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Pa. DEP should reverse order against Nicholas Meat

ROBIN C. BRANDT

Elizabethtown, Pa.

A change in standing policy by the Pennsylvania Department of Environmental Protection (DEP) has resulted in the temporary closure of Nicholas Meat at Loganton, Pa. As a principal author of the Pennsylvania Food Processing Residual Management Manual (FPR Manual, 2001), I urge the DEP to consider the big picture and revoke the compliance order issued against Nicholas Meat.

The DEP’s Feb. 9 compliance order requires Nicholas Meat to cease land application of food processing residuals (FPR) on fields that are snow-covered, after it permitted this practice for more than a decade. Nicholas Meat has safely applied this nutrient-rich and organic FPR to farmland year-round, including when snow is present on fields, using best management practices and in accordance with relevant regulations.

The FPR manual, a guidance document and not a regulation, states that “Field application of FPRs is not permitted on snow-covered ground.” At the time this narrative was drafted for the FPR manual, in the early 90s, we were not aware of any practical land application equipment that could overcome the drawbacks associated with surface application on snow-covered fields (i.e. runoff contamination concerns).

About 10 years ago I was introduced to a new developing land application technology called Shallow-Disk Injection (SDI). Using SDI, liquid manure or FPR can be injected into the soil with very minimal soil disturbance and odors are significantly reduced as the material is absorbed into the soil. From what I have seen, the Bazooka-Farmstar toolbar equipment used by Nicholas Meat LLC is very similar to the SDI device we used in a 2010 land application odor study and satisfies the intent of the FPR manual — environmentally responsible land application. Requiring this food processor to haul 150,000 gallons per day of liquid FPR to wastewater treatment facilities potentially 50 miles or more distant would, in my opinion, do far more environmental harm than allowing this practice to continue on flat snow-covered ground.

It never occurred to me that such equipment could be used to inject manure into the soil under snow until I saw a photo of a field recently treated at a rate of 6,200 gallons per acre of Nicholas FPR using the Bazooka-Farmstar toolbar. This remarkable image shows several acres of open field with no indication of FPR against the stark white snow cover. If this is typical of the Bazooka-Farmstar toolbar performance with the Nicholas FPR, I see no reason to be concerned with FPR contaminated runoff from this area when combined with other best management winter precautions involving modest application rates on flat well-drained fields, isolated from waterways.

It’s time to look at the modern practices used by Nicholas Meat and let them reopen their doors.

Again, I urge the Pennsylvania DEP to reverse its stance on this matter and allow Nicholas Meat to reopen their facility as quickly as possible.

(Robin C. Brandt, Ph.D., P.E., is a principal author of the Pennsylvania Food Processing Residual Management Manual and is an expert witness on the topic for Fox Rothschild LLP, attorneys at law, which Nicholas Meat LLC has under retainer.)

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