United States
Environmental Protection
Agency
Hazardous Waste Engineering
Research Laboratory
Water Engineering Research Laboratory
Cincinnati, OH 45268
EPA/600/9-85/030
September 1985
Research and Development
Proceedings:
National Workshop on
Pesticide Waste Disposal
Do not remove. This document
should be retained in the EPA
Region 5 Library Collection.
-------
EPA/600/9-85/030
September 1985
PROCEEDINGS: NATIONAL WORKSHOP ON PESTICIDE WASTE DISPOSAL
Denver, Colorado, January 28-29, 1985
JACA Corporation
Fort Washinyton, Pennsylvania 19034
Contract No. 68-03-3131
Project Officer
James Bridges
Office of Program Operations
Hazardous Waste Engineering Research Laboratory
Cincinnati, Ohio 45268
U.S. Environmental Protection Agency e
Region 5, Library (PL-12J) rt u _. .
77 West Jackson Boulevard, 12th FlooP
Chicago, IL 60604-3590
HAZARDOUS WASTE ENGINEERING RESEARCH LABORATORY
WATER ENGINEERING RESEARCH LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CINCINNATI, OHIO 45268
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DISCLAIMER
The following papers have been reviewed in accordance with the U.S.
Environmental Protection Agency's peer and administrative review policies
and approved for presentation and publication:
Federal Regulation of Pesticide Disposal
Land Disposal of Pesticide Rinsate
Incineration Options for Disposed of Waste Pesticides
Storage, Handling and Shipment of Pesticide Waste -
Regulatory Requirements
The following papers describe work that has not been funded by the
U.S. Environmental Protection Agency and therefore the contents do not
necessarily reflect the views of the Agency and no official endorsement
should be inferred.
Overview: Pesticide Wastes Disposal
Applicator Disposal Needs
Pesticide Wastes Disposal: An Agricultural Aviator's Perspective
Pesticide Wastes Disposal: A Private Applicator's Perspective
California Regulatory Requirements
Pesticide Degradation Properties
Physical Treatment Options: Removal of Chemicals from
Wastewater by Adsorption, Filtration and/or Coagulation
A Practical System to Treat Pesticide-Laden Wastewater
Pesticide Wastewater Disposal: Biological Methods
Chemical Treatment Options for Pesticide Wastes Disposal
The Logistics of Transporting Pesticide Wastes From the User
to Disposer
Empty Pesticide Container Management: An Overview
Alberta Pesticide Container Collection Program
Maine's Returnable Pesticides Container Program
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FOREWORD
The U.S. Environmental Protection Agency is charged by Congress with
protecting the Nation's land, air, and water systems. Under a mandate of
national enviornmental laws, the agency strives to formulate and imple-
ment actions leading to a compatible balance between human activities and
the ability of natural systems to support and nurture life. The Clean
Water Act, the Safe Drinking Water Act, and the Toxic Substances Control
Act are three of the major congressional laws that provide the framework
for restoring and maintaining the integrity of our Nation's water, for
preserving and enhancing the water we drink, and for protecting the
environment from toxic substances. These laws direct the EPA to perform
research to define our environmental problems, measure the impacts, and
search for solutions.
The Water Engineering Research Laboratory is that component of EPA's
Research and Development program concerned with preventing, treating, and
managing municipal and industrial wastewater discharges; establishing
practices to control and remove contaminants from drinking water and to
prevent its deterioration during storage and distribution; and assessing
the nature and controllability of releases of toxic substances to the
air, water, and land from manufacturing processes and subsequent product
uses. This publication is one of the products of that research and
provides a vital communication link between the researcher and the user
community.
The national workshop on the disposal of pesticide wastes was developed
to provide a national forum that assembled pesticide users, pesticide
producers, federal and state agencies and agricultural and environmental
researchers to collectively address the complex issues of pesticide waste
disposal and serve as a basis for continued dialogue and interaction.
The Office of Research and Development with the Office Pesticide Programs
sponsored the development of these Proceedings to document the conduct
of this solution-oriented workshop. It is hoped that the content of
these Proceedings will stimulate action to reduce pollution by illustrating
approaches and techniques highlighted by the wealth of excellent papers
presented at the workshop.
Francis T. Mayo, Director
Water Engineering Research Laboratory
m
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ABSTRACT
A national workshop on the disposal of pesticide wastes was held in
Denver, Colorado, on January 28-29, 1985. The purpose of this workshop
was to work with government, pesticide user groups, pesticide producers,
farm organizations, and academia to define practical solutions to pesti-
cide users' disposal problems.
This publication is a compilation of the speakers' papers and a tran-
script of the summary panel. The following topics are covered: disposal
needs; Federal/State regulatory requirements; pesticide degradation
properties; disposal technology options, including physical treatment
options, biological options, chemical treatment options, land application
option, and incineration option; storage, handling, and shipments of
pesticide wastes; and empty pesticide container disposal programs.
This report was submitted in fulfillment of Contract No. 68-03-3131
by the JACA Corporation under the sponsorship of the U.S. Enviromental
Protection Agency. This report covers the period October 1984 to July
1985, and work was completed as of June 30, 1985.
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CONTENTS
Program
Overview: Pesticide Wastes Disposal
Orlo R. Ehart, Wisconsin Department of Agriculture,
Trade and Consumer Protection
Applicator Disposal Needs
William T. Keane, Arizona Aerial Applicators Association .... 12
Pesticide Wastes Disposal: An Agricultural Aviator's Perspective
Alvin Hamman, Al-Don Dusting Service Inc 15
Pesticide Wastes Disposal: A Ground Applicator's Perspective
Stanley Jones, Top Crop Fertilizer, Inc .__ 19
Pesticide Wastes Disposal: A Private Applicator's Perspective
James Mergen, Illinois Farm Bureau 21
Federal Regulation of Pesticide Disposal
Raymond F. Krueger, U.S. Environmental Protection Agency .... 22
California Regulatory Requirements
John Masterman, State of California 34
Pesticide Degradation Properties
Philip C. Kearney, USDA Agricultural Research Service 3t>
Physical Treatment Options: Removal of Chemicals from
Wastewater by Adsorption, Filtration and/or Coagulation
John C. Nye, Louisiana State University 43
A Practical System to Treat Pesticide-Laden Wastewater
William H. Dennis, Jr., Consultant 49
Pesticide Wastewater Disposal: Biological Methods
Arthur L. Craigmill and Wray L. Winterlin
University of California at Davis 54
Chemical Treatment Options for Pesticide Wastes Disposal
Richard C. Honeycutt, CIBA-GEIGY Corporation 72
Land Dispoal of Pesticide Rinsate
Ronald E. Ney, Jr., U.S. Environmental Protection Agency .... 86
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Incineration Options for Disposal of Waste Pesticides
Donald A. Oberacker, U.S. Environmental Protection Agency ... 87
Storage, Handling and Shipment of Pesticide Waste --
Regulatory Requirements
Rolf P. Hill, U.S. Environmental Protection Agency 95
The Logistics of Transporting Pesticide Wastes From The User
to Disposer
William B. Philipbar, Rollins Environmental Services, Inc. . . . 102
Empty Pesticide Container Management: An Overview
Harry W. Trask, Environmental Consultant 105
Alberta Pesticide Container Collection Program
James G. McKinely, Alberta Department of Environment Ill
Maine's Returnable Pesticides Container Program
Robert L. Denny, State Board of Pesticides Control 113
Summary Panel 117
List of Speakers and Attendees 131
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ACKNOWLEDGMENTS
The workshop was sponsored by the following organizations:
American Chemical Society (Division of Pesticide Chemistry)
American Farm Bureau Federation
American Society of Agricultural Engineers
Association of American Pesticide Control Officials, Inc.
National Agricultural Aviation Association
National Agricultural Chemicals Association
National Alliance of Independent Crop Consultants
National Forest Products Association
U.S. Department of Agriculture (Science and Education and
Soil Conservation Service)
U.S. Environmental Protection Agency (Hazardous Waste
Engineering Research Laboratory and Water Engineering
Research Laboratory) Office of Pesticide Programs
A special note of appreciation is extended to Mr. Roy R. Detweiler,
Chairperson of the Workshop Coordinating Committee and Mr. Thomas J. Gilding,
Workshop Coordinator. Also many thanks are given to Ms. Elaine McDonald
and Ms. Marilyn McKinnis for all their contributions in making sure the
workshop ran smoothly. These individuals along with the members of the
Workshop Coordinating Committee worked diligently to make this National
Workshop on Pesticide Waste Disposal an overwhelming success.
vn
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PROGRAM
Chairman: Roy R. Detweiler
E. I. duPont deNemours & Co,
January 28, 1985
8:30 - 8:40 a.m. Opening Remarks
8:40 - 9:00 a.m. Overview
9:00 - 10:00 a.m. Applicator Disposal Needs; Panel
10:00 - 10:40 a.m. Federal/State Regulatory Requirements
11:00 - 11:30 a.m. Pesticide Degradation Properties
Disposal Technology Options
11:30 - 12:15 p.m. Physical Treatment Options
2:00 - 2:45 p.m. Biological Options
2:45 - 3:30 p.m. Chemical Treatment Options
3:30 - 4:15 p.m. Land Application Option
4:15 - 5:00 p.m. Incineration Option
January 29, 1985
8:30 - 9:15 a.m. Storage, Handling and Shipments of Pesticide Wastes
9:15 - 10:15 a.m. Empty Pesticide Container Disposal
10:45 - 12:15 p.m. Workshop Summary Panel
12:15 - 12:30 p.m. Adjournment
-1-
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OVERVIEW: PESTICIDE WASTES DISPOSAL
Orlo R. Ehart
Wisconsin Department of' Agriculture, Trade
and Consumer Protection
Madison, WI 53708
ABSTRACT
A major agreement must be reached on what can be done, legally and technically, to deal
with the difficulties of proper pesticide related waste disposal, and who should share
in the cost of a clean environment. Many potential problems exist; however, the wastes
from mixing, loading and cleaning operations present the greatest challenge for pesti-
cide applicators. Although the current laws and regulations must form the state-of-
the-art for required disposal techniques, more appropriate incentives, less burdensome
governmental mandates which appropriately protect the environment, and more feasible,
technological solutions are needed in the future. Although past disposal problems and
future policy changes are of major importance, the primary focus must be the solutions
to the existing problems facing the pesticide user industry today.
INTRODUCTION
In 1976, the U.S. Congress passed
the Resource Conservation and Recovery
Act (RCRA) which amended the Solid Waste
Disposal Act (SWDA). This legislation
regulates disposal of wastes, including
pesticides which may create a hazard, to
assure minimum effects on human health
and the environment. The law places the
burden of protecting the environment on
all users and handlers of hazardous
materials, which may include both active
and/or inert ingredients of some pesti-
cides.
Pesticides are intended to control
or kill harmful plants, insects, germs,
bacteria, plant diseases, etc., but for
lack of specificity may be hazardous to
the environment. Pesticide commerce and
use are regulated under the Federal
Insecticide, Fungicide and Rodenticide
Act (FIFRA) and by state law and rules.
However, once applications of pesticides
are completed, any excess pesticide con-
centrate, unapplied diluted pesticide,
and discarded pesticide containers may
be regulated as wastes, some of which
may be considered hazardous.
REGULATIONS
Containers, if triple rinsed or its
equivalent, are not regulated as hazard-
ous waste but still must be disposed of
properly, generally in accordance with
label directions and in some situations
under additional state rules. Disposal
of containers that are not triple rinsed
is regulated according to the ingredients
they contained; some pesticides are regu-
lated as toxic waste, others as acutely
toxic waste ("acute hazardous"), and
still others are regulated by their pro-
perties or characteristics; some are not
regulated. Most of the pesticide pro-
ducts sold in the United States are not
regulated as hazardous waste.
The rules concerning regulated
wastes (Code of Federal Regulations
(CFR), (1980), Title 40, Parts 261-276;
and companion state rules) apply to those
who generate, store, treat, transport or
dispose of these wastes. The list of
regulated wastes is quite voluminous;
materials are listed by their chemical
names. Several pesticide active ingre-
dients are included as regulated wastes
(Tables 1 and 2).
-2-
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TABLE 1
"ACUTE HAZARDOUS" COMMERCIAL PESTICIDE
PRODUCTS1. 2» 3
"ACUTE HAZARDOUS" COMMERCIAL PESTICIDE
PRODUCTS Continued
Active Ingredient
Acrolein
Aldicarb
Aldrin
Allyl alcohol
Alpha-Naphthylthio-
urea
Aluminum phosphide
4-Aminopyridine
Arsenic acid
Arsenic pentoxide
Arsenic trioxide
Calcium cyanide
Carbon disulfide
p-Chlo roanili ne
Cyanides
Cyanogen chloride
2-Cyclohexyl-4,
6-dinitrophenol
Dieldrin
0,0-Diethyl
S-[2-ethylthio)-
ethyl]
phosphorodithio-
ate
0,0-Diethyl 0-pyra-
zinyl
phosphorothioate
Dimethoate
0,0-Dimethyl
0-p-nitrophenyl
phosphorothioate
4 ,6-Dinitro-O-cres-
ol and salts
4,6-Dinitro-O-
cyclohexylphenol
2,4 Dinitrophenol4
Dinoseb
Disulfoton
Common or
Trade Name
Aqualln, Acrylalde-
hyde, Magnacide H
Temik
ANTU
Phostoxin, Delicia
Avitrol
orthoarsenic acid
Cyanogas
soluble cyanide
salts
Dinex
disulfoton;Di-Sys-
ton, Dithiodemeton,
Dithiosystox,
Thiodemeton
thionazin, cynen;
Zinophos, Nemafos
Cygon, De-Fend,
Rogor
methyl parathion,
thiophosphate
Dinitro, Sinox
dicyclohexylamine
salt
Dinitro, DNBP
Di-Syston
Active Ingredient
Endosulfan
Endothall
Endrin
Famphur
Fluoroacetamide
Heptachlor
Hexaethyl tetra-
phosphate
Hydrocyanic acid
Hydrogen cyanide
Magnesiuni phosphide
Methomyl
Methyl parathion
Nicotine and salts
Octamethylpyro-
phosphoramide
Parathion
Phenylmercuric
acetate
Phorate
Potassium cyanide
Propargyl alcohol
Schradan
Sodium azide
Sodium cyanide
Sodium fluoro-
acetate
Strychnine and salts
0,0,0,0-Tetraethyl
dithiopyrophosphate
Tetraethyl pyro-
phosphate
Thallium sulfate
Thiofanox
Toxaphene
Warfarin5
Zinc phosphide"
; Common or
: Trade Name
iThiodan
lAquathol
;Warbex
;Compound 1081
:HEPT
Magtoxin
:Lannate, Nudrin
: Black Leaf 40
ischradan, OMPA
: ethyl parathion
;PMA
iThimet
OMPA
;Kazoe, Smite
Cymag
: Compound 1080
:Sulfotepp,
: Bladafurae
;TEPP
:Dacamox
: octochlorocamphene;
: Camphechlor,
i Alltex, Toxak.il
iCoumafene,
; Coumaphene,
: Dethmor
:ZP
1Pesticide active ingredients also found in Table E of 40 CFR, Part 261, Subpart D.
^Some information on pesticide active ingredients provided by Office of Pesticide
Program staff, USEPA, Washington, DC.
^The author neither implies nor intends endorsement or criticism of products nor assumes
any responsibility for inadvertently omitting any products.
*1,4-Dinitrophenol is listed as a pesticide active ingredient.
^When the commercial chemical product is greater than 0.3% warfarin.
"When the commercial chemical product is greater than 10% zinc phosphide.
-3-
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TABLE 2
"TOXIC" COMMERCIAL PESTICIDE
PRODUCTS1. 2» 3
Common or
Active Ingredient Trade Name
Acetone
Acetonitrile
Acrylonitrile
Amitrole
Benzene
Bis(2-ethylhexyl)
phthalate
Cacodylic acid
Carbon tetrachlor-
ide
Chloral hydrate
Chlorobenzilate
Chlordane, techni-
cal
Chlordecone
Chlorobenzene
4-Chloro-m-cresol
Chloroform
0-Chlorophenol
4-Chloro-O-tolui-
dine hydrochlor-
ide4
Creosote
Cresylic acid
Cyclohexane
Cyclohexanone
Cyclophosphamide
Decachlorooctahy-
dro-1,3,
A—metheno—2H—cy—
clobuta-
[c,d]-pentalen-
2 - one
Dial late
l,2-Dibromo-3-
chloropropane
Dibutyl phthalate
S-2,3-(Dichloroal-
lyl) diisopro-
pylthiocarbamate
0-Dichlorobenzene
p-Dichlorobenzene
"TOXIC" COMMERCIAL PESTICIDE PRODUCTS
Cont inued
:Common or
Active Ingredient tTrade Name
Acrylofume
cyanoethylene;
Acritet
Cytrol, Weedazol
Phytar, Rad-E-Cate,
Arsan, Silvisar
Acaraben
synklor; Chlor Kill,
Orthoklor
Kepone
Cresols
Endoxan
chlordecone;
Kepone
Avadex, DATC
DBCP, Nemagon,
Fumazone
diallate;
Avadex, DATC
orthodichlorobenzene
paradichlorobenzene;
Moth Crystals
Dichlorodi fluoro-
methane
3,5-Dichloro-N-(l,
l-dimethyl-2-pro-
pynyl) benzamide
Dichloro diphenyl
dichloroethane
Dichloro diphenyl
trichloroethane
Dichloroethyl ether
2,4-Dichlorophenoxy-
acetic acid, salts
and esters
1,2-Dichloropropane
1,3-Dichloropropene
Dimethyl phthalate
Ethyl acetate
Ethyl 4,4'-dichloro-
benzilate
Ethylene dibromide
Ethylene dichloride
Ethylene oxide
Formaldehyde
Furfural
Hexachlorobenzene
Hexachlorocyclohex-
ane; gamma isomer
Hexachlorocyclopen-
tadiene
Hexachloroethane
Hexachlorophene
Hydrofluoric acid
Isobutyl alcohol
Lead acetate
Lindane
:Freon 12,
Propellant 12
pronamide; Kerb,
Propyzamide
ODD, TDE
DDT
Chlorex
2,4-D
Propylene
dichloride
Telone, D-D
Mixture, Nemex,
Vidden D
:DMP
; Chlorobenzilate,
:Acaraben
EDB, Bromofume,
: Dowfumen-85,
: Pestmaster
; EDB-85,
; Soilbrom-85
EDC
;0xirane
:HCB, Anticarie,
: No Bunt
:benzene hexa-
: chloride, gamma
: isomer; lindane
:Avlothane
^Pesticide active ingredients also found in Table F of 40 CFR, Part 261, Subpart D.
^Some information on pesticide active ingredients provided by Office of Pesticide
Program staff, USEPA, Washington, D.C.
•>The author neither implies nor intends endorsement or criticism of products nor assumes
any responsibility for inadvertently omitting any products.
^3-Chloro-p-toluidine hydrochloride (Starlicide) listed as active ingredient.
-4-
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"TOXIC" COMMERCIAL PESTICIDE PRODUCTS
Cont inued
Common or
Active Ingredient
Maleic hydrazide
Mercury
Methyl alcohol
Methyl bromide
Methyl chloride
2,2'-Methylenebis
(3,4,6-trichloro-
phenol)
Methylene chloride
Methyl ethyl ketone
4-Methyl-2-penta-
none
Naphthalene
Nitrobenzene
p-Nitrophenol
Pentachloroethane
Pentachloronitro-
benzene
Pentachlorophenol
Perchlorethylene
Phenol
Phosphorodlthioic
acid,
0,0-diethyl,
methyl ester
Pronamide
Propylene dichlor-
ide
Pyridine
Resorcinol
Safrole
Trade Name
MH3Q, Slo-Gro,
Sucker-Stuff,
Retard
Methanol
hexachlorophene;
G-ll
MEK
methyl isobutyl
ketone; MIBK
Moth Balls
PCNB, Quintozene,
Tritisan,
Terraclor
Penta, PCP
tetrachloroethy-
lene
carbolic acid
Kerb
"TOXIC" COMMERCIAL PESTICIDE PRODUCTS
Cont inued
Common or
Active Ingredient Trade Name
Selenium disulfide
Silvex
1,2,4,5-Tetrachlor-
obenzene^
1,1,2,2-Tetrachlor-
oethane
Tetrachloroethylene
2-(2,4,5-Trichloro-
phenoxy)
propionic acid
2,3,4,6-Tetrachlor-
ophenol
Thiram
Toluene
1,1,1-Trichloro-
ethane
Trichloroethylene
Trichloromonofluor-
omethane
2,4,5-Trichloro-
phenol
2,4,6-Trichloro-
phenol
2,4,5-Trichloro-
phenoxyacetic
acid
Xylene
Warfarin6
Zinc phosphide^
perchlorethylene
silvex
Arasan, Thylate,
TMTD, Spotrete,
Delsan, Pomarsol,
Tersan
methyl chloroform;
Methoxychlor,
Marlate
Freon 11,
Propellant 11
Dowicide 2
Dowicide 2S
2,4,5-T
Coumafene,
Coumaphene,
Dethmor
ZP
^1,2,3,4 Tetrachlorobenzene is listed as a pesticide active ingredient.
6When the commercial chemical product is 0.3% or less warfarin.
the commercial chemical product is 102 or less zinc phosphide.
The pesticides in this publication
are listed alphabetically according to
the active ingredient named in the
statement on the front panel of the pes-
ticide container; some are listed under
both common name and scientific chemical
name. Common names and/or trade names
follow the active ingredient name where
they exist to identify any pesticide
also designated as an "acute hazardous"
(Table 1) or "toxic" (Table 2) material.
The list includes some chemicals once
sold as pesticides but no longer market-
ed as pesticide active ingredients. The
chemicals found in the CFR as regulated
wastes frequently are named by a dif-
ferent nomenclature than that used in
naming pesticide active ingredients.
The names found in this publication are
those found in the Third Edition of
Acceptable Common Names and Chemical
Names for the Ingredient Statement on
Pesticide Labels (1975) and may not
necessarily be found under the listed
name in 40 CFR, Part 261.
-5-
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The lists included in this publica-
tion do not contain commercial chemical
products that may become regulated
wastes as a result of the EPA's Hazard-
ous Waste Management System; Dioxin-
Containing Wastes rule (1985). In addi-
tion by early 1986, according to the
Hazardous and Solid Waste Amendments of
1984, EPA must determine whether or not
to list as "acute hazardous" or "toxic"
wastes products containing any of the
following: chlorinated aliphatics,
dioxin, carbamates, bromacil, linuron,
organo-bromines, solvents and chlorin-
ated aromatics. The impact of this
review may significantly impact a large
number of pesticide products currently
not listed.
Even if a pesticide is not listed
in Tables 1 and 2, it may still be a
regulated waste. If the pesticide is
ignitable (flash point below 140° F.),
corrosive (pH less than 2 or greater
than 12.5), reactive (potential for
chemical reactions), or "extraction
procedure toxic" (contains an active
ingredient above a maximum concentration
determined by a specified extraction
test), the pesticide is regulated as a
"hazardous waste" (40 CFR, Part 261,
Subpart C and companion state rules).
If 2.2 pounds (1 kilogram) or more
of any "acute hazardous" pesticide waste
(Table 1) is accumulated in any month,
SWDA and the corresponding state laws
and rules require the generator to dis-
pose of this waste in a hazardous waste
facility. When the limit of 2.2 pounds
of waste is exceeded, approximately
1 quart of material including diluent of
"acute hazardous" products, the law
requires the generator to obtain a num-
ber from the Environmental Protection
Agency (EPA) or the State Lead Agency
(SLA) administering SWDA to dispose of
the waste in an approved, regulated haz-
ardous waste landfill site. The entire
waste, no matter how dilute, must be
treated as if it were "acute hazardous"
material. Therefore, it is prudent to
segregate all "acute hazardous" material
from other wastes during storage to
reduce the cost and effort of disposal.
Several commercial and private pes-
ticide applicators and pesticide dealers
may have to become official "waste gen-
erators" to dispose of leftover pesti-
cides. Some regulated landfills require
an identification number from anyone
attempting to dispose of any pesticide
wastes, regardless of whether or not the
pesticide is a "toxic" or "acute hazar-
dous" material. Landfill operators have
the right to be more restrictive than
the law; in turn, this places more bur-
dens on the waste generator, the pes-
ticide applicator or dealer. When land-
fill operators are more restrictive,
however, a dilemma is created for appli-
cators as all wastes are then handled as
if they were "acute hazardous" wastes.
Since SWDA allows persons to be held
strictly liable for past disposal prac-
tices, such reactions by landfill opera-
tors are to be expected.
Table 2 lists pesticide active in-
gredients classified as "toxic" wastes.
If 2,200 pounds (1,000 kilograms or
approximately 284 gallons) or more of
waste of these products is generated in
any month, a generator number is
required for disposal of the waste.
A number must be obtained from EPA
or the SLA administering SWDA if the
2,200 pounds of "toxic" waste or
2.2 pounds of "acute hazardous" waste
are reached in any one month, without
regard to the amount of waste which may
be generated in other months. It also
bears repeating that the waste includes
the diluent as well as the pesticide.
Therefore, during the application season
the water used to clean a spray rig for
applications made during a month, in and
of itself, may be enough to require an
applicator to obtain a waste generator
number. Additionally, it would appear
that any liquid spray mixture of any
formulation of pesticide active ingredi-
ents found in Table 1 would result in
sufficient waste water and/or leftover
spray mixture to require many commercial
applicators to become recognized waste
generators.
The 1984 amendments to SWDA require
the EPA to promulgate standards for
waste in quantities greater than 100 and
less than 1000 kg/mo. These standards
may vary from the existing regulations,
but must protect human health and the
environment. Therefore, the information
detailed in this paper may be modified
-6-
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by rules expected by March 31, 1986
(Schaffer, 1985).
CONFERENCE FOCUS
The pesticide use versus disposal
issue can be equated to a heavyweight
title fight. In the one corner, repre-
senting the pesticide disposal inter-
ests, are the NIMBYs, the Not In My Back
Yard philosophy people. Representing
the NIMBYs is Hester Foster. Hester
Foster has been known to have problems
turning on her radio ever since she
learned that herbicides could be broad-
cast. (Guindon, 198A)
In the other corner, representing
the pesticide users, is the pesticide
applicators' industry. They have not
yet selected their actual participant
for the bout. Suffice it to say, they,
too, have a choice between the extremely
professional representative and an un-
aware, ill informed user. It is obvious
that currently differing philosophies
along a long spectrum of concerns
exists; some rightful, some not.
Differing philosophies in the way
that disposal and use are regulated also
exist. On the one hand is the SWDA and
on another hand is the FIFRA. These
laws are very similar in the way that
they mandate handling some of the dis-
posal issues; in some other ways they
establish inconsistent requirements.
Communication may in some instances be
inhibited between the administrators of
the SWDA and FIFRA on a state level
since frequently the programs are admin-
istered through different SLAs. The
conference participants will focus upon
the existing policies, the plight of the
pesticide users and what can be done to
minimize their problems and better
define their concerns.
This discussion cannot ensue, how-
ever, without the recognition that there
is going to be an increased cost asso-
ciated with the solutions to the pesti-
cide waste disposal dilemma. For exam-
ple, in an Iowa study in 1974, Ryan
(1974) asked farmers how much they would
be willing to pay, as an increased cost
per year, to dispose of pesticide con-
tainers. The answer was $10.00. The
same question was asked of commercial
pesticide applicators and dealers; their
answers were $20.00 to $30.00. That
questionnaire hasn't been repeated, how-
ever, considerable increases in prices
people are willing to pay today to rid
themselves of pesticide waste disposal
burdens might be anticipated.
It also must be recognized, that
the Hester Fosters of the world are not
all wrong, even though they may be some-
times uninformed. It must be accepted
that problems do exist, and they need to
be addressed. That is, of course, the
reason for the conference.
PROBLEMS, ISSUES AND POLICIES
The sources of potential problems
are as follows: The containers; un-
wanted, unuseable and unidentifiable
products; tank rinse waters; leftover
materials; equipment wash waters; incom-
patible mixtures; spilled materials from
accidents; stormwater and run-off from
natural occurrences; and debris from
fires.
In order to understand how these
sources may be potential problems, it is
necessary to recognize how wastes are
designated. In addition to the two met-
hods previously Indicated, by listing or
testing, a product may be designated as
a hazardous waste simply by the owner
declaring it as hazardous waste. This
occurs most generally when a waste is
suspected to be a hazardous waste and
the owner decides not to incur the po-
tential additional expense of determin-
ing the actual contents of the materi-
als. This may also occur at the insis-
tence of hazardous waste disposal facil-
ity operators who wish to reduce their
liabilities.
Who determines when a pesticide is
a waste? That question has been asked
many times in recent months and the
answer is always, "It is the person who
is the owner of the pesticide." How-
ever, there is also another caveat to
the answer which is not articulated.
The caveat is that a regulator may de-
cide that the activity is unacceptable,
and therefore, determine that the pesti-
cide is a waste for the owner.
Is recycling the answer to the pes-
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f\
ticide disposal problem? It is only par-
tially the answer. The philosophy of
recycling is more appropriate to solvents
which may have continued uses than it is
to pesticide wastes. People who stress
recycling as the alternative to disposal
are generally unaware of the pesticide
users' inability to find a buyer for a
few gallons of diluted pesticide product
of which the effacacy is in question. In
addition, recycling does not merely mean
finding another use for a pesticide drum.
In experiments conducted in Wisconsin
after triple rinsing and then re-rinsing
with acetone, pesticide active ingredient
was still found in every container
(Myrdal, 1984).
If a pesticide is used at one rate,
can it be disposed of on land at that
same rate? It depends upon several
factors, but, in general, SWDA policy
condemns that approach. The State Issues,
Research and Evalutation Group (SFIREG)
Committee on Groundwater Protection and
Pesticide Waste Disposal has identified
that problem as one of the major issues
needing resolution.
There are several options and poli-
cies currently in place which must be
reviewed in order to better understand
the issues related to the disposal of
pesticide waste.
The containers; Recycling and dis-
posal are the two options of getting rid
of them which are quite frequently sug-
gested. As mentioned before, if the
containers have been triple rinsed they
may be recycled, in some circumstances,
directly back to manufacturers; they can
also go to scrap metal dealers. The
triple rinse requirement is like the
seat belt law. The statistics associ-
ated with the advantages of using seat
belts are well known, but many do not
take the time to actually follow through
with their use. The same is true of
triple rinsing. Until the provisions
are strictly enforced, compliance will
be minimal.
If the containers are to be dis-
posed, they must be placed in a land-
fill, sometimes in an approved landfill,
depending on state regulations, and, if
the farm exemption is allowed, they may
be disposed on the farm. If the con-
tainers are not triple rinsed the con-
tainers remain regulated according to
their contents.
Label directions on the pesticide
container may require other specific
actions. Therefore the label must be
consulted before any actions can be ta-
ken, regardless of whether the SWDA re-
quirements are understood. Many labels,
however, have poorly written language
which Is difficult to interpret. Some
changes in label language have been re-
quired by PR Notice 83-3 (Campt, 1983).
That language does standardize the lan-
guage required, however, it still does
not simplify the label language to the
extent necessary. For example, the sug-
gested wording required by the label im-
provement program (LIP) may have elimi-
nated the SWDA farmer exemption. There
apparently is a notice coming out of EPA
that may allow the continuation of the
farmer exemption. If a notice is needed
to explain the policy it appears the sug-
gested LIP language is unclear and needs
to be reviewed.
The unwanted, unuseable and uniden-
tifiable products: Since no incentives
exist for clean up and most users do not
recognize the potential for a spill prob-
lem in their storage area, this issue is
neglected until the sites are a problem
and/or they are abandoned. It is appar-
ently considered to be a better philos-
ophy to create a superfund problem than
it is to spend tax dollars to eliminate
problems before the neglected products
contaminate the environment. Pesticide
collection and amnesty days programs,
which previously have been aimed mostly
at homeowners, seem to be prudent program
dimensions to be instituted on a broader
scale basis to avoid problems of super-
fund proportions.
Pesticide residual waste: Currently
some attempts are being made to recycle
residual wastes by making use of them in
the next load. The utility of this
option depends on the operation and its
location. For example, if all the major
pesticide uses for an applicator are for
control of pests on soybeans and corn,
this option may be useful as rinse waters
may be easily segregated and reused.
Where an applicator makes applications to
a wide variety of crops there may be
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problems with phytotoxicity and toler-
ances associated with the subsequent use
of the water on other crops. Under these
conditions it may be too costly to segre-
gate all the rinse waters in separate
facilities and illegal to use the rinse
waters on another crop.
gpllled materials, Incompatible mix-
tures and fire debris: When the material
created by these situations is a sizable
quantity the current policy requires pro-
per clean up and disposal. Applicators
are simply going to have to have good
insurance and bite the bullet.
Storm water and runoff: A recently
published final rule of EPA will require
all applicators to receive a national or
state pollution discharge elimination
system permit to deal with stormwater
removal and runoff from any mixing, load-
ing, holding, storage or disposal site.
It means that yet another layer of regu-
lations exists with which an applicator
must deal.
STATE RESTRICTIONS
States can be, and generally are,
more restrictive than the federal law.
Some of the disposal options condoned un-
der the federal law are currently not op-
tions available to the end users at the
state level; burning of pesticide bags
has been prohibited by some states or lo-
calities. A number of states have pro-
hibited reuse of containers except when
they are triple rinsed and recycled back
to the manufacturer or to scrap metal
dealers, even though the federal regula-
tions may not have specifically mandated
that prohibition. Many states have gone
beyond the scope of FIFRA and have imple-
mented rules requiring proper storage of
pesticides to minimize any effect on the
environment. Although this does not re-
late directly to waste it is a progres-
sive policy of attempting to assure that
unnecessary environmental contamination
does not occur from storage sites. In
addition there are groundwater concerns
in several states; those programs have
traditionally been established on a state
level.
GROUNDWATfiR
No disposal paper in 1985 would be
complete without some discussions of
groundwater contamination. First of all
it must be recognized that common law, in
general, handles groundwater and surface
water in completely separate fashions.
Only recently have the courts recognized,
in a few cases, that groundwater is not
as mysterious as what medieval people
might have thought. Although the hydro-
logic cycle is quite complex there is an
interconnection between surface and
groundwater. A local flow system occurs
in a relatively localized area. Flow is
at a faster rate than for a regional flow
system and the water generally discharges
close by. In a regional flow system
recharge of the groundwater can be from
some distance way, the water generally is
deeper below the surface and travels
miles over many years before it dis-
charges.
Long Island, for example, has some re-
gional flow systems that take many hun-
dreds of years from the time of recharge
until discharge (Guerrera, 1981). There-
fore, if pesticides enter groundwater it
may be years later and miles away before
the contaminated water actually surfaces,
or, for that matter, is tapped for use as
groundwater. For that reason it must be
recognized that land uses have poten-
tially important impacts on groundwater
quality now and into the future.
Since pesticide use may result in
the presence of pesticides in ground-
water it is extremely necessary to look
critically at mixing, loading and han-
dling sites where the potential for the
introduction of pesticides from those
activities may be increased simply be-
cause of the frequency of which pesti-
cides are handled at a site. This in-
creases the need for standards for mix-
ing, loading and handling sites in order
to standardize the industry's practices
and assure a clean environment.
Water pollution can result from
neglect; those circumstances require
immediate action both in clean up and in
enforcement. It should be recognized,
however, that sometimes pesticides get
into water on purpose; something that is
frequently overlooked in assessing the
protection of the environment.
The EPA has recently published a
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strategy on how it will conduct ground-
water programs. One of the major ele-
ments is the coordination between EPA
and the states of many program func-
tions. It is very clear that the EPA's
intent is for the strategy to have a ma-
jor impact on all environmental policies
regardless of whether they are under
FIFRA, SWDA or any other act. The clas-
sification of groundwater according to
the EPA strategy is of concern. In add-
ition there have been implications that
beneficial use of water does not include
agricultural use.
The discussions of the presence of
pesticides in groundwater has focused
rightfully on the health effects asso-
ciated with exposure. Risk assessments
will need to be calculated and health
advisories will need to be established if
the impact of the presence of a pesticide
in groundwater is to be determined. With
some idea of the health significance of
exposure, adequate management strategies
can be proposed to minimize the effect of
exposure and, where possible, eliminate
the presence of pesticides in ground-
water.
SOLUTIONS
Standards must be established for
mixing and loading sites; separate stan-
dards for dealing with situations that
occurred prior to the passage of RCRA and
more stringent standards for compliance
since the passage of RCRA. Since the law
holds people accountable retroactively,
current policy suggests a standard of
strict liability for past circumstances
even when they were done using best
available technologies. This creates a
lot of fear and disgust on the part of
people who are trying, and willing, to
comply with the regulations. It cer-
tainly has not created a situation with
which applicators can easily comply with-
out completely stopping their businesses.
They, therefore, do not admit to prob-
lems. This does not result in any
cleaner environment. A societal desire
for actual cleanup must be invented.
One of the solutions to the conflic-
ting policy difficulties may lie in the
provision of SWDA which allows for
delisting treatment methods. Methods of
waste treatment, some of which will be
discussed at this conference, haven't
been assessed to determine if they can be
delisted. Although the original intent
of the delisting procedure did not in-
clude the assessment of whole categories
of potential wastes, such as rinse water,
an assessment of whether, and wider what
conditions, it could be delisted should
be pursued.
Land spreading needs more research.
One program of EPA condemns it and
another condones it. Land spreading
does have a real applicability in the
pesticide disposal area, however, until
a consistent policy is developed this
area remains a questionable solution to
problems which should be easily re-
solved. For example, if monitoring
wells are required where a pesticide
waste is being land spread at low rates,
the cost of compliance eliminates the
practical use of the option.
Collection of wastes before they
become problems must become a societal
desire. The prioritization only after
major contamination is shortsighted.
Incentives which allow more involvement
of producers of waste in forming their
own destiny would result in a cleaner
environment.
A small quantity generators study is
due to Congress by April 1985. The study
will possibly also assess the farmer
exemption. This may provide some relief
to small quantity generators or it may
not. Regardless, more regulation of
small quantity generators will result.
From a research perspective assess-
ments of biological breakdown mechanism
has received considerable attention.
Papers will be presented at this confer-
ence on chemical and physical decomposi-
tions as well. Many practices already
exist to eliminate problems; some of them
are legitimate answers to problems and
some are far too expensive. Many, how-
ever, are not legal since the regulations
or the assessments of the technologies
have not kept pace with emerging technol-
ogies. There are a number of practical
application attempts occurring to pro-
perly manage waste on the farm, at appli-
cator sites and in researcher areas.
They are not being shared. People are
fearful of letting regulators,
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tors, researchers or competitors know
about them. They are afraid that the
practice might be illegal, slightly il-
legal or not proven beyond a reasonable
doubt. Those practices must be brought
into the discussions. Methods which have
the potential to reduce the threats to
the environment must be authorized, if
only on an interim basis.
Amnesty programs, where practical,
may provide more open discussion and a
cleaner environment. There needs to be
more discussion with the Hester Fosters
in place of fighting with them. Users
must do a good job of managing waste. If
something happens responsible parties
need to react immediately.
SUMMARY
If compliance is easy, it is a good
policy. But that statement should not be
misinterpreted as meaning that the status
quo is good enough. There are costs
associated with that policy. Noncompli-
ance with reasonable expectations must
result in serious consequences to the
offenders. A "less clean" environmental
policy cannot be accepted; however, bet-
ter, more reasonable policies are needed
to obtain the desired goal. Changes in
policies should provide avenues for
assuring minimization of contamination,
rather than rhetorical statements of pur-
pose. Once reasonable policies have been
established strict enforcement is an
absolute necessity.
If the problem of pesticide use ver-
sus pesticide disposal were reduced to a
simple equation that equation might read:
do benefits of pesticide use equal risks
of disposal? Hopefully the answer to
that is no; benefits of use outweigh the
risks of disposal if both use and dis-
posal are done judiciously and properly.
All parties must work together and com-
municate openly if the equation is ever
to have legitimate, lasting solutions.
REFE HENCES
Aim, A.L., 1985. Hazardous Waste Manage-
ment System; Dioxin-Containing Wastes,
Federal Register 50(9): 1976-2006,
January 14, 1985.
Campt, D.D., 1983. Notice to Manufac-
turers, Formulators and Registrants of
Pesticides - Label Improvement Program
- Storage and Disposal Label Statement,
PR Notice 83-3, USEPA, March 29, 1983.
13 pp.
Cawell, R.L., M.L. Alexander and H. Boyd,
1975. Acceptable Common Names and Chem-
ical Names for the Ingredient Statement
on Pesticide Labels, OPP-EPA,
Washington, D.C. 181 pp.
Code of Federal Regulations (CFR), 1980.
Title 40, Parts 260-265. U.S. Govern-
ment Printing Office, pp. 892-1006.
Federal Insecticide, Fungicide and
Rodenticide Act (FIFRA), as amended in
1978 (7 USC. 136 et. seq.).
Guerrera, A.A. 1981. Chemical Contamin-
ation of Aquifers on Long Island, New
York. AWWA, April 1981, pp. 190-199.
Guindon, R. 1984. Syndicated Cartoon
Character and Cartoon Caption, News
America Syndicate, News Group Chicago,
Inc.
Hazardous and Solid Waste Amendment of
1984. House of Representatives Report
98-1133, October 3, 1984. 131 pp.
Myrdal, G., 1984. Personal communica-
tions on unpublished laboratory
studies, DATCP General Labs, Madison,
Wisconsin.
Ryan, S.O., 1974. A Study of Pesticide
Use, Storage and Disposal in Iowa,
Ph.D. Dissertation, Iowa State
University, Ames, Iowa as reported in
Little, A.D., 1977. Economic Analysis
of Pesticide Disposal Methods, U.S.
EPA, Washington, D.C. 181 pp.
Schaffer, A. 1985. Unpublished
Presentation to the Groundwater
Protection and Pesticide Disposal
Working Committee of SFIREG.
Washington, D.C. January 14-15,
1985.
Solid Waste Disposal Act (SWDA) as
amended in 1984 (42 USC. 6901 et.
seq.).
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APPLICATOR DISPOSAL NEEDS
William T. Keane
Arizona Aerial Applicators Association
Phoenix, Arizona
ABSTRACT
The state-of-the-art of the mechanical technology available to applicators makes
it difficult for compliance with the Resource Conservation and Recovery Act (RCRA).
Spray nozzles that leak with optimum maintenance; lack of consistency in the size and
composition of pesticide containers; the wide variety of orifices in pesticide con-
tainers; the fact that this business is conducted out-of-doors, sometimes after dark,
many times away from an applicator's base of operation, and in a wide variety of
weather conditions discourages full compliance with the intent of RCRA.
There are inconsistencies throughout the United States in enforcing RCRA. In many
states there appears to be minimal or no enforcement. There is need for more uni-
formity in guidance, regulation, and enforcement associated with pesticide wastes
disposal. Development is needed for efficient and cost effective methods of waste
disposal techniques for use by applicators. Guidance by the Environmental Protection
Agency is required to insure than any major expenditures by application firms will
enhance compliance with the law and not subsequently be declared inadequate.
DISCUSSION
Compliance with RCRA is difficult
and in some instances impossible for all
pesticide applicators. Recommendations
are given for mutual cooperation between
pesticide applicators and the EPA so that
compliance can be achieved over time with-
out causing financial hardship and/or
bankruptcies.
Based upon the presentations we have
just heard, it is apparent that growers,
ground applicators, and aerial applica-
tors of pesticides are probably in viola-
tion of many provisions of RCRA and
undoubtedly violate this law many times
during the spraying season. These repeti-
tive violations of federal law should not
be interpreted as a disregard for environ-
mental quality. Instead, the panelists
have provided repeated examples of lack
of technical ability to come into com-
pliance, a mechanical state of art in their
industry which does not enable them to
stay in compliance when and if they ac-
hieve that objective, and confusion about
the regulations and how they apply to
all handlers of pesticides.
All spray nozzles available to
pesticide applicators will leak if one
particle of dirt or sand finds its way
into the nozzle. This can and does re-
peatedly occur with both ground and
aeriel applicators. For example,
aerial applicators generate large
clouds of dust as a result of the prop
wash associated with takeoffs and
landings. You have learned from a
ground applicator that he also gene-
rates large amounts of dust while
applying pesticides. The very nature
of the work environment and the job to
be performed guarantees the generation
of dust resulting in leaky spray
nozzles. Before a mechanic can un-
plug spray nozzles, he must first
rinse them with copious amounts of
water so that some of the fine mechani-
cal work, which can only be accomplished
with bare hands, can be safely under-
taken.
After a spray application, the
pesticide residues must be rinsed from
the interior and exterior of the appli-
cation equipment. Under the farmers'
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exemption to RCRA, it is permissible to
apply this rinsate to the farmers' crops.
However, after this has been accomplished,
one to three gallons of residual rinsate
will remain in the spray apparatus. This
remaining rinsate solution should be re-
moved from the aircraft before the next
spray job in order to avoid cross con-
tamination of pesticides.
Washing the outer surface of ground
spray rigs and aircraft at regular in-
tervals is a necessity. During a single
washing of one of these pieces of equip-
ment, approximately 80 to 100 gallons of
rinsate will be generated. You have
learned from the aerial applicator on
the panel that this rinsate will contain
dirt, oil, hydraulic fluid, insect
parts, and pesticides. Utilization of
this rinsate as a diluent in the next
spray job is impossible since the con-
taminants would occlude the spray system.
During the active spraying season, an
applicator will generate thousands of .
empty pesticide containers. These con-
tainers vary dramatically in size, compo-
sition, and the toxicity of their con-
tents. The federally approved pesticide
label permits disposal of these con-
tainers in sanitary landfills after they
have been triple rinsed, punctured, and
crushed. However, some sanitary land-
fills refuse to accept these decon-
taminated pesticide containers. Based
upon the formulation originally contained
in the pesticide container, it is
entirely possible that triple rinsing is
not adequate to remove all of the pesti-
cide residue contained therein. Addi-
tionally, many of the pesticides are
extremely odoriferous and even the
triple-rinsed containers generate a
pugent organic odor. The strong or-
ganic odors eminating from empty pesti-
cide containers labeled with a skull and
crossbones can cause a sanitary landfill
operator to refuse acceptance. Many
pesticide applications occur at night
and in the early morning hours before
daylight. In many instances, the
applicator will be working at a remote
site many miles from his base of opera-
tion. At these remote work sites, there
may be no sources of water and no means
of catching and collecting even relatively
small volumes of liquid. When work is
performed at these remote sites, it is
performed under a wide variety of weather
conditions, out-of-doors, with only a
limited amount of equipment and tools
readily available. Attempting to
comply with all of the provisions of
RCRA is exceedingly difficult under
these conditions.
Many operators have asked me what
type of construction could be under-
taken at the primary site of operation
in order to collect and store these
various types of pesticide wastes.
At the present time, there is no
answer for these inquiries since the
EPA has not formally approved any
type of pesticide collection and
storage construction. It would be
poor business judgment for any small
businessman, such as an applicator,
to undertake an expensive construc-
tion project with no guarantee that
the final result would gain EPA
approval. Additionally, if the EPA
would disapprove the final construc-
tion project after it had been
installed and utilized, all of the
construction materials would contain
pesticide residues and would have
to be treated as a hazardous waste,
thereby resulting in an extremely ex-
pensive disposal project.
In meetings with applicators
from across the United States, I have
learned that there is no consistency
with respect to the enforcement of
RCRA. In some states, neither the
EPA nor the state agency empowered
to enforce RCRA has addressed the
issue of pesticide application. In
other states, pesticide applicators
are only inspected when a formal com-
plaint has been lodged with the
responsible agency. In the remaining
states, a more active investigation
of applicators is taking place. Once
an applicator is found by a regula-
tory agency to be in violation of
RCRA, no uniform, economically
feasible methods exist for that
applicator to come into compliance.
In some cases, with which I am personally
familiar, the cost of compliance will re-
sult in bankruptcy. In other instances.
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once the applicator has spent the
necessary funds to come into compliance,
no available technology exists to en-
sure that the applicator can stay in
compliance. Also, the statutory fines
imposable against violators under RCRA
may be appropriate for multi-national
corporations, but become ridiculous when
applied to small businessmen, such as
applicators.
Since I started my comments by
stipulating that all pesticide appli-
cators are probably in violation of
RCRA, it appears that the responsible
regulatory agencies could, at any time
they desire, cite all pesticide applicators
for these violations. The resulting cost
of compliance and/or penalties imposed
would put them out of business, thereby
bringing to a halt the great majority of
all food and other production in this
country. This is obviously an untenable
result of enforcement and not the
original intent of this Congressional leg-
islation. In order to avoid such a harsh
result, research is required to develop
efficient and cost effective methods
of compliance for pesticide applicators.
The EPA and responsible state agencies must
give guidance to the pesticide applicators
by defining proper methods of dealing with
pesticide hazardous waste. Uniformity
in enforcement with respect to all
pesticide handlers must be established
throughout the United States. And before
this massive and costly undertaking
commences, it would seem prudent that this
threshhold question be answered: "Does the
use and application of pesticides cause a
hazardous waste problem and what is the
nature and extent of that problem?"
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PESTICIDE WASTES DISPOSAL:
AN AGRICULTURAL AVIATOR'S PERSPECTIVE
Alvin Hamman
Al-Don Dusting Service, Inc.
Eloy, Arizona
ABSTRACT
In my opinion, the average aerial application firm in the United States is comprised
of approximately two pilots and two working aircraft. (Some operators maintain back-up
aircraft.) In the Sunbelt, pesticides are applied to approximately 140,000 acres per year,
utilizing approximately 50,000 gallons of pesticide. This results in the generation of
4,400 containers each year. These containers are composed of glass, plastic, metal and
paper. Container sizes are 1 gallon, 2-1/2 gallons, 5 gallons, 30 gallons, and 55 gallons.
The majority of the glass containers are 1 gallon. There is no consistency in the size or
shape of caps, bungs, or pouring spouts on most of these containers. In some cases, oper-
ators work from bulk storage tanks.
Large volumes of rinsate are generated from the triple rinsing of disposal containers,
and the rinsing of hoppers and booms. The washing of the outer skin of the aircraft and
other ground support equipment is a problem because such rinsate cannot be used as a dilu-
ent for future spray mixtures.
The average applicator's main base of operation may be located on land which he owns
or may be on rented land, which in some instances may be located on a public airport.
The aerial application of pesticides is a very competitive business. As a conse-
quence, the price charged for this service has not increased over time at a rate equal to
inflation. Payment to the applicator for the services rendered is directly dependent upon
the profitability of the farmer/rancher customer. Historically, the farmers'/ranchers'
lack of profit or narrow profit margin has made it difficult, if not impossible for com-
mercial applicators to pass on any new costs associated with the handling of hazardous
waste.
DISCUSSION
Aerial applicators of pesticides gen-
erate pesticide rinsate when triple rinsing
empty pesticide containers, rinsing air-
craft hoppers and spray booms, washing the
outer surface of the aircraft, and -from
leaks with various couplings and mechanical
appliances. Generating the pesticide rin-
sate and the presence of pesticide leaks
occur under optimum operating conditions
and with properly maintained equipment.
Any substantial expenditures required to
come into compliance with RCRA will cause
a severe financial hardship to aerial ap-
plicators who are only marginally profit-
able due to the depressed farm economy.
An aerial applicator is a businessman
in a highly technical area handling maybe
a hundred toxic pesticide formulations
during a single growing season. In addi-
-1.5-
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tion, an aerial applicator is a pilot who
has refined his flying skills so he is cap-
able of flying at night, around and over
obstacles, at slow speeds extremely close
to the ground. These flying skills are re-
quired in order to insure optimum insect
eradication while simultaneously minimizing
pesticide drift.
I have been an aerial applicator for
35 years. At the present time, the aerial
application firm owned by my partner and me
applies pesticides for approximately 35
growers. On the average, these growers
will have 15,000 acres under cultivation in
any one year. My partner and I would apply
some material to all of this acreage ap-
proximately 10 times each year. These ap-
plications would include seeding, fertiliz-
ing, pre-emergence herbicides, as well as
the application of the entire spectrum of
pesticide chemicals. On the average, I
would log approximately 500 flying hours
per year exclusively doing agricultural
work. In those states with a relatively
short summer growing season, an aerial ap-
plicator would log less flying hours. On
the other hand, other applicators in the
Sunbelt with long growing seasons might log
as much as 700 to 1,000 flying hours per
year doing agricultural work.'
In .my opinion, the average aerial ap-
plication firm in the United States is
comprised of approximately 2 pilots and 2
working aircraft. However, some aerial
application firms have only 1 pilot and 1
aircraft. In a few instances, aerial appli-
cation firms will consist of multiple air-
craft and multiple pilots. Some firms may
maintain additional back-up aircraft.
In the Sunbelt, an average aerial
application firm during a representative
spraying season would repetitively apply
pesticides to approximately 140,000 acres.
This would require the utilization of ap-
proximately 50,000 gallons of pesticides.
This would result in the generation of 4,400
pesticide containers each year. However,
the magnitude of the problem becomes more
self-evident when one realizes that in a
state such as Arizona there are approxi-
mately 70 aerial application firms, each
generating 4,400 pesticide containers a
year. Therefore, the total number of pest-
icide containers generated in Arizona per
year is approximately 308,000. In addi-
tion, each application firm will generate
hundreds of empty containers which previ-
ously held anti-drift agents, buffer solu-
tions, Surfactants, and adjuvants.
Most aerial applicators have no con-
trol over the size, shape, and composition
of the pesticide containers with which they
work. Pesticide containers are composed of
glass, plastic, metal and paper. Pesticide
containers range in size from one quart,
one gallon, 2 gallon, 2-1/2 gallons, 5 gal-
lons, 30 gallons, and 55 gallons. The ma-
jority of the glass containers are one gal-
lon. It is extremely difficult to triple
rinse all of these containers since some
aerial applicators empty the containers
into their hoppers at locations extremely
distant from their base of operations where
no source of rinse water exists. Any ef-
fort to mechanize this rinsing operation
becomes extremely difficult due to the
varying size, shape and container construc-
tion. The triple rinsing of these contain-
ers as required by federal regulations re-
sults in the generation of a substantial
amount of rinsate.
Additional sources of large volumes of
pesticide rinsate arise from the rinsing of
aircraft hoppers and spray booms. Flight
safety and maintenance of proper aerodynam-
ics require frequent washing of the outer
skin of the aircraft. Again, this results
in the generation of large volumes of pes-
ticide rinsate. Less frequently, other
ground support equipment must also be
rinsed.
Many applicators make an effort to
utilize pesticide rinsate as a diluent for
future spray mixtures. However, federal
law prohibits cross contamination of pesti-
cides; therefore, reutilization of the
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rinsate is not always possible. Addition-
ally, each pesticide is not registered for
application on all crops and the applica-
tion of a pesticide on a crop for which
there is no federal registration or toler-
ance could result in quarantining and des-
truction of that crop. Therefore, reutili-
zation of pesticide rinsate is not easily
accomplished in all circumstances. Reuti-
lization of pesticide rinsate is impossible
when the rinsate contains hydraulic fluid,
greases, oils, insect parts, and other
foreign matter. This foreign matter would
plug up filter screens and nozzles if an
attempt were made to use it in future spray
mixes.
Other possible sources of contamina-
tion by pesticide solutions are as follows:
1. A failure of dry brakes.
2. Plugging of the filter screen.
3. Leaking of rubber diaphragms in the
spray nozzles.
4. Rupture of loading hoses and rubber
hoses on the aircraft.
5. Failure of hose clamps.
6. Failure of pump seals on the loading
equipment or aircraft.
7. ~ Dripping from triple rinsed containers.
8. Draining from dry brake systems after
the system has been disconnected from
the aircraft.
9. Dripping from the 2" pipe utilized to
transfer pesticides from 30 and 55 gal-
lon containers after the pipe has been
removed from the empty drums.
10. Leaks from aluminum spray booms on the
aircraft.
11. Leaks from plumbing connections and
piping on trailers.
12. Human errors in handling all equipment.
These sources of pesticide leaks can
occur with optimum equipment maintenance and
with the utilization of the best equipment
presently available to aerial applicators.
These pesticide leaks may cause more concern
when the applicator's main base of operation
is located on land which is rented or in
some instances, is a public airport.
The aerial application of pesticides
is a very competitive business. The total
number of acres under active cultivation in
the United States is decreasing each year.
Simultaneously, the number of aerial appli-
cators is decreasing each year. Addition-
ally, farming is not a healthy industry in
the United States. In the past years the
media and, indeed, the movie picture indus-
try have graphically depicted the rising
number of bankruptcies by farmers and fore-
closures on farm mortgages. As a conse-
quence, th.e price charged growers for aeri-
al application services has not increased
with time at a rate equal to inflation. In
general, the cost of operation for an aeri-
al applicator has increased approximately
300% in the past 10 years. However, the
average increase in price charged growers
for aerial application services has been
only approximately 85% during the same time
interval.
Consequently, profitability in the
aerial application industry has been pro-
gressively decreasing. Many aerial appli-
cators are attempting to sell their busi-
nesses. The average age of an aerial ap-
plicator in the United States is progres-
sively increasing. There are very few
young men being attracted to this industry.
Any additional financial burdens placed on
aerial applicators in the form of addition-
al regulations, making capital improvements
to comply with existing hazardous waste
regulations, or the expenditure of large
sums of money to eradicate past contamina-
tion, may be the final determinate as to
whether these businesses will function at a
profit or a loss or, indeed, survive at all.
With respect to the existing hazardous
waste regulations, it is my opinion that
some changes are required to insure ade-
quate food and fiber production for this
nation. Some of the changes which would
achieve this objective are as follows:
1. A reduction in the daily fines levied
on small businessmen, such as aerial appli-
cators , once they are cited for a viola-
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tion;
2. Permit aerial applicators to qualify as
small waste generators by defining that
term as the weight of active ingredient in
the waste rather than the weight of the
total hazardous waste solution;
3. Permit all aerial applicators to have
a grace period to come into compliance with
RCRA so that the cost of compliance can be
spread over many years of operation rather
than a large capital expenditure in a short-
time interval;
4. Delegation by the EPA of inspection and
enforcement activities to those state and
federal agencies who have historically re-
gulated agriculture and aerial applicators
thereby gaining, over many decades, an
extensive knowledge of pesticides and the
agricultural industry.
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PESTICIDE WASTES DISPOSAL:
A GROUND APPLICATOR'S PERSPECTIVE
Stanley Jones
Top Crop Fertilizer, Inc.
Benkelman, Nebraska
ABSTRACT
Commercial ground application of pesticides is a growing business in the United States.
It is economical for the farmer in terms of time and capital expense. Federal and state
authority over pesticide use may also be enhancing the commercial applicator role. In my
state, a single unit of ground equipment may apply pesticides and fertilizer to 25,000
acres of Nebraska farmland annually. This involves as many as 30 pesticide products, of
which five are restricted and 25 are general use.
During a typical work day a single ground rig can apply 20,000 gallons of spray mix,
involving between 250 and 3-,000 gallons/pounds of pesticide concentrate. The average
volume of spray mix applied per acre is 20 gallons. The operation involves two to three
persons on site, including a supply truck with water and chemicals. This work unit will
range as far as 50 miles from the home business location, and may be gone for seven or
more days before returning.
Generation of pesticide waste, i.e., chemical concentrate of spray mix which will no
longer be used as intended, can occur as a result of normal work activity or an accident.
Unused spray mix, residue on equipment exteriors, damaged pesticide containers, equipment
malfunctions, and accidents are all potential sources of pesticide waste. The equipment
and/or facilities used to accumulate and contain pesticide waste is an individual appli-
cator decision. Federal/state statutes and regulations merely tell pesticide applicators
what may not be done with pesticide waste.
DISCUSSION:
The pesticides that I apply are all in-
tended for use on cropland. Soil in the
treatment site can be moved to non-target
areas via vehicle tires, worker boots and
clothing, equipment exteriors, and wind or
water erosion. It seems to me that such
transfers from the target site could be a
technical violation of solid waste dis-
posal regulations and perhaps FIFRA too.
Water is seldom available at spray
sites so I use nurse- rigs to carry water
for preparing spray mix. It takes 200
gallons or more to flush the hopper of a
Big A spray rig. Farmers do not like this
rinsate applied to the crop just treated
because of additional soil compaction. If
the next job site requires a different pest-
icide and the previous pesticide was not
labelled for use on the second crop, stor-
age of the rinsate becomes a serious hand-
ling problem.
Commercial and private applicators
need assistance in developing affordable
and nationally approved methods for hand-
ling and/or disposing of pesticide wastes.
Such methods should be acceptable for time
periods of sufficient duration to offset
initial and continuing expense.
How much can a pesticide applica-
tor afford to spend on proper handling
and disposal of hazardous waste? This
question is unanswerable until we know
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what will be approved. Many applicators
who tried to anticipate what would be ac-
ceptable already have wasted thousands of
dollars. . Compliance with the law and the
regulations cannot occur until all ques-
tions are answered.
Also, remember that whatever becomes
required will be needed by commercial and
private applicators alike. Both user groups
work over the same aquifers and near the
same rivers, lakes, streams, etc. Condi-
tions at the pesticide storage and mix-
load sites are relatively common. Spills
and container disposal that occurred in the
1950"s or last month all have the potential
for creating a detectable pesticide pres-
ence in a non-target site.
Obviously, the best way to avoid the
problem is to eliminate the generation of
waste. Failing that, instead of hauling
waste all over the country to approved dis-
posal sites, perhaps industry could develop
soil and spray tank additives that would
neutralize such wastes. Soda ash, lime, and
activated charcoal may be an easy solution
to some of our current problems.
As we all strive to reduce waste gene-
ration, perhaps a moritorium should be
declared on enforcement activities to every-
one. Perhaps existing laws and regulations
should be amended for the same reason.
Today, there are too many regulatory
groups addressing the same problem. A sin-
gle waste generator may be compelled to deal
with a Department of Health, a drinking
water agency, a Department of Environmental
Affairs, the Department of Agriculture, the
Department of Transportation, and other sub-
divisions of government at both state and
federal levels. Our business is agricul-
ture. Maybe everyone who wants to tell us
how to run our businesses should coordinate
their needs through the Department of Agri-
culture. We have worked within the USDA
system for years. They know us and our work
and we know who to call for help. Let's
consolidate everyone's need all in one
place.
Finally, let's meet again one year from
now. Let's find out if you were able
to solve some of our problems and
whether or not we as applicators were
able to reduce the amount of waste
generated and handled in a better man-
ner.
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PESTICIDE WASTES DISPOSAL:
A PRIVATE APPLICATOR'S PERSPECTIVE
James Mergen
Illinois Farm Bureau
Bloomington, Illinois
The scope of the "on the farm"
disposal problem fits into the following
parameters:
On the positive side—of 100,000
farming operations in Illinois, no fatali-
ties have resulted from farmer application
or disposal of agricultural chemicals in
the past five years.
Of these 100,000 operations, an
average of two complaints are filed per
year due to improper fanner activities
such as dumping chemicals or washing out a
sprayer tank along a stream resulting in
fish kills.
Five to six complaints per year arise
from improper disposal of chemical containers,
On the negative side—a study found
that approximately 40 percent of farm
wells in Illinois suffer from some form of
contamination. While this contaminaion
arose mainly from bacterial sources due to
improperly capped wells; in a significant
number of cases, pesticides were found.
The primary source of these pesticides
were considered by the researchers to be
from chemical mixing and disposal opera-
tions at the well.
Also a simple visual inspection of
most farmsteads will produce at least
one example of improper chemical disposal
from a dead patch of grass in the yard to
empty chemical containers in the tool
shed.
The Illinois EPA ranks farm chemical
disposal problems it perceives as: 1)
disposal of obsolete or frozen product, 2)
disposal of tank rinsates, and 3) disposal
of chemical containers.
This presentation is aimed at pesti-
cide users who generate or transport a
hazardous waste and who must comply with
federal hazardous waste management stand-
ards. The purpose is to give these people
a basic understanding of the regulatory
requirements and enforcement ramifications.
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FEDERAL REGULATION OF PESTICIDE DISPOSAL
Raymond F. Krueger
U.S. Environmental Protection Agency
Hazard Evaluation Division
Office of Pesticide Programs
Washington, D.C. 20460
ABSTRACT
There are many questions about the regulation of pesticide disposal in the minds of
pesticide users. Considerable confusion exists about the EPA regulation of pesticide
disposal. To further complicate the issue, State laws have become increasingly stringent
and prevail in many cases. One reason for all of this uncertainty is the lack of a clear
understanding of the two Federal laws administered by EPA. The laws are the Federal
Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Resource Conservation and
Recovery Act (RCRA). Regulations promulgated under these two legislative acts, particu-
larly RCRA, are quite comprehensive and in a state of continual change. Each of the two
laws have a place in the overall system of regulating pesticide disposal. The objective
of this discussion is not so much to present an in-depth discussion of the regulations on
pesticide disposal but to introduce the pesticide user to those parts of FIFRA and RCRA
relating to management of pesticide-containing wastes that might be generated in the
course of using pesticides. Therefore, only the key issues will be addressed.
FEDERAL INSECTICIDE, FUNGICIDE, AND
RODENTICIDE ACT
Pesticides were first regulated in
1910, pre-dating Federal regulation of food
for human consumption by several years.
Comprehensive regulation of pesticide use
did not occur until the Congress passed the
Federal Insecticide, Fungicide, and Rodent-
icide Act of 1947. Until passage of the
1972 amendments, little or no attention was
given to the problem of safe disposal.
Prior to the 1972 amendments the main con-
cern was an accurate label statement.
Given the interest in protecting the envi-
ronment shown in the I ate 1960's and 1970's,
the 1972 amendments directed the EPA to
consider the potential effects on the en-
vironment in registering the use of a pest-
icide. These amendments included specific
clauses related to pesticide disposal by
directing the EPA Administrator to publish
regulations and procedures covering the
disposal of pesticide wastes. More recent
amendments require disposal instructions to
be included with any cancellation notices
issued. The basic control of the use of a
pesticide through FIFRA is by way of the
premarket clearance of a proposed use and
the EPA-approved instructions to the user
that appear on the label. Since FIFRA says
it is a violation of Federal law to use a
pesticide in a manner inconsistent with
its labeling, compliance with the label
directives becomes mandatory. Regulations
that have been issued under the authority
of FIFRA require that disposal statements
appear on the label.
The statements that appear on the
container label generally address disposal
of the container itself. However, infor-
mation on disposal of the formulated prod-
uct is sometimes included. More compre-
hensive advisory information may be supp-
I ied by the producer of the product. EPA
has provided guidance on disposal labeling
to pesticide producers in Pesticide Regis-
tration Notice: 83-3, (PR Notice 83-3)
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specifying what the disposal statement must
cover. More recently EPA published PR No-
tice 84-1 which up-dates and amends PR
Notice 83-3.
These notices require that all products
bear specific label instructions covering
storage and disposal and that the infor-
mation be grouped together in the "Direc-
tions for Use" portion of the label under
the heading "Storage and Disposal". Al-
though all product labels are required to
have appropriate storage instructions spe-
cific statements are not prescribed. Each
registrant must develop his own statement
considering the factors listed in PR Not-
ices 83-3 and 84-1.
For purposes of disposal labeling,
wastes from pesticide products that are
intended for household use are treated as
non-hazardous wastes by PR Notice 83-3.
Many of the pesticide products that are
intended for use in public areas such as
office buildings, retail stores, hotels,
schools, and hospitals, do not result in
hazardous waste when discarded and will
bear a label statrnent on disposal that is
the same as that which appears on a house-
hold product. However, some of these prod-
ucts are RCRA regulated waste when discard-
ed and are required by PR 83-3 to show a
label statement reflecting that fact. It
must be noted that RCRA does not regulate
household wastes, however, wastes from
hospitals, schools and the like may be
subject to Federal or State hazardous waste
rules. The statement "Do not reuse con-
tainer (bottle, can, bucket). Wrap (con-
tainer) and put in trash" must appear on
all products registered for household use
or other domestic use products that do not
result in a RCRA regulated waste when disc-
arded that are sold in containers of one
gallon or less for liquids (except for
bleach products up to 1-1/2 gallons) and
5 pounds or less for dry material (except
for lawn fertilizer herbicide products up
to 25 pounds). In addition, PR Notice
83-3 provides container disposal statements
for these products based on container type.
The instructions for household/domes-
tic products are based on the determination
that these products, in limited quantities,
do not pose a threat to human health or
the environment. The dilution factor is
so large that small amounts of these rela-
tively non-toxic materials will not create
a hazard. On the other hand, acutely toxic
material of any kind should never be placed
in the trash. To do so could endanger the
workers that collect the trash.
Products that contain active ingred-
ients appearing on the "Acutely Hazardous
Commercial Chemical Products List" (RCRA E
List) or are assigned to Toxicity Category I
on the basis of oral or dermal toxicity,
skin or eye irritation potential, or Toxic-
ity Category I or I I on the basis of acute
inhalation toxicity must bear the following
statement: "Pesticide wastes are acutely
hazardous. Improper disposal of excess
pesticide, spray mixture, or rinsate is a
violation of Federal law. If these wastes
cannot be disposed of by use according to
the label instructions, contact your State
Pesticide or Environmental Control Agency,
or the Hazardous Waste representative at
the nearest EPA Regional Office for guid-
ance." Products on RCRA's Commercial Chem-
ical Products I ist (40 CFR §261 .33(e)) would
be subject of regulation if a generator
produced more that one kilogram or more of
such waste per month. There are exceptions
where much lower levels of these products
are regulated as in the case of products
that contain dioxins.
The labels of all products, except
those intended for household/domestic use,
containing active or inert ingredients that
appear on the "Toxic Commercial Products
List" (RCRA F List) or meet any of the
criteria in RCRA Subpart C, 40 CFR 261 for
a hazardous waste, must bear the same state-
ment. Labels for all other products, except
those intended for household use, must bear
the following pesticide disposal statement:
"Wastes resulting from the use of this pro-
duct may be disposed of on site or at an
approved waste disposal faciIity." Required
container disposal statements are shown in
Table 1.
It should be noted that the terms used
in disussing the RCRA regulations that rel-
ate relate to hazard, such as "Acutely
Hazardous" or "Toxic Commercial Products",
have different meaning from the same terms
used in the FIFRA regulations. The reason
is that different criteria used to estab-
lish the hazard level.
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RCRA
The Resource Conservation and Recovery
Act may appear to be burdensome, complic-
ated, and unnecessary to many pesticide
users. However, when the basic Objectives
of the legislation are considered, the
regulatory system makes good sense. Prot-
ecting human health and the environment
from the insults of mismanaged waste is a
basic need of modern society. The pesticide
user need not be concerned with much of the
regulatory structure, unless he plans to
establish on-site disposal operations.
However, there are some basic requirements
of RCRA that are important to the pesticide
user.
To understand RCRA regulations it is
necessary to start with a definition of
what is regulated. In short, RCRA is int-
ended to regulate the management of all
solid waste. The term "solid waste" means
any waste; I iquid, sludge, dry, or anything
in between that is disposed of, burnt, or
recycled (with several exceptions). A
waste is defined as any material that is
intended to be discarded or has served its
useful purpose, regardless if the material
is to be disposed of, re-used, or recycled.
Since the most stringent regulations are
directed at the control of wastes identi-
fied as "hazardous wastes", it is most
important to the pesticide user to be aware
of the status of any material that becomes
a "solid waste". A solid waste is a hazar-
dous waste if it exhibits any of the chara-
cteristics of a hazardous waste:
(1) ignitabi Iity, (2) corrosivity,
(3) reactivity, and (4) toxicity
(40 CFR §5261.21 261.24), or is listed in
the RCRA regulations (40 CFR 55261.31,
261.32, 261.33). Pesticide wastes are a I so
considered hazardous if they exhibit any of
the following characteristics:
-are solvent based and have a flash
point of less than 60° C,
-are aqueous and have a pH less than
2.0 or greater than 12.5,
-release HCN or H_S upon contact
with acids,
-leach greater than threshold levels
of one or more of the elements
arsenic, barium, cadmium, chromium,
lead, mercury, selenium, and silver
-the pesticides endrin, lindane,
methoxychlor, toxaphene, 2,4-D,
or 2,4 ,5-TP (S i I vex)
Most of the pesticides that are cur-
rently listed on the RCRA "E" or "F" lists
are shown in Table 2. These lists, prepar-
ed in October of 1984, should not be con-
sidered The final word in that they are
under almost continual change. Additional
guidance can be found on the pesticide
product label. Pesticides that meet the
hazardous waste criteria will usually bear
a disposal statement on the label that
reads in part: "Pesticide wastes are acute-
ly hazardous" or "Pesticide wastes are Tox-
ic". In some cases, it may be necessary
to obtain professional technical assistance
in making the determination that a given
material is indeed a hazardous waste. Some
sources of such information are given later
in this paper.
Part of the confusion that arises
from identifying hazardous waste comes from
the way RCRA handles mixtures. For exam-
ple, wastes from pesticide formulations
that contain more than one active ingre-
dient are not currently regulated (there
are exceptions to this that are explained
later). On the other hand, single active
ingredient products that contain pesticides
listed in Table 2 (from the RCRA "E" and
"F" lists) are regulated hazardous wastes
when disposed of unused. Other sources of
regulated wastes containing single ingred-
ient products might be left-over tank mix-
es, empty containers that have not been
rinsed for "E" list wastes or unrinsed
containers with over an inch of chemical
for "F" list wastes, spill residues, or
wash water from cleaning out equipment con-
containing "E" list wastes. However, if
there is more than one active ingredient
in the formulation and if one or even all
of the active ingredients appears on the
"E" or "F" list, then the formulation is
not regulated as a RCRA listed hazardous
waste. There are regulations under de-
velopment that will eventually regulate
mixtures that contain "E" and "F" chemicals
on the basis of toxicity.
Once a waste material has been desig-
nated as RCRA hazardous waste as a single
active ingredient product as discussed ab-
ove, then RCRA has a mixture rule that
prohibits designated or listed wastes from
just being diluted or mixed in order to
dispose of them. This means that mixing
two listed waste streams together will not
exempt the mixture from regulation.
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An exception to the rule that exempts
pesticides that contain more than one ac-
tive ingredient, one of which is listed,
involves the characteristics of the waste.
Even if the pesticide residues are not
RCRA "E" or "F" sole active ingredient
listed wastes, they may be hazardous on
the basis of the following characteristics:
ignitable, corrosive, reactive, or EP toxic
In that case, although there may be more
than one pesticide in the regulated mixture
the rule for mixtures of listed waste does
not apply. The waste is only hazardous as
long as it exhibits the characteristic and
the characteristic may be due to one of the
inert ingredients in the formulation. Of
course, if the generator produces regulated
quantities of pesticides, then the act of
mixing that renders the hazardous waste
non-hazardous is considered treatment.
Treatment is subject to further regulation,
including permitting that covers operating
procedures, inspections, and so on. If a
generator decides to render waste non-haz-
ardous on site, then he must make sure he
understands all the regulations that apply.
In summary, mixing RCRA "E" or "F"
listed wastes that are sole active ingred-
ients will result in a mixture of listed
wastes still subject to regulation. Mixing
characteristic wastes may actually serve
to render the waste non-hazardous, but the
act of mixing may be subject to RCRA regu-
lation.
Mixtures involving a pesticide which
is performing its intended function, such
as fungicide-treated seeds, are not regu-
lated as commercially unused RCRA listed
waste, because the pesticide has already
been applied to serve its intended purpose.
It should be noted that not all pest-
icide-containing wastes are "hazardous was-
tes" regulated by RCRA requirements, but
those that are, should be the focus of
serious attention for the user. There are
regulatory requirements for storage, trans-
portation, treatment, and disposal of all
such wastes along with some severe penalty
in the event of a violation. When a pest-
icide user produces more than the amount
established as a minimum exemption level by
EPA of RCRA regulated waste materials he
becomes subject to appiicable generator and
other RCRA regulations. In the case of
wastes listed in §261 .33(e) of RCRA (the
RCRA E list), the lower limit may be as
little as 1 kilogram per month. The upper
limit currently is 1,000 kilograms per mo-
nth, however, recent congressional amend-
dments to RCRA mandate control at the 100
kilogram per month level. This means that
about 100,000 Small Quantity Generators
(SQGs) of all kinds will come under the
RCRA regulations for some aspects of haz-
ardous waste management. Under RCRA,
generators must meet many special requir-
ements such as notification of hazardous
waste activity, obtaining an EPA ident-
ification number, shipping wastes only by
registered waste haulers that are subject
to hazardous waste regulations, including
the use of the uniform manifest.
The lowering of the SQG exemption
level will take effect in August of 1985,
but the final regulatory program has not
been completed. The 100 kilogram level
will bring many others into the ranks of
the regulated community, including auto
repair and painting shops, printers, eng-
ravers, ceramics producers, dry cleaners
and others. Aerial applicators may find
that their airframe and engine maintenance
shops are also SmaM Quantity Generators.
A training program to inform the newly reg-
ulated SQGs of their responsibilities under
the new rules is a basic part of current
EPA planning. As is always the case, av-
ailable resources will be a governing fac-
tor in determining how extensive such a
program can be.
REGULATION OF USERS OF HOME AND GARDEN OR
DOMESTIC PRODUCTS
Household wastes are not regulated
under RCRA, since they are specifically
excluded (40 CFR 261.4). As is the case
in the use of any pesticide, it is most
important that the user read the label.
The label will provide information on
precautions that must be observed and
directions for disposal of the empty con-
tainer. Because of the small quantities
of residue left after product use and the
generally low toxicity of these kinds of
products, the empty containers, as well as
small amounts of the pesticide materials
themselves, may be wrapped in several
layers of paper, or otherwise packaged and
disposed of in the trash collection. The
purpose of the wrapping or extra packaging
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is to confine the material during compac-
tion so that unnecessary exposure does not
occur. Up to one (1) gallon of liquid
pesticides (1-1/2 gal Ions of disinfectants)
may be safely disposed of in this manner.
The maximum Iimit for dry pesticide mater-
ials is five pounds or in the case of
fertilizers that contain small amounts of
herbicide, 25 pounds. Occasionally, a
homeowner is found to have something I ike a
five gal Ion can of parathion that was given
to him by a well-meaning friend or relative
to "take care of those aphids on the roses"
such materials should never be placed in
the municipal trash collection. For dis-
posal of such toxic material, the homeowner
should seek professional help.
REGULATION OF FARMERS
The use of pesticide products on the
farm can result in the production of wastes
which may be "RCRA" hazardous wastes.
However, a farmer is exempt from the gen-
erator requirements of RCRA provided he
triple-rinses his empty containers or rin-
ses them using a method of equivalent eff-
ectiveness, and disposes of the pesticide
residues on his own farm in manner consis-
tent with the disposal instructions on the
pesticide label (40 CFR262.51). This exem-
ption is quite narrow and quite specific.
What it means is that left over tank mixes
and wash waters can be sprayed over an area
allowed by the label directions, such as
the margins of the field where the product
was used or can be used as make-up water in
the tank mix. It does not mean that a
farmer is allowed to bury or dump waste
pesticides anywhere on his property.
REGULATION OF COMMERCIAL APPLICATORS
Commercial applicators do not enjoy
an exemption as do farmers. All wastes
produced should be evaluated considering
the pesticide material present, asking the
question: "Is this a hazardous waste?" Left
over tank mixes, empty containers that have
not been properly rinsed, unusable prod-
ucts, or wash water from cleaning spray
equipment may be a hazardous waste regulated
under RCRA. Generating more than 100 kilo-
grams per month of regulated wastes will
qualify the applicator as a "generator".
In any event, all hazardous wastes must be
disposed of in a permitted facility, or in
some cases for small quantity generators,
at State-approved municipal or industrial
facilities. On site treatment, storage,
and disposal facilities (such as the fam-
iliar evaporation pond) must have RCRA per-
mits, and the requirements for hazardous
waste permits are extensive. Also consider
that the 100 kilograms per month limit is
reached when one 55-galIon drum is a Iittle
over half full of a hazardous waste. In
addition, disposal of one full drum by
a commercial disposer of hazardous wastes
could cost as much as $3,000. All of this
would appear to present the commercial app-
licator with a difficult, almost hopeless
situation, squarely facing a loss in the
never ending battle of keeping the sale
price of competitive services from being
over taken by the cost of operation and
becoming, by default, a non profit organ-
ization. Happily, the situation is not
hopeless. There are ways of addressing the
problem.
STRATEGIES FOR OPERATING UNDER FEDERAL
REGULATION
First of all, the pesticide user must
learn what pesticide products will result
in wastes regulated as "hazardous wastes"
under RCRA. Wastes that contain any one
of the many pesticide products that, for
one reason or another, are not classed as
"hazardous wastes" are simply non-hazaru$t
solid waste which is also known as "gar-
bage" or "trash". EPA has not as yet seen
fit to regulate this type of waste.
Al I users of pesticides are constantly
reminded to read the label. This is impor-
tant in assuring safe and effective use of
the product, as well as assuring proper
disposal. Users should always be familiar
with the disposal instructions and precau-
tions that appear on the label. In the
case of farmers and homeowners, this is
particularly important. Users of pesti-
cides should make every effort to eliminate
the production of any waste, especially
"hazardous wastes", and there are ways of
doing just that. For example, rinse all
empty containers and add the rinse solution
to the spray mix. This not only eliminates
the concern over disposal of the empty
container as a hazardous waste, but also
saves the user money by utilizing every
-26-
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last drop of what is often a very expensive
material. Liquids from equipment washdown
or container rinses can often be sprayed
out on the target area or on the field
margins. In this case the label directions
for use must be carefully observed. Rinse
and/or wash solutions may be put in tanks
and held for future use as diluents in
spray mixes of products of the same type.
Obviously, care must be exercised to keep
incompatable materials separated. Again,
the label directions can serve as a guide.
Careful management of inventories and tank
m i xes will not on Iy serve to minimize pro-
duct ion of waste, but will also save money.
A Iittle extra care in ordering a pesticide
can often eliminate that half bag or gal Ion
or two left over that can not be used. If
it can not be used, it is a sol id waste.
The same is true of tank mixes. Mix only
what is needed for the job. There is
nothing new here. These strategies have
been around since there have been pesti-
cides. The only thing different is that
eliminating waste has taken on a new mean-
ing.
If it becomes necessary to dispose of
a small quantity of a "hazardous waste",
the services of a commercial hazardous was-
te disposal firm may be required. Unfor-
tunately, the larger commercial operations
are generally not interested in small am-
amounts, especially when the material for
disposal is many miles from the nearest
disposal facility. It may be possible to
arrange for "milk run" pick-ups in conjunc-
tion with other small quantity generators.
Pooling wastes for disposal through local
cooperatives may also be a possibility, as
long as incompatible materials are not com-
bined. Manufacturer/distributor return
services should be explored. Bear in mind
that the local auto repair shop and the
neighborhood dry cleaner may also be SQGs.
Local waste collection sites or transfer
stations might also be considered.
Extensions to the time limit that
generators may hold their waste without a
storage permit have been mandated by Cong-
ress. These extensions raise the present
90 day limit to 180 days and to 270 days
for SQGs shipping their waste over 200
miles. In this way pesticide users with
hazardous wastes will be allowed to acc-
umulate a more economical amount for ship-
ment, if necessary.
The pesticide user should learn what
facilities and services are available in
the local area for the management of hazar-
dous wastes. Information of this kind is
generally available from the agency respon-
sible for enforcement of waste management
regulations for the area.
Many pesticide users are "Certified
Applicators". This title is needed to ob-
tain authorization to buy and to apply
restricted use pesticides. To achieve cer-
tified status, the applicator must learn
how to safely and effectively apply pesti-
cides and demonstrate a knowledge of the
regulations. Now that hazardous waste
disposal is also regulated, the pesticide
user, regardless of certification status,
is well advised to extend his knowledge to
include the regulations that cover storage
and disposal of pesticide wastes in the
local area. Since many States have more
stringent rules than those discussed here,
it is most important to contact the State
or local hazardous waste regulatory agency.
Each EPA Regional Office has a hazardous
waste representative that may be able to
help. Another source of information on
waste management is the RCRA Hot Line.
A trained staff is available to answer a
wide range of questions on the subject.
The Hot Line number is 800-424-9346. For
pesticide users that are also smalI busines-
smen, the EPA Small Business Ombudsman is
available to provide assistance. The SmalI
Business Hot Line telephone number is as
follows: 800-368-5888. There are many
other sources of information such as trade
organizations, cooperatives, and the many
publications available to users of pesti-
cide products.
-27-
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TABLE 1
CONTAINER DISPOSAL STATEMENTS
Container |
Type
Disposal statement
Metal
containers
Triple rinse (or equivalent). Then offer for
recycling or reconditioning, or puncture and
dispose of in a sanitary landfill, or by other
approved State and local procedures.
Plastic
containers
Triple rinse (or equivalent). Then offer for
recycling or reconditioning, or puncture and
dispose of in a sanitary landfill, by incineration
or, if allowed by State and local authorities,
by burning. If burned, stay out of smoke.
Glass
containers
Triple rinse (or equivalent). Then dispose of
in a sanitary landfill, or by other approved
State and local procedures.
Fi ber
drums
with
Iiners
Completely empty liner by shaking and tapping
sides and bottom to loosen clinging particles.
Empty residue into application equipment. Then
dispose of liner in a sanitary landfill or by
incineration if allowed by State and local
authorities.
of in the
If drum cannot
same manner.
be reused , dispose
Paper and
plastic
bags
Completely empty bag into application equipment.
Then dispose of bag in a sanitary landfill, by
incineration or, if allowed by State and local
authorities, by burning. If burned, stay out of
smoke.
Large
compressed
gas
cyIinders
Return empty cylinder for refilling (or similar
word i ng).
I/
Manufacturer may replace this phrase with one indicating
whether and how fiber drum may be reused.
-28-
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TABLE 2
PESTICIDE ACTIVE INGREDIENTS THAT APPEAR ON THE RCRA "ACUTELY HAZARDOUS
COMMERCIAL PRODUCTS" LIST (THE RCRA E LIST)
Acrolein
Aldicarb
Aldrin
AIlyl alcohol
Aluminum phosphide
4-Aminopyrid ine
Arsenic acid
Arsenic pentoxide
Arsenic trioxide
Calcium cyanide
Carbon disulfide
p-ChloroaniIine
Cyanides (soluble cyanide salts)
Cyanogen
2-Cyclohexy1-4,6-d initrophenol
Dieldrin
0,0-Diethyl S-12-ethyIthio)ethy11 phosphorodithioate
(disulfoton, Di-Syston®)
0,0-Diethyl 0-pyrazinyl phosphorothioate (Zinophos®)
Dimethoate
0,0-Dimethyl 0-p-nitrophenyI phosphorothioate
(methyl parathion)
4,6-Dinitro-o-cresol and salts
4,6-Dinitro-o-cyclohexyI phenol
2,4 Dinitrophenol
Dinoseb
Endosulfan
EndothalI
Endri n
Famphur
Fluoroacetamide
Heptachlor
Hydrocyanic acid
Hydrogen cyanide
MethomyI
alpha-Naphthylthiourea (ANTU)
Nicotine and salts
OctamethyIpyrophosphoramide (OM^A, schradan)
Parath ion
PhenyI mercuric acetate (PMA)
Phorate
Potassium cyanide
Propargyl alcohol
-29-
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TABLE 2 RCRA E List (continued)
Sodium azide
Sodium cyanide
Sod i urn fIuoroacetate
Strychnine and salts
0,0,0,0-TetraethyI dithiopyrophosphate (sulfotepp)
Tetraethyl pyrophosphate
Thai Mum sul fate
Thiofanox
Toxaphene
Warfarin
Zinc phosphide
There are currently no inert pesticide ingredients on the RCRA "E" list.
-30-
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TABLE 2
October 1984
PESTICIDES AND INERT PESTICIDE INGREDIENTS CONTAINED ON THE
RCRA " TOXIC COMMERCIAL PRODUCTS LIST (RCRA F LIST)
Active Ingredients
Acetone
Aery Ionitrile
Am i troIe
Benzene
B i s(2-ethyIhexyI)phthaI ate
CacodyIic acid
Carbon tetrachloride
Chloral (hydrate)
Chlordane, technical
Chlorobenzene
4-Chloro-m-cresol
Chloroform
o-Chlorophenol
4-Chloro-o-toluidine hydrochloride
Creosote
Cresylic acid (cresols)
Cyclohexane
Cyclohexanone
DecachIorooctahydro-1 ,3,4-metheno-2H-cyclobutalc,d]-pentaI en-2-one
(Kepone, chlordecone)
1,2-Dibromo-3-chloropropane (DBCP)
Dibutyl phthaI ate
S-2,3-(Dichloroallyl diisopropyIthiocarbamate) (dial I ate, Avadex)
o-Dichlorobenzene
p-D i chIorobenzene
Dichlorodifluoromethane (Freon 12®)
3,5-Dichloro-N-(I,l-dimethyl-2-propynyI) benzamide (pronamide, Kerb®)
Dichloro diphenyl dichloroethane (DDD)
Dichloro diphenyl trichloroethane (DDT)
Dichloroethyl ether
2,4-Dichlorophenoxyacetic, salts and esters (2,4-D)
1,2-Dichloropropane
1 ,3-Dichloropropene (Telone)
Dimethyl phthaI ate
Ep i chIorohydr in (1-chIoro-2,3-epoxypropane)
Ethyl acetate
Ethyl 4,4'-dichlorobenzilate (chlorobenzilate)
Ethylene dibromide (EDB)
Ethylene dichloride
Ethylene oxide
Formaldehyde
Furfural
-31-
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Table 2 RCRA F List (continued)
HexachIorobenzene
HexachIorocycIopentad i ene
Hydrofluoric acid Maleic hydrazide
Isobutyl alcohol Mercury
Lead acetate Methyl alcohol (methanol)
Lindane Methyl bromide
Methyl chloride
2,2'-Methylenebis (3,4,6-trichlorophenol) (hexachlorophene)
Methylene chloride
Methyl ethyl ketone
4-Methyl-2-pentanone (methyl isobutyl ketone)
Naphthalene
Nitrobenzene
p-Nitrophenol
Pentachloroethane
Pentachloronitrobenzene (PCNB)
Pentachlorophenol
Phenol
Phosphorodithioic acid, 0,0-diethyl, methyl ester
Propylene dichloride
Pyridine
Resorcinol
Safrole
Selenium disulf ide
1,2,4,5-TetrachIorobenzene
1,1,2,2-Tetrachloroethane
2,3,4,6-TetrachIorophenoI
Th i ram
Toluene
1 ,1 ,1-Trichloroethane
Tr i chIoroethyIene
TrichloromonofIuoromethane (Freon 11®)
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
2,4,5-Trichlorophenoxyacetic acid (2,4,5-T)
2,4,5-TrichIorophenoxyprop ionic acid (Silvex)
Xylene
-32-
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INERT PESTICIDE INGREDIENTS APPEARING ON THE TOXIC COMMERCIAL
PRODUCTS LIST (RCRA F LIST)
Acetone
Aceton itr iIe
Acetophenone
Aery Iic acid
AniIi ne
Benzene
Chlorobenzene
Chloroform
Cyclohexane
Cyclohexanone
Oichlorodif Iuoromethane (Freon 12®)
Diethyl phthalate
Dimethylamine
Dimethyl phthalate
1 ,4-Dioxane
Ethylene oxide
FormaIdehyde
Formic acid
Isobutyl alcohol
Maleic anhydride
Methyl alcohol (methaneI)
Methyl ethyl ketone
Methyl methacrylate
Naphthalene
Saccharin and salts
Thiourea
To Iuene
1 ,1,1-Trichloroethane
1 ,1,2-Trichloroethane
TrichIoromonofIuoromethane (Freon 11®)
Vinyl chloride
Xylene
-33-
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CALIFORNIA REGULATORY REQUIREMENTS
John Masterman
State of California, Department of Health Services
Sacramento, California
Pesticide wastes disposal is regu-
lated in California by the Department
of Health Services (DHS), the Water
Quality Control Boards (WQCBs), and the
Department of Food and Agriculture (DFA).
DFA regulations establish a generic
performance standard that pesticides
(including wastes) shall not be stored,
handled or disposed of in a manner which
may present a hazard to persons, animals,
food, feed, crops, or property, and
establish specific standards for rinsing
of containers and posting of storage
areas. WQCB regulations require that
waste discharge requirements be obtained
where a discharge or potential discharge
exists which threatens water quality.
These requirements generally consist of
water monitoring programs and design and
construction requirements to prevent any
degradation of water quality. The WQCBs
have the primary responsibility where
water quality is threatened, however, the
DHS is the lead agency with regard to
hazardous waste control and will act to
correct any environmental threat from
hazardous waste. DHS regulations establish
specific construction and operating
standards for hazardous waste handling,
treatment, storage and disposal and
establish criteria for determining whether
or not a waste is hazardous. A waste is
regulated as hazardous if it consists of
or contains a material cited in a regula-
tory list or if it meets specific regula-
tory criteria. The list contains many
pesticides and includes the generic
categories of insecticides, unrinsed
pesticide containers, unwanted or waste
pesticides, and weed killer. Hazardous
wastes generators, treaters, storers,
transporters, and disposers have specific
regulatory requirements which they must
conform to or obtain a variance from. The
DHS, WQCBs, and DFA strive to work closely
together to minimize the potential of
conflicting or duplicative regulations.
The proper management of pesticide wastes
should be a major consideration of pesti-
cide users. The cleanup costs and
potential civil and criminal penalties are
so great that the long term cost of
improper management far exceeds any short
term savings.
-34-
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PESTICIDE DEGRADATION PROPERTIES
Philip C. Kearney, Ralph G. Nash, Charles S. Helling
Pesticide Degradation Laboratory
Agricultural Research Service
Beltsville, Maryland 20705
ABSTRACT
Pesticide waste disposal is a significant problem for the agricultural applicator.
Understanding the properties of the ca. 680 pesticide active ingredients used in Amer-
ican agriculture is useful in developing an effective disposal scheme. In reality, less
than 30 active ingredients make up more than 90% of the pesticides used annually on
approximately 300 million acres of major U.S. field crop acreage. Persistence and
mobility in the environment are two of the most useful properties of a pesticide. These
two properties are especially important when one is considering any form of land dis-
posal system, the most widely used and economical option available to the user.
Persistence increases the probability of movement, although persistent pesticides are
not necessarily mobile. Movement of a waste pesticide by volatilization into air or
leaching through soil into groundwater must be avoided. Therefore, containment and
degradation are important features in the design of any waste treatment facility. Three
additional criteria that must be met by any disposal option for the average user are the
legal, economic, and practical aspects. From an economic standpoint, the technology
that manufacturers of chemicals use to handle large volumes/low concentrations of waste-
water is often too expensive to be feasible for the agricultural applicator. On the
other hand, the cost of pesticide degradation at the user level is small compared with
the astronomical costs associated with cleanup at a waste site. The persistence and
mobility patterns of the most widely used herbicides and insecticides will be considered
in detail, along with some economic aspects of disposal.
INTRODUCTION
In organizing this workshop we agreed
to consider practical approaches to waste
disposal and not to get into complex equa-
tions, sophisticated models, or physical
and chemical constants in selecting a
process. One problem is that there are no
simple constants available for all pesti-
cides that fully apply to all of the op-
tions being considered for waste disposal.
In other words, you can't consult an
encyclopedia to find a universal disposal
constant.
A second problem is the large number
of compounds that make up the pesticide
family. One estimate suggests that there
are 680 pesticide active ingredients cur-
rently used in American agriculture.
Theoretically, any such universal disposal
parameter would have to be developed for
each pesticide. Our problems are simpli-
fied, however, because less than 30 active
ingredients account for more than 90% of
the pesticides used annually.
For evaluating waste disposal meth-
ods, two of the most important practical
properties of a pesticide are its persist-
ence and mobility in the environment.
These properties are especially important
considerations in land disposal, which is
the most widely used and economical option
available to the user. Persistence and
mobility are also important considerations
in spill situations, abandoned waste
sites, or in disposal processes that lead
to incomplete destruction or binding of
the pesticide and its subsequent release
-35-
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in the environment. One possible conse-
quence of a poorly designed disposal proc-
ess is groundwater contamination. For the
groundwater issue, it is also necessary to
understand the persistence and mobility of
the pesticides to be disposed.
Persistence reflects the rate at
which the sum total of all processes
degrade a molecule in the environment, in-
cluding oxidation, reduction, or hydrol-
ysis. Most disposal options are usually
an intensified form of one of these proc-
esses. An understanding of the processes
that affect persistence and mobility of a
pesticide in the environment also gives
some clue as to the possible choice of a
disposal option. For example, most per-
sistent compounds are generally not read-
ily biodegradable; therefore, biological
treatment is not a viable method of dis-
posal. Progress in molecular biology
eventually may provide engineered micro-
organisms capable of metabolizing these
more recalcitrant structures, but gene
manipulation research in our own labo-
ratory suggests that progress here will
be slow and costly. Movement of a waste
pesticide by volatilization into the air
or leaching through soil into groundwater
must be avoided. Therefore, economical
containment and degradation are two
important features in the design of any
waste treatment facility.
PURPOSE
The objective of this paper is to re-
view current knowledge regarding pesticide
persistence and movement and the impact of
these processes on waste disposal. Some
economic consequences of waste disposal
will also be considered. The herbicides
and insecticides most widely used in Amer-
ican agriculture that will be considered
are shown in Table 1.
PERSISTENCE
First, the persistence of these same
20 pesticides and waste disposal will be
considered. Specifically, the effect of
concentration on pesticide persistence in
a land disposal option will be examined.
Bar graphs were developed in a pre-
vious publication (4) to depict the time
required for 90% of added pesticides to
disappear from soil environments. These
graphs dealt with chemical classes of pes-
ticides and were derived from persistence
data available at that time. The data
used to develop these bar graphs come
largely from field studies where normal
TABLE 1. TEN MOST WIDELY USED HERBICIDES AND INSECTICIDES
Herbicides
Insecticides
Common Name
alachlor
atrazine
butyl ate
trifluralin
metolachlor
cyanazine
2,4-D
metribuzin
propanil
bentazon
Trade Name
Lasso
AAtrex
Sutan
Treflan
Dual
Bladex
many
Sencor
Stam
Basagran
Common Name
carbaryl
carbofuran
chlorpyrifos
methyl parathion
parathion
phorate
synthetic pyrethroids
terbufos
toxaphene
chlordane
Trade Name
Sevin
Furadan
Dursban
Penncap
Folidol
Thimet
many
Counter
Alltox
Aspon
-36-
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use patterns prevailed. The graphs were
updated as new data became available and
are presented in Figures 1 and 2 for the
seven leading insecticides and in Figures
3 and 4 for the 10 leading herbicides.
The length of the bars is the estimated
time in days required for 90% of the pes-
ticide to disappear from the soil surface.
Since most forms of land disposal involve
adding the pesticide directly on the soil,
the data in Figures 1, 3, and 4 represent
the time required for loss from the sur-
face. For some uses, pesticides are in-
corporated into the soil and consequently
their persistence patterns would be dif-
ferent from those shown. The upper and
lower bars represent the normal range
within which each pesticide is likely to
dissipate by 90%. This range depends on
soil and climatic conditions. The per-
sistence data come from a large compila-
tion prepared by Nash (5).
Regulatory actions by the U.S. En-
vironmental Protection Agency in the
1970's removed most of the highly persist-
ent chlorinated hydrocarbon insecticides
from the market. Consequently, with the
exception of toxaphene (Alltox), most in-
secticides used currently, methylcarbam-
ates and organophosphates, are biodegrad-
able and disappear rapidly from the soil
environment. In fact, there is now seri-
ous concern that some readily biodegrad-
able compounds like carbofuran (Furadan)
and butyl ate (Sutan) are disappearing so
rapidly that they are failing to control
the target pests (3). Soil situations
that lead to rapid or enhanced metabolism
are termed "problem" soils. The reasons
for the formation of "problem" soils are
complex, but evidence is accumulating that
soil microbial populations responsible for
metabolism of these pesticides cause their
rapid disappearance.
As a general rule, organic herbi-
cides, when used at normal application
rates, do not persist in soils. With the
exception of metribuzin (Sencor) and atra-
zine (AAtrex), most of these herbicides
disappear within the growing season. Some
herbicides, such as butylate (Sutan) and
trifluralin (Treflan), disappear so
rapidly from soil surfaces that they must
be incorporated into the soil. Soil in-
corporation generally increases the per-
sistence of herbicides because it reduces
the effects of volatilization and photo-
decomposition.
Land disposal can lead to problems
when the natural degradative processes are
overwhelmed by massive applications of
pesticides. Generally, persistence of
most pesticides increases as concentra-
tions in soils increase. For example, the
persistence of 2,4-D is between 40 and 75
days when applied at the rate of 1-2 Ib
per acre. This application rate results
in concentrations of about 0.5-1 part per
million (ppm) in the surface 6 inches
(15.2 cm) of soil. At very high concen-
tration of 2,4-D in soil, i.e. 500 ppm or
higher, very little degradation occurred
(7). In an EPA-sponsored study (1), it
was found that the lag time, or the time
required for degradation to begin, was
longer for high concentrations (>50 ppm)
of 2,4-D and methyl parathion than for
lower concentrations. Variables that
influenced the rate of degradation of
2,4-D in these studies included formula-
tion, nutrients, soil type, soil pH, tem-
perature, soil water content, organic mat-
ter, and microbial ecology. Nevertheless,
as concentration of 2,4-D was increased
(from 50, 500, 5,000, and 20,000 ppm) the
time for degradation also increased. The
same trends were observed for methyl
parathion (Penncap). At concentrations of
10,100 ppm, very little technical grade or
formulated methyl parathion was degraded
in two soils after 52 days.
MOVEMENT
The relative downward mobility into
soils of the leading herbicides and insec-
ticides are found in Figures 5 and 6.
Rather than using actual depth measure-
ments, the pesticides are ranked on the
basis of 1 to 10 based on leaching
measurements determined by Helling (2)
primarily from thin-layer chromatograms.
The 10 herbicides are generally more
mobile than the 10 insecticides, with the
possible exception of carbofuran (Fura-
dan). Based on their mobilities, land
disposal without some form of containment
could pose a threat for groundwater con-
tamination. It must be stressed that the
mobility rankings are simply a relative
guideline to Teachability. Many soil and
climatic conditions may affect the actual
mobility. In reality, the degradative
processes shown in Figures 1 through 5 are
also operating on the pesticides. There-
fore, depending on the rate of breakdown,
the amount reaching the water table may be
small or none.
-37-
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Sutan
Treflan
40
Figure 1. Time in days required for 90% dissipation of the herbicides Sutan, Stam,
Treflan, Basagran and Lasso from the soil surface.
(See Table 1 for common names)
2,4-D
Bladex
Sencor
AAtrex
160
200
240
Figure 2. Time in days required for 90% dissipation of the herbicides 1,4-D, Bladex,
Dual, Sencor and AAtrex from the soil surface.
(See Table 1 for common names)
-38-
-------
JDursban
40
240
Figure 3. Time in days required for 90% dissipation of the insecticides Dursban,
Sevin, Thimet, Furadan and Alltox from the soil surface.
(See Table 1 for common names)
Folidol
Counter
240
Figure 4. Time in days required for 9Q% dissipation of the insecticides Folidol and
Counter incorporated in soil.
(See Table 1 for common names)
-39-
-------
SOIL SURFACE
Treflan
Sencor Bladex AAtrex
Dual
Basagran
Figure 5. Relative mobility of ten widely used herbicides based on a scale of
1-10.
SOIL SURFACE
Dursban Alltox Aspon syn.
pyrethroids
Penncap Folidol Thimet Counter
Figure 6. Relative mobility of ten widely used insecticides based on a scale of
1-10.
-40-
-------
Problems associated with mobility
arise when massive amounts of a pesticide
are deposited in a small area, thereby
overwhelming the soil's natural ability to
degrade or bind the pesticide. The exper-
iments of Davidson et al. (1) show that
2,4-D mobility increases as the concentra-
tion in soils increases, and movement with
water is virtually nonretarded at 5000
ppm. Due to the greater mobility at
higher concentrations, even relatively
labile pesticides may move in substantial
quantities away from their original dispo-
sal site. The property of mobility or
movement is a very important factor in
designing a waste treatment facility, and
particularly any set of conditions that
increases mobility must be avoided. Any
pretreatment step designed to reduce the
concentration, and thus indirectly to re-
duce persistence and mobility, should be
an important feature in any disposal
option.
ECONOMICS
From the pesticide user's standpoint,
the cost of disposing of a pesticide be-
comes a major consideration. Each of the
options examined in subsequent papers will
consider the cost factor. From a prac-
tical standpoint, cost is also an im-
portant "property" of a pesticide. The
purchase price of pesticides, like most
other items in our economy, has increased
over the last several years.
The sales price, at the manufactur-
er's level, for herbicides, insecticides
fungicides, and all pesticides combined
is shown in Table 2. The retail price to
the user is not as readily available, but
roughly equals twice the manufacturer's
price. One survey of aerial applicators
(8) showed that roughly 10,000 gallons
(37,800L) of wastewater containing 45 Ib
(20 kg) pesticides are generated each year
per plane. Based on the retailer's price
of $7.70/lb, this translates to a loss of
about $350/year. Any operation that
disposes of amounts greater than 45 Ib of
pesticides per year should re-examine
projected use levels to reduce this loss.
At the retail price level, this loss can
amount to a substantial sum of money.
A second cost "property" that must
be considered in any disposal option is
the cleanup cost associated with any sites
where problems arise. This cost can be
substantial. One EPA estimate (6) puts
the average cleanup costs at abandoned
sites at several million dollars. The
cost breakdown is about $800,000 to study
the site, $440,000 to design the clean-
up, and $7,200,000 for actual cleanup.
With the recent passage of the RCRA amend-
ments hazardous waste management require-
ments are becoming more stringent. This
is expected to increase the average cost
of remedial actions. To date, 786 sites
are listed or proposed for cleanup of
about 20,000 sites identified.
There are secondary costs associated
with a cleanup operation that may involve
legal fees, containment, and site loss for
future disposal options; these, too, can
be substantial expenses. By comparison to
a cleanup operation, the costs associated
with effective and safe disposal methods
may be nominal.
TABLE 2. INTERNATIONAL TRADE COMMISSION, SYNTHETIC ORGANIC CHEMICALS:
U.S. PRODUCTION AND SALES—1982
Sales of pesticides—Manufacturer's level ($/lb)
Type
Herbicides
Insecticides
Fungicides
All Pesticides
1978
2.78
2.04
1.46
2.34
1979
3.08
2.32
1.77
2.65
1980
3.33
2.50
1.98
2.90
1881
4.02
3.27
2.52
3.60
1982
4.32
3.38
2.73
3.86
-41-
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REFERENCES
1. Davidson, J.M., P.S.C. Rao, L.T. Ou,
W.B. Wheeler, and D.F. Rothwell,
1980. Adsorption, movement, and bio-
logical degradation of large concen-
trations of selected pesticides in
soils. EPA-600/2-80-124. Municipal
Environmental Research Laboratory,
U.S. Environmental Protection Agency,
Cincinnati, Ohio.
2. Helling, Charles S., 1971. Pesticide
mobility in soils I. Parameters of
soil thin-layer chromatography.
Proceedings of the Soil Science
Society of America, pp732-737.
3. Kaufman, D.D. and D.F. Edwards, 1983.
Pesticide/microbe interaction effects
on persistence of pesticides in soil.
In J. Miyamoto et al., eds., IUPAC
Pesticide Chemistry: Human Welfare
and the Environment. Pergamon Press,
New York, pp!77-182.
4. Kearney, P.C., R.G. Nash, and A.R.
Isensee, 1969. Persistence of pes-
ticide residues in soils. In M.W.
Miller and G.C. Berg, eds., Chemical
Fallout: Current Research on Persist-
ent Pesticides. Charles C. Thomas,
Springfield, Illinois, pp54-67.
5. Nash, R.G. Methods for estimating
pesticide dissipation from soils. Jji
D.G. DeCoursey, ed., Small Watershed
Model. Vol. 3. Unpub.
6. Office of Emergency and Remedial
Response, U.S. Environmental Protec-
tion Agency, 1985.
7. Ou, L.T., J.M. Davidson, and D.F.
Rothwell, 1978. Response of soil
microflora to high 2,4-D concentra-
tions on degradation and carbon diox-
ide evolution in soils. Journal of
Environmental Quality. 7, pp241-246.
8. Seiber, J.N., 1981. Disposal of Pes-
ticide Uastewater—Review, Evaluation
and Recommendations. U.S. Environ-
mental Protection Agency, DER, ORD
Draft report.
-42-
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PHYSICAL TREATMENT OPTIONS
(Removal of Chemicals from Wastewater by
Adsorption, Filtration and/or Coagulation)
John C. Nye
Professor and Head
Agricultural Engineering Department
Louisiana State University Agricultural Center
and
Louisiana State University and ASM College
Baton Rouge, LA 70803
ABSTRACT
A two stage treatment system has been developed to remove pesticides from contami-
nated wastewater. The first step is primary flocculation and sedimentation. The
pesticides in the supernatant can then be adsorbed to activated carbon. The system has
been installed by several commercial pesticide applicators. The major problems that users
have observed are related to: proper flocculation of the wastewater; selection of a small
enough pump to pump the supernatant through the carbon columns; sealing the carbon columns
to avoid leaks when under pressure; and disposal of the accumulated sludge and spent acti-
vated carbon. All of these problems are correctable with proper supervision. It would be
extremely helpful if a commercial company would design and develop the physical equipment
and sell the systems to pesticide applicators.
INTRODUCTION
During the past six years a two stage
physical treatment system has been devel-
oped to remove pesticides from contaminated
wastewater. The complete system is the
result of four studies. The project was
initiated under a USEPA Grant No. R 805
466010. This study (Whittaker, et al.
1982) was conducted to determine the extent
of the problem of pesticide contaminated
wastewater and evaluate alternative treat-
ment means that might be acceptable to
pesticide applicators. As an outgrowth of
this project, K. F. Whittaker(1980) evalu-
ated the effectiveness of activated carbon
for removal of dissolved pesticides from
water. T. J. Ruggieri(1981) then inves-
tigated the use of the two stage treatment
system to remove 5 RPAR or near RPAR
herbicides from a mixed solution of
herbicides in water. This study was
supported by the North Central Regional
Pesticide Impact Assessment Program. The
final study performed by K. L.
Farrell(1984) investigated the feasibility
of encapsulating the two wastes, sludge and
spent activated carbon, in a portland
cement matrix. This study was also sup-
ported by the Pesticide Impact Assessment
Program. This paper summarizes the results
of these four studies and projects the cost
for installing and operating the treatment
system.
PURPOSE
In the late 1970's several aerial
pesticide applicators in Indiana were in
disputes with local airport authorities
regarding the handling of pesticide contam-
inated wastewater. As a result the Indiana
Aeronautics Commission requested assistance
from Purdue University to develop a system
that would prevent ground water pollution
or soil contamination around the areas that
aerial applicators were using for loading
and washing application equipment. A study
was initiated to develop a method for
collecting and treating the contaminated
wastewater. The system was to be simple to
operate and capable of producing an efflu-
-43-
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ent that was free of detectable levels of
pesticides. The system had to be flexible
enough to handle the wide variety of agri-
cultural chemicals currently in use and be
equally applicable to ground applicators as
well as aerial applicators. The final
constraint was that the system must be
economically acceptable.
APPROACH
The first step in the development was
to characterize the wastewater that had to
be treated. Samples were collected from
several pesticide applicators during the
course of the various research projects and
the results were so dependent on the chem-
icals being applied and the techniques that
were used to clean the application equip-
ment that it is difficult to present any
meaningful results except that any system
that is developed to treat the pesticide
contaminated wastewater must be capable of
handling a wide variety of concentrations.
The variability in concentration and
quantities of wastewater to be treated
required that a system be developed that
would not be sensitive to these factors.
Since evaporation ponds and soil-gravel
degradation pits were under investigation
at other sites, a physical separation
system was investigated. Particle size
filtering systems were tested and were
found to be either ineffective or of
inadequate capacity to be useful in
treating the wastewater.
Flocculation was then tested and found
to be very effective. Alum, hydroxide
coagulation and ferric chloride were eval-
uated as flocculents. Many other floccu-
lent aids are available and should be
considered by any applicator that installs
this system. Alum was found to be effec-
tive on the wastewater samples that we
studied. An anionic polymer (Watcon 1245)
was added to enhance settling. Alum
concentrations of from 200 to 500 mg/L and
polymer concentration of ,4mL/L were used
throughout the study. Jar tests were
performed prior to treatment to select the
alum concentration for use.
After the wastewater was flocculated
and allowed to settle, the supernatant was
pumped through activated carbon columns.
Filtrasorb 300 (Calgon Corporation) was
used for carbon column with a surface
loading rate of 1.5 gallons per minute per
square foot of surface area and a 15 minute
residence time. The initial carbon columns
were made out of water softener columns.
The resin was removed from these columns
and they were filled with activated carbon.
The system was used in the agricul-
tural engineering department's agricultural
waste management lab on the Purdue Univer-
sity campus for one year. Samples were
hauled to the lab in a 250 gallon tank
mounted in the back of a pickup truck. The
wastewater was pumped from the tank into
four 100 gallon flocculation tanks. A
variable speed mixer was used to mix the
flocculent and polymer with the wastewater.
The treated wastewater was analyzed for
pesticide concentration. In addition to
the field samples that were treated,
synthetic wastewater solutions were
prepared containing malathion, carbaryl and
metribuzin.
The system was then mounted in an 8 x
10 trailer and pulled to an applicator's
loading pad at Monon, Indiana for field
test. The mobile system consisted of two
100 gallon flocculation tanks and two
carbon columns. The system would treat 1
gallon per minute. A smaller system was
constructed using four 4-inch diameter by
4-foot long carbon columns constructed of
PVC pipe. The smaller unit would handle
0.2 gallons per minute.
Following the initial feasibility
study, Whlttaker(1980) investigated the
adsorption of 30 classes of pesticides on
activated carbon in isotherm and column
studies.
Ruggieri(1981) then investigated the
feasibility of using the entire system,
flocculation and activated carbon columns,
for removal of a mixture of alachlor,
dinoseb, trifluralin, paraquat and 2,4-D
from wastewater.
During the conduct of the various
projects about 5000 gallons of wastewater
were treated. As a result about 50 gallons
of sludge had accumulated. This sludge was
used in a study by Farrell(1984) on the
feasibility of encapsulating the sludge
with portland cement.
The four studies combine to form a
feasibility analysis of a complete system
for handling the pesticide contaminated
wastewater that is produced by agricultural
-44-
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TABLE 1. SUMMARY OF ADSORPTION ISOTHERM STUBIES(WHITTAKER, 1980)
Compound
Name
Propham
Propanil
Linuron
Propachlor
Fluometuron
Cycloate
Metolachlor
Metribuzin
Prometone
Ametryne
Cynazine
Diazinon
Fensulfothion
Methylparathion
Carbaryl
Carbofuran
Dinoseb
2,4-D
Naptalam
Diphenamid
Monocrotophos
Phorate
Oxycarboxin
Methomyl
CDAA
Bentazon
Malathion
Diquat
Methamidophos
Dalapon
Trade
Name
ChemHoe
Stam
Lorox
Ramrod
Cotoran Lanex
Ro-neet
Dual
Sencor
Pramitol
Evik SOW
Bladex
Basudin
Dasanit
(many)
Sevin
Furadan
Premerge
(many)
Alanap
Enide
Azodrin
Thimate
Plantvax
Lannate
Pandox
Basagran
Cythion
Ortho-Diquat
Monitor
DowPon
Predominant
Chemical Class
Amide
Amide
Urea
Amide
Urea
Amide
Amide
Heterocyclic Amine
Heterocyclic Amine
Heterocyclic Amine
Heterocyclic Amine
Organophosphate
Organophosphate
Organophosphate
Carbamate
Carbamate
Phenolic
Carboxylic Acid
Amide
Amide
Organophosphate
Organophosphate
Amide
Carbamate
Amide
Heterocylic Amide
Organophosphate
Quaternary Nitrogen
Organophosphate
Carboxylic Acid
Molecular Water
Weight Solubility
(mg/L
-------
chemical applicators. The complete system
would require a collection system for
collecting and storing the contaminated
wastewater, the treatment system consist-
ing of at least one flocculation tank and
three activated carbon columns, and a small
cement mixer for mixing the portland
cement, activated the carbon and sludge to
form the encapsulated final product.
PROBLEMS ENCOUNTERED
Flocculation of the wastewater is
essential to the success of this treatment
system. Numerous problems have arisen when
the system was used in other parts of the
country where alum would not form a floe.
Since numerous flocculent aids are avail-
able and this technology is used in many
municipal and industrial water and waste-
water treatment plants one should be able
to find an effective substitute for alum.
It is recommended that the nearest water or
wastewater treatment plant be contacted to
obtain effective flocculent aids for your
locale.
The carbon columns must be used
periodically to prevent bacterial con-
tamination. As a general rule, thumb water
should be pumped through the columns at
least once a week. If the system is going
to be idle for more than a week the columns
should be drained. Bacteria will form a
slim layer over the carbon, preventing the
pesticide molecules from being adsorbed on
to the carbon. If the effluent from the
carbon columns has an odor it will be
necessary to replace the carbon in the
columns.
RESULTS
The initial study produced two consis-
tent results. First the wastewater could
not be easily characterized because it was
highly variable in both concentration of
pesticide and quantity of wastewater. As a
result a very broad based treatment system
had to be employed. Flocculation was
chosen for initial treatment and found to
be very effective in reducing the concen-
tration of the pesticide to its water
solubility.
After treating numerous field produced
samples, it was found that the system could
reduce the concentration of pesticides to
below the detection limits of the Indiana
State Chemist Office's pesticide residue
lab. Since it was difficult to obtain an
accurate estimate of the pesticide concen-
trations and volume of wastewater, it was
impossible to determine the capacity of the
carbon columns used for the initial treat-
ment system. The next two studies were
conducted to determine the capacity of the
activated carbon to remove a variety of
pesticides.
Table 1 presents the isotherm data
collected by Whittaker(1980) to determine
the capacity of carbon for 30 classes of
pesticides. Generally between 100 and 300
mg of pesticides can be adsorbed on to a
gram of carbon. Three compounds, diquat,
methamidophos and dalapon are not readily
adsorbed to activated carbon and the
Langmuir theory cannot be used to compute a
capacity. Generally less than 10 mg of
these three pesticides will be adsorbed on
to one gram of carbon. Diquat can be easily
removed by adding bentonite clay during the
flocculation step. No wastewater that was
made up of predominantly methamidophos and
dalapon has been treated with the system.
TABLE 2. CARBON COLUMN CAPACITY
(Ruggeiri, 1981)
Carbon Capacity
Herbicide
Initial
Breakthrough
(mg/gm)
Maximum
Capacity
(mg/gm)
Dinoseb
Alachlor
2,4-D
125
50
10
250
30
1
No Alachlor was in the effluent.
Table 2 presents the adsorption capa-
city of carbon to remove dinoseb, alachlor
and 2,4-D.(Ruggieri, 1981) The carbon
becomes saturated with 2,4-D first as would
be predicted by the results of Whittaker's
study. Trifluralin and paraquat were
removed during flocculation. This study
showed that the carbon columns would become
saturated with the most soluble and least
adsorbable pesticide compound first.
Carbon requirements would have to be based
on the most difficult pesticide to adsorb.
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TABLE 3. ECAPSULATION OF HERBICIDES
Cement: Herbicide
Sludge: Trifluralin Dinoseb Alachlor
Activated (%) (%) (%)
Carbon
Ratio
3:2:0.10
3:2:0.15
3:2:0.20
3:2:0.40
3:2:0.80
99.7
99.9
99.9
100.
100.
2.5
69.4
69.1
100.
100.
0.0
78.6
66.9
99.8
99.9
Percent of herbicide retained in the
encapsulated samples that were crushed
and subjected to the EPA Extraction
Procedure.
Table 3 presents the results of the
concrete encapsulation study conducted by
Farrell(1984). Concrete cylinders were
constructed by mixing the sludge from the
flocculation procedure with portland cement
and adding varying ratio of powdered acti-
vated carbon. The concrete was placed in
an 8 oz. paper cup and allowed to set for
28 days. The EPA Extraction Procedure was
used to determine the percent of pesticide
encapsulation. The Indiana State Chemist
Office analyzed the samples for dinoseb,
trifluralin, and alachlor. Only 0.1% of
the alachlor leached out of crushed samples
of the concrete when a mixture of 3 parts
cement, 2 parts sludge and 0.8 parts acti-
vated carbon was used. All of the other
two herbicides were retained in the
concrete encapsulate. This technique shows
promise of providing a safe and simple
method of handling the sludge and spent
carbon.
In summary, primary flocculation and
sedimentation followed by activated carbon
adsorption appears to be a feasible means
of handling pesticide contaminated waste-
water. The system has been used on a
variety of pesticide contaminated waste-
waters. Proper flocculation is very
important and it is sometimes necessary to
receive assistance from a distributor of
flocculent aids, such as Nalco Chemical Co.
In test in Indiana, alum dosages of 300-
500 mg/L were effective when used with an
anionic polymer. The sedimentation step
can be accomplished in a 55 gallon drum. A
variable speed mixer is needed to assure
proper flocculation and sedimentation. A
flat blade paddle mixer, about 4x8 inches
attached to the end of a 3 foot rod can be
mounted on a variable speed electric motor
and used as the mixer. The mixer should
have at least 2 speeds. A 100-300 rpm
mixing speed is necessary for mixing the
chemicals for 15 minutes initially, fol-
lowed by a 30 minute slow mix at 5-20 rpm
to build the floe. Since the flocculation
step is critical it is important to use the
most effective polymer available. Persons
interested in installing such a treatment
system should seek advice from a local
water or wastewater treatment plant or a
supplier of flocculent aids to be sure that
the initial flocculation step removes as
much of the pesticides and carriers as
possible. If the wastewater contains
paraquat, bentonite clay should be added
during flocculation.
The translucent supernatant that
remains after the flocculated wastewater is
allowed to settle will contain the dis-
solved pesticides. This liquid should be
pumped through a series of activated carbon
columns, usually 4. PVC or ABS pipe can be
used to construct these columns. Four foot
lengths of four or six inch diameter pipe
will hold enough activated carbon to treat
2000 to 5000 gallons of most wastewater.
The flow rate should be less than 1 gpm/ft
and the contact time should be at least 15
minutes. A pump that will deliver 0.1 to
0.2 gpm at 10 psi pressure should be used
with the 4 or 6 inch diameter columns,
respectively. Under these conditions
approximately .25 grams of pesticide can be
adsorbed on each gram of carbon.
Based on the results to date, a 55
gallon drum of flocculent will treat over
1000 gallons of wastewater. Four 6-inch
diameter, 4-foot long columns will hold
about 200 Ibs. of carbon and will be
capable of handling at least 5000 gallons
of wastewater. The carbon costs about
$1.00 per pound. Total cost of chemicals
for treatment of the wastewater is about
$.20 per gallon. A typical agricultural
chemical applicator would produce 5000
gallons of wastewater per year. The cost
of the mixer and tank would be less than
$1000. The major cost would be the
construction of a collection system to
collect the wash water used to clean the
application equipment.
-47-
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The system produces two hazardous
solid wastes. The sludge that accumulates
from the flocculation and sedimentation and
the spent activated carbon. The sludge can
be reused in the sedimentation step until
the volume of sludge limits the quality of
supernatant. The total volume of pesticide
contaminated waste is substantially
reduced. Approximately 100 gallons of
sludge and 200 pounds of spent activated
carbon will be produced when 5000 gallons
of wastewater is treated.
Using the simple encapsulation process
that has been described in which the sludge
is mixed with powdered activated carbon and
Portland cement, it would be possible to
produce a concrete block that will meet the
EPA Extraction Procedure test and would not
be considered a hazardous waste. The 100
gallons of sludge and 200 pounds of spent
activated carbon produced during the treat-
ment of 5000 gallons of wastewater can be
encapsulated in about 2 cubic yards of
concrete.
The treatment system that has been
developed can be used to remove the pest-
icides from the wastewater that is produced
during cleanup of application equipment.
The equipment is simple to operate and
provides applicators with a realistic
alternative for managing their contaminated
wastewater.
REFERENCES
1. Farrell, K. L. and J. C. Nye, 1984.
Concrete encapsulation of pesticide
contaminated sludge. ASAE paper no.
84-457A. American Society of Agricul-
tural Engineers, St. Joseph, MI, plO.
2. Ruggieri, T. J. 1981. Determination of
the ability of a flocculation/sedimen-
tation/activated carbon treatment plant
to remove herbicides from application
equipment washwater and examination of
the feasibility of bioassays for
determination of activated carbon
exhaustion. MSE thesis. Purdue
University, West Lafayette, IN, p!41.
3. Whittaker, K. F. , 1980. Adsorption of
selected pesticides by activated carbon
using isotherm and continuous flow
column system, Ph. D. thesis, Purdue
University, West Lafayette, IN, p342.
4. Whittaker, K. F., J. C. Nye, R. F.
Wukasch, R. G. Squires, A. C. York and
H. A. Kazimier, 1982. Collection and
treatment of wastewater generated by
pesticide applicators, PB 82-255 365,
Oil and Hazardous Materials Spills
Branch, MERL-Cincinnati, USEPA, Edison,
NJ, p98.
ACKNOWLEDGEMENTS
The author would like to acknowledge
the financial support provided for these
studies by the United States Environmental
Protection Agency and the North Central Re-
gional Pesticide Impact Assessment Program.
Three graduate students, T.J. Ruggieri,
K.F. Whittaker, and K.L. Farrell conducted
research and wrote theses on various seg-
ments of the entire system. Their work
combined to provide the technical basis for
the recommendations presented in this
paper.
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A Practical System to Treat Pesticide-Laden Wastewater
William H. Dennis, Jr., Sc.D.
Box 51, Braddock Heights, MD 21714
ABSTRACT
A treatment system based on recirculation of pesticide-contaminated wastewater
through a bed of granular activated carbon is described. Testing demonstrated that
a mixture of seven pesticides could be removed from 400 gallons of water with 45 Ib
of granular carbon. The most challenging test purified 400 gallons of water contain-
ing of 100 PPM of each pesticide. The process has a mathematical basis and thereby
predictable. The system is inexpensive and simple to operate? the spent carbon has
a very low leach rate.
INTRODUCTION:
Businesses supporting agricultural
production such as small farmers and ae-
rial pesticide applicators have need of
a pesticide waste disposal process that
is simple to use, effective for a wide
variety of pesticides and herbicides and
inexpensive. Such a system was developed
for use by the US Army and installed at
Ft. Eustis, VA in 1981. At that time it
was clear that this system had a direct
application to any generator of small
volumes of mixed pesticide wastes if the
batch could be confined to a volume below
2000 gallons.
The pest control facility at Ft.
Eustis has a unique waste drainage system
whereby all pesticide wastewater is col-
lected from mixing operations, storage
area spills, container rinsing and wash-
down of dispersal equipment. This waste-
water drains into a sump in the floor of
a waste treatment room adjunct to the main
building. When a sufficient volume is
collected (500 gallons), it is treated to
remove pesticides by recirculation through
activated carbon. When treatment is com-
plete (24 hours), the water is trans-
ferred to a second tank and later used as
a diluent to make fresh pesticide formu-
lations for spray applications.
PURPOSE:
This article will summarize the de-
velopment and testing of an activated
carbon treatment system assembled to re-
move pesticides from water. Detailed in-
formation on system assembly, experimental
methods and test data is available from
other published material (1, 2, 5) and
will not be given here.
APPROACH:
During FY 79-80, research was funded
jointly by the US Army Training and
Doctrine Command and the Environmental
Protection Agency to design, build and
test a system to treat pesticide-laden
wastewater. The system would be based on
adsorption of pesticides by activated car-
bon. The goal was to produce a workable
system under $3,000 (in capital equip-
ment) that would be easy to operate and
maintain, and need little attention during
operation. By August, 1982, this goal was
achieved.
The adsorption of organic chemicals
from water by activated carbon is a well-
known phenomenon. It has broad applica-
tion. The efficacy and low cost of car-
bon adsorption are attested by its common
use in water treatment plants for removal
of color and odor from raw water.
DESCRIPTION:
The treatment system is built around
the CARBOLATOR 35 water purification unit
(6). Figure 1 shows the drawing of the
treatment concept.
-49-
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pesticide-laden
wastewaler
v (gallons)
pump
CARBOLATOR
FIGURE 1. Schematic Drawing of Test
Assembly Used at Fort
Detrick, April, 1981.
The CARBOLATOR 35 is light-weight
and portable, consisting of an 18-gallon
reinforced epoxy tank with an O-ring seal
cover. The granular carbon is held in
two polypropylene bags within the tank.
Wastewater from the holding tank is then
pumped continuously into the bottom of
the CARBOLATOR and upward through the car-
bon bed. The effluent water is returned
to the waste-holding tank. Upward flow
reduces channeling and compaction of the
carbon bed, problems common to a down-
flow configuration. Moreover, the opera-
tion of this recirculation system can be
described mathematically by:
where:
C. = the concentration of pesticide
at any time (minutes) after treatment
begins.
C = the concentration of pesticides
in the wastewater before treatment begins.
q = the flow rate (gallons per
minute) passing through the carbon bed.
v = the volume of water (gallons)
being processed.
t = the time (minutes) in operation.
k = the efficiency constant, or the
fraction of pesticide removed when a unit
volume passes through the carbon bed.
The mathematical basis of this configura-
tion gives the process predictability.
For example, if the concentration of
pesticide is given the value of 1.0 and
the volume of waste is 500 gallons, it is
possible to calculate how long the system
must run in order to reach a desired level.
Let the desired pesticide level be 0.001
and the flow rate through the system be
10 gallons per minute. If we assume a
removal efficiency of 0.5 (k - 0.5), then:
In (Ct/Co) = -kqt/v
In 0.001/1 = -0.5(10)(t)/500
-6.907 = -0.01(t)
t = 691 minutes = 11.5 hours
Of course, dropping from a level of 1 to
0.001 is a 99.9% removal of pesticides in
11.5 hours.
RESULTS:
The first test of the system was
carried out at the US Army Medical Bio-
engineering R&D Lab at Ft. Detrick, MD.
Of three tests performed, the most chal-
lenging to the system involved treatment
of 400 gallons of water containing a mix-
ture of seven different pesticide formu-
lations. The concentration of each pesti-
cide was 100 PPM. During the treatment,
the tank was stirred while wastewater was
pumped at 6.4 gpm through 45 Ib of Calgon
F-300 activated carbon within the CARBO-
LATOR. Stirring was needed to insure
homogeneity of the tank contents, for the
validity of the equation requires homo-
geneity. The decrease of pesticides in
the water was monitored by gas chromato-
graphic analysis. Details of chemical
analysis and complete concentration vs.
time data for all tests are described
elsewhere (2). Table 1 presents an ab-
breviated array of data for the most con-
centrated wastewater.
Table 1. Decrease in Pesticides (PPM)
with time - Ft. Detrick, MD, Feb 1981
PesticideOhr Ihr 2hr 3hr 6hr lOhr 20hr
Baygon
Dimethoate
Diazinon
Ronnel
Malathion
100
100
100
100
100
65
62
54
47
54
(continued -
42
40
46
55
44
30
31
46
44
38
15
16
24
38
19
5
3
7
15
5
0
0
1
2
1
next page)
-50-
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Table 1 - continued:
Pesticides Ohr Ihr 2hr 3hr 6hr lOhr 20hr
Dursban
2,4-D
ester
100
100
59
69
52
54
52
52
32
33
14
20
3
6
As predicted by the equation, all
pesticides decreased with time exponen-
tially. Also, when the measured rate of
decline is compared with the theoretical
decline (where k = 1.0), all pesticides
deviated from the ideal rate of removal.
All showed fractional values of k. At the
100 PPM level Baygon (Propoxur) showed the
highest k value at 0.32 and 2,4-D ester
the lowest with k = 0.16. With a more
dilute waste (20 PPM in each pesticide)
there was greater efficiency in removal.
Again Baygon showed the highest efficiency
(k = 0.82) and 2,4-D ester the lowest
(k = 0.56). In addition to the seven
pesticides listed in Table 1, four
others were briefly examined in bench-
scale (1 gallon) adsorption testes (2,5).
All were removed from water by Calgon F-
300. These were: 2,4-D amine salt (2),
parathion (3), carbaryl (3) and chlordane
(2). The former was removed most
efficiently (k = 1.0 at 100 ppM).
The disposal of spent carbon was also
considered during these first tests.
Landfill disposal of the carbon can be
considered if the carbon can be shown not
to be a hazardous waste as defined by the
EPA. A test has been published by EPA
(4) to measure the degree to which haz-
ardous pollutants leach from a solid
waste. To test the leaching characteris-
tics, the carbon having the highest level
of adsorbed pesticides (that used in the
experiment in Table 1) was subjected to
the leach test. Details of this leach
test are found in the Federal Register
(4) and the description of the procedure
followed and chemical analysis of leachate
have been published (2). Table 2 shows
that after 24 hours contact with water,
a carbon holding 5.4% of its weight in
pesticides yields little of the adsorbed
pollutant.
Table 2. Analysis of aqueous leachate
after exposure of water (pH 5) to Calgon
F-300 holding 5.4% of pesticides - con-
centration of pesticides given as parts
per billion (ppB)<
Pesticide
Dimethoate
Baygon
Ronnel
Malathion
Diazinon
Dursban
2,4-D ester
concentration in leachate
(ppB)
4.0
8.0
0.2
0.3
0.1
0.2
10.0
Following three sucessful tests with
a prepared waste under ideal conditions,
the treatment system was taken to Ft.
Eustis, VA for testing with wastewater
from actual operations. This waste was
found to have a large amount of sus-
pended solids. To trap the grit, a ten
micron cartridge filter was added to the
treatment line (placed between the pump
and the CARBOLATOR). Figure 2 shows a
schematic drawing of the final assembly
installed at Ft. Eustis. Tables 3 and 4
present the removal of pesticides from
Ft. Eustis wastewater as a function of
operation time. The rates of removal
found with the Ft. Eustis waste were
similar to those observed in the Ft.
Detrick tests.
Table 3. Decrease in pesticide conc-
entration (ppM) with time, Ft. Eustis, VA,
July 1981, 600 gallons wastewater at 6.1
gpm through 30 Ib Calgon F-300 carbon.
Pesticide Ohr 2hr 3hr 5hr Thr 24hr
Dimethoate 48 31 23 9 4 0
Malathion 34 18 15 2 0 0
Baygon 2.5 1.4 0.8 0.5 0.2 0
Diazinon 0.5 0.5 0.5 0.6 0
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Figure 2. Schematic drawing of system for treating water contaminated with
pesticides. A \ HP pump (P) passes water through a cartridge filter and into bottom of
CAKBOLATOR (C). Part of the flow is diverted through line LI to maintain homogeneity of
tank contents. Carbon treated effluent passes back into tank through line L2 for
recirculation.
Table 4. Decrease in pesticide
concentration (ppM) with time, Ft.
Eustis, VA, Sept 1981, 410 gallons at
6.0 gpm, 40 Ib Calgon F-300.
Pesticide Ohr Ihr 3hr 5hr lOhr 20hr
Malathion
Baygon
Dursban
Dimethoate
Diazinon
2,4 -D
82
41
19
17
10
6
7
31
15
13
7
5
0
14
8
6
4
4
0
6
5
3
2
2
0
0.
2
0
0.
0.
5
1
1
0
0
0.
0
0
0.
3
1
By the summer of 1982, the final
configuration (Figure 2) was set and
testing completed. The system was turned
over for use by the pest control opera-
tors at Ft. Eustis. Since that time the
system has remained in use and similar
systems have been (or will be) installed
at nine other Army pest control facili-
ties (7).
PROBLEMS:
A. Employing k-values
Caution is advised in using k
values to predict how long to operate
the system in order to achieve a certain
degree of pesticide removal. A sys-
tematic variation in all operational
parameters was not done and the value of
k for a different set of parameters
would be uncertain. Efficiency of pest-
icide removal will be influenced by the
following factors:
1. Configuration
Channeling can occur in the carbon
bed causing poor contact between the
water and granular carbon. Careful
placement of the bags of carbon in the
CARBOLATOR will give good contact, thus
giving a higher value of k.
2. Carbon Loading
At a given flow rate, the water
will contact more carbon in a larger
carbon bed. Since k is actually the
fraction of pesticide removed when
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a unit volume passes through a bed, a
larger carbon bed will give a larger
value of k.
3. Pesticide Concentration
As stated above, when flow, volume
and carbon bed are held constant, effi-
ciency increases with decreasing pesti-
cide concentration in the waste.
4. Carbon Type
In all testing described (1,2,5),
only Calgon F-300 activated carbon was
employed. It is likely that other carbon
types would show varying efficiencies.
B. Effluent Analyses
Although this system removes pesti-
cides from water and is simple to operate,
the time needed to atain a specific
degree of removal remains uncertain. To
insure the absence of pesticides in the
effluent, a simple chemical test would be
beneficial. During the Ft. Eustis opera-
tions, a simple method for analyzing the
effluent was devised. This technique was
thin-layer chromatography, TLC (2).
Briefly, an aliquot of water is extracted
with an organic solvent and a portion of
the extract placed on a small glass plate
coated with silica gel. To each side of
the spot is placed a solution containing
the pesticides known to be in the waste.
The plate is then placed into a jar con-
taining sufficient solvent to immerse
several millimeters of the plate below
the area of sample application. When the
solvent has risen (by capillary action)
about 10 cm, the silica gel plate is re-
moved, dried and is sprayed with a re-
agent that reacts chemically with the
pesticides to produce a visible spot.
Any spots present in the sample are com-
pared with those in the standard mixture.
This gives a qualitative analysis of the
effluent water and allows the operator
to judge the degree of pesticide re-
moval achieved. Glassware and materials
to perform TLC are quite inexpensive and
readily available. Although the analysis
is best carried out by a chemist, the
pest control operators at Ft. Eustis
were trained in the use of the TLC
technique.
C. Lack of Operational Data
Some operational data is available
for the removal of seven pesticides from
wastewater. However, variation in the
parameters of flow, carbon loading, car-
bon type, waste volume and waste concen-
tration are very limited. The pesticides
studied reflect those in use at Army
facilities and not those common to agri-
culture. Indeed, further work is needed
to assess this method of water treatment
for waters contaminated with pesticides
and herbicides that are in widespread use
by farmers and aerial applicators.
REFERENCES:
1. Dennis, W.H. and E.A. Kobylinski,
1983. Pesticide-laden Wastewater Treat-
ment for Small Waste Generators, Environ.
Sci. & Health, B18, pp 317-331.
2. Dennis, W.H., A.B. Rosencrance, T.M.
Trybus, C.W.R. Wade and E.R. Kobylinski,
Treatment of Pesticide-laden Wastewaters
From Army Pest Control Facilities by
Activated Carbon Filtration Using the
CARBOLATOR Treatment System, US Army
Medical Bioengineering R&D Laboratory,
Technical Report 3203, Aug 1983, AD
Al38399.
3. Dennis, W.H., Laboratory Notebooks,
unpublished data, 1979-1982.
4. Federal Register, Rules and Regula-
tions, Vol. 45 No. 98, May 19, 1980.
5. Kobylinski, E.A., W.H. Dennis and
A.B. Rosencrance, 1984, "Treatment of
Pesticide-laden Wastewater by Recircu-
lation Through Activated Carbon", in
Treatment and Disposal of Pesticide
Wastes, ed. R.F. Krueger and J.N. Seiber,
ACS Symposium Series 259, ACS, Washing-
ton, D.C.
6. Sethco MFC Corp., Freeport, NY
Bulletin 451.
11520
7. Spencer, B., HQ-TRADOC, Ft. Monroe,
VA, Personal communications, Feb 1985.
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PESTICIDE WASTEWATER DISPOSAL: BIOLOGICAL METHODS
Arthur L. Craigmill and Wray L. Winterlin
University of California Cooperative Extension and Environmental Toxicology
Davis, CA 95616
The potential of microorganisms to metabolize pesticides is well documented. In-
deed, biological treatment has been used industrially to treat pesticide manufacturing
wastes. Mlcroblal metabolism of pesticides is an integral part of many disposal sys-
tems, particularly those that use soil as a component. A brief review of the types of
pesticides degraded by soil microbes, and the metabolic reactions and microbes involved
will be presented as background for the discussion of available biological disposal
methods. Most of the methods that will be described have a limited use on a large-scale
basis and due to their complexity, would not be economically feasible on a small scale.
Examples of these effective but costly systems are activated sludge treatment systems
and trickling filter systems. Two systems that have utilized a combination of evapora-
tion beds and soil will also be discussed with relation to the contribution of biologi-
cal pesticide degradation. Other biological systems that are still under experimental
development (e.g., enzymatic methods) will also be discussed. In general, biological
methods are effective for the detoxification of most types of pesticide waste, but due
to regulatory constraints may not have applications for small scale pesticide waste
generators. Biological methods may be quite useful in the clean-up of currently
existing pesticide waste disposal sites. An example of a situation of this type in
California will be presented.
INTRODUCTION:
I would like to address pesticide
waste disposal from two perspectives.
The first is the need of applicators to
find reasonable, inexpensive and en-
vironmentally safe methods to deal with
current and future dilute pesticide
solution (DPS) disposal. The second is
the need for applicators and regulatory
agencies to find reasonable, inexpensive
and environmentally safe methods to
clean up sites used for pesticide appli-
cator waste disposal in the past that do
not conform to current regulatory
specifications.
The focus of this presentation will
be on the biological treatment of dilute
pesticide solutions which we will
define as solutions of pesticides that
are below the concentrations usually
applied in agriculture. The main source
of this type of wastewater would be from
rinsing and washing down application
equipment as well as disposing of unused
solutions. Pesticide container disposal,
which will be covered in a presentation
later today, is another possible source
of DPS.
One point I would like to make is
that we consider DPS to be a special
category of hazardous waste and that as
such, DPS should receive a different
regulatory treatment than other hazardous
wastes. Most contemporary pesticides are
now designed to breakdown naturally in
the environment into less toxic
materials, and this fact should be taken
into account when considering how DPS
should be regulated.
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BIOLOGICALDEGRADATION
OF PESTICIDES
Dr. Kearney has already presented
an overview of pesticide degradation
properties, and I would like to expand
on it a bit to cover biological pesti-
cide degradation. We will define bio-
logical pesticide degradation as the
chemical breakdown of pesticides
mediated by microorganisms, plants and
subcellular systems (such as enzymes)
that have originated from living cells.
The metabolism of pesticides by soil
microorganisms is one of the major
routes of .pa pesticide degradation
after agricultural pesticide
application. Microbial pesticide
degradation can take place in two ways,
as a result of co-metabolism, or with
the pesticide used as a carbon source
for the microbes involved. Co-
metabolism occurs when the pesticide is
metabolized by the organism, but the
products of the metabolism are not
incorporated into the organism. When a
pesticide is used as a carbon source for
an organism, it might be considered as a
nutrient since the products of
metabolism are incorporated into the
chemical structure of the organism
(proteins, carbohydrates, etc).
The most important reactions that
occur in biological degradation include
oxidation, reduction, and hydrolysis.
The result of these reactions are meta-
bolites that are generally more water
soluble than the parent compound, and
that are also less toxic. In many cases
the metabolites may be further meta-
bolized and the ultimate end products
are carbon dioxide, water, and salts.
Some of the many factors that influence
biological pesticide degradation in
soils are soil type, organic matter
content, degree of hydration, tempera-
ture, types of microbes present, numbers
of microbes present, pH, and oxygen
level. I also should mention that
chemical insult can influence biological
activity particularly at high concentra-
tions. In general, microbial metabolism
is best in soils that are warm, moist,
well oxygenated, and which have lots of
organic matter. It is also important to
recognize that soils may become accli-
mated to pesticide use and the microbes
induced to metabolize pesticides faster
than after the first application. This
results in a more rapid removal of the
pesticide from the soil.
Biological pesticide degradation is
very dependent on the pesticide involved.
For example, the organophosphates,
carbamates, and pyrethroids are much more
readily metabolized by microbes under
aerobic conditions than are the
organochlorine insecticides. However
even DDT and toxaphene are susceptible to
microbial metabolism under anaerobic
conditions. The chlorinated phenoxy
herbicides for example are quite
susceptible to biological degradation
whereas paraquat is quite resistant to
metabolism by microbes.
Some work that has been underway at
Davis and which will soon be reported by
Schoen and Winterlin has shown that pest-
icide degradation is greatly influenced
by concentration, organic matter, and the
amount of moisture in the soil medium,
not to mention other factors such as pH,
soil type, etc. Many of these factors
influence the type of microbial activity
which in turn effects the degradation
process. One of the more interesting
facets of this study was the discovery
that there is no one factor that is best
for all pesticides or even within a
classification of pesticides. The condi-
tions that may be optimum for one pesti-
cide may or may not be for another.
Therefore the more degradation processes
that can be incorporated into the DPS
disposal process, the more effective it
will be in degrading mixtures of pesti-
cides. If one can incorporate aerobic
and anaerobic conditions, as well as
organic matter and other treatments and
amendments, it is possible to enhance
microbial degradation of pesticide mix-
tures in DPS. I will now present some
systems that have been used in the past
or that are presently in operation, and
which incorporate biological methods for
enhancing the degradation of pesticides
and pesticide manufacturing wastes.
INDUSTRIALPESTICIDE
WASTE DISPOSAL
The individuals who were first faced
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with the problems of pesticide waste
disposal were the manufacturers, and
they have developed the technologies to
a very .sophisticated level. The best
documented biological, industrial pesti-
cide disposal techniques are those used
for treatment of organophosphate manu-
facturing wastes. In 1966 Coley and
Stutz described the development of an
activated sludge treatment system for
organophosphate manufacturing waste for
Monsanto. An activated sludge system is
composed of a concentrated biomass which
is supplied with nutrients and oxygen in
order to promote the most efficient use
of the waste by the microorganisms
(Figure 1). Their first experiment was
conducted at a city sewage treatment
plant under an agreement that specified
that if Monsanto could prove that the
parathion wastes and domestic wastes
could be adequately treated together,
the city would accept the parathion
waste for treatment. This was the case
but when Monsanto expanded its opera-
tions, the city treatment plant could
not handle the additional load and Mon-
santo developed its own activated sludge
treatment facility. The system developed
by Monsanto included some preliminary
treatments to neutralize acidity and the
addition of chlorine to control odor
(Figure 2). After a 7-10 day treatment
period which was found to be necessary
for complete destruction of parathion
and paranitrophenol, the sludge was
allowed to settle, and the treated
effluent was discharged into the city
sewer system. The sludge was then re-
circulated and remixed with new para-
thion waste.
The Monsanto system requires inten-
sive management due to the high degree
of biotoxicity of the parathion waste.
Samples were taken as often as every
four hours to monitor the status of the
system and adjust the inflow of the
waste so as not to shock the activated
sludge.
In 1968 Lue-Hing and Brady
described a system designed for Chemagro
Corporation. This activated sludge
system was designed to degrade a mixture
of organophosphates such as guthion,
meta-systox, coumaphos, and fenthion.
The final design utilized a first-stage
activated sludge process to absorb some
of the shock that this waste had on the
microbes, and a second stage activated
sludge process for the ultimate degrada-
tion (Figure 3). The authors noted the
sensitivity of the activated sludge
system to heavy loads of waste, and that
it took at least 30 days for the system
to become acclimated to the waste when
the system was first used.
In 1969, Howe mentioned the
development of a biological treatment
method for trifluralin, but did not
disclose any details of the system.
Atkins (1972) performed a survey for EPA
and reported that a trickling filter and
activated sludge process was used
successfully for the treatment of 2,4-D
waste. The trickling filter is a system
composed of a deep bed filled with stones
(or other suitable media) 2-4 inches in
diameter (Figure 4). Wastewater is
dripped over the bed and air flows up
through the bed from the bottom.
Biological slimes attach themselves to
the surface of the rocks and utilize the
waste as they trickle over the stones.
As the slime layer builds up, it
eventually sloughs off (Figure 5). The
trickling filter can handle large pulse
loads of toxics because the contact time
is short. Thus a toxic pulse may kill
off the surface layer of the slime, but
the lower layers survive to utilize the
waste. This makes the trickling filter a
good pretreatment device for biologically
degradable toxic wastes. Atkins (1972)
also discussed the use of aerated lagoons
and simple stabilization ponds for
treatment of pesticide wastes. These two
methods, while somewhat effective, are
also quite slow and thus not much
utilized by industry.
These two "industrial strength"
pesticide waste treatment methods are
excellent examples of the efficiency of
biological processes for treating certain
hazardous wastes. They are
environmentally safe hazardous material
treatment methods and as such are regu-
lated as treatment facilities. The
principle advantage of these systems is
their efficiency in almost completely
degrading different types of pesticides
and that waste can be treated on site,
with little left over material for
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landfill disposal or incineration.
There are numerous disadvantages to
these systems when viewed through the
eyes of a small waste generator. They
require considerable monitoring and
testing to insure proper operation, they
take up a fair amount of space, and they
are expensive to build and maintain. In
1979, SCS Engineers prepared a report
for EPA on the disposal of DPS that
included cost estimates for activated
sludge and trickling filter systems.
Their estimates are based on 225 days of
operation per year and a volume of 450
gallons of waste per day. Their esti-
mates are shown in Figure 6. It is
readily apparent that these systems are
costly to build and maintain. In addi-
tion, there is no information available
as to their effectiveness when used to
treat complex mixtures of different
classes of pesticides.
CONSUMERORIENTED
PESTICIDE DISPOSAL SYSTEMS
I will now discuss two different
but similar systems currently in use at
University field stations, one in Iowa
and the other in California. Both of
these systems contain soil as one of the
components and thus biological pesticide
degradation is involved in processing
waste in both of these systems. The
Iowa State University system is a con-
crete pit 0.9 meters deep at one end,
1.2 meters deep at the other and is 8.8
m long and 3.7 m wide (Figure 7). It
has a movable cover to prevent entry of
rainwater and the system has been used
for pesticide disposal for over 12
years. The pit is stratified and the top
and bottom layers consist of 4 cm
diameter gravel, and the middle layer
consists of topsoil. A complete
description of the system and the
studies performed on it was published by
Hall et al. in 1981. Pesticide wastes
enter by rinsing out tanks directly into
the disposal pit. This results in an
uneven loading of pesticide wastes into
the pit which may be advantageous if the
concentration of pesticide in the waste-
water is very high.
The pit has been used for the dis-
posal of chlorinated hydrocarbons, or-
ganophosphates, carbamates, triazines and
others. Hall (1984) reported that this
pit has received over 50 kg of 40
different pesticides since it began
operation (Figure 8). Hall et al. (1981)
reported that there has not been
significant accumulation of any pesticide
in the pit, that it has not leaked, that
microbes flourish in the soil and water,
and that it has been highly successful as
a disposal facility for DPS. Johnson and
Hartman, (1980) have published the
results of the microbiological studies
carried out on this disposal facility.
They reported that there was substantial
biological activity in the pit based on
the fluctuation of the numbers of
bacteria in the pit during the study.
They also found that bacterial isolates
from the pit would grow on filter-
sterilized pit liquid. They concluded
that this data is strong indirect
evidence that the bacteria are involved
in the metabolism of pesticides in the
pit, particularly when all other
processes of degradation are taken into
consideration.
The University of California
Experiment Stations have installed evap-
otranspiration inspired systems at field
stations throughout California. These
systems are lined beds to which the
wastewater is introduced through per-
forated pipes which lie under gravel on
the bottom of the bed (Figure 9). The
gravel is covered by from 10 to 20 inches
of topsoil. Pesticide wastewaters are
collected from equipment washpads, passed
through a sedimentation box, and then
directed into a distribution box where
the liquid is passed into the bed leach
lines. At two sites, the liquid is stored
in tanks, and then metered into the beds.
The ideal situation is to keep the top
layer of soil moist but not flooded, and
thus promote evaporation. This is not
always the case since the beds are
sometimes overfilled during peak seasonal
use, or the storage tanks often fill and
are emptied into the beds faster than
evaporation can occur. This may not be
detrimental since this process results in
both aerobic and anaerobic conditions
that are important when a broad spectrum
of pesticides are introduced into the
system.
-57-
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These beds have been in operation
for 4 to 8 years and in 1981 we under-
took a study to determine their
effectiveness and environmental safety.
Results of these extensive studies have
shown that the beds will function well
if operated properly. The highest
levels of pesticide are found in the top
1 inch of the soil due to mass transport
of the pesticides to the surface which
is sometimes referred to as the
"wicking" effect. Several of the beds
have had lime incorporated into the soil
in order to provide a basic environment
which is conducive to chemical hydroly-
sis of organophosphates, carbamates, and
certain other pesticides.
Schoen in her recent work with one of
the California evaporation beds
incorporated 2" diameter open ended PVC
tubes into the beds. The tubes which
were 12" long were inserted into the
beds in each of four quadrants in such a
manner as to have the tubes in contact
with the underlying gravel. The tubes
were packed with a silt loam soil which
had been amended with acid or base to
give a pH of 4, 7.2, and 10
respectively. The tubes were then
removed periodically and analyzed for 5
detectable pesticides. Each column of
soil removed from the tube was divided
into three segments, 0-1", 1-6" and 6-
12". Results from this study showed
mass transport of the pesticides with
time to the soil surface, and although
degradation was attributed to hydrolysis
in a few cases the primary cause of
degradation appeared to be microbial.
Even though this particular study was
conducted in the cool northern regions
of California, microbial degradation was
effective in reducing the concentration
by approximately 66% in 16 months and
90% or more after 24 months in all three
pH adjusted soils.
Both of the systems just described
appear to be quite effective and envi-
ronmentally safe. Current technology
(and regulations) make it advisable that
lined bed disposal facilities should
have a means for detecting whether leaks
have developed, and these features could
easily be incorporated into these
systems. California regulations
currently require pesticide disposal
beds to have double liners, and a means
of detecting leakage of the top liner.
Technically, both of these systems are
hazardous waste treatment facilities,
which makes them subject to considerable
regulatory constraints. These con-
straints may be indeed the biggest dis-
advantage of these systems because on the
whole, they are economical and require
little maintenance or chemical sampling.
Both of the systems also act as
evaporation beds, and research is
currently underway at the University of
California Davis to find means to enhance
the evaporation capacity of the UC
disposal beds. Estimates of the costs of
these systems, as calculated by SCS
Engineers in 1979, and based on 225 days
of operation per year and 450 gallons of
waste per day are shown in Figure 10.
CURRENT
RESEARCH AREAS
Composting:
The effects of composting on pesti-
cide degradation is also being explored
as a practical method of disposal or
detoxification. In 1981, Seiber et al.
reported on the effects of composting
cotton gin trash on residue levels of
sodium chlorate, methidathion, omite, DEF
and paraquat. They found that sodium
chlorate levels of greater than 400 ppm
could be reduced to undetectable levels
in 5 weeks by aerobic composting, and in
8 weeks by anaerobic composting of cotton
gin trash. Methidathion levels of 2 ppm
were reduced to undetectable levels in 5
weeks by either aerobic or anaerobic
composting. Omite levels of about 3 ppm
were reduced to undetectable levels in 8
weeks, and to 1.2 ppm in 8 weeks by
aerobic and anaerobic composting
respectively. Aerobic composting reduced
DEF levels of 45 ppm to 10 ppm in 8
weeks. Composting of cotton gin trash
that had low DEF residues of about 1.3
ppm did not result in lower DEF levels
after 8 weeks. Composting did not have
any effect on paraquat levels in cotton
gin trash.
Arndt et al. (1981) described a
study in which they examined the effects
of composting garbage on parathion de-
gradation. They could not find any
-58-
-------
metabolites of parathion after seven
days of composting and concluded that
composting was not effective in de-
grading parathion.
In contrast, Dr. Don Mullins and
associates at Virginia Polytechnic
Institute have been experimenting with
the effects of composting on diazinon
and chlordane. Dr. Mullins graciously
supplied me with a copy of an in press
manuscript of their work for inclusion
in this discussion. He will also be
presenting a poster presentation of his
work during this workshop. In their
work they used a bench-top system for
composting dairy cow manure and sawdust
and added radio labelled diazinon and
chlordane to the compost media to
achieve concentrations of 100 pmm. The
compost was incubated for three weeks
and then analyzed. They found that
approximately 15% of the diazinon was
lost due to volatilization, and that the
remaining radioactivity in the soil was
not associated with diazinon, but a
hydrolysis product IMHP (2-isopropyl-A-
me thyl-6-hydro xy py rimi dine). The loss
of chlordane from the compost was
approximately 50% through volatiliza-
tion, and there was virtually no
measurable metabolism.
Dr. Mullins also informed me that
they have performed some field studies
using peat amended with ground corn as
the compost media, and that this com-
bination is very effective in degrading
very high concentrations of diazinon.
This area of research should provide
some very useful data in the future, and
due to the low cost of the ingredients,
would be economically feasible for small
operators.
Enzymatic Methods:
Munnecke (1976 and 1980) described
his efforts to degrade organophosphate
pesticides using enzymatic systems de-
rived from mixed bacterial cultures
grown on parathion as the sole source of
energy and carbon. He found that his
crude cell extracts and crude enzyme
extracts when added to solutions of
various organophosphates, promoted hy-
drolysis of the pesticides at a faster
rate than chemical hydrolysis. While the
hydrolysis of organophosphates is not a
complete detoxification, it does provide
a significant reduction in toxicity.
Honeycutt et al. (1984) utilized
parathion hydrolase purified by Dr.
Munnecke in further studies on the de-
gradation of high concentrations of
diazinon in soil. Their studies simu-
lated situations in which spills of
diazinon would result in localized, high
concentrations of pesticide in the soil.
They found that parathion hydrolase was
very effective in promoting the hydroly-
sis of diazinon at levels as high as 5000
ppm. They found that the enzyme
preparation hydrolyzed diazinon several
times faster than a chemical hydrolysis
method using sodium hydroxide. Their
results indicate that this enzyme pre-
paration may indeed have a practical use
as a method for rapidly detoxifying
spills of organophosphate pesticides.
Microbial Acclimation and Genetic
Engineering:
Microbes can be acclimated to
utilize pesticides as a carbon source by
growing them in increasingly higher
concentrations of pesticide. This has
been done for 2,4-dichlorophenoxyacetic
acid and 2,4-dichlorophenol (Tyler and
Finn, 1974), DDT (Francis et al. 1976)
and parathion (Daughton and Hsieh, 1977).
The focus of this research has been to
acclimate the microbes so that they can
tolerate extremely high levels of the
pesticide and thus be useful in treating
concentrated waste such as pesticide
spills. One limitation of this research
is that it usually has focused on a
single pesticide rather than mixtures of
pesticides. Theoretically, a low level
acclimatization of this type should take
place in disposal facilities like the
Iowa State University and University of
California systems.
Another promising area of research
is the genetic engineering of bacteria to
degrade organic pollutants. One aspect
of genetic engineering involves the
transfer of plasmids from one bacteria
species to another. Plasmids are small,
extrachromosomal, closed DNA molecules
that can replicate. Plasmids usually
-59-
-------
code for a special function such as
antibiotic resistance, or chemical
degradation. Pseudo monas species,
commonly found in soils, have been most
extensively examined for degradative
plasmids and at least 8 have been found
so far (Quensen and Matsumura, 1984).
These plasmids may be passed from one
bacteria to another naturally, or
"engineered" into another bacteria.
Quensen and Matsumura (1984) have
recently shown that the chemical de-
gradative capacity of one Bacillus
species can be transferred partially to
another Bacillus species. This area of
research could well lead to the develop-
ment of bacteria that would have the
capacity to metabolize many different
pesticides and that would be useful in
the treatment of pesticide wastes.
CLEANUP OF PESTICIDE
DISPOSAL SITES
The last area that I would like to
address this afternoon is the detoxifi-
cation of existing pesticide waste dis-
posal sites that may be a hazard to the
environment. Our involvement in this
began in September of 1980 with the
discovery of such a site at a county
airport that had been used by an aerial
applicator for over 10 years. During
that time equipment washwater and unused
spray solution had been washed into the
airport drainage system which emptied
into an eight foot deep ditch and
holding pond over four hundred feet
long. Figure 11 shows the results of
analysis of samples taken at the mouth
of the outlet pipe into the ditch. The
California Department of Health Services
and Regional Water Quality Control Board
mandated the cleanup of this site and we
were contacted by the county to find a
realistic method to accomplish this.
After considerable sampling to establish
that the site was not currently
contaminating local groundwater, and
negotiation with state regulatory
agencies, we began an experimental on-
site detoxification test that continues
to this day.
The first step in the detoxifica-
tion was the addition of lime to promote
the breakdown of the organophosphates
which were considered to be the most
acute hazard. The second step was the
establishment of a test plot to study the
breakdown of toxaphene, the most
persistent pesticide found there. A
three year study conducted by Mirsatari,
1978, had shown that toxaphene was very
resistant to aerobic degradation even in
organic matter amended non-sterilized
soils. In non-sterilized, organic matter
amended soil under anaerobic conditions
(or flooding) degradation was 80%
effective in a matter of seven weeks.
Soils which had been autoclaved and
amended with organic matter did not
degrade toxaphene to any measurable
extent nor did soils not amended with
organic matter. Therefore, based in
large part on the Masatari study, it was
decided to amend the contaminated test
plot with cow manure followed by roto-
tilling, flooding, and covering the area
with polyethylene plastic to promote
anaerobic conditions which had been shown
to be conducive to toxaphene metabolism.
The results of the test plot studies is
shown in Figure 12.
Based on the results of this field
trial, the entire ditch was amended with
manure prior to the winter rainy season.
Monitoring wells were drilled to check
for groundwater contamination and none
has been found at any time over the last
four years. The results of this decon-
tamination procedure have been compli-
cated by the fact that the pipes draining
the airport are quite long (about 100
yards) and continue to bring pesticide
waste into the ditch each rainy season.
We can say without reservation that the
treatment process has not promoted
movement of pesticide into groundwater,
and has contributed to the biological
metabolism of toxaphene (based on
capillary column GLC analysis). We will
begin trials at another similar but more
controlled site later this year. With
further refinement, this procedure may be
a very effective, safe and inexpensive
alternative to the all too common
practice of soil removal to a hazardous
waste disposal landfill.
CONCLUSIONS
Biological methods of pesticide
waste detoxification are effective and
may provide for the complete detoxifica-
-60-
-------
tion of pesticide waste. The activated
sludge and trickling filter processes
used by industry, while practical for
manufacturing operations, are not
practical alternatives for the small
generator because of the intensive
management they require. The disposal
beds used by Iowa State University and
the University of California both appear
to be effective, safe methods of pesti-
cide waste disposal. These systems
incorporate biological, chemical and
evaporation processes into an integrated
system. The regulatory constraints on
these systems may be the biggest
hindrance to their use since they are
technologically and economically
feasible. The composting procedure
being investigated at VPI holds promise
for the future as do enzymatic methods
of detoxification and genetic
engineering.
More is known of the environmental
fate of pesticides than any other class
of chemicals. This wealth of informa-
tion makes it possible to design systems
for the detoxification of pesticide"
wastes that take advantage of the
susceptibility of these chemicals to
degradation. Biological pesticide de-
toxification methods offer a variety of
techniques that can be used in the over-
all process. Because of the diversity
of chemicals in use as pesticides, it is
very unlikely that any one method of
degradation will be able to handle all
types of waste. By combining chemical,
biological, and physical treatments it
should be possible to develop pesticide
waste disposal systems that can fill all
needs.
From a practical point of view,
more laboratory and field research must
be done to integrate all of the disposal
technologies currently available into
economical and environmentally safe
methods of DPS disposal. All parties
involved in pesticide use, industry,
state and federal government agencies
and commercial users should contribute
to this research effort if it is to be
successful.
REFERENCES:
Arndt, W.; Schindlbeck, E.; Parlar, H.
and Korte, F. Behavior of Organo-
phosphorus Insecticides in Garbage and
Waste Composting (Degradation, Environ-
mental Contamination). Chemosphere
12(9): 1035-1040, 1981.
Atkins, P.R. "The Pesticide
Manufacturing Industry - Current Waste
Treatments and Disposal Practices." U.S.
Environmental Protection Agency, 12020,
Jan. 1972.
Coley, G. and Stutz, C.N. Treatment of
Parathion Wastes and other Organics.
Journal WPCF, pg. 1345-1349, August 1966.
Daughton, C.G. and Hsieh, D.P.H.
Accelerated Parathion Degradation in Soil
by Inoculation with Para thion-Utiliz ing
Bacteria. Bull. Environ m. Contain.
Toxicol. 18(l);48-56, 1977.
Doyle, R.C.; Kaufman, D.D. and Burt, G.W.
Effect of Dairy Manure and Sewage Sludge
on C-Pesticide Degradation in Soil. J^
Agric. Food Chem. 26(4):987-999, 1978.
Francis, A. J.; Spanggord, R.J.; Ouchi,
G.I.; Bramhall, R. and Bohon, N. Met-
abolism of DDT Analogues by a Pseudomonas
sp. Appl. Environ. Microbiol. 32:213-
216, August 1976.
Hall, C.V. et al. "Safe Disposal Methods
for Agricultural Pesticide Wastes." U.S.
Environmental Protection Agency, EPA
600/2-81-074, May 1981.
Hall, C.V. Pesticide Waste Disposal in
Agriculture in "Treatment and Disposal of
Pesticide Wastes"; Krueger, R.F.; Seiber,
J.N., Eds.; American Chemical Society,
Washington, D.C., 1984; Chap. 3.
Honeycutt, R.; Ballantine, L.; LeBaron,
H.; Paulson, D.; Seim, V.; Ganz, C. and
Milad, G. Degradation of High Concentra-
tions of a Phosphorothioic Ester by
Hydrolase in "Treatment and Disposal of
Pesticide Wastes"; Krueger, R.F.; Seiber,
J.N., Eds.; American Chemical Society,
Washington, D.C., 1984; Chap. 20.
Howe, R.H.L. Toxic Wastes Degradation
and Disposal. Process Biochemistry, pg.
25-28, 37, April 1969.
-61-
-------
Johnson, L.M. and Hartman P.A. Micro-
biology of a Pesticide Disposal Pit.
Bull. Environm. Contain. Toxicol. 25:448-
455, 1980.
Junk, G.A. and Richard, J.J. Pesticide
Disposal Sites: Sampling and Analysis in
"Treatment and Disposal of Pesticide
Wastes"; Krueger, R.F.; Seiber, J.N.,
Eds.; American Chemical Society,
Washington, D.C., 1984; Chap. 5.
Klein, S.A.; Jenkins, D.; Wagenet, R.J.;
Biggar, J.W. and Yang, M-S. "An Evalua-
tion of the Accumulation, Translocation,
and Degradation of Pesticides at Land
Wastewater Disposal Sites." U.S. Army
Medical Research and Development
Command, Washington, D.C. National
Technical Information Service AD/A-
006551, Nov. 1974.
Lue-Hing, C. and Brady, S.D. Biological
Treatment of Organic Phosphorus
Pesticide Waste-Waters. Purdue Univ.
Eng. Ext. Ser. 132 (pts. 1/2): 1166-11 77,
1968.
Mirsatari, S.G. Some Characteristics of
Toxaphene Residues on Foliage and in
Soil and Sediment. Ph.D. Thesis
Abstract, University of California,
Davis, 1978
Montgomery, M.L.; Klein, D.; Goulding,
R. and Freed, V.H. Biological
Degradation of Pesticide Wastes.
Pesticide Chemistry; Proceedings 6:117-
125, 1972.
Munnecke, D.M. Chemical, Physical, and
Biological Methods for the Disposal and
Detoxification of Pesticides. Residue
Reviews _70:l-26, 1979.
Munnecke, D.M. Enzymatic Detoxification
of Waste Organophosphate Pesticides. J.
Agric. Food Chem. 28( 1);105-111, Jan/Feb
1980.
Petruska, J.A.; Mullins, D.E.; Young,
R.W. and Collins, E.R., Jr. A Benchtop
System for Evaluation of Pesticide
Disposal by Composting. Nuclear and
Chemical Waste Management. In press.
Quensen, J.F., III and Matsumura, F.
Transfer of Degradative Capabilities:
Bacillus megaterium to Bacillus subtilis
by Plasmid Transfer Techniques in Evapo-
ration Beds in "Treatment and Disposal of
Pesticide Wastes"; Krueger, R.F.; Seiber,
J.N., Eds.; American Chemical Society,
Washington, D.C., 1984; Chap. 19.
SCS Engineers, Long Beach, CA. "Disposal
of Dilute Pesticide Solutions." U.S.
Environmental Protection Agency, EPA/SW-
174c, 1979.
Seiber, J.N.; Winterlin, W.W.; McChesney,
M. and Roati, S.B. Behavior of Chemical
Residues during Screening, Composting and
Soil Incorporation of Cotton Gin Wastes.
Proceedings of Gin Waste Utilization,
Roundup and Tour, University of
California Cooperative Extension,
Hanford-Kings County, Feb. 5, 1981.
Stojanovic, B.J.; Kennedy, M.V. and
Shuman, F.L., Jr. Edaphic Aspects of the
Disposal of Unused Pesticides, Pesticide
Wastes, and Pesticide Containers. J.
Environ. Quality 1(1); 54-62, 1972.
Tyler, J.E. and Finn, R.K. Growth Rates
of a Pseudomonad on 2,4-Dichlorophenoxy-
acetic Acid and 2,4-Dichlorophenol.
Appl. Microbiol. 28(2):181-184, August
1974.
Winterlin, W.L.; Schoen, S.R. and Mourer,
C.R. Disposal of Pesticide Wastes in
Lined Evaporation Beds in "Treatment and
Disposal of Pesticide Wastes"; Krueger,
R.F.; Seiber, J.N., Eds.; American
Chemical Society, Washington, D.C., 1984;
Chap. 6.
Munnecke, D.M. Enzymatic Hydrolysis of
Organophosphate Insecticides, a Possible
Pesticide Disposal Method. Applied
Environ. Microbiol. _32_( 1 ): 7-13, July
1976.
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INFLUENT
AERATION TANK
SLUDGE RETURN
CLARIFIER
EFFLUENT
INFLUENT
t t L
i r
EFFLUENT
RETURN SLUDGE
Figure 1. Activated Sludge System (Taken from SCS Engineers, Long Beach,
CA. "Disposal of Dilute Pesticide Solutions." U.S.
Environmental Protection Agency, EPA/SW-174c, 1979.)
-63-
-------
V-Notch Weir &
Mixing Chamber
Supplementary
Organic Feed
(Trout Food)
Nutrients
Plant
Domestic
Sewage
Modified Activated
Sludge Process
' Biological
I Aeration Tank Final
Clarifier
~l
pH Adjust
Aerated
Lagoon
City Water
Primary
Clarifier
Final
Effluent
Figure 2. Monsanto activated sludge system for biodegradation of paration
manufacturing wastes. ( Taken from Lue-Hing, C. and Brady, S.D.
Biological Treatment of Organic Phosphorus Pesticide Waste-
Waters. Purdue Univ. Eng. Ext. Ser. 132 (pts. 1/2): 1166-11 77,
1968.)
Primary Activated Final
Settling sludge Process Settling
Main
Waste Stream
Final pH
Adjust PS
Chemical Feed
Pre-settling
AcM Wastes
Excess Sludge
'Sludge
Oewatering
Equipment Room [ Lab
Sludge
for Disposal
Pilot Plant Pre-treat
Figure 3. Chemagro Corporation activated sludge system for biodegradation
of a mixture of organophosphate manufacturing wastes. ( Taken
from Lue-Hing, C. and Brady, S.D. Biological Treatment of
Organic Phosphorus Pesticide Waste-Waters. Purdue Univ. Eng.
Ext. Ser. 132 (pts. 1/2): 1166-1177, 1968.)
-64-
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FILTER ROCK
FILTER WALLS
UNDER DRAINS
CTl
O1
I
DISTRIBUTION ARMS
AND NOZZLES
EFFLUENT CHANNEL
INFLUENT PIPE
Figure 4. Trickling filter system. (Taken from SCS Engineers, Long Beach,
CA. "Disposal of Dilute Pesticide Solutions." U.S.
Environmental Protection Agency, EPA/SW-174c, 1979.)
-------
AEROBIC
ANAEROBIC
BIOLOGICAL
SLIME LAYER
-'•• •"•"•: 4',:x$
Figure 5. Biological slimes in a trickling filter system. (Taken from SCS
Engineers, Long Beach, CA. "Disposal of Dilute Pesticide
Solutions." U.S. Environmental Protection Agency, EPA/SW-174c,
1979.)
-66-
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BIOLOGICAL TREATMENT COST ESTIMATES*
Basis for Calculation
1.7 m3 (450 gal)/day
385 m3 (102,000 gal)/yr
225 operating days/yr
Capital Costs
Activated Sludge
Holding tank $1,750
Pump 600
Reaction tank 4,500
Aeration pump system 1,500
Sludge recirculation 2,500
system
Pretreatment system 8,300
Piping 1,750
Fencing 700
Total $21,600
Trickling Filter
$1,750
600
Trickling filter 4,000
Recirculation system 2,500
2,500
8,300
1,750
700
$19,600
Yearly Operating Costs
Monitoring
Electricity
Checmicals
Labor (1,000 hr G> $12/hr)
Fixed charges (25% of
capital cost)
Sludge disposal
Total
Operating cost per m3 ~
per gal -
$600
300
1,200
12,000
5,400
1,500
$21,000
$54.54
$0.20
$600
300
1,200
12,000
4,900
750
$19,750
$51.30
$0.19
* Equipment and operating cost are based on Menas Building Construction
Cost Data 1978.
Figure 6. Cost estimates for activated sludge and trickling filter
systems. (Taken from SCS Engineers, Long Beach, CA. "Disposal
of Dilute Pesticide Solutions." U.S. Environmental Protection
Agency, EPA/SW-174c, 1979.)
-67-
-------
8" CAST IRON CAPPED SAMPLMG RISER
'\-'>'-'v-'''.-'•';-'-'.;o'.-:;:V:-V:'--V"vt
'-^ - ^•'^'•,,-el^jT'a''"'!' J^'*^' 7" r /S^ — — " ^ ''' --•''-'•---
I
01
00
1 H
1
^n
i —
-in
01
2' 10 1/2"
I
I
Pj
^ WATER OUTLET -J
h*
i
=
* 4'5"
L
•*
i
RELOCATED n
1" CONDUIT-3
^- SAMPLING
RISER
I
*
_
—
_
»
K
}
^ RELOCATED 11/4" SUMP PUMP DISCHARGE
' 10"
I n
{ I
o'rv'.'
* l
uT^-ijr^^
III:
ill
l — — n i —
5 Hi 6-0" -l"^
III — III i
IH= i
CD
e'o"1"-^
in -
in
12"CONC.-7
r PIER
— 1»
-.
2'0" ~'":
= Ui
III
(b)
Figure 7. Cross-section of Iowa State University pesticide waste disposal
bed. ( Taken from Hall, C.V. et al. "Safe Disposal Methods for
Agricultural Pesticide Wastes." U.S. Environmental Protection
Agency, EPA 600/2-81-074, May 1981.)
-------
Compound
Compound
A1 achl or
Atrazine
Azinphos methyl
Benomyl
Bensulide
Butral in
Captan
Carbaryl
Chlorothalonil
Chloroxuron
Citcop
2,4-D
2,4-DB
DCPA (Dacthal)
Diathane M-22, M-45, and Z-78
Dicamba
Dichl obenil
Diphenamid
Endosulfan I and II
EPTC (Eptam)
Ethyl pa rat ion
Folpet
Glyph osate
Guthion
Heptachlor
Hexachlorobenzene
Kel thane
Lannate
Malathion
Mancozeb
Ma neb
MCPP
Methomyl
Methoxychlor
Metribuzin
Naptalam
Omite
Paraquat di chloride
Penoxalin
Phosmet
Polyram
Propachlor
Simazine
Sulphur
Trifluralin
Figure 8. Types of pesticide wastes disposed into Iowa State University
Horticulture Station Pesticide disposal Bed ( Taken from Hall,
C.V. Pesticide Waste Disposal in Agriculture in "Treatment and
Disposal of Pesticide Wastes"; Krueger, R.F.; Seiber, J.N.,
Eds.; American Chemical Society, Washington, D.C., 1984; Chap.
3.)
Butyl rubb4r lin«r
\ 2* wothtd »
ond
Figure 9. Cross-section of a University of California pesticide wastewater
disposal bed. (Taken from Winterlin et. al. Disposal of
Pesticide Wastes in Lined Evaporation Beds, in "Treatment and
Disposal of Pesticide Wastes"; Krueger, R.F.; Seiber, J.N., Eds.;
American Chemical Society, Washington, D.C., 1984; Chap. 6.)
-69-
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SOIL MOUNDS AND PITS COST ESTIMATES*
Basis for Calculations
1.7 m3 (450 gal)/day
385 m3 (102,000 gal)/yr
225 operating days/yr
Capital Costs Soil Mound Soil Pit
Holding tank $1,750 $1,750
p™p 600 600
Distribution box 50
Pit, concrete liner,
backfill (6m x 12m x 1m) 7,500 7,500
Leach lines 450
Gravel , soil 50 50
Roof 1,750 1,750
Fencing 700 700
Total $12,850 $12,350
Yearly Operating Costs
Monitoring $2,400 $2,400
Electricity 100 100
Labor (250 hr @ $ll/hr) 2,750 2,750
Fixed charges (25% of
capital costs) 3,212 3,087
System clean-up and spent soil
disposal (prorated over
10 yr) 1,240 1,240
Total $9,702 $9,577
Operating costs per m3- $25.20 $24.88
Per 9al - $0.095 $0.09
* Based on Means Building Construction Cost Data in 1978.
Figure 10. Cost estimates of Iowa State University and University of
California pesticide wastewater disposal beds. (Taken from SCS
Engineers, Long Beach, CA. "Disposal of Dilute Pesticide
Solutions." U.S. Environmental Protection Agency, EPA/SW-174c,
1979.)
-70-
-------
PESTICIDE LEVELS IN SOIL SAMPLES TAKEN DIRECTLY BELOW DRAIN PIPE OUTLET
(PPM)
Pesticide
Dacthal
Diazinon
Parathion
Toxaphene
Dursban
2,4-D
Top 1'
300-1000
60-80
300-500
200-750
200
30
1 '-2'
1
1
1
20
5
10-20
depth
Figure 11. Pesticide contamination at the outflow pipe of airport drainage
system.
TOXAPHENE CONCENTRATION IN SOIL SAMPLES REMOVED FROM MANURE AMENDED TEST
PLOTS (PPM)
Date
10/07/80
10/14/80
10/22/80
10/31/80
11/7/80
1/2/81
2/1/81
Day Number
0
7
15
24
31
85
117
Toxaphene Concentration
62
45.9
43.2
40.2
38.9
27.8
23.4
Figure 12. Results of soil amendment with manure in the airport drainage
system test plots. Half-life of toxaphene in the test plots was
calculated to be 98.7 days.
-71-
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CHEMICAL TREATMENT OPTIONS FOR PESTICIDE WASTES DISPOSAL
R. Honeycutt, D. Paulson, H. LeBaron, G. Rolofson
Members of the Product Neutralization Task Force
CIBA-GEIGY Corporation
Greensboro, North Carolina
C. Ganz
EN-CAS Laboratories
1409-J South Stratford Road
Winston-Salem, North Carolina
ABSTRACT
The development of chemical means of detoxification of pesticide wastes and spills is
an increasingly important endeavor for the pesticide industry. The objective of this
paper is to review some of the chemical degradation methods for pesticide decontamination
that exist today. In presenting each method, less emphasis has been put on technical
detail of the method and more emphasis has been put on the cost of the method, regulatory
attractiveness, and simplicity to potential users of the method. Some methods that will
be discussed are microwave plasma destruction, photolysis, hydrolysis, ozonation, wet air
oxidation, chemical fixation, and reductive degradation. Recent screening experiments
carried out by the Product Neutralization Task Force at CIBA-GEIGY on the chemical
destruction of several of our pesticides show that household bleach (NaOCl) is effective
over a broad range of chemicals. Further, results show that for some chemicals, biologi-
cal destruction or other means of detoxification would be preferred over chemical means.
Details of these studies will be discussed.
INTRODUCTION
Pesticide wastes and pesticide spills
are becoming an increasingly visible prob-
lem throughout the world. Pesticide s'pills
can be both hazardous to the environment
and to man, expensive to clean up, and
result in adverse publicity for the manu-
facturer. An example of such a spill
occurred recently in the Midwest. In this
case several hundred gallons of a liquid
concentrate was discharged after a plug
broke on a storage tank. Clean up of the
resulting water contamination cost about
$150,000, mainly due to the cost for resin
and the expensive equipment brought in to
clean up the spill. Since the manufactur-
ers of pesticides are generally responsible
for clean up of spills, it is clearly
advantageous and profitable for the
manufacturers to provide inexpensive and
effective means to decontaminate pesticide
discharges into the environment. Pesticide
waste from farm activities results usually
in smaller spills, but are of equal impor-
tance, since contamination of surface or
groundwater may result. Currently there
are few, if any, widely accepted methods to
decontaminate soil or contaminated water
resulting from rinsates of spray tanks
which may be discarded.
PURPOSE
The objective of this presentation is
to review some of the available chemical
methods for decontamination of pesticide
wastes and spills. I will avoid getting
into technical detailed kinetic descrip-
tions of these methods and attempt to deal
with 1) a brief description of the method,
and 2) an evaluation of its complexity in
-72-
-------
terms of cost and simplicity to the poten-
tial users of the method. I will also
present some recent results of chemical
degradation studies which we have carried
out on some of our products at CIBA-GEIGY
Corporation.
HISTORICAL PERSPECTIVE
Several chemical techniques are avail-
able for degradation of pesticide wastes.
Dillon (1) has published an extensive
review of these techniques in the book,
Pesticide Disposal and Detoxification
(1981) - Chapter 6. Dillon categorizes
existing physicochemical methods as to the
type of material phase that is encounter-
ed:
I. Gas Phase Methods
A. Microwave Plasma Destruction
B. Photolysis
II. Liquid Phase Methods
A. Activated Carbon and Resin
Adsorption
B. Hydrolysis and Simple Chemical
Treatment
C. Molten Salt Baths
D. Ozonation Technique
E. Wet Air Oxidation
III. Liquid - Solid Phase Method/Chemical
Fixation
IV. Catalytic Liquid Phase Methods
A. Catalytic Dechlorination
B. Reductive Degradation
In order to stay within the scope of
this paper, I will discuss only the chemi-
cal techniques outlined by Dillon.
GAS PHASE METHODS
Microwave Plasma Destruction: Micro-
wave plasma destruction employs an appa-
ratus as shown in Figure 1. The organic
material is channeled through a plasma
detector tube where destruction is ini-
tiated by microwave radiation producing
electrons. The electrons react with the
organic molecules to form free radicals and
final simple reaction products such as SO ,
C02 , CO, ^0, HP03 , COC12 , C120, and Br2 .
For example, the overall reaction for
malathion is:
Plasma + C, „ H, 0 Or PS0
150,
2500
10CO,
-73-
The plasma method results in an exten-
sive detoxification for several pesticides
as shown in Table 1. Detoxification levels
of 99+% are achieved at 0.18 to 3 kg/hr.
The microwave plasma method is relatively
expensive (0.50 dollars/kg detoxified) and
would not be a simple devise for farmers to
use for disposal of rinsates. However,
production facilities may find such a
devis.? extremely effective for decontamina-
tion of effluents and will have to weigh
costs vs. effectiveness of alternatives.
Further, safety evaluations have to be made
for the discharge of the products into the
environment.
PHOTOLYSIS
Pesticides undergo many types of
photolysis reactions such as ring fusion,
condensation, bond rearrangement reductive
loss of chlorine, replacement of chlorine
by hydroxyl groups and replacement of halo-
gens by phenyl groups. Figure 2 shows some
examples of photolytic reactions that take
place with pesticides. One of the most
practical applications of photolysis to
pesticide decontamination is that of the
photodegradation of 2,3,7,8-tetrachlorodi-
benzo-p-dioxin (TCDD). TCDD in herbicide
orange is photolyzed in sunlight with a
t. of 6 hours. To date, photolysis has
not been applied to clean up of spills or
rinsates.
LIQUID PHASE METHODS
Activated Carbon and Resin Adsorption:
Adsorption processes are used widely to
cleanup chemical spills and to clean up low
concentrations of unwanted chemicals in
waste streams. Generally, solutions of
chemicals should be <1,000 ppm when employ-
ing adsorption processes. Costs of using
adsorption processes are high (generally
$1.33/1,000 liters of pesticide plus con-
siderable capital investment), but this
process is quite effective. One example,
waste streams of 100 ppm chlorophenols have
been decontaminated to levels of <1 ppm by
carbon adsorption processes.
Hydrolysis and Simple Chemical Treat-
ment: Hydrolysis and chemical treatment
are common methods used to clean up pesti-
cide waste streams and spills. Table 2
shows an example of several organophosphate
insecticides that were detoxified using
various chemical reagents. Kennedy and co-
workers found that several reagents could
be used to degrade these organophosphates
and that the percentage of degradation
ranged from 92-100% for the reagents shown
-------
in Table 2. Obviously, metallic sodium in
liquid ammonia was the most effective,
however, the human hazard, corrosive nature
and high cost of these reagents would pro-
hibit their use.
When trying to determine which reagent
would be the best to decontaminate chemical
spills or wastes, an appropach similar to
the one used recently at CIBA-GEIGY is
recommended. We carried out a series of
studies to determine if any one of a number
of common simple reagents would degrade a
variety of our formulated products. A
10,000-30,000 ppm active ingredient in
aqueous suspension of formulated pesticide
product was treated with a molar excess of
reagent for 24 hours at which time the
entire solution was extracted with acetone
and aliquots taken for parent analysis.
Table 3 shows the results of these studies.
Of the seven reagents, hypochlorite appear-
ed to be the most effective. Hypochlorite
reduced the active ingredient level by at
least 50% for 7 of the 10 products tested.
Dual® and Tilt® appear to be the most
chemically resistant products since none of
the reagents appeared to degrade either
product to a significant degree.
These screening studies were cursory
in nature and were only used to tell us
which products were likely candidates for
employment of simple chemical detoxifica-
tion methods or conversely which chemicals
may be more stable and hence candidates for
development of biological degradation
methods. For the promising reagents, fur-
ther research will be needed to define the
optimum reagent/active ingredient ratio,
reaction time, and potential exposure and
toxicity of the degradation products.
Molten salt processes: One extremely
interesting detoxification process devel-
oped by Rockwell International is the molt-
en salt process. Waste material is blown
into a large bath (10 ft. high and 3 ft. in
diameter) of molten salt at 800-1,000°C.
Feed rates are 23-91 kg/hr. Figure 3 shows
a schematic of a molten salt combustion
process. The overall chemical reaction is:
C,H,0,N+02 molten salt
C0
iron catalyst
About 99.94% degradation has been
achieved at the bench scale for DDT, 2,4-D,
and chlordane. The cost for this process
has been estimated at $1.10/kg of chemical.
A mobile molten salt combustion unit that
would decontaminate 230 kg/hr has been
proposed by Rockwell International.
Ozonation methods: There are three pesti-
cide chemical degradation methods utilizing
ozone gas:
• Ozone/ultraviolet irradiation
• Sonocatalysis
• Catalytic ozonation
Ozone/Ultraviolet Irradiation:
Ozone/ultraviolet irradiation processes to
degrade pesticides are being developed at
several locations around the United States.
Houston Research, Inc., Westgate Research
Corp., and Pure Water Systems, Inc. are
three laboratories pioneering this field.
The chemical reaction of interest with
this chemical detoxification process is:
PESTICIDE + 0,
UV LIGHT
>
OTHER SIMPLE SPECIES
-74-
-------
Dr. Phil Kearney and coworkers (2), at
USDA, Beltsville, Maryland, has explored
the practicality of using UV/ozonation
methods to decontaminate farm generated
pesticide rinsates. Dr. Kearney and co-
workers carried out their research at the
USDA farm at Beltsville, Maryland, where
about 3,000 acres are sprayed annually. In
one experiment, the researchers collected
spray rinstate from AAtrex® 4L (40.8% ai)
and processed it using a mobile UV/ozona-
tion apparatus purchased from Pure Water
Systems, Inc., Fairfield, New Jersey.
Figure 4 shows some of the results of this
study. Atrazine was degraded rapidly with
this system. For a 12,000 ppm (ai) solu-
tion, 40% degradation was achieved in 30
minutes. It was also found that if the
concentration of the active ingredient was
reduced, the degradation rate dramatically
increased.
The economics of this system has been
studied by Kearney, as well. The UV/ozona-
tion unit is $35,000. The cost for running
it would come to about $650 annually. This
annual cost compares well to incineration,
but is more expensive than physical treat-
ment or land disposal. The advantages of
the unit are its mobility, relative base of
operation, low operating cost, production
of less toxic degradation products, and
extensive degradation in a short period of
time. This last advantage is important
since most spills should be cleaned up
raidly and toxic materials disposed of
rapidly and cheaply.
Zimmerman Process (Wet Air Oxidation):
This process utilizes heat (up to 350°C)
and pressure (up to 2,500 psig) in the
presence of oxygen to oxidize pesticide
wastes. Table 4 shows some of the results
using wet air oxidation as a chemical
decontamination method. Amiben® has been
degraded 88-99.5% and atrazine by 100%
using this process. The cost of this pro-
cess relative to other destruction methods
applied to pesticides has not been exten-
sively studied.
CATALYTIC LIQUID PHASE METHODS
Catalytic liquid phase methods are of
two types: catalytic dechlorination and
reductive degradation. I will deal with
only reductive degradation in this paper.
Reductive Degradation Metallic
Couples: Reductive degradation processes
utilize metallic couples such as zinc/
copper or iron/copper. Bench scales reduc-
tion processes have been tested at 1.7
liters/min. resulting in degradation of 50
ppb chlorinated hydrocarbons in water to
0.02 ppb. This process could have signifi-
cant application to clean up of contami-
nated groundwater.
SUMMARY AND CONCLUSIONS
Table 5 shows a summary of the several
pesticide degradation processes which were
discribed in this paper. Several charac-
teristics of these processes, including
degradation products, environmental impact
and relative costs, are presented in this
table. Of the nine listed processes, the
economics of only five has been researched
extensively. All five of these processes
require considerable capital expenditure.
While the UV/ozonation and microwave plasma
destruction processes appear to be the most
economical of the five, they may be practi-
cal for only clean up of industrial wastes
such as effluents or large spills. Indi-
vidual farmers or commercial applicators
may find such capital investments hard to
justify. More simple, less expensive
degradation processes such as chemical
treatment or biological treatment may be
better suited for decontamination of farm
rinsates.
Although considerable progress has
been made on chemical processes to clean up
chemical spills and wastes, considerable
research remains to be done on many of
these processes mentioned above. From the
variety and complexity of these chemical
processes which are now under study, it is
easy to see that considerable time and
expense will be needed before a final solu-
tion to the problem of decontamination of
chemical wastes is realized.
ACKNOWLEDGEMENTS
The authors would like to acknowledge
the technical assistance of Wayne Barker
and Joe Keeney of EN-GAS Laboratories,
Winston-Salem, North Carolina.
REFERENCES
1. Dillon, A. P., 1981. Physical and
Chemical Disposal Methods. Pesticide
Disposal and Detoxification Processes
and Techniques. Noyes Data Corpora-
tion, Park Ridge, New Jersey, U.S.A.
PP. 83-156.
2. Kearney, P. C., Q, Zeng, and John M.
Ruth, 1984. A Large Scale UV-Ozonation
Degradation Unit-Field Trials on Soil
Pesticide Waste Disposal, ACS Symposium
Series No. 259 - Treatment and Disposal
of Pesticide Wastes, R. F. Krueger and
J. N. Seiber, Editors. PP. 195-209.
-75-
-------
Micro wove
Power Source
Microwave
Applicator
Microwave
Power Source
Receiver
Pesticide
Dropping
Funnel
Moss
Spectrometer
Flow Meterj
O2 Supply Alternate
Gas Supply
3-Way Stopcock
Manometer
Vacuum Pump
Cold Trap
FIGURE 1. SCHEMATIC OF MICROWAVE PLASMA APPARATUS (FROM
DILLON, 1981)
-76-
-------
ci ci
3,4-DICHLOROANILINE (CONDENSATION)
NH2
NH2
CI x COOM CI ^^ COOM
AMIBEN (3-AMINO-2,5-DICHLOROBENZOIC ACID)
REDUCTIVE LOSS OF CHLORINE
OCHjCOOH-
HjO
CI OH
ON
REPLACEMENT OF CHLORINE BY HYDROXYL
OM
CM
CM
IOXYNIL (4-HYDROXY-3,5-DIIODOBENZONITRILE)
REPLACEMENT OF HALOGEN BY PHENYL
FIGURE 2. PHOTOLYTIC REACTIONS OF PESTICIDES (FROM DILLON,
1981).
-77-
-------
STACK
OFF-GAS
CLEANUP
HASTE
O3
1
HASTE
TREATMENT
AND FEED
AIR
| HASTE AND AIR
MOLTEN SALT
FURNACE
SALT RECYCLE
n
i
i
SPENT MELT
DISPOSAL
SPENT MELT
REPROCESSING
OPTION
ASH
FIGURE 1>. SCHEMATIC OF MOLTEN SALT COMBUSTION APPARATUS (FROM DILLON, 1981).
-------
-6Z-
% Remaining
o
o
-------
TABLE 1. SUMMARY OF MICROWAVE OXYGEN-PLASMA REACTIONS
HAZARDOUS MATERIALS
HALATHION
CYTHION* ULV
PCB
AROCLOR* 1242
PMA
TROYSAN* PMA-30
KEPONE* 80/20
20% METHANOL
SOLUTION
KEPONE*
2 TO 3 G
SOLID Discs
U.S. NAVY RED DYE
FEED RATE, KG/HR
0.5
0.27
1.0
0.73
—
0.5 SLURRY;
0.09 EQUIVALENT
PRESSURE
PA (TORR)
3,700-6,100
(28-46)
2,300-4,700
(17-35)
16,000-18,700
(120-140)
7,200
(54)
930
(7)
4,600-7,900
(35-60)
CONVERSION
(%)
99.998
99
EST. 99.99
99
99
99.99
FROM DILLON (1981),
-80-
-------
TABLE 2. SUCCESSFUL CHEMICAL DEGRADATION OF OUR
ORGANOPHOSPHORUS INSECTICIDES
INSECTICIDES
REAGENT EMPLOYED
PERCENTAGE
DECONTAMINATED
DDVP, PARATHION, SCHRADAN,
SYSTOX*
DDVP/ SYSTOX/ SCHRADAN/
PARATHION
DDVP
DDVP
SYSTOX
PARATHION
METALLIC SODIUM IN
LIQUID AMMONIA
METALLIC LITHIUM IN
LIQUID AMMONIA
TRIETHANOLAMINE
IMIDAZOLE
H202
H202
100
100
100
97
97
92
100
93
FROM DILLON (1981).
-81-
-------
TABLE 3. CHEMICAL DEGRADATION OF CIBA-GEIGY PRODUCTS
PRODUCT NAME
TILT* 3.6E
CGA-112913 (AD
DUAL* 8E
TRIUMPH™ 4E
CURACRON* 6E
DIAZINON AG500
TRIGARD* 75W
GALECRON* 4E
RIDOMIL* 2E
ACARABEN* 4E
WATER
CONTROL
111
102
104
88
100
94
123
87
123
106
5%
HCL
97
81
108
89
92
22
82
78
114
101
* OF AC
24
5%
NAOH
93
90
105
52
0
77
106
82
0
0
TIVE INGREDIENT KEMAINING
HOURS AFTER TREATMENT
3%
108
80
119
96
78
98
127
74
109
110
5%
NAOCL
105
22
111
0
o_
JZ
11
0
100
42
FE
+5%
HCL
114
119
114
96
96
43
67
87
112
105
LIME
SLURRY
155
42
59
74
83
93
129
149
108
77
-82-
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TABLE
WET AIR OXIDATION PESTICIDAL WASTE APPLICATIONS
WASTE SOURCE
(SPECIFIC CONSTITUENT)
UPERATING CONDITIONS
TEMPERATURE PRESSURE
*C (PSIG)
SPECIFIC
CONSTITUENT
REMOVED %
AMIBEN* HERBICIDE PROCESS
(DICHLORONITROBENZOIC ACID)
S-TRIAZINE HERBICIDE PROCESS
(ATRAZINE DERIVATIVES)
280
260
1,560
1,200
>99.5
100
FROM DILLON (1981).
-83-
-------
TABLE 5, CHEMICAL DESTRUCTION OF CHEMICAL WASTES AND SPILLS
oo
-Ca
I
CHEMICAL
PROCESS
MICROWAVE
PLASMA
DESTRUCTION
PRODUCTS
SIMPLE CO, /SO,
CO,H,0,HP03,
COCL2/CL2,BR2
bNVIRONMENTAL
IMPACT OF PROCESS
MINIMAL
SCRUBBERS
FEED RATE
20 KG/MR
LARGE SCALE
COST
$0.50/KG
$100/000 CAPITAL
PHOTOLYSIS
ACTIVATED
CARBON
ADSORPTION
HYDROLYSIS
SIMPLE
CHEMICAL
TREATMENT
RING FISSION/
CONDENSATION
LOSS OF HALOGEN
HYDROXYLATION
ADSORBED-
UNALTERED
NOT SIGNIFICANT
ALTERATION TO
SIMPLE PRODUCTS
NOT SIGNIFICANT
ALTERATION TO
SIMPLE PRODUCTS
CONSIDERABLE
MINIMIZE
EXPOSURE AND
TOXICITY OF
PHOTOPRODUCTS
MINIMUM
DISPOSAL OF
ABSORBED
CHEMICAL
CONSIDERABLE
MINIMIZE
EXPOSURE AND
TOXICITY OF
PRODUCTS
CONSIDERABLE
MINIMIZE
EXPOSURE AND
TOXICITY OF
PRODUCTS
UNKNOWN
200 PPM-1 PPM
600/000 L/DAY
UNKNOWN
UNKNOWN
UNKNOWN
$1,33/1/000 LITERS
$420/000 CAPITAL
UNKNOWN/ LESS
EXPENSIVE THAN
ENERGY INTENSIVE
PROCESS
UNKNOWN/ LESS
EXPENSIVE THAN
ENERGY INTENSIVE
PROCESS
(CONTINUED)
-------
TABLE 5. (CONTINUED)
on
en
i
CHEMICAL
PROCESS
MOLTEN SALT
PROCESS
UV/OZONATION
WET AIR
OXIDATION
REDUCTIVE
DEGRADATION
PRODUCTS
SIMPLE, CO,/
H20,02,N2
MIXED/ SIMPLE/
E.G., 02
COMPLEX/ E.G./
HYDROXY TRIA7INE
C02/H20
COMPLEX
tNVIRONMENTAL
IMPACT OF PROCESS FEED RATE
MINIMAL 23-91 KG/HR
SCRUBBERS
PROTECT WORK
ENVIRONMENT
MINIMAL
CONSIDERABLE
MINIMIZE
EXPOSURE AND
TOXICITY OF
PRODUCTS
MINIMAL 118 KG/HR
CONSIDERABLE UNKNOWN
MINIMIZE
COST
$1.10/KG
$1/000/000 CAPITAL
MORE COSTLY THAN
CHEMICAL METHODS
$35/000 CAPITAL
$0.36/KG
$2/200/000 CAPITAL
UNKNOWN
EXPOSURE AND
TOXICITY TO
PRODUCTS
-------
LAND DISPOSAL OF PESTICIDE RINSATE
Ronald E. Ney, Jr.
U.S. Environmental Protection Agency
Washington, D.C.
The Environmental Protection Agency
(EPA) was formed because of increasing
concerns of adverse pollution effects on
humans and the environment. One concern
is the safe disposal of pesticide rinsate.
My discussion focuses on technical and
environmental aspects of three disposal
options for pesticide rinsate. I will
also mention other options. The applicable
EPA rules under the Resource Conservation
and Recavery Act (RCRA) are also briefly
described.
Three disposal options available to
generators of a pesticide rinsate are
land treatment units, landfills, and
surface impoundments. These techniques
have many similar, as well as different
characteristics. Land treatment is the
process of applying waste to the soil
surface with a scientific design to
degrade, transform, detoxify, and immobil-
ize hazardous waste constituents. Surface
impoundments can be designed for treatment
or disposal. Landfills are for disposal.
Land treatment units and surface impound-
ments can receive liquids, whereas land-
fills have controls for disposal of liquid
waste. In all three cases it is generally
important to know: 1) waste characteris-
tics (e.g., solubility), 2) treatment
processes (e.g., biodegradation, photode-
gradation), and 3) hydrogeologic setting
(i.e., soil types and groundwater level
and flow characteristics). Advantages and
disadvantages of each of these disposal
options will be presented.
The discussion of the regulations
will: cover definitions of terms which
may be unfamiliar; describe what is a
hazardous waste, a small quantity gener-
ator, and when various rules apply;
describe generator and transporter rules
for off-site shipments (the manifest
system); and describe rules for storage,
treatment, and disposal facilities. By
the end of the discussion I will have
covered acceptable disposal techniques,
some of RCRA's requirements, reuse of
pesticide rinsate, and other considerations.
-86-
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INCINERATION OPTIONS FOR DISPOSAL OF WASTE PESTICIDES
Donald A. Oberacker
Senior Mechanical Engineer
U.S. Environmental Protection Agency
Hazardous Waste Engineering Research Laboratory
Cincinnati, Ohio 45268
ABSTRACT
This paper presents a summary of a number of EPA's tests of high-temperature incin-
erators with an overview of their typical waste destruction performance when properly
operated. In general, these tests have indicated that current incinerators are capable
of effectively destroying most types of organic hazardous wastes including several
organic pesticides and a wide variety of industrial/commercial compounds fired either
singly or in multi-compound mixtures. However, to date EPA's testing experience has
not emphasized the waste disposal problems of the agricultural industry simply because
most of the interest and testing dealt with industrial/commercial chemicals. The
author's comments concerning incinerating all agricultural pesticide wastes not yet
tested must largely be based on extrapolations from incineration test experience from
industrial hazardous wastes which have similar chemical and physical characteristics.
Like many industrial hazardous waste streams, agricultural wastes may include a
variety of organic and organochlorine compounds and physical forms (e.g., aqueous, non-
aqueous wastes, contaminated soils, inerts, or solids, and pumpable and non-pumpable
solids. Various types of containers ranging from metal cans or drums to burnable fiber
or paper or plastic canisters or bags are also encountered. Certain pesticide formula-
tions, however, may contain various amounts of heavy toxic metals or problem elements
(e.g., lead, zinc, mercury, bromine, etc.). These materials may rule out incineration
unless suitable pretreatment steps are employed or the metal or, for example, bromine
content is either very low or controllable via air pollution control equipment on the
incinerator.
EPA has conducted pilot and full-scale incineration tests on a number of actual
pesticide types. From these tests plus a much larger data base on many industrial/com-
mercial chemicals including containerized materials, we do not envision many technical
limitations in incinerating most organic agricultural pesticides or their containers
because of the successful experience thus far with incineration in general.
Regulatory issues regarding incinerating pesticide wastes are similar to other haz-
ardous waste requirements and are discussed briefly.
INTRODUCTION ical compounds. Pesticides are specific,
sub-categories of the overall system of
Although some types of pesticides have chemicals known as hazardous or toxic
already been disposed of by high tempera- compounds. Pesticides may involve either
ture incineration, the majority of the purely organic molecular structures, or a
United States experience and performance combination of organic and inorganic
data with hazardous waste incineration structures, where the inorganic fraction
involves other types of industrial/chem- may include heavy metals, etc. While
-87-
-------
many industrial chemicals often fit this
same description. Pesticide compounds as
a rule tend toward following characteris-
tics:
"Pesticides tend to be somewhat larger
and more complex molecules;
"They more frequently involve elements
such as sulfur, phosphorus, and/or
nitrogen, in addition to chlorine;
"They more often include such heavy
metals as lead, mercury, and other
halides such as bromine in signifi-
cant concentrations.
APPROACH
The EPA research indicates that most
organic molecules including chlorinated
hydrocarbons breakdown into harmless or
easily controlled combustion products
under sufficient exposure to a high-tem-
perature oxidizing combustion atmosphere.
The primary concern still under investi-
gation for organic hazardous chemical
waste is what amounts or types of
potentially harmful residuals and/or in-
complete combustion byproducts may be
formed and emitted, should the incinera-
tor operate at less than its normal tem-
perature or oxygen conditions. In the
case of well-designed and operated incin-
erators, input organic compounds includ-
ing organic pesticides are normally de-
stroyed such that only about 0.01 percent
or less by weight of each original com-
pound exits the incinerator stack. The
total weight of all identified byproducts
or products of incomplete combustion
(PIC's) in the stack is normally less than
0.01 percent of the total weight of the
input principal organic hazardous consti-
tuents (POHC's). Thus, the bulk (i.e.,
99.99 percent) of the organic hazardous
waste stream is converted to such harmless
exhaust products as C02 and H20 under pro-
per operating conditions, plus some
amounts of particulate matter. Hydro-
chloric acid (HCL) is produced from the
burning of chlorinated compounds, but is
relatively easily scrubbed from stack
gases using existing air pollution control
technology.
PROBLEMS ENCOUNTERED
The issues involved with incinerating
toxic heavy metal-containing compounds or
wastes, become much more complicated.
Also, halogens other than chlorine (e.g.,
bromine, iodine), sulfur, or phosphorus
potentially present technical problems
for conventional incineration. Metals of
course are not thermally destroyed by in-
cineration. The fate of metals in an in-
cinerator is basically a function of in-
dividual physical properties of boiling
point and/or chemical reactivity in the
hot zone of the incinerator's combustion
chamber. A metal may simply stay behind
and become part of the ash; or it may va-
porize and recondense in the scrubber, or
exit the stack still in vapor form; it
could oxidize and either become ash,
scrubbed particulate, or escape through
the scrubber as a very fine particulate;
or the metal may exhibit a combination of
all of these behaviors. Potential prob-
lems with compounds like bromine and io-
dine or their hydrogen halides exist as
well because they are not nearly as easily
scrubbed as HCL has been demonstrated to
be. Phosphorus can potentially generate
P20s, a toxic compound in itself, and sul-
fur can present its own acid gas emissions
problem.
RESULTS
Pesticide Destruction Results
Of primary importance in this paper
is the Agency's actual incineration test
data on representative types of pesti-
cides. Over the period from 1974 to the
present time, EPA has conducted a number
of incineration tests with the specific
pesticides listed in Table 1. The listing
shows the pesticide common name and type
of formulation (e.g., liquid, dust, pellet
form, etc.) and the scale or size of the
incineration test. Measured destruction
efficiency results are also indicated. It
should be noted that most pesticides test-
ed were capable of being destroyed to an
efficiency of 99.99 percent (4-9's). Ex-
ceptions were Mi rex and Zineb. In the
case of Mirex, investigators felt that
destruction could be improved to the 4-9's
level with a somewhat more effective in-
cineration design. Zineb exhibited a 4-
9's destructive performance of its organ-
ic fraction, however, investigators noted
that the stack effluent was characterized
by a white, cloudy appearance judged to be
fine particulate zinc oxide. Despite the
use of a three-stage wet scrubbing device,
apparently the zine oxide failed to be
-88-
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captured efficiently.
Industrial/Commercial Hazardous Haste
Destruction
The EPA has developed a rather compre-
hensive data base on incineration testing
and performance results on a larger number
of industrial/organic hazardous wastes.
These wastes have been tested in twelve
(12) different incinerators. The waste
streams studied typically represented the
incinerator facility's daily disposal ac-
tivity. Table 2 presents a summary of
chemical compounds in these wastes for
which destruction and removal efficiency
was determined. Also, a listing of the
typical operating conditions noted in the
incinerators which destroyed the wastes in
Table 2 is presented in Table 3.
The above mentioned list of industrial
organic compounds were generally all found
to be incinerable to the 99.99 percent or
better destruction level in the variety of
size and design of incinerators tested by
EPA. Only rare exceptions to this rule
occurred when a somewhat lower calculated
destruction efficiency (i.e., only 99.0 to
99.9 percent) was determined for the fol-
lowing special circumstances.
"in the cases where the compound con-
centration in the waste was quite low
(e.g., less than 100 ppm);
"or where solid types of waste were
not agitated or retained sufficient-
ly long in the hot zone;
"where stack gas analyses were made
difficult by the fact that the feed
compound of interest is also a known
breakdown product of incomplete com-
bustion (PIC) of another compound;
"in cases of deliberate reduction of
combustion temperature or air supply
where EPA was seeking to determine
the operational bounds of effective
performance.
Some heavy metals were involved along
with the organic chemicals incinerated in
Table 2 during EPA's field testing ac-
tivities. These metals included lead,
TABLE 1
SUMMARY EPA PESTICIDE INCINERATION TEST RESULTS
(References 1, 2, 3, and 7)
Pesticide
DDT
DDT
DDT
Aldrin
Picloram
Picloram
Malathion
Malathion
Toxaphene
Toxaphene
Atrazine
Atrazine
Captan
Zineb
Mirex
Herbicide Orange
PCP
Kepone
Chlordane
Formulation
25% Emulsifiable Cone.
10% Dust
20% Liquid In Diesel Oil
41.2% Emulsifiable Cone.
21.5% Liquid
10% Pellets
57% Emulsifiable Cone.
25% Wettable Powder
60% Emulsifiable Cone.
20% Dust
40.8% Liquid
90% Wettable Powder
50% Wettable Powder
75% Wettable Powder
0.3% Bait
Full Strength*
0.1% In Wood
Liquid
Commercial
Scale Of Test
Pilot Scale
Pilot Scale
Commercial Scale
Pilot Scale
Pilot Scale
Pilot Scale
Pilot Scale
Pilot Scale
Pilot Scale
Pilot Scale
Pilot Scale
Pilot Scale
Pilot Scale
Pilot Scale
Pilot Scale
Full Scale
Pilot Scale
Pilot Scale
Pilot Molten Salt
Destruction Efficiency
(Of Organic Fraction)
99.99%+
99.99%+
99.999%+
99.99%+
99.99%+
99.99%+
99.99%+
99.99%+
99.99%+
99.99%+
99.99%+
99.99%+
99.99%+
99.99%+
98 to 99%
99.99%+
99.99%+
99.9999%+
99.99%+
*TCDD in HO above as a 2 ppm contaminant; 50/50 mixture of 2,4,-D and 2,4,5-T.
-------
TABLE 2
TYPICAL INDUSTRIAL ORGANIC HAZARDOUS
COMPOUNDS INCINERATED
(References 3, 4, 5, 6, 8, 9, and 10)
PCB
Toluene
Tetrachloroethylene
Trichloroethylene
Carbon Tetrachloride
Naphthalene
Chloroform
Methylene Chloride
Methy Ethyl Ketone
Phenol
Benzene
Butyl Benzyl Phthalate
Bis-(Ethyl Hexyl) Phthalate
Chlorobenzene
1,1,1-Trichloroethane
Aniline
Benzyl Chloride
Diethylphthalate
Phthalic Anhydride
Amines
Chlordane
Chlorobenzenes
Chloromethane
Chloroethanes
Cresol(s)
Dimethyl Phenol
Dodecanol
Hexachlorobutadiene
Hexachlorocyclopentadiene
Isocyanates
Methylene Bromide
Methyl Pyridine
Phosgene Gas
TABLE 3
TYPICAL OPERATING CHARACTERISTICS OF INCINERATORS MEETING REGULATORY REQUIREMENTS
ON DESTRUCTION AND REMOVAL EFFICIENCY
Combustion Chamber Temperature Level:
Residence Time:
Excess Combustion Air:
Stack Gas Composition:
Oxygen :
Carbon Dioxide :
Carbon Monoxide :
Total Hydrocarbons:
Stack Particulate Emissions:
Units Without Control Devices:
Units With Control Devices :
820°C to 1500°C (1500°F to 2700°F)
0.2 sec to 6.5 sec for gases and
1iquid/vapors
several minutes to 1/2 hour for
solids/sludges
60 to 130 percent
8 to 15 percent
6 to 10 percent
0 to 50 ppm (with rare exceptions up to
500 ppm or more)
0 to 5 ppm (with rare exceptions up to
75 ppm or more)
60 to 900 mg/dscm (0.03 to 0.39 gr/dscf)
20 to 400 mg/dscm (0.01 to 0.17 gr/dscf)
-90-
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zinc, arsenic, chromium, and others which
are normally neither destroyed nor com-
pletely captured by the air pollution con-
trol device on the incinerator. In most
cases the levels or concentrations of the
metals in the feed were in the low ppm by
weight range.
Additional information on EPA's test-
ing program on industrial/commercial haz-
ardous waste incineration is provided in
Table 4 which shows the year the tests
were performed, a brief description of the
study, and brief information on the wastes
involved in each of twelve (12) case stud-
TABLE 4
TWELVE MAJOR EPA SUPPORTED TESTS OF PILOT, FIELD, OR FULL-SCALE
HAZARDOUS WASTE INCINERATORS (1974-1984)
CASE
NO.
1
2
9
10
11
12
YEAR STUDY
1974 Incineration of DDT in a full-scale
liquid injection unit
1974 Pilot 3-chamber incinerator adapted
from classical early garbage burners
1974 Vulcanus incinerator ship tests in
Gulf of Mexico
1975 Full-scale industrial incinerators
1977 Vulcanus ship in South Pacific
1981 Pilot-scale starved air (controlled-
air) Los Alamos National Laboratory
Incinerator
1981 Full-scale Cincinnati MSD incinerator
1981-1982
1983 Vulcanus II ship in North Sea
Vulcanus ship in Gulf of Mexico
(2 burns)
1982-1983 Eight (8) typical field-scale commer-
cial incinerators studied on regula-
tory impact analysis (RIA) program
1982-1983 EPA's Edison, New Jersey mobile rotary
kiln with afterburner facility
1983-1984 EPA's Combustion Research Facility
pilot-scale rotary kiln with after-
burner
HAZARDOUS WASTE DESCRIPTION
28 drums (55 gallons each)
of DDT at 20% in oil
Nine (9) commercial liquid
and solid pesticide formu-
lations
Mixed Shell Chemical Co.
high-chlorine organic
chemicals
PVC plastic residues, or-
ganic solvents, etc.
Herbicide Orange stocks
including TCDD
PCP-treated wood
Pesticide and high-chlorine
liquids, HCB, HCPD, etc.
PCB liquids, TCDF, chloro-
benzenes
Mixed organochlorine vola-
tive compounds
Large variety of gaseous
liquid, and solid hazardous
materials
PCB, dioxins, chloroben-
zenes
HCB and 1,2-4 trichloroben-
zenes in toluene
-91-
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ies. For additional details, the reader
may wish to obtain more detailed reports
from the list of references provided here-
in.
The EPA has advanced to a state of
"cautious optimism" about the effective-
ness of high temperature incineration as a
safe disposal practice for most organic
compounds, based largely upon the case
studies listed in Table 4. This is not to
to say that EPA has ceased its research
and development programs in this area,
however. EPA is agressively pursuing a
number of yet unanswered issues on incin-
eration, the primary ones being:
°As incinerator operating conditions
(e.g., temperature, air supply,
steady behavior or normal func-
tioning systems, etc.) degrade, what
are the impacts on overall environ-
mental performance?
"Which parameter (e.g., CO, tempera-
ture, residual hydrocarbons in emis-
sions, etc.) may best serve as a
real-time, effective measure of per-
formance, in lieu of detailed,
lengthy, and costly stack emissions
analysis procedures?
"Besides the currently measured emis-
sions from the incinerator stack
(e.g., small amounts of original com-
pounds, small amounts of known prod-
ucts of incomplete combustion/recom-
bination chemical species), what is
the remaining amount of organic com-
pounds in stack gas made up of?
"What is the fate and transport mech-
anism for any inerts or inorganics
(including metals and organo-metal-
lics, etc.)' should they be present in
the feed insignificant amounts?
"Lastly, can even the most acutely
toxic organic compound (e.g., diox-
ins, furans) be safely incinerated
in low, medium, or high concentra-
tions in the feed?
Regulatory Issues
Table 5 is a comparison of EPA's cur-
rent regulatory requirements for inciner-
ating hazardous wastes of the RCRA type,
TSCA type, and for incinerating on ocean-
going incineration ships. During the de-
velopment of these regulations, the Agency
based the various performance parameters
primarily on the achievable performance
experience noted for organic industrial
wastes and to a lesser degree on organic
pesticide formulation test results. Less
pesticide incineration data is available
than for other organics, although, the
pesticide data that is on record indi-
cates that except for the complicating
issues of inorganics that are part of some
cidies, organic pesticide compounds
appear to thermally decompose about the
same as their industrial counterparts.
Regulatory requirements for pesticides
are currently the same as for other RCRA
or TSCA hazardous wastes. The issue of
incinerating pesticides with metals or
other complicating factors would probably
be handled on a case-by-case basis, that
is, EPA's permitting authorities (e.g.,
Regional Administrators and Headquarters
personnel) would seek or require informa-
tion on individual compounds or elements
and their potential for release to the en-
vironment. Clearly, there may be a number
of pesticides whose content of heavy met-
als, or halides such as bromine, for ex-
ample, may preclude incineration unless
either pretreatment steps can be devel-
oped or unless effective pollution con-
trols on the incinerator can be demon-
strated. Other purely organic types of
pesticides (e.g., DDT, Silvex, 2,4,-D,
chlordane, etc.) have already been allow-
ed to be incinerated under current regula-
tions.
ACKNOWLEDGEMENTS
The author wishes to acknowledge Mr.
James S. Bridges for the opportunity to
include this paper in this Pesticide Sym-
posium, as well as the authors of the
technical references cited here for their
excellent contributions to EPA's incinera-
tion data base.
REFERENCES
1. Leighton, I.W., Feldman and J. B.,
Demonstration Test Burn Of DDT In Gen-
eral Electric's Liquid Injection In-
cinerator, USEPA Region I Report of
1974 (unpublished).
2. Ferguson, et al., Determination of In-
cinerator Operating Conditions Neces-
sary for Safe Disposal of Pesticides,
EPA-600/2-75-041, December 1975.
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TABLE 5
COMPARISON OF REGULATORY REQUIREMENTS
RCRA
POHC DESTRUCTION AND RE-
MOVAL EFFICIENCY (DRE)
TSCA
99.99% 99.9999%
OCEAN INCINERATION
(PROPOSED)'
99.99% (99.9999%
For PCB)
TEMPERATURE
Per Trial 1200°C min. (PCB Liquids) 1100°C (Wall) min.
Burn Per Trial Burn (Non-liquid)
RESIDENCE TIME
Per Trial 2 sec. min. (1200°C)
Burn 1.5 sec. min (1600°C)
Non-liquid Per
Trial Burn
1 sec. min.
COMBUSTION EFFICIENCY
STACK 02
None
99.9%
Per Trial 3% min. (PCB Liquids)
Burn 2% min. (1600"C)
Non-liquid Per
Trial Burn
99.9%
3% min.
HC1 CONTROL
PARTICULATES
4 Ibs./hr. Per Regional
max. or Administrator
99%
Control
180 mg./ Per Regional
dscm Administrator
None
None
3. Stretz, L. A., et al., Controlled Air
Incineration Of Pentachlorophenol
(PCP) Treated Wood, USEPA IAG No. AD-
89-F-1-539-0, Draft Report.
4. Yezzi, J. J., et al., Results Of The
Initial Trial Burn Of The EPA-ORD Mo-
bile Incineration System, ASME 1984
National Waste Processing Conference,
Proceedings, June 3-6, 1984, pages
514-534.
5. Ackerman, D. G., et al., Incineration
Of Volatile Organic Compounds On The
M/T Vulcanus II, TRW Energy and Envi-
ronmental Division, April 1983.
6. Jackson, M. D., Ackerman, D. G., et
al., At-Sea Incineration Of PCB-Con-
taining Wastes Onboard The M/T Vulcan-
us I, EPA Contract 68-02-3174, EPA
Report 600/7-83-024, April 1983.
7. D. G. Ackerman, et al., At-Sea Incin-
eration of Herbicide Orange Onboard
the M/T Vulcanus, EPA-600/2-78-036,
April 1987.
8. Whitmore, F. C., Carnes, R. A., et
al., Systems Reliability And Perform-
ance, PilotScale Incineration Of Chlo-
rinated Benzenes At The USEPA Combus-
tion Research Facility, EPA Contract
-93-
-------
No. 68-tkJ-3i28, August iy«4, Keport
In Publishing.
9. Trenholm, A., Oberacker, D. A., et
al., Performance Evaluation Of Full-
Scale Hazardous Waste Incinerators,
Volumes 1-5, EPA Contract 68-02-3177,
NTIS Nos. PB 85 129500, 129518,
129526, 129534, and 129542, November
1984.
10. Gorman, P. G., et al., Trial Burn
Protocol Verification At A Hazardous
Incinerator, EPA Contract No. 68-03-
3014, NTIS PB84-159193, August 1984.
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STORAGE, HANDLING AND SHIPMENT OF PESTICIDE WASTE-
REGULATORY REQUIREMENTS
Rolf P. Hill
U.S. Environmental Protection Aqency
Office of Waste Programs Enforcement
Washington, D.C. 20460
This presentation will address the storage and transportation aspects of
proper waste pesticide management under Federal law. Topics include the identi-
fication and classification of waste pesticides, notification reguirements, the
pre-transport reguirements of storage, packaging, labeling, marking and placarding,
the Uniform Hazardous Waste Manifest, recordkeeping, reporting and the farmer
exemption. Under each topic, the waste pesticide generator's or transporter's
reguirements and the problems they may face in trying to comply with the regulations
are discussed. Problem areas include waste determination, proper use of Department
of Transportation nomenclature, compliance by small guantity generators, proper
storage of waste pesticides, and compliance by commercial applicators.
Special focus is made on compliance with the new Uniform Manifest reguirements
and the impact of State laws on completion of this manifest.
Another area of focus is the RCRA reauthorization reguirements for small
guantity generators — which includes waste pesticide generators.
National enforcement priorities and penalties are contained in the
presentation. Although generators and transporters of hazardous waste account
for the smallest percentage of EPA enforcement inspections, they represent a
large national total. Additional enforcement inspections by other Federal agencies
and state offices will augment the EPA program.
This presentation is aimed at pesticide users who generate or transport a
hazardous waste and who must comply with Federal hazardous waste management
standards. The purpose is to give these people a basic understanding of the
regulatory reguirements and enforcement ramifications.
WASTE PESTICIDE STORAGE AND
TRANSPORTATION
I. REGULATORY BACKGROUND:
The Resource Conservation and Recov- were promulgated in May of 1980. These
ery Act (RCRA) was passed by Congress in regulations establish a series of stand-
1976. The first set of regulations that ards including those for generators and
the U.S. Environmental Protection Agency transporters of hazardous waste. Many
(EPA) promulgated appeared in the Federal waste pesticides were identified as haz-
Federal Register in February 1980. The ardous waste and therefore are regulated
major portion of the regulations, however, under RCRA.
-95-
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II. GENERATOR/TRANSPORTER REQUIREMENTS
DETERMINATION
A qenerator's first obligation is to
determine whether he has a hazardous waste.
The generator may determine that his
waste is excluded from regulation according
to exemptions the Agency has established.
One of the exemptions is for solid wastes
which are returned to the soils as
fertilizers. If a generator's waste is
not exempted, a determination must be made
that will classify and identify the waste
he produces based on two general methods
EPA developed. The easiest method is by
finding the waste pesticide listed in the
regulation. There are two ways that
a waste can be listed. First, specific
identification of waste pesticides are
included (e.g., Aldrin and Dieldrin).
The second which is a more generic method
is one that identifies waste pesticides
based on the means of production. For
example, wastewater treatment sludge
from toxaphene production. The other
method reguires more general effort on
the part of the generator and involves a
general classification method that includes
the characteristics of waste pesticides.
These classifications are defined by EPA
as ignitable, reactive, corrosive and EP
toxic.
Depending on the method of determina-
tion used by a waste pesticide generator,
the level of compliance difficulty will
vary. If it is necessary to test a
waste to determine if it meets any of
the characteristics, this may cause the
greatest burden, including cost. A
higher level of technical expertise
GENERATOR REQUIREMENTS
• Waste Determination
• Notification
• Pre-Transport Requirements
(including Accumulation Time)
• Manifest
• Recordkeeping/Reporting
• Special Conditions
wil] also be reguired for some waste
determinations, and many waste pesticide
generators may not posess this technical
training.
EPA IDENTIFICATION NUMBER
Once a generator has determined that
he is regulated under RCRA, he must notify
EPA (or the authorized state in which he
is located) that he is a generator,
transporter, or owner or operator of a
treatment, storage, or disposal facility,
and obtain an EPA Identification Number.
This notification number is reguired
prior to offer!no hazardous waste for
transportation, transportina, or treatina,
storina, or disposing of a hazardous
waste. Application for an EPA ID Number
may be made on EPA Form 8700-12.
This reguirement is not likely to
cause a high level of compliance diffi-
culty. Also, since it is a one-time acti-
vity, the cost of compliance will be low.
UNIFORM HAZARDOUS WASTE MANIFEST
The Uniform Hazardous Waste
Manifest (UHWM) is a new reguirement
which became effective September ?0, 19R4.
The UHWM reguires the use of a specific
form for a manifest. Early reguirements
for the manifest did not include a specif-
ic form, but rather any form that contain-
ed certain information about a waste
shipment. The UHWM manifest was develop-
ed as a result of an effort on EPA's
part to minimize the burden of duplica-
tive paperwork reguirements placed on
generators after several states developed
their own manifest forms. Currently,
the UHWM incorporates all the Federal
information as a reguirement of the
manifest and provides a shaded area for
optional information. Otherwise, genera-
tors would have been faced with the
continued reguirment to prepare several
manifests for a sinale shipment of hazard-
ous waste as a function of individual
state reguirements. By reguiring the
use of the UHWM, other state information
reguirements are preempted by Federal
-96-
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law as a condition of transportation.
States may obtain the additional informa-
tion they believe is necessary directly
from the generator or from the treatment,
storage, or disposal facility, but they
may not detain a shipment of hazardous
waste that is otherwise properly mani-
fested for a minifest that does not
contain information in the shaded area.
The shaded area is, however, designed to
allow the states to collect the informa-
tion they believe is necessary without
duplication of paperwork.
EPA has made it simplier for states
that wish to obtain additional informa-
tion to do so by requiring generators to
acquire blank copies of the manifest frcm
those states most likely to require
additional information. EPA has develop-
ed a copy acguisition hierarchy that
requires generators to get copies of the
manifest first from the receiving (or
consignment) state. Second, if the
receiving state does not distribute
copies of the UHWM, the generator must
obtain copies from the state in which he
is located (the generator state). If
neither the receiving state nor the
generator state distribute the UHWM, the
generator may get copies of the manifest
from any source.
This hiearchy was developed to
provide the consignment state with the
first opportunity to identify any addi-
tional information they believed neces-
sary to run their hazardous waste manage-
ment program since that state would have
the ultimate responsibility for manage-
ment of the waste. It should be noted,
however, that where the receiving state
and the generator state have duplicative
or different information reguirements
for the shaded area, that the generator
and the states involved must resolve any
potential problems that result.
Management and tracking of the mani-
fest includes signatures by the generator,
each transporter and the owner or operator
of the designated facility. If the
generator has not received a signed copy
of the manifest back from the facility
within 45 days he is obligated to submit
an Exception Report to the Regional
Administrator. (See a more complete
discussion of Exception Reports under
"Reporting", below.)
Compliance with the manifest system
is likely to be the most important aspect
of the generator's responsiblities.
Since the UHWM is the transportation
safety and tracking document that serves
as proof of proper management of a waste
shipment, cradle to grave, generators
should take special care to ensure that
it is handled properly. Generators
should take care to properly identify
their waste shipment on the manifest and
establish a good internal tracking system
to help ensure timely follow-up.
PRE-TRANSPOTT
The next reguirement for generators
is the compliance with pre-transport
reguirements which include standards for
packaging, labeling, marking, placarding
and accumulation time (or temporary
storage). Since most of these standards
are related directly to transportation,
EPA chose to reference the existing
Department of Transportation (DOT)
requirements in most cases. Specifically,
the POT reguirements for packaging,
labelina, marking and placarding are
adopted by EPA for hazardous waste gener-
ator pre-transport requirements. In
addition to the DOT standards, EPA estab-
lished new marking requirements and
requirements for accumulation of hazard-
ous wastes prior to treatment, storaqe,
or disposal. The EPA marking require-
ments require the generator to mark each
container of 110 qallons or less with a
specific statement:
HAZARDOUS WASTE: Federal Law Prohibits
Improper Disposal. If found, contact the
nearest police or public safety authority
or the U.S. Environmental Protection
Agency.
Generator's Name and Address
Manifest Document Number
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The accumulation time provision
allows generators up to 90 days to hold a
hazardous waste without obtaining a per-
mit for storage, provided they meet
certain reguirements. These standards
include the use of tanks or DOT contain-
ers and compliance with certain reguire-
ments for owners and operators of treat-
ment, storage, or disposal facilities
(including container and tank management
requirements and certain prevention and
contingency/emergency reguirements). In
addition, each container must be marked
with the words "HAZARDOUS WASTE" and the
date upon which accumulation began.
Although most of the pre-transport
reguirements reference existing DOT
standards, there may be some initial
compliance difficulties for waste pesti-
cide generators not familiar with those
standards. The accumulation time provi-
sion may cause additional compliance
problems particularly for those waste
pesticide generators who are sometimes
small guantity oenrators. Close scrutiny
of waste management practices will,
however, help alleviate most of these
problems. Many waste pesticide genera-
tors may find it beneficial to utilize
the services of specialized transporters
experienced in farm waste or small quan-
tity generator waste management.
PRE-TRANSPORT
REQUIREMENTS
• Packaging
• Labeling
• Marking
• Placarding
• Accumulation Time
DOT EPA
X
X
X X
X
X
NOTE: Changes in the accumulation time
and small guantity generator reguirements
are being made as a result of recent
Congressional changes to RCRA. See
Section III, RCRA Reauthorization, below.
RECORDK EEPINO/REPORTING
Record k eep i ng:
The recordkeeping practices reguired
of generators under RCRA are in keeping
with most qood business recordkeeping
practices. Copies of documents such as
manifests, Biennial Reports and Exception
Reports are reguired to be kept for at
least three years. Similarly, copies of
test results, waste analyses, or other
assessments made as a result of determin-
ing whether a generator is regulated
must be kept for at least three years
from when the waste was sent for on-site
or off-site treatment, storage, or dispos-
al.
The periods of retention (at least
three years) are extended automatically
during the course of any unresolved
enforcement action regarding the regu-
lated activity or as requested by EPA.
Reporting:
Generators who ship hazardous waste
off-site must submit a single copy of a
Biennial Report to the Regional Adminis-
trator by March lst of each even numbered
year and the report must cover informa-
tion gathered during the previous calen-
dar year. These reports contain seme
administrative information plus descrip-
tions of the wastes managed including
the amounts shipped off-site.
Exception Reports must be file by
the generator for every manifest not
signed by the owner or operator of the
designated facility and returned within
45 days from the date of shipment. The
Exception Report contains a legible copy
of the manifest and a letter that ex-
plains the generator's effort to locate
the hazardous waste and the results of
those efforts.
Additional reporting may also be
required by EPA.
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Compliance with the recordkeepinq
and reporting requirements is not expected
to be difficult. No special technical or
costly management practices will be in-
volved in complying with the recordkeep-
ing or reporting requirements.
SPECIAL CONDITIONS:
The generator standards contain two
special conditions. One, international
shipments, is not likely to effect waste
pesticide generators as much as the other,
the farmer exemption.
The farmer exemption allows a farmer
disposing of waste pesticides from his
own use to do so on his own property if
he complies with the disposal instruc-
tions on the label and triple rinses the
pesticide container.
For many farmers, this provision
will allow them to manage their hazardous
waste pesticides without substantial
burden of regulation under RCRA. The
good pesticide management practices of
mix control, application seguencing and
rinse water reuse will also help minimize
the generation of hazardous waste pesti-
cides. Extension to the time a generator
may hold his hazardous waste without
needing a permit will soon be extended
frcm 90 days to 180 days for small quan-
tity generators (SCGs) and 270 days for
SOGs who ship thier waste over 200 miles
(see Section III, RCRA Reauthorization,
below). Other generators will still
have 90 days to accumulate up to 1000kg
of hazardous waste prior to treatment,
storage, or disposal. These accumulation
times will allow generators, and especial-
ly farmers, sufficient time to prepare
economically feasible quantities for
shipment off-site.
III. RCRA REAUTHORIZATION
Small Ouantity Generators (SCGs)
Congress reauthorized RCRA at the
end of 1984. Part of that reauthoriza-
tion requires the Agency to develop
standards for small quantity generators
that lower the exemption level from 1000
kilograms per month (kg/mo) to 100 kg/mo.
The effect that this will have is to
increase the number of generators from
approximately 55,000 to about 175,000.
Waste pesticide generators are among the
top ten newly regulated generators.
Sane relief, however, is provide to
SOGs. Since, by definition, SOG will be
producing small quantities of hazardous
waste, the amount of waste they will
accumulate in a 90-day period is also
likely to be very small and uneconomical
to ship off-site. Congress, therefore,
has allowed for an extension of the 90
day accumulation time provision. The new
requirement will allow for 180 days or
270 days if the waste will be shipped to
a treatment, storage, or disposal facil-
ity over 200 miles away. In addition,
SOGs will be allowed a maximum of 6000
kilograms of accumulation rather than
the 1000 kg limit for other generators.
There may also be some relief for
SQGs effective August 1985. The reauth-
orization provisions establish a minimum
manifest. This provision would reduce
some of the information requirements but
this reduction in information is not
considered by seme to be a significant
savings.
Compliance difficulties for waste
pesticide generators is not likely to be
any more difficult than for other waste
generators with the exception that many
farmers, together with all small quantity
qenerators, will not be familiar with
federal hazardous waste management rules.
The EPA is examining the possibility of
an education program aimed at SOS's, and
therefore farmers, the purpose of which
would be to explain the requirements of
the new regulation. It is expected that
specific industry categories, will be
targeted for special attention (e.g.,
farmers, automotive services, metal
finishers, photography). Once the learn-
ing process has been achieved, compliance
with the lower exemption levels is not
expected to be difficult.
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TV. ENFORCEMENT STRATEGY
EPA has developed an enforcement
strateqy that helps us to manage our
resources effectively and to promote an
aggressive enforcement program. The
result is a strategy that calls for
inspections of all major hazardous waste
handlers (including 3% of all generators
and transporters), 25% of all non-major
hazardous waste treatment, storage, or
disposal facilities, 7% of non-major
generators and transporters, and 100% of
closed treatment, storage, or disposal
facilities.
Major hazardous waste handlers
include: 100% of facilities subject
to ground-water monitoring, all
incinerators, 10% of remaining treat-
ment, storage, or disposal facilities
and 3% of generators and transporters.
Although 3% of major generators and
transporters and 7% of non-major genera-
tors and transporters is not a large
percentage, the number of inspections is
relatively large. There are several
other factors that increase the number of
inspections that are likely to occur
against generators of hazardous waste.
Some of the major and non-major handlers
that will be inspected will also be
generators.
States that are authorized to run
the hazardous waste program will be
required to have an inspection strategy
similar to EPA's. They will, however, be
allowed to have a more stringent program
and as a result, may have a more string-
ent inspection program. Further checks
on compliance will be conducted as a
matter of routine inspections conducted
by other Federal agencies, in particular,
the U.S. Department of Transportation.
V. PENALTY POLICY
The RCRA administrative penalty
policy establishes a procedure by which
administrative penalties can be calculat-
ed in a fair and consistent manner. It
is designed in such a way that penalty
amounts should reflect the gravity of the
violations and eliminate any economic
benefit gained through non-compliance.
The penalty amount is initially
determined by consulting a 3x3 matrix
which considers on one axis the potential
for harm resulting from the violation and
on the other axis, the degree to which
the violator deviated frcm the regulatory
requirement. The basic penalty amount
can then be adjusted on the basis of
several additional factors, includinq:
"economic benefit derived from
non-compliance
°qood faith efforts to comply
°degree of willfullness and/or
negligence
°history of noncompliance
"ability to pay (downward
adjustment only)
"other factors.
Further, the basic penalty can be consid-
ered a per-day penalty and can be multi-
p]ed by the number of days of non-compli-
ance, if the Agency so chooses.
TABLE I
PENALTY POLICY MATRIX
Extent of Deviation
from Requirement
p
o
t
e
n
t
i
a
1
f
o
r
H
a
r
m
Major
Moderate
Minor
Major
$25,000
to
$20,000
$10,999
to
$ 8,000
$2,999
to
$1,500
Moderate
$19,999
to
$15,000
$ 7,999
to
S 5,000
S 1,499
to
$ 500
Minor
$14,999
to
$11,000
S 4,999
to
$ 3,000
$ 499
to
$ 100
ALL PENALTY AMOtlNTS ARE PER DAY VIOLATIONS
-100-
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The administrative penalty policy
was developed for EPA use. It was in no
way intended that the States would be
required to follow the policy, although
they are welcome to do so if they choose.
It should be noted that the penalty
amounts suggested in the matrix are based
on the maximum penalty authorized by
RCRA - $25,0no/day/violation. State
statues may or may not authorize the
assessment of similar amounts of penal-
ties.
NOTE; The RCPA/Superfund Hot Line is
available to answer any questions you
have regarding this or any other RCRA
topic. [(800) 424-9346 — In Washington,
D.C. call 382-3000].
ALSO NOTE; The EPA Small Business
Ombudsman is also available at (800)368-
5888 to assist small business faced with
conpliance with EPA regulations.
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THE LOGISTICS OF TRANSPORTING PESTICIDE WASTES
FROM THE USER TO DISPOSER
William B. Philipbar
Rollins Environmental Services, Inc.
Wilmington, Delaware 19899
ABSTRACT
The new RCRA reauthorization act will require that most pesticide wastes be dis-
posed of in a RCRA approved incinerator, and it will also increase the number of
generators of pesticide wastes that will be subject to RCRA regulations.
There are only five major commercial incinerators in the United States that can
incinerate pesticide wastes, which means that the wastes will have to be transported
long distances for disposal. To economically accommodate the logistics of picking up
small quantities of wastes and transporting them long distances, transfer stations are
needed throughout the pesticide use areas. At these transfer stations, small quantities
of wastes would be consolidated and shipped by tractor trailers or rail cars to the dis-
posal facility.
The paper covers the operation of the transfer station, the type of company that
would likely operate the station, and the transportation requirements from the generator
of the pesticide wastes to the transfer station and then to the disposer.
DISCUSSION
"The Hazardous and Solid Waste Amend-
ments of 1984" - The Resource Conservation
and Recovery Act (RCRA) reauthorization
will have far reaching effects on those
involved with pesticides. The three major
effects of this legislation and the resul-
ting regulations on the user of the pesti-
cide, who is the generator of the pesti-
cide wastes, the transporter of the wastes,
and the disposer of the wastes are:
• Many more generators will be
covered by RCRA regulations because of the
generator definition being changed from
those who produce less than 2,200 pounds
of waste per month to those who produce
less than 220 pounds per month.
• Additional types of pesticide
wastes will be regulated by RCRA.
• Restrictions on the treatment/
disposal processes used to handle pesti-
cide wastes.
This means there will be greater vol-
umes of pesticide wastes to manage under
the new RCRA standards and that there will
be fewer treatment/disposal facilities
available that can meet the new treatment/
disposal criteria. This in turn means
that wastes will probably have to be ship-
ped greater distances for treatment/dis-
posal. The costs for managing these wastes
will obviously increase because of the more
costly treatment/disposal requirements
along with longer shipping routes.
A higher percentage of the organic
pesticide wastes and the solvents used to
flush empty contaminated containers will
probably have to be incinerated because
of the forthcoming RCRA regulations.
There are presently only a few such incin-
erators available, and with the present
siting problems, there is a very slim chance
that major new incinerator capacity will
come on stream in the near future. This
will generally mean longer hauls between
the generators and the disposer's sites.
-102--
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If all the generators had full 42,000
pound truckload quantities of wastes, the
transportation problems would easily be
solved. However, with a number of small
generators, and with a large part of the
waste problem being the disposal of con-
taminated empty containers, new solutions
have to be forthcoming.
Transfer station networks have to be
established to accommodate the small gen-
erator's wastes, so as to most cost effec-
tively clean and return the containers to
commerce, and to prepare the wastes for
bulk shipment to the disposer. There is
no such major network presently operating
in the United States. There is a govern-
ment sponsored container collection pro-
gram in operation in Alberta, Canada that
is described in James L. McKinley's paper,
"The Pesticide Container Collection Program
of Alberta, Canada". To fill this void in
the United States, a transfer network could
be established by:
Distributor of the Pesticide
Manufacturer of the Pesticide
Local Hauling Company
Disposal Company
Government
What would be the transfer station
and transportation needs? One scenario
is a pesticide distributor and a major
transporter/disposal company working to-
gether to solve the generator's pesticide
waste problems.
The empty, contaminated pesticide
containers would be picked up at the gen-
erator's site by the same truck that the
distributor used to haul the full contain-
ers. This truck would have to be properly
placarded and, depending on the forth-
coming small generator regulations, may
also have to have a hazardous waste mani-
fest.
As an option to this, the generator
could transport his own containers direct-
ly to the transfer station. Again, appro-
priate truck placarding and manifesting
would have to be followed. In actual prac-
tice, both of these options would probably
happen. The local transfer station could
be part of the distributor new product
warehouse. When a full truckload of con-
tainers were collected at the local trans-
fer station, the containers would be sent
to a regional process/transfer station.
At these stations the metal and plastic
containers would be separated and the
smaller than 55 gallon shredded.
The shredded metal and plastic would
be solvent washed. One appropriate approach
would be to utilize a Freon cleaning sys-
tem. This system would include a Freon
distillation column so that the Freon and
pesticide wastes can be separated, with the
Freon being reused and the pesticide waste
isolated for transportation to a treatment/
disposal site. This system would reduce
the costs of the solvent used, and also re-
duce the amount of contaminated solvent
that would have to be disposed. If the
pesticide was water soluble, a triple rin-
sing with water would take the place of the
solvent cleaning.
The cleaned metal and plastic can be
sold into the reclaim market, or if no mar-
ket exists, sent to a local sanitary land-
fill. The pesticide wastes can be contain-
erized in 55 gallon steel drums, or if the
quantity dictates, pumped into holding
tanks.
Since this facility would be process-
ing and storing RCRA controlled wastes, it
would have to have a RCRA permit, and be
in compliance with the appropriate RCRA
regulations. Unless the regulatory agen-
cies can simplify the permitting procedures,
this permitting aspect of this operation
could be a major problem, and one that could
cause long time delays in implementing
these plans.
The transportation between the trans-
fer site and the treatment/disposal facil-
ity would be by box tractor trailer if the
wastes were in drums, or if in bulk a
5,000 gallon tractor tank trailer or a
20,000 gallon rail tank car. For most pes-
ticide wastes, carbon steel would be the
material of construction required for these
tankers. If water was used as the wash
medium, it would have to be collected and
analyzed for the degree of contamination.
The disposal of the contaminated water
would depend on the amount and type of pol-
lutants present. The disposal options
would range from discharge to local sewer
to incineration.
The waste shipments would require a
waste manifest, with the transfer facility
being considered the generator. The trans-
portation costs for shipping truckloads
-103-
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of hazardous wastes are about $2.75 to $3.00
per loaded mile and rail shipments about
$1.00 per loaded mile.
High temperature incineration would
probably be required for the disposal of
the pesticide waste mixture. If this is
the case, the wastes would be transported
to the incinerator facility, and before the
material was offloaded from the transport
vehicle it would be sampled, analyzed, and
a decision made on what storage tank it can
be pumped to and what incineration condi-
tions are needed to incinerate it. The
waste is pumped from the storage tank to a
blend tank, where it is mixed with other
wastes to achieve a blend for optimum burn-
ing. The incineration would take place at
temperatures above 2000°F with destruction
efficiencies of greater than 99.99%.
Based on ballpark economics, it is
felt that a 5 gallon container could be
handled through this system, including
cleaning, transportation and disposal of
the residues for under $5.00 per container.
Although this price may seem high in
comparison with present disposal costs,
the RCRA regulations are going to dictate
more stringent requirements for the manage-
ment of our pesticide wastes, which are
all going to cost additional money.
CONCLUSION
The scenario presented is a practical,
cost effective approach. The greatest
hurdle in putting this plan into action is
not attracting private enterprise to par-
ticipate, but obtaining the cooperation
from the regulatory agencies in obtaining
the necessary permits and approvals.
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EMPTY PESTICIDE CONTAINER MANAGEMENT
AN OVERVIEW
Harry W. Trask
Environmental Consulting
John St., Goodwins Mills
RFD#3, Biddeford, ME OAOOf
ABSTRACT
There are three basic options for managing empty oesticide containers
including return for reuse, recycling, and disposal by burning or burial in
aonroved facilities. Fn.ch is surrounded with economic, environmental, and
institutional barriers, and are not widely practiced; containers continue
to pile up in uncontrolled sites which evoke citizen comulaints and provide
a basis for regulatory action. Open burning and burial in fields is no
longer legal under environmental legislation, and applicators are starting
to express concerns regarding their options. A major institutional barrier
is the EPA definition of empty, which varies depending on which hazardous
waste list the pesticide is on; amendments cause confusion over whether a
container must be triple rinsed, and the provision for an inch of residue
in some containers worries landfill operators.
Recycling currently is the best available option, but substantial
research work on plastic containers is urgently needed. Plastic compounds
used need to be identified, and the behavior of pesticides at the tempera-
tures used in plastic reforming needs to be described. Similarly, operators
of resource recovery/trash-to-energy facilities require data on products of
combustion of pesticide containers and residues.
Overall, a major communication crisis exists between the pesticide
community and the waste management community. Concerted efforts must be
made by those who make, sell, use, and regulate pesticides to learn how to
convince waste handlers and their regulators that 'empty1 containers are not
hazardous wastes. Development of programs to promote proper rinsing will
help, but an on-site verification procedure also is necessary. Failure to
address this situation now will increase the broadly-based pressure that
already exists to legislatively mandate the return of containers to the
manufacturers for reuse.
INTRODUCTION
At the National Conference on Pesticide Containers in 1972 a number of
problem areas were identified. These related to : a convenient means to
decontaminate containers; reduction of the hazard of pesticide exposure to
landfill workers; disposal of containers at airstrips; need for more infor-
mation by States to regulate containers; and the urgent need for better
communication between Industry, government, and the public. Not much has
been done to resolve these problems, and the same concerns are expressed
by the same people today.
In 1978 many of these same problems were repeated at EPA's Pesticide
Disposal Research Symposium. In addition, a plea was made for the devel-
opment of inexpensive, simple, low-technology methods that could be used
by farmers and commercial applicators. It also was suggested at that forum
that an examination of the impact of all Federal rules on pesticide con-
tainer disposal be made, and that research into ways of communicating with
-105-
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the public regarding pesticides and
containers be undertaken. There is
no evidence that any of these concern
have been resolved, or that serious
study is underway. We still do not
have any simple 'water bucket1 chem-
istry methods for decontamination, or
soil column filtration and land dis-
posal techniques. Organized pro-
grams to promote proper rinsing do
not seem to exist, and there appears
to be little or no sentiment on the
part of industry to cooperate. No
moves have been made to improve com-
munications, on a national level,
with the waste management industry,
and the need for addressing citizens'
concerns seems to have been for-
gotten .
AVAILABLE OPTIONS
There are only three basic and
feasible options for dealing with
the management of 'empty' containers.
These are return for reuse or re-
filling, recycle to the scrap stream
of for energy recovery, and disposal
by burial or burning in approved fa-
cilities. Each has its own set of
economic, environmental, and insti-
tutional problems which must be dealt
with before being put into practice.
Disposal by open burning or burial
in the field is not viable, long term,
because of prohibitions in the many
environmental laws that have been
adopted to help prevent further envi-
ronmental insult.
A first step in using any of the
feasible options is to make sure the
container is empty. According to EPA
rules, an empty container is not a
hazardous waste, and thus can be han-
dled or disposed of in a facility that
does not need a hazardous waste per-
mit. These rules, which provide the
basic guidance for many States, are,
however, confusing. As shown in the
table (Table 1.), a pesticide con-
tainer may need to be triple rinsed,
or it may contain an inch of residue
and still be classified as empty,
depending on which hazardous waste
list the pesticide is on. Note that
TABLE 1. EPA EMPTY CONTAINER RULES*
Size of Container
Type of Waste 110 gal. 110 gal.
Acute Hazard.
Toxic Hazard.
Tr. Rinse Tr. Rinse
1 inch or 0.3% wt/vol
3% wt./vol residue
residue
•"-Basis: 4-OCFR261.7, 1984..
these were the rules, as far as
could be determined, in the fall of
1984-. Continuing amendments to the
EPA hazardous waste regulations tend
to change the type of waste that is
assigned to each pesticide, and the
impact of new requirements in the
amendments to the Resource Conser-
vation and Recovery Act (RCRA) have
yet to be felt. EPA could make a
major contribution to dealing with
this institutional barrier by issuing
interpretations on a timely basis
that can be readily understood by
both the pesticide community and by
those who must handle and regulate
the disposal of municipal wastes.
HOW CLEAN IS CLEAN ?
In a practical sense, it seems
apparent that all containers must
be triple rinsed, since continuing
changes in the EPA hazardous waste
lists categories may change the ex-
isting rules. But another, and per-
haps more important, reason is to
help convince waste managers that it
is safe for them to accept empty
containers. Even with the best
procedures, some small residues may
remain, as shown in Table 2. These
TABLE 2. TRIPLE RINSE CALCULATIONS*
Residue
Stage
Drained
Rinse/Drain 1 .
Rinse/Drain 2.
Rinse/Drain 3-
Liquid
1 oz .
1 oz .
1 oz .
1 oz .
Pesticide
U.1875**.
0.2183g.
0.0034e.
0.00005s;.
-"-Basis 4- lb/gal.5 gal., 10f, of vol.
-106-
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theoretical, calculated data are
based on rinsing a 5 gallon metal
container which formerly contained
a 4 lb. per gallon formulation with
solvent equivalent to 10% of the
capacity of the container (2 qt.).
Assuming full 'solution' at each
rinse step, and draining until no
more than 1 oz. remains, there will
still be some residues left. While
residues from a single container may
seem insignificant, quantities may
become measurable when a larger num-
ber is involved, as shown in Table 3.
TABLE 3. IMPACT OF THREE RINSES
Stage
After
After
After
After
Pesticide left in
25,000 containers
draining
1 st rinse
2nd rinse
3rd rinse
780
12
0.2
0.003
lb.
lb.
lb.
lb.
It becomes very clear, then, that we
need to triple rinse in order to re-
move these residues from containers,
and put them in the spray tank where
they belong.
THE RE-USE OPTION
Manufacturers have long consid-
ered taking containers back and re-
using them, but except for a few
specialized cases, have rejected the
option out of hand. Reasons given
are costs (new containers have been
cheap,comparatively) , DOT regulation
of certain types , and the potential
for cross contamination in the event
of another pesticide being put into
a labeled container. However, this
option needs to be rethought, after
some serious study of these problem
areas. Calls for legislation to
mandate reuse were heard many times
during development of container reg-
ulations in Maine, and not only from
environmentalists and regulators;
dealers and users also think it's a
good idea. A re-evaluation of all
the factors involved could provide
data for use in development of pro-
grams to forestall the passage of
precipitous laws that might be dif-
ficult to live with.
RECYCLING OPTIONS
Recycling metal, glass, and
plastic containers into the scrap
stream remains the best and most
reasonable option. The small res-
idues of pesticides are totally
consumed by heats of upwards of
2000°F. used in melting steel and
glass. Unfortunately, not all of
the containers sent for recycle
have been properly rinsed, and the
scrap handlers have, in some cases,
refused to accept them. A means of
verification that containers really
have been triple rinsed, one that
can be demonstrated on the spot and
for each container if necessary, may
be the only solution to this problem
area. Managers of recycle operations
must be convinced that only clean
containers will be delivered, and
assured that the sins of the past
won't be repeated.
Plastic recycling is a whole
different matter. Lower tempera-
tures used in molding are not high
enough to destroy pesticide residues
but may be sufficient to cause the
generation of fumes. Plastic re-
cyclers are reluctant to accept con-
tainers when there is a lack of
knowledge concerning the potential
compounds they may encounter. Yet,
manufacturers continue to adjust
the mix of resins and plasticizers
used in containers for specific
pesticides and formulations. There
also is genuine concern that the
relatively porous walls of plastic
containers may retain some of the
pesticide; as one person described
it, "those pesticide-soaked jugs."
-107-
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These problems should be studied
to facilitate plastic recycle. Many
products, such as sewer pipe, soil
drainage tubing, agricultural mulch
film and others offering sizeable
markets may be appropriate uses for
this scrap. And there aren't many
institutional problems here, since
environmentalists and regulators by
and large support the concept and
will work to facilitate it.
RESOURCE RECOVERY
Recycling containers via resour-
ce recovery plants means converting
combustible containers into energy,
usually with high temperature incin-
erators. Modern units generally can
reach the temperature levels needed
to destroy all the fumes from pesti-
cides, but many are not operated at
such levels continuously. Operators
need to know ahead of time what the
burning characteristics are for each
pesticide, and they also need to be
aware of the potential for harmful
stack gases, such as chlorine, sulfur,
bromine, fluorine and the like. A
major concern is the amount of dry
material (powder,dust,etc.) that may
cling to bags, boxes, and fiberboard
drums, as well as liquid pesticides
that may have soaked into the walls
of plastic jugs.
Generally speaking, operators of
resource recovery plants will accept
empty pesticide containers if asked.
However, they also want to know more
information about the burning pro-
files of pesticides than is generally
available. Thus, some advance plan-
ostablishmsnt of ?ooci com-
munications are absolutely necessary
if this option is to be viable. Un-
fortunately, as EPA noted at this
workshop, data on incineration of
most pesticides are not available at
this point in time.
There is an urgency to develop
the necessary data and information.
Increasing concerns about the impact
of landfill leachate on groundwater
have led the waste community to favor
disposal of all combustibles in such
resource recovery plants. The time
may come when landfills will be off
limits to all but inert wastes.
DISPOSAL
Final disposition of those
containers that could not be reused
or recycled traditionally has been
in landfills or out on the back
forty. Sometimes these were buried
properly, sometimes improperly, and
sometimes not at all. It's the last
method that has caused so much con-
cern and stimulated passage of laws
to control disposal.
Burial in the field where the
pesticide was used has long been
recommended by manufacturers and
agriculturists. Many container
labels still have such recommenda-
tions. The amended RCRA, however,
precludes this option, since it
mandates that disposal of any waste
in a non-approved site be called
'open dumping', which is prohibited.
Similarly, open burning of pes-
ticide containers is prohibited by
Federal and most State laws. The
concerns center around the lack of
knowlede^ concerning unburned or
partially burned containers and res-
idues. Often compounds more toxic
than the parent pesticides are gen-
erated around the edges of open and
uncontrolled burning sites. Until
these can be identified and their
toxicities described, it's likely
that open burning will continue to
be banned most everywhere.
LANDFILLS
Pesticide containers that have
been triple rinsed or equivalent
are classified as non-hazardous by
Federal rule0: on hazardous waste.
While many States use these as a
basis for their own regulations, not
all agree with the classification.
As a result, some States classify
triple rinsed pesticide containers
as 'special waste', and require any
landfill wishing to dispose of them
to obtain a special permit. In at
least some cases, this is the only
excuse needed to prohibit disposal
of pesticide containers, especially
in areas where there have been prior
concerns about pesticides.
In a larger sense, landfill op-
erators have major concerns over how
-108--
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well containers were rinsed and
how well they were drained. The
importance of good draining after
each rinse step can easily be seen
in the calculated residues shown in
Table 4- The residues remaining
TABLE 4. IMPORTANCE OF DRAINING
Stage
Liquid residues
2 oz. 3 oz .
After draining
After 1st rinse
After 2nd rinse
After 3rd rinse
. lb. pesticide)-"-
1560 2340
47
0.04
105
4.7
0.2
* 25,000 containers
when all except 1 ounce was drained
were shown earlier. These data re-
veal that while linear increases can
be expected after the first drain
step, residues higher than this can
be expected after the rinse/drain
steps. Thus, it becomes extremely
important to drain containers as
completely as possible at each stage
in the triple rinse procedure. It
also becomes apparent that containers
should be punctured to facilitate
good drainage as well as to prevent
unauthorized reuse.
Even if well rinsed and drained
containers, with verification, are
delivered to landfills, operators
may be reluctant to take them for
another reason. Landfills are ex-
pensive; capital costs in the North-
east range from $15,000-25,000 per
acre for unlined sites, and from
$70,000-85,000 per acre for sites
where linings are necessary. A site
to handle the wastes for 20 years
from a community of 5,000-8,000 will
require 30-40 acres. Officials who
must raise the funds and fight for
site approvals aren't exactly happy
when approached with demands to take
a waste that not only will help fill
up the landfill faster, but may be
the cause of problems in the future
if some of the containers were not
properly rinsed and drained. Again,
an urgent need for communications.
THOUGHTS AND SUGGESTIONS
The pesticide community needs to
start paying serious attention to
this problem. Research in the past
has focused on degradation and dis-
posal of pesticides, but little has
been done on containers. A place
to start is the development of a test
that can be used on-site to verify
that containers have been properly
rinsed. A start on such a quick
test has been made in Maine for a
limited number of compounds; it
should be expanded to be useful on
the national scene.
Work also is needed on how to
deal with dried-on residues. Many
applicators plead that there is not
enough time during their busy hours
to properly rinse containers as
they are emptied. Yet, there are
no practical methods to remove the
residues that dry out before rinsing.
Landfill operators fear that the
"garbage juice" found in their sites
may be strong enough to dissolve
these residues and result in con-
tamination of their liquids. Even
if they are wrong, work to show
what does happen is needed.
The pesticide community also must
learn how to communicate effectively
with the waste community and the
public on this matter. We must
learn how to convince everyone that
we are a responsible group and that
we really are cleaning up our act.
We need to achieve credibility in
order to do this, and perhaps a
good start would be to initiate some
highly visible training programs to
promote better rinsing of containers.
These need to be well planned, and
involve all of the pesticide com-
munity - manufacturers, dealers, and
distributors as well as users, reg-
ulators, and educators. If the pub-
lic can see for itself that real
efforts are being made, then perhaps
some of the hysteria can be dealt
with in a rational manner. Media
cooperation in such programs is
absolutely necessary; they are often
uncritical in their treatment of the
so-called deadly chemicals, and pes-
ticide containers seem to fall into
that category, whether rinsed or not.
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Another suggestion is to develop
some creative enforcement policies
and ideas to replace the confron-
tational programs of the past. Reg-
ulation of the disposal of pesticides
and containers cuts across several
programs at both the Federal and
State levels. These programs need
to be coordinated so that new ideas
and plans put into effect by one
agency won't be shot down by another.
Conversely, programs clearly at odds
with existing rules should never be
allowed to surface.
SOME QUESTIONS
One question that has bothered me
for a long time is "Why does every-
one except those in the pesticide
community get so emotional whenever
the word 'pesticide1 is mentioned ?"
Do all those people think that we
are irresponsible and out to poison
them and the environment ? What
brought us to this situation ? More
importantly, what can we do about it
now ? Is it our desting to always be
on the defensive, and scorned by the
public in general ?
Are people skeptical about our
intentions because no truly deman-
ding training courses or programs
are required for those who use the
most toxic pesticides ? Would it be
an improvement if dealers and dis-
tributors - locally perceived as the
real experts - established some tough
standards for training their own
workers, and publicized this ? And
then assisted in training others ?
What should the roles be for dealers
a.nd distributors in disposal ?
Would their credibility be improved
if they were in the inspection and
verification chain to assure that
containers are properly rinsed ?
A LAST THOUGHT
In an overall sense, we cannot
have practical and successful empty
container management programs unless
we have the full cooperation of the
waste management industry, including
the regulators. Whether we elect to
send empty containers to the scrap
stream, recycle them for energy, or
dispose of them by burning or burial
in approved facilities, we can do it
only with appropriate permission and
oversight. A first step, then, must
be to establish good lines of com-
munications; only then can we learn
how to speak their language, and
work to improve our credibility.
It must be said that we need them,
but they don't need us.
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ALBERTA PESTICIDE CONTAINER COLLECTION PROGRAM
James G. McKinley
Alberta Department of Environment
Edmonton, Alberta, Canada
ABSTRACT
The lack of convenient disposal facilities for empty pesticide containers prompted
the Alberta Government to initiate a province wide container collection and disposal
system.
The use of pesticides has become a very
integral part of agriculture. Farmers have
become very dependent upon the use of
chemicals to maximize their annual crop
production. This chemical dependency has
promoted a dramatic increase in the number
and type of pesticides available for use.
Due to the increase in pesticide use and
the potential hazards associated with
pesticides, the safe disposal of the empty
pesticide containers has become important.
Despite potential hazards, the undertaking
of safe disposal methods has not been
followed by many users of commercial
pesticides. Often, empty containers have
been discarded as conveniently as possible.
The containers have not been rinsed,
punctured or crushed as recommended. Most
empty containers have been mixed with
various forms of garbage and deposited in
unapproved landfill sites. Empty pesticide
containers have also been dumped in out-of-
the-way, seemingly unimportant areas. Such
areas have included coulees, river banks,
creeks, roadside ditches or various corners
of private land. Some of the containers
that were not discarded are being re-used
for such purposes as carrying feed or
water. Unfortunately, public awareness of
recommended safety precautions and proper
disposal methods associated with pesticide
chemicals has not kept pace with the
expanding chemical industry. Some
pesticide users seem to be either ignorant
or unconcerned of the consequences of
their actions. They do not realize that
by following the convenient method of
disposal, they have created hazards for
both themselves and their environment. To
complicate matters, approved disposal
sites that are equipped to deal with the
disposal of empty pesticide containers are
too few in number. Pesticide users often
had to travel a far distance to dispose of
their containers at these approved sites.
For most users, the inconvenience and time
involved to deliver the containers
discouraged them from following
recommended disposal procedures.
The continued use of unsafe disposal
methods has produced a situation of
concern to many officials. The lack of
public awareness and disposal alternatives
have contributed to the growth of
extensive public and environmental
hazards. A regular program involving
public information and the establishment
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of safe disposal methods will help to
alleviate and eventually eliminate these
hazards. In order for such a program to be
effective, the public must be convinced
that the disposal alternatives offered can
be equally or more convenient than their
present methods. The program must also
inform the public of the hazards they may
be faced with and the importance of
following the acceptable forms of container
disposal. The success of such a program
will require the co-operation of all
individuals concerned; chemical
manufacturers, governmental and local
authorities and the general public.
The pesticide container collection
program in Alberta has attempted to address
these problems with a cooperative program
which has not relied on legislation to meet
its objectives.
The program began in the summer of 1979
when large numbers of pesticide containers
were found in water bodies in southern
Alberta. It was decided at that time to
remove and dispose of these containers.
The containers that were removed were
temporarily stored at Environment property
with the idea to crush and landfill them at
a later date. However, farmers in the area
noticed what was happening and began
bringing containers to the storage area.
The result was instead of having 300
containers we now had 5000 and the
beginnings of a container collection
program.
Since that time the program has been
expanded to 78 permanent collection sites
and a yearly collection of over 500,000
containers. These sites are built to our
specifications by the local municipality
using a grant provided by the provincial
government. Each spring a contractor is
hired to remove the containers and residues
for recycling and/or disposal. We have
been attempting to recycle this material as
much as possible although the main purpose
of the program is to keep the containers
and residues from contaminating the
environment.
Pesticide containers are constructed
of metal, plastic or paper. The paper
containers (bags) are relatively easy to
handle and are either burned or
landfilled. The metal containers are
recycleable if handled properly. We have
tried numerous handling methods however,
the most cost effective and simplest is
the one we use. The container is crushed
with a simple hydraulic crusher and
transported to a scrap metal dealer.
There the crushed containers are stored
until they can be inserted into scrap car
bodies which are then recycled at a local
steel mill.
When the program began the number of
plastic containers collected was less than
10 percent of the total. That number has
been climbing steadily and this year,
1984, for the first time plastic
containers will exceed 50% of the total.
The recycling and/or disposal of this
plastic is much more difficult than the
metal. Our tests have shown that chemical
residues are completely broken down at the
high temperatures used to melt the metal.
However, we have no burning system
available for plastics and the pesticide
industry has informed us that they expect
to be 90X converted to plastic by 1990.
The material used in plastic pesticide
containers is a high impact polyethylene
which has many uses as recycled material.
However, the problem is that in order to
utilize the plastic the pesticide residues
must be removed and this requires that the
containers be shredded and washed. This
is not an inexpensive process as we found
out in 1983 when we cleaned 180,000
containers at a cost of $90,000. This is
not a cost effective process and a method
must be found to reduce the cost before we
can begin recycling plastic containers
again. In the interim we are now storing
the containers in a shredded form while we
search for an economical recycling method.
The program is a cooperative one
between the pesticide user, local
municipality and the provincial government.
The provincial government provide the
funding and administration, the local
municipality provides a collection point
and the pesticide user provides the empty
containers. This system has worked
exceptionally well and we estimate that 68X
of all commercial pesticide containers sold
in Alberta are voluntarily returned to a
collection site for disposal.
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MAINE'S RETURNABLE PESTICIDES CONTAINER PROGRAM
by
Robert L. Denny, Executive Director
Board of Pesticides Control
State House Station #28, Augusta, ME 04333
The State of Maine is in the
process of developing a program
for the management of all hard
plastic, metal and glass re-
stricted use and limited use
pesticide containers. The scope
of this program is not extremely
large. It is true that the Maine
restricted use list is somewhat
larger than the federal list. The
limited use pesticides, however,
are those that have shown unusual
propensity to cause environmental
or human damage due to chronic
exposure. Limited use pesticides
are, in effect, a kind of "super
restricted use" granted only in
circumstances where there are no
viable alternatives. At the pre-
sent time only two limited use
pesticides are in use in the
state.
In 1981 one of our inspectors
reported to me that he felt the
pesticides containers were being
improperly managed, particularly
in the northern portions of the
state, comprising Aroostook and
Penobscot Counties. Attention to
open dumping, visible from the
roads, resulted in an enforcement
action that year plus several in-
stances of compliance and clean
up. However, it was not until we
began aerial surveillance of
right-of-ways, looking for herbi-
cide damage and improper applica-
tion in the fall of 1981 when
midway through the program, we
discovered that we had found no
herbicide damage but had uncover-
ed 14 pesticide container dumps
in or adjacent to the utility
and railroad right-of-ways. We
shifted our emphasis in mid-
stream and have continued a simi-
lar type of program every year
since, resulting in the identifi-
cation of over 400 illegal and
open pesticide container dumps in
our state.
The cleaning up of pesticide
containers by burying them in the
ground is only a partial solution
of the problem. For one thing,
it is difficult if not impossible
to monitor on-farm burial sites
to determine if containers have
been adequately triple rinsed and
properly crushed and buried. The
opportunity for abuse and burial
of actual pesticide material is
quite great and the probability
of enforcement activity resulting
in prosecution is quite low.
Another avenue of container dis-
posal for plastics has been open
burning of these materials. Both
the burying on the farm and the
open burning in the field has
subsequently been banned by our
state's Department of Environ-
mental Protection. Today, in the
State of Maine, an applicator,
either commercial or private, has
few options for legal and proper
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disposal of pesticide containers.
Due to the fears of a chemophobic
society, an increasing number of
municipal landfills and even
metal recycling facilities are
becoming skittish about the
acceptance of any waste associa-
ted with pesticides. In order to
deal with the increasing squeeze
between environmental regulations
and proper use and disposal of
containers, the Maine Board of
Pesticides Control asked for and
received an authorizing 1983
statute requiring that: 1) all
containers under the scope of the
act must have identifying stick-
ers affixed by April 1, 1985; 2)
a deposit sufficient to encourage
the return of the container must
be collected by dealers at the
time of sale; and 3) containers
must be triple rinsed or equiva-
lent. As a result of a study
authorized by the 1982 legisla-
ture, the Board had already de-
termined that limited and
restricted use containers were
only a small fraction of the
total pesticide container pic-
ture, but that the mechanisms
put into place for their safe
return, disposal and public over-
sight would be useful for the
handling of all pesticide con-
tainers .
The act and the regulations
which implement it are designed
to: 1) provide a tracking system
for said containers; 2) reduce
the potential for surface and
groundwater contamination; 3)
provide for improved solid waste
management; 4) encourage material
recycling and promote refillable
containers; 5) increase confi-
dence of the municipalities and
the general public that triple
rinsed containers are safe; 6)
prevent unauthorized use ard
handling of empty containers; and
7) encourage the use of the least
toxic pesticide that is practi-
cable for a given application.
On November 19, 1984 the
Board adopted its regulations to
implement the 1983 statute, and
they cover three types of situa-
tions: 1) when pesticides are
purchased within the state; 2)
when pesticides are purchased
outside of the state; and 3)
pesticides already on hand at the
time of the April 1, 1985 imple-
mentation date.
In-State Purchases. At the
time of sale or delivery from an
in-state dealer to an in-state
applicator, the dealer shall col-
lect the deposit in cash or
posted credits on each pesticide
container. For less than 30 gal-
lons capacity, the deposit is
$5.00 per container. For non-
refillable containers 30 gallons
capacity and over, the deposit is
$10.00 per container. On refill-
able containers, at their option,
dealers may collect greater than
those required for non-refillable
containers. The dealer, prior to
or at the time of delivery of the
pesticide to the purchaser or his
agent, must also affix a sticker
obtained from the Board of
Pesticides Control. This sticker
is an alphanumeric, designed to
identify both the purchaser and
the seller. Dealers are required
to affix the stickers prominently
and securely to containers in a
manner that will not obscure or
interfere with any trademark or
label instruction. Dealers are
allowed to place stickers on the
exterior of unopened cases prior
to delivery and in such event,
the purchaser or his agent shall
either affix the stickers to the
containers immediately upon open-
ing the case or the container
shall at all times be kept with
the case on which the stickers
remained affixed and shall be re-
turned to the dealer or his agent
as a unit for return of deposit
and disposal. Dealers also must
provide an affidavit form to the
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purchaser or their agents at the
time of delivery of the pesti-
cide. The affidavit must con-
tain the following provisions:
the name and address of the pur-
chaser, the registered name of
the pesticide and the number and
size of each container, the
serial number of each sticker
affixed to a container, the
amount of the deposit paid or
posted credit, the place where
containers may be returned for
refund and a certification,
signed by the purchaser stating
"this is to certify under oath
that the containers with the
sticker numbers listed herein
have been properly rinsed accord-
ing to the regulations adopted by
the Board of Pesticides Control",
and finally, the place and date
of return as confirmed by the
dealer or the operator of the
collection, recycling or disposal
facility. Once the applicator
uses the pesticide, he or she
must follow a triple rinse or
equivalent procedure that is
specified in the Board of Pesti-
cides' regulations. Key elements
of the triple rinse procedure in-
volve complete emptying and
draining for at least 30 seconds
after steady flow of pesticide
formulation has ceased and after
individual drops are evident. A
solvent usually specified by the
manufacturer and capable of re-
moving the pesticide residue
shall be added to the drained
container in an amount equal to
10% of its capacity. The con-
tainer then shall be shaken,
agitated or rolled vigorously in
such fashion as to dislodge resi-
dues from the top, bottom and
sides. The liquid residues or
rinsate shall be added as a make-
up to the spray tank and the con-
tainer shall be allowed to drain
for at least 30 seconds after a
steady flow has ceased and after
individual drops are evident.
This same procedure must be per-
formed two more times, each time
allowing the container to drain
for at least 30 seconds. In cases
where undiluted formulations are
used and rinsate cannot be added
to the spray tank, the residue
must be disposed of in accordance
with label instructions. Any
equivalent methods for removal of
pesticide residues must be autho-
rized by the Board. Once con-
tainers bearing the Board's
stickers have been properly
rinsed according to the Board's
regulations, they may be returned
to either: 1) an authorized col-
lection, disposal or recycling
facility specified by the dealer
on the affidavit form - provided
that the arrangements for the use
of such facility have been made
by the dealer; or 2) the place of
business of the dealer who sold
the pesticide. Upon the return
of the containers and receipt of
the affidavit, cash deposits will
be refunded by the dealer in cash
and deposits that were posted in
credit will be credited to reduce
such accounts.
Out-of-State Purchases. In
this situation, the Board has, of
course, no control over out-of-
state dealers unless those deal-
ers bring a person into the state
and essentially function as an
in-state dealer. In such case
they fall under the previously
mentioned regulations. Otherwise
an out-of-state dealer has no re-
quirements. However, an in-state
applicator who purchases from
out-of-state must purchase a
sticker from the Board of
Pesticides Control and pay a de-
posit on the container to the
Board of Pesticides Control at
the same rate as the in-state
dealer/purchaser arrangement. It
is the responsibility of the
applicator to affix the stickers
and the Board furnishes the affi-
davit to persons seeking stickers
for containers, but the Board is
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not responsible for designating
the final disposal site. Once a
pesticide is completely used and
the container is triple rinsed in
the fashion outlined previously,
the container bearing the Board's
sticker must be returned to a
Maine Department of Environmental
Protection approved solid waste
or recycling or disposal facility.
The applicator's affidavit is
then returned to the Board of
Pesticides Control for a refund
of the appropriate deposit.
A third and final situation
covers containers on hand as of
April 1, 1985. According to the
statute, it is unlawful for any
person to possess a restricted or
limited use pesticide container
without a sticker issued by the
Board and affixed to the contain-
er after that date. Persons
holding such containers must
apply for a sticker from the
Maine Board of Pesticides Control,
Stickers issued by the Board
under this subchapter will be
supplied without a fee.
Currently, the Board is in
the implementation phase of this
new and somewhat novel program.
Implementation covers education
and development of safety pro-
cedures for applicators, deal-
ers and solid waste and recycl-
ing facility operators. The
Board's own staff must also be
trained for compliance monitor-
ing, safety procedures and for
training other groups. In
addition to education materials,
the Board has developed, through
a contractor, instrumentation
and test kits for determining if
containers have been triple
rinsed or not. Such testing in-
volves the use of colorimetric
photometers that have previously
been used in drug detection
systems. Commercial marketing
of these systems appears to be
likely and may well represent
the most interesting off-shoot of
our regulatory activity.
A lot of thought, a lot of
effort and a lot of consideration
has gone into Maine's returnable
container program. Undoubtedly,
a lot of thinking, doing and
bending still remains to be done,
but we are becoming increasingly
convinced that we're on the right
track. We are already satisfied
that what we're doing is worth-
while, and we're also certain
that no matter what our final
program may look like, we can
never go back to the disposal
practices of even two years ago.
Pesticide container disposal is a
present day problem, and as such,
demands the best solutions that
we can create.
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SUMMARY PANEL
Roy Detweiler, Workshop Chairman
E.I. du Pont de Nemours & Co.
James N. Seiber, Panel Chairman
University of California, Davis
Jim Parochetti, USDA Extension Service
Ray Krueger, EPA Office of Pesticide Programs
Philip C. Kearney, Pesticide Degradation Laboratory
Orlo R. Ehart, State of Wisconsin
William Keane, Attorney
Roy Detweiler:
We've heard from applicators,
regulators, scientists, and consultants
about the needs of pesticide users. I'm
sure many of us are overwhelmed and
wonder where we're going to go from here.
How can we use the technology that
we've heard about? How can these ideas be
implemented? What actions can we take?
What are our future research needs? These
are some of the objectives that were
developed while planning this conference.
There are still a lot of questions to be
answered and we're really a long way from
giving you something that you could put
into effect and use tomorrow.
During this workshop, we've had a
number of experts listening to the
problems of the user community, as well as
some of the proposed solutions. We're
going to listen to how they would summar-
ize the meeting. I'd like to introduce to
you some of the panelists whom you have
not heard from.
Jim Parochetti represents USDA
Extension Service, he is Program Leader,
Pesticide Application and Weed Science.
We've got Ray Krueger from EPA Office of
Pesticide Programs, who spoke to us
earlier; Philip C. Kearney, Chief, Pesti-
cide Degradation Laboratory, who spoke to
us; Orlo R. Ehart, Chief of Pesticide
Control, State of Wisconsin, and William
Keane, attorney for aerial applicators in
Arizona who has also spoken to us. The
one man we haven't heard from yet is James
N. Seiber, Professor, Department of
Environmental Toxicology at the University
of California, Davis. Dr. Seiber was
educated as a chemist, has a Ph.D. from
Utah State, was formerly involved in
research at Dow Chemical, and also holds a
position as Vice Chairman of Pesticide
Chemistry for the American Chemical
Society. Let me introduce James Seiber.
James Seiber:
Thank you. I want to express my
congratulations and appreciation to
the organizing committee and sponsors for
undertaking a timely and useful workshop.
The brochure stated that the objective of
the workshop was to serve as a national
forum to assess the needs of users, the
available technology (and I assume tech-
nology gaps) , technology transfer, how to
get the technology to the users, regula-
tory issues at all levels, and recommenda-
tions and future actions. That's the part
we're down to now, the recommendations
and future actions.
We have six panelists, including
myself, each of whom is going to give
you their recommendations in their own
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areas of expertise. After that we
would like you to be thinking ahead. We'd
like to solicit your recommendations and
comments on this conference, and where we
go from here, as soon as the panelists
present their summaries. Before we hear
the individual panelists, I have a few
comments.
My first encounter with pesticide
waste disposal came five years ago
at a wastewater ditch in the Sacramento
Valley which had then been used for
several years for disposal of application
equipment rinsate. Poison signs had been
freshly erected around the site, while
representatives of at least four state and
local agencies along with a TV station
crew milled about. It occurred to me that
there must be better ways (a) for the
commercial applicator to handle wastewater
disposal and (b) for public agencies to
provide needed inputs to facilitate
clean-up of sub-optimum or dangerous
sites. I learned subsequently, during a
1981 summer Fellowship program at EPA's
Office of Research and Development,
that indeed much attention had been given
to these problems by researchers around
the U.S. and solutions had been proposed
to alleviate the wastewater disposal
problem. However, this rather large
research effort was generally not known to
pesticide users, partly because much of
the prior work was in reports or report
drafts not generally available to the
agricultural community. I concluded that
many of the elements for solving this
problem existed, and that substantial
progress could be expected in a relatively
short time frame with a fairly modest
effort.
My feelings have been reinforced
during this conference, but I must
admit to some disappointment that more
progress has not taken place during
the last 3-1/2 years. Among the things
which I perceive have not changed since
1981:
1. We are still confusing issues.
We need to separate the problem
of cleanup of old, sub-optimum
sites from the problem of imple-
menting new disposal systems to
handle future needs. We must
also clearly differentiate
container disposal from waste-
water disposal. And we must
distinguish between containment,
detoxification, and destruc-
tion of wastes as strategies for
disposal.
2. We are still hoping for that one
magic answer that will handle
everyone's problem. This is
clearly unrealistic because the
nature of application practices,
pesticide use, climate, and
transportation distances vary so
much from location to location.
3. We are still waiting for a stamp
of approval before we start
recommending/installing disposal
facilities. It isn't going
to happen that way; some of us
will need to take risks, initiate
treatments or install facilities,
and log some time with them to
prove to the regulators and
public that they will work, and
do so with safety to the environ-
ment.
4. We are still looking for techno-
logical breakthroughs -- totally
new concepts, which can allow us
to look beyond the old, less
glamorous processes (evaporation
beds and ponds, carbon sorption,
etc.) which are working now in
several locations. While we
cannot rule out breakthrough
solutions, we also cannot afford
to wait for them.
5. We want "fast" solutions, perhaps
because we perceive that people
looking over our shoulders expect
the problems to be solved over-
night. Perhaps we can generate
"breathing room" by showing an
honest effort even if it requires
months or even years to complete.
6. We still want cheap solutions,
even though the experience to
date tells us that installation
of double-lined, leak-free, fail-
safe facilities with monitoring
wells, etc. will cost more --
probably much more -- than we
thought just a few years ago.
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My recommendations to improve on the
rather slow pace of progress in waste
disposal in its broadest context fall into
three categories. First, we need to put
ourselves on a timetable, such that one
year from now we can reconvene having
logged experience at the demonstration-
scale with several of the leading technol-
ogies for safe cleanup and waste disposal.
Second, we need to call for realism on the
part of regulators in implementing exist-
ing regulations and in putting new regula-
tions on the books. Regulation is clearly
ahead of development in this field,
although the gap can be closed with a
well-directed effort. Third, we need
capitalI, to fund research, the installa-
tion of demonstration-scale facilities,
and the development of affordable equip-
ment by entrepreneurs. Federal, state,
and private funding will all have a role
to play in this endeavor, but the agricul-
tural chemical industry could justifiably
shoulder a larger share than has been
evidenced in the past. At a future
conference we may be able to pat ourselves
on the back and say: "That problem has
been solved; let's move on to something
else." Unfortunately we can't say that
now.
William T. Keane:
From the applicators' standpoint, I
feel that this was a very productive
workshop. On behalf of all applicators, I
would like to thank all attendees for
taking time away from their daily duties
to assist us in solving our pesticide
problems. This workshop was productive
because it provided a good survey of
pesticide hazardous waste issues confront-
ing the applicator. On the other hand,
the workshop had one major shortcoming
because nothing presented is commercially
available today to enable applicators to
come into compliance and to stay in
compliance.
I would like to remind you of the
problems confronted by applicators
which were outlined on the first morning
of the workshop. In discussing these
problems, you should recall that applicat-
ors are being told by regulators that
immediate answers must be forthcoming.
1. Dripping nozzles — There were no
speakers on the topic of new
nozzle research. We are still
utilizing the same nozzles and
nozzle technology that have been
in existence for decades.
Research is required to develop
nozzles which do not leak.
2. Container problems — There were
no presentations outlining
new, innovative container designs
directed at solving the container
hazardous waste problem. Indeed,
Mr. Trask identified many of the
areas which require research.
3. Rinsate problems — The applicat-
ors in attendance were impressed
with the activated charcoal
methods of treating hazardous
wastes. We feel that these
methods hold future promise.
However, none of these methods is
available for purchase. There
were no exhibitors with activated
charcoal systems that could be
purchased today and immediately
pressed into service.
4. Collection of rinsate — We have
learned that no federally-approved
blueprints exist for the construc-
tion of rinsate collection systems,
On the other hand, applicators
are being informed by regulators
that these chemicals can no
longer be introduced into
the soil. Small businessmen,
such as applicators, cannot
afford to independently pay for
the engineering research and
design of workable collection
systems.
5. Soil contamination — This is the
most significant, most complex,
and most expensive problem facing
applicators today. We have
learned as a result of this
workshop that no commercially
available, economically feasible
methods exist for removing
pesticides from the soil of
applicators' homes and remote
work sites. If applicators were
able to clean up the soil today,
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they would contaminate the soil
again tomorrow due to leaking
nozzles and inadequate rinsate
collection equipment. Soil
contamination will continue
to occur in the future even
though applicators utilize
state-of-the-art equipment,
employ good application tech-
niques, and perform proper
maintenance on their equipment.
One of the soil treatment
techniques presented by Dr.
Arthur Craigmill may hold great
potential for soil cleanup, but
more research is required under a
wide variety of meteorological
and soil conditions.
I have substantial concern that EPA
regional enforcement personnel are not in
attendance in greater numbers. Also, the
state regulators who are responsible for
enforcing RCRA (Resource Conservation and
Recovery Act) are absent from this workshop.
On the first morning of this workshop, I
informed you of the inconsistency of
enforcement of RCRA throughout the United
States. Attendance at this workshop by
enforcement personnel could have been the
first step toward uniformity of enforcement.
In conclusion, the mood of the
applicators in attendance at this workshop
is one of frustration. They are faced
with immediate problems, but there are no
immediately available solutions. They are
compelled to come into compliance, yet the
scientific tools which would make compli-
ance feasible do not exist. The appli-
cators in attendance had high expectations
for this workshop to provide immediate
solutions, and those expectations have not
been met. We would like to encourage the
researchers to keep in mind that their
target consumer is an applicator with no
formal scientific training, who many
times employs workers who do not speak the
English language and who cannot read and
write, and who works under extremely
adverse environmental conditions. In
short, applicators require scientific
advancements which are user friendly.
Dr. Seiber:
Thank you very much Bill. The
viewpoint of the applicators is extreme-
ly important. I think those comments
needed to be heard. Now I'd like to
call on Bob Ehart for his summary remarks.
I'd like to remind you that we'd like your
recommendations too, so please jot them
down, and we'll read them after the
panelists make their recommendations.
Bob.
Orlo R. Ehart:
A significant amount of time has been
devoted at this conference to what state
and federal agencies have done to regulate
disposal of pesticide related wastes. One
aspect, however, may not have been made
perfectly clear. Regulators, in general,
carry out functions required of them by
legislation. Although it is true that the
creative genius of regulators sometimes
far exceeds the intended authority provided
them, it is most often the case that
policies are mandated, implemented and
carried out consistently with the will of
the people, with adequate checks and
balances on the system. Therefore, in
reviewing actions which state regulatory
personnel can involve themselves, it must
be understood that actions will be elevated
or tempered according to the state or
federal authority bestowed upon the
agencies and the amount of funding provided
to actually carry out activities.
Although this conference has dwelt
upon the regulation of pesticide waste
disposal, it is short sighted not to
recognize that the purpose of these
regulations is not, or at least should not
be, to regulate pesticide waste per se but
to protect the environment. Unfortunately
some of the regulations discussed appear
to regulate pesticide waste but do not
necessarily protect the environment.
The FIFRA (Federal Insecticides,
Fungicide and Rodenticide Act) policies
authorize the introduction of pesticides
into the environment. The SWDA (Solid
Waste Disposal Act) policies mandate a
"clean" environment free from hazardous
chemicals introduced by humans. Therefore,
if applicators use a pesticide, they are
"blessed" with the right, and responsi-
bility, to assure the pesticide is placed
where they intended to put it. Meanwhile,
in cleaning up after the "blessed uses",
if they leave behind any of a "dreaded"
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product persons may be placed in the
public square and held for public flogging.
This is difficult for users to understand;
their actions are condoned, although
usually tacitly, when they use a pesticide
and condemned when they dispose of a
pesticide, even though the rate of effect
on the environment may be the same under
both instances. This inconsistent policy,
along with the fact that, the "listing" of
wastes is a dynamic process, where what is
legal today may be illegal tomorrow, has
created a difficult situation, at best,
for even the most compliant pesticide
user.
The problems for a pesticide user
have not been solved as a result of
this conference. The lines have just been
better defined. In 1974, after passage of
FIFRA, and before passage of RCRA (Resource
Conservation and Recovery Act), technology
had reached the point where protection of
the environment was at hand; best avail-
able technology was nearly economically
feasible to be used to protect the environ-
ment. In 1976, with the passage of RCRA,
many experts, users and others, as so
frequently is the case, took sabbaticals
from developing practices to protect the
environment while the rules to the new
SWDA were developed. Then adances in
technology to adhere to the new rule began
to be developed. Now, however new SWDA
amendments have been passed long before
even the experts have mastered the 1976
version of the SWDA changes. Compromise
rules may need to be published if the goal
is to return to proper protection of the
environment. Activities must be better
managed rather than merely regulated out
of existence. Each and every user has
responsibilities that must not be taken
lightly if the onslaught of over regula-
tion is to be corrected.
A minor, but important, step in
addressing pesticide users' concerns is
to assure that every EPA FIFRA, SWDA, and
water program office -- headquarters
and regional -- does receive a copy of the
proceedings of this conference. In
addition every SLA (State Lead Agency) for
FIFRA, SWDA, and water programs must
receive a copy of the proceedings. This
will aid in the identification and recog-
nition of problems and the realization of
the state-of-the-art of technology to deal
with the problems.
Contacts must be established between
all levels of personnel responsible for
the administration of SWDA and FIFRA
within EPA and at the states' level.
Communication on problem recognition,
assessment and management must begin in
earnest. Responsible parties can ill
afford to continue to point the finger at
another person and suggest that the
problem is really the other person's
concern.
Joint agency programs such as those
developed between the agencies in Louisiana
and Vermont are indications of the useful-
ness of establishing these ties. With
these joint efforts a "filter point" for
referrals on disposal concerns can be
established in each state. Perhaps even
"1 stop shopping" systems can be estab-
lished where persons, wishing to comply
with all related laws and rules, can have
some assurance that they have been informed
of all of the interregulated governmental
programs which regulate their operations.
Innovations which protect the environ-
ment must be condoned even though the
innovation may be only the first step in
solving a larger problem. Perhaps the
experimental permits recently authorized
under SWDA can start that process. Regula-
tions must become a basis for solving
problems rather than merely developing
mazes in the quagmire of bureaucratic red
tape. Perhaps amnesty for some of the
past problems rather than strict liability
will provide better protection of the
environment for the future. Standards
for mixing, loading, and handling sites
might provide protection of the environ-
ment, at least more protection than is
provided by the currently unenforceable
prohibition against even so much as a drop
of a regulated hazardous waste reaching
the ground. Container and unwanted
pesticide product collection programs,
aided by the government, may eliminate
some problems. If incineration is to be a
major answer in the future, the NIMBY
(Not in My Back Yard) and LULU (Locally
Unacceptable Land Use) philosophy which
pervades our society simply must be dealt
with; the sites and/or transfer points
must be located somewhere.
To state that whoever currently owns
a site is strictly liable for all past
actions, regardless of how legal the
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actions were when performed, is simply bad
public policy. To state that someone is
liable for actions which were illegal or
negligent in the past, currently, or in
the future is another matter. Therefore,
the lines which rightfully separate
societal responsibility and cost from
individual responsibility, cost, and
penalty must be determined. If the
environment is to be truly cleaned up and
protected, society is going to have to
accept some of the ills which have existed
in the past, especially those which were
done according to the existing best
available technology at the time of the
activity. By accepting it, however, it
does not mean that clean up may not be
necessary, only that a shared recognition
of the problem exists and mutual responsi-
bility for reaction to the problem is a
prudent policy.
This conference has established a
network of individuals interested in
the solution to pesticide waste disposal
problems. For that reason the ability to
communicate has been aided. This confer-
ence has increased all participants'
knowledge of the problem and potential
solutions. It has elevated our ability to
communicate to a higher level. With that
in mind there are a number of items which
SLA (State Lead Agency) personnel can do
in the coming months.
They should act as the "filter point"
for the identification of the most typical
disposal and waste management questions,
concerns and issues facing the pesticide
users. It must be recognized, however,
that some questions will not have answers;
that must be clearly identified.
Uniform standards for pesticide waste
treatment or disposal for all pesticide
products should be developed. Separate
standards for disposal of pesticide wastes
of low concentration, similar to the
concentration of labeled use rates, should
be developed.
The location of all operating and
pending hazardous waste sites should
be identified so that persons wishing to
comply know where they must go for
disposal. If hazardous waste sites do not
exist, they should be developed in
each state so that problems can be dealt
with on a localized societal basis.
Col lection of wastes before they become
problems should become a societal desire.
Materials should be developed which
identify which pesticides are definitely
hazardous waste and under which conditions.
Specifically, it should clearly state on
the label of every pesticide container
whether the product is, for disposal
purposes, an "acute hazardous", toxic, or
some other type of waste.
Protocols should be developed for
clean up of spills, fires, and abandoned
sites.
Treatment systems should be categor-
ized which differentiate between major
facilities, regional facilities and
on-site treatment.
The development of acceptable solu-
tions to the problems and funding of
practical disposal research should be
reprioritized to be consistent with the
priority of enforcing the prohibitions
against any disposal practice affecting
the environment.
The adequacy and availability of high
quality education should be increased.
SLA personnel can do or be involved
in many of these suggestions. It is
obvious, that the same is true for many
other persons as well. Two elements,
however, must be recognized.
1) If the affected industries do not
take their destiny into their
own hands and work outwardly,
openly and diligently toward
finding solutions to the problems,
SLAs will not prioritize these
issues.
2) This is clearly a vote in favor
of regulation. And regulations
do not come without cost —
sometimes high cost. In those
instances where compliance is
needed, it is imperative that
strict enforcement occur. If a
balance between societal and
individual desires, needs, and
responsibilities is to be achieved
it is going to cost everyone.
Support, encouragement, direction,
tenacity, and perhaps just a
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measure of patience, both indi-
vidually and societally, is
needed in order to succeed in
protecting the environment.
Dr. Seiber:
Thank you very much Bob. Our next
panelist is Ray Krueger from the Environ-
mental Protection Agency.
Ray Krueger:
One of the biggest problems we have
in the pesticide area is the fact that
these RCRA regulations and laws are here
to stay. Congress put those things on the
books for specific reasons, and they're
there. Learn what they are, learn what
they mean. Otherwise, you can't comply
with them. A lot of the pesticides are
not regulated. It's incumbent upon EPA to
supply that information.
We'd like to mention the mixture
rule. There are changes being made
to it that will offer some opportunity for
de-listing some of the rinses, and
wastes; some of the low level stuff.
Clearly, one of the methods of choice
for disposal is on-site treatment. In
general, that's true of the hazardous
waste business across the board. No one
thinks it's a good idea to transport
this stuff.
On-site facilities are up for encour-
agement; carbon units, soil mounds,
evaporation ponds, have all been proven
useful. My feeling is that they need to
be engineered to meet the RCRA standards.
They've got to be permitted to be used.
One of the things we'd like to work toward
is to develop engineering specs for these
kinds of units, to enable class permitting
to be done. If you can build a system
that meets the specific recommendations,
the permit would be a rubber stamp operation.
The RCRA people have an initiative
going for storage facilities. It lessens
the work load of EPA and state regulators,
releasing them to do other things.
Experimental units: there is going
to be relief in this area. From the new
amendments, there are provisions in there
for permitting experimental facilities.
We need to coordinate very closely with
the small quantity generator information
programs to be put into effect later this
year.
There is a need for better disposal
statements on labels. To do this we've
got to publish guidelines for the manufac-
turers to be able to submit necessary data
to support the disposal system of their
choice. Such things as instructions on
how to hydrolize any residual material, or
possibly a small bag of enzymes taped to
the outside of the container with instruc-
tions to empty this bag into the container
when you're through, add a little water,
let it sit for an hour, and you have a
non-hazardous waste. These would be
exempt wastes, not regulated by RCRA, and
you wouldn't have that problem.
This workshop has been a learning
experience for me. I've learned that
there are more problems than solutions. I
feel it has been profitable. I regret
that we have been unable to give the magic
overall solution to your problems in one
motion. But as Jim pointed out, that does
not exist. Thank you.
[Applause]
Dr. Seiber:
Thank you Ray. There has been a lot
of discussion and recommendations about
disseminating information to get informa-
tion in the hands of those who need it.
We're putting Jim Parochetti from USDA on
for his comments and recommendations.
Jim.
James V. Parochetti:
Extension Service is proud to have
been a sponsor of this workshop. The
Extension Service and its affiliated State
Cooperative Extension Service have, since
the mid 1960's, been actively involved in
pesticide education for the pesticide
user, both farmer and commercial applicator.
A majority of the land-grant universities
were represented at the conference which
is indicative of our commitment to research
and extension in matters relating to
pesticides and, in particular, pesticide
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wastes disposal. We, from the land-grant
universities, at this meeting have learned
a great deal. One of which is there is a
considerable amount yet to be implemented
at the user level with regard to the
proper disposal of pesticide wastes. The
rules in technology are continually
changing which makes a task of Extension
education difficult at best.
The teachable moment, however, is at
hand evidenced by the several hundred
"people in attendance.
Recommendations
1. A recommendation which is made by
the Extension Service for the
Extension Services is that we
will continue our commitment to
provide the best educational
programs tailored by each State
Extension Service on pesticide
waste disposal. Our focus is
education which is an important
component of the solution to the
problem.
I would like to stress that
this is a continued commitment
of education. All states have a
pesticide education program
(general) and a more specific
educational program with regard
to the training to enable pesti-
cide applicators to become
certified, i.e., the pesticide
applicator training program.
This program has provided informa-
tion in the past on pesticide
waste disposal but a greater
emphasis will and must be made in
response to the users' needs and
demands at the state level.
2. The Extension Service recommends
that those at the Federal level
specifically, and in each state
where the Extension Service is
conducting educational programs
that have a responsiblity for
RCRA and FIFRA, provide the
technical interpretation for all
of us. The Extension Service and
the State Cooperative Extension
Services then, in turn, can and
shall distribute these interpreta-
tions to the States. A recommen-
dation was made in the first
day's sessions of this workshop
that Extension Service be the
interpreter of the regulations.
This is not acceptable to the
Extension Service. The Extension
Service walks a tight rope
between regulations and education.
Our function is education. When
one walks a tight rope one runs
the risk of falling off that
rope. Therefore, we leave the
interpretation and the development
of fact sheets to those that are
responsible for enforcemnet and
interpretation of RCRA and FIFRA.
The Extension Service will not
jeopardize its role as an educator
by interpreting rule making.
In summary, I would like to make the
analogy that this conference is very much
like a child's puzzle. There are large
pieces that have been put together. We
see the general outline of the picture but
there are one or two pieces missing. We
are going to find those pieces and put
them together. We must because the
pressures of enforcement are upon many
users.
Dr. Seiber:
Thanks Jim. Now I'd like to turn to
Dr. Phil Kearney, USDA/ARS for a summary
of research needs and research recommenda-
tions in this area. Phil.
Dr. Phil Kearney:
Thank you Jim. This is a shared
effort. I'll give you some of my impres-
sions, and I'd like Jim to follow up. We
were given a format in this discussion
panel, to talk about problems, solutions,
needs, and workshop accomplishments. Some
of the problems here are like the joke
about the real estate salesman. A fellow
said to him: "What's the most important
thing when selling a piece of property?"
The real estate salesman said: "There are
three things: location, location, loca-
tion." The problem with waste disposal is
cost, cost, cost. Just that.
We have looked at a lot of processes
over the last few days. I hope you looked
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at some of the cost figures involved.
Some of them are mind boggling. We have
to resolve this cost issue. I have some
ideas.
Another problem we have is regulatory
constraints that limit our flexibility. It
could stifle innovation. Before I came
here I was willing to take a number of
chances looking at new processes. I
wonder whether we, as a research organiza-
tion might have to come under these same
regulations.
Another problem we have is unique to
the pesticide applicator field. We're not
really dealing with concentrated solutions.
It's been a hard message to get across.
Our problem is the rinsing from the can,
the tractor, spray tank, and the airplane.
At the current costs of pesticides, we
better not dispose of large amounts of
concentrated materials; it's too expensive.
The problem has been high volume, low
concentration, low value wastes. We have
some ideas, but we don't have a process
that we could give you a solution which
will satisfy all of our needs.
A final problem that this meeting may
have generated is a level of expectation.
I sensed that. Someone said to me today,
to understand our problem I've been to a
number of these conferences over the
years. We've solved the problem many
times. We haven't listened to what these
people can afford, what their problems
are, or the magnitude of the problem. I
thought the ground and aerial applicators
shared some useful information with
us. Not all of their information, for
obvious reasons has been shared. [Laughter].
I'm like the Catholic priest, I won't tell
you their confessions. They have problems.
Some of my impressions are that land
disposal may be regulated out as an
option. That's disappointing. It's a
widely used, economically used method
of waste disposal. I am so confused about
the regulations that I'm concerned
about using it as a method. Some of the
chemical options are good, but very
expensive. If they are to be successful,
we've got to think about bringing the cost
down. Absorption looks good. But I am
concerned about running into a problem of
a secondary residue. I worked for 10
years trying to dispose of Agent Orange.
We looked at literally hundreds of propos-
als for destroying it. One of the most
innovative was to package these materials
in a box with a Woodies label on it, park
it in your car, park the car on 9th St.,
and leave the doors unlocked. [Laughter].
Some of the biological processes hold
promise. The high-tech, genetic engineer-
ing will play a role. We have a small
unit in genetic engineering which is
growing, which is going to be very expen-
sive, but which is very specific. Some
have a broad specificity, and some are
narrow.
Let's talk about needs. One of them
is a time of development. We need a
period of grace to develop the technology
and to come into compliance. We in
technology can't meet the regulations, but
I think the agency has time to enforce
them. Whatever the process is, it should
be shared with many users. We have to
share the cost over a large population.
It has to be durable, and last for a
number of years, have a low maintenance
cost, and be mobile. If its mobile, it'll
take it out of the hands of the user. I
am concerned that the user will need to
become a chemist. I also don't want to
build a lot of monuments. We need the
ability to replace and update materials
and processes as innovations become
available. That's why I like mobility.
The rate of flow must be good, we
must be able to accomodate large volumes.
The purchaser may not make a profit, the
producer might, but the person that
provides the service may not. It may have
to be a formulator, or a co-op, which is a
possibility. We're reluctant to gamble
here, until we know what the ground rules
are. We can't take a big plunge with big
dollars in programs, or someone's money.
A fourth need is that field trials
should begin this summer, to be reported
back next year. The workshop accomplish-
ments were an excellent review of current
knowledge; state-of-the art. The speakers
were good, but I also leave here with a
sense of urgency that we do something.
Thank you.
[Applause]
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Dr. Seiber:
Thank you Phil and thanks to all of
our panelists. We'll turn over the floor
to Roy Detweiler again for a reading of
the questions that I hope you'll come up
with and recommendations from your perspec-
tive. We all pretty much agree on a
timetable. Phil suggested that we get
together in a year from now and compare
notes. I think that's a good idea, and
we'd like to hear your remarks. Second
thing that was said was regulations are
ahead of development. I think we need to
take that to heart. We need to make sure
that the message gets in place at the
local, state, and federal levels.
Finally, Jim said that we've not
given everyone everything at this confer-
ence. We know the problem a lot better.
We have a better sense of urgency.
Someday at a future conference, we can pat
ourselves on the back and say yes, we
solved the problem. We can move on but
we're not there yet with pesticide disposal.
We still have a long way to go. Roy,
we're ready for the questions.
First, let's have a hand for the
panelists.
[Appl ause]
We've had a couple of cards about a
follow-up conference. And a very good
suggestion from Francis Mayo, EPA Research
Director, who suggested that I ask for a
show of hands to see whether the interest
is there for a future workshop. Please
snow your hands. Just about unanimous.
Also EPA would be willing to co-sponsor
such an activity. We will certainly put
that into our committee. Our committee
will be meeting at 2:00 PM today to decide
where to go from here.
I've got a number of questions here,
and I'll divide them up so everybody can
participate. Phil Kearney, can anyone
name sources that are available for
research?
Phil Kearney:
I don't know, there is the NAPIAP
funds, and some of the state people
know what I'm talking about. This is the
National Agricultural Pesticide Impact
Assessment Group. They have funds desig-
nated thru ARS and CRS. I don't know
how many dollars are left. Those funds
may be available. That money may be
narrowly aimed at other problems. I'm not
optimistic. I'd like to see some funds
made available by the agencies. Industry
has to really look hard at this thing
because we're all going to suffer if we
don't solve it. It is going to put
burdens on the users, sales people, all
levels. I'd like a special fund set up to
do this and see what we can identify as a
source of funds. People may have to
compete for these funds. We have to do it
soon.
Roy Detweiler:
This next one could be answered by
any of the state or federal people.
Which agency or organization will develop
a central clearing house for information
on pesticide waste disposal research?
Jim Seiber:
I can say who I would like it to be.
At the federal level, I hope the EPA and
the Office of Pesticide Programs could
make that information available. At the
state level, I'd like to see it be the
state lead agency in each state. In
California it would be the Department of
Food and Agriculture.
Another element is that EPA is
talking about monitoring an environ-
mental area, establishing an electronic
bulletin board that would give not a
lot of information other than just the
essentials -- who's doing it, and what
the concept is. It would be available to
anyone, electronically.
Roy Detweiler:
This is for Bob Ehart. This confer-
ence has identified the problem with
regulatory pesticide waste disposal by the
RCRA people. Would the state pesticide
programs and EPA's OPP be willing and able
to address the problem except for the
obvious unused, banned, and overage
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products identified repeatedly as hazard-
ous? Can this group push to get a major
change out of EPA?
Last part answered first. Yes. This
group can push to get changes. I think
there are a number of things that can be
done as to who is going to be the respons-
ible agency. What it comes down to is the
first part can be answered like the last.
That movement is going to have to come
from you, not from us. If I mentioned
that I want to take on pesticide disposal
in the state of Wisconsin, it becomes a
turf battle between the Dept. of Natural
Resources and the Dept. of Agriculture.
The legislature doesn't look kindly
whan I state things such as that. They
think I'm a dynasty builder. I think
it has to come from a grass roots movement.
There can be changes in it. Vermont and
Louisiana have joint programs, where most
of the responsibility is under the state
agency for pesticide.
Roy Detweiler:
Jim Parochetti, this is addressed to
you. You stress the importance of educa-
tion, but states don't have the funds.
How can we move into education with such a
1ack of funding?
Jim Parochetti:
We have a responsibility to dissem-
inate information and I'm aware that
funding is available. There is no ques-
tion that funding is going to be limited
now, and in the future. I don't have a
good answer to that. My response is that
we have an obligation and to the limit
that the states have resources and the
federal government provides funds in
support of the state program, that's the
extent that each state is going to have to
evaluate their educational program.
Roy Detweiler:
Does anyone else wish to add to
that?
Ray Krueger:
I'd like to make a comment. I've
been listening to some of the questions
and answers, and it seems to me that we're
letting industry off a little easy. I
think industry bears a little responsi-
bility to fund some of these things where
we don't have funding. This is true in
research and information dissemination
areas, and as far as coming up with
concrete suggestions, like what tempera-
ture it takes to break down one of
their products in an incinerator. I'm not
sure the EPA should be looked at to supply
that information. I don't think the state
universities and extension service should
supply that information.
Roy Detweiler:
I agree. We have that information on
our products, and we should make it
available. Anybody else? OK, we have one
here that Bill Keane, could probably
address. This is a statement that says:
"Loading sites should be ruled on an equal
basis so that no one type of applicator is
at an advantage or disadvantage in the
market place, referring to ground, and
other types. No one size operation should
have an advantage." Just make a comment,
pi ease Bi 11.
Bill Keane:
I think the whole soil contamination
issue is an extremely important issue. If
we were to dig up and transport to our
closest hazardous waste site all the
pesticide contaminated waste sites in
Arizona, we would be shipping it to
West Covina, California. If we were to do
that, I think our Chamber of Commerce
could advertise, if you want to visit
Arizona go to West Covina, California.
Incidentally, now I know what to do with
our containers, we could ship them to
Canada. [Laughter].
In all sincerity, I have difficulty
understanding when pesticides which are
designed and intended and approved/regis-
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tered for use on agricultural fields when
everyone in the room knows that a given
fixed percentage of those pesticides will
find their way through the plant canopy
and down into the soil. Somehow, we're
saying that the pesticides that are
getting onto the soil from the approved
labeled use and application is acceptable,
though they aren't regulated under RCRA.
On the other hand, the identical pesticide
in a non-target area is illegal and
subject to disposal.
It's going to be a tough issue for
the EPA to legally uphold and defend in
court. I hope it doesn't come to that.
In fact, one of the easiest solutions to
this problem appears to be, why can't we
dig up that soil and spread it out over
the agricultural fields. An extremely
thin layer or concentration rate. Sample
the agricultural field before we put it on
so we know what the residue levels are
pre-existing and after we spread out this
soil. We can analyze again with time to
prove it's broken down over time.
All the registrants have been telling
us for years that one of the quickest ways
to break down pesticides is by ultra-violet
rays from the sun. We get it for free if
we spread the pesticides out on the soil
over big surface areas. Its all handled
for us by Mother Nature. My applicators
don't understand why that isn't the proper
solution.
Roy Detweiler:
Thank you Bill. I think we have the
world's best expert, Phil Kearney.
Maybe you could add to that.
Phil Kearney:
Well, you know I'm a high-tech guy,
and I like all these enzymes and things,
but you know there is much common sense in
that kind of solution. One of the problems
with common sense, is that it's not very
common. That idea seems to have a lot of
merit to me.
Roy Detweiler:
How about Ray. Can you pick that up
and put it into your pesticide program?
Ray Krueger:
Well, it would be a nice idea, but
unfortunately it's a disposal technique
called "land spreading, or land farming,"
which is regulated by the RCRA rules, and
any operation of that kind would have to
be permitted and meet the requirements to
obtain to that permit.
Roy Detweiler:
Here's another subject, it's directed
to Dr. Seiber. To determine if effluents
from treatment and disposal facilities are
acceptable, government needs to establish
concentrations of mixtures which will be
considered "non-hazardous" and also
facilities operated will need effective
and acceptable analytical procedures to
characterize their waste streams at lower
cost than currently available.
Dr. Seiber:
Well, that's true and that's a
research need that's worth repeating.
The need for simple on-site monitoring
techniques to check whether a treatment
system is working. We've heard about
double liners, and the need for monitor-
ing wells, and impoundment systems. I
think a lot of people would be willing
to go along if they could take a sample
and get an answer the same day. When
they send it to a lab, spend $200.00 and
wait 3 months, its just not accept-
able. We need on-site, cheap monitoring
techniques. I feel this is an area
for research.
As far as setting the standards,
that's a whole different subject. In
the State of California, the Dept. of
Health Services is setting levels of how
clean is clean for various situations.
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I'm not part of that decision making.
They take toxicity and other things into
consideration and are coming up with
standards. We're going to have to live
with the standards they come up with.
Roy Detweiler:
Anybody want to add to that answer?
I have one that's directed to Ray Krueger.
I know you can't answer it directly, but
they wanted to ask where are the hazardous
waste sites. Is there such a list? Is it
available to people that want to use them?
Ray Krueger:
I don't believe there is a published
list. The agency has a listing of all the
facilities that are permitted to treat
specific waste. If you went to the
regional office, and asked where can I go
with it, they could probably give you a
list of facilities that could handle it.
There area growing number of waste brokers,
people who have no waste facility of their
own but do have connections with permitted
facilities that are listed in the yellow
pages. They will contract with you to
dispose of your wastes and work a deal
with the waste disposal people. The
problem is that they're all expensive.
We're trying to avoid that burdensome cost
on the applicator.
Roy Detweiler:
I've got a question/comment here. Of
the 400-plus attendees, this meeting
represents a very small percentage of
those involved in pesticides use and
disposal. Why wasn't this conference
given wider publicity?
I guess I can say that we felt the
400 was a good response. We used all the
methods that we had available at the time
to publicize it. We were expecting
between 100-300 people and we have 400, so
we think we did pretty well. Back to the
panel.
This is to Bob Ehart. You've made
several points about what should be
done to improve the system, to educate the
users and the public, and to update
the enforcement activities of the agencies.
Someone needs to push this. Maybe we
could help promote them to the respective
state personnel.
Bob Ehart:
I was wondering how to weave in
something that I wanted to leave as a
message. There has recently been formed a
committee of state, RCRA, FIFRA, and Water
people, along with the EPA, to continue
discussions on solutions, directions,
where we want to go, and answers to the
most typically asked questions. The full
intent of that group is to focus on those
issues. There are also people from the
extension service, who are looking at it
from the educational perspective. So
there's a committee function that is
purposely established to address the
ground water protection and disposal
elements. It's something we feel strongly
about for looking at resolutions and
directions. I encourage you to make your
comments known directly to me or your
state lead agencies. A lot of those things
will begin to surface and directions will
be given in that forum.
Roy Detweiler:
This is directed to Kruger/Ehart.
There will need to be a change in permit
requirements under RCRA for the average
agricultural retail facility and aerial
applicators to be willing to use treatment
for disposal technology. The present TSD
requirements are too tight for the average
businessman. What areas are government
agencies willing to review under existing
regulations to allow our industry to use
new practices? Ray?
Ray Krueger:
I can answer it in one word. None.
The reason being that the RCRA regulators
regulate hazardous waste. Pesticides are
a sub-set of that unit. They are not
about to make special provisions for
special parts of it. Class permitting
might be possible, but as I indicated
before, there are engineering requirements
to be met there to be able to meet the
permitting standards.
-129-
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Roy Detweiler:
Please outline who is or will be
considered a hazardous waste genera-
tor under the various laws. This isn't
clear and they are referring to the
small generator exemption. Could you
verify? They are referring to the 100
kilogram per month requirement.
Ray Krueger:
What that means is, if you produce
and dispose of more than 100 kilograms in
a month period, you are a regulated
generator. That means 100 kilos of
hazardous waste. Non-hazardous materials
won't put you into that category.
Roy Detweiler:
Somebody here will have to deal
with collecting, shredding, and burning
polyethylene pesticide containers with
adequate air. Why doesn't EPA design and
operate such a facility? Re: incinera-
tion facility.
Ray Krueger:
EPA is not a service organization.
Congress appropriates money for specific
operations. They wouldn't let us do
anything like that.
Roy Detweiler:
Is there an import quota on Canadian
logic.
[Applause]
Speaker(?):
As an uncommon man, I'll try to use
some logic on that. It seems to me that
the Canadian government has decided they
have some responsibility to solve the
problem. I've indicated that our federal
government helped cause this problem, and
I think they should help solve it. With
respect to the land farming issue, why
can't we go to our USDA research farms,
our farms with land grant colleges, have
them permitted as hazardous waste sites,
and let us spread our soil over those
permitted waste sites, and have ultra-
violet light take care of it.
One way to help solve the rinsing
problems of containers, when an applicator
is away from his home location, is to
carry a drum of clean water on the unit.
It will help with containers, and solve
the exterior wash down problem, also
provide a solution to rinsing before the
container dries out.
Bill Keane:
Our ground rig applicator said that
many times he goes as far away as 70 miles
from home, for at least a week. Many
times they work in areas where there
aren't additional volumes of water that
they have access to. So it isn't that
easy a problem.
Roy Detweiler:
Some suggestions for industry. We
have a sub-committee container meeting at
2:00 PM that has to do with standardizing
containers, simplifying container disposal,
addressing the ultimate way to dispose of
containers, etc. Several people have
suggested that the list of attendees be
expanded to include addresses. We'll
consider that. You may know that the
proceedings will be published by EPA.
They're paying for it. There is a
suggestion here that the proceedings could
be made available to others that are not
attending this conference through the
NTIS, which is the national technical
information center. So with that I want
to thank the panel, thank all of you
who have come here to our first workshop.
We also want to extend thanks to the
Clarion Hotel, JACA, and NACA staff, the
National Agricultural Aviation Association
staff, our committee and our sponsors.
[Applause].
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LIST OF SPEAKERS AND ATTENDEES
Larry Adams
Executive Asst. Int. & Agriculture
Ofc. of Congressman Charles Pashayan
129 Cannon House Office Building
Washington, D.C. 20515
Scott Ashcom
Mgr. National & Env.
Oregon Farm Bureau
P. 0. Box 2209
Salem, OR 97301
Research Div.
Joseph Allen
Project Coordinator
Union Carbide Ag Products Co.
P. 0. Box 12014
Research Triangle Park, NC 27709
Rodney A. Awe
Chief, Bureau of Pesticides
Idaho Department of Agriculture
120 Klotz Lane
Boise, ID 83701
Stewart Allen
Regulatory Affairs
Wilbur-Ellis Company
191 W. Shaw Ave. Ste. 107
Fresno, CA 93704
Paul M. Bachman
South Dakota Department
of Agriculture
445 East Capitol
Pierre, SD 57501
Scott W. Allison
Product & Systems Development Mgr.
Monsanto Ag Products Co.
800 N. Lindbergh Blvd.
St. Louis, MO 63167
Bob Ball
Ever-Green
Lawns
6803 Joyce Street
Golden, CO 80403
Greg Alpers
Sales Representative
Elanco Products Company
2505 N. Washington
Roswell, NM 88201
James Barnett
Dir., Natural Resources Dept,
Indiana Farm Bureau, Inc.
130 E. Washington Street
Indianapolis, IN 46206
Diane Anderson
Agronomy Department
University of Illinois
N305 Turner Hall - 1102 S. Goodwin Ave.
Urbana, IL 61801
Robert E. Bash
Director of Public Affairs
Ohio Farm Bureau Federation
35. E. Chestnut Street
Columbus, OH 43216
Laurel E. Anderson
Professor
University of Missouri
214 Waters Hall
Columbia, MO 65211
W. C. Bauer
Research Institute
Colorado School of Mines
5920 Mclntyre Street
Golden, CO 80403
Robert Argauer
Research Chemist
U.S. Department of Agriculture
Agriculture Research Service
ReJtsville, MD 20705
Joseph M. Beckstrand
Pesticide Specialist
Utah Department of Agriculture
350 M. Redwood Road
Salt Lake City, Utah 84116
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Gary Beeler
Pest. & Haz. Materials Specialist
Pioneer Hi-Bred International Inc.
6800 Pioneer Parkway
Johnston, IA 50131
Richard A. Beyer
Dir. of Natural Resources
Louisiana Farm Bureau
P. O. Box 95004
Baton Rouge, I,A 70895-9004
Daniel W. Belger
SPEAKER
Rollins Environmental Services, Inc.
P. 0. Box 609
Deer Park, TX 77536
George R. Bierman
Associate Div. Director
Engineering & Economic Research, Inc.
3300 Berkley Drive
Fairfax, VA" 22031
Dan Bench
Region 8
U.S. Environmental Protection Agency
1860 Lincoln Street
Denver, CO 80295
Freeman E. Biery
Dir., Weed & Pesticide Division
Kansas State Board of Agriculture
109 SW 9th
Topeka, KS 66612-1281
Philip R. Benedict
Dir., Plant Ind., Lab. & Stnds Div.
Vermont Department of Agriculture
116 State Street, State Office Bldg.
Montpelier, VT 05602
James W. Bigelow
Pesticide Coordinator
Wyoming Dept. of Agriculture
2219 Carey Avenue
Cheyenne, Wyoming 82002-0100
John P. Bennington
Environmental Aff. & Safety
Standard Oil Company of Indiana
Mail Code 4903
Chicago, IL 60601
Mike Biggerstaff
Director
Montana Aviation Trades Association
P. O. Box 340
Stanford, MT 59479
Gordon Berg
Editor
Farm Chemicals Magazine
37841 Euclid Avenue
Willoughby, Ohio 44094
Toby Billings
Research Assistant Professor
Primate Research Institute
P. O. Box 1027
Holloman AFB, NM 88330
Michael Bergin
Region 8
U.S. Environmental Protection Agency
1860 Lincoln Street
Denver, CO 80295
Randy Bodley
Plant Engineer
Transbas, Inc.
1525 Lockwood Road
Billings, MT 59101
James S. Berry, Jr.
Health & Safety Manager
Union Carbide Ag Products Co.
P. O. Box 12014
Research Triangle Park, NC 27709
Robert Boesch
Environmental Protection Specialist
U.S. Environmental Protection Agency
215 Fremont Street
San Francisco, CA 94116
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Bert L. Bohmont
Agricultural Chem. Coordinator
Colorado State University
127 Shepardson Building
Fort Collins, CO 80523
James S. Bridges
U.S. Environmental Protection Agcy.
Municipal Research Engineering Lab
26 W. St. Clair Street
Cincinnati, OH 45268
A. L. Bonner
Supervisor
Oklahoma Dept. of Agriculture
2800 N. Lincoln
Oklahoma City, OK 73105
Robert L. Bright
Sr. Marketing Manager
Calgon Carbon Corporation
Box 1346
Pittsburgh, PA 15230
Henry Bonzek
Region 8
U.S. Environmental Protection Agency
1860 Lincoln Street
Denver, CO 80295
Dennis Brown
VP Membership & Public Affairs
National Fertilizer Solutions Assn.
8823 N. Industrial Road
Peoria, IL 61615
Bryan L. Borup
Supv. Transportation Engineer
California Dept. of Transportation
5554 Kiva Drive
Sacramento, CA 95841
Ron Brown
Ever-Green
Lawns
6803 Joyce Street
Golden, CO 80403
John B. Bourke
Professor
Cornell University
NYSAES
Geneva, NY 14456
Edwin L. Brunken
Manager, Safety Systems
The Pillsbury Company
311 2nd Street, S.E/
Minneapolis, MN 55414
Gary Boutz
Ecological Specialist
KS Board of Agric.-Weed & Pest. Div.
109 9th Street, S.V7.
Topeka, KS 66612
David Buchanon
Environmental Quality Specialist
Texas Department of Water Resources
P. 0. Box 13087, Capitol Station
Austin, TX 78746
Verne Brakke
Dir. Division of Regulatory Svcs.
South Dakota Dept. of Agriculture
Anderson Building
Pierre, SD 57501
Dennis Burchett
United Agri
Products Co.
P. O. Box 1286
Greeley, CO 80632
Barry Brecke
Weed Scientist
Univ. of Florida, Agricultural
Research Ctr.
Rt.3 Box "575
Jay, FL 32565
Gary J. Calaba
Environmental Analyst
Oregon Dept. of Environmental Quality
522 SW 5th Street
Portland, OR 97207
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Joe Capizzi
Ext. Pesticide Coordinator
Oregon State University
2055 Cordley Hall
Corvallis, OR 97331
Ray C. Christensen
Public Affairs Director
Colorado Farm Bureau
2211 W. 27th Avenue
Denver, CO 80217
Nancy Cargile
Deputy Director, Lab. Division
Biospherics, Inc.
4928 Wyaconda Road
Rockville, MD 20852
Beverly A. Clark
General Counsel
Pioneer Hi-Bred International Inc,
700 Capital Square, 400 Locust
Des Moines, IA 50309
David J. Carlson
Environmental Control Supv.
McLaughlin Gormley King Co.
8810 Tenth Avenue North
Minneapolis, MN 55427
Barry S. Cogan
Vice President
At-Sea Incineration, Inc.
1930 N. Fleet Street
Elizabethport, NJ 07206
Duncan Carter
Mgr. Entomology & Pesticide Control
Del Monte Corporation
Box 9004
Walnut Creek, CA 94598
Daniel R. Coleman
Head, Biotechnology Division
Southern Research Institute
2000 9th Avenue South
Birmingham AL 35255
Wayne Chenault
Research Associate
Texas A&M University
Drawer 10
Bushland, TX 79012
Harold Collins
Executive Director
Nat'l Agricultural Aviation Association
115 D Street, S.E. Suite 103
Washington, D.C. 20003
Brian Chicoine
Technical Advisor
PureGro Company
Box 22274
Denver, CO 80222
David Combs
Region 8
U.S. Environmental Protection Agency
1860 Lincoln Street
Denver, CO 80295
Robert Chidester
Director of Marketing
O. H. Materials Co.
1950 Channel Drive
W. Sacramento, CA 95691
Mark Connor
Pesticide Disposal
Project
800-275 Portage Ave.
Winnepeg, Canada R3B 2B3
Christian M. Christensen
Professor
Department of Entomology
University of Kentucky
Lexington, KY 40546
James R. Costello
Operations Mgr-Formulation &
BASF Wyandotte Corporation
100 Cherry Hill Road
Parsippany, NJ 07054
Pkg,
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William A. Cote
Vice President
TRC-Environmental Consultants
7002 S. Revere Parkway
Englewood, CO 80112
J. H. Davidson
Consultant
American Chemical Society
P. O. Box 1706
Midland, MI 48640
Linda Coulter
Chief, Pesticide Section
Colorado Dept. of Agriculture
1525 Sherman
Denver, CO 80203
Jeanne Davies
Master, Colorado State Grange
The National Grange
51 W. 84th Avenue, Ste. 230
Denver, Colorado 80221
Arthur L. Craigmill
SPEAKER
Environmental Toxicology
University of California
Davis, CA 95616
R. A. Davis
Plant Pathologist
U.S. Dept. of Agriculture
BARC-East
Beltsville, MD 20906
Don Cress
Extension Pesticide
Coordinator
Kansas State University
Manhattan, KS 66506
Howard Deer
Pesticide Coordinator
Utah State University
UMC-46
Logan, Utah 84322
James Cruver
President
Saleor, Inc.
P. 0. Box 705
Solana Beach, CA 92075
Clyde R. Dempsey
Chief, Chem. & Chem.
Products Br.
U.S. EPA, Water Engineering
Research Lab.
26 W. St. Clair Street
Cincinnati, OH 45268
Anita C. Dale
Environmental Compliance Coord.
Chevron Chemical Company
940 Hensley Street
Richmond, CA 94804
William H. Dennis, Jr.
SPEAKER
Physical Scientist
4814 Old National Pike
Frederick, MD 21701
David W. Dally
Pesticide Control Specialist
Minnesota Dept. of Agriculture
90 W. Plato Boulevard
St. Paul, MN 55107
Charles H. Darrah, III
Director, Technical Services
Chemlawn Corporation
8275 N. High Street
Columbus, Ohio 43085
Robert L. Denny (SPEAKER)
Maine Board of Pesticide Control
Maine Department of Agriculture
State House Atation #28
Augusta, Maine 04333
Roy R. Detweiler (CHAIRMAN)
Manager, Environmental Affairs
E.I. du Pont de Nemours & Co.
Barley Mill Plaza, WM 6-252
Wilmington, DE 19898
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Tricia Diaz
Kirke-Van Orsdel
4041 N. Central
Suite A-200
Phoenix, AZ 85012
John Eden
Ever-Green
Lawns
6803 Joyce Street
Golden, CO 80403
Kevin Dirks
Supervisor of Government Affairs
Farmland Industries Chemical Plant
1417 Lower Lake Road
St. Joseph, MO 64502
Larry Draheim
Agronomist
CENEX
P. 0. Box 64089
St. Paul, MN 64089-0089
Preston Driggers
Ever-Green
Lawns
6803 Joyce Street
Golden, CO 80403
William S. Dunn
Chief Chemist
Colorado Department of Health
4210 East llth Avenue
Denver, CO 80220
Steven Dwinell
Environmental Specialist
FL Dept. of Environmental Regulation
2600 Blackstone Road
Tallahassee, Florida 32301
Orlo R. Ehart (SPEAKER)
Chief, Pesticide Use & Control
WI Dept. of Agric.,
Trade & Consumer Prot.
801 W. Badger Road
Madison, WI 53708
Delbert Ekart
Safety Director
Kansas Farm Bureau
2321 Anderson Avenue
Manhattan, KS 66502
Paul Ekoniak
Reg. Specialist & Envir. Coord.
ICI Americas, Inc.
Biological Research Center
Goldsboro, NC 27530
Cindy Emmons
Regulatory Specialist
West Agro Inc.
Box 1386
Shawnee Mission, KS 66222
W. B. Ennis, Jr.
Center Director
Ft. Lauderdale Research & Education Ctr.
3205 College Avenue
Ft. Lauderdale, FL 33314
Thomas K. Dykwell
Sanitation Superintendent
Travis Air Force Base
118 Albany Ave.
Vacaville, CA 95688
Jack D. Early
President
National Agricultural Chemicals Assn.
1155 15th Street, N.W. Ste. 900
Washington, D.C. 20005
R. F. Enos
V/estern Farm Service, Inc.
3075 Citrus Circle
Suite 195
Walnut Creek, CA 94598
Winton W. Etchen
Executive Vice President
Iowa Fertilizer & Chemical Association
323 University Drive
Des Moines, IA 50314
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Merlin L. Fagan, Jr.
Director, Environmental Affairs
California Farm Bureau
llth & L Building, Suite 626
Sacramento, CA 95814
Marshall F. Finner
Professor
University of Wisconsin-Madison
10 Babcock Drive
Madison, WI 53706
Vincent J. Farrell
Plant Manager
Agway Inc.
980 Loucks Mill Road
York, PA 17402
Irvin R. Fisher
Chemical Division
Agway Inc.
P. O. Box 4933
Syracuse, NY 13221
Steve Farrow
Region 8
U.S. Environmental Protection Agency
1860 Lincoln Street
Denver, CO 80295
Dick Fitz
Environmental Analyst
Tennessee Valley Authority
228 Summerplace Building
Knoxville, TN 37902
Peter Fay
Associate Professor of Agronomy
Montana State University
Johnson Hall-MSU
Bozeman, MT 59717
Roger A. Flashinski
Pesticide Mgmt. Specialist
Dept. of Agronomy
University of Wisconsin
Madison, WI 53711
Mary P. Ferguson
Asst. Regional Coordinator URPIAP
Pesticide Impact Assessment Program
University of California
Davis, CA 95616
Jon Flint
Pesticide Law Administrator
KS St. Board of Agric.-Weed & Pest. Div.
109 9th Street, S.W.
Topeka, KS 66612
John D. Ferrell
Chemical Engineer
Morrison-Knudson Engineering
P. 0. Box 7808
Boise, ID 83729
Sam S. Fluker
Professor
University of Florida
Building 817
Gainesville, FL 32611
John J. Filchak, III
Director of Governmental Relations
Connecticut Farm Bureau Association
101 Reserve Road
Hartford, CT 06114
Robert E. Frame
Pesticide Program Leader
West Virginia Department of Agriculture
Capital Building
Charleston, WVA 25305
Hugh C. Finklea
Sr. Environmental Group Leader
CIBA-GEIGY Corporation
P. O. Box 11
St. Gabriel, LA 70776
Virgil H. Freed
Professor
Agricultural Chemicals Dept.
Oregon State University
Corvallis, OR 97331
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Darrell Frey
Manager
Lakeland Dusters Aviation
P. O. Box 926
Corcoran, CA 93212
Thomas J. Gilding
Director of Environmental Affairs
Nat'l Agricultural Chemicals Assn.
1155 15th Street, N.W. Ste. 900
Washington, D.C. 20005
Ray Frye
President
American Dusting Company, Inc.
P. O. Box 226
Hereford, TX 79045
Dean Gilliam
Region 8
U.S. Environmental Protection Agency
1860 Lincoln Street
Denver, CO 80295
Robert Fugitt
Agricultural Chemicals Dept.
E.I. du Pont de Nemours & Co.
Barley Mill Plaza, WM 3-156
Wilmington, DE 19898
Gary Gingery
Administrator-Envir. Mgmt. Div.
Montana Dept. of Agriculture
Capitol Station
Helena, Mt 59620-0205
Bill R. Fuller
Asst. Public Affairs Director
Kansas Farm Bureau
2321 Anderson Avenue
Manhattan, KS 66502
Ron Glebe
Region 8
U.S. Environmental Protection Agency
1860 Lincoln Street
Denver, CO 80295
Robert H. Fulton
Technical/Client Svc. Manager
Rohm and Haas Co.
2600 Douglas Road
Coral Gables, FL 33134
John Goforth
United States
Airforce Academy
Colorado Springs
Colorado 80840
William A. Gebhardt
Entomologist
Naval Facilities Engineering Command
200 Stovall Street
Alexandria, VA 22332
Steven Geist
Spray Supervisor
Swing It Tree Company
620 S. Dahlia
Denver, CO 80372
Bill Giese
Region 8
U.S. Environmental Protection Agency
1860 Lincoln Street
Denver, CO 80295
D. Lyle Goleman
Pesticide Coordinator
Dspt. of Entomology-
Chic State University
1735 Neil Avenue
Columbus, OH 43210
Thomas Good
American Cyanamid Company
Agricultural Division
One Cyanamid Plaza
Wayne, NJ 07054
John L. Goodwin
Managing Director
Custom Farm Service of Arizona
P. 0. Box 338
Stanfield, AZ 85272
-138-
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James Gordon
Pesticide Disposal
Project
800-275 Portage Ave.
Winnepeg, Canada R3B 2B3
Robert W. Gruber
President
Moore Pest Control Service Company
3995 South Mariposa
Englewood, CO 80110
C.P. Bert Gorman
Director, Environmental Affairs
Eli Lilly and Company
Lilly Corporate Center
Indianapolis, IN 46285
Herb Gundell
Ever-Green
Lawns
6803 Joyce Street
Golden, CO 80403
Sandra Gowanlock
Regulatory Coordinator
Velsicol Chemical Corporation
341 East Ohio Street
Chicago, IL 60611
Steven R. Gylling
NAPIAP Coordinator
South Dakota State University
Box 2007a, Ag Hall, SDSU
Brookings, SD 57007
Jeff Graham
Research Group Leader
Monsanto Ag Products Company
800 N. Lindbergh Blvd.
St. Louis, MO 63167
Darrel Hale
Supervisor Entomologyst
US AEHA
14590 E. Evans Place
Aurora, CO 80014
Mark Graustein
Pesticides Coordinator
University of Delaware
Rm. 254 Townsend Hall
Newark, DE 19717-1303
Alvin D. Hamman
SPEAKER
Al-Don Dusting Service, Inc.
P. O. Box 474
Eloy, AZ 85231
Philip H. Gray
Intergov't'l Relation Officer
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Lou Hamman
American Fertilizer
& Chemical Company
Box 98
Henderson, CO 80640
Mary L. Grodner
Pesticide Coordinator
LA Cooperative Extension Service
Louisiana State University
Baton Rouge, LA 70803
G. M. Handschumacher
HS&E Representative
Shell Development Company
P. O. Box 4248
Modesto, CA 95352
Diane Groh
Region 8
U.S. Environmental Protection Agency
1860 Lincoln Street
Denver, CO 80295
David Hannemann
Environmental Protection Specialist
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
-139-
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Charles R. Hanson
Dir. Memphis Environmental Center
Velsicol Chemical Corporation
2603 Corporate Ave., Suite 100
Memphis, TN 38132
Virginia Hathaway
Research Associate
JACA Corp.
550 Pinetown Road
Fort Washington, PA
19034
Harold J. Hardcastle
c/o National Agricultural
Aviation Association
115 D Street, S.E.
Washington, D.C. 20003
Erik K. Haupt
Director of Regulatory Affairs
The F.A. Bartlett Tree Expert Company
2964 Falmouth Road, Box 177
Falmouth, MA 02655
Cynthia D. Harmon
Department of Environmental
Conservation
State of New York
Albany, NY 12225
D. w. Heinritz
Regional Manager
IT Corporation
1815 Arnold Drive
Martinez, CA 94553
Anne T. Harri
Hazardous Chemical Safety Officer
North Dakota State University
Sudro Hall 35
Fargo, ND 58105
Dan L. Hemker
Environmental Engineer
Chevron Chemical Company
P. O. Box 7145
San Francisco, CA 94120-7145
David A. Harris
Group Manager
ICI Plant Protection Division
Fernhurst, Haslemere
Surrey, England GU29 3JE
Janelle L. Henderson
Director, Environmental Health
Larimer County Health Department
363 Jefferson Street
Fort Collins, CO 80524
John A. Harris
Mgr., State Env. Reg. Activities
Dow Chemical U.S.A.
2030 Building
Midland, MI 48674
Tony Herold
United Agri
Products Co.
P. O. Box 1286
Greeley, CO 80632
Emmett D. Harris, Jr.
Ext. Entomologist & Pest. Coord.
GA Cooperative Extension Service
Cooperative Ext. Service, Univ. of GA
Albany, GA 30602
Clifford L. Hill
Special Agent
Union Pacific
Railroad
Green River, Wyoming
82001
Samuel A. Hart
Owner
S.A. Hart, C.E.
629 Elmwood Drive
Davis, CA 95616
D. Kill (SPEAKER)
Ofc. of Waste Programs Enforcement
U.S. Environmental Protection Agency
(WH-527) 401 M Street, S.W.
Washington, D.C. 20460
-140-
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John C. Hillis
Executive Secretary
SFIREG
1309 Lucio Lane
Sacramento, CA 95822
Paul M. Horton
Extension Entomologist
Clemson University
108 Barre Hall
Clemson, SC 29631
Winand K. Hock
Professor of Plant Pathology
Penn State University
419 Agricultural Admin. Building
University Park, PA 16802
Dennis W. Howard
Entomologist
Maryland Department of Agriculture
50 Harry Truman Parkway
Annapolis, MD 21401
Dave Hodapp Winston L. Howell
Research Assistant Kirke-Van Orsdel
Department of Environmental Toxicology 4Q41 N. Central
University of California Suite A-200
Davis, CA 95616 Phoenix, AZ 85012
Richard C. Honeycutt (SPEAKER)
Senior Environmental Specialist
CIBA-GEIGY Corporation
P. 0. Box 18300
Greensboro, N.C. 27419-8300
William C. lest
President
Flight Service, Inc.
P. O. Box 38
Caldwell, ID 83606
Frederick W. Honing
Asst. Director, FPM
U.S. Department of Agriculture-
Forest Service
P. 0. Box 2417
Washington, D.C. 20013
George Hook
President
Hook Spraying Service Inc,
19702 172nd Street, South
Big Lake, MN 55309
Marvin E. Hora
Minnesota Pollution
Control Agency
1935 W. County Road B-2
Roseville, MN 55113
Robert L. Horsburgh
Professor of Entomology
V.P.I, and State University
2500 Valley Ave.
Winchester, VA 22601
W. C. Jenson
Western Farm Service, Inc.
3075 Citrus Circle
Suite 195
Walnut Creek, CA 94598
Richard E. Johnsen
Associate Professor
Dept. of Entomology
Colorado State University
Fort Collins, CO 80523
Dave Johnson
Production Manager
Pueblo Chemical & Supply Company
P. 0. Box 636
Garden City, KS 67846
David W. Johnson
Group Leader & Pathologist
U.S. Dept. of Agriculture-
Forest Service
11177 W. 8th Avenue
Lakewood, CO 80225
-141-
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Oscar H. Johnson
Self-Employed
16337 Swartz
Cyn Road
Ramona, CA 92065
William T. Keane
SPEAKER
Arizona Aerial Applicators Association
803 North 3rd Street
Phoenix, AZ 85004
Allan A. Jones
Technical Manager
May & Baker Canada, Inc.
1274 Plains Road E.
Burlington Ontario Canada
L7S 1W6
Philip C. Kearney (SPEAKER)
Chief, Pesticide Degradation Lab
USDA-ARS
BARC-West
Beltsville, MD 20705
Stanley A. Jones
SPEAKER
Top Crop Fertilizer, Inc.
P. O. Box 685
Benkleman, NE 69021
Jim Kelty
Chemist
Illinois Environmental Protection Agency
2200 Churchill Road
Springfield, IL 62704
Thomas L. Jones
Manufacturing Mgr. Pesticide Prod
American Cyanamid Company
One Cyanamid Plaza
Wayne, NJ 07470
Martin G. Kemplin
Mgr. Industrial Health & Env. Aff.
American Cyanamid Company
One Cyanamid Plaza
Wayne NJ 07470
Robert A. Junkin
Manager
Valley Chemical Company
P. 0. Box 1317
Greenville, MS 38701
John M. Kenney
Immediate Past President
Professional Lawn Care Assn. of America
82 Herbert Street
Framingham, MA 01701
Ken Kadlec
Dir., Ag & Economic Sciences
Texas Dept. of Agriculture
P. O. Box 12847
Austin, TX 78711
Abdallah M. Khasawinah
Manager, Scientific Services
Velsicol Chemical Corporation
341 East Ohio Street
Chicago, IL 60611
Lynne Kaneshiro
Research Associate II
UH Cooperative Extension Service
1800 East West Road
Honolulu, HI 96822
John King
Regional Manager
Tetra Tech
153 Kearny Street, Suite 506
San Francisco, CA 94108
Dean C. Kassera
Manager, Chemical Dept.
McLaughlin Gormley King Co,
8810 Tenth Avenue North
Minneapolis, MN 55427
James A. Klinger
Traffic Manager
Nor-Am Chemical Company
3509 Silverside Road
Wilmington, DE 19803
-142-
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Daryl F. Koch
Sr. Hazardous Materials Specialist
Idaho Dept. of Health & Welfare
450 W. State Street
Boise ID 83720
Dennis K. Kuhlman
Extension Ag. Engineer
Kansas State University
Seaten Hall 237
Manhattan, KS 66506
Kenneth R. Kornegay
Officer-In-Charge
USDA, APHIA,
Plant Protection & Quarantine
P. O. Box 291
Elizabethtown, NC 28337
Bong T. Kown
Bechtel National
Incorporated
P. O. Box 3965
San Francisco, CA 94119
Frank T. Lancaster
Dir. Forestry & Solid Waste Mgmt.
Larimer County
P. O. Box 1190
Fort Collins, CO 80522
Ronald Lane
Geologist II
Palm Beach County Health Dept.-
Engineering
P. O. Box 29
West Palm Beach. FL 33402
Frank Kranik
Ecology and
Environment Inc.
Ill W. Jackson Street
Chicago, IL 60604
Robert LaRue
Field Svcs. Bureau Chief
Montana Department of Agriculture
Capitol Station
Helena, MT 59620-0205
Robert Krause
Senior Research Manager
Dow Chemical Company
9001 Building, E. Ashman & Rockwell Dr
Midland, MI 48640
Dave Leatherman
Colorado State Forest Service
Colorado State University
Forestry Building
Fort Collins, CO 80523
Craig Kreuter
Ever-Green
Lawns
6803 Joyce Street
Golden, CO 80403
Charles B. Lennahan
Attorney
Office of the General Counsel-USDA
1444 Wazee Street, Suite 230
Denver, CO 80202
Raymond F. Krueger
SPEAKER
U.S. Environmental Protection Agency
401 M Street, S.W. (TS-769C)
Washington, D.C. 20460
D. Lewis
Plant Engineer
FMC Corporation
P. 0. Box 2386
Fresno, CA 93745
Erich H. Krumm, Jr.
Silviculturist
Champion International Corporation
P. O. Box 191
Huntsville, TX 77340
Alfred C. Little
Environmental Engineer
FMC Corporation
2000 Market Street
Philadelphia, PA 19103
-143-
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Charles Ljungberg
Region 8
U.S. Environmental Protection Agency
1860 Lincoln Street
Denver, CO 80295
Mark S. Maierhofer
Technical Sales Representative
Magna Corporation
1023 Atwood Street
Longmont, CO 80501
Harley Lonebear
Enforcement Coordinator
Three Affiliated Tribes
Box 640
New Town, ND 58763
Warren Maierhofer
Colorado School
of Mines
17603 W. Lunnonhaus Drive #7
Golden, CO 80401
Jack J. Lonsinger
Manager, Environmental Control
Mobay Chemical Corporation
P. O. Box 4913
Kansas City, MO 64120
Narinder P. Malik
Sr. Environmental Scientist
Engineering and Economic Research, Inc.
1951 Kidwell Drive
Vienna, VA 22180
Art G. Losey
Assistant Director
Washington State Dept. of Agriculture
406 General Administration Bldg.
Olympia, WA 98504
James G. Marria
President
Perma-Green Lawn Co., Inc,
P. 0. Box 6946
Boise, ID 83707
Donald A. Low
Special Agent
Union Pacific
Railroad
Denver, CO 80202
John Marshall
Hazardous Materials Coordinator
Denver Fire Department
745 W. Colfax
Denver, CO 80204
Ned Lynn
Farm Foreman
USDA-ARS-Southern Plains Area
P. O. Box 267
Westaco, TX 78596
Larry D. Martin
Consultant, Environmental Affairs
Eli Lilly and Company
Lilly Corporate Center
Indianapolis, IN 46285
Jake Mackenzie
Western Reg. Compliance Director
U.S. EPA
Office of Compliance Monitoring
215 Fremont Ave.
San Francisco, CA 94105
Phil Martinelli
Dir., Div. of Plant Industry
Nevada Dept. of Agriculture
P. 0. Box 11100
Reno, Nevada 89510
Mark A. Maslyn
Jeffrey G. Madore Asst. Dir., National Affairs
Environmental Services Specialist American Farm Bureau Federation
Maine Dept. of Environmental Protection 600 Maryland Avenue, S.W.
State House Station #17 Washington, D.C. 20024
Augusta, ME 04333
-144-
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John Masterman
SPEAKER
CA Department of Health Services
714/744 P Street
Sacramento, CA 95814
Max McCombs
Government Issues Manager
Monsanto Ag Products Company
800 N. Lindbergh Blvd.
St. Louis, MO 63167
David L. Matthew
Department of
Extension Entomology
Purdue University
West Lafayette, IN 49707
Murray L. McKay
Dir., Div. of Pesticide Con.
New Hampshire Dept. of Agriculture
105 Loudon Road-Prescott Park
Concord, NH 03301
Francis Mayo
U.S. Environmental Protection Agcy,
Water Research Engineering Lab.
26 W. St. Clair Street
Cincinnati, OH 45268
James L. McKinley (SPEAKER)
Alberta Environment
Environmental Protection Service
Oxbridge Place, 9820-106 Street
Edmonton, Alberta T5K 2J6
Dean K. McBride
Extension Entomologist
North Dakota State University
Fargo, ND 58105
Robert McCarty
Assistant Director
Mississsippi Dept. of Agriculture
Box 5207
Mississippi State, MS 39762
Von McCaskill
Pesticide Supervisor
Clemson University
201 Barre Hall, Clemson University
Clemson, SC 29631
Marilyn McKinnis
Legislative Assistant
Nat'l Agricultural Aviation Assn.
115 D Street, S.E. Suite 103
Washington, D.C. 20003
Ray V. McManus
Agricultural Center Safety Officer
L.S.U. Agricultural Center
Rm. 187 Knapp Hall-L.S.U. Univ. Station
Baton Rouge, LA 70803
S. K. McMullen
Field Inspector
AP Dept. of Pollution Control & Ecology
8001 National Drive
Little Rock, AR 72209
Paula McClain
Haz. Mat. Disposal Program Manager
Defense Logistics Agency
(DLA-SME) Cameron Station
Alexandria, VA 22314
William T. McClelland
Pesticide Specialist
North Carolina Dept. of Agriculture
P. 0. Box 27647
Raleigh, NC 27611
William F. Megargle
Packaging Engineer
FMC Corporation
2000 Market Street
Philadelphia, PA 19103
James Mergen (SPEAKER)
Natural Resource Specialist
Illinois Farm Bureau
1701 Towanda Avenue
Bloomington, IL 61702-2901
-145-
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Darren W. Mertens
President
Benson Aviation
Incorporated
Sterling, CO 80751
David R. Miskell
Assoc. State LDR Agric. Industry
Coop. Ext. Service-Ohio State Univ,
2120 Fyffe Road
Columbus, Ohio 43210
Robert L. Mesecher
Michigan Department
of Agriculture
P. O. Box 30017
Lansing, MI 48909
Craig A. Monroe
Regional Sales Manager
E. I. Du Pont de Nemours & Co.
7401 W. Mansfield, Ave. Suite
Lakewood, CO 80235
300
Olav Messerschmidt
Regulatory Affairs Dept.
Velsicol Chemical Corporation
341 East Ohio Street
Chicago, IL 60611
Daniel D. Mickelson
General Manager, Manufacturing
Monsanto Ag Products Company
800 North Lindbergh Blvd.
St. Louis, MO 63167
Dallas Miller
Region 8
U.S. Environmental Protection Agency
1860 Lincoln Street
Denver, CO 80295
Richard Miller
Ever-Green
Lawns
6803 Joyce Street
Golden, CO 80403
Tom Mills
California Agricultural
Aircraft Association
383 W. Duarte
Brawley, CA 92227
L. H. Miner
Technical Director
Soilserv, Inc.
P. O. Box 3650
Salinas, CA 93912
Rafael Montalvo-Zapata
Chemist in Charge
P.R. Agric. Exp. Station
Univ. of Puerto Rice
Venezuela Contact Station
Rio Piedras, PR 00927
Dick Montgomery
Ever-Green
Lawns
6803 Joyce Street
Golden," CO 80403
John C. Mullen
IT Corporation
7400 S. Alton Court
Suite 109
Englewood, CO 80112
Donald E. Mullins
Associate Professor
Dept. of Entomology
V.P.I, and State University
Blacksburg, VA 24061
L. O. Nelson
Pesticide Administrator
Office of the Indiana State Chemist
Dept. of Biochemistry Purdue University
West Lafayette, IN 47907
O. Norman Hesheim
Pesticide Coordinator
Oklahoma State University
501 Life Science West
Stillwater, OK 74074
-146-
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Ronald E. Ney, Jr. (SPEAKEP)
Ofc. of Solid Wastes & Emerg. Resp.
U.S. Environmental Protection Agency
401 M Street, S.W. (WH-565E)
Washington, D.C. 20460
David L. Olson
Manager, Registrations
Rhone-Poulenc Inc.
125 Black Horse Lane
Monmouth Junction, NJ 08852
Mike Nolan
United Agri
Products Co.
P. 0. Box 1286
Greeley, CO 80632
Jacqueline L. Oravitz
Environmental Chemical Engineer
Morrison-Knudson Co., Inc.
1400 Broadway - Suite 2100
Denver, CO 80290
John C. Nye
SPEAKER
Agricultural Engineering Department
Louisiana State University
Baton Rouge, LA 70803
Julian H. Oser
Vice President
Oser Exterminating Company
1028 Acoma Street
Denver, CO 80204
Donald A. Oberacker (SPEAKER)
Sr. Mechanical Engineer
U.S. Environmental Protection Agency
26 W. St. Glair Street
Cincinnati, OH 45268
Larry Palmer
Pest Control Supervisor
Minnesota Dept. of Agriculture
90 W. Plato Blvd.
St. Paul, MN 55107
John E. O'Connell
President
MJ Aviation, Inc.
RR2 Box 56A
Letcher, SD 57359
Joseph D. Panetta
Registration Project Leader
NOR-AM Chemical Company
P. O. Box 7495, 3509 Silverside Road
Wilmington, DW 19803
Hipolito O'Farrill
Pesticide Coordinator
Univ. Puerto Rico
•Agricultural Ext. Service
University of Puerto Rico
Mayaguez, Puerto Rico 00708
James V. Parochetti
Program Leader
U.S. Dept. of Agriculture
Extension Service
14th and Independence Ave. S.W.
Washington, D.C. 20250
Ross L. Ohman
Engineer
Minnesota Pollution Control Agency
1935 West County Road B2
Roseville, MN 55113-2785
Lidio Parra
Product Develop. Mgr. - L.A.
Monsanto Ag Products Company
800 N. Lindbergh Blvd.
St. Louis, MO 63167
James R. Oliver
Master
North Carolina State Grange
P. O. Box 10157
Raleigh, NC 27605
Richard M. Parry, Jr.
Assistant Administrator
USDA-ARI-Office of Administrator
14th & Independence Ave. S.W.
Washington, D.C. 20250
-147-
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Linda D. Parson
Quality Assurance Manager
American Beauty Macaroni Co.
4500 Lipan
Denver, CO 80207
Paul Pryor
Industrial Hygienist
UPHS/CDC/NIOSH
9255 W. Euclid Ave.
Littleton, CO 80123
Gabe Patrick
Sr. Agricultural Specialist
Colorado Dept. of Agriculture
1525 Sherman
Denver, CO 80203
Jim Putney
Owner
Aerial Applicator
Box 476
Junction City, KS 66441
J. H. Paulson
State Chemist
Arizona Office of State Chemist
P. O. Box 1586
Mesa, AZ 85201
David O. Quinn
Professor
West Virginia University
408 Brooks Hall, P. O. Box 6057
Morgantown, W VA 25606-6057
Donald L. Paulson, Jr.
Sr. Industrial Health Specialist
CIBA-GEIGY Corporation
P. 0. Box 18300
Greensboro, NC 27419-8300
Stephen Raab
Mgr., Health, Safety & Envir. Aff,
Zoecon Corporation
975 California Avenue
Palo Alto, CA 94034
Robert Pell
Manager, Technical Services
Vulcan Industrial Packaging, Ltd.
1800-46th Street
Lachine, Quebec, Canada H8T-2P2
Nancy J. Rachman
Registration Specialist
Chevron Chemical Company
940 Hensley Street
Richmond, CA 94804
William B. Philipbar
Vice Chairman
Rollins Environmental Services, Inc.
Rollins Plaza
Wilmington, DE 19899
Patrick Rafferty
Research Associate
JACA Corp.
550 Pinetown Road
Fort Washington, PA
19034
John Poehlmann
Dir./Mgr. Agronomy Research Ctr.
University of Missouri
138 Munford Hall
University of Missouri
Columbia, MO 65211
K. Ivan Rash
Field Development Manager
Nalco Chemical Company
2809 Tarn O'Shanter
Richardson, TX 75080
Don E. Rawlins
Director, NER Division
American Farm Bureau Federation
Bill Potts
Planner-MT Solid & Haz. Waste Bur.
Montana Dept. of Health & Env. Sciences 225 Touhy Avenue
Rm. B-210 Cogswell Building Park Rld9e, IL
Helena, MT 59620
60068
-148-
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Bob Reabe
Reabe Spraying Service
Route 1
Box 425
Plainfield, WT 54966
Bradford R. Robinson
Sr. Environmental Analyst
Ct. Dept. of Env. Prot. &
165 Capitol Avenue
Hartford, CT 06106
Pest. Control
J. R. Reabe
Reabe Spraying Service
Route 1
Box 425
Plainfield, WI 54966
Mark G. Robson
Extension Pesticide Coordinator
New Jersey Cooperative Extension Service
J.B. Smith Hall, P.O. Box 231
New Brunswick, NJ 08903
Jeff Reabe
Reabe Spraying Service
Route 1
Box 425
Plainfield, WI 54966
Patrick Roche
Manager
Pesticide Disposal Project
800-275 Portage Ave.
Winnepeg, Canada R3B 2B3
Richard Reade
President
Mid-Continent Aircraft Corporation
Drawer L
Hayti, MO 63851
Charles G. Rock
Sr. Regulatory Specialist
Agricultural Div., CIBA-GEIGY Corp.
P. O. Box 18300
Greensboro, NC 27419-8300
Dennis B. Redington
Environmental Control Manager
Monsanto Ag Products Company
800 N. Lindbergh Blvd.
St. Louis, MO 63167
Jerome C. Rockwell
Mgr., Registrations & Reg. Affairs
Gustafson, Inc.
P. O. Box 66065
Dallas, TX 75266
Rick Reed
Reed1s Fly-On
Farming
P. O. Box 1276
Mattoon, IL 61938
Thomas Rogers
Loss Control Supervisor
Terra Chemicals International, Inc.
815 West Blackwell Ave.
Blackwell, OK 74631
Darryl Rester
Associate Specialist
Louisiana Cooperative
Extension Service
Louisiana State University
Baton Rouge, LA 70803
T. J. Robichaux
Director-SHEA
Petrolite Corporation
369 Marshall Avenue
St. Louis, MO 63119
Gerald D. Rosebery
Manager, Registrations
Pennwalt Corporation
Three Parkway
Philadelphia, PA 19102
Gene Ruppe
United Agri
Products Co.
P. O. Box 1286
Greeley, CO 80632
-149-
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Harry K. Rust
Supv., Ofc. of Pesticide Regs.
Virginia Dept. of Agriculture
P. 0. Box 1163
Richmond, VA 23209
Lora L. Schroeder
Agriculture Manager II
Georgia Dept. of Agriculture
Capital Square
Atlanta, GA 30334
Steven J. Rutz
Environmental Administrator
Florida Dept. of Agric.
& Consumer Svcs.
Mayo Building, Rm. 209-B
Tallahassee, FL 32301
Robert E. Safay
Entomologist
U.S. Army
USAEHA Building 180
Fort McPherson, GA 30330
James L. Sandeno
Sr. Registration Specialist
Pennwalt Corporation
Three Parkway
Philadelphia, PA 19102
Steven A. Sanders
Self-employed
Crop Duster
1068 El Freda
Tempe, AZ 85284
Drake Santistevan
Ever-Green
Lawns
6803 Joyce Street
Golden, CO 80403
John E. Schmidt
Mgr., Formulation & Packaging
BASF Wyandotte Corporation
100 Cherry Hill Road
Parsippany, NJ 07054
Robert Schneider
Senior Scientist
U.S. EPA, NEIC, Building 53
Denver Federal Center
Denver, CO 80225
James N. Seiber (SPEAKER)
Dept. of Environmental Toxicology
University of California
Davis, CA 95616
James Sell
United Agri
Products Co.
P. O. Box 1286
Greeley, CO 80632
D. L. Shankland
Professor
Dept. of Entomology
University of Florida
Gainesville, FL 32611
Liane M. Shanklin
Environmental Scientist
U.S. Environmental Protection Agency
301 S. Park, Drawer 10096
Helena, MT 59626
Leland Shelton
President
National Agricultural Aviation Assn.
115 D Street, S.E., Suite 103
Washington, D.C. 20003
Suzanne Shepard
Mgr., Safety and Health
Zoecon Industries
12200 Denton Drive
Dallas, TX 75234
Jerry Shepler
Dir., Envir. & Local Affairs
Iowa Farm Bureau Federation
5400 University Ave.
West Des Moines, IA 50265
-150-
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Edward R. Shuster
SOLIDTEK Systems
Incorporated
P. 0. Box 888
Morrow, GA 30260
Eugene P. Speck
Associate Director
Agricultural Field Stations
University of California
Davis, CA 95616
Joel Siegel
Hydrogeologist
Canonie Engineers
6551 So. Revere Parkway, Suite 155
Englewood, CO 80111
Fred Staab
Western Regional Manager
Poly-America Linings
P. O. Box 4585
Englewood, CO 80155
Jesse T. Simmons
Assistant Branch Chief
Tennessee Valley Authority
1410 Commerce Union Building
Chattanooga, TN 37401
David Simon
Assistant Editor
Pesticide and Toxic Chemical News
1101 Pennsylvania Ave. S.E.
Washington, D.C. 20003
Michael G. Standish
Larimer County Agronomist
Larimer County Forestry
& Solid Waste Mgmt.
P. 0. Box 1190
Fort Collins, CO 80522-1190
William P. Statham
Airport Planner
Hosac Engineering Inc.
2250 N. Meridian Road
Meridian ID 83642
John Smart
Project Officer
Ontario Ministry of the Environment
40 St. Clair Ave. West - 5th Florr
Toronto, Ontario Canada M5V IPS
H. Grier Stayton
Pesticide Compliance Supervisor
Delaware Department of Agriculture
Drawer D
Dover, DE 19903
John L. Smith
Pesticide Administrator
North Carolina Dept. of Agriculture
P. 0. Box 27647
Raleigh, NC 27611
William G. Smith
Extension Associate
Cornell University
Dept. of Entomology
Comstock Hall
Ithaca, NY 14853
Ed Stearns
Region 8
U.S. Environmental Protection Agency
I860 Lincoln Street
Denver, CO 80295
Mike Steffensmeier
Chief, Haz. Waste Section
Nebraska Dept. of Environmental Control
P. O. Box 94877
Lincoln, NE 68509
Edgar Snoke
Sr. Market Development Analyst
Miles Laboratories, Inc.
P. 0. Box 932
Elkhart, TN 46515
Raymond Steil
Loss Control Supervisor
Terra Chemicals International, Inc.
600 4th Street
Sioux City, IA 51101
-151-
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Dale Steward
Executive Director
Arizona Ag-Aviation Association
2707 E. St. John
Phoenix, AZ 85032
Norwood K. Talbert
Dir., Environmental Safety
Agway Inc.
P. O. Box 4933
Syracuse, NY 13221
Dennis R. Stipe
Assistant Director
Louisiana Agricultural Exp. Station
P. 0. Box E
University Station, LA 70893
Don Tang
Senior Staff Engineer
U.S. Environmpntal Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
R. W. Stockstill
Sales Manager
Rollins Environmental Services, Inc.
P. 0. Box 609
Deer Park, TX 77536
Jim Stoner
Laboratory Director
IT Corporation
937 Mathew Street
Santa Clara, CA 95050
Don Sump
Regional Vice President
PureGro Company
3482 Glade North Road
Pasco, WA 99301
Richard W. Sweet
Admini strator
Arizona Board of Pesticide Control
1624 W. Adams, Room 103
Phoenix, AZ 85007
A. G. Taylor
Environmental Protection Specialist
Illinois Environmental
Protection Agency
2200 Churchill Road
Springfield, IL 62706
George L. Taylor
Soil Conservationist Rm 345
USDA-Soil Conservation Service-MNTC
100 Centennial Mall N. Fed. Bldg.
Lincoln, NE 68528
David H. Teem
Asst. Dean & Asst. Director
Alabama Agri. Experiment Station
105 Corner Hall
Auburn University, AL 36849
Bernard Teeters
Quality Control Manager
Chem Grind Chemical Corporation
P. O. Box 24244
Houston, TX 77229
Craig Swenson
Mgr. Product & Waste Treatment
Mobay Chemical Corporation
P. 0. Box 4913
Kansas City, MO 64120
Walter G. Talarek
General Counsel
American Wood Preservers Institute
1945 Gallows Road #405
Vienna, VA 22180
Charles R. Terrell
Nat'l Water Quality Specialist
USDA-Soil Conservation Service
P. 0. Box 2890
Washington, D.C. 20013
Michael Thede
Coordinator
Environmental Engineering
O.M. Scott
Marysville, OK 43041
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Larry C. Thetford
Supervisor-NE Research Station
CIBA-GEIGY Corporation
RD2 Box 92
Hudson, NY 12534
Fred H. Tschirley
Professor
Pesticides Coordinator
Michigan State University
East Lansing, MI 48823
Lony J. Thomas
Self-Employed
2961 Kendrick Street
Golden, CO 80401
Ron Turner
Sales Representative
Greif Brothers Corporation
4330 E. 48th Ave, Unit B
Denver, CO 80216
Victor M. Thomas
Senior Safety Engineer
Stauffer Chemical Company
P. O. Box 760
iiountain View, CA 94042
Dale E. Uhl
Loss Control Manager
Terra Chemicals International, Inc.
600 4th Street
Sioux City, IA 51101
Angelo Tompros
Chief, Pest, & Haz. Waste Mgmt.
D. C. Gove rnme nt
1705 Chesterford Way
McLean, CA 22101
Robert M. Vallowe
Director of Manufacturing
Southern Mill Creek Products
P. 0. Box 1096
Tampa, FL 33601
Harry W. Trask
SPEAKER
Environmental Consulting
John Street, RFD#3
Biddeford, ME 04003
Ron Venezia
Program Manager
Radian Corporation
P. 0. Box 13000
Research Triangle Park, NC
27709
Harvey D. Tripple
Regional Product Development Mgr.
Monsanto Ag Products Company
9785 Maroon Circle #110
Englewood, CO 80112
Edward F. Vitzthum
Ext. Specialist-Communications
University of Nebraska-Lincoln
101 Natural Resources Hall
Lincoln, NE 68583-0818
Albert Troglin
Chmn. Hazardous Waste Commission
California Agricultural Aircraft Assn.
12145 N. De Vries Road
Lodi, CA 95240
Robert A. Wachter
Environmental Engineer
Anheuser-Busch Company
One Busch Place
St. Louis, HO 63118
Francis J. Trunzo, Jr.
Coordinator, Biochemicals
PPG Industries, Inc.
One PPG Place
Pittsburgh, PA 15272
Acie C. Waldron
Coordinator, NCRPIAP
Ohio State University
1735 Neil Avenue
Columbus, OhH 43210
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William Waldrop
Dist. & Quality Assurance Mrg.
The Dow Chemical Company
P. O. Box
Midland, MI
John G. Welles
Regional Administrator
U.S.EPA Region 8
1860 Lincoln Street
Denver, CO 80295
Joe P. Via 1 drum
Ext. Pesticide Assessment Spec.
University of Arkansas
P. O. Box 391
Little Rock, AR 72203
Janes W. Wells
Unit Chief-Pesticide Enforcement
California Dept. of Food and Agriculture
1220 N Street
Sacramento, CA 95814
D. D. Walgenbach
Professor
South Dakota University
Plant Science Dept. SDSU
Brookings, SD 57007
Suzanne E. Wells
Environmental Protection Specialist
U.S. Environmental Protection Agency
PM-223, 401 M Street, S.W.
Washington, D.C. 20460
Glen Walker
Department of Environmental
Toxicology
University of California
Davis, CA 95616
Lee West
Vice President
West Consulting, Inc.
260 Adams Street
Ilonte Vista, CO 81144
John Ward
Project Officer
U.S. Environmental Protection Agency
Reg. V
26 W. St. Clair Street
Cincinnati, OH 45268
Joseph H. Wargo, Jr.
Chief Chemist/Group Leader
Rhone-Poulenc, Inc.
P. O. Box 125
Monmouth Junction, NJ 08852
Steve West
President
West Consulting, Inc.
260 Adams Street
Monte Vista, CO 81144
Brian A. Westfall
Environmental Engineer
USEPA
Hazardous Waste Engineering Res. Lab.
26 W. St. Clair St.
Cincinnati, OH 45268
Michael J. Weaver
Extension Coordinator
Chemical, Drug & Pesticide Unit
139 Smyth Hall - VPI & SU
Blacksburg, VA 24061
W. B. Wheeler
Professor
University of Florida
Pesticide Research Laboratory
Gainesville, PL 32611
Allan Welch
South Dakota Department
of Agriculture
Anderson Bldg., 445 East Capitol
Pierre, SD 57501
Susan E. White
Environmental Engineer
Hew York Power Authority
123 Main Street
White Plains, NY 10601
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Richard W. Whitney
Professor
Oklahoma State University
121 Ag Hall
Tusla, OK 74078
Tom Yarbrough
Applications Engineer
Quadrex HPS Inc.
1940 NW 67th Place
Gainesville, FL 32606-1649
John H. Wilson
Associate Professor
North Carolina State University
Horticulture Dept. Box 7609
Raleigh, NC 27695-7609
Donald Yon
City of
Fort Collins
P. 0. Box 580
Fort Collins, CO 80522
VJray Winter 1 in
Environmental Chemist
Dept. of Toxicology
University of California
Davis, CA 95616
Joan E. Young
Registration Specialist
Petrolite Corporation
369 Marshall Ave.
St. Louis, MO 63119
Lyle Wong
Dir., Environmental Affairs
Dole Hawaii Division (Dole Pineapple)
650 Iwelei Road
Honolulu, HI 96817
R. W. Young
Professor
Dept. of Biochemistry
V.P.I, and State University
Blacksburg, VA 24061
Roy W. Wood
National Agricultural
Aviation Association
Rt. 3 Box 56
Raeford, NC 28376
Suzanne Wuerthele
Region 8
U.S. Environmental Protection Agency
1860 Lincoln Street
Denver, CO 80295
Ned Zuelsdorff
Enforcement Supervisor
Wisconsin Dept.
Agric.,Trade & Cons. Prot.
801 W. Badger Road, P. O. Box 8911
Madison, WI 53708
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