United States Environmental Protection Agency Hazardous Waste Engineering Research Laboratory Cincinnati OH 45268 Research and Development EPA/600/S9-87-001 Apr. 1987 Project Summary Proceedings: National Workshop on Pesticide Waste Disposal Denver, Colorado, January 27-29, 1986 The National Workshop on Pesticide Waste Disposal -1986 was held in Den- ver, Colorado, on January 27-29, 1986. This workshop was jointly sponsored by the American Chemical Society's Di- vision of Agrochemicals, the American Farm Bureau Federation, the American Society of Agricultural Engineers, the Association of American Pesticide Con- trol Officials, Inc., the National Agricul- tural Aviation Association, the National Agricultural Chemicals Association, the National Alliance of Independent Crop Consultants, the National Barrel and Drum Association, the National Forest Products Association, the National Pest Control Association, the U.S. Depart- ment of Agriculture, and the U.S. Envi- ronmental Protection Agency's Office of Pesticide Programs, Office of Solid Waste, and Office of Research and De- velopment. The primary purpose of this workshop was to work with govern- ment, pesticide user groups, pesticide producers, farm organizations, and academia to define and offer practical solutions to pesticide users' disposal problems. The proceedings of the workshop are a compilation of the speakers' papers and transcripts of the summary panels. Topics included in- dustry's role in users' waste disposal, on-site demonstration projects, regula- tory update, the pesticide research workshop summary, users' waste mini- mization/reuse, users' waste treat- ment/storage/disposal, and summary panels on technology, regulations, and application of pesticide wastes. The 1986 workshop was an outgrowth of the workshop held in 1985 which was developed to provide a national forum that assembled pesticide users, pesti- cide producers, researchers, and regu- lators to collectively address the com- plex issues of pesticide waste disposal and serve as a basis for continued dia- logue and interaction. The workshop committee continued to meet through 1985 to develop this 1986 solution- oriented workshop. These proceedings contain nineteen papers and three sum- mary panel transcripts that provide practical information on the issues and solutions of pesticide waste treatment, storage, and disposal. Specific treatment, storage, disposal and waste minimization technologies were addressed during the workshop. On-site demonstration projects in- cluded: carbon adsorption treatment of rinsewater, treatment of pesticide- containing soils, biological treatment, biological/physical process for the elim- ination of cattle-dip pesticide wastes, and biological and chemical •disposal systems for waste pesticide solutions. Waste minimization/reuse technology included: direct injection, wastewater recycling, rinsewater recycling, and en- gineering considerations. Container management technologies were ad- dressed for reconditioning containers, recycling metal containers, disposal of 55-gallon plastic drums, and off-site disposal of pesticide wastes. This Project Summary was devel- oped by EPA's Hazardous Waste Engi- neering Research Laboratory, Cincin- nati, OH, to announce key information concerning this research project that is fully documented in a separate report ------- of the same title {see Project Report or- dering information at back). After opening remarks and a wel- come from John G. Welles, the U.S. En- vironmental Protection Agency (EPA) Regional Administrator for Region VIII, Robert Wayland who is a special Assis- tant to the EPA Administrator in Wash- ington, D.C. delivered the Keynote Ad- dress. Mr. Wayland discussed the joint efforts of the Office of Pesticide Pro- grams and the Office of Solid Waste, the RCRA activities largely mandated by the 1984 amendments, and specific chal- lenges and opportunities for pesticide producers and users to work with state and federal agencies. Also recognized was the essential role of research in deriving future solutions that will tran- scend any of the regulatory structures put into place. Mr. Wayland applauded the workshop as a valuable opportunity for the private and public sector to work together on a cooperative venture that signals the positive aspects of the new ways EPA hopes to conduct its busi- ness. To bring the 1986 workshop into focus, Dr. James N. Seiber of the Uni- versity of California at Davis gave a re- view of the 1985 National Workshop, which provided a forum for exchanging ideas, determining needs, and identify- ing potential solutions. Dr. Seiber indi- cated the most tangible result of the 1985 workshop was that it led directly to a Research Workshop held in Cincin- nati, Ohio, only 6 months after Denver, where many decisions were reached on what technologies should be pursued. Less tangible, however positive, was the sense of urgency, expectations of progress, and hope for solutions. Over 400 attendees with a wide diversity of backgrounds came to the 1985 work- shop looking for direction and seeking solutions to the pesticide waste prob- lems. The National Agricultural Chemicals Association (NACA) has for the past 4 years directed a great deal of attention to the needs of pesticide users concern- ing pesticide waste disposal. Dr. Jack D. Early of NACA defined industry's role to assist pesticide users in finding waste disposal options that are environmen- tally sound, cost-effective and realistic in meeting their legal responsibilities. NACA has funded five verification stud- ies to further enhance technology. Dr. Early identifies a regulatory scheme that recognizes the types of wastes as- sociated with pesticide use and is re- sponsive to the economic and operating restrictions of both private and com- mercial applicators. The first morning session included on-site demonstration project reports. Dr. John C. Nye of Louisiana State Uni- versity described the operation of a car- bon adsorption treatment unit that was constructed and tested during the fall and winter of 1985 to 1986. The objec- tives of the test were to identify the crit- ical factors that affect the flocculation of pesticide-contaminated wastewater and to provide the data for use by appli- cators and regulatory agencies to adopt this technology. The criteria for select- ing flocculant aids are described in de- tail within the report, and the tests prove this treatment process was effec- tive in removing pesticides from wastewaters. Dr. Ian L. Pepper, a University of Arizona professor, presented a study re- port on the treatment of pesticide- containing soils where pesticides have accumulated in soils adjacent to aerial applicator landing strips. The objective of the project was to identify a time- and cost-effective detoxifying treatment. The treatment technology identified is ultraviolet (UV) photo decomposition and microbial degradation. The project was initiated in November 1985, and preliminary data of the project are en- couraging in finding a reduction to toxaphene concentrations at these land- ing strips. Researchers at the University of California-Davis are evaluating two dif- ferent pesticide waste disposal sites for in situ decontamination using biological methods. Dr. Authur Craigmill dis- cussed the two field trials used to test the biological methods. One of these trials was the continuation of the cleanup of the Sutter County Airport and the other field study was located at the Glenn County Airport. Both of these sites are associated with aerial applica- tor operations using toxaphene at the Sutter County Airport and using diuron, atrazine, dursban, trifluralin, Me parathion, and diazinon as the major pesticides at the Glenn County Airport. These studies will provide background data needed to implement full-scale de- contamination of pesticide waste ponds and airport strips with decontaminated waste pesticide ditches. Extensive cattle-dipping operations are continuously carried out along the U.S./Mexican border as part of an effort to eradicate the cattle fever tick prob- lem. These operations generate large volumes of aqueous pesticide wastes. Dr. Jeffrey Karns described a biological/ physical process for the elimination of cattle-dip pesticide wastes using UV- ozonolysis after natural degradation by microorganisms in soil. This combined treatment of microbial hydrolysis followed by UV-Ozonolysis proved that a safe and effective disposal of coumaphos-containing cattledip wastes can be achieved in the laboratory- This process has also been field tested and was shown to be an effective waste treatment method. Research is under- way to simplify the process for field per- sonnel utilization. The final report of the on-site demon- stration projects was presented by Dr. Brian Klubek of Southern Illinois Uni- versity. Acidic and alkaline trickling fil- ter systems were assessed for biologi- cal and chemical decomposition of waste pesticide solutions. This was per- formed by using a disposal pit filled with coarse-grade limestone to pro- mote alkaline hydrolysis and by using another pit filled with acid-waste mate- rial gathered from a strip mine opera- tion to promote acid hydrolysis. The treatment systems enhanced degrada- tion by including indigenous pesticide- decomposing bacteria. Degradation rates of up to 30% per day were ob- served in the acid system compared to about 2.5% per day rates for the alkaline disposal system. These systems appear to be comparatively inexpensive and simple to construct, operate and main- tain and work on most pesticides used in Illinois. The downside of such pit sys- tems is the overwhelming resistance to using in-ground disposal systems, therefore this technology should be considered for above ground usage. A regulatory update panel consisting of Raymond F. Krueger who discussed FIFRA, Matthew Straus who discussed RCRA, and Marvin Frye who presented EPA regional perspectives to pesticide waste disposal began the afternoon presentations. These EPA speakers fielded questions from the attendees and were available for discussions dur- ing the workshop. A research workshop on the treat- ment/disposal of pesticide wastewater generated by the agricultural applica- tion of pesticides was held at the USEPA's A.W. Breidenbach Environ- mental Research Center in Cincinnati, Ohio, on July 30-31, 1985. The partici- pants were divided the second day into ------- two workgroups. One workgroup was entitled "Physical/Chemical Treatment and Recycling" and the second work- group was entitled "Biological Treat- ment and Land Application." The pro- ceedings of this research workshop are a compilation of sixteen speakers' ab- stracts, both work group results, and a conclusion with recommendations. Francis T. Mayo of EPA and Dr. Philip C. Kearney of USDA presented a summary of the research workshop and briefly de- scribed the twelve technologies dis- cussed. A consensus of opinion ad- dressed immediate research needs. Concurrent sessions on the second day of the Denver Workshop provided participants with an opportunity to se- lect Session A - "Users' Waste Mini- mization/Reuse" or Session B - "Users' Waste Treatment/Storage/Disposal." Both sessions were repeated to assure that all participants had an opportunity to attend each presentation and enjoy smaller groups for more effective inter- action among speakers and attendees. Session A - "Users' Waste Minimiza- tion/Reuse" began with a presentation by Lawrence Roth, Oklahoma State Uni- versity, entitled "Direct Injection As a Rinsewater Minimization Technology." This state-of-the-art injection technol- ogy was reviewed along with an exami- nation to reduce or eliminate the waste of expensive materials. The idea is that nothing would be premixed and what- ever is introduced into the system would be metered, measured, intro- duced, mixed, and controlled by an on- board control unit. The direct injection system would release the pesticide di- rectly from a container into the sprayer pressure system, on demand, just be- fore the mixture is discharged from spray nozzles. This technology will en- hance application safety, sprayer sys- tem reliability, and proper application management. The second presentation in the area of rinsewater management was by Darryl Rester of Louisiana State Univer- sity. Wastewater recycling involves the collection and storage of aircraft waste- water for later use as aqueous dilution for future applications. Pesticide waste can be disposed of by rinsing the air- craft over the treated field or by recy- cling the washwater. Mr. Rester re- ported no illegal crop residues or crop damage as a result of these practices. It was also stressed that the large cement wash area was ideal for mixing and loading pesticides as well as for servic- ing the aircraft. The cost of such collec- tion systems must be included in evalu- ating the cost of any pesticide waste disposal system. The final rinsewater management speaker, A.G. Taylor with the Illinois En- vironmental Protection Agency, pre- sented a paper entitled "Recycling Pest- icide Rinsewater." During the 1984 cropping season, wastewater manage- ment systems at thirteen agrichemical outlets in Illinois were studied to deter- mine the feasibility of recycling pesti- cide rinsewaters by using them as a diluent in corn and soybean herbicide spray solutions. Pesticide rinsewater re- cycling systems appear to be a practical and feasible means of managing large volumes of dilute pesticide solutions. The two basic system components are a concrete wash pad and a receptacle for rinsewater containment. A manage- ment scheme is required to budget the use of rinsewater generated. The topic of product storage and han- dling equipment was discussed by David Callahan who represented the equipment industry with the presenta- tion on "Tanks and Fittings for Fluid Fer- tilizers, Pesticides and Other Liquid Products Related to Agriculture." Mr. Callahan also stressed the importance of knowing the rules and regulations, as the manufacturers' rules are sometimes different from EPA and state regula- tions. Session A was completed with a pre- sentation by C. Alvin Yorke of the U.S. EPA entitled "Dealing With Emergen- cies." Adequate contingency planning, training, and adequate preparation were discussed as the requirements needed to handle emergencies involv- ing pesticides. Responsible parties and government agencies must be prepared for a variety of possible spill situations. Coordination, team work and being aware of limitations are important fac- tors in any emergency. Responding parties must be aware of pesticide- related regulations and know how to contact government personnel who can provide appropriate information to deal with notification, clean-up, and treat- ment/disposal requirements. Between and after Sessions A & B, a room was available for participants to further discuss presentations using posters and exhibits. This was ex- tremely helpful because it allowed more time for the first day on-site demonstra- tion presenters to better explain their projects. Session B, entitled "Users' Waste Treatment/Storage/Disposal," provided the other half of the day's technical pre- sentations featuring container manage- ment, on-site options, off-site options, and storage and transportation regula- tions. Lawrence Bierlein with the Na- tional Barrel and Drum Association (NABADA) began this session's discus- sion on container management with a presentation entitled "Reconditioning Containers." A major problem for the container reconditioner is knowing which drums may contain hazardous waste residues. The user and recondi- tioner are often running the risk of un- knowingly handling a contaminated drum. The NABADA has developed an Empty Container Certification Form to be signed by the emptier which assures compliance with the U.S. Department of Transportation (DOT) and EPA regula- tions. Drum reconditioners are working with the Association to develop a practi- cal, easy-to-use mechanism for emp- tiers, transporters, disposers, and/or re- conditioners to comply with federal regulations. Herschel Cutler, Executive Director of the Institute of Scrap Iron and Steel, pre- sented a paper entitled "Recycling Metal Containers." Recycling of metals is vital to metal manufacturing and also provides important environmental ben- efits. The lack of demand, however, is causing a rather large involuntary in- ventory of recyclable scrap. When the threat of potential hazardous waste con- tamination is added to the already in- creasing problem, the weak and over- supplied market problem increases. Residues of pesticide wastes add to these problems since legally "empty" is difficult to determine by the scrap proc- essing industry. Because of liability as- sociated with processing such contain- ers, scrap processors have totally banned the acceptance of barrels, drums, or containers where they "might have" contained hazardous wastes or other hazardous substances. The charge of the Institute is to design recy- clability into the products at the start and the problems of hazardous waste contamination threats will lessen markedly. Changes are necessary where recyclability is researched for so- lutions to the problems that exist today. The scrap processing industry supports environmentally sound metal recycling. The Plastic Drum Institute (PDI) was represented by Daniel Barber who pre- sented a talk entitled "Disposal of 55- ------- Gallon All-Plastic Drums." The Plastic Drum Institute is a division of the Soci- ety of the Plastics Industry and is com- prised of member companies which manufacture industrial plastic shipping containers with a liquid capacity of 3 U.S. gallons and above, as well as man- ufacturers of raw materials for such containers, the major objective of PDI is the integrity of container performance which extends beyond the first-time shipment to secondary service and fi- nally to the disposal of the spent con- tainer. A great deal of interest has been expressed in reusing all-plastic drums because they are a valuable resource utility and reduce packaging costs. Re- search by the new Plastic Recycling In- stitute is being conducted to improve recyclng system efficiencies, to improve the quality of recycled materials, to de- velop the recycling processes for vari- ous materials, and to share the technol- ogy with the recycling industry. This presentation rounded out an excellent discussion on container management by the container industry. "RCRA Permitting of On-Site Pesti- cide Waste Storage and Treatment" was presented by Felix Flechas who is with the EPA in Region VIII. Mr. Flechas discussed the on-site disposal options associated with pesticide use. These op- tions were analyzed along with corre- sponding RCRA requirements. Option groups included on-site treatment and on-site storage with off-site disposal. RCRA requirements included discus- sions of the Hazardous and Solid Waste Amendments of 1984 and small quan- tity generator treatment, storage and disposal facilities. It was concluded that on-site options for storage and treat- ment of pesticide residues where a RCRA permit is required can result in an extensive investment of time and re- sources by a pesticide waste generator while securing a permit. For a user who is a small quantity hazardous waste generator, the economics of acquiring such a system may not be worth the benefits, and off-site disposal options should be explored. Mr. H. Clayton Ervine, who repre- sented the Governmental Refuse Col- lection and Disposal Association (GRCDA), presented "Off-Site Disposal of Pesticides and Pesticide Containers." Because of a combination of factors in- cluding past abuses of the systems, new regulations, and public attitudes con- cerning waste management, the man- agement of waste pesticides and waste pesticide containers is becoming in- creasingly more difficult for the genera- tor. It does seem reasonable to dispose of empty pesticide containers using local systems if certain conditions can be met. These conditions must permit the ready verification that the contain- ers are truly empty and must provide the ability to pay for any additional costs incurred. Such arrangements can be accomplished through discussions with disposal site owners and the gen- erators and/or their representative trade associations. The storage and transportation as- pects of proper waste pesticide man- agement under RCRA was presented by Rolf Hill, EPA, in his discussion entitled "Storage, Handling and Shipment of Pesticide Waste Regulatory Require- ments." Discussion topics included the identification and classification of waste pesticides; notification requirements; the pretransport requirements of stor- age, packaging, labeling, marking, and placarding; the Uniform Hazardous Waste Manifest; recordkeeping; report- ing; and the farmer exemption. Special focus was made on compliance with the new Uniform Manifest requirements and the impact of state laws on comple- tion of this manifest. Another area of focus was the RCRA reauthorization re- quirements for small quantity genera- tors. The presentation was aimed at pesticide users who generate or trans- port a hazardous waste and who must comply with federal hazardous waste management standards. After 2 full days of presentations con- cerned with research and solutions to proper pesticide wastes disposal, the last session on the third day encour- aged participation by using three panel groups of experts who represented technology, regulatory, and user groups. Questions and comments were gathered from attendees at all of the previous presentations for these panel discussion^ Roy Detweiler, Workshop Chairman, provided pertinent remarks regarding the assessment of the work- shop and where we must go from here before acting as the moderator for all three panels. The Technology Summary Panel con- sisted of Dr. James N. Seiber as Chair- man, Dr. Philip C. Kearney, Francis T. Mayo, and George P. Nassus. Each Panel member (well-known to most of the attendees) spent a few minutes summarizing the technology aspects of the workshop. Questions and answers followed the panel's comments. The Regulatory Summary Panel was i chaired by Raymond F. Krueger and other distinguished panelists included Orlo Robert Ehart and H. F. "Butch" Cal- houn, III. Each panelist summarized state, regional, and federal regulatory issues. The entire workshop attendance was impressed with the efforts of the researchers, associations, users, regula- tors, and producers in communicating with each other in working toward solu- tions that will benefit the whole group. It was noted that workshops such as the ones held in 1985 and 1986 are a result of people working together for a common environmental goal. At the 1985 workshop, a user group began the workshop by describing the problems and at this 1986 workshop, the Users' Summary Panel concluded the program with a discussion of what had been accomplished by the first and second workshops. Harold M. Collins chaired the panel, which included Richard Byer, Robert M. Russell, and Dr. William T. Keane. The concensus of this group was that whereas we have come a long way from the first workshop, we still have a long way to go. The work- shop ended with a good exchange of questions and answers. The transcripts of all three panel interactions are part of the proceedings. The full report was submitted in fulfill- ment of Contract 68-03-3252 by JACA Corporation under the sponsorship of the U.S. Environmental Protection Agency. ------- ------- This Project Summary was prepared by staff of JACA Corporation, Fort Washington, PA 19034. James Bridges is the EPA Project Officer (see below). The complete report, entitled "Proceedings: National Workshop on Pesticide Waste Disposal -1986," (Order No. PB 87-153 318/AS; Cost: $18.95, subject to change) will be available only from: National Technical Information Service 5285 Port Royal Road Springfield, VA22161 Telephone: 703-487-4650 The EPA Project Officer can be contacted at: Hazardous Waste Engineering Research Laboratory U.S. Environmental Protection Agency Cincinnati, OH 45268 United States Environmental Protection Agency Center for Environmental Research Information Cincinnati OH 452G3 BULK RATE POSTAGE & FEES Pf EPA PERMIT No G-35 Official Business Penalty for Private Use S300 EPA/600/9-87/001 0000329 ------- |