JSH Farms, Inc., the Respondent, grows mint on an 80 acre field called Rowe 80 on the Yakama Reservation. Private applicators working for the Respondent have applied pesticides through its irrigation system. Respondent applied Chlorpyrifos 4# AG (EPA Reg. No. 51036-291) through its irrigation system on September 20-22, 2004. On September 20, the neighbor complained that pesticide delivered through the irrigation system drifted onto her pastureland and her. An EPA Credentialed FIFRA inspector visited the site on September 21, photographed the irrigation system spraying onto the neighbors field, and took a composite vegetation sample. Lab results showed the sampled contained 6.5 ppm chlorpyrifos. Inspector returned September 22, to photograph and document an improper chemigation set-up. EPA received the inspection report. EPA is issuing a Civil Complaint for two counts of using a restricted use pesticide in a manner inconsistent with its labeling (FIFRA 12(a)(2)(G)) for drift and improper chemigation set-up. EPA is proposing a civil penalty of $1680.