-------
27551 (10) were capable of completely
degrading the 1500 ppm of coumaphos left in
a spent dip-vat sample (Fig. 2). The rate
of coumaphos degradation was dependent upon
cell density, with a very high cell density
catalyzing complete hydrolysis within 2
hours. The reaction catalyzed by the
parathion hydrolase enzyme of
Flavobacterium is shown in Figure 3. The
only products of this reaction are diethyl-
thiophosphoric acid and 3-chloro-4-methyl-
7-hydroxycoumarin (commonly called chlor-
feron).
C,H,0
C,H,O
II
:POH
CH,
Coumaphos
Figure 3. Hydrolysis of Coumaphos
b.y parathion hydrolase
The chlorferon produced -by the microbi-r
al hydrolysis of coumaphos was much more
susceptible to destruction by UV-ozonation
than was coumaphos itself (Fig. 4). This
figure represents the complete microbial
hydrolysis-U.V. ozonation process where
1500 ppm of coumaphos in an authentic waste
sample from an APHIS dip-vat was exposed to
whole cells of the parathion hydrolase
producing Flavobacterium for 4 hours
followed by U.V.-ozonation for an
additional 3 hours. Although the
chlorferon hydrolysis product was no longer
detectable by high-performance liquid
chromatography after 3 hours of U.V.-ozona-
3 Vo
Time (hours)
Figure 4. Microbial metabolism/U.V.-Og
of dip-vat Coumaphos
tion, most of the carbon derived from the
benzene moiety of chlorferon (as measured
by radioactive **C label) remained in
solution, indicating that the oxidation of
chlorferon was incomplete. The products of
this reaction are water soluble organics
with 2,4-dihydroxyacetophenone as the major
product. When the U.V.-ozonated material
was applied to top soil that had been
biologically activated by preincubation
with glucose and yeast extract the remain-
ing 1*C labeled material was released
as i^cc^ (Fig. 5) indicating that the
products of U.V.-ozonation of microbially
hydrolyzed coumaphos were rapidly and
completely oxidized by the indigenous soil
bacteria. There was little 1^CC>2
released from coumaphos that had been
U.V.-ozonated without prior microbial
hydrolysis or from material that had been
subjected to microbial hydrolysis but had
not been U.V.-ozonated.
Figure 5. ^CC>2 release from treated
dip-vat Coumaphos added to
soil
What we have described thus far is a
set of laboratory, experiments in which 1
liter volumes (or less) of raw waste cat-
tle-dip were treated. One interesting
result from these experiments is that the
Flavobacterium cells added to the vat waste
were rapidly killed during the U.V.-ozona-
tion process. This was not completely
unexpected since many European communities
use U.V.-ozonation as a water purification
process (in lieu of chlorination) to
control harmful microbes. This aspect of
the process could become more important if
we try to utilize genetically engineered
41
-------
microbes as a part of the process. In
order to determine whether this process
could be useful on a large volume of waste
in more uncontrolled field conditions a
preliminary field trial was set up at an
APHIS cattle-dipping site. It was decided
to attempt to treat 650 gallons of waste
cattle dip in one compartment of a 3
compartment, 2000 gallon, stainless steel
tank used in the APHIS operation for
hauling water and waste dip material.
The field trial was performed in
mid-August at a vat site in Laredo, TX.
In order to overcome the need to deliver an
extremely large number of organisms to the
site we decided to add the organisms as a
1% inoculum (6 gallons of culture grown in
nutrient broth plus xylose) along with 21
pounds (Ib.) of xylose as a carbon source
and 10 Ib. of Southern States ammonium
sulfate fertilizer as a nitrogen source, in
order to allow growth of the organisms in
the waste. The pH of the material in the
tank was adjusted to between 6.8 and 7.0 by
the addition of 3 Ib. of monobasic
potassium phosphate and 4 Ib. of dibasic
potassium phosphate. The temperature of
the liquid varied between 36°C (98°F) and
33°C (90*F). The tank was rigorously
aerated. Samples were taken at various
times and diluted with methanol for later
analysis of coumaphos and chlorferon. On-
site determination of coumaphos levels in
the tank was performed using .a coloimetric
assay kit (Bayvet, Shawnee, KS).
The microbial hydrolysis of coum-
aphos in the treated compartment was essen-
tially complete within 48 hours (Fig. 6).
3,0
1.0-
•Coumaphos
•Chlorferon
10 20 30 40 SO
Time (hours)
Figure 6. Microbial metabolism of
dip-vat Coumaphos at
the Laredo field-trial.
As expected, the chlorferon hydrolysis
product accumulated. At this point aera-
tion of the tank was stopped and ozone
(generated using a Griffin ozone generator)
was introduced into the tank for about 20
hours. Delayed analysis indicated that
over 50% of the chlorferon was degraded
during this process. Laboratory analysis
on smaller volumes of material had in-
dicated that chlorferon was very suscepti-
ble to oxidation by mechanically generated
ozone in the absence of U.V. light.
The results of the Laredo field trial
indicate that the method of microbial
hydrolysis-U.V.ozonation is very effective
in the elimination of waste coumaphos.
Some technical problems that hampered our
effort at Laredo were a lack of familiarity
with the site, difficulties in delivering
fresh, actively growing bacterial cultures
to a remote site, and lack of the analyti-
cal chemistry capability to follow the
course of the degradation process. None of
these problems are insurmountable. A
second, more extensive field trial is
planned for the late spring of 1986. Among
the things to be tested are alternative
methods for the delivery of active cultures
to a remote location. The delivery of ade-
quate amounts of ozone into the hydrolyzed
material was also a problem during this
trial. However, this is strictly a problem
of engineering existing technology to fit
this unique purpose and should pose no
great difficulty to the development of this
process. Large scale U.V.-ozonation units
for the treatment of extremely large vol-
umes of drinking water already exist and
the technology behind such systems should
be directly applicable to our purposes.
Based on the one preliminary field
trial described here, the cost to
completely eliminate the waste from one
3,000 gallon vat would be less than
$500(US). This cost is based on a price of
$2.49/lb for xylose and $0.12/lb. for
ammonium sulfate. We used an analytical
grade of potassium phosphate but a much
less costly source of phosphate could be
found. Much work needs to be done to
determine the optimum amounts of the above
chemicals needed to run the system cost
effectively. With additional research many
of the parameters on the biological portion
of the system could be optimized leading to
large reductions in costs . The $500/vat
42
-------
estimate also includes an estimated cost of
$12/week to run the U.V.-ozonation unit at
$0.05/kilowatt hour.
What does the future hold for the
treatment of agrochemical wastes? Recent
research has shown that many types of
pesticides are directly ammenable to
destruction by U.V.-ozonation (4,5).
However, the capital cost of purchasing the
U.V. ozonation unit is somewhat high.
Perhaps pesticide distributors will be able
to purchase portable units and provide
their customers with waste removal as a
service. On the biological front the
future is very bright as more laboratories
begin to explore the biochemistry and
molecular biology of pesticide degradation
by plants, animals, and microbes. We have
isolated and partially purified an enzyme
which degrades the N-methylcarbamate
insecticide carbofuran. Like the parathion
hydrolase so well characterized by Munnecke
and his co-workers (8), this enzyme is a
hydrolase with a broad substrate
specificity so that it can also hydrolyze
carbaryl and aldicarb. Unlike parathion
hydrolase this enzyme is unstable in crude
extracts, but once partially purified it,
too, exhibits remarkable stability. The
pesticide hydrolase enzymes characterized
so far are active over a broad range of pH
and temperature. As more research is
conducted we are sure similar enzymes will
be found for acylanilide herbicides (such
as alachlor and metolachlor) and
dithiophosphorate insecticides (such as
Terbufos and Dyphonate). Such enzymes
might be distributed as packets, containing
enzyme and buffer, that the farmer or
applicator could add to containers and
tanks to assure overnight degradation of
waste pesticides in rinsates. While such
enzymes do not totally degrade pesticides,
the one step hydrolysis they catalyze- does
destroy the biological activity of the
compounds (thus, in the case of insecti-
cides greatly reducing their toxicity)
making them safer to dispose of or to store
until enough has accumulated to make it
practical to subject them to further '
destructive techniques such as U.V.-
ozonation or incineration.
The techniques associated with bio-
technology may be used to increase the
production of microbial enzymes or to
change the range of compounds that an
enzyme can degrade. As more research is
done in the area of biological waste
management further advancements are antici-
pated. What is needed is a new level of
committment from manufacturers, users and
government to finance research and to
develop the network of research scientists,
engineers and technicians required to take
basic research and develop practical
systems that can be used in the field.. The
level of protection demanded by the general
public and embodied in RCRA should not be
viewed as an obstacle to progress but as a
goal that can and will be obtained.
REFERENCES
1. Brown, K. A., 1980.
Phosphotriesterases of Flavobacterium
sp. Soil Biol. Biochem. 12 pp!05-112.
2. Dorn, E., Hellwig, M., Reineke, W.,
and H. J. Knackmuss, 1974. Isolation
and characterization of a
3-chlorobenzoic acid degrading
pseudomonad. Arch. Microbiol. 99
pp61-70.
3. Evans, W. C., Smith, B. S. W. ,
Fernley, H. N., and J. I. Davies,
1971. Bacterial metabolism of
2,4-dichlorophenoxyacetate. Biochem.
J. 122 pp543-551.
4. .Kearney, P. C., Plimmer, J. R., and
Z. M. Li, 1983. U.V.-ozonation and
land disposal of aqueous pesticide
wastes. Pp397-400 in J. Miyamoto,
ed., Pesticide Chemistry-Human Welfare
and the Environment, Vol. 4. Pergamon
Press, Oxford.
5. Kearney, P. C., Zeng, Q., and J. M.
Ruth, 1984. A large scale U.V.-ozona-
tion degradation unit - Field trials
on soil pesticide waste disposal. In
R. F. Krueger and J. N. Seiber, eds.,
Treatment and Disposal of Pesticide
Wastes. ACS Symp. Series 259.
6. Kilbane, J. J., Chatterjee, D. K.,
Karns, J. S., Kellogg, S. T., and A.
M. Chakrabarty, 1982. Biodegradation
of 2,4,5-trichlorophenoxyacetic acid
by a pure culture of Pseudomonas
cepacia. Appl. Environ. Microbiol. 44
pp72-78.
43
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REFERENCES (Continued)
7. Munnecke, D. M and D. P. H. Hsieh,
1974. Microbial decontamination of
parathion and p-nitrophenol in aqueous
media. Appl. Microbiol. 28 pp212-217.
8. Munnecke, D. M., 1976. Enzymatic
hydrolysis of organophosphate
insecticides, a possible pesticide
disposal method. Appl. Environ.
Microbiol. 32 pp7-13.
9. Nelson, L. M., 1982. Biologically
induced hydrolysis of parathion in
soil: Isolation of hydrolyzing
bacteria. Soil Biol. Biochem. 14
pp219-222.
10. Siddaramappa, R., Rajaram, K. P., and
N. Sethunathan, 1973. Degradation of
parathion by bacteria isolated from
flooded soil. Appl. Microbiol. 26
pp846-849.
11. Stanlake, G. J. and R. K. Finn, 1982.
Isolation and characterization of a
pentachlorophenol degrading bacterium.
Appl. Environ. Microbiol. 44
pp!421-1427.
44
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BIOLOGICAL AND CHEMICAL DISPOSAL SYSTEMS FOR WASTE PESTICIDE SOLUTIONS
Catherine Schmidt, Brian Klubek and James Tweedy
Department of Plant and Soil Science
Southern Illinois University - Carbondale
Carbondale, Illinois 62901
ABSTRACT
Acidic and alkaline trickling filter systems were assessed for biological and
chemical decomposition of pesticides. A disposal pit (6.1 m x 6.1 m x 1.2 m) was filled
with coarse grade limestone for promotion of alkaline hydrolysis, another with acid waste
material from a strip mine operation foo promote acid hydrolysis. A network of 2-in per-
forated PVC pipe suspended over the filter material and a circulation pump facilitate
distribution of the test solutions. The treatment systems were inoculated with indigen-
ous pesticide-decomposing bacteria to enhance degradation.
Microbial counts have been determined over time and compared with pesticide concen-
trations (via gas chromatography). Compounds tested include alachlor, atrazine, butylate,,
cyanazine, linuron, metolachlor, metribuzin, pendimethalin, and trifluralin. All but
granular formulations have been used. Greater degradation rates were generally observed
in the acid system (up to 30% per day). Degradation rates for the alkaline disposal
system averaged 2.5% per day.
INTRODUCTION
Pesticide applicators and dealers are
faced with a waste disposal problem which
may vary according to the size and type of
operation. Waste-water from vehicle wash-
ing, spray or nurse tank rinse-water,
haul back solutions, facility runoff,
spilled materials, obsolete or unidentifi-
able chemicals, containers and incompati-
ble mixtures are all recognized sources of
waste pesticide solutions (6).
LITERATURE REVIEW
The use of toxic chemical compounds
in agriculture has created problems of
biological and environmental concern since
the pesticides employed may not be totally
specific and degraded to a harmless state.
The concern for potential biohazards which
may exist from yearly application was
acknowledged in a study carried out by the
Association of State Universities and Land
Grant Colleges and United States Depart-
ment of Agriculture (20).
The Fate of Pesticide in the Soil
Pesticides applied to the soil or
which ultimately reach the soil may be
acted upon physically, chemically, or bio-
logically. ATI result in a change of
structure and/or toxicity (2, 17). Physi-
cal losses of pesticides from the soil
include: wind and water erosion, adsorp-
tion to soil particles such as organic
matter, leaching, and volatilization.
Chemical mechanisms of transformations are
much less understood and only recently are
being proposed as major pathways of pesti-
cide degradation. In addition, chemical
transformations may contribute essential
stages to principally biological decom-
position pathways (16). Alkaline hydro-
lysis, reduction, elimination, decarboxyla-
tion, oxidation, and isomerization are
among the reactions that may occur (12).
Photodecomposition is a,combination of
physical and chemical transformations.
The majority of pesticides are subject to
Photodecomposition and this may be the
prominant degradative mechanism of pesti-
45
-------
cide vapors. However, it is not signifi-
cant when the material is soil incorporat*-
ed or on crops and crop residues (14).
Soil microorganisms and plants are
responsible for biological pesticide trans-
formations. Transformations by plants
(such as plant uptake of herbicides) re-
sult in a decrease of pesticide concentra-
tions (1, 13). Indigenous microbial pop-
ulations of bacteria and fungi play a key
role in pesticide biodegradation (2).
Alexander (2) and Atlas and Bartha (8) have
categorized microbial transformations of
pesticides on the basis of the end-product
formed: detoxification, degradation, con-
jugation, complex formation, activation,
defusing, and a change in the spectrum of
toxicity.
Rates and mechanisms of pesticide de-
gradation are dependent on the environment-
al conditions (15). Biological, chemical,
and physical transformations cannot be
separated since exclusion of one will alter
rates and pathways of the decomposition
process (15, 17).
The pesticides used in this study were
selected on the basis of their popularity
in Illinois agriculture systems. For in-
formation on the degradation of alachlor
(2-chloro-2', 6'-diethyl-N-[methoxymethyl]
acetanilide), atrazine (2-chloro-4-[ethy-
lamino]-6-[isopropylamino]-s-triazine),
butylate (s-ethyl diisobutylthiocarbamate).
cyanazine (2-[[4-chloro-6-(ethylamino)-s-
:triazin-2-yl]amino]-2-methylpropionitrrie).,
linuron (3-[3,4-dichlorophenyl]-l-methoxy-
1-methylurea), metolachlor (2-chloro-N-E2-
ethyl-6-methylphenyl]-N-[2-methoxy-1-methy-
1ethyl]acetamide), metribuzin (4-amino-6-
tert-butyl-3-[methylthio3-as-triazin-5[4H]-
one), pendimethalin (N-[l-ethylpropyl]-3,4
dimethyl-2,6 dinitrobenzenamine), and tri-
fluralin (2,6-dinitro-N,N-dipropyl-4-tri-
fluoromethylaniline) please consult the
following sources: Brown (9), Cripps and
Roberts (11), Herbicide Handbook of the '
Weed Science Society of America (7),and"
Knuesli et al. (18). *~'
Pesticide Disposal Practices
The mismanagement of generated waste
pesticide materials may cause" potential
environmental problems: the contamination
of ground and surface water via runoff from
the site of pesticide mixing, and/or dis-
charges of chemical spray tank rinsates
into streams (4, 6). The difficulty of
implementing regulatory measures for the
proper disposal of waste pesticide materi-
als has resulted in certain illegal dis-
posal practices such as rinsing spray tanks
on open lots without providing containment,
improper disposal of the rinsate solutions,
dumping excess spray solutions and tank
rinsings along fence rows, and discharging
pesticide-contaminated waste-waters into
ditches and streams (6).
Various methods of treatment and dis-
posal of waste pesticide solutions have
been proposed and evaluated. Such methods
include land disposal (land cultivation,
soil mounds and pits), evaporation basins
and lagoons, chemical treatments, physical
treatments(adsorption and reverse osmosis),
biological treatment (trickling filters
and activated sludge) and incineration (4).
From 1977 to 1979, Iowa State Univer-
sity conducted an experimental study of
pesticide decay by using 56 minipits (plas-
tic garbage cans), 2 macropits, and 4
micropits (5). The macropits were designed
for the more practical aspect of waste
pesticide disposal. Essentially, they were
soil pits with a top or middle layer of
rock. Neither circulation nor aeration
occurred, thus representing static systems.
These pits were also uncontrolled since
timing, amount, and type of waste materials
to be disposed were not planned, but merely
monitored over time. The pH, chemical
constituents, and microbial populations
were determined. However, the role of the
microbial populations in pesticide decom-
position was not delineated.
In a recent project at Southern Illi-
nois University-Carbondale, the disposal of
atrazine and trifluralin was assessed in an
acid.and alkaline trickling filter system
(21). Trifluralin phytotoxity was observed
to decline to 3 and 5% in the acid and
alkaline disposaT pits, respectively*
following 21 days of incubation. Atrazine
phytotoxicity fell to 23% in the acidic
pit after 21 days of incubation bu,t re-
mained constant (68 to 70%) in the alka-
line pit. However, herbicide concentra-
tions were not determined. Population
counts of herbicide decomposers demonstra-
ted a one to two log increase in the alka-
line pit following 5 to 9 days of incuba-
tion. The acidic pit showed two peaks in
the counts of herbicide decomposers after
46
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1 and 14 days of incubation. Significant
cubic and quadratic functions were deter-
mined for herbicide phytotoxicity and de-
composer counts versus time in the acid
and alkaline disposal pits, indicating .a
direct effect by the microbial population
on herbicide activity.
The objectives of this study were:
to evaluate a variety of herbicides com-
monly used in high volumes in Illinois for
disposal in acid and alkaline trickling
filter systems and to compare numbers of
pesticide degrading microorganisms with
pesticide degradation.
MATERIALS AND METHODS
Description of Pesticide Disposal Pits
During the summer of 1981, trickling
filter disposal pits were constructed at
the Southern Illinois Fruit Station,
Carbondale, Illinois in an argil!ic (Bt)
horizon of a Weir silt loam (fine,
montmorillonitic, mesic typic ochraqualf)
(Figures 1 and 2). The dimensions of the
pits are 6.1 m x 6.1 m x 1.2 m or 44.7 m3.
The pits are side by side but separated by
a 1 m clay barrier and surrounded by a 61
centimeter (cm) berm. In one pit, the
filtering medium is coarse grade limestone
(alkaline pit). This creates a neutral to
alkaline environment facilitating chemical
hydrolysis and microbial growth. In the
adjacent pit, the medium is acid mine gob
obtained from a nearby coal strip mine,
creating a highly acidic arid strongly
anaerobic system (acid pit). Each pit has
a single well equipped with a 248 kilogram
meter squared per cub.ic second (kg- rt)2 S^j
sump pump discharging the dilute pesticide
solutions through a network of 5.1 cm PVC
perforated pipe. The flow rate of the
pumps was rated at 10.4 (m3 hr~1). Because
of high porosity of the limestone, the
pesticide solutions were discharged in a
continuous mode in the alkaline pit. The
very low porosity of the gob material only
permitted intermittent discharging (at 30
minute (min) cycles) of the pesticide
solutions.
PVC RECIRCULATED
PIPE WASTE SOLUTIONS
t
SUBMERSIBLE '
PUMP
-WASTE PESTICIDE
^ "' •-••••• -• •« SOLUTION
-FILTRATION MEDIUM
Figure 1. Side view of pesticide disposal
system.
Figure 2. Overhead view of pesticide dis-
posal system.
Isolation of Pesticide Decomposing Micro-
organisms
Soil samples, as a source of herbi-
cide decomposing microorganisms, were
taken from the soils adjacent to the acid/
alkaline trickling filter system. The
soil samples were composited and sieved to
a two to five millimeter (mm) particle
size-followed by storage at 4 degrees
celcius (C) until used.
The isolation of herbicide decomposers
utilized the soil perfusion method de-
scribed by Collins and Simms (10). This
system was used as an enrichment technique.
Super Floe 127 (American Cyanimid), a soil
stabilizer, was added (0.8% dry weight
basis) to each 100 gram (g) soil sample.
Tap water was added to bring the mixture
to a smooth paste consistency. The soil-
paste was sieved, obtaining five to seven
mm crumb-like particles. The particles
were air dried for two days at room temp-^
erature.
Following drying, 20 g of the stabili-
zed particles were placed in a perfusion
flask containing 250 milliliters (ml) of
tap water. A total of 18 flasks were per-
fused for 24 hours. The perfusates were
discarded and replaced with 200 milligrams
per liter (mg L-l) solution of alachlor,
atrazine, butylate, cyanazine, linuron,
pendimethalin, metolachlor, metribuzin, or
trifluralin, plus 30 ml of pesticide grade
methanol (two flasks per treatment). The
experimental units were run for 14 days in
the dark at room temperature under optimal
aeration and suction.
The perfusates were analyzed initially
and every four days thereafter for herbi-
cide degrading microorganisms employing a
differential medium (19) modified from
Thorton's agar. Each of the herbicides
being tested was the sole carbon source in
the growth media. A 0.1 ml sample from
each perfusion flask was plated on the
47
-------
appropriate differential medium. The
appearance of red or blue colonies allowed
for the identification and subsequent cul-
turing of the desired microorganisms.
Disposal Pit Inoculation
Isolates of herbicide decomposing
bacteria were maintained on fresh plates
containing 200 mg L~1 of the appropriate
herbicide. One to two isolates of each
type of herbicide decomposer were grown in
1 L of Thorton's medium and used to innocu-
late each disposal pit prior to herbicide
additions. Samples of the inoculum were
plated on the differential media as pre-
viously described for an initial herbicide
decomposer count.
Loading of the Disposal Pits
On October 4, 1985, each disposal pit
was loaded with 4.7 L Aatrex (40.8% a.i.),
4.4 L Bladex 4L '(43%,va.i.), 1.9 L Dual 8E
(86.4% a.i.), 1.6 L Lasso (45.1% a.1.),
and 1.7 L Sutan* (6 Ib/gal a.i,,),, The
water level was maintained at approximately
51 cm in the alkaline pit and 40 cm in the
acid pit.
A second inoculation and herbicide
loading of the disposal pits were made on
November 7, 1985. Each pit received 1
kilogram (kg) Lexone DF (75% a.i.), 4L
llorox (41% a.i.), 0.4 L Prowl (42.3% a..i.),
and 4.8 L Treflan (41.2%). Due to ex-
treme amounts of rainfall throughout Novem-
ber, the pump was removed from the alkaline
pit on November 12 and from the acid pit
November 17.
Sampling and Biological/Chemical Analyses
Composit water samples were taken
from each PVC pipe at a schedule of 1, 4,
7, 10, 13, 16, 19, 22, 25, and 28 days.
Duplicate 125 ml samples were collected in
sterile plastic bottles. Total bacteria
counts, herbicide decomposer counts,
herbicide concentration, and pH were
determined for each sample.
Total bacteria counts were made by
plating the water samples.on Thorton's
medium. Herbicide decomposer; counts were
determined by employing the various differ-
ential media as previously described.
The pH of the water samples was de-
termined with a Fisher accumet pH meter,
model 620.
To extract the herbicides, ten milli-
ters of sample were added to a 50 ml Erlen-
myer flask followed by the addition of 20
ml diethyl ether. The mixture was shaken
for 5 min on a rotary shaker and trans-
ferred to a 250 ml separating funnel and
allowed to stand for 15 min. The water
layer was then removed and the ether frac-
tion was collected for analysis via gas-
liquid chromatography.
For the determination of each herbi-
cide, a 1 microliter (pi) sample was in-
jected into a Varian 3700 series gas
chromatograph equipped with a flame ioniza-
tion detector. Nitrogen was used as the
carrier gas (flow rate 30 ml mfn-1) while
air (flow rate 300 ml.min-l) and hydrogen
(flow rate 30 ml min~l) provided for flame
ionization. The herbicides were separated
on a 1.8 m x 4 m glass column packed with
PT 5% SE-30 on Chrom W-HP, 80 to 100 mesh
(Alltech Associates, Deerfield, IL). The
column temperature was maintained at 180 C
while the injector temperature was main-
tained at 210 C and the detector tempera-
ture was set at 230 C. Range and attenua-
tion setting was set at 4 x 10-11. A 200
microgram per milliliter (yg ml-1) stand-
ard of each herbicide was used as a refer-
ence. The concentration of each herbicide
in the water samples was then determined
as described by Standard Methods of Water ,
Analysis (3).
Statistical Analysis
An analysis of variance and trend
analysis of total and herbicide decomposer
bacteria counts over time were conducted.
Percent decay curves were determined 'for
applied-herbicides. Statistical analysis
was performed by an IBM 370 computer using
the SAS statistical package.
RESULTS AND DISCUSSION
Disposal of Corn Herbicides
Total bacteria and average herbicide
decomposer population counts for corn
herbicides applied to the alkaline and
acid disposal systems are summarized in
Figures 3 and 4, respectively. Total
bacteria numbers represent the mean of
seven samples. Decomposer counts repre-
sent the mean of alachlor-*-, atrazine-,
butyl ate-, cyanazine-, and metolachlor-
48
_
-------
decomposers, ihe value for each type of
herbicide decomposer is the mean of seven
samples. Herbicide concentrations (micro-
gram per liter, yg L-1) for alachlor +
metolachlor, atrazine, and butylate in the
alkaline and acid systems are presented in
Figures 5 and 6, respectively.
7r
500r
• Total Count
A Decomposer Count
1 4 7 10 13 16 19 22 25 28
Time, Days
Figure 3. Total and decomposer counts
for corn herbicides applied
to the alkaline disposal
system.
O)
o
a
• Total Count
A Decomposer Count
T
1 4 7 10 13 16 19 22 25 28
Time, Days
Figure 4. Total and decomposer counts
for corn herbicides applied to
the acid disposal system.
A Alachlor + Metolachlor
• Butylate
• Atrazine
1 4 7 10 13 16 19 22 25 28
Time, Days
Figure 5. Corn herbicide concentrations
in the alkaline disposal system.
500-
A Alachlor +
Metolachlor
• Butylate
• Atrazine
Figure 6.
13 16 19
Time, Days
Corn herbicide concentrations
in the acid disposal system.
Total and decomposer counts responded
similarly to the addition of herbicides to
both pits. The population counts initi-
49
-------
ally increased, with the highest values
occurring between days 4 and 10. In the
alkaline pit, counts decreased throughout
the remainder of the trial with a slight
gain at days 25 and 28 for total bacteria
and day 28 for decomposer bacteria. In
the acid pit, the overall population counts
decreased. However, secondary and terti-
ary peaks occurred at days 16 and 25 for
total bacteria and days 22 and 28 for de-
composer bacteria. These non-primary
peaks may be the result of several influ-
ences. The microbial response to desbrbed
herbicide from the gob material .and/or ini-
tial breakdown products as new substrates
or changes in pH are likely candidates.
According to analysis of variance,
total counts were significant at P*0.05
for the alkaline pit and at P<0.1 for the
acid pit. Trend analysis showed these
relationships over time to be non-signifi-
cant in the acid pit and quartic (P<0.05)
in the alkaline pit. The analysis of
variance of decomposer counts was also
significant .at P<0.05 and quartic over
time (P<0.05) by trend analysis.
In the alkaline system, herbicide
concentrations generally decreased through-
out this first experiment. Decay rates
were 3% per day for alachlor + metolachlor
(r=0.904), 2.5% per day for atrazine (r=
0.951), and 3% per day for butylate (r=
1.133). Herbicides in the acid system
degraded more readily. Initial concentra-
tions were two fold that of the alkaline
system and final concentrations were nearly
non-existant. Minor increases (less than
30 v9 L-1) in concentrations are likely due
to either inherent error in the sampling
and preparation for gas chromatography
analysis, or desorption of the herbicide
from the gob material. Decay rates were
30% per day for alachlor + metolachlor
(r=1.005), 28% per day for atrazine (r=
0.897), and 19% per day for butylate (r=
0.824).
Disposal of Soybean Herbicides
Total bacteria and average herbicide
decomposer bacteria counts for .soybean
herbicides applied to the alkaline and
acid disposal pits are given in Figures
7 and 8 respectively. Total bacteria
counts represent the mean of seven samples.
Decomposer counts are the average of linu-
ron-, metribuzin-, pendimethalin-, and
trifluralin-decomposer bacteria. There
were seven samples for each specific
herbicide decomposer. Herbicide concen-
trations (tig L~') of metribuzin and pendi-
methalin for alkaline and acid systems
are illustrated in Figures 9 and 10, re-
spectively.
51-
JO
*c
0)
(J
£ 4
m Total Count
A Decomposer Count
1 4 7 10 13 16 19 22 25 28
Time, Days
Figure 7. Total and decomposer counts for
soybean herbicides applied to
the alkaline disposal system.
O)
o
• Total Count
A Decomposer Count
1 4 7 10 13 16 19 22 25 28
Time, Days
Figure 8. Total and decomposer counts for
soybean herbicides applied to
the acid disposal system.
Total and decomposer counts demonstra-
ted tri-modal curves for both disposal
systems with peaks occurring approximately
10 days apart. This cyclic growth pattern
is a likely-microbial response to the addi-
tion of the herbicides. The secondary and
tertiary peaks are the result of the micro-
bial population adjusting to new and perhaps
50
-------
500
250
« 75
8
1 'I
§ 5°
u
0)
TJ
25
• Metribuzin
A Pendimethalin
1 4 7 10 13 16 19 22 25 28
Time, Days
Figure 9. Soybean herbicide concentra-
tions in the alkaline disposal
system.
250r
150
S
§
Q
01
•o
50
25
• Metribuzin
A Pendimethalin
1 4 7 10 13 16 19 22 25 28
Time, Days
Figure 10. Soybean herbicide concentra-
tions in the acid disposal
system.
more complex substrates as degradation
proceedes. Microbial counts for the acid
pit increased after day 16. This is in
response to a more favorable pH. The dis-
posal systems were inundated with rain.
The pumps had to be removed to prevent
water damage. Under the static conditions,
the pH of the trench water increased, be-
coming more favorable for rnicrobial growth.
Analysis of variance showed all bact-
eria counts to be significant at P<0.05,
and these relationships (over time) were
quartic according to trend analysis (P<
0.05).
Herbicide degradation in both disposal
pits was very slow, and may be related to
the cooler temperatures observed for Novem-
ber. Metribuzin decayed at a rate of 2%
per day (r=0.8T7) in the alkaline pit anrfTB
per day (r=0.858) in the acid pit. Slight
increases (less than 54 yg L'1) in metri-
buzin concentration occur in the alkaline
pit. Again, this may be due to either de-
sorption or inherent error in preparation
for gas chromatography analysis.
CONCLUSIONS
The load capacity of these systems is
dictated.by the size of pits constructed.
The estimated capital and operating costs
(1985 dollars) are $6,000 and $2,500/yr.,
respectively. Some advantages to these
systems are that they are effective on most
commonly used herbicides and insecticides in
Illinois, and further disposal of residues
is not required. Another desirable aspect
is that the skills required to construct
and maintain either of these systems are
available in any agricultural community.
Persistence of triazines in the alkaline
system, Tow infiltration rates of waste
solutions through the acid material;, and
necessity of noncorrodable pumps are the
disadvantages to these systems. Life ex-
pectancy, identification of major breakdown
products contained in the systems and of
volati-lized compounds should be established
prior to use of this technology for the
treatment and disposal of pesticide waste-
water. Current trends in state regulation
of in-ground disposal systems may cause
them to become obsolete. However, this
technology can be readily incorporated into
an above-ground system as illustrated in '
Figure 11.
PERFORATED PVC PIPE
CRUSHED
LIMESTONE
OR ACID GOB
Figure 11. Proposed above-ground pesticide
disposal system.
51
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REFERENCES
Press, New York, pp. 669-730.
1. Alexander, M. 1973. Nonbiodegradable
and other recalcitrant molecules. Bior-
technology and Bioengineering. 15, pp.
611-647
2. Alexander, M. 1977. Introduction to ,
Soil Microbiology. John Wiley and
Sons, New York.
3. Anonymous. 1975. Standard Methods for
the Examination of Water and Waste
Water. American Public Health Associa-
tion, Washington D.C.
4. Anonymous. 1979. Disposal of Dilute
Pesticide Solutions. Prepared for the
Environmental Protection Agency,
Washington D.C. Office of Solid Waste.
National Technical Information Service,
Alexandria, Virginia.
5. Anonymous. 1981. Safe Disposal Meth-
ods for Agricultural Pesticide Wastes.
Prepared for Municipal Environmental
Research Laboratory, Cincinnati, Ohio
by Iowa State University, Ames. Na-
tional Technical Information Service.
6. Anonymous. 1982. A Guide to Minimiz-
ing Problems of Pesticide Waste Manage-
ment. A report by the Joint Illinois
Environmental Protection Agency.
Illinois Department of Agriculture and
Industry Task Force on Management of
Pesticide Waste Materials, Springfield,
Illinois.
7. Anonymous. 1983. Herbicide Handbook
of the Weed Science Society of America,
5th Edition, Weed Science Society of
America, Champaign, IL.
8. Atlas, R.M. and R. Bartha. 1981.
Microbial Ecology: Fundamentals and
Applications. Addison-Wesley Publish-
ing Co., Reading, Massachusetts.
9. Brown, A.W.A. 1978. Ecology of Pesti-
cides. John Wiley and Sons, New York.
10. Collins, F.M. and C.M. Simms. 1956.
A Compact Soil Perfusion Apparatus.
Nature, 178, pp. 1073-1074.
11. Cripps, R.E. and T.R. Roberts. 1978.
Microbial Degradation of Herbicides
In I.R. Hill and S.J.L. Wright (eds.)
Pesticide Microbiology. Academic
12. Crosby, D.6. 1973. The Fate of Pesti-
cides in the Environment. Analytical
Review of Plant Physiology, 24, pp.
467-492.
13. Edwards, C.A. 1973. Persistant Pesti-
cides in the Environment, 2nd Edition.
CRC Press, Cleveland, Ohio.
14. Goring, C.A.I., D.A. Laskowski, W.
Hamaker, and R.W. Meikle. 1975.
Principles of Pesticide Degradation in
Soil. In R. Haque and V. Freed (eds.)
Environmental Dynamics of Pesticides.
Plenum Press, New York, pp. 135-172.
15. Greaves, M.P., H.A. Davies, J.A.P.
Marsh, and G.T. Wingfield. 1976.
Herbicides and Soil Microorganisms.
CRC Critical Review of Soil Microbio-
logy, 5, pp. 1-38.
16. Hill, I.R. 1978. Microbial Transfor-
mation of Pesticides. In I.R. Hill
and S.J.L. Wright (eds.) Pesticide
Microbiology. Academic Press, New
York, pp. 137-202.
17. Hill, I.R. and S.J.L. Wright.' 1978.
The Behavior and Fate of Pesticide in
Microbial Environments. In I.R. Hill
and S.J. L. Wright (eds.) Pesticide
Microbiology. Academic press, New
York, pp. 79-136.
18. Knuesli, E., D. Berrer, G. Kupuis, and
H. Esser. 1969. Triazines. In P.C.
Kearney and D.D. Kaufman (eds.) Degra-
dation of Herbicides. Marcel Dekker,
Inc., New York pp. 51-78.
19. Loos, M.A. 1975. Indicator Media for
Microorganisms degrading Chlorinated
Pesticides. Canadian Journal of
Microbiology, 21, pp. 104-107.
20. Ridge, E.U. and C. Theodorou. 1972.
The Effect of Soil Fumigation on
microbial Recolonization and Mycorr-
hizal Infection. Soil Biology and
Biochemistry, 4, pp. 295-305.
21. Schmidt, C.A. 1985. Disposal Pits
for Waste Pesticide Solutions. Mast-
er's Thesis. Southern Illinois
University - Carbondale. 60 pp.
52
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PESTICIDE RESEARCH WORKSHOP SUMMARY
(Research Workshop on the .Treatment/Disposal of Pesticide Wastewater)
Philip C. Kearney
Pesticide Degradation Laboratory
U. S. Department of Agriculture
Beltsville, Maryland
and
Francis T. Mayo
Water Engineering Research Laboratory
U. S. Environmental Protection Agency
Cincinnati, Ohio
ABSTRACT
A research workshop on the treatment/disposal of pesticide wastewater
generated by the agricultural application of pesticides was held at the
U. S. Environmental Protection Agency's Andrew W. Breidenbach Environmental
Research Center in Cincinnati, Ohio on July 30-31, 1985. The purpose of
this workshop was to address issues regarding the effectiveness of current
state-of-the-art capabilities, identification of emerging techniques or
technologies that may be applicable along with technologies being applied
in other areas, and the need for research efforts capable of providing
results in a 3- to 5-year time frame as they pertain to the treatment/
disposal of dilute pesticide wastewater.
The format of the two-day workshop included the sixty-one invited
participants representing an appropriate cross-section of interests and
expertise attending at their own expense. Participants were mostly.
individuals actively involved in related research as well as adequate
representation from the user and regulatory community to assure that the
problem and candidate solutions were kept in proper perspective. The first
day plenary session addressed twelve technologies as follows: (1) pesticide
rinsewater recycling, (2) granular carbon adsorption, (3) UV-ozonation,
(4) small-scale incineration, (5) solar photo-decomposition, (6) chemical
degradation, (7) evaporation, photodegradation and biodegradation in
containment devices, (8) genetically engineered products, (9) leach fields,
(10) acid and alkaline trickling filter systems, (11) organic matrix
adsorption and microbial degradation, and (12) evaporation and biological
treatment with wicks. The second day divided the participants into two
workgroups. Workgroup A was entitled, "Physical/Chemical Treatment and
Recycling" and Workgroup B was entitled, "Biological Treatment & Land
Application."
A publication entitled, "Proceedings: Research Workshop on the
Treatment/Disposal of Pesticide Wastewater" resulted from this research
workshop. The publication is a compilation of the sixteen speaker's
abstracts, both work group results and a conclusion with recommendations.
While a brief summary was presented at the 1986 National Workshop on
53
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Pesticide Waste Disposal, the full Proceedings can be obtained through
the National Technical Information Service (NTIS). Please refer to
EPA 600/9-86-001 and NTIS Accession No. PB 86-167004/AS.
Physical/Chemical Treatment and Recycling
Workgroup A considered six technologies which included x) pesticide
rinsewater recycling, 2) granular activated carbon adsorption, 3) UV-ozonation,
4) small-scale incineration, 5) solar photodecomposition, and 6) chemical
degradation. Sub-workgroups were organized to evaluate each of these
technologies. Each sub-workgroup was asked to address three aspects of
its assigned technology: state-of-the-art capabilities, emerging technology
and (or) technology transfer opportunities, and research needs over the
next three to five years. In addition, information was developed on
current applications, potential difficulties, cost, ease of operation,
size, and shortcomings. Each technology was ranked on its suitability-
for on-site farm disposal. These findings were then discussed by the
full workgroup and modified as necessary to meet the consensus of opinion.
Two processes were considered proven technologies that are in use
and the techniques are available. These are recycling and granular acti-
vated carbon adsorption.
Recycling pesticide rinsewater has been used extensively in the past
by aerial applicators as a method of reducing or minimizing the amount of
wastewater that must be managed. Only the volume of spray needed for a
spray operation is mixed and any rinsewaters from containers are used as
diluents for subsequent spray solutions. Care must be exercised in
avoiding mixing any combination of active ingredients that could result in
subsequent crop damage or illegal residues.
Granular activated carbon adsorption has been used in certain
industrial situations as a means of removing organic chemicals from
water. It has been used on a very limited basis for pesticide rinsewater.
It can handle large volumes of wastewater in a relatively short time.
The process generates a carbon-pesticide residue that subsequently must
be treated/ disposed by additional methods.
UV-ozonation and chemical degradation were considered transfer
technology opportunities that require further development before full
implementation can be achieved. The remaining two technologies were
determined to be in the early development stage (emerging technology)
and would require research and evaluation before they would be available.
Biological Treatment and Land Application
Workgroup B also considered six technologies: 1) evaporation, photo-
degradation and biodegradation in containment devices, 2) genetically
engineered products, 3) leach fields, 4) acid and alkaline trickling filter
systems, 5) organic matrix adsorption and microbial degradation, and 6)
evaporation and biological treatment with wicks. As in Workgroup A; sub-
workgroups were organized for each of these technologies and the same
evaluation process was followed.
It was found that two technologies were currently in use and available
for managing dilute pesticide wastewater. These are 1) evaporation,
photodegradation in containment devices, and 2) leach fields. While
these two technologies are not endorsed by EPA or USDA, both technologies
were reported as existing technologies.
54
-------
Universities and other research facilities have been employing
evaporation, photodegradation and biodegradation in containment devices
(often referred to as "pits") to treat pesticide wastewaters for over 15
years; however, this method is not widely utilized for several reasons.
These include such unknowns as the potential for the treatment to further
produce hazardous wastes, uncertainty of the science and the product
results and lack of understanding of the treatment process on specific
pesticides.
Leach fields are being.used by many small fruit farms in New York.
However, additional information is needed to fully assess the groundwater
pollution potential posed by this system and it appears that the State
of New York is re-evaluating the acceptability of this technology.
The remaining four technologies, found to be emerging technologies,
will require.three to five years of research and development before
they can be expected to be available.
SUMMARY
There was a consensus of opinion that an immediate research effort
was needed to:
1. Address those research needs identified for the currently available,
proven technologies such that utilization of these methods can at
least be maximized on an interim basis.
2. Conduct preliminary assessments of the effectiveness of the emerging
technology opportunities and rank them for further development.
Consider the combination of technologies as part of this effort.
3. In priority order, address the identified research needs for the
emerging technology opportunities.
In addition, it was generally agreed that a combination of several
technologies probably offers one of the best opportunities for overcoming
some of the shortcomings of each individual method. Overriding issues
that ultimately will determine the widescale acceptance of any disposal
technology at the farm or commercial applicator level are effectiveness,
cost, ease of operation, durability, safety, and mobility.
Reference:
Bridges, J. and Dempsey, C., "Proceedings: Research Workshop on the
Treatment/Disposal of Pesticide Wastewater." U. S. Environmental Protection
Agency, EPA 600/9-86-001, January 1986.
55
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DIRECT INJECTION AS A RINSEWATER MINIMIZATION TECHNOLOGY
Lawrence 0. Roth
Oklahoma State University
Stillwater, OK 74078
Direct injection of pesticides into
a spray system is a potential means of
minimizing rinsewater. For the purpose
of this paper, direct injection is de-
fined as "Any scheme by which pesticide
concentrates are metered, injected or in-
troduced and mixed, by whatever means,
into a sprayer pressure system directly
from one or more shipping containers or
other specialized containers and at a
point in the system just before or near
where the mixture would be discharged
from the spray nozzles". A direct injec-
tion system (Figure 1) is essentially two
systems — a diluent system and a pesti-
cide concentrate system, with the
tank (the one we now use to put spray mix-
tures into )used only for diluent. Ideal-
ly, nothing would be pre-mixed and what-
ever is introduced into the pressurized
lines would be metered, measured, intro-
duced, mixed and controlled by an on-
board control unit. The control unit
would monitor the ground speed, the flow
from the diluent tank and from one or
more concentrate tanks and would then act-
uate the appropriate control valves in re-
sponse to the incoming signals or to any
pre-set or prescribed values. The con-
trol unit could permit the introduction
of pesticide concentrate either in
response to ground travel or at a
GROUND
TANK-
DILUENT
ONLY
PUMP
INJECTION
& MIXING
BOOM&
NOZZLES
VALVE
Figure 1. Schematic Diagram of Direct Injection System.
56
_
-------
pre-determined constant flow rate. In
any event, for such a system, when the
flow of pesticide concentrate into the
boom supply line would be stopped, short-
ly thereafter, only diluent would flow
from the spray nozzles and there would be
no left-over mixtures in a tank to dis-
pose of at the end of a spraying opera-
tion.
Conceptually, this is a very simple
idea and has several advantages to offer
over conventional systems. The most obvi-
ous advantage would be to eliminate or
significantly reduce the generation of
un-used mixtures. Other significant bene-
fits would be to reduce human exposure
and the hazards associated with measur-
ing, mixing and the transfer of mixed
spray materials, as well as providing a
quick, easy and thorough method of clean-
ing a sprayer immediately following each
use — something that is not now commonly
and routinely done with existing equip-
ment. This essentially automatic mainten-
ance procedure would, by itself, almost
certainly result in improved sprayer reli-
ability. All of these contribute to di-
rect economic benefits in terms of chemi-
cal saving and reduced application and
waste disposal costs.
On the other hand, such systems
would, of necessity, be more complica-
ted, and consequently, if properly de-
signed and thoroughly field tested, would
be more expensive — and likely by quite
a bit. It is not clear that the market
will stand an order of magnitude increase
in the selling price — even though the
units demonstrate the desired and needed
performance. More skill and training
would be required to operate such equip-
ment properly. Such systems may also
tend to be product specific and some flex-
ibility in use may be sacrificed, com-
pared to the sprayers we now use that are
supposed to handle all compounds that are
put into them.
A few commercial direct injection
systems similar to the one described al-
ready exist, though they may use differ-
ent arrangements to acomplish the desired
tasks. The basic notion of direct injec-
tion is not new, as work on such systems
was done as long as 20 years ago by Nelson
(1), Harrell (2) and Peck (3) and at a
time when there was no great interest in
or generally accepted need for such
devices. More recent work has been done
by Vidrine (4), Kennedy (5), Larson (6),
Reichard (7) and Ladd (8) some of whom
used microprocessor technology in the con-
trol systems. Thus, there has been and
is now a fair amount of research and de-
velopment activity in this regard.
There are some important considera-
tions and realities that must be dealt
with in the design of a direct injection
system. First, the nature of the pesti-
cide must be considered, i.e., the formu-
lation, whether a liquid concentrate, a
flowable, a wettable powder or something
else. At the present time, the known sys-
tems are being designed to handle only
liquid formulations. The physical proper-
ties of viscosity and density must be
known and especially how the viscosity
may change with a change in temperature,
if the metering is to be done accurately
over the range of temperatures normally
encountered in field operations. The con-
centration or strength of the product
must also be known, as a value for this
parameter will be needed to determine the
metering rate of the pesticide concen-
trate into the system.
Early on in a design, the decision
will need to be made whether the equip-
ment will be product specific or will be
designed to handle one or more pesticide
formulations having different physical
properties.
Although the same basic concept may
be applicable to either ground-based
equipment or equipment for aircraft,
there are several aspects of aircraft sys-
tems that require special consideration.
For example, larger flow and pumping
rates are required as well as special
fast acting control valves, because.of
the greater speed of travel. Weight,
space and drag limitations, provision for
shock and vibration mounting of compo-
nents, among others, are factors that
must be considered for aircraft systems.
Direct injection systems designed
for use by private applicators, that is,
farmers, may not satisfy the needs of com-
mercial applicators, who may need to ap-
ply more than one compound at a time and
who require equipment, because of a large
amount of use, that features a high level
of durability and reliability.
57
-------
Proper tank sizing is not only impor-
tant from the space and weight involved,
but also the tank sizes need to be
matched from a relative capacity stand-
point so that both tanks will be empty at
about the same time and one does not have
to make two trips to fill one tank or the
other. Provision must also be made for
emptying and cleaning the concentrate
tanks and system when it is necessary to
use different materials, as well as dis-
posing of the small amount of waste that
may be generated in this process.
Since the metering device is the
heart of a system, it must be selected to
match the flow rates that it will be ex-
pected to handle and to provide the preci-
sion required. Means of adjusting the
flow rate accurately and easily will need
to be considered. If the pesticide con-
centrate metering rate is in response to
ground travel, changes in ground travel
speed will cause concentration transients
that are a function of the system config-
uration and these will have to be care-
fully evaluated and minimized. The injec-
tion and mixing unit should be as close
to the nozzles or discharge points as pos-
sible to minimize the amount of mixture
in the supply lines and boom and minimize
any undesirable concentration transient
variations. However, this may result in
relatively more of the concentrate materi-
al remaining in the concentrate supply
lines. This may be satisfactory for sin-
gle material systems, but must be consid-
ered if it is desired to have a system
that will handle several different materi-
als for long and reliable service.
The control system is where the new-
est technology will come into play, that
is, microprocessor control technology.
Microprocessors are currently used to mon-
itor spray systems and perform specific
application calculations. Thus, there is
very little reason today that direct in-
jection systems can not be monitored and
controlled using such devices. In addi-
tion to monitoring and controlling, a
microprocessor system could also be used
to record pertinent operational informa-
tion such as the type, amount and rate of
pesticides used, weather data during ap-
plication, dates and times of spray opera-
tions, field identification and location
(including graphs showing salient
features of the field and surrounding
area) along with the application
history for the field, among other
things. Periodically, then, the recorded
data would be removed and transferred to
a master computer for permanent storage
and analysis and reference.
Some important decisions have to be
made relative to the attachment, detach-
ment and filling of the concentrate con-
tainers, as well as what to do with the
small amount of liquid that may be
trapped in the connecting supply lines.
There may well need to be closer coopera-
tion between the chemical manufacturers,
the container suppliers and the equipment
manufacturers to solve some of these prob-
lems.
Simple and accurate calibration pro-
cedures will be needed to assure that the
pesticide and diluent are being applied
at the correct rates. Monitoring systems
and displays will be required to assure
proper functioning of the system. With
the development of more concentrated and
more costly pesticides, small mistakes in
the application can not be tolerated.
Potential users of direct injection
technology include production agriculture
(field crops and orchards), wide-area con-
trol, vector control, right-of-way, lawn
and garden, pest control (residential and
business), nurseries, greenhouses, ani-
mal pest control and forestry. Several
of these application industries are al-
ready using equipment featuring concepts
of direct injection and others are using
undiluted materials directly without fur-
ther dilution. Thus it should be obvious
that one machine or one system will not
be suitable for all application needs.
Different chemicals and formulations with
different physical properties and differ-
ent application rates and different re-
quired methods of application, will
require different systems.
The matter of retro-fitting needs to
be mentioned since not all of the work go-
ing on will lead to entirely new pieces
of equipment. There are a lot of spray-
ers currently being used that will not
and can not be thrown away. Thus, there
is a built-in market for retro-fit equip-
ment. However, considerable ingenuity
will be required in order to design work-
able retrofit systems for the host of dif-
ferent types of ground and aircraft spray-
er systems now in use.
58
-------
The development of direct injection
equipment is complicated by one other fac-
tor. The equipment industry serving the
pesticide manufacturing industry is com-
posed of a number of relatively small com-
panies, small compared to the major pesti-
cide manufacturers. Most of these com-
panies manufacture a limited variety of
rather specific equipment for a limited
market — and certainly a depressed mar-
ket at this time. Few, if any, of these
equipment companies have large amounts of
money to invest in research and develop-
ment for new and innovative products and
thus will likely not venture very far
away, very quickly, from traditional de-
signs now in the market place. Along
with some new products from these compa-
nies, it is likely to expect a number of
new small companies to appear with new de-
signs and products that address this new
need. Because there is a demonstrated
need for a new generation of products and
because there is a new technology, that
is, the microprocessor technology, avail-
able to control and monitor these more
complicated systems, an increasing number
of new and innovative designs are almost
certain to be developed and marketed.
Further, the designs of the equipment now
in common use have essentially "matured"
— that is, there is not much more that
can be done with them, as such, to im-
prove their performance, especially given
a new set of constraints placed on the
process of application. Hopefully, the
new designs and equipment that do appear
in the market place will be carefully and
thoughtfully designed and thoroughly
field tested.
Pesticides are becoming increasingly
sophisticated ~ and will likely be more
concentrated and accordingly, more expen-
sive. Thus, the pesticide application
equipment of the future, direct injection
or whatever, will also have to be more
sophisticated to accurately meter and pre-
cisely apply these materials at the pre-
scribed rates in a safe and efficacious
manner.
REFERENCES
1. Nelson, Rex R. and Lawrence 0. Roth,
1973. Powder induction system for
field sprayers. Transactions of the
ASAE. 16:1, pp 44^46^
Harrell, E. A., W. W. Hare and J. R.
Young, 1973. Mixing pesticides with
water concurrently with spraying.
Journal of Economic Entomology.
66:1211-1213.
Peck, D. R. and L. 0. Roth, 1975.
Field sprayer induction system devel-
opment and evaluation. ASAE Paper
No. 75-1541. American Society of
Agricultural Engineers, St. Joseph,
MI 49085.
Vidrine, C. 6., C. E. Soering, C. L.
Day, M. R. Gebhardt and D. B. Smith,
1975. A constant pesticide rate
sprayer model. Transactions of the
ASAE. 18:pp439-433~I
Kennedy, Steven C., R. W. Whitney and
L. 0. Roth, 1982. A microprocessor
controlled liquid concentrate meter-
ing system for agricultural aircraft.
ASAE Paper No. AA-82-006. American
Society of Agricultural Engineers,
St. Joseph, MI 49085. ,
Larson, 6. H., D. K. Kuhlman and 6.
TenEyck, 1982. Direct metering of
pesticide concentrations. ASAE Paper
No. MC-82-134. American Society of
Agricultural Engineers, St. Joseph,
MI 49085.
Reichard, D. L. and T. L. Ladd, 1983.
Pesticide injection and transfer
system for field sprayers.
Transactions of the ASAE.
26:pp683-686.
Ladd, T. L. and D. L. Reichard, 1983.
Injection-type field sprayer for con-
trol of insects. Journal of Econom-
ic Entomology. 76:pp930-932.
59
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WASTE WATER RECYCLING
Darryl Raster, Associate Specialist (Engineering)
Louisiana Cooperative Extension Service
Louisiana State University
Baton Rouge, Louisiana 70803
ABSTRACT
The Louisiana Department of Agriculture began enforcement of pesticide waste disposal
regulations on January 1, 1985. These regulations pertain to all commercial pesticide
applicators. Basically, these regulations require that applicators have facilities to
clean the equipment spray tank, spray system, mixing tanks and pesticide containers with-
out contaminating the soil, ground water or other bodies of water.
After evaluation of various pesticide waste disposal techniques, 60% of Louisiana's
190 commercial aerial applicators elected to use waste water recycling to dispose of
aircraft spray system wash water.
Waste water recycling involves collecting the aircraft wash water and storing the
water in tanks for use as a dilution agent on future application jobs. Three to five
tanks are normally used to store various pesticides thus preventing label violations and
the possibility of crop damage. Thirty percent of the applicators rinsed the aircraft
over the field being treated. Ten percent modified the aircraft or used other waste
disposal techniques.
At the completion of the 1985 season, several aerial applicators were interviewed
to determine the cost of constructing and operating the waste water recycling systems as
well as suggested operating procedures and problems encountered during 1985.
Most aerial applicators used a 50' X 50' or 50' X 60' cement wash area and three to
five 250 to 500 gallon waste water storage tanks. Most waste water recycling systems
cost $8,000 to $12,000 to build with a range of $3,000 to $15,000. Very few problems were
reported and there were no reported incidences of crop damage.
INTRODUCTION
During 1981 and 1982, discussions
were held between Louisiana aerial appli-
cators, members of the Louisiana Coopera-
tive Extension Service (LCES) and the
Louisiana Department of Agriculture. These
discussions covered techniques required to
comply with proposed Louisiana Department
of Agriculture pesticide waste disposal
regulations (1), (2), (3).
It was generally agreed that pesti-
cide containers could be converted from
pesticide waste to solid waste via the well
established triple rinsing process (4).
Most of the pesticides commonly used in
Louisiana require dilution with water prior
to application. The water used to wash
the containers could be easily used for
dilution (4). Mixing and loading equip-
ment could be easily washed and the wash
water used for dilution. The triple
rinsed containers .could be sold for scrap
or sent to an approved solid waste land
fill for disposal. Based on EPA regu-
60
-------
lations, containment of water used to wash
the exterior of the aircraft was not re-
quired (5). However, water used to wash
the interior of the aircraft spray system
must be contained and disposed of in an
environmentally safe manner.
Current research, state of the art
technology, public attitudes toward waste,
cost of transporting and disposal of waste
by hazardous water disposal firms as well
as other factors were carefully evaluated.
It was decided that an affordable, envi-
ronmentally safe system must consider the
following factors'(1), (2), (3), (6):
1. The commercial aerial applicators,
whether they have 1, 2, 3 or more
aircraft, must be able to install
the waste disposal facilities and
provide quality aerial application
at an affordable price. In short,
the system must be affordable.
2. The applicator, pilots and/or load-
ing crew members must be able to
operate the system with minimal
training.
3. The system must be compatable with
normal operations and not require
a lot of additional labor.
4. The system must be designed to elim-
inate the storage of waste at the
applicators place of business during
the off season.
5. The system must dispose of the pes-
ticide waste without requiring
transport of waste to hazardous
waste disposal sites. It was gener-
ally felt that the industry could
not afford this disposal technique.
After further research in 1982, it
was decided that some type of waste water
recycling system, rinsing the aircraft
over the treated field or modifying the
aircraft to clean the aircraft while in
flight would meet these five objectives.
Based on these conclusions, it was felt
that rinsing over the field would be fea-
sible for aerial applicators who flew less
than 300 hours per year. However, it
would be too costly for larger aerial
applicators. Therefore, it was decided to
further evaluate waste water recycling (2).
Engineers from the LCES designed a
waste water recycling system to accomodate
applicators with two or more aircraft.
These systems were evaluated on a limited
scale in 1982 and 1983 (7). Regulations
adopted in 1984 by the Louisiana Department
of Agriculture legalized the use of these
systems (1), (4). Enforcement of these
regulations began on January 1, 1985.
During 1985, about 60% of Louisiana's
commercial aerial applicators built and
used waste water recycling systems, 30%
rinsed the aircraft over the treated field
and 10% modified the aircraft or used other
techniques (3).
AIRCRAFT MODIFICATIONS
Agricultural aircraft are equipped
with 150 to 600 gallon spray tanks. After
the completion of a spray job, 6 to 10
gallons of field strength pesticide will be
left in the spray system. Three to five
gallons of this.pesticide will be in the
bottom of the spray tank and three to five
gallons will remain in the spray pump,
spray booms and connecting lines. In add-
ition, pesticide residue will remain on the
inside walls of the aircraft spray
tank (9).
AIRCRAFT SPRAY TANK
Figure 1. Aircraft spray tank illus-
trating location of various
components and remaining 3 to
5 gallons of pesticide.
61
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As shown in Figure 2, a simple device
can be added to the pump intake to remove
2 to 4 gallons of pesticide. This pump
intake extension is now commercially avail -
1ble at a cost of $200 to $300 (9). This
simple device will reduce pesticide waste
by 30 to 40%. In addition, installing a
simple check valve in the loader line will
eliminate contamination of this area.
AIRCRAFT SPRAY TANK
The number and size of tanks depends
on the size of the operation and the
variety of pesticides used. Under Louisi-
ana conditions most applicators will have
three to five tanks with a capacity of
250 to 500 gallons each. The pesticide
wash water must be segregated and stored
in separate tanks to avoid label violations
and the possibility of crop damage.
Tank cost varied from $50 to $550 per
tank depending on tank size, type of tank,
and whether new or used. A typical wash
water recycling system is shown in Figure
3. Data for construction cost is shown
in Table 1 and data for operating cost is
shown in Table 2. This data is based on
a system for 3 to 5 aircraft with each
aircraft flying 400 to 700 hours per year.
TABLE 1. CONSTRUCTION COST FOR
WASH WATER RECYCLING
SYSTEMS
Figure 2. Aircraft spray tank illus-
trating installation of pump
intake extension and loader
line check valve.
WASH WATER RECYCLING SYSTEM
The wash water recycling system desi-
gned by the LCES consists of a cement wash
area, a sump to contain the wash water,
pump, connecting lines and 3 to 5 holding
tanks with a capacity of 250 to 500 gal-
lons each (7).
The size of the wash area construc-
ted by Louisiana aerial applicators varied
from 50' X 50' to 50' X 60'. Cost varied
from $1.50 to $2.50 per square foot
depending on the site preparation re-
quired, fill material required, thickness
of cement, amount of steel used for rein-
forcement and other factors. As expected,
applicators who did most or all of their
own construction had the lowest cost (9).
Specifications for the wash area, sump and
tanks are contained in the Louisiana
Department of Agriculture pesticide waste
disposal regulations (4), (7).
50' X 60' Cement Wash Area
Five Tanks (500 Gallons Each)
Plumbing and Electrical
Pump (2 HP, 2" Capacity)
Labor
Total
Range $3,000 - $15,000
$ 6,000
2,750
1,000
750
1,250
$ 11,750
TABLE 2. ANNUAL OPERATING COST
FOR WASH WATER RECYCLING
SYSTEMS
Depreciation (10 year life) $ 1,175
Interest on Investment
(12% Interest) 705
Maintenance 500
Labor (75 Hours @ $6.00) 450
Total
$ 2,830
62
-------
50* X 50'
CONCRETE
WASH RACK
2-500 GAL.
MIXING TANKS
W/VALVES
^BA
\CHECK VALVE
—*l
GFRES
-FRESH WATER
SUPPLY
LEGEND
© PUMP
-
-------
It 1s important to note that the
cement wash area can be used to mix and
load pesticides as well as service the
aircraft. These costs are listed as a
cost of pesticide waste disposal. In
reality, a portion of these cost should be
attributed to other phases of the oper-
ation.
Regardless of the waste water dispos-
al system utilized, the waste water must
first be collected. Facilities to collect
the wash water is a major portion of the
recycling system cost.
OPERATING PROCEDURES
The applicator must first decide what
pesticide waste will be stored in each
tank. It is important that wash water from
various pesticides be segregated to avoid
label violations and compatibility prob-
lems. The applicator must 'label each con-
tainment tank so that all pilots and load-
ing crew members will always know what
waste is stored in each tank. This will
reduce the possibility of errors in util_
izing the wash water as a dilution agent
in future application jobs. An example
of how the tanks can be utilized is shown
in Table 3. The type waste stored in the
various tanks will vary from area to area
within Louisiana as well as from year to
year.
TABLE 3. EXAMPLE OF WASTE WATER CONTAINMENT TANK UTILIZATION
TANK NUMBER
AND SIZE
1 (250 Gal.)
2 (400 Gal.)
3 (500 Gal.)
4 (500 Gal.)
5 (300 Gal.)
TYPE OF WASTE WATER
EARLY SEASON
Soybean Pre- emerge
Herbicides
Soybean Post-emerge
Herbicides
Cotton Pre-emerge
Herbicides
Cotton Post
Emerge Herbicides
Rice Herbicides
LATE SEASON
Soybean Insecticides
Soybean Defoliants
Cotton Insecticides
Cotton Defoliants
Rice Insecticides
Note: The number and size of tanks can be varied to meet the needs of the applicator.
In this example, the wash water gener-
ated from clearing the aircraft after
applying soybean pre-emerge herbicides will
be stored in tank number one. Most soy-
bean pre-emerge herbicides will be applied
in April - June. Therefore, this tank can
be cleaned and utilized to store soybean
insecticide wash water during July -
September.
Waste water from soybean insecticides
will be recycled by mixing one part waste
water with four parts fresh water for
dilution of the soybean insecticide.
64
-------
The second step in utilizing the waste
water recycling system requires that the
applicator decide whether or not to wash
the aircraft between spray jobs. As an
example, when changing from soybean fungi-
cides to soybean post-emerge herbicides to
soybean insecticides it will not be necess-
ary to wash the aircraft. All three types
of pesticides are labeled for application
on soybeans. Therefore, phytotoxicity and
label violations will not be a problem.
The applicator should use his experi-
ence, judgement and knowledge of various
pesticides to schedule application jobs and
aircraft washing to minimize the volume of
wash water.
The applicator should never store wash
water unless he knows of a future job where
this wash water can be added to the pesti-
cide mixture and promptly applied. Ideal-
ly, waste water should be used within two
weeks.
The aircraft should be rinsed over
the field being treated if the applicator
is uncertain about how or when he can re-
cycle the wash water. This is especially
true if the pesticide is seldom used in
his operation.
Rinsing the aircraft over the treat-
ed field could be costly and time comsurn-
ing. However, this could be less costly
than transporting the waste to an
approved disposal site or other types of
on-site treatment.
The applicator can use two techniques
to collect the aircraft spray system wash
water. The first technique involves dump-
ing the waste on the cement wash area. The
second technique allows pumping the pesti-
cide waste and wash water directly from
the aircraft.
If the first technique is used, the
wash area should be washed to remove all
soil particles and other debris. The air-
craft is then taxied onto the cement wash
area. After dumping the waste pesticide,
the aircraft spray system is thoroughly
washed. This includes washing the spray
tank and purging the spray booms, spray
pump and all connecting lines.
The waste pesticide, spray system
wash water and water used to again wash
the cement area is drained into a sump
located adjacent to the wash area.
The waste pesticide and wash water
is pumped into the storage tank designated
for storage of this type waste water.
The second technique requires connect-
ing hoses with appropriate adaptors to the
outer end of each spray boom. The spray
system is washed as previously described.
The waste pesticide and wash water is
pumped into the designated storage tank.
The pump will promptly remove all waste
from the spray boom. Thus, very little,
if any waste will drip from the spray
nozzles.
Use of this system reduces contamin-
ation problems that could cause aircraft
nozzle plugging.
The use of flexible hoses to trans-
fer the wash water from the aircraft to
the containment tanks is recommended.
After cleaning the aircraft, the hose is
always flushed with clean water to remove
all pesticide residue. This practice
eliminates cross contamination and possible
label violations as well as crop damage.
In addition, physicially connecting the
hose to the proper storage tank assures
that the wash water will be stored in the
proper tank. This practice also holds
true when removing the water from the
tanks.
Applicators report that it requires
at least 60 to 80 gallons of water to
thoroughly wash the aircraft spray system
(9). The aircraft spray system will norm-
ally contain 4 to 7 gallons of field
strength pesticide waste. Therefore, the
waste water stored in the containment
tanks will have a pesticide concentration
of less than 10% of normal field strength
(9).
One part wash water should be mixed
with four parts fresh water when using the
water for pesticide dilution^ The result-
ing spray mixture will contain a maximum
of 2% additional pesticide. This low level
of additional pesticides reduces the
65
-------
possibility of label violations, illegal 4.
residue or crop damage should an error
be made in mixing.
SUMMARY 5.
Interviews with Louisiana aerial
applicators after the completion of the
1985 spray season indicates that problems
were minimal. Pesticide waste can be dis-
posed of by rinsing the aircraft over the
treated field or recycling the wash water.
There were no reports of illegal crop 6.
residues or crop damage caused by recycling
of pesticide wash water.
Aerial applicators flying less than
300 hours per year felt that rinsing the 7.
aircraft over the field costs less than
constructing waste water recycling systems.
Larger applicators felt that use of a re-
cycling system consisting of three to
five 250 to 500 gallon tanks and a 50' X
50' to 50' X 60' wash area was a good in-
vestment. Construction cost ranged from 8.
$3,000 - $15,000 with most systems cost-
ing $8,000 - $12,000. Annual operating
cost was about $2,500 - $3,000 for an
applicator with 3 to 7 aircraft with each 9.
aircraft flying 400 to 700 hours per year.
Most applicators reported that the 10.
large cement wash area was ideal for mix-
ing and loading pesticides as well as
servicing the aircraft. Also, when evalu-
ating the cost of any pesticide waste
disposal system, the cost of the collection
facilities must be included.
REFERENCES
1. Unpublished minutes of Pesticide
Revue Commission. (1983 and 1984').
Louisiana Department of Agriculture,
Baton Rouge, Louisiana.
2. Unpublished minutes of the Louisiana
Cooperative Extension Service Aerial
Applicators Advisory Committee. (1981-
1985), Louisiana Cooperative Extension
Service, Louisiana State University,
Baton Rouge, LA 70803
3. Mr. H.F. Calhoun and Dr. John Impson
Louisiana Department of Agriculture,
Baton Rouge, Louisiana, Personal
Communication (1981-1985).
LSA 3:3201 - 3280. Section 1.0 - 31.0
Louisiana Department of Agriculture
Baton Rouge, Louisiana.
Mr. John H. Skinner, Director
Office of Solid Waste (WH-562A)
United States Environmental Protection
Agency, Washington, D.C. 20460,
Memorandum on Regulation Interpre-
tation of Pesticide Applicatior
Washing Rinse Water, July 22. 1985.
A Guide to Minimizing Problems of
Pesticide Waste Management. Illinois
Pesticide Waste Management Task Force,
July 1, 1982.
Aircraft Wash Water Recycling System.
Extension Plan Service Drawing #26-01
and #26-02, Louisiana Cooperative
Extension Service, Louisiana State
University, Baton Rouge» Louisiana
70803
Mr. A.6. Taylor, Agricultural Advisor,
Illinois Environmental Protection
Agency, Personal Communication, 1985.
Louisiana Aerial Applicators, Personal
Communication (1980-1986).
Pesticide Waste Disposal. Darryl
Rester, Associate Specialist
(Engineering), Louisiana Cooperative
Extension Service, Louisiana State
University, Baton Rouge, Louisiana,
70803
66
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RECYCLING PESTICIDE RINSEWATER
A. G. Taylor
Illinois Environmental Protection Agency
Springfield, Illinois 62706
Dick Hanson
Growmark, Inc.
Bloomington, Illinois 61701
Diane Anderson
University of Illinois Agronomy Department
Urbana, Illinois 61801
ABSTRACT
Rinsewater recycling is proposed as an alternative to the treatment or disposal of
potentially large quantities of pesticide laden washwaters. A recent Illinois study shows
that economical management systems can be installed by custom applicators using ground
equipment for collecting and subsequently re-using dilute pesticide solutions. The
recycling process is most feasible in the Midwest where applicators treat primarily corn
and soybean acreages and should be applicable to other areas where applicators apply
pesticides to a limited number of crops. Practicality of the process diminishes as the
variety of crops grown increases or when incompatibility of pesticides or adverse effects
may result. Presented in this report are design and management recommendations for
pesticide rinsewater recycling systems derived from the Illinois project.
INTRODUCTI ON
Improper pesticide rinsewater
management practices have become an
increasing environmental concern for
regulatory officials and custom
applicators in Illinois. State and
federal regulations discourage and in
some cases prohibit the disposal of
pesticide rinsewaters by landfilling.
Treatment systems including evaporation
basins, trickling filters, and
sedimentation/carbon adsorption
apparatuses have been designed but
infrequently implemented by the industry
because standards that define limitations
and acceptability for use have not been
established.
During the 1984 spray season-
Growmark, Inc., engineers and Illinois
EPA staff initiated a project to study
the feasibility of recycling pesticide
rinsewaters by using them as a diluent in
corn and soybean herbicide spray
solutions. Management systems at
thirteen commercial agrichemical
facilities were examined.
SYSTEM COMPONENTS
The two basic components of the
rinsewater management systems observed
are a concrete wash pad and receptacle
for rinsewater containment. The wash pad
design varies at each installation to
conform with the physical layout of the
site and to accommodate loading devices
and spray equipment used. Concrete tanks
serve as the means of containment. The
following design criteria include the
preferred features noted at the study
sites.
67
-------
Hash Pad Design
Rinsewater Containment
The wash pad is typically 20- by
40-feet (ft.) concrete slab. It is
instrumental to the operation of the
rinsewater containment systems as it
catches water generated in the washing of
spray equipment, drippings from hoses,
and foamovers that occur while loading.
To insure structural integrity, the
concrete is 8 inches (in.) thick and
reinforced in two layers with #10 wire
mesh in the upper half and #4
reinforcement rods crossed on 16 in.
centers 2 in. up from the bottom. The
pad is constructed with a 2% slope to a
center drain situated in a recessed mud
pit which is used for trapping sediment
and other debris (Fig. 1). Dimensions of
the mud pit are 2 ft. x 4 ft. x 2 ft.
deep. A middle partition provides
separate drainage for corn and soybean
chemicals. The pit cover is a welded
steel grate that is underlain by a
sliding steel plate to facilitate
chemical segregation (Fig. 2).
The most efficient device for
collecting rinsewater draining from the
wash pad is a 1,000 gallon (gal.)
concrete tank. A pre-cast tank or a
poured tank made of high density 6,000
psi concrete can be used for this purpose.
The collection tank is preferably set
off to the side of the wash pad; however,
if space is limited the.tank can be
situated beneath the pad (Fig. 3). In
either case, a manway into the tank must
be provided for periodic inspection and
cleaning. In setting the tanks, sand or
compact backfill must be used to prevent
settling.
A resistant sealant applied to the
joints and surfaces 'of the tanks
prohibits seepage. For the poured tanks
a waterstop is incorporated into all
joints to further insure containment.
Plumbing from the wash pad to the
tanks consists of schedule 80 black iron
pipe 3 in. in diameter or larger.
TANK RECIRCULATION LINES
1-1/2" BLACK IRON
APRON CONCRETE 4" THICK
3500 PSI w/6 x6 No. 10 MESH
11/2" MANIFOLD w/l-l/2
SELF PRIMING PUMP
BLACK IRON
TANK SUCTION LINES
1-1/2"
DRAIN OF MUD PIT
OVERHEAD LIQUID LOADING
PIPE TO VEHICLE
, j—3"x3"LEDGE FOR GRATING
1 2'x4'x2'DEEP MUD PIT
LOADING PAD CONCRETE 8" THICK 35OO PSI W/TOP
LAYER 6x6 No. 10 MESH. BOTTOM LAYER REBAR
N0.4-I6"O.C.BOTH WAYS 2" ABOVE BOTTOM.
SLIGHTLY ROUGH FINISH. DOUBLE REBAR OVER
TANKS.
SLOPE TOWARD MUD PIT
"TO 4'
4O'Q" LOADING PAD
O"
Figure 1. Top View Diagram of a Pesticide Rinsewater Collection System
68
-------
The collection tank set up varies
depending upon the scope of the
operation. A minimum of two tanks is
required in order to segregate corn and
bean chemical rinsate. The plumbing is
systematized to accommodate this
arrangement. Additional tanks can be
added to hold haulback solution. The
haulback tanks do not need to be plumbed
through the wash pad drainage system
since the unused spray solution can be
drained directly from the applicator into
the tanks. Where porous soils and high
groundwater conditions exist, storage of
the rinsewater and haulback in above
ground tanks should be considered if not
already required by state or local
regulations. In any case the underground
tanks should not be used as a permanent
storage facility.
Used steel petroleum tanks have also
been used as the underground containment
vessel. There are two inherent problems
with this alternative. First, a
substantial volume of liquid must remain
,l/2"x2" GRATE w/ 1/2" x 3" OUTSIDE FRAME
/ f
TO
CORN WASH •
• • 1=;
6
SLIDE
PLATE,
ROD/
TO
4, BEAN
WASH
NOTE:
SHADED GRATES TO BE I"
ABOVE GRATE LEVEL TO
PROTECT SLIDE ROD (4)
PLAN VIEW
3
}
56" 3".
24" T 8" 24"
yGRATING
^ 3" PL ATE C
TO DIVERT
WATER
1
SLIDE / J
PLATE'
1,
^
\y
BL
IRI
SLIDE PLATE ROD ,
TO WASH PAD SIDE — 1
FOR REMOTE
CONTROL
f-r^ ..^,-L
*eo
PIPE
ACK
3N
"o
->CJ
1 / 1
^X
24" 3",
.SLIDE
1 y6"
a 1 1 m r 1 1
SUDE 7 . ./
PLATE/ *•
-------
in inadequately anchored tanks during the
off-season because the containers, when
empty, will have a tendency to float out
of position under saturated soil
conditions. Of greater concern is the
corrosive property of the steel which may
effect leakage resulting in groundwater
contamination.
A-third containment alternative is an
industrial-type lagoon. However, these
surface impoundments are particularly
susceptible to overflow in humid climate
regions, a threat to groundwater when not
properly sealed, and in most situations
require groundwater monitoring wells.
Considering these factors, lagoon systems
are not recommended.
Clean Hater Diversion
The wash pad/loadout facility should
be situated so that it is elevated above
the surrounding area to prevent
stormwater from overloading the
collection system. Where this is not
feasible, curbing or earthen diversions
can be employed.
If provisions are made during the
initial construction, the loading pad
could eventually be covered with a roof
or building, thus eliminating rainwater
falling onto the pad.
An alternate set up could incorporate
two drains to allow separate drainage of
contaminated rinsewater from ordinary
rainwater when the system is not in use.
Each drain should have a plug which seals
tightly yet is easily and quickly removed.
Cost of Construction
Cost estimates for the basic unit
which includes the wash pad, four tanks,
plumbing and pumps are itemized in Table
1. Variation from region to region can
be expected for the cost of materials and
labor. As extras are added such as roofs
or enclosures, the expenses of
construction will escalate.
TABLE 1. INSTALLATION COST ESTIMATES
Wash pad
Tanks (4) -
plumbing,
Labor
pumps
etc.
Total
$2,500
$5,500
$2,800
$10,800
PESTICIDE RINSEWATER RECYCLING
Water samples were collected from the
containment facilities at the thirteen
agrichemical outlets throughout the spray
season and were analyzed for the
pesticides introduced into each
respective system. Concentrations in the
rinsewater mixtures were compared to
those in standard spray solutions to
assess potential contamination problems
and to determine dilution factors for
reuse.
.Analyses Comparisons
Table 2 compares active ingredient
concentrations of rinsewater solutions
taken from the concrete tanks at four
different locations during the
TABLE 2. RINSEWATER ANALYSES FROM FOUR CONTAINMENT FACILITIES
Active Ingredient
Sample Source
Site A
Site B
Site C
Site D
Atrazine
Cyanazine
Metalochlor
Alachlor
Metribuzin
Trifluralin
Butylate
Total
270
540
390
170
310
1,680
84
310
65
180
44
40
11
734
1100
9
34
160
6
6
1
1316
120
39
600
220
130
"1109
70
-------
mid-season. The analyses show
variability among the individual
components which is attributed to the
fraction of corn and soybean acreage
being treated and the preference for
certain products in each respective
region. The range in total active
ingredient concentrations is
representative of all the sites sampled.
Effect on Spray Solutions
Herbicide spray solutions for corn
and soybean production in Illinois are
typically blended for application with a
ground spray unit at a rate of 20 gal.
per acre. Since water is the most common
carrier, there is considerable interest
in recycling rinsewater as a part of the
spray mixture, thus avoiding the need to
treat or dispose of large volumes of
dilute pesticide solutions. Table 3
illustrates the effect of using the most
concentrated rinse solution analyzed in
the study as a 5 percent component of
some commonly used herbicide spray
solutions.
The study concluded that the addition
of rinsewater at a 5 percent rate will
very slightly influence the total active
ingredient concentrations of the spray
solutions. In each case the total falls
well within the limits allowed for the
primary active ingredient when used
alone, which tends to support the reuse
concept.
Precautions for Reuse
Blending of the rinsewater into the
spray solutions does raise some
questions, particularly for regions where
more diverse and sensitive specialty
crops are grown. Although USEPA's policy
allows the tank mixing of different
pesticides, unless it is specifically
prohibited on the product label, there is
concern about the reuse of rinsewaters
having varying levels of pesticide
constituents since trace amounts of some
pesticides could be phytotoxic to the
crop when applied to non-labeled target
areas and the potential exists for
residues in excess of established
tolerances.
Insuring against the potential
phytoxicity and residue problems is most
feasible where the recycling of
rinsewater is limited to corn and soybean
acreage. A favorable point is that a
number of the pesticides commonly applied
are registered for use on both crops,
which reduces the probability of the
rinsewater causing adverse effects. To
further provide a margin of safety,
segregating of corn chemical rinsate from
bean chemical rinsate is highly
recommended. Chemical segregation is
readily accomplished via the design of
the rinsewater collection system. The
practicality of doing this, however,
decreases as the variety of crops being
treated by the applicator increases.
TABLE 3. RINSEWATER EFFECTS ON SPRAY SOLUTION CONCENTRATIONS
Herbicide
Atrazine
Cyanazine
Metalochlor
Alachlor
Metribuzin
Linuron
Pendimethalin
Butyl ate
Trifluralin
Average
Rate
Per Acre
4.75pt
2.50qt
2.00pt
2.75qt
.87pt
.62pt
2.50pt
4.25pt
l.SOpt
Standard Spray
Solution
Concentration3
(ppm)
14,100
15,000
12,000
16,300
2,600
1,870
7,500
21,300
4,500
Allowable
Rate Variation
(+/-ppm) (+/
1,500
3,000
1,500
3,000
375
375
1,500
2,300
750
b
-%)
10
20
12
18
14
20
20
11
17
Recycle
Variation with
5% Rinsewater
(%)
.60
.56
.70
.52
3.23
4.49
1.12
.39
1.87
Based on median recommended application rates applied with water at 20 gallons
.per acre
Based on manufacturers' label recommendations for medium textured soils
71
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Herbicides that are foliar applied
have less opportunity for exposure to
attenuating factors prior to plant uptake
than those applied to the soil. However,
without extensive testing it is not
possible to compare the differences in
effects of recycling rinsewater in
preplant or preemergence soil applied
sprays versus postemergence foliar
applied sprays.
The University of Illinois conducted
a pilot study in 1985 using different
amounts of a rinsewater solution that was
made up of a blend of thirteen corn and
soybean herbicides in postemergence
herbicide treatments on soybeans. As the
concentrations of rinsewater in the spray
solution increased from 5% to 25% the
visible damage to the soybean plants
increased. The lower concentrations
produced necrotic spotting while higher
concentrations resulted in leaf crinkling
and cupping. In all cases, however, the
plants appeared to recover before
reaching maturity.
Since the soil environment in
productive cropland areas is conducive to
microbial degredation of most pesticide
chemicals when applied at recommended
labeled rates, and it possesses a limited
capacity to buffer against adverse
chemical effects via chemical reactions
and adsorption, it is recommended that
the reuse of rinsewater solutions be
limited to preplant or preemergence soil
applications to expose the pesticides to
these soil related attenuating
mechanisms, and that the rate of reuse be
restricted to 5% of the spray mixture or
less to preclude the possibility of
over-applying chemicals to the extent of
impeding the soil reactions.
Other Considerations
Since the wash pad is used for
loading operations as well as rinsing
equipment, there is a chance that
spillage will occur. When a quantity of
spilled concentrate is washed down into
the collection tank it is important that
the amount be recorded to enable the
operator to calculate the approximate
dilution needed to maintain the lower
rinsewater concentrations. If this is
not possible a chemical analysis may be
required before the tank contents are
used.
PLANNING CONSIDERATIONS
The implementation of a rinsewater
recycling system necessitates a
management scheme to budget the use of
rinsewater generated. First the volume
of rinsate produced seasonally is
estimated and then the acreage required
for utilization can be determined. The
following scenerio describes a situation
representative of an Illinois
establishment that custom applies
chemicals for corn and soybean production.
Scope of Operation
It is assumed that the spray season
will extend through a twelve week period
in the Spring with overlapping corn and
soybean plantings. During that time two
applicators will run an average of five
days a week being shut down only by rain
and wet field conditions.
Tank Rinsings
With two spray units operating full
time it is possible to minimize the
number of tank rinsings by using one
applicator on soybean acreage and the
other on corn at the time when both crops
are being planted. However, during the
middle six weeks of the season it is
likely that scheduling conflicts will
require that each unit be rinsed once a
day on the average in order to switch
chemical sprays. This equals a total of
60 tank rinsings. Approximately 50
gallons of water are used for each rinse
resulting in 3000 gallons of rinsewater
being generated.
Exterior Equipment Washings
.Both weather conditions (i.e. a wet
season effecting more mud) and
maintenance priorities of the plant
manager will dictate the number of times
the spray rigs are washed, but for this
purpose it is assumed that each
applicator will be cleaned every other
day of use. If a high-pressure nozzle is
used and each unit is washed for fifteen
minutes, the 60 washings at 90 gallons
per event would produce 5,400 gallons of
exterior washwater.
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Wash Pad
The concrete pad used for loading and
cleaning equipment should be rinsed off
after each day's use. This calls for 60
washings utilizing 50 gallons each time
for a seasonal total of 3,000 gallons.
Estimate Variations
This example indicates a typical
Illinois facility could generate
approximately 11,400 gallons of pesticide
rinsate during the spray season. Factors
that may effect the total are the number
of operating spray Mgs and the manager's
maintenance priorities.
Increasing the number of applicators
would require additional exterior
washings if the equipment is to be
cleaned on a regular basis. However, at
the same time having more units to
operate during the overlapping corn and
soybean planting seasons could decrease
the requirements for tank rinsing if each
piece of equipment is used soley on one
crop.
There is considerable difference
among custom applicators as to their
preference for maintaining clean
equipment. Some elect to wash their
units daily while others may only perform
this duty several times a season. At a
minimum for planning purposes, it is
preferrable to assume the equipment will
be rinsed off after two day's use.
Rainwater
Rinsewater collection facilities that
are constructed without roofs or
diversions will also have to contend with
rainwater. Although this stormwater will
not add to the chemical concentration in
the system it will increase the volume of
recycle water that the facility operator
must manage. To estimate the increase in
volume one must ascertain rainfall
records for the respective area and
calculate the amount that would
potentially fall on and be collected by
the rinse pad system.
Acreage Requirements
When spray solutions are mixed for
applications at the rate of 20 gal. per
acre and the amount of rinsewater used as
the diluent equals 5% of the total
volume, one acre of land is required for
every gallon of rinsate that is
recycled. The custom applicators at the
thirteen study sites treat approximately
5,000 to 6,000 acres per spray unit that
is in operation. This indicates that
managing the rinsewater via recycling is
feasible but must be done on a tightly
planned schedule to prevent large volumes
of rinse solutions being leftover at the
end of the preemergence spraying season.
SUMMARY
Estimates show that a typical custom
applicator in Illinois generates over
11,000 gallons of rinsewater containing
various levels of pesticides during a
spray season. Pesticide rinsewater
recycling systems appear to be a
practical and feasible means of managing
these large volumes of dilute pesticide
solutions.
The rinsewater recycling process does
afford the potential for phytotoxic
effects and crop residues to occur.
Preventive measures that are employed to
protect against such consequences
include; 1. segregating rinsates of
chemicals registered for different crops;
2. using rinsewater as a low percentage
of the spray solution (5% by volume or
less); 3. limiting rinsewater reuse to
preplant or preemergence applications,
and; 4. maintaining the dilute status of
the solutions in the rinsewater
containment tanks.
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TANKS AND FITTINGS FOR FLUIB FERTILIZERS,
PESTICIDES AND OTHER LIQUID PRODUCTS
RELATED TO AGRICULTURE
Dave Callahan, sales manager of Murray Equipment, Inc.
Fort Wayne, Indiana
ABSTRACT
There are many acceptable ways to store pesticides in bulk. The safest method is in a
316 stainless steel UL 142 approved tank. This tank meets fire codes. Also, there are 304
stainless steel? mild steel, mild steel coated, fiberglass and pololyfin tasks. All these,
tanks will contain- the same types of pesticides. In order tohhave a good, safe system, it
is important to know which tank material is compatible with the pesticide to be stored.
After the tank material has been decided, the valves and fittings should then be con-
sidered as to what is compatible with the product to be stored. Valves, more often than
not, should be 316 stainless steel locking valves. The material of the nipple between the
tank and the valves is very important. Never used PVC nipples. The results can be dias^
terous.
Venting of pesticide tanks is very important. The vent should be as large as the out-
let of the tank and should have a vacuum pressure release.
The compatibility of plumbing and products when transfering the stored product is an
absolute. Manufacturer's recommendation for product to be used in hoses should be closely
followed. Never try to use the same hose and plumbing for different products. Hose pre-
ssure rating requirements should also be observed.
When pumps and meters ure used, they should be constructeddof material compatible
with the product. Meters should meet state requirements when used for resale purposes.
Most states do not have rules regulating metered sales of pesticides, but to avoid pro-
blems, check local codes with the local weights and measures department.
All tanks should be diked. The dike should be made to hold the product for a reas-
onable time in case of a spill. In many areas an earthern dike will not work because of
soil percolation. The most common dike is the concrete walls and floor. This seems to
work very will with pesticides. Concrete however, has a problem with phosphoric acid.
Be careful if both are stored in the same diked area. Poly dikes are new on the market.
Check local codes before purchasing a poly dike and check product compatibility with the
dike material.
Mini-bulk storage is very often misunderstood. This misunderstanding is from the
lack of uniform regulations. The major manufacturers of pesticides have added to the
confusion by setting up their own rules. These rules are often different form the E.P.A.
and the state regulations. To protect yourself, know the rules.
For safe bulk storage - know your product, choose the best available equipment and
know the rules.
When purchasing tanks and fittings for
fluid fertilizer, pesticides and other liq-
uid products related to the agricultural in-
dustry, it is important to be serviced by a
knowledgeable and reputable firm. A firm
which has years of experience and technical
74
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people familiar with tanks and fittings
will know the requirements of the fertili-
zer industry and the regulatory bodies
thereof. A tank user can ill afford a
loss of inventory or a violation. First
cost is not necessary the least. Spills
detract from profits. Select a tank pro-
perly and inspect it regularly.
Six basic tank types are available
for use in fluid fertilizer and pestidice
storage.
1. Stainless steel, mild steel tanks
2. Fiberglass tankg
3. Polyolyfin tanks
4. Underground lined pits
5. Aluminum tanks
6. 'Used brewery tanks
Again, we state that is important that' the
sales person know excatly what products
are to be stored in the tanks.
1. A* 316: stainless steel tanks are
usually adequate for the storage of phos-
phoric acid and spent phosphoric acid and/
or most other chemicals and pesticides
common to the agricultural industry.
B. 304 stainless steel tanks are ade-
quate for most purposes except phosphoric
acids and some trace element solutions.
C. Mild steel tanks are economical
and provide approximately 20 years of use
for storage of fluid fertilizers. They
are usually not considered adequate for
phosphoric acid, some trace element-sol-
utions or pesticides.
D. Mild steel coated tanks may be
coated with epoxy resins, enamel glass or
many other compounds. These compounds
usually extend the life and use of the mild
steel tank. The advantages of coated tanks
are the increased life and that many more
products such as phosphoric acid, trace
elements or pesticides may be stored in the
tank. The linings are designed for spec-
ific products and if the product is to be
changed, compatability of lining and pro-
duct should be considered. In maintaining
lined tanks, it is very important to re-
pair and properly patch the inside of the
tank when damaged occurs or if the coating
develops a crack. If this is not done,
the tank is again a plain mild steel tank
thay may not have the capability of stor-
ing the products for a long period o£ time.
All mild steel tanks, whether coated or un-
ooated should have 3O4 stainless steel
threaded or flanged fittings welded into
them. Mild steel tanks are welded and it
is important that the proper metal is used
in repair. If in doubt, use a high nickel
contect rod and/or stainless steel to re-
pair a mild steel unit.
A major problem-associated with fluid
fertilzer and pesticide storage tanks is
the process called electrolytic action.
This simply involves the static electricity
in the air accumulating in the fertilizer
solution and causing the metal of the least
resistance to be transferred through the
fertilzer solution to the top of the tank.
For this reason, all welded fittings, re-
pairs and valves should be of better qua-
lity material and least resistant to the
electrolytic action than the tank body.
Cast iron or mild 'steel fittings in these
situations of fluid fertilizer storage
will deteriorate and cause failure of the
storage unit. If electrolysis exists,
the tank should, be grounded.
2. Fiberglass tanks are very specific
for the products stored. There are two
major kinds for the fertilizer industry.
Those for the storage of phosphoric acid
and those for the storage of nitrogen
solutions and/or mixed fertilzers. They
must be designed for the product. Those
for phosphoric acid should have 316 stain-
less steel threaded fittings or flanges
incorporated into the fiberglass and those
for other fluid fertilizers may use 304
stainless steel threaded or flange fittings
and bolts. It is estimated that their
useful life will be approximately 20 years.
They have riot been on the market long
enough to determine that his is an accurate
estimate. Fiberglass tanks may be repair-
ed with fiberglass and resin should be
checked regularly for cracking. If the
tank becomes weathered on the outside, it
should be treated with resine to add to
its life.
3. Polyolyfin tanks are of many and
varied compounds. Their use should pro-
bably be limited to smaller units speci-
"fically engineered for individual products.
Some of them are very susceptible to pun-
ctur and/or cracking. Most cracks, de-
pending upon the location can be repaired.
Their primary use should be for fluid fert-
ilizers containing N P K and nitrogen sol-
utions.' If properly engineered, they do
have the capability of storing many other
products. Some are made with threaded
75
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fittings molded into the compound and
others have blank holes in them that are
fitted with nylon threaded lock nuts and
Viton 0 rings. It is very important when
installing these that the 0 ring not be
damaged and a perfect seal be established
on the fittings. Some type of support
should be used under the nipple and valve
to prevent cracking. The length of life
on these tanks are quite variable in that
the compounds used are variable. The qua-
lity and amount of compound used is varied.
Color affect the ultra violet decomposition
of the compound. White tanks absorb more
ultra violet rays and thus decompose the
compound. Dark colors relfectvand increase
the life ,of the compound.
4. Plastic underground lined pits have
resulted in an economical and simple stor-
age capability during recent years. This
involves using the earth shaped into the
form of a pit or pond, lined with a nylon
reinforced plastic liner and glued fit-.
tings. These structures usually have large
volume capabilities holding 1,000 to 10,000
tons of fluid fertilizer or phosphoric acid.
They are not recommended for pesticide
storage. Again, they must be engineered
for a specific use. They are usually set
up with their own spill and/or leak pre-
venting system and are safe if properly
constructed.
5. Aluminum tanks are good for the use
of nitrogen solutions and some pesticides.
Steel fittings should never be used with
aluminum tanks. A reaction will result be-
tween the two metals and possible product
loss.
6. Used Brewery tanks and equipment
are now being used in the fertilizer in-
dustry. The standard fittings:.on these
tanks are brass, monel and plated brass.
All of these fittings should be changed.
If in doubt, contact a supplier of fit-
tings and valves for advice as to what is
needed for a brewery tank.
VALVES AND FITTINGS -
Fittings for fluid fertilizer and
pesticide tanks are specific. There are
many substitutes for Association recom-
mendations but there are reasons for not
using these products.
For phosphoric acid and some trace
element solutions use only 316 stainless
steel nipples, plugs, bushings and flanges.
316 stainless steel ball valves with Tef-
lon seals should be used.
For pesticides, 304 stainless steel
nipples, plugs, bushings and flanges are
adequate. 304 or 316 stainless steel ball
valves with Teflon or Viton seals should
be used.
For,other fluid fertilizers and nit-
rogen solutions of 32% or below, forged
steel or 304 stainless steel plugs, bush-
ings and flanges should be used. Nipples
should be 304 stainless steel or better
qaulity. Flanged or threaded ball valves
may be used but rubber lined nickel cast
valves with stainless steel butterflies
are more economical and adequate.
All storage vessel valves should have
a locking mechanism. Approximately 25% of
"spills" are caused by vandals opening
sight gauge or main valves during non-bus
iness hours.
Valves should be installed with flan-
ges, clamps or unions so they can be re-
moved from the storage unit for inspection
and repair. Valve linings, seals, balls
or butterflies may be damaged by debris in
materials flowing through the valve. Re-
move and check all valves every two years
or whenever they leak.
Polyropylene and plastic valves are
prone to break in cold weather. Cast
valves without rubber linings will dis-
intergrate or corrode because of electro-
lysis. Some butterfly valves are made
with 0 rings around the outside of the
butterfly for a seal. These are too easy
to damage in use and then leak. Follow
the aoove recommendation for long service
without loss of material. Dealing with a
reputable supplier who knows your pro-
duct specifications is a must.
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DEALING WITH EMERGENCIES
C. Alvln Yorke
Chief, Toxic Substances Branch
Environmental Protection Agency - Region VIII
Denver, CO 80202
ABSTRACT
Discharges and releases of pesticides into the environment are almost
daily occurrence throughout this country. Parties responsible for such spills
and government agencies responding to such events must be prepared to handle a
variety of situations. The key to successful response is adequate planning
prior to response. This means the development in testing of a local or
community contingency plan. This plan should project probable locations where
emergencies may occur, and the chemicals most likely to be involved. The plan
should address the spills from transportation related events and those
occuring from fixed facilities. The local contingency plan should also
address chemicals likely to be needed for neutralization or treatment of spill
materials, where these materials can be obtained, how long will it take to
deliver such materials to the scene of the emergency, and who will be
responsible for obtaining and delivering such materials. The plan should also
identify the local government agency responsible for responding to the
emergency. In addition the plan should address how operations at the local
level will interface with response operations identified in state, regional,
and national contingency plans.
During the response phase of a pesticides emergency, the responding
agency must be aware of its limitations. When these limitations are exceeded,
the response agency must know how to obtain additional response information,
and how to obtain response assistance from other governmental agencies or
private sector groups. The capabilities of such agencies or groups should be
known to the local response agency. Methods for contacting these agencies or
groups on a twenty-four hour per day basis must also be known to the local
response agency.
The discharge or release of a pesticide into the environment frequently
invokes the jurisdiction of State and Federal laws and regulations. Some of
these Federal laws include the Federal Insecticide, Fungicide and Rodenticide
Act; the Comprehensive Environmental Response, Compensation, and Liability
Act; the Resource Conservation and Recovery Act; the Clean Water Act; and the
Clean Air Act. Responding parties must be aware of these regulations or know
how to contact Agency personnel who can provide appropriate information.
These regulations typically deal with notification, clean-up liabilty, and
treatment and/or disposal requirements.
77
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INTRODUCTION
Discharges and releases of
pesticides into the environment are
almost daily occurrences throughout
this country. More than one-third of
the 379 chemicals recently identified
by the Environmental Protection Agency
(EPA) as acutely toxic chemicals are
either pesticides or active or inert
ingredients of pesticides. Pesticides
may enter the human body through three
routes: dermal, oral ingestion, and
respiratory exposure. Therefore, it is
essential that these emergency
situations involving pesticides be
dealt with in a proper manner. Dealing
with these emergencies involves proper
contingency planning, adequate
response, and recognition of legal
considerations.
CONTINGENCY PLANNING
The key to successful response is
adequate prior planning. Contingency
plans are needed at the National,
Regional, State and Local government
levels. The EPA has published the
National Contingency Plan (40 CFR Part
300) and the EPA Regional Offices, in
cooperation with the Regional Response
Teams, have published regional
contingency plans. State agencies have
also developed and published various
contingency plans. However, the most
critical and important contingency plan
is the community plan or the facility
plan. Facility plans could be made a
subpart of the community plan or be
coordinated with and referenced in the
community plan.
In 1981 the Federal Emergency
Management Agency (FEMA) published
guidance for developing such plans.
This guidance entitled "Planning Guide
and Checklist for Hazardous Materials
Contingency Plans" (popularly known as
FEMA-10) can be obtained from the FEMA
Regional Offices. It is currently
undergoing revision by the FEMA and the
EPA. Another useful document is the
"Chemical Emergency Preparedness
Program Interim Guidance" published in
November 1985 by the EPA. This
document is part of EPA's Chemical
Emergency Preparedness Program (CEPP).
CEPP is part of the Agency's strategy
to address accidental releases of
acutely toxic chemicals. The goal of
the CEPP is to assure that communities
are prepared to deal effectively with
possible accidental releases of acutely
toxic chemicals. Developing community
awareness and contingency planning are
essential parts of the process of
becoming prepared. This is not a new
goal - only a renewed emphasis on
improving preparedness nation-wide,
which EPA has been working to achieve
during the last decade.
Both contingency planning guidance
documents provide outlines of suggested
contingency plans. Since these
documents provide detailed information,
I will only highlight some elements of
a plan that I feel are particularly
important. My comments are mostly
directed toward preparation of a
facility plan.
Inventory
One of the first steps in
developing a facility plan is to
prepare an inventory of the pesticides
at the facility. The inventory should
identify the chemicals that are acutely
toxic, flammable, explosive, or
reactive. The updated inventory should
be kept at the facility and the local
fire department or the local response
agency. It will dictate many elements
of the contingency plan. The inventory
should also describe the location of
various types of pesticides and other
chemicals. Physical separation of the
types of chemicals at.the facility will
aide in efficient emergency response.
Chemicals also should be separated from
work areas to reduce the possibility of
fire from work operations such as
welding.
78
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Firefighting Methodology
Based on the Inventory of
chemicals and the environmental setting
of the facility, the fire department
should pre-determine whether a fire
should be extinguished or allowed to
burn itself out. If it is determined
that attempts will be made to a
extinguish fire, then the extinguishing
materials and methods of application
should be specified; e.g. water, foam,
etc. The location of needed materials
must be identified.
Personnel Protection/Evacuati on
Based on the inventory and the
fireflghting methods to be used, the
type of personnel protection equipment
needed must be identified. This
equipment must be obtained, maintained,
and be readily available to response
personnel. Any personnel requi red to
use this equipment must be adequately
trained.
The plan must describe all aspects
of evacuation of persons near the
emergency scene including: who will
order the evacuation, the geographic
area to be evacuated, where evacuees
will go, how they will be transported,
and who will determine when evacuees
can return.
Containment and Treatment of Released
Materials'
The anticipated flow path of
released materials needs to be
identified. If an attempt will be made
to extinguish a fire with water, the
pathway of contaminated runoff water
needs to identified. Any water
supplies, including groundwater, in
this flow path must be identified. The
plan should specify how the released
materials and/or runoff water will be
contained. The location and
availability of containment materials
and equipment must be specified. If
there 1s no fire or the fire does not
consume all spilled materials,
neutralization methods and the
materials and equipment needed must be
identified. Also, the location of any
absorbant materials that may be
necessary for response must be
identified.
Sources of Response Assistance
The plan should identify what
assistance is available from private
organizations, local, state, and
federal agencies. The role of each of
these groups must be clearly identified
in the plan. It is too late to
determine who will do what at the time
of the emergency. Methods for
contacting these responders on a
twenty-four hour per day basis must be
Included in the plan.
In addition to response
assistance, the plan should contain a
list of sources of technical or
emergency information. Two principle
sources are CHEMTREC operated by the
Chemical Manufacturers Association, and
the National Pesticide
Telecommunication Network (NPTN) funded
by the EPA and operated by the Texas
Tech University School of Medicine.
The telephone number for CHEMTREC i s
800-424-9300 and the telephone number
for NPTN is 800-858-7378,,
CHEMTREC can put the caller in
communication with the manufacturer of
specific pesticides. The NPTN can
provide the medical profession with
emergency treatment information,
information on recognition and
management of pesticide poisonings,
toxological and symptomatic reviews,
pesticide product information, and
referrals for laboratory analyses. It
can also provide the general public
with pesticide information ranging
from: product information, protective
equipment, safety, health and
environmental affects, clean-up
procedures, disposal, regulatory laws,
etc.
79
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The local response agency should
maintain an up-to-date technical
reference library of response
procedures for the pesticides and other
chemicals located in the community.
The Selected Bibliography contained in
Appendix E of the CEPP Interim Guidance
Includes a list of some of these
publications.
RESPONSE
If adequate and current facility
and community contingency plans have
been prepared and tested, the actual
response to a pesticide emergency
should proceed smoothly. Response to
pesticide emergencies can be divided
into several phases. For purposes of
illustration I have divided these into
Initial phases and secondary or
followup phases. The initial phases
can include discovery, notification,
preliminary evaluation, securing the
area, evacuation, and fire
suppression. The secondary or
follow-up phases can include
containment, counter-measures, removal
of material, disposal of material,
documentation, and cost recovery.
Notification is a particularly
important aspect of the initial
phases. All agencies having a
potential Involvement in an incident
should be notified. Many pesticides
are Identified as hazardous substances
under the Comprehensive Environmental
Response, Compensation, and Liability
Act of 1980 (CERCLA), more commonly
known as "Superfund". A list of these
hazardous substances is provided in 40
CFR Part 302. Releases of any of these
substances in quantities specified in
this regulation are required to be
reported to the National Response
Center (NRC) at 800-424-8802.
The EPA expects pesticide
emergencies to be handled at the lowest
level of government possible. As a
minimum, first responders must be
capable of handling the initial
phases. Under certain situations, as
defined in the National Contingency
Plan, the EPA can conduct some of the
secondary phases with funds provided by
the CERCLA. This work will be
performed by contractors hired by the
EPA and can include containment,
countermeasures, sampling and analysis,
removal, and disposal. A command post
can be established if needed.
The key to successful handling of
pesticide emergencies is teamwork
between the responsible party and any
governmental agencies that might be
involved. Again, the community
contingency plan should identify the
respective roles.
The crash of an aerial applicator
in Bighorn National Forest near
Sheridan, Wyoming is an example of a
pesticide emergency which involved
several agencies. As a result of this
crash, approximately 5,000 pounds of
malathion was released in a rugged
canyon area containing the headwaters
of a stream used as a municipal water
supply. Response to the incident
involved personnel from the EPA, the
U.S. Forest Service, the Wyoming
Department of Environmental Quality,
the Wyoming Department of Agriculture,
the Sheridan County Sheriff's Office,
and Sheridan City officials. The team
decided to use lime to neutralize the
malathion to prevent the contamination
of the water supply. This effective
response was the result of close
coordination and cooperation among the
responding agencies.
LEGAL CONSIDERATIONS
The discharge or release of a
pesticide into the environment
frequently invokes the jurisdiction of
state and federal laws and
regulations. Many pesticides are
identified as hazardous wastes under
the Resource Conservation and Recovery
Act (RCRA). The transport of any
pesticide hazardous waste requires a
RCRA permit unless waived in extreme
emergency situations. Also, any
disposal of a pesticide classified
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as a hazardous waste must be done In
accordance with the current RCRA
regulations. Since these regulations
will be changing over the next few
years, especially those pertaining to
land disposal, anyone disposing of
hazardous waste pesticides should
determine the current regulations.
Regulations promulgated persuant
to the Federal Insecticide, Fungicide,
and Rodenticide Act (FIFRA) may apply
to the disposal of spilled pesticides
in certain incidents. Prior to
disposal, the appropriate EPA Regional
Office should be contacted for
clarification on applicability of these
regulations. In addition, regulations
promugated under the Clean Water Act,
the Clean Air Act, and CERCLA may be
applicable. Responding parties must be
aware of these regulations or know how
to contact agency personnel who can
provide the appropriate information.
In addition to federal statutes on
regulations, state and local laws,
regulations, and ordinances must be
complied with in the disposal of
spilled or released pesticides. The
disposal of fire debris requires
particular attention.
SUMMARY
In summary, the principles for
dealing with emergencies involving
pesticides are basically no different
than the principles for dealing with
emergencies involving other
environmental pollutants. With
adequate contingency planning,
training, and adequate preparation,
emergencies involving pesticides can be
handled in a routine and orderly
fashion.
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RECONDITIONING CONTAINERS
Lawrence W. Bierlein, Attorney at Law
General Counsel, National Barrel & Drum Association
Washington, DC 20005
The National Barrel & Drum Association (NABADA) represents
reconditioners of containers, primarily 55-gallon steel and plastic
drums. Our members generally do not recondition packaging smaller
than 30 gallons. This is an established industry, and processes 30-40
million drums annually.
Most drums contain some residue of their former contents, and
often those residues are hazardous materials. The drum reconditioning
industry has been regulated for many years by the U.S. Department of
Transportation (DOT), which prescribes specifications for new and
reused packaging for hazardous materials (see 49 CFR Parts 173 and
178). Among these requirements are certain quality standards for the
drum reconditioning process, including pressure test requirements,
registration of parties engaged in the process, and various container
markings and certifications.
Under the DOT rules, an emptied container that has not been
cleaned must be shipped as if it were full of its former contents, i.e.,
with all product labels, markings, etc., in place, and all closures tight.
If the drum is going to someone other than for reconditioning, it must
be accompanied by a certified DOT shipping document (not a manifest)
that describes the contents by DOT shipping name, hazard class, and
hazard identification number.
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EPA has a very workable rule for most hazardous material
residues in empty containers, set forth in 40 CFR 261.7. Containers
that are empty by this EPA definition are not regulated as hazardous
wastes. For most residues a drum must be as thoroughly emptied as
possible, but in no case can more than 1" (2.5 cm) of residue remain on
the bottom. This does not mean that each drum may contain an inch of
residue — it means the drum must be as thoroughly emptied as possible
and, if more material will pour out, then it must be poured out before
the container is considered empty. The 1" provision is an override in
recognition of the greater viscosity of certain residues.
For residues of acutely hazardous materials listed by name in 40
CFR 261.33(e), however, emptied containers must be triple rinsed with
an effective solvent before being deemed to be empty and unregulated.
Emptied drums come to reconditioners from a variety of sources.
They can come directly from the emptier, or they can come from
unknown sources through the services of dealers who collect them and
deliver them to the reconditioner. Those coming directly from the
emptier often are transported by the reconditioner in his own trucks,
and it is common that a reconditioner's trailer will be parked at the
emptier's plant to be loaded by the emptier's employees.
Once received, drums are examined by the reconditioner and
then may be washed, or may be put through a pyrolytic chamber and
then shotblasted. Dents are removed, chimes are straightened, the
container is tested for leaks (7 psi for hazardous materials drums), new
gaskets and closures are put in place, and the drum is repainted.
Containers that cannot be put back into service are cleaned and crushed
in preparation for scrap dealers.
As you know, EPA and approved States manage a permit system
for hazardous waste treatment, storage and disposal facilities (TSDFs).
Most drum reconditioners are not permitted TSDFs — these people are
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professionals engaged in container restoration, not waste treatment.
Accordingly, as a matter of law they only can accept containers
satisfying EPA's empty container definition. Most reconditioners are
hazardous waste generators, but not TSDFs.
Containers that hold hazardous residues and do not meet this
definition must be shipped on a hazardous waste manifest, using the
services of an appropriately identified hazardous waste transporter, to
a permitted TSDF. Shipping a non-empty hazardous waste drum to
someone without a TSDF permit constitutes a serious regulatory
violation by the generator, the transporter, and the receiving facility.
The fact that this violation subjects the generator to punishment gives
no comfort to the reconditioner who also may be prosecuted for having
received a non-empty drum.
In an endeavor to heighten emptiers' awareness of these
liabilities, and of the critical provisions of Section 261.7, NABADA
developed and last November its members began to use an "Empty
Drum Certification" form. This document must be signed by the
emptier or anyone else giving drums to a NABADA reconditioner. It
says, "I hereby certify that these drums are 'empty' as that term is
defined in the national Environmental Protection Agency regulations,
40 CFR 261.7, and that they have been properly prepared for trans-
portation under the regulations of the U.S. Department of Trans-
portation, 49 CFR 173.29." A copy of this form is attached.
A serious difficulty arises for reconditioners with regard to
drums used to ship the particular materials listed in Section 261.33(e)
~ i.e., those that must be triple rinsed. This list is a hodge-podge of
materials, including liquids, solids and gases. We have been unable to
determine with any certainty which of these materials are shipped in
commerce at all, much less in 55-gallon drums. Many of the materials,
for example, are totally prohibited in transportation under DOT regula-
tions because of their instability (see 49 CFR 172.101 and 173.21).
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Under the DOT regulations a shipper must mark the "proper
shipping name" on each drum, and this name must remain on the
emptied container until it is cleaned. The DOT shipping names,
however, do not coincide with the names of the residues listed in 40
CFR 261.33(e). It is not the same as the brand name either. Thus, at
least under the regulatory requirements as we perceive them, there is
no clear notice to the emptier of the container that his residue is
(e)-listed and, therefore, must be triple-rinsed in order to be unregu-
lated under Section 261.7.
NABADA members' responsibilities and liabilities, and those of
the transporter of the emptied container, hinge upon the emptier
recognizing his material as being Section 261.33(e)-listed, and yet there
is nothing in the regulations that provides a signal to him of this fact.
This lack of a visual signal also leaves the reconditioner with no ready
mechanism to double-check incoming containers for (e)-listed residues.
NABADA has discussed this with the Chemical Manufacturers
Association, and I am raising it today for your consideration in this
forum on pesticide container management. What is needed is a visual
signal to the emptier, the transporter, and the receiving facility
(whether it be a drum reconditioner, dump, scrap yard) that this
container must be triple-rinsed or else it is a fully regulated hazardous
waste.
NABADA is not proposing a lengthy advisory statement.
Frankly, none of the truck drivers or other personnel involved has the
time or the professional background to discriminate between multi-
syllabic chemical names. NABADA perceives a need for a simple visual
stimulus that conveys this message quickly, effectively, and preferably
without having to touch the container.
As a responsible association, NABADA members believe it is
inappropriate to complain about a problem without proposing a solution.
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NABADA suggests use of a consistent signal such as that attached to
this paper, which is takes the form of a lower case "e" in a circle with a
slash through it. This has the benefit of not duplicating any other
symbols in use, and being easy to apply and to recognize, even when
upside down.
NABADA is not suggesting this is the only possible solution. This
industry is suggesting, however, that there is a communications gap
here, and that something must be done to close that gap other than by
requiring the 261.33(e) chemical name to be marked on the container.
NABADA seeks industry's involvement in the solution. If it appears
that a government rule is necessary, NABADA is prepared to petition
DOT and EPA for such rule making.
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EMPTY DRUM CERTIFICATION
I hereby certify that these drums are "empty" as that term is
defined in the national Environmental Protection Agency regulations,
40 CFR 261.7*, and that they have been properly prepared for
transportation under the regulations of the U.S. Department of Trans-
portation, 49 CFR 173.29.**
Date:
*With regard to most regulate'd residues, EPA's 40 CFR 261.7
says: "A container ... is empty if:
(i) All wastes have been removed that can be removed using the
practices commonly employed to remove materials from that
type of container, e.g., pouring, pumping, and aspirating, and
(ii) No more than 2.5 centimeters (one inch) of residue remain on
the bottom of the container. ..."
EPA has explained this rule, saying that "one inch of waste material is
an overriding cons.traint and may remain in an empty container only if
it cannot be removed by normal means. The rationale for this provision
is that there are certain tars and other extremely viscous materials
that will remain in the container even after the container is emptied by
normal means."
For residues of products specifically listed by name in 40 CFR
261.33(e), EPA says the container is empty only "if the container . . .
has been triple-rinsed using a solvent capable of removing" the product,
or has been cleaned by another method shown to achieve equivalent
removal.
**DOTs 49 CFR 173.29 says that all openings on the empty
container must be closed, and that all markings and labels must be in
place as if the drum were full of its original contents. A DOT shipping
paper is not required for transportation of a drum for reconditioning via
contract or private motor carrier. DOT placarding is not required for
vehicles carrying empty containers.
1030 Fifteenth Street N.W. • Suite 1030 • Washington, D.C. 20005
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RECYCLING METAL CONTAINERS
Herschel Cutler, Executive Director
Institute of Scrap Iron and Steel, Inc.
Washington, D. C. 20006
In order to understand the problems
related to the recycling of pesticide con-
tainers, it is essential that those not fa-
miliar with metallic recycling in general
at least obtain a passing insight into the
industry.
Metallic recycling is a big business
composed, in the main, of many small busi-
nesses which take the metallic discards of
society and convert them into feed ingre-
dients for steel mills, foundries and re-
finers.
The process of recycling metals pro-
vides vast tonnages of feed materials. For
example, steel scrap purchased by consumers
will approximate 50 million tons in 1985.
Non-ferrous scrap tonnage, while of lower
magnitudes, accounts for very impressive
annual volumes.
Recyclable metals are a vital ingredient'
in metal manufacturing and they also possess
very important public benefits. For example,
making a ton of steel from recyclable scrap
instead of virgin iron ore results in a
saving of 74% of the energy that would
otherwise have been used, as well as large
reductions in water use and water and air
pollution. It clearly is in the public and
private interest to maximize recycling, yet
that is not the case — and not the case by
a very large margin.
The volume of recyclable but not recycl-
ing metallic scrap is staggering. It has
been conservatively estimated that approxi-
mately 800 million tons of scrap iron now
available to be recycled are not moving for
want of a market. And that is the key fac-
tor that must pervade all further discus-
sion — the need for a market for recycling
to be undertaken successfully.
Because of this lack of sufficient de-
mand to consume the newly generated scrap
iron arising in the economy each year,
there is this huge and ever-growing inven-
tory — an involuntary inventory that just
keeps getting larger — it now equals more
than 15 times the annual use rate of 1985.
The result is that only the most readily
available, and the most desirable, scrap is
recycled — the rest is consigned, involun-
tarily, to the inventory.
That would be important even if there
were no problems with residues sincecontain-
er scrap is not generally considered the
highest grade scrap material. When the
weak and over-supplied market is complemented
by the threat of potential hazardous waste
contamination, the viability of metal con-
tainer- recycling is markedly lessened to
the'point_that a prpbleiji quickly surfaces.
Namely, the problem at issue — empty
containers that are not recycling.
A container is empty under the applicable
regulations if: (1) all non-acutely hazard-
ous wastes have been removed that can be
removed using the practices commonly employ-
ed to remove materials from that type of
container ,e.g., pouring, pumping, and
aspirating, and (2) no more than 2.5 cm (1
inch) of residue remain on the bottom of
the container or inner liner.
The key word is and; there must be
both a complete draining of the container
and no more than 1 inch remaining as a
residue.
If these requirements are met, a con-
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tainer is legally empty. I must add, how-
ever, that EPA has ruled that where residue
is deposited on the sides or top of a con-
tainer, the total amount of material in the
container will be considered in measuring
the "bottom coating." Thus, the apparently
"simple" rule gets more complicated.
Finally, the requirements for a con-
tainer to be considered empty where it has
held an acutely hazardous waste, are more
stringent, requiring triple rinsing. Of
course, many pesticides are classified as
acutely hazardous wastes.
If the container is a 5 or 10 gallon
labeled can, the problems are serious but
the person considering handling the contain-
er would, at least, have a pretty good
indication of the nature of the residues
(assuming limited re-use of that container)
and, .whether the container had to be triple
rinsed or not.
On the other hand, if the container is
a barrel or drum, the odds rise sharply
that other materials have been in the
container for at least some of the time
after its original use was finished. The
possible introduction of other — and un-
known —• materials into barrels and drums
during their life cycle — in addition to
the original filling — makes the risk of
threatening residues far higher.
For example, assume the container is
legally "empty." How can the processor
know that the residue remaining is from the
original material (which may or may not be
a hazardous waste) or is the result of
some other use of the container, a use
which may have left a totally different —
and hazardous — residue to address? How
can the processor know that the barrel or
drum should have been triple rinsed if it
was re-used to handle discarded commercial
chemicals? How can he ascertain that the
alleged triple rinsing actually took place?
What is his responsibility in that regard?
These and other such questions quickly
lead most processors to conclude that a
load of barrels or drums or other containers
of unknown or uncertain origin are products
that pose too great a potential threat to
be considered viable, unprepared materials
that they would be willing to process.
The problem goes beyond RCRA legal re-
quirements to manage properly the containers
themselves. Far more serious is the poten-
tial for contamination of plant and proces-
sing residues with the resultant obligations
and liabilities under both RCRA and especial-
ly Superfund.
If the processing, of containers would
contaminate processing residues, it is an
unacceptable situation for the processor.
Scrap processing waste flows, with very few
specific exceptions, are non-hazardous and
the industry intends to keep it just that
way. There is no return from handling con-
tainers if it leads (or could lead) to pos-
sible contamination of processing residues.
The only viable and realistic option is to
not handle that material.
Because of the strict and absolute
liability associated with Superfund, and
the clear risk that the residue of 1 inch
or less (even if not an acutely hazardous
waste) could contaminate a processing faci-
lity (and the contamination potential grows
in proportion to the number of 1 inch resi-
dues found in such containers), scrap pro-
cessors have been forced to re-think the
advisability of handling such containers as
recyclable items.
Indeed, some processors have totally
banned the purchase or acceptance of bar-
rels, drums or containers where they "might
have" contained hazardous wastes or other
hazardous substances. Some processors have
opted to accept such containers only from
known sources where the processor has been
assured and feels confident that the clean-
ing procedures have been followed and "no
residues remain that might be released in
processing." Finally, some have agreed to
accept containers if they are accompanied
with certifications and indemnifications
when the documents are signed by financially
responsible parties.
Processors know that under Superfund
there is no realistic defense if a hazard-
ous substance is present and requires a
clean-up.1 Thus, the processors are either
saying "no" to any material that might pos-
sess such a threat or they are taking steps
to assure themselves that financially re-
sponsible parties certify the "clean" status
of the containers and, thereby, assume
-------
at least some of that liability if their
certification is incorrect. The Institute's
suggested certification includes an indemni-
fication provision whereby the seller agrees
to indemnify the processor if the warranty
is breached.
The Institute is also cautioning its
members to not assume any unnecessary risk
and if that means turning away business that
had been realistic in the past, so be it.
The threat of a superfund clean-up is so
large (and so uninsurable) that processors
cannot take on that risk as a reasonable
business practice.
The Institute is also working to stop
the continued introduction of hazardous ma-
terials into products entering the economy
so that at some time in the future, the flpw
of hazardous waste threatening materials
will cease (or at least be sharply reduced).
For example, the Institute has mounted a ma-
jor program directed at eliminating the
use of cadmium as a coloring medium for many
household appliances. There certainly are
available many other pigmentation sources
without the need to use cadmium and create
thereby a hazardous waste potential.
Likewise, the use of cadmium as an anti-
corrosive agent on selected bolts in the
frame of an automobile, is not supportable
when evaluated against the threat such cad-
mium poses as a potential hazardous waste.
If Swedish cars can be made without cadmium,
why can't we make cars similarly protected
against corrosion with non-hazardous
metals? Obviously we can, and it is an
Institute goal to raise sharply the aware-
ness of designers that when quality, sala-
bility, durability and appearance are con-
sidered in designing a product, so also
must the concept of recyclability be con-
sidered with as much emphasis and concern.
And the same logic holds true in the
matter of solder where there is no need to
continue using solder composed of 60% lead
and 40% tin thereby providing the basis for
long-term hazardous waste generation from
many sources.
When recyclability is designed into pro-
ducts at the start, the problems of hazardous
waste contamination threats will lessen mar-
kedly.
Now that you know why the market for re-
cycling metallic containers is declining,
and why controlling hazardous wastes will ,
only succeed when hazardous materials, which
lead to hazardous wastes, are limited in
the economy, is there a solution?
Yes, the emphasis on design for rea-
sons other than recyclability must be re-
versed. Does this mean the need to con-
sider a new generation of pesticides that
do not possess the potential for hazardous
residues? Does.it mean a change in pesti-
cide concept? Does it mean a change in
pesticide distribution procedures? Does
it mean a "return container" program of some
sort whereby parties would assure that all
such containers offered for recycling have
been cleaned of any potentially hazardous
residue? Does it mean that things must
change?
It most likely means all of the
above and then some. What it also means is
that the scrap processing industry will not
become a potential hazardous waste dumping
ground. The industry will not allow others
to ship questionable materials to it for
recycling. The scrap processor did not put
the hazardous material in the container
and he will not be made to account for the
residue that remains after the container has
served its useful purpose.
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DISPOSAL OF 55-GALLON ALL-PLASTIC DRUMS
DANIEL W. BARBER
CHAIRMAN REUSE COMMITTEE
PLASTIC DRUM INSTITUTE
SOCIETY OF PLASTICS INDUSTRY, INC.
355 LEXINGTON AVE.
NEW YORK, NY 10017
The Plastic Drum Institute is a
division of the Society of the Plastics
Industry and is composed of member
companies which manufacture industrial
plastics shipping containers with a
liquid capacity of 3 US gallons and
above, as well as manufacturers of raw
materials for such containers.
The SPI, in turn, is the principal
trade association for the plastics
industry with more than 1,800 member
companies accounting for over 75 per
cent of the sales of plastics in the US
and over 95 per cent of the resin
produced in the US.
MANUFACTURING PROFILE
There are 18 companies producing
55-gallon all-plastic drums.
Production is conducted at 23 separate
manufacturing locations across the
country and in Canada.
REGULATORY STATUS, ALL-PLASTIC 55
GALLON DRUMS
On June 12, 1984, the U.S. Department
of Transportation granted full
recognition to 55 U.S. gallons,
non-removable head all-plastic drums
for the shipment of hazardous materials
which include corrosive liquids, Class
B Poisons and chemically compatible
flammable liquids.
This recognition occurred following ten
years of actual usage in the above
referenced substances, with
surveillance by D.O.T. Performance has
been excellent as demonstrated in the
integrity and safety of containers with
hazardous materials over a broad range
of distribution and environmental
conditions through the 10-year period.
fcM-185, which authorized a 55-gallon
all-plastic drum, is also referred to
as "Standards for Polyethylene
Packagings; Final_Rule". Three
paragraphs of this document are
significant to our discussions.
173.24 - Standard requirements for all
packages
(4) Each polyethylene packaging used
as an outside packaging for materials
meeting the definition of a poison
according to this subchapter shall be
permanently marked, by embossment or
other durable means, with the word
"POISON" in letters of at least 1/4
inch in height. Additional text or
symbols may be included in the
marking. The marking shall be located
within six inches of the packaging's
closure. The requirements of this
subparagraph do not apply prior to
September 1, 1985.
173.28 - Reuse of packagings
(Containers)
(d) Packagings previously used for
any hazardous material must have the
old markings (other than markings which
are required by this subchapter to be
permanent) and labels, if any,
thoroughly removed or obliterated
before being used for other materials.
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(i) Polyethylene packagings
previously used for poisonous materials
should not be reused for any materials
other than poisonous materials or
hazardous wastes.
FOCUS OF TODAY'S DISCUSSION
Integrity of container performance is
the primary objective of the FDI and
its member companies. Our concern
extends beyond the first time shipment,
to secondary service, to the final
disposal of the spent container.
The activities on these important
subjects are as follows:
REUSE
All-plastic drums conforming to U.S.
DOT Specification 34 are authorized to
be used in secondary service. The
details of the requirement are that the
drum comply with specification and
performance requirements.
Our group initiated a study on the
ability of reconditioning to neutralize
all-plastic containers from the
previous lading packaged, in order to
safely use the drum in subsequent
service.
. Objective - The purpose of
this study was to determine the
ability of drum reconditioning
to neutralize an all-plastic
drum from the previous lading
packaged, in order to safely
reuse the drum in subsequent
service.
. Conclusions - Tests examining
the effect of various ladings
on the container material
indicate:
1. The laundering process was,
in general, successful,
efficient, effective and
had no adverse effects on
the drum;
2. Minimal residue from
previous ladings remain in
the laundered drum
sidewall. For example, the
maximum residue remaining
in the drums for the
products tested was less
than 0.017% of the weight
of the laundered drum.
"REAL WORLD REUSE" TEST
Assembled to determine under field
conditions the feasibility of
utilizing reconditioned all plastic
drums in secondary service.
. Member organizations of the Task
Force are:
- National Barrel and Drum
Association, Inc.
- Petroleum Packaging
Committee of the Packaging
Institute
- Chemical Packaging Committee
of the Packaging Institute
(Observer's status).
- Plastic Drum Institute of
the Society of the Plastics
Industry, Inc.
What are the reasons for reusing
all-plastic drums?
. Utilization of a valuable resource,
. Reduction in packaging costs.
The "Task Force" has designed a program
which will, under actual conditions,
confirm the feasibility of utilization.
The evaluation will consist of the
following steps:
- One member company from each of
NABADA's five regions, eastern,
southern, central, western and
Canadian, will randomly select,
from their inventory of used
all-plastic drums (blue
pigmented), six units which have
been in a one-time shipment (date
of manufacture on the drum will
confirm this) of the following
six ladings which were subjects
of the PDI Reuse Study.
Acrylic Acid
Mineral Spirits
Methanol
Sulfuric
Acetic Acid
10W40 Lubri-
cating Oil
At this point, shippers who have
expressed an interest in utilizing
reconditioned all-plastic drums will
be furnished containers for a three
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and six month storage test of
ladings they are interested in
shipping.
The drums will be permanently
branded on the top head with a test
code number which will identify the
original lading and the
reconditioner.
The drums will then be reconditioned
under guidelines from NABADA's
Plastic Drum Committee which will
cover drum interior, exterior,
closures and final inspection.
Following each test period, the
lading will be assayed by the filler
for confirmation to their
specifications, emptied, neutralized
by rinsing with water and returned
to the reconditioner from whom they
received the test drums.
Upon receipt of the test drum, the
responsible drum conditioner will
again process the drum under
NABADA's guidelines.
Arrangements will then be made for
shipment to a central test location
for evaluation by the "Reuse Task
Group".
Evaluation will include:
-Competent Authority periodic tests.
-Visual inspection.
-Cut in half for internal inspection.
will expand as it is limited only by
the imagination of designers.
Recycled material is also an important
source of fuel. The energy value of
material from a 55-gallon drum is three
times that of an equal amount of coal.
An example is a firm in Ohio which
processes recycled material into
pellets which are used as an auxiliary
fuel in industrial furnaces.
Recycling of plastics from packaging is
receiving attention from both resin
producers and container users, this is
demonstrated in the founding of an
organization known as the PLASTIC
RECYCLING FOUNDATION, a non-profit
corporation to fund research and
develop plastic recycling technologies
to stimulate growth of the plastic
recycling industry. The new Plastic
Recycling Institute has been funded by
the foundation to conduct research with
the following objectives:
Improving recycling system
efficiencies,
. Improving trie quality of recycled
materials,
. Developing the recycling processes
for various materials,
. Sharing the technology with the
recycling industry.
Initial research will occur at Rutgers
University in New Brunswick, New Jersey
with emphasis on consumer-type
packaging, such as the PET bottle.
FINAL DISPOSAL - 22 POUNDS OF
POLYETHYLENE
The final disposal of an all-plastic
container is a subject which must and
is being addressed. I have purposely
referred in the heading to disposal of
a drum as 22 pounds of polyethylene in
order to highlight the fact that the
material is recyclable and, therefore,
has value.
The value is in the manufacture of
secondary products such as traffic
barrier cones, golf bag liners, trash
cans, and signs. Such products are
being produced today in the United
States from recycled material; the list
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RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
PERMITTING OF ON-SITE PESTICIDE WASTE
STORAGE AND TREATMENT
Felix W. Flechas, P.E.
U. S. Environmental Protection Agency
Denver, Colorado 80202
ABSTRACT
Pesticide users faced with disposal problems related to pesticide residues have a
variety of options to choose from which allow them to comply with hazardous waste laws.
The options range from on-site storage, treatment and disposal to off-site treatment or
disposal. On-site options for pesticide users which generate more than 1 kilogram per
month of acutely hazardous commercial chemical products found in the RCRA E List, 40 CFR
261.33(e), or 1000 kilograms per month of any waste as defined in 40 CFR 261.31, 32, or
33, will require a RCRA hazardous waste permit for treatment or storage over 90 days.
In Table 1, are found the pesticide ingredients from the RCRA E and F Lists. This paper
will present items which must be considered if on-site storage and treatment options are
to be implemented for managing pesticide residues.
DISCUSSION
The 1984 amendments to RCRA
require that EPA evaluate and
determine if certain hazardous wastes
should be banned from land disposal.
Included in this evaluation will be
all the E List pesticides and RCRA F
List pesticides and inert pesticide
Ingredients (40 CFR 261.33(e) and
(f)). If banned from land disposal,
only treatment or incineration will be
available for disposal of pesticide
residues. It is the opinion of the
author that on-site incineration will
not be feasible for the single
pesticide user which generates small
quantities of waste. Therefore
Incineration will not be addressed in
this paper.
Pesticide users will usually find
themselves having to store residues
until a sufficient volume has been
accumulated to make treatment
economical. If the amount of waste in
storage exceeds 1 kilogram for E List
wastes or 1000 kilograms for other
RCRA wastes and is stored for more
than 90 days, a RCRA permit will be
necessary for storage and or
treatment. Treatment is defined in
40 CFR 260.10 as "any method,
technique, or process, including
neutralization, designed to change the
physical, chemical, or biological
character or composition of any
hazardous waste so as to neutralize
such waste, or so as to recover energy
or material resources from the waste,
or so as to render such waste
non-hazardous, or less hazardous;
safer to transport, store, or dispose
of; or amenable for recovery, amenable
for storage, or reduced in volume."
The standards which must be met
before receiving a RCRA permit are
found at 40 CFR 264. The specific
information necessary in the permit
application is found in 40 CFR 270,
Subpart B. A synopsis of the design
standards which would be required for
a facility seeking a hazardous waste
storage permit for storage in
containers and/or tanks is below:
Container Storage (Requirements found
in 40 CFR Subpart I):
Container storage areas which
contain liquid wastes in containers
must have a containment system. The
containment system must be designed as
follows:
(1) A base must underlie the
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containers which is free of cracks or
gaps and is sufficiently impervious to
contain leaks, spills, and accumulated
precipitation until the collected
material is detected and removed;
(2) The base must be sloped or
the containment system must be
otherwise designed and operated to
drain and remove liquids resulting
from leaks, spills, or precipitation,
unless the containers are elevated or
are otherwise protected from contact
with accumulated liquids;
(3) The containment system must
have sufficient capacity to contain
10% of the volume of containers or the
volume of the largest container,
whichever is greater.
(4) Run-on into the containment
system must be prevented unless the
collection system has sufficient
excess capacity in addition to that
required in paragraph (3) to contain
any run-on which might enter the
system.
Tank Storage (Requirements found in 40
CFR Subpart J):
Tanks for storage of hazardous
wastes must have sufficient shell
strength and, for closed tanks,
pressure controls (e.g., vents) to
assure that they do not collapse or
rupture. This tank requirement is
currently proposed to change (see
Federal Register, Vol 50, No. 123,
June 26, 1985) and include secondary
containment for above and below ground
tanks or ground water monitoring and
leak testing only for underground
tanks. The proposed change would also
require full secondary containment of
generators which store for 90 days or
less. The proposed tank design
requirements are synopsized and are
presented below:
The secondary containment system must
be designed to:
(1) Prevent any migration of
wastes or accumulated precipitation
out of the tank system to the soil,
ground water, or to surface water at
any time during the use of the tank
system;
(2) Detect and collect any
releases of waste and accumulated
precipitation until the collected
material can be removed;
(3) Remove or permit the removal
of spilled or leaked waste and
accumulated precipitation in as timely
a manner as is necessary to prevent
releases from the secondary
containment system.
To meet the requirements above, all
secondary-containment systems must be
at a minimum:
(1) Constructed of or lined with
materials that are compatible with the
waste(s) to be placed in the tank
system and must have sufficient
strength and thickness to prevent
failure owing to pressure gradients
(including static head and external
hydro!ogical forces), physical contact
with the waste to which it is exposed,
climatic conditions, the stress of
installation, and the stress of daily
operation (including stresses from
nearby vehicular traffic);
(2) Placed on a foundation or
base capable of providing support to
the secondary containment system and
resistance to pressure gradients above
and below the system and capable of
preventing failure owing to
settlement, compression, or uplift;
(3) Provided with a
leak-detection system that is designed
or operated so that it will detect the
presence of any release of hazardous
waste or accumulated liquid in the
secondary containment system within 24
hours of entry of the liquid into the
system;
(4) Sloped or otherwise designed
or operated to drain and remove
liquids resulting from leaks, spills,
or precipitation;
(5) Designed or operated to
contain 110 percent of the design
capacity of the largest tank within
its boundary;
(6) Designed or operated to
prevent run-on or infiltration of
precipitation into the secondary
containment system unless the
collection system has sufficient
excess capacity in addition to that
required in paragraph (5) to contain
run-on or infiltration. Such
additional capacity must be sufficient
to contain precipitation from a 25
year, 24 hour rain storm.
Secondary containment for
aboveground, inground, and underground
tanks must include one or more of the
following devices:
(1) A liner (external to the
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tank);
(2) A vault;
(3) A double-walled tank; or
(4) An equivalent device as
approved by the Regional Administrator.
In addition to the requirements
above, liners, vaults, and
double-walled tank systems must
satisfy the following requirements:
(1) External liner systems must
be:
(i) Free of cracks or gaps; and
(ii) Installed to cover all
surrounding earth likely to come into
contact with the waste if released
from the tank(s) (i.e., capable of
preventing lateral as well as vertical
migration of the waste).
(2) Vault systems (concrete) must
be:
(i) Constructed as a continuous
structure with chemical resistant
water stops in place at all joints (if
any);
(ii) Provided with an interior
coating that is compatible with the
stored waste for the purpose of
preventing migration of waste through
the concrete and also an exterior
moisture barrier to prevent migration
of moisture into the vault; and
(iii) Provided with a
noncorrosive porous fill material
around the tank if the waste being
stored meets the definition of
ignitable waste under 40 CFR 261.21.
(3) Double-walled tanks must be:
(1) Designed as an integral
structure (i.e., an inner tank with an
outer shell) so that any release from
the inner tank is contained by the
outer shell;
(ii) Protected if constructed
of metal, from both corrosion of the
primary tank interior and of the
external surface of the outer shell;
and
{iii) Provided
leak monitor
Ancillary equipment associated
with tanks must be provided with
secondary containment (e.g., trench,
double-walled piping) that meet the
above secondary containment
requirements.
Treatment
When evaluating treatment
options, several regulatory issues
need to be considered. Wastes
with a built-in
identified in the RCRA E an,d F Lists
and those listed in 40 CFR 261.31 and
32 are known as listed wastes.
Mixtures of these wastes remain listed
wastes regardless of the concentration
of the waste. When treating these
wastes, the treatment residues and
treated fluids are also listed wastes
and are subject to regulation unless
they are delisted by a state or
federal environmental agency.
Deli sting actions require extensive
effort by an applicant and should not
be taken lightly. An option available
for disposal of treated fluids is to
contact the local public waste water
treatment facility and secure a permit
for discharging treated fluids into
their system. This method of disposal
does not require a RCRA permit. If
treated fluids can be discharged to
the waste water treatment facility, on
site treatment will result in reducing
the volume of wastes to only the
treatment residues which would still
require disposal as hazardous waste.
Otherwise, on-site treatment will
result in greater volumes of waste
being generated unless treatment
residues or treated fluids are
delisted.
CONCLUSION
On site options for storage and
treatment of pesticide residues where
a RCRA permit is required can result
in an extensive investment of time and
effort by a pesticide user while
securing the permit. For a user which
generates small volumes of waste, the
economics of acquiring such a system
may not be worth the effort. This
type of generator may be best served
by "milk run" or transfer station
services offered by waste management
companies. As demand increases for
these services, they will become more
available and should serve as a
solution to the pesticide users
problem of pesticide residue disposal.
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TABLE 1
PESTICIDE ACTIVE INGREDIENTS THAT APPEAR ON THE RCRA
"ACUTELY HAZARDOUS COMMERCIAL PRODUCTS" LIST (THE RCRA E LIST)
Acrolein
AT d1carb
Aldrin
Ally! alcohol
Al umi num • phosphi de lf
4-Aminopyridine
Arsenic acid
Arsenic pentoxide
Arsenic trioxide
Calcium cyanide
Carbon disulfide
p-Chloroaniline
Cyanides (soluble cyanide salts)
Cyanogen
2-Cyclohexyl-4,6-dinitrophenol
Dieldrin
0,0-Diethyl S-[2-ethylthio)ethyl]
phosphorodithioate (disulfoton, Di-
SystonR)
0,0-Diethyl 0-pyrazinyl phosphorothioate
(ZinophosR)
Dimethoate
0,0-Dimethyl 0-p-nitrophenyl
phosphorothioate
(Methyl parathion)
4,6-Dinitro-o-cresol and salts
4,6-Di ni tro-o-cyclohexylphenol
2,4 Dinitrophenol
Di noseb
Endosulfan
Endothall
Endrin
Famphur
Fluoroacetamide
Heptachlor
Hydrocyanic acid
Hydrogen cyanide
Methomyl
alpha-Naphthylthiourea (ANTU)
Nicotine and salts
Octamethylpyrophosphorami de
(OMPA, schradan)
Parathion
Phenylmercuric acetate (PMA)
Phorate
Potassium cyanide
Propargyl alcohol
Sodium azide
Sodium cyanide
Sodium f1ubroacetate
Strychnine and salts
0,0,0,0-tetraethyl dithiopyrophosphate
(sulfotepp)
Tetraethyl pyrophosphate
Thallium sulfate
Thiofanox
Toxaphene
Warfarin
Zinc phosphide
There are currently no inert pesticide ingredients on the RCRA E List.
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TABLE 1
October 1984
PESTICIDES AND INERT PESTICIDE INGREDIENTS CONTAINED ON THE
RCRA TOXIC COMMERCIAL PRODUCTS LIST (RCRA F LIST)
Active Indredients
Acetone
Acrylonitrile
Amitrole
Benzene
Bis(2-ethy1hexyl)phthalate
Cacodylic acid
Carbon tetrachloride
Chloral (hydrate)
Chlordane, technical
Chlorobenzene
4-Chloro-m-cresol
Chloroform
o-Chlorophenol
4-Chloro-o-tolui di ne hydrochlori de
Creosote
Cresylic acid (cresols)
Cyclohexane
Cyclohexanone
Decachlorooctahydro-1,3,4-metheno-
2H-cyclobuta[c,d]-pentalen-2-one
(Kepone, chlordecone)
1,2-Dibromo-3-chloropropane (DBCP)
Dimbutyl phthalate
S-2,3-(Dichloroallyl
diisopropylthiocarbamate) (dial!ate,
Avadex)
o-Di chlorobenzene
p-Dichlorobenzene
Dichlorodifluoromethane (Freon 12R)
3,5-Dichloro-N-{l,1-dimethyl-2-propynyl)
benzamide (pronamide, KerbR)
Dichloro diphenyl dichloroethane (ODD)
Dichloro diphenyl trichloroethane (DDT)
Dichloroethyl ether
2,4-Dichlorophenoxyacetic, salts and
esters
(2,4-D)
1,2-Dichloropropane
1,3-Dichloropropene (Telone)
Diethyl phthalate
Epichlorohydrin
(1-chloro-2,3-epoxypropane)
Ethyl acetate
Ethyl 4,4'-dichlorobenzilate
(chlorobenzilate)
Ethylene dibromide (EDB)
Ethylene dichloride
Ethylene oxide
Formaldehyde
Furfural
Hexachlorobenzene
Hexachlorocyclopentadiene
Hydrofluoric acid
Isobutyl alcohol
Lead acetate
Lindane
Maleic hydrazide
Mercury
Methyl alcohol (methanol)
Methyl bromide
Methyl chloride
2,2'-Methylenebis
(3,4,6-trichl orophenol)
(hexachlorophene)
Methylene chloride
Methyl ethyl ketone
4-Methyl-2-pentanone (methyl isobutyl
ketone)
Naphthalene
Nitrobenzene
p-Nitrophenol
Pentachloronitrobenzene (PCNB)
Pentachlorophenol
Phenol
Phosphorodithioic acid, 0,0-diethyl,
methyl
ester
Propylene dichloride
Pyridine
Resorcinol
Safrole
Selenium disulfide
1,2,4,5-Tetrachlorobenzene
1,1,2,2-Tetrachloroethane
2,3,4,6-Tetrachlorophenol
Thiram
Toluene
1,1,1-Trichloroethane
Tri chloroethylene
Trichloromonofluoromethane (Freon 11R)
2,4,5-Trichl orophenol
2,4,6-Trichlorophenol
2,4,5-Trichlorophenoxyacetic acid
(2,4,5-T)
2,4,5-Trichlorophenoxypropionic acid
(Silvex)
Xylene
-------
RCRA F List (continued)
Inert Ingredients
Acetone
Acetonitrile
Acetophenone
Acrylic acid
Aniline
Benzene
Chlorobenzene
Chloroform
Cyclohexane
Cyclohexanone
Dichlorodifluoromethane (Freon
Diethyl phthalate
Dimethyl amine
Dimethyl phthalate
1,4-Dioxane
Ethylene oxide
Formaldehyde
Formic acid
Isobutyl alcohol
Maleic anahydride
Methyl alcohol (methanol)
Methyl ethyl ketone
Methyl methacrylate
Naphtha!ene
Saccharin and salts
Thiourea
Toluene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Trichloromonofluoromethane (Freon 11R)
Vinyl chloride
Xylene
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OFF-SITE DISPOSAL OF PESTICIDES AND PESTICIDE CONTAINERS
H. Clayton Ervine, Sr. P.E.
Seminar Officer
Governmental Refuse Collection and Disposal Association
Silver Spring, Maryland
ABSTRACT
The Governmental Refuse Collection and Disposal Association (GRCDA) has a membership
of whom about 70% are engaged in solid waste management at the local government level.
These governments, along with private industry, provide the non-hazardous waste landfills
which pesticide end-users such as exterminators, commercial applicators, and farmers have
often utilized for disposal of empty containers and/or pesticides in the past. New regula-
tions governing hazardous waste disposal, changing regulations governing landfill design
and operation, citizen attitudes and related factors are tending to eliminate local solid
waste management facilities as recipients of pesticide wastes. This discussion will review
what are the current pressures on local disposal systems and what actions might be taken to
assist both the disposal system owner and the pesticide waste generators.
INTRODUCTION
While the Governmental Refuse Collec-
tion and Disposal Association (GRCDA) re-
presents both the public and private sec-
tors of solid waste management, this paper
will focus on the public issues which af-
fect both publicly and privately owned
solid waste collection and disposal systems
which are destined to handle non-hazardous
wastes.
Some appreciation of the complex in-
terfaces between the Federal regulations
concerning pesticides may be gleaned from
reviewing the paper presented by Raymond F.
Krueger last year (1). The paper reviews
the difficult to interpret relationships
between the Resource Recovery and Conserva-
tion Act (RCRA) and the Federal Insecti-
cide, Fungicide, and Rodenticide Act
(PIFRA).
This paper will focus on the RCRA is-
sues which significantly affect the abil-
ity of local disposal sites to cope with
waste pesticides and waste pesticide con-
tainers .
RCRA regulates hazardous wastes under
Subtitle C and non-hazardous wastes under
Subtitle D. The Subtitle D regulations
apply to all local disposal sites whether
public or private. In addition, local
sites are also subject to regulation by the
respective states as well as local govern-
mental jurisdictions. The combination of
these factors dictates much of the regula-
tion and policy under which local disposal
sites operate. These factors determine
what wastes can be managed at these sites
regardless of the specific regulations
which may apply to any category of wastes,
i.e. hazardous or non-hazardous.
The issues of disposal 'of waste pest-
icides versus waste pesticide containers
must be distinguished at the onset. Under
RCRA and other accepted guidelines, empty
pesticide containers which have been tri-
ple rinsed are considered to be empty and
therefore, non-hazardous. Waste pesticides
are viewed by the public as hazardous re-
gardless of their designation under either
RCRA or FIFRA. From a realistic point of
view, empty containers will be perceived
as significantly different from waste pes-
ticides in terms of both degree of hazard
and acceptable methods of disposal.
100
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In order to be able to consider some
of the possible options available, one must
first consider the restrictions which are
in place at the present time, those changes
which can be anticipated, and any public
perceptions which might affect pesticide
disposal processes.
RCRA-SOBTITLE C
RCRA regulates both hazardous and non-
hazardous wastes. While household and
certain other wastes are exempted, all
other hazardous wastes must be disposed of
at a hazardous waste management facility
permitted under RCRA. There are a limited
number of these sites in the country and
shipping and disposal costs can be very
expensive.
However, under RCRA any material "that
is normally applied to the land" may be
disposed of by land application. It may be
assumed that any pesticide that may normal-
ly be applied to the land could be disposed
of in this, way if the label instructions
for application were followed. That is to
say that normal spray concentrations could
be so used but not the concentrate. It
would appear that this process could be
followed whether or not a pesticide appli-
cation was needed. This process is worth
emphasizing as an allowable RCRA activity
which could be conducted off-site as well
as on-site.
Domestic sewage and wastes treated at
municipal or industrial wastewater treat-
ment plants regulated under the aegis of
the Clean Water Act are also exempted under
RCRA. Small quantity generator surveys
conducted by GRCDA have found that some
pesticides are disposed of via this route
by some small businesses, principally ex-
terminators. In general, such disposal is
not permitted except with the specific
permission of the local sewer authority.
The pesticides, in the quantities involved,
must not (1)damage the transport system
(sewers, pumps, etc.); (2)damage the treat-
ment processes; or (3}cause the plant to
be in violation of its discharge require-
ments. As may be realized, most sanitary
authorities are reluctant to give permis-
sion for discharge of pesticide of any kind
into their system even if such a process is
both legal and environmentally sound.
Unfortunately, GRCDA also found that
some generators who were exempted under
RCRA disposed of waste pesticides into
their septic systems. This process is
legal under RCRA, may or may not be legal
under state and local regulations, and
should be viewed as environmentally unsound
in almost all cases.
It also appears that, under RCRA,
waste pesticides can legally be returned to
the manufacturer for reprocessing, recy-
cling, etc. if all the applicable U. S.
Dept. of Transportation shipping regula-
tions are met.
In summary, if a pesticide is classi-
fied either now or in the future as a
hazardous waste under RCRA', limited off-
site disposal options are available and
then, only under certain conditions.
The options are:
o Disposal at a RCRA HW disposal site
o Land disposal as specified
o Wastewater treatment plant if allowed
o Return to manufacturer
RCRA-SUBTITLE D
Under Subtitle D of RCRA, the Environ-
mental Protection Agency (EPA) has de-
veloped national criteria for the proper
operation of non-hazardous waste land dis-
posal facilities (landfills). At the cur-
rent time, EPA does not have authority for
direct enforcement of these criteria; how-
ever, the criteria may be enforced in Fed-
eral District Courts when suits are brought
by appropriate parties. When RCRA was
reauthorized by Congress in the fall of
1985, EPA was directed to study the prob-
lems which may arise from the fact that
local landfills have accepted hazardous
wastes from households, other sources ex-
empted under RCRA, and possibly illegal
sources in the past. The EPA is to report
on problems, needed regulations, cost of
enforcement, etc. Also, the EPA will have
enforcement authority for any future cri-
teria and/or regulations as they currently
have under Subtitle C. This new program
regulating non-hazardous disposal sites
would be in place by about 1988.
While many issues have to be resolved,
it is possible that local landfills might
have to retrofit existing sites to comply
with the new design standards under certain
conditions. Other sites would probably
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have to close. For these reasons alone,
local landfill owners and operators will
become increasingly wary of accepting any
wastes which might cause issues to be
raised in the future.
PUBLIC ATTITUDES
Public perceptions and attitudes are
such that it has become very difficult to
obtain approval for new disposal sites,
resource recovery facilities, and other
types of solid waste management facilities.
Some national surveys have shown that the
majority of Americans feel that toxic waste
disposal is our number one environmental
problem. For these reasons it is almost
impossible to assume that the general pub-
lic will knowingly permit the disposal of
any pesticides at local landfills whether
they are publicly or privately owned.
Elected and appointed officials are
becoming more sensitive to these issues and
are beginning to look much more closely at
what they are handling in their solid waste
systems. Private landfill owners are con-
cerned about future regulatory issues,
maintaining current permits, and not gen-
erating public opposition to their opera-
tions. Therefore, the management of hazard-
ous wastes at local disposal sites is
becoming less likely each month that passes
even though such management might be per-
mitted under federal, state, and local law.
Many communities are even beginning to
address hazardous wastes generated at the
household level.
site owners and are refusing to pick up
pesticide containers.
If it is both legal and environmental-
ly sound to dispose of empty pesticide
containers at local disposal sites, why are
they being refused? There appear to be
several reasons. The principal reason is,
in the past, many of the containers were
not empty! Not too long ago I visited a
landfill in an agricultural community and
saw large quantities of farm wastes in-
cluding pesticides and other chemicals.
The operators of the landfill reported that
sometimes the chemicals would kill the
seagulls that came to the site. This may
be an extreme example; however, it does
show that pesticides have been in the past
and are currently being disposed of at
local landfills.
If the containers were truly empty,
would the local landfills accept them? In
many or possibly most cases, probably not.
Why is this the case? The principal reason
is that most disposal operations are poorly
equipped to confirm that supposedly empty
containers are indeed truly empty. Confirm-
ation is virtually impossible if the con-
tainers are brought to the site mixed with
other wastes. If this impasse is to be
overcome, the pesticide using industries
must establish working relationships with
the waste disposal facilities. This would
seem to be realistic and the result would
benefit both parties. Local governments
would like to provide disposal services for
local businesses and taxpayers and private
sites would welcome the income.
PESTICIDE CONTAINERS
Under RCRA, containers that are de-
fined as being empty are not considerd to
be hazardous wastes. The classic example
of empty is that imposed upon farmers,
namely, the containers must be triple
rinsed. This definition is actually more
strict than other definitions of empty
under RCRA; however, it seems that this is
the definition which has stuck in the minds
of the public.
Empty containers constitute a real
disposal problem for many pesticide users.
More and more local disposal sites will not
accept these containers under any condi-
tions. In addition many local collectors
are beginning to be presured by disposal
GRCDA feels that realistic programs
could be developed whereby local landfills
would accept empty pesticide containers if
certain conditions were met. Obviously,
these arrangements would have to be made
beforehand. Minimum conditions might in-
clude the following:
o Empty pesticide containers must
be brought to the site as sep-
arate , discrete loads.
o All containers would be open and
displayed so that easy and rapid
visual inspection of the con-
tainers could be made by disposal
site personnel. This might re-
quire cutting of some containers.
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o The disposers should be prepared
to pay the cost of examination by
the facility's employees or any
other reasonable fee imposed by
the facility.
Under these conditions it is reason-
able to assume that local solid waste man-
agement systems, elected officials and the
public-at-large would have no legitimate
objection to the disposal of empty pesti-
cide containers. We believe that most of
our members would agree with this position.
In many cases it would require preliminary
discussions between the potential disposers
and the system owners or operators. These
discussions could be held by individual
waste generators, but it would be better if
a trade association or other organization
representing the disposers initiated the
discussion.
REFERENCES
Krueger, Raymond F. , 1985. Federal
Regulation of Pesticide Disposal. Pro-
ceedings of the National Workshop
on Pesticide Waste Disposal. U. S.
Environmental Protection Agency,
EPA/600/9-85/030. p22.
SUMMARY
In the near future it will become
difficult if not impossible for generators
of waste pesticides and waste pesticide
containers to manage these wastes via the
local solid waste management systems. This
is due to a combination of factors in-
cluding past abuses of the systems, new
regulations at all levels of government,
and public attitudes concerning hazardous
waste management.
The disposal of waste pesticides will
probably require the use of RCRA permitted
facilities or a few other possible methods
as discussed previously.
It does seem reasonable to dispose of
empty pesticide containers using local
systems if certain conditions can be met.
These conditions must be such as to permit
the ready verification that the containers
are truly empty and the disposer must be
prepared to pay the local system for any
additional costs incurred. Individual
generators and/or representative trade as-
sociations should initiate discussions with
disposal site owners in order to implement
such arrangements.
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STORAGE. HANDLING AND SHIPMENT OF PESTICIDE WASTE -
REGULATORY REQUIREMENTS
Rolf P. Hill
U.S. Environmental Protection Agency
Washington, D.C.
This presentation will address the storage and transportation aspects of proper
waste pesticide management under Federal law. Topics include the identification and
classification of waste pesticides, notification requirements, the pretransport require-
ments of storage, packaging, labeling, marking and placarding, the Uniform Hazardous
Waste Manifest, recordkeeping, reporting and the farmer exemption. Under each topic, the
waste pesticide generator's or transporter's requirements and the problems they may face
in trying to comply with the regulations are discussed. Problem areas include waste
determination, proper use of Department of Transportation nomenclature, compliance by
small quantity generators, proper storage of waste pesticides, and compliance by commer-
cial applicators.
Special focus is made on compliance with the new Uniform Manifest requirements
and the impact of State laws on completion of this manifest.
Another area of focus is the RCRA reauthorization requirements for small quantity
generators — which includes waste pesticide generators.
National enforcement priorities and penalties are contained in the presentation.
Although generators and transporters of hazardous waste account for the smallest percent-
age of EPA enforcement inspections, they represent a large national total. Additional
enforcement inspections by other Federal agencies and state offices will augment the EPA
program.
This presentation is aimed at pesticide users who generate or transport a hazardous
waste and who must comply with Federal hazardous waste management standards. The purpose
is to give these people a basic understanding of the regulatory requirements and enforce-
ment ramifications.
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TECHNOLOGY, REGULATORY, AND USERS' SUMMARY PANELS:
OPENING COMMENTS
Roy Detweiler, Workshop Chairman
Consultant, E.I. du Pont de Nemours & Co,
Thanks to Marilyn McKinnis of NAAA, Sherry Cramer of NACA and
to the hotel staff and convention bureau here and especially
to our twelve co-sponsoring organizations.
I am pleased with the workshop and I think I know how you feel
because I have read all of the comments that were received and
will give you some feedback on that in a moment.
Special mention needs to be given to Francis Mayo of EPA and
Phil Kearney for handling the sessions yesterday and for the
work they have done behind the scenes in putting this confer-
ence and the research conference together and to all who made
presentations/ to the exhibitors and to those who are joining
us today to give their summaries as panelists who we will be
hearing from. I want to thank them very much and if you do not
mind join me in a round of applause.
My own assessment of the workshop was that it was well done and
was another step toward providing useful, environmentally safe/
and regulatory compliance/ cost effective methods and proce-
dures to the user community. But/ and it is a big but/ we have
not yet achieved our goals. We have passed some milestones
however/ such as opening up communication channels between the
users and the regulators/ between the agencies? Department of
Agriculture and EPA/ and within the agencies; EPA's Office of
Pesticide Programs/ Solid Waste and Office of Research and
Development. They are talking and making progress. And within
the Department of Agriculture/ the various sections and groups/
sub-sets have been working on this issue and notably among the
associations/ with particular emphasis on NACA and NAAA. We
have learned some ways on how to minimize waste generation by
cost effective methods/ apparatus and procedures/ as described
in the workshops yesterday, particularly in Illinois and Loui-
siana. We have heard discussions of new technology and demon-
stration projects sponsored by NACA that are coming close to
being ready for use but not yet blessed by the regulators. We
still have the problems of RCRA and state permitting with the
intended time delays and costs. Although we have learned that •
the regulators have heard us and understand our needs. They
are beginning to cut through the regulatory red tape and are
trying to accommodate our pesticide users within the FIFRA and
RCRA regulations. But sadly we do not have the answers to give
you to take home with you today. I am convinced we will get
them in the next year or maybe two/ but we really cannot wait
much longer than that.
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I have been thinking about the workshop and have some sugges-
tions. Some of them new/ some of them old and I would just
like to put them out here for consideration. I think class
permitting is a need, so that a proven treatment method could
be installed anywhere once it is approved by say a central
Washington EPA group and make a simple application that would
allow you to get a RCRA permit or a special exemption without
going through the very time-consuming, expensive RCRA part B
application. Another idea I had that maybe could be worked out
is low cost government sponsored loans for the installation of
such disposal technology for farmers, dealers, applicators and
small users. Perhaps permitting accelerated depreciation
allowances for these systems would also be useful.
Exemptions for installation of new systems to demonstrate new
technologies that is cost effective and user friendly would be
a good idea. Even if was just for a short time/ to show and,
prove these methods, it would help improve the environment.
One thing that is very important is to enter into negotiations
between EPA/ agriculture and user associations to get on with
the regulatory process and move ahead.
Yesterday-we asked for your opinions on a third conference, or
a third national workshop. The results indicate that 94% of
you supported, 4% are not in favor and 2% were unsure or said
maybe. 86% say it should be held next year, 8% say in two
years or when processes are proven and the programs are in
place so that we have really something important to say. 88%
say they would attend another conference.
Now over two—thirds of you made some comments and offered
ideas for the next conference or for the future. A great
number of different kinds of ideas and a great number of
conflicting ones too. All were in favor of achieving
prompt solutions to the pesticide and container disposal
problems that would be cost effective, environmentally safe
and user friendly. Many of you are impatient with the
regulators and had some pointed suggestions to make including:
do not invite them, too many lawyers, etc. But I have listed
maybe ten key points that I have picked up from all of these
comments.
1. Provide small quantity generator exemptions.
2. Resolve the conflict between states and EPA so that they
provide consistent guidance.
3. Make rules simple to understand and follow.
4. We need educational programs for farmers, applicators and
dealers on regulations and acceptable disposal.
5. We need a milk run for transportation of hazardous waste.
Also information on who and where these wastes can be disposed
of and the cost. And where the containers can go. Names,
costs/ information/ etc.
6. The next conference should have a brainstorming session
with representatives of various groups to develop regulator
initiatives and goals.
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7. Get the state groups to discuss their programs.
8. Survey attendees on current disposal activites, minimiza-
tion techniques/ what kinds of systems are acceptable and what
their costs are. Make this information available through
extension services and state and regulatory agencies.
9. Industry should assume a greater role in education: to
educate applicators and users on ways to minimize waste and
disposal of waste, and to pesticide applicators and
registration certification.
10. Include programs for lawn services/ household pesticides,
tree services, and other users of pesticides rather than just
the agricultural.
In summary, by and large, most of you liked the workshop, and
the ideas you submitted will be considered by our coordinating
committee; we have a meeting at 1:30 today to see what we-want
to do for the future.
We are going to keep you informed of future workshops and you
will be receiving the proceedings of this workshop, hopefully
in the next five or six months.
Now, on with the business. As you know we have had three
groups of experts attending these sessions/ paying close atten-
tion to what was said and to your questions and we are going to
hear from them next. They represent technology, regulatory,
and user groups and the first group we have at our table is the
technical group.
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TECHNOLOGY SUMMARY PANEL
James N. Seiber, Panel Chairman
University of California
Dr. Philip C. Kearney
Chief, Pesticide Degradation Laboratory
USDA, Beltsville, Maryland
Francis T. Mayo
Director, Water Engineering Research Laboratory
EPA, Cincinnati, Ohio
George P. Nassos
Director of Sales & Training, Ocean Combustion Services
Chemical Waste Management, Inc.
Jim Seiber:
Thank you very much Roy. First of all I would like to intro-
duce my co-panelists/ Dr. Phil Kearney/ Chief of the Pesticide
Degradation Lab at USDA in Beltsville, MD; Francis Mayo, Direc-
tor/ Water Engineering Research Lab, EPA Cincinnati; and George
Nassos/ Director of Sales and Training in the Ocean Combustion
Services of Chemical Waste Management. We have a rather diffi-
cult task before us. We are going to attempt to summarize the
technological aspects of the conference and particularly to
look at where we have come since the last workshop. That is,
what progress has been made and where we need to put our empha-
sis in the coming months.
As far as my own mood on the workshop goes/ one of the atten-
dees/ Bob Fuget of DuPont/ pretty much summarized what I had
not been able to express in words. He said his impression
from the conference was that people are "adapting." I thought
that was a good way of putting it. He did not say that we have
solved all of our problems/ but implied that we are making
steady progress. We said last year that solutions would not
come overnight but we could expect progress to be made; I
think that is what this workshop has shown us above all.
Surely we are recycling and conserving more. We are also seeing
some field scale demonstration of success in technologies that
were research curiosities just a few years ago — things like
carbon absorption treatment/ UV ozonation and others. We are
seeing the beginning of promise in the area of on-site cleanup.
I want to talk about the on-site cleanup now in my summary.
This is a diffucult area. Maybe it is the toughest thing that
we face in this overall problem of pesticide waste disposal.
First, we are trying to clean up sites where the waste was ge-
nerated, in some cases many years ago; so we are thus facing
the "toughest" chemicals, that is, those that last the longest.
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Second, these wastes are spread out in the soil. They are not
contained, they are not in tanks, we cannot physically manipu-
late them the way we can with liquid waste.
Third, the concentrations vary greatly in these cleanup chal-
lenges. We have seen results from our own work in Davis where
a sample might yield 100 parts per million, while another two
feet away might contain 5/000 parts per million.
Finally, we have a moving target as a goal. We do not know
"how clean is clean." We will not know when we have succeeded
in the cleanup operation. We must learn as we move forward.
There were three approaches to on-site treatment during the
conference this week. One was to spread the soil on the sur-
face and expose it to ultraviolet light and the possibility of
volatilization. Ian Pepper of Arizona described this approach
to us. A second approach that we heard about was microbiologi-
cal. Let the microbes take care of it, either in their native
state or perhaps facilitated in some way by amendment to the
soil. Art Craigmill of UC-Davis described work going on there
and again Ian Pepper described some approaches in Arizona on
the biological treatment. The third area was chemical treat-
ment. Tetra Tech described the use of sodium hydroxide in soil
in one their poster displays. Another approach was given by
Dr. Borrup of Tennessee Tech where he described the use of
hydrogen peroxide which could be added to liquid or solid waste
and, in the presence of a catalyst/ would generate hydroxyl—
radical/ one of the best oxidizing agents known. I thought
that was a very interesting approach and that his poster was
very well done.
In all of these cases we saw the beginning of residue decline
taking place in the results. We are talking about maybe 2O or
30 percent over six, seven or eight weeks/ which does not seem
very spectacular when you compare it with the UV ozonation
where you get 99% decline in a few hours or a few minutes. I
do not think we should get discouraged; we are really breaking
some new ground here and that 20 or 30 percent in 6-8 weeks may
be very significant in the long run.
I would like to share with you some problem areas and chal-
lenges I see with respect to on-site treatment.
First of all I think that we who are working in this area need
to design our experiments in such a way that we get clear—cut
analytical results. We saw a lot of scatter in the analytical
data that was presented at this conference in the on-site
treatment and decontamination area. This means we have got to
go more to controlled, replicated tests using contaminants at
known and uniform concentrations. It is tempting to go di-
rectly to the field and try to clean it up with chemical or
biological agents. But in fact we must first do basic work in
the laboratory with some controlled experiments.
Second/ we need better and quicker ways to monitor our progress
in addition to taking the samples and sending them to the
analytical lab. We heard descriptions of some interesting
trials/ but the speakers told us they could not give us the
results yet because the analysis was not done. We need to do a
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better job in that respect and Phil Kearney mentioned the use
of immunoassays as an example of an on-site, quick type of
analytical capability.
We saw immune systems being demonstrated in the poster area,
including some tests that could be run quite quickly. I be-
lieve they said that in 90 seconds they could get analytical
results. That was for water but maybe it could be adapted to
soil in the future.
I think we may have overlooked another type of on-site evalua-
tion, one that was not represented at all in our conference
this week. That is the area of bioassay. Using inexpensive
organisms like fruit flies, mosquito fish, and Daphnia. There
are some big advantages to bioassay. They tell us the total
toxic residue that is present. That is really what we are
looking for, the parent and the breakdown products.
They tell us if we are making the kind of progress 'that is
important. Are we really detoxifying the site? Only a bio-
assay can tell us that. Our chemical tests will tell us if the
parent is going down, it will not necessarily tell us (unless
we know what to look for) what toxic breakdown products are
being formed. We need to do more in the bioassay area.
Third, we need to constantly watch out for this problem of
forming secondary products are essentially are problems. I
remind myself frequently and I will share this with you also,
that any time you carry out chemical or biological degradation
of organic molecules, the rule is that you create products that
are more polar, more water soluble and thus more leachable. We
certainly do not want to get in the position of cleaning up the
parent compound but creating something that is going to cause
us more problems and perhaps penetrate to greater depths.
All of these things do not mean that you should get discouraged
about on-site treatment but rather that we need to take a
broader look at all of the possibilities and be patient.
To summarize in the area of on-site treatment, I think progress
is being made, we are "adapting," but there is still a lot to
be done.
At this point I would like to turn it over to Dr. Kearney to
bring us up to speed on physical and chemical treatment
options.
Phil Kearney:
Thank you Jim. I want to tell you about a meeting I attended
last week that reflects on what we are doing here. USDA had a
big meeting in Atlanta, Georgia, and the issue we were talking
about was groundwater pollution and what we are going to do.
About forty scientists met there, and the problem is simple: we
have got to keep pesticides out of groundwater. There is tre-
mendous concern from the public sector that we be very careful
here. It comes down to two issues: the issue of faulty waste
disposal — maybe that is not the right term, but what we are
dealing with here — and the non-point source; that is, the one
to five pounds we use normally in agriculture to control pests.
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We will put some resources into the disposal issue. I have
been attending groundwater meetings for the last two years and
our people seem to have a real grasp of the issue. It is com-
plex/ it is regulatory/ it is science? it involves users and
manufacturers. My recommendation is let us/ the government/
take our resources/ what ever we have/ and worry about the non-
point issue. People sitting in this room have the best oppor-
tunity to focus on the disposal issue. They accepted that.
ARS is going to make a strong commitment to groundwater re-
search; it is going to be a high priority item. If we have to
divert funds from other programs to keep this going then we are
going to do it.
Let me discuss disposal technologies available to us in the
areas of science. We have the possibility of reusing or re-
cycling these compounds. To take the wastewater from one day's
operation and use it as the diluent or the solvent or the mix-
ing solution for the next day. The overall idea is that you
really do not accumulate large volumes of a waste and therefore
you do not have to treat it. I was rather impressed with this
concept. We do not have to treat large volumes. We can prob-
ably do it economically/ which is the key issue. The cost of
these options must be considered in light of the current de-
pressed farm economy. I was very encouraged about recycling,
reuse/ the use of concrete pads to contain this material. On
Monday/ however/ I began to see the questions that came up from
the audience about this disposal option. As a panel chairman I
asked you to submit questions; I saw some disturbing things
that worried me. There was a question about insurance. If you
recycle maybe the insurance company may not cover you. Then a
question arose about regulation/ i.e./ does all this reuse
option fit into the regulatory pattern. There are some serious
questions here. I talked with a young chemist; the thing that
worried him was that there is no destruction going on out
there. He is also worried about the fact that some of these
highly active compounds are going to get on that pad/ wash into
the solution and are going to have a residue or phytoxic prob-
lem on the next spray operation.
We are having a revolution in chemistry in the area of pest-
icides. The compounds that we used twenty years ago are
different from the ones we know today, and by the year 2000 we
are going to have a whole series of new compounds that many of
you do not recognize today. If you are selling these materials
in stores/ you begin to see the packages are changing. There
are some fantastic new chemistry coming out and we are going to
have to be careful not to mix these new chemicals. I was con-
cerned about these questions/ and that evening I had dinner
with a lawyer friend of mine, and he related to me a problem we
are having with recycling. The case involves a client being
sued because the pesticide permeates down into that concrete
pad and now this pad may be a toxic waste! The question is, do
we take a jackhammer and break it up and haul it to a dump
site. There are so many problems but few solutions. The next
morning I heard Darryl Hester and A. G. Taylor talk and I was
impressed with progress on recycling. I talked with them about
the number of accidents that they encountered. Darryl has been
recycling pesticides for several years. 1978 was probably when
they first tried this method. So they have had 7 or 8 years of
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experience and they have had a minimal of problems. I am per-
suaded that we have a certain amount of risk here; but as Res-
ter said/ we can do two things. We can cope with it, that is
to contain it and then work on it later; or we can continue
doing what we are doing now and there are some serious prob-
lems. In some areas there is no attempt to contain it/ there
is no attempt to process it/ and we would be far better off if
we began to deal with the problem/ that is to contain it/ to
catch them/ and then to do something with it. I think that is
the way to go. And it is a question of risk. Science is risk.
Let me share an anecdote about risk. At Georgia I had the
great opportunity to meet the President of the University/ an
outstanding man/ a true visionary. He said/ let's talk about
risk. The American people are not afraid of an automobile/
they love an automobile but you look at the death record in
this country/ i.e./ about 50/000 people die in this country due
to automobile accidents. He said look at the cigarette.
America is not afraid of the cigarette. If you look at the
death records about 100/000 die a year due to smoking. You
know what the American people are terrified of? A shark! If
you mention shark to a person they just freeze. He said, I
went to the Coast Guard and to the Navy and I said to them, how
many people a year die of sharks. Coast Guard says/ we have no
idea. If you say 2 you would be off by a factor of 100. He
says/ let me give you an example of what risk is about. If you
go to a beach and stand on a high place and you holler shark/ a
thousand people rush out of the water/ they run over to their
car, close the windows and light a cigarette. I think that is
a fair assessment of risk.
We have the question of what can we do once we have the pesti-
cide wastewater contained in an area. We have a number of
options open to us. We havfe charcoal absorption. That works.
Now we can make it mobile and spread the cost out among the
number of users, it is an option that is viable to us. We have
the problem that some compounds are not absorbed and you have
to do something with the carbon. You need to burn it or bury
it in a safe place. We also have hydrolysis and if you know
some of the chemistry of the pesticides we are using now it is
viable. You can make it strongly acid or strongly basic and
break many of these compounds. The only problem that worries
me as a chemist, some of the worst accidents I have ever seen
in the lab were with somebody working with hot acid or base.
But we do not need to use a hot acid or base, we can use an
enzyme. What an enzyme does is act as a catalyst. You heard
Dr. Karns talk about biodegradation. We have large solutions
of waste water that we put organisms in. Well what he is doing
is hydrolizing that compound.
We talked about using UV-ozonation. Of course this is my pet
project. It uses intense light and it uses oxygen that we
breathe, and it puts it into a form that is a very useful ca-
talyst. Some chemists are concerned about epoxide formation in
these reactions. The thing that is saving in our situation is
that we use a very large amount of water. Water interacts and
the compounds we are seeing are really no different than the
compounds we see from a microbial metabolism. We have yet to
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see anything new and very- different in the chemistry of these
reactions. We should push ahead with UV-ozonation but it means
some industrial backing. There has to be a market for each of
these technologies.
We talked about small scale incineration. Incineration/ if we
had endless dollars and resources/ could solve the waste dispo-
sal problem tomorrow. You can burn pesticides/ and that is the
safest way to do.it. Incinerators will burn these compounds
for us and it will convert it to carbon dioxide and water. The
problem is this can be costly and I think the large incinerator
people dp not want to deal with it. They do not want to deal
with some farmers several gallons from Nebraska or Iowa or Kan-
sas. They have other bigger problems with industrial waste.
So we need to look at small scale incinerations. Can we make
it feasible as a method to dispose of pesticides?
The other technology that is really experimental is the solar
photo decomposition. You take a particle and it absorbs energy
from the sunlight and it transfers that energy to a pesticide
and destroys it. It sounds good/ but we need more experimenta-
tion.
Pesticide wastewaters are difficult to treat. They are dirty/
variable concentration and there are other things in there. I
would like those people who are interested in this area to come
join us in a very difficult area of chemistry. Where should we
go from here? I am going to propose that we send you a ques-
tionnaire and ask you as a regulator/ or as an industry person/
or as a farmer user/ these are the technologies we talked
about; what is most applicable to you? What is applicable to
you in California/ what is applicable to you in Louisiana and
in Maine. We can then begin to go forward and say to the regu-
lators/ this seems to be reasonable and let's proceed down this
option. We will keep pressing science to get better answers
for you. But I think indecision is getting us into more prob-
lems than a calculated risk. I think we had better take some
calculated risks. Thank you.
Dr. Jim Seiber:
The next panelist is Francis Mayo, Director of EPA's Water Engineering
Research Laboratory in Cincinnati, Ohio. He will summarize the biological
aspects of waste treatment.
Francis Mayo:
I certainly concur with Phil Kearney's commentary on the need for recycling.
These residues need to be reused to the maximum extent possible so that their
treatment is kept to an absolute minimum. We should not be dealing with
fairly large volumes of dilute waste if there is some other way to reuse and
recycle that material.
When what needs to be treated has reached some minimum, it seems to me we have
some fairly bright opportunities for biological treatment of those materials
if we can resolve two or three key issues.
One is the concern for leakage or seepage from pit-type facilities into
groundwater; perhaps these facilities could be placed above ground. With
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above-ground facilities, leakage could be positively observed, and criteria
for constructing these facilities could reduce the risk associated with a
structural failure to some acceptable level. If we can do that and if the
regulatory process will accept that kind of a risk, then I think there are
some opportunities for using biological mechanisms to degrade these waste
materials. The pit offers some prospects for photodegradation and
biodegradation to work in combination and provides the prospect for using
media in the pits that would enhance the opportunities for biodegradation.
Another concern is the degradation products that are contained in these
facilities. We may have a very long way to go before we understand all of the
biological and. chemical processes that are taking place in them. But if, in
fact, the products are reasonably contained and there is a degree of integrity
that satisfactorily reduces the risk of failure and if, in fact, the material
is going to be degraded and there are no difficult-to-dipose-of residues, it
may not be important in the short run that we know completely what processes
are taking place. In the pit or tank-type operation and in an above-ground
context, we can look at the work being done at the University of California,
Davis, that Art Craigmill reported on. We can look at the acid and alkaline
trick!ing-filter-type facilities at Southern Illinois University that Brian
Klubek reported on, and certainly we ought to be very, very attentive to the
commentary that Jeffrey Karns offered us yesterday about using engineered
organisms or selectively propagated organisms to help foster the efficiency of
biological processes in these kinds of facilities. We should all be aware of
genetic engineering and those techniques of engineering organisms that may be
usable or adaptable to the kinds of issues we are dealing with.
Reference has been made to the leach-field technology being used in the state
of New York. Yesterday, I had an opportunity to talk yesterday with Betty Ann
Hughes-Davis from the New York Department of Environmental Conservation. She
indicated that those facilities are being given very serious reconsideration;
that, in fact, they might not continue to be used in the New York; and that
there certainly was a question about the viability of that approach on a broad
base.
Evaporation and biological treatment with wicks, a very simple prospective
technology that was illustrated yesterday, just begs for serious
consideration. It can be very, very inexpensive, and it can be easy to
operate. At the moment, however, no one seems to be giving it much play from
a research standpoint.
I must tell you that, as far as the Environmental Protection Agency is
concerned at the present time, the Office of Research and Development is
making no contribution at all to research activities in these areas. What
modest resources we have contributed to the meeting a year ago, to the
workshop in July, and to this meeting today are funds that have been taken
from other sources; they are not part of a deliberate pesticide disposal.
research program. There are no funds in the program for 1986. There are no
funds presently planned for 1987, and in the absence of a willingness to
reprogram some manpower and resources, the Agency is not going to be making a
significant contribution to solving the kinds of problems that we have been
discussing.
I 'think equally important with the viability of the technologies (in the
context of our abilities to understand them at present) is the need for the
regulators, both in EPA and at the state level, to give us some targets at
which to shoot from an engineering standooint. If we know what levels of
concentrations will be acceptable or if we know, from the regulatory
standpoint, what kinds of technologies might be amenable to class permitting,
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I am convinced there is an engineering capability to bring together these
physical, chemical, and biological processes of understanding to solve these
issues. From the standpoint of facility performance, however, it becomes very
difficult to make judgments on costs and on the comparative effectiveness
among competing technologies without some regulatory targets. So there is an
urgent need on the regulatory side of the house to provide at least some
preliminary targets against which we can seek engineering solutions. I hope
this will take place in the near future in terms of the interaction between
the Office of Solid Waste and the Office of Pesticide Programs, and I hope
that they will be in a position to comment on that during the wrap-up remarks
a little later this morning.
This is the extent of my comments. Thank you.
Dr. Jim Seiber:
Thank you Francis.
We are up here talking about physical treatment options/ chemi-
cal treatment options/ and biological treatment options. We
need to realize/ I believe/ that the three approaches are com-
patible/ and are not competing with each other. We could
physically treat our waste streams to remove the worst factors/
then soften the molecules that remain in that waste stream by
chemical treatment/ then we could let the microbes finish them
off. I think these three fit together very nicely in a systems
approach/ which is what we should use if we are going to come
up with the optimum system.
Jim Seiber:
Our last panelist is George Nassos/ George is with Chemical
Waste Management/ Inc./ Division of Waste Management. His job
title is Director/ Sales and Operations for Ocean Combustion
Service — North America. He is going to give us a perspective
on commercial waste management options for our problems.
George Nassos:
You have heard in the last few days and this morning some of
the possible disposal methods for pesticides that are in va-
rious stages of development. Today I would like to just
briefly cover what is actually being done today and a little
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bit about some of the newer methods that are just coming into
the commercial stage. Interspersed in my talk you will pro-
bably hear a few commercial messages/ but that is something I
have to do to justify my being here.
Current methods for handling dilute streams/ basically what
many of the companies do including Chemical Waste Management/
is to take these dilute streams and put them in surface im-
poundments. We are not talking about any old surface impound-
ment; by law they must be double lined. What we mean by a
double lined surface impoundment is a clay liner of about one
to two feet thick under which is a synthetic liner which is
your first liner. Beneath the synthetic liner will be a
crushed aggregate that is used as a collection area in case you
get any leakage through the first synthetic liner and under-
neath that another synthetic liner. Below there is anywhere
from 50 to 600 feet of clay.
The material is then evaporated and the residue is stabilized
usually using something like a kiln dust or the material can be
treated biologically.
What do we do for concentrated streams? Concentrated streams
are usually handled by incineration or if it is a sludge then
it can be stabilized and' landfilled. The incinerator streams
are usually the organic ones/ the aqueous streams are the ones
that are ideal for stabilization. Solids like dusts and pow-
ders can either be landfilled or again incinerated. Some of
the new and developing methods are all based on a concept where
you first separate the toxic component from the solution media
and the idea there is .why treat gallons and gallons of water
when a small portion is really the toxic component. What are
some of the ways we can make these separations? The obvious one
is evaporation/ and if you are in an ideal climate where you
get very little precipitation that is great/ but if you are in
another part of the country where it is not possible the only
way you can evaporate is using some outside energy. A new way
that is being developed and we.hopefully will be offering it
soon is freeze crystallization where you freeze the water and
separate out the toxic components. The advantage of this is
that the heat of crystallization is significantly less than the
heat of vaporization so the amount of energy is considerably
less. Also you do not have any air or water pollutants.
What are some of the treatments in disposal methods once you
have made the separation? Well the obvious one/ and Phil
Kearney mentioned it earlier/ is incineration. The disposal
industry really believes that incineration is going to be the
way to go. We are going to need more and more capacity in par-
ticular because of the RCRA 1984 amendments banning the land-
fill of many waste streams.
What kind of incineration capabilities are there? As you know/
there are a lot of rotary kiln incinerators. They are large
ones/ as Phil mentioned. Chemical Waste Management has one in
Chicago; Rollins/ the competitor/ has several; and there are a
number of other smaller ones. Another possibility — and we
hope will be a reality very soon — is ocean incineration.
That is what I have been working on for a number of years.
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Chemical Waste Management has the Vulcanus vessel; it is in the
process now of obtaining a permit to do a research burn some-
time this spring, and hopefully that will lead to an operating
permit early 1987.
What about other incineration or thermal destruction options?
A French company is trying to bring a process called the Vicarb
process/ which is a high dispersion incinerator that shears the
droplets as they pass through a venturi. They claim that they
can get the destruction efficiency of six or seven nine's with-
in a very short distance. Other techniques/ possibilities/ is
plasma arc pyrolysis/ another incineration method that is being
developed by Chemical Waste Management and a company called Arc
Technologies. This is a system that operates in the plcisma
zone 11/000 degrees farenheit and in the furnace chamber at
3/000 degrees farenheit. The advantages are that the gcises to
be scrubbed are very minimal. Again/ this is to be used pri-
marily for solids like dusts and powders. Westinohouse has a
plasma arc which is a .mobile unit and it is all enclosed in a
45 foot trailer. Presently available, it can handle waste
streams at a capacity of about 6 gallons a minute. Not really
large but perhaps something that can be used for the small
generators.
You have heard today and on Monday about activated carbon
treatments. This is not something in the experimental stage it
is available today and again Chemical Waste Management has a
mobile unit that is presently being used for cleaning up sur-
face impoundments where we pass the material/ waste/ through a
sand bed filter and through the activated carbon system. Other
companies/ I am sure, are also developing that and have it
available.
Another option is wet air oxidation. This is a process that
has been developed by Zimpro and is again offered commercially.
It oxidizes the waste at very high pressures.
All these systems are well and good. The question is, how do
you get your waste to these systems to get it processed? There
is a need to handle the small generator and many companies are
trying to develop a system for that. Again, being that I know
more about Chemical Waste Management than any other company let
me tell you what we are doing.
Our company has nine treatment facilities throughout the
country, which may not be very close to any of you. However,
we also work with Ashland Chemical Company that has about sixty
terminals throughout the country. What Ashland does is pick up
one drum, two drums from the small generators, collects a suf-
ficient quantity to bring a truck load to one of our nine faci-
lities. Granted, Ashland is primarily in industrial areas and
not in the heart of the farmland of the US and they may not be
convenient to you. The only thing I can say about that is as a
result of this workshop I will be going back to our management,
to our planning and development department, and bring this.
problem to them and hopefully we can come up with a solution
that could help you and hopefully present it to you next year.
Thank you.
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QUESTIONS AND ANSWERS
Roy Detwei-ler:
I was surprised to hear George give information on the
competitors.
If anyone has some interest in the Westinghouse project I am
familiar with that/ I am a consultant to them. That is my
plug .
QUESTION for Francis Mayo:
It would be very helpful to have data on pesticide degradation
and activated sewage processes. Does any such data exist?
ANSWER:
Yes we do have some information because for the last six or
seven years we have been looking at the fate of priority pollu-
tants in municipal wastewater treatment systems. We have a
pretty good idea about how the conservative ones move through
the system and how those that are susceptible to biological
degradation are affected by wastewater treatment. We do have
some background on the behavior of some of these materials in
municipal wastewater systems in terms of what percentage may go
into sludge, what portion may be stripped as a consequence of
the aeration process, and perhaps what portion of it might
actually be biodegraded. We don't see, however, at least not
at the moment, the likelihood that these systems are going to
be a major receptor of these materials, particularly those that
are conservative and move through the system.
QUESTION for George Nassos:
Why is the ocean such a highly desired place to do the burning?
Isn't the risk to the sea a serious potential?
ANSWER:
There are a couple of major advantages of ocean incineration.
One is the capacity of an ocean incineration vessel relative to
a land based incinerator. The reason for this is that ocean
incineration does not require scrubbers. Land based incinera-
tors are constrained by the- throughout of the scrubber. The
exhaust gases of'an ocean incineration system are basically
carbon dioxide, excess oxygen, traces of carbon monoxide and
hydrogen chloride gas which falls into the sea water and is
neutralized by the natural alkalinity of the sea. As a result
the capacity of a vessel roughly three to five times that of
the largest commercial land based incinerators. Regarding the
question of risk to the ocean, there is a risk no matter what
you do as mentioned earlier. Our vessel has been operating in
Europe since 1972 without a single incident of accident or
spill. The ship is especially built, it is one of the finest
constructed vessels in the world with redundant safety systems
with respect to any emissions coming out. In numerous tests
the ship has demonstrated destruction efficiencies of greater
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than 99.9999%. We are not sure how nuch greater because nothing
has ever been detected coming out of the stack. To put it in
perspective/ if the ship were operating full-time in the North
Atlantic, we are talking 18 burns a year at 800/000 gallons and
if it were all PCB's and we only achieved 99.9999% we would
dump about 41 pounds of PCB in the ocean per year out of the
stack. Compare that to about 12/000 pounds of PCB's that go
out into Chesapeake Bay every year from groundwater/ through
the estuaries. So the risk is really insignificant.
QUESTION for Francis Mayo:
What is the wick material that you referred to?
ANSWER: •
We do not have any samples of it. Bob Claunch is the one who
has proposed this. He believes he has a wick material that
would accelerate the movement of the dilute waste material out
of that central trough up into the wick for evaporation and/
prospectively/ photodegradation and biodegradation. It seems
to me that there may be a variety of materials that could be
used. It may even be possible to incorporate some materials
into that wick (just by weaving it into whatever is used for a
wick) that would foster photodegradation. There are
opportunities here that warrant looking at.
COMMENT for Phil Kearney: .
This is a comment referred to Phil. The U.S. Army is using
carbon absorption to remove pesticides from equipment
wastewaters. EP toxicity tests indicate that the pesticide
cannot be leaked from the carbon therefore/ the state of
Virginia that the pesticide contaminated carbon is not a
hazardous waste and has authorized the Army installations to
bury the carbon in a sanitary landfill. Do you have any
comments on that?
RESPONSE:
That is good, if that sanitary landfill will be available in
the future. ,
INFORMATION REQUEST:
Here is a commercial message. Somebody wants some information
on Ashland Chemical, where they can be contacted. Information
will be given later rather than make an announcement here.
QUESTION for Roy Detweiler:
It says commercialization of waste minimization or disposal is
essential for major improvements and their uses. What will be
done in future workshops to obtain participation of all manu-
facturing elements who need to be encourage to join the team?
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ANSWER:
That is fairly simple to do. Through NACA we can get others
in here to discuss it if there is such a need and that will
certainly be referred to our committee who will be meeting
this afternoon.
If there are no further questions/ I would like to thank the
panel for their work.
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REGULATORY SUMMARY PANEL
Raymond F. Krueger, Panel Chairman
Office of Pesticide Programs
US EPA, Washington, DC
Orlo Robert Ehart
Executive Assistant, Wisconsin Department of
Agriculture, Trade and Consumer Protection
H. F. "Butch" Calhoun III
Director of.PestTesdes and Environmental Programs
Louisiana Department of Agriculture
Roy Detweiler:
The group we have assembled here is called the Regulatory Sum-
mary Panel with Ray Krueger as Chairman. Bob Ehart is an exe-
cutive assistant of the Wisconsin Department of Agriculture
Trade and Consumer Protection/ his job responsibilities inclu-
de: policy implementation and formulation of environmentally
related programs affecting agriculture/ he is chairman of the
SFIREG Ground Water Protection and Pesticide Waste Disposal
Committee/ and he has eight years of experience as Director of
the Wisconsi.n Pesticide Control Program. H.P. "Butch" Cal-
houn III is from the Louisiana Department of Agriculture where
he is Director of Pesticides and Environmental Programs/ his
job responsibilities include: licensing and certification of
applicators/ dealers/ consultants; he looks into damage comp-
laints/ enforcement of state and federal laws/ waiver of use
of restricted pesticides/ equipment inspection/ sampling pes-
ticides/ registration of pesticides/ and regulation of pesti-
cide waste.
Ray Krueger:
Thank you Roy.
I have been working with pesticide disposal with EPA for about
12 years and the interest and devotion to getting problems
solved shown in this workshop and in the previous one is
extremely gratifying to me. I think .for the first time in the
12 years I have been involved in it we s'tand to make some
progress/ real progress. But what this means is that the pes-
ticide users are not faced with just the regulations or the
laws that EPA administers, specifically the Federal Insecti-
cide, Fungicide and Rodenticide Act (FIFRA). The user is
faced with a number of other federal rules under Resource
Conservation Recovery ACT (RCRA), CERCLA, generally known as
superfund, DOT regulations if you are going to ship anything
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and the aerial applicators are looking at the FAA rules that'
they have to observe. Beyond all that come the state
regulations which supercede what the federal government has
to offer particularly in FIFRA and RCRA.
I see a need for better adaptation of these rules because most
of them/ particularly the RCRA rules, were designed to deal
with different problems than we have had as pesticide users.
FIFRA is designed to deal with the use of pesticides, regis-
tering them for specific crop uses and really does not have
the authority to control disposal, per se, although within
our regulations we have already identified disposal as a use
action. In other words our regulations are set up that way.
In the short term, as I indicated in my talk the other day, I
believe we can put out recommended procedures to cover some
items. The problem of disposal when we talk pesticides, we
are talking everything from sulphur to household use products.
The variety of chemicals is just astounding. In these recom-
mended procedures we will probably take a very short step in
terms of the long walk toward solving all the disposal prob-
lems. They will have to be equivalent, as it were, to the
RCRA control. They will have to provide protection to human
health and the environment in the same fashion that could be
expected from RCRA regulations.
In the long term I see us moving toward custom made label sta-
tements, as it were. Each product will have with it informa-
tion as to exactly how to dispose of that particular product
and the residuals that may result from its use. Empty con-
tainers for example.
The problem with this approach as I see it is the variations
in regional uses. We saw this with the use of evaporation
ponds when they were legal. They worked just fine in places
like Texas and California but they do not work too well where
the rainfall is particularly•high or in places like South Da- •
kota where everything freezes solid. It may be difficult to
tailor label statements to the broad uses of some products.
Some products are quite regional so it would not be difficult
there.
I can virtually guarantee you that the dialogue that has been
mentioned several times at this conference between the Office
of Solid Waste and the Office of Pesticide will continue. Our
respective chiefs are very interested in this problem and
extremely interested in getting something done. The priori-
ties are there and you can expect that we will do something in
the very near future.
We will need a lot of help from the users the state regulatory
people and others in the broad spectrum that has been repre-
sented here at this meeting. We look forward to hearing from
them.
One more comment. We will publish in the proceedings, and
there will be proceedings published as a result of this work-
shop, the E and F lists that you have heard so much about over
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the past couple of days. Jean Frame has developed" those/ we
have them/ the pesticides that are on the E and F lists/ I
should say. They will be available in the proceediings.
Thank you.
Remember we will accept questions/ we have some time/ so I
would like you to think about that and maybe pose some tough
ones to EPA. In the comments that I read last night/ these
guys dodge most of the issues/ here is your time/ I am going
to put it to them and I will not let them dodge it. So if you
have a question put it down.
Butch Calhoun:
Goodmorning. The problems I see with pesticide waste is that
it is a national problem affecting the entire U.S. But there
is no one national solution to the problem. The problem must
be addressed on a regional basis and a state-by-state basis.
We have not solved problems such as insects/ weeds or diseases
on a national basis and we have not solved problems with our
certification and enforcement programs under FIFRA on a natio-
nal basis. But we have solved these problems on a region by
region basis and on a state-by-state basis.
Here is how we handle things in Louisiana. In most states/
the departments of environmental quality or health regulate
pesticide waste. But in Louisiana/ the Department of Agricul-
ture decided back in 1981 that we were going to handle pesti-
cide waste. We assumed that no applicator could afford to be
a generator of hazardous waste under RCRA and stay._ in busi-
ness. We spent a lot of time trying to find loopholes in RCRA
that would save the commercial applicator. After this great
length of time we were unable to find these loopholes/ so we
decided that the only way for us to handle the problem was to
keep the-applicator from becoming a generator of hazardous
waste. If you do not generate a hazardous waste you do not
have to worry about RCRA. We also decided that with the pos-
sibility of the E and F lists changing from time to time/ that
the best way to approach this problem was to deal with pesti-
cide waste. Do not worry about whether the waste is on the E
or F list — do not generate pesticide waste and you do't have
to worry about what list it is on.
We took a chance on a piece of state legislation that moved
the control of pesticide waste from the state Department of
Environmental Quality to Louisiana Department of Agriculture.
Now some four years later/ pesticide users/ pesticide dealers/
manufacturers/ landfill operators and regulators in the state
agree that this move was worthwhile.
X personally feel that the state agencies that have been
regulating the pesticide applicators under FIFRA should
regulate pesticides from cradle to grave. We are the people
who know the problems. We are the people who have the
expertise. So why shouldn't we handle the problems of
pesticide waste?
In Louisiana our pesticide waste regulat-ions cover the pest
control operators/ aerial applicators and ground applicators.
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Farmers are the only pesticide users that are exempt. I do
not totally agree with this. Personally/ I feel that if a
pesticide used by a commerical applicator can cause a problem
to our environment/ then that same pesticide waste produced by
a farmer can cause a problem. Our regulations are directed to
commercial applicators in the handling of rinsate/ washwater/
and container disposal. When the laws took effect/ the users
were given three years to clean up sites and stop generating
waste. On January I/ 1985 the Department of Agriculture began
inspecting sites/ issuing compliance orders/ and bringing
charges against violators. Since then some 200,aerial appli-
cators/ 200 ground applicators and 1/000 pest control opera-
tors have been inspected. To this date we have issued some 51
enforcement actions.
Container disposal has posed a special problem for us because
many landfill operators have refused to accept triple-rinsed
crushed containers. In response we have worked with the land-
fill operators on a one-to-one basis/ explaining the disposal
laws and seeking their cooperation. As a result/ most land-
fill operators have agreed to accept these containers/ thus
giving us another victory.
I feel that in Louisiana we may be a couple years ahead of
most states in handling our pesticide waste problems and I
know the efforts of the Department of Agriculture/ the Exten-
sion Service/ with people like Darryl Rester/ the pesticide
manufacturers and the pesticide users/ that we are several
years ahead of most states on attitude. I feel that this mee-
ting is a positive step in the right direction.
In closing I would like to recommend that we do the research
in pesticide waste. Let's collect the data and let's get mo-
ving in the right direction.
Bob Ehart:
The requests of the most repetition of last year's talk,' or
the things which I spoke of last year are three things. Since
I have been asked them repeatedly, just to make sure that no-
body else in the audience is confused about some of the terms
that I used last year/ there are a number of acronyms.
Bureaucrats all like acronyms anyway/ but there are two
acronyms that are in one of my papers. One of them is NIMBY/
that is Not In My Back Yard, and LULU/ and LULU is the one
that sent everyone into a lulu/ they cannot seem to remember
that one. That is Locally Unacceptable Land Use/ and it is
something we spend a great deal of time trying to figure out
how we are going to take care of a lot of our difficulties
because of the locally unacceptable nature of things. It is
always fine if it is someplace else.
The other issue was a lady by the name of Esther Foster.
Esther is a lady who was living in a older style home/ kind of
a Cape Cod design and she has her hair all pulled back in a
bun and is really an elderly type figure with a shawl around
her shoulders/ and a woven rug on the floor. The caption
underneath this cartoon says that Esther Foster has not turned
on the radio s'ince she learned that they can broadcast herbi-
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cides. I think that does, in many ways, point to the nature
of the concerns that many people have, that there are differ-
ences between real and imaginative problems. That is some-
thing that we are still having to wrestle with. What is the
difference between the real and imaginative problems that we
actually have.
Last year I ended a talk by giving a charge to the pesticide
user industry that the destiny of their problems was in their
own hands. I think that is still the case and I think the
reason that we are having this conference this year is because
they are taking the destiny of their concerns about pesticide
disposal into their own hands.
I think that the communication aspects that were so despera-
tely needed have been definitely fostered with the amount of
efforts that have gone on in this last year and that is not
only limited to the conference, it is also the amount of con-
tact that there has been between people as a result of the
conference, the number of people who know who each other are
as a result of the conference. They are sharing a lot of the
similarities that they have in things. I think there is much
more of a communication level between researchers, which had
come to pretty much of a halt, in the meantime, on disposal
issues they were really not having the forums in which to
communicate with one another, there has been a research
conference and there is a lot more attention paid to
pesticide disposal, considering what there was before.
There has been a clear indication by the headquarters people
from EPA, they are showing us recognition. Recognition that
their purpose is to protect the environment rather than to
create infallible regulatory systems. That is a very signifi-
cant issue. It is something that before got lost in the quag-
mire of regulations that we are able to produce. That also
applies to us at the state level as well. A comment in the
proceedings last year was a statement: problems for the pesti-
cide users have not been solved as a result of this confer-
ence, the lines have just been better defined. That statement
can again be repeated this year. The end user maybe has a few
more things that they can do in order to comply, but there
really has not yet been the problem solving nature, but we are
a heck of a lot further along this year than last year. That
is a very important situation.
A good way to look at what our responsibilities as regulatory
people are is to look at what kind of challenges we gave each
other last year and see how well we have done in those parti-
cular areas. For one thing we said there was a need to focus
on the typical questions, concerns and issues in the area of
pesticide waste. One of those things is to accumulate that
kind of information. One of the efforts we have made through
the SPIREG committee is to come up with a list of questions
that are typically asked, that are typical kinds of concerns
that need to be answered. EPA on the other hand, said once
they have those kinds of questions, they will publish a ques-
tions answer sheet to address a lot of those issues. Ques-
tions are rather long and detailed, they would go into very
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specific concerns on those particular questions because that
is where most peoples' problems lie. They are not the simple
little short answers/ short questions, type of things. They
are very complicated, and they are complicated for a number of
reasons. I think that is quite an important aspect. I gave a
challenge to those of us in the states to become the one stop
shopping center for information on regulatory programs which
affect the ag industries. I went through the list, I may be
off a little bit on these figures, last years proceedings and
there were 28 state representatives present, and if I am not
mistaken, I may have missed one or two this year, there are 17
or 18 states that are here this year. At least 10 states have
already taken care of all those problems and did not need to
come back. Actually that is fairly facetious on my part, but
it is something that I think there has been quite a bit of
progress on and there is a lot more availability of informa-
tion even though I do not think that we have gone to the ful-
lest extent of becoming the center of knowledge on state prog-
rams that we need to and so I can yet again issue that parti-
cular need for us to become very intimately aware of the con-
cerns that there are in pesticide disposal and become at least
the focal point, if not the experts, on how to deal with those
particular problem areas.
Another challenge in the discussion of uniform standards
through pesticide waste treatment and disposal and also combi-
ning with that the designation of what kind of waste is
actually on the label. I have heard more comments, particu-
larly on the aspect of uniform standards for pesticide waste
treatment and disposal at this conference than I had ever
anticipated. I think it is something of an admission that
because of the fact that what is legal today may be illegal
tomorrow that we need to have concerns for liabilities for the
future. We are all accepting the fact that we need to move
directly into that area and to take care of our problems so
that we do not have an impact on the future. That is one of
the things that you will see, that we know that we have to pay
more attention to and that you will see a lot more activity on
in the future.
I am still concerned about where we are with labeling and I
think we will see some directional changes in that area as
well. It seems to be that we have to have a policy of truth
in advertising. We pure and simply have to put on the label
so the end user knows what he has to do with it. If it says
it is an E listed product or an F listed product or one that
may qualify under EP toxicity, then the end user has some abi-
lity to know what in the world he is supposed to do. Until we
get to that point we are putting it in CPR's that nobody can
read, is absolutely unacceptable if we are really expecting to
have compliance. And I think .we as regulators have a challen-
ge in front of us to establish that kind of protocol if indeed
we are going see future successes.
There were a couple of other things that we talked about last
year in the protocol, building fires in abandoned sites, there
has been some attention to that, these are local issues and
need to be handled on the localized basis. We talked about
designating systems as major regional artd onsite facilities,
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making categorization of them and there has definitely been
some in that area as well. We still need to look at regional
treatment center and that type of thing if we are going to see
the solving of a lot of the waste problems.
I think that the emphasis that we have heard at this confer-
ence has been one of do not become a generator, use up the
materials as they are intended, and the waste problems are
diminished is probably the major issue that we need to recog-
nize in the fact that if we limit the amount of the things we
are producing in that particular vein, a lot of our problems
will be taken care of. It is something that all of us need^to
go home with. The idea of recycling, the idea of minimization
as we look at all of .these particular areas.
I also gave a challenge to the fact that the efforts were need-
ed in research. Particularly the emphasis in regulatory quest-
ions needing answers, I was obviously elated to hear Francis
Mayo say this is one of the things we need to pay attention to
which they need from us. The pesticide users and research
community of the world can have some kind of list of what our
priorities are. If indeed we are going to change our mind about
what the priorities are we need to be held accountable for those
particular problems if we are actually going to solve them.
We are now seeing that creative genius switch into the re-
search court, where I personally believe is where it belongs.
Last year I accused the experts of taking a sabatical and not
actually dealing with the issues that were before them. I
think that we can definitely welcome them back.
As most people when they come back from a sabatical, I think
they have come back with renewed enthusiasm. I think we still
have a major role, all of us, in education. What is going on
right now needs to be translated into what is useable and how
it will actually impact all of us.
I think last year I labeled after the conference anyway, I
labeled the group of us, us regulatory people, the ones that
you are going to get to take a shot at here in a moment, as
the unmoveable group of people. We are hard nosed, we talked
about if you do not comply, you are out of business, it is
just tough luck.
I do not think you heard that tone from a regulatory portion
of this conference at all. I think that you saw a lot of
movement in the fact that there are policy changes that can
actually occur in these particular areas.
This year we brought in some RCRA area regional people, I
heard a much harder line. Similar to what I think we heard
from the headquarters people last year, and from FIFRA.
We also brought in the container people this year, they are
new to this conference, and I also saw them as rather taking
the approach of the unmoveables. I think next year we need to
bring in the insurance industry or next conference, the insu-
rance industry and more of the state RCRA people. The state
RCRA people that are here, I think, are on the cutting edge of
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recognizing of how to actually go about things. But I am not
convinced that those that are not here share that same parti-
cular area. Often times it seems like the RCRA states people,
because of the push from headquarters, interpret equal prog-
rams as identical. And I think we need to see a switch in
that particular area, away from being identical to having more
flexibility and that comparable is equal. The movement of
some of the administration of those particular programs, to
FIFRA to programs where in states that can be worked out, I
think would be a step in the right direction.
As Butch -has said, I think we need to look at management of
the problem as a way that we actually treat it rather than the
situation of really being more like ostriches and hoping it
will go away.
I think there is a challenge for all of us regulatory people
to recognize as we formulate our policies that people are part
of the environment. And that we are going to have effects.
But we are also the ones that have the intelligence to be able
to work out the minimization of those affects. One of the
things that there might be a need for us to look at is the
fact that we heard that what might work in one state, might
not work in another. That maybe part of the challenge is now
to look at regionalization of these kinds of efforts. So that
we look at similar problems that we have with the states that
surround us rather than looking at trying to find a locally or
an acceptable area for a national meeting.
Part of the reason, I am sure, that ten states people are not
here, that maybe were last year, is pure and simply, budgets,
difficulty in justifying travel, and that type of thing. Not
lack of interest. And with that situation there maybe is a
challenge for us to look at some kind of regionalization of
the programs as we go down the road.
I think there is ample opportunity for all of us to work to-
gether and is something that would be a highly successful part
of our program as we look at what we actually can accomplish
in this area.
QUESTIONS AND ANSWERS
COMMENT:
It is hard to believe that OPP and OSW have much concern about
this issue when as Mayo said OSW is not willing to spend any
money on it.
QUESTION for Bob Ehart:
There seems to be a great deal of confusion about land dispo-
sal of pesticide wastes. Are you saying that both landfilling
and landspreading are practices that will eventually be ille-
gal?
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ANSWER:
I think EPA might be saying that. That is an issue that we
have been working on for some time with Matt Straus and his
group. Matt is actually the person that should be asked that
question. His answer has traditionally been that congress in
the 1984 amendments suggested that they look very seriously at
that and the implication is towards actually eliminating it.
However/ Matt generally stops short of saying that is a demand
and therefore there may be some opportunity for those types of
things. But I think the general tone of things is such that
we should be looking at other methods of disposal/ if at all
practical and possible/ but not necessarily that it will be
totally eliminated.
QUESTION for Ray Krueger:
We have heard again this week of the inappropriateness of RCRA
for the regulation of low-concentration pesticide wastes.
NACA is promoting regulations under FIFRA/ Louisiana has been
successful in regulation without RCRA. When can we expect to
see similar thought or action between OSW and OPP?
ANSWER:
The answer to that is in the very near future. But as in the
case of all complex problems/ we are going to have to deal
with it a little at a time. The first things we can address/
I believe/ are the low-level dilute solutions from equipment
wash, container rinse, and so forth, because they are at a
much lower level than application rates. The problem is we do
not really know what those levels are and we do not have a
good enough handle on them to be able to address them intelli-
gently. That is one of the first things we are going to try
to do. Is to pull those numbers together as best we can.
I would like to point out that virtually all the work will
have to be done within the Office of Pesticides or utilizing
whatever outside help we can get from NACA or other user
groups. Because the Office of Solid Waste are burdened with
congressional deadlines that you would not believe. They have
a great deal of regulation writing and modifications to do and
they have very tight deadlines to gee them accomplished. The
1984 amendments to RCRA that were mentioned before, for
example/ carry a dispensation from the normal regulatory
procedures act. In other words, when we, EPA, write a regula-
tion, the first thing we do before it is published, we publish
it as a proposal and we look for public comments. We have
public meetings and all kinds of things to involve the regula-
ted community. The 1984 amendments excuse the agency from
having to do that. Those regulations, for the most part can
be put on the street without any public comment. The agency
is doing its best to involve the public on that.
What I am saying is we cannot expect much help from the Office
of Solid Waste, other than working with us, approving or dis-
approving what we propose and that sort of thing. We are
going to have to do it inhouse.
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QUESTION for Ray Krueger:
Can the FIFRA amendment be a practical solution at this time
to get transferred the authority from RCRA to FIFRA over
pesticides?
ANSWER:
Well there would not be what I would call a transfer of
authority in any event. To answer-that question, I would say
no. Because the authority to regulate the use of pesticides
is already available in FIFRA. .The only thing we would do
having equivalent rules in effect under FIFRA label statements
or recommended procedures/ would be to de-regulate those
specific wastes from the RCRA lists or from RCRA control.
QUESTION for Ray Krueger:
This is a question that should have been referred to Straus.
And I will give you the opportunity to say you do not know.
What is the status of RCRA as to when the law comes into
effect? Becomes law as it might impact on the pesticide
waste?
ANSWER:
Well there are so many rules that are being revised or
written.^ Small quantity generatory regulations for example,
that it is hard to say yes or no to that question.
Did you have any key dates in mind?
No I really do not.
QUESTION-for Butch Calhoun:
Two questions having to do with the enforcement action you
have taken. They want to know the nature of the violations,
what actions you took and was that an effective way to get
compliance? Can you comment on that?
ANSWER:
We have issued more compliance orders than we have actually
brought charges. We expect that we will have more charges
brought this year. We have a unique situation because we do
have/ under state law/'the authority to impose a maximum fine
of $25,000 per violation, dealing with the pesticide waste.
We have one case where there was some improper disposal of
container and chemical. The violator was charged $1,000 and
required to clean up his problem.
So you just had one fine paid?
So far. Yes.
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QUESTION for Butch Calhoun:
How did Louisiana handle old container dump sites?
ANSWER:
We had several different situations that we dealt with. Not
all of them were dump sites necessarily and we have a big
problem still with some old sites where we have some obsolete
chemicals. We have handled each site on a case by case basis.
We have had some sites which had to be cleaned up and hauled
to permitted hazardous waste facilities. We initiated some
research through the University/ we had some sites that we
cleaned the sites up and land farmed the contaminated soil on
a piece of state property and we are monitoring it from year
to year. Taking samples and checking to see if the chemicals
are breaking down and at what rate are they breaking down. So
we have basically just handled these on a case by case basis.
QUESTION for Ray Krueger:
Can the EPA declare and announce that spent activated carbon
containing pesticides is not a hazardous waste and may be dis-
carded in a local landfill now? Or is further data required?
ANSWER:
Given the data to show that that particular material was not a
hazardous waste. That is to say EP toxicity test results or
something on that order, the EPA could very well say that.
But the final authority still rests with the state agencies
that regulate the landfills and also given the fact of the
emotional value of the word pesticide, it may be difficult.
QUESTION for Roy Detweiler:
Will submitted answers and questions and answers be published
in the proceedings? As you have noted many questions have
been submitted but time permits only a few answers.
ANSWER:
We will discuss that in our meeting this afternoon and see
what we can do about that.
QUESTION for all panel members:
The idea of the state lead agency controlling FIFRA and RCRA
program is good. Do you think that this is possible under
federal EPA?
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ANSWER - Bob Ehart:
If you had asked me that last year, I would have probably said
no. I have a lot more belief that that is possible this year.
There has been a lot of activity, a lot of discussion as to
how would you go about doing that. Clearly a response from
the RCRA people that if a proposal under FIFRA has comparable,
not equal, but comparable capability of regulation that they
see no problem with that. It is something that can be handled
adminsitratively. And EPA has tended in the last several
years, to look a lot more at administratively handling prob-
lems rather than going to congress to try to solve dilemmas.
For that reason, I think there is a good potential, if indeed,
we as state people can come up with that kind of activity.
Our SFIREG committee will be wrestling with what we think
might be some legitimate ways of dealing with that particular
thing and looking at the kind of options that states do have.
The experience that Butch Calhoun has had in Louisiana is
somewhat of a model for us to look at and show the success
that can be done in those particular areas. That comparable
can be an equal type of a program. Therefore something of
where EPA can look at that and say, yes indeed it can work, we
would-be willing for that particular area. I think Butch's
experience also indicates that it administratively can already
be handled with existing authority and therefore is something
that makes it more obtainable as well.
ANSWER - Butch Calhoun:
To address our situation in Louisiana. Our Department of
Environmental Quality was a state lead agency for RCRA. We
worked a deal with them after we passed our pesticide waste
law that when they went for final authorization under RCRA
they made us a part of their package that they submitted to
EPA. Thus when EPA approved them receiving final authoriza-
tion they approved us receiving the pesticide waste end of it.
We received a grant from EPA just like the Department of Envi-
ronmental Quality does. It has been a very good marriage in
Louisiana and has worked very well.
ANSWER - Ray Krueger:
I would like to add a little bit more to that. Given the long
term possibilty of having tailor made disposal statements with
each product, it would be very difficult for the states to do
something different. Also, our recommended procedures, tend
to set the tone of regulation in the states. They look to the
federal government for guidance in a lot of these areas and I
think what we will probably see is local modification to meet
local needs.
COMMENT:
This is along the lines of developing one set of regulations
on pesticide waste disposal that would be appropriate for the
federal EPA to apply across the country. In all states it
would be mandatory to treat to that level. That would mini-
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mize confusion and would make it easy for all applicators
everywhere to be able to plan for waste disposal. Do you
have any comments on that, any of you?
RESPONSE - Ray Krueger
I agree. But unfortunately that is not the real world.
QUESTION:
Can you expand on that?
ANSWER:
Well we already said that the problems of regulating from
Washington are immense in terms of the regional differences
across the country. Within states and within various parts
of states. So that an even handed, across the board
regulation covering all of pesticde disposal problems would
be very very difficult. It may be possible to regulate say
empty containers in that fashion. But I see that as a dream
almost.
QUESTION for Ray Krueger:
Do you know what level of breakdown will be allowed for •
pesticides as a goal to work for? How close.to zero?
ANSWER -,Ray Krueger:
How safe is safe? That would probably be arrived at on a
chemical by chemical basis, the only way I could see doing
that. Which is what Matt said he was working on. At least
as it pertains to groundwater.
Do you have a comment Orlo?
ANSWER - Bob Ehart:
Yes. I think that one of the things that we need to recog-
nize, and that question raises it again, is that the answer
to the pesticide users problem is minimization of the waste
in itself. I do not think we are going to see any changes in
RCRA philosophy or in handling of waste itself to move away
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from a zero tolerance. Butch just said to me/ what is the
definition of zero? It keeps seemingly to get smaller.
We have to recognize that and I am not sure we are going to
see standards set that allows us to do that. I do think we
may see some standards as to what is allowable in mixing pest-
icides that you spray out onto the fields that may worry the
manufacturing industry as to what are their liability concerns
or what kind of cases might be resulting from that. I see
more opportunity for movement in that area than I do in the
disposal end. I think the thing comes down to minimizing it
as not a waste in the first place.
QUESTION for Ray Krueger:
We are in the lawn care industry. Please confirm or correct
my understanding with regard to small generators. We need to
collect recycled rinsewater and/or washwater that contains
listed E and F pesticides. If there is more than two hundred
and twenty pounds per month of sediwent collected in cur
recycling system/ then we are generators. If less than two
hundred and twenty pounds a month/ we are exempt and sediment
can be disposed of in 'a dumpster. Is that correct?
ANSWER - Ray Krueger:
I am a little bit confused by the question. Sounds to me like
the person asking that question is collecting the rinsewater
for reuse. If that is so then i't is not waste.
Then he is saying that the sediment that is leftover is what
he is concerned about. If it is less than one hundred kilo-
grams a month he is not a small generator.
Well if it is an F listed waste, one hundred kilograms would
apply. But if it is an E listed waste one kilogram would be
the minimum.
ANSWER - Butch Calhoun:
If he is doing the proper job of recycling this you will not
have any sediment. If you do not store it for long periods of
time/ if you go ahead and reuse it/ you will not have any
sediment. And also, I would like to point out that different
states have their own levels as to what is required on the E
and F lists. For instance in Louisiana under our environ-
mental quality law we have a zero tolerance.
QUESTION from Roy Detweiler:
Are you saying you could put the sediment back in and just
spray it on?
ANSWER - Butch Calhoun:
You should not have a sediment. If you reuse the washwater
within a reasonable length of time there will not be any sedi-
ment in the tank.
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QUESTION from Roy Detweiler:
You think that would depend upon what the nature of the chemi-
cals are.
ANSWER - Butch Calhounr
Yes, but then all you have to do is wash the container out and
take that washwater and use it. We have not experienced any
problems with this in a year's use with all of our
applicators.
ANSWER - Bob Ehart:
In the interest of making sure that we do not get by without
answering everything, I think that there is another part to
that question on "can I put it in the dumpster". I think you
better check with your state disposal people as to whether
they will authorize that. And you also better be careful from
the standpoint of the landfill that it is going to have the
right regardless of RCRA regulations to decide that they are
not going to allow for that or the transporter to make you
manifest it regardless of whether you have enough waste or
not. It is something of where the transporting industry is
often times a lot harder on waste generators than what the
RCRA regulations are in order to make sure that they stay as
low on the liability scale as possible. That portion of the
question to be addressed to the fact that yes some states may
allow you to do that while others would not do it for the
moment.
QUESTION:
We have heard lots of good information on costs of treatment
options. Please comment on the impact of costs of obtaining
RCRA permits to conduct a treatment. Address especially cost
impacts on small applicator operations.
ANSWER - Ray Krueger:
That is a little out of my field because I am not involved in
permitting but the costs of those things are largely dictated
by two things. One is the preparation of the necessary docu-
ments to apply for a permit and in some cases that can be
quite tedious. And the cost of permit application levied by
the state. It would vary from location to location and permit
to permit.
The label improvement program of OPP provides for specific
disposal instruction on containers for toxicity categories
one, two and three. Any plans in EPA to implement new label
directions and when?
It is still in the draft stage. But I think in the long term
we are going to definitely implement changes in those label
statements. We have to. In the short term we will probably
try to change some of those label statement that are counter
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to good disposal management practices. But to make signifi-
cant changes in the disposal statements in the future, we will
have to publish guidelines or inform the registrants of what
sort of data they will have to supply us to verify the value
of that disposal statement or the effectiveness of it. So
those guidelines will take probably a year, at least, to pre-
pare and publish.
QUESTION:
Vendors/ users and permit writers who want information on the
relative merits of individual processes or combination of pro-
cesses for a typical wastestream. What effects are being made
to establish experimental design protocols or reporting proce-
dures so that the evaluation of processes will yield a compar-
able basis rather than a confusion of dissimilar experiments?
How about providing current researchers with an information
scenario and getting them to develop practical solutions?
ANSWER - Bob Ehart:
I guess he wants to know what would be considered a standard
mix. And just anybody might want to comment on that. Is that
a possibility?
The only thing that I can think of that has an application is
the fact that RCRA in their last amendments finally came up
with an ability to allow for research and possibly as we go
along there will be some standardization, some recognition of
the needs for protocols and possibly in the future that type
of thing.
It is definitely a very important question from the standpoint
that the research that we see going on frequently is not done
in a basis of allowing easy comparability. It is something
that us black hatted people, who are trying to make sure that
there are not any loopholes, need to know those kinds of
issues. So I think it is a very appropriate one and possibly
we can help the EPA wrestle with from the state perspective as
well.
Any other comments on that?
COMMENT:
EPA has the power to control the waste container problem by
making the manufacturer take back for refilling all contai-
ners. They are the ones who created the problem, let them
solve it.
RESPONSE - Ray Krueger:
The industry has been very reluctant to even talk about that
sort of thing. I have to agree that they have a good point
from the standpoint of liability. Because they have no idea
what has been done with that container after it goes out of
their control. Difficult process to enforce.
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QUESTION:
We continue to hear about agricultural chemical waste. Is
there as much effort to find other generators/ such as dry
cleaners/ garages/ labs/ hospitals/ etc?
ANSWER - Bob Ehart:
I will take Matt's role on that one. Yes indeed there is and
I think that the groundwater contamination issues are probably
forcing the focus on a lot more of those particular issues as
well. I think that in some ways the fact that some of the
pesticide user industry people are interested in forming their
own destiny/ which is a very important factor/ and the fact
that the pesticide is not a major priority for solving prob-
lems on EPAs scale and list of their priorities means that it
is these kinds of efforts that do identify problems/ do create
enforcement situations that maybe if we did not deal with them
would not have immediately. But they are- going to happen
eventually and we are better off to handle it now than we are
in the future. It is important to recognize that we are only
a small piece of it and we are not a priority in some senses
and we have to elevate that priority to solve our own
dilemmas.
Roy Detweiler:
If there are no further questions,
panel for their work.
I would like to thank the
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USERS' SUMMARY PANEL
Harold M. Collins, Jr., Panel Chairman
Executive Director
National Agricultural Aviation Association
Richard Byer
Director of Natural Resources and Safety
Louisiana Farm Bureau Federation
Robert M. Russell
Vice President, Government Relations
Orkin Pest Control
William T. Keane
Attorney at Law, Phoenix, Arizona
Roy Detweiler:
Our,final panel presentation will be from the users of
pesticides.
First is Harold Collins, Executive Director of the National
Agricultural Aviation Association. He has had 18 years in
sales and marketing with the pesticide industry and he has been
two years as a research biologist in pesticides and of course
he is at our headtable. Very instrumental in putting this
meeting together from the very beginning and he is a good
friend.
Next to him is William T. Keane who has the unusual credential
of being an attorney/ a PhD toxicologist/ he also has a BS and
MS in chemistry/ he is chairman of the Arizona Trial Lawyers
Association for six years and is currently their president. He
has been appointed by the Arizona governor/ Governor Babbit/ to
form a committee to recommend ways to minimize public exposure
to pesticides and he is author of numerous articles and papers.
We also have with us Richard Byer, he is with the Louisiana
Farm Bureau Federation/ where he is Director of Natural
Resources and Safety and he has been for the past twelve
years. He lives in Baton Rouge, Louisiana. His areas of
responsibility with the Farm Bureau ranges from tractor and
farm machinery safety to pesticide safety. He is past
president of the National Institute for Farm Safety/ a member
of the Ag Division of the National Safety Council and a board
member of the Safety Council of Greater Baton Rouge.
Last, but not the least, is Robert M. Russell, who is Vice
President, Government Relations with Orkin Pest Control in
Atlanta/ Georgia. His job responsibility is to contact state
and federal officials to instruct in pest control, the regula-
tions and coordination with the industry and also with con-
gress. He advises his company on regulatory requirements.
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With that I will turn, it over to Harold Collins, panel chair-
man.
Harold Collins:
I just wanted to let .the audience know, this morning/ that this
panel has been selected to give a representation of the user
community since this workshop has been orchestrated to provide
assistance to the user community and therefore we felt that
this would be an appropriate time to critique what we think has
been accomplished with the first and second National Pesticide
Waste Disposal Conference.
I can tell you that for many years, users have felt a little
bit .like the boy that the parents had to tie a porkchop around
his 'neck to get the family dog to play with him. We get real
unpopular in some areas of the world. We want to do better.
We need help to do better and I think the recommendations from
this group/ representing a wide range of users, applicators/
perhaps can give direction to the future. I am most pleased
with some of the direction that has been suggested by those
presentations earlier throughout this week.
First we will start our panel with Dick Byer from the Louisiana
Farm Bureau.Federation.
Dick Byer:
Thank you Harold. If you looked at your program you saw the
name Mark Maslyn on there. Mark is our man in Washington for
the American Farm Bureau. Unfortunately Mark could not be here
and I was asked to step in for him.
It is very difficult to speak for all farm bureaus, for all
farmers, obviously. The point has been made/ and well made,
that regulations and rules should vary from state to state and
local to local. Farmers and ranchers are the major users of
pesticides and other chemical products that serve as production
aids in modern agriculture. They are the final resting point
for pesticides. We believe there is a commensurate responsibi-
lity that these products be used and disposed of in such a way
that they pose no risk to the environment of which their neigh-
bors, family and farms are a part in that fact. Unfortunately
this seems to pass by a lot of people some times. Farmers are
true environmentalists.
Agriculture is not much different than many other segments of
society. The scope and understanding of the pesticide waste
disposal problem ranges from the careful and the conscientious
user to the uninformed or those that frankly do not care. I
guess that we are really not that much different from other
segments of society.
From that standpoint, we believe that there is a fundamental
need for much more information addressing the problems and the
potential risks, and what individual farmers and ranchers can
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and should do to address these issues. There is a strong need
for user orientation. I have seen some presentations here in
the last couple of days that were very much aimed in that di-
rection. I have seen some that frankly would have left a lot
of farmers still in a quandry.
In recent years there has been a growing appreciation at the
farm level/ of the problems associated with the disposal of
pesticide wastes. Farmers need the how to's. How do I comply
with the rules and regulations. How do I actually do what
these laws say. Farm bureaus and state extension personnel and
others/ need to continue to address this need. Farmers need
very specific information on the options available to them in
disposing of the waste products and the product contianers. We
would welcome the fact sheets that we heard mentioned from EPA,
from manufacturers and others. And we would suggest that these
be distributed as soon as possible and be geared to production
agriculture.
There is a need to clarify the confusing and sometimes conflic-
ting federal and state rules and regulations regarding the
disposal of hazardous products. There needs to be more conti-
nuity/ more conformity. We have talked about that the last
several days and we firmly believe that.
We believe the subject of pesticide containers, and we think
this is a big one, needs to be addressed. We believe these
need to be addressed from the standpoint- of all users. Whether
they be commercial applicators, individual farmers and as it
was mentioned this morning, or the homeowner who purchases
pesticides. The lack of uniformity in the sizes, shapes and
material of pesticide containers, also presents practical dis-
posal problems and we have discussed that.
I would like to mention, coming from Louisiana, that we in that
state have made great strides in" eliminating much of the confu-
sion. A lot of the conflicts between the various state and
federal laws and regulations, through the efforts of people
like Butch Calhoun, who was on a panel prior to this, and
Darryl Rester, whom you have already heard from. We think that
we have a pretty good working organization down there of Farm
Bureau and Extension .and the State Department of Agriculture
and as Butch pointed out some pretty good understandings bet-
ween our Department of Environmental Quality and our Department
of Agriculture. We like having agricultural situations within
the Department of Agriculture.
In conclusion, I would suggest that next year's program might
feature a user panel made up of some farmers from around the
country. These are the folks that will flat tell you, in a
hurry, this works, this does not work, we like this, we do not
like that. We think they could shed some real light on what is
practical, what is realistic, and what is financially feasible.
Thank you.
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Bob Russell:
Thank you. I guess I will have to throw away my first line/
because I read on the program where I was going to be last. I
thought well at least there is some distinction in being last
even if there is no honor. But, I lost that.
It is certainly a pleasure to be here today with what I con-
sider a very learned group/ and to hear the available science
of what we can do with pesticide waste disposal.
I represent the structural pest control industry and we do not/
probably, measure up in as far as quality of pesticides are
concerned. But in as far as applications are concerned/ our
industry probably makes something like half a million pesticide
applications every day. So we certainly have some concerns in
as far as the field of hazardous waste are concerned.
With the present state of the science/ and the degree of regu-
lation that is required, I really do not know whether to be
frightened or frustrated or both. The requirements seem to be
this, and the results that we have to obtain are this/ and the
way between one and the other is sometimes very very difficult
for us to ascertain.
In structural pest control today we see three problem areas.
The first is in facilities for disposal. The second is the
methodology of the land disposal that we can use at our branch
or site locations. And the third is the degree of regulations
that we must sustain.
First/ I would like to say that our industry has a strong
objective not to be generators of hazardous waste. We hope
through full use and re—use to stay under the two hundred and
twenty pounds per month/ per location that would throw us into
a small quantity generator. We would prefer to stay a very
small quantity generator, under that two hundred and twenty
pounds.
We have run some tests/ both for our company and for others in
our industry/ and we think that in most locations we now can do
this. But we do not look at this as a static situation and we
feel that we have got to look ahead and make sure that we con-
sider the future probabilities.
As far as the land facilities are concer-ned, it is our under-
standing that there are now something like six hundred land
facilities in the country. And I believe that EPA has advised
that only about four hundred and ninety-two are certified for
the RCRA requirements. So their preliminary estimate is that
something like eleven hundred of these facilities may close.
Our ability to use the remaining will thus be probably more
expensive and therefore less convenient.
Also, some of these facilities now will not take our triple
rinse containers. They just refuse to take them. And some of
them will not take aerosol containers. And aerosol as a part
of pesticide applications have become a very significant part
of our technology.
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Now, our methods for onsite disposal, other than the landfill,
are very limited and expensive, at this time. I say this be-
cause many members of our industry are relatively small compa-
nies. The technology and the cost of the proposed or develo-
ping technology may be beyond their means to assimilate. So we
need some kind of a backup and we hope at a reasonable level
that our members can use at this level.
The degree of requirement is probably our most severe problem.
And it could have been even worse had it not been for an EPA
ruling that gave us the ability to dispose of rodenticide base,
up to the two hundred and twenty pound level. Without this
ruling our full use and re-use policy would be in jeopardy at
our larger locations.
We have some concerns about truck wash rinse. It is our
understanding that the aerial industry has secured an exemption
on this and we hopefully would like to qualify for the same
type exemption because the amount of rinse and the percentage
of toxic in that rinse coming off of a truck is a very, very
low level of a pesticide.
We have some concern about our sites or branch locations.
These are places where we store chemicals, where we wash our
trucks/ and where we fill our pesticide tanks. Our sites are
identical to thousands of' commercial applicators all over the
country and to hundreds of thousands of private applicators.
We all have the same conditions that we have created over the
years. This gives us some cause for concern because we really
do not know exactly where we stand on these sites and what the
future possibility may be.
Insurance is a problem for us. Premiums- are up and they clause
pollution and contamination, which is really the clause that
would cover us in as far as hazardous waste situations are
concerned, is being dropped out of the policies.
There was a recent bill in the Congress that I really liked.
It did not pass. It was HR3418 by a freshman congressman out
of New Hampshire. In this bill he set up a limitation on lia-
bility. If the operator involved would come forward and do the
cleanup/ and this bill would say that there would be some limi-
tation on liability so that it could be carried no farther past
his cost of the cleanup. I think somewhere legislatively, we
have got to look at something like this. The cost of claims,
the cost of settlements has continue-3 to escalate and we are
not alone. The insurance industry all over the country is
having problems but that is a problem for us, in particular,
because it is involved with our hazardous waste.
At^this stage I think we need some kind of a cooperative com-
pliance for us to get from this to here. There are no really
clear roadmaps for us to negotiate that tortuous trail so we
need some understanding as far as compliance is concerned. I
hope perhaps that we can work out or work with some kind of a
stage by stage progression in accordance with the science that
we have at this time.
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If there is a eminent hazard to health or to environment/ we
are going to get in and clean it up. We will do that. But if
it is a potential hazard to health or environment, or not so-
mething that definitely establishes a danger, then we would
hope that we could utilize some stage by stage progression and
work the situation out while containing and preventing any
further spread at the time.
Right now I see four short term objectives for our industry.
The first is some provision of land facilities for our cur-
rently generated waste, both hazardous and solid. The second
is control of waste being generated through management.
Through management I am talking about our full use or re-use.
In full use we want to make sure that we calculate the dose
required for the job and try to use it all up. Always there is
a small residue left that we use on that job but this has to be
in compliance with the label. Also we hope that there can be
some better science for on site control. Three, I hope that we
can gain some cooperative compliance on the sites and the prob-
lems, which there does not seem to be any practical solution at
this time. And four, I too, and it has been mentioned here
earlier, would like to see the appointment of a state lead
agency for the guidance and the regulation of all pesticides
uses. And certainly there could be backup for knowledge here
in both the land grant universities and USDA.
I think this conference has been interesting and informative
and I really believe that it can be a beginning towards a di-
rection of some type of a solution. I want to thank you very
much for letting me be a part of this today.
Bill Keane:
It is indeed "a pleasure to be with you here again, for a second
year in a row and I would like to apologize at the outset for
ray relatively husky, broken voice. I am truly not a country
western singer or a bouncer it is just that I have picked up a
clasic case of strep throat and I apologize for that. In fact
I guess that puts me in a unique position. This might be one
of the few presentations I get to make in my life, where it is
more painful for me to give it than it is for you to sit
through it.
At any rate, the first triing I would like to do is thank all of
you for attending. You know this is a unique mix of people we
have here and all of you have come forward to try to solve the
problems of ground and aerial applicators. I think the Dan
Baker, luncheon speaker on Monday, was entirely appropriate for
this group because he says you get the most enrichment out of
life when you give to other people and help them solve their
problems. That is what all of you have done. You have given
of your talents and your expertise to try to solve the problems
of ground and aerial applicators.
I had the distinct pleasure of being with you last year and I
was asked to be here on behalf of the aerial applicators and my
function last year was to try to summarize for you some of the
problems that they felt they had and to outline for you what we
thought our problems were.
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I would like to look back over the last year/ again through the
eyes of the ground and aerial applicators and give you some
idea of where I thought we have come and what some of our
future problems might be and maybe what some of the solutions
are.
Last year I stipulated at the outset that all applicators vio-
lated RCRA many times each year in doing their work. At the
end of the 1985 program when I was on a summary panel, just
like this/ I informed all of you that the applicators were
frustrated. We knew that we were confronted with RCRA/ we knew
we had to comply and we knew that the scientific techniques
available to comply did not exist and we felt that the workshop
had not provided those to us. Vie wanted immediate solutions
and we are coming to the rash realization that immediate solu-
tions are not readily available.
One year later/ if you talk to the applicators/ they are still
frustrated. They still have all the same problems that we had
before. I am not aware of one technique that has yet become
commercial out of these meetings. Some of the solutions appear
as though it is going to be many years of research before they
will come to fruition. But having said that let me hasten to
add that there is some guarded optimisim among applicators. We
now perceive that the regulators and the researchers recognize
the complexity and significance of the applicator problem. We
see bright minds in research dollars being infused into this
particular area. We know that lines of communication have been
opened up among diverse groups that did not exist one year ago.
Again/ however. I must stress that many of the critical prob-
lems we have appear to have solutions that might take years to
unfold. If research is not the immediate answer to our prob-
lems/ then maybe an innovative regulatory approach may be the
solution.
I heard some speakers recommend that the regulatory control of
pesticide hazardous waste be shifted from RCRA to FIFRA. As an
attorney/ it is my opinion/ that if properly implemented/ the
regulation of pesticide hazardous waste under FIFRA would be
equivalent in effect to regulation under RCRA. And equivalent
protection of man and the environment would result.
What other innovative regulatory approaches might yield more
rapid solutions to our daily problems? Maybe EPA could develop
various approved agricultural practices and once these approved
agricultural practices are implemented by ground and aerial
applicators/ a rebutable presumption would exist of compliance.
Now what am I really saying/ let me give you a practical exam-
ple of what I mean and let me lay some background or foundation
for this example.
The one objective that I have heard mentioned here over and
over again is that one/ we should minimize the amount of
rinsate and two/ let's do what is necessary to prevent
pesticides from impacting the soil.
One method of preventing pesticides from impacting the soil is
to build concrete pads and above ground piping and above ground
tanks to store rinsate to re-use it again on crops. Now if the
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EPA would approve a blueprint for the construction of such a
facility and if an applicator built such a pad/ in compliance
with that approved blueprint, a rebutable presumption would
exist that he indeed was in compliance. In this manner/ and if
this went into effect/ applicators would be given the security
necessary before making these substantial financial expendi-
tures to build these facilities and that have confidence that
the agency would not change their minds six months or a year
later/ and conclude that this wasn't what was really needed/
you have got to tear it all up and start again.
The things I am recommending suggest to me that regulators must
be courageous and innovative in attempting to find solutions
for some of these problems. Now I recognize and all applica-
tors recognize that the EPA knows a lot more today about these
problems than they did a year ago. We recognize that they are
going to know a lot more about these problems five years from
now/ than they know today. But in the applicators opinion,
this should not be used by regulators as an excute for failing
to take some bold innovative regulatory steps to solve these
problems now.
Since I have just talked about cement pads and above ground
tanks/ let me give you one additional observation about tanks
to store rinsate. I think that is a great idea and I am glad
it works in Illinois and some of these other states but it
appears to me that some of those states where it does work and
has been tried have a mono-culture. I come from a state where
we do not have a mono—culture. We have tried to sit down with
some of the ap'plicators and decide how many tanks we would have
to have to store rinsate due to the large variety of crops that
we spray. The answer is we are going to have to have fifteen,
eighteen/ twenty tanks sitting there and that just makes it
prohibitive. Does it mean it is not a good idea/ no. Does it
mean we should not follow it up/ no. What it may suggest is,
this is another area where we need some innovative regulation
that permits us to maybe condense those down at least for the
rinsates for similar crops or the same crop. Rinsates con-
taining pesticides for the same crop could all be put into the
same tank.
Last year I told everyone in attendance that there was a lack
of consistency in the interpretation of RCRA by regulators.
This problem still exists and I want to give you an example.
At this workshop some regulators have suggested that the way to
contain rinsate is to build either tanks or surface impound-
ments that are in the ground and level with the ground surface.
Yesterday in a meeting/ an EPA regulator said just the reverse.
He would never do that/ he would always put them in above
ground tanks. So here at a meeting/ a year after/ we have been
addressing this problem for the first time. We are hearing
different EPA people say different thing-s. And if you are an
applicator without a lot of scientific knowledge, and if you
are not an engineer/ and all applicators are not, you are get-
ting mixed vibes. They do not know how to interpret those
signals. I think by now that should have been resolved and EPA
should be speaking with one voice. And I suspect that EPA
would oppose the use of all concrete structures below ground
level. And they would want all structures to store pesticides
above ground.
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One year ago when I stated that there was no. uniformity of
enforcement of regulations I gave some examples. Well it is
still going on and I want to give one more. I have been in-
formnd that some companies that do business and have plants in
more than one region, shop from region to region to get the
most favorable interpretation of RCRA. Now most applicators
operate in just one region and therefore they are denied this
preference. They do not have the ability to farm shop. The
moral to be derived from that example is that we need uniform
regulations and uniform enforcement for all pesticide users.
And I want to stress the word all.
Now I told you a year ago that even the best nozzles on ground
rigs and aircraft used to spray pesticides indeed leak. They
contaminate the soil and soil contamination is one of the big-
gest problems we have. In fact the biggest problem we have is
the soil contamination that is built up over many years of use
of this type of equipment. Now this is the best kind of equip-
ment we can buy and even with the optimum maintenance the noz-
zles still leak and we still contaminate soil. That means if
we clean up today, I am here to tell you, we are going to re-
contaminate tomorrow. We know it, we do not like it, but it is
something we have to live with.
Now what I would like to do is encourage researchers to work on
these kinds of nozzle problems. It would greatly assist us in
preventing future contamination.
I would like to give you one last observation on this major
problem of pesticide soil contamination. Last year applicators
admitted that pesticides in soils had accumulated over many
years of use and this was their major problem. The research
reported last year and this year provided no immediate solution
to that problem. That is the problem that is going to cost us
millions and billions of dollars to clean up at each applica-
tor's site. That is the problem, that is going to put each
applicator out of business. At the EPA workshop in Cincinnati
I was fortunate enough to be asked to attend that. It was
likewise concluded that there were no immediate engineering
solutions to that problem. So last year and this year I recom-
mended a solution to the problem by spreading that contaminated
soil on existing farmland. And by analogy/ if we are now re-
commending, and that is what we have done at this meeting, that
rinsate containing pesticides can be applied to that farmland
why can't soil containing those pesticides, at similar concen-
trations, be applied to the same farmland. If what we are
doing is regulating pesticides chemicals why should it make any
difference that they are in rinsate or soil at the time they
are applied to farmland.
At the EPA workshop in Cincinnati, in July 1985, when it was
concluded that research had 'no answer to solve this problem,
one EPA employee concluded that maybe a three to five year
moratorium should be imposed in the enforcement of RCRA on
these soil contaminations alone. On just the limited, well
circumscribed problem. This would grant researchers, such as
many of you in the audience, adequate time to do the job that
you have started on to solve that problem. This type of
approach of a moratorium on citing applicators for contaminated
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soil might be another example of a courageous and innovative
regulator approach required to address this momentous problem.
In conclusion/ I guess I would just say/ when you talk to
applicators they would agree that as a result of these two
workshops we have come a long way baby. But indeed we still
have a long way to go. Thank you very much for your attention.
Harold Collins:
One of the nice things about attending a conference like this
is that you get enough smart people and they say everything
that needs to be said. The next trick, I guess, is implementa-
tion of the things that were said, to make things possible, to
make us able to comply with the law. I guess from another
applicator point of view you have done good and we need to do
gooder, if you will pardon the expression.
We would like to see, as many have spoken here, uniform regula-
tion of all users with regard to,disposal. If you took, and I
have been corrected on t-.he pronunciation of this by our asso-
ciation president, Stan Jones, the Ogalala reservoir, or aqui-
fer, it extends from Canada down to Texas. There are many many
users of pesticides in that geographical area, including com-
mercial applicators who are indeed regulated, including farmers
who are exempt, including homeowners, who have really no cont-
rols, and including government, who has wide use of pesticide.
When and if a material, the presence of a chemical, might show
up in an aquifer, what is its source? I think all of us would
agree that all of us need to take every effective action we
can to preclude the presence of chemicals in areas where they
are not wanted. And remember too, that I am carefully avoiding
the word contaminant. I am talking about the presence of che-
mical. Looking in the dictionary, the word contaminant is a
red flag/ it means bad. The presence of chemical is not neces-
sarily bad and I think we need to be careful of the words we
use because sometimes we are terribly misinterpreted/ particu-
larly by persons who do not have the time to spend, as you and
I do, devoting our lives to these kinds of problems.
Uniform regulation, we think, is necessary and will go a long
way toward creating the public awareness that is needed to keep
our health and environment in as safe a condition as we can
possibly do.
Number two, we need acceptable methods to minimize, eliminate
and handle these pesticides wastes. A moratorium, as Bill
Keane has suggested, is indeed a consideration. Particularly
in light of historical problems over which we had no control.
We lacked the scientific knowledge and expertise to know we
were creating a problem and we have since enacted legislation
that says it is bad and we are in some cases punishing the
wrong person. Indeed what we end up doing is a money hunt. We
are looking for someone to pay a bill for something that was
done before anyone knew it was not good.- We need to look at
these situations. Let's let science catch up. Science does
wonderful things. Our society is as good as it is because of
science.
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We need to take some calculated risks. As Phil Kearney said, I
believe last year/ if not he said it to me sometime this year/
we have become a society of "what if's." "What if" is indeed
the realm of a scientist and we benefit from that but we can
have too many "what if's" and we would end up doing nothing.
If we took every precaution nothing would ever get done. The
best thing to do is the status quo. We are not in that situa-
tion. Whatever we do it must be affordable/ efficient/ and it
must be practical within what we now know is the state-of-the-
art.
Number three. I think we need to begin directly to modify the
regulatory inadequacies. This will have to involve the commer-
cial/ the private/ the farmer and the urban citizen. Because
we currently we have an inability to comply with the law and
that has been described to you fully. The law' the statute
currently contains section 19 in the FIFRA which provides the
administrator with the authority to deal with disposal of pes-
ticide materials. The fact that some pesticides are currently
regulated under RCRA should not be a major problem because it
is the same administrator of the Environmental Protection
Agency who is responsible for the implementation of both laws.
That is merely then an administrative challenge and I think
working together a group like this can accomplish this.
The pesticide label will have to play a part in the matter of
disposal. At this point in time/ I believe I am correct in
sayihg that when a person does something inappropriate it may
only be prosecuted/ at least from the point of view of the law/
if it is on the label. Now that is dealing with pesticides
under FIFRA. So I think we need to work very hard at the pro-
per language/ recognizing our limitations of something that
could address the problem. To punish those who wantingly vio-
late the label or health or environmental situations and yet
provide a measure or protection for those who are doing their
very best. And certainly their very best within the tools you
have provided us.
We need further uniformity among the federal regulators. It
has come to pass in the last few years that because of the lack
of uniformity/ those of us who are in the business of worrying
about things can shop among various segments of the federal
entity/ for the best answer and then get that one on paper and
put it to work. That has some benefits but I think it has more
dangers. And so I think we need to stress more and more uni-
formity in the concerns. We need more time on how to regulate
rather than what to regulate. All too often someone will pick
a chemical and then it is totally misinterpreted. And I would
site one example that occurred this past year. This was a
media presentation. There was a chemical that was put on wa-
termelon in California that allegedly created a problem. It
made people ill. This is very inappropriate. We all agree to
that. But we blamed the chemical. The chemical had nothing to
do with it. It was the misuse of the chemical. Someone inap-
propriately used it and therefore they should feel the full
burden and responsibility for that action. So let's bo careful
what we blame and let's worry about how to regulate everything.
Let's not get so detailed on one particular thing. Let's look
at the overall issue.
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Recognize there are 35,000, approximately, registered chemical
products, probably involving 1,200 active ingredients. We can
not work on each of those individually considering the length
of time it would take to come up with definitive information.
There is a level of risk here. But certainly pesticides are
among the most tested chemicals known to man. In order to
obtain a registration for a pesticide product it must go
through elaborate and ever changing questions. And a regis-
trant who successfully gets a product on the market today will
probably be asked next year for an entirely new package of
information that no one had thought about before and it is what
if kind of situation. So let's deal with real problems and
let's get a little bit away from some of the conjecture that
really does not address the day to day real life activities.
We fully support, we continue to support the localization of
information. We have members in our industry who are contacted
by as many as five levels of state government, essentially all
asking the same question. And more important, all essentially
involved in the same process. The attempt to protect human
health and the environment. We would like to funnel all of
that, as Bob Ehart suggested last year, it is an innovative
idea on his part and many others have mimicked since, let's get
the state lead agency and/or the land grant university and/or
USDA as the place for people to go to ask questions about us.
This communication system has been in effect for many many
years, it is effective, it has worked. American farm produc-
tion is a classic example of that communication system. Anyone
who wants information from it, we would like them to go there
for it. The information in many cases, already existed and we
are asked to duplicate. We need to stop some duplication.
Another problem with this is that because of various enforce-
ment groups putting these issues among various regulatory' agen-
cies we complicate the problem and we confuse the user commun-
ity, we throw up our hands and we do not know what to do. By
localizing, by centralizing, I think you will find we will very
readily comply and will participate with you.
Finally, I am very impressed with Bill Keane's statement regar-
ding the rebutable presumption. I think that the user commun-
ity could support this concept so that we will fall within the
regulatory scheme with things like pads or tanks, so that we
are not considered inadequate or that we are illegal doing
something. Rather we have time to do the best we can for now
and adapt later but recognize there are finite financial re-
sources available to permit us to construct something and learn
only a month, a year later that that is no .longer adequate. So
there is part of the challenge, will someone give us the per-
mission to be able to expend funds and have some assurance that
we will continue in compliance over the reasonable life of
whatever it is we are expected to do.
This would provide for an automatic permitting. This is a very
interesting idea, and would be allowed if we shifted some of
the administrative out of RCRA and into FIFRA. I think, as
Bill has suggested, it does provide an opportunity for equiva-
lent protection and I think even more important it might be
very politically desirable.
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Finally, I would like to challenge the group here. I think
that all of you are to be commended for your interest. I think
we now need to get together and implement the thoughts and
ideas in a very formal way with full cooperation. By doing so
we will reduce the confusion out there. But more important/ we
need to reassure the public that there is an effort being made
and that the bad bad things that are constantly being thrown
toward them can be reduced.
How many times/ for example/ have you seen the media run out to
the airport and interview the captain of a 747 airline that
just landed successfully and ask how did you do that. Rather
they would go interview,the observer of the crash or the survi-
vor. So let's take a more positive approach on this issue as
well. I would like to challenge you to take a more advocacy
role. Let's help educate more than us/ let's spread the mes-
sage out to other people/ they too have good ideas. And let's
assure them that there are risks. There 'are things we do not
know but we are indeed being positive at" this time. I think
the education concept is an answer and I would encourage you to
do one final thing. There are applicator organizations nation-
al in scope with regional locations. I would like all of you
to take opportunity at some point in each year and attend their
state/ regional or national meetings. Visit with these folks.
I think they are another source of information. These are the
people who are on the day to day firing line. They can give
you even more indepth if not colloquial descriptions of their
problems.
Finally/ I would like to take this opportunity to thank a
gentleman who has busted his back and is very very effective
do not know of any other time we are going to get away with it.
Roy Detweiler/ he has brought this conference to this position
in two years of a lot of hard work and I sure hope if we con-
tinue into the future that-Roy's leadership will be a part of
it and I would like to thank him personally.
As one final thought. Again going back to the user attitude.
I would compare Winston Churchill with the user community and
Lady Astor who hated his guts with the other side of the fence.
On one occasion Lady Astor was known to have said to Winston
Churchill/ "if you were my husband/ I would put arsenic in your
coffee." To that Mr. Churchill replied/ "if you were my wife/
I would drink it." Thank you.
QUESTIONS AND ANSWERS
QUESTION for Bill Keane:
The first question deals with the issue of EPA approved facil-
ities. If EPA would approve site construction and/or
equipment/ when the real problem actually be in the operation/
how would operators be assured of appropriate operation?
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ANSWER:
I agree/ that is a problem, -jfhat one has not been solved yet.
Let me tell you why I have suggested and recommended this.
Some years ago, regulators told applicators in Texas that the
way to handle rinsates was to dig a surface impoundment. Some
of those were bulldozed out of the ground, some of them were
lined with plastic, some of them were lined with concrete.
Subsequently those same regulators came back and said now you
have just created a major problem. How do we know you did not
leak down to the groundwater table. We have defined it not to
be a tank but a surface impoundment so therefore you must sink
wells, you must monitor your groundwater, you must monitor for
every pesticide you have ever applied on your property. Now
let me give you 'another example. Let's not kid each other.
What is happening to rinsate today? It is going on the ground.
And what if an applicator calls me and says Bill, give me some
legal advice. What can I build today with some degree of
assurance, that it will be legal five, ten years from now. It
in itself, will not be declared hazardous waste and I will not
have to dig it up and transport it to a permitted landfill.
The answer to him is I cannot give you any advice. I can give
you some technology, I can give you what some of the engineers
are talking about, I can tell you what sounds good, what looks
good, but I can not give you any guarantees.
Last year we told you that the average applicator in the United
States had one and a half aircraft and had one and a half
pilots. That is the size of the industry we are dealing with.
They can not afford to build a facility and two or, five years
down the road tear it out and start over again. I think Bob
Ehart said it more eloquently than I ever could. We have to
bite the bullet and we have to do something that looks like a
reasonable solution to the problem. Cement pads, above ground
tanks. I think we ought to do it. Could there still be misuse
of that? Sure. Could citations result?. Sure.- If they do not
burn it up, if they do not have cement or concrete curves and
they splash over in the soil, sure there is a problem. But I
think we just have to move forward and solve this problem with
pesticides on the soil.
QUESTION for Bill Keane:
The next question. It is really a question for everybody on
the panel. Could anyone on the panel say how much a user might
be willing to pay for disposal, particularly the price per
gallon of the liquid waste?
ANSWER:
From my standpoint, the answer is no. The reason is this.
Over the last five years I have seen applicators' businesses
change dramatically. They are much more cautious trying not to
create hazardous waste, they are more cautious not to create
excess rinsate so that the volume that we need to treat conti-
nually is being reduced and as that goes down, I suspect with
that minimal volume that is left over, the amount that we are
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willing to pay to get it treated could continually rise and it
would still be appealing to applicators. I do not know if
anyone else on the panel wants to address that.
COMMENT:
With respect to surface impoundments/ they are regulated by
RCRA but indeed if you just develop above ground tanks and you
want to re—use that pesticide you do not need a permit.
ANSWER - Bill Keane:
That is exactly true. It falls under the farmer exemption in
RCRA and indeed that is one of the reasons why I think many of
the people at this meeting said look/ let's create the cement
pad/ the above ground tanks for the rinsate and let's re-use it
because no permits are required. If you get a surface impound-
ment then you must apply for a permit. Most people can not
produce permits to give to themselves. They incur a substan-
tial amount of engineering and scientific consulting fees and
it is a long drawn out process and then and only then does your
paper work really begin. Because once you are permitted for a
permitted facility there are copious amounts of records you
must keep. I think the goals of applicators are not to become
permitted facilities. We do not want to be permitted.
QUESTION for Harold Collins:
Why doesn't industry sponsor milk runs? They could do this
instead of complaining about the. government not solving a prob-
lem. That is industry's responsibility.
ANSWER:
Well I think/ number one/ we are trying to take a noncomplain-
ing mode. We are trying to draw attention to the problems we
are facing so we can maintain our businesses. I think there
has been a clear demonstration of a much broader communication
between government/ user/ state regulatory/ research community/
land grant/ university. So I see progress going and I think we
are still asking/ as most people always do/ when we have a
problem/ we would like someone to assist us when we are in-
capable of it.
QUESTION for Bob Russell:
I applaud your efforts at waste minimization. Given the small
business size of your members/ the type of products you use/ to
assure your members tend to be concentrated in urban areas/ is
it reasonable to allow even two hundred and twenty pounds per
month in a local landfill? For example/ ten applications in
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the field is ten to twelve tons of fairly toxic materials going
to a landfill not prepared for such compounds. Wouldn't a
better approach be to never take them to a landfill?
ANSWER:
I am frustrated again. When I mentioned a number of applica-
tions/ many of those are a very small quantitiy of chemicals.
It may be only a quart of chemical in a residential application
and I do not think that too many of our chemicals go into the
landfills right .now. I am just not sure that the problem that
seems to be in vision there is a problem that we have.
Anybody else want to comment on that. Harold.
ANSWER - Harold Collins:
In addition to any accumulated waste from a commercial opera-
tion/ I wonder if anyone has ever also evaluated the amount of
homeowner pesticide purchase. Again not necessarily restricted
chemicals because I think all of these should be treated as
heavy weights/ all chemicals. Has anyone evaluated how much/
in an urban situation/ is used in part and then disposed of to
the landfill. What quantity of active ingredient are we talk-
ing about coming from the homeowner population. This may be
more significant than that is coming from the commercial opera-
tion. We cannot answer it but I think it does need some con-
sideration.
QUESTION for Harold Collins and Bill KeaneS
Would you address regional differences in pestici.de use with
regional regulations and/or does your call for Uniform regula-
tions fail to address regional differences in use/ soil hydro-
logy/ and environmental impacts.
ANSWER - Harold Collins:
First of all the federal government has transferred regulatory
responsiblity to states so that they must paint a broad brush
picture of implementation of the statute. We do know and there
are indeed substantial differences in pesticide use. For
example/ our people will have a work season of six weeks in the
Dakotas and that is the total time that an aerial applicator
has to work. On the other hand/ those in the valley of Texas/
Southern California/ Florida will work essentially twelve
months out of the year. If you consider these aerial operator
locations which are located in Florida/ where you stick a
shovel in the ground and you get water at the bottom of the
shovel/ versus in the high plains of Texas where you are sit-
ting on top of 2/000 feet of caliche/ we do have substantial
differences that need to be recognized and I believe that I
would share Butch Calhoun and Bob Ehart's comments with their
need to implement and meet the regional or localized needs. So
I do not think there is a broad brush approach for all things
but I think that is the role the state can play.
153
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QUESTION:
Here is one that goes along with uniformity. Users group is
asking for uniformity in regulations but EPA says uniformity is
not possible because each state can set its own guidelines.
What is going to happen, who's idea will win out?
ANSWER - Bill Keane:
....lobbying before legislatures. There is tremendous variabi-
lity as to what laws any particular state will pass. On this
particular topic or any other topic. There is no question that
there are going to be difficulties in getting uniformity. At
this stage of the game when we are dealing about group inter-
pretations of some of the most simple issues, I think there
should be uniformity at least within the various regions of
EPA. And I give you examples where that is indeed not occur-
ring. When we get down to the state level there is not going
to be uniformity from state to state and I think that each one
of us are going to have to work that out in front of our state
legislatures and indeed our state regulators on a case by case
basis and a state by state basis. But one last thing, I find,
at least in my state, that many of the state regulators lean
heavily, at this stage, on the interpretations of RCRA given to
them by EPA. I have been told that region 9 says you do it
this way, so my state has adopted region 9's position. I am
finding out that region 8 does it a different way. Why didn't
my state adopt region 8's position. If we had consistency of
EPA interpretation, and the state is leaning heavily on their
advise and guidance, I think we would have much more uniformity
in the states. ' • ••••
QUESTION for Bill Keane:
The next is a technical issue, but it is addressed to you,
since you are a chemist and toxicologist. I am sure you can
handle it. It says if you take contaminated soil and put it
out over farmland for disposal how do you handle a soil that
contains a mixture of pesticides which may not be compatible
with the crop. For example, in pesticides and herbicides, if
you spread it out on farmland would it require monitoring to
know what is happening.
ANSWER:
It is a broad statement. You cannot land spread all pesti-
cides. Some of them would be incompatible to crops. So the
bottom line is you obviously, number one, have to analyze the
contaminated soil, find out what is in it and then find out
what crop the grower intends to use the field for and then you
would have to spread that pesticide containing soil across that
field at a concentration level or a deletion level that would
be similar/identical to the concentration that you are spraying
on there. So we are talking about a micro-thin layer. It can
be done, vc have done if in some similar situations before RCRA
was passed. Then you would have to monitor the pesticides in
that particular farmers field. To see how rapidly they have .
154
-------
degraded. The better solution/ of course/ is fallowed ground
or non—agricultural ground/ and you heard one example by Mr.
CalhoUn/ that they are using state ground. Which is fallowed
ground. So you do not have to apply it, necessarily, to the
farmers ground, but yes, I agree, you would have to do all of
the monitoring.
COMMENT:
Just a suggestion to everyone, why not a new superfund to solve
the problem contributed to by users, manufacturers and regula-
tory agencies. Another comment. I think a product should not
be allowed on the market until the manufacturer can supply a
neutralizing agent. No one knows the chemistry better than the
manufacturer. Give the manufacturers five years to comply or
remove their product from the market. No one is asked to com-
ment.
RESPONSE - Bill Keane:
Certainly when you list a product, the approved degradation of
this material may not be applicable for the mixture so you are
back to where you started from.
This is a request for technology that really did not exist at
the time that the product was originally formulated. The rules
of the game have changed. .
Many applicators have approached me and said, why cannot a
registrant when he manufactures the chemical attach to the
outside of the container a little packet. And that packet
could be antidote, if you will, or the metabilizing agent, so
that when done applying the chemical we dump, or throw this
little biodegradable packet into our hopper, it neutralizes
everything in the system and what comes out is not any longer
hazardous waste. Well, obviously that is the magical answer.
That is the optimum solution to the problem, but I do not think
chemistry is going to permit us to do that with a wide variety
of chemicals, pesticides, or chemical molecules we use for
pesticides.
COMMENT:
Here is testimonial or comment from the people in the back of
the room. Has Bill Keane ever considered seeking the appoint-
ment to head of EPA. If not, would he consider running for
president. Either position would permit him to solve
the problems of this conference with his common sense
solutions. Do not put him in the empty bus seat, we need him.
With that I want to thank you for coming. Let's give this
panel a hand. We hope for future support when we decide what
to do next. Thank you very much.
155
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LIST OF SPEAKERS AND ATTENDEES
Elaine Acevedo
Director of Government Affairs
Society of American Florists
1601 Duke Street
Alexandria, VA 22314
Marie D'Achino
Supervisor Contract Operations
BASF
100 Cherry Hill Rd.
Parsippany, NJ 07054
Joe Allen
Senior Program Coordinator
Union Carbide Agricultural Products Co
P.O. Box 12014
Research Triangle Park, NC 27709
Scott W. Allison
Product & Systems Development Manager
Monsanto Agricultural Company
800 N. Lindbergh Blvd.
St.' Louis, MO 63167 '
Treva Alston
Chemist
Department of Defense
Defense Losigtics Agency
Cameron Station
Alexandria, VA 22304-6100
James J. Anderson
Senior Scientist-Microbiologist
Crop Genetics International
7170 Standard Drive
Hanover, MD 21076
Ray J. Anderson
Assistant Director
American Farm Bureau Federation
225 Touhy Avenue
Park Ridge, IL 60068
Phillip E. Antommaria
Executive Vice President
Canonie Engineers
800 Canonie Drive
Porter, IN 46304
Hubert Attaway
Microbiologist
Manville
12977 W. Cedar Drive, #208
Lakewood, CO 80228
Patricia Bailey
Pollution Control Specialist
Minnesota Pollution Control Agency
1930 County Road B2
Roseville, MN 55113
Paul M. Bachman
Administrator
. Feed, Seed, Fertilizer & Pesticide
Program
South Dakota Department of Agriculture
445 East Capitol
Pierre, SD 57501
Dan Baker
P.O. Box 93
Bulverde, TX
78163
David E. Baker
Professor
University of Missouri
Columbia, MO 65211
- Columbia
Paul Baker
Senior Research Associate
Cornell University
Room 426 - Barton Lab.
Geneva, NY 14456
Jack M. Banks, Jr.
Hawaii Farm Bureau Federation
293 Kalihi Street
Honolulu, HI 96819
Daniel W. Barber
Container Corporation,of America
1204 E. 12th-Street
Wilmington, DE 19802
Robert W. Bath
Chemist
United Agricultural Products
P.O. Box 1286
Greeley, CO 80632
156
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Joseph M. Beckstrand
Pesticide Specialist
Utah Department of Agriculture
350 N. Redwood Road
Salt Lake City, UT 84116
Gary Beeler
Pesticide & Hazardous Material
Specialist
Pioneer Hi-Bred International, Inc.
5880 Merle Hay Rd.
Box 212
Johnston, IA 50131
Richard A. Beyer
Director of Natural Resources
Louisiana Farm Bureau Federation
P.O. Box 95004
Baton Rouge, LA 70896-9004
Lawrence W. Bierlein
P.O. Box 25576
1228 31 Street, N.W.
Washington, D.C. 20007
James W. Bigelow
Pesticide Coordinator
Wyoming Department of Agriculture
2219 Carey Avenue
Cheyenne, WY 82002-0100
Nilus Black Lance
Pesticide Officer
Pesticide Enforcement Program
Rosebud Sioux Tribe
Box 430
Rosebud, SD 57570
Dick Blodnick
Field Services Bureau Chief
Montana Department of Agriculture
Environmental Management Division
Capitol Station
Helena, MT 59620-0205
Michael R. Biggerstaff
Director
MATA
P.O. Box 340
Stanford, MT 59479
Michael Bilney
Business Manager
Hansen Container
6735 W. 58th Place
Arvada, CO 80003
Bert L. Bohmont
Coordinator, Pesticide Programs
Colorado State University
116 Weed Science Building
Ft. Collins, CO 80523
M. Brett Borup
Assistant Professor
Tennessee Technological University
Water Center
Cookeville, TN 38505
A. L. Bonner
Assistant Director
Oklahoma State Department of Agriculture
2800 N. Lincoln
Oklahoma City, OK 73105
W. T. Braswell
Director - Manufacturing/Toll Sales
Griffin Corporation
P.O. Box 1847
Valdosta, GA 31603-1847
Barry M. Brennan
Extension Pesticide Coordinator
University of Hawaii
1800 East West Road
Honolulu, HI 96822
John L. Bretsch
Supervisor
Insect Control Department
B. D. Wilhelm Company
8200 E. Harvard Avenue
Denver, CO 80231
James S. Bridges
Economist
U.S. EPA
26 West St. Clair Street
Cincinnati, OH 45268
C. H. Brooks
Palmer Manufacturing
7200 E. Dry Creek Rd., #F201
Englewood, CO 80112
Cheryl Brower
Senior Water Quality Analyst
IDHW-Division of Environment
450 W. State Street
Boise, ID 83720
Edwin L. Brunken
Manager-Product Safety/Sanitation
The Pillsbury Company
311 2nd Street, S.E.
Minneapolis; MN 55414
John A. Bumpus
Visiting Assistant Professor
Department of Biochemistry
Michigan State University
East Lansing, MI 48824
157
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Dennis Burchett
United Agricultural Products
P.O. Box 1286
Greeley, CO 80632
H. F. Calhoun
Pesticide & Environment Programs
Louisiana Department of Agriculture
P.O. Box 44153
Baton Rouge, LA 70804
David Callahan
Murray Equipment, Inc.
2515 Charleston Place
Port Wayne, IN 46808
Julie A. Campbell
Managing Editor
CPI 100 Magazine
1129 E. 17th Avenue
Denver, CO 80218
Joe Capizzi
Extension Pesticide Coordinator
Oregon State University
2055 Cordley Hall
Corvallis, OR 97331
David J. Carlson
Environmental Control Supervisor
McLaughlin Gormley King Company
8810 Tenth Avenue North
Minneapolis, MN 55427
Jeffrey L. Carlson
Pesticide Bureau Chief
Department of Pood and Agriculture
100 Cambridge Street
Boston, MA 02202
Clifton Lee Carroll
Seed & Seedlings Prod. Manager
Champion International Corp.
P.O. Box 191
Huntsville, TX 77340
Tim Chamberlain
Facility Service Specialist
State of Wyoming - Camp Guernsey
Box 399
Guernsey, WY 82214-0399
John W. Chapman
Entomologist
Terminix International, Inc.
855 Ridge Lake Blvd.
Memphis, TN 38119
Dean R. Chaussee
Environmental Engineer
U.S. EPA
301 South Park - Drawer 10096
Helena, MT 59626
Brian Chicoine
Regional Safety &
Environmental Coordinator
Pure Gro Company
P.O. Box 22274
2014 S. Pontiac Way
Denver, CO 80222
Chris Christensen
Extension Entomologist
University of Kentucky
Department of Entomology
Lexington, KY 40545
Ray C. Christensen
Public Affairs Director
Colorado Farm Bureau
2211 West 27th Avenue
Denver, CO 80217
Daniel E. Collins
Sanitarian II
Tri-County Health
22 South 4th
Suite 301
Brighton, CO 80601
Harold Collins
Executive Director
National Agricultural Aviation Assoc.
115 D Street, S.E.
Suite 103
Washington, D.C. 20003
David J. Combs
State Program Manager
U.S. EPA
Toxic Substances Branch 8AT-TS
999 18th Street
Denver, CO 80202-2413 '
Kenneth L. Conright
Chief Sanitarian
Tri-County Health Department
4301 E. 72nd Avenue
Commerce City, CO 80022
James R. Costello
Operations Manager
BASF Wyandotte
100 N.'; Cherry Hill Road
Parsippany, NJ 07054
158
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Arthur Craigmill
Extension Toxicologist
Department of Environmental Toxicology
University of California
Davis, CA 95616
Sherry Cramer
National Agricultural Chemicals Assoc.
1155 15th Street, N.W.
Suite 900
Washington, D.C. 20005
Don Cress
Extension Specialist
Kansas State University
Room 239
West Waters Hall
Manhattan, KS 66506
Harley J. Curless
Curless Flying Service
RRl, Box 151
Astoria, IL 61501
Herschel Cutler
Executive Director
Institute of Scrap Iron & Steel, Inc.
1627 K Street, N.W.
Washington, D.C. 20006
Chuck Darrah
Director Tech. Services
ChemLawn Services Corporation
8275 N. High Street
Columbus, OH 43085
John H. Davidson
Consultant
Dow Chemical U.S.A.
Box 1706
Midland, MI 48640
Betty Ann Hughes-Davies
Pesticide Control Specialist
New York State Department
Environmental Conservation
RD 3-Box 22A
Lowville, NY 13367
Bobby L. Davis
Special Projects Chief
Texas Department of Health
1100 West 49th Street
Austin, TX 78756
Christopher Davis
Registration Specialist
NOR-AM Chemical Company
3509 Silverside Road
Wilmington, DE 19803
Les W. Davis
Administrator
State of Arizona
Board of Pesticide Control
1624 W. Adams
Phoenix, AZ 85007
Ronald A. Davis
Plant Pathologist
U.S. Department of Agriculture
BARC-East
Beltsville, MD 20705
Anita Dawson
Manager Manufacturing Services
American Cyanamid
1 Cyanamid Plaza
Wayne, NJ 07470
Kenneth W. Degg
Manager
W.L.S. Flying Service
Litchfield, IL 62056
Clyde R. Dempsey
Chief, CCPB
U.S. EPA
27 West St. Clair Street
Cincinnati, OH 45268
Robert L. Denny
Executive Director
Maine Board of Pesticide Control
State House Station #28
Augusta, ME 04333
Roy R. Detweiler
Public Relations
Chadds Ford Enterprises, Inc.
P.O. Box 349
Chadds Ford, PA 19317
Kevin Dirks
Superintendent of Governmental Affairs
Farmland Industries, Inc.
P.O. Box 788
St. Joseph, MO 64502
Larry Draheim
Agronomist
CENEX
P.O. Box 64089
St. Paul, MN 55164-0089
Ron Drosselmeyer
Air-Sprayers, Inc.
Two Butles, CO 81084
159
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Paul E. Doherty
Environmental Engineer
U.S. EPA
Region 7
25 Funston Road
Kansas City, KS 66115
George B. Donaldson
Director Regulatory Affairs
Wilbur-Ellis Company
191 W. Shaw Avenue
Suite 107
Fresno, CA 93704-2876
Gary Dounay
Chemical Process Engineer
Morrison-Knudsen Engineers, Inc.
1700 17th Street
Suite 1600
Denver, CO 80290
Preston Driggers
Personnel Director
Ever-Green Lawns
6803 Joyce Street
Golden, CO 80403
Steven A. Drucker
CEO
Rose Cooperage Co.
1051 Union Street
Montebello, CA 90640
Thomas A. Dykwell
Sanitation Superintendent
U.S. Air Force
118 Albany Avenue
Vacaville, CA 95688
Jack D. Early
President
National Agricultural Chemicals Assoc.
1155 15th Street, N.W.
Suite'900
Washington, D.C. 200p5
David L. Eaton
Senior Res. Assoc.
Manville Corporation
P.O. Box 5108
Littleton, CO .80217
Ray Edmiston
Aerial Sprayers, Inc.
5112 WCR 32
Longmont, CO 80501
Jeff Edson
Industrial Hygienist
Colorado Department of Health
4210 E. llth Avenue
Denver, CO 80220
Orlo Ehart
Executive Assistant
Wisconsin Department of Agriculture
Trade & Consumer Protection
P.O. Bxo 8911
Madison, WI 53708
Robert Eisele
President
Bighorn Airways, Inc.
P.O. Box 4037
Sheridan, WY 82801
Carl G. Eisinger
Retail Field Supervisor
Cominco American, Inc.
P.O. Box 8416
Moscow, ID 83843
Delbert Ekart
Safety Director
Kansas Farm Bureau
2321 Anderson Avenue
Manhattan, KS 66502
Paul Ekoniak
Reg. Specialist
ICI Americas, Inc.
P.O. Box 298
Goldsboro, NC 27530
Ken Elledge
Program Coordinator
Louisiana Dept of Agriculture
9181 Interline
Baton Rouge, LA 70804
L. M. "Mike" English
Extension Entomologist
New Mexico State University
Box 3AE
Las Cruces, NM 88003
W. B. Ennis, Jr.
Professor
Fort Lauderdale Research &
Education Center
3205 College Avenue
Fort Lauderdale, FL 33314
Conrad Erb
Manager Industry Relations
Growmark, Inc.
1701 Towanda
Livington, IL 61701
H. Clayton Ervine
Governmental Refuse Collection &
Disposal Assoc.
P.O. Box 7219
Silver Springs, MD 20910
160
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Thomas E. Esser
Environmental Hazards Specialist
California Dept. Food & Agriculture
1220 N. Street
Sacramento, CA 95814
Winton Etchen
Executive Vice President
Iowa Fertilizer & Chemical Assoc.
323 University
Des Moines, IA 50314
Mahlor L. Fairchild
IPM Coordinator
University of Missouri - Columbia
Columbia, MO 65211
Vincent J. Parrel1
Environmental & Quality
Control Manager
Agway
978 Loucks Mill Road
York, PA 17402
Bruce Feldberg
Registration Specialist
ICI Americas
P.O. Box 208
Goldsboro, NC 27530
Mary P. Ferguson
University of California
Pesticide Impact Assessment Program
Davis, CA 95616
John J. Filchak, III
Direcotr of Governmental Relations
Connecticut Farm Bureau
101 Reserve Road
Hartford, CT 06279
Hugh Finklea
Senior Group Leader
CIBA-GEIGY Corporation
Box 11
St. Gabriel, LA 70776
William R. Fischer
Professional Lawn Care Association
of America
1225 Johnson Ferry Road
Suite B-220
Marietta, GA 30067
Irv Fisher
Agway Corporation
333 Butternut Drive
Dewitt, NY 13214
John A. Fitzgerald
Product Safety Manager
UNION CARBIDE
P.O. Box 12014
Research Triangle Park, NC
27709
Roger A. Flashinski
Pest Management Education
University of Wisconsin-Extension
1575 Linden Drive
Madison, WI 53706
Felix Flechas
Environmental Engineer
U.S. EPA - Region 8
1 Denver Place
999 18th Street
Suite 1300
Denver, CO 80202-2413
Sam S. Fluker
Professor
University of Florida
Building 817
Gainesville, FL 32611
Robert E. Frame
Pesticides Program Leader,
West Virginia Department of Agriculture
Charleston, WV 25305,
Jean M. Frane
Environmental Scientist
U.S. EPA - OPP, Registration Division
TS-767
401 M Street, S..W.
Washington, D.C. 20460
Harold Fronk
Denver Barrel & Drum, Inc.
P.O. Box 17103 Terminal Annex
Denver, CO 80217
Marvin H. Frye
Environmental. Scientist
U.S. EPA - Region 8
1 Denver Place
999 18th Street
Suite 1300
Denver, CO 80222
Robert B. Fugitt
Governmental Affairs Specialist - USA
E. I. du Pont de Nemours & Co., Inc.
Agricultural Products Department
WM3-154
Wilmington, DE 19898
161
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Bill R. Fuller
Assistant Director
Public Affairs Division
Kansas Farm Bureau
2321 Anderson Avenue
Manhattan, KS 66502
Robert A. Gable
President
Ace Exterminating Co., Inc.
796 Pleasant Hill Road
P.O. Box 576
Lilburn, GA 30247
Harold Garrett
Board Chairman
Platte County Weed & Pest Control
P.O. Box 775
Wheatland, WY 82201
William Gebhart
Entomologist
Naval Facilities Engineer Command
200 Stovall Street
Alexandria, VA 22332-2300
Steven Geist
Spray Supervisor
Swingle Tree Company
8585 East Warren Avenue
Denver, CO 80231
David R. Gengozian
Environmental Scientist
Tennessee Valley Authority
309 Walnut Street '
Knoxville, TN 37902
G. M. Gentry
Chief
Pesticide Lab
Florida Department of Agriculture &
Consumer Services
3125 Conner Blvd.
Tallahassee, FL 32301
William Gilbert
National Alliance of Independent Crop
Consultants
1901 Avery Court
Fort Collins-, CO 80525
Thomas J. Gilding
Director
Environmental Affairs
National Agricultural Chemicals Assoc.
1155 15th Street, N.W.
Washington, D.C. 20005
Michael Gingerella, Jr.
Project Manager
Western Technologies, Inc.
3737 East Broadway Road
Phoenix, AZ 85036
Gary L. Gingery
Administrator
Montana Department of Agriculture
Environmental Management Division
Capitol Station
Helena, MT 59620-0205
Kean S. Goh
Pesticide Coordinator/Asst. Professor
Department of Entomology
Cornell University
Comstock Hall
Ithaca, NY 14853
John L. Goodwin
Managing Director
Custom Farm Service of Arizona
P.O. Box 338
Stanfield, AZ 85272
Sandra J. Gowanlock
Regulatory Coordinator
Velsicol Chemical Corporation
341 East Ohio Street
Chicago, IL 60611
Mark Graustein
Pesticide Coordinator
University of Delaware
Room 254 Townsend Hall
Newark, DE 19717-1303
Dianne Groh
Environvmental Protection Specialist
U.S. EPA - Toxic Substances Branch
1 Denver Place
999 18th Street
Denver, CO 80202-2413
Robert W. Gruber
President
Moore Pest Control Service, Inc.
Englewood, CO 80110
Herb Gundell
Consultant
Ever-Green Lawns
6803 Joyce Street
Golden, CO 80403
162
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Alvin D. Hamman
President
AL-Don Dusting Service, Inc.
P.O. Box 474
Eloy, AZ 85231
C. R. Hanson
Director
Velsicol Env. Center
Velsicol Chemical Corporation
2603 Corporate Ave.
Suite 100
Memphis, TN 38132
Dick Hanson
Field .Engineer
Growmairk, Inc.
1701 Towanda
Bloomington, IL 61701
Warren S. Harris
Station Engineer
University of Arkansas
101 Agriculture.Engineer Building
Fayetteville, AR 72701
Robert W. Hartley
Technical Director
Truly Nolen of America
3620 E. Speedway
Tucson, AZ 85716
Erik H. Haupt
Director of Regulatory Affairs
The F. A. Bartlett Tree Expert Co.
2964 Falmouth Road
Box 177
Osterville, MA 02655
Ann Henson
Dev. Rep.
DuPont
926 Yucca
Longmont, CO 80501
Rolf D. Hill
Office of Waste Programs Enforcement
WH-527
U.S. EPA
401 M Street, S.W.
Washington, D.C. 20460
John C. Hillis
Executive Secretary
SFIREG
1309 Lucio Lane
Sacramento, CA 95822
Winand K. Hock
Extension Pesticides Specialist
Penn State University
419 Agriculture Administration Bldg.
University Park, PA 16802
Dave Hodapp
University of California
Davis, CA 95616
Paul M. Horton
Extension Entomologist
Clemson University
103 Long Hall
Clemson, SC 29634-0365
Kenneth C. Hunter
President
Hunter Agri-Sales Inc.
Box 2
Coatesville, IN 46121
Bill lest
President
Flight Service
P.O. Box 38
Caldwell, ID 83606
James K. Ikeda
Deputy Director
Environmental Health
State Department of Health
P.O. Box 3378
Honolulu, HI 9,6801
W. C. Jensen
Manager Engineer
Western Farm Service, Inc.
3075 Citrus Circle
Suite 195
Walnut Creek, CA 94598
Richard E. Johnsen
Associate Professor
Colorado State University
Dept. of Entomology
Fort Collins, CO 80523
Davicl W. Johnson
Supervisory Plant Pathologist
U.S.D.A.-Forest Service
11177 W. 8th Ave.
Lakewood, CO 80225
Dave Johnson ,
Production Manager
Pueblo Chemical Co.
South Star Route
Garden City, KS 67846
163
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Leeann K. Johnson
Pollution Control Specialist
Minnesota Pollution Control Agency
1935 W. County Rd. B2
Roseville, MN 55113-2785
Stan Jones
President
National Agricultural Aviation Assoc.
Box 685
Benkelman, NE 69021
Thomas L. Jones
Manager Mfg. Pesticide Products
American Cyanamid Co.
One Cyanamid Plaza
Wayne, NJ 07040
Robert A. Junkin
Manager, S & R
Valley Chemical Co.
P.O. Box 1317
Greenville, MS 38701
Bart Kaminsky
Denver Barrel & Drum, Inc.
P.O. Box 17103 T. A.
Denver, CO 80217
Jeffrey S. Karns
Microbiologist
Pesticide Degradation Laboratory
ARS-USDA
Bldg. 050-BARC-West
Beltsville, MD 20705
Dean Kassera
Manager, Chemical Dept.
McLaughlin Gormley King Co.
8810 Tenth Ave., N.
Minneapolis, MN 55427
William T. Keane
803 N. 3rd Street
Phoenix, AZ 85004
Philip C. Kearney
ARS-USDA
Bldg. 050 BARC-West
Beltsville, MD 20705
John King
Regional Manager
TETRA TECH, INC.
120 Howard Street
Suite 420
San Francisco, CA 94105
Brian P. Klubek
Associate Professor
Southern Illinois University
Department of Plant & Soil Science
Ca'rbondale, IL 62901
John J. Kolega
Associate Professor
University of Connecticut
Agricultural Engineering Department,
U-15 Room 230
1376 Storrs Road
Stprrs, CT 06268
Van Kozak
Director
Human and Environmental Hazards
Program
Texas Dept. of Agriculture
P.O. Box 12847
Austin, TX 78711
Raymond F. Krueger
Ecologist
U.S. EPA - Office of Pesticide
Programs
TS-769 C
401 M Street, S.W.
Washington, D.C. 20460
Shri Kulkarni
Senior Research Chemist
Research Triangle Institute
P.O. Box 12194
CEQA
Research Triangle Park, NC 27709
Sheila Lang
Environmentalist
Terra International, Inc.
P.O. Box 4500
Lima, OH 61820
E. R. Laning, Jr.
DOW CHEMICAL U.S.A.
P.O. Box 1706
Midland, MI 48640
David A. Leatherman
Entomologist
Colorado State Forest Service
Colorade State University
Fort Collins, CO 80523
David Leavitt
Supervising, Research Engineer
Farmland Industries, Inc.
P.O. Box 7305, Dept. 69
Kansas City, MO 64116
164
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Noel Lerner
Environmental Engineer
Kennedy/Jenks/Shi1ton
657 Howard Street
San Francisco, CA 94105
Ozzie J. Levine
Vice President
Ted Levine Drum Co.
1817 Chico Ave.
South El Monte, CA 91733
David A. Lewis
Plant Engineer
FMC Corp.
P.O. Bpx 2386
Fresno, CA 93745
Paul M. Liemandt
Pesticide Specialist
Minnesota Dept. of Agriculture
90 West Plato Blvd.
St. Paul, MN 55107
Mildred LiPuma
Senior Research Technician
Mariville Sales Corp.
P.O. Box 5108
Denver, CO 80217
Harvey L. Logan
Executive Vice President
Pest Control Operators of California
3031 Beacon Blvd.
West Sacramento, CA 95691
Art G. Losey
Assistant Director
Washington State Dept. of Agriculture
406 General Administration Bldg.
AX-41
Olympia, WA 98504
Rodney G. Lym
Assistant Professor
North Dakota State University
Agronomy Department
P.O. Box 5051
Fargo, ND 58105
James G. Marria
President
Professional Lawn Care Assoc.
of America
1225 Johnson Ferry Rd., N.E.
Suite B-220
Marietta, GA 30067
John H. Marshall
Lt. Hazardous Material Coordinator
Denver Fire Department
745 W. Colfax
Denver, CO 80204
Larry D. Martin
Consultant
Eli Lilly and Company
Lilly Corporate Center
Indianapolis, IN 46285
Phil Martinelli
Director
Plant Industry Division
Nevada State Dept. of Agriculture
P.O. Box 11100
Reno, NV 89510
Lonnie Mathews
Bureau Chief
New Mexico Dept. of Agriculture
Box 3AQ
Las Cruces, NM 88003
Mark A. Maslyn
Assistant Director
American Farm Bureau Federation
600 Maryland Avenue, S.W.
Suite 800
Washington, D.C. 20024
Fumio Matsumura
Professor
Michigan State University
Pesticide Research Center
E. Lansing, MI 48824-1311
Francis T. Mayo
Director
Water ..Engineering Research Laboratory
U.S. EPA
26 West St. Clair Street
Cincinnati, OH 45268
Tim McArdle
Director - R & D
Trace Chemicals, Inc.
P.O. Box 518
Pekin, IL 61555-0518
John R. McGlamery
Assistant Director
Food and Drug Protection Division
North Carolina Department of
Agriculture
P.O. Box 27647
Raleigh, NC 27611
165
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Patrick J. McGourty
Supervisor
Pesticide Programs
Idaho State Department of Agriculture
2270 Old Penitentiary Road
Boise, ID 83712 ,
Murray L. McKay
Director
Division of Pesticide Control
New Hampshire Department of
Agriculture
105 Loudon Road
Prescott Park, Bldg. 1
Concord, NH 03301
Jim McKinley
Supervisor of Licensing
Alberta Environment
9820-106 Str. Edmonton
Alberta Canada T5N1U4
Marilyn McKinnis
State Regulatory Liaison
National Agricultural Aviation Assoc.
115 D Street, S.E.
Suite 103
Washington, D.C. 20003
Ray V. McManus
LSU Ag. Center Safety Engineer
Louisiana State University
Knapp Hall
Baton Rouge, LA 70803
William Megargle
Packaging Engineer
FMC
2000 Market Street
Philadelphia, PA 19103
Darrel W. Mertens
President
Benson Aviation Inc.
Box 535
Sterling, CO 80751
Olav Messerschmidt
Manager, Product Registrations
Velsicol Chemical Corporation
341 East Ohio Street
Chicago, IL 60611
Douglas Mewett
Regional Pesticides Officer
Ministry of the Environment
Ontario Canada
1500 Fisher Street
North Bay, Ontario, Canada P1B2H3
Dallas E. Miller
State Program Manager
U.S. EPA - Air & Toxics Div.
Toxic .'Substances Branch
One Denver Place
999 18th Street
Denver, CO 80202-2413
Sam Milenski
President
Cal Flying Service Inc.
P.O. Box 448
Rocky Ford, CO 81067
Alexandra L. Moore
Hazardous Substance
Management Coordinator
AMOCO Corporation
200 E. Randolph Dr.
(MC 4903)
Chicago, IL 60601
Charles Moses
Pesticide Research Assistant
Inter-Tribal Council of Arizona
124 W. Thomas
Suite 201
Phoenix, AZ 85013 '.
Donald E. Mullins
Virginia Polytechnical Institute
and State University
Entomology Dept.
Blacksburg, VA 24060
George P. Nassos
Chemical Waste Management, Inc.
3003 Butterfield Road
Oak Brook, IL 60521
Emery W. Nelson
Extension Specialist
UNL
Lincoln, NE 68583-0818
O. Norman Neshelm
Pesticide Coordinator
Oklahoma State University
Dept. of Entomology
Stillwater, OK 74078
Ronald Ney
Chemist Advisor
EPA-OSW (WH-565E)
401 M Street, S.W.
Washington, D.C. 20460
166
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John C. Nye
Head
Agricultural Engineering Dept.
Ag. Eng. Bldg.
Louisiana State University
Baton Rouge, LA 70808-4505
Mike Nolan
United Agri. Products
P.O. Box 1286
Greeley, CO 80632
Julian H. Oser
Vice President
Oser Exterminating Company
1028 Acoma Street
Denver, CO 80204
Maurice Oser
Colorado Pesticide Control Assoc.
480 S. Marion
Denver, CO 80209
Joe L. Pafford
Regional Research Representative
BLANCO
3131 S. Vaughn Way 111
Aurora, CO 80014
Joseph D. Parietta
Manager, Registrations
Pennwalt Corporation,
Agrichemicals Div.
3 Parkway
Philadelphia, PA 19102
James V. Parochetti
Program Leader, Pesticides
U.S.D.A. - Extension Service
Soute Building
Washington, D.C. 20250
Richard M Parry, Jr.
Assistant to Administrator
U.S.D.A.
ARS/OA
Room 403, Bldg. 005
BARC-West
Beltsville, MD 20705
Gabe Patrick
Senior Agricultural Specialist
Pesticide Section
Colorado Dept. of Agriculture
Plant Industry Div.
1525 Sherman Street
4th Floor
Denver, CO 80203
Paula F. Paul
Manager, Regulatory Affairs
NOR-AM Chemical Company
3509 Silverside Road
Wilmington, DE 19803
D. L. Paulson, Jr.
Senior Ind. Health Specialist
CIBA-GEIGY Corp.
P.O. Box 18300
Greensboro, NC 27419
Thomas I. Peabody
Public Health Engineer
Environmental Health Service
Dept. of Health & Hospitals
City and County of Denver
605 Bannock Street
Denver, CO 80204
Dana P. Peck
Marketing
Immuno Systems, Inc.
P.O. Box AY
8 Lincoln Street
Biddeford, ME 04005
Ian L. Pepper
Associate Professor
University of Arizona
429 Shantz Bldg.
Dept. of Soil & Water Science
Tucson, AZ 85721
Fred Perry
Assistant Director
Agricultural Field Stations
University of California
Davis, CA 95616
Mark A. Peterson
Research Assistant
South Dakota State University
212 Agricultural Hall
Brookings, SD 57007
Jack Pfeifer
Chemical Waste Management, Inc.
555 Metro Plance N.
Suite 525
Dublin, OH 43017
Vernon C. Pickhardt, II
President
Arrow Pest Control, Inc.
6183 Palmer Blvd.
Sarasota, FL 33578
167
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Frank H. Plescia
Regulatory Specialist - State Liaison
Chevron Chemical Company
P.O. Box 4010
Richmond, CA 94804 - 0010
Clifford D. Porterfield
Technical Specialist
RED PANTHER CHEMICAL COMPANY
P.O. Box 550
Patton & Normandy Street
Clarksdale, MS 38614
David O. Quinn
Professor, Ext. Spec.
West Virginia University
408 Brooks Hall
P.O. Box 6057
Morgantown, WV 26506-6057
Stephen Raab
Manager
Administrative Services and
Environmental Affairs
Zoecon Corporation
975 California Avenue
Palo Alto, CA 94304
George W. Rambo
Director
Research, Education & Tech. Resources
National Pest Control Association
8100 Oak Street
Dunn Loring, VA 22027
David F. Randolph
President
Nutra-Act
915 Larkstone Lane
Palm Springs, CA 91206
Roy W. Reabe
FRS
P.O. Box 24
Waupun, WI 53963
Richard Reade
President
Mid-Continent Aircraft Corp.
Drawer L
Hayti, MO 63851
Michael X. Redig
Environmental Supervisor
Florida Department of Environmental
Regulation
2600 Blair Stone Road
Tallahassee, FL 32301
Dennis B. Redington
Manager, Environmental
Monsanto Company
800 N. Lindbergh Blvd.
St. Louis, MO 63131
Phyllis A. Reed
Chief, Pesticides & Toxic
Substance Branch
U.S. EPA - Region 5
536 South Clark
Chicago, IL 60605
Richard C. Reichel
Packaging Manager
Velsicol Chemical Corp.
341 E. Ohio Street
Chicago, IL 60611
Roy Reichenbach
Supervisor
Converse Co.
Weed & Pest Dist.
Box 728
Douglas, WY 82633
Charles 0. Reilly, Jr.
Account Specialist
Chemical Waste Management, Inc.
P.O. Box 471
Kettleman City, CA 93239
Darryl Rester
Associate Specialist
Louisiana Coop. Ext. Service
Knapp Hall
Louisiana State University
Baton Rouge, LA 70803
Carlton A. Richie
Dow Chemical Company
9001 Bldg.
Midland, MI 48640
Joseph L. Rizzo
Director
Calgon Carbon Corporation
P.O. Box 717
Pittsburgh, PA 15230-0717
Fritz Roanhorse
Pesticide Specialist
Navajo Nation
Pesticide Regulatory Program
Division of Resources
P.O. Box 308
Window Rock, AZ 86515
168
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Melinda Robin
Educational Specialist
University of Hawaii
Pesticide Safety Training
1800 East West Road
Honolulu, HI 96822
V. M. "Robbie" Robinson
Chemical Specialties International
P.O. Box 641
Cameron Park, CA 95682
J. C. Rockwell
Manager
Registration & Regulatory Affairs
Gustafson, Inc.
P.O. Box 660065
Dallas, TX 75266-0065
Tom Rogers
Loss Control Supervisor
Terra International, Inc.
815 W. Blackwell Ave.
Blackwell, OK 74631
Robert A. Rogowski
Field Service Rep.
Dow Chemical
P.O. BQX 3547
Bellevvie, WA 98009
Robert W. Rohde
Coordinator
Biochemical Labeling
PPG Industries, Inc.
One PPG Place - 34 East
Pittsburgh, PA "15272
Lawrence O. Roth
Professor
Agri-Engr. Dept.
Oklahoma State University
Stillwater, OK 74078
Gene Ruppe
United Agri. Products
P.O. Box 1286
Greeley, CO 80632
Robert M. Russell
Vice President
Government Relations
Orkin Pest Control
2170 Piedmont Road, N.E.
Atlanta, GA 30324
Steven J. Rutz
Environmental Administrator
Florida Dept. of Agri. -
Pesticide Enforc.
Mayo Building
Room 209-B
Tallahassee, FL 32301
George S. Sanders
General Manager
Agrinautics
P.O. Box 19450
Las Vegas, NV 89132
Bud Saunders
Security Consultant
Terra International, Inc.
3001 N. Big Spring
Midland, TX 79702
Dale A. Schlough
Associate Director
University of Wisconsin
Expt. Farms Dept.
620 Babcock Drive
Madison, WI 53706
John E. Schmidt
Manager
Formulation & Packaging Group
BASF Wyandotte Corporation
100 Cherry Hill Road
Parsippany, NJ 07054
Robert Schneider
Senior Scientist
U.S. EPA
NEIC
Denver Federal Center
Denver, CO 80225
Henry C. Schroeder
Hazardous Waste Program
U.S. EPA - Region 8
999 18th Street
One Denver Place
Suite 1300
Denver, CO 80202-2413
James N. Seiber
Dept. of Environmental Toxicology
University of California - Davis
Davis, CA 95616
James Sell
United Agri Products
P.O. Box 1286
Greeley, CO 80632
169
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John H. Semple
S.B. Spraying
2507 Roberts
Helena, MT 59601
Leland Shelton
National Agricultural Aviation Assoc.
Box 433
Hereford, TX 79045
Robert B. Shoemaker
Supervisor
Platte County Weed & Pest Control
P.O. Box 775
Wheatland, WY 82201
Dave Simon
Assistant Editor
Pesticide & Toxic Chemical News
1101 Pennsylvania Ave., S.E.
Washington, D.C. 20003
Daniel M. H. Simpson
Marketing Manager-Pesticides
W.R. Grace & Co.
P.O. Box 277
Memphis, TN 38101
Robert D. Slayback
Plant Materials Specialist
USDA, Soil Conservation Service
3032 Oyster Bay Ave.
Davis, CA 95616
John L. Smith
Pesticide Administrator
N.C. Dept. of Agriculture
P.O. Box 27647
Raleigh, NC 27611
William G. Smith
Extension Associate
Dept. of Entomology
Comstock HA11
Cornell University
Ithaca, NY 14853
Carl Snider
Technical Director
Research Products Company
P.O. Box 1460
Salina, KS 67402-1460
Terry D. Spittler
Associate Director
Cornell University
Analytical Laboratories
Geneva, NY 14456
. Earl C. Spurrier
Vice President
Regulatory Affairs
National Agricultural Chemicals Assoc.
1155 15th Street, N.W.
Suite 900
Washington, D.C. 20005
David C. Star
Program Assistant
M.S.U. Cooperative Extension Service
11 Agriculture Hall
E. Lansing, MI 48824-1039
H. Grier Stayton
Pestipide Compliance Supervisor
Delaware Dept. of Agriculture
2320 S. du Pont Hwy.
Dover, DE 19901
Edward L. Stearns
Life Scientist
U.S. EPA - Toxic Substances Branch
Region 8
999 18th Street
One Denver Place
Denver, CO 80202-2413
Steven D. Steed
Environmental Coordinator
PureGro Company
1276 Halyard Drive
W. Sacramento, CA 95691
Mike Steffensmeier
Section Supervisor
Nebraska DEC
Hazardous Waste Section
P.O. Box 94877
Lincoln, NE 68509
Ray Steil •
Loss Control Supervisor
Terra International, Inc.
600 Fourth Street
Sioux City, IA 51101
Jon Stein
Vice President
Operations
Consolidated Container Corp.
735 N. 3rd Street
Minneapolis, MN 55401
Thomas E. Stephen
Quality Control Coordinator
Stauffer Chemical Company
Nyala Farm Road
Westpost, CT 06881
170
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Virgil Sterling
Purchasing Manager
Champion International Corp.
P.O. Box 191
Huntsville, TX 77340
Orville F. Stoddard
Senior Public Health Engineer
Colorado Dept. of Health
Denver, CO 80220
Matthew Straus
U.S. EPA - Office of Solid Waste
WH-562-B
401 M Street, S.W.
Washington, D.C. 20460
Arlene Tail
Pesticide Director
Oglala Sioux Pesticide Enforcement
Box 468
Pine Ridge, SD 57770
Walter G. Talarek
General Counsel
American Wood Preservers Institute
#405
1945 Old Gallows Road
Vienna, VA 22180
Don Tang
Senior Staff Engineer
U.S. EPA
401 M Street, S.W.
RD-681
Washington, D.C. 20460
A. G. Taylor
Agriculture Advisor
Illinois EPA
2200 Churchill Road
Springfield, IL 62706
Charles R. Terrell
National Water Quality Specialist
USDA Soil Conservation Service
P.O. Box 2890
Washington, D.C. 20013
Lohy Thomas
12983 W. 20th Ave.
Golden, CO 80401
Edwin E. Thompson
General Manager
Chemical Waste Management, Inc.
2301 N. Broadway
Phoenix, AZ 85033
Bill Tindall
Managing Editor
Farm Chemicals
Meister Publishing
37841 Euclid Ave.
Willoughby, OH 44094
Tamara Tinto
Soil Scientist
Tetra Tech
120 Howard Street
Suite 420
San Francisco, CA 94105
Allen Tolmsoff
Environmental Specialist
PPG Industries
One PPG Place
Pittsburgh, PA 15272
Harry W. Trask
Environmental Consulting
RFD #3
Box 3215
Goodwin's Mills, ME 04005
Mike Tysowsky
Manager
Environmental/External Affairs
ICI Americas, Inc.
Concord Pike & Murphy Roads
Wilmington, DE 19897
Dale E. Uhl
Manager, Loss Control
Terra International, Inc.
600 Fourth Street
Sioux City, IA 51101
Roger C. Underwood
Becker-Underwood
701 Dayton
Ames, IA 50010
Anne P. Veigel
Environmental Specialist
Morrison-Knaudsen Engineers
P.O. Box 79
Park Blvd.
Boise, ID 83707
Edward F. Vitzthum
Associate Coordinator
Environmental Programs
University of Nebraska
101 Natural Resources Hall
Lincoln, NE 68583
171
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David Vogel
Environmental Administrator
Florida Dept. of Environmental
Regulation
2600 Blair St'one Road
Tallahassee, FL 32301-8241
Acie C. Waldron
Coordinator-NCRPIAP
Ohio State University
1735 Neil Ave.
Columbus< OH 43210
William L. Waldrop
Districution
QA Manager
Dow Chemical
9008 Bldg. Ashman Street
P.O. Box 1706
Midland, MI 48640
Tom A. Walker
Administrative Assistant
Illinois Dept. of Agriculture
P.O. Box 4906
Springfield, IL 62708-4906
L.C. Warner
Research Representative
Lilly Research Laboratories
130 Palmer Drive
Fort Collins, CO 80525
Jack Watson
Extension Specialist
University of Arizona
820 E. Cottonwood Lane
Building C
Casa Grande, AZ 85222
Thomas R. Way
Research Associate
Louisiana State University
149 Agriculture Engineer Bldg.
Baton Rouge, LA 70808
Bob Wayland
Specialist Assistant
U.S. EPA
401 M Street, S.W.
Washington, D.C. 20460
Glenn Wehtje
Auburn University
Auburn, AL 36849
Allan Welch
Supervisor
Pesticide Activity
SD Dept. of Agriculture
Anderson Building
445 East Capitol
Pierre, SD 57501
John G. Welles
Regional Administrator
U.S. EPA - Region 8
One Denver Place
999 18th Street
Suite 1300
Denver, CO 80202-2413
Suzanne E. Wells
Environmental Scientist
U.S. EPA-OPPE-OSR-CSPD-RAB
401 M Street, S.W.
PM-223
Washington, D.C. 20460
George H. Wermert
President
Agri-Air Ltd.
P.O. Box 87
Efifingham, IL 62401
Brian Westfall
Environmental Engineer
U.S. EPA - HWERL
26 W. St. Clair Street
Cincinnati, OH 45268
John W. Wilcut
Research Associate
Dept. of Agronomy and Soils
Auburn University
Auburn, AL 36849
Hal Winslow
Principal
Winslow & Associates
730 Holly Street
Denver, CO 80220
Wray Winterlin
Environmental Chemist
University of California
Dept. of Environmental Toxicology
Davis, CA 95616
Lyle Wong
Director
Environmental Affairs
Dole Packaged Foods
650 Iwilei Road
Honolulu, HI 96817
Donald W. Woodham
Staff Officer
USDA
Room 600 A - FB
6505 Belcrest Road
Hyattsville, MD 20782'
172
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Jim Worrall
Senior Environmental Project Engineer
Stauffer Chemical Co.
370 Wilton Road W.
Ridgefield, CT 06877
C. Alvin Yorke
Chief
Toxic Substance Branch
U.S. EPA - Region 8
One Denver Place
999 18th Street
Suite 1300
Denver, CO 80202
Dean M. Yoshizu
Pesticide Specialist
Hawaii Dept. of Agriculture
Pesticides Brance
P.O. Box 22159
Honolulu, HI 96822
Jimmy L. Young
Defense Logistics Agency
Alexandria, VA 22304
Rod Young
Virginia Tech
Dept. of Biochemistry &, Nutrition
Blacksburg, VA 24061
Joan E. Young
Registration Specialist
369 Marshall Avenue
St. Louis, MO 63119
Ronald Zielke
SD Fertilizer & Ag. Chem. Assoc.
121 N. Grand
Pierre, SD 57501
173
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LIST OF EXHIBITORS AND POSTER PRESENTERS
Calgon - John Castelli
Hunter Agri-Sales - Ken Hunter
Illinois EPA - A.G. Taylor
IMMUNO Systems - Dana Peck
Mid-Continent Aircraft Corp. - Rick Reade
Murray Equipment - Dave Callahan
National Alliance of Independent Crop Consultants
New York DEC - Betty Ann Hughes-Davies
Tennessee Technological University - Brett Borup
TETRA TECH - Michael Ridosh
USDA/University of Maryland - Jeff Karns
University of California (Davis) - Art Craigmill
University of California (Davis) - Dave Hodapp
University of Louisiana - John Nye
University of Southern Illinois - Brian Klubek
Virginia Polytechnic Institute - Don Mullins
174
JJ-U.S. GOVERNMENT PRINTING OFFICE: 1987-748-121/40683
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