United States
Environmental Protection
Hazardous Waste Engineering
Research Laboratory
Water Engineering Research Laboratory
Cincinnati, OH 45268
January 1987
Research and Development

National Workshop on
Pesticide Waste Disposal


                                                 January  1987

           Denver,  Colorado, January 27-29, 1986

                         JACA Corp.
            Fort  Washington,  Pennsylvania  191)34
                  Contract  No. 68-03-3252
                     Project Officer

                      James Bridges
               Office of Program Operations
     Hazardous Waste Engineering Research Laboratory
                   Cincinnati, OH 45268
                 CINCINNATI, OHIO  45268

       The following papers  have been  reviewed  in  accordance with the
  U.  S.  Environmental  Protection Agency's  peer and administrative  review
  policies and approved for  presentation and publication:

                Pesticide Research Horkshop Summary
                Dealing with Emergencies
                On-Site Disposal-RCRA Options

     The following papers describe work that has not been  funded  by the
U. S. Environmental Protection Agency and therefore the contents  do not
necessarily reflect the views of the Agency and no official endorsement
should be inferred.

                Summary of 1985 Workshop
                Industry's Role in Users' Waste Disposal
                Carbon Adsorption Treatment of Rinsewater
                Treatment of Pesticide Containing Soils
                Biological Treatment of Waste Disposal Site
                Exploitation of a Biological Process in the Eliminating
                  of Cattle-Dip Pesticide Wastes
                Biological and Chemical Disposal Systems for Waste
                  Pesticide Solutions
                Minimization Technology
                Collection and Containment
                Pesticide Rinsewater Recycling Systems
                Product Storage and Handling Equipment
                Reconditioning Containers
                Recycling of Plastic Containers
                Off-Site Disposal of Pesticides and Pesticide Containers

       The panel  discussions of January  29,  1986 were taped and transcribed
  and  have become part of these  Proceedings.   We were unable to obtain
  edited  copy from  Raymond F. Krueger  and  0. R. Ehart who were part of
  the  Regulatory  Summary  Panel and  Richard Byer who was part of the
  Users'  Summary  Panel within the available time that was scheduled for
  this task.   It  is  therefore noted that these unedited and edited
  remarks are accepted  as an  important portion of  the Proceedings  but
  do not  necessarily reflect the  views of  the  Agency nor should any
  official endorsement  be inferred.

     The U. S. Environmental Protection Agency is charged by Congress with
protecting the Nation's land, air, and water systems.  Under a mandate of
national environmental laws, the Agency strives to formulate and imple-
ment actions leading to a compatible balance between human activities and
the ability of natural systems to support and nurture life.  The Clean Water
Act, the Safe Drinking Water Act, the Resource Conservation and Recovery
Act, the Federal Insecticide, Fungicide and Rodenticide Act, and the Toxic
Substances Control Act are five of the major congressional laws that
provide the framework for restoring and maintaining the integrity of our
Nation's water, for preserving and enhancing the water we drink, and for
protecting the environment from hazardous and toxic substances.  These laws
direct the EPA to perform research to define our environmental  problems,
measure the impacts, and search for solutions.

     The Water Engineering Research Laboratory is that component of EPA's
Research and Development Program concerned with preventing, treating, and
managing municipal  and industrial  wastewater discharges; establishing
practices to control  and remove contaminants from drinking water and to
prevent its deterioration during storage and distribution; and  assessing
the nature and controllability of releases of toxic substances  to the air,
water, and land from manufacturing processes and subsequent product uses.
This publication is one of the products of that research and provides a
vital  communication link between the researcher and the user community.

     The 1986 National Workshop on the Disposal  of Pesticide Wastes was
an outgrowth of the Workshop held in 1985 which was developed to provide
a national forum that assembled pesticide users, pesticide producers,
federal  and state agencies and agricultural  and environmental  researchers
to collectively address the complex issues of pesticide waste disposal  and
serve as a basis for continued dialogue and interaction.  The Office of
Research and Development with the Office of Pesticide Programs  and  Office
of Solid Waste sponsored the development of these Proceedings to document
the conduct of this solution-oriented workshop.  It is hoped that the
content of these Proceedings will  continue to stimulate action  to reduce
pollution by illustrating approaches and techniques highlighted by  the
excellent papers presented at the workshop.
                                 Francis T.  Mayo,  Director
                                 Water Engineering Research  Laboratory

     A national workshop on the disposal  of pesticide wastes  was  held  in
Denver, Colorado on January 27-29, 1986.   The purpose of  this workshop
was to work with government, pesticide user groups, pesticide producers,
farm organizations, and academia to define and offer practical  solutions
to pesticide users' disposal problems.

     This publication is a compilation of the speakers' papers  and
transcripts of the summary panels.  The following topics  are  covered:
industry's role in users'  waste disposal, on-site demonstration projects,
regulatory update, summary of pesticide research workshop,  users' waste
minimization/reuse, users' waste treatment/storage/disposal,  and  summary
panels on technology, regulations, and application of pesticides.

     This report was submitted in partial fulfillment of  Contract No.
68-03-3252 by the JACA Corporation under  the sponsorship  of the U.  S.
Environmental Protection Agency.  This report covers the  period October 1985
to July 1986; work was completed as of June 30, 1986.


Program	     1

Keynote Address
     Robert Wayland, U.S. Environmental Protection Agency	     3

Pesticide Waste Disposal:  Review and 1985 National Workshop Summary
     James N. Seiber, University of California at Davis.	    11

Industry's Role in Users' Waste Disposal
     Jack D. Early, National Agricultural Chemicals Association. . .    20

Carbon Adsorption Treatment of Rinsewater
     John C. Nye and Tom Way, Louisiana State University	    23

Treatment of Pesticide-Containing Soil
     Ian L. Pepper and John E. Watson, University of ARizona ....    28

Biological Treatment of Waste Disposal Sites
     Arthur L. Craigmill, Wray L. Winterlin, James N. Seiber„
     University of California at Davis 	    31

A Biological/Physical  Process for the Elimination of Cattle-Dip
Pesticide Wastes
     Jeffrey S. Karns, Mark T. Muldoon and Philip C. Kearney,
     USDA Agricultural  Research Service and Pesticide Degradation
     Laboratory	 .    39

Biological and Chemical  Disposal Systems for Waste Pesticide
     Catherine Schmidt, Brian Klubek and James Tweedy, Southern
     Illinois University - Carbondale	    45

Pesticide Research Workshop Summary (Research Workshop on the
Treatment/Disposal of Pesticide Wastewater)
     Philip C. Kearney, USDA Pesticide Degradation Laboratory and
     Francis T. Mayo,  U.S. EPA Water Engineering Research Laboratory    53

Direct Injection as a  Rinsewater Minimization Technology
     Lawrence 0. Roth,  Oklahoma State University	    56

Wastewater Recycling
     Daryl Rester, Louisiana State University	    60

Recycling Pesticide Rinsewater
     A.G. Taylor, Illinois Environmental Protection Agency; Dick
     Hanson, Growmark, Inc.; and Diane Anderson, University of
     Illinois	    67

Tanks and Fittings for Fluid Fertilizers, Pesticides and Other
Liquid Products Related to Agriculture
     Dave Callahan, Murray Equipment, Inc	 .....    74

Dealing with Emergencies
     C. Alvin Yorke, U.S. EPA Toxic Substances Branch. .......    77

Reconditioning Containers
     Lawrence W. Bierlein, National Barrel  and Drum Association. . .    82

Recycling Metal Containers
     Herschel Cutler, Institute of Scrap Iron and Steel, Inc	    88

Disposal of 55-Gallon All-Plastic Drums
     Daniel W. Barber, Society of Plastics Industry, Inc.. .....    91

Resource Conservation and Recovery Act (RCRA) Permitting of On-Site
Pesticide Waste Storage and Treatment
     Felix W. Flechas, U.S. Environmental Protection Agency. ....    94

Off-Site Disposal of Pesticides and Pesticide Containers
     H. Clayton Ervine, Governmental  Refuse Collection and Disposal
     Association	   100

Storage, Handling and Shipment of Pesticide Waste-Regulatory
Requi rements
     Rolf P. Hill, U.S. Environmental Protection Agency. .......   104

Technology, Regulatory and Users' Summary Panels:  Opening Comments
     Roy Detweiler, Consultant .... 	 .....   105

Technology Summary Panel
     James N. Seiber, University of California; Philip C. Kearney,
     USDA; Francis T. Mayo, U.S. EPA; and George P. Nassos, Chemical
     Waste Management, Inc	   108

Regulatory Summary Panel
     Raymond F. Krueger,  U.S. EPA; Orlo Robert Ehart, Wisconsin
     Dept. of Agriculture; and H.F. "Butch" Calhoun III, Louisiana
     Dept. of Agriculture	   121

Users1  Summary Panel
     Harold M. Collins, Jr., National Agricultural  Aviation Assoc.;
     Richard Byer, Louisiana Farm Bureau Federation; Robert M.
     Russell, Orkin Pest  Control; and William T. Keane, Attorney at
     Law	   138

List of Speakers and Attendees	   156
List of Exhibitors and Poster Presenters  .	   174

The workshop was sponsored by the following organizations:

                American Chemical Society (Division of Agrochemicals)
                American Farm Bureau Federation
                American Society of Agricultural  Engineers
                Association of American Pesticide Control  Officials, Inc.
                National Agricultural  Aviation Association
                National Agricultural  Chemicals Association
                National Alliance of Independent Crop Consultants
                National Barrel and Drum Association   .
                National Forest Products Association
                National Pest Control  Association
                U. S. Department of Agriculture (Soil Conservation Service,
                  and Science and Education:  Cooperative State Research
                  Service, Extension Service, and Agricultural  Research
                U. S. Environmental Protection Agency (Office of Pesticide
                  Programs, Office of Research and Development, Office of
                  Solid Waste)

     A special  note of  appreciation is extended to Mr. Roy R. Detweiler,
Chairperson  of  the Workshop Coordinating Committee and Mr. Thomas J.
Gilding, Workshop Coordinator.   Also many thanks are given to Ms. Sherry
Cramer and Ms.  Marilyn  McKinnis  for all their contributions in making
sure the Workshop ran smoothly.  These individuals along with the members
of the Workshop Coordinating Committee worked diligently to make this 1986
National Workshop on Pesticide Waste Disposal a success.


                            National  Workshop on
                          Pesticide Wastes Disposal

                      Clarion Hotel — Denver,  Colorado
                             January 27-29, 1986

                      Roy Detweiler, Workshop Moderator

Opening Remarks

Welcome and Introduction

Keynote Address

Pesticide Waste Disposal:  Review and 1985 National Workshop Summary

Industry's Role in Users' Waste Disposal

On-site Demonstration Projects Reports

    Carbon Adsorption Treatment of Rinsewater
    Treatment of Pesticide-Containing Soils
    Biological  Treatment of Waste Disposal Sites
    A Biological/Physical Process for the Elimination of Cattle-Dip
       Pesticide Wastes
    Biological  and Chemical Disposal Systems for Waste Pesticide

Regulatory Update
    Regional  Perspectives

Pesticide Research Workshop  Summary

Users' Waste Minimization/Reuse

    Ri nsewater Management:
       Direct Injection as a Rinsewater Minimization Technology
       Waste Water Recycling
       Recycling Pesticide Rinsewater
    Tanks and Fittings for Fluid Fertilizers, Pesticides and other Liquid
       Products Related to Agriculture
    Dealing with Emergencies

Users' Haste Treatment/Storage Disposal

    Container  Management:
       Reconditioning  Containers
       Recycling Metal  Containers
       Disposal  of 55-Gallon-All-Plastic Drums
       Resource  Conservation and  Recovery Act (RCRA)  Permitting of
          an On-Site Pesticide Waste Storage and Treatment
       Off-Site  Disposal  of Pesticides and Pesticide  Containers
    Storage, Handling  and Shipment of Pesticide Waste-Regulatory Requirements

Summary Panels

    Opening Comments

    - Technology Summary  Panel
    - Regulatory Summary  Panel
    - Users' Summary Panel

Posters, and Exhibits

                        KEYNOTE ADDRESS

                         Robert Way! and

                 U S Environmental Protection Agency

                       Washington, D. C.

 Robert  Wayland is  a Special Assistant to the EPA
 Administrator in Washington.  He is a policy advisor to
 Lee  Thomas on Hazardous Wastes and Office of Water
 activities.   He has worked with EPA since 1974, has been a
 director for the Office of Legal and Enforcement Policies/
 a  director of Policy and External Affairs, in the Office  ',
 of Solid Waste and Emergency Response, and prior to that
 he was  a staffer in both the House of Representatives and
 the  U.  S.  Senate.
When I talked with Marcia Williams at  5:30  p.m.  Friday,
and she told me she was going  to  have  to  throw  in  the
towel and would not be able  to make  the conference  she
asked me to be sure and emphasize to all  of you  just  how
disappointed she was.  As a  former Deputy Assistant
Administrator for Pesticides and  Toxic Substances  and  now
Director of the Office of Solid Waste, her  job experience,
like mine to a degree, very  much  involves all of the
aspects of the issues under  discussion today.  So  we  hope
that Marsha will recover soon  and also that she  will  be
able to follow through on many of the directions that  I
hope will be set today.

As many of you know EPA just recently marked the 15th
anniversary of the Agency's  creation and  this milestone
naturally has been a time of reflection to  mark  where we
have been and to set a course  for the future.  Jim  Barnes,
Deputy Administrator, with whom I work most closely,  is
fond of recalling that when  he first came to the agency  in
1970, and it moved to its headquarters at Waterside Mall,
there were signs just two blocks  from the building  that
warned people not to swim, not to fish in the Potomac
river.  The other afternoon  we were  in Jim's office
talking about some momentous matter  or another and  for one
reason or another we were all  staring out the window  and
there were wind surfers on the river.  They got  into  the
water, as wind surfers often do, and we all remarked  that
at least they would not have to get  tetanus shots.

In 1970 the continued existence of our national  symbol was
threatened.  Now the bald eagle is coming back strong.
There have been some very tangible indications of  progress

 that we can look out our windows or take a trip to Alaska
 to see but just as we have made important progress there
 are some very difficult problems that remain.  In some
 respects we have used the knowledge that we have accumu-
 lated over the last 15 years to redefine what is or isn't
 the problem.  Now at EPA today we have more legal tools
 than we did in 1970.  When the Agency was established
 there was no RCRA, no TSCA, no Superfund law.  The state
 of technical and scientific knowledge has increased
 immensely.  Our ability to evaluate the tpxicity of the
 substances we work with has improved and analytical
 methods are much more advanced than they were,  allowing us
 to measure ever smaller and smaller quantities  of contami-
 nants which pose new challenges to policy makers.  There
 are more pollutants of concern/ net so much because they
 are new pollutants but because we did not know  enough to
 be concerned or we did not know that they were  there at

 We tended, in the beginning,  to put our regulatory pro-
 grams into boxes.  In our early years EPA worked hardest
 to control the largest and most obvious sources of pollu-
 tion.   With the visible polluters and pollution under
 control we face difficult policy and institutional prob-
 lems.   Designing controls and summoning the will to con-
 trol  a belching steel mill is a far different proposition
 from  regulating tens of thousands of drycleaning plants
 whose  individual solvent emissions contribute tc non-
 attainment of primary ozone standards in many areas of the
 country and subject hundreds  of thousands of  people to
 unhealthy air.

 In  the 1970's we worried about  hydrocarbons,  Co,  Nox,
 particulates,  in our air program.   Water worried about
 suspended solids and the biological  oxygen  demand.   The
 so-called conventional  pollutants.   In  the  1980's all  of
 our media worry about specific  metals and a large  number
 of  organic chemicals.

 When  the  agency was  established  there were  important
 resources,  notably ground  water,  not  addressed  at  all  in
 our legal  mandate  or anywhere  in  our  organizational
 structure.  We  simply did  not  understand their  value  or
 their  vulnerability.

 Today  we  have become  increasingly  able  to recognize that
 the same  compounds  that  are used  for  products,  pesticides
 fertilizers,  other  chemicals  that  we depend on  to maintain
 our lifestyle,  can,  in certain  circumstances, cause
 problems  for  human  health  and  the  environment.   In  other
words,  pollutants  are not  just  undesirable by-products  of
 society,  the  same  compounds can cause unintended effects
during  their  manufacture,  disposal, and  even during use.
 So as  I said  we  have  begun  to redefine  the problem.

We have also discovered  that fixing one  problem may cause
a different problem.  Reducing workplace exposures  to
carcinogens through better ventilation,  for example in  the
case of ethylene oxide,  a  common hospital disinfectant, or

other solvents, simply releases the substance into the
ambient air and we have begun to appreciate that we have a
significant air toxics problem in the country.

Incinerating solid and liquid hazardous waste as fuels in
industrial boilers may result in ambient air pollution
with metals.  Cancelling one pesticide may shift people to
a substitute which present other and possibly greater
environmental or health problems.  The simple boxes into
which we categorized our problems in the early going has
tended to cause a lot of anomalies which sometimes make a
good story for Jack Anderson and that often make real
people shake their heads.  Manufacturing smoke stacks are
unregulated for many metals and organics, yet the inciner-
ators that burn hazardous waste are highly regulated.  The
ambient air and the people who breathe it really do not
know the difference.  Ground water monitoring acceptable
for cleaning up the Superfund site is not adequate under
our rules for operating a RCRA facility.  Transportation
of hazardous waste are manifested and carefully controlled
but there are not equal and equivalent controls for
transportation of much more hazardous chemical products.

Existing pesticides and chemicals continue in use without
fully adequate data on some health or environmental
effects and the burden is on the government to prove harm,
which is a long term process.  New, safer pesticides and
chemicals are held to a higher standard.  Some may not
pass initally, all must be supported by substantial
evidence of safety.  Many pesticides and fertilizers can
be used as products and placed on the ground with limited
restriction.  These same compounds may soon be banned from
land disposal in high technology landfills even at the
most dilute concentrations.

What is the solution?  There are some that suggest that
one solution is for Congress to scrap the 14 or so
environmental laws under which we presently operate and
develop holistic, organic EPA statutes.  In fact, Bill
Ruckelshaus made such a proposal, shortly after his return
to EPA.  This seems highly unlikely however.  Congress is
now considering special groundwater legislation to plug
the gap I mentioned earlier and they continue to
reauthorize the individual statutes that EPA administers
with greater and greater specificity and more and more

I think what that leaves us with is the need to make the
existing laws work better.  One of the ways we hope to do
this is by creating a cadre of managers at EPA who
appreciate and understand more than one environmental
medium.  Le& Thomas and Jiwi Barnes undertook a major shift
of senior agency managers last year.  It was partly to
foster personal growth for the individuals involved but
they also knew that somebody who had worked for years to
protect air quality was not likely to send a drinking
water regulation to the administrator that would simply
volatalize the contaminants into the ambient air.

 Marcia Williams/  who was to be with you today/  was one of
 the beneficiaries of the senior management rotation.

 Another emphasis  is to undertake more evaluation of "cross
 media" effects of each regulation as it is developed.
 That is something I am partly responsible for in the
 Office of the Administrator.

 In  addition/  I think there is a greater recognition of the
 limitation of traditional command and control regulatory
 approaches.  EPA  is looking toward regulatory negotiation
 projects with earlier involvement of the regulated
 community in  the  development of the proposals we have  to
 manage these  problems.  In fact/ two of the first three
 regulatory negotiation projects that the Agency has
 undertaken are under FIFRA.  There is a Section 18 rule
 nearing completion now/  emergency exemptions/  and we have
 actively underway a negotiation project for the
 re-promulgation of EPA farmworker protection standards.

 This conference today signals a lot of the positive
 aspects of the new ways  we are hoping to do business with
 First and  foremost/  we  have  a  recognition  here/  as  we  did
 last year/  that  both FIFRA and RCRA  cover  aspects of
 pesticide  waste  disposal.  The conference  is  a cooperative
 venture  of government at  the state and  federal level and
 the private sector.

 Also/ I  think/ this  meeting  recognizes  that research has
 to play  a  very important  role  in  deriving  solutions for
 the future/  transcending  any of the  regulatory structures
 we may have put  into place.

 I would  like  to  turn to some specifics  now/ and  talk about
 some joint  efforts of the Office  of  Pesticide Programs and
 the Office  of Solid  Waste, the RCRA  activities that are
 largely  mandated by  amendments adopted  in  1984,  about
 which some  of you heard last year, and  close with some
 specific opportunities for the pesticide producer and  user
 communities and  state officials to work with us  to  our
 mutual benefit.

 Recently the Office  of Solid Waste and  the Office of
 Pesticide programs completed a joint action plan on
 pesticide disposal.   It is comprised of a  number of
 elements which I would like  to highlight briefly.

 First and foremost of these  is  a  need to better  communi-
 cate to the regulated community and  the regulators  recog-
 nizing that they come from a variety of state agencies.  A
 series of fact sheets is going  to be developed by the  end
 of this year, the first of them are already under prepara-
 tion,  to include topics like:  disposal  of small quantities
of waste, homeowner  disposal,  reuse and recycling oppor-
 tunities, container  rinsing  techniques, disposal of
concentrates and undiluted formulations.

The organization represented here/ NACA/ SFIREG/ NAAA/
can all assist us by suggesting additional topics  for  fact
sheets that EPA can develop/ reviewing the drafts  that we
prepare—keep us on the straight and narrow—and help  us
to insure that these materials are widely distributed  when
they are completed.

A second priority area is the need to develop a more
consistent categorization of accutely and chronically
toxic pesticides.  As you may know there are schemes that
have been adopted under both statutes by the two programs
to categorize acutely toxic pesticides.

The Office of Solid Waste wants  to try to make the FIFRA
'tox category one/ pesticides consistent with those
pesticides defined acutely  hazardous under RCRA.

The practical consequence of being defined as acutely
toxic under RCRA is that the small quantity generator
exemption drops from a thousand  kilograms to one kilogram.
To reconcile these differences/  both programs will have  to
look at  the listing criteria they have employed as well  as
specific pesticides currently listed.

There will also be an effort to  develop consistent out-
comes with respect to any future actions taken by  either
program.  That  is/ additions to  the  so called  261.33 F
list, as it is  known  in RCRA/ and the tox categorizations
that are assigned to  new pesticides  under FIFRA.

OSW is going to make  sure that all pesticides  defined  as
hazardous under RCRA  are accurately  listed and reflect
all known information.  In  the past  the Office of  Solid
Waste has been  heavily dependent on  contractor support and
in some  instances has not made full  use of the toxicity
data available  in the agencies/  filed across  the river at
Crystal  City/  that have been submitted by manufacturers
to support registrations.

Both programs are going to  endeavor  to  jointly evaluate
disposal issues and options pertaining  to dilute
pesticides:  equipment wash water, container  rinsates
and dilute mixtures'.

The key  question  is really  whether or not  these rinsates
are hazardous.  Under RCRA, as  the rules  stand today,  a
mixture  rule applies  which  establishes  that  once mixed
with a  hazardous  waste  the  resulting mixture  is always
hazardous, no  matter  how  far down  the resulting mixture  is
diluted.  A  lot of people questioned whether  this  really
makes  sense and it leads  to the  kind of  concerns  that  John
Wells  alluded  to  earlier  where  pesticides  can  be  applied
directly to  fields at concentrations far  higher  than  can
be disposed  in  landfills  after  they  have  been  diluted  as
a result of  rinsing.

OSW  indicates  that results  of  the  study,  which Matt
Strauss  is going  to  report  on  later  today, will  be used  in
re_evaluating  our regulatory postures.

One final area that both programs are concerned about/: is
the need to get ahead of the power curve/ where biotech-
nology is concerned.  We are just beginning to consider
registering the first genetically engineered pesticides
and we do not want to find ourselves three to five years
from now realizing that little or no consideration was
given to how the waste products that may result are to be

Finally/ there are some aspects to the 1984 amendment to
RCRA that I want to touch on briefly.

The hazardous and solid waste amendments of 1984 turned
RCRA into a very specific statute/ and were partly a
reaction to what Superfund was uncovering around the
country/ as we looked at abandoned hazardous waste sites.
A lot of loopholes were closed/ tight time-frames were
imposed on the agency and the regulated communities/ and
significant attention was placed on groundwater protection
and waste minimization.

EPA was directed to do a number of specific things/
including undertaking the listing of additional wastes.
We have under examination pesticide manufacturing wastes
and specific pesticides for future inclusion under the
RCRA Subtitle C framework.

In addition/ we are rerexamining our existing toxicity
characteristic test.  Wastes are captured under RCRA
either because they have been specifically listed by the
agency or because they exhibit a characteristic of ignit-
ability/ corrosivity/ reactivity or what we call EP
toxicity.  That toxicity is determined through an extrac-
tion procedure which is a pretty good basis for evaluating
whether something is harmful to groundwater/ or so we
believe.  Analysis of the EP tox test/ now involves a very
limited number of contaminants and we are considering
adding a number of pesticides to the list of things for
which analysis has to be performed in the tox test.

We have been directed to lower the small quantity
generator exemption/ which I referred to earlier/ from a
thousand to one hundred kilograms and a proposal has
already been made.  We are looking to final rule by March
31st of this year.  We did a number of informational
brochures for people who are potentially affected by the
small quantity generator being lowered/ .including one that
specifically deals with pesticides.

The Congress has also enacted a land disposal ban
provision which basically presumes/ unless the agency is
able to establish otherwise/ that hazardous waste should
not be managed in the land.

We have just proposed our decision criteria for
determining which wastes would be prohibited from land
disposal and many of the hazardous wastes that are
generated by firms that are represented here today will
very likely be candidates for the ban.

Another significant amendment directs EPA to re-evaluate
the criteria by which states regulate solid waste/ that is
those wastes which do not exhibit one of the characteris-
tics or have not been specifically listed by EPA.  There
is every possibility that this will result in some tight-
ening of the solid waste disposal requirements, though we
are not looking for that until the 1987-1988 time-frame.

I almost overlooked mentioning that we were also given
authority in the 1984 amendments to issue research
development and demonstration permits, which I think is
one of the bright spots as far as those amendments are
concerned in that we should be able soon to issue permits
on an expedited basis to evaluate promising new

I would like to close with some thoughts about the
challenges that confront all of us in the overall
framework that I have mentioned that is specific to the
topics that are going to be under discussion today.

The challenges for us at EPA as we develop a regulatory
program to protect human health and the environment from
mismanagement of hazardous waste is to do so without
over-protection.  We are going to attempt to do that, in
part, by enhancing the coordination among all parts of
EPA, including those joint OPP/OSW activities I mentioned.

We are going to endeavor inject risk based decision making
into RCRA, a statute that we traditionally implemented in
black and white terms.  Something is deemed hazardous and
is regulated under the full weight of the Subtitle C
program or it is not.

We have to ask ourselves, should not we be considering
the concentration of the waste and the toxicity of the
resulting mixture.

I think there has to be an effort on EPA's part to
simplify regulations wherever possible.  We have created a
very complex and partitioned structure of regulations and
as we expand from a universe of 1,500 or so entities
regulated under RCRA to over 150,000 we need to appreciate
that this complexity may lead to unintentional

EPA needs to focus sooner during the regulatory develop-
ment process on implementation issues.  How are we going
to get these regulations to work on the field level, are
they practical, are we asking people to undertake analyses
that are beyond the reach of the farmer or gas station
owner who may be potentially subject to some of these

I think we have to strive to create an environment of
predictability and certainty for regulated community which
will allow them to undertake the research and development
in new disposal and improved disposal techniques without
concern that their efforts would be impeded by an attitude

that has sometimes  prevailed:  if  we  have  not  seen  it
before we can not possibly  take a chance  on it.  We are
not so satisfied with present  disposal  technology  that we
can afford that kind of attitude.

I think this conference underscores  some  challenges for
our colleagues in the state.   First  of  all there is a need
for coordination between  the agriculture  and  FIPRA
implementation agencies at  the state level and those who
implement the solid and hazardous waste laws.  The state
level is where the  implementation really  occurs and a
better exchange of  information is very  important.

We are going to depend heavily on our colleagues in the
states to help us disseminate'information to  those who are
to be newly regulated and those for  whom  the  regulatory
environment is changing rapidly.   We are  going to  rely on
states to help provide early input in our regulatory
development activities as for  example/  SFIREG worked on
pesticide disposal  and groundwater issues.

I see some challenges for pesticide  users and producers.
You need to help us identify real  problems.  Some  of the
problems that we discussed at  this meeting last year and
that we face today  are ones that  ought  to have been
avoided with enough foresight  on  our part and enough
openness in our dialogue.

We are also going to depend on producer and community to
help us disseminate information.  We want to have  your
input on the effects of some of our  new activities/ such
as C evaluation.  We want you  to  continue to participate
as active players with EPA on  the  implementation issues
associated with pesticide disposal.

That is a pretty substantial menu of challenges.    I think
this conference does prove a valuable opportunity  for us
to work together and make us start meeting the challenges.

Thank you very much.

                            PESTICIDE WASTE DISPOSAL:

                                   James  N.  Seiber
                        Department of Environmental  Toxicology
                               University of California
                                   Davis, CA  95616


      The 1986 National  Workshop provided a forum for exchanging ideas ranging across
 a broad front,  from the needs of applicators, through the rationale for and
 intracacies in  regulation, to discussion of some here-and-now practical approaches
 to disposal as  well as  more esoteric ones which might become available in the
 future.  The Workshop produced the tangible result of leading directly to a Research
 Workshop held in Cincinnati just 6 months after the Denver Workshop at which more
 specific planning occurred along with implementation  of some funding of projects.
 Less  tangible results included the stimulation of attendees to a new sense of
 urgency, and the raising of expectations that solutions to the problem of waste
 disposal were on the horizon.

      A national  workshop on the disposal
 of pesticide wastes was held in Denver,
 Colorado,  on January 28-29, 1985, with
 approximately 400 persons in atten-
 dance.  The program consisted of nine-
 teen  individual  presentations and a
 summary panel expressing the views of
 governmental agencies,  pesticide user
 groups, pesticide producers, pesticide
 consultants, and academia,  with the
 purpose of defining practical solutions
 to pesticide users disposal problems.
 In this summary, I will attempt to
 reiterate  some salient  points from the
 Denver Workshop  in the  context of events
 which stimulated the organization of the
 workshop and those transpiring
 subsequent to it, rather than simply
 repeating  the proceedings as now
 available  in written form (JACA, 1985).

      An important theme to  the workshop
 was the recognition that problems exist,
 that  they  are real problems which cannot
 be ignored, and  that they are problems
-which must be solved.  The  scope of
 materials  included in the term
 "pesticide wastes" runs a broad gamut:
 Empty containers, unwanted/outdated
 products,  tank and equipment
rinsewaters, left-over materials,
equipment washwaters, incompatible
mixtures, spilled materials, stormwater
and runoff from natural occurrences, and
debris from fires (Ehart, 1985; Keane,
1985).  While the immediate driving
force for solving the waste problem is
the existence of increasingly stringent
federal and state regulations, the
contribution of such wastes to visual,
air, soil, and water pollution can not
be overlooked.  Improper waste disposal
can lead to contamination of surface and
ground water, accentuating the problem
of contamination which can occur as a
result of registered uses of crop
protection chemicals.

     On a brighter note, improper
pesticide waste disposal affords a
manageable problem which  with suf-
ficient effort  can be solved nearly to
the point to eliminating it as an
environmental hazard.  Proper waste
disposal should be regarded as an
integral part of "product stewardship"
so often touted as a means of combating
the negative feeling toward pesticides
which exists among many of our citizens.

      The  challenge of proper disposal  is
 not  a new one.   Several  symposia,  books
 (Kennedy, 1978;  Krueger  and Seiber,
 1984) and reports  (Day,  1976;  Hall  et
 al.,  1981;  Munnecke et al.,1976;  SCS
 Engineers,  1979; Wilkinson  et  al.,  1978)
 have  dealt  with  this subject just  in the
 past  ten  years.  The Resource  Conser-
 vation Recovery  Act (PL  94-580,  1976)
 made  the  situation more  immediate  by
 requiring persons  generating acutely
 hazardous waste  (including  many
 pesticides)  to notify EPA by August  14,
 1980,  and comply with interim  status
 facility  standards by November 12,
 1980.   Many  commercial pesticide
 applicators,  who could be above the
 minimum level of waste generation,
 notified  EPA by  the deadline.  While
 some  guidance of a general  nature  was
 provided  by  EPA  in 1981  (Fed.  Reg.,
 1981)  to  owners  and operators  of
 treatment,  storage,  and  disposal  systems
 (which could include commercial
 applicators  who  handled  wastes at  their
 sites  of  operation),  specific  details  on
 how to comply with RCRA  were not
 available at the time of notification
 or, to a  certain extent,  even  now.   That
 is, pesticide applicators were caught,
 as were other Small  Quantity Generators
 (SU.G's),  in  RCRA requirements, told  that
 their past  disposal  practices  were
 illegal,  but  not given specific steps
 they  could take to come  into
 compliance.   This  is  not  to  imply that
 disposal  options which could satisfy
 RCRA  did  not  exist;  the  problem lay  more
 with  sorting  out the options,  proving
 their  technical and  economic
 feasibility,  obtaining official
 sanction, and making them known and
 available to  users (Seiber,  1981).

     This background provided  the
 stimulus  to  several  organizations
 including EPA, USDA,  and  the National
Agricultural  Chemicals Association
 (NACA), to consider  the  National
Workshop  approach.   In Spring, 1984, the
Waste  Management Subcommittee  of NACA's
Environmental Management  Committee
spearheaded the organization of this
first  National Workshop.


     In general, any  excess  pesticide
concentrate, unapplied diluted material,
and discarded container  remaining after
 applications  of  pesticide  are  completed
 may  be  regulated as wastes  (Ehart,
 1985).   Beyond this general  description
 lie  several intricacies.   Containers   if
 triple  rinsed or equivalent  are  not
 regulated  as  hazardous waste.   Unused
 material remaining in the  container or
 spray tank, and  rinsewater used to
 remove  it  and to clean the spray  booms
 and  equipment exterior  are  not
 regulated  if  they are applied  sub-
 sequently  to  the crop for which the
 pesticide  is  registered.  This has  given
 rise to the practice of using  rinse-
 waters  as  diluents whenever  possible —
 a practice which can go far  toward
 minimizing the quantities  of wastes to
 be dealt with.   In some cases,  the  step
 of applying the  rinsewaters  themselves
 to the  crop,  usually along field
 borders, can  be  economically justified
 (even though  it  entails an extra
 excursion  by  the applicator) because of
 the  mounting  cost of handling  the
 rinsewaters as wastes.  This operation
 might be done when changing  from  one
 chemical to another  to prevent cross
 contamination (Keane, 1985).

     Somewhat surprisingly,  the nature
 of rinsewater contents was not  dealt
 with directly at the Denver  Workshop,
 and  in  fact has  only been addressed in
 any  detail in just one prior report
 (Whittaker et al., 1979).  Considering
 that a  typical tank mix concentration  is
 on the  order  of  10,000 ppm of  active
 ingredient, that 1-8 gallons remain as.
 residue  in the tank, and that  10-80
 gallons  of water are used to flush  the
 residue, it follows that typical  wash-
water will contain approximately  100-
 1,000 ppm  or  0.07-0.7 kg of  pesticide.
Additionally, the tank washwater  will
 also contain  additives (solvents,
emulsifiers,  other adjuvants)  and any
 other agents  (fertilizers) applied
simultaneously with the pesticide.  In
the one prior report, actual analyses  of
spray plane tank and boom rinsate
 revealed up to 18,000 ppm of total
solids.  Washings from the exterior of
the aircraft were much more  dilute  —
 less than  l/10th that of the tank rinse
— but presumably more heterogenous
because of the presence of dirt,  oil,
hydraulic  fluid, insect parts,   and  other
debris  (Keane, 1985).  Subsequent to the
Denver Workshop, aircraft exterior wash-
water was judged not to fall under  the

"mixture  rule" and thus  do  not  consti-
tute a  regulated waste  regardless  of  the
chemical(s) used.  Certainly, a more
concerted effort to  characterize,  by
direct  analysis, the variation  in
concentrations of chemicals  in  typical
spray equipment washwaters  would be
useful  in devising wastewater treatment
strategies, and perhaps  delisting  or
exempting specific types  of  waste.

     In addition to  the  origin  of  the
washwater, the chemical  nature  of  the
contents  is important to  determining
what wastes are regulated.   In  sum, only
those pesticides and formulation
ingredients appearing on  the RCRA  E and
F lists  (Ehart, 1985; Krueger,  1985)  are
regulated, and only  when  the summed
amounts exceed the exemption level for
Small Quantity Generators.   For many
such chemicals, the  exemption level will
be lowered to 100 kg/mo  in  1986 -- an
amount which could be exceeded  in  a
single washing operation.

     One  point worth noting  in  relation
to the RCRA E and F  lists is the
presence  of several  pesticide breakdown
products  on them.  These  include:
Parathion  •
E List

F List

E List

E List
     Thus, a disposal strategy which
relies on hydrolysis of parathion to p-
nitrophenol would be of limited benefit
because it merely alters the chemical
composition, from one (parathion)
falling on the E List to one (p-
nitrophenol) on the less restrictive F
List.  Simple hydrolysis of propargite
and monuron would definitely be dis-
advantageous because it would create
products on the E List from parent
pesticides falling on neither the E nor
F Lists.

     A major problem in devising
treatment strategies for pesticide
wastes is the diversity in types and
properties of the chemicals registered
for use (Kearney et a!., 1985).  There
are ca. 680 pesticide active
ingredients, of which some  30 account
for 90% of agricultural applications.
These 30 include chemicals  with water
solubilities ranging from less than  1
ppm (trifluralin, toxaphene) to totally
miscible J(2,4-D salts), vapor pressures
from <10~° Torr (2,4-D salts) to  >1  Torr
(Telone), and soil persistence times of
<1  (butylate) to >30 weeks  (toxaphene,
terbuphos).  The soil persistence can  be
dramatically affected by the formulation
type and concentration level, and
several environmental factors.

     It is thus quite unlikely that  any
single disposal strategy will be  equally
applicable to all pesticide types and
environmental conditions.   This is
particularly true for biological
degradation, where a fairly narrow range
of conditions must be satisfied for
optimal breakdown (Craigrnill and
Winterlin, 1985).

     A special waste disposal situation
exists at outdated/abandoned sites which
did not have the design features  man-
dated by current standards.  These
include evaporation ponds without double
liners (or, in many cases,  any liner at
all), no groundwater monitoring capabil-
ities, and location near to well  sources
and/or human activity.  These sites  —
some on public lands — may be classed
as hazardous waste sites under federal
or state superfund regulations.   They
may thus be subject to civil and
criminal  penalties, and to  a fairly
immediate remedial cleanup  action
requirement (Craigmill and  Winterlin,
1985; Masterman, 1985).  In these cases
contaminants are present in the soil,
with the potential of having been mixed
or leached to several feet  below  the
surface.   Concentrations at one such
site we recently studied, to be detailed
in a later presentation by  Dr. Craigmill
at this Workshop,  were in excess  of  800
ppm for 4 chemicals in the  top 4  inches
of the dried evaporation pond sediment,
with concentrations exceeding 100 ppm
for two of these at a depth of 2  feet.
The options for cleanup of  such sites
are quite limited, including removal  to
an approved waste disposal  facility
(usually  at great  cost) or  on-site
decontamination by chemical/microbial
means (Craigmill and Winterlin, 1985).
In retrospect it is clear that the

cleanup costs and potential civil and
criminal penalties are so great that the
long term cost of improper management
will far exceed any short term savings
(Master-man, 1985).  The question facing
those involved in such situations is who
should pay, given that several
applicators may have been involved,
often with some concurrence of local
agencies, and even in compliance with
the general disposal statements on the
pesticide label.

     With regard to the latter point, it
is clear that the pesticide label must
be made more explicit in terms of what
disposal options are legal for a given
product.  General label guidance
statements have been updated  recently
(Krueger, 1985), but do not yet give the
type of specific information  one needs
to carry out disposal of unused product
or in equipment washwater.


     In approaching the subject of
treatment and disposal options, several
means of classification exist.  The one
employed at the 1985 Denver Workshop
delineated physical, biological, and
chemical treatment options, with the
topics of land disposal of rinsate,
incineration, and containers  handled
separately.  Another classification
might be based on whether the option is
relatively simple and inexpensive, and
thus can be practiced on site, or
employs more sophisticated, esoteric
techniques which require transportation
of the waste off site to some central
disposal location.  The two classes are
not mutually exclusive, because one step
in a given option (e.g. carbon
adsorption) may be done on-site, with a
subsequent step (incineration of carbon)
 done off-site.   If the  on-site off-site
 classification  were imposed on the
 techniques  discussed at the Denver
 Workshop,  it might appear as follows:

 Carbon  adsorption
 Land disposal
 Biological  treatment
 Chemical  treatment

Molten salt
 The on  vs_ off-site question is  important
 because of the regulatory requirements
 of storing,  handling,  and shipping
 pesticide wastes for off-site treatment
 (Hill,  1985).   On the  other hand,  if one
 wishes  to treat on-site, this will
 entail  permitting, monitoring,  and
 reporting requirements tailored to the
 treatment facility proposed.  Many
 participants at the Workshop felt  that
 on-site treatment might be the  more
 practical alternative  for wash  and
 rinsewaters, while off-site treatment
 with an organized collection system
 might be more suited to container
 disposal.  However, basic economic,
 regulatory,  safety, and expediency
 decisions are yet to be made, and  in
 fact the decisions may vary from one
 region  of the nation to another.
      A  general schematic for on-site
 treatment includes as  components a wash
 pad for cleaning equipment, a sump/pump
 system for transferring rinsates to a
 storage tank,  and a containment for
 evaporation  of excess  water (Figure
 1).  Variables include the separation of
 suspended and dissolved materials  (e.g.
 f1occulation/sedimentation stage),
 removal of the bulk of the dissolved
 organics (e.g. adsorption stage),
.introducing  chemical reagents (e.g., in
 the storage  tank or evaporation area),
 and the design of the containment/

	 ^^// /////// / / / s?
Figure 1.  Essentials for an  on-site  disposal  system  for  pesticide  wastewaters.

 evaporation area.  Depending on choices
 in these categories, the waste effluent
 may be cleaned to the point of reuse of
 the water as spray mix diluent or for
 more than one washing operation, with
 only occasional effluent reaching the
 containment area for "finishing".
                               pesticides accommodated  (Dennis, Or.,
                               1985).  In its present form  it  appears
                               more suited to the needs of  pest control
                               operators working with smaller
                               application equipment and fewer types of
                               chemicals.  It can, in fact, be portable
                               and thus brought to PCO sites for


Purdue Flocculation/Sedimentation Carbon Arknm-Hnn 
concentrated water, and the lagoons must
be double lined and monitored frequently
to avoid leaking to underlying soil and
water.  The negatives seem to outweigh
the positives in this strategy  unless
chemical reagents can be developed to
degrade toxicants to innocuous materials
in the lagoon itself.

     The soil evaporation systems, as
extensively tested at Iowa State
University and the University of
California field stations (Craigmill and
Winter!in, 1985; Hall et al., 1981),
offer some advantages.  While preserving
water evaporation and thus volume
reduction, the soil adsorbs toxicants
thereby minimizing the potential for
their loss by volatilization or system
leakage while creating an environment in
which slow microbial and chemical
degradation can occur in a manner
analogous to what normally happens in
treated fields.  The UC system provides
for subsurface feeding of the
wastewater, so that net water movement
is upwards in the containment when
environmental conditions favor
evaporation.  Both systems are amenable
to further manipulation in terms of
prior adsorption or chemical treatment
of the wastewater to be contained  and
evaporated, and addition of nutrients to
the soil to maximize biodegradation.  On
the negative side, neither system  has
been thoroughly tested for the presence
of toxic degradation products, and both
have the same liner and monitoring
requirements mentioned above for
evaporation  lagoons.   If the
containments were constructed on the
soil surface  rather than imbedded  in  it,
monitoring could be  relatively simple
including by  visual  inspection
 (Winterlin in Bridges  and Dempsey,

     An  extension of this concept  is
found  in the Chemical  Control Centers  in
use on  many  small fruit  farms  in the
northeast U.S.  (Spittler in Bridges  and
Dempsey,  1986).  These  centers use leach
lines  embedded  in the  soil to  distribute
wastes  back  to  the  field for  subsequent
weathering.  While  no  adverse  effects
were  noted  in follow-up  monitoring,  the
potential for contamination  of surface
and subsurface  water  in  the  leach  fields
 is a  drawback of this  approach.
B.  Biological

     Biological treatment, specifically
the use of adapted microorganisms in
activated sludge and trickling filter
systems, has much utility for degrading
toxic chemicals (Craigmill and
Winterlin, 1985).  To generalize, most
such systems are best adapted to
handling one or a few chemical wastes
fed at a relatively constant rate in a
reasonably well-managed environment, and
thus seem more suited for industrial
effluents than for agricultural
wastewaters.  Exceptions to this
generalization lie in the relatively
slow but more flexible mixed microbial
populations encountered naturally in
soil, sediments, and compost piles.  The
use of these natural cultures may best
lie in containments receiving wastewater
or pre-treated wastewater, such  as  in
the evaporation beds and compost piles
mentioned above, and in detoxifying
contaminated soil at disposal sites no
longer in use.  Once again, the
formation of toxic intermediates in the
degradation process can not be
discounted, and proper containment  of
wastes for a  relatively long period of
time is  required because these natural
processes, even when artificially
facilitated by addition of nutrients,
can be quite  slow particularly when co-
metabolism is  required for
degradation.   Some help in speeding
things up may  eventually  come with  the
use of isolated enzymes capable  of
catalyzing specific transformations, and
in  genetically engineered  "super-bugs"
which can withstand harsh  environmental
conditions, variable chemical
concentrations, and gross  mixtures
 (Matsumura in  Bridges and  Dempsey,

C.  Chemical
      Honeycutt  (1985)  described  options
 currently  available  for  chemical
 degradation  of  wastes  -- a theme  further
 amplified  by several speakers  at  the
 Cincinnati Workshop  (Bridges  and
 Dempsey,  1986).  They  include  fairly
 exotic,  technology-intensive  systems
 capable  of completely  mineralizing
 organic  wastes  rather  rapidly  (microwave
 plasma,  molten  salt  methods),  systems
 capable  of effecting partial  degradation
 through  one  or  a few specific  chemical

 degradation  steps (oxidation, photo-
 lysis, hydrolysis,  reduction), and
 systems employing combinations of
 approaches  (UV/ozonation, sunlight/
 oxidation,  hydrolysis/oxidation).
 Several of  these  offer fairly immediate
 use in handling agricultural wastewater.

      The system most thoroughly studied
 at the field-ready  scale is the UV/
 ozonation procedure  developed at the
 USDA, Beltsville,  research center.
 Wastewater containing agricultural
 pesticides such as  atrazine and 2,4-D
 and animal parasite  control  agents such
 as coumaphos are  degraded in the
 ozonation unit to more polar, less
 toxic, and more biodegradable
 products.  Normally,  this technology is
 to be used in combination with microbial
 metabolism either as  a pre- or post-
 treatment.  The system is commercially
 available, potentially portable,  and has
 a  relatively low  operating cost;
 however,  it will  require more study with
 a  wider variety of chemicals before
 being recommended for general use.

      Solar photodecomposition, using
 photoactive metallic  oxide catalysts, is
 a  promising technique for degrading a
 variety of chemicals  (including those
 resistant to other degradation
 processes).  The energy  and  technology
 requirements are quite simple, involving
 only  adding the catalyst to  water
 exposed to sunlight,  and complete
 mineralization can occur.  This  could be
 a  useful  add-on to existing
 holding/evaporation pond technology
 (Nozik and Cooper in  Bridges  and
 Dempsey,  1986).  The  use of  other
 hydrolytic and/or oxidizing  agents,  such
 as  hypochlorite,  perborate,  and peroxide
 bleaches,  effects  partial  to  complete
 degradation of many pesticides and thus
 shares many of the same  advantages.   One
 cautionary  note in pursuing  this
 technology  is in  the  potential  for   -
 forming toxic intermediates,  while a
 second lies  in the potential
 deactivation of the reagents  by solvents
 and dirt  before they  attack the
 pesticide  of interest.   At any  rate,  the
 goal  of finding chemical  reagents  which
 can "neutralize" a given waste  (and
 perhaps be  purchased along with the
 pesticide)  by simple addition  and  mixing
when  needed  is  so  attractive that  it
 should  be  pursued  vigorously.
 D.  Combinations

      The concept  of combining physical,
 biological, and chemical principles  of
 removal/degradation of wastes into
 single systems affords a viable approach
 to handling wastewaters containing a
 variety of chemical  agents.  This has
 been mentioned in  connection with
 several of the processes described
 above, and can be  more formally
 summarized as in Figure 2.

                            LIQUID (PARENT)
                               ADSORPTION (Ci PEAT,

               LIQUID (PARENT)
                                SOLID RESIDUE

                     ADD TO CONTAINMENT *
                     OR LEACH SYSTEM
  (TO AIR)
Figure  2.
          (WEATHER BY NATUR,
A systems  approach to waste-
water disposal.
      Some steps could be  bypassed,
combined, or altered to fit  the needs of
individual  users.  Perhaps we  should
look  more at developing such a "systems
approach" to handling liquid wastes,
rather  than several independent
processes.   To a certain  extent this
concept  is  already being  applied to
container disposal (Figure 3).


               TRIPLE RINSE
               REUSE    RECYCLING   DISPOSAL


Figure 3.  A  systems approach to
           container disposal.

One of the major advantages of the
Workshop approach is that it provides an
opportunity to look at the whole field
of possibilities, see where technologies
can be linked, and thus work more
effectively toward integrated solutions
to the disposal problem.


     The Denver Workshop provided a
forum for exchanging ideas across a
broad front,  ranging from the needs  of
applicators,  through the rationale for
and intricacies in existing and  planned
regulation, and including some practical
here-and-now  approaches as well  as
meritorious concepts for future
development.  The most pleasant  surprise
was the size  and diversity of
backgrounds of the attendees ~  a point
which clearly underscored the urgency  of
solving the waste disposal issue.  Among
several very  appealing ideas which
surfaced  during the Workshop were the
concept of deli sting some wastewaters
from the  regulated waste classification
and of minimizing wastewaters  by
spraying  them on the target  or  recycling
them as diluent to  subsequent  tank
mixes, and of eliminating  some  entirely
by use of in-boom mixing and  system
purging over  the target.   Such  measures
might well  reduce the  volume  of
wastewater  generated  in  the  future  to a
fraction  of that  of the  past.   The  most
tantalizing  idea  was  to  develop a
 chemical  reagent which could  be added to
wastewater to "neutralize" (i.e.
 detoxify) residual  material  — clearly
 an idea  worth vigorous pursuit in the
 future.   The  availability  now of
 relatively  simple  reagents which could
 help in  degrading chemicals  in storage
 tanks  and evaporation containments is a
 step in  this  direction,  as is the
 artificial  facilitiation of
 microorganisms capable of accelerating
 the degradation of wastes in
 containments and abandoned disposal

      The biggest unknown for many
 attendees was at what level of waste
 chemical removal could the contaminated
 water or soil be considered safe, ie
 "how safe is safe".  Apparently,
 individual states are drawing up target
 figures, but the pesticide industry as a
 whole has little input into the
process.  The biggest disappointment for
the users attending the conference was
the lack of vendors of approved
systems.  Some users are clearly eager
to purchase disposal systems if and when
they became available.  A point of
confusion in the Workshop centered on
the legal acceptability of land
disposal, or"land-farming, as a disposal
option.  The most ignored issue in the
Workshop was the possibility of
producing hazardous secondary residues
in the  act of removing the primary
(parent) chemical.  Few analytical data
were presented giving complete
characterization of the "decontaminated"
wastewaters.  The most worrisome point
may well have been the economic plight
of aerial applicators, for whom the cost
of adhering to new waste handling
regulations might be prohibitive given
other economic pressures on this

     The most tangible  result of the
Workshop was that it led directly to  a
Research Workshop only  6 months after
Denver, at which many  decisions were
reached on what technologies  should be
further pursued and  a  mechanism for
funding 5  areas was  implemented.  Less
tangible  but  still  quite  positive
results  could  be  found in  the
stimulation  and sense  of  urgency
imparted to  the attendees,  and the
raising of expectations  that,  indeed,
progress was  being  made and that
solutions  were  on  the  horizon.


      The author gratefully acknowledges
 the helpful  ideas  and encouragement of
 colleagues Art Craigmill  and Wray
 Winter!in.  Financial  support was
 provided by  the Western Region Pesticide
 Impact Assessment  Program (Harold
 Alford), Environmental Protection
 Agency, and  the National  Agricultural
 Chemical Association for the author's
 work referenced in this manuscript.


 1.  Bridges, J.S.  and C.R. Dempsey.
     1986.  Proceedings:  Research
     Workshop on the Treatment/Disposal
     "SfTesticide Wastewater.  EPA/6W9-

2.  Craigmill, A.L.  and  W.L.  Winter-
    lin.   1985.   Pesticide  wastewater
    disposal: Biological  methods.   In:
    Proceedings:   National  Workshop on
    Pesticide Waste  Disposal  (JACA).
    EPA/600/9-85/030,  pp  54-71.

3.  Day, H.R.  1976.   Disposal of  Dilute
    Pesticide Solutions.  tPA/530/SW-
    519.   Washington,  O.C.  June.

4.  Dennis, Jr.,  W.H.  1985.  A
    practical system to treat pesticide-
    laden  wastewater.  In:  Procee-
    dings:  National Workshop on
    Pesticide Waste  Disposal iJACA).
    EPA/600/9-85/030,  pp  49-53.

5.  Ehart, O.R.   1985.  Overview:
    Pesticide wastes disposal.  In:
    Proceedings:  National Workshop on
    Pesticide Waste Disposal  (JACA).
    EPA/600/9-85/030,  pp  2-11.

6.  Federal Register.  1981.  Hazardous
    waste  management system; standards
    applicable to  owners  and operators
    of treatment,  storage,  and disposal
    facilities; and permit  program.
    Fed. Reg. .46_(24),  11126-11177.

7.  Hall,  C.V., J. Baker, P. Dahm, L.
    Freiburger, G. Uorder,  L. Johnson,
    U. Junk, and F. Williams.  1981.
    Safe Disposal  Methods for Agricul-
    tural  Pesticide Wastes.  Iowa State
    University, Ames,  Iowa.  EPA report
    (NTIS  Report No PB 81-197-584).

8.  Hill,  R.P.  1985.  Storage, hand-
    ling,  and shipment of pesticide
    waste  ~ regulatory requirement.
    In:  Proceedings:  National Workshop
    on Pesticide Waste Disposal (JACA"T7~
    EPA/600/9-85/030, pp  95-101.

9.  Honeycutt, R.C.  1985.  Chemical
    treatment options for pesticide
    wastes disposal.   In:   Procee-
    dings;   National Workshop on
    Pesticide Waste Disposal IJACA).
    EPA/600/9-85/03U, pp 72-85.

1U. JACA.  1985.   Proceedings; National
    Workshop on Pesticide Waste Dispo-
    sal.EPA/600/9-85/030,  September.

11. Keane,  W.T.   1985.   Applicator
    disposal  needs.  In:   Proceedings:
    National  Workshop on Pesticide Waste
    Disposal  (JACA). EPA/6UU/9-85/030.
    pp 12-14.

12. Kearney,  P.C.  1985.   Pesticide
    degradation  properties.   In:
     Proceedings:   National  Workshop  on
     Pesticide  Waste  Disposal
     EPA/600/9-85/030,  pp  35-42.

 13.  Kennedy, M.V.  (ed).   1978.   ACS
     Symposium  Series 73,  Disposal  and
     Decontamination  of Pesticides.
     American Chemical  Society,
     Washington, D.C.

 14.  Krueger, R.F.  1985.  Federal
     regulation of  pesticide disposal.
     In:  Proceedings:  National Workshop
     on Pesticide Waste Diiposal  (JACAK
     EPA/ 600/9-85/030, pp 22-33.

 15.  Krueger, R.F.  and  J.N.  Seiber  (eds).
     1984.  Treatment and  Disposal  of
     Pesticide Wastes.  ACS  Symposium
     Series 259, American  Chemical
     Society, Washington,  D.C.

 16.  Masterman, J.  1985.  California
     regulatory requirements.  In:
     Proceedings: National Workshop on
     Pesticide Waste  Disposal  (JACA).
     hPA/bOO/9-85/030,  pp  34.

 17.  Munnecke, D.,  H.R. Day,  and  H.W.
     Trask.  1976.  Review of pesticide
     disposal research.  EPA Office of
     Solid Waste, Washington, D.C.  EPA
     Report EPA-530/SW-527.

 18.  Nye, J.C.  1985.   Physical treatment
     options:  Removal  of  chemicals from
     wastewater by  adsorption, filtrat-
     ion, and/or coagulation.  In:
     Proceedings:   National  Workshop  on
     Pesticide Waste  Disposal (JACA).
     EPA/600/9-85/030,  pp  43-48.

 19.  Public Law 94-580^.  1976.  The
     Resource Conservation and Recovery
    Act.  Available  from  EPA, Office of
     Solid Waste, Washington, D.C.

20.  SCS Engineers.   1979.   Disposal  of
     Dilute Pesticide Solutions.  Long"
    Beach, CA.   EPA  Report  SW-176C (NTIS
    Report PB-297  985).

21. Seiber, J.N.   1981.   Disposal  of
    Pesticide Wastewater"-- Review,
    Evaluation, and  Recommendations.
    U.S. Environmental Protect!on
    Agency, OER, ORD, Washington, D.C.
    Draft Report.

22. Trask, H.W.  1985.  Empty pesticide
    container management:   An over-
    view.  In:   Proceedings:  National
    Workshop on Pesticide Waste Disposal
     (JACA), EPA/ 600/9-85/030, pp 105-

                         INDUSTRY'S ROLE IN USERS'  WASTE DISPOSAL

                                       Jack D. Early
                        National Agricultural Chemicals Association
                                 Washington, D. C.   20005


     The agricultural chemicals industry recognizes its role to assist pesticide users
to find waste disposal options which are environmentally -sound, cost effective and
realistic in meeting their legal responsibilities.   The National Agricultural Chemicals
Association (NACA) has funded five verification studies to further enhance technology
that can lead to practical and accessible treatment/disposal of pesticide wastes.
Equally important is the identification of a regulatory scheme which recognizes the
types of wastes associated with pesticide use and is responsive to the economic and
operating restrictions facing both private and commercial applicators.

     This paper will present NACA's assessment as to its role and responsibilities in
the identification and implementation of pesticide users' waste disposal strategies.
                      For the past four
years,  NACA has been considering envi-
ronmental needs of'those who use our
industry's products.  Our focus has been
primarily on waste disposal and water
quality issues. The waste disposal program
we decided upon took the form of providing
information to applicators on the relevant
regulations end, in general, effective
waste management practices.  It became
apparent early on to our Waste Management
Committee that the regulations governing
the wastes generated from pesticide use
were defective.  They did not relate to
the economic and operating conditions of
pesticide applicators.  Nor were the reg-
ulations really responsive to the types
of wastes involved.  They were the same
regulations companies must comply with in
dealing with more concentrated chemical
wastes.  In providing guidance to pesti-
cide applicators, the regulations left
something to be desired.

     Consequently, NACA's objective of
developing informational assistance to
pesticide users had to be put on the "back
burner," until the regulations and tech-
nology were better defined.  We recognized
a serious need for regulatory programs
that would allow practical and environ-
mentally sound waste management practices
for pesticide rinsewaters, empty con-
tainers and pesticide-containing soils
resulting from spills.

     These circumstances led us to seek
formation of this National Workshop on
Pesticide Wastes Disposal.  At that time,
probably the only ones who knew that
pesticide applicators had serious and
almost impossible challenges to effec-
tively and economically comply with
federal and state regulations were the
applicators themselves.  Needless to say,
Harold Collins, of the National
Agricultural Aviation Association, was
delighted about the prospects of a work-
shop similar to what Jim Seiber, our
previous speaker, had been recommending
for several years.  When contacted, the
organizations listed as Workshop co-
sponsors enthusiastically agreed that
such a forum was needed.  Thus the
National Workshop on Pesticide Wastes
Disposal came into existence.  I would
like to acknowledge at this time the
personal commitment and support that
Francis Mayo of the Environmental
Protection Agency (EPA) provided in
helping to launch the Workshop.  And I'd
be remiss if I didn't recognize the many

hours our own Tom Gilding has spent on
this project.

     This Workshop forum enables repre-
sentatives from academia, federal and
state government, the agricultural chemi-
cals industry, and pesticide user groups
to work together to formulate technical
and regulatory solutions to the various
aspects of the pesticide users waste dis-
posal problems.  The Workshop is now a
physical reality and  more importantly
is the evidence of commitment among the
groups involved.  It is an opportunity
to make things happen.

     Last year's Workshop was a good
start, in the sense of "baselining" the
issues involved.  As in any good manage-
ment approach, the first requirement is
to define the problem before attempting
to devise solutions.  If anything, the
first Workshop made the non-applicator
groups; i.e., NACA, EPA, etc., more aware
and appreciative, of the situation that
pesticide users already knew all too well.

     Much has happened since last year.
You will hear about it during this year's
Workshop.  However, much more needs to be
done; we cannot let up.  NACA is committed
to the achievement of the objectives on
which this Workshop is based and, as such,
has clearly defined its role as a partner
with the other cosponsoring organizations
towards making this a reality.

     One role I see for the agricultural
chemicals industry is to work with EPA,
U.S. Department of Agriculture (USDA), and
pesticide applicators towards defining
those technologies that pesticide appli-
cators can use in managing the wastes
generated from pesticide use.  During the
past year NACA member companies funded the
five technology demonstration projects
which will  be discussed in the next
presentation.  Additionally, some compa-
nies are individually supporting similar
efforts specifically related to their
products.  These "screening" projects are
necessary to begin more specific feasibi-
lity studies on those technologies.   I'm
talking about those technologies selected
as viable candidates for treating/dispos-
ing of the types of wastes we are looking
at.  We,hope that the funds our industry
has provided for these projects will  lead
to the selection of promising technologies
for further research and demonstration.
      I  look forward to the joint presenta-
 tions by  Phil  Kearney and Francis Mayo on
 their assessments and insights  into future
 research  needs.  NACA believes  that fur-
 ther  research  is needed across  the board.
 But care  must  be taken to insure that we
 identify  as accurately as possible what
 research  or demonstration is really
 necessary in fulfilling our technology
 objectives.  Since all of our organiza-
 tions are "resource limited," it is essen-
 tial that we adhere to guiding  principles
 for these research initiatives  that will
 assure  efficient use of resources expended
 by academia, government, the agricultural
 chemicals industry, and pesticide applica-
 tors.   These guiding principles should
 strive  for technology that achieves com-
 patibility with the applicators' operating
 conditions, effectiveness in protecting
 the environment, and regulatory accept-
 ability.   Further, NACA believes that EPA
 should  provide guidance on what will be
 acceptable from the regulatory  standpoint.
 In addition, the agency should  also begin
 conducting its own qualification studies
 for that  purpose.

     The  success of the Workshop objec-
 tives is  greatly dependent upon the
 regulatory programs at the federal, state
 and local  levels of government.  It is
 fair to say  that the existing  regulations
 are neither realistic nor responsive to
 the types  of pesticide wastes generated by
 applicators.  Moreover, as was pointed out
 last year, there is confusion due to the
 administration of the regulations them-
 selves.   NACA agrees with the view that
 federal and state Resource Conservation
 Recovery Act (RCRA) regulations currently
 in effect were really not designed with
 pesticide  rinsewaters or empty containers
 in mind.   Understandably, the RCRA program
 primarily  addressed the manufacturing seg-
ment of the industry and the much greater
 concentrated process wastes.   The exten-
 sive permitting process and treatment
 technologies required by RCRA are cer-
tainly beyond the economical  reach of the
 pesticide applicator community and exceed
what is actually needed.

     Federal  and state pesticide waste
regulations must be modified if applicators
are to fulfill  their legal  responsibilities
and protect the environment as  well.   When
 I talk of modifying existing regulations, I
do not mean arbitrary loosening of regula-
tions.  On the contrary,  NACA~and this is

consistent with what I understand the ap-
plicator community to be saying—believes
regulations are essential.  However, such
regulations must be defined to: (1) pro-
tect the environment, and (2) allow com-
pliance by the regulated community.  As
part of our commitment to the Workshop, we
at NACA are ready to work with the appli-
icator community, EPA and anyone else for
the purpose of identifying regulations
which meet the above criteria.  We see our
role, in the regulatory process and work-
ing directly with the applicators them-
selves, as one of helping to develop
effective and safe management practices
for pesticide wastes. I believe it is
appropriate here for me to suggest that
consideration be given to an approach for
defining these regulations:  EPA (Office
of Pesticide Programs (OPP) and Office
of Solid Wastes (OSW)) should call
together those interested parties to work
out a responsible and effective regulatory
program for pesticide wastes.   EPA has
already done something along that line in
its negotiated rulemaking under Section 18
of the Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA).  It is presently
doing the same concerning Farm Worker
Safety regulations.  I understand Marcia
Williams, according to an article in
CHEMICAL WEEK, is interested in the
negotiated rulemaking process for RCRA.
Such action, under the joint responsi-
bility of OPP/OSW, might just prove to be
the way to resolve the regulatory dilemma
facing the applicator community.

     There are some very complex issues
which will have to be addressed in such
rulemaking decisions.  The major ones
that NACA sees, at the moment, are   (1)
the respective roles of and relationship
between RCRA and FIFRA; (2) the regulatory
program, including its administration; and
(3) the communication of resulting regu-
lations to pesticide applicators.
     As to whether the regulations should
be under RCRA or FIFRA, NACA believes the
management of wastes generated from pes-
ticide use should come under the purview
of FIFRA.  FIFRA is the statute which
regulates the sale and use of pesticides.
NACA considers the safe disposal of
wastes to be the final step in the safe
use of pesticides.

     To assure sound management under
FIFRA, we recognize and agree that the
resulting regulations must adequately
meet the intent of RCRA.  This means
that FIFRA regulations would have to
assure the same or greater degree of
protection of the environment as in-
tended under RCRA.  FIFRA regulations
could afford the opportunity to design
the regulatory strategies relating to
pesticide wastes and the applicators'
operating conditions.

     Finally, the last role I see for
our industry is, in fact, what we had in
mind initially.  It is to provide infor-
mation to pesticide users on sound waste
management strategies.  Once we get
answers to the regulatory and technology
challenges associated with pesticide
waste disposal, tangible gains then will
be possible through informational assis-
tance programs.

     I personally believe that the great-
est gains and benefit in any undertaking
can be derived through educating the human

     With information properly organized
and focused comes comprehension.  With
comprehension, we then can apply the re-
sources available to us to solve the
problems.  That's what we're doing here.

                                   John C. Nye & Tom Way
                            Agricultural Engineering Department
                         Louisiana Agricultural Experiment Station
                      Louisiana State University Agricultural Center
                       Louisiana State University and A & M College
                                   Baton Rouge, LA 70803


    A carbon  adsorption treatment  unit was  constructed and  tested during  the fall  and
 winter of 1985-86.  The objectives of the test were to  identify  the critical factors  that
 affect the flocculation of pesticide contaminated waste-water and  to provide the data for
 use by applicators and regulatory agencies to adopt  this technology.

    The treatment system consisted of one-250  gallon flocculation tank, four-6 in.  ID  by 4
 foot long PVC columns filled with filtrasorb  300 and 400 activated  carbon(Calgon, Inc),  an
 air  driven  variable  speed  mixer,  a  Masterflex  variable  speed,  pump,  a  portable   air
 compressor and portable generator.   The total cost of  the complete unit with  supporting
 chemicals and lab equipment was $3500.

    A series  of flocculant  aids were tested.   Included in these tests were Ultrion  7109,  a
 cationic  coagulant that  contains aluminum chloride;  Nalco  7132,  a polyquaternary amine
 choride;  Nalclear 7763, an  anionic  flocculant,  Nalcolyte  8108,  a  polymime coagulant  and
 Nalco PF100,  a  ferric sulfate  flocculant.   These  flocculant  aids were  supplied  by  the
 Nalco Chemical Company.    Ferric sulfate and  aluminum sulfate were also used  in jar test.
 The  sludge  characteristics  were evaluated  and  the  turbi.dity  of the  supernatant  was
 observed.  The supernatant was analyzed  for pesticide content.

    The  paper  describes the operation of the treatment unit and projects the cost of using
 this  method  to treat  pesticide  contaminated  waste-water.  The criteria  for selection of
 flocculant aids  are described in detail.  The treatment process was effective in removing
 pesticides from waste-waters.

   One  of  the  problems  facing  pesticide
applicators  that have  used  the  treatment
technique   discussed  last   year   by  the
author  (Nye,  1985)  has  been the selection
of  flocculants for  the  pretreatment step.
Development of a simplified procedure for
screening  flocculants  was proposed  to the
National Agricultural  Chemical Association
and funded  in  November,  1985.  The primary
objective  was  to  establish  a  technique
that  could be  used by  pesticide  applica-
tors  to  select the  appropriate  flocculant
and   determine  the   proper  dosage   for
flocculation   of  pesticide   laden  waste-

   Several   previous   papers  have   been
presented by the author and former graduate
students describing  the development of the
treatment process. Detailed descriptions of
each project are  presented in their theses
(Whittaker,   1980,   Ruggieri,    1981   and
Farrell, 1984).  The essential steps in the
treatment   process  is   flocculation   and
sedimentation  of  the waste-water followed
by adsorption of the pesticide to activated
carbon.  This  system has been  used  on  a
wide range of pesticide contaminated wastes
with good results.

   Pesticide applicators  in  several states
have installed this treatment system.  The

primary   problem   that  most  users   have
experienced  is the  inability to  flocculate
the   waste-water.    To   understand   the
flocculation  step,   it   is  essential  to
review the basic  chemistry associated with
flocculation(Sawyer   and   McCarty,   1978).
Although  there  are  numerous  new  products
that  are designed to  enhance  flocculation
and  sedimentation,  the  oldest   and  most
reliable  products  are Ferric and  Aluminum
salts.   When  these compounds are  added to
water  with  sufficient alkalinity,  ferric
hydroxide or aluminum hydroxide are formed.
These  hydroxides   form  large   floes  and
settle rapidly.   As they settle they remove
much  of   the turbidity in  the water.   The.
chemical   reactions   that   produces   the
aluminum  or  ferric  hydroxide precipitate
          + 6
          + 6 NaOH •
2 Fe(CH)3

2 A1(OH)
   The  metal hydroxides  settle out  of the
waste-water and carry with them much of the
suspended material in the waste-water.  The
concentration of  ferric  or aluminum salts
varies  depending  on  the  turbidity  of the
waste-water.   In  the  typical  samples  of
pesticide contaminated waste-waters 300-600
mg/L of flocculant is needed.

   To enhance the settling process polymers
are   added   to  the   waste-water.    These
polymers can be either anionic or cationicy
meaning they  either  attract  positively or
negatively  charged   particles.    In  mbst
cases the  hydroxide  molecules  will settle
more rapidly  with anionic polymers.  Very
small amounts  of  polymer  are  required to
enhance  flocculation.   Dosages  of  1  mg/L
are  common.

   To  convert  these dosages  to  useable
figures   for   applicators  the  following
conversion factors are useful.

  1 mg/L  =  8.3 pounds/million gallons

  500 mg/L  m  .4 pounds/100 gallons


   Most pesticides are  mixed  with  organic
solvents, emulsions or other compounds that
allow them  to be  mixed with water and form
stable  solutions.    These  same  compounds
create the  most serious  problem during the
flocculation step.  To develop a simplified
                         procedure  for selecting flocculant  aids  a
                         synthetic  waste-water  was  prepared,   that
                         contained  large   amounts  of  solvent   and
                         emulsifiers.   The makeup of the waste-water
                         is shown in Table 1.

                         Table  1.   Chemicals added  to  45 Gallons of
                         water  to form synthetic waste-water.
                         Pesticide Name and Labeled
Super Dairy & Stock Spray              750 ml
  2,2-Dichlorovinyl dimethyl
  phosphate                0.93%
  related compounds         0.07%
  Dimethyl phosphate of alpha-
  methylbenzyl 3-hydroxy-
  cis-crotonate             0.25%
  Petroleum distillates      49.75%
  Mineral seal oil          49.00%

Darsban 30 sec                       750 ml
  Chlorpyrlfos, 0,0,-diethyl 0-
  phosphorothioate         30.0%
  Xylene range aromatic
  solvent                 19.7%
  Inert Ingredients         50.3%

Dermaton 3                           750 ml
  vinyl diethyl phosphate   12.25%
  Inert Ingredients         87.75%

Deltox                              750 ml
  Dioxathion  [2,3-p-dioxanedithlol
   s,s-bis (0,0-diethyl
  phosphoroditMoate)]      20.40%
  Related compounds          7.10%
  Inert ingredients         72.50%

Tick Trol                           6.6 kg
  Permethrin  3-(phenoxyphenyl)
  methyl (+) els, trans-3-
   carboxylate              3.20%
  Inert Ingredients         96.80%
                             The dosage  of  flocculant and  coagulant
                         were determined through  jar  test using a
                         series  of   flocculant   aids   from   Nalco
                         Chemical  Company.    The  jar   tests  were
                         conducted on 2  L beakers of  waste-water.
                         The flocculants and coagulants were diluted
                         to  1   %'  strengths  for  simplification  in
                         scaling up dosages to  the field sample.

The  2  L beakers were  filled with about  .5
gallons of waste-water.   The dosage for  50
gallons would  be the  same  volume of  100  %
flocculant.   Four  beakers  were  used  for
each test.   The dosages ranged from 200  to
500  mg/L  of  flocculant  for  most  cases.
Initially   aluminum   sulfate  and  ferric
sulfate were added  at the prescribed  dose.
Then  sodium hydroxide was  used  to adjust
the   pH.     To   enhance   coagulation   and
settling,  an   anionic  polymer   (Nalclear
7763)  was  added'  to  the  samples.    After
these  initial   test,   the  other  flocculant
aids  were then used  at lower  dosages  as
recommended  by  the  Nalco  representative.
The  flocculant aids  that were  tested  are
shown in Table  2.                         '

Table 2.  Flocculant Aids evaluated in  jar
 Ferri Floe
 Nalco #1
 Ultrion 7109
 Nalco 7132
 Nalclear 7763
 Nalcolyte 8108
Hydrated ALunrhnm Sulfate
Ferric Sulfate(50% soln)
Alundnum Sulfate
Ferric Sulfate
Cationic Coagulant
Anionic Flocculant
   The .major  thrust  of this project was  to
develop a  simplified procedure for select-
ing type and  dosage  of flocculant aids for
a  wide range of  waste-waters.   While  we
were   successful    in   flocculating   and
treating    the    pesticide    contaminated
waste-water,  we  had  limited  success   in
simplifying the screening process.

   Since  many  of the pesticides contain'
solvents   and   emulsifiers   that  resist
flocculation,  the  screening  of   the  com-
pounds can be very frustrating.   To insure
that an applicator can achieve success the
following  screening  process is  suggested.


   The following  materials  are required  to
screen flocculants:

   A. Chemicals

   1.  Ferric Sulfate or Aluminum Sulfate,
500 grams  in  1 L of water.
   2.  Anionic Flocculant, 0.1 % solution
by volume.
   3.  Sodium Hydroxide, 40 grams  in 1 L  of
   B. Equipment

   1.  Gang Stirrer
   2.  pH meter or other measurement device
   3.  Assorted  plastic ware including 2 L
beakers,  graduated  cylinders,  pipets  or


   1.  Dilute  the initial waste-water with
tap  water  by  adding  1 quart  of pesticide
waste-water to 2  gallons of water.
   2.   Fill four - 2  L beakers  with 0.5
gallons  of diluted  waste-water  and start
mixing with gang  stirrer.
   3.  Add flocculant to the waste-water in
varying  dosages   from  1 to  5 mL.(l  mL of
500,000  mg/L   flocculant  in  .5  gallons is
approximately  250 mg/L  dosage)
   4.   Adjust  pH  to  7.0  using  sodium
hydroxide.  (Add about 2 mL of hydroxide for
each mL of flocculant)
   5.  Add  1 mL of the  anionic polymer that
has been diluted  to a 0.1% solution.
   6.  Mix at high speed for  1 minute, then
reduce mixing  speed to low  (10  rpm) for 5
minutes and then  off.
   7.   Select  flocculant with  good separ-
ation and lowest  dosage.
   8.   Repeat  steps   2  through  7  with
increasing  concentrations  of waste-water.
Dosage  of   flocculant  may  have  to  be


   The  waste-water  from  the  formulation
plant  that  was  used  in  the  study  was
difficult  to   flocculate.   Raw waste-water
samples were  treated with  alum  and ferric
sulfate at  dosages up  to  1000 mg/L with no
success.  The waste-water was diluted to 10
% strength  and flocculation was successful
at dosages  of from 300  to 600  mg/L.   An
experimental  protocol  was  established  to
determine the  rate of  sludge accumulation
with  subsequent  resuspension  of  settled
solids.  The initial  sample was  made up of
10 %  pesticide and 90  %  tap  water.  These
samples  were  flocculated  with  alum  and
ferric sulfate.   After  settling, the volume
of sample was reduce to 1.8 L and 200 mL of
raw waste-water  was  added.   This procedure
was  followed  through  5  resuspensions  of
sludge.  After each flocculation the volume
of sludge  was  measured.  The first sample
that  contained   10   %  waste-water  would
flocculate  with   Nalco  #1  (40  %  aluminum
sulfate) doses of 300,  400,  500,  and 600

mg/L.   The  400  mg/L  dose  was  the  most
effective    producing     the     clearest
supernatant.   The volume of  settled  sludge
ranged  from 300 and 400 mL.   The  supernat-
ant  was  decanted  from the beaker,  leaving
1.8  L of total volume.  200 mL of  waste-
water was added to each beaker.   The mixer
was  started  and the sludge  was resuspended.
The  same  doses, 300 to 600 mg/L of Nalco  1
were  used   again   with   no  successful
flocculation.   The dosage was  increased to
700,  800,  900  and 1000  mg/L.   At  these
doses  good  separation was  achieved.  The
volume  of settled sludge  was between 400
and  500 mL.  The same procedure of  decanting
supernatant  to  the 1.8  L volume, adding 200
mL  of  waste-water  and  then  flocculating
with same dosages of  Nalco  #1  was  used.
The  volume   of  settled   sludge   remained
between   400  and  550  mL.    In all  these
trials  the volume of  sludge was  recorded
after 1 hour of settling.

   These   jar   tests  indicated   that  the
waste-water  could be flocculated using the
resuspended  solids  with  the  addition of
flocculant.   The most  effective dosage of
Nalco fl  was 800 to 1000 mg/L (an aluminum
sulfate dosage  of between 300  and 400  mg/L

   Ferric sulfate  was  then  evaluated  in the
same manner.    Ferri-Floc,   a  50%   ferric
sulfate  solution,  was  used  for these jar
tests.  The  first  10  % solution of  waste-
water  could  be  flocculated  with   ferric
sulfate  dosages of 300,  350,  400 and 450
mg/L.   The  volume  of  settled  sludge was
less  than 200  mL.   The  supernatant was
decanted  to  the 1.8L volume  and 200 mL of
waste-water  was  added.    The  sludge  was
resuspended  with  the  mixer and flocculant
was  added  at  the  same  dosages.    This
procedure was  continued  four  times.   Good
flocculation was achieved with the 350, 400
and  450 mg/L  dosages.   The  300 mg/L  dose
failed to flocculate the waste-water  on the
third trial.  The  volume of sludge remained
at  200  mL.   Because  the  ferric  sulfate
.produced   a  much  more  dense  floe  that
settled more rapidly,  it  was  selected for
treating  the larger volumes of waste-water.

   The  same  procedure  was  followed  for 55
gallon  drum  quantities of  the waste-water.
About ten gallons of waste-water was added
to 40  gallons  of  water.  Based on the jar
tests in  a 300 mg/L dose of  ferric  suifate
was used  initially.  After  150 mL  of  ferric
sulfate  was added, 150  mL  of ION  sodium
hydroxide was  added to  produce  the ferric
hydroxide  which  flocculates  and  settles.
These samples were observed  to determine if
additional  flocculant  was  needed to settle
the  waste-water.    For  the  first  batch
flocculated in  the  55  gallon drum, a total
of 200 mL of ferric sulfate was added.  The
air  drive mixer  was  used to agitate  the
drum while  the chemicals  were added.   The
mixing   speed   was   reduced   while   the
flocculant  aid  was added.   After  1 minute
of gentle agitation the mixer was shut off.
The  flocculant  was   allowed  to  settle
overnight.     The   next    morning    the
supernatant was pumped through the  acti-
vated   carbon   columns.    This   treatment
schedule was used  for  the  remainder of the

   Table  3  presents  the  sequential  batch
treatment of  the waste-water.   The sludge
was resuspended during  each treatment.  The
amount of waste-water that was added to the
sludge  varied  and  flocculant dosage  was
determined visually.

Table  3.   Chemical dosages  required  for
batch  flocculation  of  pesticide  contami-
nated waste-water

                    Chemical Dosage
„ Ferri-floc, 50 % solution of ferric sulfate
2 Sodium hydroxide, 10 N
  Nalclear 7763, anionic polymer, 0.1% solution

   As the sludge accumulated in the drum we
expected to be able to achieve flocculation
with lower dosages  of chemicals.   This was
not the case.  After  12  resuspensions, the
dosage  for  flocculation  had  risen  to  an
incredible  3000  mg/L of  Ferric  Sulfate.
The last two treatments had the highest

concentration   of   pesticide  contaminated
waste-water and required the largest dosage
of   chemicals.   Even   with   these   high
dosages,  the   supernatant  remained turbid.
The  original   results  from  the  jar  test,
indicating that less chemicals are required
to treat diluted mixture, held true for the
larger scale trials.

   Limited  data  on the  concentration  of
pesticide  in  the effluent  is  available at
this time.  The initial analysis indicates
that the concentration of permethrin in the
effluent   is    about    0.2   mg/L.    The
supernatant after  ferric sulfate  and alum
flocculation all had essentially  the same
concentration  of pesticides.

   To obtain additional  information on the
toxicity of the effluent,  bio-assays using
mosquito  fish  were conducted.   The  fish
were - taken from a drainage ditch on the LSU
campus.  Four  fish were place in a solution
of 0.5  L of ditch  water  and 0.5 L  of the
effluent  from the  carbon  columns.   The
beaker  was aerated  and after  5  days  all
fish were alive and appeared healthy.


   The major objective of this study was to
develop   a    simplified    procedure   for
selecting  flocculants  for  use  in  the  two
stage  treatment  process   that   had  been
previously developed.  Several commercially
available   "one-step"   flocculants   were
compared  to ferric sulfate  and  aluminum
sulfate.  Because of the very large dosages
required  to break   the  emulsion,  it  was
found   that    aluminum   or  ferric   salts
followed  by   the   addition  of  hydroxide
produced   the   most  consistent   results.
Dosages  as  high a  600  mg/L aluminum were
required.  It  was also  determined that the
ferric   hydroxide   would  form   a   denser

   It  is  doubtful  that   most  pesticide
applicators would  have  the  patience  to
conduct  the  numerous  jar  test  needed ,to
find   the   right   dosage,   without   some
"hands-on" training.

Farrell,  K.  L.,  1984.   Concrete Encapsul-
ation  of  Pesticide  Contaminated  Sludge.
MSAE   Thesis,   Purdue   University,   West
Lafayette, IN,

Nye,  John  C.,   1985.   Physical  treatment
options  (Removal of chemicals  from waste-
waters  by  adsorption,  filtration  and/or
coagulation),     Proceedings;	National
Workshop   on   Pesticide  Waste  Disposal.
Denver,   Colorado,   January  28-29,  1985,
EPA/600/9-85/030, HWERL, WERL,  Cincinnati,
OH 45268. p43-48.

Ruggieri,  T.  J.,  1981.   Determination  of
the  Ability  of  a  Flocculation/Activated
Carbon Treatment Plant fo remove Herbicides
from  Application  Equipment Washwater  and
Examination of the Feasibility of Bioassays
for   Determination  of  Activated   Carbon
Exhaustion.  MSE Thesis, Purdue University,
West Lafayette, IN, p!41.

Sawyer,  Clair  N.  and  Perry  L.  McCarty,
1978.  Chemistry for Environmental Engineering.
McGraw-Hill Book Company,  Inc. New  York,
NY, 532pg.

Whittaker,  K.  F.,  1980.    Adsorption  of
Selected  Pesticides  by  Activated  Carbon
using  Isotherm  and Continuous  Flow Column
System. PhD Thesis, Purdue University, West
Lafayette, IN, p342.

                           Ian L. Pepper and John E. Watson
                         Department of Soil and Water Science
                                University of Arizona
                                Tucson, Arizona  85721


     Large amounts of pesticides have accumulated in soils adjacent to aerial appli-
cator landing strips. These soils are currently considered to be toxic waste mater-
ials and must be decontaminated.  Pesticides of concern include methyl and ethyl
parathion and toxaphene.  Of these toxaphene is the most resistant to degradation.
Since toxaphene is toxic to animals, and is also carcinogenic, then methods to detox-
ify toxaphene contaminated soils must be found.  The objective, of  this current pro-
ject is to identify a time and cost effective detoxifying treatment.   Specific alter-
natives are ultraviolet (UV)  photo decomposition and microbial degradation.  The
project was initiated in November 1985.  Preliminary data indicate that  a UV treat-
ment reduced toxaphene in soil by 27.8% after 42 days.  When a UV treatment was
combined with microbial degradation,  the reduction was 4.9%.   However, this latter
treatment contained lower initial toxaphene concentrations.

     Until recently, toxaphene has been
one of the most extensively used chlori-
nated pesticides in the United States.  It
was predominantly applied in combination
with methyl parathion to cotton fields to
reduce insect damage.  Since the pesticide
was usually applied via aerial applica-
tors, then large amounts of toxaphene have
accumulated in soils adjacent to the
landing airstrips.   Toxaphene is toxic to
animals and is also a carcinogin.  Hence,
soil contaminated with toxaphene is con-
sidered to be a hazardous toxic waste
material and must be detoxified.  Sales of
toxaphene in Arizona are shown in Table 1
Ibs. sold (in thousands of Ibs.)
from the years 1966 to 1980 when it was

     Less is known about toxaphene than
any other organo chlorine.   This is due to
the complexity and variability of its
components.  It is produced by chlori-
nating comphene via photolysis in the
presence of a catalyst.   The resulting
insecticide is a conglomerate of at least
177 Cii g polychlorinated derivatives.
Each C-J^Q derivative contains 7 to 11
chlorine atoms accounting for approxi-
mately 68% of the total weight.  The
empirical formula is C^Q Hn Q Clg with
an average molecular weight: of 414 (2).

     Over the years,  toxaphene has been
applied to soils in vast quantities.
However, concentrations in soil may be
reduced by photodecompositionyor chemical
and/or microbial degradation.  Toxaphene
may leave soils via volatilization, or
leaching, or be inactivated by adsorption
to inorganic or organic colloids.
Volatilization has been  documented by
Williams and Bidleman (3) while Clark and
Matsumura  (1)  have shown that Pseudoroonas
putida can microbially degrade toxaphene.

The overall objectives of this cur-
rent project was to identify a time and
cost effective land treatment of soil
contaminated with pesticides.

     Specific objectives are to evaluate
the following land treatment systems:  a)
a surface treatment, in which the mode of
pesticide degradation was primarily 0V
photodecomposition; and b) a sub-surface
treatment, where the mode of degradation
was essentially microbial decomposition
plus DV photodecomposition.

     In achieving these objectives,
emphasis was placed on practical solu-
tions to the problem of decpntamination
of pesticide contaminated soils.  These
solutions must be time and cost effec-

     The source of pesticide containing
soil in this study was from aerial appli-
cator airstrips in Arizona.  Through the
years, these soils have acquired large
amounts of toxaphene.  Large samples of
such pesticide laden soils were
thoroughly mixed to insure uniform
composition.  The soil was screened and
sieved (<2mm) prior to use.

     Wooden boxes were constructed 1 m^ by
10 cm, lined with plastic, and placed out
in the field at the University of Arizona,
Marana Agricultural Center.  The toxaphene
contaminated soil  (TCS) was applied evenly
in the boxes to a depth of 5 mm.  This
treatment allowed maximum photodecomposi-
tion of the pesticide.  Microbial degra-
dation of the pesticide was encouraged by
diluting the TCS with 50% Pima clay loam
(PCL)  which initially contained no toxa-
phene.  The resulting mixture was simi-
larly placed in the boxes, allowing pho-
todecomposition and microbial degrada-
tion. Treatments were replicated four
times, and left exposed to the atmosphere
for a 6-month period.  Samples were
sacrificed with time and analyzed for
toxaphene and methyl and ethyl parathion
by gas chromatography.


     This project was initiated in
November 1985, thus only preliminary data
have been obtained.  The toxaphene con-
centration of soils after 0 and 42 days
are shown  in Table 2.
     Thus it can be seen that after 42
days exposure, the toxaphene in the con-
taminated soil  (TCS) was reduced 27.8%,
mainly by ultraviolet photodecomposition,
whereas when deluted 50% with PCL,  the
toxaphene was reduced 4.9%.   This latter
treatment reflects the combined effects

-ppm toxaphene	
 50% TCS + 50% PCL
of photodecomposition and microbial de-
gradation, but on a soil with a lower
initial toxaphene concentration.  Note
that in both treatments volatilization
will most likely have occurred, however
the extent of this in unknown.

     The initial methyl and ethyl para-
thion concentration in the contaminated
soil are shown in Table 3.


Pesticide        TCS  50% TCS + 50% PCL
Methyl Parathion 0.09

Ethyl Parathion  0.37

     Since the values were so low,  it was
decided not to analyze for these contami-
nants at later sampling periods.  It is of
interest that the concentrations were so
low and reflects the increased rate of
degradation of these pesticides in soil as
compared to toxaphene.


     Conclusions are really not appro-
priate, at this early stage of the pro-
ject.  However, it is encouraging that
toxaphene concentrations in both treat-
ments were reduced after 42 days in the


1.  Clark, J.H. and F. Matsumura.  1979.
Metabolism of toxaphene by aquatic sedi-
ment and a camphor-degrading Pseudompnad.
Arch. Env. Oontam. Toxicol. 8:285-298.

2.  Holmstead, RX.f S. Khalifa and J.E.
Casida.  1974.   Toxaphene composition ana-
lyzed by combined gas chromatography -
chemical ionization mass spectrometry.   J.
Agric.  Food Chem.  22:939-944.

3.  Williams, R.R. and T.F. Bidleman.
1978.   Toxaphene degradation in estuarine
sediments.  J.  Agric. Food Chem.  26:280-


                Arthur L. Craigmill, Wray L. Winterlin, James N. Seiber
                         Environmental Toxicology Extension and
                         Department of Environmental Toxicology
                                University of California
                                    Davis, CA 95616

     During the year since the first Pesticide Waste Disposal Workshop the Department
 of Environmental Toxicology and the cooperative Extension Toxicology Unit at the
 University of California, Davis have initiated two field trials to test biological
 methods  for decontamination of pesticide waste disposal sites.  One of these trials was
 the continuation of the cleanup of the Sutter County Airport which started in September
 of 1980.   Results of our first experiments at this site were reported last year.  The
 other  field study was  initiated last August with the financial support of the National
 Agricultural Chemicals Association, and is located at the Glenn County Airport in
 Willows, California.   Both of these sites are associated with aerial applicator
 operations, however the pesticides involved, and the soil types differ considerably.

      The Sutter County Airport at Yuba
 City,  California has  a pesticide disposal
 site that has served  as a drainage ditch
 for the airport for over 10 years.  The
ditch is approximately 8'  deep,  12'  wide
and 600' long.  Pesticide waste water was
released into the ditch through -one of
the runway drains, and flowed through a
drain pipe ( > 1000 ft long)  into the
drainage ditch.   The major pesticide
contaminant is toxaphene and the soil
type in the ditch is sandy loam.   The
ditch has not been used for pesticide
disposal since September of 1980,  however
the drain pipe contains high levels  of
toxaphene.   During the rainy season,
additional toxaphene is washed into  the
ditch thereby recontaminating the soil.
     Our initial studies here involved
mixing organic matter (cow manure) into
the soil followed by flooding with water
to promote anaerobic conditions.  The
results  of the first field trial were
promising, and this  year we initiated
another  trial to test the  effects of other
soil amendments on toxaphene degradation.
Ten, ten gallon plastic garbage pails were
filled with one cubic foot of ditch soil
taken within 75 feet of the drain pipe
outlet (the most highly contaminated area
in the ditch).   Dried cow manure,  finely
ground corn,  and blood meal were
thoroughly mixed with the contaminated
soil as shown in Table 1.

Bail #   Cow Manure    Corn    Blood Meal
2 Ibs
2 Ibs
2 Ibs
2 Ibs
2 Ibs
2 Ibs
2 Ibs
2 Ibs
2 Ibs

1 Ib
2 Ibs
1 Ib
2 Ibs
1 Ib
2 Ibs

1 Ib
1 Ib
1 Ib
2 Ibs
2 Ibs
2 Ibs

     Each pail was placed in the hole from
which the soil was removed, flooded with
water, and covered.  The pails were
checked daily to insure that they remained
flooded throughout the test period.  Soil
samples were taken from each pail
immediately after flooding, and 7, 13, 29,
48, and 62 days later.  Following solvent
extraction, samples were analyzed for
toxaphene residues using gas-liquid
chromatography.  Levels of toxaphene were
calculated in ppm and capillary GLC was
vised to define peak shifts associated with
biological degradation.


     Hie quantitative data was anomalous
except for the 0 time samples which ranged
from 40 to 130 ppm (mean = 83.4 ppm) and
was in the range expected based on results
of previous analysis.  The qualitative
data obtained by peak comparisons from the
capillary column GLC showed definite
shifts associated with biological
degradation.  Previous unpublished work by
Mirsatari and Seiber demonstrated that
biological degradation of toxaphene is
associated with a shift in the GLC profile
to peaks which elute earlier.

     The peaks measured are nine distinct
toxaphene peaks that are expressed in
comparison to the total peak area, 100%.
Figure 1 shows the effects of biological
degradation on the profile at various
times after adding alfalfa meal to
toxaphene contaminated soil (Mirsatari and
Seiber, 1978).  The peaks are numbered in
order of elution from the column.   Note
the relative reduction of the latter peaks
7-9 and the increase in relative height of
peaks 1-4 as compared to the standard.

     Figure 2 shows the data for all of
the test plots on day 0, immediately after
flooding the soil.  Note that all  of the
plots show shifts associated with
biological degradation as compared to the
standard.  This is particularly seen as a
reduction in the late peaks numbered 6-9,
and an increase in the early peaks
numbered 1-4.  This is most likely due to
previous biodegradation that occurred when
the entire ditch was amended with manure
prior to the 1980-81 rainy season.  Figure
3 shows the profiles for the control plot.
With the exception of the profile seen at
day 29, there is little change seen over
the course of 62 days, with only slight
increases in the proportion made up by
peak 1.  Figure 4 shows the profiles for
the plot amended with just manure.  There
are increases in peak 1 towards the end of
the test.  Figure 5 shows the profiles for
the plot amended with just corn meal.
There is little change seen over the 62
day test period.  Figure 6 shows the
profiles for the plot amended with blood
meal.  There is a substantial change in
peak 3 seen at day 7, and increases in
peak 1 towards the end of the test.
Figure 7 shows the profile change over the
62 day test period for the test plot
amended with manure, corn and blood meal.
Note the considerable increase in relative
size of the early peaks 1-4 as time

     The results of this study confirm our
initial observations and those in the
literature that toxaphene can be degraded
on site using anaerobic biological
metabolism.  Further laboratory and field
studies are planned to further define the
parameters that are most conducive to
toxaphene degradation in pesticide
disposal sites.


     The Glenn County Airport site is an
unlined evaporation pond that is

   1 n


         Manure +  Corn + Blood  Meal








                      13      29

                     Time (Days)
 Figure 7.  Change in toxaphene profile for the plot
           amended with 2 Ibs manure, 2 Ibs corn meal
           and 21bs blood meal.

approximately 3' deep and 60' square.
It is connected to a concrete wash pad of
slightly smaller size that drains into the
pond.  The site has been in use for over
10 years and is no longer used.  The soil
in the pond and surrounding areas consists
of 39% clay, 42% silt and 19% sand.
Initial samples of surface soil and water
in the partially evaporated pond, soil in
an overflow area and downwind air were
taken on May 22, 1985.  On September 6,
1985 additional samples were taken to a
depth of 27" within the pond to determine
the penetration of pesticides into the
soil.  The results are shown in Table II
and Table III.

     Due to the heavy consistency of the
soil, we had to use a soil auger to take
samples.  The low level contamination of
the first five pesticides at the 24-27"
depth is quite possibly due to slight
contamination of the samples by the highly
contaminated surface soil.  The high
levels of molinate at the 9-12" and 24-27"
depth cannot be explained in this way.
Another site assessment study is planned
for this spring to more fully characterize
pesticide movement in the soil underneath
the pond.

     We had planned to start some of the
pond treatments this fall, however delays
associated with county and regulatory
agency decisions forced us to wait until
this coming spring.  We did institute a
series of winter studies to determine
which conditions will promote biological
degradation of the pesticides in the pond.
The study was designed to test the effects
of the following parameters; organic
matter (including corn meal as an energy
source), pH, nutrients (N and P),
moisture, and anaerobic or aerobic
conditions.   The study is being run on
site at Willows and we are testing both
soil removed from the pond,  and clean soil
removed outside the pond to which the
major pesticide contaminants have been
added.  The evaporation pond was covered
with a tarp just before the rainy season
began, and in the spring we will initiate
trials in the pond based on the results of
the shed study.

     The authors would like to express
their appreciation to Ms. Janice Myers,
Mr. Mike McChesney, Mr. Jim Woodrow,  and
Mr. Glen Walker for their expert
assistance in sampling and analysis and
to Ms. Sandy Ogletree for her expert
assistance in manuscript preparation.


1.  Craigmill, A.L. and Winterlin, W.L.
    Pesticide wastewater disposal:
    biological methods.  Proceedings of
    the National Workshop on Pesticide
    Waste Disposal, pp. 54-71, 1985.

2.  Mirsatari, S.G.  Some characteristics
    of toxaphene residues on foliage and
    in soil sediment.  Ph.,D. Dissertation,
    University of California,  Davis,  1978.

3.  Seiber,  J.N.  et al.  Toxaphene
    dissipation from treated cotton field
    environments: component residual
    behavior on leaves and in  air, soil
    and sediments determined by capillary
    gas chramatography.  J^ Ag.  Food  Chem.
    27(2):284-291, 1979.

    ,                     GLENN COUNTY AIRPORT — MAY 22, 1985
Pond Soil
Spill Area    Drainage Ditch
a - Total air volume sampled = 60 cubic meters
Me Parathion
Pronamide (Kerb)
_ _

— i —
                       GLENN COUNTY AIRPORT — SEPTEMBER 6, 1985
 Soil Concentration,  ppm dry weight
   0-3"        9-12"        24-27"
                             Solubility (25°C)
Atrazine               5129        143
Chlorpyrifos           1012         44
Disulfoton             1016         40
Ethyl Parathion        1064         37
Me Parathion             38         11
Molinate                822        378
                                33 ppm
                                 2 ppm
                                25 ppm (22°C)
                                24 ppm
                             55-60 ppm
                               880 ppm (20°C)

                              OF CATTLE-DIP PESTICIDE WASTES

                 Jeffrey S. Rams, Mark T. Muldoon and Philip C. Kearney
                         United States Department of Agriculture
                              Agricultural Research Service
                             Pesticide Degradation Laboratory
                               Beltsville, Maryland  20705

    Extensive cattle-dipping operations are continuously carried out  along the border  of
the United States and Mexico as part of an effort to eradicate the cattle fever  tick from
the United States.  These operations generate large volumes of aqueous wastes containing
very high levels of the insecticide and acaricide coumaphos [0,0-diethyl 0-(3-chloro-4-
methyl-2-oxo-2H-l-benzopyran-7-yl)phosphorothioate].  Coumaphos is extremely resistant to
degradation, with a half-life of over 300 days in neutral or  acid soils.  Hydrolysis of
the coumaphos molecule by a strain of bacteria which produces parathion hydrolase  (an
enzyme which breaks down diethylthiophosphorate compounds) yielded products which  were
very susceptible to further degradation by U.V.-ozonolysis.   The products which  remained
after this combined biological/physical degradation process were easily degraded to
carbon dioxide and water by microorganisms in soil.  Thus, laboratory results indicated
that by the combined treatment of microbial hydrolysis  followed by U.V.-ozonolysis, safe
and effective disposal of coumaphos-containing cattle-dip wastes can  be achieved.  This
process has been field-tested on 650 gallons of waste and was shown to be an effective
waste treatment method.  The problem of delivery of large numbers of  viable bacteria to a
remote site was overcome by growing the bacteria in the dip-vat waste itself using xylose
as a source of carbon and energy and ammonium sulfate fertilizer as a nitrogen source.
The microbial portion of the process required 48 hours  for complete hydrolysis of  couma-
phos and was run at ambient temperature with vigorous aeration.  Research is presently
underway to simplify the process so that non-technical  field  personnel can effectively
initiate, run, and monitor waste treatment.
    The recent industrialization of  the
many discoveries made in biology over the
last 50 years into what we now call  bio-
technology, combined with ever-increasing
concern for the state of our environment,
has stimulated interest in the use of
microorganisms for the treatment of  chemi-
cal wastes.  Many reports have appeared
over the last 5 years detailing the  isola-
tion and characterization of pure cultures
of microorganisms capable of rapidly and
completely degrading various xenobiotic
compounds.  Chlorinated hydrocarbons such
as 2,4-D (3), 2,4,5-T (6), PGP (11), and
chlorobenzoates (2) have been shown  to be
relatively rapidly degraded by pure  micro-
bial cultures.  However, to date, none of
these degradative organisms has been in-
corporated into a practical system that can
be used by small source generators of agro-
chemical wastes.  Such a system must com-
bine cost-effectiveness with portability
and ease of operation.  We would like to
describe our efforts to develop such a
system for the elimination of waste cattle-
dips containing the organophosphate insect-
icide and acaricide coumaphos.

    The Animal and Plant Health Inspection
Service (APHIS) of the United States
Department of Agriculture (USDA) and the
State of Texas (TX) jointly operate a tick
eradication program along the border of
Mexico and Texas.  The program is designed

                                          2          3
                                           Time (hours)
                 Figure 1.  U.V.-ozonolysis of  1500  ppm Coumaphos
 to prevent the re-introduction of the
 cattle fever tick (Boophilus)  into the
 United States (U.S.).   This program relies
 heavily upon cattle dipping operations for
 tick control.  The primary insecticide used
 in these operations is  coumaphos [0,0-di-
 ethyl 0-(3-chloro-4-methyl-2-oxo-2H-l-ben-
 zopyran-7-yl)phosphorothioate].   Cattle are
 treated by running them through long
 trough-like vats  containing aqueous suspen-
 sions of coumaphos. Because of fouling by
 dirt,  hair and animal wastes,  these vats
 are emptied once  a year for cleaning.
 There are 42 vats  in this  APHIS  operation
 with an average volume  of  about  3,000
 gallons containing 1500 to 3000  ppm of
 coumaphos.  Thus,  in one year  this program
 generates over 140,000  gallons of aqueous
 wastes  containing  high  concentrations  of
 coumaphos.   These  wastes are currently put
 into concrete lined evaporation  ponds.
 Since  coumaphos can have a half-life of
 over 200  days in soils  it  is clear that a
 destructive method  of coumaphos  disposal
 would be  desireable.

     The technique  of UV-ozonation,  whereby
 aqueous solutions  of pesticide are  exposed
 to  intense ultraviolet  radiation in the
 presence  of oxygen  as a  pre-treatment  step
 prior to  soil  disposal,  was  shown to be
 effective in  accelerating  the degradation
 of  the herbicides  atrazine, 2,4-D and
 paraquat  (4,5).  The coumaphos in waste
 cattle-dip was very resistant to  degrada-
tion by the UV-ozonation process  with only
25% degradation over a 5 h  period of expos-
ure  (Fig. 1).  Filtering the solution prior
to exposure increased the effectiveness  of
the process  slightly, but  not  enough'to
make this process practical on a  large
scale.  Subsequent experimentation using
high levels  of mechanically generated ozone
has shown that coumaphos in aqueous
suspension is very resistant to oxidation
by ozone (data not shown).

    Several  laboratories had previously
characterized organisms capable of hydroly-
zing 0,0-diethyl phosphorothioate insecti-
cides (7,9,10).  Although originally isola-
ted because  of their ability to hydrolyze
diazinon and parathion, it was subsequently
determined that the responsible phosphotri-
esterase enzyme (parathion hydrolase) had a
very broad substrate specificity and was
capable of hydrolyzing a wide  range of
0,0-diethylphosphorothioate compoundsd,8).
Dense resting cell suspensions of the
parathion degrading Flavobacterium sp. ATCC
.S 60-
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-
 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
              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

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).
             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

 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.


 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

 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

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

10.  Siddaramappa, R., Rajaram, K. P., and
     N. Sethunathan, 1973.  Degradation of
     parathion by bacteria isolated from
     flooded soil.  Appl. Microbiol.  26

11.  Stanlake, G. J. and R. K. Finn, 1982.
     Isolation and characterization of a
     pentachlorophenol degrading bacterium.
     Appl. Environ. Microbiol.  44


                    Catherine Schmidt, Brian Klubek and James Tweedy
                          Department of Plant and Soil Science
                        Southern Illinois University - Carbondale
                              Carbondale, Illinois  62901


     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.

     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).


     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-

 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

      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-
 butylate (s-ethyl diisobutylthiocarbamate).
 cyanazine (2-[[4-chloro-6-(ethylamino)-s-
 linuron (3-[3,4-dichlorophenyl]-l-methoxy-
 1-methylurea), metolachlor  (2-chloro-N-E2-
 1ethyl]acetamide), metribuzin (4-amino-6-
 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

 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.


 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
                           -WASTE PESTICIDE
             ^	"' •-•••••	-•	•«  SOLUTION
                            -FILTRATION MEDIUM
Figure 1.  Side view of pesticide disposal
 Figure 2.  Overhead  view  of  pesticide  dis-
           posal  system.

 Isolation of  Pesticide  Decomposing Micro-

     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-^

     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

               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.


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-

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.

            • 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
            • Total Count

            A Decomposer Count
      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.
             A Alachlor +

             • 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-

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=

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-

 £  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.
                    • 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

 « 75

 1   'I
  § 5°
                         • 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



                   • 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

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<

      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.


      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
                                                                           OR ACID GOB
                                           Figure  11.   Proposed above-ground pesticide
                                                       disposal  system.

Press, New York,  pp.  669-730.
1.  Alexander, M.  1973.  Nonbiodegradable
    and other recalcitrant molecules.  Bior-
    technology and Bioengineering.  15, pp.

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,

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.

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.

  (Research Workshop on the .Treatment/Disposal of Pesticide Wastewater)

                            Philip C. Kearney
                     Pesticide Degradation Laboratory
                     U. S. Department of Agriculture
                           Beltsville, Maryland


                             Francis T. Mayo
                  Water Engineering Research Laboratory
                  U. S. Environmental Protection Agency
                             Cincinnati, Ohio

     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

     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

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.

     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

     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.

     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.


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.


                                                 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

                               Figure 1.  Schematic  Diagram of Direct Injection System.

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-

     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

     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.

     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-

     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.

     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


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.

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.

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.

                                   WASTE WATER  RECYCLING

                     Darryl  Raster, Associate Specialist  (Engineering)
                          Louisiana Cooperative Extension  Service
                                Louisiana  State University
                               Baton  Rouge,  Louisiana   70803


     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.

     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-

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

  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).


     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).
    Figure  1.  Aircraft  spray tank illus-
              trating location  of various
              components and remaining 3 to
              5 gallons of  pesticide.

     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.
      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
   Figure 2.  Aircraft spray tank illus-
              trating installation of pump
              intake extension and loader
              line check valve.

     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)
Range $3,000 - $15,000
$ 6,000
$ 11,750

Depreciation (10 year life)      $  1,175
Interest on Investment
  (12% Interest)                      705
Maintenance                           500
Labor (75 Hours @ $6.00)              450
$  2,830

                                         50* X 50'
                                         WASH RACK
2-500 GAL.
    ©   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-

      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.

     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

1 (250 Gal.)
2 (400 Gal.)
3 (500 Gal.)
4 (500 Gal.)
5 (300 Gal.)
Soybean Pre- emerge
Soybean Post-emerge
Cotton Pre-emerge
Cotton Post
Emerge Herbicides
Rice Herbicides

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 -
     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.

     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

     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

     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

     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

     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

 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.


 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

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,

                              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


     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.

     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

     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.

     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

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

                                         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
                                                   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
        "TO 4'
                                           4O'Q" LOADING PAD

          Figure 1.  Top View Diagram of a Pesticide Rinsewater Collection  System


     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



	 • 	 • 	 1=;
                                                     SHADED GRATES TO BE I"
                                                     ABOVE GRATE LEVEL TO
                                                     PROTECT SLIDE ROD (4)
                 PLAN VIEW

56" 3".
24" T 8" 24"
^ 3" PL ATE C


f-r^ ..^,-L

1 / 1
24" 3",
1 y6"
a 1 1 m r 1 1
SUDE 7 . ./

 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

     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.


Wash pad
Tanks (4) -




                   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

              .Analyses Comparisons

                   Table 2 compares active ingredient
              concentrations of rinsewater solutions
              taken from the concrete tanks at four
              different locations during the
       Active Ingredient
                                                    Sample Source
Site A
Site B
Site C
                                             Site D





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

     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
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

     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.


Butyl ate
Per Acre

Standard Spray


Rate Variation

(+/-ppm) (+/


Variation with
5% Rinsewater

     Based on median recommended application rates applied with water at 20 gallons
     .per acre
     Based on manufacturers' label recommendations for medium textured soils

     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

     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.

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

     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.


     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.

     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

     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.

                            PESTICIDES AND OTHER LIQUID PRODUCTS
                                   RELATED TO AGRICULTURE

                   Dave Callahan,  sales manager of Murray Equipment, Inc.
                                    Fort Wayne, Indiana


      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^

      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

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
      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

 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

      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

      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.

     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.

                            DEALING WITH EMERGENCIES
                                 C. Alvln Yorke
                         Chief, Toxic Substances Branch
                  Environmental  Protection Agency  - Region VIII
                                Denver, CO  80202
     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.

     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


     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.


     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

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

     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

     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

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,

     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


     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.


     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

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.


     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

             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.

       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

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).

       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
       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.

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.

       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.**
       *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
      **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

                                 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

     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-

     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

     If  these  requirements  are met,  a  con-

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-
    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

     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.

                       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.


There are 18 companies producing
55-gallon all-plastic drums.
Production is conducted at 23 separate
manufacturing locations across  the
country and in Canada.


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

   (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

   (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.

  (i) Polyethylene packagings
previously used for poisonous materials
should not be reused for any materials
other than poisonous materials or
hazardous wastes.


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:


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

.  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

.  Conclusions - Tests examining
   the effect of various ladings
   on the container material

   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.

   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
   -  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
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

  and six month storage test of
  ladings they are interested in

  The drums will be permanently
  branded on the top head with a test
  code number which will identify the
  original lading and the

  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

  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
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
 .   Improving trie quality of recycled
 .  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.

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

                           PERMITTING OF ON-SITE PESTICIDE WASTE
                                   STORAGE AND TREATMENT

                                  Felix W. Flechas, P.E.
                           U.  S.  Environmental  Protection Agency
                                  Denver, Colorado 80202


     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.

      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
     (1)  A   base  must  underlie  the

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
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
     (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
     (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

      (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
      (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
      (i)  Constructed as  a  continuous
structure   with   chemical    resistant
water stops in  place at all  joints (if
      (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;
      {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
     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


     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.

                                    TABLE 1
  AT d1carb
  Ally! alcohol
  Al umi num • phosphi de     lf
  Arsenic acid
  Arsenic pentoxide
  Arsenic trioxide
  Calcium cyanide
  Carbon  disulfide
  Cyanides  (soluble cyanide salts)
  0,0-Diethyl  S-[2-ethylthio)ethyl]
    phosphorodithioate (disulfoton, Di-
  0,0-Diethyl  0-pyrazinyl  phosphorothioate
  0,0-Dimethyl 0-p-nitrophenyl
    (Methyl  parathion)
  4,6-Dinitro-o-cresol and salts
  4,6-Di ni tro-o-cyclohexylphenol
  2,4 Dinitrophenol
  Di noseb
Hydrocyanic acid
Hydrogen cyanide
alpha-Naphthylthiourea (ANTU)
Nicotine and salts
Octamethylpyrophosphorami de
  (OMPA, schradan)
Phenylmercuric acetate (PMA)
Potassium cyanide
Propargyl alcohol
Sodium azide
Sodium cyanide
Sodium f1ubroacetate
Strychnine and salts
0,0,0,0-tetraethyl dithiopyrophosphate
Tetraethyl pyrophosphate
Thallium sulfate
Zinc phosphide
There are currently no inert pesticide ingredients on the RCRA E List.

                                    TABLE 1

                                 October 1984
                              Active Indredients
 Cacodylic acid
 Carbon tetrachloride
 Chloral  (hydrate)
 Chlordane, technical
 4-Chloro-o-tolui di ne hydrochlori de
 Cresylic acid (cresols)
   (Kepone,  chlordecone)
 1,2-Dibromo-3-chloropropane  (DBCP)
 Dimbutyl  phthalate
   diisopropylthiocarbamate)   (dial!ate,
 o-Di chlorobenzene
 Dichlorodifluoromethane  (Freon  12R)
   benzamide (pronamide,  KerbR)
 Dichloro diphenyl dichloroethane (ODD)
 Dichloro diphenyl trichloroethane  (DDT)
 Dichloroethyl ether
 2,4-Dichlorophenoxyacetic, salts and
 1,3-Dichloropropene  (Telone)
 Diethyl phthalate
 Ethyl acetate
 Ethyl 4,4'-dichlorobenzilate
Ethylene dibromide (EDB)
Ethylene dichloride
Ethylene oxide
 Hydrofluoric acid
 Isobutyl alcohol
 Lead acetate
 Maleic hydrazide
 Methyl alcohol  (methanol)
 Methyl bromide
 Methyl chloride
   (3,4,6-trichl orophenol)
 Methylene chloride
 Methyl ethyl ketone
 4-Methyl-2-pentanone (methyl  isobutyl
 Pentachloronitrobenzene  (PCNB)
 Phosphorodithioic  acid,  0,0-diethyl,
 Propylene  dichloride
 Selenium  disulfide
 Tri chloroethylene
 Trichloromonofluoromethane (Freon 11R)
 2,4,5-Trichl orophenol
 2,4,5-Trichlorophenoxyacetic acid
 2,4,5-Trichlorophenoxypropionic acid

                           RCRA F List (continued)

                              Inert Ingredients
Acrylic acid
Dichlorodifluoromethane  (Freon
Diethyl phthalate
Dimethyl amine
Dimethyl phthalate
Ethylene oxide
Formic acid
Isobutyl alcohol
Maleic anahydride
Methyl alcohol  (methanol)
Methyl ethyl ketone
Methyl methacrylate
Saccharin  and  salts
Trichloromonofluoromethane (Freon 11R)
Vinyl chloride


                                 H.  Clayton Ervine,  Sr.  P.E.
                                       Seminar Officer
                   Governmental Refuse Collection and Disposal Association
                                   Silver Spring,  Maryland

     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.
     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

     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

     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.

     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

     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

 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.

     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.

     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
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.

     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.


                                  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
     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.

                       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.


 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

 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.


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.

                      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.


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

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

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.

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

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

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-

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

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

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

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,

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

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.

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

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

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.


Roy Detwei-ler:

I was surprised to hear George give information on the

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?


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?


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


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?


That is good, if that sanitary  landfill  will  be available in
the future.                                               ,


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?


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.

                     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


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

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

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

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.


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-

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

 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,

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

 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.


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-



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?


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.

 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


 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


 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?


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.

QUESTION for Butch Calhoun:

How did Louisiana handle old container dump sites?


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?


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.


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?

 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.

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-

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.


Can you expand on that?


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

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

 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.


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

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

 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

 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.

 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

Any other comments  on that?


 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.


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
Roy Detweiler:

If there are  no  further  questions,
panel  for  their  work.
I would like to thank the

                        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

 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

 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.


With that I will turn, it over to Harold Collins, panel chair-

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

 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

 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.

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

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.


 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.

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.

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

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

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

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.


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

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

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-

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.

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.

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

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.
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?


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?


 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

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.

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.

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

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?


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-
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.


 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.


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 .

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.

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-
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

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.

                         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
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
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
 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
. Feed, Seed, Fertilizer & Pesticide
 South Dakota Department of Agriculture
 445 East Capitol
 Pierre, SD 57501
 Dan Baker
 P.O. Box 93
 Bulverde, TX
 David E. Baker
 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
 United Agricultural Products
 P.O. Box 1286
 Greeley, CO  80632

Joseph M. Beckstrand
Pesticide Specialist
Utah Department of Agriculture
350 N. Redwood Road
Salt Lake City, UT  84116

Gary Beeler
Pesticide & Hazardous Material
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
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
Insect Control Department
B. D. Wilhelm Company
8200 E. Harvard Avenue
Denver, CO  80231

James S. Bridges
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

 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
 Terminix International, Inc.
 855 Ridge Lake Blvd.
Memphis, TN  38119
 Dean R. Chaussee
 Environmental Engineer
 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
 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

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
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
State of Arizona
Board of Pesticide Control
1624 W. Adams
Phoenix, AZ  85007

Ronald A. Davis
Plant Pathologist
U.S. Department of Agriculture
Beltsville, MD  20705

Anita Dawson
Manager Manufacturing Services
American Cyanamid
1 Cyanamid Plaza
Wayne, NJ  07470

Kenneth W. Degg
W.L.S. Flying Service
Litchfield, IL  62056

Clyde R. Dempsey
Chief, CCPB
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
P.O.  Box  64089
St.  Paul, MN  55164-0089

Ron  Drosselmeyer
Air-Sprayers, Inc.
Two  Butles, CO  81084

 Paul E. Doherty
 Environmental Engineer
 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
 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
 National Agricultural Chemicals Assoc.
 1155  15th  Street, N.W.
 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
 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.
 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

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
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
P.O. Box 12014
Research Triangle Park, NC
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
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
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
 Wilmington, DE  19898

  Bill R. Fuller
  Assistant Director
  Public Affairs Division
  Kansas Farm Bureau
  2321 Anderson Avenue
  Manhattan, KS  66502

  Robert A. Gable
  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
  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
 Pesticide Lab
 Florida Department of Agriculture  &
 Consumer Services
 3125 Conner  Blvd.
 Tallahassee,  FL 32301

 William Gilbert
 National Alliance  of  Independent Crop
 1901  Avery Court
 Fort  Collins-, CO   80525

 Thomas J. Gilding
 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
     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
   Moore Pest Control Service, Inc.
   Englewood, CO  80110

   Herb Gundell
   Ever-Green Lawns
   6803 Joyce Street
   Golden, CO  80403

Alvin D. Hamman
AL-Don Dusting Service, Inc.
P.O. Box 474
Eloy, AZ  85231

C. R. Hanson
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.
 926 Yucca
Longmont,  CO  80501

 Rolf D. Hill
 Office of Waste Programs Enforcement
 401 M Street, S.W.
 Washington, D.C.   20460

 John C. Hillis
 Executive Secretary
 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
Hunter Agri-Sales Inc.
Box 2
Coatesville, IN  46121

Bill lest
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

 Leeann K. Johnson
 Pollution Control Specialist
 Minnesota Pollution Control Agency
 1935 W. County Rd. B2
 Roseville, MN  55113-2785

 Stan Jones
 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
 Pesticide Degradation  Laboratory
 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
 Bldg. 050 BARC-West
 Beltsville, MD  20705

 John King
 Regional Manager
 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
 Human and Environmental  Hazards
 Texas Dept.  of Agriculture
 P.O. Box 12847
 Austin, TX  78711

 Raymond F.  Krueger
 U.S.  EPA -  Office of  Pesticide
 TS-769  C
 401  M Street,  S.W.
 Washington,  D.C.   20460

 Shri Kulkarni
 Senior  Research Chemist
 Research Triangle Institute
 P.O.  Box 12194
 Research Triangle Park, NC  27709

 Sheila  Lang
 Terra International, Inc.
 P.O. Box  4500
 Lima, OH  61820

 E. R. Laning, Jr.
 P.O. Box  1706
Midland, MI  48640

David A. Leatherman
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

Noel Lerner
Environmental Engineer
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.
Olympia, WA   98504

 Rodney G.  Lym
 Assistant Professor
 North Dakota State University
 Agronomy Department
 P.O.  Box 5051
 Fargo, ND  58105

 James G.  Marria
 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
Eli Lilly and Company
Lilly Corporate Center
Indianapolis, IN  46285

Phil Martinelli
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
Michigan State University
Pesticide Research Center
E. Lansing, MI   48824-1311

Francis T. Mayo
Water ..Engineering Research Laboratory
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
 P.O.  Box  27647
 Raleigh,  NC   27611

 Patrick J.  McGourty
 Pesticide Programs
 Idaho State Department of Agriculture
 2270  Old Penitentiary  Road
 Boise, ID  83712 ,

 Murray L. McKay
 Division of Pesticide  Control
 New Hampshire Department of
 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
 2000 Market  Street
 Philadelphia, PA  19103

 Darrel W. Mertens
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
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
Lincoln, NE  68583-0818

O. Norman Neshelm
Pesticide Coordinator
Oklahoma State University
Dept. of Entomology
Stillwater, OK  74078

Ronald Ney
Chemist Advisor
401 M Street, S.W.
Washington, D.C.  20460

John C. Nye
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
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
Room 403, Bldg. 005
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
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
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
Arrow Pest Control, Inc.
6183 Palmer Blvd.
Sarasota, FL  33578

Frank H. Plescia
Regulatory Specialist - State Liaison
Chevron Chemical Company
P.O. Box 4010
Richmond, CA  94804 - 0010

Clifford D. Porterfield
Technical Specialist
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
Administrative Services and
Environmental Affairs
Zoecon Corporation
975 California Avenue
Palo Alto, CA  94304

George W. Rambo
Research, Education & Tech. Resources
National Pest Control Association
8100 Oak Street
Dunn Loring, VA  22027

David F. Randolph
915 Larkstone Lane
Palm Springs, CA  91206

Roy W. Reabe
P.O. Box 24
Waupun, WI  53963

Richard Reade
Mid-Continent Aircraft Corp.
Drawer L
Hayti, MO  63851

Michael X. Redig
Environmental Supervisor
Florida Department of Environmental
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
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
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

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
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
Biochemical Labeling
PPG Industries, Inc.
One PPG Place - 34 East
Pittsburgh, PA  "15272

Lawrence O. Roth
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
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
Formulation & Packaging Group
BASF Wyandotte Corporation
100 Cherry Hill Road
Parsippany, NJ  07054

Robert Schneider
Senior Scientist
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

 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
 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
 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

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
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
1945 Old Gallows Road
Vienna, VA  22180

Don Tang
Senior Staff Engineer
401 M Street, S.W.
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
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
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

David Vogel
Environmental Administrator
Florida Dept. of Environmental
2600 Blair St'one Road
Tallahassee, FL  32301-8241

Acie C. Waldron
Ohio State University
1735 Neil Ave.
Columbus< OH  43210

William L. Waldrop
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
 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
401 M Street, S.W.
Washington, D.C.  20460

George H. Wermert
Agri-Air Ltd.
P.O. Box 87
Efifingham, IL  62401

Brian Westfall
Environmental Engineer
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
Winslow & Associates
730 Holly Street
Denver, CO  80220

Wray Winterlin
Environmental Chemist
University of California
Dept. of Environmental Toxicology
Davis, CA  95616

Lyle Wong
Environmental Affairs
Dole Packaged Foods
650 Iwilei Road
Honolulu, HI  96817

Donald W. Woodham
Staff Officer
Room 600 A - FB
6505 Belcrest Road
Hyattsville, MD  20782'

Jim Worrall
Senior Environmental Project Engineer
Stauffer Chemical Co.
370 Wilton Road W.
Ridgefield, CT  06877

C. Alvin Yorke
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


                      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




                                                                          TJ O
                                                                          CD -*»
                                                                          D =ft
                                                                          Q) O


ii j
O 3- 3"
             3.9 3
             S-S ffl
             i? a
               D -<

               ** G)
        5' 31
               ® S
                                                                                       > me
                                                                                       (Q 3  D
                                                                                         (D  Q)
                                                                                       (Jl   O

                                                                                       55   1
                                                                                       00   CD