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PCS Nitrogen, L.P.


526 Jean Lafitte Ave.
Baton Rouge, LA 70810
504-751-5701October 22, 1996

Regulatory Reinvention Pilot Program
FRL - 5179-9. Water Docket Mail Code
4101, U.S. EPA, 401 M. Street, S. W.
Washington, D.C. 20460

Atten: Lisa Lund

Ref: X-L Project

Dear Ms. Lund:

We are the creators and initiators of the process that uses phosphogypsum as an ingredient to create a safe and valuable soil enhancer. We are working jointly with Arcadian. Your staff at the Project X-L Program has in it's hands the proposal from Arcadian Fertilizer L.P. that will significantly lower pollution by recycling two waste products that are currently responsible for considerable runoff pollution. Arcadian has submitted for approval to reuse two waste products - phosphogypsum (a by-product of the chemical fertilizer industry) and agricultural waste - and process them by our innovative method of composting, to produce a superior soil enhancer.

This soil enhancer will be a blessing to the over-worked, humus-poor, over-fertilized soils of the United States and the world. Tests have proven the new soil enhancer to be effective in promoting healthier crops by improving the drainagability and aeratability of the soil, by increasing the organic composition of the soils, and by aiding the root systems of the crops to more easily absorb the available nutrients in the soil. In addition, studies have shown that the use of such a soil enhancer has an added benefit: considerably less chemical based fertilizers are needed for the same results.

We can no longer ignore the serious problems that are caused by agricultural chemical run-off. One need only look at the serious problems already evident in the Everglades and emerging problems of the Atchafalaya Basin to understand the positive and significant impact this product can have on the Southern farming region alone.

Unfortunately, the ambiguity of the regulations have this project stalled, even though this project has been viewed very positively by the Louisiana Department of Agriculture, the Louisiana Department of Environmental Quality, and the EPA Region Six, Dallas office, who recommended the project to the X-L Program for expedited approval.

The current regulations for the use and handling of phosophogypsum, which is slightly radio active, call for it's use only if the radio activity - that is measured in picouries per gram (pCi/g) - be under a level of 10 pCi/g. Use of phosphogypsum with a radium 226 level less that 10 pCi/g is safe for agricultural use, as per the EPA, under present regulations. The present regulations do not address the use of phosphogypsum that has been reduced by to under 10 pCi/g by scientific process.

Under current regulation if the phosphogypsum is above 10 pCi/g it can not be moved for any reason, other than testing. Arcadian's proposed process takes this slightly higher phosphogypsum (10-15 pCi/g) and processes it to form a valuable final product that is below 10 pCi/g. All Arcadian asks for is the permission to use the phosphogypsum as an ingredient to make the safe product. Once soil enhancer is produced, it is safe and acceptable for agricultural use under current regulations, under which all safety factors have been taken into consideration.

We want to offer the farmers of America a cost-effective, safe and beneficial product. We want to decrease harmful run-offs from stock piled waste products, both industrial and agricultural. We want to provide a product that will help slow the destruction of our waterways and wetlands. Yet we are being hindered by an ambiguous regulation that does not accommodate revolutionary technology for the use of phosphogypsum. We have an innovative process that could not have been foreseen when these regulations were written, and thus these regulations are illogically hindering progress.

Any and all assistance you may be able to provide to help us to overcome this stumbling block so that we can achieve our goals will be greatly appreciated.


Dave Basu, P.E.

cc: Arcadian Fertilizer, L.P.

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