrete; SIC 33-
primary metals; SIC 3441-fabricated structural metal; and SIC 373-ship and
boat building and repairing.
Category iii: Facilities classified as SIC 10-metal mining; SIC 12-coal
mrning; SIC 13-oil and gas extraction; and SIC 14-nonmetallic mineral
mining.
Category iv: Hazardous waste treatment, storage, or disposal facilities.
Category v: Landfills, land application sites, and open dumps that receive or
have received industrial wastes.
Category vi: Facilities classified as SIC 5015-used motor vehicle parts; and
SIC 5093-automotive scrap and waste material recycling facilities.
Category vii: Steam electric power generating facilities.
Category viii: Facilities classified as SIC 40-railroad transportation; SIC 41-
local passenger transportation; SIC 42-trucking and warehousing (except
public warehousing and storage); SIC 43-U.S. Postal Service; SIC 44-water
transportation; SIC 45-transportation by air; and SIC 5171-petroleum bulk
storage stations and terminals.
Category ix: Sewage treatment works.
Category x: Construction activities except operations that result in the
disturbance of less than five acres of total land area.
Category xi: Facilities classified as SIC 20-food and kindred products; SIC
21-tobacco products; SIC 22-textile mill products; SIC 23-apparel related
products; SIC 2434-wood kitchen cabinets manufacturing; SIC 25-furniture
and fixtures; SIC 265-paperboard containers and boxes; SIC 267-converted
paper and paperboard products; SIC 27-printing, publishing, and allied
industries; SIC 283-drugs; SIC 285-paints, varnishes, lacquer, enamels, and
allied products; SIC 30-rubber and plastics; SIC 31-leather and leather
products (except leather and tanning and finishing); SIC 323-glass products;
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SIC 34-fabricated metal products (except fabricated structural metal); SIC 35-
industrial and commercial machinery and computer equipment; SIC 36-
electronic and other electrical equipment and components; SIC 37-
transportation equipment (except ship and boat building and repairing); SIC
38-measuring, analyzing, and controlling instruments; SIC 39-miscellaneous
manufacturing industries; and SIC 4221 -4225-public warehousing and
storage.
Pretreatment Program
Another type of discharge that is regulated by the CWA is one that goes to a
publicly owned treatment works (POTW). The national pretreatment program
(CWA § 307(b)) controls the indirect discharge of pollutants to POTWs by
"industrial users." Facilities regulated under §307(b) must meet certain
pretreatment standards. The goal of the pretreatment program is to protect
municipal wastewater treatment plants from damage that may occur when
hazardous, toxic, or other wastes are discharged into a sewer system and to
protect the quality of sludge generated by these plants.
EPA has developed technology-based standards for industrial users of
POTWs. Different standards apply to existing and new sources within each
category. "Categorical" pretreatment standards applicable to an industry on a
nationwide basis are developed by EPA. In addition, another kind of
pretreatment standard, "local limits," are developed by the POTW in order to
assist the POTW in achieving the effluent limitations in its NPDES permit.
Regardless of whether a state is authorized to implement either the NPDES or
the pretreatment program, if it develops its own program, it may enforce
requirements more stringent than federal standards.
Wetlands
Wetlands, commonly called swamps, marshes, fens, bogs, vernal pools,
playas, and prairie potholes, are a subset of "waters of the United States," as
defined in Section 404 of the CWA. The placement of dredge and fill material
into wetlands and other water bodies (i.e., waters of the United States) is
regulated by the U.S. Army Corps of Engineers (Corps) under 33 CFR Part
328. The Corps regulates wetlands by administering the CWA Section 404
permit program for activities that impact wetlands. EPA's authority under
Section 404 includes veto power of Corps permits, authority to interpret
statutory exemptions and jurisdiction, enforcement actions, and delegating the
Section 404 program to the states.
EPA's Office of Water, at (202) 260-5700, will direct callers with questions
about the CWA to the appropriate EPA office. EPA also maintains a
bibliographic database of Office of Water publications which can be accessed
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through the Ground Water and Drinking Water resource center, at (202) 260-
7786.
Oil Pollution Prevention Regulation
Section 31 l(b) of the CWA prohibits the discharge of oil, in such quantities as
may be harmful, into the navigable waters of the United States and adjoining
shorelines. The EPA Discharge of Oil regulation, 40 CFR Part 110, provides
information regarding these discharges. The Oil Pollution Prevention '
regulation, 40 CFR Part 112, under the authority of Section 311 (j) of the
CWA, requires regulated facilities to prepare and implement Spill Prevention
Control and Countermeasure (SPCC) plans. The intent of a SPCC plan is to
prevent the discharge of oil from onshore and offshore non-transportation-
related facilities. In 1990 Congress passed the Oil Pollution Act which
amended Section 311(j) of the CWA to require facilities that because of their
location could reasonably be expected to cause "substantial harm" to the
environment by a discharge of oil to develop and implement Facility Response
Plans (FRP). The intent of a FRP is to provide for planned responses to
discharges of oil.
A facility is SPCC-regulated if the facility, due to its location, could
reasonably be expected to discharge oil into or upon the navigable waters of
the United States or adjoining shorelines, and the facility meets one of the
following criteria regarding oil storage: (1) the capacity of any aboveground
storage tank exceeds 660 gallons, or (2) the total aboveground storage capacity
exceeds 1,320 gallons, or (3) the underground storage capacity exceeds 42,000
gallons. 40 CFR § 112.7 contains the format and content requirements for a
SPCC plan. In New Jersey, SPCC plans can be combined with DPCC plans,
required by the state, provided there is an appropriate cross-reference index to
the requirements of both regulations at the front of the plan.
According to the FRP regulation, a facility can cause "substantial harm" if it
meets one of the following criteria: (1) the facility has a total oil storage
capacity greater than or equal to 42,000 gallons and. transfers oil over water to
or from vessels; or (2) the facility has a total oil storage capacity greater than
or equal to 1 million gallons and meets any one of the following conditions: (i)
does not have adequate secondary containment, (ii) a discharge could cause
"injury" to fish and wildlife and sensitive environments, (iii) shut down a
public drinking water intake, or (iv) has had a reportable oil spill greater than
or equal to 10,000 gallons in the past 5 years. Appendix F of 40 CFR Part 112
contains the format and content requirements for a FRP. FRPs that meet
EPA's requirements can be combined with U.S. Coast Guard FRPs or other
contingency plans, provided there is an appropriate cross-reference index to
the requirements of all applicable regulations at the front of the plan.
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For additional information regarding SPCCplans, contact EPA's RCRA,
Superfimd, andEPCRA Hotline, at (800) 424-9346. Additional documents and
resources can be obtained from the hotline's homepage at
www.epa.gov/epaoswer/hotline. The hotline operates weekdays from 9:00
a.m. to 6:00 p.m., EST, excluding federal holidays.
Coastal Zone Management Act
The Coastal Zone Management Act (CZMA) encourages states/tribes to
preserve, protect, develop, and where possible, restore or enhance valuable
natural coastal resources such as wetlands, floodplains, estuaries, beaches,
dunes, barrier islands, and coral reefs, as well as the fish and wildlife using
those habitats. It includes areas bordering the Atlantic, Pacific, and Arctic
Oceans, Gulf of Mexico, Long Island Sound, and Great Lakes. A unique
feature of this law is that participation by states/tribes is voluntary.
In the Coastal Zone Management Act Reauthorization Amendments (CZARA)
of 1990, Congress identified nonpoint source pollution as a major factor in the
continuing degradation of coastal waters. Congress also recognized that
effective solutions to nonpoint source pollution could be implemented at the
state/tribe and local levels. In CZARA, Congress added Section 6217 (16
U.S.C. § 1455b), which calls upon states/tribes with federally-approved
coastal zone management programs to develop and implement coastal
nonpoint pollution control programs. The Section 6217 program is
administered at the federal level jointly by EPA and the National Oceanic and
Atmospheric Administration (NOAA).
Section 6217(g) called for EPA, in consultation with other agencies, to
develop guidance on "management measures" for sources of nonpoint source
pollution in coastal waters. Under Section 6217, EPA is responsible for
developing technical guidance to assist states/tribes in designing coastal
nonpoint pollution control programs. On January 19, 1993, EPA issued its
Guidance Specifying Management Measures For Sources of Nonpoint
Pollution in Coastal Waters, which addresses five major source categories of
nonpoint pollution: (1) urban runoff, (2) agriculture runoff, (3) forestry runoff,
(4) marinas and recreational boating, and (5) hydromodification.
Additional information on coastal zone management may be obtained from
EPA's Office of Wetlands, Oceans, and Watersheds at
http://www.epa.gov/owow or from the Watershed Information Network at
http://www.epa.gov/win. The NOAA website at
http://www.nos.noaa.gov/ocrm/czm/also contains additional information on
coastal zone management.
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Safe Drinking Water Act
The Safe Drinking Water Act (SDWA) mandates that EPA establish
regulations to protect human health from contaminants in drinking water. The
law authorizes EPA to develop national drinking water standards and to create
a joint federal-state system to ensure compliance with these standards. The
SDWA also directs EPA to protect underground sources of drinking water
through the control of underground injection of fluid wastes.
EPA has developed primary and secondary drinking water standards under its
SDWA authority. EPA and authorized states enforce the primary drinking
water standards, which are, contaminant-specific concentration limits that
apply to certain public drinking water supplies. Primary drinking water
standards consist of maximum contaminant level goals (MCLGs), which are
non-enforceable health-based goals, and maximum contaminant levels
(MCLs), which are enforceable limits set generally as close to MCLGs as
possible, considering cost and feasibility of attainment.
The SDWA Underground Injection Control (UIC) program (40 CFR Parts
144-148) is a permit program which protects underground sources of drinking
water by regulating five classes of injection wells. UIC permits include design,
operating, inspection, and monitoring requirements. Wells used to inject
hazardous wastes must also comply with RCRA corrective action standards in
order to be granted a RCRA permit, and must meet applicable RCRA land
disposal restrictions standards. The UIC permit program is often state/tribe-
enforced, since EPA has authorized many states/tribes to administer the
program. Currently, EPA shares the UIC permit program responsibility in
seven states and completely runs the program in 10 states and on all tribal
lands. . .
The SDWA also provides for a federally-implemented Sole Source Aquifer
program, which prohibits federal funds from being expended on projects that
may contaminate the sole or principal source of drinking water for a given
area, "and for a state-implemented Wellhead Protection program, designed to
protect drinking water wells and drinking water recharge areas.
The SDWA Amendments of 1996 require states to develop and implement
source water assessment programs (SWAPs) to analyze existing and potential
threats to the quality of the public drinking water throughout the state. Every
state is required to submit a program to EPA and to complete all assessments
within 3 1A years of EPA approval of the program. SWAPs include: (1)
delineating the source water protection area, (2) conducting a contaminant
source inventory, (3) determining the susceptibility of the public water supply
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to contamination from the inventories sources, and (4) releasing the results of
the assessments to the public.
EPA's Safe Drinking Water Hotline, at (800) 426-4791, answers questions
and distributes guidance pertaining to SD WA standards. The Hotline
operates from 9:00 a.m. through 5:30 p.m., EST, excluding federal holidays.
Visit the website at http://www.epa.gov/ogwdwfor additional material.
Resource Conservation and Recovery Act
The Solid Waste Disposal Act (SWDA), as amended by the Resource
Conservation and Recovery Act (RCRA) of 1976, addresses solid and
hazardous waste management activities. The Act is commonly referred to as
RCRA. The Hazardous and Solid Waste Amendments (HSWA) of 1984
strengthened RCRA's waste management provisions and added Subtitle I,
which governs underground storage tanks (USTs).
Regulations promulgated pursuant to Subtitle C of RCRA (40 CFR Parts
260-299) establish a "cradle-to-grave" system governing hazardous waste
from the point of generation to disposal. RCRA hazardous wastes include the
specific materials listed in the regulations (discarded commercial chemical
products, designated with the code "P" or "U"; hazardous wastes from specific
industries/sources, designated with the code "K"; or hazardous wastes from
non-specific sources, designated with the code "F") or materials which exhibit
a hazardous waste characteristic (ignitability, corrosivity, reactivity, or toxicity
and designated with the code "D").
Entities that generate hazardous waste are subject to waste accumulation,
manifesting, and recordkeeping standards. A hazardous waste facility may
accumulate hazardous waste for up to 90 days (or 180 days depending on the
amount generated per month) without a permit or interim status. Generators
may also treat hazardous waste iri accumulation tanks or containers (in
accordance with the requirements of 40 CFR 262.34) without a permit or
interim status.
Facilities that treat, store, or dispose of hazardous waste are generally required
to obtain a RCRA permit. Subtitle C permits for treatment, storage, or
disposal facilities contain general facility standards such as contingency plans,
emergency procedures, recordkeeping and reporting requirements, financial
assurance mechanisms, and unit-specific standards. RCRA also contains
provisions (40 CFR Subparts I and S) for conducting corrective actions which
govern the cleanup of releases of hazardous waste or constituents from solid
waste management units at RCRA treatment, storage, or disposal facilities.
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Although RCRA is a federal statute, many states implement the RCRA
program. Currently, EPA has delegated its authority to implement various
provisions of RCRA to 47 of the 50 states and two U.S. territories. Delegation
has not been given to Alaska, Hawaii, or Iowa.
Most RCRA requirements are not industry specific but apply to any company
that generates, transports, treats, stores, or disposes of hazardous waste. Here
are some important RCRA regulatory requirements:
Criteria for Classification of Solid Waste Disposal Facilities and
Practices (40 CFR Part 257) establishes the criteria for determining
which solid waste disposal facilities and practices pose a reasonable
probability of adverse effects on health or the environment. The
criteria were adopted to ensure non-municipal, non-hazardous waste
disposal units that receive conditionally exempt small quantity
generator waste do not present risks to human health and environment.
Criteria for Municipal Solid Waste Landfills (40 CFR Part 258)
establishes minimum national criteria for all municipal solid waste
landfill units, including those that are used to dispose of sewage
sludge.
Identification of Solid and Hazardous Wastes (40 CFR Part 261)
establishes the standard to determine whether the material in question
is considered a solid waste and, if so, whether it is a hazardous waste
or is exempted from regulation.
Standards for Generators of Hazardous Waste (40 CFR Part 262)
establishes the responsibilities of hazardous waste generators including
obtaining an EPA ID number, preparing a manifest, ensuring proper
packaging and labeling, meeting standards for waste accumulation
units, and recordkeeping and reporting requirements. Generators can
accumulate hazardous waste on-site for up to 90 days (or 180 days
depending on the amount of waste generated) without obtaining a
permit.
Land Disposal Restrictions (LDRs) (40 CFR Part 268) are
regulations prohibiting the disposal of hazardous waste on land
without prior treatment. Under the LDRs program, materials must
meet treatment standards prior to placement in a RCRA land disposal
unit (landfill, land treatment unit, waste pile, or surface impoundment).
Generators of waste subject to the LDRs must provide notification of
such to the designated TSD facility to ensure proper treatment prior to
disposal.
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Used Oil Management Standards (40 CFR Part 279) impose
management requirements affecting the storage, transportation,
burning, processing, and re-refining of the used oil. For parties that
merely generate used oil, regulations establish storage standards. For a
party considered a used oil processor, re-refiner, burner, or marketer
(one who generates and sells off-specification used oil directly to a
used oil burner), additional tracking and paperwork requirements must
be satisfied.
RCRA contains unit-specific standards for all units used to store, treat,
or dispose of hazardous waste, including Tanks and Containers.
Tanks and containers used to store hazardous waste with a high
volatile organic concentration must meet emission standards under
RCRA. Regulations (40 CFR Part 264-265, Subpart CC) require
generators to test the waste to determine the concentration of the
waste, to satisfy tank and container emissions standards, and to inspect
and monitor regulated units. These regulations apply to all facilities
who store such waste, including large quantity generators
accumulating waste prior to shipment offsite.
Underground Storage Tanks (USTs) containing petroleum and
hazardous substances are regulated under Subtitle I of RCRA. Subtitle
I regulations (40 CFR Part 280) contain tank design and release
detection requirements, as well as financial responsibility and
corrective action standards for USTs. The UST program also includes
upgrade requirements for existing tanks that were to be met by
December 22, 1998.
Boilers and Industrial Furnaces (BIFs) that use or burn fuel
containing hazardous waste must comply with design and operating
standards. BIF regulations (40 CFR Part 266, Subpart H) address unit
design, provide performance standards, require emissions monitoring,
and, in some cases, restrict the type of waste that may be burned.
EPA's RCRA, Superfund, andEPCRA Hotline, at (800) 424-9346,
responds to questions and distributes guidance regarding all RCRA
regulations. Additional documents and resources can be obtained
from the hotline's homepage at www.epa.gov/epaoswer/hotline. The
RCRA Hotline operates weekdays from 9:00 a.m. to 6:00 p.m., EST,
excluding federal holidays.
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Comprehensive Environmental Response, Compensation, And Liability Act
The Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA), a 1980 law commonly known as Superfund, authorizes EPA
to respond to releases, or threatened releases, of hazardous substances that
may endanger public health, welfare, or the environment. CERCLA also
enables EPA to force parties responsible for environmental contamination to
clean it up or to reimburse the Superfund for response or remediation costs
incurred by EPA. The Superfund Amendments and Reauthorization Act
(SARA) of 1986 revised various sections of CERCLA, extended the taxing
authority for the Superfund, and created a free-standing law, SARA Title HI,
also known as the Emergency Planning and Community Right-to-Know Act
(EPCRA). ,
The CERCLA hazardous substance release reporting regulations (40 CFR Part
302) direct the person in charge of a facility to report to the National Response
Center (NRC) any environmental release of a hazardous substance which
equals or exceeds a reportable quantity. Reportable quantities are listed in 40
CFR §302.4. A release report may trigger a response by EPA, or by one or
more federal or state emergency response authorities.
EPA implements hazardous substance responses according to procedures
outlined in the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP) (40 CFR Part 300). The NCP includes provisions for cleanups.
The National Priorities List (NPL) currently includes approximately 1,300
sites. Both EPA and states can act at other sites; however, EPA provides
responsible parties the opportunity to conduct cleanups and encourages
community involvement throughout the Superfund response process.
EPA's RCRA, Superfund and EPCRA Hotline, at (800) 424-9346, answers
questions and references guidance pertaining to the Superfund program.
Documents and resources can be obtained from the hotline's homepage at
http://www.epa.gov/epaoswer/hotline. The Superfund Hotline operates
weekdays from 9:00 a.m. to 6:00 p.m., EST, excluding federal holidays.
Emergency Planning And Community Right-To-Know Act
The Superfund Amendments and Reauthorization Act (SARA) of 1986
created the Emergency Planning and Community Right-to-Know Act
(EPCRA, also known as SARA Title III), a statute designed to improve
community access to information about chemical hazards and to facilitate thp
development of chemical emergency response plans by state and local
governments. Under EPCRA, states establish State Emergency Response"
Commissions (SERCs), responsible for coordinating certain emergency
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response activities and for appointing Local Emergency Planning Committees
(LEPCs).
EPCRA and the EPCRA regulations (40 CFR Parts 350-372) establish four
types of reporting obligations for facilities which store or manage specified
chemicals:
EPCRA § 302 requires facilities to notify the SERC and LEPC of the
presence of any extremely hazardous substance at the facility in an
amount in excess of the established threshold planning quantity. The
list of extremely hazardous substances and their threshold planning
quantities is found at 40 CFR Part 355, Appendices A and B.
EPCRA § 303 requires that each LEPC develop an emergency plan.
The plan must contain (but is not limited to) the identification of
facilities within the planning district, likely routes for transporting
extremely hazardous substances, a description of the methods and
procedures to be followed by facility owners and operators, and the
designation of community and facility emergency response
coordinators.
EPCRA § 304 requires the facility to notify the SERC and the LEPC
in the event of a release exceeding the reportable quantity of a
CERCLA hazardous substance (defined at 40 CFR 302) or an EPCRA
extremely hazardous substance.
EPCRA § 311 and § 312 requires a facility at which a hazardous
chemical, as defined by the Occupational Safety and Health Act, is
present in an amount exceeding a specified threshold to submit to the
SERC, LEPC and local fire department material safety data sheets
(MSDSs) or lists of MSDSs and hazardous chemical inventory forms
(also known as Tier I and II forms). This information helps the local
government respond in the event of a spill or release of the chemical.
EPCRA § 313 requires certain covered facilities, including SIC codes
20 through 39 and others, which have ten or more employees, and
which manufacture, process, or use specified chemicals in amounts
greater than threshold quantities, to submit an annual toxic chemical
release report. This report, commonly known as the Form R, covers
releases and transfers of toxic chemicals to various facilities and
environmental media. EPA maintains the data reported in a publically
accessible database known as the Toxics Release Inventory (TRI).
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All information submitted pursuant to EPCRA regulations is publicly
accessible, unless protected by a trade secret claim.
EPA's RCRA, Superfund and EPCRA Hotline, at (800) 535-0202, answers
questions and distributes guidance regarding the emergency planning and
community right-to-know regulations. Documents and resources can be
obtained from the hotline's homepage at
http://www.epa.gov/epaoswer/hotline. The EPCRA Hotline operates
weekdays from 9:00 a.m. to 6:00 p.m., EST, excluding federal holidays.
Clean Air Act
The Clean Air Act (CAA) and its amendments-are designed to "protect and
enhance the nation's air resources so as to promote the public health and
welfare and the productive capacity of the population." The CAA consists of
six sections, known as Titles, which direct EPA to establish national standards
for ambient air quality and for EPA and the states to implement, maintain, and
enforce these standards through a variety of mechanisms. Under the CAA,
many facilities are required to obtain operating permits that consolidate their
air emission requirements. State and local governments oversee, manage, and
enforce many of the requirements of the CAA. CAA regulations appear at 40
CFR Parts 50-99.
Pursuant to Title I of the CAA, EPA has established national ambient air
quality standards (NAAQSs) to limit levels of "criteria pollutants," including
carbon monoxide, lead, nitrogen dioxide, particulate matter, ozone, and sulfur
dioxide. Geographic areas that meet NAAQSs for a given pollutant are
designated as attainment areas; those that do not meet NAAQSs are
designated as non-attainment areas. Under §110 and other provisions of the
CAA, each state must develop a State Implementation Plan (SIP) to identify
sources of air pollution and to determine what reductions are required to meet
federal air quality standards. Revised NAAQSs for particulates and ozone
were proposed in 1996 and will become effective in 2001.
Title I also authorizes EPA to establish New Source Performance Standards
(NSPS), which are nationally uniform emission standards for new and
modified stationary sources falling within particular industrial categories.
NSPSs are based on the pollution control technology available to that category
of industrial source (see 40 CFR Part 60).
Under Title I, EPA establishes and enforces National Emission Standards for
Hazardous Air Pollutants (NESHAPs), nationally uniform standards oriented
toward controlling specific hazardous air pollutants (HAPs). Section 112(c)
of the CAA further directs EPA to develop a list of sources that emit any of
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188 HAPs, and to develop regulations for these categories of sources. To
date, EPA has listed 185 source categories and developed a schedule for the
establishment of emission standards. The emission standards are being
developed for both new and existing sources based on "maximum achievable
control technology" (MACT). The MACT is defined as the control
technology achieving the maximum degree of reduction in the emission of the
HAPs, taking into account cost and other factors.
Title II of the CAA pertains to mobile sources, such as cars, trucks, buses, and
planes. Reformulated gasoline, automobile pollution control devices, and
vapor recovery nozzles on gas pumps are a few of the mechanisms EPA uses
to regulate mobile air emission sources.
Title IV-A establishes a sulfur dioxide and nitrogen oxides emissions program
designed to reduce the formation of acid rain. Reduction of sulfur dioxide
releases will be obtained by granting to certain sources limited emissions
allowances that are set below previous levels of sulfur dioxide releases.
Title V of the CAA establishes an operating permit program for all "major
sources" (and certain other sources) regulated under the CAA. One purpose of
the operating permit is to include in a single document all air emissions
requirements that apply to a given facility. States have developed the permit
programs in accordance with guidance and regulations from EPA. Once a
state program is approved by EPA, permits are issued and monitored by that
state.
Title VI of the CAA is intended to protect stratospheric ozone by phasing out
the manufacture of ozone-depleting chemicals and restricting their use and
distribution. Production of Class I substances, including 15 kinds of
chlorofluorocarbons (CFCs), were phased out (except for essential uses) in
1996. Methyl bromide, a common pesticide, has been identified as a
significant stratospheric ozone depleting chemical. The production and
importation of methyl bromide, therefore, is currently being phased out in the
United States and internationally. As specified in the Federal Register of June
1, 1999 (Volume 64, Number 104) and in 40 CFR Part 82, methyl bromide
production and importation will be reduced from 1991 levels by 25% in 1999,
by 50% in 2001, by 70% in 2003, and completely phased out by 2005. Some
uses of methyl bromide, such as the production, importation, and consumption
of methyl bromide to fumigate commodities entering or leaving the United
States or any state (or political subdivision thereof) for purposes of
compliance with Animal and Plant Health Inspection Service requirements or
with any international, federal, state, or local sanitation or food protection
standard, will be exempt from this rule. After 2005, exceptions may also be
made for critical agricultural uses. The United States EPA and the United
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Nations Environmental Programme have identified alternatives to using
methyl bromide in agriculture. Information on methyl bromide phase-out,
including alternatives can be found at the EPA Methyl Bromide Phase-Out
Web Site: (http://www.epa.gov/docs/ozone/mbr/mbrqa.html).
EPA's Clean Air Technology Center, at (919) 541-0800 and at the Center's
homepage at www.epa.gov/ttn/catc, provides general assistance and
information on CAA standards. The Stratospheric Ozone Information
Hotline, at (800) 296-1996 and at http://www.epa.gov/ozone, provides general
information about regulations promulgated under Title VI of the CAA; EPA's
EPCRA Hotline, at (800) 535-0202 and at
http://www.epa.gov/epaoswer/hotline, answers questions about accidental
release prevention under CAA §112(r); and information on air toxics can be
accessed through the Unified Air Toxics website at
http://www.epa.gov/ttn/uatw. In addition, the Clean Air Technology Center's
website includes recent CAA rules, EPA guidance documents, and updates of
EPA activities.
Federal Insecticide, Fungicide, and Rodenticide Act
The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) was first
passed in 1947, and amended numerous times, most recently by the Food
Quality Protection Act (FQPA) of 1996. FIFRA provides EPA with the
authority to oversee, among other things, .the registration, distribution, sale and
use of pesticides. The Act applies to all types of pesticides, including
insecticides, herbicides, fungicides, rodenticides and antimicrobials. FIFRA
covers both intrastate and interstate commerce.
Establishment Registration
Section 7 of FIFRA requires that establishments producing pesticides, or
active ingredients used in producing a pesticide subject to FIFRA, register
with EPA. Registered establishments must report the types and amounts of
pesticides and active ingredients they produce. The Act also provides EPA
inspection authority and enforcement authority for facilities/persons that are
not in compliance with FIFRA.
Product Registration
Under §3 of FIFRA, all pesticides (with few exceptions) sold or distributed in
the United States must be registered by EPA. Pesticide registration is very
specific and generally allows use of the product only as specified on the label.
Each registration specifies the use site, i.e., where the product may be used,
and the amount that may be applied. The person who seeks to register the
pesticide must file an application for registration. The application process
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often requires either the citation or submission of extensive environmental,
health and safety data.
To register a pesticide, the EPA Administrator must make a number of
findings, one of which is that the pesticide, when used in accordance with
widespread and commonly recognized practice, will not generally cause
unreasonable adverse effects on the environment.
FIFRA defines "unreasonable adverse effects on the environment" as "(1) any
unreasonable risk to man or the environment, taking into account the
economic, social, and environmental costs and benefits of the use of the
pesticide, or (2) a human dietary risk from residues that result from a use of a
pesticide in or on any food inconsistent with the standard under §408 of the
Federal Food, Drug, and Cosmetic Act (21 U.S.C. 346a)."
Under FIFRA § 6(a)(2), after a pesticide is registered, the registrant must also
notify EPA of any additional facts and information concerning unreasonable
adverse environmental effects of the pesticide. Also, if EPA determines that
additional data are needed to support a registered pesticide, registrants may be
requested to provide additional data. If EPA determines that the registrant(s)
did not comply with their request for more information, the registration can be
suspended under FIFRA § 3(c)(2)(B) and § 4.
Use Restrictions
As a part of the pesticide registration, EPA must classify the product for
general use, restricted use, or general for some uses and restricted for others
(Miller, 1993). For pesticides that may cause unreasonable adverse effects on
the environment, including injury to the applicator, EPA may require that the
pesticide be applied either by or under the direct supervision of a certified
applicator.
Reregistration
Due to concerns that much of the safety data underlying pesticide registrations
becomes outdated and inadequate, in addition to providing that registrations
be reviewed every 15 years, FIFRA requires EPA to reregister all pesticides
that were registered prior to 1984 (§ 4). After reviewing existing data, EPA
may approve the reregistration, request additional data to support the
registration, cancel, or suspend the pesticide.
Tolerances and Exemptions
A tolerance is the maximum amount of pesticide residue that can be on a raw
product and still be considered safe. Before EPA can register a pesticide that
is used on raw agricultural products, it must grant a tolerance or exemption
from a tolerance (40 CFR.163.10 through 163.12). Under the FederallFood,
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Drug, and Cosmetic Act (FFDCA), a raw agricultural product is deemed
unsafe if it contains a pesticide residue, unless the residue is within the limits
of a tolerance established by EPA or is exempt from the requirement.
Cancellation and Suspension
EPA can cancel a registration if it is determined that the pesticide or its
labeling does not comply with the requirements of FEFRA or causes
unreasonable adverse effects on the environment (Haugrud, 1993).
hi cases where EPA believes that an "imminent hazard" would exist if a
pesticide were .to continue to be used through the cancellation proceedings,
EPA may suspend the pesticide registration through an order and thereby halt
the sale, distribution, and usage of the pesticide. An "imminent hazard" is
defined as an unreasonable adverse effect on the environment or an
unreasonable hazard to the survival of a threatened or endangered species that
would be the likely result of allowing continued use of a pesticide during a
cancellation process.
When EPA believes an emergency exists that does not permit a hearing to be
held prior to suspending, EPA can issue an emergency order that makes the
suspension immediately effective.
Imports and Exports
Under FIFRA § 17(a), pesticides not registered in the United States and
intended solely for export are not required to be registered provided that the
exporter obtains and submits to EPA, prior to export, a statement from the
foreign purchaser acknowledging that the purchaser is aware that the product
is not registered in the United States and cannot be sold for use there. EPA
sends these statements to the government of the importing country. FIFRA
sets forth additional requirements that must be met by pesticides intended
solely for export. The enforcement policy for exports is codified in 40 CFR §
168.65, 168.75, and 168.85.
Under FIFRA §17(c), imported pesticides and devices must comply with
United States pesticide law. Except where exempted by regulation or statute,
imported pesticides must be registered. FIFRA § 17(c) requires that EPA be
notified of the arrival of imported pesticides and devices. This is
accomplished through the Notice of Arrival (NO A) (EPA Form 3540-1),
which is filled out by the importer prior to importation and submitted to the
EPA regional office applicable to the intended port of entry. United States
Customs regulations prohibit the importation of pesticides without a
completed NO A. The EPA-reviewed and signed form is returned to the
importer for presentation to United States Customs when the shipment arrives
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in the United States. NOA forms can be obtained from contacts in the EPA
Regional Offices or www.epa.gov/oppfeadl/international/noalist.htm.
Additional information on FIFRA and the regulation of pesticides can be
obtained from a variety of sources, including EPA's Office of Pesticide
Programs' homepage at www.epa.gov/pesticides, EPA's Office of
Compliance, Agriculture Division at
http://es.epa.gov/oeca/main/offices/division/ag.html, or The National
Agriculture Compliance Assistance Center toll-free at (888) 663-2155 or
http://www. epa.gov/agriculture. Other sources include the National Pesticide
Telecommunications Network toll-free at (800) 858-7378 and the National
Antimicrobial Information Network toll-free at (800) 447-6349.
Toxic Substances Control Act
The Toxic Substances Control Act (TSCA) granted EPA authority to create a
regulatory framework to collect data on chemicals in order to evaluate, assess,
mitigate, and control risks which may be posed by their manufacture,
processing, and use. TSCA provides a variety of control methods to prevent
chemicals from posing unreasonable risk. It is important to note that
pesticides as defined in FIFRA are not included in the definition of a
"chemical substance" when manufactured, processed, or distributed in
commerce for use as a pesticide.
TSCA standards may apply at any point during a chemical's life cycle. Under
TSCA §5, EPA has established an inventory of chemical substances. If a
chemical is not already on the inventory, and has not been excluded by TSCA,
a premanufacture notice (PMN) must be submitted to EPA prior to
manufacture or import. The PMN must identify the chemical and provide
available information on health and environmental effects. If available data
are not sufficient to evaluate the chemical's effects, EPA can impose
restrictions pending the development of information on its health and
environmental effects. EPA can also restrict significant new uses of chemicals
based upon factors such as the projected volume and use of the chemical.
Under TSCA § 6, EPA can ban the manufacture or distribution in commerce,
limit the use, require labeling, or place other restrictions on chemicals that
pose unreasonable risks. Among the chemicals EPA regulates under § 6
authority are asbestos, chlorofluorocarbons (CFCs), lead, and polychlorinated
biphenyls (PCBs).
Under TSCA § 8(e), EPA requires the producers and importers (and others) of
chemicals to report information on a chemicals' production, use, exposure,
and risks. Companies producing and importing chemicals can be required'to
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report unpublished health and safety studies on listed chemicals and to collect
and record any allegations of adverse reactions or any information indicating
that a substance may pose a substantial risk to humans or the environment.
EPA's TSCA Assistance Information Service, at (202) 554-1404, answers
questions and distributes guidance pertaining to Toxic Substances Control Act
standards. The Service operates from 8:30 a.m. through 4:30 p.m., EST,
excluding federal holidays.
IV.B. Industry-Specific Requirements for Agricultural Production Industries: Crops,
Greenhouses/Nurseries, and Forestry
The agricultural production industries discussed in this notebook are regulated
by several different federal, state, and local agencies. EPA has traditionally
relied on delegation to states to meet environmental standards, in many cases
without regard to the methods used to achieve certain performance standards.
This has resulted in some states with more stringent air, water, and hazardous
waste requirements than the federal minimum requirements. This document
does not attempt to discuss state standards, but rather highlights relevant
federal laws and proposals that affect the agricultural production industries of
crops, greenhouses/nurseries, and forestry.
Clean Water Act
Under the CWA, there are five program areas that potentially affect
agricultural establishments and businesses. These include: point source
discharges, storm water discharges, nonpoint source pollution, wetland
regulation, and sludge management. Key provisions addressing each of these
areas are summarized below:
Point Source Discharges: The CWA establishes a permitting program
known as the NPDES program for "point sources" of pollution. The
term "point source" includes facilities from which pollutants are or
may be discharged to waters of the United States and is further defined
at 40 CFR Part 122. If granted, the permit will place limits and
conditions on the proposed discharges based on the performance of
available control technologies and on any applicable (more stringent)
water quality considerations. Usually the permit also will require
specific compliance measures, establish schedules, arid specify
monitoring and reporting requirements.
— Concentrated Animal Feeding Operations (CAFOs): The
CWA defines CAFOs as point sources. Therefore, CAFOs are
subject to the NPDES permitting program. See 40 CFR Part
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122.23 and 40 CFR 122 Appendix B. A CAFO is prohibited
from discharging pollutants to waters of the U.S. unless it has
obtained an NPDES permit for the discharge.
*• Definition of an AFO - An AFO is defined in EPA
regulations as a lot or facility where (1) animals
have been, are, or will be stabled or confined and
fed or maintained for a total of 45 days or more in
any 12-month period, and (2) crops, vegetation,
forage growth, or post-harvest residues are not
sustained in the normal growing season over any
portion of the lot or facility.
>• Definition of a CAFO — CAFOs are a subset of all
AFOs. Whether an AFO is a CAFO under the
regulations depends on the number of animals
confined at the facility. A CAFO is defined as
follows:
(1) More than 1,000 AUs are confined at the facility [40
CFR 122, Appendix B (a)]; OR
(2) From 301 to 1,000 AUs are confined at the facility
and:
*• Pollutants are discharged into waters of the U.S.
through a man-made ditch, flushing system, or
other similar man-made device; or
*• Pollutants are discharged directly into waters of
the U.S. that originate outside of and pass over,
across, or through the facility or come into
direct contact with the confined animals. [40
CFR 122, Appendix B (b)] OR
(3) The facility has been designated as a CAFO by the
permitting authority on a case-by-case basis [40 CFR
122.23(c)], based on the permitting authority's
determination that the operation is a "significant
contributor of pollution." In making this determination,
the permitting authority considers the following factors:
• Size of the operation;
• Amount of waste reaching waters of the
United States;
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• Location of the operation relative to
waters of the U.S.;
• The means of conveyance of animal
wastes and process wastewater into
waters of the United States;
• The slope, vegetation, rainfall, and other
factors affecting the likelihood or
frequency of discharge of animal wastes
and process wastewater into waters of
the U.S.; and
• Other relevant factors (e.g.,waste
handling and storage, land application
timing, methods, rates and areas, etc.).
A permit application shall not be required from a
concentrated animal feeding designated under the case-
by-case authority until after the Director has conducted
an on-site inspection and determined that the operation
should and could be regulated under the NPDES permit
program.
No animal feeding o'peration with less than the number
of animals set forth in 40 CFR 122, Appendix B shall
be designated as a concentrated animal feeding
operation unless either (1) pollutants are discharged into
waters of the U.S. through a manmade ditch, flushing
system, or other similar means, or (2) pollutants are
discharged directly into waters of the U.S. which
originate outside of the facility and pass over, across, or
through the facility, or otherwise come into direct
contact with the animals confined in the operation.
The NPDES
permit
regulations
[40 CFR 122,
Appendix B]
contain an
exemption
for any AFO
from being
defined as a
C AFO if it
discharges
A 25-year, 24-hour rainfall event
means the maximum precipitation
event with a probable occurrence of
once in 25 years, as defined by the
National Weather Service in
Technical Paper Number 40,
"Rainfall Frequency Atlas of the
United States," May 1961, and
subsequent amendments, or
equivalent regional or state rainfall
probability information developed
therefrom [40 CFR Part 412.1 l(e)]
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only in the event of a 25 year, 24-hour, or larger, storm
event. To be eligible for an exemption, the facility must
demonstrate to the permitting authority that it has not
had a discharge. It must also demonstrate that the entire
facility is designed, constructed, and operated to contain
a storm event of this magnitude in addition to process
wastewater. An operation that qualifies for this
exemption from being defined as a CAFO may still be
designated as a CAFO by the permitting authority on a
case-by-case basis.
Storm Water Discharges: Under 40 CFR §122.2, the definition of
"point source" excludes agricultural storm water runoff. Thus, such
runoff is not subject to the storm water permit application regulations
at 40 CFR §122.26. Non-agricultural storm water discharges,
however, are regulated if the discharge results from construction over 5
acres or certain other types of industrial activity such as landfills,
automobile junk yards, vehicle maintenance facilities, etc.
- Concentrated Aquatic Animal Production Facilities: Under
40 CFR Part 122.24, a concentrated aquatic animal production
facility is defined and designated as a point source subject to
the NPDES permit program.
> Definition of concentrated aquatic animal
production facility (40 CFR Part 122 Appendix C) -
- A concentrated aquatic animal production facility
is a hatchery, fish farm, or other facility that meets
one of the following criteria:
(1) A facility that contains, grows, or holds cold water
fish species or other cold water aquatic animals in
ponds, raceways, or similar structures which discharge
at least 30 days per year. The term does not include (a)
facilities which produce less than 9,090 harvest weight
kilograms (approximately 20,000 pounds) of aquatic
animals per year, and (b) facilities which feed less than
2,272 kilograms (approximately 5,000 pounds) of food
during the calendar month of maximum feeding. Cold
water aquatic animals include, but are not limited to, the
salmonidae family (e.g., trout and salmon).
(2) A facility that contains, grows, or holds warm water
fish species or other warm water aquatic animals in
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ponds, raceways, or similar structures which discharge
at least 30 days per year. The term does not include (a)
facilities which produce 45,454 harvest weight
kilograms (approximately 100,000 pounds) of aquatic
animals per year or (b) closed ponds which discharge
only during periods of excess runoff. Warm water
aquatic animals include, but are not limited to, the
Ameiuridae, Centrarchidae, and Cyprinidae families of
fish (e.g., respectively catfish, sunfish, and minnows).
Designated facility — A facility that does not otherwise
meet the criteria in 40 CFR Part 122 Appendix C
(described above) may be designated as a concentrated
aquatic animal production facility if EPA or an
authorized state determines the production facility is a
significant contributor of pollution to waters of the U.S.
No permit is required for such a designated facility until
the EPA or state officials have conducted an onsite
inspection and determined that the facility should be
regulated under the NPDES permit program.
Aquaculture Projects: Under 40 CFR Part 122.25(b),
aquaculture means a defined, managed water area that uses
discharges of pollutants to maintain or produce harvestable
freshwater, estuarine, or marine plants or animals. Discharges
into approved aquaculture projects are not required to meet
effluent limitations that might otherwise apply. The entire
aquaculture project (discharges into and out of the project) is
addressed in an NPDES permit.
Exemption for Irrigation Return Flows: Under 40 CFR Part
122.3(f), return flows from irrigated agriculture do not require
NPDES permits.
Wastewater Guidelines for Point Source Silviculture
Activities: Under 40 CFR §122.27, silvicultural point sources
are subject to the NPDES permit program. Such silviculture
point sources include discrete conveyances related to rock
crushing, gravel washing, log sorting or log storage facilities
operated in connection with silvicultural activities and from
which pollutants are discharged into waters of the U.S. The
term does not include nonpoint source silviculture activities
such as nursery operations, site preparation, reforestation,
thinning, prescribed burning, pest and fire control, harvesting
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operations, surface drainage, or road construction and
maintenance from which there is natural runoff.
Nonpoint Source Pollution: Under the CWA §319 Nonpoint Source
(NFS) Management Program and 40 CFR §130.6, states (tribes, and
territories) establish programs to manage NFS pollution, including
runoff and leaching of fertilizers and pesticides, and irrigation return
flows. These NFS management programs must identify: (a) best
management practices (BMPs) to be used in reducing NFS pollution
loadings; (b) programs to be used to assure implementation of BMPs;
(c) a schedule for program implementation with specific milestones;
and (d) sources of federal or other funding that will be used each year
for the support of the state's NFS pollution management program.
Congress provides grant funds to the states annually for the
administration of these management programs.
Discharges to Publicly Owned Treatment Works (POTWs): Under
40 CFR Part 403, facilities, including agricultural establishments, may
discharge certain substances to a POTW if the facility has received
prior written permission from the POTW and has completed any
required pretreatment. Facilities must check with their POTWs for
information about permitted discharges and for conditions and
limitations.
Discharges of Designated Hazardous Substances. Under 40 CFR
Parts 116-117, facilities, including agricultural establishments, must
immediately notify the National Response Center (1-800-424-8802)
and their state agency of any unauthorized discharge of a designated
hazardous substance into (1) navigable waters, (2) the shorelines of
navigable waters, or (3) contiguous zones, IF the quantity discharged
in any 24-hour period equals or exceeds the reportable quantity. A
designated hazardous substance is any chemical listed in Section 311
of the Clean Water Act. The reportable quantity is the amount of the
hazardous substance that EPA has determined might cause harm. The
list of hazardous substances along with each chemical's reportable
quantity is found in 40 CFR Parts 116 and 117. Ammonia and several
pesticides are on the list.
Discharges of Oil. Under 40 CFR Part 110, facilities must
immediately notify EPA's National Response Center (1-800-424-
8802) of any unauthorized discharge of a harmful quantity of oil
(including petroleum, fuel oil, sludge, oil refuse, or oil mixed with
other wastes) into (1) navigable waters, (2) the shorelines of navigable
waters, or (3) contiguous zones and beyond. A discharge of oil is
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considered harmful if it violates applicable water quality standards,
causes a sludge or emulsion to be deposited under the surface of the
water or on adjoining shorelines, or causes a film or sheen on, or
discoloration of, the water or adjoining shorelines. In practice, any
quantity of oil or a petroleum product is a harmful quantity, since even
small amounts will cause a film or sheen on surface water.
- Oil Spill Prevention Control and Countermeasure (SPCC)
Program: Under 40 CFR Part 112, facilities, including
agricultural establishments, must comply with EPA's SPCC
program when they store oil at their facility. SPCC
requirements apply to non-transportation related onshore and
offshore facilities of specified size engaged in storing,
processing, refining, transferring or consuming oil products,
which due to their location, could potentially discharge oil into
waters of the U.S. or adjoining shorelines.
Facilities must comply with the SPCC program: (1) if they
have a single aboveground container with an oil storage
capacity of more than 660 gallons, multiple aboveground
containers with a combined oil storage capacity of more than
1,320 gallons, or a total underground oil storage capacity of
more than 42,000 gallons and (2) if there is a reasonable
expectation that a discharge (spill, leak, or overfill) from the
tank will release harmful quantities of oil into navigable waters
or adjoining shorelines. The requirements are triggered by tank
capacity, regardless of whether tanks are completely filled.
Facilities subject to the SPCC requirements must prepare an
SPCC plan. This plan must include: (I) prevention measures
that keep oil releases from occurring, (2) control measures
installed to prevent oil releases from reaching navigable waters,
and (3) countermeasures to contain, clean up, and mitigate the
effects of any oil release that reaches navigable waters. Each
plan must be unique to the facility and must be signed by a
registered professional engineer.
Wetlands on Agricultural Lands: Swamps, marshes, fens, bogs,
vernal pools, playas, and prairie potholes are common names for
wetlands. Wetlands provide a habitat for threatened and endangered
species as well as a diversity of other plant, wildlife, and fish species.
In addition to providing habitat, wetlands serve other functions,
including stabilizing shorelines; storing flood waters; filtering
sediments, nutrients, and toxic chemicals from water; and providing an
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area for the recharge and discharge of groundwater. It is important to
note that not all wetlands will be obvious to the untrained observer.
For example, an area can appear dry during much of the year and still
be classified as a wetland. Your local Natural Resources
Conservation Service (NRCS) office can help to identify and delineate
wetlands on your property.
NRCS, formerly the Soil Conservation Service, is the lead agency for
identifying wetlands on agricultural lands. According to NRCS,
agricultural lands means those lands intensively used and managed for
the production of food or fiber to the extent that the natural vegetation
has been removed and therefore does not provide reliable indicators of
wetland vegetation. Areas that meet this definition may include
intensively used and managed cropland, hayland, pastureland,
orchards, vineyards, and areas that support wetland crops (e.g.,
cranberries, taro, watercress, rice). Lands not included in the
definition of agricultural lands include rangelands, forest lands,
woodlots, and tree farms.
— Exemption to Section 404 Permit Requirements. The
placement of dredge and fill material into wetlands and other
water bodies (i.e., waters of the United States) is regulated by
the U.S. Army Corps of Engineers (Corps) under 33 CFR Part
328. The Corps regulates wetlands by administering the CWA
Section 404 permit program for activities that impact wetlands.
The 404 permit program requires a permit for point source
discharges of dredged and fill material into waters of the
United States. However, many normal established farming
activities (e.g.,"plowing, cultivating, minor drainage, and
harvesting), silviculture, and ranching activities that involve
discharges of dredged or fill materials into U.S. waters are
exempt from Section 404 permits and do NOT require a I
permit (33 CFR §323.4). In order to be exempt, the activity
must be part of an ongoing operation and cannot be associated
with bringing a wetland into agricultural production or
converting an agricultural wetland to a non-wetland area.
If not covered by the above exemption, a permit is required
before discharging dredged or fill material into U.S. waters,
including most wetlands (33 CFR Part 323). The Army Corps
of Engineers (Corps) reviews Section 404 permit applications
to determine if a project is the least environmentally damaging
and practicable alternative.
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POTW Sludge Management - Land Application of Biosolids. Land
application is the application of biosolids to land to either condition
the soil or fertilize crops or other vegetation grown in the soil.
Biosolids are a primarily organic solid product produced by
wastewater treatment processes that can be beneficially recycled.
• EPA regulates the land application of biosolids under 40 CFR Part
503. As described in A Plain English Guide to the EPA Part 503
Biosolids Rule (EPA/832/R-93-003, September 1994), the Part"503
rule includes general provisions, and requirements for land application,
surface disposal, pathogen and vector attraction reduction, and
incineration. For each regulated use or disposal practice, a Part 503
standard includes general requirements, pollutant limits, management
practices, operational standards, and requirements for the frequency of
monitoring, recordkeeping, and reporting. For the most part, the
requirements of the Part 503 rule are self-implementing and must be
followed even without the issuance of a permit covering biosolids use
or disposal requirements.
Total Maximum Daily Load (TMDL) program. There are still
waters in the nation that do not meet the CWA national goal of
"fishable, swimmable" despite the fact that nationally required levels
of pollution control technology have been implemented by many
pollution sources. The TMDL program, established under Section
303(d) of the Clean Water Act, focuses on identifying and allocating
pollutant loads to these waterbodies. The goal of a TMDL is the
attainment of water quality standards.
A TMDL identifies the amount a pollutant needs to be reduced to meet
water quality standards, allocates pollutant load reductions among
pollutant sources in a watershed, and provides the basis for taking
actions needed to restore a waterbody. It can identify the need for point
source and nonpoint source controls.
Under this provision, States are required to (1) identify and list
waterbodies where State water quality standards are not being met
following the application of technology-based point source pollution
controls; and (2) establish TMDLs for these waters. EPA must review
and approve (or disapprove) State lists and TMDLs. If state actions are
not adequate, EPA must prepare lists and TMDLs. TMDLs are to be
implemented using existing federal, state, and local authorities and
voluntary programs.
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TMDLs should address all significant pollutants which cause or
threaten to cause waterbody use impairment, including:
- Point sources (e.g., sewage treatment plant discharges)
- Nonpoint sources (e.g., runoff from fields, streets, range, or
forest land)
- Naturally occurring sources (e.g., runoff from undisturbed
lands)
A TMDL is the sum of the individual wasteload allocations for point
sources, load allocations for nonpoint sources and natural background
pollutants, and an appropriate margin of safety. TMDLs may address
individual pollutants or groups of pollutants, as long as they clearly
identify.the links between: (1) the waterbody use impairment or threat
of concern, (2) the causes of the impairment or threat, and (3) the load
reductions or actions needed to remedy or prevent the impairment.
TMDLs may be based on readily available information and studies. In
some cases, complex studies or models are needed to understand how
pollutants are causing waterbody impairment. In many cases, simple
analytical efforts provide an adequate basis for pollutant assessment
and implementation planning.
Where inadequate information is available to draw precise links
between these factors, TMDLs may be developed through a phased
approach. The phased approach enables states to use available
information to establish interim targets, begin to implement needed
controls and restoration actions, monitor waterbody response to these
actions, and plan for TMDL review and revision in the future. Phased
approach TMDLs are particularly appropriate to address nonpoint
source issues.
Numerous TMDLs are under development in many states and TMDLs
are likely to impact agricultural activities by prompting states and
stakeholders to mitigate water pollution caused by agricultural sources
(assuming agriculture-related industries are identified as significant
contributors to water quality impairment).
Coastal Zone Act Reauthorization Amendments of 1990
The Coastal Nonpoint Pollution Control Program, which is implemented
under the authority of Section 6217 of the Coastal Zone Act Reauthorization
Amendments (CZARA) of 1990, is administered at the federal level jointly by
EPA and the National Oceanic and Atmospheric Administration (NOAA).
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The Section 6217 program requires the 29 states and territories with NOAA-
approved coastal zone management programs to develop and implement
coastal nonpoint pollution control programs. These programs are intended to
serve as an update and expansion of existing state programs focused on
nonpoint source pollution affecting coastal areas. These submitted programs
must include: (1) management measures that are in conformity with applicable
federal guidance and (2) state-developed management measures as necessary
to achieve and maintain applicable water quality standards.
On January 19, 1993, EPA issued its Guidance Specifying Management
Measures For Sources of Nonpoint Pollution in Coastal Waters. The federal
guidance specifies management measures for the following agricultural
sources: (1) erosion from cropland, (2) confined animal facilities, (3) the
application of nutrients to croplands, (4) the application of pesticides to
cropland, (5) grazing management, and (6) irrigation of cropland.
Once approved, the programs are implemented through state nonpoint source
programs (under CWA §319) and state coastal zone management programs
(authorized under §306 of the Coastal Zone Management Act). Agricultural
establishments located in coastal states should determine whether their land is
included in the state's coastal management area. If so, they must comply with
their state's applicable coastal nonpoint programs. Currently, all state coastal
nonpoint management programs have been conditionally approved and have
begun to be implemented.
Coastal Zone Management Act
The 1996 amendments to the Coastal Zone Management Act that may affect
agriculture-related industries include those that relate to aquaculture in the
coastal zone. Eligible states may now receive grants for developing a
coordinated process among state agencies to regulate and issue permits for
aquaculture facilities in the coastal zone. States may also receive grants for
adopting procedures and policies to evaluate facilities in the coastal zone that
will enable the states to formulate, administer, and implement strategic plans
for marine aquaculture. Each state that receives such grants will make its own
determination as part of its coastal management plan on how to specifically
use the funds. Therefore, persons engaged in aquaculture productivity in the
coastal zone may be eligible for technical or financial assistance under their
state's plan.
Safe Drinking Water Act
The SDWA, which has been amended twice since 1974, protects the water
supply through water quality regulations and source protection, such as
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underground injection control (UIC) regulations. SDWA requirements apply
to all public water systems (PWSs). Currently, 54 of 56 states and territories
have been delegated primacy to run the drinking water program.
Public Water Systems. Under 40 CFR Parts 141-143, facilities that
operate a PWS or receive water from a PWS and provide treatment to
it are subject to SDWA regulations. Prior to 1996, SDWA defined a
PWS as "a system for the provision to the public of piped water for
human consumption if such system has at least 15 service connections
or regularly serves at least 25 individuals." The 1996 Amendments
expanded the means of delivering water to include not only pipes, but
also other constructed conveyances such as ditches and waterways.
While there are three categories of PWSs, an agricultural establishment
will most likely operate a non-transient, non-community system. This
type of system serves at least 25 people for over 6 months of the year,
but the people generally do not live at the facility. All PWSs must .
comply with the national primary drinking water regulations (40 CFR
141). Under 40 CFR Part 141 Subpart G, EPA has established
drinking water standards for numerous pesticides.
Establishments that operate a non-transient, non-community system, in
general, will need to: (1) monitor for the contaminants the state has
established for that type of system, (2) keep records of the monitoring
results, (3) report results from all tests and analyses to the state/tribe on
a set schedule, (4) take immediate action to correct any violations in
the allowable contaminant levels, (5) make a public announcement of
any violations to warn people about potential adverse effects and to
describe the steps taken to remedy the problem, and (6) keep records of
actions taken to correct violations.
• Comprehensive State Ground Water Protection Program. Under
the SDWA §1429, states/tribes are allowed to establish a
Comprehensive State Ground Water Protection Program to protect
underground sources of drinking water. Under this program, a state/
tribe can require facilities, including agricultural establishments, to use
designated best management practices (BMPs) to help prevent
contamination of groundwater by nitrates, phosphates, pesticides,
microorganisms, or petroleum products. These requirements generally
apply only to facilities that are subject to the public water system
supervision program. Persons applying pesticides or fertilizers must
know the location of all the public water supply source areas in the
vicinity that are protected by state/tribal (and sometimes local)
requirements.
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Source Water Protection Program. Under the SDWA, states are
required to develop comprehensive Source Water Assessment
Programs (SWAP). The statutorily defined goals for SWAPs are to
provide for the protection and benefit of public water systems and for
the support of monitoring flexibility. These programs plan to identify
the areas that supply public tap water, inventory contaminants and
assess water system susceptibility to contamination, and inform the
public of the result.
Wellhead Protection Program. Under the SDWA §1428, if a
facility, has an onsite water source (e.g., well) that qualifies as a PWS,
it must take the steps required by the state/tribe to protect the wellhead
from contaminants. A wellhead protection area is the surface and
subsurface area surrounding a water well or wellfield supplying a PWS
through which contaminants are reasonably likely to move toward and
reach such water well or wellfield.
Since drinking water standards (40 CFR Part 141 Subpart G) exist for
numerous pesticides, which may be used in various agriculture-related
activities, some state/tribe and local wellhead and source water
protection programs restrict the use of agricultural chemicals in
designated wellhead protection areas, hi addition, persons applying
pesticides or fertilizers must know the location of all the public water
supply source areas in the vicinity that are protected by state/tribal (and
sometimes local) requirements, and the requirements for mixing,
loading, and applying agricultural chemicals within any designated
wellhead or source water protection areas.
Sole Source Aquifer Protection Program. Under the SDWA §1424
and 40 CFR Part 149 Subpart B, EPA can establish requirements for
protecting sole source aquifers. EPA designates an aquifer as a sole
source aquifer if it supplies at least 50 percent of the drinking water
consumed in the area overlying the aquifer and no alternative drinking
water sources are feasible. The Sole Source Aquifer program prohibits
federal financial assistance (any grant, contract, loan guarantee, or
otherwise) for any project, including agricultural projects, that may
result in contamination to the aquifer and create a hazard to public
heath. Currently, only a few aquifers have been designated as
protected sole source aquifers.
Underground Injection Control (UIC) Program. The UIC program
(40 CFR Parts 144 and 146-148) is a permit program that protects
underground sources of drinking water by regulating five classes of
injection wells (I - V). Underground injection means depositing fluids
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beneath the surface of the ground by injecting them into a hole (any
hole that is deeper than it is wide). Fluids means any material or
substance which flows or moves whether in a semisolid, liquid, sludge,
gas, or any other form or state.
If a facility disposes of (or formerly disposed of) waste fluids onsite in
an injection well, it triggers the UIC requirements. In general, a
facility may not inject contaminants into any well if the contaminant
could cause a violation of any primary drinking water regulation or
endanger an underground source of water if the activity would
adversely affect the public health. Most deep well underground
injections are prohibited without a UIC permit. No Class I, II, or in
injection well may be constructed or opened before a permit has been
issued. UIC permits include design, operating, inspection, and
monitoring requirements. In many states/tribes, EPA has authorized
the state/tribal agency to administer the program.
Class V Wells. Owners/operators of Class V wells (shallow wells that
inject fluids above an underground source of water) must not
construct, operate, maintain, convert, plug, abandon, or conduct any
other injection activity in a manner that allows the movement of fluid
containing any contaminant into underground sources of drinking
water, if the presence of that contaminant may cause a violation of any
primary drinking water regulation (40 CFR Part 142) or may otherwise
adversely affect the health of persons. Examples of Class V wells
potentially applicable to agricultural establishments include, but are
not limited to:
Drainage wells, such as agricultural drainage wells, primarily
used for storm runoff.
* Cesspools with open bottoms (and sometimes perforated sides)
and septic system wells used to inject waste or effluent from
multiple dwellings or businesses (the UIC requirements do not
apply to single family residential septic system or cesspool
wells or to non-residential septic system or cesspool wells that
are used solely for the disposal of sanitary wastes and have the
capacity to serve fewer than 20 persons per day).
• Dry wells used for waste injection.
Recharge wells used to replenish aquifers.
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Injection wells associated with the recovery of geothermal
energy for heating, aquaculture, and production of electric
power.
Floor drains in maintenance shops/work areas.
Agricultural drainage wells typically drain water from low-lying farm
land, but some serve to recharge aquifers from which irrigation water is
withdrawn. These wells are usually constructed in areas with poor soil
drainage, but where underlying geologic formations allow rapid infiltration
of water. Sometimes abandoned water supply wells are adapted for use in
agricultural drainage. Agricultural drainage wells typically receive field
drainage from saturated topsoil and subsoil, and from precipitation,
snowmelt, floodwaters, irrigation return flow, and animal feedlots. The
types of pollutants injected into these wells include (1) pesticide runoff,
(2) nitrate, nitrite, and salts, such as those of calcium, magnesium, sodium,
potassium, chloride, sulfate, and carbonate from fertilizer runoff, (3) salts
and metals (i.e., iron, lead, cadmium, and mercury) from biosolid sludges
and compost, (4) microbes (i.e., bacteria and viruses) from animal waste
runoff, and (5) petroleum contaminants, such as fuel and oil, from runoff
from roads or equipment maintenance areas.
If a facility has a Class V well, it must furnish inventory information
about the well to the appropriate state/tribal agency. If at any time
EPA or the state/tribal agency learns that a Class V well may cause a
violation of primary drinking water regulations (40 CFR Part 142) or
may be otherwise adversely affecting the health of persons, it may
require the injector to obtain an individual UIC permit, or order the
injector to take such actions (including, where required, closure of the
injection well) as may be necessary to prevent the violation.
Resource Conservation and Recovery Act
The Resource Conservation and Recovery Act (RCRA) was enacted to
address problems related to hazardous and solid waste management. RCRA
gives EPA the authority to establish a list of solid and hazardous wastes and to
establish standards and regulations for the treatment, storage, and disposal of
these wastes. Regulations in Subtitle C of RCRA address the identification,
generation, transportation, treatment, storage, and disposal of hazardous
wastes. These regulations are found in 40 CFR Part 124 and 40 CFR Parts
260-279.- Under RCRA, persons who generate waste must determine whether
the waste is defined as solid waste or hazardous waste. Solid wastes are
considered hazardous wastes if they are listed by EPA as hazardous or if they
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exhibit characteristics of a hazardous waste: toxicity, ignitability, corrosivity,
or reactivity.
Most agriculture-related activities do not generate significant amounts of
hazardous waste. Generally, the activities potentially subject to RCRA
involve the use of pesticides and fertilizers, and the use and maintenance of
different types of machinery.
Hazardous Waste Generator Categories. Facilities that generate hazardous
waste can be classified into one of three hazardous waste generator categories
as defined in 40 CFR Part 262:
Conditionally exempt small quantity generator (CESQG). A facility
is classified as a CESQG if it generates no more than 220 Ibs (100 kg)
of hazardous waste in a calendar month. There is no time limit for
accumulating < 2,200 Ibs of hazardous waste onsite. However,
CESQGs cannot store more than 2,200 Ibs (1,000 kg) of hazardous
waste onsite at any time. In addition, CESQGs cannot accumulate
onsite more than 2.2 Ibs (1 kg) of acutely hazardous waste or more
than 220 Ibs spill residue from acutely hazardous waste for any period
of time.
Small quantity generator (SQG). A facility is classified as a SQG if it
generates >220 Ibs (100 kg) and <2,200 Ibs (1,000 kg) of hazardous
waste in a calendar month. SQGs can accumulate onsite no more than
13,200 Ibs (6,000 kg) of hazardous waste. SQGs can store hazardous
waste onsite for up to 180 days (or up to 270 days if the waste
treatment/disposal facility is more than 200 miles away).
Large quantity generator (LQG). A facility is classified as a LQG if it
generates > 2,200 Ibs (1,000 kg) of hazardous waste in a calendar
month. While there is no limit on the amount of hazardous waste that
LQGs can accumulate onsite, they can only store it onsite for up to 90
days.
If a facility is a CESQG and generates <;2.2 Ibs (1 kg) of acutely hazardous
waste; or ^220 Ibs (100 kg) of acutely hazardous waste spill residues in a
calendar month, and never stores more than that amount for any period of
time, it may manage the acutely hazardous waste according to CESQG
requirements. If it generates more than 2.2 Ibs (1 kg) of acutely hazardous
waste or >220 Ibs (100 kg) of acutely hazardous waste spill residues in a
calendar month, the facility must manage it according to LQG requirements.
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The hazardous wastes that must be measured are those: (1) accumulated at the
facility for any period of time before disposal or recycling, (2) packaged and
transported away from the facility, (3) placed directly into a treatment or
disposal unit at the facility, or (4) generated as still bottoms or sludges and
removed from product storage tanks.
Requirements for CESQGs. Based on the quantity of hazardous waste
generated per month, most agricultural establishments will qualify as
CESQGs. As CESQGs, facilities must comply with three basic waste
management requirements:
(1) Identify all hazardous waste generated.
(2) Do not generate per month more than 220 Ibs (100 kg) of hazardous
waste; more than 2.2 Ibs (1 kg) of acutely hazardous waste; or more
than 220 Ibs (100 kg) of acutely hazardous waste spill residues; and
never store onsite more than 2,200 Ibs (1,000 kg) of hazardous waste;
2.2 Ibs of acutely hazardous waste; or 220 Ibs of acutely hazardous
waste spill residues for any period of time.
(3) Ensure proper treatment and disposal of the waste. This means
ensuring that the disposal facility is one of the fqllowing:
- . A state or federally regulated hazardous waste management
treatment, storage, or disposal facility.
- A facility permitted, licensed, or registered by a state to manage
municipal or industrial solid waste.
- A facility that uses, reuses, or legitimately recycles the waste
(or treats the waste before use, reuse, or recycling).
- A universal waste handler or destination facility subject to the
requirements for universal wastes.
CESQGs are allowed to transport their own wastes to the treatment or storage
facility, unlike SQGs and LQGs who are required to use a licensed, certified
transporter. While there are no specific RCRA requirements for CESQGs
who transport their own wastes, the U.S. Department of Transportation (DOT)
requires all transporters of hazardous waste to comply with all applicable DOT
regulations. Specifically, DOT regulations require all transporters, including
CESQGs, transporting hazardous waste that qualifies as a DOT hazardous
material to comply with EPA hazardous waste transporter requirements found
in 40 CFR Part 263. CESQGs are not required by federal hazardous waste
laws to train their employees on waste handling or emergency preparedness.
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Requirements for SQGs and LQGs. Facilities determined to be SQGs or
LQGs must meet many requirements under the RCRA regulations. These
requirements, found in 40 CFR 260-279, include identifying hazardous waste;
obtaining an EPA identification numbers; meeting requirements for waste
accumulation and storage limits; container management; conducting personnel
training; preparing a manifest; ensuring proper hazardous waste packaging,
labeling, and placarding; reporting and recordkeeping; and contingency
planning, emergency procedures, and accident prevention.
Notes: Facilities that fall into different generator categories during different
months may choose to simplify compliance by satisfying the more stringent
requirements all the time.
Specific Provisions. RCRA regulations include several specific provisions
addressing agriculture-related materials and activities. Key provisions are
briefly summarized below:
Exemption for Certain Solid Wastes Used as Fertilizers. Under 40
CFR §261.4(b), solid wastes generated by (1) growing and harvesting
of agricultural crops, or (2) raising animals (including animal manure),
and that are returned to the soils as fertilizers are excluded from
regulation as hazardous waste.
Exemption for Certain Hazardous Waste Pesticides. Under 40 CFR
§262.70, farmers who generate any amount of hazardous waste
pesticides from their own use are excluded from the generator,
treatment/storage/disposal facility, land disposal, and permit
requirements under RCRA Subtitle C, provided that the farmer: (1)
disposes of the waste pesticide in a manner consistent with the label on
the pesticide container; (2) triple rinses each empty container in
accordance with requirements at 40 CFR §261.7(b)(3); and (3)
disposes of the rinsate on his own farm in accordance with the
instructions on the label. If the label does not include disposal
instruction, or no instructions are available from the pesticide
manufacturer, the waste pesticide and rinsate must be disposed of in
accordance with Subtitle C hazardous waste requirements. (Also see
40 CFR Part 165 - FIFRA).
Exemption for Commercial Fertilizers. Under 40 CFR §266.20,
commercial fertilizers produced for general public (including
agricultural) use that contain recyclable materials are not presently
subject to regulation provided they meet the applicable land disposal
restriction (LDR) standards for each recyclable material they contain.
For example, zinc-containing fertilizers containing K061 (emissipn
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control dust from the primary production of steel in electric furnaces)
are not subject to regulation.
Fertilizers Made from Hazardous Wastes. Under 40 CFR Parts 266
and 268, EPA regulates fertilizers containing hazardous wastes as
ingredients. Hazardous wastes may be used as ingredients in fertilizers
under certain conditions, since such wastes can be a beneficial
component of legitimate fertilizers. EPA has established standards
that specify limits on the levels of heavy metals and other contents
used as fertilizer ingredients. These standards are based on treatment,
by the best technology currently available, to reduce the toxicity and
mobility of all the contents of the hazardous waste components. These
standards are based on waste management considerations and do not
include consideration of the potential agronomic or dietary risk.
Food Chain Crops Grown on Hazardous Waste Land Treatment
Units. Under 40 CFR Part 264.276, food chain crops (including feed
for animals consumed by humans) may be grown in or on hazardous
waste land treatment units under certain conditions and only with a
permit. The permit for a facility will list the specific food-chain crops
that may be grown. To obtain a permit, the owner/operator of the
facility wishing to grow the food-chain crops must demonstrate — prior
to the planting of such crops — that there is no substantial risk to
human health caused by the growth of such crops in or on the
treatment zone.
Solid Waste Disposal Criteria. Under RCRA Subtitle D, 40 CFR
257.3 establishes solid waste disposal criteria addressing fioodplains,
endangered species, groundwater protection, application to land used
for food chain crops, disease vectors, air pollution, and safety. These
criteria are largely guidelines used by states in developing solid waste
regulations, which control the disposal of waste on a farmer's property.
Land Application of Fertilizers Derived from Drinking Water
Sludge. Under 40 CFR Part 257, EPA regulates the land application
of solid wastes, including drinking water sludge applied as fertilizer.
These requirements include: (1) cadmium limits on land used for the
production of food-chain crops (tobacco, human food, and animal
feed) or alternative less stringent cadmium limits on land used solely
for production of animal feed; (2) polychlorinated biphenyls (PCBs)
limits on land used for producing animal feed, including pasture crops
for animals raised for milk; and (3) minimization of disease vectors,
such as rodents, flies, and mosquitoes, at the site of application
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through incorporation of the fertilizer into soil so as to impede the
vectors' access to the sludge.
Pesticides That Are Universal Wastes. Under 40 CFR Part 273, EPA
has established a separate set of requirements for three types of wastes
called universal wastes. Universal wastes include certain batteries,
certain pesticides, and mercury thermostats. Pesticides designated as
universal wastes include (1) recalled pesticides that are stocks of a
suspended or canceled pesticide and part of a voluntary or mandatory
recall under FIFRA §19(b); (2) recalled pesticides that are stocks of a
suspended or canceled pesticide, or a pesticide that is not in
compliance with FIFRA, that are part of a voluntary recall [see FIFRA
§19(b)(2)] by the registrant; and (3) stocks of other unused pesticide
products that are collected and managed as part of a waste pesticide
collection program.
The Universal Waste rule is optional for states/tribe to adopt. In those
states/tribes that have not adopted the Universal Waste rule, these
wastes must be disposed of in accordance with the hazardous (or
acutely hazardous) waste requirements (see 40 CFR Part 262).
Exemption for Small Quantities of Used Oil. Under 40 CFR §279.20,
agricultural establishments that generate an average of 25 gallons or
less of used oil per month over a calendar year from vehicles or
machinery used on the establishment are not subject to the
requirements of 40 CFR Part 279.
Exemption for "Farm Tanks" and Tanks of 110 Gallons or Less.
Under the underground storage tank (UST) regulations (RCRA
Subtitle I, 40 CFR §280.12), "farm tanks" of 1,100 gallons or less
capacity used for storing motor fuel for non-commercial purposes are
not regulated as underground storage tanks. "Farm tanks " include
tank's located on a tract of land devoted to the production of crops or
raising animals (including fish) and associated, residences and
improvements. Also under 40 CFR §280.10, the UST program does
not apply to UST systems of 110 gallons or less capacity, or that
contain a de minimis concentration of a regulated substance.
Even with the above exemptions, keep in mind that many agricultural
establishments may be subject to the UST program (40 CFR Part 280).
The UST regulations apply to facilities that store either petroleum
products or hazardous substances (except hazardous wastes) identified
under CERCLA. UST regulations address design standards, leak
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detection, operating practices, response to releases, financial
responsibility for releases, and closure standards.
Comprehensive Environmental Response, Compensation, and Liability Act
Under CERCLA, there are a limited number of statutory and regulatory
requirements that potentially affect agricultural businesses. The key provisions
are summarized below:
• Emergency Release Notification Requirements. Under CERCLA
§103 (a), facilities are required to notify the National Response Center
about any release of a CERCLA hazardous substance in quantities
equal to or greater than its reportable quantity (RQ). Releases include
discharges into the air, soil, surface water, or groundwater. Any
release at or above the RQ must be reported regardless of whether
there is a potential for offsite exposure.
- Hazardous Substances. The term "hazardous substance" is
defined in CERCLA §101(14) and these substances (more than
700) are listed at 40 CFR Part 302, Table 302.4. Several
agricultural chemicals are on the CERCLA hazardous
substance list, including many pesticides, anhydrous ammonia,
and ethylene glycol.
— Reportable Quantities. For each hazardous substance, EPA has
designated a RQ of 1, 10, 100, 1,000, or 5,000 pounds. RQs
are listed in 40 CFR Part 355, Appendices A and B and 40
CFR Part 302, Table 302.4.
- When No Notification is Required. There are several types of
releases that are excluded from the requirements of CERCLA
release notification. Two of these releases, excluded under
CERCLA §§101(22) and 103(e), include the normal
application of fertilizer and the application of pesticide
products registered under FIFRA. Keep in mind that spills,
leaks, or other accidental or unintended releases of fertilizers
and pesticides are subject to the reporting requirements.
• Facility Notification and Recordkeeping Requirements -
Exemption for Agricultural Producers. Under CERCLA §§103(c)
and (d), certain facilities must notify EPA of their existence and the
owners/operators must keep records. However, CERCLA §103(e)
exempts agricultural producers who store and handle FIFRA-registered
pesticides from the facility notification and recordkeeping
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requirements. CERCLA does not define the term agricultural
producer.
Liability for Damages. Under CERCLA § 107(a), an owner/operator
of a facility that has CERCLA hazardous substances onsite may be
liable for cleanup costs, response costs, and natural resource damages
associated with a release or threatened release of hazardous substances.
Agricultural establishments are potentially liable under this section,
and that liability extends to past practices.
Emergency Planning and Community Right-to-Know Act
A summary of the potential applicability of specific sections of EPCRA on the
agricultural sector follows below.
Emergency Planning and Notification. Under EPCRA §302, owners
or operators of any facility, including agricultural establishments, that
have extremely hazardous substances (40 CFR Part 355 Appendices A
and B) present in excess of the threshold planning quantity must notify
in writing their state emergency response commission (SERC) and
their local emergency planning committee (LEPC) that they are subject
to EPCRA planning requirements. Under EPCRA §303, they must
also notify the LEPC of the name of a person at their facility whom the
LEPC may contact in regard to planning issues related to these
extremely hazardous substances. They must also inform the LEPC
promptly of any relevant changes, and when requested, must provide
information to the LEPC necessary for emergency planning.
Ammonia, several agricultural pesticides, and certain fuels are
included on the list of extremely hazardous substances found in 40
CFR Part 355 Appendices A and B. If a listed substance is a solid, two
different planning quantities are listed (e.g., 500 lbs/10,000 Ibs). The
smaller amount (e.g., 500 Ibs.) applies if the substance is in powder
form, such as a soluble or wettable powder, or if it is in solution or
molten form. The larger quantity (10,000 Ibs.) applies for most other
forms of the substance. If the extremely hazardous substance is part of
a mixture or solution, then the amount is calculated by multiplying its
percent by weight times the total weight of the mixture or solution. If
the percent by weight is less than one percent, the calculation is not
required (40 CFR Part 355.30).
S Ammonia -- The quantity of anhydrous ammonia that triggers
the planning requirement is 500 pounds.
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S Pesticides — Examples of pesticides on the list with the
quantity in pounds that triggers the planning requirement
include: ethion (1,000), nicotine (100), dichlorvos (1,000),
parathion(lOO), chlordane (1,000), methyl bromide (1,000),
ethylene oxide (1,000), fenitrothion (500), phorate (10), zinc
phosphide (500), aluminum phosphide (500), terbufos (100),
phosphamidon (100), demeton (500), ethoprop (1,000), and
disulfoton (500).
S Solid Pesticides — Examples of pesticides with dual quantities
that trigger the planning requirements include: coumaphos
(100/10,000), strychnine (100/10,000), dimethoate
(500/10,000), warfarin (500/10,000), azinphos-methyl
(10/10,000), methyl parathion (100/10,000), phosmet
(10/10,000), methidathion (500/10,000), carbofuran
(10/10,000), paraquat (10/10,000), methiocarb (500/10,000),
methamidophos (100/10,000), methomyl (500/10,000),
fenamiphos (10/10,000), and oxamyl (100/10,000).
§304 Emergency Release Notification. Under 40 CFR 355, facilities
must immediately notify the SERC and LEPC of releases of EPCRA
extremely hazardous substances and CERCLA hazardous substances
when the release equals or exceeds the reportable quantity within a 24-
hour period and has the potential for offsite exposure. There are two
notifications required: the initial notification and the written followup
notification.
Exemption for Substances Used in Agricultural Operations. Only
facilities that produce, use or store hazardous chemicals are subject to
EPCRA release reporting. EPCRA §31 l(e) excludes from the
definition of hazardous chemicals those substances used in routine
agricultural operations. The exemption covers fertilizers and
pesticides used in routine agricultural operations and fuelk for
operating farm equipment (including to transport crops to market). If
all the hazardous chemicals present at the facility do not fall within this
exemption, the facility must report all releases of any EPCRA
extremely hazardous substance or CERCLA hazardous substance.
Additionally, spills, leaks, or other accidental or unintended releases of
fertilizers and pesticides are subject to the EPCRA release reporting
requirements.
§311 and §312 Hazardous Chemical Inventory and Reporting.
Under EPCRA §311 and §312, facilities must inventory the hazardous
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chemicals present onsite in amounts equal to or in excess of the
threshold planning quantities, and meet two reporting requirements:
- A one-time notification of the presence of hazardous chemicals
onsite in excess of threshold levels (EPCRA §311) to the
SERC, LEPC, and the local fire department; and
- An annual notification (Tier I or Tier II report) to the SERC,
LEPC, and the local fire department detailing the locations and
hazards associated with the hazardous chemicals found on
facility grounds (EPCRA §312).
Exemption for Substances Used in Agricultural Operations. As
mentioned above, the term "hazardous chemical," as defined in
EPCRA §31 l(e), excludes substances used in routine agricultural
operations.
Clean Air Act
Agriculture-related industries generally do not include those industry sectors
considered to be major sources of air pollution. Nevertheless, some
agriculture-related activities are potentially subject to regulation under the
CAA. The provisions identified below summarize the CAA requirements
applicable to certain .agriculture-related activities:
Risk Management Program. Under § 112(r) of the Clean Air Act,
EPA has promulgated the Risk Management Program Rule. The rule's
main goals are to prevent accidental releases of regulated substances
and to reduce the severity of those releases that do occur by requiring
facilities to develop risk management programs. A facility's risk
management program must incorporate three elements: a hazard
assessment, a prevention program, and an emergency response
program. These programs are to be summarized in a risk management
plan (RMP) that will be made available to state and local government
agencies and the public.
Under 40 CFR Part 68, facilities that have more than the threshold
quantity of any of the listed regulated substances in a single process are
required to comply with the regulation. Process means any regulated
activity involving a regulated substance, including manufacturing,
storing, distributing, or handling a regulated substance or using it in
any other way. Any group of interconnected vessels (including
piping), or separate vessels located close enough together to be
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involved in a single accident, are considered a single process.
Transportation is not included.
Listed regulated substances are acutely toxic substances, flammable
gases, volatile liquids, and highly explosive substances listed by EPA
in the Risk Management Program rule. The threshold quantity is the
amount of a regulated substance that triggers the development of a
RMP. The list of regulated substances and their corresponding
threshold quantities are found at 40 CFR Part 68. Examples of
threshold quantities of listed regulated substances include:
formaldehyde » 15,000 pounds; ethylene oxide - 10,000 pounds;
methyl isocyanate — 10,000 pounds; anhydrous ammonia — 10,000
pounds; and mixtures containing ammonia in a concentration of 20
percent or greater ~ 20,000 pounds.
Exception: Ammonia that farmers are holding for use as fertilizer is
not a regulated substance under the risk management program.
Farmers are not responsible for preparing a risk management plan if
ammonia held for use as a fertilizer is the only listed regulated
substance that they have in more than threshold quantities. However,
ammonia that is'on a farm for any other use, such as for distribution
or as a coolant/refrigerant, is not exempt.
Three program levels. The risk management planning regulation (40
CFR Part 68) defines the activities facilities must undertake to address
the risks posed by regulated substances in covered processes. To
ensure that individual processes are subject to appropriate
requirements that match their size and the risks they may pose, EPA
has classified them into 3 categories ("programs"):
- Program 1 requirements apply to processes for which a worst-
case release, as evaluated in the hazard assessment, would not
affect the public. These are processes that have not had an
accidental release that caused serious offsite consequences.
- Program 2 requirements apply to less complex operations that
do not involve chemical processing.
- Program 3 requirements apply to higher risk, complex
chemical processing operations and to processes already
subject to the OSHA Process Safety Management Standard
(29 CFR 1910.119).
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Risk Management Planning. Facilities with more than a threshold
quantity of any of the 140 regulated substances in a single process are
required to develop a risk management program and to summarize
their program in a risk management plan (RMP). A facility subject to
the requirements were required to submit a registration and RMP by
June 21,1999, or whenever it first exceeds the threshold for a listed
regulated substance after that date. .
All facilities with processes in Program 1 must carry out the following
elements of risk management planning:
— An offsite consequence analysis that evaluates specific
potential release scenarios, including worst-case and alternative
scenarios.
- A five-year history of certain accidental releases of regulated
substances from covered processes.
- A risk management plan, revised at least once every five years,
that describes and documents these activities for all covered
processes.
Facilities with processes in Programs 2 and 3 must also address each of
the following elements:
An integrated prevention program to manage risk. The
prevention program will include identification of hazards,
written operating procedures, training, maintenance, and
accident investigation.
- An emergency response program.
- An overall management system to put these program elements
into effect.
National Ambient Air Quality Standards (NAAQS)/SIPS. Under
the CAA § 10, each state must develop a State Implementation Plan
(SIP) to identify sources of air pollution and to determine what
reductions are required to meet federal air quality standards. If the
applicable SIP imposes requirements on an agricultural establishment,
that facility must comply with the SIP. The most likely pollutant of
concern with respect to agriculture-related businesses is particulate
matter.
Federal Insecticide, Fungicide, and Rodenticide Act
For agricultural producers, FIFRA is the environmental statute that most
significantly impacts day-to-day operations of pesticide use. It also imposes
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administrative requirements on pesticide users, including agricultural
producers. A summary of major provisions applicable to agricultural
producers is provided below.
• Use restrictions: The pesticide product label is information printed on
or attached to the pesticide container. Users are legally required to
follow the label. Labeling is the pesticide product label and other
accompanying materials which contain directions that pesticide users
are legally required to follow. Under FIFRA §12, each pesticide must
be used only in a way that is consistent with its labeling.
— As a part of the pesticide registration, EPA must classify the
product for general use, restricted use, or general for some uses
and restricted for others (Miller, 1993). For pesticides that may
cause unreasonable adverse effects on the environment,
including injury to the applicator, EPA may require that the
pesticide be applied either by or under the direct supervision of
a certified applicator.
— It is against the law (Endangered Species Act) to harm an
endangered species. Harm includes not only acts that directly
injure or kill the protected species, but also significant habitat
modification or degradation that disrupts breeding, feeding, or
sheltering. Pesticide users must comply with any pesticide
labeling restrictions or requirements that concern the protection
of endangered species or their habitats.
• Tolerances and Exemptions A tolerance is the maximum amount of
pesticide residue that can be on a raw product and still be considered
safe. Before EPA can register a pesticide that is used on raw
agricultural products, it must grant a tolerance or exemption from a
tolerance (40 CFR.163.10 through 163.12). Under the Federal Food,
Drug, and Cosmetic Act (FFDCA), a raw agricultural product is
deemed unsafe if it contains a pesticide residue, unless the residue is
within the limits of a tolerance established by EPA or is exempt from
the requirement.
To avoid being responsible for products being over tolerance, users
must be particularly careful to comply with the label instructions
concerning application rate and minimum days between pesticide
application and harvest (i.e., preharvest interval), slaughter, freshening,
or grazing.
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Worker Protection Standard (WPS) Requirements for Users. The
WPS for Agricultural Pesticides (40 CFR Parts 156 and 170) covers
pesticides that are used in the commercial production of agricultural
plants on farms, forests, nurseries, and greenhouses. The WPS
requires pesticide users to take steps to reduce the risk of pesticide-
related illness and injury if they or their employees may be exposed to
pesticides used in the commercial production of agricultural plants.
Cancellation and Suspension EPA can cancel a registration if it is
determined that the pesticide or its labeling does not comply with the
requirements of FIFRA or causes unreasonable adverse effects on the
environment (Haugrud, 1993).
In cases where EPA believes that an "imminent hazard" would exist if
a pesticide were to continue to be used through the cancellation
proceedings, EPA may suspend the pesticide registration through an
order and thereby halt the sale, distribution, and usage of the pesticide.
An "imminent hazard" is defined as an unreasonable adverse effect on
the environment or an unreasonable hazard to the survival of a
threatened or endangered species that would be the likely result of
allowing continued use of a pesticide during a cancellation process.
When EPA believes and emergency exists that does not permit a
hearing to be held prior to suspending, EPA can issue an emergency
order that makes the suspension immediately effective.
Toxic Substances Control Act
TSCA has a limited impact on the agricultural sector. TSCA §3, Definitions,
specifies that the term chemical substance means any organic or inorganic
substance of a particular molecular identity. The definition also states, as
declared at subsection (2)(B)(ii), that such term does not include any pesticide
(as defined in FIFRA) when manufactured, processed, or distributed in
commerce for use as a pesticide. Since the majority of potentially hazardous
substances used by agricultural producers are pesticides, they are regulated
under FIFRA. Regulation of hazardous substances under other authorities is
part of TSCA's overall scheme which allows EPA to decline to regulate a
chemical under TSCA if other federal regulatory authorities (e.g., FIFRA) are
sufficiently addressing the risks posed from those substances.
Asbestos and Asbestos-Containing Material. Under TSCA §6 and
40 CFR Part 61, Subpart M, EPA regulates the renovation/demolition
activities, notification, work practices and removal, and disposal of
asbestos-containing material (ACM). ACM should be carefully
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monitored; however, the mere presence of asbestos in a building is not
considered hazardous. ACM that becomes damaged, however, may
pose a health risk since it may release asbestos fibers over time. If a
material is suspected of containing asbestos and it is more than slightly
damaged, or if changes need to be made to a building that might
disturb it, repair or removal of the ACM by a professional is needed.
Asbestos Brake Pads. Facilities that repair their own brakes should
be aware of asbestos requirements. Asbestos brake pads must be
removed .using appropriate control measures so that no visible
emissions of asbestos will be discharged to the outside air. These
measures can include one of the following: (1) wetting that is generally
done through the use of a brake washing solvent bath, such as those
provided by a service; (2) vacuuming that is usually performed with a
commercial brake vacuum specifically designed for use during brake
pad changing or pad re-lining operations; or (3) combination of
wetting and vacuuming.
Asbestos brake pads and wastes must be managed by: (1) labeling
equipment, (2) properly disposing of spent solvent, (3) properly
disposing of used vacuum filters, and (4) sealing used brake pads. The
containers or wrapped packages must be labeled using warning labels
as specified by OSHA [29 CFR 1910.001 (j) (2) or 1926.58 (k)(2)(iii)].
Asbestos waste must be disposed of as soon as practical at an EPA-
approved disposal site. The asbestos containers must be labeled with
the name and location of the waste generator. Vehicles used to
transport the asbestos must be clearly labeled during loading and
unloading. The waste shipment records must be maintained (40 CFR
61.150) so that the asbestos shipment can be tracked and substantiated.
Polychlorinated Biphenyls (PCBs). PCBs were widely used in
electrical equipment manufactured from 1932 to 1978. Types of
equipment potentially containing PCBs include transformers and their
bushings, capacitors, reclosers, regulators, electric light ballasts, and
oil switches. Any equipment containing PCBs in their dielectric fluid
at concentrations of greater than 50 ppm are subject to the PCB
requirements.
Under TSCA §6 and 40 CFR Part 761, facilities must ensure through
activities related to the management of PCBs (e.g., inspections for
leaks, proper storage) that human food or animal feed are not exposed
to PCBs. While the regulations do not establish a specific distance
limit, any item containing PCBs is considered to pose an unacceptable
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exposure risk to food or feed if PCBs released in any form have the
potential to reach/contaminate food or feed.
Lead. Approximately 1.7 million children have blood-lead levels high
enough to raise health concerns. Studies suggest that lead exposure
from deteriorated residential lead-based paint, contaminated soil, and
lead in dust are among the major existing sources of lead exposure
among children in the U.S.
Section 1018 of the Residential Lead-Based Paint Hazard Reduction
Act of 1992 directs EPA and the Department of Housing and Urban
Development (HUD) to jointly issue regulations requiring disclosure
of known lead-based paint and/or lead-based paint hazards by persons
selling or leasing housing constructed before the phaseout of
residential lead-based paint use in 1978. Under that authority, EPA
and HUD jointly issued on March 6, 1996, regulations titled Lead;
Requirements for Disclosure of Known Lead-Based Paint and/or
Lead-Based Paint Hazards in Housing (40 CFR Part 35 and 40 CFR
Part 745). In these regulations, EPA and HUD established
requirements for sellers/lessors of residential housing built before
1978.
Pre-Renovation Lead Information Rule. If conducted improperly,
renovations in housing with lead-based paint can create serious health
hazards to workers and occupants by releasing large amounts of lead
dust and debris. Under TSCA §406 and through a rule published on
June 1, 1998 entitled Lead; Requirements for Hazard Education
Before Renovation of Target Housing (40 CFR Part 745), EPA
required the distribution of lead hazard information (i.e., EPA-
developed pamphlet) prior to professional renovations on residential
housing built before 1978.
IV.C. Proposed and Pending Regulations
Coastal Zone Act Reauthorization Amendments of 1990
Implementation of Management Measures. Under Section 6217,
states/tribes must fully implement the management measures in their Coastal
Nonpoint Pollution Control Programs by January 2004. States/tribes are
required to perform effectiveness monitoring between 2004 and 2006 and
implement other measures between 2006 and 2009,
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Safe Drinking Water Act
Management of Class V Wells. EPA plans to propose additional
requirements addressing the environmental risks posed by the highest risk
Class V wells. This rulemaking potentially affects agricultural operations that
use industrial and commercial disposal wells and large capacity cesspools.
Federal Insecticide, Fungicide, and Rodenticide Act
Pesticide Management and Disposal: Proposed Rule - issued on May 5,
1993 (FR26857). The regulations for this rule will be found in the Code of
Federal Regulations (CFR) at 40 CFR Part 165 - Regulations for the
Acceptance of Certain Pesticides and Recommended Procedures for the
Disposal and Storage of Pesticides and Pesticides Containers. This final rule
will:
• Describe procedures for voluntary and mandatory recall actions.
• Establish criteria For acceptable storage and disposal plans which
registrants may submit to EPA to become eligible for reimbursement of
storage costs.
• Establish procedures for the indemnification of owners of suspended and
canceled pesticides.
• Amend the Agency's responsibility for accepting for disposal suspended
and canceled pesticides.
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Compliance and Enforcement History
V. COMPLIANCE AND ENFORCEMENT HISTORY
V.A. Background
Until recently, EPA has focused much of its attention on measuring
compliance with specific environmental statutes. This approach allows the
Agency to track compliance with the Clean Air Act, the Resource
Conservation and Recovery Act, the Clean Water Act, and other
environmental statutes. Within the last several years, the Agency has begun to
supplement single-media compliance indicators with facility-specific,
multimedia indicators of compliance. In doing so, EPA is in a better position
to track compliance with all statutes at the facility level and within specific
industrial sectors.
A major step in building the capacity to compile multimedia data for industrial
sectors was the creation of EPA's Integrated Data for Enforcement Analysis
(IDEA) system. IDEA has the capacity to "read into" the Agency's single-
media databases, extract compliance records, and match the records to
individual facilities. The IDEA system can match air, water, waste,
toxics/pesticides, EPCRA, Toxics Release Inventory (TRI), and enforcement
docket records for a given facility and generate a list of historical permit,
inspection, and enforcement activity. IDEA also has the capability to analyze
data by geographic area and corporate holder. As the capacity to generate
multimedia compliance data improves, EPA will make available more in-
depth compliance and enforcement information. Additionally, EPA is
developing sector-specific measures of success for compliance assistance
efforts.
V.B. Compliance and Enforcement Profile Description
This section uses inspection, violation,
and enforcement data from the IDEA
system to provide information about the
historical compliance and enforcement
activity of this sector. While other
sector notebooks have used Standard
Industrial Classification (SIC) data from
the Toxics Release Inventory System
(TRIS) to define their data sampling
universes, none of the SIC codes
associated with the crop production
sectors identifies facilities that report to
the TRI program. As such, sector-
defining data have been provided from
EPA data systems linked to EPA's Facility Indexing System (FINDS), which
Note: Many of the previously
published sector notebooks
contained a chapter titled
"Chemical Release and Transfer
Profile. " The information and
data for that chapter were taken
primarily from EPA's Toxic
Release Inventory (TRI). Because
the industries discussed in this
notebook do not, in general,
directly report to TRI, that chapter
has not been included in this
sector notebook.
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tracks facilities in all media databases. This section does not attempt to define
the actual number of facilities that fall within each sector. Instead, the section
portrays the records of a subset of facilities within the sector that are well
defined within EPA databases.
As a check on the relative size of the full sector universe, most notebooks
contain an estimated number of facilities within the sector according to the
Bureau of Census. With sectors dominated by small businesses, such as metal
finishers and printers, the reporting universe within the EPA databases may be
small in comparison to Census data. However, the group selected for
inclusion in this data analysis section should be consistent with this sector's
general make-up.
Before presenting the data, the next section defines general terms and the
column heads used in the data tables. The data represent a retrospective
summary of inspections and enforcement actions and solely reflect EPA, state,
and local compliance assurance activities that have been entered into EPA
databases. To identify trends, EPA ran two data queries, one for five calendar
years (March 7, 1992 to March 6, 1997) and the other for a twelve-month
period (March 7,1996 to March 6, 1997). The five-year analysis gives an
average level of activity for that period for comparison to the more recent
activity.
Because most inspections focus on single-media requirements, the data
queries presented in this section are taken from single media databases. These
databases do not provide data on whether inspections are state/local or EPA-
led. However, the table breaking down the universe of violations does give
the reader a crude measurement of the EPA's and state's efforts within each
media program. The presented data illustrate the variations across EPA
regions for certain sectors.1 This variation may be attributable to state/local
data entry variation, specific geographic concentrations, proximity to
population centers, sensitive ecosystems, highly toxic chemicals used in
production, or historical noncompliance. Hence, the exhibited data do not
rank regional performance or necessarily reflect which regions may have the
most compliance problems.
1 EPA Regions are as follows: I (CT, MA, ME, RI, NH, VT); II (NJ, NY, PR, VI); m (DC,
DE, MD, PA, VA, WV); IV (AL, FL, GA, KY, MS, NC, SC, TN); V (IL, IN, MI, MN, OH, WI); VI
(AR, LA, NM, OK, TX); VH (IA, KS, MO, NE); Vm (CO, MT, ND, SD, UT, WY); IX (AZ, CA, HI,
NV, Pacific Trust Territories); X (AK, ID, OR, WA).
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Compliance and Enforcement Data Definitions
General Definitions
Facility Indexing System (FINDS) - assigns a common facility number to
EPA single-media permit records, establishing a linkage capability to the
permit data. The FINDS identification number allows EPA to compile and
review all permit, compliance, enforcement, and pollutant release data for any
given regulated facility.
Integrated Data for Enforcement Analysis (IDEA) - is a data integration
system that can retrieve information from the major EPA program office
databases. IDEA uses the FINDS identification number to link separate data
records from EPA's databases. This allows retrieval of records from across
media or statutes for any given facility, this creating a "master list" of records
for that facility. Some of the data systems accessible through IDEA are AFS
(Air Facility Indexing and Retrieval System, Office of Air and Radiation),
PCS (Permit Compliance System, Office of Water), RCRIS (Resource
Conservation and Recovery Information System, Office of Solid Waste),
NCDB (National Compliance Data Base, Office of Prevention, Pesticides, and
Toxic Substances), CERCLIS (Comprehensive Environmental and Liability
Information System, Superfund), and TRIS. IDEA also contains information
from outside sources, such as Dun and Bradstreet (DUN) and the
Occupational Safety and Health Administration (OSHA). Most data queries
displayed in this section were conducted using IDEA.
Data Table Column Heading Definitions
Facilities in Search - based on the universe of TRI reporters within the listed
SIC code range. For industries not covered under TRI reporting requirements,
or industries in which only a very small fraction of facilities report to TRI, the
notebook uses the FINDS universe for executing data queries. The SIC code
range selected for each search is defined by each notebook's selected SIC code
coverage described in Section II.
Facilities Inspected - indicates the level of EPA and state agency inspections
for the facilities in this data search. These values show what percentage of the
facility universe is inspected in a one-year or five-year period.
Number of Inspections - measures the total number of inspections conducted
in this sector. An inspection event is counted each time it is entered into a
single media database.
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Average Time Between Inspections - provides an average length of time,
expressed in months, between compliance inspections at a facility within the
defined universe.
Facilities With One or More Enforcement Actions - expresses the number of
facilities that were the subject of at least one enforcement action within the
defined time period. This category is broken down further into federal and
state actions. Data are obtained for administrative, civil/judicial, and criminal
state actions. A facility with multiple enforcement actions is only counted
once in this column, e.g., a facility with 3 enforcement actions counts as 1
facility.
Total Enforcement Actions - describes the total number of enforcement
actions identified for an industrial sector across all environmental statutes. A
facility with multiple enforcement actions is counted multiple times (i.e., a
facility with 3 enforcement actions counts as 3).
State Lead Actions - shows what percentage of the total enforcement actions
are taken by state and local environmental agencies. Varying levels of use by
states of EPA data systems may limit the volume of actions accorded state
enforcement activity. Some states extensively report enforcement activities
into EPA data systems, while other states may use their own data systems.
Federal Lead Actions - shows what percentage of the total enforcement
actions are taken by the U.S. EPA. This value includes referrals from state
agencies. Many of these actions result from coordinated or joint federal/state
efforts.
Enforcement to Inspection Rate - is a ratio of enforcement actions to
inspections, and is presented for comparative purposes only. The ratio is a
rough indicator of the relationship between inspections and enforcement. It
relates the number of enforcement actions and the number of inspections that
occurred within the one-year or five-year period. This ratio includes
inspections and enforcement actions reported under the Clean Water Act
(CWA), the Clean Air Act (CAA) and the Resource Conservation and
Recovery Act (RCRA). Inspections and actions from the
TSCA/FIFRA/EPCRA database are not factored into this ratio because most
of the actions taken under these programs are not the result of facility
inspections. Also, this ratio does not account for enforcement actions arising
from non-inspection compliance monitoring activities (e.g., self-reported
water discharges) that can result in enforcement action within the CAA, CWA
and RCRA.
Facilities with One or More Violations Identified - expresses the percentage
of inspected facilities having a violation identified in one of the following data
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Compliance and Enforcement History
categories: In Violation or Significant Violation Status (CAA); Reportable
Noncompliance, Current Year Noncompliance, Significant Noncompliance
(CWA); Noncompliance and Significant Noncompliance (FIFRA, TSCA, and
EPCRA); Unresolved Violation and Unresolved High Priority Violation
(RCRA). The values presented for this column reflect the extent of
noncompliance within the measured time frame, but do not distinguish
between the severity of the noncompliance. Violation status may be a
precursor to an enforcement action, but does not necessarily indicate that an
enforcement action will occur.
Media Breakdown of Enforcement Actions and Inspections - four columns
identify the proportion of total inspections and enforcement actions within
EPA Air, Water, Waste, and TSCA/FIFRA/EPCRA databases. Each column
is a percentage of either the "Total Inspections," or the "Total Actions"
column.
V.C. Compliance History for the Agricultural Production Industries: Crops,
Greenhouses/Nurseries, and Forestry
Exhibit 23 provides an overview of the
reported compliance and enforcement
data for the agricultural production
industries over the past 5 years (March
1992 to March 1997). These data are
also broken out by EPA regions thereby
permitting geographical comparisons.
Note: It should be noted that the
data presented in this section
represent federal enforcement
activity only. Enforcement activity
conducted at the state level is not
included in this analysis.
A few points evident from the data are listed below. It should also be noted
that agriculture crop production (SIC code 01) and forestry (SIC code 08) are
presented separately in the exhibits.
• As shown, of the 6,688 facilities identified through IDEA with crop
•production NAICS codes, nearly half (3,046) were inspected over the
5-year period. The total number of inspections over the same 5 years
was 10,453, which means that, on average, each facility was subjected
to nearly 3.5 inspections over the 5 years.
• Region 7 has the most crop production facilities with 2,391 and has
conducted the most inspections (3,180). Similarly, Region 5 has the
second most facilities and has conducted the second most inspections.
Inspections in these regions comprise more than half (57%) of all
inspections conducted.
• The 10,453 inspections conducted* nationwide have resulted in 262
enforcement actions, which results in an enforcement-to-inspection
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Compliance and Enforcement History
rate of 0.03. This means that for every 100 inspections conducted,
there are approximately 3 resulting enforcement actions.
• The average enforcement-to-inspection rate across the regions ranged
from 0.01 in Region 5 to 0.08 in Regions 1 and 2.
Exhibit 24 provides an overview of the reported compliance and enforcement
data for forestry SIC codes over the 5-year period by EPA region.
• Of the 97 facilities identified, approximately 25 percent (24 facilities)
were inspected in the 5-year period.
• The 68 inspections conducted nationwide have resulted in 10
enforcement actions, which results in an enforcement-to-inspection
rate of 0.15.
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Compliance and Enforcement History
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Sector Notebook Project
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Agricultural Crop Production Industry
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Sector Notebook Project
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Compliance and Enforcement History
Comparison of Enforcement Activity Between Selected Industries
Exhibits 25 and 26 provide both the 5-year and 1-year enforcement and
compliance data for most of the industries covered by the sector notebooks.
These data allow the reader to compare the enforcement and compliance
history of the sectors and identify trends across sectors and over the 5-year
period.
• Of the industries presented, the crop production sector has the second
most identified facilities with 6,688; it also has the second highest
number of facilities inspected (3,046) over the 5-year period. The
enforcement-to-inspection rate of 0.03 was the second lowest among
all sectors.
• Forestry has the second fewest number of facilities (97) among all
sectors and the fewest number of facilities inspected (24). Its
enforcement-to-inspection rate of 0.15 is the second highest, next to
petroleum refining (0.25).
In Exhibit 26, when compared to all sectors over the last year, the crop
production sector had the fifth most facilities inspected (1,012) and the fourth
most inspections conducted (1,459). The enforcement-to-inspection rate of
0.02 for the crop production sector was among the lowest rates across all
sectors. From March 1996 - March 1997, forestry had the fewest number of
facilities inspected and the lowest number of inspections conducted.
Exhibits 27 and 28 provide a more in-depth comparison between the crop
production and forestry sectors and others by organizing inspection and
enforcement data by environmental statute. Exhibit 27 provides inspection
and enforcement data over the 5-year period, while Exhibit 28 provides data
for the March 1996 - March 1997 only.
As shown in Exhibit 27, over the 5-year period, nearly three-quarters of all
inspections conducted at crop production facilities were under the Clean Air
Act. However, the CAA accounts for only 35 percent of all enforcement
actions. The enforcement actions are spread out across the CAA (35%), CWA
(23%), and RCRA (25%) with FIFRA/TSCA/EPCRA/Other having the lowest
percentage of enforcement actions (17%). For forestry, more than half of all
inspections and exactly half of all enforcement actions have come under
RCRA.
For March 1996 - March 1997 (see Exhibit 28), again CAA inspections
account for nearly three-quarters of all inspections for the crop production
sectors. And, similarly to the 5-year history, enforcement actions are fairly
evenly disbursed among the CAA (31%), CWA (34%), and RCRA (28%). It
Sector Notebook Project
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Agricultural Crop Production Industry
Compliance and Enforcement History
should be noted that 7 percent of all enforcement actions were taken under the
FIFRA/TSCA/EPCRA/Other category although no inspections were
conducted within that category. This number is possible because in many
EPA regions, media inspectors are being trained to examine the facility from a
multimedia viewpoint. As a result, these actions may originate from the
media inspections. Regarding the forestry industry, 83 percent of all
inspections were conducted under the RCRA program. However, no
enforcement actions were taken based on those inspections. Two-thirds of all
enforcement actions were taken under the FIFRA/TSCA/EPCRA/Other
category, although no inspections were conducted under those programs (see
above note).
Sector Notebook Project
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Compliance and Enforcement History
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VI. REVIEW OF MAJOR LEGAL ACTIONS
This section provides summary information about major cases that have
affected this sector, and a list of Supplemental Environmental Projects (SEPs).
Review of Major Cases
The following cases are examples of EPA's enforcement against the
agricultural production industries of crops, greenhouses/nurseries, and
forestry.
Cumberland Farms, Inc. In September 1996, a District Court entered a
consent decree between the U.S. and Cumberland Farms, Inc., which resolves
a long standing wetlands enforcement action against Cumberland Farms, Inc.,
for its unpermitted filling of 180 acres of wetlands in violation of the Clean
Water Act between 1977 and 1990 in Halifax and Hanson, Massachusetts.
Under the consent decree, Cumberland is required to deed two undeveloped
tracts of land, totaling 225 acres, to the Massachusetts Division of Fisheries
and Wildlife for permanent conservation. In addition, the company will
establish a 30-acre wildlife and wetlands corridor on the most seriously
damaged site and pay a civil $50,000 penalty. This settlement, along with
others, will preserve a total of 490 acres of undeveloped habitat in the same
watershed as the violations. This represents the largest permanent
preservation of habitat arising from a federal enforcement in New England.
U.S. v. Tropical Fruit. Tropical Fruit, S.E., in Guayanilla, Puerto Rico,
operates a plantation where it grows mangoes, bananas, and other fruits. On
December 20, 1996, Region 2 issued an administrative order under CERCLA
106(a) to Tropical Fruit, S.E., and its three individual partners of that company
(Avshalom Lubin, Cesar Otero Acevedo, and Pedro Toledo Gonzalez) for
application of pesticides using a high pressure applicator that produced a
cloud which sometimes would drift into the adjacent residential community,
which is composed of minority and low income residents. The CERCLA
order requires that the respondents immediately cease and desist from spraying
pesticides, fungicides, and any other materials that contain hazardous
substances in such a manner that these substances might drift or otherwise
migrate beyond the boundaries of the farm.
Region 2 also issued an administrative complaint for violations of the Worker
Protection Standard for agricultural workers under FIFRA. The complaint
cited Tropical Fruit's failure to post warning signs during and after
application, as well as its failure to maintain a decontamination area and a
central bulletin board with pesticide safety information.
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On March 26, 1997, DOJ (acting on EPA's behalf) filed a complaint against
Tropical Fruit seeking an injunction requiring the firm arid its partners to
comply with EPA's CERCLA order and all applicable FIFRA requirements.
Three of the pesticides routinely used by Tropical Fruits on its mango trees are
not registered for use on mangoes; their use in this manner is in violation of
FIFRA. The judicial complaint also sought penalties for violations of the
CERCLA order since its issuance. Also on March 26, 1997, the court signed
an interim consent order requiring Tropical Fruit to modify its pesticide
application procedures to prevent these substances from drifting into the
adjacent residential community. The order also requires Tropical Fruit to
better protect its workers by providing extensive training, protective clothing,
respirators, and decontamination equipment. Subsequently on May 21, 1997,
EPA documented further violations of the CERCLA administrative order and
the judicial interim consent order. On August 22, 1997, Tropical Fruit paid
$ 10,000 in stipulated penalties for those violations.
Region 2 also has documented additional FIFRA violations by Tropical Fruit,
which included the illegal importation of Guitar, an unregistered pesticide
from the Middle East. In addition, the region has documented violations of
RCRA UST regulations, as well as violations of CWA §404 and the
associated regulations regarding discharge of dredged or fill materials into
wetlands. EPA anticipates that all of these violations will be subject to further
enforcement action.
Supplementary Environmental Projects (SEPs)
SEPs are compliance agreements that reduce a facility's stipulated penalty in
return for an environmental project that exceeds the value of the reduction.
Often, these projects fund pollution prevention activities that can significantly
reduce the future pollutant loadings of a facility. Information on SEPs can be
accessed via the internet at http://www.epa.gov/oeca/sep.
There was one SEP at an agricultural crop producing facility. This SEP was
negotiated with Franklin Mushroom Farms, Incorporated (Franklin Farms) of
Southington, CT. The complaint alleged that Franklin Farms illegally
discharged pollutants to a nearby river in violation of their NPDES Permit. As
part of a settlement, Franklin Farms agreed to a SEP in which they would
institute water recycling/conservation methods to reduce overall pollutant
loading to the river. The cost of instituting these methods was $89,900 at the
time of the settlement. Franklin Farms also was required to pay a penalty of
$75,000. Details on this SEP can be found by accessing
http://es.epa.gov/oeca/sep/searchsep.html, selecting '01 Agriculture - Crop
Productipn' in the Industrial Sector of Violation field, and choosing the
Submit Search button.
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VII. COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES
This section highlights the activities undertaken by this industry sector and
public agencies to voluntarily improve the sector's environmental
performance. These activities include those independently initiated by
industrial trade associations. In this section, the notebook also contains a
listing and description of national and regional trade associations.
VILA. Sector-Related Environmental Programs and Activities
There are several federal programs available to the agricultural community to
assist agricultural producers in complying with environmental regulations and
reducing pollution. The following examples represent some industry
initiatives that promote compliance or assess methods to reduce environmental
contamination.
National Agriculture Compliance Assistance Center
The U.S. Environmental Protection Agency (EPA), with the support of the
Department of Agriculture (USD A), has developed a national Agriculture
Compliance Assistance Center (Ag Center) to provide a base for "first-stop
shopping" for the agricultural community — one place for the development of
comprehensive, easy-to-understand information about approaches to
compliance that are both environmentally protective and agriculturally sound.
The Ag Center, a program offered by EPA's Office of Compliance, seeks to
increase compliance by helping the agricultural community identify flexible,
common sense ways to comply with the many environmental requirements
that affect their business. Initial efforts will focus on providing information
about EPA's requirements. The Ag Center will rely heavily on existing
sources of agricultural information and established distribution mechanisms.
The Ag Center is designed so growers, livestock producers, other
agribusinesses, and agricultural information/education providers can access its
resources easily — through telephone, fax, mail, and Internet. The Ag Center
website can be accessed at http://www.epa.gov/agriculture.
Unified National Strategy for Animal Feeding Operations
As part of President Clinton's Clean Water Action Plan (C WAP), a USD A-
EPA unified national strategy has been developed to minimize the water
quality and public health impacts (e.g., nutrient loading, fish kills, odors) of
animal feeding operations (AFOs). USDA and EPA's goal is for AFO owners
and operators to take actions to minimize water pollution from confinement
facilities and land application of manure. To accomplish this goal, this
Strategy is based on a national performance expectation that all AFOs should
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develop and implement technically sound, economically feasible, and
site-specific Comprehensive Nutrient Management Plans (CNMPs) to
minimize impacts on water quality and public health.
CNMPs identify actions or priorities that will be followed to meet clearly
defined nutrient management goals at an agricultural operation. They should
address, as necessary, feed management, manure handling and storage, land
application of manure, land management, recordkeeping, and other utilization
options. While nutrients are often the major pollutants of concern, the plan
should address risks from other pollutants, such as pathogens, to minimize
water quality and public health impacts from AFOs. CNMPs should be site-
specific and be developed and implemented to address the goals and needs of
the individual owner/operator, as well as the conditions on the farm. USDA
and EPA issued the final draft of this Strategy in March 1999. For more
information, the complete unified national strategy can be accessed at
http://www.epa.gov/owm/finafost.htm.
VII.B. EPA Programs and Activities
Section 319 Nonpoint Source Management Program
In 1987, Congress amended the Clean Water Act (CWA) to establish the §319
Nonpoint Source Management Program in recognition of the need for greater
federal leadership to help focus state and local nonpoint source efforts. Under
§319, states, territories,,and Indian tribes receive grant money to support a
wide variety of activities, including technical assistance, financial assistance,
education, training, technology transfer, demonstration projects, and
monitoring to assess the success of specific nonpoint source implementation
projects. For more information about the Clean Water Act §319 Program,
refer to EPA's Office of Water website at
http://www.epa.gov/OWOW/NPS/sec319.html.
Clean Lakes Program
EPA's Clean Lakes Program supports a variety of lake management activities
including classification, assessment, study, and restoration of lakes. The
program, authorized in §314 of the Clean Water Act, was established to
provide technical and financial assistance to states/tribes for restoring the
quality of publicly owned lakes. The Clean Lakes Program has funded
approximately $145 million for grant activities since 1976 to address lake
problems, but there have been no appropriations for the program since 1994.
EPA has not requested funds for the Clean Lakes Program in recent years, but
has encouraged states to use §319 funds to fund "eligible activities that might
have been funded in previous years under Section 314." Information on the
Clean Lakes Program is available at the following Internet site:
http://www.epa.gov/owow/lakes/cllkspgm.html.
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National Estuary Program
EP A's National Estuary Program is a national demonstration program,
authorized in §320 of the Clean Water Act, that uses a comprehensive
watershed management approach to address water quality and habitat
problems in 17 estuaries. Nonpoint source pollution is a major contributor of
contaminants in the estuary and coastal waters around the country. In this
program, EPA and states/tribes develop conservation and management plans
that recommend priority corrective actions to restore estuarine water, quality,
fish populations, and other designated uses of the waters. Information on the
National Estuary Program is available at the following Internet site:
http://www.epa.gov/owowwtrl/estuaries/nep.html or by contacting the
National Estuary Program Office at (202) 260-1952.
Chesapeake Bay Program and The Great Lakes National Program
EPA's Chesapeake Bay Program and the Great Lakes National Program focus
substantial resources on understanding the extent of nonpoint source pollution
problems in their respective watersheds and supporting State implementation
of nonpoint source pollution controls. Since 1984, the Chesapeake Bay
Program, in particular, has supported the implementation of a substantial
amount of animal waste management practices through State cost share
programs funded jointly by the Bay States and EPA. Information on the
Chesapeake Bay Program is available at
http://www.epa.gov/owowwtrl/ecoplaces/partl/site2.html. Information on
The Great Lakes National Program is available at http://www.epa.gov/glnpo/.
AgSTAR Program
The AgSTAR program is a voluntary program that promotes the use of
profitable manure management systems that reduce pollution. The program, a
component of President Clinton's Climate Action Plan, is based on a
computer model that shows the economic value of capturing the methane
naturally produced by manure.
AgSTAR, a joint program of EPA, USD A, and the Department of Energy,
helps agricultural producers determine which methane recovery and use
technologies will work best for them, and develops financing sources to help
with start-up costs. By investing in these technologies, AgSTAR participants
realize substantial returns through reduced electrical, gas, and oil bills,
revenues from high quality manure by-products, and savings on manure
management operational costs. Partners also reduce pollution associated with
water resources, odors, and global warming. Information on AgSTAR is
available at the following Internet site:
http://yosemite.epa.gov/methane/home.nsf/pages/agstar.
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Pesticide Environmental Stewardship Program
EPA's Pesticide Environmental Stewardship Program (PESP) is a voluntary
program dedicated to protecting human health and preserving the environment
by reducing the risks associated with pesticide use. The partnership is a key
element of the program, which is sponsored by EPA, USD A, and FDA.
Current partners include agricultural producers as well as non-agricultural
interests. Partners in PESP volunteer to develop arid implement a well
designed pesticide management plan that will produce the safest and most
effective way to use pesticides. In turn, EPA provides a liaison to assist the
partner in developing comprehensive, achievable goals. Liaisons act as
"customer service representatives" for EPA, providing the partner with access
to information and personnel. EPA also promises to integrate the partners'
stewardship plans into its agricultural policies and programs.
So far, agricultural producers have committed to a number of projects,
including conducting more research into IPM techniques, developing
computer prediction models for more precise pesticide applications, educating
their members and the public regarding pesticide use, and working with
equipment manufacturers to refine application techniques. Information on
PESP is available at the following Internet site: http://www.pesp.org, or
contact the PESP hotline at (800) 972-7717.
Endangered Species Protection Program
The Endangered Species Protection Program (ESPP) began in 1988. This
program is largely voluntary at the present time and relies on cooperation
between the U.S. Fish and Wildlife Service (FWS), EPA Regions, States, and
pesticide users. EPA's Endangered Species Protection Program is designed to
protect Federally-listed endangered and threatened species from exposure to
pesticides. The program is intended to provide information concerning and
regulation for the use of pesticides that may adversely affect the survival,
reproduction and/or food supply of listed species. Due to labeling
requirements, potential users will be informed prior to making a purchase that
there may be local limitations on product use due to endangered species
concerns. Information on the Endangered Species Protection Program is
available at the following Internet site:
http://www.epa.gov/oppfeadl/endanger/index.htm.
Energy Star® Buildings and Green Lights® Partnership
In 1991, EPA introduced Green Lights®, a program designed for businesses
and organizations to proactively combat pollution by installing energy-
efficient lighting technologies in their commercial and industrial buildings. In
April 1995, Green Lights® expanded into Energy Star® Buildings— a
strategy that optimizes whole-building energy-efficiency opportunities. The
energy needed to run commercial and industrial buildings in the United States
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produces 19 percent of U.S. carbon dioxide emissions, 12 percent of nitrogen
oxides, and 25 percent of sulfur dioxide, at a cost of $ 110 billion a year. If
implemented in every U.S. commercial and industrial building, the Energy
Star® Buildings upgrade approach could prevent up to 35 percent of the
emissions associated with these buildings and cut the nation's energy bill by
up to $25 billion annually.
The more than 2,900 participants include corporations, small businesses,
universities, health care facilities, nonprofit organizations, school districts, and
federal and local governments. As of March 31, 1999, Energy Star®Buildings
and Green Lights® Program participants are saving $775 million in energy
• bills with an annual savings of 31.75 kilowatt per square foot and annual cost
savings of $0.47 per square foot. By joining, participants agree to upgrade 90
percent of their owned facilities with energy-efficient lighting and 50 percent
of their owned facilities with whole-building upgrades, where profitable, over
a seven-year period. Energy Star® participants first reduce their energy loads
with the Green Lights® approach to building tune-ups, then focus on "right
sizing" their heating and cooling equipment to match their new energy needs.
EPA's Office of Air and Radiation is responsible for operating the Energy
Star® Buildings and Green Lights® Program. (Contact: Energy Star Hotline,
1-888-STAJR-YES (1-888-782-7937) or Maria Tikoff Vargas, Co-Director at
(202) 564-9178 or visit the website at http://www.epa.gov/buildings.)
WasteWi$e Program
The WasteWi$e Program was started in 1994 by EPA's Office of Solid Waste
and Emergency Response. The program is aimed at reducing municipal solid
wastes by promoting waste prevention, recycling collection, and the
manufacturing and purchase of recycled products. As of 1998, the program
had about 700 business, government, and institutional partners. Partners agree
to identify and implement actions to reduce their solid wastes by setting waste
reduction goals and providing EPA with yearly progress reports for a three-
year period. EPA, in turn, provides partners with technical assistance,
publications, networking opportunities, and national and regional recognition.
(Contact: WasteWi$e Hotline at (800) 372-9473 or Joanne Oxley, EPA
Program Manager, (703) 308-0199.)
Climate Wise Program
In October 1993, President Clinton unveiled the Climate Change Action Plan
(CCAP) in honor of the United States' commitment to reducing its greenhouse
gas emissions to 1990 levels by the year 2000. Climate Wise, a project jointly
sponsored by the U.S. Department of Energy and EPA, is one of the projects
initiated under CCAP.
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Climate Wise is a partnership between government and industry that offers
companies a nonregulatory approach to reducing greenhouse gas emissions.
Climate Wise state and local government "allies" work with U.S. industries to
develop flexible, comprehensive strategies for achieving energy efficiency and
pollution prevention. They help local business identify and implement projects
that often require little capital investment, but promise a high rate of return.
Companies that become Climate Wise partners receive technical assistance
and financing information to help them develop and implement cost-effective
changes. (Contact: Climate Wise Clearinghouse at (301) 230-4736 or visit the
Climate Wise website at http://www.epa.gov/climatewise/allies.htm or
http://www.epa.gov/climatewise/index.htm.)
VII.C. USDA Programs and Activities
Environmental Quality Incentives Program
The Environmental Quality Incentives Program (EQIP) is a USDA funded
program (led by Natural Resources Conservation Service) that was established
in the 1996 Farm Bill to provide a voluntary conservation program for fanners
and ranchers who face serious threats to soil, water, and related natural
resources. EQEP embodies four of USDA's former conservation programs,
including the Agricultural Conservation Program, the Water Quality
Incentives Program, the Great Plains Conservation Program, and the Colorado
River Basin Salinity Control Program.
EQIP offers 5 to 10 year contracts that provide incentive payments and cost-
sharing for conservation practices called for in a site-specific conservation
plan that is required for all EQIP activities. Cost-sharing may include up to
75 percent of the costs of certain conservation practices, such as grassed
waterways, filter strips, manure management facilities, capping abandoned
wells, and other practices. Incentive payments may be made to encourage land
management practices such as nutrient management, manure management,
integrated pest management, irrigation water management, and wildlife habitat
management. These payments may be provided for up to three years to
encourage producers to carry out management practices they may not
otherwise use without the program incentive.
EQEP has an authorized budget of $1.3 billion through the year 2002. It was
funded for $174 million in 1999. Total cost-share and incentive payments are
limited to $10,000 per person per year and $50,000 for the length of the
contract. Eligibility is limited to persons who are engaged in livestock or
agricultural production. Fifty percent of the funds must be spent on livestock
production. The 1996 Farm Bill prohibits owners of large confined livestock
operations from being eligible for cost-share assistance for animal waste
storage or treatment facilities. However, technical, educational, and financial
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assistance may be provided for other conservation practices on such
operations. Further information relating to EQIP may be found on NRCS's
website located at
http://www.nhq.nrcs.usda.gov/OPA/FB96OPA/eqipfact.html.
Conservation Reserve Program
The Conservation Reserve Program (CRP) is a highly successful conservation
program administered by USD A. Since 1986, CRP has provided financial
incentives to farmers and ranchers to take land out of agricultural production
and plant trees, grass and other types of vegetation. The result has been
reduced soil erosion, improved air and water quality, and establishment of
millions of acres of wildlife habitat.
With the New Conservation Reserve Program, launched with the final rule
published in the Federal Register on February 19, 1997, the Farm Service
Agency (FSA) begins a renewed effort to achieve the full potential of
government-farmer conservation partnerships. Only the most
environmentally-sensitive land, yielding the greatest environmental benefits,
will be accepted into the program.
The 36.4-million-acre congressionally mandated cap on enrollments is carried
over from the previous program, meaning that the new CRP has authority to
enroll only about 15 percent of the eligible cropland. To make the most of the
program's potential, a new Environmental Benefits Index (EBI) was
developed. The new EBI will be used to select areas and acreages offering the
greatest environmental benefits.
Conservation priority areas (CP As) are regions targeted for CRP enrollment.
The four national CPAs are the Long Island Sound region, the Chesapeake
Bay and surrounding areas, an area adjacent to the Great Lakes, and the Prairie
Pothole region. FSA State Committees may also designate up to 10 percent of
a State's remaining cropland as a State Conservation Priority Area. The
NRCS is responsible for determining the relative environmental benefits of
each acre offered for participation.
Continuous Sign-Up. For certain high-priority conservation practices yielding
highly desirable environmental benefits, producers may sign up at any time,
without waiting for an announced sign-up period. Continuous sign-up allows
farmers and ranchers management flexibility in implementing certain
conservation practices on their cropland. These practices are specially
designed to achieve significant environmental benefits, giving participants a
chance to help protect and enhance wildlife habitat, improve air quality, and
improve the condition of America's waterways. Unlike the general CRP
program, sign-up for these special practices is open continuously. Provided
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certain eligibility requirements are met, acreage is automatically accepted into
the program at a per-acre rental rate not to exceed the Commodity Credit
Corporation's maximum payment amount, based on site-specific soil
productivity and local prevailing cash-equivalent rental rates. For more
information on the CRP, see USDA's website at
http://www.fsa.usda.gov/dafp/cepd/crpinfo.htm.
Conservation Reserve Enhancement Program
The Conservation Reserve Enhancement Program (CREP), a refinement of the
CRP, is a state-federal conservation partnership program targeted to address
specific state and nationally significant water quality, soil erosion and wildlife
habitat issues related to agricultural use. The program uses financial incentives
to encourage farmers and ranchers to voluntarily enroll in contracts of 10 to 15
years in duration to remove lands from agricultural production. This
community-based conservation program provides a flexible design of
conservation practices and financial incentives to address environmental
issues. For more information about CREP, refer to USDA's website at
http://www.fsa.usda.gov/dafb/cepd/crep/crephome.htm.
Wetlands Reserve Program
Congress authorized the Wetlands Reserve Program (WRP) under the Food
Security Act of 1985, as amended by the 1990 and 1996 Farm Bills. USDA's
Natural Resources Conservation Service (NRCS) administers the program in
consultation with the Farm Service Agency and other Federal agencies. WRP
is a voluntary program to restore wetlands. Landowners who choose to
participate in WRP may sell a conservation easement or enter into a cost-share
restoration agreement with USD A to restore and protect wetlands. The
landowner voluntarily limits future use of the land, yet retains private
ownership.
WRP offers landowners three options: permanent easements, 30-year
easements, and restoration cost-share agreements of a minimum 10-year
duration. In exchange for establishing a permanent easement, the landowner
receives payment up to the agricultural value of the land and 100 percent of
the restoration costs for restoring the wetland. In exchange for the 30-year
easement, the landowner receives a payment of 75 percent of what would be
provided for a permanent easement on "the same site and 75 percent of the
restoration cost. The restoration cost-share agreement is an agreement
(generally for a minimum of 10 years) to re-establish degraded or lost wetland
habitat, in which USD A pays the landowner 75 percent of the cost of the
restoration activity. Restoration cost-share agreements establish wetland
protection and restoration as the primary land use for the duration of the
agreement. In all instances, landowners continue to control access to their
land. For more information about WRP, see NRCS's website at:
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http://wl.fb-net.org/.
Conservation Farm Option
The Conservation Farm Option (CFO) is a voluntary pilot program for
producers of wheat, feed grains, cotton, and rice. The program purposes
include conservation of soil, water, and related resources, water quality
protection and improvement, wetland restoration, protection and creation,
wildlife habitat development and protection, or other similar conservation
activities. Eligibility is limited to owners and producers who have contract
acreage enrolled in the Agricultural Market Transition program. Participants
are required to develop and implement a conservation farm plan. The plan
becomes part of the CFO contract which covers a ten year period. CFO is not
restricted as to what measures may be included in the conservation plan, so
long as they provide environmental benefits. During the contract period the
owner or producer (1) receives annual payments for implementing the CFO
contract, and (2) agrees to forgo payments under the Conservation Reserve
Program, the Wetlands Reserve Program, and the Environmental Quality
Incentives Program in exchange for one consolidated program.
Wildlife Habitat Incentives Program
The Wildlife Habitat Incentives Program (WHIP) is a voluntary program
(administered by NRCS) for people who want to develop and improve wildlife
habitat primarily on private lands. It provides both technical assistance and
cost-share payments to help establish and improve fish and wildlife habitat.
Under this program, NRCS helps participants prepare a wildlife habitat
development plan in consultation with the local conservation district. The
plan describes the landowner's goals for improving wildlife habitat, includes a
list of practices and a schedule for installing them, and details the steps
necessary to maintain the habitat for the life of the agreement. This plan may
or may not be part of a larger conservation plan that addresses other resource
needs such as water quality and soil erosion.
USDA and the participant enter into a cost-share agreement that generally
lasts between 5 to 10 years from the date the agreement is signed. Under the
agreement: the landowner agrees to install and maintain WHIP, practices and
allow NRCS or its agent access to monitor the effectiveness of the practices;
and USDA agrees to provide technical assistance and pay up to 75 percent of
the cost of installing the wildlife habitat practices.
WHIP is currently budgeted for $50 million total through the year 2002.
WHIP funds are distributed to States based on State wildlife habitat priorities,
which may include wildlife habitat areas, targeted species and their habitats
and specific practices. WHIP may be implemented in cooperation with other
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Federal, State, or local agencies; conservation districts; or private conservation
groups. For more information, see NRCS's website at
http://www.nrcs.usda.gov.
Conservation of Private Grazing Land Initiative
The Conservation of Private Grazing Land initiative will ensure that technical,
educational, and related assistance is provided to those who own private
grazing lands. It is not a cost share program. This technical assistance will
offer opportunities for better grazing and land management; protecting soil
from erosive wind and water; using more energy-efficient ways to produce
food and fiber; conserving water; providing habitat for wildlife; sustaining
forage and grazing plants; using plants to sequester greenhouse gases and
increase soil organic matter; and using grazing lands as a source of biomass
energy and raw materials for industrial products.
The Wetland Conservation Provision (Swampbuster)
This provision, part of the 1985, 1990, and 1996 farm bills, requires all
agriculture producers to protect wetlands on the farms they own or operate if
they want to be eligible for USDA farm program benefits. The Swampbuster
program generally allows the continuation of most ongoing farming practices
as long as wetlands are not converted or wetland drainage increased. The
program discourages farmers from altering wetlands by withholding Federal
farm program benefits from any person who does the following:
— Plants an agricultural commodity on a converted wetland that was
converted by drainage, dredging, leveling or any other means after
December 23, 1985.
— Converts a wetland for the purpose of or to make agricultural
commodity production after November 28, 1990.
In order to ensure farm program benefits under the Swampbuster provisions,
the local NRCS office should be contacted before clearing, draining, or
manipulating any wet areas on any farmland.
VII.D. Other Voluntary Initiatives
NICE3
The U.S. Department of Energy sponsors a grant program called National
Industrial Competitiveness through Energy, Environment, and Economics
(NICE3). The NICE3 program provides funding to state and industry
partnerships (large and small businesses) for projects demonstrating advances
in energy efficiency and clean production technologies. The goal of the NICE3
program is to demonstrate the performance and economics of innovative
technologies in the U.S., leading to the commercialization of improved
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Compliance Assurance Activities and
Initiatives
industrial manufacturing processes. These processes should conserve energy,
reduce waste, and improve industrial cost-competitiveness. Industry applicants
must submit project proposals through a state energy, pollution prevention, or
business development office. Awardees receive a one-time, three-year grant of
up to $400,000, representing up to 50 percent of a project's total cost. In
addition, up to $25,000 is available to support the state applicant's cost share.
(Contact: View the website at http//www.oit.doe.gov/Access/nice3; Steve
Blazek, DOE, (303) 275-4723; or Eric Hass, DOE, (303) 275-4728.)
ISO 14000
ISO 14000 is a series of internationally-accepted standards for environmental
management. The series includes standards for environmental management
systems (EMS), guidelines on conducting EMS audits, standards for auditor
qualifications, and standards and guidance for conducting product lifecycle
analysis. Standards for auditing and EMS were adopted in September 1996,
while other elements of the ISO 14000 series are currently in draft form.
While regulations and levels of environmental control vary from country to
country, ISO 14000 attempts to provide a common standard for environmental
management. The governing body for ISO 14000 is the International
Organization for Standardization (ISO), a worldwide federation of over 110
country members based in Geneva, Switzerland. The American National
Standards Institute (ANSI) is the United States representative to ISO.
Information on ISO is available at the following Internet site:
http://www.iso.ch/welcome.html.
American Forest and Paper Association Sustainable Forest Initiative
(SFI)
The Sustainable Forestry Initiative (SFI) program is a comprehensive system
of principles, objectives and performance measures that integrates the
perpetual growing and harvesting of trees with the protection of wildlife,
plants, soil and water quality. AFPA members are committed to following the
substance and spirit of best management practices (BMPs) on their own land
and in operations they are involved in with other landowners and loggers.
VILE. Summary of Trade Associations
There are more than 200 trade associations that deal with agricultural issues.
Many of these are at the national level, while others deal specifically with
regions of the country or individual states. The following identify some of the
major associations addressing agricultural production.
Sector Notebook Project
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Agricultural Crop Production Industry
Compliance Assurance Activities and
Initiatives
Agricultural Retailers Association
(ARA)
11701 Borman Drive, Suite 110
St. Louis, MO 63146
314-567-6655
American Farm Bureau Federation
Headquarters Office
225 Touhy'Ave.
Park Ridge, IL 60068
847-685-8600
American Farm Bureau Federation
Washington DC Office
Suite 800
600 Maryland Ave. S.W.
Washington, DC 20024
202-484-3600
American Feed Industry Association
1501 Wilson Blvd., Suite 1100
Arlington, VA 22209
703-524-0810
American Oat Association
415 Shelard Parkway, Suite 101
Minneapolis, MN 55426
612-542-9817
American Society of Agronomy
677 S. Segoe Rd.
Madison, WI53711
608-273-8080 ext.3030
American Sugarbeet Growers
Association
156 15th Street, NW, Suite 1101
Washington, DC 20005
202-833-2398
American Crop Protection
Association
1156 15th Street, NW, Suite 400
Washington, DC 20005
202-296-1595
American Forest & Paper
Association (AF&PA)'
1111 19th St., NW, Suite 800
Washington, DC 20036
202-463-2700
E-mail: INFO@afandpa.org
American Nursery & Landscape
Association
1250 I Street, NW
Suite 500
Washington, DC 20005
202-789-2933
American Pulpwood Association,
Inc.
.,600 Jefferson Plaza, Suite 350
Rockville, Maryland 20852
301-838-9385
American Soybean Association
540 Maryville Centre Drive
P.O. Box 419200
St. Louis, MO 63141
314-576-1770
Association of American Pesticide
Control Officials
P.O. Box 1249
Hardwick, VT 05843
802-472-6956
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Agricultural Crop Production Industry
Compliance Assurance Activities and
Initiatives
Association of American Plant Food
Control Officials (AAPFCO)
Food & Drug Protection Division
North Carolina Department of
Agriculture'
4000 Reedy Creek Rd.
Raleigh, NC 27607
919-733-7366
Clean Water Network
1200 New York Ave, NW
Washington, DC 20005
202-287-2395
Eastern Dark-fired Tobacco Growers
Association
1109 S. Main Street
PO Box 517
Springfield, TN 37172
615-384-4543
Farmworker Justice Fund
1111 19th Street, NW Suite 1000
Washington, DC 20036
202-776-1757
Garden Centers of America
1250 I Street, NW, Suite 500
Washington, DC 20005
202-789-2900
National Association of State
Departments of Agriculture
(NASDA)
1156 15th St., NW, Suite 1020
Washington, DC 20005
202-296-9680
National Coalition Against the
Misuse of Pesticides
701 E Street, SE, Suite 200
Washington, DC 20003
202-543-5450
Burley Tobacco Growers
Cooperative Association
PO Box 860
Lexington, KY 40587
606-252-3561
California Fertilizers Association
1700 I St., Suite 130
Sacramento, CA 95814
916-441-1584
Conservation Technology
Information Center (CTIC)
1220 Potter Drive, Room 170
West Lafayette, IN 47906-1383
765-494-9555
Environmental Working Group
1101 Wilson Blvd.
Arlington, VA 22209
703-243-3002
Forest Landowners Association
P.O. Box 95385
Atlanta, Georgia 30347
800-325-2954
Institute for Agriculture and Trade
Policy
2105 1st Avenue South
Minneapolis, MN 55404
612-870-0453
National Association of Wheat
Growers
415 2nd Street, ME, Suite 300
Washington, DC 20002
202-547-7800
National Corn Growers Association
1000 Executive Parkway, Suite 105
St. Louis, MO 63141
314-275-9915
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Agricultural Crop Production Industry
Compliance Assurance Activities and
Initiatives
National Cotton Council
1521 New Hampshire Avenue, NW
Washington, DC 20036
202-745-7805
National Council of Farmer Coops
(NCFC)
50 F Street, NW, Suite 900
Washington, DC 20001
National Hay Association
102 Treasure Island Causeway
Suite 201
St. Petersburg, FL 33706
813-367-9702
National Sunflower Association
4023 State Street
Bismark, ND 58501
701-328-5100
Society of American Foresters
5400 Grosvenor Lane
Bethesda, MD20814
301-897-8720
E-mail: safweb@samet.org
United Farm Workers of America
1188 Franklin Street, Suite 203
San Francisco, CA 94109
415-674-1884
USDA's Forest Service
Auditors Building
201 14th Street, S.W.
Washington, DC 20024
202-205-1661
National Council of Agricultural
Employers
1112 6th Street, NW, Suite 920
Washington, DC 20036
202-728-0300
National Grain and Feed Association
1201 New York Avenue, NW
Suite 830
Washington, DC 20005
202-289-0873
National Pest Control Association
8100 Oak Street (NPCA)
Dunn Loring, VA 22027
703-573-8330
Potato Association of America
University of Idaho
1776 Science Center Drive
Idaho Falls, ID .83402
208-529-8376
The Fertilizer Institute (TFI)
501 Second Street, NE
Washington, DC 20002
USA Rice Council
P.O. Box 740123
Houston, TX 77274
713-270-6699
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Agricultural Crop Production Industry
Contacts/Resource Materials/Bibliography
VIII. CONTACTS/RESOURCE MATERIALS/BIBLIOGRAPHY
For further information on selected topics within the agricultural crop production industries, a
list of contacts and publications are provided below.
Contacts2
Name
Ginah Mortensen
Arty Williams
Jean Frane
David Stangel
Joseph Hogue
Robert McNally
Joseph Nevola
Ellen Kramer
Robert A. Forrest
Nancy Fitz
John MacDonald
Organization
EPA, Office of Enforcement and
Compliance Assurance (OECA),
Agriculture Division, Agriculture
Branch
EPA, Office of Prevention, Pesticides
and Toxic Substances (OPPT)
EPA, OPPT
EPA, OECA
EPA, OPPT
EPA, OPPT
EPA, OPPT
EPA, OPPT
EPA, OPPT
EPA, OPPT
EPA, OPPT
Telephone
913-551-5211
703-305-5239
703-305-5944
202-564-4162
703-308-9072
703-308-8085
703-308-8037
703-305-6475
703-308-9376
703-305-7385
703-305-7370
Subject
Notebook Contact
Ground Water
Pesticide Management
Plan Rule
Food Quality
Protection Act
Stored or Suspended
Pesticides; Good
Laboratory Practice
Standards; Pesticide
Management and
Disposal
FIFRA
Restricted Use "
Classifications
FIFRA Pesticide
Tolerances
FIFRA Pesticide
Tolerances
FIFRA Pesticide
Tolerances
FIFRA Exemptions
FIFRA Pesticide
Management and
Disposal
Certification and
Training
2 Many of the contacts listed above have provided valuable information and comments during the development
of this document. EPA appreciates this support and acknowledges that the individuals listed do not necessarily
endorse all statements made within this notebook.
Sector Notebook Project
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Agricultural Crop Production Industry
Contacts/Resource Materials/Bibliography
Kevin Keaney
Al Havinga
Carol Galloway
Sharon Buck
Greg Beatty
Roberta Parry
Robin Dunkins
Kurt Roos
Howard Beard
Tracy Back
EPA, OPPT
EPA, OECA
EPA, OECA
EPA, OWOW
EPA, OWM
EPA, OPEI
EPA, OAQPS
EPA, OAR
EPA, OGWDW
EPA, CCSMD
703-305-5557
202-564-4147
913-551-5008
202-260-0306
202-260-6929
202-260-2876
919-541-5335
202-564-9041
202-260-8796
202-564-7076
FIFRA Worker
Protection Standards .
Livestock Issues
Livestock Issues
Nonpoint Source Issues
NPDES Permniting
Issues
Livestock and Crop
Issues
Air Issues
Atmospheric Programs
Drinking water Issues
Compliance Assistance
Centers
General Profile
1997 National Resources Inventory - Summary Report, National Resources Conservation
Service, United States Department of Agriculture. December 1999.
Occupational Outlook Handbook Home Page, Bureau of Labor Statistics Home Page.
December 1996.
SIC Code Profile 01 and 07, U.S. Environmental Protection Agency, Office of Pollution
Prevention and Toxics, Draft, September 30, 1994.
Newsletter: Small and Part Time Farms, U.S. Department of Agriculture, Fall 1996.
Enforcement Accomplishments Report, FY 1992, U.S. EPA, Office of Enforcement
(EPA/230-R93-001), April 1993.
^
Enforcement Accomplishments Report, FY 1993, U.S. EPA, Office of Enforcement
(EPA/300-R94-003), April 1994.
Enforcement and Compliance Assurance Accomplishments Report, FY 1994, U.S. EPA,
Office of Enforcement and Compliance Assurance (EPA/300-R94-003), April 1995.
Sector Notebook Project
170
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Agricultural Crop Production Industry
Contacts/Resource Materials/Bibliography
Enforcement and Compliance Assurance Accomplishments Report, FY 1995, U.S. EPA,
Office of Enforcement and Compliance Assurance (EPA/300-R94-003), April 1996.
Enforcement and Compliance Assurance Accomplishments Report, FY 1996, U.S. EPA,
Office of Enforcement and Compliance Assurance (EPA/300-R-97-003), 1997.
Enforcement and Compliance Assurance Accomplishments Report, FY 1997, U.S. EPA,
Office of Enforcement and Compliance Assurance (EPA/300-R-98-003), July 1998!
Occupational Outlook Handbook Home Page, Bureau of Labor Statistics Home Page.
December 1996.
North American Industrial Classification System, Office of Management and Budget.
Standard Industrial Classification Manual, Office of Management and Budget, 1987.
U.S. Agriculture Census, 1992 and 1997.
Operations and Pollution Prevention .
Best Management Practices for Field Production of Nursery Stock, North Carolina State
University Biological and Agricultural Engineering Extension Service
(http://www.bae.ncsu.edu/programs/extension/ag-env/nursery/).
Biocontrol of Plant Diseases Laboratory, Agricultural Research Service, 1997 Internet
search.
1998 Crop Residual Management Survey Executive Summary, Top 10 Conservation Tillage
Benefits, Conservation Tillage Information Center.
Effect ofpH on Pesticide Stability and Efficacy, Winand K. Hock, Perm State University
(http://pmep.cce.cornell.edu/facts-slides-self/facts/gen-peapp-ph.html).
Environmental Guidelines for Greenhouse Growers - Site Planning, British Columbia
Ministry (http://www.agf.gov.bc.ca/resmgmt/fppa/pubs/environ/greenhse/grnhse.htm).
Guidance Specifying Management Measures for Sources of Nonpoint Pollution in Coastal
Waters, U.S. Environmental Protection Agency (http://www.epa.gov/OWOW/NPS/MMGI/)
January 1993.
Nonpoint Source Pollution: The Nation's Largest Water Quality Problem Pointer No. 1, US
EPA 1996.
NRCS Conservation Practice Standards, http://www.ncg.usda.gov/practicejstds.h1ml.
Sector Notebook Project
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Agricultural Crop Production Industry
Contacts/Resource Materials/Bibliography
Principles of Irrigation Management: Water Management Guidelines for Nursery/Floral
Producers, 1997, http://aggie-horticulture.tamu.edu/greenhouse/environ/wmprinc.html).
Texas Greenhouse Management Handbook, Dr. Don Wilkerson, Texas Agricultural
Extension Service (http://aggie-horticulture.tamu.edu/greenhouse/guides/green/green.html)
(no date).
Treating and Recycling Irrigation Runoff: Water Management Guidelines for Nursery/Floral
Producers, 1997, http://aggie-horticulture.tamu.edu/greenhouse/envirori/wmrecyc.html).
Water Quality and Waste Management, North Carolina Cooperative Extension,
http://www2.ncsu.edu/bae/programs/extension/publicat/wqwm/index.html.
Miller, W.P., "Environmental Considerations in Land Application of By-Product Gypsum,"
Agricultural Utilization of Urban and Industrial By-Products, American Society of
Agronomy, Madison, WI, 1995.
Regulatory Profile '
Ag Environmental Programs, http://es.epa.gov/oeca/ag/aglaws/.
Enforceable State Mechanisms for the Control ofNonpoint Source Water Pollution,
Environmental Law Institute, 1997.
1996 Farm Bill Conservation Provisions,
http://www.nhq.nrcs.usda.gov/OPA/FB96OPA/FBillLnk.html.
1996 Farm Bill Summary, http://www.usda.gov/farmbill/titleO.htm.
Major Existing EPA Laws and Programs That Could Affect Producers of Agricultural
Commodities, U.S. Environmental Protection Agency, Agriculture and Ecosystems Division
Augusts, 1996.
Overview of the Storm Water Program, Office of Water, U.S. Environmental Protection
Agency, June 1996. EPA 833-R-96-008.
U.S. EPA Permit Writers' Manual, U.S. Environmental Protection Agency, Office of Water
(EPA-833-B-96-003) December 1996.
Haugnid, K. Jack. "Agriculture," Chapter 8 in Sustainable Environmental Law, Integrating
Natural Resource and Pollution Abatement Law from Resources to Recovery, Environmental
Law Institute, St. Paul, 1993.
Landfair, Stanley W. "Toxic Substances Control Act," Chapter 11 in Environmental Law
Handbook, 12th ed., Government Institutes, Inc., Rockville, MD, 1993.
Sector Notebook Project
172
September 2000
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Agricultural Crop Production Industry
Contacts/Resource Materials/Bibliography
Miller, Marshall E. "Federal Regulation of Pesticides," Chapter 13 in Environmental Law
Handbook, 12th ed., Government Institutes, Inc., Rockville, MD, 1993.
Other Resources ^___
AgNIC, http://WAVw.agnic.org/.
Farm*A*Syst, http://www.wisc.edu/farmasyst/index.html.
The Quality of Our Nation's Water, http://www.epa.gov/305b.
Manure Master Decision Support Tool, http://www.ftw.nrcs.usda.gov/ManureMaster/.
State Partners of the Cooperative State Research, Education, and Extension Service,
http://www.reeusda.gov/statepartners/usa.htm.
Sector Notebook Project
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September, 2000
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'raffle of the Aerospace Industry, 130 paqes
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'rofile of Local Government Operations, 310 pages
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'rofile of the Agricultural Chemical, Pesticide and Fertilizer Industry 200p
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