vvEPA
           United States
           Environmental Protection
           Agency
            Office of Research and
            Development
            Washington DC 20460
EPA/600/9-91/047
January 1992
Proceedings of
International Workshop on
Research in Pesticide
Treatment/Disposal/
Waste Minimization

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                                                 EPA/600/9-91/047
                                                 January 1992
                    PROCEEDINGS OF

   INTERNATIONAL WORKSHOP ON  RESEARCH IN PESTICIDE

        TREATMENT/DISPOSAL/WASTE  MINIMIZATION


                 February 26-27, 1991


                      Edited By:

                  T. David  Ferguson
         U.S.  Environmental  Protection Agency
        Risk Reduction  Engineering Laboratory
               Cincinnati,  Ohio   45268


                    Sponsored  by:

         U.S.  Environmental  Protection Agency
         Office of Research and Development
        Risk Reduction  Engineering Laboratory
               Cincinnati,  Ohio   45268

                         and

              Tennessee Valley Authority
National Fertilizer and  Environmental  Research Center
            Muscle Shoals,  Alabama   35660
                   Coordinated by:

   Science  Applications International Corporation
               Cincinnati, Ohio  45203
                                    U.S. Environmental Proton A2ency
                                    Region 5, Library (P:. ;   /,
                                    77 West Jackson F:-."..:.    -, l&h Hoar
                                    Chicago, IL  60604-iojO
        RISK REDUCTION ENGINEERING LABORATORY
         OFFICE  OF RESEARCH AND DEVELOPMENT
        U.S.  ENVIRONMENTAL PROTECTION AGENCY
                CINCINNATI, OH  45268
                                             Printed on Recycled Paper

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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:

               Tracking Small Quantities of Cancelled or Excess  Pesticides
                 Containing Dioxins and Furans
                 by J.  Paul E. des Rosiers


               Waste Minimization for Non-Agricultural  Pesticide Applicators:
                 EPA's  Pollution Prevention Guide
                 by Teresa M. Harten


               Pesticide Container Management in the United States
                 by Nancy Fitz


               Pesticide Disposal in Guinea-Bissau:   A Case History
                 by Janice Jansen
     All  other papers published in this Proceedings describe  work that was not
funded by the U.S.  Environmental  Protection Agency and therefore do not
necessarily reflect the views of the Agency and no official  endorsement should
be inferred.
                                      ii

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                                   FOREWORD
     Today's rapidly developing and changing technologies and industrial
products and practices frequently carry with them the increased generation of
materials that, if improperly dealt with, can threaten both public health and
the environment.  The U.S. Environmental Protection Agency is charged by
Congress with protecting the Nation's land, air, and water resources.  Under a
mandate of national environmental laws, the agency strives to formulate and
implement actions leading to a compatible balance between human activities and
the ability of natural systems to support and nurture life.  These laws direct
the EPA to perform research to define our environmental  problems, measure the
impacts, and search for solutions.

     The Risk Reduction Engineering laboratory is responsible for planning,
implementing, and managing research, development, and demonstration programs
to provide an authoritative, defensible engineering basis in support of the
policies, programs, and regulations of the EPA with respect to drinking water,
wastewater, pesticides, toxic substances, solid and hazardous wastes, and
Superfund-related activities.  This publication is one of the products of that
research and provides a vital communication link between the researcher and
the user community.

     The U.S. Environmental Protection Agency and the Tennessee Valley
Authority's National fertilizer and Environmental Research Center have begun
promoting cost-effective treatment techniques for pesticide disposal.  In
1991,  the two agencies co-sponsored a workshop on the pesticide waste
minimization, treatment, and disposal.  The workshop focused on current
research in waste minimization strategies and cost-effective/disposal
techniques as they effect applicators, fertilizer/agrichemical dealers and
farmers.

     These proceedings from the 1991 Workshop provide the results of projects
recently completed and current information on projects presently underway.
Those wishing additional information on these projects are urged to contact
the author.  It is hoped the conclusions and recommendations reached at this
workshop will be the basis of a series of regional workshops to be held in
1992.
                                      E. Timothy Oppelt,  Director,
                                      Risk Reduction Engineering Laboratory

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                                   ABSTRACT


      The International Workshop on Research  in Pesticide Management, Disposal,
and Waste Minimization was held in Cincinnati,  Ohio,  February 26-27,1991.  The
purpose of this workshop  was  to  provide government  officials,  pesticide user
groups,  pesticide  producers  and  farm  organizations  practical   solutions  to
pesticide treatment  and  disposal  problems.   The workshop  focused on  how  to
destroy  pesticides  and their  residuals  at  low  cost  by  the applicators  and
dealers.   The technical program included presentations by government researchers
and regulators, university agricultural station  professors, industry experts and
individuals involved in pesticide  disposal  and  treatment.
                                      IV

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                               TABLE OF CONTENTS
Disclaimer	   ii
Foreword	   ii:L
Abstract	   iv
Agenda	vii
List of Attendess	*
Introduction  	   xii

Papers Presented:

 1.   Tennessee Valley Authority National Fertilizer and
         Environmental Research Center - An Overview
         by Joe Gautney	    1

 2.   Tracking Small Quantities of Cancelled or Excess
         Pesticides Containing Dioxins and Furans
         by J. Paul E. des Rosiers	    8

 3.   Research and Development Needs for Agrichemical Retail
         Dealership Site Assessment  and Remediation
         by Chris Myrick	   23

 4.   An Evaporation/Degradation System for Pesticide
         Equipment Rinse Water
         by Steven E. Dwinell	   28

 5.   Pesticide Disposal Using a Demulsification, Sorption,
         Filtration and Chemical and Biological Degradation Strategy
         by D.E. Mullins,  R.W. Young, G.H. Hetzel, and D.F. Berry  ....   32

 6.   Landfarming and Biostimulation for Decontaminating
         Herbicide Wastes  in Soil
         by Kudjo Dzantor  and A.S. Felsot	   46

 7.   Removal of Pesticides From Aqueous Solutions Using
         Liquid Membrane Emulsions
         by Dr. Verrill M. Norwood,  III	   68

 8.   Field and Laboratory Evaluations of an Activated Charcoal
         Filtration Unit
         by J.H. Massey, T.L. Lavy and B.W. Skulman	   85

 9.   Preliminary Studies  of Batch Chemical Oxidation of
         Wastewaters Containing Agrichemicals
         by C.E. Breed and M.C. Crim	   95

10.   Extraction of Pesticides from  Contaminated  Soil Using
         Supercritical Carbon Dioxide
         by G.B. Hunter	100

                                      V

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                             CONTENTS (continued)


                                                                          Page

11.   Modular Concrete Pads for Pesticide and Liquid
         Fertilizer Handling, Storage and Containment
         by Ronald T. Noyes	Ill

12.   Waste Minimization for Non-Agricultural Pesticide
         Applicators: EPA's Pollution Prevention Guide
         by Teresa M. Harten	136

13.   Pesticide Container Management in the United States
         by Nancy Fitz	144

14.   Pesticide Disposal  in Guinea-Bissau:  A Case History
         by Janice Jansen	151

15.   Downstream Injection Equipment for Sprayers and
         Fertilizer Spreaders
         by A.W. Mclaughlin, S.A.  Weeks, and 0.  L. Vanderslice  	  157

16.   Evolution of the Pesticide Container Disposal  Program in Alberta
         by C.G. Van Teeling and W. Inkpen	161

17.   Retail  Fertilizer Dealer Product Containment
         by M.F. Broder	166
                                      vi

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                                    AGENDA
TUESDAY, FEBRUARY  26,  1991
Plenary Session

 9:00   Welcome
        E. Timothy  Oppelt,  Director
        Risk Reduction  Engineering Laboratory
        U.S. EPA

        John E. Culp, Director
        Technology  Introduction
        National  Fertilizer & Environmental Research Center
        Tennessee Valley Authority

 9:30   U.S. EPA, ORD,  RREL - An Overview
        Glenn M.  Shaul
        U.S. EPA

 9:50   Tennessee Valley Authority, National Fertilizer and Environmental
        Research  Center - An Overview
        Joe Gautney
        Tennessee Valley Authority

10:10   Break

10:20   Tracking  Small Quantities of Canceled or Excess Pesticides
        Containing Dioxins  and Furans
        J. Paul E. des Rosiers
        U.S. EPA

10:40   Agrichemical Dealer/Applicator Site Assessment and Remediation
        Chris Myrick
        National  AgriChemical Retailers Association

11:00   Keynote Address
        Robert Denny
        Office of Pesticide Programs
        U.S. EPA

11:30   Lunch
        Caprice 1 and 4 (4th Floor)
                                     Vll

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                              AGENDA  (continued)


Innovative Biological Treatment of Control of Pesticides

 1:30   The Evaporation/Degradation System for:   Pesticide  Equipment
        Rlnsewater - A Practical  Solution to a Pesticide  Waste  Management
        Problem
        Steven E. Dwinell
        Florida Department of Environmental Regulation

 2:00   Pesticide Disposal Using  a Demulsification,  Sorption, Filtration,  and
        Chemical and Biological Degradation Strategy
        D.E. Mullins, R.W. Young, G.H.  Hetzel, and D.F. Berry
        Virginia Polytechnic Institute  and State  University

 2:30   Break

 2:45   Remediation of Herbicide  Haste  in Soil:   Experiences with Landfarming
        and Biostimulation
        Alan Pel sot and Kudjo Dzantor
        Illinois Natural History  Survey

 3:15   Open Discussion

 5:00   Reception - Cash Bar
        Mezzanine Level above Palm Court
WEDNESDAY, FEBRUARY 27, 1991
Innovative Physical/Chemical Treatment for Control of Pesticides

 8:30   Removal of Pesticides from Aqueous Solutions Using Liquid
        Membrane Emulsions
        Verrill M. Norwood, III and Joe Gautney
        Tennessess Valley Authority

 9:00   Field and Laboratory Evaluations of an Activated Charcoal
        Filtration Unit
        J.H. Massey, T.L. Lavy, and B.W. Skulman
        University of Arkansas

 9:30   Preliminary Studies of Batch Chemical Oxidation of Wastewaters
        Containing Agrichemicals
        Claude E. Breed and Mike C. Crim
        Tennessee Valley Authority

10:00   Break
                                     viii

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                              AGENDA (continued)
10:15   Cleanup of Soil Contaminated with Pesticides Using Supercritical
        Carbon Dioxide Extraction
        G. Bradley Hunter
        Tennessee Valley Authority


Waste Minimization Practices for Pesticide Products. Formulations
and Applications

10:45   Pesticide Containment Systems
        Ronald T. Noyes
        Oklahoma State University

11:05   Waste Minimization for Non-Agricultural Pesticide Applicators
        Teresa M. Harten
        U.S. EPA

11:25   Pesticide Container Disposal in the U.S.
        Nancy Fitz
        U.S. EPA

11:45   Lunch
        Caprice 1 and 4 (4th Floor)

 1:30   Pesticide Disposal in Guinea-Bissau:  A Case History
        Janice Jensen
        U.S. EPA

 1:50   Downstream Injection Equipment for Sprayers and Fertilizer Spreaders
        Stanley Weeks
        Agway Farm Research Center

 2:10   Evolution of the Pesticide Container
        C.G. Van Teeling and W. Inkpen
        Alberta Environment

 2:30   Break

 2:40   Retail  Fertilizer Dealer Containment
        Michael  F. Broder
        Tennessee Valley Authority

 3:00   Summary Discussion on Future Research and Technology Transfer
        Chaired by Patrick Eagan
        University of Wisconsin
                                      ix

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                                              UST OF ATTENDEES AT
                              INTERNATIONAL WORKSHOP ON RESEARCH IN PESTICIDE
                                    TREATMENT/DISPOSAL/WASTE MINIMIZATION
     Lea Aurelius
     Environmental Quality Specialist
     Texas Department of Agriculture
     Pesticide Regulatory Program
     P.O. Box 12847
     Austin, TX 78711

     David Balke
     Ciba-Geigy
     P.O. Box 113
     Mclntosh, AL 36553
                                       Gene Carpenter
                                       PSES Department
                                       University of Idaho
                                       Moscow, ID 83843
                                      Arthur L Coleman, Jr.
                                      Ohio EPA
                                      1800 Watermark Drive
                                      P.O. Box 1049
                                      Columbus, OH 43266-0149
                                       Steven Dwineil
                                       Florida Dept. of Environmental Re
                                       2600 Blair Stone Road
                                       Tallahassee, FL 32399-2400
                                      Kudjo Dzantor
                                      Associate Research Biologist
                                      Illinois Natural History Survey
                                      607 E. Peabody Dr.
                                      Champaign, IL 61820
lr
Dr. Duane F. Berry
Assistant Professor
Dept. of Crop & Soy
Environmental Sciences
Virginia Polytechnic Institute &
State University
Blacksburg, VA 24061

Bill Bounds
Ciba-Geigy
P.O. Box 113
Mclntosh, AL 36553
    Claude Breed
    Tennessee Valley Authority
    CEB 3A-M, P.O. Box 1010
    Muscle Shoals, AL 35560-1010
    Michael Broder
    Agricultural Engineer
    Tennessee Valley Authority
    NFE 2E, P.O. Box 1010
    Muscle Shoals, AL 35560-1010

    Marvin Burchfield
    Qemson University SCAES
    209 Agricultural Service Center
    Cherry Road
    demson. SC 29634-0369
                                          John E. Gulp
                                          Manager, Technology Introduction
                                          Tennessee Valley Authority
                                          NFE 2E, P.O. Box 1010
                                          Muscle Shoals, AL  35560-1010
Robert Denny
U.S. EPA
Office of Pesticide Programs
401 M Street, S.W.
Washington, DC  20460

Paul E. des Rosiers
Senior Staff Engineer
EPA - ORD
401 M Street. S.W.
Washington, DC  20460

Roy R. Detweiler
Chadds Ford Enterprises, Inc.
P.O. Box 349
Chadds Ford, PA  19317
                                      Clyde J. Dial
                                      SAIC
                                      635 W. 7th St., Suite 403
                                      Cincinnati, OH 45203
                                      Dr. Patrick Eagan
                                      University of Wisconsin
                                      Deptartment of Engineering
                                      Professional Development
                                      432 N. Lake St., Room 717
                                      Madison, Wl 53706
Lee Faulconer
Washington State Department
of Agriculture
406 General Adm. Bldg., AX^I1
Olympla, WA 98504

Dave Ferguson
U.S. EPA, RREL
26 W. Martin Luther King Drive
Cincinnati, OH  45268
Nancy Fitz
Office of Pesticide Programs
U.S. EPA
401 M Street, S.W.
Washington, DC 20460

Joe Gautney
Research Chemist
Tennessee Valley Authority
NFE 2J, P.O. Box 1010
Muscle Shoals, AL 35660-1010

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Tom Gilding
NACA
1155 15th St., N.W.
Washington, DC  20005
Janet Goodwin
U.S. EPA
Office of Water Regs & Stds.
401 M Street, S.W.
Washington, DC  20460
Margaret Groeber
SAIC
635 W. 7th St., Suite 403
Cincinnati, OH 45203

Cathleen J. Hapeman-Somich
USDA, Agr. Research Service
Room 110, Bldg. 050, BARC-West
Beltsville, MD 20705

Teresa Marten
U.S. EPA (MS 476)
26 W. Martin Luther King Dr.
Cincinnati, OH 45268
Robert Hayes
Idaho Department of Agriculture
Division of Agriculture Tech.
P.O. Box 790
Boise, ID 83701

Dan Herndon
Radian Corporation
2455 Horsepen Rd., Suite 250
Herndon, VA 22701

Brad Hunter
Research Chemist
Tennessee Valley Authority
NFE 2J, P.O. Box 1010
Muscle Shoals, AL 35660-1010

Janice Jensen
Office of Pesticide Programs
U.S. EPA
401 M Street, S.W.
Washington, DC  20460
Shripat T. KamWe
State Liaison-Pesticide
Impact Assessment
University of Nebraska
101 NRH, Environmental Programs
Lincoln, NE  68583-0818

Richard N. Koustas
Treatment of Pesticides in
Contaminated Soils
U.S. EPA, RREL
2890 Woodbridge Ave.
Edison,  NJ  08837

Larry Le Juene
LA Dept. of Agriculture & Forestry
P.O. Box 3596
Baton Rouge, LA 70821-3596

David Macarus
U.S. EPA Region V (5 SPT-7)
230 S. Dearborn
Chicago, IL 60604

Joe Massey, Research Assist.
University of Arkansas
Altheimer Lab
276 Altheimer Drive
Fayetteville, AR  72703

Bill McCarthy
U.S. EPA
401 M Street, S.W.
Washington, DC  20460
William T. McClelland
N.C. Department of Agriculture
P.O. Box 27647
Raleigh, NC  27611

Dr.  Donald E. Mullins
Assoc. Prof., Entomology Dept.
Virginia Polytechnic Institute &
State University
Blacksburg, VA 34061

Chris Myrick
Dir. of Legislative Reg. Affairs
National Agrichemical Retailers Assn.
1155 15th St., N.W., Ninth Floor
Washington,  DC 20005
Verrill M. Norwood, Jr.
Pioneer Chlor Alkali Co.
121 Blueberry Hill Rd., N.W.
Cleveland, TN  37312
Verrill M. Norwood, III
Research Chemist
Tennessee Valley Authority
NFE 2J-M, P.O. Box 1010
Muscle Shoals, AL  35630
Ronald T. Noyes
Oklahoma State University
225 AG Hall
Stillwater, OK 74078-0469

E. Timothy  Oppelt
U.S. EPA, RREL
26 W. Martin Luther King Drive
Cincinnati, OH 45268

Erdal Ozkan
Agricultural Engineering Department
Ohio State  University
Columbus,  OH 43210
Donald L Paulson, Jr.
Ciba-Geigy Corp.
P.O. Box 18300
Greensboro, NC  27419-8300
Tom Powers
U.S. EPA, RREL
26 W. Martin Luther King Drive
Cincinnati, OH 45268

Ghulam M. Memon
Pandalia Coatings
837 6th St.
Brackenridge, PA  15014
Loma Poff
Ontario Ministry of Environment
135 St. QairAve., W.
Toronto, Ontario M4V 1P5
                                                   XI

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Dairy! Rester, Specialist                  Robert Wulfhorst, Specialist
Louisiana Cooperative Ext. Service        Ohio Department of Agriculture
Louisiana State University                8995 E. Main Street
Knapp Hall                             Reynoldsburg, OH 43068
Baton Rouge, LA  70821-3596

Dave Scott                             R. W. Young
Office of Indiana State Chemist           Virginia Polytechnic
Department of Biochemistry              Institute & State University
Purdue University                       352 Litton, Reaves Hall
West Lafayette, IN  47907                Blacksburg,  VA 24061

Glenn Shaul                            Steve Zahos
U.S. EPA, RREL                        Envirocyde
26 W. Martin Luther King Drive            P.O. Box 7
Cincinnati, OH  45268                   St. Joseph, MO  64502

Subhas Sikdar
U.S. EPA, RREL
26 W. Martin Luther King Drive
Cincinnati, OH  45268

Jack M. Sullivan
Tennessee Valley Authority
NFE, 2J-M
Musde Shoals,  AL  35660

Dr.  Lynne Tudor
U.S. EPA
Office of Water
401 M Street, S.W.
Washington, DC 20460

Dr.  C. G. Van Teellng
Special Projects Officer
Alberta Environment  Pesticide
5th ROOT, Oxbridge Place
9820-106 St.
Edmonton,  Alberta  T5K 2J6

Dr.  Stan Weeks
Agway, Inc.
P.O. Box 4933
Syracuse, NY  13221-4933

Brian Westfall
Cincinnati Solid Waste Project
26 W. Martin Luther King Drive
Cincinnati, OH  45268

Roger Wilmoth
U.S. EPA, RREL
26 W. Martin Luther King Drive
Cincinnati, OH  45268
                                                     xii

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                                 INTRODUCTION
      An international workshop on treatment, disposal, and waste minimization
of pesticides and pesticide wastes was held in Cincinnati,  Ohio  on February 26-
27, 1991.  The purpose of this workshop was to work with government, pesticide
user groups,  pesticide producers,  farm organizations  and academia to define and
offer practical solutions to pesticide users' treatment and disposal problems.
The technical  program  included  presentations  by government  researchers and
regulators,  academia,  industry experts and  individuals  involved  in pesticide
disposal and treatment.

      The workshop was sponsored by the following organizations:


                     U.S. Environmental Protection Agency
                      Office of Research and Development
                     Risk Reduction Engineering  Laboratory
                            Cincinnati,  Ohio  45268

                                      and

                          Tennessee Valley Authority
             National  Fertilizer  and  Environmental Research Center
                         Muscle Shoals,  Alabama   35660


      The following people were on the workshop planning committee:

                  Glenn M. Shaul
                  U.S. Environmental Protection Agency
                  Risk Reduction Engineering Laboratory

                  T. David Ferguson
                  U.S. Environmental Protection Agency
                  Risk Reduction Engineering Laboratory

                  Edwin F. Barth
                  U.S. Environmental Protection Agency
                  Center for Environmental Research  Information

                  Margaret M. Groeber
                  Science Applications International  Corporation

                  Joe Gautney
                  Tennessee Valley Authority
                  National Fertilizer & Environmental Research Center


      Aside  from  the technical presentations,  the  workshop allowed  for some
discussion among the participants.  Several  issues/concerns were discussed by the
attendees. The two issues which cause  the greatest concern were site remediation
and regulatory framework.
                                      Xlll

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      Discussions on site remediation were directed toward dealer  sites.   The
focus on the cleanup was both soils and groundwater contamination.   The largest
problems identified with dealer site cleanup were costs and issues  of how clean
is clean enough.   It was noted that many dealers could go bankrupt if costs were
high.  Also, very little remediation is being conducted because dealers feel that
regulators can not give them cleanup  levels that  will  hold true  in  the future.

      Regulatory framework is also of great concern.  There was much discussion
over how to solve their problem.   Suggestions  included  the following:

1)    Prove technology then worry about  the regulatory  framework.

2)    Regulatory  framework  needs to be  looked  at while  technology  is  being
      developed—it can and does  drive  costs.

3)    Policy people are not listening to  research people.

4)    Get the  key players involved - Target  State Regulators  since  they are
      closest to  the problem - Get the concerns  and scientific  information to
      the pertinent regulatory  people.


      Another topic of discussion was waste minimization and education.  It was
agreed that many  of the pollution prevention  ideas would  greatly  decrease the
number  of  future poblems  involving  pesticides.   These  waste  minimization
techniques were generally low cost practical solutions to managing pesticides and
pesticide wastes.  It is important that  these  ideas become common  practices by
educating appropriate users and dealers  of pesticides.
                                     xiv

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                          Tennessee Valley Authority,
             National Fertilizer and Environmental Research Center

                                  An Overview

                                       by

                                  Joe Gautney
                         Chemical  Research Department
                         Muscle  Shoals, Alabama 35660
ABSTRACT

      The  National  Fertilizer and Environmental  Research  Center (NFERC) is a
unique part of the Tennessee Valley Authority (TVA), a  government agency created
by an Act  of Congress in  1933.  The Center, located in Muscle Shoals,  Alabama,
is   a   national   laboratory   for   research,   development,   education   and
commercialization for fertilizers  and related agricultural chemicals  including
their  economic  and  environmentally  safe  use,   renewable  fuel  and   chemical
technologies,  alternatives  for   solving  environmental/waste   problems,   and
technologies which support  national  defense.   NFERC projects in the  pesticide
waste minimization/treatment/disposal areas include "Model Site  Demonstrations
and  Site  Assessments,"  "Development  of Waste Treatment  and Site Remediation
Technologies  for Fertilizer/Agrichemical  Dealers,"  "Development of  a  Dealer
Information/Education Program," and "Constructed  Wetlands."


BACKGROUND AND INTRODUCTION

      The  National  Fertilizer and Environmental  Research  Center (NFERC) is a
unique part of the Tennessee Valley Authority (TVA),  a  government agency created
by an Act of Congress in  1933 as part of President Franklin D. Roosevelt's  New
Deal for lifting the Nation  from  the Great Depression.   Congress gave the  new
Agency a broad mandate for development of the Tennessee Valley region along with
national responsibility for fertilizer research, development, and introduction.
The Agency was also given responsibility for supporting national defense.

      The  Tennessee  Valley Authority is  a  rather  unique  government agency.
President  Roosevelt described  it  as "a corporation clothed  with the  power of
government,  but  possessed  of  the flexibility  and  initiative  of a private
enterprise."  The Agency  is headed by a three-person  Board of Directors, each
appointed to a nine-year term by the President of the United States with approval
of the Congress.   Organizationally (Figure 1), TVA consists of three  operating
groups: Generating,  Customer,  and Resource. The Generating and Customer  Groups
are associated primarily with TVA's power production operations.  The Agency owns
and operates the largest  electric  utility  in  the  United States.  The  Resource
Group  includes  the Agency's  river basin  operations, economic  and   community
development  activities,   budget and  business  operations,  and the   National
Fertilizer and Environmental Research  Center (NFERC).  Many of the organizations
in the Resource  Group receive  core funding from Congressional appropriations.
In contrast, TVA's power  production operations are entirely self-supporting.

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NATIONAL FERTILIZER AND ENVIRONMENTAL RESEARCH CENTER (NFERC)

      The National Fertilizer and Environmental  Research  Center is  located on a
1200-acre site  in Muscle  Shoals,  Alabama.   The  Center has about 450 employees
which include chemists, engineers,  agronomists,  soil  scientists, and a highly
skilled  blue-collar  staff  for   operation  of  pilot  and prototype  research
facilities.  The NFERC receives core funding from Congressional  appropriations
and during the last decade has come under increased pressure to  supplement these
appropriations with funds from outside contract  work.  The FY91  NFERC budget is
$54 million ($33 million  Congressional appropriations).

      Fertilizer research  and development was the main thrust of  NFERC activities
from its beginning until a few years ago.  The Center conducted  basic laboratory
research with  scale-up  of  promising  technologies in  pilot-   and full-scale
production facilities located at NFERC.  Agronomic testing of  the new fertilizer
products was conducted in parallel  with development of the  production technology.
Once developed, new fertilizer technologies were introduced across the Nation.
This fertilizer orientation resulted in  unparalleled  technical improvements.
NFERC technologies  are  involved  in  production of  about 75  percent  of  the
fertilizers in use today,  and through the years NFERC has  issued licenses to 400
companies for use of patented NFERC processes.

      A few years ago NFERC began  a shift more toward environmental  research and
development.  This shift was prompted by growing public and regulatory concern
over environmental pollution,  particularly that from agriculture,  and driven
internally by NFERC staff and  externally by NFERC's  Executive  Industry Review
Group (EIRG).  As a result of these internal and external forces, in  January 1990
the Center was  reorganized and its  name changed  from the National Fertilizer
Development Center to NFERC.   The mission of NFERC is to serve as a national
laboratory for research, development, education, and commercialization for:

             Fertilizers and Related Agricultural Chemicals Including Their
             Economic and Environmentally Safe Use

             Renewable Fuel And Chemical Technologies

             Alternatives for Solving Environmental/Waste Problems

             Technologies Which Support National Defense

      The NFERC (Figure 2) is headed by  Senior Vice President, John T. Shields.
The  Center   has  three   divisions:   Research,   Development,  and  Technology
Introduction.    The  Research division consists  of  Biotechnical,  Chemical,  and
Agricultural Research departments.  These departments conduct basic and applied
research in  their respective speciality areas.  The Development division consists
of Prototype Operations, Chemical Development and Project Management departments.
The Prototype Operations  Department maintains  and operates  NFERC's prototype
facilities  for  testing  and  demonstrating new  fertilizer  and environmental
technologies;  the Chemical Development Department conducts bench- and pilot-scale
research and development; and the Project Management Department  is responsible
for capital  projects such  as demolition of old full-scale  production facilities,
construction of new prototype facilities, and contractual projects which NFERC
conducts for  the  U.S.  Department  of Defense.    The Technology  Introduction
division  consists of  Field Programs,   Marketing,  and   Engineering  Services
departments.  The Field Programs Department works with  industry  and universities

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 through  its  field engineering staff and national network of area  directors  to
 introduce and test NFERC technologies and products.  The Marketing Department  is
 responsible  for marketing  NFERC  technologies and  products.   The  Engineering
 Services  Department  provides  engineering  design  services  to  other NFERC
 organizations and outside clients.  It also houses the NFERC environmental staff
 which is responsible for ensuring that NFERC projects and project activities meet
 environmental and  regulatory  requirements.

 NFERC Pro.lects  in  Pesticide Waste Minimization/Treatment/Disposal

      NFERC  currently   has  a  number  of  projects  in  the  pesticide waste
 minimization/treatment/disposal areas.  Most of these projects are being pursued
 using interdisciplinary  project teams which span  division and department lines.
 The projects are "Model Site Demonstrations and Site Assessments,"  "Development
 of Waste Treatment and Site  Remediation Technologies for Fertilizer/Agrichemical
 Dealers,"   "Development  of  a  Dealer  Information/Education   Program,"  and
 "Constructed Wetlands."

 Model Site Demonstrations and  Site Assessments--

      NFERC  is  establishing  model   demonstrations  at  fertilizer/agrichemical
 dealer  sites across the United  States  to  demonstrate secondary  containment
 systems   and  other   "best  management  practices"   (BMPs)   for  minimizing
 fertilizer/pesticide losses to the environment.  Selection of sites is  made by a
 group  composed  of  state  fertilizer  and  agrichemical   trade   associations,
 individual dealers, TVA regional directors,  and field programs staff.  Under the
 program,  NFERC  provides—at  no  charge—technical   assistance  in planning  and
 designing the containment system and  recommends other BMPs based on existing and
 anticipated rules and regulations for that  particular  state.  The participating
 dealer  pays  all  construction costs  associated  with  bringing  the  site  into
 compliance and  agrees  to open his or her facility to visits by  other  dealers,
 regulators, and other interested parties.  The NFERC plans to establish twenty
 model demonstration sites in fourteen states.  Four sites have been completed.

      NFERC   also   conducts   site   assessments  on   a   fee   basis   for
 fertilizer/agrichemical  dealers across  the  United  States.   Under this  program
 NFERC environmental staff will conduct a "friendly"  assessment  of a  dealer site
 and make written recommendations for secondary containment and other BMPs. NFERC
 also  provides   the  dealer  with  information on  applicable regulations,  and
 depending on the  fee,  will  provide  either  generic  or customized drawings  for
 secondary containment facilities,  rinse pads, etc.   To  date NFERC has conducted
 approximately thirty environmental  site assessments  for dealers.  The charge for
 a standard site assessment  is $3,500.

Development of Waste Treatment  and Site Remediation Technologies for  Fertilizer/
Agrichemical Dealers--

      The objectives of this project  are to develop,  introduce,  and market waste
treatment and site remediation technologies for fertilizer/agrichemical dealers.
The project  consists  of  four  phases: Phase  I -  Define Problems,  Phase  II  -
 Identify "Current  State of  the Art"  for Waste Treatment and Site Remediation
Technologies, Phase III  - Evaluate/Modify/Research/Develop Waste Treatment  and
Site  Remediation  Technologies,  and  Phase   IV  -  Introduce  and  Market Waste
Treatment and Site Remediation Technologies.

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       In Phase I information to guide the project was collected from Federal and
state regulatory agencies, nonregulatory agencies, universities, dealer and trade
associations,  and basic producer  organizations.    During  Phase  II  which  was
conducted concurrently with Phase I, extensive literature reviews were conducted
to  identify  waste  treatment  and  site  remediation  technologies which  are
potentially   applicable  to waste   treatment  and  remediation  problems  at
fertilizer/agrichemical dealer sites.  The information from Phases I and  II was
published in  internal and external  reports (TVA Circular Z-288)  and  in a  series
of three TVA  bulletins (Y-213 - Y-215).

      The project  is  currently in Phase III.   In  this phase research is being
conducted  on  a   number  of  promising   waste  treatment  and  site remediation
technologies  ranging  from low to high technology.  These projects are:

              Supercritical   Fluid Extraction of Pesticides From Soils

              Bioremediation of Pesticide Contaminated Soils

              Batch Oxidation of Pesticides in Rinsates

              Best Management Practices  Bioremediation of Pesticide
              Contaminated Soils

              Development/Validation of  Immunoassays for Pesticide Analysis

              Solar Evaporation/Concentration/Degradation of Pesticides in
              Rinsate Wastes

              Effects of Best Management Practices on "Natural" Remediation

              Soil Washing To Remove Pesticides From Soils

              Supercritical  Water Oxidation of Pesticide Wastes

              Remediation of Pesticide-Contaminated Soils by Application  to
              Cropland

      Promising technologies from Phase III will be demonstrated,  introduced, and
marketed in  Phase IV.  Many of  the technologies  developed in  Phase  III will
likely be applicable  (with modification)  to  the problems  of  other industries
besides fertilizer/agrichemical  dealers.

Development of a Dealer Information/Education Program--

      The objectives  of this project  are to  provide fertilizer/agrichemical
dealers with  information/education necessary to operate environmentally sound and
profitable businesses.  A dealer environmental  checklist was recently developed
in cooperation with  the National  Fertilizer Solutions  Association and  the
National  AgriChemical  Retailers  Association.    More  than  15,000  of  these
checklists have been distributed to dealers across the country.  Other activities
under this project  include development of an  environmental handbook,  a video
questionnaire for environmental self-assessment, and environmental  workshops for
dealers; and  compilation of information on state-sponsored pesticide/household
waste amnesty.days  (contract work  for  EPA).   In  addition, research  is being
conducted to evaluate different concretes  and  concrete additives,  coatings, and
liner materials for construction  of  load pads  and other containment structures.

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Constructed Wetlands--

      The objective  of  this project is to develop  a low-cost, low-technology
solution to  the  treatment of contaminated waste waters  from the agribusiness
industry.  Potential  users  of this technology include fertilizer/agrichemical
dealers and food processors.

      Constructed wetlands are generally rock filled, shallow cells which util ize
plants  and biological  colonies that grow  around  their root  system  to absorb
and/or  destroy the  contaminants in  the waste water.  A  constructed wetlands
research and development  facility  is scheduled  for  completion at NFERC in the
Spring of 1991.  The facility includes a greenhouse for conducting small-scale
test work,  32 treatment test cells, and 2  larger nursery cells for propagating
plants.  Data from the  greenhouse  work  and test cells will  be used to install
several demonstration test cells throughout the United States.  These sites will
be selected to demonstrate a variety of waste water compositions, flow patterns,
plants, and climatic conditions.

Other NFERC Research Activities

      Other NFERC research activities include production of ethanol and  other
chemicals from the cellulosic  portion of municipal solid wastes, utilization of
industrial  and  agricultural  wastes  in  fertilizer production,  development of
controlled availability fertilizer  materials,  and development  of improved fluid
fertilizers.

Future Goals

      NFERC plans to  become a leader in  environmental  research  and development--
it will continue to develop and introduce  improved fertilizer technologies for
the nation—develop and demonstrate  technologies for converting cellulosic wastes
to  ethanol   and  other  useful  chemicals;  remove  old  full-scale  fertilizer
production  facilities and  clean up the plant sites; design and  operate prototype
facilities  for  demonstrating  fertilizer  and  environmental  technologies;  and
upgrade staff to  meet new job demands through training, affirmative actions, and
hiring  of  new  employees.    In  addition,  NFERC  will  intensify  its efforts to
increase funding  from npnappropriated sources  by conducting contractual work for
national defense agencies, other government agencies, and private firms.

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                Tracking Small  Quantities of Canceled or Excess
                   Pesticides Containing Dioxins and Furans

                                      by

                            J. Paul E. des Rosiers
                     U.S. Environmental Protection Agency
                  Office of Research and  Development  (RD-681)
                             Washington,  DC   20460
ABSTRACT
      Confusion currently exists regarding the  treatment of suspended, canceled
or excess, registered pesticides and their respective formulations under FIFRA,
RCRA  or CERCLA,  particularly  if  soil  and debris  are contaminated  by these
chemicals.

      The paper describes what options exist for pesticide-contaminated soil and
debris or excess,  registered pesticides, given that the former wastes  are subject
to  the  RCRA  land disposal  restrictions  and  must  meet  prescribed  treatment
standards  and  the  latter formulations  may  be  amenable   to   some  creative
interpretations of RCRA small quantity generator rules or may  qualify  under FIFRA
for reuse and recycle by  application as a  pesticide  according to  label rates on
label-approved crops or cropland.

Storage and Disposal Plans — Final Disposition

      Confusion may exist  regarding the treatment of suspended and/or canceled
pesticides  (e.g.,  endrin,  heptachlor, chlordane, 2,4,5-T,  2,4,5-TP  (Silvex),
lindane, DDT, etc.) under FIFRA,  RCRA or CERCLA particularly  if soil and debris
are contaminated by excess registered or suspended/canceled  pesticides.

      After the applicable  effective dates, restricted waste may be land disposed
only if it meets the prescribed RCRA treatment standards, or if it  has been shown
to a reasonable degree of certainty, that there will be no migration of  hazardous
constituents from the disposal  unit for as long as the waste remains hazardous.

      At present, a treatment standard is based on the performance of the best
demonstrated  available   technology  (BOAT)  (51  FR  40578).    Compliance  with
performance  standards  may be  ascertained by  determining   the  concentration
level(s) of the principal organic hazardous constituent(s)  (POHCs) in the waste,
in the treatment residual,  or in the extract of the waste or treatment  residual.

      The Agency has identified U,  P (pesticide)  and F waste for which proposed
concentration-based  standards have  been  changed to  technology-based  standards
(e.g.,  incineration).  (See Tables 1-3.)

      Furthermore, soil  and debris that are contaminated with prohibited waste
are subject to the land disposal restrictions (LDRs)  and must meet the  treatment
standard, as  previously  described,  for the contaminating waste  prior to land
disposal.   The Agency  realizes,  however,  that  there  are  certain sampling and
analytical difficulties associated with regulating hazardous waste  in soil and
debris matrices.  Because  of such problems, the Agency is preparing a separate
rule-making that will establish treatability groups  and treatment standards for
contaminated soil and debris.  (See Table 4 and 5.)

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       If the pesticide contaminated soil and debris cannot be  treated to meet the
 promulgated   treatment   standards,   alternative   treatment   standards   can  be
 established under  a site-specific variance from the treatment standards (see 53
 FR  31221,  August 27,  1988)  or a  full-scale  variance  (40  CFR  268.44).   In  order
 to  be  granted  a  site-specific  variance  from   the  treatment  standard,  the
 petitioner must demonstrate to the Agency that because the physical (or chemical)
 properties of the waste differ significantly from  the waste analyzed and used to
 develop the treatment standard, the waste cannot  be treated  to specified levels
 (see  40 CFR 268.44).

      Moreover, the Agency has established guidance levels for granting  soil and
 debris treatability variance based on limited soil and debris treatment  data and
 these can be found  in  Superfund LDR Guides #6A and  6B, July 1989 (U.S.  EPA,  1989a
 and U.S. EPA  1989b).

 Conceptual Approach under FIFRA

      The  soil  that  contains  the pesticides  should  be  viewed as a "new  inert
 diluent" and, as such,  comprises a carrier  for the active ingredient(s) within
 the pesticide  formulation.   Representative  soil  samples should be analyzed  by
 acceptable  EPA methods  to  determine the concentration(s)  of pesticide(s)  of
 regulatory  concern.    This  target  pesticide (and others)  should be  used  to
 calculate  what an  appropriate FIFRA-approved  label  rate  would be  for   that
 particular pesticide.   Once  this rate is determined, the  pesticide-soil  may then
 be applied or redistributed at or below its  "label rate" or  agronomic  rate for
 the type of crop grown on the  receiving field in order to  take advantage, during
 the active growing season or  summer months, of natural or enhanced ultraviolet
 (UV)  photolysis   and   controlled   biodegradation  by   natural   or   special
microorganisms.  This  approach is legal under RCRA because it  represents recycle
 and reuse of a product; the approach should also be legal  under FIFRA because the
 target pesticide(s) (those of most significance within the soil) is being applied
 according to label  rates on label-approved crops.

      The success of this approach will vary from location to  location,  based  on
 specific active  ingredient(s), concentration(s),  and other  factors,  and   this
process should  maintain the  contaminated  soil  within the  framework  of  FIFRA
regulations and guidelines.    If, however, RCRA becomes controlling,  one option
 is to utilize the approach being used under CERCLA, i.e., obtaining a  soil and
debris treatability variance  for remedial  or removal actions  (Superfund LDR
Guides #6A and 6B).  (See also Table 6.)

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Excess Pesticides, Rinsates and Other Pesticides Containing Materials (FIFRA Part
165.62 proposed under Subpart D)

165.62 Allowable Practices and Procedures

      (a)    Application as a pesticide  (primary method  of disposition)

            (1)   Pesticide  in the  material must  be  known;  total  amount  of
                  pesticide applied to  the  labeled  site does  not exceed  the
                  total amount allowed  on  the
                  label;  and other directions  and conditions on the label  are
                  compiled with.

            (2)   Any specific instructions on the  label  for application  of
                  excess  pesticides,  rinsates,  another materials  are  compiled
                  with.  For excess formulation or mixture of  formulation  and
                  diluent,  application  as  a pesticide to a labeled site  at  or
                  below the rate of application allowed on the label  is clearly
                  within  the provisions  of the  act.

      (b)    Use as  diluent--Pesticide-contaminated  rinsates  can  be  used  as
            diluents for  subsequent mixtures or the same pesticides.   Rule-of-
            thumb--no more  than 5-10% of the volume  of a mixture can be  composed
            of rinse water containing pesticide residues.

      (c)    Recycle   or recovery—Excess  pesticides,  rinse  water containing
            pesticides and other pesticide containing materials can be offered
            for recycling  or  recovery under proposed regulation; but  EPA Office
            of Pesticide  Programs  (OPP)  definitions of  each option differ from
            normally accepted definitions.   For  example,  recycling  involves
            returning  of  the  pesticide  to  the manufacturer  of  the active
            ingredient for extraction of same;  whereas, recovery is limited  to
            combustion for energy  value.

      (d)    Storage  as a pesticide—If excess pesticide, rinse waters,  or  other
            pesticide containing materials cannot be immediately  applied  as  a
            pesticide,  such  as a diluent,  or  recycled  and  recovered,  the
            material may  be stored as a pesticide until it can be employed  in
            one of those manners.   However, it must  be stored in compliance with
            applicable pesticide storage regulations  (at the  present time,  the
            regulations do  not specify  a  time  limit  for  storage  of  these
            materials as  pesticides.)   The applicability  limit  set  by  FIFRA
            Subpart  B is  11,000 pounds (5.5 tons or approximately 20 drums)  and
            60 days.  The  limit is also triggered by 1,350 gallons  of rinsates.

      (e)    Waste  materials—If the excess  pesticide,  rinse  waters,   or  other
            pesticide containing material  cannot  be used as stated previously,
            then these materials must be handled as wastes  under RCRA,  that is,
            if they  cannot be handled in accordance with 40 CFR 165.62 (a)-(d)
            or if  they contain any solvent other  than the diluent  specified  on
            the label.
                                      10

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 Practical  Example and Potential  Remedy

       Waste containing chlorophenols are particularly difficult to address under
 RCRA and has often perplexed many  during  and after the implementation  of  the
 removal  or remedial  action phases (Collison, 1990).  Not only are  the  current
 RCRA rules confusing, but EPA has added to the discomfort index by publishing  the
 Final  Rule on the Identification and Listing of Hazardous Waste (Wood Preserving)
 that delineates as hazardous waste, wastewaters, process residuals,  preservative
 drippage,  and discarded spent formulations  from  wood  preserving processes  at
 facilities   that  currently  use   or   have  previously  used   chlorophenolic
 formulations--F032  (55  FR  50450).

       During  the  conduct   of  a   routine environmental property audit  at   an
 agricultural chemical dealer, four 55-gallon  leaking drums  of pentachlorophenol-
 formulated  pesticides were  found.   It  could  not be  determined  if the  pesticide
 was  "spent" or unused formulation.   Chemical  analyses  showed it  to  contain  the
 following  constituents:

       Pentachlorophenol                  3.5%
       Tetrachlorophenols                 0.2%
       Hexachlorobenzene                  50   ppm
       Polychlorodibenzoethers            100   ppm
            TCDDs                        ND
            TCDFs                        ND
            PCDDs                         5   ppb
            PCDFs                        20   ppb
            HxCDDs                       15   ppb
            HxCDFs                       30   ppb
            HpCDDs                       150   ppb
            HpCDFs                       320   ppb
            OCDD                        1000   ppb
            OCDF                        2000   ppb

      One-hundred  cubic yards  of  contaminated  soil  were  found   to contain
 approximately 0.5% PCP,  and concentrations of  dioxins and furans (CDDs  and CDFs)
were about  ten  percent  of those indicated  for  the  liquid  pesticide.   Because
discarded, unused formulations of pentachlorophenol (PCP) and tetrachlorophenols
 (T4CPs)  are considered  RCRA-listed  acutely  hazardous  F027 wastes,  these waste
pesticides must be treated according to the  RCRA Land Disposal Restriction Rule
 (40  CFR  268.41)  for  "F"  wastes,  which  requires  treatment  of the TCDDs,  TCDFs,
PCDDs, PCDFs, HxCDDs, and HxCDFs  to  < 1 ppb  for  each homolog  and  < 50  ppb, < 50
ppb, <100  ppb,  and < 10  ppb for 2,4,5-TCP,  2,4,6-TCP, 2,3,4,6-TCP,  and PCP,
respectively.  Two treatment methods currently  can  reduce  this waste to below
these limits—high temperature incineration and chemical  detoxification (Fuhr and
des Rosiers, 1988).  However, no firm in the United States has the  requisite RCRA
permits to perform this  service on a routine basis; besides,  the total  volume of
four drums of liquid pesticide and 100 cubic yards of  pesticide-contaminated soil
is too small to  justify  the high  cost  of incineration  (>  $1500 per drum for a
relatively simple, hazardous waste).

      There are options that have practical  merit  and have been recommended and
employed, and  these include:  (a)  on-site chemical detoxification under  RCRA, and
 (b) land application as a pesticide under FIFRA.
                                      11

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(a)   On-site chemical  detoxification of the liquid pesticide,

      The RCRA small  quantity generator rule (40 CFR 161/162)
      (U.S.  EPA,   1986)  can  be  employed   for  the  on-site
      treatment of <  1000  kg/month  (see  Table 7)  without
      having to obtain  a RCRA permit.  Potassium polyethylene
      glycolate (KPEG)  is  used to  detoxify  (i.e.,  remove
      chlorine) the  liquid  pesticide.   The  KPEG  agent  is
      produced by  reacting  polyethylene  glycol-400 (MW=400)
      with  potassium  hydroxide  (85% purity),  removal  of
      aqueous   waste,   and   dosing   at   2.5   times   the
      organochlorine content  of the  pesticide  formulation.
      The temperature of the stirred  reaction  is  maintained
      between 70-120° C for at  least 24 hours.   Byproducts
      produced are water soluble, biodegradable and have been
      shown not to  be toxic to aquatic  organisms (des Rosiers,
      1986)  (des   Rosiers,  1989)  (Taylor,  et  al..  1990).
      Composite analyses  of  POHCs and  CDDs   and   CDFs  are
      performed by a  qualified analytical laboratory prior to
      and after detoxification to assure compliance with RCRA
      rules.

      Regarding  the   100   cubic  yards  of  CDD-and   CDF-
      contaminated soil, OSWER policy requires cleanup to RCRA
      standards  if  the   2,3,7,8-TCDD  equivalency  (TCDDe)
      exceeds  1   ppb in  residential   areas or  20  ppb  in
      industrial  sites (desRosiers, 1988).  (Note  that this
      contaminated soil contains  15.7 ppb  TCDDe  calculated
      using toxicity equivalent factors  (TEFs)  per the 1989
      method) (Bellin and  Barnes,  1989).

(b)   Land application as  a pesticide.

      (This  option  has   been   previously  discussed  under
      Conceptual Approach  under  FIFRA.)
                                12

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                                   REFERENCES

 Bell in,  J.S.  and D.G.  Barnes  (1989).   Interim Measures for  Estimating  Risks
 Associated  with Exposures to Mixtures  of Chlorinated Dibenzo-p-Dioxins  and  -
 Dibenzofurans   (CDDs  and  CDFs)  and  1989  Update.    Risk  Assessment  Forum.
 EPA/625/3-89/016, March.

 Collison, G.H.  (1990).   Waste Without  a  Place — the  Pentachlorophenol  Problem:
 HMCRI, Superfund  '90, Washington,  DC,  November  26-28,  446-9.

 des Rosiers, P.E.  (1986). APEG Treatment  of Dioxin- and Furan-Contaminated Oil
 at  an  Inactive Wood Treating Site  in  Butte,  Montana.   Paper  presented  at  the
 Panel  on New  and Emerging  Technology, Annual  Meeting of  the American  Wood
 Preservers  Institute, Washington,  D.C.,  October 28.

 desRosiers, P.E.  (1988).   General  Approach Used by the Dioxin Disposal  Advisory
 Group  (DDAG)   Regarding  Pentachlorophenol  Waste  (also  PCBs).   OSWER  Dioxin
 Disposal Advisory Group,  November  15.

 desRosiers, P.E.  (1989).   Chemical Detoxification of Dioxin-Contaminated Wastes
 Using Potassium Polyethylene Glycolate.   Chemosphere.  18  (1-6),  343-353.

 Fuhr, H.S.  and  P.E.  des Rosiers (1988).   Methods of Degradation,  Destruction,
 Detoxification, and Disposal of Dioxins and Related  Compounds, in:   Pilot Study
 on  International  Information  Exchange  on  Dioxins  and  Related  Compounds.
 NATO/CCMS,  Report No. 174, August.

 Offutt, C.K. and J. O'Neill Knapp (1990).  The Challenge of Treating  Contaminated
 Superfund Soil.  HMCRI,  Superfund '90,  Washington, DC,  November 26-28,  700-711.

 Taylor, M.L.,  Wentz,  J.A., Dosani,  M.A.  Gallagher, W., and Greeber,  J.S.  (1990).
 Treating Chlorinated Wastes with the KPEG Process.  ORD-RREL,  EPA/600/S290/026,
 July.

 U.S. EPA  (1986).   Understanding  the Small  Quality  Generator Hazardous  Waste
 Rules:   A Handbook for Small Business.  OSWER,  EPA/530-SW-86-019,  September.

 U.S. EPA (1989a).  Obtaining a Soil  and Debris Treatability Variance  for  Remedial
Actions.  Superfund LDR Guide #6A.  OSWER  Directive: 9347.3-06FS,  July.

U.S. EPA (1989b).  Obtaining a Soil and Debris Treatability Variance for Removal
Actions.  Superfund LDF Guide #6B.  OSWER  Directive:   9347.3-07FS,  December.
                                      13

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Table 1.  Pesticide Active Ingredients That Appear on the RCRA
            "Acutely Hazardous Commercial Products" Lists (RCRA P List)
                                                            Hazardous
Pesticide Active Ingredients	Waste No.

Acrolein                                                    POOS
Aldicarb                                                    P070
Aldrin                                                      P004
Allyl alcohol                                               P005
Aluminum phosphide                                          POOS
4-Aminopyridine                                             POOS
Arsenic acid                                                P010
Arsenic pentoxide                                           P011
Arsenic trioxide                                            P012
Calcium cyanide                                             P021
Carbon disulfide                                            P022
p-Chloroaniline                                             P024
Cyanides (soluble cyanide salts)                            P030
Cyanogen                                                    P031
2-Cyclohexyl-4,6-dinitrophenol                              P034
Dieldrin                                                    P037
0,0-Diethyl S-[2-(ethylthio)ethyl]        „                 P039
  phosphorodithioate (disulfoton, DiSyston )
0,0-DiethylR0-pyrazinyl phosphorothioate                    P040
  (Zinophos )
Dimethoate                                                  P044
0,0-Dimethyl 0-p-nitrophenyl phosphorothioate               P071
  (Methyl parathion)
4,6-Dinitro-o-cresol and salts                              P047
4,6-Dinitro-2-cyclohexylphenol                              P034
2,4-Dinitrophenol                                           P048
Dinoseb                                                     P020
Endosulfan                                                  P050
Endothall                                                   P088
Edrin                                                       P051
Famphur                                                     P097
Fluoroacetamide                                             P057
Heptachlor                                                  P059
Hydrocyanic acid                                            P063
Hydrogen cyanide                                            P063
Methomyl                                                    P066
alpha-Naphthylthiourea (ANTU)                               P072
Nicotine and salts                                          P075
Octamethylpyrophosphoramide  (OMPA,                          P085
  Schradan)	
                                      14

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 Table  1.   Pesticide Active Ingredients That Appear on the RCRA
             "Acutely  Hazardous  Commercial  Products"   Lists   (RCRA  P List)
             (continued)
                                                             Hazardous
 Pesticide  Active  Ingredients	Waste No.

 Parathion                                                    P089
 Phenylmercuric  acetate  (PMA)                                 P092
 Phorate                                                      P094
 Potassium  cyanide                                            P098
 Propargyl  alcohol                                            P102
 Sodium azide                                                 P105
 Sodium cyanide                                               P106
 Sodium fluoroacetate                                         P058
 Strychnine and  salts                                         P108
 0,0,0,0-Tetraethyl dithiopyrophosphate                       P109
   (Sulfotepp)
 Tetraethyl pyrophosphate                                     Pill
 Thallium sulfate                                             P115
 Thiofanox                                                    P045
 Toxaphene                                                    P123
 Warfarin                                                     P001
 Zinc phosphide                                               P122
 Pentachlorophenol                                            F027
 2,3,4,6-Tetrachlorophenol                                    F027
 2,4,5-Trichlorophenol                                        F027
 2,4,6-Trichlorophenol                                        F027
 2,4,5-Trichlorophenoxyacetic acid  (2,4,5-T)                  F027
 2,4,5-Trichlorophenoxypropionic acid                         F027
   (Silvex)
 Chlorophenolic Formulations from Wood                        F032
  Preserving
Creosote Formulations from Wood Preserving                   F034
 Inorganic Preservatives Containing Arsenic                   F035
  or Chromium
                                      15

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 Table  2.   Pesticide  Active  Ingredients  Contained on the RCRA
             "Toxic Commercial  Products"  (RCRA U) List

                                                            Hazardous
 Pesticide  Active  Ingredients	  Waste No.

 Acetone                                                     U002
 Acrylonitrile                                               U009
 Amitrole                                                    U011
 Benzene                                                     U019
 Bis(2-ethylhexyl)phthalate                                  U028
 Cacodylic  acid                                              U136
 Carbon tetrachloride                                        U211
 Chloral (hydrate)                                           U034
 Chlordane, technical                                        U036
 Chlorobenzene                                               U037
 4-Chloro-m-cresol                                           U039
 Chloroform                                                  U044
 o-Chlorophenol                                              U048
 4-Chloro-o-toluidine hydrochloride                          U049
 Creosote                                                    U051
 Cresylic acid (cresols)                                     U052
 Cyclohexane                                                 U056
 Cyclohexanone                                               U057
 Decachlorooctahydro-1,3,4-metheno-                          U142
  2H,5H-cyclobuta[c,d]-pentalen-2-
  one (Kepone, chlordecone)
 l,2-Dibromo-3-chloropropane (DBCP)                          U066
 Dibutyl phthalate                                           U069
 S-2,3-(dichloroallyl  diisopropyl-                           U062
  thiocarbamate)  (diallate, Avadex)
 o-Dichlorobenzene                                           U070
 p-Dichlorobenzene                R                          U072
 Dichlorodifluoromethane (Freon 12 )                         U075
 3,5-Dichloro-N-(1,1-dimethyl-2-                             U192
  propynyl)benzamide (pronamide, Kerb)
 Dichloro diphenyl dichloroethane (ODD)                      U060
Dichloro diphenyl trichloroethane  (DDT)                     U061
Dichloroethyl ether                                         U025
 2,4-Dichlorophenoxyacetic, salts and                        U240
  esters (2,4-D)
 1,2-Dichloropropane                                         U083
 1,3-Dichloropropene (Telone)                                U084
Dimethyl  phthalate                                          U102
 Epichlorohydrin (l-chloro-2,3-epoxypropane)                 U041
 Ethyl acetate                                               U112
 Ethyl 4,4'-dichlorobenzilate (chlorobenzilate)               U038
 Ethylene dibromide (EDB)                                    U067
 Ethylene dichloride	            	           U077
                                      16

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Table 2.  Pesticide Active Ingredients Contained on the RCRA
          "Toxic Commercial Products" (RCRA U) List (continued)
Pesticide Active Ingredients
Hazardous
Waste No.
Ethylene oxide                                              U115
Formaldehyde                                                U122
Furfural                                                    U125
Hexachlorobenzene                                           U127
Hexachlorocyclopentadiene                                   U130
Hydrofluoric acid                                           U134
Isobutyl alcohol                                            U140
Lead acetate                                                U144
Lindane                                                     U129
Maleic hydrazide                                            U148
Mercury                                                     U151
Methyl alcohol (methanol)                                   U154
Methyl bromide                                              U029
Methyl chloride                                             U045
2,2'-Methylenebis (3,4,6-trichlorophenol)                   U132
  (hexachlorophene)
Methylene chloride                                          U080
Methyl ethyl ketone                                         U159
4-Methyl-2-pentanone (methyl isobutyl                       U161
  ketone)
Naphthalene                                                 U165
Nitrobenzene                                                U169
p-Nitrophenol                                               U170
Pentachloroethane                                           U184
Pentachloronitrobenzene (PCNB)                              U185
Phenol                                                      U188
Phosphorodithioic acid, 0,0-diethyl,                        U087
  methyl ester
Propylene dichloride                                        U083
Pyridine                                                    U196
Resorcinol                                                  U201
Safrole                                                     U203
Selenium disulfide                                          U205
1,2,4,5-Tetrachlorobenzene                                  U207
1,1,2,2-Tetrachloroethane                                   U209
Thiram                                                      U244
Toluene                                                     U220
1,1,1-Trichloroethane                                       U226
Trichloroethylene                   R                       U228
Trichloromonofluoromethane  (Freon 11 )                       U121
Xylene                                         	U239
                                      17

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Table 3.  Pesticide Inert Ingredients Contained on the RCRA
          "Toxic Commercial Products" (RCRA U) List
                                                            Hazardous
Pesticide Active Ingredients	Waste No.

Acetone                                                     U002
Acetonitrile                                                U003
Acetophenone                                                U004
Acrylic acid                                                U008
Aniline                                                     U012
Benzene                                                     U019
Chlorobenzene                                               U037
Chloroform                                                  U044
Cyclohexane                                                 U056
Cyclohexanone                    R                          U057
Dichlorodifluoromethane (Freon 12 )                          U075
Diethyl phthalate                                           U088
Dimethylamine                                               U092
Dimethyl phthalate                                          U102
1,4-Dioxane                                                 U108
Ethylene oxide                                              U115
Formaldehyde                                                U122
Formic acid                                                 U123
Isobutyl alcohol                                            U140
Maleic anhydride                                            U147
Methyl alcohol (methanol)                                   U154
Methyl ethyl ketone                                         U159
Methyl methacrylate                                         U162
Naphthalene                                                 U165
Saccharin and salts                                         U202
Thiourea                                                    U219
Toluene                                                     U220
1,1,1-Trichloroethane                                       U226
1,1,2-Trichloroethane               R                       U227
Trichloromonofluoromethane  (Freon 11 )                      U121
Vinyl chloride                                              U043
Xylene	         U239
                                       18

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    Table 4.   Predicted  Treatment Effectiveness  for  Contaminated  Soil  *
^^
""•"^^^
— technology
Treatability Grout*1*^
Non-Polar Halogenated
Aroma tics
(W01)
PCBs, Halogenated
Dioxins, Furans, and
Their Precursors
(W02)
Halogenated Phenols,
Cresols, Amines, Thiols,
and Other Polar
Aroma tics (W03)
Halogenated
Aliphatic Compounds
(W04)
Halogenated
Aliphatics, Ethers,
Esters, and Ketones
(W05)
Nitrated Conpoonds
(W06)
Heterocyclics and
Sample Non- Halogenated
Aromatics
(W07)
Polynuclear
Aromatics
(W08)
Other Polar
Non- Halogenated
Organic Compounds
(W09)
Non-Volatile
Metals
(W010)
Volatile
Metals
(W11)


Thermal
Destruction
•






• 3


•



•


•

•

•



•

O1

X1



Oechlor-
i nation
A



A



A

A



A1


o1

O2

o2



o2

Qi

Qi



Bioremed-
i at ion*
3
A



A



A

A2



A1


•

•

•



•

0 x1

0 x1


Low Temp
Thermal
Oesorption
• A


•V




A

•



O1


o1

•

o



A

O1

O1

Chemical
Extraction
& Soil
Washing
A



A



A

A



A1


A

A

3
A



A

A

A



Immobi 1 i -
zation*
A


i
A



A

A



A1


A1

A2

A



A

•

•

Demonstrated  Effectiveness
Potential  Effectiveness
No Expected Effectiveness (no
 expected  interference to process)
 No Expected  Effectiveness (potential
 adverse effects to environment  or  process)
 (Offut  and Knapp, 1990).
1  Data were not available for this treatability group.
  Conclusions are drawn from data for compounds with
  similar physical and chemical characteristics
1  High removal  efficiencies may be due to volatilization
  or soil washing
1  The predicted effectiveness may be different than the
  data  imply due to limitations in the test conditions
4  These technologies may have limited applicability to high
  levels of organics
                                               19

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Table 5.  Examples of Where RCRA-Listed Pesticides May Fit in
          Treatability Groups
Pesticide
Treatability Group
o-Dichlorobenzene
Halogenated Non-Polar Aromatic
Compounds (W01)
Silvex, 2,4,5-T
PCBs, Halogenated Dioxins, Furans
and their Precursors (W02)
                                                or
                                          Halogenated Phenols, Cresols,
                                          Amines, Thiols, and other Polar
                                          Aromatics (W03)
Pentachlorophenol
Halogenated Phenols, Cresols,
Amines, Thiols, and other Polar
Aromatics (W03)
l,2-Dibromo-3-ch!oro-
  propane (DBCP)
Halogenated Aliphatic Compounds
(W04)
Endosulfan
Halogenated Cyclic Aliphatics/
Ethers/Esters/Ketones (W05)
Toxaphene
Halogenated Cyclic Aliphatics/
Ethers/Esters/Ketones (W05)
Dinoseb
Nitrated Aromatic & Aliphatic
Compounds (W06)
Aniline
Heterocyclics and Simple Non-
Hal ogenated Aromatics (W07)
Naphthalene


Acrolein
Polynuclear Aromatics (W08)
Other Polar Organic Compounds (W09)
                                      20

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Table 6.  Alternate Treatability Variance Levels for Contaminated
          Soil and Debris.*
Structural
Functional
Group
Halogenated
Non- Polar Aromatics
Dioxins
PCBs
Herbicides
Halogenated
Phenols
Halogenated
Aliphatics
Halogenated
Cyclics
Nitrated
Aromatics
Heterccyclics &
Non-Halogenated Aromatics
Polynuclear
Aromatics
Other Polar Organics
Concentration
Range (ppm)a
0.05

0.00001
.01
0.002
0.5

0.5

0.5

2.5

0.5

0.5

0.5
- 10

- 0.05
- 10
-0.02
- 40

- 2

- 2

- 10

- 20

- 20

- 10
Threshold Percent
Concentration Reduction
(ppm)a Range
100

0.5
100
0.2
400

40

200

10,000

200

400

100
90

90
90
90
90

95

90

90.9

90

95

90
- 99.9

-99.9
- 99.9
-99.9
- 99

-99.9

- 99.9

- 99.99

- 99.9

- 99.9

-99.9
Structural
Functional
Group
Antimony
Arsenic
Barium
Chromium
Nickel
Selenium
Vanadium
Cadmium
Lead
Mercury
Concentration
Range
0.1 -
0.27 -
0.1 -
0.5 -
0.5 -
0.005
0.2 -
0.2 -
0.1 -
0.0002 -
(ppm)D
0.2
1
40
6
1

22
2
3
0.008
Threshold Percent
Concentration Reduction
(ppm)b
2
10
400
120
20
0.08
200
40
300
0.06
Range
90
90
90
95
95
90
90
95
99
90
- 99
-99.9
- 99
- 99.9
- 99.9
- 99
- 99
- 99.9
- 99.9
- 99
* If the constituent concentration of the untreated waste is less than the
  threshold concentration, use the concentration range; if it is more than
  the threshold concentration, use the percent reduction range.

a Total Waste Analysis

b TCLP Analysis
                                      21

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              Table 7.   Categories  of Hazardous  Waste  Generators
                               (40 CFR 161/162)
            KEY:  1 barrel =  about 200 kilograms of hazardous waste
                        which is about 55 gallons
 Generators  of No  More
    Than 100 kg/mo

    If you  generate no
more than 100 kilgrams
(about 220 pounds or
25 gallons) of
hazardous waste and no
more than 1 kg (about
2 pounds) of acutely
hazardous waste in any
calendar month, you
are a conditionally-
exempt small quantity
generator and the
federal hazardous
waste laws require you
to:
•   Identify all
    hazardous waste
    you generate.
•   Send this waste to
    a hazardous waste
    facility,  or a
    landfill  or other
    facility approved
    by the  state for
    industrial  or
    municipal  wastes.
•   Never accumulate
    more than 100  kg
    of hazardous waste
    on your property.
    (If you do, you
    become  subject to
    all the require-
    ments applicable
    to 100-1000 kg/mo
    generators ex-
    plained in this
    handbook.
    100-1000 kg/mo
      Generators

    If you generate
more than 100 and less
than 1000 kg (between
220 and 2,200 pounds
or about 25 to under
300 gallons) of
hazardous waste and no
more than 1 kg of
acutely hazardous
waste in any month,
you are a 100-1000
kg/mo generator and
the federal hazardous
waste laws require you
to:
•   Comply with the
    1986 rules  for
    managing hazardous
    waste,  including
    the accumulation,
    treatment,  storage
    and disposal  re-
    quirements  de-
    scribed in  this
    handbook.
    Generators of
  1000 kg/mo or more

    If you generate
1000 kg (about 2,200
pounds or 300 gallons)
or more of hazardous
waste, or more than 1
kg of acutely
hazardous waste in any
month, you are a
generator of 1000
kg/mo or more and the
federal hazardous
waste laws require you
to:
•   Comply with all
    applicable
    hazardous waste
    management rules.
                                      22

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                Research and Development Needs For Agrichemical
               Retail Dealership Site Assessment and Remediation

                                       by

                                 Chris Myrick
                Director  of Legislative  and  Regulatory Affairs
                  National Agrichemical Retailers Association
 INTRODUCTION

      Why is research and development needed for the assessment  and  remediation
 of agrichemical dealerships?

      Over the  last  few decades, many  agrichemical  dealers  have  slowly,  and  in
 most cases, inadvertently contaminated  the  soil  at  their dealerships with  many
 different  pesticide, fertilizer, and  solvent  products.   As  a  result  of  this
 contamination,  one  of the  most uncertain  and  ominous issues  now  facing the
 agrichemical industry is the cleanup of contaminated  soils  and water at  retail
 agridealer facilities.

      Currently, agridealers have very  limited  and  expensive  options available
 to them for the  cleanup of contaminated soil  and water.  For example,  if  the  soil
 at  a  dealership  contains  pesticide  waste   regulated  under  the   Resource
 Conservation and Recovery Act  (RCRA),  estimates indicate  that it could cost a
 dealer from three to  five million dollars to cleanup his facility. In addition,
 a  large  data gap  now exists  with  respect  to  the  remediation  of  chemically
 contaminated soils and water at  retail facilities that prohibits  regulators  from
 reviewing the viability of  new  and more cost effective procedures.

      It  is  the goal of  the  agrichemical  community to work in concert  with
 federal and state regulatory officials as well as private and  government  research
 scientists  to   develop  new  and acceptable site  assessment and  remediation
 technologies that dealers can  economically apply to  their operations.   Over the
 next few pages,  I would like to  review several areas  of research and development
 that  the  agrichemical   industry   deems   critical   to  addressing   the   site
 contamination problem.


 RESEARCH AND DEVELOPMENT IN SITE ASSESSMENT

Development of Preliminary Site Assessment  Procedures That Can Be Undertaken
bv a Retail Dealer

      Today, an environmental  consultant  hired by  a dealer   to  do  a   site
assessment must  report contamination,  if found,  to the  State authorities.  This
requirement is  currently prohibiting many dealers from moving forward with any
corrective action  because  of the fear of  bankruptcy  and  the high cost  of  a
consultant.
                                      23

-------
       It  is  the position  of  the National  Agrichemical  Retailers Association
 (NARA) that the development of visual as well as preliminary  sampling procedures
 that can be carried out by  retail dealers will help the industry move forward in
 discovering and correcting contaminated sites.

       Specific Research Needs:

       •     Development of guidelines that can be used in a historical records
            check of a facility.  These  guidelines would help pinpoint specific
            practices  or  evidence  that  would indicate  high  probability of
            contamination.

       •     Development  of guidelines  for  visual  site  assessment procedures
            based on vegetative state, soil decolorization,  proximity to wells
            and ditches, etc.

       •     Development of preliminary sampling procedures that can be carried
            out by a retail dealer.

Development of Sampling Technology That Is Centered on the Unique
Characteristics of Agrichemical  Facilities

       Sampling  soils  and  water  that may  be  contaminated with  pesticides,
fertilizers and solvents is a very complex task.  Even though there  is a minimal
amount of research going on in this area at this time, much more research must
be carried out in order  to gain  a  better  understanding of how to sample soils
with  a mixture  or  high  concentration of  wastes.    Not  only will  sampling
technologies have to concentrate  on waste  mixtures, they will also have to take
into consideration soil type,  hydrogeology and potential  for constituent(s) to
leach.

      Specific Research Needs:

       •     Research  aimed at  establishing  the  validity  of a  variety  of
            different   extraction   procedures  and   their   relationship   to
            constituent leaching potential.

      •     Research aimed at  developing low cost procedures that are workable
            on  soil  containing  a  mixture   of  constituents.    This  sampling
            technology  could  accurately  assess  soils containing  mixtures of
            Carbamates, Chlorinated Hydrocarbons,  Triazines, Organophosphates,
            Organic  Nitrogen  Pesticides,   Chlorophenoxy   Acids,   and  other
            pesticide and fertilizer constituents.

       •     Development  of  standardized  analytical  procedure  which  would
            stimulate leaching or  predict the  degree of  downward  migration of
            agrichemical   contaminates    by   actually   testing   soils   from
            contaminated sites.   This  may  be  generically comparable to the E.P.
            Toxicity or TCLP procedure.
                                      24

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Development of Remediation Trigger Levels  Based on Risk Assessment

       It  has  been  discovered  through  site  assessment  activities  already
undertaken    that    individual    agrichemical   facilities   possess   unique
characteristics.   These  unique  characteristics in many cases may require that
regulators establish trigger levels on  a facility by facility basis.

       In the  establishment of these individual trigger levels, regulators must
now  set them conservatively  because  of  the  limited  amount  of  information
regarding the risk that  single or multiple waste mixtures present in different
soil and hydrogeologic situations.

       The  development  of  remediation  trigger level  standards  is  of utmost
importance to the entire agrichemical industry cleanup initiative.

       Specific research  needs:

       •     Development  of risk assessment model which would accurately assess
            different constituents based on actual sampling, predicted  leaching
            potential,  and individual facility characteristics.

       •     Development  of   remediation   trigger   levels  based   on  model
            predictions.   These predictions  would  be based on  health hazard
            constituent(s)  present and  potential to leach into ground water at
            each individual location.

Development of Micro-Economic Cost Analysis Formula That Can Be Used on a
Site-Bv-$ite Basis

      The cost of site  assessment activities are of great importance to the end
goal of cleaning  up contaminated sites.  Agrichemical dealers typically operate
on a small margin which leaves little funding for site assessment and remediation
cost.

      The development of micro-economic cost analysis formula that may be used
by agrichemical  dealers, consultants, and regulators would be of great benefit
in determining whether  a  particular  facility  is  financially  capable  of  the
cleanup recommended.  This  formula would also be very helpful when cleanup costs
must be spread over a prolonged period of time.

      Specific research needs:

      •     Development  of site assessment  cost  data  base  which  takes  into
            consideration  multiple  site  assessment  technologies  based  on
            individual  site characteristics.

      •     Development  of  linear  programming  model  which  considers  basic
            facility characteristics  and  gives  lowest  cost site  assessment
            procedure based on those characteristics.

      •     Development of  financial data base which will  be used to give lowest
            cost  site assessment technology  and  individual  facility financial
            capability.
                                      25

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RESEARCH AND DEVELOPMENT IN SITE REMEDIATION

Development of Soil Cleanup Levels

      The discovery  of soil  and water  cleanup  levels that mitigate  risk are
important to the cleanup objectives of the agrichemical industry and regulators.
Even  though  water  cleanup   levels   are  already  specified  through  Maximum
Contaminate Levels and Health  Advisories in  many cases, cleanup levels for soil
are much more ambiguous.

      Some basic research is already being conducted regarding the establishment
of soil cleanup levels based on contaminate concentration,  leaching potential,
soil characteristics  and  hydrogeology.    However, much  more research  must  be
conducted in order to gain a more  accurate  picture of the  risk that different
mixtures and concentrations of contaminants present  under various conditions.

      Specific Research Needs:

      •     Development of  attainable  soil cleanup levels  (thresholds) that take
            into consideration  individual constituents and constituent mixtures.
            These  cleanup levels must meet risk/benefit analysis criteria that
            take  into consideration the facility's ability to finance cleanup as
            well  as the actual hazard that the waste  present.


Development of Low Cost Remediation Technology

      According to a  review of literature on remediation technology, not much is
known about  the workability of  current  technology as it relates to agrichemicals.
From preliminary  cost estimates of technology currently being  used however,  it
is evident that new in-situ low cost technologies  must be developed in order for
the agrichemical  industry to cleanup contaminated sites and remain economically
viable.

      Because of  the  wide  variety of chemical constituent mixtures  currently
present  in  dealership soils,  researchers  must  take  into consideration  the
regulatory  implications  of technological  innovations.    For  example,  waste
regulated under RCRA cannot be treated in the same manner as waste that is not
regulated under RCRA or special state  laws.  Research must  be directed at finding
low  cost  remediation  technology  that  can  be carried  out by  the dealer  or
consultant.

      Specific Research Needs:

      •     Development of onsite remediation technologies  that can be carried
            out by the agridealer  under  regulatory agency  supervision.   These
            remediation technologies  must  be proven  capable of  attaining the
            cleanup objectives  of  regulatory agencies while remaining  low  in
            cost.

      •     Development of a remediation  technology  data base  that takes into
            consideration laws governing remediation  activities.
                                      26

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Development of Micro-Economic Cost Analysis That Can be Used on a
Site-bv-Site Basis

      As was the case for site assessment, the development of a Micro Economic
cost analysis formula for the  remediation of  agrichemical  facilities would be
very  helpful  in  projecting  the  short-   and  long-term  cost  of  remediation
activities.

      Understanding remediation cost and weighing different remediation methods
based on cost would  be  extremely helpful   in  insuring  the continued financial
security of the  entire agrichemical industry.

      Specific Research Needs:

      •      Development  of  a  remediation  cost  data  base  which  includes
            remediation cost information on contaminating constituents, leaching
            potential, soil  and water cleanup objectives,  and technology used.

      •      Development  of  linear  programming  model  which  can  be used  by
            individual dealers,  regulatory officials, lending institutions, and
            insurance companies  in  determining the financial capability  of a
            facility to successfully carry out remediation activities.
                                      27

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    An Evaporation /Degradation System for Pesticide Equipment Rinse Water

                                      by

                               Steven  E.  Dwinell
                           Environmental Specialist
                      Pesticides and Data Review Section
                Florida Department of Environmental Regulation
INTRODUCTION

      In the  1985-86 a system  for the evaporation/degradation  was developed
jointly by our Department and the University of Florida Agricultural Engineering
Department  to provide  a  viable option  for  the  disposal  of  rinsewater from
pesticide  application equipment.   This system  was  based on work  done  in the
1970's  by   Charles  Hall and  others  at  Iowa State  University on  pesticide
degradation pits.  This  system does not use new technology but  is an attempt to
apply  a  workable  technology  in an  environmentally  acceptable  manner  in  an
economical  way.  It has almost been successful.

      The system itself is quite simple.   It  consists of an above-ground tank
(or, if the tank is below grade, a double tank), a covered wash down slab, and
a system of transferring rinsewater containing pesticide  residues from the slab
to the tank.   The  tank  contains  a  soil  or gravel  matrix  and is covered with a
clear fiberglass or glass roof.  The pesticide  rinsewater is adsorbed by the soil
matrix,  the  liquid  portion   evaporated  by  sunlight,  and  pesticides   in  the
rinsewater degraded by microorganisms  in the matrix.   There is no discharge from
the system.   A secondary containment  system is used to protect against leaks.
Attached are several  figures and tables that describe the  system.  These figures
are taken from the Institute of Food and Agricultural Sciences Bulletin 242.


      The basic components of the system in Florida are:

            Above-ground or double walled tank.
            Clear roof over tank.
            Covered wash down slab.
            Transfer system for water from slab to tank
            with option for storage capacity.


      The keys to successful  operation in Florida  are:

            Optimized evaporation.
            Containment of rinsewater discharged into system.
            Protection of evaporation/degradation tank from rainfall.
                                      28

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These are achieved by:

            Evaporation
            Maximizing surface area of tank  and  sizing tank for different parts
            of the state.  The size of the surface area of the tank is decided
            based on the amount of water to be discharged to it.  Tables 1 and
            2  of  Bulletin  242  provide  the  figures  for  calculating  the
            appropriate surface area.

            Using a clear roof.  Clear fiberglass, glass, or other green house
            roof materials can be used.

            Using a rinsewater distribution  system  that  avoids  film formation
            that could impede evaporation.  This  distribution  system consists of
            a vertical pipe that conducts the rinsewater through the media to
            the bottom gravel  layer of the tank.  The rinsewater then moves up
            vertically through the media. (See Figure 2 from Bulletin 242).

            Requiring setback from structures to aid airflow.
            The evaporation/degradation tanks are required to  be  built a minimum
            of  seventy-five   (75)   feet  from   other   structures   to   avoid
            obstructions to air flow.

            Containment

            Above-ground tank for leak inspection.  The tank must be a minimum
            of eight inches off the ground  to allow  for  inspection  for leaks.
            If the tank must be below grade, a double tank must be used with an
            automatic leak alarm and pump system.

            Lined pad and sump.   Both the wash down  pad and the  sump are lined
            to prevent leaks  to underlying soil.  The sump must  also be pumped
            dry at the end of each day of operation.

            Secondary containment. A  berm  is required around the  evaporation
            /degradation tank to provide for  secondary containment  should the
            tank fail.  The bermed area is also covered  by a roof and is lined.

            Alarm system.  An alarm system and pump cutoff switch is required to
            prevent overfilling the tank  when pumping water from the wash down
            slab to the tank.

            Rainfall  protection

            Fixed roof over tank and  secondary containment.  A roof covers both
            the tank and the bermed area to prevent rain from filling this area.

            Cover over slab - fixed or moveable.  A low profile moveable cover -
            such as a swimming pool  cover  -  can be  used to  prevent  rain from
            getting onto slab,  but  a fixed  roof  is preferred.
                                      29

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            Roof  design  - 30  degree  overhang.  The  roof  must have  a minimum
            thirty degree  overhang  measured from the  edge  of the pad  or the
            berm, in  order to  prevent rain from blowing  into  theses areas in
            significant quantities.  (See Figure 1 of Bulletin 242.)

      Two questions that were addressed early on in the process of development
of this system were  air emissions  and  the rate of degradation of the pesticides
added to the system.  The question of air emissions was resolved based on data
developed in  the  Iowa State studies  that  showed only very  low  detections of
pesticides downwind  from  the degradation  pit.  Also,  it was decided that air
emissions from the degradation tank would have to be much less  than air emissions
from an  application  site, since  the  concentration  of the  pesticide solution
discharged to the tank was two  orders  of magnitude less than the concentrations
used in applications.

      It was  also  decided that the  degradation rate of the pesticides placed into
the system was not important, since there was no  discharge  from the system, and,
therefore, even slow rates were not a concern.

IMPLEMENTATION

      The goal of implementation was to make this system economically feasible
by minimizing permit and regulatory costs.   In order to do this, it was important
to: avoid high costs for permits, a requirement for a  professional engineer seal,
and high costs for compliance with applicable regulations.
This was accomplished by:

      •     Obtaining an exemption from the RCRA facility  permit initially

      •     Developing a general permit that

            - did not require engineer seal
            - did not require record keeping
            - did not require monitoring

      •     General  permit did specify:
            - certain components
            - operation
            - closure requirements

      Deviations from the components and specifications in the general  permit not
allowed.

      A publication,  Institute  of  Food and Agricultural  Sciences (IFAS) Bulletin
242, was  developed  which  described  construction  and operation  in  terms that
average farmer could understand and use.

      The state  regulation allowing  the construction  and operation of these
systems, DER Rule Chapter  17-28.822 was adopted in June 1988.  The designation
of this rule  was  changed in 1989 to Chapter 17-660.802,  but language of the rule
was not changed.

      Currently there are three systems permitted under this  rule - one each in
1988, 89, 90. Two of them  are at  research farms, one is at a golf course.


                                      30

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 Experience

      The systems  have proven to be more expensive than  originally  estimated,
 with costs of about thirty to fifty  thousand dollars per system.  They have also
 been  capable of  handling more  water than  estimated,  about  double what was
 estimated.  The  pesticide users  have  found  the systems to  be very  useful and
 helpful in their operations,  and  other applicators are interested in using  these
 systems,

 Regulatory Problems

      In late 1989 we  became  aware  that  a new  interpretation  of  RCRA exemption
 for waste water treatment units had  been made.  This  new  interpretation requires
 that treatment systems must have  either a RCRA  permit or Clean Water Act  (  known
 as a National Pollution Discharge Elimination System - NPDES) permit.   Since the
 NPDES permits  apply  only to  facilities  that discharge,  these systems can not
 obtain an NPDES permit.  The  Farmer's Exemption under RCRA also may not apply to
 these systems.

 Current options for maintaining  the economic feasibility  of these  systems  are:

      •      Pursue RD&D  permit through Technology Innovation  Program

      •      Petition EPA  for  regulatory  relief

      •      Petition Congress  for exemption


 CONCLUSION

      The evaporation/degradation system is  a  promising technology  and a good
 option for pesticide waste management that is being hampered primarily by current
 regulations and their interpretation, not because of environmental shortcomings.
This  is  a  system  that  can  be  utilized  now,  without  years  of  research and
development, but  that  will require  innovative regulatory action  to become  a
useful option for pesticide users.
                                      31

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            Pesticide Disposal Using a Demulsification, Sorption,
          Filtration  and  Chemical  and  Biological  Degradation  Strategy

                                      By

                   D.  E.  Mull ins,  Department  of  Entomology
             R.  W.  Young,  Department of  Biochemistry  and  Nutrition
             G. H. Hetzel, Department of Agricultural Engineering
       D. F. Berry, Department of Crop and Soil,  Environmental Sciences

              Virginia  Polytechnic  Institute  and  State  University
                             Blacksburg,  Va.  24061


ABSTRACT

      Research  concerning disposal  of  pesticide-laden   solutions,  including
emulsions  or  particulate  suspensions  (wettable powders  and  flowables),  has
focused  on  concentration  and/or  containment  methods  using  biodegradable
lignocellulosic sorbents.  Contaminated sorbents are used as a matrix on which
the pesticides are degraded in a composting environment.   In laboratory studies,
significant amounts of  selected  pesticides  were removed from solutions (ranging
in  concentrations   from  1,250  to  20,000   mg/kg)  by  a   combination   of
demulsification,   sorption  and  filtration in the  presence  of lignocellulosic
materials.   In  other  studies,   high  concentrations  of diazinon  and  other
pesticides were degraded   rapidly in a nutrient-enriched lignocellulosic medium.
 Based  on  our  research,   a  pesticide disposal  system  is  currently  under
development that should  prove to  be practical,  effective, safe and relatively
inexpensive.   It is  envisioned  that  this pesticide disposal method  will  be
useful in a variety of agrichemical situations.


INTRODUCTION

      It is important that pesticide waste disposal  methods be developed because
inappropriate handling  may result  in soil contamination at mixing and pesticide
handling sites.  Failure  to properly handle pesticides at  these  sites can result
in groundwater contamination (Myrik, 1990; Norwood,  1990).  Minimization of waste
by rinsate recycling  and  spraying on treatable areas under  many  circumstances is
a reasonable and effective means for rinsate disposal.  However, there is still
a need for practical, inexpensive, and effective methods for disposing of small
volumes of  concentrated  and  dilute pesticide wastes.  A  variety of potential
technologies suitable for pesticide  waste  disposal have been  examined, but few,
if any, satisfactory  methods  are available  to  pesticide users.  (Bridges, 1988;
Norwood,  1990).   It  has  been difficult to  develop  a  general  disposal  method
because many of the pesticidal materials that  are  available have unique chemical
and formulated characteristics.  As a result, development of "universal" disposal
techniques  is problematic.

      According to Ware (1989),  there  are currently about  200 active pesticidal
ingredients formulated  in an estimated  37,000 formulations, and 75% of pesticides
used are  liquid  sprays.   Emulsifiable  concentrates,  wettable powders,  soluble
liquids, and suspension concentrates represent the most  common  formulations used
in  liquid  sprays  (Ware, 1989;  Seaman, 1990).    Among   these,  emulsifiable
concentrates, wettable  powders and soluble liquids are the most commonly used but

                                      32

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 suspension concentrates, capsule emulsions, water-dispersible granules, emulsions
 in  water and suspoemulsions may  increase  in  usage  at the expense of the  more
 traditional   formulations   (Seaman,   1990).     Future  trends   in  formulation
 development  and availability  will  be  significantly  influenced by  regulatory
 pressures resulting from reassessment of inert ingredients used in  formulations
 (Seaman, 1990; Thomas, 1990).   Because of this, it would appear that development
 of pesticide waste disposal  strategies must take into account current  and future
 trends in pesticide formulation chemistry.  The pesticide waste disposal strategy
 described  here  is  designed to  remove  pesticides  from a variety of  aqueous
 formulations  and dispose of them  using  chemical and biological  degradation.


 DISPOSAL STRATEGY

      We have proposed a conceptual/functional model  for pesticide  wastewater
 disposal (Hetzel, et  al., 1989).  A modified  version  is presented  in  Figure  1.
 The  disposal  process  is divided  into  a  sorption  and a  disposal  phase.  The
 sorption  phase  includes addition of demulsification agents and lignocellulosic
 materials  (peat  moss,   wood   products).   During  this   phase, solubilized
 pesticides  are  removed  from  the rinsate  solution  and concentrated onto the
 organic sorbents.  We have found that addition of demulsifying  agents  facilitate
 the sorption process when treating various  emulsifiable concentrate formulations
 (Judge  et  al., 1990). The disposal phase involves physical  separation of the
 pesticide-laden  sorbents  and  suspended   pesticide  particulates (derived  from
 wettable powders, flowables, etc.) from the aqueous phase.  The aqueous phase may
 then be recycled or discarded.  The solid phase containing pesticides sorbed  onto
 the  lignocellulosic  matrices  and/or  particulates  removed   from  pesticidal
 particulates are then placed into  a  composting environment where the  pesticides
 are chemically and biologically  degraded.  Lignocellulosic materials have  been
 selected for use in disposal processes because they  are  relatively  inexpensive,
 have  been  found to  be highly  sorbent,  and  may  serve  to support or  enhance
 biodegradation  activities.  We have selected  three such  materials for  study.
 Peat moss is a highly  sorbent material which is readily available and  relatively
 inexpensive.  Because peat  does  not contain readily  degradable carbohydrates,
 addition  of  high  energy substrates  (corn meal)   is  added  to enhance solid
 substrate fermentation activities.  Ground pine bark  mulch is  included   in our
 studies  because  it  has  been  found  to  sorb some  pesticides   effectively.
 Steam-exploded  wood fibers  (Overend  and Chornet,  1987)  were  selected not  only
 because  of  their potential  as  effective  sorbents,  but also  because of their
 potential to support solid substrate fermentation with a reduced requirement of
 nutrient enrichment.

      The effectiveness of composting as a means for hazardous waste management
 has been recently reviewed  (Hart, 1991).  Composting  occurs  widely in  nature
 and as a process is  being employed to  dispose  of municipal sewage sludge  wastes
 (Hart, 1991; Parr,  et al.,  1978)  and its potential to  cleanup contaminated  soil
 sites is being examined (Williams and Myler,  1990).  The use of  composting  as a
means for degrading  pesticides  is  shown Figure 2.  It illustrates a  hypothetical
 situation where a pesticide contained in  a composting environment can be degraded
to relatively low levels.   The degradation may be  due to  direct metabolism or
cometabolism  of the  pesticide  by   the  various   composting  microorganism
populations.  With time, the compost cycles from high to lower  energy content,
and microbial population dynamics will change reflecting the nutritional changes
 in  substrate  availability.    In  situations  where  the  initial  pesticide
concentration is low,  or where a  pesticide is easily  degraded, one .feeding or

                                      33

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compost cycle may be sufficient to reduce the pesticide to low levels.  However,
under circumstances  where  the pesticide concentrations  may  be  high,  or under
circumstances where they are not easily degraded, additional  energy input may be
required.  Figure 2 includes three feeding cycles (nutrient addition) increasing
the energy  level  of the compost  at each  addition.   During  each cycle as the
temperature increases and then decl ines,  the metabol ic activities  of thermophil ic
and mesophilic  microbial populations will  also cycle.  The  strength  of solid
substrate fermentation as a method  of pesticide  disposal  is that it relies on a
consortia  of degrading microbes  and  not  just  one  species.    Under  these
conditions, rates of pesticide degradation are expected to be  enhanced  since the
combined activities  of  a diverse microbial  population  is expected  to be more
efficient.
EXPERIMENTATION

      Laboratory experiments have been  conducted  using approaches designed to
reflect what  is  envisioned  as  applicable to development  of a field prototype
disposal unit.  A variety of systems have been evaluated and  the system selected
for  our studies includes  mixing samples  containing  pesticide  solutions and
sorbents in an Erlenmeyer flask using a magnetic mixer or shaking table, followed
by settling and  filtration.  In our initial experiments,  pesticide-laden sorbent
material was filtered  sorbent material was filtered through Whatman filter paper
using a vacuum system.  Currently, we are using a filtration system consisting
of polyvinyl chloride  (PVC)  columns  [3/4 in  (dia)  x  12  in  (length)] fitted with
a PVC coupling containing a stainless steel  screen  (40 mesh) 15 grams of fine
sand and several  layers  of filter paper.   Samples were taken  at different stages
of the sorption process and analyzed. Solvents used in this study were pesticide
grade.

      The  general  pesticide  extraction  and analytical  procedures  used are
described by  Walls  (1981).   Analytical  standards were  obtained  from the U.S.
Environmental Protection Agency  Pesticide  and  Industrial  Chemicals Repository
MD-8,  Research   Triangle  Park,   NC.   Depending  upon  the  pesticide,  several
different solvents were  used as extractants (ie.  acetone, hexane,  etc.). We also
used sonication  as a means to improve extraction efficiencies.

      Following various  purification and  volume reduction procedures samples were
analyzed using gas-liquid chromatography.  Sorbents tested  include sphagnum peat
moss, steam-exploded yellow  poplar wood fibers (1. water and alkaline washed;
2. bleached), and pine bark  mulch. All lignocellulosic  materials were ground in
a  Wiley mill  using a 2 mm screen). Activated carbon (Calgon FiltrasorbR 200) was
used as the comparison sorbent material  (control).


RESULTS AND DISCUSSION

Sorption phase

      Table  1 summarizes  information obtained  when peat moss was  mixed with
various concentrations of Diazinon AG500 and Dursban 4E for  24 hours.  Removal
of diazinon from solution was effective at all concentrations tested, however,
removal of chlorpyrifos, was not effective at the higher (20,000 & 10,000 mg/kg)
concentrations   tested  (Hetzel,  et  al.,   1989).     Experiments  with   other
emulsifiable concentrate formulations using similar protocols, provided variable

                                      34

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removal rates.   During these preliminary  studies, we observed that emulsions
persisted after mixing the pesticidal emulsifiable concentrates  with peat moss.
Studies   using  a   fluorescent  probe,   emulsifiable  concentrate blanks and
emulsifiable  concentrate pesticide  formulations  (chlorpyrifos,  diazinon, and
malathion)  revealed  that  addition  of calcium  hydroxide  was  an  effective
demulsification agent.   We  have  found that the use of calcium hydroxide in the
presence  of  peat  moss  greatly  increased  the  rate of  removal   for  several
pesticide formulations from aqueous  suspensions  (Judge, et al., 1990).


Table 1.  Sorption of Diazinon  as Diazinon AG 500  and Chlorpyrifos as Dursban
          4E at Several Concentrations after Mixing with Peat Moss for 24 Hours


                              Pesticide  Remaining  in Solution1'2'3
                              (percent  of initial  concentration)


 Formulated
Concentration     20.000      10.000      5.000       2.500        1.250
Pesticide

Diazinon          1.4 ± 0.8    0.7 + 0.1  1.0 ± 0.7   6.0 ± 0.8   3.0 ± 0.6

Chlorpyrifos      45  ± 6     19.0 ± 11   5.3 ±5     2.4 ± 2.0   7.6 ± 4.6


1   Actual initial concentrations for diazinon averaged 92 ± 6% of the intended
   formal ation.
   10 grams  of sphagnum peat moss  were mixed in  200 ml  pesticide containing
   solution on a magnetic stirrer.
3   Percentage  of remaining concentration represented  as  the mean  ± standard
   error.
4   For details see Hetzel et al., 1989.
      Table  2  contains  information  which we  have  obtained using  a one-step
demulsification, sorption and filtration process on 10 pesticide  formulations and
four sorbents.   In a effort to represent what  might  occur  in the field, we have
used high  initial  pesticide concentrations (approximately  5000 mg/kg)  in our
laboratory experiments.  Data provided in Table 2 indicates that in most cases,
we were able to significantly reduce the amount of pesticide contained in test
solutions using the demulsification,  sorption, and filtration procedure.  It is
important to note that  under certain circumstances,  sorption  may only contribute
insignificantly to pesticide removal.  Some of  the pesticides  are quite unstable
in  alkaline  solutions  (ie.  captan,  folpet,  malathion, etc; Hartely and Kidd,
1987) and as a result may be degraded in the demulsification process.  Extraction
of the sorbent material  indicated that this was the case  for certain pesticides,
since little material was recovered from the  sorbents (data not shown).  Also,
large amounts of  the pesticides  formulated for use  as particulate suspensions
(wettable  powders and  flowables),  can be removed by filtration.  When filtered


                                      35

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residues containing the participate and sorbent phase  obtained from experiments
on  these formulation  types were extracted,  measurable  quantities  of residues
could  be detected  in  these extracts  (data not  shown).   Most of  the pesticides
tested are not very soluble in water,  and  as a result are  sorbed onto hydrophobic
sorbent sites if  they  are not physically  removed  (filtration)   or chemically
degraded  (alkaline hydrolysis).   Comparatively  large  amounts of  metolachlor
remained in solution  after  one   step  treatment (Table  2).  Since metolachlor
is  somewhat   soluble  in water and  not  significantly  transformed  by alkaline
treatment, additional  treatment will be required for effective wastewater cleanup
of  this  compound.     It  is possible  that  lignocellulosic  materials  could  be
modified in  such  a manner that  they might be  capable  of  binding  more  water
soluble materials  such  as  2,4-D, metolachlor  and alachlor.   We  are currently
investigating the possibility  of modifying  steam-exploded wood fibers  to improve
specific sorptive  properties  in a manner  similar to  that described by MacCarthy
and Djebbar (1986)  for  chemical modification of peat.


Table  2.  Removal  of  Pesticides  from  Aqueous Suspensions of Various Pesticide
           Formulations  Using  Demul si fi cation,  Sorption,  and Filtration
                                              % Pesticide remaining1'1'1
Compound/
Formulation
Atrazine (EC)
Azinphos-methyl (WP)
Captan (WP)
Carbofuran (F)
Chlorpyrifos (EC)
Diazinon (EC)
Folpet (WP)
Lindane (EC)
Malathion (EC)
Metolachlor (EC)
Wood
Fibers
1.0±0.6
0.0±0.0
O.OtO.O
0.5±0.4
2.4±0.8
1.5±1.3*
O.OtO.O
0.2±0.1
0.9±0.6*
9.9±2.8
Activated
Carbon
0.6±0.4
1.3±0.1
0.0±0.0
0.3±0.1
O.OtO.O
0.1±0.1*
O.OtO.O
O.OtO.O
O.QiO.O*
5.9±1.1
Pine
Bark
1.2±0.6
-
O.OtO.O
-
12±0.6
2.U2.2
O.OtO.O
-
O.OtO.O*
13.6±8.7*
Peat
Moss
1.2±0.2

O.OtO.O
4.9±1.1
S.ltl.O*
2. Oil. 4
0.7±0.0
0.1±0.1
O.OtO.O*
39.6±8.7
1  Initial formulated concentration of pesticide solutions was approximately 5000 mg/kg, the percentages were
  calculated as changes from initial concentration after treatment.  Means and standard errors are based on
  3 replicates. Quantitation limits were set at 1 mg/kg.
1  100 ml  of solution was mixed with 2.5 grams sorbent and 1 gram calcium hydroxide on a shaking table for 4
  hours (or 24 hours as indicated by an asterik).  The  solution was allowed to settle  (30 min) followed by
  filtration in PVC columns.
1  Formulations used were as follows: atrazine as AATREX"  (SOX ai), azinphos-methyl as Guthion" (35% ai), captan
  (49% ai), carbofuran as Furadan" (40.631), Chlorpyrifos as Oursban" (44.4X ai), diazinon (48% ai), folpet
  (SOX ai), lindane as Ortho" (20X ai), malathion as Dragon" (SOX  ai) and metolachlor as Dual" (68.4X ai).
  Emulsifiable concentrates (EC), flowable (F) and wettable powders (WP).
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      Since  applicators   may   choose  to  mix  and   apply   some  pesticides
simultaneously, as  in  some orchard  pest  control  operations, we  conducted an
experiment using an  insecticide  (azinphos-methyl)  and  a fungicide (captan) to
examine the efficacy of the system we are developing  to remove  high levels of
these two pesticides.  The  results of this experiment are shown in  Table 3.  The
effects of alkaline addition on the stability  of captan and azinphos-methyl are
quite striking.  When no calcium hydroxide was present  about  1000 mg/kg of both
pesticides remained in solution after filtration.   Treatment of the pesticide-
laden  solution with  calcium   hydroxide  essentially obliterates  both of the
pesticides (control with calcium hydroxide).  When  these pesticides are mixed
with the demulsifying agent in  the presence of sorbents, small amounts of captan
were detected in the  filtrate.  It is possible that  the  presence of the sorbents
influences the alkaline degradative process.   Sorbents  mixed  with  calcium
hydroxide seem  to  have lowered the amount of azinphos-methyl retained  in the
filtrate.  From these results   it appears that the use of calcium hydroxide has
utility  in  the one-step  process even  though both  of the  formulations  were
particulate suspensions.

      We envision that acceptable levels of pesticide removal should be in low
mg/1 (0  to 9 mg/1) range  and  lower  before the treated  rinsate can  be  safely
discarded.   Since  the system  which  we  have  been developing using  a one-step
process  can  reduce the levels  of  pesticide   to a  very low  percentage  of the
initial concentration, (Table  2) we  have begun to  experiment with  a two-step
process.  This  process includes a  first  step similar  to the one-step process
where  sorbent  and a  demulsifying  agent  are mixed  with the pesticide  waste
solution.  Instead  of filtering the  solution,  it is then cycled through a column
containing additional  sorbent material.   Table  4 includes data which   was
obtained from a experiment  using  a two-step demulsification/sorption process on
a solution containing emulsified chlorpyrifos. It can  be seen that significant
reduction  in  chlorpyrifos concentration  was achieved by first  demulsifying
(calcium hydroxide) and sorbing (steam-exploded wood)  (first  step), followed by
additional exposure  of the solution  to  one  of three  sorbents  tested (second
step).   Although activated  carbon did not remove as  much chlorpyrifos  as did two
types of steam-exploded wood,  the level was less than that found resulting from
a one-step (24 hours of mixing) treatment.

      We are in the process of applying the information which we have obtained
to field studies.   We have  constructed a prototype which  is designed to cleanup
30 to 40 gallons of pesticide-laden rinsate in a one-step  process.  Difficulties
have been encountered in developing a suitable filtration  system associated with
the apparatus.   We  have found that to achieve  good wastewater  cleanup when using
finely  ground   lignocellulosic sorbents,  removal   of  these particulates  by
filtration is  essential  because pesticides  sorbed to these particles  remain
suspended in solution  as a part of the particulate phase.   Filters have been
found to  be  too porous to achieve good  cleanup,  or they  become  clogged with
particulates,  resulting  in   unacceptably slow  filtration  rates.    Because
laboratory findings  suggest  that  a two-step process  is  more  effective in
wastewater cleanup,  we are redesigning the prototype  unit to field test this
hypothesis.
                                      37

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 Table  3.   Removal of Pesticides From a Two Component Pesticide  Mixture in  One
 	Step Using Demulslfication, Sorption.  and Filtration.	

 Treatment          	Captan	     	Azinphos-methvl	

                         mg/kg        %  of initial       mg/kq          % of  initial
                                      concentration                     concentration
Initial
Control ,
no Ca(OH)2
Control
Activated Carbon,
with Ca(OH)2
Peat Moss
Wood Fibers
7764 ± 1860
983 ± 717
0 ± 0
0.7 ± 1.2
0 ± 0
0.7 ± 1.2
100
13
0.00
0.00
0.00
0.00
8377 ± 976
1000 ± 576
46 ± 22
10 ± 17
12 ± 21
12 ± 21
100
11.9
0.5
0.12
0.14
0.14
   Azinophos-methal as Guthion* 35% VP and captan as a 49% WP in 100 ml were mixed with 2.5 grams sorbent and
   1 gram calcium hydroxide for 4 hours.   The solution was allowed to settle (30 min) and filtered using a PVC
   column.  Means and standard erros based on 3 replicates.
Table 4.   Removal  of Chlorpyrifos1 from Aqueous Solutions Using Two Steps:
	Demulslfication and  Sorption, and  Column  Sorption and  Filtration

Treatment                         Concentration             % of  initial
                                      (mg/kg)                concentration

Initial                           4866 ±  146                    100

4 hour mix,  no  filtration
     (first step)                 2841 ±  152                    56

24  hour mix  + filtration2
    (first  step  only)             116 ±   38                      2.4

Activated  carbon
(second step)
Wood fiber (second step)
Bleached wood fiber
(second step)
72 ±
7 ±
1 ±
2
2
0
1.5
0.13
0.013
   Chlorpyrifos as Oursban" 4E (44.4% ai) at approximately 5000 mg/kg  (1500ml) was mixed with 37.5 grams of
   steam-exploded wood fiber  and 15 grams calcium hydroxide for 4 hours.  After mixing,  100 ml was filtered
2  through 2.5 grams sorbent  contained in glass columns.  Means and standard errors based on 3 replicates.
   Data from a previous experiment (Table 2) using one step demulsification/sorption and filtration was included
   here for comparison.


                                            38

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 Disposal  Phase

       Studies on chemical and biological degradation of pesticides in bioreactors
 using solid substrate fermentation  have  been  conducted at several levels.   A
 benchtop  composting  system has been  employed to examine the rate  and  metabolic
 fate of chlordane and diazinon using radiolabeled materials  (Petruska,  et  al.
 1985).   Field studies using large  (6.7 cu  ft)  bioreactors have been  used  to
 demonstrate efficacy of  biodegradation  of diazinon,  chlorpyrifos,  metolachlor,
 atrazine, carbofuran and chlordane (Mull ins,  et al.,  1989; Hetzel, et al., 1989).
 Some compounds are degraded quite rapidly in bioreactors  containing  peat moss
 that is enriched with corn meal.  High levels of  Diazinon AG500 (7.4 liters;   at
 an  estimated 66,000 mg/kg) were not detectable one year after the  last addition
 of  diazinon  (Hetzel, et al., 1989).  Recent studies using ten gallon bioreactors
 to  examine  degradation of  carbofuran and atrazine  using  enrichment  microbial
 culture have provided some interesting results (Berry, et al., unpublished data)
 Carbofuran  sorbed onto peat  moss  (1771  ± 29 mg/kg)  and  mixed with  corn meal
 (10:1) was degraded to  7 ± 3 mg/kg (0.4% of the initial concentration) in days.
 One metabolite, carbofuran phenol  increased in concentration from 0 (initial)  to
 198 ± 108  mg/kg  (35  days)  to 0 (50   days)  indicating  that degradation  of
 carbofuran  metabolites may  continue  towards complete  mineralization.  Solid
 substrate fermentation of atrazine-laden lignocellulosic materials (1455 ±  11
 mg/kg)  in  10 gallon bioreactors resulted  in a  concentration reduction  to  117
 mg/kg  (8% of the initial concentration)  in  104  days.   The concentration of  a
 metabolite  hydroxyatrazine  reached  232  ±  82  mg/kg,  and decreased  to non-
 detectable levels at 104 days.  This also demonstrates the potential  obliteration
 of  pesticide metabolites  contained in  composting environments (Berry, et al.,
 unpublished  data).


 CONCLUSIONS  AND FUTURE NEEDS

      The   pesticide  wastewater   disposal   strategy  using   sorption  and
 biodegradation as a potential  method for pesticide applicators is  supported by
 the  information presented.  We have demonstrated that one-step demulsification,
 sorption and filtration provides effective removal of pesticides having  low water
 solubilities.  The pesticides tested  represented several types of pesticides and
 formulations.  Aqueous solutions containing two  pesticides  also were reduced to
 low  concentration  levels  by  the  one-step process.     An  experiment with
 chlorpyrifos using a two-step demulsification-sorption,  and sorption-filtration
 process indicates effective wastewater cleanup can be achieved in this manner.

      Comparison of  results obtained using  this method with  other reports  is
 encouraging.  Dennis and Kolbyinsky (1983) were able to remove  7 pesticides (100
mg/kg, totaling 700 mg/kg) contained in 400 gallons using 45 Ibs of Calgon  F-300R
 activated carbon  in  a Carbolator.   After  a  21  hour treatment, concentrations
ranged from  0.5 to 5.6 mg/kg.  Somich,  et al. found  that treatment  of  a mixture
of 4 pesticides (ranging from 17 to 82 mg/kg using ozone and biologically  active
soil columns, 1 to 20% of the  pesticides remained.   It should be noted that in
our experiments,  much higher  initial  concentrations (approximately 5000 mg/kQ)
have been  used resulting  in removal of significant quantities of the pesticides
from the aqueous phase.
                                      39

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      The  advantages  of the  system under  development  includes  its  relative
simplicity,  reliance  on low cost  materials,  safety,  and potential  for using
microbial enrichment cultures for other purposes.  It is likely that our batch
demulsification,  sorption  and  filtration  system  can  be  replaced by  column
demulsification, sorption  and filtration system that will be less cumbersome to
the operator.   The use  of lignocellulosic sorbents in  the system  show good
promise  because  of their low cost  and  potential  availability.   Peat  moss is
currently  quite  readily  available at  low cost  ($0.05/lb).    Steam-exploded
lignocellulosic materials represent a new source of sorbent materials that have
shown good potential in our experiments.  Virtually any lignocellulosic material
(wood products, crop residues, recycled  newsprint/paper) can be steam-exploded.
Cost estimates of bulk crude or unprocessed steam-exploded wood  are  in the range
of  ($0.07/lb)  which  would  make it competitive  with peat  moss.   Additional
processing  to  produce   specialized  sorbents  for  the  more   polar  (soluble)
pesticides would add  to  the cost,  but this  might  not prove  to  be prohibitive.
Calcium  hydroxide  was   selected  as  a demulsifying  agent   because  of  its
effectiveness, relatively inexpensive and available.  In fact, calcium hydroxide
is marketed as  burn lime, and sold as an agrichemical  at many agricultural supply
stores.   Cost estimates  for  the  pesticide  rinsate disposal  prototype under
development range between $600 to $900.

      A major advantage  of a sorption disposal process is that  once the rinsate
has been treated, the sorbed pesticide no longer represents a major contamination
threat,  should it  be  spilled.   It  can   be collected and moved  to a bioreactor
quite  easily.    It should  also be  pointed out  that  as  pesticide-degrading
enrichment cultures are  developed for a variety of pesticides, it  is likely that
these consortia could be used to degrade pesticides in  contaminated soil.   In
situ,   on   site  bioremediation  may  be   possible   by   amending  soils  with
lignocellulosic materials and pesticide-degrading microbes.

      Several questions  regarding the  rinsate solution  cleanup process need to
be answered. Acceptable  pesticide levels contained in treated rinsates destined
for release  in sewer  systems,  land application,  etc.  need to be established
before the system can  be approved and implemented.  If alkaline demulsification
is used,  it  will  be necessary to neutralize the  treated rinsate.   Laboratory
studies  have  indicated  that  small amounts  of  dilute solutions (0.2N)  of
hydrochloric acid  can neutralize the  treated rinsate.   Hydrochloric  acid (as
muratic acid) is commonly used to cleanup masonry and is relatively inexpensive
and available at most  hardware stores.  Another concern  is what  can  be done with
spent compost material when it  is removed from bioreactors?  It should be noted
that during the composting process,  the  volume of lignocellulosic material will
be reduced by as much as 20%.  Ideally,  if pesticides are effectively degraded
in the bioreactors,  there will be little  pesticide residue remaining in the spent
matrix.   If  this  is the  case, it would  appear  that  the  material  could be land
farmed or alternately, incinerated.  It  is also possible  that  spent compost could
be reused as a sorbent.   Studies  are planned to  evaluate these and other options
which might be available for final  disposal of this material.


ACKNOWLEDGEMENTS

      This work was supported in part, by the Southern Region Impact Assessment
Program, Virginia Agricultural Council, and the Virginia Center for Innovative
Technology  (Biobased Materials Center).  Appreciation is extended to Ms. Andrea
DeArment for the technical assistance  she  provided during major portions  of our
work.


                                      40

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REFERENCES

Bridges,  J.  S.   and  C.  R.  Dempsey,  Eds.  1988.    Pesticide  Waste Disposal
Technology.  Park  Ridge,   N. J. Noyes Data  Corporation.

Dennis, W. H. and E. A.  Kobylinski. 1983.   Pesticide-laden  Wastewater Treatment
for Small Waste Generators. J. Environ. Sci. & Health  18:317-331.

Hart,  S.  A.  1991.  Composting Potentials  for  Hazardous Waste Management.   In
Biological Processes, Innovative Hazardous  Waste Treatment  Series, Vol.  3,  F.  R.
Sfrerra,  Ed. Technomic  Publishing  Co. Lancaster, Pa.

Hartley,  D.  and H.  Kidd,  Eds.  1987.  The Agrichemicals Handbook. 2nd edition.
Royal  Soc. Chem., The University of Nottingham, England.


Hetzel, G. H., D.  E. Mull  ins,  R.  W. Young and J. M.  Simonds.  1989.   Disposal  of
Dilute and Concentrated Agricultural Pesticides Using Absorption and Chemical and
Microbial Degradation.  In: Pesticides  in Terrestrial  and Aquatic Environments.
Proc.  Nat. Res. Conf.  Richmond, Va.  D. L. Weighman,  Ed.  pp  239-248.

Judge, D. N., D.  E.  Mull ins, G.  H. Hetzel  and R.  W. Young.   1990.   Studies  On
Demulsification   and  Sorption  of Several  Pesticides  onto Lignocellulosic
Substrates   Using  Fluorometric  and  Gas  Chromatographic Techniques.    In:
Pesticides in the  Next Decade:  The Challenges Ahead. Proc. 3rd  Nat. Res.  Conf.
on Pesticides. Richmond,  Va.  D. L. Weighman, Ed. p 145-158.

MacCarthy, P. and K. E.  Djebbar.  1986.   Removal of Paraquat, Diquat  and Amitrol
From Aqueous Solution by Chemically Modified Peat.  J. Environ.  Qual.  15:103-107.

Mull ins,  D. E. R. W. Young, C.  P. Palmer, R.  L.  Hamilton and P. C. Sherertz.
1989.  Disposal of Concentrated Solutions of Diazinon  Using Organic Absorption
and Chemical and Microbial Degradation.  Pestic. Sci.  25:241-254.

Myrik, C. 1990.  AgriChemical Dealership Site Assessment and Remediation.   Proc.
Infer. Exchgn. Meet., Memphis,  TN.   Nat.  AgriChem. Retail.  Assn. Norwood,  V.  M.
1990.   A Literature Review  of  Waste  Treatment   Technologies  Which  May   Be
Applicable   to  Wastes  Generated   at  Fertilizer/Agrichemical  Dealer  Sites.
Tennessee Valley Authority Bulletin Y-214.

Overend,  R.  P.  and  E.  Chornet,  1987.   Fractionation  of  Lignocellulosics   by
Steam-aqueous Pretreatments.  Phil. Trans. R. Soc.  Lond. A. 321:523-536.

Petruska, J. A., D.  E. Mull ins, R. W. Young  and E. R. Collins. 1985.    A Benchtop
System for Evaluation of  Pesticide Disposal  by Composting.  Nuclear and  Chem.
Waste Manag. 5:177-182.

Parr, J. F., E. Epstein and G.  B. Willson. 1978.  Composting  Sewage  Sludge for
Land Application.   Agri.  Environm.   4:123-137.

Seaman, D.  1990.  Trends  in the Formulation of Pesticides—An  Overview. Pestic.
Sci. 29:437-449.
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Somich, C. J.,  M.  T.  Muldoon,  and P. C. Kearney.  1990.   On-site Treatment of
Pesticide Waste and Rinsate Using Ozone and Biologically Active Soil. Environ.
Sci Technol. 24:745-749.

Thomas, B. 1990.  Regulatory pressures on pesticide  formulations.  Pestic. Sci.
29:475-479.

Walls, R.  R.  1981.   Analytical Reference Standards  and  Supplemental Data for
Pesticides and Other Organic Compounds/ USEPA-600-12-81-001.

Ware, 6.  1989.  The Pesticide  Book.  Thomson  Publications,  Fresno, Ca. 3rd Ed.
340pp.

Williams,   R.  T.  and  C.  A. Myler,  1990.    Bioremediation  Using Composting.
BioCycle.  31:78-82.
                                      42

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LEGENDS FOR FIGURES
        Figure 1.  Conceptual/Functional Model  for Pesticide Wastewater Disposal
                  using Organic Sorption and Microbial  Degradation.

                  The process  involves two  phases:  a  sorption  phase,  and  a
                  disposal  phase.

                  The  sorbent   phase   involves  mixing  pesticide-laden  waste
                  solutions    (or    suspensions)    with   organic   sorbents
                  (lignocellulosic materials such  as peat moss,  processed wood
                  products, etc.).  During this  phase, pesticides are removed
                  from the  aqueous solution  by  demulsification  and  sorption
                  processes.

                  The disposal  phase begins with the separation  of the sorbed
                  pesticide from  the  treated aqueous  solution  by filtration.
                  The aqueous solution  may then be discarded and the pesticide-
                  laden sorbent added  to  bioreactors.    Microbial  populations
                  native  to the matrix will degrade the pesticide.
        Figure 2.  Pesticide  Biodegradation  Using  Nutrient   Enrichment   and
                  Microbial  Consortia.

                  A  hypothetical   representation  of   pesticide   microbial
                  degradation  in  a  situation  where  an  organic  matrix  and
                  nutrients are available  to microbial   populations.   As  the
                  bioreactor  cycles  from  higher  to  lower  energy  content,
                  microbial  populations will  also cycle  reflecting the changes
                  in   substrate  availability.     Pesticides  which  are   more
                  resilient  to  microbial   degradation   will   require  longer
                  reaction times.
                                      43

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                                    VASTE:
                                      Pesticide-laden
                                      Vaste Solution
                                  DEHULSIFICATION  &
                                  SORPTION:
                                    Lignocellulosic
                                    Matrices
                                       FILTRATION
                       DISCARD/RECYCLE:
                         Purified Solution
DISPOSAL:
 Pesticide Degradation
 Microbial Bioreactor
Figure 1.  Conceptual/Functional Node!  for Pesticide  Wastewater
   Disposal Using Organic Sorptlon and  Mircrobial Degradation
                                44

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 Nutrient
 Adcftion
   I
   c
   u
   B
   a
   n
   t>
   0.
Mcrobial
Coreortiim
Changw ?
                                                                       0.
                                                                       E
                                                                       e
5
0)
J
                                                                       0)
  Figure 2.   Pesticide Biodegradation Using Nutrient  Enrichment  and
                           Hicrobial  Consortia
                                   45

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              Landfarming and Biostimulation  for Decontaminating
                           Herbicide Wastes In Soil

                                      by

                         Kudjo Dzantor and A.S.Pel sot
       Center for Economic Entomology, Illinois Natural History Survey
              607 E. Peabody Drive, Champaign Illinois 61820 USA


ABSTRACT

      The utility of  landfarming for detoxifying pesticide waste  in  soil  was
examined at an  agrichemical  facility  in  Piatt  County,  111.   Soil  contaminated
with  the herbicides  alachlor,  atrazine,  metolachlor,   and  trifluralin  was
excavated, and  various amounts were  applied  to  an adjacent  field  divided into
corn and soybean plots.  Dissipation  of  residues  was monitored  for nearly two
years following  application  of the contaminated  soil.   Data  from soiltreated
subplots were compared to data from subplots in which herbicides  were freshly
sprayed.  Herbicides did  not  dissipate significantly  in excavated soil that had
been  stockpiled on the  ground.    After  two years,  alachlor and  metolachlor
concentrations in subplots with the highest application rate of contaminated soil
were significantly  greater  than  concentrations in the  corresponding  freshly-
sprayed subplots.  In  subplots with the lowest application rate of contaminated
soil, alachlor  and  metolachlor persistence did not  differ  significantly from
persistence in plots freshly-sprayed with recommended application  rates.

      In the  laboratory, soil amendment  with  2%  w/w  ground corn  or soybean
residues or sewage  sludge enhanced the degradation of 100 ppm alachlor compared
to the degradation in unamended controls.   Soil  amendment  with the crop residues
at the  rate  of  10% w/w  did not  significantly  increase  the rate  of  alachlor
degradation over that  observed at the 2%  level of  amendment, however 10% sewage
sludge significantly accelerated  alachlor degradation  when  compared to the 2%
amendment. Addition  of 1000 ppm inorganic N in the  form of NH4N03 significantly
inhibited alachlor degradation in both unamended and crop residueamended soils
compared to the degradation in soils without N or with 10 ppm N.

      In two soil types  alachlor disappeared  fastest in  water-saturated soils
that were left unamended  or amended with  2% w/w ground corn residue.  Under the
saturated conditions, alachlor was transformed  into  an unidentified nitrogen-
containing product that was not detected  under unsaturated conditions.

      Soil  inoculation    with an alachlor-cometabolizing  fungus   produced  a
transient and marginal increase in alachlor degradation rate over the degradation
rate in uninoculated soils.  Combinations of 2% w/w corn residue amendment and
fungal inoculation did not increase alachlor degradation over that caused by corn
amendment alone.
INTRODUCTION

      There is increasing recognition that soils at many agrichemical facilities
and farms have been contaminated with high concentrations of pesticides through
accidental  spills  or  improper rinsing and discharge  procedures  (Long, 1989).
High  concentrations  of  ordinarily  biodegradable  pesticides can  be extremely
persistent  in soil  partly because they inhibit  soil  bioactivity  (Wolfe et


                                      46

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 al.,1973,  Staiff et al.,1975,  Davidson et al.,1980, Winterlin et al.,1989, Felsot
 and Dzantor  1990a,  Dzantor  and  Felsot  1991).    High  concentrations  of  many
 pesticides are more mobile than low concentrations (Davidson et al.,1980).   The
 combination of prolonged persistence and greater mobility increases the risk of
 surface and  groundwater   contamination  by  high  pesticide concentrations  and
 emphasizes the need  for their expeditious cleanup.

        The usual methods of disposing of waste contaminated soils are excavation
 and subsequent landfill ing or incineration.  These  methods  are expensive  in
 economic and environmental terms, yet they do not always address the problem of
 contaminant detoxification.   As more contaminated sites are discovered, it  is
 becoming increasingly  important to seek cleanup technologies that are permanent
 and duly cognizant of the widespread nature of the  waste problem.  More permanent
 solutions  could  involve  decontamination  by landfarming (also  known  as  land
 application  or  land  treatment),  biological  treatment  (bioremediation),  or
 combinations thereof.

       Typical problems faced by agrichemical  facilities were demonstrated at the
 Galesville Chemical Co. (GCC)  in Piatt County, 111. (Felsot et  al.  1988).   Soil
 to  a depth of 1m along a railroad-right-of-way at the GCC facility had been found
 by  the Illinois EPA  (IEPA) to be contaminated with unacceptably  high levels  of
 herbicides (e.g. 24,000  ppm alachlor in the  top 10 cm, 100 ppm at a depth of 60
 cm).   The herbicides were discharged  to  this  area  as a waste stream arising  from
 the mixing,  loading,  and  cleaning  operations of GCC.  Pesticide residues  were
 detected in  the ditches lining the streets of Galesville  (population <500),  and
 trace  levels were detected in two  water wells.    IEPA  ordered excavation  and
 clean-up of the site.

       To avoid obtaining a special waste permit and hauling contaminated soil  to
 a municipal landfill,  the  Illinois Natural History Survey collaborated with  IEPA
 and the  management of GCC to landfarm the contaminated soil  in  corn  and soybean
 plots  on an adjacent farm.  The soils were excavated and  stored  on the ground  in
 piles,  which  were  sampled  to  determine residue levels and microbial  activity.
 After  application  of contaminated soil  to  soybean  and  corn  plots,  herbicide
 residues were monitored  in  the soil  for nearly  two years.   Along with  the
 landfarming  studies, laboratory experiments  were  performed to  identify  factors
 that  influence the  degradation of  alachlor,  the  prevalent  chemical  at  the
 contaminated  site, and  determine how they may  be  manipulated  to  maximize
 degradation  of the herbicide.  We  wish  to  present  our observations on  the
 dissipation of herbicides after landfarming of contaminated soils.  In laboratory
 studies,  we  also  show how degradation  of  alachlor  is  affected  by  nutrient
 amendment,  soil moisture content ,and microbial inoculation.


 METHODOLOGY

 Landfarminq Experiment

 Site Description--

       GCC drained waste water from loading and tank  rinsing operations onto a
 railroad right-of-way along the eastern edge of its property.  Soil  in this area,
which covered approximately 1,215 m2, was excavated and stored   on the ground at
 the site in four piles designated as "waste  pile  soil" 1-4.
                                      47

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      After excavation, the site was backfilled with soil  from an  adjacent fence
row that was at a higher elevation and  presumed not to be contaminated from the
waste-water discharges.  Waste-pile soil 2, which contained the  highest levels
of herbicides, was excavated from the top 60 cm of an area encompassing 122 m2
and was used in subsequent  land  application experiments.  Contaminants included
alachlor, atrazine, metolachlor, and trifluralin.

      During  the  spring of 1986,  a  four-acre  field adjacent  to the railroad
right-of-way  and to the  north of  the waste  piles was divided into two, 2-acre
fields for land application of waste-pile soil 2.   The field had been  planted to
corn in 1985  and chisel plowed  in the fall.  In 1986, the southern half of the
field was designated for corn production and the northern half was  designated for
soybeans.  The soil was a mixture of Ipava silt  loam and a Sable silty clay loam
with an  organic carbon  content of 3.1 percent  and  moisture  content  of 22.6
percent w/w at 0.3 bar.  Waste-pile  soil  had an  organic  carbon content of 5.6
percent and a moisture content  of 30.3 percent  w/w at 0.3 bar.

      The corn and soybean plots were further subdivided into three  replicated
blocks containing  six  subplots, (12.3m x 12.3m  or  40 ft x  40  ft),  that were
treated with contaminated soil or freshly sprayed  with herbicides  (see below for
details of the treatments). Each plot was surrounded by a 6.2m x  6.2m untreated
buffer zone.  Corn and soybeans were planted within one week of  soil and spray
applications.  Each plot contained 16 crop rows spaced 76 cm apart.

      After the crop was harvested in  1986,  the  plots were left untilled, and
benchmarks placed so that  plots could  be  re-established  in the  same positions
during the 1987 crop  year.   In May, the  field was treated with paraquat to burn
down perennial weeds.   On June 10,  1987,  the field was prepared by  chisel plowing
in a north-south direction,  parallel  to the old crop rows.   Untreated border
areas around  each  plot prevented soil  from one  subplot  from contaminating an
adjacent subplot.  Corn and soybeans were planted along the north-south direction
on the same day.  No further applications of soil or herbicides  were made.

Application of waste-contaminated soil--

      Persistence of  herbicides  in landfarmed, contaminated soil was compared to
persistence of herbicides  that  were freshly sprayed with amounts calculated to
yield concentrations in  soil similar to those  in waste-pile soil 2.  Rates of
application were determined on  the basis of the alachlor concentration since it
was the most prevalent  contaminant.  Treatments  were designated by the following
codes:

1.    CHECK:  untreated soil;
2.    Ix-N:   herbicide  spray  mixture  applied  in 1986  at the  rate normally
      recommended for alachlor,  3.36 kg active ingredient  [a.i]./ha; the mixture
      consisted  of  alachlor,   atrazine,   metolachlor,   and  trifluralin  in
      proportion to the concentrations found in waste-pile soil  2 in May, 1986
      (74,  48,  17,  and  3  mg  herbicide/kg oven-dry  soil  [ods],  respectively,
      Pel sot  et al. 1988);
3.    5x-N:   herbicide spray mixture applied in  1986 at  18.6 kg a.i./ha, five
      times the recommended alachlor rate;
4.    Ix-S:   contaminated  soil  from waste-pile  2  applied  at  the  equivalent
      alachlor rate of 3.36 kg  a.i./ha;
5.    2.5x-S:  waste-pile soil applied at the equivalent alachlor rate of 8.4 kg
      a.i./ha;
                                      48

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 6.     5x-S:  waste-pile soil  applied  at  the equivalent alachlor rate of 18.6 kg
       a.i./ha.

       Soil  was applied  with a manure spreader.  The spreader was filled by using
 a front loader that was  calibrated  by weighing the entire  loader with and without
 a full load of soil.  Within 24 hours  after application of contaminated soil and
 herbicide  sprays,  all plots were disked twice in two directions  to incorporate
 the pesticides and soil.   Buffer zones were  also disked, which  served to clean
 equipment  and minimize  cross-contamination  between treatment  plots.

 Soil  sampling,  preparation,  storage--

       Soils were collected from field  plots with a 5-cm diam. bucket auger during
 1987  and early 1988.   Two subsamples of soil from  depths 0-15 cm  and  15-30 cm
 were  collected from each replicated subplot.  The subsamples were combined in the
 field and returned to the laboratory on the same day.  The auger was washed with
 methanol between subsamples taken  by soil depth and between  different  subplots.
 Soils were  sieved  through a 3mm mesh  screen  and stored  at  2i C for up  to one
 month prior  to  extraction.    Herbicide  residues  remained  stable  under  these
 conditions  for at  least four  months (Felsot  et  al.  1988).

 Extraction  and Analysis--

       Fifty grams  of soil  were  slurried  with  20  ml of distilled  water  and
 extracted twice with 90 mL  of  ethyl acetate  as  described by Dzantor and  Felsot
 (1989) for  methyl  carbamate  insecticides.   All herbicides  were qualitatively
 analyzed by packed  column gas-liquid chromatography (GLC,  Packard Model  328) with
 nitrogen-phosphorus specific detection.  Residues were separated isothermally at
 190 fC on a 90 cm x 0.2  mm  i.d. glass column packed with 5% Apiezon  + 0.1% DEGS.
 Residues were quantified by the method of external standards, which  were used to
 calibrate the  GLC  response each  day of analysis.

 Biostimulation and Bioauqmentation Experiments

 Soil  Incubation--

      The soil  used in most  of the experiments was  collected  from untreated
 experimental plots at the Galesville  landfarming site.   Freshly collected  soil
 was air dried to  about  20% moisture  content, passed  through  a  2mm sieve,  and
 stored a 5iC  until  needed.   All  experiments  were performed  in triplicate  with
 30 g ods in 250 mL erlenmeyer  flasks.  An emulsifiable concentrate of  alachlor
 (Lasso, 4EC; 45.1% a.i)  was added as a  dilution  in water to give  100 mg  ai/kg in
 soil.   After  treatment,  soils in  individual  flasks were  brought to desired
 moisture tensions by additions of distilled water.  The flasks  were  covered  with
 parafilm and  the soils  were   incubated at  25iC  for specified periods of time.
 The soils were aerated  once a week.   At the start of each  experiment and  at
 specified  intervals during  the  incubation   period,  three  flasks from  each
 treatment were frozen (-10f C)  for chemical  assay.   Soil in three flasks  from
 each treatment were slurried with 15 mL of water and extracted  twice by stirring
with 90 mL  of  ethyl acetate.   Parent  alachlor was  determined by packed column
gas-liquid  chromatography as described above.
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Effect of nutrient amendments on alachlor degradation--

      To determine the effect of organic amendments on alachlor degradation, bulk
soil samples  were weighed into  large  plastic  bags and mixed  thoroughly with
either corn plant residue, soybean  plant  residue or municipal sewage  sludge at
the rate of 20  or lOOg/kg ods  (2 or 10%  w/w)  before distribution into flasks.
The amendments  had been ground  to  pass  a  2 mm sieve.  Soils  without organic
amendment served  as controls.

      To examine the  effect of inorganic nitrogen on  alachlor degradation, soils
were amended with NH4N03  to yield 10 or 1000 mg N/kg ods.  Soils without NH4N03
served as controls.   Combinations of the crop residue amendments and inorganic
N were also tested.

Effect of fungal  inoculation on alachlor degradation--

      To examine the  effect of microbial inoculum on  alachlor degradation, soils
were inoculated with  an  alachlor-cometabolizing Fusarium sp.  (Felsot and Dzantor
1990a).  The  inoculum  was grown in a peptone-yeast  extract-alachlor (lOOppm
alachlor) medium  on  a rotary shaker at  25i  C.   After three days,  growth was
harvested by centrifugation at 13,000 rpm  (25931  x g) for 10 mins.   The cells
were washed once and  resuspended  in  autoclave-sterilized phosphate  buffer
containing  lOOppm alachlor.   Washed cells  were stored at 2i  C  until  needed.
Soils were  inoculated within 24h of harvest  and within one  to  two hours after
addition of alachlor.


RESULTS AND DISCUSSION

Landfarming Study

      During the  planning of  the   landfarming experiment,  we developed four
criteria for successful  remediation  of the herbicide-contaminated  soils:   (1) no
significant difference  after one growing season between herbicide residues in
soil from waste-treated  plots and freshly sprayed plots; (2) no contamination of
shallow groundwater above  maximum contaminant  levels  (MCLs)  suggested by U.S.
EPA; (3)  no significant  residues in  grain;  (4) no significant toxicity to crops
as measured by  phytotoxicity  assays  in the field or greenhouse and by comparison
to yields from  the untreated check plots.  The extent to which criteria  2-4  were
met has been presented elsewhere (Felsot and Dzantor 1991),  so this discussion
will be limited to herbicide dissipation during landfarming.

Herbicide residues in soil--

      Soil  samples collected within a day after application  of waste-pile soil
and herbicide  sprays afforded  a comparison of the initial concentration  of
herbicides found  in all  experimental plots compared to the theoretical amounts
corresponding to  the  various rates  of  application.   On the  basis of a 3.36 kg
a.i./ha application  rate  (i.e..,  Ix treatment),  the soil  to a depth  of 15 cm
should have contained theoretically 1.71, 4.28, and 8.55 ppm of alachlor for a
Ix, 2.5x, and 5x application  rate,  respectively.  The percentage of theoretical
recovery ranged from 33.6% for the  5x-S soybean treatment  to 110% for the Ix-N
corn treatment.  Percentage of  theoretical  recovery  for all treatments combined
was 66.5+/-23.0%.


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       Another concern was the initial concentrations of herbicides in soiltreated
 plots compared  to  the corresponding  treatments  in  sprayed  plots.   With  the
 exception of the 5x-S  and 5x-N alachlor treatments  in the soybean  plots,  there
 were no significant differences in recovery of herbicides between  soil-applied
 and sprayed herbicide on day  0  in the top 15 cm of  the  profiles  (Fig.  1,  2).
 Nearly twice  as  much  alachlor was  recovered from the  5x-N treatment in  the
 soybean plot as from the  5x-S treatment.   This difference may reflect sampling
 error because  concentrations of alachlor recovered later from the 5x-S treatment
 were much higher than  the initial  recoveries (Fig.  1).

       During the first  140  days  of  sampling,  high variability precluded  the
 detection of significant differences between corresponding rates of application
 of fresh  herbicide and  contaminated soil.   By days 380  and 520,  however,
 significantly  more  alachlor  and metolachlor were recovered from 5x-S treatments
 than  from 5x-N treatments (Fig. 1,  2).  No statistically significant differences
 were  seen between Ix-N and Ix-S or 2.5x-S treatments, although the  latter  two
 were  often  numerically greater  than  the  Ix-N  treatment  (data  not  shown).
 Recovery  of the other  herbicides did  not  differ  significantly among  treatments
 on these  sampling days.  Residues  at  the 15-30  cm depth did not  differ  among
 treatments.

       The three-to-10  fold greater recoveries  of  alachlor and metolachlor from
 the  5x-S  treatment  than from the 5x-N  treatment  suggested that  the residues  in
 the  aged,  contaminated  soil  were less  available  to  microbial  degradation.   The
 residues  recovered  1.5 years  after  application were  more than half of what  would
 be expected after a  recommended application rate of 3.36 kg ai/ha. The prolonged
 persistence of alachlor and metolachlor in waste-pile soil  and  in the field  plots
 is not characteristic of the  comparatively rapid degradation of  these compounds
 when  used at normal  rates  of application.  Alachlor half-life generally ranges
 from  2-4  weeks  (Sharp  1988),  and it is less  persistent than metolachlor,  whose
 half-life is highly variable  (13-108 days) depending on moisture  and temperature
 conditions  (LeBaron et al. 1988).   On  the  other hand, several studies  have  shown
 that  high concentrations of  pesticides, which  are characteristic of  waste,  are
 unusually persistent (Davidson et  al.  1980,  Stojanovic 1972, Junk  et al.  1984,
 Schoen  and Winter!in 1987,  Wolfe  et   al.  1973).    In  our study,  alachlor  and
 metolachlor were still found  in waste-pile 2 at concentrations of 23  and 17ppm,
 respectively,  two years following  excavation.

      Two hypotheses were developed  to explain the  prolonged  persistence  of
 alachlor  and metolachlor in the waste-pile soils and in the field plots.  First,
 studies of high concentrations of  pesticides  in soil  have shown that microbial
 populations  can be  severely reduced,  which may be  the critical  factor for
 explaining  the prolonged  persistence of those  chemicals  (Stojanovich  1972,
 Davidson  et al. 1980, Dzantor and Felsot 1991).  We  therefore  hypothesized that
 the microbial  populations  in the waste-pile  soils were reduced as a  result  of
 exposure  to toxic concentrations of the herbicides.

      The  inhibition  of  microbial  populations,   however  does   not explain
 adequately the prolonged persistence of the  herbicides after mixing  waste-pile
 soil with uncontaminated soil  during land  application.  The herbicides in waste-
pile soil  could be considered to be  aged (Smith et al. 1988),  i.e., the chemicals
were in contact with the soil  for an extended  period  of time.  Aged residues have
been shown to be less desorbable (McCall  and Agin 1985, Steinberg et  al.  1988)
and in  some  cases  seem to degrade  more  slowly than freshly-applied  chemicals
 (Steinberg et al. 1988, Byast and Hance 1981).  Thus,  a second hypotheses, but

                                       51

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not  mutually exclusive  of the  first,  ascribes the  slow degradation  of the
herbicides to a lack of  pesticide bioavailability upon aging in the soil.

Biostimulation Study

      The  prolonged  persistence of alachlor after  contaminated  soil  had been
spread on  cropland suggested  that  landfarming  alone may  not be sufficient for
remediating  all   contaminated  soils  regardless  of contaminant  composition,
concentration, or age.   We  previously  reported that  amending  soils  in the
laboratory with 2% corn or soybean  residues  enhanced the degradation of  100 ppm
but not  1000 ppm  of  freshly applied alachlor  (Pelsot  and  Dzantor  1990a).  If
degradation of up to  100 ppm of herbicide  can be  thus accelerated in the field,
then biostimulation may  be the  strategy for detoxifying high concentrations of
contaminants  after they  have been  diluted  by  landfarming,  or  for detoxifying
moderately high concentrations of pesticides in situ. Successful application of
this strategy depends on  the understanding  of the soil environmental factors that
control  degradative  processes.   In  our  continuing efforts to  stimulate the
degradation  of alachlor  in soil, we have further investigated  the  effects of
types and levels  of nutrient amendments, soil moisture content, combinations of
moisture and nutrient amendments, and bioaugmentation with fungal inoculation.

Effect of nutrient amendments on alachlor degradation--

      Similar to  our previous  observations,  100  ppm of alachlor degraded more
rapidly in corn or soybean residue-amended  (2% w/w) soils than in unamended soil
(Fig. 3,4).  Soil  amendment with 10% of either type of crop residue produced only
marginal  increases in alachlor degradation over that  observed  with 2% amendment.
In a more recent  experiment we observed that alachlor degraded at similar rates
in soils that were amended  with either 2% corn residue or 2% municipal  sewage
sludge.  But unlike corn  residues,  soil amendment with 10% sewage sludge caused
a significant enhancement in alachlor degradation over that observed at the 2%
level of amendment (Fig.  5).  Within 28 days, <12% of the initial lOOppm dose of
alachlor was recovered in  soils amended with  10% sewage  sludge.   In contrast,
about 40% of the  initial  dose was  recovered in the  soils  amended with 2% corn
residue or sewage sludge; the unamended soil still  contained approximately 70%
of the added alachlor after  28 days.   Since  the  enhancement  of the  rate of
alachlor degradation did not appear to be  a  linear function of the  level  of
sewage sludge, we are  now  attempting  to  determine  the minimum  sewage  sludge
application rate  at which degradation is  optimized.

      In a preliminary experiment,  we observed that  addition of NH4N03 to soil
to give 1000 ppm  N appeared to inhibit the stimulatory effect that crop residue
amendment had on the degradation of  100 ppm alachlor (Felsot and Dzantor 1990 b).
Recoveries of the  herbicide in residue amended soils  that were also treated with
N were not significantly  different  from recoveries in unamended soils.  Because
we did  not determine  the effect  of  inorganic N on alachlor degradation  in
unamended soil in  preliminary experiments, a follow  up experiment was performed
to examine the effect of different levels of  inorganic N  with  or without crop
residue amendments on the degradation of 100 ppm alachlor.

      After 56 days,  alachlor recoveries were highest (>80% of initial dose) in
unamended  soils that  were also  treated with  1000  ppm N (Fig. 6);  the  lowest
recoveries of the herbicide  (4-5 %) were  from  crop  residue-amended  soils that
were treated with  0 or 10 ppm N.   The 1000 ppm N  addition reduced the stimulatory
effect of  organic residue amendment, as  we have had observed  in  preliminary

                                      52

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 studies,  but alachlor dissipation was  still  significantly faster than  in  all
 unamended  soils  (Fig.  6).   Other  researchers  have  shown  that  certain  forms  and
 levels of  inorganic N  inhibit degradation of some pesticides.   For example,  the
 degradation  of parathion  in  soil  was  inhibited by  100  ppm  N  in the form  of
 (NH4J2S04  but not as NH4N03 (Ferris and  Lichtenstein  1980).  However,  at 182  ppm
 N  equivalent,  NH4N03  also  significantly reduced  degradation of  parathion.   The
 inhibition of pesticide degradation by high  concentrations of  inorganic N may be
 quite  important.    Operations at  many  agrichemical  facilities  and  farms  may
 involve nitrogen fertilizers as well as pesticides;  it is quite likely that soils
 contaminated by  pesticides at some of these sites may also be  contaminated  by
 high levels  of N  fertilizers.

 Effect of  Soil Moisture  Tension on Degradation of  Alachlor--

      Figures  7   and  8  show the effects  of  soil moisture  content  on  the
 degradation  of 100 ppm  of alachlor   in  two soil  types  that  were either left
 amended or amended with  2% ground corn residue.  The  second soil  type,  coded  as
 soil 52, was collected from part of an  experimental  field at the Illinois Natural
 History Survey.   It is a Drummer-Catlin  mixture  with an organic  carbon content
 of 2.0%, and moisture content of 24.7% w/w at 0.3 bar.  Alachlor  degradation was
 investigated at  soil  moistures   ranging from wilting coefficient  (15  bar),
 corresponding to  11.6  and  12.1% w/w  for GCC soil  and soil 52,  respectively  to
 saturation (0 bar) or  100% w/w moisture  content  in both soil  types.

      Alachlor recovery  from both soil types decreased  as  soil moisture content
 increased  (decreasing  moisture tension) (Fig. 7); the combination of 2% corn
 residue amendment and  increasing moisture content stimulated further dissipation
 of parent  alachlor from both soils (Fig. 8).  Several workers  have demonstrated
 enhanced degradation of  chlorinated pesticides in  anaerobic soils  amended with
 organic materials.   For example,   degradation  of pentachlorophenol in flooded
 soils was  enhanced  by addition of anaerobic  sewage  sludge (Mikesell  and Boyd
 1988), and DDT degraded significantly  faster in anaerobic  soils  amended with  1%
w/w glucose (Parr et al  1970) or rice straw  (Mitra and Raghu 1986).  Also, gamma-
 hexachlorocyclohexane  degraded significantly faster in  flooded soils with green
manuring compared to unamended soils.(Drego et al.,1990).

      In this study alachlor also  dissipated rapidly  in unamended soil 52 under
 saturated  conditions (Fig. 7).  But the  rapid disappearance of parent alachlor
under saturated conditions  may be misleading because,  as we have observed in this
and other  unpublished experiments, the  loss  of  parent alachlor under  these
conditions  was  accompanied  by the  appearance  of  an  unidentified  nitrogen-
containing metabolite  that was not detected  under non-saturating conditions.
Effective  bioremediation would ideally require that  transformation products  be
removed as rapidly as  parent compounds.

Effect of  Fungal Inoculation on Alachlor Degradation--

      We have  previously reported that   inoculation  of soil with an alachlor-
cometabolizing fungus at the rate  of 0.015% w/w ods caused a transient marginal
increase in the rate of degradation of 100 ppm alachlor,  compared  to the  rate
of degradation in uninoculated controls  (Felsot and  Dzantor 1990a).  The small
and temporary nature of  the  increase  in degradation  caused us to question the
efficiency and competitiveness of  the  fungus once it  has been  reintroduced into
the soil.  In an  attempt to  answer this question,  we examined the effect of a
higher level of fungal  inoculation (0.045%)  on the degradation  of alachlor  in
soils that were left unamended or amended with 2%  corn  residue.


                                      53

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      Figure 9 shows that within 28 days in unamended soil, significantly more
alachlor was recovered from uninoculated treatments than from inoculated ones.
During  the  same  period,  soils inoculated  at  the  rate of  0.045%  w/w showed a
slightly higher  rate of alachlor  loss than  those  inoculated at  the  rate of
0.015%.   By day  56,  alachlor recoveries  from all  unamended  treatments were
practically identical,  indicating that the stimulation  in degradation rate by the
fungal  inoculum  had waned  over  time.   Amending  soils  with  2%  corn  residue
completely masked the effect of fungal inoculation (Fig. 10)


CONCLUSIONS

      Landfarming  and  biostimulation  are becoming  practical strategies  for
detoxification of wastes  in  soils.  The procedures involved are environmentally
more desirable than traditional "out  of  sight - out  of mind"  disposal  methods
such as landfill ing.  The technologies are also more readily affordable by small
scale operations  than  the more expensive and  less accessible methods  such as
incineration. However, these waste  cleanup methods have certain limitations that
require careful evaluation prior to implementation.  Our landfarming experiments
revealed that herbicides applied as waste  soil  generally degraded more slowly
than fresh  applications,  particularly  at high loading  rates. Another  concern is
the potential  for crop phytotoxicity  when  the waste soil contains  a  diverse
mixture  of  herbicides.       A combination   of  excessively  high   levels  of
contamination and space  limitation may necessitate higher than normal  loading
rates during landfarming.   Prolonged  persistence  and the  possibility  of crop
phytotoxicity may restrict the use of landfarming.

      The strategy of  biostimulation   is based on the  so  called  principle of
microbial ubiquity (Mathewson and Grubbs  1989)  which assumes that the requisite
degrader microorganisms  are  present  at all contaminated  sites and only their
appropriate  stimulation  is  necessary to accelerate  the degradation  of each
contaminant.  However, soils  do differ in  their abilities to  be  stimulated to
degrade individual compounds (Dzantor and  Felsot 1990).  Often,  these differences
are related to  differences in  microbial profiles and accompanying specificities
to degrade different compounds.  Differences  in microbiological  profiles also
imply that  soil manipulations  that may stimulate degradation of one compound may
not necessarily act on a different compound; finding  the right conditions that
will accelerate degradation  of pesticide mixtures may  be difficult.  Even  if the
requisite organisms are present at a contaminated site, it may  be impractical to
stimulate them to overcome toxic effects  of certain chemicals if concentrations
are too high.

      Our fungal  inoculation experiments  have  demonstrated  to  us the difficulty
of using bioaugmentation  alone to decontaminate soils.   First the procedures for
obtaining individual or consortia of microorganisms to degrade specific parent
compounds and their  metabolites  may  be tedious and  time-consuming;  thus,  the
approach may not be  amenable for contaminated  sites that require  immediate
cleanup.  More importantly, this approach  may not  be  feasible because  of poor
competitiveness of laboratory-obtained degrader microorganisms  once  they have
been reintroduced into soil, as our results have suggested.

      In summary, our results suggest  that    no  one  strategy  alone  may  be
sufficient to clean up all contaminants regardless of composition, concentration
or age.  The limitations  have  been  discussed to stimulate debate rather than to
diminish the enormous potential of  landfarming and bioremediation.  We have yet

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 to   explore   all   the   combinations   of   landfarming.   biostimulation,   or
 bioaugmentation   necessary  to  accelerate   contaminant  detoxification.     An
 understanding  of the  microbial  ecology  of biodegradation  may be the key to the
 successful  use of these  strategies  to decontaminate wastes   in  soils.


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and loam  soils  containing  aged and freshly  applied  residues.   Bull. Environ.
Contam.  Toxicol. 41:569-573.

Staiff,  D.C.,  S.W.  Comer, J.F. Armstrong, and H.R.  Wolfe.   1975.  Persistence of
azinphosmethyl in soil.  Bull.  Environ. Contam. Toxicol. 13:362-368.

Steinberg, S.M.,  J.J.  Pignatello,  and  B.L. Sawhney.   1987.   Persistence of
l,2dibromoethane in soils:  entrapment  in intraparticle micropores.   Environ.
Sci. Technol.  21:1201-1208.

Stojanovich,  B.J., M.V. Kennedy and F.L.  Shuman, Jr.   1972.  Edaphic aspects of
the disposal   of  unused  pesticides,  pesticide wastes and pesticide containers.
J. Environ. Qual. 1:54-62.


                                      56

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Winterlin,W., J. N. Seiber, A. Craigmill, T. Baier, J. Woodrow, and G. Walker.
1989.   Degradation of pesticide waste  taken from a  highly  contaminated soil
evaporation pit in California.  Arch. Environ. Contam. Toxicol. 18:734-747.

Wolfe, H.R., D.C.  Staiff,  J.F.  Armstrong and S.W. Comer.  1973.  Persistence of
parathion in soil.  Bull.  Environ.  Contam. Toxicol. 10:1-9.
                                     57

-------
       freshly spraye*
                  •soil treated — A— untreated
                                           8OO
0    100   2OO   30Q   400   SQO
             10O   200   300
                          0   500    600
             Days After Application


Figure 1.  Alachlar residues In corn and soybean plots
          treated with fresh herbicide sprays or with
          herbicide-contaminated soil at the equivalent
          rate of 16.8 kg a.i./ha.
                           58

-------
        freshly spraye<
        10
•soil treated — A— untreated
 as
 I
 I
 i
      o.oi
          0     1OO    2OO    30O    400    500    BOO
               10O    80O    000   400   600   GOO


               Days After Applicatio:


Figure 2.  Metolachlor residues in corn and soybean plots
          treated with fresh herbicide sprays or with
          herbicide-contaminated soil set the equivalent
          rate of 2.85 kg aui./ha.
                           59

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            Figure 3. Effect of Corn Residue Amendment on
                    Degradation of 100 ppm Alachlor in GCC Soil
s
                                                          Corn Residue
                                                                 none
                                                                 2%
                                                                 10 »
                              10    20   30   40   SO   60

                                Days after Treatmen

-------
             19
  % of Initial Recovered
       10
       o
G)
O
GO
O
O
o
O 4-

-------
        Figure 5. Effect of Type and Level of Amendment on
                Degradation of 100 ppm Alachlor in GCC Soil
cr>
ro
Amendment
      None
      Corn Res.
      2% Sew. Slg
      10% Sew. Slg
                            Days

-------
CJ
        Figure 6. Effect of Inorganic N on Degradation
                 of 100 ppm Alachlor in GCC Soil
        -0
        B
        U
        U
100
                                           Inorganic PI
                                            0 None
                                            M 10 ppm
                                            • 1000 ppm
                  None    2% corn 2% soybean
                    Organic Amendment

-------
Figure 7, Effect of Moisture Tension on Degradati*
         of 100 ppm Alachlor in 2 Soil Type
       100
              Soil GCC       Son 52
                   Soil Type
                                      Moistuit
                                      Tension
                                      U 15 bat
                                      i 0.3 bar
                                      • Obai

-------
o>
en
    Figure 8. Effect of Moisture Tension on Degradation

              of 100 ppm Alachlor in 2 Soil Types

        _   100
        T3


        E.eoj

             60
        •a    40
          o
             20


              «
Amended
                   SoilGCC
        Soil 52
                         Soil Type
                   Moisture

                   Tension
                       15  bat

                       0.3 bar

                       Obar

-------
           99
% of Initial Recovered
      10
      o
en
o
o
o

-------
0>
      Figure 10. Effect of Fungal Inoculation on Degradation
               of 100 ppm Alachlor in GCC Soil
         100
             0
                            Amended
                                               Inoculation
                                                      None
                                                      0.015%
                                                      0.045%

-------
                 Removal of Pesticides From Aqueous Solutions
                       Using Liquid Membrane Emulsions

                                      by

                          Dr. Verrill  M.  Norwood,  III
                         Chemical Research Department
                          Tennessee Valley Authority
             National  Fertilizer  and  Environmental  Research  Center
                      Muscle Shoals,  Alabama  35660-1010
ABSTRACT

      Extractive liquid membrane technology is based on a water-in-oil emulsion
as the  vehicle to effect  separation.   An  aqueous  internal reagent  phase is
emulsified into an organic phase containing a surfactant and optional complexing
agents.   The  emulsion,  presenting  a  large  membrane surface  area,  is  then
dispersed in an aqueous continuous phase containing the species to be removed.
The desired species is  transferred from the continuous  phase through the organic
liquid membrane and concentrated in  the  internal reagent phase.  Extraction and
stripping  occur simultaneously  rather  than  sequentially  as  in  conventional
solvent extraction.

      Liquid membranes  have  been used  to  extract phenol,  acetic  acid,  other
weakly  ionized acids  and  bases, and  various metallic  species  from aqueous
solution with  high efficiency.    In  this  work,  experiments were  conducted to
assess  the  feasibility of using  liquid  membranes to extract  pesticides  from
rinsewaters typical  of those generated  by  fertilizer/agrichemical  dealers.  A
liquid membrane emulsion containing 10% NaOH as  the internal  reagent phase was
used to extract herbicides  from  aqueous  solution at a continuous phase:emulsion
ratio of 5:1.   Removals of 2,4-D, MCPA,  Carbaryl,  Diazinon,  and Atrazine were
85.4, 61.2,  80.2, 73.9, and 92.9%,  respectively, after 15-20 minutes mixing time.


INTRODUCTION

      There are over  14,000  agricultural  chemical dealers  ("dealers")  in the
United  States.  Dealers sell fertilizers  and/or  pesticide  products;  they also
custom mix and  apply these  products.  Incidental spillage of fertilizer/pesticide
products  may   occur  during handling  and  can  result  in  the  accumulation of
hazardous chemicals in the soil, surface water and groundwater.  Chemicals can
also accumulate in these media when tanks and application equipment are rinsed
with water  and the rinsewater  is not  disposed of  or recycled properly.   As
dealers continue their efforts to contain, collect, and recycle  their wastes and
spills, there  will be an increased need for technologies to treat that portion
of the wastes  and spills that cannot be recycled.

      The  National  Fertilizer  and  Environmental  Research  Center  (NFERC) has
recognized that the waste treatment problems currently facing dealers are real
and  cannot  be  ignored.  Therefore,  in  March 1990, a multidisciplinary NFERC
project team was organized to identify,  research, develop, and demonstrate waste
treatment and  site remediation technologies for dealers.  The work reported in
this paper was undertaken as part of the research phase of this program.

                                      68

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OBJECTIVE

      The  primary  objective   of  this  research  project  was  to  assess  the
feasibility of using liquid membrane emulsions to remove  herbicides from aqueous
solutions  similar  to  the rinsewaters  generated  at  dealer  sites.    Several
experiments were also run with aqueous solutions  of phenol or acetic acid to gain
experience  in the  experimental  techniques  involved  in  the  preparation  and
handling of liquid membrane emulsions.

      The five herbicides investigated in this study were:

      (1)  2,4-D  (2,4-dichlorophenoxyacetic acid)
      (2)  MCPA (4-chloro-O-tolyloxyacetic acid)
      (3)  Carbaryl  (1-napthyl N-methylcarbamate)
      (4)  Atrazine  (2-chloro-4-ethylamino-6-isopropylamino-l,3,5-triazine)
      (5)  Diazinon  (0,0-diethyl-0-[2-isopropyl-4-methyl-
            6-pyrimidyl]phosphoro-thioate)


BACKGROUND

      General Description of Liquid Membranes:  Liquid membranes were invented
by Norman N.  Li  in 1968 (1-3).  Liquid membranes  are made by forming an emulsion
of two immiscible phases  (the  membrane and internal  phases)  and then dispersing
the emulsion  into a  third phase (the continuous phase).   Usually, the internal
phase and the continuous  phase  are miscible.  If  the liquid membrane emulsion is
to  remain  stable,  the membrane phase  must  not be miscible with  either  the
internal or  the  continuous  phase.   To maintain  the integrity  of the emulsion
during  an  extraction experiment,  the membrane  phase  usually contains certain
surfactants,  additives as  stabilizing agents, and  a  base  material  which is a
solvent for all  the ingredients.  Since the compositions  of the  membrane and the
internal  phase  can  be  varied, liquid  membranes can  be  tailor-made  to meet
specific requirements for a given application (4-7).

      When the liquid membrane  is dispersed by  agitation in the continuous  phase,
many small globules of emulsion are formed (Figure 1).  Their size  depends  on the
nature  and concentration  of   the  surfactants  in  the membrane,  the emulsion
viscosity, and the  mode and intensity of  mixing.  In general, the globule size
is controlled in the range from 0.1 to 1 millimeter in  diameter.   A large  number
of globules of emulsion are formed to produce  a  large  membrane  surface area for
rapid mass transfer  for species from the continuous  phase  to the  internal phase
of  the  emulsion.    In  addition,  many smaller droplets,  typically  1  micron in
diameter, are encapsulated within each globule.   A  variety  of chemical species
can be trapped and concentrated in  the internal  phase  and  subsequently disposed
of or recovered for  reuse or recycle.

      Liquid  Membrane  Separation  Technologies:   Liquid  membrane technology is
very promising  for  a variety  of applications.  Examples of these applications
include:   the  separation  of  hydrocarbons  (8,  9)  and  metal  ions  from water
(10-25);   hydrometallurgy  (10-25)   and   wastewater   treatment  applications
(13, 26-36);  and  biochemical engineering,  such  as the encapsulation  of enzymes
and bacteria  (37, 38).  Liquid membrane technology  currently has  two  commercial
applications;  one  in zinc  extraction and recovery (4)  and the  other   in oil
production as a well control fluid  (39, 40).


                                      69

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      Liquid Membrane Extraction Mechanisms:   The  effectiveness  of the liquid
membrane process can be enhanced by utilizing  "facilitated transport" mechanisms
to maximize both the  flux through  the membrane  and the capacity of the internal
phase for  trapping and  concentrating  the diffusing species (7).   One  type of
facilitated transport  consists of carrying  the  diffusing species  across  the
membrane by incorporating liquid  ion exchange  reagents  in  the  membrane.   This
type of carrier-mediated transport can be illustrated by  the separation of metal
ions from wastewater  or ore-leaching solutions.  A conceptualized drawing of a
liquid membrane "capsule" for extracting copper ions from wastewater is given in
Figure 2.   Extraction  of copper ions occurs at the membrane/continuous  phase
interface.  A  liquid  hydroxyoxime-type ion-exchange  reagent specific for copper
ions is incorporated in the membrane phase.  Stripping of copper ions from the
ion-exchange reagent  occurs at the membrane/internal  phase interface by  10%
H2S04.   The overall  reaction represents an  exchange  of a copper  ion  for  two
hydrogen ions.   The copper is effectively trapped in the interior of the liquid
membrane by the large excess of hydrogen ions (16-21).

      One important advantage of the liquid membrane process for metal extraction
lies in the concurrent extraction and stripping in  a single  stage rather than in
two  separate   stages  as  required  by  solvent  extraction.    In  addition,  by
concurrently extracting  and stripping,  the liquid  membrane process drives  the
extraction by removing the complexed ions as  they  are formed,  thereby removing
the equilibrium  limitation  inherent in  solvent  extraction.    Another  benefit
resulting from the nonequilibrium  feature of  the liquid membrane process is the
significant reduction  of the  reagent   inventory required  for the extraction
process.

      The second type of facilitated transport  is illustrated by the removal of
oil-soluble contaminants such  as  ammonia  (26, 30,  32-34),  phenol  and  other
organic acids  such as acetic acid (32-36) from aqueous solution.  In  these cases,
the membrane phase does not  contain a liquid  ion-exchange reagent.  Rather, the
extraction is  driven  by minimizing the concentration of the diffusing species in
the internal phase.  This is accomplished by reacting the diffusing  species with
a reagent in the  internal  phase to form a product(s)  incapable of diffusing back
through the membrane.

      This type of facilitated transport can be illustrated by the separation of
phenol  from wastewater (Figure  3).  In this  case, sodium  hydroxide (10% NaOH) is
encapsulated inside the internal  phase as the reagent which reacts with phenol.
The phenol first dissolves in the membrane  phase from the continuous phase and
then diffuses  to  the interface between the membrane phase and the Internal phase.
At this interface, the phenol reacts with 10% NaOH to form sodium phenolate that
is insoluble in the membrane phase.  As a result, the concentration  of phenol at
the  membrane/internal   phase   interface is  maintained  at zero,  allowing  a
continuous driving force  for permeation through the membrane.   In  addition to
phenol, contaminants which can be removed by reaction with sodium hydroxide in
the internal phase are cresols, carboxylic acids,  and hydrogen sulfide.

      In  principle,  the liquid membrane extraction process  should be broadly
applicable  to  many acidic species  containing an  ionizable chemical functional
group(s).   These species include many  types of  herbicides.   Two  of the five
herbicides investigated in this study are representative of these acidic species,
i.e., 2,4-D and MCPA.  The other three herbicides,  i.e.,  Carbaryl, Diazinon, and
Atrazine, were chosen for study because each are soluble in organic solvents and,
furthermore, each are known to hydrolyze rapidly in alkaline solution.

                                      70

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EXPERIMENTAL

      Preparation of the Liquid Membrane Emulsion:  The membrane phase consisted
of a mixture of surfactant (4%)  and solvent (96%).  The surfactant was EGA 4360
(Paramins Co.,  Paramus,  NJ),  a  polyamine with  an  average  molecular weight of
1500.  The solvent used  was Low Odor Paraffin Solvent  (LOPS);  this solvent is an
isoparaffin hydrocarbon  (Exxon, Houston, TX). All the herbicides were analytical
grade and used as received (ChemService, Inc., West Chester, PA).

      Liquid membrane emulsions  for use in bench-scale batch tests were prepared
by extensive mixing of  the membrane  and  internal  phase (10% NaOH)  in a Waring
blender.  The internal phase was mixed with the membrane phase on a 1:1 weight
ratio to form a water-in-oil emulsion. The mixing was accomplished at 10,000 rpm
for 6 minutes to ensure complete encapsulation. The resulting  emulsion was mixed
with  the continuous  phase  (aqueous  solutions of  phenol,  acetic acid,  or
herbicides)  at  a  continuous  phase:emulsion ratio of  5:1  in  a baffled 2-liter
resin kettle. Mixing  was accomplished with 2 marine-type propellers attached to
a variable speed stirrer via a 1/4 inch stainless steel stirring rod.  The mixing
speed ranged from 400 to 600  rpm for  the phenol  experiments and 420-440 rpm for
the acetic acid and herbicide experiments.   The  mixing  speed  was monitored by a
hand-held  digital  tachometer  (Shimpo  Model  DT-201).    The length  of  all
experiments was 20 minutes.  Samples were taken at 1, 5, 10, 15 and 20 minutes
via a stopcock at  the bottom of the  resin kettle.  All  experiments were conducted
at ambient temperature.


RESULTS AND DISCUSSION

Phenol and Acetic Acid Solutions

      Extraction of Phenol from Aqueous Solution (35,36):   Figure 4 shows data
from an experiment to assess  the effect of  mixing speed  (rpm) on the extraction
of phenol.  Three observations can be noted:

      (1)   The percent extraction values at the 1 minute sampling  time
            decrease as the mixing speed decreases.
      (2)   The maximum extraction value of each curve shifts to longer
            sampling times as the mixing speed decreases.
      (3)   The slopes  of  the extraction  curves after about 5 minutes
            increase from nearly zero at the low rpm to larger negative values
            as the mixing speed increases.

      As  the mixing speed increases  two  phenomena  occur:    (1) the  emulsion
globule size decreases,  and (2) the rate at which globules are broken increases.
A smaller globule size will lead to more interfacial  transfer area  between the
continuous phase and the liquid  membrane, thus allowing  the extraction to occur
at a higher rate.   In addition,  the higher rate of shear and subsequent higher
rate of breakage of globules at the higher rpm values  allows more leakage of the
phenol ate ion back into the continuous phase  from the internal phase  of  the
liquid membrane emulsion.

      Extraction of Acetic Acid from Aqueous Solution (36):  Aqueous solutions
of acetic acid  (5000,  3000, and  1000  ppm) were used as the continuous phase for
the three extraction  runs shown in  Figure  5.   Percent extraction  values  are
plotted versus  mixing time.   The results shown  in Figure 5  indicate that as the

                                      71

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concentration of acetic  acid  in  the  continuous  phase increases the extraction
rate decreases.   This did not  appear to be the case  in the experiments described
above  where phenol  was the  pure component in  the continuous  phase.    The
difference in the results from the acetic  acid and phenol  extraction runs is most
likely  due  to  the  difference   in  the  partition  coefficient  values of  the
components between the membrane  and  continuous  phases.   In the case of acetic
acid, its solubility in  the membrane phase is likely the controlling factor.

Herbicide Solutions

      2,4-D:  Table 1 contains data from the first extraction run where an
aqueous  solution  containing  approximately  100 ppm 2,4-D  was  used as  the
continuous  phase.   After  1  minute  mixing  time,  the  concentration  of  2,4-D
decreased from 96.8 to 30.7 ppm,  a reduction  of  68.2%.  After 20 minutes mixing
time, the  amount  of 2,4-D extracted  from  the continuous  phase  by the  liquid
membrane increased to a  value of 85.4%.   Based  upon  the results summarized in
Table 1, no leakage of 2,4-D from the internal phase of the membrane back into
the continuous phase occurred during this experiment.

      HCPA:   Table 2 contains  data  from  the  second extraction  run  where an
aqueous solution  containing approximately 100 ppm MCPA was used as the continuous
phase.  After 1 minute mixing time,  the concentration of MCPA decreased  from 96.1
to 67.4 ppm, a reduction of only  29.9%.   However, after 15 minutes mixing time,
the  amount  of MCPA  extracted from the  continuous  phase  increased  to  61.2%.
Unfortunately, some leakage of the MCPA  from the  internal  phase of the  liquid
membrane emulsion back into the continuous phase occurred during this experiment
based on  the fact that the  concentration  of  MCPA  in  the continuous  phase
increased from 37.3  ppm  at  15 minutes to 41.4  ppm at 20  minutes  total  mixing
time.

      Diazinon:   Table 3 contains  data from  the third extraction run where an
aqueous  solution  containing  approximately 30  ppm  diazinon was  used as  the
continuous phase.   After 1  minute mixing  time, the  concentration of diazinon
decreased from 28.3 to 14.7  ppm,  a reduction  of  48.1%.  After 15 minutes mixing
time, the amount of diazinon extracted from the continuous phase by the liquid
membrane  emulsion   increased  to  a  value  of  73.9%  and   thereafter  remained
essentially constant.  No significant leakage  of diazinon from the internal phase
of the membrane back into the continuous phase is indicated by the  data given in
Table 3.

      Carbaryl:   Table 4 contains data from the fourth extraction run
where an aqueous solution containing approximately 30 ppm carbaryl was used as
the continuous phase.  After 1 minute mixing time, the concentration of carbaryl
decreased from 31.3 to 10.3 ppm,  a reduction  of  67.1%.  After 20 minutes mixing
time, the amount  of carbaryl  extracted from the  continuous  phase increased to a
value of 80.3%.   No leakage of carbaryl from  the internal phase of the membrane
into the continuous phase was indicated by the experimental data.

      Atrazine:   Table 5 contains data from the fifth and final extraction run
where an aqueous solution containing approximately 30 ppm atrazine was used as
the continuous phase.  After 1 minute mixing time, the concentration of atrazine
in the  continuous  phase  decreased  by 64.9%.   However,  after 15 minutes mixing
time, the amount of atrazine extracted from the continuous phase by the liquid
membrane  increased to a value  of 92.9%.   Some leakage of  atrazine  from the
internal phase back into the continuous phase is indicated  by the  data given in
Table 5 at the 20 minute mark.


                                      72

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SUMMARY
      The major results obtained from this study may be summarized  as  follows:

      (1)   More  than  99% of phenol  can be extracted from  aqueous solution
            after  approximately  1   minute  with  a  liquid  membrane   emulsion
            containing 10% NaOH as the internal reagent phase.

      (2)   Acetic acid can  also  be  extracted  by the liquid membrane  emulsion
            but at a slower  rate (5-10 minutes mixing time).

      (3)   The liquid membrane emulsion containing 10%  NaOH  as the  internal
            reagent  phase can extract herbicides  from aqueous  solution  at a
            continuous phaseremulsion ratio of 5:1.   Removals of 2,4-D, MCPA,
            Carbaryl, Diazinon, and  Atrazine were  85.4,  61.2,  80.2, 73.9, and
            92.9%, respectively, after 15-20 minutes mixing  time.
CONCLUSION

      Based upon the  exploratory  work  reported in this paper, it appears that
liquid  membrane technology  can  be  used to  extract herbicides  from aqueous
solution.   The types  of herbicides that can  be extracted  by  the particular
membrane composition reported in this paper  are limited  to those that will form
an ionized species or hydrolyze in alkaline  solution.   Further work  is required
to determine whether other types  of herbicides are amenable to extraction from
aqueous solution by different  liquid membrane  compositions.   Also,  it will  be
useful to analyze the composition of the internal reagent phase, after the liquid
membrane  emulsion  is  broken,  to  perform a material balance calculation and
identify degradation products.
                                      73

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  Table 1.   Extraction  of 2,4-D from Aqueous  Solution
Mixing Time (min)             Concentration fppm)
       0                            96.8
       1                            30.7  (68.2% Removed)
       5                            16.6
      10                            14.9
      15                            16.3
      20                            14.1  (85.4% Removed)
  Table 2.  Extraction of MCPA from Aqueous Solution
Mixing Time (mini             Concentration (pom)
       0                            96.1
       1                            67.4  (29.9% Removed)
       5                            62.2
      10                            52.4
      15                            37.3  (61.2% Removed)
      20                            41.4
                          74

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Table 3.  Extraction of Diazinon from Aqueous Solution

Mixing Time  (min)             Concentration  (ppm)
       0                            28.3
       1                            14.7   (48.1% Removed)
       5                            10.3
      10                             9.3
      15                             7.4   (73.9% Removed)
      20                             7.6
Table 4.  Extraction of Carbaryl from Aqueous Solution

Mixing Time (min)             Concentration (ppm)
       0                            31.3
       1                            10.3  (67.1% Removed)
       5                            14.7
      10                            11.3
      15                             9.4
      20                             6.2  (80.2% Removed)
                          75

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Table 5.  Extraction of Atrazine from Aqueous Solution

Mixing Time (mini             Concentration (ppm)
       0                            29.8
       1                            10.5  (64.9% Removed)
       5                             6.3
      10                             4.1
      15                             2.1  (92.9% Removed)
      20                             4.6
                          76

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 LITERATURE  CITED

  1.   Li, N.  N.,  "Separating Hydrocarbons with Liquid Membranes", U.S.  Patent
      3,410,794 (November  12,  1968).

  2.   Li, N.  N.,   "Permeation  Through Liquid  Surfactant  Membranes",  AIChE  J.
      17(2),  459  (1971).

  3.   Li, N.  N.,  "Facilitated Transport  Through  Liquid Membranes-An  Extended
      Abstract",  J. Membr. Sci. 3,  265  (1978).

  4.   Frankenfeld,  J.  W.;  Li,  N.  N.,  "Recent  Advances  in  Liquid   Membrane
      Technology",  in Handbook of  Separation Process  Technology,  Wiley, New
      York, p. 840  (1987).

  5.   Cussler, E.  L.;  Evans,  D. F.,  "How to Design  Liquid Membrane  Separations",
      Sep.  Purif. Methods 3, 399  (1974).

  6.   Del Cerro,  C.;   Boey,  D.,   "Liquid  Membrane  Extraction",  Chemistry and
      Industry, 681 (November 7,  1988).

  7.   Matulevicius, E.  C.; Li, N.  N.,  "Facilitated  Transport  Through  Liquid
      Membranes", Sep.  Purif. Methods 4, 73  (1975).

 8.   Cahn,   R.  P.;  Li,  N.  N.,  "Hydrocarbon Separation  by  Liquid  Membrane
      Processes",  in  Membrane  Separation Processes,  P. Mears  (Ed.),  Chap.  9,
      Elsevier, New York (1976).

 9.   Li, N.  N.,  "Separation of  Hydrocarbons  by  Liquid Membrane Permeation",
      Ind.  Eng. Chem.  Proc. Res.  Dev. 10, 215  (1971).

10.   Cahn,  R. P.; Frankenfeld, J. W.; Li, N. N.; Naden,  D.; Subramanian,  K. N.,
      "Extraction  of  Metals  by Liquid  Membranes",  in  Recent  Developments  in
      Separation Science, N.  N. Li (Ed.), Vol. VI,  p. 51, CRC  Press, Boca  Raton,
      Florida (1981).

11.   Gu, Z. M.; Wasan,  D. T.; Li, N. N., "Liquid Surfactant Membranes for Metal
      Extractions", Faraday Discuss. Chem. Soc. 77, 1 (1984).

12.   Hayworth, H. C.; Ho, W. S.;  Burns, Jr., W.  A.; Li, N.  N., "Extraction of
      Uranium from  Wet  Process Phosphoric Acid Using  Liquid Membranes", Sep.
      Sci. Technol. 18, 493 (1983).

13.   Frankenfled,  J.  W.; Li,  N.  N.,  "Waste Water  Treatment  by Liquid Ion
      Exchange in  Liquid Membrane  Systems", in Recent Developments  in Separation
      Science, Li, N.  N. (Ed.), Vol. II, p.  285, CRC Press, Boca Raton, Florida
      (1977).

14.   Hochhauser,  A. M.; Cussler, E.  L.,  "  Concentrating  Chromium with  Liquid
      Surfactant Membranes",  AIChE Symp. Ser. 71,  136 (1975).

15.   Bock,  J.;  Valint,  Jr.,  P.  L.,  "Uranium  Extraction  from Wet  Process
      Phosphoric Acid.   A Liquid Membrane Approach",  Ind. Eng. Chem. Fundam. 21,
      417 (1982).


                                      77

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16.   Li, N. N.; Cahn, R.  P.; Naden, 0.; Lai, R. W.,  "  Liquid Membrane Processes
      for Copper Extraction", Hydrometallurgy 9, 277  (1983).

17.   Strzelbicki, J.; Charewicz,  W., "The Liquid Surfactant Membrane Separation
      of  Copper,  Cobalt  and Nickel  from Multicomponent  Aqueous Solutions",
      Hydrometallurgy 5, 243 (1980).

18.   Volkel, W.; Halwacks, W.; Schugerl, K., "Copper Extraction  by Means of a
      Liquid Surfactant Membrane  Process", J. Membr. Sci. 6, 19 (1980).

19.   Martin,  T.  P.;  Davies,  G.  A.,  "The  Extraction  of Copper from Dilute
      Aqueous Solutions Using a Liquid Membrane Process",  Hydrometallurgy 2, 315
      (1977).

20.   Frankenfeld, J.  W.;  Cahn,   R.  P.;  Li, N.  N.,  "Extraction  of  Copper by
      Liquid Membranes", Sep. Sci. Technol.  16, 385 (1981).

21.   Lee, K. H.;  Evans, D.  F.; Cussler, E.  L.,  "Selective Copper  Recovery with
      Two Types of Liquid Membranes", AIChE J.  24, 860 (1978).

22.   Fuller, E. J.;  Li, N.  N., "Extraction of Chromium and Zinc from Cooling
      Tower Slowdown by Liquid Membranes", J. Membr. Sci. 18, 251 (1984).

23.   Teramoto, M.;  Tohno,  N.; Ohnishi,  N.; Matsuyama,  H.,  "Development  of a
      Spiral-Type Flowing  Liquid  Membrane Module with High  Stability  and its
      Application to the Recovery  of Chromium and Zinc",  Sep. Sci. Technol. 24,
      981 (1989).

24.   Cahn,   R.  P.;  Li, N.  N.,  "Metal Extraction  by  Combined  Solvent and LM
      Extraction", U. S. Patent 4,086,163 (April 25, 1978).

25.   Xinchang, Z.;  Linain,  L.; Jianjun, G.; Fusheng, L.,  "A Study  of Extracting
      Vanadium  from  Wastewater by Emulsified Liquid  Membrane  Process", Water
      Treatment 2, 214  (1987).

26.   Cahn,  R. P., Li, N. N.; Minday, R.  M., "Removal  of Ammonium Sulfide from
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      (1978).

27.   Li, N. N.; Cahn,  R. P.; Shrier, A. L.,  "Use of  Liquid Membrane Systems for
      Selective Ion Transfer",  U.  S. Patent 4,292,181  (September  29,  1981).

28.   Kitagawa, T.;  Nishikawa, Y.;  Frankenfeld,  J.  W.;  Li,  N.  N., "Wastewater
      Treatment by  Liquid  Membrane  Process",  Environ.  Sci. Technol.  11,  602
      (1977).

29.   Ruppert,  M; Draxler,  J.;  Marr,  R.,  "Liquid-Membrane-Permeation  and its
      Experiences in Pilot-Plant  and Industrial Scale", Sep. Sci. Technol. 23,
      1659  (1988).

30.   Downs, H. H.;  Li,  N. N., "Extraction of Ammonia from Municipal Waste Water
      by the Liquid Membrane  Process", J. Separ. Proc.  Technol.  2(4), 19 (1981).
                                      78

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31.   Li, N.  N.;  Chan,  R.  P.;  Shrier,  A. L., "Liquid Membrane Process  for  the
      Separation  of Aqueous Mixtures",  U.  S. Patent  3,779,907  (December  18,
      1973).

32.   Li, N. N.; Cahn, R. P., "Process for Removing the Salt of a Weak Acid  and
      a Weak Base From Solution", U. S.  Patent 4,029,744  (June 14,  1977).

33.   Chan, C. C.; Lee,  C.  J.,  "A Mass Transfer Model for the Extraction  of Weak
      Acids/Bases in Emulsion  Liquid-Membrane Systems", Chem.  Eng.  Sci. 42, 83
      (1987).

34.   Lee,  C.  J.;  Chan,  C.  C.,  "Extraction of Ammonia  from a Dilute  Aqueous
      Solution  by  Emulsion Liquid Membranes.   1.    Experimental  Studies  in a
      Batch System", Ind. Eng. Chem. Res. 29, 96 (1990).

35.   Cahn, R.  P.;  Li,  N.  N.,  "Separation  of Phenol  from  Waste  Water  by  the
      Liquid Membrane Technique", Sep. Sci. 9, 505  (1974).

36.   Terry, R.  E.;  Li,  N. N., "Extraction  of Phenolic Compounds  and  Organic
      Acids by Liquid Membranes", J. Membr. Sci.  10, 305  (1982).

37.   Mohan,  R.  R.;  Li,  N.   N.,  "Nitrate  and  Nitrite  Reduction  by  Liquid
      Membrane-Encapsulated Whole Cells", Biotechnol. Bioeng.  17, 1137  (1975).

38.   Mohan, R. R.;  Li,  N.  N.,  "Reduction and  Separation of  Nitrate  and  Nitrite
      by  Liquid  Membrane-Encapsulated Enzymes",  Biotechnol.  Bioeng.  16,   513
      (1974).

39.   U. S.  Patent 4,359,391 (1982).

40.   U. S.  Patent 4,397,354 (1983).
                                      79

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CO
o
                         Oil
                     Surfactant
                     Membrane
                                                                        Aqueous Feed
                                                           Aqueous Reagent
                                                               Droplets
Emulsion
Globules
                               Figure 1. Dispersion of Liquid Membrane Emulsion20

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00
                             Internal
                            Aqueous
                             Droplets
                           (+Stripping
                             Agent)
                             Oil
                 Acid
             (Stripping
               Agent)
Aqueous
  Feed
     Liquid
   Membrane
Ugand (R) + Surfactant
                               Figure 2.  Cooper Transfer In a  Liquid Hembrane Globule
                                                                                   20

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                                                                         liquid Membrane
                                     Surfactant
                              Hydrophobic Hydrophlllc
Solvent
Surfactants
Additives
CO
ro
                                                                                                      Phenol Reaction
                                                                                                             Droplets
                                                                                                      Phenol +  NaOH

                                                                                                     •»• Sodium Phenolale
                                                                                                      I Won Permeable)
                                                                                                   Aoueous Feed  Outside
                                                                                                     (Continuous Pliate)
                                          Figure 3.   Liquid  Hembrane  System  for Phenol  Removal
                                                                                                           20

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                                   PERCENT EXTRACTION OF PHENOL
                      S
to
c
(D
n
3
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                                100
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                         o
                         0
                                 30
                                        lOOOppm
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                              Figure  5.   Effect of Concentration on the Extraction  of Acetic Acid

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               Field and Laboratory Evaluations of an Activated
                           Charcoal  Filtration Unit

                                       by

            Joseph  H. Massey, Terry  L.  Lavy, and  Briggs W. Skulman
         Department of Agronomy, University of Arkansas,  Fayetteville


ABSTRACT

      An activated  charcoal  filtration unit  was  designed to remove pesticides
from  leftover  pesticide  solutions  and  rinsates  generated  under  farm-like
conditions.  The system, fabricated for less  than  $1200  using readily available
components,  effectively removed the pesticides   atrazine,  benomyl,  carbaryl,
fluometuron, metolachlor, and trifluralin from wastewater. A  total of 2253  L of
wastewater were treated using the system.  Of these  1768  L were generated  from
washing out the spray  tank while 485 L stemmed from leftover pesticide solutions
that were mixed, but not applied.  Typical initial pesticide concentrations in
the wastewater were on  the order of  300 to 1000  parts per million (ppm).  The
final pesticide concentrations remaining after charcoal filtration were generally
less than 10 ppm.  Approximately 1514 L of wastewater were treated  with  23 kg of
charcoal before  the  charcoal  was replaced.   This  resulted  in  an  estimated
pesticide loading rate  of  0.05 to 0.10  kg pesticide active  ingredient per kg
activated charcoal.  Incubation of alachlor-treated charcoal with a  mixed culture
of microorganisms resulted in approximately a 50%  loss of alachlor after 50 d.
These results suggest that the degradation of alachlor sorbed to charcoal does
occur but more research is needed to determine if  it  is a feasible alternative
to incineration for spent charcoal.   A  reduced  adsorption  of  methylene blue and
alizarin red  dye with  increasing  amounts of  trifluralin sorbed to  charcoal
occurred.   Activated  charcoal  treated  with  more  than 200 mg/g trifluralin
adsorbed considerably less of these dyes than the  control where no trifluralin
was added.   The  adsorption of malachite green dye was  less  affected  by these
trifluralin  concentrations.    These  results  suggest that  methylene  blue or
alizarin dye might be used to rapidly assess the remaining adsorptive capacity
of a activated charcoal used to treat pesticide-laden wastewater.


INTRODUCTION

      Several researchers have successfully  used  activated  charcoal  to remove
pesticides  from  leftover  solutions  and  rinsates.   Nye  (1988)  developed  a
flocculation/sedimentation  and  filtration  process  that  reduced  18925 L of
wastewater to 379 L  of sludge and 91  kg of  spent carbon.  Dennis (1988) built a
similar system based on the CARBOLATOR 35 water purification unit.  After 20 h
of filtration with 18  kg of Calgon-300 charcoal, 4  out of 6 pesticides initially
present in 1552 L of water were not detectable.

      In each of these systems, pesticides were filtered from wastewater using
granular activated charcoal  (GAC).   After  filtration, the wastewater  could be
reused as a diluent or returned to the environment with minimal impact.  Although
activated charcoal  has proven to be quite effective at removing many different
pesticides from wastewater,  more research  is needed  in order  to  optimize  the
charcoal adsorption  process.


                                      85

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      One major drawback of activated charcoal filtration is that the pesticides
are  adsorbed,  not  destroyed,  and  contaminated charcoal  is produced.   This
contaminated charcoal presents  the problem of proper disposal in order to prevent
environmental contamination. While  regeneration of the charcoal  is possible,  it
is  not  economically  feasible  when less  than  225  kg spent  charcoal/day are
generated (Zanitsch and Stenzel, 1978).  For this reason spent charcoal generated
in small quantities  is  normally incinerated.

      An  alternative disposal  treatment  for spent  charcoal may involve the
degradation of sorbed pesticides  by  microorganisms.   The degradation of organic
pollutants in soil  is frequently the result of microbial activity.  However, the
sorption of  some organics by  soil  constituents has been  found to reduce the
availability of  organic molecules  to microorganisms  and  decrease the rate  of
degradation  (Miller  and Alexander,  1991).   The  typical diameters  of activated
charcoal micropores  range  from 10 to  1000 angstroms while most  bacterial cell
diameters range  from 5000 to > 10,000  angstroms.   Consequently,  bacteria are
physically excluded from the micropore structure of activated charcoal (Perrotti
and Rodman,  1974).   For this reason it  is not clear that microbial degradation
of pesticides sorbed  to  spent charcoal  will be feasible.  However, the successful
degradation of pesticides sorbed to soil (Kilbane et al.,  1983;  Somich et al.,
1990)  and peat  moss   (Mullins  et  al.,  1989)  suggests  that   the  microbial
degradation of pesticides sorbed to charcoal deserves  investigation.

      Simple  techniques for assessing  the  adsorptive capacity  of activated
charcoal are needed  in order to optimize the filtration  of pesticide wastes.
Although a thin-layer chromatography method was developed  to detect pesticides
in filtered effluent  (Dennis,  1988),  this  is  likely impractical for use under
farm conditions.  Another approach may be to use  dyes to indicate when activated
charcoal  no  longer  has the capacity to  effectively adsorb  pesticides from
solution.   The  use  of dyes to  assess the  adsorptive capacity of activated
charcoal has  proven to be helpful  in  many industrial  situations (Hassler,  1974).
To qualify for use, the dyes should have adsorptive characteristics similar  to
those of the chemicals  being adsorbed.


PURPOSE AND OBJECTIVES

      The overall goal  of this  research was to further the progress towards  an
economical and  practical pesticide waste disposal technology.  The specific goals
were to:  a), fabricate and field test a pesticide rinsate disposal unit based
on activated charcoal  filtration technology,  b).  determine the feasibility  of
microbially degrading pesticides  sorbed  to spent charcoal,  and c).  determine  if
visual  assays  could  be  used  to  assess the  remaining adsorptive capacity  of
activated charcoal.
MATERIALS AND METHODS

Activated Charcoal Filtration Unit

      A schematic diagram  of  the  activated  charcoal  filtration unit (ACFU) is
given  in  Figure  1.   The  system,  like that  described  by Dennis  (1988),  was
fabricated using  readily available materials  and  was  simple  in  design.   The
fiberglass tank was  filled  with 23  kg of Cullar-D granular activated charcoal
(American  Norit  Co.,   Inc.;  Jacksonville,   FL 32205).    A  1/2   hp  electric

                                      86

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 centrifugal  pump  produced a flow rate through the charcoal  filter of 0.65 L/s.
 A 30  m paper pre-filter was placed before the charcoal  filter to remove sediment
 and  debris from  the  wastewater.   By mounting the  pump and cartridge  filter
 housing onto a wagon and using a hand-truck for the fiberglass tank, the unit was
 easily transported  to  the pesticide mixing/loading site.
                 Actlvated
                Charcoal FIIter
                Waste Drum
                Figure 1.  Schematic of the  activated charcoal
                   filtration unit used for rinsate disposal
      Two modifications  were made
pressure cutoff switch was added.
the water  pressure dropped  below
installed  which  would   not  allow
to the  electric  water pump.   First,  a  low-
This safety switch shut the system down  when
10 psi.    Also,  a  manual  reset  button  was
 the  pump to  automatically  restart after
overheating  without  the  assistance  of  the operator.    These modifications
increased the level  of equipment protection and eliminated the need  for constant
supervision of the  ACFU while  in  use.   The retail cost of the  ACFU,  including
modifications, was  about $1200.

      Pesticide-laden  wastewater  generated  during  1990 on  the University of
Arkansas Main Agricultural Experiment Station, Fayetteville (MAES) was stored in
208 L teflon-lined  drums.    The  wastewater  stemmed  from  two primary sources:
leftover pesticide  solutions and rinsates from cleaning spray equipment.   Prior
to filtration, the wastewater was mixed, solution pH and temperature  measured,
and  a  sample collected  for  time-zero  analysis using  either  gas or  high
performance liquid chromatography.  During filtration, effluent from the charcoal
filter was circulated  back into the containment drum.  At various  time  intervals,
more samples  were collected from the bulk solution.   As  a general rule,  fil-
tration  was continued  until  the wastewater was clear and odorless (ca. 3 to 5 h).

                                      87

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Microbial Degradation of Spent Charcoal

      A system was designed to aid in determining the feasibility of microbial
degradation of pesticides sorbed to spent charcoal.  The system was similar to
that reported by Wolf and Legg (1984)  except  that  no  C02 trapping was involved.
The degradation of Lasso 4EC  herbicide  (alachlor,  Monsanto Co.,  St. Louis, MO
63167) sorbed to activated  charcoal  was  measured by using a gas chromatographic
rather than a radioisotopic technique.

      Alachlor-amended charcoal1 was prepared to have  a concentration of 24,820+
1816  g alachlor/g GAC.  Approximately 60 g (wet weight)  of  the amended charcoal
was placed  into  a 125 mL erlenmeyer flask containing 25 mL  of nutrient broth
solution  and  1  mL of  a 105 soil  dilution.   Six  replications of  the  amended
charcoal treatment were employed.  Aeration  was provided  by  bubbling  room air
through the samples.   The samples were incubated at 33 ± 1  C in a water bath.

      Two controls were included in the study.  One was a charcoal control which
contained similar amounts of charcoal,  nutrient  broth, and soil inoculant but had
no alachlor added.  A water control consisted of 30 mL of water containing 620
± 89 ppm of alachlor with nutrient broth solution  and  soil inoculant but with
no charcoal  present.   Five repetitions of these  controls  were  incubated with the
alachlor-amended charcoal samples.

Adsorptivitv Assays for Used Charcoal

      For the first  series  of tests Treflan herbicide  and methylene  blue dye
(85%,  Matheson Coleman  & Bell,  Norwood,  OH)  were  used.   To  1  g  quantities of
oven-dried charcoal dried (24 h  at 105°C), various amounts of Treflan herbicide
solution were added.   Final concentrations of trifluralin ranged from 0 to 384
mg trifluralin/g charcoal.   Three  replications  per  concentration were used.

      To the trifluralin-amended charcoal,  5  mL of  a  0.021 M methylene blue dye
solution  (dissolved  in a  0.22  M  sodium  phosphate monobasic  buffer  solution
adjusted to pH 6.5) was added.  The glass culture  tubes  were capped and shaken
at 12  rpm for  15 min at room temperature.  After measuring the absorbance of the
dye remaining in solution,  the dye concentration was  estimated using a standard
curve.

      Similar studies were  conducted  using 0.021  M  malachite  green dye (99%,
Eastman Kodak  Co.,  Rochester, NY)  and  0.022  M alizarin  red dye  (J.T.  Baker
Chemical  Co.,  Phillipsburg,  NJ).    For the  alizarin   red  study,   the  buffer
concentration was reduced to 0.04 M to prevent precipitation of the dye.


RESULTS AND DISCUSSION

Field Evaluation of the ACFU

      About 485 L of  leftover pesticide  solutions  and 1768 L of rinsates were
treated using the ACFU.  These figures reveal  that  79% of the wastewater treated
stemmed from the  cleaning of  spray equipment.  There were  3785 L of pesticide
solutions mixed during  the  1990  growing season.   Of these,  485  L  or  13% were
     1A11  studies used Cullar-D activated charcoal  like that used in the ACFU.

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returned unused to the waste drums.  The average volume of the leftover solutions
was 23 ± 23  L while  that  of the  rinsates was 87 ± 34 L.

      The ACFU effectively removed the commonly applied herbicides AAtrex Nine-0
(atrazine,   CIBA-GEIGY Corp.,  Greensboro, NC  27409),  Bicep 4.5L (metolachlor,
CIBA-GEIGY  Corp.,  Greensboro,  NC  27409),  and Treflan  EC (trifluralin, Elanco
Products Co., Indianapolis, IN 46285)  (Figure  2) and other pesticides including
Benlate 50% WP fungicide (benomyl,  DuPont Co.  Inc., Wilmington, OE 19898), Sevin
insecticide  (carbaryl,  Union Carbide  Co. Inc., Res.  Triangle Park,  NC 27709)  ,
and Cotoran herbicide  (fluometuron,  CIBA-GEIGY  Corp.,  Greensboro,  NC 27409)
(Figure 3).  Typical  initial pesticide concentrations were on the order of 300
to 1000 ppm  while  final concentrations after filtration were < 10 ppm.

      An estimated 0.05  to 0.10  kg  of pesticide  active ingredient could be
adsorbed by  each kg of GAC.  These values are  based on  the fact that after 1514
L of wastewater had been filtered, the 23 kg of GAC no longer effectively removed
pesticides from solution.   At this  point the spent  charcoal  was  replaced.
                   Solution Cone, ppm
                                                      " trff II*-BI In
                       20    40   60   80   100   130

                                  Minutes of Filtration
                                                    HO   160   180
                 Figure 2.  Removal of three  herbicides  using
                        activated charcoal  filtration.
                                      89

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                   Solution Cone, ppm
                              20     30    40    50

                                  Minutes of Filtration
                                                     60
                                                           70
                 Figure 3.  Removal of three pesticides using
                        activated charcoal filtration.
      Other than  adsorption  onto the charcoal, there  were  at least two  other
avenues of pesticide dissipation not  explored  in this study.  First, some of the
pesticides were trapped by the 30  m  paper pre-filter.  Solid-carrier pesticide
formulations  (e.g.  AAtrex Nine-0)  were trapped to  some  degree by the  filter.
Moreover,  bright  yellow  stains  formed  on the paper  filters, indicating  that
Treflan  herbicide  was  being  sorbed.    Besides  the  spent  charcoal,   these
contaminated filters are another source of contaminated material which will  have
to be properly disposed.

      Volatilization from solution  is a potential avenue of dissipation  for some
pesticides.   Controlling factors  of volatilization  from water  include  the
solubility, molecular weight, and vapor pressure of the pesticide and the nature
of the air-water interface through  which it must pass,  the turbulence generated
during the recirculation of the wastewater would likely enhance volatilization.
Of the pesticides  involved in this  study, only trifluralin has a Henry's  Law
Constant great enough  to  suggest that volatilization from solution might  be  a
significant problem  (Jury et  al.,  1987).
                                      90

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 Hicrobial  Degradation of Spent Charcoal

       Figure 4 presents data generated from incubating alachlor amended charcoal
 under  conditions  which  should  favor  microbial  growth.   The  degradation  of
 alachlor on charcoal  occurred  at a slow,  steady rate.  After 21 d of incubation
 slightly less than  70% of the originally  applied alachlor still remained on the
 charcoal.   Thirty-nine days of incubation  resulted  in a 52% retention  of the
 alachlor  initially applied  to the charcoal  while the  water  control  retained
 approximately 46%.  After 59 d the  amended charcoal retained  43% while the water
 control retained  33%  of  the initial  alalchlor.  These data suggest a half-life
 of  about 50 d for the alachlor sorbed to charcoal.
                  X of Alachlor Homfnlng
                  0  3
                         9 12 15 18 21 24  27 30 33 36 39 42 45 48 51 54 57 SO

                                  Days of Incitotron
                 Figure 4.  Degradation  of alachlor  sorbed  to
                              activated charcoal.
      While these data are preliminary, results suggest that the degradation of
alachlor sorbed to charcoal via microbial action can occur.  Alachlor is degraded
in soil  primarily by microorganisms and  its  losses due to volatility  are  low
(Humburg, 1989).  This study did not address the possibility that degradation may
have occurred through chemical reactions.

      Until the  feasibility  of microbially degrading  spent charcoal  is  fully
determined, spent charcoal can be incinerated.  For this  reason, an estimated cost
of disposing the  spent  charcoal  via incineration at the Environmental  Systems
Company  (ENSCO)  El Dorado, AR  plant  was  calculated.   According  to an  ENSCO
representative, charcoal containing pesticides can be incinerated for $2.10/kg.
Transportation  costs  normally  run $25/208-1  drum with a  $50  stop-fee.    An
analytical determination of the drum contents  is  also  required  ($300/sample).
                                      91

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      About  23  kg  of  spent  charcoal  was  generated  by filtering  1514  L of
wastewater.   Given  an apparent density of 470 kg/m3, a  208  L  drum of charcoal
would weigh about 97 kg.  At $2.10/kg disposal fee, this would cost about $210,
plus $75 for  shipping  and  $300  for  analytical  costs.   Since  there is a minimum
invoice of $1000, at least  2 drums would be required for economical  reasons.  Two
drums would contain 200 kg of charcoal, resulting  in a  total  cost of $1120 to
dispose of charcoal  (including transportation and analytical  costs).  Excluding
the  cost  of  charcoal,  this  amount of  charcoal  could treat about  13000  L of
wastewater at  a  cost  of about  $0.09/L.

Adsorptivity  Assays for Used Charcoal

      Figure  5 gives  the  results  of  the dye test studies.   All  three  dyes
experienced reduced adsorption with increasing trifluralin concentration on the
charcoal.  Compared  to methylene blue  and alizarin red dyes, malachite green dye
adsorption  was not  as  affected  by increasing  amounts  of  trifluralin.   For
trifluralin concentrations less than 200 mg/g, there was little difference in the
amount of  dye adsorbed  compared to the  control.   Trifluralin  concentrations
greater than  200 mg/g  resulted  in greatly diminished  adsorption  of the dyes.
                  mg dy« adaorbod/g
                            100         200         300
                                mg trffILTB!fn/g charcoal
                                                             •400
                      ' malachite groan
                                     'mathylan* blua
                                                    ' at frarln r«d
                   Figure 5.  Adsorption of three  dyes  onto
                         tri fIuralin-amended charcoal.
      These results suggest that  it might  be  feasible  to  use methylene blue or
alizarin red  dye  to assess the  remaining pesticide capacity of charcoal.   A
possible scenario  might have  a  pesticide user  needing to  filter 300  to 500
gallons of wastewater.   Filtration of this waste could take a considerable amount
of time (18 to 24 h).  To test  the remaining adsorptive  capacity of used, but not

                                       92

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necessarily  spent  charcoal,  the  pesticide  user would  take  a  sample  of  charcoal
and add a known amount of dye dissolved in buffer  solution.  If any color remains
in solution  after  shaking  the dye and charcoal  together,  the charcoal  may  not
have the capacity to remove pesticides from pesticide-laden wastewater.   In this
case, the charcoal would be  replaced, saving  the operator  valuable  time by  not
using charcoal with  a diminished  capacity  to  remove pesticides.


CONCLUSIONS

      An activated charcoal filtration unit,  fabricated using readily available
components,  effectively removed  the  pesticides atrazine,  benomyl, carbaryl,
fluometuron, metolachlor, and trifluralin from leftover pesticide solutions  and
rinsates.  Approximately 1500 L of wastewater could be  effectively treated using
23 kg  of Cullar-D activated  charcoal  before replacement  was  necessary.   The
disposal  of  spent   charcoal  via  microbial   degradation   is  still   under
investigation.  Results from an alachlor incubation study suggest that  this  may
represent an alternative to incineration but  more research is required  to fully
determine the treatment's potential.  The ability of methylene blue and  alizarin
red dye to reflect differing amounts of adsorbed trifluralin on charcoal  suggests
that these dyes could potentially be used as  a rapid  test  to  indicate  when  the
capacity of activated charcoal  is  exhausted and,  therefore, when it is necessary
to replace the charcoal filter.


ACKNOWLEDGEMENTS

      The authors  gratefully acknowledge funding  provided by the Cooperative
States Research Service and the Arkansas Water Resources Research Center.   The
laboratory   assistance   of  Mrs.  Michelle   Fitzgerald   is   also  gratefully
acknowledged.
                                      93

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LITERATURE CITED

Dennis, VI.H., Jr.   1988.  A practical system to treat pesticide-laden wastewater.
In  Pesticide Waste Disposal  Technology, J.S.  Bridges  and C.R.  Dempsey  (eds).
Noyes Data Corp.   331 p.

Hassler, J.W.   1974.  Purification with activated carbon.  Chemical Publishing
Co., Inc.  New  York, NY.  390 p.

Humburg, N.E.   1989.  Herbicide Handbook.   Sixth  Edition.  Weed  Sci. Soc. Amer.
Champaign, IL.  310 p.

Jury, W.A.,  Winer,  A.M.,  Spencer,  W.F.,  and  D.D. Focht.   1987.   Transport and
transformations of organic chemicals  in  the  soil-air-water  ecosystem.   Rev.
Environ. Contam. Toxicol.  99:119-164.

Kilbane, J.J., Chatterjee, O.K.,  and A.M. Chakrabarty.  1983.   Detoxification of
2,4,5-trichlorophenoyacetic acid from contaminated soil by Pseudomonas cepacia.
Appl. Environ.  Microbiol.  45(5):1697-1700.

Miller, M.E.  and  M. Alexander.   1991.   Kinetics of  bacterial  degradation of
benzylamine  in  a  montmorillonite suspension.    Environ.    Sci.    Technol.
25(2):240-245.

Mullins, D.E.,  Young,  R.W.,  Palmer,  C.P.,  Hamilton, R.L. and  P.C.  Sherertz.
1989.  Disposal of concentrated  solutions of diazinon using organic absorption
and chemical and microbial degradation.  Pestic. Sci.  25:241-254.

Nye, J.C.    1988.    Physical  treatment  options:   Removal  of  chemicals from
wastewater by adsorption,  filtration,  and/or coagulation.  In Pesticide Waste
Disposal Technology. J.S. Bridges and C.R. Dempsey (eds).  Noyes Data Corp.
331 p.

Perrotti,  A.E.  and  C.A.  Rodman.   1974.    Factors  involved with  biological
regeneration of activated charcoal.  AIChE Symposium Series 144 vol.70,  p. 316-
325.

Somich, C.J., Muldoon,  M.T.,  and  P.C.  Kearney.   1990.   On-site  treatment of
pesticide waste and rinsate using ozone and biologically active  soil.  Environ.
Sci. Technol.   24(5):745-749.

Wolf, D.C.  and J.O. Legg.   1984.   Soil  microbiology.  In Isotopes and Radiation
in  Agricultural  Sciences, M.F.  L'Annunziata  and J.O.  Legg,   (eds).   Academic
Press,  New York.  p.100-139.

Zanitsch, R.H. and M.H.  Stenzel.   1978.   Economics of granular activated carbon
water and wastewater  treatment systems.  In  Carbon  Adsorption  Handbook. P.N.
Cherermisinoff  and F. Ellerbusch,  (eds). p. 215-239.
                                      94

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              Preliminary Studies of Batch Chemical  Oxidation of
                     Wastewaters Containing Agrichemicals

                                      By

                      Claude E.  Breed and Michael C. Crim
                          Tennessee Valley Authority
              National  Fertilizer & Environmental  Research  Center
                        Chemical  Development Department
                       Muscle Shoals,  Alabama  35660-1010
 ABSTRACT
       The  increased use of containment in  the agribusiness industry has resulted
 in  improved control  of contaminated wastewater  but has also  resulted in  an
 accumulation  of wastewater  that  contains agrichemicals  and  cannot  be  easily
 recycled or reused.   TVA  is  currently investigating  chemical  oxidation  methods
 to decontaminate this wastewater.  The major objective of the investigations  have
 been to develop procedures that can  be carried out onsite using existing  process
 equipment.  One approach  tested was the use of strong acids  and  air  sparging.
 This resulted  in air  stripping  of the volatile compounds  and  little oxidation.
 A  second  approach  has been  to use  hydrogen  peroxide  in  the  presence of  a
 catalyst. This method has  resulted in a high level of destruction of the original
 agrichemical but only about  80  percent  destruction of the total  organic  carbon
 (TOC)  present.  Future  test  work will be  directed toward  identification  of the
 remaining  TOC  and developing  procedures to oxidize it.


       TVA's  National   Fertilizer  &  Environmental  Research  Center  (NFERC)  is
 actively engaged in environmental research work as part  of its ongoing mission,
 especially  as  it relates  to  environmental  issues and  problems  which have  an
 impact on fertilizer manufacturers,  dealers,  and users.   One such  problem faces
 more than 3,000 small  dealers who custom mix fertilizers  and pesticides for  sale
 to local farmers.  After a dealer prepares a custom mix  and transfers  it  to the
 farmer,  he often  rinses  his  storage  and mixing  equipment   so  as  to avoid
 contamination of the next  mix.  This results in a volume of rinse water  (rinsate)
 containing  a low-level  pesticide contamination.  Additional  contaminated water
 results from external  equipment wash down and spills during transfer or storage.
 In the  past, dealers  generally disposed of the  contaminated  water on his  own
 site,  and  this resulted in localized soil or  ground water  contamination  from
 repeated disposal.  Currently,  the  main alternatives open for a dealer  are  to
 field apply the contaminated water,  reuse  it  in formulations of similar blends,
 or in  the  worst case,  to  pay a waste disposal  company to remove and  treat  the
waste rinsate.

      NFERC  initiated  an  applied  research  project  with a  narrow  focus  to
determine  if a simplified, cost-effective method of destroying  (or  removing)
pesticides  in  rinsate  solutions could be  developed.   A  major  objective was  to
make the  method  simple enough  that it  could  be carried  out  using process
equipment commonly available to the mix dealers.  A secondary objective was  to
tailor the  decontamination process in such  a way that the decontaminated solution
could be recycled, thus allowing the dealers to avoid the problems (and costs)
associated with effluent monitoring and reporting.


                                      95

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      The work was done in two main phases, the first being to test the use of
strong acids/heat/air to oxidize the  pesticides.   This  work was  followed by a
study of the use of chemicals and heat to oxidize the materials.

Strong Acids/Heat/Air Oxidation

      The initial research test work focused on the possibility of using strong
acids, such  as  phosphoric,  sulfuric,  or nitric,  to  catalyze  the  oxidation of
pesticides by air  in  a  batch system.   This idea was  appealing  because of the
unique operating and  marketing  position of the fertilizer  dealers.   A dealer
would be able to take the process by-product solution, which now contains acid
from the decontamination process,  and  convert  it to a usable fertilizer product
by ammoniation.   In this way, the dealer could  substantially  recover the cost of
the acid.  Potentially,  the  ammoniated acid  solution could be used for blending
with other solutions or, if adjusted to a standard grade, sold directly to the
customer.

      The test work was  performed using  synthetic waste rinsates containing one
of four commonly used  herbicides:  trifluralin, alachlor, metolachlor, and 2,40
amine.  All  synthetic rinsates  used in the testing were produced  by adding a
commercial-grade herbicide solution  directly to tap water.  The concentration of
the active ingredient  was  standardized to a  level of  1,500 parts per million, a
level that is considered to be at the upper end of the  range for dealer rinsates.
Since all  of the commercial herbicides  that  were tested,   except  2,40 amine,
contained an organic solvent, the concentration of total organic matter in the
synthetic rinsates varied among the different test pesticides.

      Tests were made  using each of the three strong acids  (phosphoric, sulfuric,
and nitric)  added directly to the synthetic rinsates. Combinations of these acids
were also tested.  The test equipment was arranged so that the acid-dosed rinsate
could be pumped  to a  venturi mixer  and  returned  to the  batch  holder.   Air was
injected into the venturi to produce  a  turbulent contact between the two streams.
Most of the  oxidation was expected  to  come  from  the  oxygen  in the air, rather
than donation of oxygen  from the acid.  Test solutions were heated to accelerate
the rate of oxidation.  Test temperatures ranged from a low of 140«F up to a high
of about  190»F.   Also included as  part  of the test work was the  addition of
soluble trace metals,  as suggested by  the literature, to act as catalysts.  The
catalytic metals were generally limited to  those  metals that  are  innocuous in
fertilizer solutions or are micronutrients, such as copper or iron.

      The results of these tests were generally disappointing.  In most cases,
the test herbicides were simply removed by  air stripping  in the  venturi.  The
least volatile herbicide, 2,40 amine, was essentially  unaffected in these tests.
Some attempts were made  to set  up new  equipment arrangements that would utilize
fixed-bed catalysts, instead of soluble catalysts.  However,  it was soon realized
that any such scheme would violate a core objective of the project—simplicity.
These  efforts  did,  however,  lead  to  the generation  of  an idea  involving
three-phase  batch oxidation.

Chemical/Heat Oxidation

      The second phase of the bench-scale work involved the use of chemicals and
heat to oxidize  pesticide contaminates.  Two  separate approaches were tested, the
first utilized a phosphoric acid, Mn02, and the second, Fenton's reagent  (ferrous
ions in presence of peroxide). Results of these tests were encouraging.

                                      96

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       Phosphoric Acid -  Mn02  Slurry:   With  this  method,  a  solid,  relatively
 insoluble  catalyst,  manganese dioxide, was  slurried  by an agitator  in  a  2,4D
 amine  rinsate  solution to which phosphoric acid had been added.  The key to the
 system was  to  operate the agitator at a sufficiently high rotational speed  that
 a deep vortex was produced.   This  created an  intense three-phase mixing zone for
 the  air, manganese dioxide,  and rinsate solution to come  in  contact  with  each
 other.  This method  was  able to effectively  oxidize all  of the test pesticide,
 2,4D amine, within detection limits (about  10 ppm).  However, about a quarter of
 the  original organic matter remained, as measured by a standard laboratory test,
 total  organic  carbon (TOC).   Since the 2,4D  amine herbicide  solution contains
 only water  as a solvent,  it  is  assumed that the remaining organic matter existed
 as fragments of the original  herbicide.  No attempt has been made to identify the
 fragment compounds to date.    However,  it  is clear from the total  quantity  of
 oxidation that took place, that the molecular bonds in  the  chlorinated aromatic
 rings  of  2,4D amine were broken.   This was  considered  a  major hurdle  in  the
 oxidation chemistry since these bonds are considered to be particularly oxidation
 resistant.

      A major  drawback of this method  is the potential  energy  cost.  During  the
 lab  experiments, nearly all of the water in the solution  is evaporated due to the
 large volume of air pulled into the solution  by the agitator.  This is also due,
 in  part,  to the high operating  temperature,  230°F,  needed  for oxidation  to
 proceed.  (Note:  The presence of phosphoric  acid  elevates  the boiling point  of
 the  solution to  well above  230°F.)  A second drawback  to  this method  is that
 those pesticides which are relatively volatile are  likely to be evaporated before
 oxidation can  take place.  This  would  probably mean that the  off-gas  from the
 process would  have to be treated in  some manner,  perhaps by incineration  or
 activated carbon recovery.   Both  of these methods would complicate  the process
 beyond the  desired objective.

      Fenton's Reagent:   A method of liquid  phase oxidation that is commonly used
 in laboratory analytical  chemistry is Fenton's reagent.  This reagent, discovered
 during the late 19th century,  is a mixture of ferrous ions and  hydrogen peroxide
 that was observed  to  have enhanced  ability to oxidize organic compounds.  The
 basis for this  property  is the  initial reaction of peroxide  with ferrous ions  to
 form ferric ions  and hydroxyl radicals.  The hydroxyl radicals react readily with
 organic  hydrogen  by  attacking carbon-hydrogen  bonds.   This attack  in turn
 facilitates direct oxidation  of  the  organic  compound  by  reaction  with free
 hydrogen peroxide.

      Potentially, an adaptation of Fenton's  reagent could  meet all  the project
 objectives.  It  is simple enough to be applied  in a single  tank batch.  The
 oxidant,   hydrogen  peroxide,   is  relatively   inexpensive  compared  with other
 chemical  oxidants.  Furthermore,  if the decontaminated solution is used  in the
 preparation of fertilizer mixes,  then the  catalyst,  ferrous ion,  becomes a
 fertilizer micronutrient.  Additionally, commercial sources of ferrous ion are
 available in which the  associated cationic  species is  also a nutrient  (e.g.,
 ferrous sulfate).  Finally,  since  the literature suggests that  Fenton's reagent
 is more active  under conditions of acidic pH,  strong acids,  such as phosphoric,
can be used that add nutrient  value to  the solution.

      Test work was initiated to determine the parameter effects and  the overall
effectiveness of Fenton's reagent when  applied to synthetic rinsate solutions.
The herbicide 2,4D  amine was again selected  for the initial series of tests.  All
test work was done  using synthetic rinsates containing  about 1,500  ppm  by weight

                                      97

-------
2,4D amine.   Ferrous  sulfate  heptahydrate  was  chosen  as  the source of ferrous
ions.  Phosphoric acid was used  to  adjust  the  pH  of the  test solutions in the
acid range, and potassium hydroxide was  used for  the  basic range.   Tests were
made using mild agitation and temperatures ranging  from 120 to 180«F.  Laboratory
grade 30% hydrogen peroxide solution was used in all tests.

      Early  tests  focused  on determining  the overall  effectiveness of the
Fenton's reagent method.   Tests in which a large quantity of peroxide was used
(about 16 times the stoichiometric quantity needed to oxidize all of the organic
matter) and with  a high temperature (180«F)  produced very  good results.  As much
as 86% of  the organic matter was oxidized  in  one of the tests.   None of the
original   2,4D  amine  pesticide,  within  detectable  limits,  remained  after
oxidation.   In these  early  tests,  ferrous  ion content and  pH were studied to
determine parameter effects.  Both parameters exhibited plateau-shaped curves.
Organic  destruction   increased  with  increasing  ferrous   sulfate  heptahydrate
addition up to a level of about 7  grams per liter, above which no further benefit
was found. Similarly, organic destruction increased with  increasing pH up to a
level of around pH of 4, above which  the effect was generally flat, even  into the
basic range.  This seemed to  be  somewhat contradictory to literature sources,
which suggested that acidic conditions  were  beneficial, and that a maximum effect
in most cases  might  be expected  near  a pH of 3.5.  However,  based  on the test
results,  pH  adjustment was  eliminated in  subsequent testing.   (Since ferrous
sulfate is slightly acidic,  the unadjusted  test  solutions  have an initial pH of
about 5.)

      The  follow-up  test work with  the Fenton's  reagent has focused  on two
related objectives:   (1)  increasing  the  percentage of total  organic matter that
is oxidized  during the  process, and  (2)  reducing  the  quantity  of hydrogen
peroxide required by  the process.   The  first  objective,  increasing oxidation
percentage,  has  not   been  achieved  in  subsequent tests.   It appears that  a
destruction level of 85 to 88% was a barrier for Fenton's reagent when applied
to 2,4D  amine.   Longer  retention  times,  and  even repeated  applications  of
Fenton's reagent to the same solution, were unable to increase the quantity of
organic matter destroyed.  It  appears that in future tests of 2,4D amine and all
other  pesticides which  exhibit  similar  oxidation resistance,  the  organic
compounds  which  remain  after  oxidation  must  be  identified by  qualitative
analysis.  If these compounds are  innocuous, then the decontaminated  solution may
be reuseable as make-up water for fresh fertilizer/pesticide mixes.   If not, then
clearly,  additional  treatment steps will  be required.   At  this point in the
research work, this is a major problem to be identified.

      Modest  improvements were made during the  study  of  the second objective,
reducing hydrogen  peroxide usage.   By adding  a  small  amount of  copper (II)
sulfate to the solution as  a  supplemental catalyst,  the hydrogen peroxide usage
was cut in half, from 16 times stoichiometric to 8 times  stoichiometric, while
still maintaining the maximum organic  destruction  level of 85 to 88%.   In terms
of commercial scale volumes,  the  quantity of 30% hydrogen  peroxide solution was
lowered from  23 gallons per 100 gallons of rinsate to 11.5 gallons.

      A further reduction of  hydrogen  peroxide  is desirable.  In a commercial
process, the cost of  hydrogen  peroxide will  be the major operating cost.  At the
minimum  peroxide  requirement   stated   above,   the  peroxide  cost  will  be
approximately $32 per 100 gallons of rinsate.
                                      98

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Conclusions from Preliminary Test Work

      The  results  of  this  preliminary  test  work has  shown the  use  for a
simplified  approach  to  the onsite  treatment of  contaminated  rinsewater is
feasible.   Depending  on the composition  of some  of  the  residual  degradation
compounds, the proposed process  based on Fenton's reagent appears  to be  the most
promising approach tested to date.  Other treatment schemes will  be considered
in future work and the most attractive process will be carried to pilot and/or
demonstration scale.
                                      99

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by varying the temperature and/or the pressure such that the density of the fluid
can approach that of typical liquid solvents.  For example, at 50oC  and 68 bar
(1000 psi) C02 has a density of 0.2 g/mL, at 120 bar (1760 psi) the  density  is
0.6 g/mL,  ana  at 214 bar (3150  psi)  the density is 0.8  g/mL.   If  a constant
temperature is maintained and the pressure is increased  sufficiently the density
will approach  the liquid density.  The density of liquid  C02 is 1.101 at -37oC
(1).  At its critical point (Tc  =  31°C,  PC = 73 bar) C02 has a density of 0.46
g/mL (3).

      The unique characteristic of  supercritical fluid extraction (SCFE)  is that
an SCF remains in  a gaseous state and as  such  can  penetrate the  interstitial
spaces of solid materials much more readily than liquids.  This allows the SCF
to make intimate contact with any substance that is sorbed to  the solid material
and facilitates the  removal of contaminating materials.  Figure 2 shows the self-
diffusivity of C02 over a wide temperature-pressure range and, for comparative
purposes, the range  of diffusivities for  solutes in organic liquids  ((average  of
about 10"5 cm2/sec (4)).  With changes in  temperature and  pressure  an  SCF can  be
tailored to extract  substances that are difficult, if not impossible, to separate
by other means.   Supercritical  C02 is a nonpolar solvent, and  a  good rule  of
thumb is that most compounds that are  soluble  in  hexane will  also be  soluble  in
supercritical  C02.   However, the extraction  characteristics  may be  changed  to
make the extraction  fluid  more polar by adding  enhancers  such  as methanol   or
acetone to the system.

      Another  interesting characteristic of SCFs  is  that  shown in Figure 3 (5).
The figure shows the solubility  of  naphthalene (wt. %) in  supercritical C02 with
varying temperature  and constant pressures.   The diagram  shows  that at lower
pressures the solubility increases  with increasing temperature but  at  some point
the solubility begins to decrease with an increase  in temperature.  However,  at
about 150 atmospheres and higher,  the solubility continues to increase with  an
increase in  temperature.    If  the  temperature is  increased  sufficiently,  the
solubility will  probably again  begin  to decrease.   This is because  the  SCF
becomes more  like  a gas than  a  liquid and,  as such,  has  much  less solvating
power.   The dashed line  represents  the solubility of naphthalene in liquid C02.
Figure 4 (6)  shows similar behavior for the solubility  of Si02 in water, and  it
is suspected that this   behavior will exist for all solutes in SCFs.

      The following equation of state was taken from an English translation  of
the Russian text Thermophysical Properties of Carbon Dioxide (7).

The expanded form of the equation  of state for gaseous C02 may be  written  as:

      PV/RT =  1 + (Bd  + Cd2 +  Dd3  + Ed4  + Fd6 + Gd8)  where

      B = 0.486590(i+97/96+T)~[(l.90843+5.351ea)A]-(0.079526/T8)

      C = 2.39169-[(6.9619-12.1824ea)/-r] + (6.86903/T2)-(3.34265/i3)

      D = -1.69007+[(10.2469-6.38963ea)A]-(14.7337/T2) + (7.32711/-u3)

      E1  =  8.69339-(16.9642/t)+(8.92312/T3)

      E2  =  -2.40368+(6.61817/t)+(9.92898/T2)-(36.4789/T3)+(22.0167A4)

      F,  =  -37.3064+(102.476/T-6737594A2)

                                      101

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      Wt. % in soil

      Wt. % in soil
                        Atrazine    Alachlor
            3.6
                        8.9
Bentazon

   11.9
Permethrin

   10.2
after ext.
Wt. % removed
0.06
98.3
0.18
97.9
0.59
95.0
0.21
97.9
      The use of  SCFE  in remediating sites contaminated  with  various organic
compounds  is currently  under  consideration   by   EPA's  Superfund  Innovative
Technology Evaluation  (SITE)  program.   Other laboratories  (outside  TVA)  have
indicated that
and  toxaphene
from  contaminated  soils,
that no difference  in overall
from dry soil and wet soil.
supercritical  C02  readily  extracts  compounds  such as PCBs,  DDT,
                            Initial  work  by  Brady  et  al.  (9)
                         of 70-90%  for these compounds and found
              extractability existed between contaminant removal
demonstrated C02 extraction efficiencies
CONCLUSIONS

      SCFE should be applicable to  remediation of contaminated soil.  There are
both advantages and disadvantages  to  using  supercritical  C02.   The advantages
include:  1)  CO, is non-polluting, 2) C02 is  relatively inexpensive, 3) material
can be recycled*^ if enough is extracted,  and  4) it should be possible to build a
portable unit that can  be  moved  from  site  to site  without problems associated
with  interstate  regulations because  no hazardous  materials  are transported.
Disadvantages include:  1)  relatively high pressures needed, 2) all contaminants
may not be extracted with one set of conditions,  and 3) the contaminants are not
destroyed.   However,  because  the  volume of contaminated material  is reduced
considerably, a small  secondary treatment unit such  as incineration, ultraviolet
ozonation, or chemical reduction could be added to the system.   Incineration may
be the most readily adaptable, if local regulations do not prohibit it.
                                      104

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REFERENCES
1.    Hannay, J.  B.  and  J.  Hogarth,  "On the Solubility of Solids  in
      Gases," Proc. R. Soc. London,  1879, 29, 324.
2.    CRC Handbook of Chemistry and  Physics, 67th Ed,  1986-1987.
3.    Perry's Handbook for Chemical  Engineers, 5th Ed.
4.    Paulaitis,  M.  E.,   Krukronis,  V.  J.,  Kurnik,  R. T.,  and  Reid,  R. C.,
      "Supercritical Fluid Extraction," 1983a,  Ber. Bunsenges.  Phys. Chem., 88,
      869.
5.    Modell,  M.,  Robey,  V.   J.,  Krukonis,  V.  J.,  de  Fillipi,  R.   D., and
      Oestereich, D., "Supercritical  Fluid  Regeneration of Activated Carbon."
      Paper presented at the National  AIChE Meeting, Boston, MA,  1979.
6.    Kennedy, G. C.,  "A  Portion of the System Silica-Water,"  Econ.  Geol.,  1950,
      45, 629.
7.    Vulkalovich, M.  P.  and Altunin, V. V.,  Thermophysical Properties  of Carbon
      Dioxide,  translation  edited  by  Dr. D.  S.  Gaunt, Kings  College  London,
      published by London & Wellington,  1968.
8.    Viorica  Lopez-Avila and  N.   S.  Dodhiwala,  Journal of  Chromatographic
      Science,   "Supercritical   Fluid   Extraction  and   Its   Application  to
      Environmental Analysis,"  1990,  28, 468-476.
9.    Brady et  al.,  "Supercritical  Extraction of Toxic Organics from  Soils,"
      Ind. Eng. Chem. Res., 1987, 26,  261-268.
                                      105

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                                                                                                        X)

-------

-------

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details in multiple sizes.   Kammel  and  O'Neil  (1990)  reported on a farm sized
concrete loading pad that meets many small facility needs.


STANDARDIZED MODULAR CONCRETE PAD DESIGN

      Modular concrete mixing/loading/storage containment pad designs are needed
to fit individual operator requirements.  Standardized pad designs can be used
by aerial  and ground pesticide applicators using 1,100 to 1,900 liter (300-500
gallon) rinsate  tanks, pesticide mini-bulk  or small  volume  returnable (SVR)
containers,  non-returnable  containers,  and  a  range  of  pesticide or  liquid
fertilizer bulk tank sizes.


DESIGN OBJECTIVES

Modular design objectives are to:

1.    Develop a simple, modular concrete pad design suitable for mixing/loading
      and rinsing aerial or ground pesticide and liquid fertilizer sprayers.

2.    Develop watertight reinforced concrete specifications to resist ground and
      weather stress,  and chemical or mechanical damage.

3.    Design shallow watertight sumps that can  resist ground and weather stress
      cracks, and can  be easily cleaned.

4.    Provide secondary containment  for pesticide  and  liquid fertilizer leaks
      and spills.

5.    Incorporate areas for pesticide and liquid fertilizer and rinsate storage,
      handling, mixing, transfer, recovery,  and disposal.


FUNCTIONAL PAD LAYOUT  AND USE

      Agrichemical  facility  management functions should be  the first  item
addressed in  planning  new or remodeled  facilities areas  and functions should
include the following:

•  Chemical Storage     •  Mixing/Loading       •  Secondary Containment
•  Loading Pad          •  Worker Safety        •  Rinsate/Waste Disposal
•  Pesticide Security    •  Storm Water  Control   •  Tanking Mounting/Plumbing


Chemical  Storage

      Pesticides  should be   stored  in  a  building  for protection  from theft,
vandalism, temperature extremes and  unauthorized personnel.  It should be used
only  for  pesticides  and be  isolated  from  other buildings.    Warning signs
indicating dangerous toxic materials must be posted outside by all building or
fence entrances.  Buildings should be ventilated to prevent an accumulation of
toxic fumes.  Figure  1  shows  the arrangement of functional  areas in a farm or
small business-sized pesticide  facility.  Figures  2  and 3 illustrate plan and
cross section details  of this same facility.   Specifications for  a  small  storage

                                      112

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 bui 1 a i "iq  d,'-.> ^
               '•'
                                                              i;': i o n . i iduiu can be used
                                                                j1 >;;• .  '- ;fci  to  transfer
                                                                '  :r'=    1' (Q   1}  or in
                                                                 1 • ;;r,-:if:r pumps  should
                                                                    ', '  .V! n'ixinq tanks
                                                                   . ' - ••••v.-nt.   provides
                                                                 ,• ••-•• 'c "'oading areas.
>' •» i : i : .<• e r
or'  pest.c : i ,
t>on?  1 e.-.t.h .
f er* i ' ~;2fir
                                                                  !.ito three
                                                                          icid? mixing,
                                                                           HXi covered,
                                                                           sir^age tank
                                                                          r -vtorn. plus
hd-i  d  SCUf" ''">•'""  .ii S'd 'I 1 •:;'.(,   ri
tank r i'Vi -4 if;  ; s ,/:;H\!  4 • -  .-,
Sprayer eu1: i'.'>.r •:  n. .,••((.-.,'-,•,•,•. c -;
COMed 't-.jf";  0>- u?ip>  f-u.,; ;;
surf axe '<-. •-.!':?.) t-u  *:o  ^  .^h-i < :c-v.
spiiis,  w.iLi.'i  ru,.;' '/'"• :.;.,",   '
U50  -J S "••', -'(.  ,  '•„..!..""'"  '.   '      '
                                                             ••'. us^o' to park  equipment
                                                             .r'x^r facility, (Figure 4)
                                                             es.   Sprayer plumbing and
                                                              I  - p«  containment  area.
                                                              hi;  a ine  on this area to
                                                               iHp curbec concrete pad
                                                              ..-v-;v; ^ater from leaks or
                                                             ' '  i'.*.: .,f,o^;;qe  tanks for
       A s'oi'^t*  i«t*.;y  .J/'^-!
first- aid tu  v.'orkers.   An e'
cherpif.a's f ro^ the eys.s,  ^-.,,
a/ara for MaerrjGiicy  et^si^in
be easily .-;;:( ^^s ihlt? to '!e^
safety  data  >»!e..n/>  (MSDS/ '
posted   -':;;f - ;;
c. tonne •-!,?' of or N,-  Icirn:.
                                 o>-
    u'iq p.{\: innr-,"!. Mviuid oe equipped  for
              should  be provided to rinse
              equipment should trigger an
.•1-1 ?r-o  -.^piil  iespon:,e  kits  should also
c._(. i'lf-i-ts or. .-> ••,)';•!?]v marine-•".   Material
;  '\::,  .,?.<;»•-o  .i:  i:'-3  facility  should  be
 .•').;"'•-.:•  »r  emergency   sise.    A  fire
                ^i  L".«i  oocitioned outside

-------
Rinsate/Waste Disposal

      Rinsate is segregated by crop  or  pesticide and reused on the target crop,
eliminating disposal  as  hazardous  waste.   If  the loading pad  is  not roofed,
rainwater falling on the pad is collected and stored for future use,  if there has
been a spill.   If the pad is clean, rainwater may be pumped  off  the  pad.   To
eliminate contaminated  solids disposal  problems,  exterior washing of ground
applicators  should be done  at  the  application  site  immediately  after  each
operation.

Pesticide Security

      Chemical and rinsate storage containment  areas should be secured by heavy
chain-link fencing  (Figure 4) or be inside a locked building.  Fencing mounted
flush with the outer containment  wall should be at least 1.8 meters (6 feet) of
combined height.  Fencing not flush wall  mounted (with a concrete ledge) should
extend 1.8 meters  (6  feet)  above concrete walls.  Containment  section widths
(Figures  4  and  8)  can be  sized  for the  installation   of   pesticide storage
buildings, such  as the OSU  (1983)  pesticide  building,  Midwest  Plans Service
(1979) storage building or other suitable structures.

      Empty disposable containers should be  stored on a covered, curbed area to
prevent rain entry  into  containers or  leaks from  containers  contaminating the
soil.  Empty minibulk  or Small Volume Returnable (SVR) containers should also be
stored in this area.

Storm Water Control

      Divider walls separating loading from containment areas, Figures  5, 6, and
7, have no openings.  Spills, leakage,  or stored rinsate can not be discharged
into surface water channels without pumping.  Sumps should  be formed using coned
bottom cylindrical stainless  steel sump liners  cast in-place with the liner used
as the inside concrete form for ease of cleanout.

Tank Mounting and Plumbing

       Rinsate tanks should be elevated at least 8-15 centimeters (3-6 inches)
above concrete floors for quick leak  identification.  Tanks must be anchored to
prevent overturning and plumbed with  flexible hoses between tanks to avoid pipe
ruptures from floatation of partially filled,  improperly anchored tanks during
major leakage events or rain  storms.  Transfer  hoses should be  marked by crop or
chemical  for positive  I.D. of tank and product to eliminate cross-contamination.


LIQUID FERTILIZER CONTAINMENT

      The major problem in designing containment sections is determining the best
combination of  containment  area and wall height  (CVD +  liquid  freeboard) to
provide the 125% of volume of the largest tank.  The area  displaced  by all tanks,
including the area  of the  largest tank,  plus  any  equipment in the containment
area must be added  to the net fluid volume that can be released by the largest
tank when the  liquid  level  stabilizes.  The volume of  fluid  remaining in the
largest tank at the liquid level  equilibrium height must be subtracted  from the
total tank volume  in  the computation, Equation 1.


                                      114

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       The  containment  holding volume should be designed to provide a minimum of
 "125% of  largest tank"  for pesticide,  rinsate,  or  liquid  fertilizer  tank
 containment to provide inches of liquid level  freeboard.  Rinsate tank management
 systems  normally  are operated with 3 to 6 tanks ranging from 300 to 500 gallons
 each.  If small to moderate sized liquid fertilizer tanks,  ranging from 5,000 to
 25,000 gallons  are planned  for use  with  this pad design,  containment  section
 widths and sidewall  heights  need  to be sized to accommodate the  required  125%
 volume of  largest tank.  Some states use 110% of largest tank plus a 6" rain as
 their containment volume regulation  design.

       The  use of very large liquid  tanks (50,000 - 1,000,000 gallons) is outside
 the scope  of this paper. These tanks require  development of special  containment
 pads  and foundations due to their size.  They may be incorporated into the  main
 concrete pad containment,  or  be designed as individual structures with their own
 containment areas separate  from the wash pad and pesticide tank containment area.
 Design guidance by Midwest Plan Service (1983) for  circular concrete  tanks may
 be helpful for large tank  foundation designs.

       Some state  laws  allow  non-concrete  containment designs for  large  liquid
 fertilizer tank installations.  One design uses flexible liners,  either a 36 or
 45 mil thickness DuPont Hypalon,  laid on a sand sub-base with 6  inches of clean
 smooth washed river run gravel  as   ballast.   Liners  are  placed over soil  berms,
 concrete outer  walls  (padded  on  the inside),  or  special  composite  plastic
 structural walls.   Some states allow  compacted  clay or other impervious  soil
 lined  containment; the risk  of having  to  dispose of contaminated soil after a
 leak or  spill makes this option a high risk.

       NOTE: The total containment volume must  be reduced bv the volumes  displaced
 by tanks and equipment  that take UP containment space.  Pesticide  rinsate  should
 not be stored in the same containment section with fertilizers. Fertilizers  must
 not be stored 1n  the same containment section with  full  strength  pesticides. BY
 LAW!


 DESIGN LAYOUT CONSIDERATIONS

       NOTE!  It is extremely Important to do scale drawing layout of the  area
with the tanks drawn to scale in position,  as  the 125% of largest tank provides
minimum area when depths of 3 ft.  or more or used.

       Functional  Layout Questions:

       (1)   Is there adequate space for present and future tanks plus mixing and
            transfer equipment in  the proposed containment  area?
       (2)   Will   the   area  be  adequate  for  potential  growth  and  can  small
            existing tanks  be replaced by larger tanks in the future?
       (3)   From  a safety standpoint,  can  workers move between tanks with hoses
            and move over  containment walls without undue risk or hazards?
       (4)   Will  safety steps and handrails be required  to move over walls,  and
            if so, will this  be a  continual problem for workers, especially in
            icy weather?
       (5)   Can  all outside  surfaces of  all  tanks  be  visually  inspected   for
            corrosion,  damage and  potential leaks?
       (6)   Are  tanks  securely anchored  individually  or  braced  together to
            prevent floatation,  tipping over, and damage to other tanks.

                                      115

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      (7)   Are tanks plumbed  individually or with flexible plumbing connections
            to avoid plumbing  damage and multiple leaks from  tank floatation (No
            rigid pipe manifolds connecting tanks).

      These questions  should  all  be  answered "YES" when the  layout  design is
checked  for  tank fit  and  completed  and  the  wash/containment layout  plan is
submitted to the appropriate state regulatory agency.

      In general, a 30 to 36 inch  containment  section  depth  (27-33 inch CVD + 3
inch freeboard) appears  to  be  the  most  practical,  although  it may be slightly
more expensive than  a  deeper  section.   If a  deeper section is selected, "wide
steps on both  sides  of  the wall at security fence gate  openings  must be provided
for personnel  safety, comfort, and convenience,

      Table 5 gives  volume  data  tank  sizes from 5 ft.  to 15  ft.  diameter for
heights to 20 ft.  Volume for additional heights can be  computed by selecting the
volume at the additional  incremental depths used  for heights  above maximum table
values  and  adding  the two  values   together,    Tank  base areas are  needed in
computing the total  tank area displaced.
CONTAINMENT VOLUME SIZING

      Containment volume  and  liquid freeboard  must  provide at least  125% of
volume of  the  largest  tank.    The area  displaced by  other  tanks,  plus  any
equipment  in  the containment area  must  be aaded  to  the net  secondary fluid
containment volume (SCV) that can be released by  the largest tank when the liquid
level stabilizes.

      The secondary containment  volume can be computed for 125% of the largest
tank by using Equation 1:
EQUATION 1.
    SCV = LTV x 1.25 + TBV  (METRIC) or SCV
                1000
                                              LTV x 1.25 + TBV (ENGLISH)
                                                    7.5
EQUATION 2:

    CFA « SCV/CVD

      Where:

      SCV   =
      LTV   =
      CFA   =
      CVD   =

      1.25  =
      1000  =
      [7.5] =
      TBV   =
                  Secondary Containment Volume, Cubic Meters.  [Cubic Feet]
                  Largest Tank Volume, Liters [Gallons]
                  Total Containment Floor Area, Square Meters.  [Square Feet]
                  Containment Volume Depth, meters [Ft.] (Total  Average
                  Liquid Depth Plus Freeboard Depth)
                  125% of Largest Tank Leakage (Provides Freeboard)
                  Liters of Liquid per Cubic meter
                  [Gallons of Liquid per Cubic foot]
                  Sum of Tank Base Volumes, Cubic Meters [Cubic Feet] (Does
                  not Include Largest Tank as Some Liquid Remains in the
                  Tank.)

                                      116

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       NOTE:   The  volume  of fluid remaining in the largest tank at the  liquid
 level  equilibrium  height  must be subtracted from the total tank volume  in the
 computation.  The total  containment volume must include the volumes  displaced bv
 tanks  and equipment that  take up  containment space.  Once  the approximate wall
 height  or depth  of the  containment  section  is  selected, and  the  secondary
 containment volume  (SCV)  is determined, the floor area can be calculated.  The
 total  containment  floor area  (CFA)  is computed from Equation 2.

       For states  that  use  100%  of largest  tank plus a  24 hour 25-year storm
 instead of 125% of the largest tank, use 1.00 (100%) in place  of  1.25 (125%) and
 add the predicted volume of water that falls  on  the  containment area.  REMEMBER:
 All tank bases displace water, so a 6  inch rainfall may raise containment level
 by 9-12 inches, if 25% to 50% of  the volume is taken up  by tanks.

       EXAMPLE:  A  liquid  fertilizer dealer has 2 - 12 ft.  x 20 ft., 3  -  10 ft.
 x 15 ft.,  and 2 - 9 ft.  x  15 ft.  vertical storage tanks that must be contained.
 He is  concerned with building an  economical containment  section as  part  of his
 new applicator load pad and his bulk truck unloading safety pad.   He  is  trying
 to decide between  a 3  ft. 3  in.  and  a  4 ft.  3  in.  containment  depth.  These
 depths will provide  a  3  inch  freeboard depth  plus  average containment  volume
 depth  (CVD).

      He first needs to calculate the Net Containment Volume, NCV for each  of the
 two containment section depths, Table 7.

 For 3 ft., NCV = (LTV - GPF x CVD) x 1.25 = (16.690 - 848  x 3) x 1.25  -
                        7.5                         7.5

               - (16.960  - 2.544)  x 1.25 = 2,402 cu. ft.
                        7.5

At 3 ft.  depth, the floor area
     covered by the leaking liquid = 2,402/3 = 801 sq. ft.
For 4 ft.,

   NCV = (16.960 - 848 x 4) x 1.25 - H6.960 - 3.392) x 1.25 - 2,261 cu. ft
                7.5                         7.5

      At 4 ft. depth, the floor area covered by - 2,261/4 = 565 sq. ft.


      Equipment  area or  displacement  volume of  transfer  pumps  is  usually
insignificant and will be  ignored  in  this  example.   If large mixing tanks and
transfer tanks or pesticide rinsate containment  tanks  are  to be placed in the
containment area, their displacement area and volume must be included.

      The floor area displaced by all  tanks, including the "leaking" tank is 2
x 113.1 (12 ft.  tanks) +  3 x  78.5 (10 ft.  tanks) +  2  x 63.6 (  9 ft.  tanks) -
226.2 + 235.5  + 127.2 = 588.9 or  589 sq. ft.   The total containment  section floor
area  for  a 3  ft.  depth  - total  liquid  displacement area  + total  tank  and
equipment area = 801 + 589 = 1,390 sq.  ft.   For the 4 ft. depth, the total area
= 565 + 589 = 1,154 sq.  ft.  A  23 ft.  x  60 ft.  or 28 ft. x 50  ft area would

                                      117

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      Competition causes significant price differences, even within a 30 to 50
mile radius.  For example, in central Oklahoma a 6 or 7 bag Type  IIA concrete mix
will cost about $45-50 per cubic yard.  In central Indiana in an  area with little
or no competition,  prices run $55-60 per cu,  yd.  Type  II cement normally costs
$2-5 per cubic  yard  more than Type I cement.  A 45' x 70'  pad of this design
installed at an aerial applicator site in North Eastern  Idaho  in November, 1989,
had delivered concrete costs  of $46.00/cu. yd.  Today,  this  cost would run about
$50-52/cu. yd.

      Table  4  lists  estimated  prices  for components  and services  needed  to
construct the modular concrete pad designs shown in Figures 4-6  and Table 1, for
6.0 and 7.0 bag mixes.   From  Table  2, the cement volume required is basically a
function of  the maximum aggregate  size selected.   With 1.0 inch  to  1.5 inch
aggregate, a 5.5 or 6.0 bag/cubic yard mix  should provide  equivalent strength to
a  7.0  bag  mix using  1/2 inch  aggregate for  approximately  4,000-4,500  psi
compressive strength  concrete.

      Forming labor and  finishing  labor usually quoted  on a cost/sq. ft. basis.
Some concrete contractors combine forming and finishing  quotes at slightly lower
costs.   Typical  forming costs  range  from $.20 to  .30/sq.  ft.;  finish costs range
from $.25 to .35/sq.  ft.  Total forming placement and finishing costs range from
$.45 to .65/sq. ft.   These costs may increase by 30-50% in some high labor cost
areas.   The differences   in total cost for 6.0 bag  versus 7.0 bag mixes amounts
to about $5.00-$7.00/cu.  yd.  finished, or about, 5% added cost for a 7.0 bag mix.

      NOTE:  The cost estimates in  Table 4 are based on constructing new concrete
pads on bare undisturbed earth within the  base zone of  the concrete plant, when
no unusual  construction problems are encountered.   No security fences and gates,
rinsate tanks,  pumps, plumbing,  electrical wiring, buildings, or approach ramps
are included.

      Concrete  pad  costs   vary    significantly  with   geographic  location,
availability  and  competitive costs  of concrete  and  concrete  readimix  plant
location from the construction site.   Total  pad costs  as a ratio of delivered
concrete costs typically  range from about 2.5  to 3.0 X (where ground  is level and
clear  --  minimum earthwork).   If  substantial earthwork or  reconstruction  is
required, costs may run 3.5 to 4.5  X delivered concrete costs. At a ratio of 3.0
for $50/cu. yd. concrete, total  finished cost would be  3.0 X  $50/cu. yd. = $150
cu. yd.  At  that rate,  a 50' x 65', 68 cu.  yd. pad would  cost $10,200.   With
substantial site preparation  or removal of an existing  structure was involved at
a remote site, the cost  for this size pad may be $13,000 to $15,000.


FUTURE DESIGN ASSISTANCE

      Standardized concrete  wash  and  containment  pad  designs  for  aerial  and
ground agricultural  chemical  applicators  in  the U.S. are  now  being developed by
the  authors  of MWPS-37,  "Fertilizer  and  Pesticide  Facilities  Handbook"  for
Midwest Plan Service, Ames,  IA and Tennessee  Valley Authority (TVA) for Summer
1991 publication.  More construction cost,  structural design and  tank volumes vs.
containment pad size  and shape detail  on the  commercial pads  can be obtained by
requesting the technical paper by  Noyes and Kammel  (1989),  and on the farm pads
by contacting Kammel  and O'Neil (1990).
                                      120

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 REFERENCES

 Concrete  Sealers for Protection of Bridge Structures, 1981. National Cooperative
 Highway Research Program  Report  244,  Iransportation Research  Board,  National
 Research  Council,  Washington,  D.C.,  12/81,  138p.

 Effects of Substances on Concrete and Guide  tc Protective  Surfaces,  1986.  PCA
 Bulletin  IS001.067,  Portland Cement  Association,  Skokie,  IL,  21p.

 Gilding,  T.  J.  (Editor),  1988.  "Managing Pesticide Wastes:  Recommendations  for
 Action",  Summary  of National  Conferences  and  Workshops  on   Pesticide  Waste
 Disposal,  National  Agricultural Chemical Association, Washington,  D.C.,  July,
 1988,  85p.

 Hirsch, Itzhak, 1986. "Chemical  Waste Management at  Agricultural Airstrips", ASAE
 Paper  No.  AA86-002,  Chimav Services,  Herzliya Airport,  Israel,  NAAA/ASAE  Joint
 Technical  Session, Acapulco,  Mexico,  9p.

 Hofman,  V,  and  J.  Gardner,  1989.    "SAFE  Storage, Handling  and  Disposal   of
 Pesticides  and  Containers", Fact Sheet AE-977, Cooperative Extension  Service,
 North  Dakota State University,  4p.

 Isaacson,  Lief,  1989.  Personal  Telephone  Conversation  from Terraton,  Idaho,
 November  18,  1989.

 Joint  Design for  Concrete Highway  and  Street Pavements,  1975.  PCA  Bulletin
 IS059.03P,  Portland  Cement  Association,  Skokie, IL,  13p.

 Kammel,  D.  W.,  1988.   "Protective   Treatments  for Concrete",   Agricultural
 Engineering Department,  University of Wisconsin, Madison, WI, February, 1988,  7p.

 Kammel, D. W., 1989.  "Protective Treatment Companies", Agricultural  Engineering
 Department,  University of  Wisconsin, Madison,  WI,  January,  1989, 3p.

 Kammel,  D.  W.  and  D.   O'Neil,  1990,    "Farm Sized  Mixing/Loading  Pad  and
 Agrichemical Storage Facility",  American Society of Agricultural Engineers Summer
 Meeting, Columbus, OH, June,  14p.

 Kearney,  P.C.,  M.T.  Muldoon,  and C.J.  Somich,  1987.   "A Simple  System  for
 Decomposing Pesticide Wastewater", Pesticide Degradation Laboratory,  ARS,  USDA,
 Beltsville,  MD.  Presented  to  Division  of  Environmental   Chemistry,  American
 Chemical Society, New Orleans,  LA, August 30,  1987,  4p.

 Noyes,  R.  T.,  1988-A.    "Modular Concrete  Pad  Facility  for  Pesticide  Waste
 Management", Aerial Agricultural Association of Australia, Ltd., Convention  88,
 Coolangatta, Queensland, Australia, May 30-June 1,  1988, 22p.

 Noyes, R. T., 1988-B.  "Modular Concrete Chemical   Handling Pad  Facility", 1988
 NAAA/ASAE Joint Technical Session, Las Vegas,  NV,   25p.

Noyes, R.  T., 1989-A.  "Modular Concrete Chemical   &  Liquid Fertilizer  Handling
 Pad Facility", Agricultural Engineering Department,  Oklahoma State University,
January, 32 p.
                                      121

-------
Noyes,  R.  T.,  1989-B.    "Modular Farm  Sized Concrete  Agricultural Chemical
Handling Pads",  Agricultural Engineering Department, Oklahoma State University,
February, 25 p.

Noyes, R. T.  and D. W. Kammel, 1989.  "Modular Concrete Wash/Containment  Pad  For
Agricultural  Chemicals",  American  Society  of  Agricultural  Engineers  Winter
Meeting, New Orleans, LA, December, 32p.

"Pesticide Storage  Building,  1983. Plan  no. Ex.  6346,  Cooperative Extension
Service, Oklahoma State University, Ip.

"Pesticide Storage and Mixing Building", 1979. Plan No. MWPS-74002,  Midwest Plan
Service, Ames,  IA, 4p.

Powers, T.C., Durability of Concrete,  ACI Publication SP-47, American Concrete
Institute, Detroit, 9p.

Rester,  Darryl,  1986.  Waste Water  Recycling,  Paper  No.  AA86-001, 1986 Joint
Technical Session  of  National  Agricultural  Aviation  Association and American
Society of Agricultural  Engineers, Acapulco, Mexico,  December, 1986, 11 p.

Rester, Darryl,  1984. Aircraft  Washwater  Recycling System,  Drawing No. 26-01,
Sheet  1 of  1,  Louisiana  State  University,  Cooperative  Extension Service,
September 1984.

Thickness Design for Concrete Highway and Street Pavements, 1984. PCA Engineering
Bulletin EB109.01P, Portland Cement Association, Skokie,  IL, 47p.

Watertight Concrete,  1975.  PCA Bulletin  IS002.03T,  Portland Cement Association,
Skokie, IL,  4p.
                                      122

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                                                            Table  1.   CONCRETE  PAD DIMENSIONS
to
             Dimension"
   A
   B
   C
   D
   E
   F
   G
   H
   'I
   J
   K
   L
   M
   N
   0
   P
   Q
   R
   S
   T
   "U
   V
   M
   X,
   X,
   Y,
   t,

NOTES:
 6.1x9.1 (20x30)

 6.10 ii (20'-0")
 3.05 M (10'-0")
 9.H M (30'-0»)
 6.10 • (20'-0")
 3.05 HI (10'-0»)
  35.56  cm (14")
  35.56  cm )
   2.13 m (71)
 2839 L  (750 Gal.)
54.61 cm (21  1/2")
49.53 cm (19 1/2")
  60.96  cm (24")
50.48 cm (19 7/8")
  66.04  cm (26")
55.56 cm (21  7/8")
9.1x12.2 (30x40)

 9.14 m (30'-0")
 3.05 m (10'-0")
 12.19 m (40'-0»)
 9.14 m (30'-0")
 4.57 m (15'-0»)
 43.18 cm (17")
 43.18 cm (17»)
 53.34 cm (21")
    0 cm (0")
 27.94 cm (11")
  17.78 cm (7")
 27.94 cm (11")
 45.72 cm (18")
 76.20 cm (30»)
   5.08 cm (2")
 12.70 cm (5.0»)
      3.OX
 0.95 cm  (3/8")
   3.05 m  (10')
   3.05 m  (10')
5678 L  (1500  Gal.)
85.09 cm (33  1/2")
80.01 cm (31  1/2")
 91.44  cm (36")
80.96 cm (31  7/8")
 96.52 cm (38")
86.04 cm (33  7/8")
                                                                     Pad Site  m x m  (ft x ft)

                                                        12.2x16.8 (40x55)    15.2x21.3 (50x70)
                                                                                                                   18.3x24.4 (60x80)   24.4x33.5 (80x110)
 12.19 m (40'-0")
 4.57 m  (15'-0")
 16.76 m (55'-0")
 12.19 m (40'-0»)
 6.10 m  (20'-0")
  45.72 cm (18»)
  45.72 cm (18»)
  58.42 cm (23")
     0 cm (0")
  30.48 cm (12")
   17.78  cm (7»)
  30.48 cm (12")
  45.72 cm (18")
  76.20 cm (30")
   5.08 cm (2")
  12.70  cm (5.0")
       2.5X
  0.95 cm (3/8»)
   3.96 m (13*)
    3.96 m(13>)
12924 L  (3415  Gal.)
85.09 cm (33 1/2")
80.01 cm (31 1/2")
  91.44  cm  (36")
80.96 cm (31 7/8")
  96.52  cm  (38»)
86.04 cm (33 7/8")
 15.24 • (50--0")
 6.10 m (20'-0")
 21.3 m (70'-0")
 15.24 m (50'-0")
 7.62 m (25'-0")
  45.72 cm (18")
  53.34 cm (21")
  68.58 cm (27")
     0 cm(0")
  38.10 cm (15")
   22.86 cm  (9")
  38.10 cm (15")
  45.72 cm (18")
  76.20 cm (30")
   5.08 cm (2")
  13.97 cm (5.5")
       2.5X
   1.27 cm (1/2»)
   3.96 m (13')
   3.96 m (13')
27303 L (7215  Gal.)
85.09 cm (33  1/2")
80.10 cm (31  1/2")
   91.44 cm  (36")
80.96 cm (31  7/8")
   96.52 cm  (38")
86.04 cm (33  7/8")
  18.29 m(60'-0")
  6.10 m(20'-0")
  24.38 m(80'-0")
  18.29 m(60'-0")
  9.14 m(30'-0")
  45.72 cm (18»)
  60.96 cm (24")
  78.74 cm (31»)
     0 cm (0")
  45.72 cm (18")
  27.94 cm (11»)
  45.72 cm (18")
  45.72 cm (18")
  76.20 cm (30")
  76.20 cm (30")
  13.97cm (5.5")
       2.5X
  1.27 cm (1/2")
   4.57 m (15')
   4.57 m (15')
39612 L(10465 Gal.)
 85.09cm (33 1/2")
 80.01cm (31 1/2")
  91.44 cm  (36")
 80.96cm (31 7/8")
  96.52 cm  (38")
 86.04cm (33 7/8")
 24.38 • (80'-0")
  9.15 m (30'-0")
 33.53 m (110'-0">
 24.38 m (80'-0")
 12.19 m (40'-0")
  60.96 cm (24")
  76.20 cm (30")
  96.52 cm (38")
     0 cm (0")
  60.96 cm (24")
  40.64 cm (16")
  60.96 cm (24")
  45.72 cm (18")
  76.20 cm (30")
  76.20 cm (30»)
  15.24 cm (6.0»)
         2.5X
  1.27 cm (1/2")
    3.96 m (13')
    3.96 m (13*)
110230 L(29125 Gal.)
 85.09 cm(33 1/2")
 80.01 cm(31 1/2")
  91.44 cm  (36")
 80.96 cm (31 7/8")
  96.52 cm  (38")
 86.04 cm(33 7/8")
                                                                              If "I" is changed,  add the new  "I"  value
    "I"  can  be  increased  to provide Increased containment  volt
    to ''G"."H","J" and "K" dimensions.
    "U"= Total Containment Section Volume, Gallons; Displacement Volume of tanks, and equipment must be
    subtracted to determine Net  Usable Volume to meet EPA requirements.
    See Figures 2-8 for letter designation

-------
                                        Table 2.  WATERTIGHT  CONCRETE  MIX DESIGNS     APPROXIMATE  VALUES
Mdx.  Coarse
Aggregate  Size
cm /(Inches;
  i
                      Kg!L)/n'
                0 4C;"      04V"
Lbs (Gals  }/yd'
0 40!"     0.45"'
% By
Volume
                            134/134!
                109(109}
200(24)    22
-------
                                        Table 3.   CONCRETE  AND STEEL COMPONENT ESTIMATES
•vj
LT!
Pad Size Concrete (1)
U x L

Reinforcing Steel (2)
Total Volume Pad Thickness Beinf. Steel Size

B x a (ft x Ft) cu. • (C*j. Tcfa;
fc ',-5.1
o '..» 12.
U' /V '!•>
15. ;>.,.!.
<8.i<-,^4.
21.3x>9
24.4*3"',.
Note;
( 1 ) tor
(2) SVJ
(3) £ur
(20x30) 9.2 (12)
2 (30x40; 18.3 (?4)
f <40n55) 33 6 (4411
. < 50x70) 52.0 {i-S}
i (60*80) 78.7 (103)
0 {70,95*, 108.6 (142)
i (80x110) HV.1 r°K;

•"r*te volumes • ,:''V"f 81 10X -J-
sl includes 5X jc^" cverleo '*• -
^ area ste.-:- at 6" f 6" sp£.c>,vj
Corns irwnt Wash Length Wei]
r* (ir.'* Ceniabter* (in) Oia. OB (in) m (Ft.) kg (Ib.)
V. - , a.Q) 11.4 '4. 5) U.95 (3/8) 610 (2,000) 340 (750)
-.' ' • 'I'. 12.7 (5. (•) 0-95 (3/8> 1/bS (5,800) 6^9 (1,430)
'' i .')'- ''.^ {S 0'. 0.95 (3/8) 2 000 (6 560) 1 120 (2 465)
",:., .. •'. •: : o f-: \ .27 {I--; ?,772 (9,129) 2,770 (6,110)
:*.-.' • . . .' -.-•! 1.27 ;1/2' 3,955 v"i2,V75) 3,945 (3,695)
T- ' • •. S ' .2^ {•-?> 5,iOO -<:i ; uv"-;-^ ;a , -tt-c-1 jo'nts - 20 diemeters or 12'- minimum.
T :. '. , - . 'r.wf! - -.>'*.' btibC" witf! an 18" extension into the concrete pad.
Steel Pattern

Pad t Walls
at (in)
30.5x30.5
30.5x30.5
30.5x30.5
30.5x30.5
30.5x30.5
30.5x30.5
30.5x30.5




(12x12)
(12x12)
(12x12)
(52x123
(12x12)
(12x12)
(12x12;




Spacing (3)

ca (in)
15.2>'5.2 (6x6)
15.2x1: .,: (6x6)
15 2x1-- ' (6x6)
15.2xij.l' (6x6)
15.2x1'.. ; (6x6)
15 -2x i'. ,2 (6x6
15. It, . ,2 (6x6





-------
                             PESTICIDED STORAGE AREA
                             < SECONDARY  CONTAINMENT >
                                                                                               WAItK
                                                                                               SUPPLY
                                            i?INSATE  STORAGE


                                   MINIBLJLK & SV« STORAGE
                                                                                                - RRE EXTINGUISHER
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 8, EYE WASH
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                                                                  WITH GRATE
                                          LOADING/WASH PA3
                                          ( SECOM3ARY CONTAINMENT )
1,3-   1.5  W
   (With Building)
                                                                         Figure  i.

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                                    129

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                                                         WATER
                                                         SUPPLY
                                                             MIXING AND
                                                             CONTAINMENT
                                                                            FERTILIZER
                                                                            STORAGE
              FLOOD
FIRE         \  LIGHT
  EXTINGUISHER
  PESTICIDE
STORAGE AREA
     WORKER SAFCTY AREA
CMERGENCV SHOWER t EYEWASH
                          SECURITY
                          FENCE
                                                                     R1NSATE AND SVR
                                                                         STQRGAE
                                                        MIXING / HANDLING
                                                             AREA
                              Figure  4.

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-------
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                  SECTION D-D EDGE CROSS SECTION SIDE VIEW OF WASH PAD 4 CONTAINMENT SECTION
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-------
                            Waste Minimization  for
                    Non-Agricultural  Pesticide  Applicators:
                       EPA's Pollution Prevention Guide

                                      by

                               Teresa M. Marten
                     U.S. Environmental Protection Agency
                      Office of Research and Development
                     Risk Reduction  Engineering Laboratory
                               Cincinnati, Ohio
INTRODUCTION
      U.S. EPA's Office of Research and Development is preparing a guide to be
published later this year for non-agricultural pesticide applicators which will
provide  specific  information about waste minimization for  pesticide  users in
industries such  as  commercial lawn care, structural  pest  control,  greenhouse
operations, and forestry.  The guide is  being published under the authority and
responsibility given to EPA under the  1984 Hazardous and Solid Waste Amendments
to the  Resource  Conservation and Recovery Act (RCRA).  As  the  federal agency
responsible for writing regulations under RCRA, the U.S. Environmental Protection
Agency  (EPA) has  an interest in insuring that new methods  and  approaches are
developed for minimizing  hazardous  and other wastes and that  such information is
made available  to the industries that generate waste.   The guide being developed
for non-agricultural  pesticide applicators  is  one in  a  series  of industry-
specific pollution  prevention  guides  that will  assist companies from selected
industries in minimizing wastes generated within their operations.

      EPA has  defined waste minimization to  consist  of source  reduction and
recycling.  In  EPA's four tiered  waste management hierarchy, which presents the
Agency's ordered strategy for addressing waste generation and management, source
reduction and recycling are the top two tiers:

            •   source reduction
            •   recycling
            •   treatment
            •   disposal

Of the two waste minimization approaches, source reduction -not creating waste
in the first  place -  is considered environmentally preferable to recycling.  The
recently  passed   "Pollution  Prevention   Act"  of  1990  further emphasizes  the
preference for source reduction  in that Congress requires  EPA  to  carry out a
number of activities related to researching and promoting source reduction.  The
treatment and disposal of wastes, long the focus of EPA's research and regulatory
attentions, are considered neither waste minimization nor pollution prevention.


EPA'S WASTE MINIMIZATION OPPORTUNITY ASSESSMENT MANUAL

      Before EPA began work on developing industry specific guidance manuals for
waste minimization,  EPA's Office of Research and Development (ORD) published a
general manual  for waste minimization  which  can be used by companies within all
industrial and commercial sectors,  including non-agricultural  pesticide users.

                                      136

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The Waste Minimization Opportunity Assessment Manual  (USEPA 1988)  describes  how
to conduct a waste minimization assessment and develop options for reducing waste
generation.   It explains the management  strategies needed  to  incorporate waste
minimization  into company policies and  structure, and discusses how to establish
a  company-wide  waste minimization  program,  conduct  assessments,  implement
options, and  make the program an  on-going one.

      The systematic  procedure outlined  in the manual for  carrying out  a waste
minimization  opportunity assessment  (WMOA)   has  four  phases.    They  are:   1)
planning and  organization, 2) assessment, 3)  feasibility analysis, and
4) implementation.  In the planning and  organization phase, essential elements
are:   getting  management  commitment,   setting  waste minimization  goals,   and
organizing  an assessment task force.    The next  phase,  the assessment  itself,
involves the  following steps:

      1.    Collect waste generation data
      2.    Prioritize and select  assessment  targets
      3.    Select assessment team
      4.    Review data  and inspect site
      5.    Generate options for  reducing waste
      6.    Screen and select options  for feasibility study.

      Options  that  pass  the assessment  screening  are  carried  into  the third
phase, the feasibility analysis,  in which a technical  evaluation and an economic
evaluation are performed.  The technical evaluation determines whether a proposed
option will work in the specific  application  that is  envisioned  at the company.
During the  feasibility phase, an  economic evaluation is carried out to  analyze
the cost  ramifications  of implementing  an  option  using  standard measures  of
profitability,  such as  payback period,  return on  investment,  and net  present
value.

      Finally,  in  the  fourth phase,  implementation,  the options that  pass
technical and economic feasibility reviews should be executed.  It is then up to
the assessment team, with management support,  to continue the process of tracking
wastes  and  identifying  opportunities  for  waste  minimization  by performing
periodic reassessments.


INDUSTRY SPECIFIC POLLUTION PREVENTION GUIDES

      While the WMOA manual has been very popular and has  proven  successful  in
providing generic guidance to industry for establishing waste reduction programs,
EPA's Office of Research  and  Development wanted to  build on this achievement by
offering recommendations for waste reduction techniques and technologies that
were  industry  specific.   And so  in 1989, ORD's  Pollution Prevention  Research
Branch  began  developing a  series of  industry   specific  pollution prevention
guidance manuals.

      The manuals are based on existing  waste reduction reports already developed
for targeted industries by the State of California Department of  Health Services
(DHS).   California's  DHS  performed waste  reduction assessments  for   several
businesses within an industrial category and  compiled them  in a report  for  the
industry.  What EPA is doing  is modifying and  augmenting the California  reports
so that they are comprehensive, nationally applicable guidance documents.   The
EPA manuals describe  wastes  and  waste  generating processes within the  subject

                                      137

-------
 industry  followed  by specific  suggestions  for reducing  these  wastes through
 source reduction and recycling.   Also provided  are  industry-specific worksheets
 to assist companies and environmental professionals in methodically conducting
 waste minimization assessments  for facilities within the  subject industry.

      In 1990, EPA published seven industry-specific pollution prevention guides,
 and plans another 12 for 1991.   One  of the manuals  already published, Guides to
 Pollution Prevention: The Pesticide  Formulating Industry.  EPA/625/7-90/004, and
 the  manual  to  be  published  later   this year  for  non-agricultural  pesticide
 applicators should be of special  interest to this audience.  It is this second
 manual that  is the subject  of  the   present  paper.   Below,  a  summary  will be
 provided  of  the major  recommendations  for  reducing  waste  generation  within
 companies and operations that use pesticides for non-agricultural purposes.


 NON-AGRICULTURAL PESTICIDE APPLICATOR INDUSTRY PROFILE

      The  non-agricultural   pesticide application  industry  consists  of  the
 following types of firms: landscape maintenance firms, commercial nurseries, and
 structural pest control  firms,  as well  as government  agencies  that  run these
 kinds of  operations.  The  SIC  codes which apply to the  industry  are lawn and
 garden services (SIC 0782), tree  spraying (SIC 0783), ornamental floriculture and
 nursery products (SIC 0181), food crops grown  under cover (SIC 0182), forest pest
 control  (SIC 0851),  mosquito eradication (SIC 4959), and disinfecting and pest
 control  services for dwellings and buildings (SIC 7342).

      This group represents  a  sizable  portion of the  demand  for and  use of
 pesticides.  A 1980  study, which presented the  results of  a survey of pesticide
 users classified into three categories: agriculture, industry and government, and
 home and  garden, attributed 21% of pesticides use to the industry and government
 sector,  roughly equivalent to the non-agricultural pesticide  applicators group.
Of the remainder of  pesticide used,  agriculture accounts for  72% and only 7% is
due to home and garden use (Aspelin  and Ballard, 1980).


WASTE GENERATION

      Operational  activities within  the  industry that have  the  potential  for
generating wastes include: pesticide  storage  and distribution; pesticide mixing
and formulation; application of pesticides;  cleaning of  storage,  mixing,  and
 application equipment; and waste management.   Major waste streams  within this
 industry are:  used protective clothing; empty pesticide containers; rinsate from
pesticide containers and applicators; and surplus inventory.  In a broader, but
 still very  legitimate  sense, pesticide wastes also include those pesticides
 unnecessarily or over-applied to targeted  areas and pesticides  mistakenly or
 inadvertently applied to non-targeted areas.


SOURCE REDUCTION

      Source  reduction  as  mentioned  above  is  the  preferred method  of  waste
minimization.  It can be defined as  any activity that reduces or eliminates the
generation of waste  at the source, usually by substituting non-  or less toxic or
hazardous  chemicals  for more  highly toxic  or hazardous  chemicals,  changing
operations and maintenance procedures to reduce waste, and technology innovations

                                      138

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 that improve efficiency of raw material  usage.

 Integrated Pest Management

       Clearly,  one of the best ways of minimizing  pesticide waste is to minimize
 pesticide  use.   By utilizing a whole  range  of  approaches,  including  cultural,
 biological  and chemical methods,  for controlling pests to  acceptable levels,
 integrated pest management (IPM) significantly reduces pesticide use.  The amount
 of reported  reduction  in  pesticide  use  upon implementation of an  IPM program
 commonly  ranges from 50%  to  90% and  above.   Instead of relying on  pesticide
 application  frequencies that are predetermined and calendar based, IPM strategies
 only resort to chemical  pesticide applications when other methods have failed and
 plant  or habitat monitoring indicates that chemical  pesticide  applications are
 needed to  prevent pest  damage  from exceeding economic or aesthetic  thresholds.
 An added advantage of IPM is that with  decreased exposure to chemical  pesticides
 because alternatives  are employed, pests  are less likely to become  resistant.
 When chemical  pesticides must  be used they are  likely to be  more effective.

       Much   has  been  written  about  various   IPM  programs  within  the  non-
 agricultural  sector,  including descriptions of programs  used for  controlling
 pests  in forests and parks  (Daar,  1987;  Widin,  1987;  and Nielsen, David,  1989;
 Ticehurst  et al.,  1988; Collman,  1990)  greenhouses  (Helyer and Payne,  1986),
 commercial  lawn care   (Leslie  et  al.,  1989),  and  mosquito  abatement.    The
 citations  provided are  only a partial listing;  the literature describing IPM is
 extensive for non-agricultural, as  well as  agricultural sectors.  Because of the
 success of IPM and the large reductions in pesticide use and pesticide waste that
 can  be achieved, an  investigation  of  IPM  alternatives should  be a  fundamental
 part of any waste minimization  program for  the pesticides application industry.

 Inventory Control

       Within the pesticide  applicator  industry, as with any  industry that  uses
 raw  materials  which in themselves  are  hazardous or  toxic,  proper inventory
 management can  prevent  chemicals from becoming  waste when  shelf life  has  been
 exceeded or  improper storage has resulted in spills  or spoilage.  To avoid  this
 kind of waste generation, tight controls should be placed on ordering pesticides,
 and only those needed for the current season should  be purchased and stored on-
 site.  This reduces the  chance that pesticide will  become out-of-date or useless
 due  to bans  on its use.   Larger operations may want  to go  to a computerized
 inventory  control  system.   In  the event  that  pesticide expiration dates are
 exceeded,  the prudent purchase of pesticides from suppliers who have policies for
 accepting the timely return of full, unopened containers will  avoid this  material
 from becoming waste.

      Good storage and  spill  control  provisions  help reduce pesticides waste
 resulting  from  spoilage and spills.   Precautions  should be  in  place to secure
 pesticide  storage locations and  to prevent entry and mishandling by unauthorized
 personnel.    Only a limited number  of  trained personnel  should have access to
 storage areas.   To  reduce  the  possibility of  spoilage, pesticides  should be
 stored  in  areas that  are  protected  from moisture,  sunlight,  and  extremes in
temperature.   Most pesticides have  a longer shelf life if  stored  in cool, dry
areas out of  direct sunlight (Ware,  1983).  To reduce  the possibility of spills,
exposure to high activity areas, floor traffic and machinery should be  avoided.
Pesticides  should  be  stored on  pallets or shelves  that allow for easy,  periodic
 inspection  for signs of  damage or leakage.  To isolate  and properly handle those

                                      139

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spills  that may  occur,  storage  areas  should  have  secondary  containment or
drainage control  (California DHS, 1991).

Product Substitution

      Pesticide  wastes  may be  reduced  by  replacing  or substituting  a toxic
pesticide with one that is  less  toxic.   Examples include using biodegradable or
short-lived  herbicides  instead  of  those  that  are  very  persistent;  using
relatively  non-toxic  insecticidal  soaps instead of toxic  insecticides; using
pesticide formulations that rely  on  less  toxic  "inerts" for active ingredient
carriers, such as water instead of solvent; and using non-chemical or mechanical
pest control devices such  as  traps  instead  of chemical  pesticides (California
DHS, 1991).

      Choice of formulation can minimize loss of pesticide to the non-targeted
environment as well as reduce worker exposure.  Solid  formulations for popular
sprayable products, which must be dispersed in water before spraying, may be  sold
as wettable powders, dry flowables,  or  water  dispersible  granules.   While the
powders have significant dust making potential,  especially when conditions are
windy,  dry flowables and  water dispersible granules have the advantage of being
dust free if they are well  designed.  Liquid formulations that carry especially
toxic actives,  can be microencapsulated  to  improve  their safety and reduce
release to the non-targeted environment (Hudson  and Tarwater,  1988).

Containers and Packaging

      Containers that are triple rinsed are not regulated as hazardous waste, but
they remain  a  source of solid  waste if disposed  of  and  not recycled.    (The
recycling of rinsate and containers will be covered below).  Businesses should
take a  critical  look at their  container  wastes.  Product should be purchased in
the  size container  needed  for one  season's  usage  and,  to minimize  waste
containers, the procurement of multiple small containers  should be avoided.  The
use of  refill able containers could be explored by purchasers  and suppliers.  For
example,  pesticide  applicators  could  purchase   and  dispense  product   from
refillable containers.   Fifteen- gallon small  volume returnable containers are
available for some termiticide products.

      The purchase and use of pesticide in premeasured water soluble packages can
eliminate packaging  as a source of waste because  the packaging  dissolves and
becomes  part  of  the  application mixture.   Cleanup  of measuring and mixing
equipment is also avoided.   Certain pesticides  that  are  marketed  as wettable
powders can now  be purchased  in water-soluble,  polyvinyl  alcohol  film packets
that are added directly  to application  equipment.   Water-soluble packaging is
also being  investigated  for liquid  pesticides sold  as  emulsifiable  liquid
concentrates.  (Hudson and Tarwater,  1988)

Improved Mixing and Application Technology

      Wastes  from mixing  and  application  processes  can be  minimized  by  a
combination  of good  standard  operating  procedures  and  improved mixing  and
application technology.  By mixing  only enough  pesticide  for  the job at hand,
using premeasured  water soluble packages if available, and using closed mixing
systems, wastes  can  be  kept  to a minimum.  (Marer  et  al.,  1988).  In  addition,
computerized  mixing and  application systems  are now  available  that reduce
cleaning requirements and have the added advantage  of accurately controlling the

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 quantity  of  pesticide  applied.   In  these systems  pesticide and  water  are
 independently pumped to spray nozzles by computer controlled metering pumps  and
 mixed  directly  in  the  nozzle,  thus eliminating  the need  for  a  large  volume
 container for holding ready-to-apply diluted pesticide.  (California  DHS,  1991)

       The correct  application equipment  for the job  should  be  selected  because
 most  application  equipment used by  the  non-agricultural  applicators group  is
 suited only  to  a limited  number of situations  (Marer  et  al., 1988).   Equipment
 too  large for  the job  is likely  to release  pesticide  to  the  non-targeted
 environment  as well as  increase  the amount of rinsate generated  during equipment
 cleanup.

      With the  advent  of controlled droplet technology,  the size of droplets
 emitted  from  pesticide  spraying  equipment  can  be  tightly   controlled  and
 standardized so that exactly  the  right droplet size  is generated by  the  spray
 equipment, maximizing the amount of pesticide  hitting its target.  Historically
 used high volume  spray  equipment  reliant on hydraulic nozzles produces  a wide
 range of droplet sizes, from 100 to  1000 microns  in diameter, some of which  is
 wasted: too  large droplets may fail to meet  their target, fall to the  ground  and
 end up as run off,  and  droplets that are too  small are prone to wind or  drift
 loss.   Other waste minimizing technological  improvements to  the   controlled
 droplet  sprayer  are  the  ultra  low  volume  sprayer  and electrodyne  spray
 technology.   (Sastry, 1987).

 Application  Sequencing and Application Timing

      Cleaning requirements for  application  equipment  can be minimized by proper
 sequencing of pesticide applications.  By applying all pre-emergent products  in
 sequence followed by all  post-emergents,  applicator cleanings between  different
 product types can be avoided. As an alternative, dedicated application equipment
 for each type of pesticide would result  in  similar reductions (California DHS,
 1991). By properly timing the application of pesticides, additional applications
 can be avoided.   For example,  by applying  pre-emergents  at the correct time,
 future applications of post-emergents may not be needed.

      Weather conditions  should be taken into  account when planning  pesticide
 applications so  that pesticide effectively meeting targeted plants  or  insects  is
 maximized.    Application  efficiency will   be  compromised  on  windy  days and
 applications should be rescheduled if windy conditions  prevail.  Depending on the
 type pesticide  applied,  rain  in small  to moderate amounts  can  be a  help or a
 hindrance to pesticide application efficiency.


 RECYCLING AND REUSE

      According  to EPA's  waste  management hierarchy,  if  wastes   cannot   be
 eliminated via source reduction practices, recycling and reuse are  the next best
 solution  to   managing   them.    For  non-agricultural  pesticide  applicators,
opportunities exist for recycling rinsate and product containers.   Rinsewaters
generated by  cleaning product containers,  application equipment,  and vehicles can
 be  recycled   by  using  them  as  make-up  water  in new  formulations  that are
compatible with the specific rinsate.  Plastic  containers  of the  size used  by
this industry are not widely recycled; however, several states have  test programs
to  investigate the feasibility of recycling the  plastic  containers used for
packaging agricultural  pesticides.

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SUMMARY

      The above provides a brief summary of the options for minimizing waste that
will  be  included  in  EPA's  upcoming  guide  for  non-agricultural   pesticide
applicators.  In addition to the presentation of options, the manual  will  include
a  more  detailed description of the  industry than  is  presented  here and  will
include worksheets to assist companies in examining wastes  generated  as  well  as
opportunities  for  reducing  them.   Comments  are  invited from non-agricultural
pesticide applicators and the companies and/or universities that are researching
and  promoting  waste  reducing  techniques and technologies  of interest  to  this
industry.


REFERENCES

Aspelin, A.  L.,  and G.L. Ballard.  1980.  "Pesticide  Industry Sales and Usage:  1980
Market Estimates." Economic Analysis  Bureau, Environmental Protection  Agency,
Washington, D.C.
12 pp.

Burn, A.J., Coaker,  T.H.,  and Jepson, P.C., Eds.,  Integrated Pest Management
Academic Press, Harcourt Brace Janovich, 1987.

California Department of Health Services,  "Waste  Audit Study Non-Agricultural
Pesticide Application Industry" Prepared  for California DHS by Tetra Tech,  Inc.,
March 1991.


Collman, Sharon J.,  "Integrated Pest  Management:  A Seattle Street Case Study"
Forestry on the Frontier: Proceedings of American Foresters  National Convention,
Spokane, Washington,  September 24-27, 1989, p 416-420.

Darr, Sheila,  "Urban  Integrated Pest  Management:  Policy Options  for State and
Local Government"  Pesticides and Pest Management: Proceedings of  the 16th ENR
Annual Conference, November 12 and 13, 1987, p 295-299.

Helyer,  Neil L. and  Payne,  C.C.,  "Current  progress and future developments  in
integrated pest management  on  protected vegetable crops"   Aspects of  Applied
Biology,
Vol 12,  1986,  p 171-187.

Hudson,  J.L.  and Tarwater, O.R.,  "Reduction of  Pesticide Toxicity by Choices  of
Formulation" American Chemical Society, ACS Symposium Series, 1988 pp 124-130.

Leslie,  Ann R.  and Metcalf,  R.  L., Eds., Integrated Pest Management for Turfgrass
and Ornamentals USEPA Office of Pesticide Programs, August 1989.
Marer, Patrick J. The Safe and Effective Use of Pesticides
University of California Statewide Integrated Pest Management Project Division
of Agriculture and Natural Resources Publication 3324  University  of California,
Davis, 1988.

Nielsen, David G., "Integrated Pest Management  in  Arboriculture:  From Theory  to
Practice"  Journal of Arboriculture,  Vol.15, No.2, February,  1989, p 25-30.
                                      142

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Sastry, V.C.  "Pesticide  Application  Techniques in Integrated Pest Management"
Plant Protection Bulletin Vol 39: 1-2, 1987 p  23-26.

Ticehurst,  Mark  and Finley, S.,  "An Urban Forest  Integrated  Pest Management
Program for Gypsy Moth: An Example"   Journal of Arboriculture, Vol. 14:7, 1988,
p 172-175.

U.S. Environmental  Protection Agency, Waste Minimization Opportunity Assessment
Manual EPA/625/7-88/003, 1988.

Ware, George W.  Pesticides  Theory and Application University of Arizona; W.H.
Freeman and Company, San Francisco,   1983.

Widin,  Katharine,   "Integrated  pest  management:  A  preventative  approach  to
landscapes"  American Nurseryman, Vol. 165:10, 1987.
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              Pesticide Container Management in the United States

                                      by

                                  Nancy Fitz
                                   U.S. EPA
                         Office of Pesticide Programs
ABSTRACT

      The disposal of containers is a very visible problem in the agricultural
pesticide  industry.   EPA's  role  in pesticide container  management increased
drastically with the 1988 amendments to  the Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA).  Section  19 of  FIFRA requires EPA to address pesticide
containers  in  three  ways:    to  promulgate container  design  regulations,  to
promulgate  residue  removal  regulations, and to  conduct a study  of pesticide
containers and report the results to Congress.   In fulfilling these tasks, EPA
has gathered a great deal  of information on pesticide containers including use,
refill, residue removal, and disposal.  The two  most common disposal methods for
nonrefillable containers  are  landfill ing and open  burning,  although there are
problems associated  with  both of  these options.    Recycling is  becoming  an
increasingly viable pesticide container management option.  As a result of the
container study, EPA has developed  a container management strategy, including a
hierarchy of desirable  containers.  The hierarchy is  designed to  reduce the
number of containers requiring disposal.  To accomplish this, EPA would like to
encourage the use of refill able containers  and water soluble packaging as well
as increasing the number of containers being recycled.


INTRODUCTION

      The disposal of containers is a very  visible problem in the agricultural
pesticide  industry.    Accordingly,  pesticide  containers  have  received  a
significant amount of attention beginning with a National  Conference on Pesticide
Containers in 1972.   At  the  1985 National Workshop on Pesticide Waste Disposal,
container disposal was  a  focus of  the  keynote  address.   Additionally,  another
speaker at the 1985 workshop discussed the  three feasible options for managing
empty containers:

      •  Return for reuse or refilling;

      •  Recycling to the scrap stream or use for energy recovery; and

      •  Disposal by burial  or burning in approved facilities.  (Trask, 1985).

      These are still the three main options available  for pesticide container
management, although all of the options have changed since 1985.

      EPA's role in pesticide container management increased drastically with the
1988  amendments  to the Federal  Insecticide,  Fungicide,  and  Rodenticide Act
(FIFRA).  Section 19  of FIFRA requires  EPA  to  address  pesticide  containers in
three ways:

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       •   To  promulgate  container  design  regulations;

       •   To  promulgate  residue  removal regulations;  and

       •   To  conduct  a study of pesticide containers and report the  results  to
          Congress.

       Specifically,  the study  is required  to  develop  options to encourage  or
 require:

       •   The return,  refill,  and  reuse of containers;

       •   The development  and  use  of  formulations  that  facilitate  residue
          removal; and

       •   The use of  bulk storage  facilities to reduce  the number of  containers
          requiring disposal.

       In the past two years, EPA has worked with many of the people involved with
 pesticide  containers,  including industry trade organizations, State  agencies,
 equipment  and container manufacturers, packaging experts, and many individuals
 such as distributors, dealers, commercial applicators,  and farmers to gather  as
 much data on pesticide containers as possible.  This  information  is compiled  in
 the report to Congress  and  is being used to develop the regulations.

      The container design  and residue removal regulations are intended to apply
 to containers in all  segments  of the pesticide  industry including agricultural,
 institutional, industrial,  household,  and specialty markets.   EPA has data that
 show there are  approximately  three  times as many aerosol  pesticide  containers
 (used  almost exclusively in the household  and institutional markets)  produced
 each year  than  agricultural pesticide containers.   Despite  the  wide range  of
 pesticides intended to be included in  the regulations,  this  paper will  focus  on
 the agricultural segment of the pesticide industry.

      A great deal of progress has been made in the  past five years in  terms  of
 pesticide container  disposal  and  waste minimization,  although there are still
 problems.  This  paper will briefly present the common types of  containers in the
 agricultural  pesticide industry, discuss  the disposal options for nonrefillable
 containers,  and describe the EPA container management  strategy.


 CONTAINER TYPES

      EPA has divided pesticide  containers into two major types:  nonrefillable
 and refillable.  Nonrefillable containers are considered one-way or "throw-away"
 packages.  Generally, nonrefillable containers are relatively small, although
 there is no  maximum  size limit.   Nonrefillable containers include  1- and 2.5-
gallon jugs,  5-gallon cans  and pails,  bags,  bag-in-a-box designs, aerosol cans,
 and water  soluble bags.   One  major change  in  nonrefillable containers in the
 1980's was the nearly universal  adoption of plastic as the major packaging type.
 Plastic containers were introduced  to the pesticide  market  in the  late 1970's
 and, with the exception  of  aerosol products, have become the dominant container
type for liquids.  Most  recently, with the advent  of dry pesticide products that
 require  smaller  amounts of active  ingredient per unit  area,  more  of these
products are being packaged in plastic jugs.

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      Refillable  containers  are  designed and  intended to  be  refilled  with
pesticide  for  further sale or  distribution.   The construction  materials and
design specifications are generally selected to maintain the structural integrity
of the container  under adverse  storage,  shipping,  and use  conditions over the
course of multiple fill and use cycles.  Some of the containers that fall into
this  category   are  bulk  storage  tanks,  minibulks,   small  volume  returnable
containers, and refill able bags.


MANAGEMENT OF NONREFILIABLE CONTAINERS

      As  discussed  in the  introduction,  the  relative  use  of  the  container
management and disposal options  available  in  1985  have changed.   This section
addresses the methods currently  used  to dispose of nonrefill able containers and
recycling; reuse  and refilling  are  discussed in  greater  detail in  the next
section.

      Many states have done surveys to determine the container disposal methods
used by farmers and dealers.   Table 1 contains the results  of a survey done by
the Minnesota Department  of Agriculture in  1988, which  is representative of the
various surveys.


                                   Table 1
                Methods of Container  Disposal  (Minnesota, 1988)


                Percent of Respondents  Who Use Method1  (%)

Disposal  Method                  Farmers            Dealers
Burn
Rinse/take to landfill
Rinse/bury
Return to dealer
Store on site
Salvage
Can't dispose
Out-of-state hazardous
waste landfill
Other
65.0
23.7
27.5
17.8
11.8
3.6
2.8

1.3
14.2
30.1
56.1
8.3
7.8
7.4
11.5
3.2

0.7
7.6
1   The  columns  total to greater than 100 percent because respondents could list
more than one disposal option.


      By far, the two  most  common disposal methods for nonrefill able containers
are landfilling and open  burning.  Also, in some states,  a significant number of
farmers bury containers on their own property.

      However, there  are problems with  these  disposal  methods.  An increasing
number  of  farmers,   commercial  applicators,  and  dealers are  having  their
containers rejected by landfill operators for several reasons:
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      •  Existing  landfill  space  is  diminishing and  siting  new landfills  is
         difficult;

      •  Concern for ground water contamination from earlier disposal  practices
         is  increasing;

      •  States  are  adopting  solid  waste  management  strategies  that   rank
         landfill ing as  the least  desirable disposal option;  and

      •  Potential liability for future  releases of hazardous substances exists.

      Open burning is restricted or prohibited by a number of  Federal  and State
regulations.  The open burning of pesticide containers  is  a good  example of the
interjuristictional nature of pesticide  disposal issues and involves regulations
on air, solid waste,  and pesticides.   Additionally,  burying containers presents
a certain risk of contaminating  soil, ground water,  and surface water.

      Because of the  difficulty and  problems  associated  with the disposal  of
nonrefillable containers, a number of container  collection and recycling programs
have begun.   EPA is aware of such  programs in Mississippi, Oregon,  Iowa, Florida,
Illinois, North Carolina, Missouri, and Washington.  Currently,  most of these
programs are  in  the  pilot project stage,  although  many  are expanding.   Also,
Maine has a deposit and return program,  although  it  does not involve recycling.

      The existing collection and recycling programs  are  all  different.   For
example, some are run by the  State and  others  by industry.  Additionally,  some
of the programs collect only plastic containers,  while  some accept both plastic
and  metal.    However,  there  are  two  common   features  of  the  collection  and
recycling programs:

      •  Properly rinsed containers are essential  for a successful program; and

      •  Inspection of the containers is necessary  to  ensure proper rinsing.

      EPA believes  that these  are two crucial aspects of establishing successful
container collection and recycling programs.


EPA CONTAINER MANAGEMENT STRATEGY

      Several general  conclusions  relating to the  development  of a pesticide
container management strategy emerged from EPA's study and  report to Congress.
Part of  this  strategy  includes  promulgating the container design and residue
removal  regulations.  Additionally, the  pesticide container management strategy
includes long-term goals, which  can be divided into  several main categories.

Formulation and Container as  a Unit

      The first long-term goal is  to  have  the  pesticide  industry consider the
pesticide formulation and its  container as  a single  entity.  This would require
a significant change  in philosophy.   Generally, formulating  and  packaging a
pesticide are separate  projects done by  different groups within a company or by
different companies altogether.   The  change in  perception from  considering a
container simply as a vessel to transport a pesticide to seeing the container as
an important part of the pesticide itself is an integral  step in the long-term

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 improvement  of containers.   The relationship  between  the container  and the
 pesticide  is important in all  stages  of the  pesticide/container  life cycle,
 including use of the container (transportation,  storage, transferring pesticide
 from the container, etc.), residue removal, and disposal of the container.

 Provide Leadership

      The second long-term container management goal is to provide leadership in
 the area of pesticide containers. The  container study  involved a great deal of
 cooperation between EPA, other Federal agencies, State agencies,  industry groups,
 environmental  organizations,   and  many  individuals  involved  with  pesticide
 containers.   EPA  would like  to continue this  dialogue  and  cooperation in the
 future.

 Move Toward  Environmentally Preferable Containers

      Another part of EPA's leadership  role  is  to monitor and affect the trends
 of pesticide containers.   In conducting the study,  EPA determined that there are
 several desirable  classes of containers.   EPA has  identified a  hierarchy of
 environmentally sound container classes.  This hierarchy is based on information
 collected on the use  of containers, residue  removal,  and disposal,  as well as
 pollution  prevention  and  reducing  solid  waste.    The Agency  would  like to
 encourage the development  and use of the most desirable container classes.  These
 container classes are described in the following hierarchy.

      This hierarchy is based on the characteristics that EPA has identified for
optimal pesticide containers.   Any efforts, both public  and private, to address
 pesticide containers should strive for:

      •  Protection  of  the   integrity  of  the  pesticide  product  and  the
         environment through  which the container passes;

      •  The  safe  and easy transfer  of pesticide  from the container to the
         application equipment;

      •  Minimization of the amount of unused pesticide  residue remaining in the
         container after the  pesticide has been transferred; and

      •  Minimization of the  number of  pesticide containers requiring disposal.

 Preferred Pesticide Container Hierarchy

      The hierarchy of preferred pesticide container classes is given in  Table
2.  The most desirable container  classes  are on top and the least desirable are
on the  bottom.   For  the   purposes of  this paper,  a container is  considered
recyclable  if  the technology  exists  to recycle  the material  from  which the
container is constructed.
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                                    Table 2
                       EPA Pesticide Container Hierarchy
      Refillable containers  and water soluble packaging

      Nonrefillable, recyclable containers that are currently being recycled

      Nonrefillable, recyclable containers that are not currently being recycled

	Nonrefillable, nonrecyclable containers	


      The first two characteristics of optimal containers -- protection of the
pesticide  product  and  the  environment,  and the  safe  and  easy  transfer  of
pesticide  --  are  functions  of the  container design.   Therefore,  these two
characteristics are generally independent of  the position within  the hierarchy,
although they vary  within each class.  Improperly designed or handled containers
in the most  desirable  category may be potentially more  harmful  than the best
designed or handled containers in the least desirable category.

      Refillable containers  and water soluble packaging are the most desirable
container class because they:

      •  Reduce or eliminate the need for residue removal;  and

      •  Reduce the number of containers requiring disposal.

      The next category -- nonrefillable,  recyclable containers currently being
recycled -- is attractive because  it  reduces  the number of containers requiring
disposal  as waste.

      The third  category, nonrefillable, recyclable  containers  not  currently
being recycled,  includes most nonrefillable steel  and  plastic containers.  Also,
the  steel  industry maintains that  aerosol  cans  are  recyclable,  although EPA
believes  additional   study  is  necessary  in  this  area.    With  the  proper
infrastructure and market,  the  containers in this category could  move  up the
hierarchy to reduce the number of containers requiring disposal.

      The  least  desirable  category,  as determined  through  the  study,  are
nonrefillable, nonrecyclable containers.  Because multiwall paper  shipping sacks
are  usually  constructed of  more  than  one material  (e.g.,  kraft  paper  and  a
barrier layer),  they are not recyclable.

      In summary, EPA is addressing pesticide containers in several ways.  EPA
would like to reduce  the number of containers requiring disposal by encouraging
the use of refillable containers and water soluble packaging.   Also,  EPA would
like to increase  the number of pesticide containers that are being recycled.  At
the same time, EPA is addressing pesticide container issues on a broader scale
than just disposal.  The container design and residue removal  regulations that
are being drafted are  intended to  increase safety  during use,  refill,  residue
removal,  and disposal  of containers.
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ENDNOTES

Minnesota Department of Agriculture.  Minnesota Empty Container Disposal Report,
March 1988.

Trask,  Harry  W.    "Empty  Pesticide  Container  Management:   An  Overview,"
Proceedings:  National  Workshop on Pesticide Waste Disposal,  JACA Corporation,
Fort Washington,  Pennsylvania,  September 1985.
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              PESTICIDE DISPOSAL  IN GUINEA-BISSAU:  A CASE  HISTORY

                                        by

                                  Janice  Jensen
            US  Environmental Protection  Agency,  Washington DC 20460
ABSTRACT
       Guinea-Bissau is a small,  underdeveloped country on the southwestern coast
 of  Africa.    In  June  1990,  the  Guinea-Bissau  Crop  Protection Service  (CPS)
 requested  USEPA  assistance with  disposal  of  surplus  pesticides.    This  paper
 describes  the  problems  encountered,  and  outlines  several  practical  disposal
 options  which  were  presented  to  the  CPS.    These  low-cost,  low-technology
 approaches can provide  developing countries such  as Guinea-Bissau  with viable
 methods  of pesticide disposal.


 INTRODUCTION

       Although the chemical approach to pest problems  can  significantly improve
 crop yields  and reduce the incidence  of insect-borne diseases,  without careful
 handling,  pesticides  also can  pose  a serious  threat to  human health  and  the
 environment.   One unfortunate consequence of chemically-intensive  pest control
 programs is  their tendency to generate potentially toxic wastes. The problem of
 disposal  of obsolete or  unwanted stocks  of pesticides   is  of vital  concern,
 particularly in developing countries  which may lack the technical  expertise or
 financial  resources necessary to  accomplish sophisticated disposal  solutions.

       Disposal  of unwanted pesticides  is  of special  concern in Africa,  where
 severe tropical climates cause chemicals and their containers to deteriorate more
 rapidly  and  where poor  storage practices  are  common.   (Jensen, 1983;  Jensen,
 1987a; Jensen,  1987b; Jensen,  1990;  Krueger, 1989)   Aging pesticide  drums  are
 frequently encountered  being stored  in the open  sun, with leaking  chemicals
 posing a direct threat to human health  and surface or groundwater  quality.

       In  the countries  in and  near  the  Sahara desert,  thousands  of  tons  of
 obsolete  pesticides  stocks require disposal.  (GIFAP,  1991; World  Environment
 Center, 1987)  Many of these stocks were purchased  in the late 1960's to control
 pests  such as migratory locusts, tsetse flies and other insects, Quelea birds and
 weeds.

       Government  officials in  these  countries are acutely aware of the potential
 problems posed  by these obsolete  stocks,  but are unaware of feasible,  low-cost
 options for  implementing their  safe disposal.
      •To whom correspondence may be addressed.  J.K. Jensen's current address is Pesticide Management &
Disposal Staff,  Environmental Fate  and Effects  Division  (H-7507C),  Office  of Pesticide Programs, US
Environmental Protection Agency, 401 "H" Street SU, Washington DC 20460,  USA.

      Presented at  the International  Workshop on Research in Pesticide Treatment, Disposal,  and Waste
Minimization, Cincinnati, Ohio, USA, February 26-27, 1991.
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      This  paper provides a case  study of surplus pesticide  problems  in the
developing African country of Guinea-Bissau and describes several  practical, low
cost  disposal  options  which   the  USEPA  identified   for  the  Guinea-Bissau
authorities.


BACKGROUND  INFORMATION

      Guinea-Bissau  is  a- small,  underdeveloped  country,   located   on  the
southwestern coast of Africa.   The capital city of this predominantly agrarian
nation is Bissau. Table 1 provides  limited economic statistics for this country.


                                   TABLE 1

                     Economic statistics for Guinea-Bissau


                           $160  per capita income
                           36,125  square miles
                           900,000  population
                           90% rural  population
                           20% adult  literacy
                           134/1000 infant mortality
                           90% employed in agriculture


      Self-sufficiency  in  staple   food  production is  a national  priority  in
Guinea-Bissau.  To assist  in achieving  this goal,  in  1978 the U.S. Agency for
International  Development  (USAID)  initiated  a  $4.25  million  dollar  crop
protection.   (USAID,  1988)  The purpose of the project was  to strengthen the
capacity of the National  Crop Protection Service (CPS)  so that  it could develop,
direct and implement its own crop  protection program.   The USAID project ended
in September 1990.

      The USAID program developed  integrated pest management (IPM)  as the crop
protection strategy of choice,  with the use of  pesticides as a key element of the
IPM program.   CPS concerns regarding the importation,  storage,  handling,  and
disposal of pesticides as well as the management of pesticide containers resulted
in formal requests to the USEPA  for technical  assistance before the end of the
project.  This  assistance  was provided by the author  in June  1990.   Although
assistance was provided in all of these  areas,  only the disposal portion of the
assistance will be addressed in  this  paper.


DISPOSAL OF "OLD" PESTICIDE STOCKS

      As an initial step, the CPS conducted an  inventory of all pesticide stocks
in country,  including pesticides  potentially  requiring  disposal.  (Castleton,
1990;  CPS,  1990)      Generally,  these  pesticides   had  been  stored  under
unsatisfactory conditions for  many years, and  the Service was uncertain of the
quality  of  the products and the  integrity of  their  containers.   No  quality
testing laboratory was available in Guinea-Bissau  to assist in this evaluation.
The pesticides  ultimately  identified for disposal, primarily  on the basis  of
their age and the condition of their  containers, are listed  in Table 2.

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                                    TABLE 2

                    Pesticides  for  Disposal  in  Guinea-Bissau

Pesticide
carbaryl (Sevin*)
dichlorvos (OOVP*)
dicofol (Kelthane*)
edifenphos (Hinosan*)
fenitrothion (Agrothion*)
fenthion (Baytex*)
phoxim (Volaton*)
triadimefon (Bayleton*)
pesticide with no label
c = carbamate
op = organophosphate
oc = organochlorine
* = trade name
Chemical
Type
c
op
oc
op
op
op
op







Quantity
6,4001
3501
6001
6001
781
1001
1,0001
75kg
2001




Warehouse
Location
Bissau
Contuboel
Bissau
Sonoco
Bafata/Contuboel
Bafata
Contuboel
Bafata
Bafata




      The next step was to develop practical, low cost options  for  the disposal
of these relatively small quantities of over-age pesticides.   Carbaryl,  the only
pesticide present  in significant quantities, was  considered separately.


CARBARYL DISPOSAL

The Carbaryl Story

      Carbaryl (6,400  liters)  was  imported into Guinea-Bissau in 1988 for the
locust campaign being carried out by donor organizations in West Africa.   The
carbaryl formulation purchased was Seven 4-Oil,  chosen primarily because  it  could
be aerially applied and because it contained  sticking  agents which enhanced its
persistence on foliage.

      Because the oil-based formulation was a  thick suspension, an agitation pump
was needed  for application.   However,  the  outbreak  of a more severe locust
infestation in neighboring Senegal caused a  realignment of priorities,  and the
spray plane and  agitating  pump  destined for  Guinea-Bissau  never  arrived.
Consequently, none of the carbaryl was used.

      All of the  carbaryl drums were  stored  in one warehouse near the capital
city and were  in good condition.   However,  because the drums  had never been
agitated or  rolled as  recommended on the label, the  carbaryl  settled  in the
containers and resuspension efforts by the CPS proved futile.  This eliminated
the possibility for using the carbaryl for other locust control methods such as
coating   grains to  make  baits,  or  for  application    with  available  ground
equipment.
                                      153

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 Return To Sender

      One disposal option identified for these carbaryl stocks was to return  them
 to the US manufacturer for reformulation and resale, with the manufacturer paying
 for transportation costs.  This course of action was being pursued for remaining
 carbaryl stocks in neighboring Senegal  and was strongly  recommended to  the  CPS.
 The CPS was advised to decide quickly, as shelf-life considerations for  carbaryl
 limited  the time  for which  this option  was viable.    The manufacturer could
 reformulate and resell  the carbaryl,  but not  if its  effective date had  expired.

 In-country Disposal

      This  was  a  less  desirable  option.    There  was  no high  temperature
 incinerator or dedicated hazardous waste landfill in Guinea-Bissau.  Co-firing
 pesticides  as  fuel in  a cement  kiln  is  being considered  in  several  African
 countries and  this  method  of  disposal  may be appropriate when  there are large
 amounts  (>50  metric tons) of  pesticides  to  be  discarded.  (World  Environment
 Center, 1987;  Krueger, 1989)  Although it can  be a practical and  efficient method
 of disposal, cement kiln incineration of wastes typically  invites  a variety of
 technical and political  complications.  (Jensen, 1987b)

      Land burial of the carbaryl  was not  recommended.   Because of a high water
 table and  routine flooding in most  areas in Guinea-Bissau,   there  is a   real
 potential for groundwater  contamination or  for run-off  into receiving waters,
 streams, drinking water or other pathways that affect the environment.


OTHER PESTICIDES FOR DISPOSAL

      For the  pesticides  in  Table 2 other than  carbaryl,  practical,  low   cost
 options were recommended for the disposal  of these relatively  small quantities
of over-age pesticides.

 Find Safe Alternative Uses

      In a country like Guinea-Bissau with extremely limited financial resources,
taking advantage of the  economic  benefit of the pesticide  product  is always the
preferred method of disposal.   Finding safe  alternative uses for pesticides of
questionable integrity was recommended.

      A strategy for obtaining additional information on alternative uses and
methods for safe disposal for  the pesticides  in Table 2 was worked  out with the
CPS.  A first  step  in the strategy was to test the products for  quality.  Six of
the nine pesticides in Table 2 are products of Bayer Chemical Company. The USEPA
consultant recommended that the CPS request  that  Bayer  -- at  no  charge to the
CPS, which has no foreign exchange to pay for the  analysis -- analyze samples of
their products in Guinea-Bissau for quality.   It was possible that  this request
would be granted, considering the enhanced product stewardship programs now in
 place with  the  large  chemical companies.   Bayer would  advise the CPS how to
 safely collect and ship the samples for analysis.

      Many of the pesticides in Table 2 potentially can be used
 to control pests where  the exact  dosage  rate is  not critical.  (Farm Chemicals
Handbook, 1990; Asian Development Bank,  1986)   For example, dichlorvos  could be
 sprayed on the inside of the walls and ceiling  of mud grain storage bins  to limit

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 pest infestation.  Phoxim is also registered for controlling stored product pests
 in granaries  and  for armyworm  control.   The dicofol  could be used  successfully
 against the cassava green  spider mite, which was  identified in  1990  as  a major
 pest problem  in Guinea-Bissau.

    To summarize,  it is preferable to use these  chemicals  as they were designed
 to be used, rather than dispose of them.   All  possible effort should  be  made to
 avoid disposal.

 In-countrv Disposal

      Chemical degradation was considered  as a possible disposal option,  given
 that:   1)  relatively  small  quantities  were involved,  and  2)  most  of the
 pesticides in Table 2 are carbamates or  organophosphates, which decompose when
 treated with alkaline (basic) chemicals,  such  as  lye  or lime. (Lawless,  et. al.
 1975)  Lime is readily available in  Guinea-Bissau.  (Chemical  degradation  was not
 considered as a realistic option for the  large stocks of carbaryl on  hand.)   A
 "cook book" chemical treatment procedure using lime was provided to  the  CPS.

      If the chemical degradation option  is selected,  the procedure  is best done
 in the middle  of  the  dry season (January), not  during the  rainy season, when
water contamination would be of greater  concern.

No Action

      This option  was  not  recommended.  Other than  the carbaryl  stocks, the
containers for the pesticides  in Table 2 are  not in  good  condition.   Some are
leaking and the released material has contaminated the porous concrete floors of
the storage areas  and may  have  passed  through to the ground.   The fumes could
pose a risk of worker exposure  by  inhalation, and increase  the  risk of  fires.
Most of the storage facilities are located in populated areas.


CONCLUSION

      The purpose  of the technical assistance to  the Crop Protection Service was
to provide guidance on practical, low cost options for  the disposal of relatively
small  quantities  of  over-age pesticides.   The   intent  of  the  Service  was  to
carefully consider these options, and start the implementation phase in the near
future.
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REFERENCES

Asian Development Bank,  1986.  Study of Pesticide Usage in Selected DMC's of the
Bank, prepared by Cecilia Gaston and Roy Pavey.

Castleton,  C.,  1990.   Trip Report-APHIS/IS,  Region  IV,  Africa,  by  Carl  W.
Castleton, Area Director (Africa), in Guinea-Bissau from April 23-30, 1990.

CPS, 1990. Materias e productos recebidos-disbribuicaes, camapanha Fitossanitaria
de  1990,  prepared by Pedro  Landim,  Head  of  Field Operations,  National  Crop
Protection Service, Guinea-Bissau.

Farm Chemicals Handbook, 1990.   Meister  Publishing Company, Willoughby, Ohio,
USA.

GIFAP, 1991. Disposal of Unwanted Pesticide Stocks, booklet prepared by GIFAP,
the International  Group of National Associations of Manufacturers of Agrochemical
Products.

Jensen, J.K., 1983.  Trip Report  to  Dar  es Salaam and Zanzibar,  July 6-11983,
prepared by J. Jensen for USAID, REDSO/ESA, Nairobi, Kenya.

Jensen, J.K., 1987a.  Trip Report - Pesticide Disposal  Sana'a,  Yemen, June 26 -
July 4, 1987.   Prepared for the Consortium for International Crop Protection,
4321 Hartwick Road, Suite 404,  College Park, MD 20740, USA.

Jensen, J.K., 1987b.  Trip Report - USAID/OFDA Pesticide Disposal Survey Team to
Sudan, Ethiopia,  Kenya and Somalia, May  28 -  June 25, 1987.  Prepared for the
Consortium for  International Crop Protection,  4321 Hartwick  Road,  Suite 404,
College Park, MD 20740,  USA.

Jensen, J.K., 1990, Pesticide Storage  and Disposal in Guinea-Bissau, West Africa.
Trip report  prepared  for the  USAID Guinea-Bissau Food Crop Protection Project III
and the Government of Guinea-Bissau, by Janice K. Jensen,  Environmental Chemist,
USEPA, Washington, DC, July 1990.

Krueger, R.,  1989. An  Examination  of the  Problems Created  by  the  Long-Term
Storage of  Pesticides  and  Empty  Drums  (in Morocco)  and  Some Suggestions for
Management of the Problems,  by  R.  Krueger,  Office  of Pesticide  Programs, USEPA.

Lawless, et. al.  1975. Guidelines  for the Disposal  of Small  Quantities of Unused
Pesticides,   by  E.W.  Lawless,  et  al,  prepared  for  the Office  of  Research and
Development, USEPA.

USAID,  1988.   Guinea-Bissau  Food  Crop  Protection  III   (657-0012)  Project
Evaluation,  USAID/Guinea-Bissau, February.

World Environment  Center, 1987.   Evaluation of Disposal  Options RE:  Pesticide
Waste in East Africa -- the Sudan, Ethiopia, Kenya, and Somalia.
                                      156

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                  DOWNSTREAM INJECTION EQUIPMENT FOR SPRAYERS
                            AND  FERTILIZER  SPREADERS

                                       by

                 Arthur  W.  Mclaughlin, Consumer  Sales  Manager
                                Agway Inc., MTS
                                  Cortland,  NY

                      Stanley A.  Weeks, Ph.D., Director,
                   Farm Systems  Research &  Applied Technology
                                  Agway Inc.
                                  Syracuse,  NY

         01 in  L. Vanderslice, Equipment Testing  & Engineering Manager
                          Agway Farm  Research Center
                                   Tully,  NY
 INTRODUCTION

      Agway Inc., a regional agricultural cooperative, owned by 91,000 farmer-
members provides truck mounted custom application spraying and spreading services
on farms in twelve Northeastern  states.  Motor Transportation Services (MTS),  is
a division on Agway Inc.  It is  responsible  for  manufacturing and/or  assembling
the truck mounted equipment that service 287 Agway owned stores, 350  certified
representatives, 54 fertilizer plants and contract operators for Agway. A total
of 213 liquid applicators and 219 lime and  fertilizer  spreaders  at 80  locations
cover from  2,000 to 15,000 acres  each  per year with 90%  of the liquid units
applying some kind of agricultural chemicals.


BACKGROUND

      Because of Agway's total  involvement  with  agriculture and  the application
of crop protectants, fertilizer, and lime to improve crop production,  Agway has
made major efforts to improve facilities, spraying and spreading equipment.

      In 1975, a major research effort was  initiated resulting  in a new design
for spraying equipment which produced constant  application rates regardless of
ground speed.   This design in turn was reflected in less driver error and more
exact control  of  the  amount of  material  applied per  acre.   These improvements
became standard on all new Agway spray trucks and were made available to retrofit
older spray units.

      In 1977-78, Agway introduced impregnation (usually of herbicides) of dry
fertilizers in  their  fertilizer blend plants.  This  allowed spreading by all
available spreading equipment but caused some  problems with cleanup in order to
prevent contamination  of blend plant and spreading equipment.  Also, segregating
and storing impregnated  leftover material from field miscalculations of acreages
was a problem.  Washing  units after  use and waste water disposal  was a strong
concern during this time period.   Agway studies showed  that from seventeen to
twenty gallons of water were required to internally and externally wash down a
650 gallon sprayer unit and its booms.

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      In  1983,  a  dilute pesticide management facility was  constructed at the
Agway Farm  Research  Center (AFRC) at Tully,  New York.   This  consisted  of an
underground,  roof covered  storage  system with  an  adjacent,  interconnected
building  with  concrete washdown  pad  and an  ag  chemical  storage  room.   This
facility  was based  on  the  design  of   the  Iowa  State  units  that  had  been
functioning  successfully  for several years.   The  idea  was to  construct and
monitor a unit  that  would serve as a model  for  possible  future facilities at
Agway sprayer and  spreader locations.  Monitoring began in  1984  and  continues to
the  present  in cooperation  with  New York  State Department of Environmental
Conservation (NYSDEC).   The facility has been operating continuously since it was
installed.

      During the  early 1980's,  Agway cutbacks in  people  and  research funding
delayed research work on experimental  and/or  prototype units but work continued
on studying the problems and  travel to witness demonstrations of some equipment
made by other  manufacturers.    It  was recognized that rinse pads  and storage
structures were not only expensive but that the time required for sprayer units
to come in from the  field  to be cleaned  and  reloaded  before going back to the
field was  not cost effective.  Studies were initiated on the concept of chemical
injection  systems using positive displacement pumps as well  as  pump-tube units
during this period but  funding to build a unit was unavailable and we could find
no one in  the industry to cooperate with Agway in putting such  a unit together
for field  testing.

      In 1986, some research funding became available and hydraulic boom controls
were designed allowing  variable  boom height adjustment  and folding and unfolding
the booms—all  done by a touch of the controls by the driver in the cab.   This
innovation provided ease of changing from short to tall crops, hastened entering
and exiting fields and cut down on driver fatigue.

      Also in 1986, a spray truck  tank rinse  and wash-down system was developed
that allowed the inside of the spray tank to be rinsed  with clean water and then
sprayed off in  the field.  A hose and hand gun nozzle were a part of this system
so that  after inside  tank  rinsing, the outside of the truck unit could be rinsed
with clean water before leaving the field and traveling down the road.  An eye
wash system was also made a part of this cleanup system.

      During this time period,  a second  look was taken of the direct injection
project and  information  was assembled  from various resources.   From  this
assembled  information,  specifications  for a system were established. The number
of modules,  rate  controllers and  interfacing  were specified  to adapt  to Agway
sprayer systems in the  field.  Agway selected a three module system  with fifteen
gallon tanks, positive displacement  pumps  and range  capabilities  of  5 to 200
ounces per minute  for  each module.   The  Agway concept was  to inject liquid ag
chemicals  directly into the  boom  on  a spray truck  so that  it  could go to the
field with  clean  water in the  tank and have as many as three  separate  crop
protectants and/or liquid  fertilizers directly injected into the boom where they
would mix  before  being sprayed through  the  spray  nozzles.    Since  each  crop
protectant is carried in its  own special  container,  at the end of the field the
container valves can  be shut off, fresh water from the spray tank flushed through
the boom,  and a clean  machine  is  ready  to leave  the  field  and go to the next
customer with a  clean rig and a clean  tank of water (no rinsate or leftover spray
mixes for  disposal).   Such a system added from $8,000 to $10,000 to  each sprayer
unit and no  store  location could be found  willing to pay this  additional  cost for
a unit.

                                      158

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       In September 1989, Agway top management made the decision  that at least one
 of these injection units would be placed  at strategic locations within the Agway
 territory  so that experience  with  operators,  managers and customers could  be
 obtained.   The plan was  to  place  each  unit at  a site having an  experienced,
 well-trained driver and a diversified spray business that was well  established.

       With this mandate, nine downstream injection sprayer units  were built and
 eight  of them were placed at strategic locations in the field during  the Spring
 and Summer of 1990.  The ninth  unit was kept at  MTS  for testing and research work
 with  chemical  companies with  new products.  During the Spring of 1990,  newly
 formulated liquid and  dry flowable  ag chemicals from Monsanto and DuPont were
 tested through the MTS  unit.

       In the early 1980's, pneumatic spreaders  were new, were investigated,  and
 found  to be inferior in spread pattern performance when compared with Agway's dry
 spreader trucks.  As time passed and more manufacturers entered  the  field,  the
 air spreaders  showed  improved performance.   After six  years of evaluation,
 attending demonstrations, and  testing different  brands  and models  it  was  found
 that the Tyler pneumatic spreader was the unit  that could be recommended  for use
 by  Agway.

       In the Spring of 1989,  a Tyler unit was purchased and  put into  service  at
 one of Agway's western New York locations.  It had  the  capability  for on-board
 impregnation  (both  liquid and dry),  which  is  a  method of one-pass, in-field
 mixing and application of herbicides and  fertilizer.  The key to this  concept  is
 that it takes mixing away from  the blend plant and puts it in the field where the
 product  is  being applied.    Only  the amount  of  herbicide  and/or  fertilizer
 required is  applied and there  is no mixed product  to go back to the  plant.   It
 also saves time and allows the fertilizer rate to  be varied on-the-go.


 DISCUSSION AND RESULTS

      The Tyler air spreader successfully operated in the field for 6,200  acres
 in  1989 and  8,200 acres in 1990.   A  new improved  liquid injection system was
 installed and replaced the old liquid system on the unit after  the  1989  season.
Although this spreader unit has the capability of both dry and liquid  fertilizer
 impregnation, the operation manager and  driver feel  that the liquid   system  is
 superior and used it exclusively during  the 1990 season.

      Each injection sprayer  unit operated  in  the field covered  from 2,500  to
 14,000 acres  for  the 1990 season.  A questionnaire was sent to each location and
 filled out by  the store manager  and equipment  operator.   Follow-up personal
 interviews were also conducted with  some  store managers and operators.  From the
questionnaires and interviews  Agway learned  that some equipment  modifications
will be  forthcoming  on all  1991  models that  will retrofit the  1990 models.
Results of the first year of  testing and  interviews with fanners and Agway Crop
Center managers clearly indicate that application accuracy and protection of the
environment were  both achieved with this type of equipment.   Injection  equipment
had the following advantages over conventional  spraying equipment:

      •  Main spray tank contamination eliminated  --  no unused product  in the
         main supply tank.

      •  Ground orientation was the most accurate system ever used.

                                      159

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       •   Rate and chemical  changes  can  now be made in  the  field.

       •   Costly run-outs  and  mix  times  are reduced or  eliminated.

       •   Exact usage  of chemicals.

       •   Unused chemicals can be easily  transferred from 15 gal. module tanks to
          containers.

       •   Reduced cost  for wash  down  and  containment areas.

       •   Environmental  threats  minimized.

       •   Ability to go  to isolated,  distant  field  locations and spray  all  day.

       Acceptance of the injection sprayers by customers has been outstanding.
Most  demand  that  their fields  be  sprayed  with  the  new  injection sprayers.
However,  when  asked, most are not willing  to  pay any more  for  the service  than
for conventional,  less  accurate equipment.  The dilemma faced  by Agway is  that
in high  competition  areas,  spraying or  spreading  rates  are determined by  the
lowest bidder  and  expensive equipment will not pay  for itself  unless a higher,
more realistic  fee is charged.  Also, Agway  is forced to charge the same price
per  acre  for  the  more  expensive  equipment  as  they charge  for  their   own
conventional equipment.

       Because of mandated state and  federal licensing requirements for  applying
and storing crop protectants, many farmers and small  custom applicator operations
have made  the  decision  to get  out of the application business.  This  puts  the
burden of  providing equipment, chemicals and the storage of chemicals  directly
on those who have chosen to remain in the custom application business.   Agway is
especially concerned with handling  and   accuracy in applying  ag chemicals  and
fertilizers.  One of the primary challenges  for Agway is handling of ag chemicals
that must  be returned from the farm  (such  as sprayer rinsate)  to an Agway farm
center location.   Ag  chemical  storage and containment  structures  can  be very
expensive.

      State and federal  laws and mandated requirements continue to change so that
those  trying  to comply  to  the best  of their  ability are always shooting at a
moving target.   A  good  example  of this  is  Agway's  dilute pesticide management
facility.   It  has been monitored continuously  and  functioned  successfully  as
designed  since  1983.   If  a  similar  unit of the  same capacity  was  to be built
today, the cost would  be  from two  to  three times  the  cost   of the original
facility  because of new mandated  structural  requirements.   Inflation over  the
eight year period would, of course, add even more to the cost.  Agway originally
planned to build these management facilities at many locations, but now cannot
afford to do so.  When rules are different from state to state it becomes very
difficult to meet competition.   Agway feels that  all  its facilities and  all   its
equipment must meet the requirements of all states.

      For  1991,  six  new  injection  spray units  are expected  to be  built   and
located at strategic Agway locations.

      Agway Inc.  is not in  the equipment  selling  business.  All  equipment  is
designed and specified in-house  and built to Agway specifications by others,  and
used at Agway locations to serve  farmers.
                                      160

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                     Evolution of the Pesticide Container
                          Disposal  Program in Alberta
                                   (speech)

                                      by

                        C.G. Van Tee!ing and W. Inkpen
                              Alberta Environment
      I would like to outline our present comprehensive system in Alberta.  We
do have a complete system which is up and running.

      In this discussion, I will indicate how we got there as well as pointing
out  things  that did  not work.    Finally,  I will  describe some  of  our still
outstanding  problems,  some  of which  I  hope will  be  solve though information
exchange at these types of meetings.

      The present system in  Alberta,  handles  each year about 700,000 containers
made up of about 500,000 plastics and 200,000 metal containers or a million Ib
of plastic and metal.

      Our system started in 1980 when one of our staff members collected loose
containers in the coulees of  Southern Alberta  and  piled  them in  a snow fenced
enclosure.  Within a short time farmers had started  to use the site as  a drop off
place for the container.  During  the years,  1980 to 1986,  Alberta Environment
started to provide funding to  the local level of government  to  build these sites
and periodically contracted for their clean out.  There was no planned program
as the program grew  incrementally.   But  by 1986,  Alberta Environment realized
that it should not  be involved and wanted to  turn the program  over to industry.

      The present system consists of 106 sites classed as permanent. These sites
received  funding of  up to  $10,000  per  site  from Alberta   Environment.   We
published construction  standards  and guidelines  to ensure  that the sites were
well constructed.  In the design, we followed three principles namely security
ie fenced: containment,  ie  berms  and clay  or plastic  liner and water control.
The province has a dry  southern half where we recommended evaporation areas to
remove the projected rainfall  while  in the  northern parts with high rainfall we
recommended roofs on  the sites.   At  this time  more than  2/3  of the sites have
been upgraded although a very small number of  local levels of government ran into
siting problems.  The word NIMBY describes  the problem.   The local  level  of
government can set  up any  number of their own  temporary sites  but the system
allows for clean out only from the permanent improved sites.

      The sites  are operated by the local  level of government,  either a municipal
district, a county or in some cases  a regional  Landfill  Authority.  The sites
therefor are a local responsibility and is legislated under the Public Health Act
which make the local level of government responsible for wastes generated within
their jurisdiction.  The system thus  operates  as part of the  waste  stream without
any extra costs  or  facilities.  The  106  sites are operated  by  64  of these local
levels of government.  The most any  local government has is four sites and the
average would be one  or two sites.   A great deal  depends  on  the shape of the
local unit.   In  cases where  the  farmer  may have to drive greater distances we
have provided for another site.


                                      161

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      In our system, the farmer is responsible for triple rinsing and bringing
the empty containers to  the sites.  Our agriculture consists  of wheat barley and
canola with an average  farm size of one to two sections.   We  do not have a large
percentage  of custom  application.    This means  that  we   have  to  train  the
individual farmer to triple rinse.

      The Alberta Environment Minister has appointed the Alberta Special  Waste
Management Corporation to act as  program  manager.   The Corporation  is also the
part owner of the Swan  Hill Waste  Treatment facility.  The Corporation puts out
a tender to the private  sector for the clean out of all the sites.  The clean out
involves the shredding of the plastic  and metal, transport to  a storage location,
processing and washing the material  and finally recycling.

      We have  one  processing plant  in operation  operated by  Wearmounth  Waste
Services in Medicine Hat, Alberta.   The  plant is  based  on  water washing with
carbon  absorption  of  the pesticide material,  all  in one closed loop  with no
discharge allowed.  Another plant is  on the drawing board by Newalta at Ryley,
Alberta.

      The washed and processed metal  is  sold as  #2  scrap to  an  Alberta  scrap
dealer.   They in  turn will ship the material  to one of two Alberta steel mills.
The steel mills  have  indicated that  they will accept the metal  as  long  as it
meets our  100 ppm standard  and  there  is  no odor  or  liquids  which can be
identified a; pesticides.

      However the recycling of plastic material is another matter.  We funded an
early study which clearly indicated that even  over prolonged  extraction more and
more pesticide could be removed from  the  plastic.   It meant  that pesticides can
migrate   into  the plastic and that we would  never  be  able  to remove  all  the
contaminants from the plastic.

      On the recycling of plastic, the joint  industry and government consensus
in Canada is that we have three options: either into new cans, into other plastic
products or incinerations.   As government policy,  we are not  in  favour of the
incineration options for various  reason.   The first option of closing the loop
into new containers will  require a number of years of lead time which leaves the
middle option.  We have done  some  trails  on fence  posts and  curb stops with the
Superwood process.   We would  consider geomembrane liner or other uses as long as
we could get some comfort as to the final use of the end product.

      In summery, it is hard  to predict how we will finally  recycle the plastic
material.  We  recognize  that  some of these concepts belong in the private sector
although we are interested in ensuring that the material  is  handled properly in
recognition that they do contain  residues.

      I   indicated  that  in   the  early days  of  the program,  it was  Alberta
Environment  that  operated   the   program.     However that  changed  with  the
establishment of the "the polluter must pay"  and "industries being responsible
for its  own wastes" concept.  The  Canadian industry took the position that  it was
a shared responsibility.  Consequently we had a two year time period where the
containers piled up on our sites.   Industry did take  a major step by collecting
a $1.00  surcharge per container shipped into Alberta.  That meant  that there was
money on the table to set up a program.

      In Canada,  we have the Crop  Protection Institute of Canada to represent the
chemical producers.  CPIC would be your equivalent to NACA.


                                      162

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       Starting in November  1988,  CPIC collected  the  $1.00 per container  and
 places the money into a Trust Fund.  I understand that the operation of the trust
 fund by CPIC  involves  no extra staff or other costs.  The money collected is to
 be used to cover the operational disposal costs as well as such agreed to costs
 as farmer education  and research.

       We recognized very early on that we needed toxicology  support in areas such
 as occupational  health and  recycling.   I  have been on container sites  in  the
 middle of an  Alberta summer day and there is a smell  of pesticide  there.   Our
 strategy was  to bring together a number of Universities resources and set up our
 toxicology  support  system.    That  system is  now made  up of  staff from  the
 Universities  of Guelph,  Alberta  and  Saskatchewan.   We  thus  have  available
 independent expert advice  to ensure  that we  are operating  a safe system.

       A major study  is currently underway by this  toxicology  network.   We  have
 a  $250,000 project, all paid out of the CPIC funds, made up of four  components.
 The  first component looks at  the occupation health aspect of the crews that clean
 out  the sites.  We expect to  get the  first result in May.  The second components
 looks  at the  occupation health aspects of the washing and  processing plants.
 Thirdly we will look at the recyclers either the steel  mill operators or in  the
 recycling plastic plants,   all  for occupational  health.   Finally,  we will
 investigate  a number  of plastic  products   as  suitable end  products  for  the
 pesticide contaminated material.

       In the program we always run  up against the rhetorical question "How clean
 is clean" or  "What level of contamination will  you accept?"  Again we turned to
 our  toxicology support group and they have set  an arbitrary standard of  100  ppm
 of total pesticide.  We use a standard  screen of the seven most common chemicals
 in  Alberta   including   trifluralin,  triallate,  bromoxynil,  2-4-D, M.C.P.A.,
 picloram and  diclofop-methyl.   We use  this  standard as a requirement for  the
 final wash processing  step.  The figure itself is based on  WMIS  standards and a
 safety  factor of 10.   The guideline is useful in that it provides for a quality
 controllable  endpoint   and  a  level  at which  we  will  class the  material   as
 recyclable.

       I  have talked mainly  about the Alberta  program.  However,  I should stress
 that we  are  part of a three provinces block where we  share  the same  agriculture
 and  disposal  problems.  While  each  province,  has  its  own infrastructure,  we
 freely  exchange information  and coordinate our programs.   Looking at the three
 provinces, our market  now comes to nearly 2.5 million containers in  total.   It
 is a hope that eventually we will rationalize the  system so that if  becomes  as
 efficient as possible.

      In the programs early stages, we took the  strategy of identifying all  the
 stakeholder  in the  program and  bringing   them   around  one  table  to  share
 information  and ideas.  The committee of stakeholder is made up of interested  and
affected parties.   It  has no formal power at this  stage.

The stakeholder we have around the table are:
         two farmer end user
         an  Alberta Environment member  involved in regulations and monitoring
         one representative of the  local municipal  governments who operates  the
            waste streams and sites
         one CPIC member
         one representative of the  Boards of Health who are  active in  the public
            safety aspect


                                      163

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          one  member of  the  recycling  industry
          one  member of  the  regional landfill association who operate the  sites
          one  representative of the operational agricultural staff  involved  in
            rural  agriculture.

      The committee meets  about every  three  months.   It  has served  as  an
excellent sounding board for new  ideas and approaches to operational problems.
The  individual  members  serve   as  informational  links  to  their respective
organizations  who  continue  to support the program.

      Each  of the  above  stakeholders has  an  important  part  to  play  in  our
program.  Many aspects of our system are  unique to our province.  But I believe
that the  concept to identify your stakeholders and work them into  the decision
making process makes the program work better.

      Alberta Environment role is  in the monitoring and regulatory areas.   I have
indicated that we provided site  design specifications.   We  also  soil sample  off
and on  sites.   We have established water  wells  to  monitor for  any  off site
movement.  We  inspect sites three to four times a year and can take regulatory
action if sites are not operated correctly.

I would now like to touch on some problems we have faced.

      We are not happy with the amount  of "other than pesticide containers" waste
streams on the sites.  The sites are not under our control and we are addressing
the problem though various education and  training  program.  The presence of  any
of the other wastes on the sites, increases the program costs.

      Our sites grew up around the various landfills.  The containers have become
associated with wastes and being just another waste stream.  As a  consequence,
people have taken to dropping off  other wastes stream including household wastes,
industrial wastes and  hazardous  wastes on  sites which were  not planned for this
purpose.  We are vigorously pursuing  proper site maintenance and  operation as  per
our own guidelines.  If sites are not operated properly we will not clean them
out and we  have  the legal  power to take other actions  to  remove  other  wastes
streams from the sites.  What I  want  to  suggest  is that you  consider locating
site outside of the general  waste stream.

      We are still  not happy with  the triple rinsing done at the  farm level.  We
believe that the  solution to our problems  starts with the farmer triple rinsing.
We estimate that about 70% of can are washed.  The problem has  to  be addressed
through education  and I suppose we must be patient.  Both  industry, through CPIC,
and various government agencies  are getting  the  message  out.   We  still  have a
long way to go on farmer education keeping in mind that we are dealing with more
than 50,000 farmers

      We have  had contractor problems.  Many did not know what business they were
getting into.   The first contracts were not specific and open ended as to what
was required.   We  both  learned  on the fly.  Some contractor quickly  left  the
business but a few have survived.  In the future, we will both  be  getting more
efficient leading to decreased costs.

      In the early stages there  was a lack of funding.   This  was solved by  the
$1.00 per container surcharge.
                                      164

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       It  took  nearly  three  years  to  resolve  the  government  vs  industry
 responsibility.   Right now,  government is still too  heavily involved  in  the
 program.   We agree  that all  parties must have an  active  and supporting role in
 getting  the  system  operational.  We want to help and be around the table but we
 do  not see our  role working  on the  operational  aspects of the program.

      We have a major question mark  in regards to  the washing  and  processing
 steps.  We believe that washing or processing  is necessary.  However the current
 water washing and  carbon  filtration may not do the job.   It  is  old  technology
 which has  some  questions  in  regards to  costs,  efficiently and through  put.

      The  final end products  of the recycled plastic  material  is still not clear.
 I outlined the  three options.   The  future  may be  a  combination of the  three.
 We  may also  take the attitude  that  this is an industry problem and our program
 will voluntary  or involuntary  give  it back to industry.

      Perhaps this  next one deserves a  separate heading.   It has  to do  with  the
 total costs  of the program.  As noted, the funds collected under  the program is
 currently  $1.00 per  container.  However,  it is  clear now  that this will  not be
 enough.  We wont get an accurate figure until  we have  been in operation for  two
 or  so years.  We may be able to rationalize the system and  optimize  it between
 provinces  and thus be able to cut down costs.  We need to  finally  close  the loop
 by getting rid of all the  material.  So  we  have a number of uncertainties impact
 my  estimated  cost figures.

      My best guess  is that  the final figure  will probably  be around the $1.50
 per  container in Canadian  dollars.  This is  a  best  estimate  based  on some
 practical  experience and  some future assumptions.  Not  all costs for  example
 those from   CIPC or  government are  attributed  back  to  the  actual  program.   The
 local levels of government do not  in Alberta at present receive any funding  for
 their work.   Also Alberta Environment has funded the site construction for  an
 estimate of  $1.5m Can.

      That brings me to the  last point.  The  provincial government has  largely
 carried  out   the  program  even thought  we believe in  the  "cradle to grave
 environmental principle."   We are able to turn over a functioning  system at this
 time to  industry.   Industry  can and should be able  to operate the system much
 more efficiently and effectively and be in a better position to control the costs
 which in our  program seem to be rising  steadily.

      The program has been voluntary up  the present time for all parties whether
 farmer or  industry.   With the current  legislative  review in Alberta,  Alberta
 Environment  will  be  gaining  broad new   powers  in the  recycling  and waste
minimization  areas.   We  are  prepared to  legislate  the recycling of pesticide
container by all parties  if that becomes necessary.  We hope  that  industry will
take over the program in keeping with the cradle to grave environmental approach.
                                      165

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                  Retail  Fertilizer Dealer Product Containment

                                       by

                               Michael F. Broder
                             Agricultural Engineer
              National Fertilizer  and Environment Research  Center
                             Muscle Shoals,  Alabama
INTRODUCTION

      Environmental  protection  is  one  aspect  of the ratal 1  fertilizer industry
that has become as important as the products and services the retail fertilizer
dealer supplies.  This emphasis on environmental protection at the dealer level
has largely  been  in  response  to regulations being  written by  some  States to
protect groundwater.  States were given the  predominant role in developing their
own groundwater protection  strategies  when  the  U.S.  Congress  passed amendments
to the Clean Water Act in I'W.  To keep abreast of regulations being developed
and to  maintain  public  trust,  in  the fertilizer  and  agrichemical  industry,
fertilizer dealers have been called upon to  take an active role in promoting the
protection of groundwater,  7M$ paper  describes  :.r  cjf-oundwatt-" contamination one can begin to
design an environmentally  sound  frrtiiuer  dealership,   Sources  of groundwater
contamination can  be  gn,up( r. c,-^- •  ff"^e  headings:   water  supplies,  transfer
areas, and storage ^rt.ts
      A  poorly  designed  v-:
contaminants to  move  di^cU
supplies must be design-?-:? fr-
system.

      Transfer areas  (wi..-v .
from the mixer)  are  sites of >
if not  properly contained,
runoff,  are  as  likely  to  r •
mobility in water make it s;;<
in contact with rainfall.   Ni
to spillage of dry  ni

      Storage areas a
or piping attached to  tank;-
surface water and eventually
fertilizer stored under rocf >.
is in a  low  area orone to  ~
areas that flood, however.  ','•<'.
than ideal from  an  er-vir-jr-rsCi
                                i-'j  ••'  one  H:
                               ipl/t  Around ,-«t/
                                '•''>!";*' ;fi'JT, _ r 1 ;1 I  f
o.  faulty  casing   can  allow
 Connections to public water
33 :k  siphoning  into the water
                              rc-c'.-v:  <.   naoed,  urH-,<;c.:d,  or  transferred to and
                             (!'. Kif.'fiia"; -piI i <•  that  find  their way to groundwater
                              \orr-, -.~r'y materials,  net protected  from rainfall
                             ";.-:•  Inc croundwater  as are  Hquids.   Nitrate's
                             , -Yt  'i.i! ° ! .  learn inn from any nitrogen fertilizers
                              n'"' ' :/il?n^!i3ticn of ground vater has been linked
                             a,-* ; • - ,-cr   at dealer  location',.
                                                 j.-idwa^er contamination.   Tanks
                                                 fw.sive f.pi!l that can pollute
                                                 ..ontained in a dike.  Even dry
                                                 t.r* during storms  if the storage
                                                 dre not  likely to  be  built in
                                                 1 o-' -ted in  areas that are less

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SITE  SELECTION
       When  choosing  a site (:•• <  now \- o ;!.:')>'. or  : tiar^r,^ my  an existing facility
the  environmental suitability  of the  s'le  should  be assessed.   An ideal  site
should be located a  safe  distance froii private wells or surface water supplies.
Sites  in a flood plain or with shallow groundwater depth should  be  avoided.   Soil
bearing capacity  should be sufficient  to support the  loads of buildings, storage
areas,  and  vehicle traffic.   Existing drainage patterns and  topography should be
studied  to  determine how the
off the  site.  A  loading pad
runoff.   Likewise, a wpl1
pesticide  handling  areas.
airborne should  ba locate'!
associated  with  vehicle  t,
should not  be  located in i;
                               • 'j\'',
                                are
 is  affected by surface water movement  on  and
 /,,1'iiple, should not be  located  in  the  path of
 o: be  lj:aied  down  grade from fertilizer or
 V-rsf'.ip handling  frail-rials  that  can  become
 d 1ue to the  liability
  of  fbrtihfe;  -srd  pe?tiroes, a dealership
 •,i>  when: traffic  irooien'S
      A  problem facing man,-,
This  is  common  in  the  tasi  *r
built in rural areas.  In  thcv-
to relocating to a more  f
upgrade  of  a  facility
o-:; b
                                             ir  clr-,e '.,ro,., ;iri< v  to  urban areas.
                                             '-jruw?< ^rai^n oual^r s~tes that were
                                            i-r:ous cons iaer•:):<
should  be  consuHed  whon uea
                              rr-a ;oiu';0 ; f
                   -, <,.v;-  i*v  '•:  ir.  Important
                   :->m past  practices.   Those
                    i.,uuetun;  should  consider
                    r.oi i  sf.ould be tested  to
                    If the- cor.taninants  are a
                    t'ire  -Jiat prevents further
                   rtiMt; ?:hicn do  not readily
                    !!••*•  ;:.'U  •-  clean-up  costs
                    . P I
                                                               '.-a
                                                                ih
                                     secondary
used  as
  i-alers  in  states
     -.,  attainment
     rank failure.
     e   "loading  and
                are
Wellhead Protection
      The  first  step  in  making  .
inspect the water source.  DeA-t:
the wellhead.  The concrete  p?«  ,
above the  surrounding  area to  9; .
Runoff allowed to pond arouna tile-
way to groundwater  by  seaping  ^r.
casing.  The risk associated vfii.^,
that regulations  us  hon.-- :,tii.-'
handling facilities  wHhin  '•.').'•  o
Agriculture,  1989;  Souln Oak:' ,  .
                                               t  i i environmentally secure is to
                                              ,ite w?11 should thoroughly inspect
                                              -round  the well  should be elevated
                                              -ft  -i-;  carried ?»viay from the well.
                                               1 •.;,-- t,'-;.ii-  the wellhead can find its
                                                • .sine -„•-  i.hrough a crack in the
                                                               
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      Frost  pits  are not  allowed  on new  well  installations in  most  states.
Dealers with a wellhead in a pit  should consider extending the casing above the
surrounding soil surface.  The minimum recommendation is to ensure that the pit
is water  tight  and that no  contaminants  can  enter the pit.   Local  officials
should be contacted concerning requirements for private wells.

      Abandoned wells or wells that are rarely used are common at dealer sites.
These should be  retired and sealed.   Generally a permit is required  to close down
a well.  The Cooperative  Extension  Service  or local Public Health Office should
be contacted for details regarding well  closures.

Water System Protection

      All connections to the process water  supply system should be inspected to
ensure that fertilizers  and  pesticides can not enter the  water  system by back
siphoning.  Areas where  this  can occur are through the  water inlet  to the mix
tank or where vehicles are filled through a bottom connection.  Even hoses which
have their discharge end  submerged in a pool of liquid  can allow material to back
siphon when there  is a loss of pressure in the system.   The two standard methods
for preventing  back  siphoning are  an  air break tank  and a reduced  pressure
principle zone (RPZ)  valve.

      An air break tank is  merely a  water supply tank which receives water from
a well  or public water system through a pipe having an  air space between the pipe
discharge and highest  water level   attainable in the  top  of the  supply  tank.
Generally, the distance  between  the pipe  and maximum water  level is  two pipe
diameters.  The  supply tank generally provides water for the entire facility and
a pump can be used to boost pressure if the static  pressure in  the supply tank
is inadequate.

      An RPZ valve is a special device  that has  two independently acting  check
valves and a pressure differential  relief  valve located between  the  two  check
valves.   When there  is  a loss of  pressure  in  the  water supply the  two  check
valves close to prevent the flow of water from reversing and siphoning process
material into the water supply.  One undesirable  feature of RPZ valves is that
they may reduce  line  pressure by  as much as 10 psi.  These valves may have to be
regulated  by  State or  local  agencies  and will,   thus,  require  approval  for
installation and be periodically tested and inspected.

Transfer Operation Containment

      Transfer  operations   include  loading,  unloading,  and other  operations
involving the movement of pesticides and fertilizers.  Before emphasis was placed
on groundwater protection,   there was little concern over the small quantity of
material spilled when spreaders or nurse trucks were overfilled.  Likewise, leaks
from valves, pump seals, and dry fertilizer conveyors were not thought to have
a  detrimental   effect  on  water  supplies.   At   some  dealer  locations  the
accumulation of these types of spills have not only contaminated soil  but also
the groundwater.  Consequently,   containment  for loading and mixing  areas are
receiving the highest  priority in  many state regulations  (Iowa  Department of
Agriculture, 1988; South Dakota Department of Agriculture; Illinois Department
of Agriculture,  1989).
                                      168

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       Loading areas  (load  pads) are generally concrete pads designed to collect
 spills occurring while loading tenders, spreaders, nurse equipment, and sprayers.
 The main design features are; liquid holding capacity,  pad  length,  pad width,
 slope,  sump location,  and  sump  design.   No single load pad design  will  satisfy
 everyone's  needs.  Many  pads  are used for equipment washing.  Pads  used to wash
 dirt and residues from field equipment should be large enough  to catch all liquid
 sprayed  while washing  and  should  have  a  good  sediment  removal   system,
 particularly if rinse  water  is intended  for use  in solution  (clear  liquid)
 fertilizers.   The  following discussion applies to both  loading  pad  design  and
 equipment wash  pad design.  At most locations  a single pad serves both purposes.

 Liquid Holding Capacity--
       The liquid holding capacity  of load pads should be based on the volume of
 the largest tank loaded  on the  pad.   For example,  a  pad  used for loading large
 transports  should  be designed  to  hold the entire  contents of  the  transport,
 typically 4,000 gallons  (Illinois Department of Agriculture, 1989;  South Dakota
 Department  of Agriculture,  1990).   One state requires  that loading pads for fluid
 fertilizer  have a  capacity of  at  least  1500  gallons  (Wisconsin Department  of
 Agriculture,  1988).  Some states do not require a  pad for unloading raw materials
 at  the site:  other states  require  load-in  pads but with  volumes  as  small  as  25
 gallons  (South Dakota  Department  of Agriculture, 1990;  Illinois Department  of
 Agriculture,  1989).  Consequently, a single pad used for loading out as  well  as
 unloading raw materials should be sized to  satisfy the requirement  for  load-out
 pads.  Since  incidental spills at raw material unloading  sites are  common,  some
 containment should be provided  for recovering spills.

      The  entire  contents  of the  tank  on a  large   transport  vehicle  can  be
 difficult to contain on a pad  designed to accommodate one vehicle.  For example,
 a pad  12-feet  wide  and  60-feet  long designed  to hold 4,000  gallons  of  liquid,
 will be  2.2 feet lower at  the sump  if the  four edges  are at  the  same elevation
 and  all slope to the sump (see figure 1).   If  the pad has a 12-foot  long trough
 in  the center,  the top edge of the trough would  be 1.5 feet below the height  of
 the  edges (figure 2).   The steep  slope of  both pads would make  vehicle  access
 difficult.

       Increasing the area of the pad permits a shallower pad for a given  volume.
 However, a larger pad will be more likely to overflow with  rainfall accumulation.
 The  pad  in  figure 1 can hold  9  inches of rain.  A pad with the same  volume but
 twice as wide  will be  half as deep and will  hold only 4.5 inches of rainfall.
 Rainfall  can  only  be discharged  if  the  pad  is clean before rain   begins.
 Otherwise,  it must  be handled  as a  dilute fertilizer  or pesticide mixture.  For
 this reason, many dealers are  building roofs over loading pads.   This should  be
 considered  in high rainfall areas.

      One practical  way to  increase the volume of a pad  is to form a roll-over
 curb on the perimeter.  The addition of such  a curb,  4 inches high,  on  the pad
 in figure 1 increases its volume 45 percent (see calculations under  figure 1).

      In some state regulations the volume requirement for the load  pad can  be
met using an automatic sump pump connected  to  a storage tank  inside a secondary
containment basin (111 inois Department of Agriculture, 1989;  Wisconsin  Department
of Agriculture, 1988).  A  more  reliable  method  for increasing the  volume of a
load pad  is to provide  an overflow  to  another  basin.   This can  be  done  by
elevating the load pad above a secondary containment dike.  Buried tanks  or pits
should not  be  used  to store  liquid  from  loading pads.    Some states allow

                                      169

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temporary storage of liquid from load pads (Department of Agriculture  - Illinois,
1989; South Dakota, 1989; Wisconsin, 1988).   Long  term  storage of fertilizer or
pesticides in pits or wet wells is prohibited without an approved ground water
monitoring system  ( Wisconsin Department of Agriculture, 1988).  Dealers using
pits or buried  tanks  should  remove  them or  retire them by thoroughly cleaning
them, sealing all  inlets, and filling them with sand or clay.

Pad Length and Width--
      The pad dimensions should be based on the area required for work done on
the pad.  A pad used for equipment washing should  be  a minimum of 20 feet wide.
If the pad will  be  used for both loading  and unloading, it should be wide or long
enough  to  accommodate two vehicles.   Dealers handling  liquid  fertilizer and
pesticides may need extra space for loading or unloading mini-bulk containers.
Some dealers may require space on the load pad for tanks used to store spillage
or rinsates.   Experience  has shown that load pads are never too large.  Load pads
40 feet by 60 feet are not uncommon for fluid fertilizer/pesticide dealers.

      Pads for  loading dry fertilizer must be  sized  to collect material  which
spills over the  sides of spreaders or tenders.  Experience has shown that the pad
should extend about 10 feet beyond each side of vehicles being loaded with the
elevation of the edges of the pad being about 4 inches above the center.   Pads
for dry materials have no volume requirement.  A gravity drain with a lockable
shut-off valve can  be installed to discharge snow melt or rain free of fertilizer
and  pesticide  residues.    As  in   liquid  operations,  rainfall  accumulation
contaminated with  fertilizer  must be  handled as  a dilute fertilizer/pesticide
mixture.  Most problems associated  with rainfall  and snow can be eliminated by
building a roof over the load pad.

      Spills occurring while filling dry fertilizer bins should also be collected
and kept away  from rainfall.   Some dealers  place the  boot  of portable augers
inside a large  tray  to collect  spillage.  The  most  common type of containment
around these areas is a concrete pad that facilitates the manual collection of
spilled material.   Railcar unloading areas are a problem to keep clean.  The best
way to keep the area between  the tracks  clean is to pave the area and slope the
pavement away from the conveyor.  A  water tight  lid  should  be placed over the
conveyor to keep rain water out  of the conveyor.   This is critical if the bottom
of the  conveyor is  not  sealed to  prevent   water from leaking out,  carrying
fertilizer nutrients downward.

      Liquid  railcar  unloading sites have been  contained by paving  the  area
between the tracks  and sloping the pavement to a point where a tie can be removed
permitting liquid to flow under one rail and into a basin  where it can either be
used as  make-up water  or,  if  free  of contaminants,  discharged.    There  are
prefabricated pans made of fiberglass reinforced plastic that can be installed
between and  on  both sides of  the  rails for  collecting liquid  spills.   These
prefabricated pans are sloped  to built-in sumps which  facilitate  the recovery of
spilled material.   Portable  pans  can be used to  collect  small  spills  at  rail
sidings, however, catastrophic  spills are difficult to contain.

      One method for containing large spills  at liquid railcar loading areas is
to install a synthetic liner  in  the gravel beneath the tracks.  The liner can be
extended away from the tracks and sloped to a sump for recovering liquid.
                                      170

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       Few dealers have installed spill containment systems for railcar loading
 and unloading areas and state regulations have not addressed this problem.  As
 containment technology  and regulations progress, more  methods  for containing
 spills at rail sidings should be developed.

 Pad SI ope--
       The slope  of  loading pads should be  a minimum of  2  percent.   Concrete
 surfaces which come  in frequent contact with fertilizers  or pesticides should be
 sloped 2  percent to minimize the  corrosive  effect  of  these materials  and to
 facilitate the washing down of the pad (Noyes, 1989).  This slope is preferred
 over shallower slopes because  it reduces the chance for errors in finishing that
 will cause liquid to puddle on the pad after being drained.

 Sump Location--
       The location of the  sump depends on how it is used  and how vehicles travel
 on the pad.   If the  pad  is to be accessible from all  four sides,  then the sump
 should be near the center of the pad.   A sump located in the center of the pad
 can interfere with  the movement  of product  if the sump has to cleaned  out or
 manually pumped out  while product  is being loaded.   For this  reason  sumps are
 often located on one side of the pad.  This  still permits vehicle access from
 three sides.  Some dealers have a sump  in the middle of the  pad and a deeper sump
 on the side.   The two are  connected by a trough or a pipe that runs beneath the
 pad.  The  sump in the middle of the pad  traps  solids while  liquid is pumped from
 the second sump.

 Sump Design--
       Sump designs vary considerably  in terms  of how they are used  to  handle
 solids.  Suspension  dealers who can handle solids in their products have  simple
 sumps  and  pump all the sediment directly into  applicators.  A screen either over
 the sump  or the pump inlet is used to remove rocks,  cigarette butts  and  other
 debris.   Other dealers go  to  great length  to separate all solids  from  liquid
 being  recycled.  These dealers either use an extra sump for  solids removal  or use
 a  sediment trap around their sump.  Figure 3 shows a  typical  concrete  sump with
 a  perimeter sediment trap.  Some dealers slope the sediment trap  to one side to
 decrease   the  area  where  solids   settle.     Sediment traps  must  be cleaned
 periodically  to keep sediment from overflowing  into  the main sump from  where
 liquid is  pumped.  Figure 4 shows a pad with two sumps.  A pan can  be fabricated
 to  fit beneath the discharge of the higher sump.  Solids  can  then  be removed by
 dumping the pan. Dealers  not equipped to handle sediment in sumps  should realize
 that this  material may be  too  contaminated to discard as dirt.  Experience has
 shown  that, where pesticides are handled, sediment collected in sumps can destroy
 vegetation.  The two  approaches for handling these solids is to slurry  them into
 a liquid mix or dry them and add them to dry  fertilizer,  being careful to  apply
 the material on crops not  subject to injury from  the  contaminants  and at  rates
 at  or  below that  specified  on  product labels.

       The  labor associated with  forming  and  pouring a  concrete  sump  can  be
 avoided using  prefabricated sumps.   Stainless  steel  sumps are usually double
walled with ports on  top  to permit leak detection between the walls.  Stainless
 steel sumps can be fabricated in any size, however,  most have a capacity of  about
30 gallons.

       Precast-concrete sumps can  be custom  built in  a range of sizes and  with
fittings to accept piping  connected to other load-pads and operational areas.
At  large  facilities  recycling of  rinsates  can  be   simplified  by collecting

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material in a common sump.   Pipe inlets should be above the bottom of the sump
so that  liquid  can  be pumped to a  level  below the inlets.  This  reduces  the
chance for liquid to leak into  the  ground  around  pipe  inlets.   Concrete sumps
usually have a capacity of about 100 gallons.   Some dealers prefer a large sump
and  sediment  collection system to increase  the  time  between  clean-out.  If
pesticides are rinsed  or handled on the pad, a  large sump is undesirable because
of the problems  associated with contamination.   For example,  if a dealer switches
from corn to soybean herbicides, he has to completely  clean the  sump to avoid
contaminating his  soybean  make-up  water  with corn  herbicide  residues.   The
simplest way to  avoid contamination  of herbicides is to  use  a small sump that is
cleaned daily or more often  if needed  to purge the system.   Sumps in areas  not
protected from rainfall should be kept clean to permit  the unrestricted use or
discharge of collected rain  water.

      There are  alternatives for segregating rinsates other than cleaning out the
pad and sump.  One is to divide the load pad into two or more  areas by sloping
sections of the  pad  to different sumps.  Another alternative is to slope the pad
to a wall where multiple drains with valves  are used to direct spills and rinsate
into a particular sump.  Each sump has a dedicated pump and rinsate storage tank.
This system is ideal for locations  where rinsate segregation is  important.

      A trend in the industry  is to add pesticides to  fertilizer products in the
applicator in the  field  and rinse the applicator in the  field.  This practically
eliminates the need  to segregate rinsates because they will  normally not contain
pesticides.    This  management  practice permits  the  use of one  rinsate tank.
Other  management  practices  which   enhance the  environmental   security of  a
dealership will  be discussed later.

Mixing Area Containment

      Mixing areas are the site of  incidental  spills that require containment.
A  variety  of materials are  handled  in  the mixing  area.   Spills  occur  when
materials are manually added  to  the mixer.  Piping systems and conveyors for dry
materials often leak.   Consequently,  mixing areas are  as  important as loading
areas with regard to containment.

Liquid Mixing Areas--
      Containment for the  liquid mixing area usually  involves installing a curb
along the inside wall  of the mix house.  The containment volume should be equal
to the volume of the mix tank.   At several locations the  mixing area has been
contained by allowing the area  to  drain  onto  the loading  pad  and installing a
curb  on  the  inside of the  other   three  walls of the mix house.    Figure  5
illustrates how a  curb can be built  on  an existing  slab.   At some sites the mixer
has been moved to one corner of the load pad.  Combining the mixing containment
and load pad is  common because they  are usually  adjacent and both receive  all the
products handled at the facility.

      Since  it  is  desirable  to  keep  fertilizer containment  areas  free  of
pesticides, areas where pesticides  are  mixed should not  be allowed  to drain into
the fertilizer containment.   Mixing area containment should be large enough to
accommodate mini-bulk containers and other portable pesticide containers that are
not located in  a secondary containment dike.   When combining containment areas
it is sometimes desirable to  segregate different  areas inside smaller dikes to
keep incidental  spills isolated. For example,  a pump  that leaks or a place where
hose  connections  are  frequently made, can be contained in a pan  or inside a

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 separate  curb.   Confining frequent spills to a small area can reduce the  amount
 of  rainfall  that becomes  contaminated  and must  be  handled  as dilute product.

       Piping from storage tanks to the mixer and to the load pad should also  be
 contained.   At  most  facilities,  these areas are  connected and the piping  is
 always above a contained area or over the load pad.   Piping used to transfer full
 strength  materials  should not be buried underground without being placed  inside
 a larger  pipe.   The larger  pipe can be  sloped so that  leaks in  the  inside pipe
 will  flow to one end of the piping  system where  leaks  can be contained and
 detected.   Buried  pipes  are acceptable for  transferring  rinsate  or  material
 collected in  sumps  to a  larger sump or  to a  rinsate holding tank.

 Dry Mixing Areas--
       Dry fertilizer mixing  areas are best contained under roof.  Several dealers
 have extended the roof of their dry fertilizer storage building to include their
 blender and load-out conveyor.  Others have kept  their blender inside the storage
 building  and  have built  a concrete pad  to collect  material  which  falls beneath
 the conveyor as well as material  spilling over the side of spreaders and  tenders.
 The latter  approach has been taken in  the  Great  Plains where  annual  rainfall
 amounts are  below 20  inches.

       Blending  towers, blending systems having  a cluster hopper, weigh hopper,
 and blender  stacked vertically in a tower,   should  be  enclosed  and  have  a roof
 over the  loading  area.  If the tower is not  enclosed, the  pad beneath the tower
 should be large enough to catch leaks in the blending system as well  as  material
 spilling  over the sides of  spreaders and tenders.

      Facilities  where dry fertilizers are impregnated with herbicides must have
 containment for confining pesticide spills in a  manner  to prevent contamination
 of fertilizer raw materials.  The  impregnation operation and load-out should be
 under roof, otherwise, rainfall coming in contact with pesticide  residues  in the
 blender  or  conveying  system must  be  collected  and  handled  as a  dilute
 pesticide/fertilizer  mixture.  Spilled material  and  product  cleaned out  of the
 blender  should   be  stored   inside  and  added  in  small   proportions  to  blends.
 Pesticide concentrations may be  too high in this  material  to permit  it  to be
 directly applied.   If water  is used to  clean  the blender,  it must be treated as
 a dilute pesticide.   Dealers without liquid  application equipment may  not  want
 to use water to decontaminate their blender.  Limestone or potash can be used to
 purge the system  of pesticides.   This fertilizer-pesticide  mixture  should  then
 be applied on crops in accordance with the labels of the pesticides contained in
 the mixture.

 Storage Area Containment

      When  dealing with  liquid  products,  storage  area  containment  involves
 secondary containment, a dike or basin which holds  the material  if  the primary
 containment (storage tank) fails.  The major difference  in secondary containment
 for fertilizers and pesticides is  the construction  material.   Earthen dikes are
 allowed for fertilizer secondary containment and  are not permitted for pesticides
 (Illinois Department of Agriculture, 1989).  When dealing with dry fertilizer,
containment involves storing material  in a building that has a roof, walls, and
 floor that prevents fertilizer  from coming  in  contact with precipitation and
 surface water.
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 Liquid  Fertilizer  Savage  CunM'nm.:v> •
      Secondary  containment for 1-ouid  fertilizer  consists  of a basin  with  a
 floor and walls that, are essentially  '^pervious to liquids.  The basin is usually
 sloped  to  a  sump where  liquid  can  be pumped  to  a  holding  tank  or  discharged is
 not contaminated.   The volume of the secondary containment,  excluding the space
 taken up by  tanks,  must be at. least  110 or 125 percent of the volume of largest
 tank in the  containment (Departments of Agri'jUure - Iowa,  1988;  South Dakota,
 1989; Wisconsin, 1988; Minnesota, <989).   Th=*  percentage varies by state and one
 state requires that  the secondar,? containment hold 6 inches  of rain  in  addition
 to the  volume  of  the largest tanK (rinnoir>  Department of Agriculture,  1989).
 The following  discussion  deals with  secondary  containment  for tanks,  not  in-
 ground pits  with flexible liners.  In-ground pits are not  permitted  for primary
 containment  of fertilizers or pesticide;  in most states.   If allowed, pits will
 be regulated as  underground storage  tanks and must be double-lined  and  have  a
 means to check  leaks in the primary liner.  In-ground  systems are well suited for
 secondary  containment.   This  application will  be  discussed  later.     Local
 regulatory officials should be  contacted  by dealers considering pits  for primary
 storage.

      In  secondary containment  'iy3>.r:"\.,  pic-im;: runs  should be  over  and  not
 through the  containment w;.]'.    i: cu'i:^}  if-=: pass through a containment wall,
 care  should  be  taken to  get  a good  1,1},,;'  necween  the  pipe  and  wall.    The
 structural integrity uf  the will  :.:-..-:=j''.i oft hs compromised nor should the liquid
 holding capacity.

      Rain accurcu?3i:;'.n :,b?ukl  r,t  j,: unseen out with a manually controlled  pump.
 Drains should  only  be us?d w':h a locxable  valve  that  is strictly  managed to
 prevent the inadvertent release of tufitarmnared water or fertilizer (South Dakota
 Department  of  Agriculture,  ]989;.    1.1  some  states,  drains  are   prohibited
 (Department  of Agriculture  - icwa, 1988;  Illinois, 3989).

      Sight  gages   used to monitor  liquid levels  in tanks  are  a  source of
 liability because they are easily damaged or  broken, releasing the contents of
 the tank.   Sight gages should only be used if a stainless steel valve which is
 normally closed is installed between the  Dottom  of the  sight  gage  and the tank.

      The  most  difficult   aspect  of   retrofitting  secondary containment at  a
 facility  is  selecting dimension^  mat   «il;  conserve space  without  impeding
 vehicle and employee access, u.  the  uanks.   A  •ypica]  facility has  tanks grouped
 in one  or  more clusiers.    If   possible,  tanks  should be consolidated  in  one
 cluster.  This  usually minimi?ac> the raquired wall height since the volume of the
 containment is  based on the largest  Dingle  tank. Providing adequate  space  between
 tanks  will  also decrease wall height.   Spacing  tanks close together  will minimize
 floor  area, but will  increase wal1 height.  In general, 36  inches is  the  highest
 practical  height for secondary  containment walls, even though higher walls  can
 result in a  less expensive  design  due tc the reduction in floor area.   Higher
walls  impede employee access, increase problems  associated with tanks floating,
 and expose employees to  more risk, while inside  the wall.

      The  first  st&p in  sizing a secondary  containment  is to  determine  the
 required volume.    Then t  scaled drawing  of the plan  view of the tanks  and
containment  should  be made.  The net containment  area  should be determined by
 subtracting the area of all but  the  u^qesr tank  from the total containment area.
The height of the containment •»«;] is 'Vti'tTisned by dividing  the required  volume
by the  net  containment area.  If the contamnent wall  is higher  than  desired  the

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 containment  area  should  be  enlarged.   For  example:

      Assume  a containment  for  Pour 25,000-qallon tanks is desired.  All  tanks
      are  12  feet in diameter,  have flat  bottoms.,  and  are  29 feet high.  The
      containment  floor  dimensions are 20  feet  by 50 feet.  Containment  volume
      must be 110  percent of the  largest tank,

      Required volume  (RV)  in cubic feet

      RV = LTV x  FF /  7.5

      Where,
      LTV = Largest tank volume in gallons
      FF = Freeboard Factor, 1.1  for 110%  or  1.25 for 125%
      7.5  = gallons per cubic  feet

      For this example,
      RV = 25,000  gal  x  1.10 /  7.5 gal/cubic  ft
      RV = 3,667  cubic ft

      Net containment  area  (NCA)  in square feet
      NCA = Total  area - tank area
      NCA = (20 x  60)  -  (3  x 113)
      NCA = 1200  - 339 sq ft
      NCA =861 sq ft
      Note:  The  area  of only  3 tanks  was  subtracted since the spilled  liquid
      will occupy  space  in  the  leaking tank.

      Wall height  (WH) in feet,
      WH = RV/NCT  = 4.3  ft

      The required wall  height  for this  design  is  4.3  feet  or 52 inches.  The
      floor area  should  probably  be increased to decrease the wall height.

      Tanks should be  anchored  to prevent them  from floating when empty. The
concern is that  other  tanks in the containment  can  lose  product from damaged
plumbing or can rupture from collisions  with the  floating tank.   The simplest way
to anchor tanks is to  weld  three  or mor? brackets  to the  tank where the  sides
meet the  floor.   Each bracket  is then bolted  to the  concrete with anchoring
bolts.   Chains and tie-down cables can  be  used  with brackets  welded above the
tank bottom.   In  clay-lined  earthen dikes,  weights can be  added to  the tanks or
cables  can be used to  secure the  tank to anchors outside  the dike.  Anchors in
the soil beneath the liner or cables  connected to concrete deadmen can be used
if the area where the liner is penetrated  is properly sealed.  Anchoring of tanks
is a practice often neglected when tanks are placed in secondary containments.
The following example  should illustrate the importance of anchoring tanks.

      A typical  carbon steel tank, 12-feet in diameter and 29 feet high,  holds
      25,000 gallons of  liquid  and weighs  about 13,000  pounds when empty.  An
      inch of ammonium polyphosphate  solution  in the tank  weighs 825 pounds.
      Sixteen  inches   of  material in  the  tank weighs  about 13,000  pounds.
      Exceeding this  same level  of solution outside the  tank will cause the tank
      to float when empty.   If  a 36-inch-high  containment  were full of solution
      the buoyancy force pushing  upward on the empty tank would be the same as
      20 inches  of solution  in  the tank or  16,500 pounds.  Shorter  tanks  of the

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      same diameter weigh less and would float in a shallower depth of liquid.
      Stainless steel tanks weigh slightly less than carbon steel tanks of the
      same  size and  fiberglass  and  some polyolifin  tanks  are considerably
      lighter.

      Another design consideration of  secondary  containment is  the method for
leveling  tanks  on  a sloped containment  floor.   Containment  floors  should be
sloped to minimize the corrosive effects of fertilizer on the floor and to ensure
proper drainage.  Concrete floors should  be sloped a minimum of 2 percent.  The
simplest  way  to level  the tanks  is  to place them in a  metal  ring filled with
coarse, washed gravel.  In addition to providing a level surface for the tank,
the gravel provides  a space for detecting leaks and keeps moisture away from the
tank bottom,  thus prolonging the tank life by  reducing corrosion.  The objection
some dealers have with gravel  is the difficulty in cleaning the gravel  after a
spill.  The quality  of rain water could be adversely  affected long after a spill
has been  recovered.

      An  alternate  method for leveling tanks is to pour  raised  concrete pads
beneath each  tank.   This  is  most easily done by  pouring  the  tank foundations
first and making a  second pour for  the space between tanks.  This is  not the
preferred method of construction because of the  sealing  required around tank
foundations.   The best method is to make the sloped and level surfaces in one
pour.  The second  best  approach is to  pour the entire bottom of the pad and use
dowels to attach the tank  foundations  made in a second pour.  Many dealers have
had success with level  secondary  containment floors with tanks setting directly
on the floor.  The key to their success is attributed to keeping the floor dry
and free  of fertilizer.

      The  most  common  construction  material   for  secondary  containment  is
reinforced concrete.  The major considerations are that the walls and floor be
strong enough to support the gravity loads of the  tank and the hydrostatic loads
of a massive spill  with a minimum amount of cracking.   It is also important to
provide a watertight seal  between the floor and wall  connection.   Figure 6 shows
a typical concrete  containment floor  and  wall  construction.  Figure  7  shows a
containment wall on  a floating slab.   Floating slabs are common in colder areas
where frost depths are such that deep footings are required.   A typical secondary
containment showing tank  foundations and anchors (Kammel et al.  1990) is shown
in figure 8.

      Dealers not experienced  in water-tight concrete construction should secure
the services of  a qualified contractor.  A brief summary  of recommended concrete
specifications is given in a another section.

      Concrete block can be used  for secondary containment walls.  To withstand
the hydrostatic  forces  of  liquids, block walls must be reinforced  with steel and
filled with concrete.  Some type  of sealer should also  be used  since concrete
blocks are not watertight.

Large Tank Containment--
      Designing secondary containment  for tanks with capacities over  100,000
gallons presents some engineering challenges.   These tanks are usually built on
sand, providing  no barrier to downward  movement of leaking material. They cannot
be raised with a crane and placed inside a containment.   Many dealerships lack
adequate  space  to  build  a secondary  containment dike  for  these large tanks.
State regulations regarding large tanks vary.  Proposed methods  for containing

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 these tanks  are so varied, one state issues experimental permits for designs not
 explicitly defined in the  regulations (111inois Department of Agriculture, 1989).

       In new installations  the tank can  be  built  within a  concrete  containment
 or some other watertight  basin.  The aim is to be able to detect  leaks in the
 tank  inside  the containment.   Providing some type of impervious barrier beneath
 existing tanks is a problem with no simple solution.  The most common method for
 detecting leaks is a false bottom.  A false bottom is a steel floor welded inside
 the tank over a thin layer of sand  (Figure 9).  If the tank  has  a sump, it is cut
 out and  a steel plate is welded in  its place.  A layer of sand is placed over the
 old tank floor.  There are two  methods for attaching  the new floor over the layer
 of sand.   One involves sliding  steel sheets for the  new floor through slits cut
 in the wall  just above the sand.  The steel plate  is welded to the wall  and when
 the new floor is  complete the slit circles the entire wall  separating  the old
 bottom  from  the tank.  The old bottom merely becomes a shallow pan full  of sand.
 Some  contractors weld the old bottom to the edge of the false  bottom and install
 leak  detection ports  in the  sand  layer.

      The other method for attaching the false bottom to the  tank wall  involves
 the use  of an angle iron which  is bent to match the  curvature of the wall.   The
 angle is welded  to  the wall  and provides a surface on which to  attach  the new
 floor.  Steel sheets for the new bottom are delivered through a large opening cut
 in the  the top of the  tank.

      The area around the  tank is  usually sealed with a clay lined earthen dike.
 Clay  lined  earthen  dikes are made  by  uniformly  incorporating  bentonite or
 attapulgite  clay into the top 6 inches of soil.  Large  rocks  and gravel  must be
 removed  as well as soil high  in organic matter.  A thorough  analysis of the soil
 is  required  to determine  the amount of clay required per  square foot  of soil.
 An engineering recommendation or the recommendation of the appropriate regulatory
 agency should be followed concerning clay addition.   In most  state regulations,
 the maximum  permeability  is  one-millionth centimeters per  second  (one-third of
 an  inch per day).   The clay seal should cover the area inside  the dike and up to
 the top of the dike (Figure  10).  The top of the dike should  be three feet  wide
 and the sides should slope no more than one foot per two feet of run.   A  six-inch
 layer of gravel or soil should be placed  over  the  clay  liner  to protect  it  from
 erosion  and  desiccation.

      Natural soil can be used for an earthen  dike without  the  addition  of  clay
 if the soil has the following physical properties;  50 percent or more of the  soil
 passes through a No. 200  sieve  and no more than 5 percent   is retained  on  a No.
 4 sieve.  The soil must also contain  less than 2 percent organic matter  and  have
 a plasticity index of at  least  15  (Wisconsin Department of Agriculture,  1988).

      Synthetic liners are an  alternative to clay liners.   Sheets of synthetic
 liner material are bonded to form a  solid barrier inside the containment.  The
walls  and  floor of  the basin can be made of  packed earth  or the floor can be
 earthen with walls made of concrete or prefabricated panels bolted together and
 anchored  in concrete.  Properly installed, synthetic liners are available with
 a guaranteed service life of 20 years.  The disadvantage of clay and synthetic
 liners is the problem associated with cleaning up a spill.   Their advantage is
their  lower cost compared to concrete or steel.
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       Some  large tanks have been  contained  in a large  steel  tub to conserve
 space.   The  idea is  bizarre  but not  as  impractical  as  it  sounds  when one
 considers that a million gallon tank  requires a dike over an acre in size  if the
 walls  are 3 feet  high.  The steel  containment, coined the elephant ring,  for a
 million gallon tank occupies an area smaller than one-fifth acre.  An elephant
 ring is typically half as deep as  the tank  is  high.  With this  ratio in height,
 110 percent of the  tank  can  be contained  in  a tub having a diameter 1.5  times
 that of the tank.   A  tub diameter 1.6  times  that of the tank will contain 125
 percent of  the  tank.   The tank and  tub combined  require nearly twice as much
 steel  plate to build as does the tank.  The walls of the  ring must  be reinforced
 with members attached to  the tank and the tank  should rest on a 2 to 4 inch  layer
 of gravel or  sand to reduce corrosion and for  leak detection.   As with  other
 secondary containments,  rainwater has  to  be  dealt  with.  A  variation  of the
 elephant ring that  eliminates  rain water problems  is  a  ring  that has a radius
 about  4 feet larger than  the tank  radius with  a  roof over the space between the
 tank and ring.  This system has been proposed but has not yet been built.

       Though large tanks  are not easily moved,  there are  some methods for moving
 large  tanks into  a  containment basin,  eliminating  the need for a false bottom
 that is costly compared to a synthetic or a clay liner.   Since large tanks are
 easily damaged,  an  engineer or experienced contractor should be contacted for
 assistance  in moving  them.   Large tanks have  been moved  by  floating  them in
 water.   Some of these tanks are made primarily  of steel only three-sixteenths of
 an inch thick and will float  in water  no deeper than  10 inches.   A clay  lined
 dike is built around the tank  and water is pumped into the dike until  the tank
 begins to float.   It is then moved to a clay lined area in the dike.  Water is
 pumped or drained out  of the  dike and the area where the  tank was previously
 located is then  sealed with clay.  To  reduce  the  chance of damaging the  tank,
 projections, such as the sump should be  removed.  Interior braces may be required
 to support the bottom against the buoyant forces of the water.

      Tanks as large as 300,000 gallons have been moved by the same method as
 houses are moved.  Two large beams which pass  through holes  cut  in the  in the
 tank wall  are used to support the weight of the tank while being moved.   After
moving the tank,  the holes must be patched and tested for leaks.

      Four tanks  in  Nebraska were  moved two miles using three dollies made from
 semitrailer axles.  The dollies consisted of a  framework  that bolted to brackets
welded to the side of  the tank.   Hydraulic jacks  on the dollies  were  operated
 simultaneously to raise each tank.  One of the three dollies  had a fifth wheel
 that allowed a tractor to pull  the tanks.

      A fourth way to move large  tanks is  on  a  cushion  of  air.  This  involves
 attaching a skirt around the bottom of the tank and using large blowers  welded
to the tank to provide a cushion of air on  which the tank can ride while being
pulled on a relatively smooth surface.

      Another alternative to false bottoms for leak detection involves subsurface
drainage that  spills into a sump or containment basin around the tank.  Equipment
 used by utility companies to bore under  roads can be used. The containment would
 resemble  a  moat  with  perforated  piping  discharging  into a  moat.   Someone
 specializing  in   subsurface  drainage  should  be  consulted  to determine the
 suitability of the site for this type of leak detection.
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       Large tanks must also be anchored.   Weights can be attached to the tank or
 tanks  can  be  constrained using cables attached to anchors outside of  the  dike
 (Kammel et a!.  1990).  Concrete  deadmen  or  earth anchors  can  be  placed beneath
 the liner  if the clay or synthetic liner is properly sealed.   Since the bouyant
 force  on a large tank can exceed 100,000 pounds,  an alternate  method  to protect
 the tank and dike is to constrain the tank from lateral  movement  while  allowing
 it to  float.   Flexible plumbing is required to allow the tank to  move without
 damaging plumbing.   It is  also a good practice to leave  fittings  and  manholes
 open when tanks are empty to equalize liquid levels inside and outside  the  tank
 in the event of a spill  or  rainfall  accumulation.

 Pesticide  Storage Containment--
       Pesticide storage containment is similar to fertilizer storage containment
 with   the  exception  of  earthen  containments  which  are  not  permitted   for
 pesticides.    It  is  also   important  to  separate  pesticide  containment  from
 fertilizer containment.  The two can be adjacent inside one containment area  with
 a dividing wall between the  two.  The dividing wall  can be lower than the outside
 wall to allow the whole area to be  used as one containment during  a  catastrophe.
 Pesticides should also be kept under roof because of the problems associated  with
 contaminated rain water.   Packaged pesticides should  be stored  in  a  separate
 warehouse  and  not   inside  a  secondary  containment  for  bulk  pesticides  or
 fertilizer.  Flammable pesticides should be separated from non flammable ones and
 the  warehouse  should  be  curbed  to  contain large  spills or water  used  in
 extinguishing  fires.

 Dry Fertilizer Storage Containment--
       Dry fertilizer storage buildings should be  elevated above ground  level  to
 prevent rainfall runoff from entering  the building.  The  floor should  be paved
 with concrete  and cracks should  be routinely repaired to prevent the  downward
 movement of fertilizers.  The  roof and walls should be free of leaks that  will
 allow  rain water to come  in contact with  fertilizer.   Floor sweepings and scrap
 fertilizer materials  should be kept under  roof  as are  other  dry  fertilizers.
 Limestone  is  generally the  only dry  fertilizer  material that  can  be stored
 outside.

       Until  recently,  wood  was  the material  of choice  for dry  fertilizer
 buildings.  Some new buildings are being  made primarily of reinforced concrete.
 The floor  is  poured with slots wide enough  for walls  to be  stood edgewise  in
 them.  Wall sections are then poured horizontally  on the floor.  Reinforcement
 steel and clips for connecting wall sections are  accurately placed  in each  wall
 section.  A crane is then used to erect the  walls and connect  adjoining panels.
 The bin walls are supported laterally across the  top of  the open  end with steel
 or concrete beams.   The  advantage  to this type construction  is the  savings  in
 labor compared to wooden buildings.


WATER-TIGHT CONCRETE CONSTRUCTION

      To ensure  that concrete for load  pads and  containment structures  will
 resist penetration  by moisture  and  chemicals  and  have  a  durable  finish,   the
 following specifications should be followed  (Noyes, 1988):

      Use Type  IIA  or  Type II cement with  air entrainment  at 4,000-4,500  psi
      compressive strength.  Type  II provides moderate sulfate resistance.


                                         179

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      Use  water-cement  ratio  of  0.40-0.45  for  a   stiff   (1.5"-3"  slump),
      relatively dry mix for maximum strength,  chemical resistance, freeze/thaw
      resistance,  and watertightness.

      Use  5.5% to 7%  air-entrainment  in  cement  to  improve  workability at
      placement, and improve watertightness and strength  of low  slump concrete.

      Use concrete plasticity admixture for easier workability at placement and
      for improved watertightness and strength.

      Vibrate concrete during placement  at 5,000 to 15,000 vibrations per minute
      for minimum  aggregate  segregation.

      Powered steel trowel  surface finish  to minimize coarse  surface texture to
      improve washing and cleanup.

      Immersion or moist cure concrete  at  least  14 days  (28 day immersion or
      moist cure preferred for maximum strength).

      Allow  no more  than  30  minutes  between  concrete  truck loads  during
      placement.

      Mix concrete 70-100 revolutions at mixing speed,  then an additional 200-
      230 revolutions (maximum of 300 total revolutions)  at agitating speed.

      Discharge mixed concrete within 1.5 hr per ACI C94.

      Minimize discharge drop distance by using a discharge chute.

      Use large (1" - 1.5"),  clean,  impervious aggregate or  aggregate 1/3 the
      size of the  slab thickness for maximum strength and watertightness.

      Use clean, drinkable mixing water at a pH - 5.0 - 7.0.

      Oven  test   aggregate   for  excess   moisture  and   adjust  water  added
      accordingly.   If oven  testing  is  not  possible, reduce  total  added water
      assuming 3.5% excess water in sand and 1.5% excess  in aggregate.

      Continuous pour in one day - no cold joints.

      Expansion joints  should be spaced  close enough  to prevent  cracks from
forming in undesirable places.  Joints should be machine cut to a depth of one-
fourth to one-fifth the slab thickness.   The rule of thumb is that the minimum
joint spacing in feet  be 2.5 times the slab  thickness in  inches.  That is, a 8-
inch slab should have joints  no  farther than 20  feet apart.   Joints  should be
located in areas where  they can be  monitored,  for  example,  not under a tank.
Joints should be sealed  with a material  resistant  to fertilizers and pesticides
and should be  periodically checked  for repair or replacement.  The  sections
between joints  should  be square.  If not square the  length-to- width ratio should
not exceed 1.5.

      A vapor barrier should not be used  beneath  pours  as this may  cause the
concrete  to  retain moisture and increase  degradation  of  the  concrete  from
freezing and thawing.


                                      180

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       Frost  heave problems can be reduced by keeping  the  area  around  concrete
 slabs  dry.  The area beneath the concrete should be higher than  the surrounding
 area and surface  drainage should be provided to keep  water  from  standing  near
 containment  structures.   The drainage  around concrete  structures should  be
 monitored  for  two or  three years  after construction  to ensure that the area is
 well drained after the structure settles.  Runoff from  buildings and paved areas
 should be  kept away from  containment  sites  using curbs and gutters.

       Steel reinforcement bars are recommended for containment structures.  Wire
 mesh or  fiber additives will  not  provide resistance to  cracking over the life of
 the  facility.   Generally, No.  4 reinforcement rod  is required and spaced  12
 inches in  both horizontal  directions.   The steel  in sumps is usually  spaced 6
 inches.  Since steel reinforcement requirements vary with soil bearing capacity,
 strength of concrete,  and  the  anticipated loads, an  engineering recommendation
 should be  followed regarding  steel  requirements.

       To  prevent secondary   containment   basins  from  leaking   beneath   the
 containment wall,  waterstops  are needed between containment floors  and  walls.
 Molded vinyl waterstops are available  in several shapes.  These must be  embedded
 in the concrete floor  beneath  the  wall.  Other water stops are  available which
 can  be placed  on  the perimeter of  the  slab  after it  has cured.

       Many  fertilizer and pesticide  handling facilities  have  concrete slabs
 beneath  tanks  that may be incorporated into a secondary containment design  by
 attaching walls.   The suitability of the slab for  supporting  the wall should  be
 determined.  In most  instances this is  not the case.  If the concrete is in  good
 condition and free from cracks it  can serve as part of the  containment floor and
 the pad  can be extended.  The wall can then  be built  above new concrete.   It  is
 important when joining new concrete to old concrete  to seal the crack between the
 two slabs and to connect the slabs using dowels inserted into  holes  drilled  into
 the existing concrete.   In some instances even where existing concrete is in  good
 condition the best decision is to remove the concrete if the  slope  is incorrect
 or the pad is  too low  due to settling.  An  engineer  experienced in  concrete
 design should  be  consulted regarding the use of existing concrete.


 MANAGEMENT PRACTICES

       Containment  systems  are an essential   part of  environmental  security  at
 fertilizer/pesticide dealerships,  but they are no substitute for good management.
 Environmental  management  involves,  1)  the proper  handling of fertilizers and
 pesticides,  2) the security of the facility during periods of  nonoperation,  and
 3) the  reliability of equipment designed to transport or contain these materials.

       Proper handling  of materials begins  with employee training and education.
 Employees  should  understand  the  sources of  groundwater contamination  and the
 importance of keeping  fertilizer  and pesticides contained.  The rinsate storage
 scheme should be understood by  all and all  storage containers  should be  labeled,
 including rinsate  containers.  A typical scheme may involve rinsate  storage tanks
designated as corn, cotton, soybean, and pesticide  free make-up water.  Schemes
vary according  to  the  variety of crops  treated and  the amount  of rinsate that  is
handled at the facility.  To prevent contamination of  materials, spills  should
be cleaned up immediately  after they occur.  To minimize the amount  of rainwater
that must be collected and used,  the loading pad and containment system  should
be cleaned and  sumps should be pumped out at  the end of each working day  or prior

                                      181

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to rainfall even*->.   ' -  heip (ir'i-r^ir.*  if  water  is  suitable for discharge kits
are now  beinc; marketer  to  i >st.  liouids for  contaminants.   Some  tests  can be
completed  in  a few minutes, '?fh::r-s  require a  few hours.

      There are two app: Oidv-3 re pesticide handling;  mixing pesticides to the
carrier in the batch mixer and mixing pesticide with carrier at the application
site.   Mixing  pesticide and Carrier at tht1 facility is the common practice.  This
practice  ensures  f o^rsulrilcn  accur.icy  because  an  experienced mixer  operator
oversees the additiji of  pest cides to the mix. This  approach also requires less
equipment  si no:; pesticides are not mixed ana handled in equipment separate from
fertilizer.   The  di '.advantage  of  mixing  pesticides and  fertilizers  at  the
facility  is  the   amount  cJ'  equipment  that  has  to be  cleaned  to  prevent
contamination when jwit.cfr, r-y  products.    The mix tank,  nurse equipment,  and
application equiw.ie.Vr  must  .-•».!!  be cleaned to purge  the system of  a particular
mater i a1.  Another c!*s-v;lv;8 apn'i--<;iu>'  *- rinsed  in  the  field.  On-board rinse systems are
available which have  m>22.'>?s mounted  inside the applicator tank to clean the tank
walls s no baff;=s,  PU; t^bie sprayers are also available for cleaning pesticide
residues fror.i  the outside of applicators.  To ensure  formulation  accuracy some
operators weigh or !iH?'rer out batches of pesticide at the facility for each load
of fertilizer     "-.-:•&  pesticide  is then  transported to  the field  in separate
containers  on   nurse  equipment.   The  containers  should  be  approved  by  the
Department of  fransp'Vtat ion for  transporting pesticides.

     Applicators can  be equipped with en-board injection or impregnation systems.
These systems add  pesticide to fertilizer in the output stream of the applicator.
These systems  are ideal  for  reducing rinsate  since pesticide  never enters the
applicator tank.  Direct injection and impregnation systems,  however, are limited
in the number of products ihey ''an handle and  some dealers are skeptical of their
accuracy
             dSS  o:  wh^r-?.  oecticides and fertilizers are mixed,  the amount of
rinse water bandied at the facility can be reduced by rinsing as much equipment
as possible  in  the  field.   To reduce the chance  for  rinsates  to  enter surface
water ihe rinsing should ;/e done a safe distance from ditches and creeks.  When
on-board rinse  systems  are used,  the rinsate left  in the applicator should be
broadcast over  the  f'-eld  last treated.   Csood judgement  should  be exercised to
maintain the total pesticide  application  rate within  label  recommendations.

     Other method-",  for  VO-IIK:! ,M  the  vc/ jnse  and cost associated  with handling
rinsates include  (oicder df.d  L,O!SS  J987):

      Job scheJ.jiirvj.  for  oxarnple,  :? dealer who  plans to apply fertilizer and
      herbicide  t;>  corn ana cotton  can  group  the jobs  so  that equipment must
      only be rinsed  only  onci>  per  day.

      Equipment c«ifi be mod • f • -HI to reouce the amount of residue remaining after
      being  emptied,   hv>  punu!  on iarne  application equipment,  for example, is
      driven  by 3 b*L  >r(m chc engiue  and is  nearly  10  feet  from the tank
      drain.   As <;n  opt. on,  *,ne purr.p can  be  driven hydraul ically  and placed
      directly  beno-.it h  ^he applicator tank.

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       Using high-pressure rinse  equipment  can also reduce the volume of rinsate
       reduced.   Though  centrifugal  pumps  are well suited  for  handling  liquid
       fertilizer,  their high  output  and low operating pressure make them poorly
       suited for washing out  equipment.   High pressure washers  do a better job
       of cleaning for the amount of water used.

       Proper equipment  calibration and accurate measurement  of the acreage to be
       applied will  minimize the  amount of pesticide  that must  be rinsed  out of
       the applicator or hauled back for recycling.

      The security  of the  facility during periods of nonoperation requires daily
 inspections of the security system,  closing of valves,  and disabling of pumps and
 electrical  circuits.  Facilities in  areas subject to theft or vandalism must have
 a security  fence with locks on gates around the property  or  should have the area
 patrolled.   At the  end  of  each  working  day  the facility should be  locked  and
 valves on tanks and all  pumps  should be turned off.  Some  facilities are equipped
 with  a  single  switch  which  locks  out  all   electrical  circuits  to pumps  or
 electrically driven  valves.

       Facilities  in  areas not subject to  vandalism may  not require  a  security
 fence,  however,  all  valves on tanks  should  be  locked in the closed  position.
 Since  valves  on tanks and valves  at  the bottom of external sight gages both need
 to be  locked,  the  two can be  positioned  on each  tank  so  that a  single  lock  can
 be used  to  lock both  valves.   Gravity  drains  on containment  areas are  not
 recommended,  however, in some  areas drains are permitted to discharge rain  water.
 The discharge of rainwater must be closely supervised and  drain valves  should
 otherwise be locked  at all  times.   During  extended  periods  of  nonoperation
 storage  areas and containment  systems  should be checked frequently.  Prior to the
 winter season the facility should be "winterized".  Water  trapped in lines  should
 be discharged and water  in containment basins  should be  removed to prevent  damage
 to the system due  to freezing.

       The  integrity  of  containment  systems,  storage  containers,  and   other
 equipment designed to keep fertilizer and pesticides from entering water supplies
 should  be checked frequently.   Tanks,  valves,  and  piping systems  should  be
 frequently  checked for  leaks.   In some  proposed  regulations,  a considerable
 number  of inspections  of these  systems with documentation of  inspections  is
 required.   This practice  is recommended as a part of an  overall  inspection  and
 maintenance  program  for  the facility.  Tanks and plumbing,  for example,  should
 be inspected annually for leaks and trouble areas should be physically tested by
 either  a vacuum  or  pressure  test.  A  strict  maintenance  schedule  should  be
 followed, not only to protect  water supplies,  but to reduce down-time  during  the
 season.
COST AND WORK SCHEDULING

      Containment  of  materials  at  fertilizer  dealerships  can  be  a  costly
proposition.  A  concrete  slab can usually be  poured  for about $100 per cubic
yard.  A survey  of  dealers  in the  Midwest and Great Plains has shown that the
cost for loading  pads,  including site preparation, reinforcement,  form work, and
finishing has ranged from $140 to  $200  per cubic yard of concrete.  This high
cost was due,  in part, to  the  special  requirements  for retrofitting  new and
existing concrete,  site preparation, and the labor associated with  forming sumps.
Other costs associated  with  a  load pad include the cost of rinsate holding tanks

                                      183

-------
and pumps and plumbing to  transfer material  to  and  from  these tanks.   At most
facilities, three or  four  500-gallon tanks are needed.  The  total  cost for a
rinsate  recycling  system should be  around  $2500,  depending on  the  amount of
material that must be purchased.

      The cost of secondary containment will depend  on the materials used for
construction.  Concrete has the advantage of conserving space but  is more costly
than synthetic or clay liners.  The following cost comparisons for alternative
diking  systems  were  presented by  Hansen  (1990).    In each alternative,  a 10
percent contingency was included in the total cost.   Also  security fencing at
$10 per linear  foot was  included  in  each  alternative.    A typical  secondary
containment for  six tanks,  all  12 feet in diameter,  the largest  having a capacity
of 30,000 gallons,  costs  $26,000 if made of  concrete.   Per  square foot of floor
area the concrete dike costs about $11.00.

      A clay-lined-earthen-dike with the same floor area would cost $14,000.  Due
to the  sloping sides, the  earthen dike can  contain  a tank  with a volume up to
45,000  gallons.   Per square foot of  floor area the  earthen  dike  costs about
$6.00.

      A similar dike with a  hypalon liner sandwiched between  polypropylene liners
will cost $19,500, or $8.25 per  square foot of  floor area. The polypropylene
liners, geotextile liners, are  needed to  protect  the main liner  from damage
during  installation.    In  some synthetic  liner  installations one  or  both
geotextile liners can be ommited  if clean sand or smooth pebbles are adjacent to
the hypalon liner and steps are  taken  to protect the liner during installation.
This can result in a savings of 13 to 40 cents  per square foot of floor area.

      Dealers typically spread containment construction over a two- or three-year
period and regulations generally have a compliance schedule spanning a similar
time period.  The areas and materials at dealerships requiring containment are
prioritized in most regulations  and should be prioritized by dealers scheduling
containment work over an extended period.  Containment work should  be prioritized
in the following order; water  system  protection, pesticide storage containment,
loading/mixing/equipment  washing  area containment,   and  fertilizer  storage
containment.


CONCLUSION

      Before designing a complete containment system,  dealers should visit sites
and study existing  systems.   Dealers with  containment systems  are  a valuable
source of information, particularly if they have operated a system for some time.
Experience  and  hind-sight are  invaluable.    A  good  system   design  should
incorporate methods for expanding in the future.  Provisions  for the construction
of roofs over areas subject to incidental spills should be included in the long-
range plan.

      Even in states where  there are  no containment regulations,  dealers should
contact  local  agencies  involved  with water  supplies,  such  as  the  Health
Department,  Local  Emergency  Management  Agency,  and the  local  Environmental
Regulatory  Agency  when  modifying  a  facility.    For assistance  in  designing
containment, the Cooperative Extension Service,  State Department of Agriculture,
fertilizer and ag-chemical  dealer organizations and TVA's National  Fertilizer and
Environmental Research Center can be  contacted.

                                      184

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      Fertilizer and pesticide containment provides opportunities for the retail
fertilizer industry to take a  leadership role in protecting our water resources.
Indications are that  there will be more and not less regulation for fertilizer
and  ag-chemical  dealers  in  the future.   It is  everyone's  responsibility to
protect our water resources.  After all,  we are only borrowing this water  from
our descendants.
BIBLIOGRAPHY

Noyes, Ronald T., 1989.  "Modular Concrete Wash/Containment  Pad  for Agricultural
Chemicals", Paper No. 891613,  American Society of Agricultural Engineers, St.
Joseph, MI, December 1989.

Illinois  Department  of Agriculture,  1989.  Part  255  Aqrichemical  Facilities;
Subchapter i:  Pesticide Control; Chapter I:  Department of Agriculture; Title
8:  Agriculture and Animals, 111 inois Department of Agriculture,  Springfield, IL.

South  Dakota Department   of  Agriculture,  1989.  Bulk Commercial  Fertilizer
Operations Manual. South Dakota Department of Agriculture, Division of Regulatory
Services, Pierre, SO, July, 1989.

Iowa Department of Agriculture, 1988. Bulk Commercial Fertilizer Storage. Article
12:44; Chapter 12:44:05, Iowa Department of Agriculture, Des Moines, IA.

Wisconsin Department of Agriculture, Trade & Consumer  Protection, 1988. Chapter
Ag  162,   Bulk  Fertilizer  Storage,  Wisconsin  Administrative  Code,  Register,
February, 1988,  No.  386, Wisconsin Department of Agriculture, Madison, WI.

Minnesota Department of Agriculture, 1989. Bulk  Pesticide Storage Facility Rule
Summary.  Minnesota Department  of Agriculture,  Agronomy Services Division, St.
Paul, MN.

Kammel, D. W.;  G.  L. Riskowski,  R.  T.  Noyes,  V.  L.  Hofman.,  1990.  Draft  of
Fertilizer and Pesticide Containment Facilities  Handbook, Midwest Plan Service,
Agricultural  Engineering,  Iowa State University, Ames, IA.

Hansen, T. L., 1990. "Diking  Alternatives for  Secondary Containment of Liquid
Fertilizers".  Dultmeier Engineering Services,  Inc. Omaha,  NE.  January, 1990.
                                      185

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                                           HP a  wo.o'
                                                               PLAN
CO
en
                         Liquid Holding Capacity in  Gallons
                         LHC = 7.5 x L  x W x 12
                                        3
                         Where.
                           L — pad length in feat
                           W = pad width In  feet
                           D = depth  at sump inlet in  feet
                         7.5 = gallons per cubic foot

                         LHC = 7.5 x 60 x  12 x 2.2
                                        J
                             =  3960 gallons excluding sump
By adding a 4" high  rollover curb around the pad
the LHC Is increased by 1800 gallons.
LHC of the curb is computed as follows:
  LHC = 7.5 x L x W x CH
  where.
     CH = curb height in  feet
  LHC - 7.5 x 60 x 12 x  O.3J
  LHC = WOO gallons
                                                              Figure  1
                                               LOAD  PAD FOR  SINGLE  VEHICLE

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                            60


IP EL 9/9.5' -^
SLOP IT ^




„ SLOP£



H)

N

      HP E.L 100.0'
                          PLAN
The Liquid Holding Capacity for this pad is
computed by the equation
 IHC.  =7.5 x L x W 4 Q
             2
 LHC  = /,.? x 60 x 12 x  1.5
              2
 LHC  — 4,050 gallons excluding the  trough
                          Figure 2
        SINGLE VEHICLE LOAD PAD  WITH  TROUGH
                            187

-------
CO
00
                                                  2'X 4' SUMP W/SAND TRAP
                       fr
                          r6
                         '
                                           PLAN
                                                      4" SPLASH CURB
                         lrk=£J"

                       SECTION A-
*
 ,      ..I'll..  *' J|'U
•-I  \  -Hl~rfM- \
                         SUMP DETAIL
                                         Figure J
                                   LOAD PAD WITH SUMP
                                AND PERIMETER  SAND TRAP

-------
00
to
                                 rfl
                    SECTION A-A
                    SCALE:  1/4' = 1'-0
          Figure 4

LOAD PAD WITH  TWO SUMPS

-------
'4 REBAR @ 12'O.C. —^
CLEAN ie SCARIFY — ,
(-\iir~T /VW^P/~7T~ / 	 1
a
/-
-9*
tX/o / t-t/'VOj (L /C. / 1 /
SURFACE L_ \f
~^S
<- #4 ff£SA/? SET /A/ EPOXY
W' INTO EXIST CONCRETE
/- JOINT SEALANT
— ^
  DRILL SLAB TO
  RECEIVE DOWEL
              Figure 5
NEW CURB ON EX/SUNG  CONCRETE
 6" COMPACTE.
 SAND OR GRAVEL
                 Figure 6
           CONTAINMENT
                   190

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     #4 BARS S
        *jO^.«-«t«^W*UW«IB^ W(«3" - pa* .—~
  -_^___™. _\ ___- '
  T  ""r~	
COMPACTED $>*
-------
 01
 4
                       T/WALL EL 100.0'
          HP EL 97.42'
                             6"(TYP)
LP EL 96.58'
-,/- 2'X 2'X 2' SUMP
Iff  W/SANDTRAP
                                                 o
                                                 
-------
        NEW BOTTOM
  COMPACTED SAND
                           EXIST TANK WALL
                             •DRILL  1"0 WEEP HOLES
                             AROUND  TANK
                             ® ABOUT 5'  O.C.
EXIST TANK BOTTOM
              Figure  9
     FALSE BOTTOM TANK
     6" CRUSHED STONE
     OR GRAVEL-}    20
                W\
                          J'
      12'

      ~6" CLAY / SOIL MIXTURE
                               COMPACTED EARTH
                 Figure  10
          CLAY LINED  EARTHEN DIKE
»US GOVERNMENT PRINTING OFFICE ] 9 92 -6 *• 8 - " 5 3/. o 6 3 1 193

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                                   TECHNICAL REPORT DATA
                            (fleau read Instructions on the reverse before completinf)
 REPORT NO.
 :PA/600/9-91/047
                                                            3. RECIPIENT'S ACCESSION NO.
                              PB92-11994Q
 TITLE AND SUBTITLE
Proceedings of  International Workshop on  Research in
'esticide Treatment/Disposal/Waste Minimization
                            6. REPORT DATE
                                    January 1992
                            6. PERFORMING ORGANIZATION CODE
 AUTHORIS)

VARIOUS
                                                            8. PERFORMING ORGANIZATION REPORT NO.
 PERFORMING ORGANIZATION NAME AND ADDRESS
 cience Applications International Corporation
635 W. 7th  Street
Suite 403
Cincinnati,  OH   45203
                                                            10. PROGRAM ELEMENT NO.
                            11. CONTRACT/GRANT NO.

                               68-C8-0061
 2. SPONSORING AGENCY NAME AND ADORE
U.S: EPA
RREL                        And
26 W. Martin  Luther King Dr.
 incinnati,  OH  45268	
^Tennessee Valley  Authorit
  NFE2J
  P.O. Box 1010
  Muscle Shoals,  AL 35660
13. TYPE OF REPORT AND PERIOD COVERED
  Proceedings	
14. SPONSORING AGENCY CODE

   EPA/600/14
 5 SUPPLEMENTARY NOTES

Project Officer:  T.  David Ferguson   Comml.  (513) 569-7518
                                 FTS 684-7518
 6. ABSTRACT
     The  International Workshop  on  Research in Pesticide Management, Disposal,  and
Waste Minimization was held in Cincinnati, Ohio, February  26-27,  1991.  The  purpose of
this workshop was to provide government officials, pesticide  user groups, pesticide
producers and farm organizations practical solutions to pesticide treatment  and disposal
problems.  The workshop focused  on  how to destroy pesticides  and  their residuals at
low cost  by the applicators and  dealers.  The technical program included presentations
by government researchers and regulators, university agricultural station professors,
industry  experts and individuals involved in pesticide disposal and treatment.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                               b.IDENTIFIERS/OPEN ENDED TERMS
                                           c.  COSATi Field/Croup
 1)   Pesticide
 2)   Herbicide
 3)   Insecticide
 4)   Fungicide
18. DISTRIBUTION STATEMENT

   RELEASE TO PUBLIC
                19. SECURITY CLASS (Tliis Report)
                   UNCLASSIFIED
               21. NO. OF PAGES
                 208
                                               20. SECURITY CLASS /This page I

                                                   UNCLASSIFIED
                                                                           22. PRICE
 EPA Form 2220-1 (R«». 4-77)   PREVIOUS COITION is OBSOLETE

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