Regulation of Chemigation in California:

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Regulation of Chemigation in California
Challenges and Changes
John Troiano jtroiano_at_cdpr.ca.gov, Mark Pepple
mpepple_at_cdpr.ca.gov Joy Dias jdias_at_cdpr.ca.gov
California Department of Pesticide Regulation,
1001 I Street, Sacramentio, CA 95812
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Potential Contamination of Ground Water
Backsiphoning of chemical into wellhead.
Irrigation system shutdown causes
water-chemical mixture to flow backwards into
water source. Devices are required to
eliminate this potential problem.
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Current DPR Backflow Prevention Regulation
California Code of Regulations (Title 3. Food and
Agriculture)Division 6. Pesticides and Pest
Control Operations
6610 Backflow Prevention
Each service rig and piece of application
equipment that handles pesticides and draws water
from an outside source shall be equipped with an
air-gap separation, reduced pressure principle
backflow prevention device or double check valve
assembly. Backflow protection must be acceptable
to both the water purveyor and the local health
department.
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PR 87-1 Example of Required Components
(C)
(D)
(A)
(B)
(E)
(H)
(G)
(F)
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Inception of DPRs Chemigation Initiative
1999 Cooperative contract with U.S. EPA Region 9
to provide an analysis of backflow prevention
activities in California Were DPRs regulations
in compliance with U.S. EPA label requirements?

• Language in 6610 written in 1977 taken from
  municipal connections not relevant to label
  language protecting rural irrigation/domestic
  wells
• General lack of awareness of label requirements
  amongst regulators and regulated community -
  education needed to explain need for and
  recognition of devices, enabling compliance
  inspections.
• Significant number of active ingredients labeled
  for chemigation
• 109 of 420 (25)
• Many pesticides labeled for chemigation were not
  restricted use materials. Posed a problem with
  identifying sites for inspection.

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Components of DPR Chemigation Initiative

• Comply with EPA Label Improvement Program
• PR Notice 87-1.

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Comply with EPA Label Improvement Program

• Issued policy letters to County Agricultural
  Commissioners (CAC)
• clarifying that they were to enforce the label
  instructions,
• thereby superceding DPR's backflow
  regulations.
• Handlers must comply with all chemigation
  requirements
• specified on label.
• Defined outside source an outside water source
  includes
• all sources of water, except water that
  stored in a reservoir
• tank, that is owned or under the control of
  the pesticide
• applicator and/or property owner. (Domestic
  well included)
• But also issued second letter to clarify that
  there were
• acceptable alternative devices to those
  listed on the label.

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Components of DPR Chemigation Initiative

• Comply with EPA Label Improvement Program PR
  87-1.
• Education/Training.

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Training/Education

• Contracted with irrigation specialists at Center
  for Irrigation
• Technology (CIT), CSU Fresno to provide
  educational materials
• and training.
• Manuals in English and Spanish.
• o       English
  http//www.cdpr.ca.gov/docs/gwp/chem/grower_manual
  .pdf
• o       Spanish http//www.cdpr.ca.go
  v/docs/gwp/chem/120804_chemgtn_tr_man_span.pdf 
• Pamphlets in English and Spanish.
• o       English http//www.cdpr.ca.
  gov/docs/gwp/chem/chempamp_engrev2.pdf
• o       Spanish http//www.cdpr.ca.g
  ov/docs/gwp/chem/2chempamp_span0505_final.pdf
• Trailer equipped for hands-on training.

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Mobile Backflow Display
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Training/Education

• Contracted with irrigation specialists at Center
  for Irrigation
• Technology (CIT), CSU Fresno to provide
  educational materials
• and training.
• Contracted with irrigation specialists at UC,
  Davis to provide
• illustrations of systems.
• DPR Website http//www.cdpr.ca.
  gov/docs/gwp/chem/diagrams/chem_diagrams.pdf

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Training/Education

• Contracted with irrigation specialists at Center
  for Irrigation
• Technology (CIT), CSU Fresno to provide
  educational materials
• and training.
• Contracted with irrigation specialists at UC,
  Davis to provide
• illustrations of systems.
• DPR Website http//www.cdpr.ca.
  gov/docs/gwp/chem/diagrams/chem_diagrams.pdf
• Contracted with irrigation specialists at Cal
  Poly SU, San Luis
• Obispo to develop webpage and advertise their
  course in
• trade journals.
• Cal Poly website http//www.itrc.org/reports/
  chemigation/chemigationandfertigationforca.htm

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Training/Education

• Training Objectives
• CAC staff
• Clarify policy letters on PR 87-1.
• Recognition of devices.
• Awareness of alternative devices and though not
  listed on
• label are appropriate.

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Training/Education

• Training Objectives
• CAC staff
• Regulated Community.
• Well on property drawing ground water must be
  equipped
• with backflow prevention devices according to
  label
• requirements.
• Devices required and their alternatives e.g.
  more than just
• that listed on the label.
• Heads-up DPR enforcement of policy letters and
  potential
• new regulations.

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Training/Education

• Training Objectives
• CAC staff
• Regulated Community.
• Irrigation system specialists.
• Need for devices to protect ground water.
• Sources of information on devices and specs.

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Components of DPR Chemigation Initiative

• Comply with EPA Label Improvement Program PR
  87-1.
• Education/Training.
• Initiate Chemigation Inspections.

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Initiate Chemigation Inspections

• Contracted with irrigation specialists at CIT to
  provide
• consultation.
• Restricted materials available as technical
  consultant
• during CAC staff inspections of devices used
  for chemigation
• of soil fumigants.
• Respond through e-mail to questions from staff.
• Available for request of visits to wellheads.

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Initiate Chemigation Inspections

• Contracted with irrigation specialists at CIT to
  provide
• consultation.
• Provided funding for focused to CAC for
  interested counties to
• Develop method to identify growers using
  chemigation.
• Conduct site inspections on a percentage of
  growers they
• identified as using chemigation as a method of
  application.

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Components of DPR Chemigation Initiative

• Comply with EPA Label Improvement Program PR
  87-1.
• Education/Training.
• Initiate Chemigation Inspections.
• Create Chemigation Task Force.

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Create Chemigation Task Force

• CIT contracted to head a chemigation task force
  comprised
• of diverse personal - agricultural
  engineers, irrigation
• specialists, participating growers,
  irrigation manufacturers,
• registrants, EPA Region 9 staff, and DPR
  field staff
• Provide an integrated approach for further
  regulatory
• actions by acting as a forum for input from
  the group.

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Task Force Issues/Actions

• Review educational manuals.

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Task Force Issues/Actions

• Review educational manuals.
• Advise and review proposed revisions to DPRs
  regulation.

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Task Force Issues/Actions

• Review educational manuals.
• Advise and review proposed revisions to DPRs
  regulation.
• Provide expertise in questions on system
  design.
• Equivalency in design of sand filters to
  gooseneck.
• Use of hydraulic cut-off in remotely located
  injections.
• Equivalency of hydraulic positive displacement
  pumps.

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Task Force Issues/Actions

• Review educational manuals.
• Advise and review proposed revisions to DPRs
  regulation.
• Provide expertise in questions on system
  design.
• Is certification necessary, how to do it?

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Task Force Issues/Actions

• Review educational manuals.
• Advise and review proposed revisions to DPRs
  regulation.
• Provide expertise in questions on system
  design.
• Is certification necessary?
• Should components be tested, how to do it?

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Task Force Issues/Actions

• Review educational manuals.
• Advise and review proposed revisions to DPRs
  regulation.
• Provide expertise in questions on system
  design.
• Is certification necessary?
• Should components be tested, how to do it?
• Groups to train irrigation system designers.

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Task Force Issues/Actions

• Review educational manuals.
• Advise and review proposed revisions to DPRs
  regulation.
• Provide expertise in questions on system
  design..
• Is certification necessary?
• Should components be tested, how to do it?
• Groups to expand training to irrigation
  system designers.
• Develop guidance on application methodology
• (emerging issues).

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Components of DPR Chemigation Initiative

• Comply with EPA Label Improvement Program PR
  87-1.
• Education/Training.
• Initiate Chemigation Inspections.
• Create Chemigation Task Force.
• Update regulations to clarify requirements.

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Clarify Requirements in Californias Regulations

• Issue California irrigation systems are diverse
  with a constant
• stream of new improvements/ideas/designs.
• Problem How can a regulation be written that
  will be flexible
• and allow for implementation of new
  devices.

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Clarify Requirements in Californias Regulations

• Proposed Approach
• Indicate in regulation the engineering
  principle to be controlled and then refer to a
  website/manual that contains acceptable devices.
  The manual can be updated according to the
  Directors policy.
• Example Language
• Backflow prevention equipment on irrigation
  systems that
• draw water from an outside source shall
  functionally
• accomplish the following objectives
• (A) Keep irrigation water containing
  pesticides from
• contaminating the outside water source.
  
• (B) Keep irrigation water from entering the
  chemical supply tank
• and causing the tank to overflow.
• (etc)

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Clarify Requirements in Californias Regulations
Publication/Internet Site
Chemigation Safety Devices That Meet the
Requirements of 3CCR Section 6610 For Direct
Chemical Injection into a Pressurized Water
System with No Air Gap with an Outside Water
Source
I. To Keep Irrigation Water Containing
Pesticides From Contaminating The Water Source.
Install one of the following three devices
Original Device A main water line check valve
and main water line low pressure .. or
Alternative Device Standard gooseneck pipe
loop. or Alternative Device Irrigation
system media filter gooseneck . and install one
of the following two devices Original Device
Vacuum relief valve or Alternative Device
Combination vacuum relief and air release valve
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Emerging Issues

• Complexity of irrigation systems in CA raise
  questions of
• appropriate devices current required
  statements on label
• not reflective of majority of systems.
• Approach in PR 87-1 part A for VI-IX needs to be
  revisited
• to incorporate protective language but
  flexibility.
• Example of micro systems though
  positive displacement
• pump listed on label, a venturi
  injector is easiest and
• most common method used to inject
  pesticides into
• a system.

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Emerging Issues

• Complexity of irrigation systems in CA raise
  questions of
• appropriate devices.
• Greater emphasis/research on appropriate
  application
• methodology.
• Human exposure from chemigating fumigants.

• Incident Monterey County 2005
• Drip application of chloropicrin
• Injection point far from field
• Lines flushed after application
• Water switched to sprinklers
• Early evening, people began calling

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Causes of Exposure

• Off-gassing from puddles caused by leaks in line?
• Line was not really fully flushed due to length
  of feed?
• Blind laterals? Pipes/tubing placed in line
  with no
• emitters.

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Emerging Issues

• Complexity of irrigation systems in CA raise
  questions of
• appropriate devices.
• Greater emphasis on application methodology.
• Human exposure from chemigating fumigants.

• Bird kill from chemigating nematicide
• - Chemigation in early November, overcast, rain
  forecast.
• - Conducted by vineyard management company.
• - Fertigated in morning.
• - Chemigated in afternoon (on a schedule).
• - Cut short, county rules allow for rain to
  incorporate.
• - Left ponds in field that song birds were
  exposed to.

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Emerging Issues

• Complexity of irrigation systems in CA raise
  questions of
• appropriate devices.
• Greater emphasis on application methodology.
• Human exposure from chemigating fumigants.

• Bird kill from chemigating nematicide

• Exact application method to assure efficacy.
• - Conducted co-operative research that
  promoted chemigation of pre-emergence
  herbicides for 24C
• - Issues have arisen as to the best method
  to apply short, fast burst vs longer,
  slower injections

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